Defence National
Environmental
Standard
Standard for the Prevention and Management of
Pollution from Open Burning and Incineration
Quality information
DNES Approver
DNES Exemption
Approver
This DNES takes effect from the Date of Issue
Document number
Revision
DNES Owner
Date of Issue
Date of Next Revision
DNES Endorsers
Terms, definitions and acronyms
Standard definitions for key terms (including acronyms where applicable) are included in the table
below.Table 1.
Table 1: Key Terms
Term
Acronym (if
applicable)
Ash
Base Support
Manager
Solid waste residues that remain after the completion of a combustion process.
BSM
Best Achievable
Environmental
Outcome
Best Available
Techniques
Definition
Under the Base Accountabilities Model, a BSM is the DSRG representative
accountable for delivery of base support management and services, including
integrated delivery of agreed support services, for a given base.
The best environmental outcome achievable within the constraints of a given
operation, taking into consideration both immediate and long-term environmental risks.
BAT
Those techniques that are most effective in controlling emissions to the environment
with a consideration of technical and economic factors, and available on a scale
relevant to a given sector.
Burning Ground
A site at which open burning or incineration is conducted.
Clinical Waste
Clinical waste is considered Hazardous waste (See Hazardous Waste definition) that
arises from the course of medical activities and do not meet the description of general
waste. Examples include the following: Materials containing or suspected of
containing human blood or bodily fluids, faecal materials, human tissue, bones,
diagnostic specimens, laboratory cultures, sharps, bandages, dressings, surgical
waste, sanitary waste and cytotoxic waste. Waste from patients know to have, or
suspected of having a communicable disease.
Defence
Environmental
Management
System
EMS
Defence Estate
The Defence EMS operates in support of the Defence Environmental Strategic Plan
2010-2014 and aims to deliver environmental services in an integrated and systematic
manner to support ADF capability.
Land owned, leased or used by the Department of Defence.
Defence
National
Environmental
Standard
DNES
A set of quality or performance conditions specifying Defence’s minimum acceptable
level of environmental management for an environmental factor, activity or process.
Defence
Support and
Reform Group
DSRG
DSRG support the Australian Defence Force (ADF) and the other Defence Groups in
meeting their capability and corporate objectives.
Dioxin
The family of compounds comprising polychlorinated dibenzo-p-dioxins (PCDDs) and
polychlorinated dibenzofurans (PCDFs).
Directorate of
Energy
Efficiency and
Resource
Management
DEERM
Directorate within Environment and Engineering (E&E) branch of DSRG Infrastructure
Division, responsible for policy and technical advice relating to energy efficiency and resource
management, including pollution prevention.
Directorate of
Environmental
Remediation
Programs
DERP
Directorate within Environment and Engineering (E&E) branch of DSRG Infrastructure
Division, responsible for policy and technical advice relating to management and
remediation of contaminated sites.
Directorate of
Operations and
Training Area
Management
DOTAM
Directorate within Environment and Engineering (E&E) branch of DSRG Infrastructure
Division, responsible for policy and technical advice relating to management and
remediation of contaminated sites.
Explosives
Custodian
Officer
ECO
Explosives Custodian Officer
Environment
Environmental
Clearance
Certificate
Surroundings in which Defence personnel and its contractors operate, including air,
water, land, natural resources, heritage, flora, fauna, humans, and their interrelation.
ECC
General Waste
Hazard Risk
Assessment
Document that details a planned activity, mitigation measures relevant to the planned
activity and sets out conditions to minimise the likelihood of significant environmental
impacts arising. ECCs are used by exception in instances where the planned activity is
not fully covered by existing operational controls.
Waste that is produced through routine operations that does not meet the description
of hazardous or munitions waste. Examples include used packaging, broken, damage
or consumable items, food waste, and paper.
HRA
An assessment of hazards and risks associated with a particular activity.
Hazardous
Waste
Waste that meets the following description:

Clinical waste;

Waste oils/water, hydrocarbons/water mixtures, emulsions;

Wastes from the production, formulation and use of resins, latex,
plasticizers, glues/adhesives;

Wastes resulting from surface treatment of metals and plastics;

Residues arising from industrial waste disposal operations; and

Wastes which contain certain compounds such as: copper, zinc, cadmium,
mercury, lead and asbestos.
…is considered hazardous waste when it possesses one or more of the following
characteristics:

Explosive;

Flammable (Liquids and solids);

Poisonous;

Toxic;

Ecotoxic; and

Infectious.
Incident
Any occurrence that can result in an impact or impacts on the environment. This
includes incidents, complaints, near misses, observations and non-conformances.
Incident Form
Electronic Form linked to the Incident Register, where information on the incident and
associated actions are recorded. The Incident Form comprises three parts:
Part A: First stop form completed by Originator to capture initial information
about an incident;
Part B: Review and verification of initial information; and
Part C: Form used to guide and document the findings of an investigation into an
incident and prescribe subsequent actions.
Incineration
The combustion of waste in an incinerator; a device comprising a chamber or number
of chambers in which waste and resultant gases are combusted, and from which
combustion products are exhausted as a coherent gas stream.
Mobile
Able to be readily moved.
Munitions
Waste
Waste comprising weapons, ammunition and/or waste materials associated with the
ammunition manufacturing processes. Examples include faulty, malfunctioning or
expired ammunition and ordnance.
National
Association of
Testing
Authorities
NATA
NATA provides assessment, accreditation and training services to laboratories and
technical facilities throughout Australia and internationally
Nonconformance
An action or omission that did not meet Defence’s environmental operational controls
including Defence Instructions, Defence Environmental Standards, Environmental
Clearance Certificate conditions, Range Standing Orders, Standard Operating
Procedures; or an action or omission that did not meet external conditions placed on
Defence.
Open Burning
The combustion of waste in an open or partially open combustion environment such as
a burn pit, burn box, burn pan, barrel, or the open ground.
Other Waste
Waste that does not meet the specification for general, clinical or munitions waste, and
requires special consideration with regard to disposal options.
Personnel
Members of the Australian Defence Force (ADF), members of the Australian Public
Service (APS) employed by Defence, contractors/subcontractors and/or consultants
performing work or providing services for Defence, and third parties or other visitors to
the Defence Estate.
Regional
Environment
Officer
REO
Supports and represents the Senior Environment Manager at bases and groups of
bases.
Senior ADF
Officer
SADFO
Under the Base Accountabilities Model, the role of SADFO is an additional role for an
appointed senior military officer on a given base. SADFOs are required to provide
broad leadership to all military staff on the base, consistent with the Chief of Defence
Force’s expectations of all senior ADF officers.
Senior
Environment
Manager
SEM
Senior professional advisor for environmental matters in a DSRG region, advising
Defence personnel including senior Commanders and managers. Leads the
environmental team and manages the regional implementation of national strategic
programs.
Standard
Operating
Procedures
SOP
Operational control that specifies how a standard activity should be undertaken. This
may include specific requirements to minimise WHS and environmental risks. Initial
incident responses may also be detailed for certain activities.
Temporary
In use at a given location for a period of less than 6 months.
Waste
Any discarded, rejected, abandoned, unwanted or surplus material.
Purpose
1.
The purpose of this DNES is to establish the minimum performance requirements for
the prevention of pollution associated with open burning and incineration practices.
Scope
2.
This DNES applies to Defence Establishments where waste materials are burnt in
open air (e.g. burn pits, barrels, burn boxes) or within incinerators. This DNES also
applies to contractors operating Government Furnished Facilities at which burning of
waste takes place.
3.
This DNES does not apply to the destruction of classified documentation or the
destruction of munitions by open detonation.
Performance Requirements
4.
The following performance requirements collectively support this DNES:









The Environmental Manager’s Guide, Burning Grounds (CH2, 2005)
Defence Environmental Strategic Plan 2010-2014
Defence Waste Minimisation Policy (2007)
National Environment Protection (Ambient Air Quality) Measure (NEPC, 1998)
National Environment Protection (Air Toxics) Measure (NEPC, 2004)
National Environment Protection (Assessment of Site Contamination) Measure
1999 (as amended 2013) Guideline on Investigation Levels For Soil and
Groundwater, enacted by the Standing Committee on Water and the
Environment (SCEW)
Australian and New Zealand Guidelines for Fresh and Marine Water Quality
(ANZECC, 2000)
Stockholm Convention on Persistent Organic Pollutants
The Environment Protection and Biodiversity Conservation Act 1999 (the EPBC
Act).
Minimum Performance Levels – Avoidance of Open Burning
5.
Waste is to be managed in accordance with the Defence Waste Minimisation Policy
(2007), and The Environmental Manager’s Guide, Burning Grounds (CH2, 2005).
This consists of the following measures:
a. Prior to the consideration of disposal methods, every effort should be made
to reduce waste in accordance with the waste hierarchy of prevention,
minimisation, reuse, recycling and energy recovery, as shown in Annex A
b. Burning may only be used as a last resort for waste disposal, after a
thorough investigation of alternative disposal measures
c. In the case that burning is deemed necessary, the use of an enclosed
combustion environment (e.g. an incinerator or confined burn facility) is
preferred to open burning, given improvements in the ability to control the
combustion environment, as well as the ability to capture and treat the
combustion gases
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d. All open burn and incineration activities must be approved by an
SEM/REO, and covered by an Environmental Clearance Certificate (ECC).
For recurrent practices, these activities must be performed in accordance
with a site-specific Environmental Management Plan (EMP) that addresses
the proposed burning activity.
Minimum Performance Levels – Open Burning
6.
Open Burning of Munitions Waste
e. In situations where open burning of munitions waste is proposed, open
burning shall be:
i. performed in accordance with appropriate approvals as attained from
Explosive Ordnance Division (Explosives Custodian Offocer to
provide)
ii. subject to an ECC administered by the SEM/REO that is supported
by a document which includes:

A brief background to the disposal requirement (location,
source of waste, waste characterization, volume of waste
present and rate of generation)

Identification and assessment of waste disposal alternatives
(see Annex B for examples of reference material on the
consideration of alternative disposal methods)

Environmental monitoring as required to demonstrate that
exposures do not constitute an unacceptable health risk to
personnel, nearby receptors, and/or the environment (e.g. air,
soil, groundwater and/or surface water)

Nomination of appropriate monitoring methods including
compliance criteria in cases where quantitative monitoring is
proposed

Requirements for development of (or revisions to an existing)
EMP for the activity.
For locations where open burning is proposed to occur on an
ongoing basis, this document is to be reviewed, updated and reapproved on an annual basis; and
iii. Located a sufficient distance from sensitive human and
environmental receptors and operated in a manner that minimises
human and environmental health risks (see Appendix C of
[CH2MHill, 2005] for relevant environmental factors).
iv. Bunded and contained to prevent ash, debris and liquids from
passing into the natural environment
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f. In addition to specific requirements of this DNES, open burning is to be
conducted in accordance with the guidance provided in (CH2MHill, 2005)
Environmental Manager’s Guide to Burning Grounds
g. Where approved, open burning of munitions waste is to be conducted on
an engineered structure of an impermeable nature, such as a concrete pad
and/or metal pan, as required to prevent the release of contaminants
(e.g. accelerants, untreated wastes or ash residues) to the environment:
i. The structure should be constructed of a material sufficient to
withstand burning processes, and of sufficient depth and size to
contain the ash residues
ii. The structure should be constructed with guards or baffles, as
required to prevent the dispersion of ash residues in wind
iii. The structure may be elevated slightly above the ground to enhance
cooling and to allow inspections for leaks
iv. The structure should be fitted with a removable cover, and covered
when not in use in order to prevent the generation of contaminated
wastewater in the event of rain
v. Where appropriate, the structure should be fitted with a (blind)
collection sump to handle liquids that may accumulate should a spill
occur.
h. Ash residues and other wastes are to be collected and stored in an
appropriately secured container, for subsequent disposal in accordance
with relevant legislative requirements and Defence policies.
7.
Open Burning of General Waste
a. Open burning is only to be used for the disposal of general waste if no
other viable alternative exists.
b. Outside of Australia, open burning of general waste should only occur:
i. in accordance with Avoidance of Open Burning priorities (as
outlined in this Section 4 of this DNES)
ii. where there are no other feasible options
iii. in situations where the activity constitutes the best achievable
environmental outcome for the management of the subject waste
stream in the context of operational constraints.
c. In situations where open burning of general waste is proposed, the
activity shall be:
i. subject to an approval by the SEM/REO (or delegate), in
accordance with an application that includes:
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
A brief background to the disposal requirement (location,
source of waste, waste characterization, volume of waste
present and rate of generation)

An assessment of waste disposal alternatives

Environmental monitoring as required to demonstrate that
exposures do not constitute an unacceptable health risk to
personnel, nearby receptors, and/or the environment (e.g.
air, soil, groundwater and/or surface water).
ii. limited to temporary use (<6 months), and accompanied by
expediting the establishment of preferred longer term waste
disposal capabilities (e.g. establishment of a landfill)
iii. located and operated in a manner that minimizes human and
environmental health risks (see Appendix C of [CH2MHill, 2005]
for relevant environmental factors)
iv. subject to measures shall that avoid direct contact between liquid
accelerants and the soil
v. Ash residues and other wastes should be collected and stored in
marked, secure, sealed containers, for subsequent disposal in
accordance with relevant legislative requirements and Defence
policies.
8.
Open Burning of Clinical Waste
Clinical waste must not be disposed of by open burning.
9.
Open Burning of Other Waste
Open burning of other waste may be considered by the SEM/REO on a case by
case basis, and in accordance with the intent of this DNES. Such activities must
be administered under an ECC.
Minimum Performance Levels – Incineration
10. In accordance with Australia’s obligations under the Stockholm Convention on
Persistent Organic Pollutants, wastes containing chlorine (e.g. TCE, salt [NaCl],
biomass, or paper) should be treated using an incinerator that applies Best
Available Techniques (BAT) for minimisation of dioxin emissions. Within
Australia, this is recognized as an emission concentration of less than
0.1 nanograms per cubic metre (TEQ), as corrected to the reference conditions
of 1 atmosphere and 0°C.
Ash residues and other incineration wastes (e.g. sorbents used in emission
control devices) should be collected and stored in marked, secure, sealed
containers, for subsequent disposal in accordance with relevant legislative
requirements and Defence policies.
11. Incineration of General Waste
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Incinerators burning general waste must treat the exhaust stream in accordance
with air emission standards provided in Annex A to this DNES. These
standards are generally protective of state-based emission legislation, however
in cases where compliance with state-based emissions limits is sought, relevant
state-based requirements should be consulted directly.
Compliance testing should be performed by a dedicated stack tester that is
NATA accredited for the test methods employed. The frequency of compliance
monitoring is to be at the discretion of the REO.
12. Incineration of Clinical Waste
Permanent incinerator installations must treat the exhaust stream in accordance
with air emission standards provided in Annex A to this standard. These
standards are generally compliant state-based emission legislation, however in
cases where compliance with state-based emissions limits is sought, relevant
state-based requirements should be consulted directly.
Compliance testing should be performed by a dedicated stack tester that is
NATA accredited for the test methods employed. The frequency of compliance
monitoring is to be at the discretion of the REO.
In the case of temporary applications where it is not considered feasible to treat
the exhaust stream in accordance with the emission limits in Annex A,
incineration of clinical waste can be undertaken in accordance with the following
conditions:
a. The incinerator is mobile in nature, and used on a temporary basis
(<6 months)
b. Contains secondary combustion chamber that maintains combustion
gases at a temperature of 1000 °C or greater for a period of 2 seconds
or greater
c. A screening level human health and environmental risk assessment,
which contains a site-specific consideration of environmental and
human health risks
d. Nomination of appropriate monitoring and management measures,
including compliance criteria in cases where quantitative monitoring is
proposed.
13. Incineration of Munitions Waste:
Incinerators used for the disposal of munitions waste within Australia must treat
the exhaust stream in accordance with relevant state-based legislative
requirements specified in Annex A to this standard.
Compliance testing should be performed by a dedicated stack tester that is
NATA accredited for the test methods employed. The frequency of compliance
monitoring is to be at the discretion of the REO.
14. Incineration of Other Waste:
Incineration of other waste may be considered by the SEM on a case by case
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basis, and in accordance with the intent of this standard. Such activities are to
be administered under an ECC and EMP.
Minimum Performance Levels – Pollution Events
15. Where a pollution event has resulted in contamination of soil, surface water or
groundwater, actions must be taken to characterize and delineate the extent of
the impacts. This shall be in the form of soil and water sampling, and analysis
for contaminants of potential concern. If only a small area has been impacted or
this sampling can be carried out by DSRG environment staff. For larger areas or
where groundwater is suspected to have been impacted, the Defence
Environment and Heritage Panel (DEHP) is available from which can be
engaged a consultant with suitable site assessment capability.
16. Should concentrations of contaminants in soil and water exceed the adopted
guidelines, guidance must be sought from DEPA and the Defence
Environmental Remediation Programme (DERP) on the approach to managing
and potentially remediating the pollution event.
Incident, Emergency and Non-Conformance
17. Non-conformances must be documented and corrective actions implemented to
ensure conformance with the Minimum Performance Levels. This is contained
in the monitoring, audit and review section below.
Monitoring, Audit and Review
18. An annual report of burning operations will be prepared by the SEM/REO for
submission to DEERM. This will provide a summary of information on the
adequacy of this DNES, including:
a. A summary of open burning and incineration activities undertaken
within the year.
b. A review of the adequacy of this DNES in achieving the prevention of
pollution, including the compilation of any feedback, pollution events,
and shortcomings in the application of this DNES in the context of its
objectives.
19. All Defence personnel shall be responsible to report any non-operationally
approved pollution event to the REO and their direct supervisor. The REO shall
be responsible for external reporting of any uncontained pollution event.
20. Auditing or monitoring and analysis reports must be performed annually by a
Defence accredited auditor.
21. General reporting requirements under the Defence EMS are addressed in other
DNES – refer to the Defence Environmental Standards Register (published on
EMS Intranet Site).
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User feedback
22. Personnel are encouraged to provide feedback on this DNES. Feedback will be
used to inform future versions of this document, which is reviewed at regular
intervals as part of the Defence EMS continual improvement process.
23. Provide any feedback on this DNES via email to
environmentandheritage@defence.gov.au. Please include the DNES title in the
subject line of email/feedback.
Useful References
24. Defence Environmental Strategic Plan 2010-2014, Department of Defence,
http://www.defence.gov.au/environment/strat_plan.pdf (accessed: 02/07/2013)
CH2MHILL, 2005 Environmental Manager’s Guide, Burning Grounds,
CH2MHILL, September 2005
NEPC, 2004 National Environment Protection (Air Toxics) Measure, National
Environment Protection Council, 2004
NEPC, 1998 National Environment Protection (Ambient Air Quality) Measure,
National Environment Protection Council, 1998
ANZECC, 2000, Australian and New Zealand Guidelines for Fresh and Marine
Water Quality, Volume 1, The Guidelines, Australian and New Zealand
Environment and Conservation Council, November 2000
DoD, 2007, Defence Waste Minimisation Policy, Department of Defence, 2007
National Environment Protection (Assessment of Site Contamination) Measure
1999 (as amended 2013) Guideline on Investigation Levels For Soil and
Groundwater, enacted by the Standing Committee on Water and the
Environment (SCEW)
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Annex A
Waste Hierarchy Pyramid
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Annex B
Air Emission Standards for Incinerators
These emission standards represent generic performance standards relevant to the
control of emissions from incinerators. These have been developed from state-based
emissions legislation, and represent levels that are generally protective of compliance
with state-based legislation across all states. State-based legislation should be
consulted directly with regard to the assessment of compliance with limits within a
specific state.
Table A1
Air Emission Standards for Incinerators
Indicative Emission Standard
Substance
mg/m3, dry @11%O2, 0°C, 1 atm
General
Oxides of Nitrogen (as Nitrogen Dioxide)
350
Carbon Monoxide
125
Particulate Matter
50
0.1 X 10-6 (a)
Dioxins & Furans (TEQ)
Acid Gases
Hydrogen Chloride
100
Chlorine
200
Sulphuric Acid Mist and Sulphur Trioxide (as Sulphur Trioxide)
100
Hydrogen Fluoride
50
Heavy Metals
Cadmium
0.2
Mercury
Aggregate of Type 1+2
(a)
(b)
(c)
(d)
0.2
Substances(b,c)
1
Applicable to incinerators treating waste streams containing the precursors of dioxin formation. This includes chlorine
containing compounds such. Examples include chlorinated solvents and biomass;
Type 1 Substance means the elements antimony, arsenic, cadmium, lead or mercury or any compound containing one or
more of those elements.
Type 2 Substance means the elements beryllium, chromium, cobalt, manganese, nickel, selenium, tin or vanadium or any
compound containing one or more of those elements;
These emission standards are not intended for application to mobile incinerators used in a temporary capacity (< 6months).
New South Wales – POEO (Clean Air) Regulation 2010
NSW (2010) Protection of the Environment Operations (Clean Air) Regulation 2010, as in force under
the Protection of the Environment Operations Act 1997, NSW Government, 13 August 2010.
Victoria – SEPP (AQM) 2001
VIC (2001) State Environment Protection Policy (Air Quality Management) of the as in force under the
Environment Protection Act 1970, Victorian Government, 21 December 2001.
South Australia – EPP (AQ) 1994
SA (2005) South Australia Environment Protection (Air Quality) Policy 1994 under the Environment
Protection Act 1993, V3.11.2005, South Australian Government, 3 November 2005.
Western Australia – Medical Waste Incinerator Guidance Statement
WA EPA (2001) Guidance for the Assessment of Environmental Factors Western Australia (in
accordance with the Environmental Protection Act 1986) Environmental Protection Authority No. 13
Final March 2000 Management of Air Emissions from Biomedical Waste Incinerators, Western
Australian Environmental Protection Authority, 17 March 2000.
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Annex C
Example references for the Consideration of Alternatives to
Open Burning
1.
2.
3.
4.
5.
NG 2008, Best Practice Guide on the Destruction of Conventional Ammunition, Government of
the Netherlands, Document Ref: FSC.DEL/59/08/Rev.1, 2 June 2008
UN 2001, A Destruction Handbook Small Arms, Light Weapons, Ammunition and Explosives,
United Nations Department for Disarmament Affairs, 2001
US ACE 1998 Alternatives to Open Burning/Open Detonation of Energetic Materials, A Summary
of Current Technologies, Technical Report 98/104, United States Army Corps of Engineers,
August 1998
UN 2011, International Ammunition Technical Guideline - Demilitarization and Destruction of
Conventional Ammunition, United Nations Office for Disarmament Affairs, Document Ref: IATG
10.10:2011, 2011
MSIAC 2006, Review of Demilitarisation and Disposal Techniques for Munitions and Related
Materials, J Wilkinson (RAN) & D Watt (MSIAC), January 2006 website:
http://www.rasrinitiative.org/pdfs/MSIAC-2006.pdf (accessed 01/07/2013)
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