New National Guidance for PFAS Contamination

Per- and polyfluoroalkyl substances (PFAS) have been used in a range of consumer products, stain repellants, pesticides and firefighting foams. This group of chemicals is persistent and highly resistant to physical, chemical and biological degradation. They are also highly soluble in water, meaning that they may readily leach from soil to surface water or groundwater and then be transported long distances from the original source. As a result of this, PFAS are found in humans, animals and the environment in Australia and globally. There are some uncertainties regarding the potential risks of PFAS, and there is no natural background level, so a precautionary approach to protect human health and the environment has been adopted by authorities.

In May 2020, new and updated guidance on the environmental management of PFAS contaminated materials was released. The PFAS National Environmental Management Plan (NEMP) Version 2.0 (http://www.environment.gov.au/protection/publications/pfas-nemp-2) was developed by the Heads of EPAs Australia and New Zealand (HEPA) and represents best practice across Australia and New Zealand. It provides a framework for the investigation and management of PFAS contamination. This is part of the process to implement International standards for the management of these chemicals, some of which are listed as Persistent Organic Pollutants (POPs) under the Stockholm Convention.

Revised Guidance in the PFAS NEMP 2.0

Key areas of new and revised guidance in the PFAS NEMP 2.0 include on-site containment, wastewater management, soil reuse and environmental guideline values. A brief summary of the nature of these new aspects of the PFAS NEMP 2.0 is:

On-site containment for both short and long-term storage of PFAS contaminated wastes and/or equipment is detailed. Design requirements for containment and a risk-based matrix based on the duration of storage are both provided to assist site managers with planning for on-site material handling and storage;
A discharge criterion is not provided for PFAS-wastewater management, however, that will be a priority in a future update to the PFAS NEMP. A strategy for minimising PFAS entering wastewater streams is stressed;
There is no single national criterion for soil reuse in the updated PFAS NEMP. A multiple lines of evidence strategy, including a soil reuse flow chart, is recommended to be used to support reuse decisions; and
The environmental guideline values have been updated. Human health and/or ecological guideline values for soil and biota have been updated to include the sum of perfluorooctane sulfonate (PFOS) and perfluorohexane sulfonate (PFHxS) concentrations rather than only PFOS. Also, there was a minor update to the soil human health guideline for residential land use and residential and industrial ecological soil guidelines are now the same.

How PJRA Can Assist

With regard to PFAS, PJRA has experience with assessment of soil, waters, sediment and biota for PFAS, soil containment and reuse of PFAS impacted soil, and risk assessments for Fire Fighting Foam stored for emergency use to determine management options and requirements. The PFAS NEMP 2.0 recognises that PFAS remediation and management are complex topics with challenging technical aspects and therefore recommends that site managers ‘seek expert advice.’ PJRA can assist you with:

Planning and designing monitoring programs for PFAS in a variety of media (e.g. soil, groundwater, surface water, sediments, biota);
Completing human health and/or ecological risk assessments;
Preparing environment management plans for the storage/use of PFAS containing products in accordance with the PFAS NEMP;
Risk assessment of Aqueous Fire Fighting Foams to determine management options and requirements; and
Developing remedial or reuse strategies for PFAS-contaminated waste.

Peter J Ramsay & Associates’ extensive experience in environmental audits, due diligence, risk assessments and contaminated land assessments provide our firm with a solid foundation to assist in satisfying regulatory and compliance requirements regarding PFAS contamination.

If you have any questions about how the updated PFAS NEMP may impact your business, please call Mr Peter Ramsay on (03) 9690 0522.