Environmental Impact Assessment Policy for Contamination

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Policy
ENVIRONMENTAL ASSESSMENT POLICY
Prepared by:
Name: Georgia Derham
Position: Assistant Director, DERP
Date: 21 May 2012
Contact Details:
Approved by:
Name: Vicki Pearce
Position: Program Manager
Date:
Document Control:
Issued:
Version 3.0
6 Dec 2012
1
Environmental Impact Assessment Policy For Contamination
Management And Environmental Remediation Work
1. Introduction
This policy is based on the requirement to:

clarify the environmental assessment process for contamination projects and ensure it is
consistent with Environment and Engineering (EE) Branch Policy on environmental impact
assessment;

ensure any risks of impacts on the environment or heritage are identified and appropriately
managed.
2. Purpose
There are two key aspects of environmental assessment for contamination projects:
a) Risks the contamination poses to human health and the environment in its current unmanaged
state;
b) Potential impacts associated with undertaking contamination management activities, including
stage 2 intrusive sampling and stage 3 remediation planning and design and the stage 4
environmental remediation works.
The requirement under the Statement of Requirement (SOR) issued to consultants for contamination
projects focuses on meeting the requirements of the National Environmental Protection
(Assessment of Site Contamination) Measure 1999. There is also a requirement that potential
impacts on matters identified under the Environment Protection and Biodiversity Conservation Act
1999 (EPBC Act) be considered. This includes considering matters of National Environmental
Significance (NES) and impacts on the environment in general under sections 26 and 28 of the
EPBC Act. Consideration of impacts under these sections should take into account the EPBC Act
Policy Statement 1.2 Significant Impact Guidelines “Actions on, or impacting upon,
Commonwealth land, and actions by Commonwealth agencies”. Responsibilities for the protection
of heritage are described under sections 324 and 341 of the EPBC Act, particularly for buildings
and indigenous cultural matters.
The environmental assessment process for conducting contamination projects where the activity of
intrusive sampling or decontamination works may have an impact on the environment is set out in
this policy and includes the processes set out in the EE Branch’s Environmental Assessment Policy.
It involves conducting Initial Environmental Reviews, developing Environmental Management
Plans and preparing Environmental Assessment Reports to ensure appropriate consideration of
environmental impacts where necessary.
An Initial Environmental Review (IER) is a desktop study of existing environmental studies and
literature and broad environmental assessment of the potential impacts associated with the action
(An IER template is attached).
An Environmental Management Plan (EMP) is a plan that covers management of all aspects
associated with the project, including associated equipment, construction, maintenance and
rehabilitation of facilities and disposal of materials.
An Environmental Assessment Report (EAR) is an evaluation of the relative risks and
opportunities associated with undertaking a particular project and may include recommendations for
an ‘approval in principle’.
Document Control:
Issued:
Version 3.0
6 Dec 2012
2
3. Roles and Responsibilities
The roles and responsibilities for the different environmental assessment processes are listed below.




Initial Environmental Review – consultant engaged to conduct the project to prepare
Environmental Assessment Report – EE Branch (Defence Project Manager (PM))
Environmental Clearance Certificate – Regional Environmental Officer (REO)
Environmental Impact Assessment – consultant to prepare, the Directorate of Environmental
Protection and Approvals to submit to Commonwealth Environment Agency as a referral under
the EPBC Act
4. Environmental Assessment Process
The level of environmental assessment required for contamination projects will depend upon the
stage of work being conducted, and activities being undertaken for the contaminated site. The
process for the four stages of contamination work, are detailed below and represented also in flow
diagram.
Stage 1 Desktop Review
There is no requirement for an IER or ECC for desktop reviews undertaken by consultants.
The final report will consider the potential environmental issues, particularly where significant
impacts might arise from the identified contaminant risks.
Stage 2 Intrusive Sampling and Analysis Investigations
At the same time as preparing the Sampling and Analysis Plan (SAP), an Environmental
Management Plan and Workplace, Health and Safety (WHS) Plan must be prepared by the Lead
Consultant for the investigations proposed. These documents must be cleared by the Defence
Project Manager and REO.
The additional requirement for an IER will be determined on a case by case basis by the Defence
Project Manager, considering the nature of the intrusive work required to conduct the stage 2
investigations. If an IER is developed, the PM will prepare an EAR following receipt of the IER to
determine if a referral under the EPBC Act is required.
An Environmental Clearance Certificate must be prepared for the stage 2 intrusive works and must
be completed by the REO prior to the commencement of the environmental works.
The stage 2 report will consider the potential impacts associated with the contamination risks under
the EPBC Act.
Stage 3 Remediation Action Planning
The stage 3 remediation planning works involve the following components: developing a
Remediation Action Plan (RAP) and associated design documents, conducting a cost benefit
Document Control:
Issued:
Version 3.0
6 Dec 2012
3
analysis of the works, preparing an EMP for the remediation works and preparing and IER for the
proposed environmental remediation works.
An IER must be prepared by the Lead Consultant to consider the potential impacts associated with
the proposed environmental remediation works. This can not be finalised until the RAP and
associated management documentation for the activity, including the EMP and WHS Plan, are
developed and the scope of the work is known.
In accordance with EE Branch’s environment assessment policy, following completion of the IER,
the PM will complete an EAR that will consider the level of approval required for the proposed
activity considering the IER. This will include determining whether internal approval through an
ECC is sufficient, or whether further assessment of impacts through a more detailed EIA is
required, before deciding whether external approval under the EPBC Act may be required.
Stage 4 Environmental Remediation Works
An ECC must be prepared for the works (regardless of the level of environmental assessment) and
must be agreed by the REO prior to the commencement of the environmental remediation works.
This will incorporate measures identified in the EMP to ensure the protection of the environment
during the works.
The close out report submitted by the consultant discusses the results of the stage 4 environmental
works and should consider the likelihood of any residual impacts on the environment and
obligations under the EPBC Act.
Document Control:
Issued:
Version 3.0
6 Dec 2012
4
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