AQUOUS FILM FORMING FOAM (AFFF) DIRECTIVES

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POLICY FOR THE PREVENTION AND MANAGEMENT OF
POLLUTION FROM THE BURNING OF WASTE
Version 1.0; June 2014
Purpose
The purpose of this policy is to ensure that pollution from open burning and incineration is
prevented. This is achieved through the implementation of a framework for the identification
and management and of risks associated with Defence’s open burning and incineration
practices. The Open Burning and Incineration Defence National Environmental Standard
(DNES, to be read in conjunction with this Policy) stipulates the minimum performance
requirements for burning practices in accordance with waste type and burning method.
This policy applies to Defence Establishments where waste materials are burnt in open air
(e.g. burn pits, barrels, burn boxes) or within incinerators. This policy also applies to
deployed forces in Areas of Operations.
This policy does not apply to the destruction of classified documentation or the destruction of
munitions by open detonation.
Where full compliance with this policy cannot be assured, alternative methods must be
proposed and endorsed by the Technical Authority, the Assistant Secretary Engineering and
Environment.
Background
Burn pits and incinerators are used by Defence as a waste disposal method. The combustion
of waste can generate a range of environmental contaminants, which have the potential to be
released to the air, water and land. The environmental contaminants associated with such
activities may include:
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Gaseous pollutants such as oxides of nitrogen, carbon monoxide and acid gases (e.g.
sulphur dioxide, hydrogen chloride and hydrogen fluoride)
Particulate matter
Heavy metals (e.g. lead)
Dioxins, furans, and other organic compounds.
These contaminants must be eliminated or minimised by avoidance of burning (i.e. avoidance
of waste generation, or use of alternative disposal methods), ash containment, runoff
management and emissions control.
Michael Healy
A/HEAD INFRASTRUCTURE
1
Regulatory Requirements
Legislation – Defence must comply with the Environment Protection and Biodiversity
Conservation Act 1999 (EPBC Act) to prevent significant environmental impacts and must act
to prevent impacts upon Matters of National Environmental Significance (MNES). Where
Defence activities have resulted in pollution of a state regulated environment, Defence must
comply with the relevant State or Territory environmental legislation and regulations.
Defence is also bound to implement all National Environmental Protection Measures (NEPM)
enacted by the Standing Committee on Water and the Environment (SCEW).
Waste burning and incineration guidelines – several guidelines exist which govern the
burning of waste at the State, national and international levels. Defence has adopted the
NEPM on Air Toxics, Ambient Air Quality and Assessment of Site Contamination to guide
the pollution prevention measures associated with burning and incineration of waste.
Responsibilities
Authority - The Assistant Secretary Engineering and Environment (ASEE) is the Technical
Authority for infrastructure engineering and environmental policy in Defence.
Implementation – The Senior Australian Defence Force Officer (SADFO) and Base Support
Manager (BSM) at each Defence Establishment are responsible for the implementation of this
policy at the site level. Senior Environmental Managers (SEM) and Regional Environmental
Officers (REO) will facilitate and advise on the implementation of the policy.
Management of Open Burning and Incineration
The following requirements are mandated as the minimum to ensure that pollution from the
burning of waste is prevented or minimised:
1. Waste must be managed in accordance with the Defence Waste Minimisation Policy
(DoD, 2007) following the waste reduction hierarchy of prevention, minimisation,
reuse, recycling, energy recovery and disposal
2. Burning is only permitted as a last resort for waste disposal, after a thorough
investigation and evaluation of alternative disposal measures
3. In the case that burning is proposed an enclosed combustion environment (e.g. an
incinerator or confined burn facility) must first be considered as this improves control
of the combustion environment and provides the ability to capture and treat
combustion gases
4. All open burn and incineration activities must be approved by an SEM/REO in
accordance with the Environmental Clearance Certificate (ECC) for the activity
5. Open burning must not be used for the disposal of clinical waste
6. Incinerators burning general waste must treat the exhaust stream in accordance with
air emission standards provided within Annex A of the DNES
7. Permanent incinerators designed and approved for the burning clinical waste must
treat the exhaust stream in accordance with air emission standards provided within
Annex A of the DNES. Mobile incinerators burning clinical waste must be used in
accordance with performance requirements provided in the DNES.
Michael Healy
A/HEAD INFRASTRUCTURE
2
Reporting
All spills or incidents shall be reported to the line management and SEM/REO promptly.
Incident reports must be through environmentalincident@defence.gov.au in addition to local
arrangements. Where a large incident is concerned, the SEM is to assess whether the incident
is likely to affect offsite environments, and whether the incident should be reported to State
environment authorities.
Michael Healy
A/HEAD INFRASTRUCTURE
Michael Healy
A/HEAD INFRASTRUCTURE
3
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