CONTAMINATED SITES

Guidelines for the Assessment

and Management of
Groundwater Contamination


Limitations
These guidelines should be used in conjunction with other relevant
guidelines made or approved by the Department of Environment
and Conservation NSW under section 105 of the Contaminated Land
Management Act 1997 when assessing and managing groundwater
contamination. The References section lists other relevant and useful
documents.
These guidelines do not include occupational health and safety
procedures. The NSW WorkCover Authority should be consulted on these.
Appropriate action must be taken to manage any potential hazard and
adequately protect the health of any workers on, or occupiers of, the site.

Disclaimer
The Department of Environment and Conservation NSW has prepared
this document in good faith, exercising all due care and attention, but no
representation or warranty, express or implied, is made as to the relevance,
completeness or fitness of it for any other purpose in respect of a particular
user’s circumstances. Users of this document should satisfy themselves
about its application to their situation and, where necessary, seek expert
advice.
The Department of Environment and Conservation is pleased to allow this
material to be reproduced in whole or in part, provided the meaning is
unchanged and its source, publisher and authorship are acknowledged.

Published by:
Department of Environment and Conservation NSW
59–61 Goulburn Street
PO Box A290
Sydney South 1232
Ph: (02) 9995 5000 (switchboard)
Ph: 131 555 (environment information and publications requests)
Ph: 1300 361 967 (national parks information and publications requests)
Fax: (02) 9995 5999
TTY: (02) 9211 4723
Email: [email protected]
Website: www.environment.nsw.gov.au
DEC 2007/144
ISBN 978 1 74122 366 8
March 2007
Printed on recycled paper
Preface
Background
Groundwater contamination can arise from either point sources
or diffuse sources. Common examples of point sources that could
contaminate groundwater are leaking underground storage tanks,
inadequately-managed waste disposal sites and accidental chemical
spills. An example of a diffuse source is pesticides and nutrients
applied to broad-acre agricultural land that infiltrate through soils to
groundwater.
These guidelines focus on groundwater pollution arising from point
source contamination rather than on broad-scale groundwater issues
arising from diffuse sources.
Contaminated groundwater can be unsuitable for use and may also
adversely affect the quality of surface water and sediments. It may
then harm human and ecological health. Contaminated groundwater
may also affect the types of land uses that may safely be carried out
above a contaminant plume.
The legacy of groundwater contamination can be a major burden
on the community because once groundwater is contaminated it
is generally difficult and costly to remediate. Therefore, preventing
groundwater contamination is the most practical way of protecting
groundwater quality.
Where contamination of groundwater is identified, acute risks,
such as the possible accumulation of explosive vapours in
subsurface utilities, must be immediately managed. The source of
contamination must be removed to ensure the protection of human
health and the environment. The following actions should also be
taken whenever practicable:
• the environmental values of the groundwater must be restored
• groundwater quality must be restored to its natural background
concentration.
These Guidelines for the assessment and management of groundwater
contamination (the guidelines) outline a best-practice framework for
assessing and managing contaminated groundwater in NSW.
The Department of Environment and Conservation NSW (DEC) must
be notified about certain groundwater contamination under the
Contaminated Land Management Act 1997 and the Protection of the
Environment Operations Act 1997. Following notification, DEC may
decide that the contamination warrants regulatory intervention.
These guidelines should help consultants and industry to devise
groundwater assessment and management strategies that are
consistent with DEC’s expectations.
The guidelines are not intended to be a text book for groundwater
contamination nor to provide detailed technical advice on the
assessment and management of contaminated groundwater.
Information about groundwater fundamentals is presented in other
publications, including those presented under ‘Suggested further
reading’ on page 39. In all cases, groundwater contamination
assessments and remediation must be conducted by competent
professionals who already have relevant qualifications and
experience. Where technical guidance material may be useful to
readers, it is referred to in the relevant section of the guidelines or
under ‘References’. Reference to these documents, however, does
not mean DEC endorses them. Policy documents endorsed by DEC
are published every six months under the Freedom of Information
Act. Contact DEC’s Environment Line on 131 555 for further
information.
Various other guidelines that may be updated from time to time are
referred to throughout this document. Where a referenced guideline
which is endorsed by the NSW Government or DEC is updated, the
relevant reference(s) in this document should be read as if they were
to the endorsed updated version. For all other guidelines, references
should be read as if they were to the updated references as soon as
updated versions have been released.
Table of contents
1 Introduction, 1
1.1 About the guidelines, 1
1.2 Scope of the guidelines, 1
1.3 Policy, legislative framework and existing guidance, 2
1.3.1 Key policy principles from NSW groundwater policies, 2
1.3.2 Framework for groundwater management in NSW, 3
1.3.3 Existing guidance on groundwater, 6
1.4 Importance of groundwater, 7
1.5 Definition of groundwater contamination, 7

2 Assessing groundwater contamination, 9

2.1 Introduction, 9
2.2 Preliminary assessment, 10
2.2.1 Determining natural background groundwater quality, 12
2.2.2 Comparing contaminant concentrations against GILs, 12
2.3 Detailed assessment, 13
2.3.1 Protecting the groundwater’s environmental values, 14
2.3.2 Site-specific risk assessment, 15
2.3.3 Contaminant fate and transport modelling, 16
2.3.4 Additional aspects to consider, 18

3 Managing groundwater contamination, 21

3.1 Introduction, 21
3.2 Management responses to contamination, 22
3.3 Controlling short-term threats, 22
3.4 Restricting groundwater use, 23
3.5 Source control, 24
3.5.1 Non-aqueous phase liquids, 25
3.6 Plume containment, 26
3.7 Clean-up of contaminated groundwater, 26

4 Cleaning up contaminated groundwater, 27

4.1 Clean up so natural background water quality is restored, 27
4.1.1 Monitored natural attenuation, 27
4.2 Clean up to protect the relevant environmental values of
groundwater, and human and ecological health, 28
 4.3 Clean up to the extent practicable, 29
4.3.1 Demonstrating restoring environmental values is
impracticable, 29
4.4 Clean-up impacts, 31
4.5 Clean-up timeframe, 31
4.6 Degraded local groundwater quality, 32
4.7 Environmental monitoring, 33
4.8 Groundwater management plans, 33
4.8.1 Regulatory controls for ongoing management of
groundwater contamination, 34

5 Regulation, 35
5.1 Regulation under the CLM Act, 35
5.2 Regulation under the POEO Act, 35
5.3 Requirements under SEPP 55, 36

6 References, 37
Relevant Acts of Parliament and policies, 39
Suggested further reading, 39

Appendices, 43
Appendix 1 Glossary, 43
Appendix 2 Identifying environmental values, 44
2.1 Major aquifers of drinking water quality, 50
Appendix 3 Monitored natural attenuation, 51
Appendix 4 Contacting NSW government departments for advice on
groundwater contamination, 57

1 Introduction
1.1 About the guidelines
These Guidelines for the assessment and management of groundwater
contamination (the guidelines) outline a best-practice framework for
assessing and managing contaminated groundwater in NSW. While
the guidelines do not articulate legislative requirements, they are
made under section 105 of the Contaminated Land Management Act
1997 (CLM Act), so the Department of Environment and Conservation
(DEC) must take them into account whenever they are relevant. DEC
exercises certain statutory functions and powers (including
those set out in the Protection of the Environment Operations Act
1997 (POEO Act) and CLM Act) in the name of the Environment
Protection Authority.
Site auditors accredited under the CLM Act must also consider
these guidelines when finalising site audits. The guidelines will also
be useful for environmental consultants, local councils, industry
organisations, water regulators, water users and other members of
the community.
These guidelines should help consultants and industry to devise
groundwater assessment and management strategies that are
consistent with DEC’s expectations.

1.2 Scope of the guidelines

The guidelines are set out as follows:
Section 2 – Assessing groundwater contamination – outlines ways
of identifying whether groundwater is contaminated and describes
how to conduct preliminary and detailed assessments.
Section 3 – Managing groundwater contamination – outlines ways
of controlling groundwater contamination and identifying what
remediation is needed to resolve it.
Section 4 – Cleaning up contaminated groundwater – describes
a clean-up hierarchy including when it is essential to clean up so
natural background water quality is restored and when clean-up to
the extent practicable is acceptable.
Section 5 – Regulation – explains DEC’s regulatory involvement in
managing groundwater contamination.
Section 6 – References – contains references, relevant Acts and
policies, and a suggested further reading list.

 Appendix 1 – contains a glossary of terms used throughout these
guidelines.
Appendix 2 – contains information about how to identify
environmental values, and a list of major aquifers of drinking water
quality identified by the NSW Department of Natural Resources
(DNR).
Appendix 3 – contains more detailed information about monitored
natural attenuation.
Appendix 4 – contains contact details for relevant NSW Government
departments.

1.3 Policy, legislative framework and existing guidance

1.3.1 Key policy principles from NSW groundwater policies
Legislation and published policies in NSW have articulated key
principles for assessing and managing groundwater contamination.
These include the principles of ecologically sustainable
development, which require the effective integration of economic,
social and environmental considerations in decision-making. This
can be achieved by implementing:
• the precautionary principle
• intergenerational equity
• conservation of biological diversity and ecological integrity
• improved valuation, pricing and incentive mechanisms for
environmental factors (including the concept of ‘polluter pays’)
– see section 10 of the CLM Act.
The groundwater policies set out in 1.3.3 encourage ecologically
sustainable development to:
• slow and halt, or reverse, any degradation of groundwater
resources
• ensure long-term sustainability of the ecological support
characteristics of groundwater systems
• maintain the full range of beneficial uses of these systems
• maximise economic benefit to the region, state and nation.
The policies set out basic principles that should guide the
management of groundwater in NSW. In relation to groundwater
contamination, these include:


 • preventing groundwater pollution so future remediation is not
required
• managing all groundwater systems so their most sensitive
identified beneficial use (or environmental value) is maintained,
recognising the cumulative impacts of human activities on
groundwater quality
• replacing processes and practices that degrade groundwater
systems, either directly or indirectly, with ecologically sustainable
alternatives
• requiring developments to minimise adverse impacts on
the environment by preventing pollution of, or changes in,
groundwater quality
• applying the precautionary principle to protect groundwater-
dependent ecosystems where scientific knowledge is lacking
• affording town water supplies special protection against
contamination
• rehabilitating degraded groundwater systems, where practical,
to minimise the impacts of contamination on groundwater-
dependent ecosystems, and to restore the ecosystem support
characteristics of groundwater systems.
DEC will consider the above principles of ecologically sustainable
development when exercising functions under the CLM Act, and
others managing contaminated groundwater must also implement
these principles.
These guidelines establish a decision-making framework for
addressing groundwater contamination that is consistent with these
principles.

1.3.2 Framework for groundwater management in NSW

Various government departments in NSW, including the Department
of Natural Resources (DNR), Department of Environment and
Conservation NSW (DEC), and the Department of Planning, along
with local councils, share groundwater management responsibilities.
Department of Natural Resources
The Minister for Natural Resources and DNR regulate the use of
groundwater through a licensing framework under the Water
Management Act 2000 (WM Act). The WM Act recognises that
landholders overlying an aquifer can access groundwater for


 domestic consumption and stock watering purposes without
requiring an access licence or water use approval. However,
landholders exercising this basic right require approval to construct
a water bore, and the installation of any groundwater bore in NSW
requires a licence from DNR.
Under the WM Act, environmental water rules for all planned
environmental water sources in NSW (including groundwater) must
be implemented as soon as possible. Environmental water rules are
provisions for identifying, establishing and maintaining planned
environmental water, which is water reserved through management
plans for fundamental ecosystem health or other specified
environmental purposes. The WM Act also requires all water sources,
including groundwater, to be protected and restored, and their water
quality to be protected, and wherever possible, enhanced.
At the time of writing, not all the provisions of the WM Act have
commenced. Macro water sharing plans are being prepared for
water sources, including groundwater sources, that have not been
included in any water sharing plans in force under the WM Act. The
macro plans will provide generic water sharing rules for four distinct
aquifer types: coastal sands, unconsolidated sediments, porous
rocks, and fractured rocks.
In the context of groundwater resource management, DNR is also the
key agency for designating appropriate uses of groundwater in NSW,
including potential uses. DNR helps make decisions about what risks
may be present as a result of groundwater contamination and what
degree of clean-up is required.
Department of Environment and Conservation
The key pieces of legislation for preventing and regulating
groundwater contamination in NSW are the Protection of the
Environment Operations Act 1997 (POEO Act) and the Contaminated
Land Management Act 1997 (CLM Act), which are both administered
by DEC.
The POEO Act governs the protection of the environment from
pollution. Under this Act it is an offence to pollute waters, including
groundwater. The Act also gives powers to the appropriate
regulatory authority, generally DEC or local councils, to issue clean-
up notices, which are one way of regulating the clean-up and
ongoing management of groundwater contamination. The POEO Act
also establishes a duty to notify the appropriate regulatory authority
of pollution incidents that are causing or threatening material harm
to the environment.

The CLM Act sets out a framework for assessing and managing
contaminated land, which includes groundwater. It also places a
duty on polluters and landowners to notify DEC of certain types of
contamination.
Minister for Planning/Department of Planning/local councils
The Department of Planning and local councils have several
responsibilities for groundwater and groundwater contamination.
Under Parts 4 and 5 of the Environmental Planning and Assessment
Act 1979 (EP&A Act), consent authorities and determining authorities
must consider the likely impacts of proposed development and
other activities on the environment, including groundwater. Under
Part 3A of the EP&A Act (which applies to certain major infrastructure
and other projects), the Minister for Planning, when deciding
whether to approve a project, is required to consider the report by
the Director General of the Department of Planning. The Director
General’s report is required to include, among other things, a copy
of the proponent’s environmental assessment report and any
environmental assessment undertaken by the Director General.
Under State environmental planning policy no. 55 – Remediation of land
(SEPP 55) (NSW DUAP and NSW EPA 1998), planning authorities must
consider land contamination issues when assessing certain rezoning
applications. Consent authorities must also consider whether the
land is contaminated when assessing development applications. If
the land has been contaminated, the planning or consent authority
must be satisfied that it is suitable in its contaminated state, or will
be suitable after remediation, for the purposes for which the land
is to be rezoned or for which the development is proposed to be
carried out. In some instances groundwater contamination can make
the land unsuitable for a particular use and, therefore, management
of the contamination may be necessary before the development or
rezoning application is approved.
Local councils also have powers under the POEO Act to issue clean-
up notices to deal with pollution at sites for which they are the
appropriate regulatory authority. In addition, the Local Government
Act 1993 specifies that a charter of councils in NSW is to:
‘properly manage, develop, protect, restore, enhance and
conserve the environment of the area for which it is
responsible in a manner that is consistent with, and
promotes, the principles of ecologically sustainable
development’.

 NSW Health
Under the Public Health Act 1991, NSW Health has powers to close
any water supply, including a groundwater source, if a drinking
water source becomes unfit for human consumption or if the water
constitutes, or is likely to constitute, a risk to public health.

1.3.3 Existing guidance on groundwater

There are several guidelines that relate to groundwater protection
and assessment in NSW.
The key overarching policy, The NSW state groundwater policy
framework document (NSW Government 1997), outlines the roles
of the key NSW authorities in relation to groundwater, which are
summarised in 1.3.2.
The framework’s subordinate policy documents, including The NSW
state groundwater dependent ecosystems policy (NSW Government
2002) and The NSW groundwater quality protection policy (NSW
Government 1998) are also relevant.
The National environment protection (assessment of site contamination)
measure (NEPC1999) (the site contamination measure) is a broad
framework-setting statutory instrument that reflects agreed national
objectives and contains guidelines for assessing groundwater
contamination. The site contamination measure is implemented in
NSW in the form of guidelines approved under the CLM Act.
Schedule B(6) of the site contamination measure provides
a framework for a risk-based assessment of groundwater
contamination, including guidance on applying the National Water
Quality Management Strategy (NWQMS) criteria to groundwater.
Other documents belonging to the NWQMS are:
• the National water quality management strategy implementation
guidelines (ARMCANZ & ANZECC 1998), which include principles
outlining the need to develop a strong, growing and diverse
economy, that can enhance the capacity for environment
protection
• the Australian and New Zealand guidelines for fresh and marine
water quality (ANZECC & ARMCANZ 2000a), which identify generic
water quality criteria that protect environmental values from a
wide range of potential contaminants, as well as articulating a
process for undertaking site-specific assessments of water quality
to determine whether the water can sustain aquatic ecosystems.


 The ANZECC & ARMCANZ (2000a) guidelines also include a chapter
on drinking water, which refers to the Australian drinking water
guidelines (NHMRC & NRMMC 2004) for relevant guideline values.
The Guidelines for groundwater protection in Australia (ANZECC &
ARMCANZ 1995) provide a framework for protecting groundwater
from contamination. The document also defines beneficial uses of,
and values for, groundwater.

1.4 Importance of groundwater

Groundwater is important for the health, and in some areas the
economic wellbeing, of NSW’s community. It is used:
• as a source of domestic, recreational, rural and industrial water,
and, in some parts of NSW, as drinking water
• to irrigate gardens, parks, and playing fields in urban
environments, especially in recent times
• by the agricultural and industrial sectors to support food
production and other activities
• to help sustain life in streams and rivers
• to support fragile ecosystems such as wetlands in dry periods
(note that groundwater itself can be a valuable ecosystem).
Groundwater is also important because humans can be indirectly
exposed to groundwater contaminants. For example, the
consumption of vegetable crops irrigated with contaminated
groundwater or products from animals which drank contaminated
groundwater can constitute a human health risk. Also, volatile
contaminants in groundwater may accumulate in enclosed spaces
above a contaminant plume and then pose risks from inhalation or
explosion depending, for instance, on the type of the contaminants
and the severity of the contamination.

1.5 Definition of groundwater contamination

Contamination of land, which includes groundwater, is defined in the
CLM Act and the EP&A Act as:
‘the presence in, on or under the land of a substance at a
concentration above the concentration at which the substance
is normally present in, on or under (respectively) land in the
same locality, being a presence that presents risk of harm to
human health or any other aspect of the environment’.


 In practice, however, groundwater is considered to be contaminated
where any substance or waste has been added at above natural
background concentration, and represents, or potentially represents,
an adverse health or environmental impact. For the purpose of
these guidelines, any undesirable change in groundwater quality
constitutes an adverse environmental impact.
In relation to the POEO Act, these guidelines also refer to the term
‘pollution’. The dictionary of the POEO Act defines ‘pollution of
waters’ to include:
‘placing in or on, or otherwise introducing into or onto
waters (whether through an act or omission) any matter
whether solid, liquid or gaseous, so that the physical,
chemical or biological condition of the waters is changed’.


2 Assessing groundwater contamination
2.1 Introduction
Assessing groundwater contamination involves identifying risks
to human and ecological health, and providing the necessary
information to manage these risks. Generally, the risks are
unacceptable if groundwater quality has deteriorated to the
extent that it can no longer support relevant environmental values
including current and realistic future use and non-use values. While
the risk from groundwater contamination may be unacceptable
due to adverse effects of the contamination on the groundwater’s
environmental values, the level of risk to human and ecological
health will vary depending on site-specific conditions. More detailed
assessments of the risks posed by the groundwater contamination
may then be required to identify an appropriate management
response and evaluate the urgency of that response. Such a response
may require additional groundwater investigations aimed at
evaluating and selecting remedial technologies. Such investigations
are not covered by these guidelines, and relevant guidance should
be obtained from documents dealing with remedial technologies.
The following presents a framework for assessing risks from
groundwater contamination, taking into account the environmental
values of the groundwater. It recognises existing, nationally
developed approaches, policies and water quality criteria developed
to protect water under the National Water Quality Management
Strategy (NWQMS) and the numerical guideline criteria for the
protection of environmental values that have been presented
in NWQMS documents. For the purpose of these guidelines,
the NWQMS criteria are hereafter referred to as existing generic
groundwater investigation levels (GILs). Note, however, that in
addition to the existing generic criteria, GILs may also be derived on
a site-specific basis.
These guidelines adopt a tiered approach for the assessment
of groundwater contamination. They advise conducting both a
preliminary assessment (see 2.2) and a detailed assessment (see 2.3).
DEC may consider information obtained from these groundwater
assessments in deciding whether to regulate the management of
the contamination. Details about DEC regulation are presented in
Section 5.


 Assessments of groundwater contamination require:
• careful planning
• a detailed sampling and analysis plan
• the establishment of data quality objectives
• appropriate data quality assurance and quality control
procedures.
The data should be collected only by appropriately-trained
personnel and interpreted by competent professionals with
qualifications and experience relevant to assessing the presence,
extent and behaviour of contaminants in groundwater. A good
understanding of data uncertainty and temporal and spatial data
variability is important as may be knowledge about remedial
technologies. For detailed quantitative assessments, assessors
should have training in the risk-based assessment of groundwater
contamination and in modelling the transport of contaminants in
groundwater. While relevant sources of toxicity data are listed in
the site contamination measure and ecotoxicological information
is provided in ANZECC & ARMCANZ 2000a, specialised toxicological
advice may also be required.
These guidelines do not provide detailed technical advice on
assessing groundwater contamination. Such guidance is available
from other sources including guidelines in the References section.

2.2 Preliminary assessment

The potential for groundwater contamination due to, for instance,
current or previous activities at a site, or the confirmed presence of
contaminants in soil, should prompt a preliminary assessment of
groundwater contamination. The preliminary assessment should aim
to identify groundwater contamination and evaluate whether it may
pose a threat to human and ecological health. If a potential threat is
identified, the results of the preliminary assessment should assist in
planning a more detailed groundwater contamination assessment
(see 2.3)
The preliminary assessment of groundwater contamination begins
with investigating readily available information through a desktop
study, including:
• appraising the site history and identifying all past and present
contaminating activities and associated potential contaminants

10
• finding out available information about the local and regional
geology and hydrogeology, including identifying water-bearing
zones which may, for instance, include perched groundwater near
the surface, unconfined groundwater at shallow depth, and semi-
confined or confined groundwater at greater depth
• identifying aquifers and confining layers, and at least conducting
a basic assessment of expected hydraulic conductivities and
porosities
• investigating the groundwater flow domain, including the
expected elevation of the water table and any potentiometric
surfaces, lateral and vertical hydraulic gradients, likely flow
direction and flow velocity, sources of recharge, possible
discharge points and other hydraulic boundaries
• identifying potential receptors, including current and realistic
future water users, surface water bodies, groundwater-dependent
ecosystems and groundwater ecosystems, and vapour flux
receptors
• identifying the natural hydrogeochemistry of the groundwater
system, such as pH, redox potential, total dissolved solids, and
major anion and cation concentrations.
For the desktop study:
• relevant information on DEC’s public record of declarations and
orders under the CLM Act, and in the public register under the
POEO Act, as well as information from local councils and DNR
(e.g. in relation to known bore locations and beneficial uses)
should be obtained
• the NSW Natural Resource Atlas (visit www.nratlas.nsw.gov.au)
should be consulted, which includes relevant information such as
the locations of registered bores.
In addition to the desktop study, the preliminary assessment includes
intrusive investigations to identify the presence of contaminants and
enable likely maximum contaminant concentrations in groundwater
beneath a site to be compared with existing generic GILs (see 2.2.2).
Contamination is present if there is an undesirable change in the
natural background quality of the groundwater.
While the preliminary assessment may not reveal all the above
information, the information obtained must be sufficient to gain
a preliminary conceptual understanding of the hydrogeological

11
 regime and the risks associated with any potential contamination.
The preliminary assessment should also identify important data
gaps.

2.2.1 Determining natural background groundwater quality

If potential site contaminants, such as metal compounds and non-
metallic inorganics, are substances that might occur naturally at
the site, an evaluation of natural background groundwater quality
may be required to distinguish naturally occurring concentrations
of substances from anthropogenic contamination. Where
contamination has been identified, DNR should be informed about
all water quality data obtained during the investigation.
While it is not essential to determine natural background
concentrations, if the investigation does not uncover information
about natural background concentrations, it must be assumed,
for the purpose of the preliminary assessment that the detected
substances are not naturally occurring and constitute contamination.

2.2.2 Comparing contaminant concentrations against GILs

Following the identification of contamination and likely maximum
contaminant concentrations in groundwater at a site, these
concentrations must be compared against existing generic GILs, if
available, which protect the following environmental values:
• drinking water (see NHMRC & NRMMC 2004)
• aquatic ecosystems (see ANZECC & ARMCANZ 2000a).
For the protection of aquatic ecosystems, the GIL for 95% protection
should be used. If the concentration in groundwater exceeds a GIL
for any contaminant and there could be current or future exposure
to the contaminant (e.g. if the contamination may migrate off-
site or there are on-site potential human or ecological receptors
for the contaminant), the contamination may pose a threat to
human or ecological health and a more detailed assessment of the
groundwater contamination, as outlined in 2.3, will be required.
Because of the longevity of the contamination, a more detailed
assessment is always required if non-aqueous phase liquids such as
fuel are present in or on groundwater.
Regarding protection of aquatic ecosystems:
• where the existing generic GIL is below the naturally occurring
background concentration of a particular contaminant, the
background concentration becomes the default GIL

12
 • where the existing generic GIL for a particular contaminant is
below the practical limit of reporting or below the detection limit,
the quantitative limit of reporting or the detection limit should be
used instead of the existing generic GIL.
Where a generic GIL does not exist for a particular contaminant, DEC
should be contacted for advice. DEC should also be contacted if
the existing generic GILs for drinking water and aquatic ecosystem
protection are not considered stringent enough to protect ecological
and human health, given the potential exposure routes (e.g. dermal
contact in relation to some contaminants).

2.3 Detailed assessment

Contamination that may pose a threat to ecological or human health
requires more detailed assessment. The detailed assessment consists
of developing, and progressively improving, a conceptual site model
on the basis of the relationship between:
• sources of the contamination and release mechanisms
• the nature and extent of the contamination
• the dominant fate and transport characteristics of contaminants,
– a detailed appraisal may mean using analytical or numerical
solute fate and transport models – see 2.3.3
• potential receptors and exposure pathways.
In assessing potential receptors and exposure pathways, all relevant
environmental values, including those associated with current
and realistic future beneficial uses of the groundwater, need to be
accounted for (see 2.3.1).
Information on developing conceptual site models for contaminated
sites can be found in American Society for Testing and Materials
2003.
During the detailed assessment, uncertainties should be addressed
via further investigations. New findings should then be used to
validate and improve the conceptual site model in relation to,
for instance, an improved understanding of the extent of the
contamination, the fate of the contaminants, or the nature of the
water bearing zones and any potential receptors.
The assessment must provide enough information about the nature
and severity of the risks associated with the contamination to
develop meaningful conclusions about the need for, and the urgency

13
 of, management responses. The findings of the detailed assessment
should assist in identifying a management response that, at a
minimum, ensures that groundwater quality – when groundwater
comes to the surface from natural seepages or existing or potential
future bores – does not compromise relevant environmental values.
An exception to this is the protection of organisms in groundwater,
if applicable. Further information about the protection of such
organisms is included in Appendix 2.
Where the detailed assessment includes predictions of future
contaminant concentrations and concludes that these will not
compromise environmental values, appropriate groundwater
monitoring needs to be implemented to verify the predicted
concentrations. Also, contingency measures including triggers
for implementing these measures should be developed as the
groundwater monitoring may show that the prediction is invalid.

2.3.1 Protecting the groundwater’s environmental values

‘Environmental values’ are defined in ANZECC & ARMCANZ 2000a as:
‘particular values or uses of the environment that are
important for a healthy ecosystem or for public benefit,
welfare, safety or health which require protection from the
effects of pollution, waste discharges and deposits’.
To protect the groundwater’s environmental values, the current
and projected contaminant concentrations at the points of existing
and realistic future use may need to be estimated. If analytical
or numerical fate and transport models are used to estimate
contaminant concentrations over time at these points, the models
must be based on a valid conceptual site model.
The current and projected contaminant concentrations should then
be compared against GILs to determine if the relevant environmental
values may be adversely affected. The principle for determining the
appropriate GILs for the relevant environmental values is articulated
in The NSW groundwater quality protection policy (NSW Government
1998), which states that:
‘water quality objectives should always protect the
groundwater quality to a level that meets the most sensitive
end user’s requirements’.
All relevant environmental values should be considered, including
current and potential uses of the groundwater and ecosystems.

14
 The concept of environmental values recognises that the nearest
receptor of the groundwater may change as a result of development
occurring between the site and the receptor, i.e. there may be future
uses for the groundwater.
Schedule B(6) of the site contamination measure (NEPC 1999)
provides a methodology for using GILs to assess contaminated
groundwater. The following six environmental values are presented:
• aquatic ecosystems
• aquaculture and human consumers of food
• agricultural water
• recreation and aesthetics
• drinking water
• industrial water.
Details about how to identify environmental values are provided
in Appendix 2. For each environmental value, a set of generic GILs
is provided that defines acceptable water quality at the point of
use. For some environmental values, the existing generic GILs
are an adequate guide to the water quality required to protect
environmental values, such as drinking water criteria at the point
where the groundwater is used for drinking. For other environmental
values or for a point of groundwater extraction where groundwater
is not used, exceeding GILs may trigger further investigation.
As GILs protect relevant environmental values, groundwater quality
that meets the GILs does not generally pose unacceptable risks.
If the groundwater quality does not meet the relevant GILs, the
groundwater may not be safe for the environmental values and
action would have to be undertaken to more accurately determine
whether the groundwater is safe or to resolve the problem.

2.3.2 Site-specific risk assessment

Generic GILs do not exist for all contaminants or exposure scenarios
(e.g. the protection of human health from the inhalation of volatile
contaminants). If there is no generic GIL, relevant criteria from
overseas or GILs developed from a site-specific risk assessment may
be used. Such GILs may also be used if contaminant concentrations
exceed an existing generic GIL at a point where groundwater is not
used and is not likely to be used in the future.

15
 Any detailed (e.g. quantitative) assessment of risks posed by
groundwater contamination requires a thorough understanding of
all relevant aspects. Of particular importance are aspects relating
to sampling methods, the fate and transport of contaminants
in groundwater, spatial and temporal data variability, and data
uncertainty. Particularly where groundwater contamination may
already affect a receptor such as an aquatic ecosystem, other
specialist advice, for instance, ecotoxicological advice, may be
needed.
Any site-specific assessment of risks must follow the risk-assessment
guidance in the site contamination measure (NEPC 1999). In a site-
specific risk-based assessment, the following may also need to be
considered as they present additional information:
• for assessing human health risks, Department of Health and
Aging & EnHealth 2002
• for assessing risks to aquatic ecosystems, ANZECC & ARMCANZ
2000a.
Whenever criteria from overseas or site-specific risk-based criteria
are used, agreement from DEC should be obtained. The study results
plus the accompanying analysis should be provided to DEC for
review and, if appropriate, endorsement of the criteria for use at the
site in question.
In the context of site-specific risk assessment, risk perception
may influence the type or level of risk considered ’acceptable‘.
The perception of risk may not be the same as the level of risk
assumed by those undertaking the study. Also, where there is
significant uncertainty about the risks associated with exposure to
groundwater contamination, measures to prevent exposure should
be implemented before resolving complex aspects of risk.

2.3.3 Contaminant fate and transport modelling

Contamination assessment commonly incorporates contaminant
fate and transport predictions, including analytical and numerical
mathematical modelling. Such modelling can be used to:
• assist in validating the conceptual site model and identifying
important data gaps
• predict the travel times of contaminants from the point of
groundwater extraction to a point of groundwater use

16
• predict contaminant concentrations, mass fluxes, and exposure
doses
• assess the impact of assumptions and uncertainty in parameter
values on the predictions
• assist in selecting a management strategy and demonstrating its
effectiveness
• assist in remedial design.
Contaminant fate and transport modelling will often be necessary
to assess the likely effectiveness of natural attenuation in achieving
remedial goals and demonstrating remedial progress and success.
Where fate and transport modelling is undertaken for predictive
purposes (e.g. for a risk assessment), the model must be based on a
valid conceptual site model and the information obtained from the
modelling study must adequately assist in making decisions about
the action needed to address groundwater contamination.
Modelling the fate and transport of groundwater contaminants is a
complex task. In all cases:
• modelling should only be undertaken by appropriately qualified
professionals experienced in groundwater contamination
• the model used must reflect best industry practice, and the
proponent must clearly demonstrate the applicability and
adequacy of the model for a specific site and modelling objective
• model assumptions and parameter values must be appropriately
conservative and the associated report must clearly explain the
validity of all assumptions made and all input parameter values
selected.
The degree of conservatism required in the model will depend on
various factors. Generally, the level of conservatism can be reduced
by improved site characterisation, adequate model calibration and
sensitivity analyses.
While contaminant migration in groundwater occurs in three
dimensions, not all dimensions need to be incorporated into the
mathematical model, depending on the objective of the modelling
study and the degree of conservatism that is employed.
Some guidance on fate and transport modelling is provided in
Schedule B(2) of the site contamination measure (NEPC 1999).

17
2.3.4 Additional aspects to consider
Although a wide range of analytical and numerical modelling tools
and visualisation aids is now available to assist in the assessment of
groundwater contamination, professionals using these tools must
have considerable knowledge of relevant processes combined with
analytical skills and professional judgement.
Among other aspects, the following issues should be taken into
account in planning investigations into groundwater contamination:
• Appropriately qualified and experienced groundwater
professionals must plan and implement a suitable groundwater
investigation.
• Schedule B(2) of the site contamination measure (NEPC 1999) and
the Australian guidelines for water quality monitoring and reporting
(ANZECC & ARMCANZ 2000b) should be considered.
• Data quality objectives, for instance as per the Guidelines for the
NSW site auditor scheme (second edition) (DEC 2006), should be
defined before the investigation.
• The existence of groundwater has to be acknowledged at
every potentially contaminated site. If there is the potential for
groundwater contamination, intrusive groundwater investigations
should generally be carried out unless groundwater is present at
greater depth (e.g. more than 15 m below the ground surface), in
which case the risks to potential receptors should be considered
in assessing the need for intrusive investigations. Intrusive
investigations at greater depth may not be required where the
natural background quality of the groundwater is poor and
the groundwater yield is low. In any case, advice from relevant
agencies should be obtained if intrusive investigations are
considered unwarranted.
• Groundwater investigations at a source site require careful
planning and execution to avoid groundwater contamination as
a result of bore construction. Under certain circumstances (e.g.
contamination with dense non-aqueous phase liquid (DNAPL)),
observation bores may need to be installed away from suspected
source areas.
• The complexity of the groundwater system, which may include
perched groundwater near the surface, an unconfined aquifer at
shallow depth and semi-confined or confined aquifers at greater
depths, needs to be considered.

18
• Different water-bearing zones at a site may have different
attributes, such as permeability and yield, and different
environmental values.
• Properly constructed groundwater monitoring wells are essential.
Aquifer interconnection and cross-contamination must be
avoided. Guidance on construction and use of monitoring wells
is provided in Minimum construction requirements for water bores
in Australia (LWBC 2003) and in Groundwater sampling guidelines
(EPA Victoria 2000).
• Many methods are available for obtaining groundwater samples
from monitoring wells. Depending on the conditions (e.g.
chemicals of concern, geology), some give more reliable results
than others. It is important to select the most appropriate
sampling technique for a particular well and contaminant suite,
taking account of modern sampling methods. In this context, the
Groundwater sampling guidelines (EPA Victoria 2000) should be
considered.
• The collection of groundwater samples from pits is subject to
potential interference, including gas exchange and mixing during
pit excavation and high suspended solid loads. Although useful
qualitative indications may often be obtained from such samples,
they should not be included in the same data set as samples from
monitoring wells.
• The Australian Standard AS2368 (Standards Australia 1990) Test
pumping of water wells should be considered in the context of
assessing hydraulic properties of aquifers.
• Appropriate licences/consent for groundwater bores must be
obtained from DNR.
• Extracted groundwater must be disposed of in accordance
with the POEO Act and the trade wastes agreement with the
appropriate water authority. Off-site disposal must consider
the Environmental guidelines: assessment, classification and
management of liquid and non-liquid wastes (NSW EPA 1999).
• Groundwater investigations must consider that groundwater flow
and contaminant transport occur in three dimensions. Generally,
observation wells should be designed to sample discrete,
relatively short, vertical intervals targeting a depth of sampling
based on expected concentration profiles and relevant exposure
scenarios.

19
 • Geophysical techniques that may contribute to valuable
information about the contaminant plume should be considered.
• Both natural and emplaced ground materials are heterogeneous.
The potential presence of preferred pathways should always
be considered when designing a groundwater monitoring well
network.
• Off-site groundwater investigations will generally be required to
delineate a contaminant plume. Such investigations may also be
important to gain evidence that the site under investigation is not
the source site.
• The effect of groundwater recharge on the depth of contaminant
plumes must be considered in deciding on sampling depths.
• Information in the Groundwater management handbook
(Sydney Coastal Councils Group 2006) should be considered
as the handbook contains relevant details on, for instance,
decommissioning bores.

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3 Managing groundwater contamination
3.1 Introduction
In these guidelines, the term ‘management’ covers all measures
taken to address groundwater contamination, including measures to
mitigate risks from the contamination. Measures may include, but are
not limited to:
• notifying DEC, DNR, NSW Health, local councils, affected property
owners, groundwater users, owners of subsurface utilities
and others, as appropriate, of the presence of groundwater
contamination
• plume containment
• active or passive clean-up of contaminated groundwater
• ongoing monitoring of groundwater, and contingency plans
• implementing groundwater management plans to mitigate risks
• restricting groundwater use in, and down-gradient of, the
contaminant plume.
Managing groundwater contamination, for instance, to protect town
water supply wells may also include implementing strategies such
as wellhead protection plans to prevent groundwater in areas that
supply water to a public well from becoming contaminated. More
details about wellhead protection plans can be found in The NSW
groundwater quality protection policy (NSW Government 1998).
The most appropriate management strategy for a particular site
where groundwater is contaminated will depend on a range of
factors including the nature and extent of contamination, the
severity of the contamination, the availability of practical remedial
options, and community expectations. Public involvement is
important in identifying appropriate management responses.
In this context, the Guidelines for groundwater protection in
Australia (ANZECC & ARMCANZ 1995) and Schedule B(8) of the site
contamination measure (NEPC 1999) should be considered.
The following sections discuss ways of determining an appropriate
management strategy. Note that the issues discussed in these
sections are relevant to the management of contaminated
groundwater irrespective of whether the contamination is managed
under the CLM Act.

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3.2 Management responses to contamination
While prevention of groundwater contamination is a key principle,
contamination of groundwater is in many cases a legacy of past
practices. Where contamination is identified, the management
objectives are to protect human and ecological health and to
ultimately restore the groundwater to its natural background quality.
To achieve these objectives, the following management responses
must be considered:
• control short-term threats arising from the contamination (see
3.3)
• restrict groundwater use (see 3.4)
• prevent or minimise further migration of contaminants from
source materials to groundwater (see 3.5)
• prevent or minimise further migration of the contaminant plume
(see 3.6)
• clean up groundwater to protect human and ecological
health, restore the capacity of the groundwater to support the
relevant environmental values and, as far as practicable, return
groundwater quality to its natural background quality (see
Section 4).
As a minimum, management of contaminated groundwater should
continue until human and ecological health is protected and the
capacity of the groundwater to support relevant environmental
values is restored.
Management responses to groundwater contamination should focus
on the greatest threats first, and the benefits of groundwater clean-
up must outweigh any incidental negative impacts that could arise.

3.3 Controlling short-term threats

Immediate action is required where short-term threats, that is, acute
risks, are identified. Such risks include the accumulation of explosive
vapours in underground utilities, or unacceptable risks to human or
ecological health from short-term exposures to contamination.
As an example of the type of management response that may be
required, DNR may impose a ban on the extraction of groundwater
from bores to prevent exposure to contaminants. In certain
circumstances, NSW Health also has powers to restrict the use of
groundwater in NSW.

22
3.4 Restricting groundwater use
In some circumstances, the use of contaminated groundwater both
on- and off-site may need to be restricted.
DNR is the lead agency for managing groundwater use in NSW.
DNR also determines whether use restrictions are necessary where
contamination precludes the safe use of groundwater. Liaison with
DNR is essential if groundwater use restrictions are considered
necessary.
In specific cases, DNR may restrict groundwater use near a
contaminated site to prevent exposure while groundwater
remediation occurs. This type of institutional control may be
necessary, for example, where a site is implementing a long-term
groundwater remedy. In general, use restriction, other than as an
emergency response to reduce risks, would only be supported
where:
• the sources of contamination have been controlled
• the existing boundaries of the contaminant plume have been
identified
• the groundwater contamination is being cleaned up or has been
cleaned up consistent with DEC’s requirements
• there is an acknowledgement from the party responsible for the
remediation of its obligations to protect human and ecological
health, and a commitment that groundwater management
actions will continue until the groundwater quality protects
relevant environmental values
• the groundwater management plan, including provisions for
the regular reporting of ongoing groundwater quality, has been
documented and provided to DNR.
Restricting access to groundwater will not be considered an
appropriate management strategy in isolation unless there are no
other remediation options available.
Where groundwater use is restricted because of contamination, DEC
or DNR may require the party responsible for the contamination
to undertake some actions to support the use restrictions. These
could include, for instance, the development and implementation
of a communication strategy to inform the community about
groundwater contamination or ongoing bore sampling in the area of
the contaminant plume.

23
 In any case, the fact that the use of groundwater is restricted should
not be be used to argue the case for lower clean-up standards,
although the timeframe to achieve the clean-up may be affected.

3.5 Source control

The elimination or control of all known and suspected sources
of groundwater contamination is important. A source is any
material that acts as a reservoir for the continued contamination
of groundwater. Sources of ongoing groundwater contamination
include primary sources, such as leaking chemical storage tanks, and
secondary sources, such as separate phase liquids in groundwater
and overlying soils.
Source control refers to a range of actions, including removal,
treatment in place, and containment, which are designed to
minimise migration of contaminants into groundwater. Source
control is important because minimising further contaminant
releases to the environment is often required for the successful
management of a contaminant plume. Sources of groundwater
contamination also need to be addressed because it is an offence
under the POEO Act to pollute groundwater.
Source control actions should be undertaken early in the assessment
and management process. In particular:
• Leaking underground tanks must be repaired or replaced in
accordance with appropriate standards such as The design,
installation and operation of underground petroleum storage
systems (Australian Institute of Petroleum 2002) as soon as a leak is
confirmed, and further investigations must determine the extent,
if any, of contamination of soils and groundwater.
• Non-aqueous phase liquids must be cleaned up to the extent
practicable – see 3.5.1.
• Contaminated soils need remediating so they no longer pose
a potential risk to groundwater quality. This may require the
development of soil criteria that take into account the leaching
potential of contaminants from soil into groundwater. Note that
the health-based soil investigation levels adopted in Guidelines
for the site auditor scheme (DEC 2006) and the site contamination
measure (NEPC 1999) do not take groundwater protection into
account.

24
 Where complete source removal or treatment is not possible:
• the remaining source should be contained for the entire time that
it is present in the groundwater
• any source containment will generally need to be supported by
ongoing groundwater quality monitoring.
Source containment as part of a long-term management response
will generally only be appropriate where there are significant
difficulties in removing or treating the contamination, for instance
where:
• treatment technologies are not available or treatment is not
technically feasible
• the volume of materials or complexity of the site make source
removal or treatment impracticable
• removing or treating the source would have unavoidable severe
adverse effects on other aspects of the environment.

3.5.1 Non-aqueous phase liquids

Non-aqueous phase liquids (NAPLs) in the subsurface provide
an ongoing source of contamination. NAPLs that are in contact
with groundwater constitute groundwater contamination. Where
light NAPLs (LNAPLs) or dense NAPLs (DNAPLs) are present in the
subsurface, they must be removed or treated as much as practicable.
Particular care, however, is required in the assessment and clean-up
of DNAPL contamination to prevent mobilisation or an increased rate
of dissolution.
Where complete removal or treatment of the NAPL is impracticable,
as may be the case with some DNAPLs in complex geological
media, ongoing monitoring and management of the contamination
is required as a minimum for as long as necessary, to ensure the
protection of human and ecological health. Sources and plumes
will need to be contained to the maximum extent practicable, and
remediation to address the dissolved-phase contaminants may also
be required.
A strategy for controlling NAPL contamination should have the
following objectives:
• to ensure the protection of human and ecological health
• to control further migration of contaminants from subsurface
NAPLs to the surrounding groundwater (source control)

25
 • to reduce NAPL mass to the extent practicable (source removal or
treatment).
It is recognised that clean-up of NAPL contamination can be difficult.
For instance, there can be high costs and uncertain benefits in
aggressive source zone treatment of some NAPLs. Therefore, the
remedial objective for some sites with recalcitrant sources of NAPL
may be to contain the source material and prevent or minimise
further contaminant migration. Nonetheless, presumptions about
the practicability of source zone remediation must keep pace with
emergent technology; it should not automatically be assumed that
source zone remediation is not feasible.
Any assessment that source removal of NAPL contaminants is
impracticable should be clearly documented.

3.6 Plume containment

In responding to groundwater contamination, one goal is to contain
the extent of the contaminant plume, that is, to prevent or minimise
further plume migration while other management actions are
taking place. Plume containment, as the sole long-term response
to groundwater contamination, is generally only acceptable when
cleaning up contaminated groundwater is not practicable.
Proponents of long-term containment must demonstrate they
have adequately considered all risks posed by the groundwater
contamination. Systems must be developed to monitor the
effectiveness of the containment in the long term, and contingency
plans must be developed if monitoring data shows that the
containment is not effective. In this context, the responsibilities for,
and resourcing of, long-term management and contingency plans
need to be addressed.

3.7 Clean-up of contaminated groundwater

Clean-up is an important part of managing groundwater
contamination. Section 4 provides in-depth information on
objectives and procedures for cleaning up contaminated
groundwater, and should be read in conjunction with this section.

26
4 Cleaning up contaminated groundwater
This section should be read in conjunction with Section 3 as clean-up
is an important part of managing contaminated groundwater, and
material in Section 3 will also be relevant for this section. Discussion
of clean-up has been separated from Section 3 for ease of readability.
Clean-up objectives for contaminated groundwater should be
established in the following preferential order:
1 Clean up so natural background water quality is restored.
2 Clean up to protect the relevant environmental values of
groundwater, and human and ecological health.
3 Clean up to the extent practicable.
This hierarchy is discussed below.

4.1 Clean up so natural background water quality is restored

Ideally, contaminated groundwater should be restored as much
as practicable to its natural background quality. This is particularly
important for pristine or near-pristine groundwater systems of high
yield.
In practice, cleaning up so natural background concentrations are
restored can be technically difficult and extremely costly. Therefore,
where it is not practicable to restore background quality, an interim
clean-up goal can be based on protecting environmental values and
preventing potential risks to human and ecological health.
Even where it is not practicable in the short term, restoring water
quality to its natural background state should remain the long-term
remedial objective for contaminated groundwater. In this context,
the use of monitored natural attenuation should be considered.

4.1.1 Monitored natural attenuation

Natural attenuation of contaminants in groundwater may be defined
as the:
‘effect of naturally occurring physical, chemical and
biological processes to reduce the load, concentration, flux
or toxicity of polluting substances in groundwater’ (UK
Environment Agency 2000).

27
 These processes include biodegradation, dispersion, diffusion,
sorption, volatilisation, and chemical or biological stabilisation,
transformation or destruction.
Monitored natural attenuation (MNA) can also be part of a strategy
for managing risks from contaminated groundwater. However, a
detailed evaluation of the contamination, the aquifer characteristics
and potential risks is necessary to confirm that MNA should be part
of the management strategy.
A proposal for MNA must include clear evidence demonstrating that:
• significant attenuation of contaminants is occurring
• remedial goals can be met in an adequate timeframe
• the proposed monitoring program is suitable.
For DEC to accept MNA as a suitable approach at a site, natural
attenuation processes that reduce the mass of dissolved
contaminants (e.g. biodegradation) will generally need to be clearly
demonstrated.
Appendix 3 presents more detailed guidance on the appropriate
evaluation and implementation of MNA for use in NSW.

4.2 Clean up to protect the relevant environmental values of

groundwater, and human and ecological health
Where the clean-up goal is to protect the environmental values of
groundwater, and human and ecological health, numerical clean-
up criteria may need to be used to measure the success of remedial
actions.
Clean-up criteria at the point of use must employ relevant existing
generic GILs or GILs derived on a site-specific basis. At the point of
extraction, site-specific clean-up criteria may be derived that protect
the applicable environmental values, and human and ecological
health, at the point of use. Where numerical clean-up criteria for
either the point of use or the point of extraction are proposed, based
on a site-specific assessment of risks, the criteria must be derived
through comprehensive evaluation of all actual and potential
exposure pathways.
The site-specific use of clean-up criteria must take into account
schedules B(4) and B(5) of the site contamination measure (NEPC
1999). Clean-up criteria derived for the point of use which are

28
 considered to be protective of aquatic ecosystems may also need to
consider the process outlined in ANZECC & ARMCANZ 2000a. DEC
should be consulted if site-specific risk-based criteria are used.

4.3 Clean up to the extent practicable

Where DEC has decided to regulate the management of
contaminated groundwater under Part 3 of the CLM Act, DEC must
be satisfied with any remediation plan or proposal for a voluntary
remediation agreement. In this context, DEC will consider what
is practicable and may seek independent expert verification of
any supporting claims. In some cases, it may not be practicable
to continue cleaning up the groundwater to the point where all
its environmental values are restored. In such instances, when
regulating the remediation, DEC may consider proposed interim
clean-up goals in consultation with stakeholders.

4.3.1 Demonstrating restoring environmental values is impracticable

If a proponent considers that clean-up to restore the protection of
environmental values is impracticable in the future, this must be
clearly demonstrated to DEC. The evaluation of practicability should
be documented against each factor listed below:
• technical capability to achieve the clean-up
• clean-up costs
• the value of the groundwater resource
• threats the contamination poses to human or ecological health.
Proposed clean-up measures should correlate with the value of
the groundwater resource and the severity of the contamination.
Further, any proposal for the clean-up that argues impracticability
must include an acknowledgement that the long-term objective
is to restore the protection of all relevant environmental values,
and ultimately achieve natural background quality. In such cases,
ongoing management and monitoring of the groundwater may be
required to ensure the protection of human and ecological health.
In considering the nature of the remediation required for a site,
DEC may consider what actions are practicable. If it is impracticable
to clean up groundwater to a concentration needed to restore the
protection of environmental values, DEC may accept that clean-up to
the extent practicable has occurred and that, subject to appropriate
ongoing management of exposures to the contaminants and
periodic review, further clean-up is not required. However, acute risks

29
 from the contamination, such as risks from short-term exposure or a
risk of explosion from the accumulation of vapours, must be resolved
without delay.
In all cases where clean-up to restore environmental values cannot
be achieved:
• it is still necessary to clean up to the extent practicable, to
minimise the impact on environmental values
• human and ecological health must be protected
• plume containment should be implemented to prevent the
plume from spreading
• ongoing groundwater monitoring may be required
• the possibility of cleaning up the groundwater contamination
should be periodically reassessed to account for emerging
technologies
• provisions are required for long-term resourcing and
responsibility for any ongoing management strategy
• information must be recorded and disseminated.
In considering the practicability of cleaning up the groundwater
contamination, DEC will take into account technical, logistical and
financial considerations.
Before DEC agrees to the proposal, it may seek input from DNR on
the current and realistic future uses of the groundwater and the
implications that residual contamination may have for groundwater
resource management. DNR would consider the information
provided in a groundwater management plan where long-term
restrictions on groundwater use are required.
Where DEC agrees that clean-up to the extent practicable has
occurred, this does not remove the proponent’s responsibility
for ongoing management of the residual contamination. The
remediation proposal should be accompanied by:
• a commitment to ongoing monitoring and re-evaluation of the
practicability of clean-up. A satisfactory monitoring and reporting
program must be implemented to continually evaluate the
contamination.
• a groundwater management plan (GMP) that specifies measures
which will be implemented to mitigate risks to human and
ecological health (see 5.3.2).

30
 • acknowledgement that future management including clean-
up action may be required by the government to ensure the
protection of human and ecological health.
• provision for long-term resourcing and responsibility for any
ongoing management strategy.
Any ongoing management actions may be enforceable through
statutory means such as a regulatory instrument issued under the
CLM or POEO Act.

4.4 Clean-up impacts

The benefits from undertaking groundwater clean-up must
outweigh any incidental negative impacts to human health or the
environment that could arise from the clean-up.
Groundwater remediation technologies that involve discharge to
surface water, land or air must not pollute the receiving environment.
Remediation incorporating discharge to groundwater must not
cause unacceptable contamination, such as an adverse impact on
environmental values, from the uncontrolled presence of treatment
products or compounds derived from contaminant degradation.
Where it is proposed to add any substance to groundwater for
treatment purposes, such as chemical or biological agents to help
the contaminants degrade, the proponent must ensure that all
necessary approvals and licences have been obtained.

4.5 Clean-up timeframe

The clean-up of groundwater contamination should occur in a
timeframe that is commensurate with technical difficulties and
potential risks.
Where remediation is being managed under the CLM Act, DEC will
set appropriate clean-up timeframes.
Unacceptable exposures to contaminants must be addressed as
a priority. If receptors are already being exposed to potentially
unacceptable concentrations of contaminants in groundwater,
directly or indirectly (e.g. contaminants emitted from groundwater to
indoor air), action must be taken as soon as possible to prevent these
exposures.
Examples of factors that should be taken into account when
developing clean-up timeframes for a specific site include:

31
 • the risks from exposure to contamination
• the relevant environmental values which may be affected
• the source, nature and extent of contamination
• hydrogeological conditions
• the reliability of interim exposure controls
• the availability and effectiveness of suitable clean-up
technologies and disposal options
• community preferences
• the financial resources of the party responsible for clean-up
• intergenerational equity.
When evaluating remedial options, those that achieve the desired
clean-up goals in the shortest timeframe should be preferred.
Uncertainties associated with cleaning up groundwater may make
it difficult to exactly specify when a remedial strategy will achieve
the clean-up goals. It is not always possible to predict how long it
will take to return groundwater quality to a state that protects the
relevant environmental values because of complexities associated
with, for example, specific contaminant types and contaminant
interactions, hydrogeological characteristics and technology
limitations. Nonetheless, predicting clean-up timeframes is valuable
in evaluating and selecting the preferred remediation options.
Longer timeframes for cleaning up groundwater contamination may
be acceptable when there are adequate monitoring and reliable
controls to protect human and ecological health, and the plume has
been appropriately contained.

4.6 Degraded local groundwater quality

In some cases, the extent to which the groundwater can be cleaned
up may be limited by the presence of contamination from other
sources, such as contaminant releases from other sites that are
hydraulically up-gradient of the subject site.
Where elevated concentrations of contaminants in groundwater are
identified entering a site, DEC should be contacted to discuss what
implications these may have for clean-up strategies.
The local groundwater may also be degraded due to naturally
occurring substances. The local council and DNR may need to be

32
 informed in such cases because unacceptable human health and
ecological risks may be associated with these substances.
Pollution prevention remains of paramount importance. Where less
stringent clean-up is justified in the interim to deal with degraded
local groundwater quality, this does not diminish the need to
prevent further contamination.

4.7 Environmental monitoring

Environmental monitoring and reporting are often needed to assess
whether management actions at a particular site are achieving, or
moving towards, the clean-up goals. Environmental monitoring is a
key component of any remediation strategy, and is also implemented
through an ongoing management strategy if residual contamination
remains at a site after remedial works have ceased.
Monitoring groundwater is not a management response in isolation
but is needed to supplement other management actions.
Monitoring strategies should articulate:
• appropriate monitoring locations and depths within and down-
gradient of the contaminant plume
• the relevant assessment criteria to be used in evaluating
monitoring results
• the frequency of monitoring and reporting
• the process for reviewing monitoring data and ways in which
the data will feed into decisions about the contamination and
management strategy
• the length of time for which monitoring is expected to continue
(generally, monitoring should continue while there is residual
groundwater contamination)
• the regulatory authorities involved (including state and local
government) and the management inputs required from each.

4.8 Groundwater management plans

A groundwater management plan (GMP) provides a mechanism
for managing risks from potential exposure to contaminants in
groundwater. For instance, where skin contact with contaminated
groundwater is possible, a GMP can outline procedures that protect
people who could come into contact with groundwater, such as
workers undertaking excavations below the water table. GMPs

33
 should be tied to a regulatory framework to ensure that they are
appropriately implemented and enforced.
A GMP should include a contingency plan which will need to state
clearly what the objectives of the plan are, what circumstances
will trigger clean-up actions, and who will be responsible for its
implementation.

4.8.1 Regulatory controls for ongoing management of groundwater

contamination
Where ongoing management of groundwater contamination is
proposed at a regulated site:
• The management plan should be reasonably enforceable
(e.g. via a regulatory instrument issued under the CLM Act or
development consent conditions issued by the relevant planning
authority). The management plan should include well-defined
reporting arrangements to local or state authorities as applicable.
• There should be appropriate public notification of the restrictions
applying to the land to ensure that potential purchasers or other
interested parties are aware of the restrictions, for example,
appropriate notations on a planning certificate issued under
section 149(2) of the Environmental Planning and Assessment Act
1979 or a covenant registered on the title to land under section
88B of the Conveyancing Act 1919.
• There should be a clear delineation of monitoring and reporting
responsibilities.
• The party responsible for the contamination (i.e. the polluter
or current owner or other parties as per the CLM Act) would
normally be responsible for implementing and maintaining all
necessary ongoing management.

34
5 Regulation
5.1 Regulation under the CLM Act
Owners of contaminated sites and parties who caused
contamination must notify DEC under the CLM Act. Once DEC
is notified of contamination, it will review relevant information
to determine whether the assessment and management of the
contamination warrants regulatory control under the CLM Act. At the
time of writing, the CLM Act is under review and amendments to the
Act, including amendments to the notification requirements, have
been proposed.
On the basis of this information, DEC may require further
investigation, clean-up, or another appropriate management
response. If there is no acceptable voluntary proposal to carry
out the required works, DEC may require the ’appropriate person‘
(as defined in the CLM Act), or a public authority that is not an
’appropriate person‘, to carry out the works in accordance with the
CLM Act.
The cost of investigation or remediation carried out under the CLM
Act can be recovered in court from the people who were responsible
for the contamination. Management under the CLM Act also ensures
that the assessment and management process is transparent so the
affected or interested community is kept informed.
Involvement by DEC can be initiated at any stage during the
assessment or management of contaminated groundwater. The
possibility of future involvement by DEC does not prevent a party
from undertaking the investigations outlined in Section 2. When
contaminated groundwater is being managed under the CLM
Act, DEC may require a person responsible for managing the
contamination, such as the polluter or site owner, to notify DNR of
the contamination. DNR may use and make this information available
as it sees fit for groundwater resource management, which may
include implementing necessary use restrictions. The appropriate
persons may also be required to notify other affected parties
including the local community where, for instance, groundwater
uses are precluded by contamination.

5.2 Regulation under the POEO Act

Prevention of groundwater pollution is a key factor. Pollution of
groundwater is an offence under the POEO Act and prosecution for
offences against the provisions of the Act can result in significant
35
 fines. If an appropriate regulatory authority reasonably suspects that
a pollution incident has occurred or is occurring, they can also direct
the occupier of a premises or person causing the pollution to take
clean-up action. DEC will be the appropriate regulatory authority for
activities licensed under the POEO Act.

5.3 Requirements under SEPP 55

State environmental planning policy no. 55 – Remediation of land (SEPP
55) contains requirements for remediating contamination, including
groundwater contamination.
In summary, SEPP 55:
• requires planning authorities to consider, when considering a
rezoning application, whether the land is contaminated. If the
land is contaminated, the planning authority must be satisfied
that it is suitable in its contaminated state, or will be suitable after
remediation, for the purposes for which the land will be rezoned.
If the land requires remediation before use for a particular
purpose, the planning authority must be satisfied the land will be
so remediated before being used for that particular purpose.
• provides that a consent authority must not agree to the carrying
out of any development unless it has considered whether the
land is contaminated. If the land is contaminated, the consent
authority must be satisfied that it is suitable in its contaminated
state, or will be suitable after remediation, for the purposes for
which the development is proposed to be carried out. If the
land requires remediation before use for a particular purpose,
the consent authority must be satisfied it will be so remediated
before being used for that particular purpose.
• provides that, before determining an application for rezoning
or development consent for certain classes of land, a planning
authority/consent authority must consider a report on the
findings of a preliminary investigation carried out in accordance
with contaminated land management guidelines.
• makes remediation permissible across NSW despite any provision
of an environmental planning instrument to the contrary,
although in some cases only with consent.
• requires all remediation to comply with certain standards and
guidelines including guidelines in force under the CLM Act.

36
6 References
American Society for Testing and Materials 2003, Guide for developing
conceptual site models for contaminated sites, ASTM E1689-95e1
ANZECC & ARMCANZ 2000a, Australian and New Zealand
guidelines for fresh and marine water quality, National Water Quality
Management Strategy, Paper No. 4, Commonwealth of Australia,
www.mincos.gov.au/pub_anzwq.html
ANZECC & ARMCANZ 2000b, Australian guidelines for water quality
monitoring and reporting, National Water Quality Management
Strategy, Paper No. 7, Commonwealth of Australia, www.mincos.gov.
au/pub_agwq.html
ARMCANZ & ANZECC 1998, National water quality management
strategy implementation guidelines, National Water Quality
Management Strategy, Commonwealth of Australia, www.mincos.
gov.au/pdf/nwqms/implementationguidelines.pdf
ANZECC & ARMCANZ 1995, Guidelines for groundwater protection
in Australia, National Water Quality Management Strategy,
Commonwealth of Australia, www.mincos.gov.au/pdf/nwqms/
guidelines-for-groundwater-protection.pdf
Australian Institute of Petroleum 2002, The design, installation and
operation of underground petroleum storage systems
Danielopol DL, Griebler C, Gunatilaka A & Notenboom J 2003,
‘Present state and prospects for groundwater ecosystems’, in
Environmental Conservation 30, pp 104–130
DEC 2006, Guidelines for the NSW site auditor scheme, 2nd edition,
Department of Environment and Conservation NSW, www.
environment.nsw.gov.au/resources/auditorglines06121.pdf
Department of Health and Ageing & EnHealth 2002, Environmental
health risk assessment: Guidelines for assessing human health risks from
environmental hazards, Commonwealth of Australia, www.health.gov.
au/internet/wcms/Publishing.nsf/Content/health-pubhlth-publicat-
document-metadata-env_hra.htm/$FILE/env_hra.pdf
EPA Victoria 2000, Groundwater sampling guidelines,
Publication 669, http://epanote2.epa. vic.gov.au/EPA/
publications.nsf/2f1c2625731746aa4a256ce90001cbb5/
6bc0feabe895bc044a25670f00215055

37
 Hancock PJ, Boulton AJ and Humphreys WF 2005, ‘Aquifers
and hyporheic zones: Towards an ecological understanding of
groundwater’, Hydrogeology 13, pp 98–111
LWBC 2003, Minimum construction requirements for water bores
in Australia, Edition 2, revised September 2003, Land and Water
Biodiversity Committee, Commonwealth of Australia, www.nrme.qld.
gov.au/water/pdf/bore_aust/mcrwba.pdf
NEPC 1999, National environment protection (assessment of site
contamination) measure 1999, (site contamination measure), National
Environment Protection Council, www.ephc.gov.au/nepms/cs/con_
sites.html
NHMRC & NRMMC 2004, Australian drinking water guidelines, www.
nhmrc.gov.au/publications/_files/awgfull.pdf
NSW DUAP & NSW EPA 1998, Managing land contamination: Planning
guidelines, SEPP 55 – remediation of land, NSW Department of Urban
Affairs and Planning and NSW Environment Protection Authority,
www.epa.nsw.gov.au/resources/gu_contam.pdf
NSW EPA 1999, Environmental guidelines: assessment, classification
and management of liquid and non-liquid wastes, NSW Environment
Protection Authority, www.environment.nsw.gov.au/resources/
waste_guide.pdf
NSW Government 2006, Environmental objectives for water quality and
river flow, www.environment.nsw.gov.au/ieo
NSW Government 2002, The NSW state groundwater dependent
ecosystems policy, NSW Department of Land and Water Conservation,
www.dlwc.nsw.gov.au/care/water/wr/pdfs/ policy_180602.pdf
NSW Government 1998, The NSW groundwater quality protection
policy, NSW Department of Land and Water Conservation, www.dlwc.
nsw.gov.au/care/water/wr/pdfs/quality_policy.pdf
NSW Government 1997, The NSW state groundwater policy framework
document, NSW Department of Land and Water Conservation, www.
dlwc.nsw.gov.au/care/water/wr/pdfs/gfrmpol.pdf
Standards Australia 1990, Test pumping of water wells,
AS2368 (1990) www.standards.com.au/select/Script/Details.
asp?DocN=stds000000718
Sydney Coastal Councils Group Inc 2006, Groundwater management
handbook, www.sydneycoastalcouncils.com.au

38
 UK Environment Agency 2000, Guidance on the assessment and
monitoring of natural attenuation of contaminants in groundwater,
Environment Agency, Bristol, http://publications.environment-
agency.gov.uk/pdf/SR-DPUB95-e-e.pdf

Relevant Acts of Parliament and policies

Contaminated Land Management Act 1997 www.epa.nsw.gov.au/
legal/envacts.htm
Conveyancing Act 1919 www.austlii.edu.au/au/legis/nsw/consol_act/
ca1919141/
Environmental Planning and Assessment Act 1979 www.legislation.nsw.
gov.au/viewtop/ inforce/act+203+1979+first+0+N
Local Government Act 1993 www.austlii.edu.au/au/legis/nsw/consol_
act/lga1993182/
NSW Public Health Act 1991 www.austlii.edu.au/au/legis/nsw/consol_
act/pha1991126/
NSW Water Sharing Plans www.naturalresources.nsw.gov.au/water/
ind_sharing_plans.shtml
Protection of the Environment Operations Act 1997 www.epa.nsw.gov.
au/legal/envacts.htm
Water Act 1912 www.austlii.edu.au/au/legis/nsw/consol_act/
wa191283/
Water Management Act 2000 www.dlwc.nsw.gov.au/care/water/wml/
pdfs/wmact2000-92.pdf

Suggested further reading

American Petroleum Institute 2000, Non-aqueous phase liquid (NAPL)
mobility limits in soil
American Petroleum Institute 1998, Evaluation of sampling and
analytical methods for measuring indicators of intrinsic bioremediation
American Society for Testing and Materials 2004, Standard guide
for remediation of groundwater by natural attenuation at petroleum
release sites, ASTM E1943-98
American Society for Testing and Materials 1992, Standard practice
for evaluating mathematical models for the environmental fate of
chemicals, ASTM E978

39
 Bedient PB, Rifai HS and Newell CJ 1999, Groundwater contamination:
transport and remediation, Prentice Hall & Sons
British Geological Survey 2003, Groundwater and its susceptibility
to degradation: a global assessment of the problem and options for
management, report on behalf of the United Nations Environment
Programme’s Division of Early Warning and Assessment
BP Oil International 2001, RISC-integrated software for clean-ups, user’s
manual, Sunbury, UK
Building Research Establishment 2001, Concrete in aggressive
ground, Special Digest No.1, Part 1: Assessing the aggressive chemical
environment, UK Department of Trade and Industry, BRE Centre for
Concrete Construction, BRE Centre for Ground Engineering and
Remediation, London, UK
Davis GB, Trefry MG, and Patterson BM 2004, Petroleum and solvent
vapours: quantifying their behaviour, assessment, and exposure, a
CSIRO Land and Water Report to the Western Australian Department
of Environment
Department of Environmental Protection (Western Australia) 2004,
Use of monitored natural attenuation for groundwater remediation
Department of Environmental Protection (Western Australia) 2001,
Potentially contaminating activities, industries and land uses
EPA Victoria 2006, Hydrogeological assessment (groundwater quality)
guidelines, Environment Protection Authority Victoria, Publication
668.
EPA Victoria 2002, The clean up and management of polluted
groundwater, Environment Protection Authority Victoria, Information
Bulletin, Publication 840
Fetter CW 2000, Applied hydrogeology, Prentice Hall Inc, Englewood
Cliffs, NJ, USA
Fetter CW 1998, Contaminant hydrogeology, Prentice Hall Inc,
Englewood Cliffs, NJ, USA
Freeze RA & Cherry JF 1979, Groundwater, Prentice Hall Inc,
Englewood Cliffs, NJ, USA
Interstate Technology and Regulatory Cooperation Work Group 2001,
Technical and regulatory guidance for in-situ chemical oxidation of
contaminated soil and groundwater

40
Interstate Technology and Regulatory Cooperation Work Group
2000, Dense non-aqueous phase liquids (DNAPLs): review of emerging
characterization and remediation technologies
Murray-Darling Basin Commission 2000, Groundwater flow modelling
guideline
Nielsen DM 2005, Practical handbook of environmental site
characterization and ground water monitoring, Taylor & Francis, CRC
Press
NSW EPA 1999, Guidelines on significant risk of harm from
contaminated land and the duty to report, NSW Environment
Protection Authority
Pankow JF & Cherry JA 1996, Dense chlorinated solvents and other
DNAPLs in groundwater: history, behaviour and remediation, Waterloo
Press, Portland, Oregon, USA
PASCALIS 2002, Sampling manual for the assessment of regional
groundwater biodiversity, F Malard (chief editor), European Project:
Protocols for the Assessment and Conservation of Aquatic Life in the
Subsurface
Schwartz FW and Zhang H 2002, Fundamentals of ground water, John
Wiley & Sons
Standards Australia 1996, Alkali aggregate reaction – Guidelines
on minimising the risk of damage to concrete structures in Australia,
document reference number HB-79 1996
State of California 1998, Guidelines for groundwater investigation
reports, Board for Geologists and Geophysicists, Sacramento,
California
Todd, DK and Mays, LW 2004, Groundwater hydrology, John Wiley &
Sons.
UK Environment Agency 2002, Guidance on the use of permeable
reactive barriers for remediating contaminated groundwater
UK Environment Agency 2001, Benchmarking and guidance on the
comparison of selected groundwater risk-assessment models, NGWCLC
Report NC/00/14
UK Environment Agency 2001, Guidance to good practice for the
development of conceptual models and the selection and application
of mathematical models of contaminant transport processes in the
subsurface, NGWCLC Report NC/99/38/2

41
 US Army Corps of Engineers 1997, In-situ air sparging
USEPA 2004, User’s guide for evaluating subsurface vapor intrusion into
buildings
USEPA 2002, Handbook on groundwater protection and clean up
policies for RCRA corrective action, EPA/530/R-01/015
USEPA 2002, Draft guidance for evaluating the vapor intrusion to indoor
air pathway from groundwater and soils (subsurface vapor intrusion
guidance)
USEPA 2002. Handbook of groundwater protection and cleanup policies
for RCRA corrective action, EPA/530/R-01/015
USEPA 2002, Groundwater sampling guidelines for Superfund and RCRA
project managers, EPA 543-S-02-001
USEPA 2001, The state of the practice of characterization and
remediation of contaminated groundwater at fractured rock sites, EPA
542-R-01-010
USEPA 1998, Technical protocol for evaluating natural attenuation of
chlorinated solvents in ground water, EPA/600/R098/128
USEPA 1997, Design guidelines for conventional pump and treat
systems, EPA/540/S-97/504
USEPA 1996, Low-flow (minimal drawdown) ground-water sampling
procedures, EPA/540/S-95/504
USEPA 1996, Hydrogeologic characterization of fractured rock
formations: a guide for groundwater remediators, EPA/600/S-96/001
USEPA 1996, Pump and treat groundwater remediation – A guide for
decision makers and practitioners, EPA/625/R-95/005
USEPA 1995, Light nonaqueous phase liquids, EPA/540/S-95/500
USEPA 1993, Suggested operating procedures for aquifer pumping tests,
EPA/540/S-93/503
USEPA 1992, General methods for remedial operation performance
evaluations, EPA/600/R-92//002
USEPA 1992, Statistical analysis of groundwater monitoring data at
RCRA facilities – addendum to interim final guidance
USEPA 1992, Fundamentals of groundwater modelling, EPA/540/92/005
USEPA 1991, Dense nonaqueous phase liquids, EPA/540-4-91-002

42
 USEPA 1989, Statistical analysis of groundwater monitoring data at
RCRA facilities – interim final guidance
Water Technology International Corp 1997, Site remediation
technologies: a reference manual, Contaminated Sites Management
Working Group, Burlington, Ontario, USA
Wiedemeier TH, Rifai HS, Newell CJ and Wilson JT 1999, Natural
attenuation of fuels and chlorinated solvents in the subsurface, John
Wiley & Sons Inc

Appendices
Appendix I: Glossary
Aquifer: a geological unit capable of storing and transmitting useful
quantities of groundwater.
Contamination of groundwater: defined in 1.5 of these guidelines.
Ecological health: the ability of an ecosystem to support and
maintain key ecological processes and organisms so their species’
compositions, diversity and functional organisations are as similar as
possible to those occurring in natural habitats within a region.
Ecosystem: a community of organisms plus the physical and
chemical environment in which they live and interrelate.
Environmental health: aspects of human health and disease that
are determined by factors in the environment.
Environmental values: particular values or uses of the environment
that are important for a healthy ecosystem or for public benefit,
welfare, safety or health, which require protection from the effects of
pollution, waste discharges and deposits.
Exposure: contact of a physical, chemical, or biological agent
with the outer boundary of an organism, e.g. through inhalation,
ingestion, or dermal contact.
Exposure pathway: physical course a chemical or pollutant takes
from its source to the exposed organism.
Groundwater: all waters occurring below the land surface.
Groundwater investigation level (GIL): the concentration of a
groundwater parameter at which further investigation (point of
extraction) or response (point of use) is required. Includes both

43
 ANZECC & ARMCANZ 2000a and NHMRC & NRMMC 2004 criteria, and
site-specific criteria.
Harm: in relation to contaminated land, harm to human health or
the environment (including any direct or indirect alteration of the
environment that degrades the environment), whether in, on or
under the land or elsewhere.
Hazard: the capacity of an agent to produce a particular type of
adverse health or environmental effect.
Hyporheic ecosystem: ecosystems that exist in alluvial sediments,
commonly linked to the base flows of rivers and streams.
Natural background concentration: the naturally occurring
ambient concentration of a substance in groundwater in the local
area of a site.
Plume: a volume of groundwater containing dissolved-phase
contaminants, extending from the source of contamination.
Point source: a source of contamination which comes from a
contaminating activity at a particular site.
Receptor: the entity that may be adversely affected by a
contaminant.
Remediation: all measures taken to mitigate risks from
contamination.
Risk: the probability in a certain timeframe that an adverse outcome
will occur in a person, a group, or an ecological system that is
exposed to a particular dose or concentration of a hazardous agent.

Appendix 2: Identifying environmental values

For assessing potential risks from groundwater contamination, all
environmental values of the groundwater need to be identified. The
principle of basing decisions about water quality on environmental
values is outlined in the Environmental objectives for water quality
and river flow (NSW Government 2006), which have been developed
for 31 surface water catchments across the state. Note that the term
‘environmental values’ includes consideration of human as well as
ecological health, and incorporates values associated with what are
commonly termed the ‘beneficial uses’ of groundwater.
Typically, groundwater quality at a particular site may protect some
or all of the following environmental values, depending on the
location of the contaminated site:

44
• Aquatic ecosystems: these include surface water ecosystems
and groundwater ecosystems.
• Human uses: these include but are not limited to potable water
supply, agricultural water supply (irrigation and stock watering),
industrial water use, aquaculture and human consumption of
aquatic foods, recreational use (primary and secondary contact
with surface waters) and visual amenity of surface waters.
• Human health in non-use scenarios: this includes consideration
of health risks that may arise without direct contact between
humans and the groundwater, for example, exposure to volatile
contaminants above groundwater contaminant plumes.
• Buildings and structures: this includes protection from
groundwater contaminants that can degrade building materials
through contact, for example, the weakening of building footings
resulting from chemically aggressive groundwater.
Cultural and spiritual values that are associated with the
environment, including groundwater, should also be protected.
Cultural and spiritual values may include spiritual relationships,
sacred sites, customary uses, the plants and animals associated with
the water, drinking water supplies and recreational activities. In
managing groundwater contamination, it is generally considered
that cultural and spiritual values will be protected where
groundwater quality protects all other relevant environmental values
on a site.
In identifying applicable environmental values for groundwater on a
particular site, the following matters must be considered.
Water sharing plans for groundwater resources
Water sharing plans (WSPs) and macro plans for groundwater
resources are being developed for aquifers across NSW. These plans
are statutory instruments created under the Water Management Act
2000 with the primary aim of establishing management rules for the
extraction of groundwater and provision of environmental water.
Although focused mainly on groundwater extraction, water
sharing plans and macro plans also provide an additional source of
information to identify beneficial uses or environmental values of
groundwater. These plans are available at www.naturalresources.
nsw.gov.au/water/plans.shtml. Note that DEC regards aquatic
ecosystems and drinking water as default environmental values in all

45
 preliminary assessments of groundwater contamination, including
where these values are not identified in water sharing plans.
Protecting aquatic ecosystems
Many aquatic ecosystems are partially or wholly dependent on
interactions with groundwater to sustain ecological structure and
function. Aquatic ecosystems include, but are not limited to, springs,
wetlands, karst and cave systems, and rivers and estuaries with a
strong base flow component, especially in the dry season. Also,
groundwater, while it supplies water for rivers, wetlands and other
ecosystems, may itself form part of a critical aquatic ecosystem. It
has become increasingly obvious that organisms in groundwater
contribute significantly to biodiversity, and are also important for
the self-purification processes in groundwater. General background
information about groundwater ecosystems is available in the
References section, for example, Danielopol et al 2003 and Hancock
et al 2005.
In NSW, little is known about groundwater organisms and their
sensitivity to pollutants. Hyporheic systems (those present in
groundwater within alluvial sediments linked to the base flow of
streams) are better known, and research suggests they play a key
role in cycling organic matter and processing pollutants.
Where organisms in groundwater that require protection have been
identified, for instance, by DNR in the process of identifying priority
groundwater dependent ecosystems (GDEs), management of the
contamination should aim to restore groundwater quality as much
as practicable to its natural background state in the shortest time
practicable, and prevent further groundwater pollution. The local
DNR office should be contacted for information about GDEs.
While it is vital to protect all known GDEs, ecosystems that have
not been specifically identified by DNR also require protection
from contamination. Therefore, in the preliminary assessment
of groundwater contamination, it must be assumed that aquatic
ecosystem protection is an applicable environmental value
of groundwater. A subsequent, more detailed assessment of
groundwater contamination may, however, demonstrate that this
environmental value does not apply.
Determining whether groundwater is a potential drinking water
supply
Because of basic landholder use rights, the preliminary assessment
of groundwater contamination must assume that drinking water is

46
an applicable environmental value of the groundwater, although
subsequent more detailed assessment may show that this value does
not apply at the site.
For the detailed assessment, there are three key steps in determining
whether drinking water supply is a relevant environmental value at a
site:
• checking DNR’s list of major aquifers of drinking water quality
• identifying actual groundwater users in the site vicinity
• referring to total dissolved solids (TDS) as an indicator parameter.
DNR has developed a list of major aquifers of drinking water
quality, which is included in Appendix 2.1. DNR has indicated that
these major NSW aquifers must be protected for drinking water
supply at the time of these guidelines being published. This list
may be updated. DNR should be consulted during an assessment of
groundwater contamination about an aquifer that does not appear
on this list.
This list and updated versions of it should also be consulted as part
of the groundwater assessment to determine whether drinking water
use has already been specified by DNR for a particular aquifer.
The list is a useful screening tool to find out whether drinking water
is a relevant environmental value, although it is not an exhaustive
list of all groundwaters in NSW which require protection to that
level. If the groundwater under consideration is not listed, the site
investigator needs to determine whether it should be considered as
a drinking water supply. This determination would need to take into
account the current uses of groundwater in the local area. If in the
process of site investigations, the site investigator obtains additional
water quality information at a specific location that may supersede
DNR information, DNR should be contacted for confirmation.
If neither of the first two steps identifies groundwater as a potential
drinking water supply, the site investigator should use an indicator
parameter, namely total dissolved solids (TDS), to reach a conclusion.
To do this, the site investigator should first determine the TDS
concentration of groundwater samples obtained at the site.
Groundwater with TDS concentrations below 2000 mg/L is suitable
for potential drinking water supply, and hence should be afforded
this level of protection from contamination unless other site-
specific factors, such as low yield, render such use unlikely. A TDS
concentration of 2000 mg/L has been selected as the level above

47
 which groundwater is unlikely to be acceptable as drinking water
because of taste. While it is acknowledged that, based on the
Australian drinking water guidelines (NHMRC & NRMMC 2004), the
TDS content in drinking water should not exceed 500 mg/L because
of taste considerations, the World Health Organisation (WHO) states
that there is an enormous variation in the taste that is regarded as
acceptable by different individuals and communities.
In addition, there is significant variation between individuals in
their ability to detect tastes in drinking water. WHO indicates that
TDS concentrations above 1000 mg/L may give rise to consumer
complaints. This suggests that some individuals will accept water
with a TDS higher than 1000 mg/L for drinking. Further, in some
cases higher TDS water may be diluted before drinking. Therefore,
a ‘filter’ TDS concentration of 2000 mg/L should be used in NSW to
confidently rule out the use of groundwater as a likely drinking water
supply.
If aquifers with a TDS concentration of less than 2000 mg/L are or
could be affected by contamination (e.g. due to contamination in
perched groundwater in low permeability sediments overlying
a higher permeability aquifer), relevant information should be
provided to DNR and DEC prior to discounting drinking water as an
applicable environmental value.
TDS is not an appropriate filter for considering the relevance of
environmental values other than drinking water supply.
Determining the relevance of other environmental values
People use groundwater for a variety of purposes. The relevance of
these environmental values needs to be considered on a site-specific
basis.
Information on current or proposed extraction of groundwater, such
as for agricultural or industrial use, may be obtained by searching
for licensed groundwater extractors in the area, and seeking
other advice from DNR. The potential presence of yet unidentified
extractors also needs to be considered.
Basic landholder use rights need to be considered when
identifying the environmental values that require protection from
contamination. These rights mean that in NSW water, including
groundwater, may be able to be used for domestic consumption
(including drinking water) and stock water purposes as well as for
uses consistent with native title rights without requiring the approval
of DNR. Note, however, that licensing requirements apply to the

48
construction of groundwater bores irrespective of the requirements
to approve groundwater use.
It should always be assumed that groundwater is discharging to
identified surface water bodies and, therefore, all environmental
values of the surface water such as recreational uses, visual amenity
and aquaculture operations, require consideration unless the
local hydrogeology has been fully characterised and groundwater
discharge is unlikely to occur. Allowance should be made in such
cases for any possible alteration to groundwater flow (e.g. due to
differing climatic conditions).
Where groundwater discharges to surface waters, the community
in 31 catchments across NSW has agreed to environmental values
for surface waters known as water quality objectives (WQOs). These
have been endorsed by the NSW government and are available on
www.environment.nsw.gov.au/ieo. The ANZECC & ARMCANZ 2000a
guidelines are used to establish the numerical default criteria (trigger
values) supporting the environmental values established by the
WQOs.
In identifying environmental values, it must be recognised that
information about aquifer yield, groundwater quality and beneficial
uses which is valid regionally may not necessarily be valid locally. For
instance, while a rock formation may have generally low yield which
may not sustain certain beneficial uses, locally the yield may be
sufficient to sustain these uses.
Groundwater uses consistent with basic landholder rights do not
require significant yield. Moreover, the lack of a sufficient yield in
the context of specific uses is not enough to disregard such uses in
groundwater or surface water systems, including wetlands, rivers,
or creeks, that are hydraulically connected to the groundwater that
is being assessed. For instance, contaminated groundwater in a
low yielding formation may leak into an underlying aquifer that is
extracted for human use, or may discharge to surface water that
supports aquatic and benthic life, recreation or a drinking water
supply.
The concept of environmental values of groundwater extends
to considering the potential impact of contamination on media
other than water and sediments. It is, therefore, important that all
relevant exposure pathways are carefully considered in determining
the relevant environmental values of groundwater. Also, concrete
structures, such as building footings, may need to be considered
as these can be susceptible in some circumstances to corrosion by

49
 particular types of groundwater contamination, particularly sulphur
compounds and acidity. Section 6 lists several publications that
may be useful in assessing risks to building materials under ‘Further
reading’.
Indoor air quality is another important environmental value of
groundwater quality which can be affected when groundwater
is contaminated with volatile chemicals, for instance, beneath or
near a building. Risks from inhaling volatile contaminants from
groundwater have received significant attention over recent years,
particularly in the USA where technical guidelines have been
developed by state and federal agencies. Assessing inhalation
risks associated with contaminated groundwater is complex,
and a relevant technical discussion is beyond the scope of this
document. In general, however, a weight of evidence approach
should be used taking into account relevant information, which may
include geology, soil moisture, depth to groundwater, water table
fluctuations, building details, soil–gas measurements, flux hood
measurements, indoor air quality, spatial and temporal variations in
contaminant mass flux estimates and other factors. Section 6 lists
some documents assessing risks from volatile contaminants from
contaminated groundwater under ‘Suggested further reading’.

2.1 Major aquifers of drinking water quality

DNR has deemed the aquifers below to be actual or potential
drinking water supplies and to require protection of groundwater to
this level:
• Araluen alluvium and weathered granite
• Clarence-Morton Basin (except the Grafton Formation)
• coastal alluvium (part only)
• Cudgegong Valley alluvium
• Great Artesian Basin intake beds
• Hunter alluvium and tributaries
• Lachlan Fold Belt Province (part only, e.g. limestones)
• Lower Gwydir alluvium
• Lower Lachlan alluvium
• Lower Macquarie alluvium
• Lower Murrumbidgee alluvium
• Lower Murray alluvium
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 • Lower Namoi alluvium
• Mangrove Mountain sandstone
• Maroota tertiary sands
• mid Murrumbidgee alluvium and tributaries
• miscellaneous coastal sand beds
• miscellaneous tributaries of Namoi (alluvium)
• New England fold belt province (part only e.g. granites and
basalts)
• Orange basalt
• Oxley Basin
• Peel River alluvium
• Tomago/Stockton/Tomaree sand beds
• Triassic sandstones in the Sydney Basin
• Upper Lachlan alluvium and tributaries
• Upper Macquarie alluvium and tributaries
• Upper Murray alluvium
• Upper Namoi alluvium
• Young granite.
Where a groundwater contaminant plume is identified within one of
these aquifers the remediation target should at least meet the water
quality criteria in the Australian drinking water guidelines (NHMRC &
NRMMC 2004).
If it is considered that the designation as drinking water supply is
not appropriate at a particular site above one of these aquifers,
it is possible to seek confirmation of this conclusion from DNR’s
regional hydrogeologist. The proponent should make available to
DNR sufficient evidence of the groundwater quality to support their
conclusion.

Apppendix 3: Monitored natural attenuation

Natural attenuation of contaminated groundwater is defined as:
‘The effect of naturally occurring physical, chemical and
biological processes to reduce the load, concentration, flux
or toxicity of polluting substances in groundwater’ (UK
Environment Agency 2000).

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 These processes include biodegradation, dispersion, diffusion,
sorption, volatilisation, and chemical or biological stabilisation,
transformation or destruction. Although natural attenuation is
sometimes referred to as intrinsic bioremediation, non-biological
processes may also be important.
The term monitored natural attenuation or MNA refers to reliance on
natural attenuation processes – as part of a planned, controlled and
monitored remedial approach – to achieve site-specific remediation
objectives within a timeframe that is reasonable compared to that
offered by other more active methods. It emphasises that monitoring
to demonstrate and document the progress of MNA must be an
integral part of a natural attenuation strategy for any site.
Natural attenuation may reduce the potential risk posed by site
contaminants, for instance through:
• reducing toxicity due to transformation of contaminant(s) through
destructive processes such as biodegradation or abiotic chemical
transformations. Note that contaminant transformation will not
always reduce the risk. Some contaminants, for example, some
chlorinated organic compounds, may transform to more toxic
contaminants as they degrade in the environment. A proposal
for MNA must therefore evaluate the impacts of all degradation
pathways and their effect on the suitability of MNA at a site.
• reducing contaminant mobility and bioavailability through
sorption into the soil or rock matrix
• reducing dissolved contaminant concentrations and subsequently
reducing potential exposure concentrations.
Note that dilution within a receptor, such as a surface water body
or groundwater abstraction system, is not considered to be natural
attenuation.
Research over the last 20 years has resulted in a sound technical
understanding of natural attenuation processes for many
groundwater contaminants and knowledge of the specific conditions
under which contaminants may be degraded. On this basis, MNA
is accepted as one remedial strategy that should be considered
when evaluating clean-up options for sites where groundwater is
contaminated. MNA may be particularly useful in areas of a plume
where contaminant concentrations are low. Based on this, MNA
may often be applied where more aggressive clean-up has already
reduced contaminant concentrations in the core of the plume.

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Advantages of MNA
Used alone or in combination with other strategies, such as
secondary source removal, MNA may be a non-intrusive, safe and
cost-effective strategy to remediate groundwater contamination. In
some circumstances, it may be the only practicable strategy that can
be used.
Disadvantages of MNA
There may not be the necessary environmental conditions for
effective natural attenuation of a particular contaminant at the
location of concern. Natural processes may work slowly in the
subsurface environment, where reaction rates may be restricted
by low temperatures and limited availability of the necessary
microorganisms, electron acceptors or electron donors, co-
metabolites and nutrients. Natural attenuation may not achieve
remediation goals within adequate timeframes in those cases.
Sometimes intervention or enhancement may change the conditions
to allow natural processes to work more effectively, but in other
cases this will not be possible, and MNA must be discounted as an
option. Also, sometimes the concentration of a contaminant is so
great, or the risks to human or ecological health so severe, that other
strategies with a shorter effective timeframe must be used.
Demonstrating whether MNA is applicable
To decide whether remediation by monitored natural attenuation
is appropriate for a particular site (relative to site-specific remedial
goals), professionals should:
• characterise the site
• assess potential risks
• ensure there is primary and secondary source removal or control
• evaluate potential effectiveness.
Remediation by natural attenuation requires demonstrating
progress towards attaining the remedial goals. This is achieved by
using converging lines of evidence, which are obtained through
monitoring and evaluating the resulting data. Monitoring should
continue until the remedial goals have been met.
Primary evidence that remediation by natural attenuation is working
is seen when there is a reduction in the lateral and vertical extent of
the plume, and reductions in concentrations of the contaminants of
concern within the plume.

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 Secondary evidence is provided by geochemical indicators of
naturally occurring degradation and estimates of attenuation rates.
Additional optional lines of evidence can be provided by
microbiological information, including field and laboratory
microcosm studies, where this information directly demonstrates the
occurrence of a particular biodegradation process at a site. Further
analysis of primary and secondary lines of evidence may also be
required using, for example, solute transport modelling or estimates
of assimilative capacity.
Any application of MNA at a site requires extensive hydrogeological
and geochemical site characterisation, which may often need to be
supported by appropriate modelling. It is not sufficient to simply
indicate that, for example, groundwater conditions beneath the
site are being reduced, and therefore reductive dechlorination of
chlorinated aliphatic hydrocarbons will occur.
When is MNA appropriate?
Generally, monitored natural attenuation should only be considered
as a remediation methodology where the following conditions are
met:
• the source of the contamination, including contamination ’hot
spots‘, have been removed as much as practicable
• the three-dimensional extent of the contamination has been
defined
• the site and hydrogeology have been adequately characterised
and there is clear evidence that attenuation rates are sufficient to
achieve the remedial goals within an adequate timeframe
• the natural attenuation processes include those which reduce the
mass of dissolved contaminants
• the effects of degradation have been considered.
As with other remedial approaches, it is expected that where
monitored natural attenuation is proposed as part of a remedial
strategy for a site, its feasibility and appropriateness would be
demonstrated in a remedial action plan (RAP). The RAP should draw
on site characterisation and risk assessment data acquired during
previous investigation of the site. Within the RAP, the proponent
should:
• demonstrate an understanding of the particular attenuation
processes relevant to the contaminant(s) of concern under the
conditions at that site
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• define remedial goals and set out the scope, frequency and
expected duration of the monitoring required to demonstrate
that natural attenuation has been effective and the goals have
been met
• define monitoring frequency, which should be sufficient to allow
the progress of natural attenuation to be tracked, and to provide
early warning if expectations are not being met, or if adverse
impacts on sensitive receptors become possible
• address the integration of MNA with other remedial technologies
that may be proposed for source removal or reduction, and any
potential interactions or interferences.
The long-term sustainability of MNA during and following
any proposed redevelopment of the site must be considered.
Where reference is made to experience from other sites, an
understanding of the potential impacts of differences in, for
instance, hydrogeological conditions between the sites must be
demonstrated.
The RAP and ongoing monitoring and validation reports should
set out the lines of evidence for the progress and success of natural
attenuation. Unless the primary line of evidence is conclusive, it
will be necessary to evaluate secondary and additional lines of
evidence. A checklist has been provided on the next page to assist in
undertaking a review of the suitability of MNA at a particular site.
Considering the effect of contaminant degradation on toxicity
and mobility
Some contaminants degrade and become more toxic. Vinyl chloride,
from the reductive dechlorination of trichloroethene (TCE), is a
well-known example. Therefore, the potential effects of degradation
products on the toxicity and mobility of the contamination need
to be carefully considered when evaluating the appropriateness of
MNA.
In some cases, and in the right hydrogeological conditions, the
more toxic degradation products may break down further to form
less toxic compounds. In such instances, MNA may be deemed
acceptable if it can be demonstrated that the more toxic compounds
will not represent a threat to human or ecological health.

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 Checklist for assessing the applicability of monitored natural
attenuation
q Has the site been adequately characterised in relation to
stratigraphy, lithology, structure, water-bearing zones,
groundwater flows, solute transport, lateral and vertical
hydraulic gradients, hydraulic conductivities and porosities?
q Has the site been adequately characterised in relation
to geochemical conditions, including salinity, temperature,
pH, redox potential, organic carbon sources, nutrient
availability, sorption capacity and the availability of electron
donors and acceptors?
q Have all contaminants of potential concern been identified?
q Has the toxicity of the contaminants of concern been
adequately assessed?
q Has the plume been fully delineated for all contaminants of
concern?
q Have all potential receptors been identified?
q Have all potential beneficial uses and environmental values
of the groundwater been identified?
q Are proposals to remove or control primary sources (e.g.
leaking infrastructure) and secondary sources (e.g. residual
NAPL, adsorbed phase) adequate and feasible?
q Is the proposed attenuation mechanism feasible for all the
contaminants of concern under the conditions prevailing at
the site?
q Do the natural attenuation processes include processes that
reduce the dissolved mass of the contaminants of concern?
q Are there condition conflicts among multiple contaminants
of concern?
q Have the toxicity and fate of all potential degradation
products been considered?
q Will attenuation to acceptable concentrations be achieved
well before potential human or ecological receptors could
be impacted on?
q Have all feasible alternative remedial options been
considered?

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 q Will the remediation goals be reached within a timeframe
that is reasonable compared with other remedial options,
and community expectations?
q Is monitored natural attenuation sustainable, considering
proposed source control measures and redevelopment of
the site and surrounding area?
q Are there financial mechanisms in place to ensure that
monitoring can be continued for the required period?
q Have adequate contingency measures been proposed?

Appendix 4: Contacting NSW government departments for

advice on groundwater contamination
These guidelines refer to the need to contact one or more
government departments throughout the course of groundwater
contamination assessment and management.
The proponent will need to collate and present a variety of
information to the relevant department to assist it in providing
advice or reaching agreement on proposed management strategies.
The contact details are summarised below.
Department of Environment and Conservation (DEC)
Manager Contaminated Sites
59–61 Goulburn Street, Sydney NSW 2000
PO Box A290, Sydney South 1232
Telephone: (02) 9995 5000 (switchboard)
Telephone: 131 555 (NSW only)
www.environment.nsw.gov.au
Department of Natural Resources (DNR)
For advice on beneficial uses of groundwater, contact the regional
hydrogeologist.
For hydrogeological information, visit www.nratlas.nsw.gov.au.
Contact details for DNR’s regional offices are available at:
www.DNR.nsw.gov.au/aboutus/contactus.shtml.
NSW Health
Area Health Service Public Health Unit
Contact details for regional Public Health Units are available at:
www.health.nsw.gov.au/public-health/phus/phus.html or in the
Business Section of the White Pages.

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