However, where there is an indication that the land may potentially be contaminated, as a result of current or past PCAs, a Preliminary Site Investigation (PSI) should be conducted by a suitably qualified and experienced consultant. A PSI usually includes a desktop study to identify the site characteristics (site location, site layout, building construction, geological setting, historical land uses and activities at the site and on adjacent sites) and a site inspection (including interviews with site representatives).
The PSI should be sufficient to determine contaminants of concern and identify areas of potential contamination, including all areas of potential contamination sources. The PSI may also include initial sampling to provide a preliminary assessment of site contamination and need for further investigation.
A starting point of a Site History Review (and a PSI) is consideration of the
Potentially Contaminating Activities List and whether the land in question has hosted or currently hosts or is adjacent to a site that has hosted or currently hosts a PCA.
The risk to underground services from contamination should be fully assessed, including the possibility of ingress by way of seepage or permeation. This is of particular importance where subsurface plastic pipes deliver potable water through or near hydrocarbon or solvent contaminated land.
A review of the EPA's LISTmap layers may also form part of a Site History Review - see the
Land Contamination Information page.
The information collected as part of the PSI should result in the development of an initial conceptual site model (CSM) - a representation of site-related information regarding potential or known contamination sources and receptors, and the potential exposure pathways between those sources and receptors.
Refer to the
Site History Reviews and Developing a Conceptual Site Model page or the
NEPM Schedule B2 for more information.
Where a PSI demonstrates that the land is not contaminated or the potential for risk to human health and the environment is limited based on current or intended future land use, there may be no need for further investigation. However, where contaminating activities are suspected or known to have occurred, or if the site history is incomplete or where contamination requires full delineation to determine the risk as sampling indicates levels above guidelines, it may be necessary to undertake a Detailed Site Investigation (DSI).
Stage 2 – Detailed Site Investigations
A Detailed Site Investigation (DSI) involves the taking of samples in the field from air, soil, groundwater or other water sources to confirm the presence or absence of contamination identified or suspected in the PSI.
The DSI should involve the development of Data Quality Objectives (DQOs) based on an initial CSM and be undertaken in accordance with a Sampling & Analysis Quality Plan (SAQP). The SAQP sets the sampling program and data quality objectives as well as the
Quality Assurance and Quality Control methodologies to be employed to manage the field work stage of the assessment.
A number of sampling events may be required to delineate the contamination and determine the risks to human health and the environment. Any additional sampling events or changes to the sampling methodology should be reflected by amending the SAQP.
Note that in accordance with the
NEPM (Schedule B6)
'The assessment process for groundwater contamination differs from that of land contamination in that there is greater emphasis on suitability for current and realistic future uses, compared with the emphasis on current and intended uses for soil assessment'.
The NEPM Field Checklist, which is part of the NEPM Toolbox provides details of the parameters that should be collected in the field based on the objectives of the investigation and the contaminants of concern.
The DSI should be comprehensive enough to identify the nature of the contamination and delineate its lateral and vertical extent to a sufficient degree that an appropriate level of human health and environmental risk assessment may be undertaken and, if necessary, to provide the basis for the development of an appropriate remediation or management strategy.
Where management is proposed for residual contamination and not remediation, the consultant should justify the approach and ensure the management measures are appropriate to the current and/or future use or development of the site.
Stage 3 – Remediation
If site contamination is found to pose an actual or potential risk to human health and/or the environment, either on or off the site and therefore the site may not be suitable for its current or proposed use, remediation and/or management should be considered.
The consideration of remediation or management methods should take into account the guidance provided by the
National Remediation Framework (NRF). The NRF was developed by the Cooperative Research Centre for Contamination Assessment and Remediation of the Environment (CRC CARE) in collaboration with stakeholders to enable a nationally consistent approach to the remediation and management of contaminated sites. In late 2019, the NRF was endorsed as best practice by all jurisdictions through the Heads of EPA forum.
The
purpose of the NRF is to:
- establish a nationally consistent approach to remediating and managing contaminated sites
- establish a common and consistent approach to deciding whether remediation is or is not required, and what remediation needs to achieve
- provide practical guidance for those who remediate and manage contaminated sites
- educate and inform government, industry and the community about the issues
Where remediation involves asbestos the WA Heath Department publications including the
Guidelines for the Assessment, Remediation and Management of Asbestos Contaminated Sites in Western Australia (2009) should be considered.