1. OBSERVATIONS OF THE RANDOM APPROACHES TO
REMEDIATION PLANNING IN AUSTRALIA
Anthony Lane1, Peter Gringinger1, Wendy Morrison1
1
Lane Piper Pty Ltd, Bldg 2, 154 Highbury Rd, Burwood, 3125, AUSTRALIA
anthony.lane@lanepiper.com.au
INTRODUCTION
In recent years, remediation of contaminated sites in Australia has increased in complexity
due to land shortage, regulation, restrictions on use of the “dig and dump” approach for soil
and an increased expectation of thorough groundwater remediation (e.g. CUTEP, RTEN).
The latter is partly driven by water scarcity and increased recognition of groundwater as a
vulnerable environmental element (GDEs etc). This, together with the greater availability and
options for on-site and in-situ soil and groundwater remediation technologies, has made the
use of alternative options more widespread. But this has also led to more complex
remediation engineering design and implementation (not only for larger and complex sites
but also for challenging issues like LNAPL, DNAPL and remediation of recalcitrant
compounds), with higher degrees of uncertainty, possible failure, potential for ongoing liability
and need for long term management.
Therefore, it would be expected that the regulatory agencies (i.e. state EPAs) would have
provided increasing guidance on the remediation planning and implementation process.
However, as previously discussed by the Authors (Lane & Gringinger, 2006) there is
repetitious guidance on the site (and to some extent risk) assessment phases of the
Contaminated Land Management (CLM) process and a dearth of guidance on the
remediation planning components of the CLM process. Based on the Author’s experience,
not much has changed since then, including the proposed revision of NEPM that provide no
further guidance on remediation planning. Remediation planning in this context is viewed as
the link between site and risk assessment and implementation of remedial measures. This
should ideally include aspects like definition of remediation drivers, goals, objectives and
targets, remediation options screening & evaluation, development of a remediation strategy
followed by remedial investigations and feasibility studies, which should lead to a remedy
selection, detailed design, specifications and implementation plans.
Taking a holistic point of view, to restore contaminated sites through the CLM life cycle to
make them “fit for use”, it is the remediation stage which is the most expensive, time
consuming and resource demanding, and is the most critical stage for the success or failure
of a site revitalisation project. Some industry sources would say that the scale and cost of the
majority of remediation projects in Australia are underestimated in the site assessment phase
by up to 100%. The current shortage of remediation planning guidelines in Australia
contrasts unfavourably with that available elsewhere (e.g. USA, Canada, UK and others –
Gaboriau & Colombano, 2006, Lane & Gringinger, 2006). Significant potential for inadequate
and under-costed or excessive and unnecessary remediation exists and has occurred
frequently for poorly planned and implemented remediation programs. This is a waste of
limited resources, which could be better directed elsewhere (where environmental
improvement and sustainability can be achieved in real terms), as well as potentially causing
ongoing or re-emerging management and legal liabilities.
It would be inconceivable to advance any serious engineering project of even moderate size
directly from a preliminary scoping and evaluation stage into implementation, without prior
feasibility assessment, detailed evaluation, detailed design, costing, and specifications
(including peer review and sign off). However, this appears the approach still taken to a
variable extent for many CLM projects in Australia.
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2. METHODS
We have been involved in a number of remediation projects completed over recent years as
part of the completion of statutory environmental Audits undertaken by the Authors or in our
role as assessors and advisors. The review focused on the type and level of remediation
planning approaches applied by the assessment consultants on these sites to determine (1)
any use of remediation planning guidelines from other jurisdictions, (2) level of sophistication
of remediation planning approach, and (3) success rate – i.e. adequacy of the remediation
approach to achieve the desired project outcomes in the most cost-efficient manner. The
review included many types of projects, of various sizes (both for sites and remediation
costs), complexity (simple soil removal to complex large scale soil remediation), multiple
groundwater plumes (including LNAPL & DNAPL), various settings (from sand to fractured
rock) and a wide range of assessment consultants and client companies.
RESULTS AND DISCUSSION
The summary results of our review revealed the following results in relation to the questions
posed:
(a) There are no consistent commonalities (i.e. it appears to be random) of remediation
planning approaches. These approaches appear to be highly individualised
according to the methods adopted by particular companies (and often depending on
the choice of personnel responsible for individual projects), such that there is a great
variability in approach and risk management.
(b) Occasional loose reference appears to be made to remediation planning
approaches (and terminology) from other jurisdictions, most prominently from the
UK, which may also reflect personal experience and background of remediation
engineers involved in these projects.
(c) The sophistication of remediation planning approaches generally increases with the
size and complexity of the remediation project, but frequently still follows what has
been previously described as the “conventional view” of the remediation process
(Lane & Gringinger, 2006) including the widespread use of a RAP. However, the
content and sophistication of RAPs are highly inconsistent (even though some
guidance on RAPs exists in NSW and WA), including the random use of
terminology/jargon. In many of these, remediation planning approaches were
incomplete or superficial, without predefined planning logic, or without the use of a
CLM life cycle approach and an outcome focussed (end-in-mind) approach, in
contrast to those in other jurisdictions.
(d) Because most reviewed remediation projects were undergoing statutory Audits
(some are still in progress) it is conceivable that the desired project outcomes were
or could be achieved (i.e. Audit completion), however significant delays (in Audit
and/ or project completion process), re-work, additional reviews, additional work,
and at times onerous management requirements as well as significant cost overruns
occurred on many projects. In our opinion this reflects the inadequacy of the
remediation planning process for these projects.
CONCLUSIONS
Our review presented in this study and previous work (Lane & Gringinger, 2006) confirms
that the lack of Australian guidelines for the remediation planning process is not only
unsatisfactory and at times frustrating for all stakeholders but places an excessive burden
(financial, resources, time and liability) on site redevelopers. This is likely to continue and
may worsen with the prevailing trend of increasingly sophisticated on-site and in-situ
remediation approaches. Hence, to provide for better, more effective and efficient
remediation success, planning guidelines are an essential tool in the CLM life-cycle tool box.
This study shows the need for national guidelines for a sensibly structured but flexible
remediation planning process and its details. If regulators are not willing to develop these
guidelines, then professional organisations (e.g. ACLCA, ALGA) in cooperation with other
stakeholders (e.g. EPAs, CRC CARE etc) should lead the way.
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