PFAS investigation process

What the investigation involves

PFOS and PFOA are both very stable chemicals that bioaccumulate, do not break down, and can persist for a long time in the environment. Due to their widespread use in a range of industrial and consumer products over many decades PFAS contamination is commonly found in the environment at low levels.

The EPA is investigating sites where there is a likelihood that large quantities of PFAS have been used in the past, to better understand the extent of PFAS use and contamination in NSW. This way the EPA will be better prepared to respond if any health and environmental impacts become known. 

The initial focus is on sites where there has been known use of PFAS-containing fire-fighting foams, primarily where fire training exercises were conducted. This includes sites managed by NSW Fire and Rescue (FRNSW), Rural Fire Service (RFS), Airservices Australia and other airports.

The EPA undertakes a thorough assessment of the available information for each identified site to evaluate the likelihood of nearby sensitive receiving environments and possible pathways to water bores or fisheries.

An inspection is then carried out with the owner or occupier of the land and samples of soil and/or surface water are taken from readily accessible targeted locations to investigate potential exposure pathways identified in the initial assessment or the site inspection.

Once surface water and soil screening samples are taken at these sites, they are subject to analysis in a laboratory. It can take several weeks for the results to become available.

As elevated levels of PFOS or PFOA alone do not indicate a risk to the environment, or to human health, the results are considered in the context of the potential exposure pathways to water supplies, recreational waters and fisheries.

The NSW EPA shares these screening sample findings with the landowner and the land occupier, and recommends next steps, including further site investigation.

Once a site is flagged by the EPA for further investigation there are four stages of the investigation:

The person or organisation accountable for the contamination has responsibility for conducting the investigation, and will commonly contract a consultant for  the work. One consultant may be employed to do all stages or a number of consultants may be engaged.

Stages progress depending on findings.

A preliminary site investigation includes:

Understanding a site’s history is fundamental to the preliminary site investigation. It is important to review and assess all relevant information about the site to determine where the preliminary sampling and analysis should occur.

This stage can take between one and three months.

The detailed site investigation gives comprehensive information on the type, extent and level of contamination.

It focusses on:

The samples are analysed and can take weeks for the laboratory to process.

If the results of the detailed site investigation show that the site poses risks to human health or the environment – on-site or off-site – a remedial action plan must be prepared and implemented.

This stage can take up to six months.

If significant exposure pathways are identified, a human health risk assessment may then be undertaken. This will evaluate potential risks to health and prioritise remediation measures. Such assessments vary in scope but usually take several months.

The RAP focusses on:

Once remedial work is complete, a report is prepared detailing the site work conducted and regulatory decisions made.

The development of a RAP can take many months, but the timeframe is subject to the assessed need and risk.

Where remedial action has been carried out, the site must be ‘validated’ to ensure that the objectives stated in the RAP have been achieved.

A report detailing the results of the site validation is required and includes:

If the results of the post-remediation testing indicate that the clean-up has not been successful, additional site work is proposed to achieve the original RAP objectives.

Where full clean-up is not feasible, or on-site containment of contamination is proposed, the option of ongoing monitoring is assessed. The proposed monitoring strategy, parameters to be monitored, monitoring locations, frequency of monitoring, and reporting requirements are included in the program.

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