The soil management plan (SMP) must include the following key information:
The executive summary is a high-level synopsis of the project’s SMP and should include a summary of all the key information.
Project delineation and contamination
The proponent must provide a delineation of the entire project area, detailing any areas where contaminated soil is to be managed or reused. This should include official surveys with detailed maps and boundaries including:
- project delineation (x/y coordinates)
- geological and hydrogeological features
- details of the legal ownership and/or occupiers of each part of the project area
- previous uses of the land
- proposed future uses of the area (including the infrastructure to be developed)
- details of the applicable planning scheme and other relevant information about the land.
Contaminated soil source, location, quantity and characteristics
The SMP must include the source, location, quantity, characteristics and other relevant attributes of any contaminated soil which might be excavated in the project, including any preliminary investigations or testing (environmental site assessments/soil sampling) which may have identified contamination (whether man-made or naturally occurring).
Sampling is to be conducted in accordance with Industrial Waste Resource Guideline – Soil sampling (publication IWRG702).
The proponent must specify if the contaminated soil will be reused (with or without reprocessing or treatment, refer to section 6). If soil is to be reused, details must be provided on how it is to be reused including:
- the location of reuse
- physical, geological/hydrogeological characteristic of that location
- the extent to which the soil at that location has similar or distinct hazard characteristics to the soil to be reused.
A risk assessment and management plan must also be submitted. This needs to include an assessment of both the immediate and long-term environmental risks, the control measures intended to mitigate risks, and the on-going management measures. The proponent must consult with the land owner and ensure that works are completed in accordance with the land owner agreement.
Further information on contaminated land and what may be able to be reused can be found in the SEPP (Prevention and Management of Contaminated Land).
Temporary storage and containment
If temporary storage or containment is required during the project, further information is to be provided and must include the following:
- intended location and method of storage or containment
- duration of storage or containment, including any facilities or buildings used for storage or containment.
The classification process does allow for soils to be temporarily moved and stored. However, EPA expects that some preliminary sampling will have been undertaken in-situ to sufficiently characterise the soil. Further testing can then be undertaken if required.
The use of classifications does not exempt sites from obtaining a works approval for on-site containment as required under the Environment Protection (Scheduled Premises) Regulations 2017. For onsite containment of soil greater than 1000m3, an EPA works approvals pathway form will need to be completed.
Further information on best practice environmental management is available in the Environmental guidelines for major construction sites (publication 480).
The proponent must detail whether it is proposed to reprocess or treat contaminated soil that has been excavated prior to reuse. The reprocessing or treatment process that is proposed needs to be detailed, including how it is to be reused or managed afterwards.
Environmental and human health risks
The proponent must detail any identified environmental and/or human health risks that might reasonably arise from the management or reuse of contaminated soil (for example direct contact by site workers or others, dust, leaching, surface water run-off, unexpected contamination encountered, and other possible on- or off-site impacts). Information should include details of how it is proposed to manage/mitigate those risks through further risk assessment and contingency planning.
The proponent must detail whether it is proposed to transport the contaminated soil for management, reuse or disposal, including proposed transport routes and form of transport (having regard to the likely attributes of such soil, the proposed transportation vehicles and other relevant matters).
Per- and poly-fluorinated alkyl substances (PFAS)
The PFAS National Environmental Management Plan (NEMP), released in February 2018, provides state and federal governments with the foundations on which to build regulations to manage PFAS. The PFAS NEMP is an adaptive plan, able to respond to emerging research and knowledge.
EPA will be working with proponents on assessing PFAS contaminated soil on a case-by-case basis for major projects using the NEMP and EPA’s Interim position statement on PFAS (publication 1669). Please include PFAS in your SMP. It is advised that you contact your Major Project contact to discuss PFAS management options prior to submission of your application.
Current and future uses of the project area
The proponent must detail the nature of the current and future uses of the project land. Particular regard must be made to any sensitive, or other uses, which might be susceptible to detrimental impacts (either immediate or long-term) from any aspect of the management or reuse of the contaminated soil.
Stakeholder assessment and consultation
The proponent must provide details of any stakeholders or other persons whose interests may be affected by the proposed management of contaminated soil, including any consultation undertaken, any environmental or human health concerns or risks raised, and any proposal for further consultation and stakeholder engagement with such persons during the project.
Any further information, including technical or scientific data, necessary to determine either:
- the environmental or human health risks associated with the proposed management or reuse of contaminated soil or soil; or
- the regulatory requirements administered by EPA that might apply to such activities.