3
Palumbo, Luciano (EPA)
From:
Cuenca, Edward (EPA)
Sent:
Monday, 21 October 2019 12:54 PM
To:
Boyce, Wendy (EPA)
Subject:
FW: Fw: EPA enquiry [DLM=For-Official-Use-Only]
Attachments:
RFE0048 Mt Barker Waldorf School_Draft Soil Classification Summary Table.pdf
Security Classification:
For Official Use Only
For Official Use Only
21 October 2019
Hi Wendy,
I received the response below following our comments to the report submitted by Mt. Barker Waldorf School. It
appears that the consultant is proposing to undertake additional work to address our concerns. Will you be able to
have a look at the proposed scope of work for comments please?
Thanks very much.
Regards,
Ed
From: Mark Lucas [mailto:xxxxxx@xxxxxxxxxxxxxxx.xx.xxx.xx]
Sent: Thursday, 17 October, 2019 10:12 AM
To: Cuenca, Edward (EPA) <xxxxxx.xxxxxx@xx.xxx.xx>
Subject: FW: Fw: EPA enquiry [DLM=For‐Official‐Use‐Only]
Hi Edward
Please find the response from RFE Consulting to the comments raised in regards to our situation in the email chain
below as well as a further attachment. If anything further is needed please contact me.
Regards
Mark
Mark Lucas | Business Manager 27 Sims Rd | PO Box 318 | Mt Barker SA 5251
P: 8391 0411 | F: 8391 2386
www.mtbarkerwaldorf.sa.edu.au
STRENGTH GRACE AND SKILL ‐ FOR LIFE
From: Ross Fitzgerald <xxxx@xxxxxxxxxxxxx.xxx.xx>
Sent: Wednesday, 9 October 2019 11:09:47 PM
1
To: Helen Platell <xxxxxxxx@xxxxxxxxxxxxxxx.xx.xxx.xx>
Subject: Re: Fw: EPA enquiry [DLM=For‐Official‐Use‐Only]
Hi Helen,
SA EPA Contamination Branch Review
Thanks for sending through the review completed by the SA EPA Contamination Branch.
A number of the items raised were discussed during the initial site visit. Please find the following
responses below to the potential areas of uncertainty / data gaps identified by the SA EPA review and
proposed additional assessment to clarify the outstanding items.
Whether the sampling locations targeted all known discard areas: It is acknowledged by both the Consultant and the Client that it is unlikely that all known discard areas
were targeted. Sampling locations were identified by the Client during the site walkover undertaken
prior to commencing the sampling program based on best information available.
The following additional investigations may assist in further refining potential discard areas:
Additional intervews with former and current site users (including the person who discarded the
laboratory chemicals to the garden areas if possible) who may have witnessed the potential
discarding of laboratory chemicals or may have made observations of potential sources of
contamination as a result of the potential discarding of laboratory chemicals
Review of the historical and current management of surplus laboratory chemicals
Review of book keeping associated with volumes chemicals used/discarded
Review of site works (including earthworks) completed at the site in the vicinity of the Science
Centre, including the upgrade completed to the subsurface sump designated for managing
surplus laboratory chemicals, including technical specifications and/or site plans
Review of historical aerial photographs and site photographs
Review of chemicals present at the site as well as the chemical storage and transfer areas and
management processes
Review location, volume and type of chemicals spilled, incidents and accidents
Completion of a chronology summarising the information from the above sources of information
to target potential contaminants and areas of contamination.
The outcomes of the above desktop study may assist in refining the analytical suite and investigation
areas associated with the potential
discarding areas of laboratory chemicals and therefore provide
greater certainty in the contamination status of the site.
Whether site layout has changed over time which might change where lab chemicals were discarded: Review of the following sources of information may increase the certainty on the location of the
potential discard areas of laboratory chemicals at the site:
review of historical aerial photographs over the period of time when the potential discarding of
material may have been occurring
review of site photographs
review of site works completed within the vicinity of the science centre.
Whether the chemical analytes tested were properly representative of the (all) lab chemicals
discarded: It is acknowledged that the original request from the Client was to analyse for lead only. RFE
Consulting (RFE) recommended, at a minimum, expanding the analytical suite to metals (8) (arsenic,
cadmium, chromium, copper, mercury, lead, nickel and zinc). During discussions on-site with the
Client a broader suite of analytes was proposed in addition to requesting a summary of the laboratory
chemicals used at the Science Centre to further refine the proposed analytical suite.
2
A review of a summary of the chemicals used at the Science Centre and of book keeping associated
with volumes used and discarded will assist to refine the potential contaminants of concern associated
with the potential discarding of laboratory chemicals to the garden areas.
Additional sampling and laboratory analyses will be a likely outcome from the review of laboratory
chemicals used to quantify potential areas of contamination at the site.
Potential for any run-off to have entered any surface water channels / waterways: Review of site plans and online databases to determine the potential for run-off to impact potential
surface water receptors. Confirmation of the desktop review of surface water receptors and potential
pathways from a site walkover / insepection.
Further intrusive assessment:
Outcomes from the additional assessment summarised above may provide additional potential areas of
contamination which may warrant additional assessment.
Following the additional desktop assessment as summarised above, should additional areas and/or
contaminants of concern be identified, a conceptual site model (CSM) should be completed to present
a summary of all information collated. The CSM should clearly identify the potential source('s) of
contamination, potential pathways and potential sensitive receptors identified at the site.
The CSM should feed into a sampling and analysis quality plan for further additional assessment as
required.
Further proposed scope of works can be provided when, and if, additional assessment is triggered.
Soil classification results:
Please find attached the draft laboratory results summary table for soil classification for off-site
disposal.
The following exceedances of Waste Fill criteria (
Environment Protection Regulations, 2009) were
reported by the NATA accredited laboratory
(MGT Eurofins):
Concentrations of copper reported in BH3_0.0 (110mg/kg) exceeded the Waste Fill (WF)
criteria of 60 mg/kg but were below the Intermediate criteria
(SA EPA (2010)
Current criteria
for classification of waste) of 2,000 mg/kg;
Concentrations of mercury reported in BH5_0.0 (7.6 mg/kg) exceeded the WF criteria of 1 but
were below the Intermediate criteria of 30 mg/kg; and
Concentrations of zinc reported in BH2_0.0 (300 mg/kg) and Dup B (370 mg/kg) exceeded the
WF criteria of 200 mg/kg but were below the Intermediate criteria of 14,000 mg/kg.
Based on the dry weight concentrations reported for the analytes tested, the soil analysed can be
classified as Intermediate. However, additional leachate analysis is required in accordance with
AS4439.3_1997 for copper in BH3_0.0, mercury in BH5_0.0 and zinc in Dup B to classify this material
as Intermediate.
Additional analytes identified in the desktop assessment summarised above should be analysed for
prior to classification and/or a broad suite of analytes such as the SA Wase Screen be completed to
confirm classification.
Should you require to excavate the material prior to confirmation of classification of the material based
on laboratory results, we recommend documenting:
the source of the material of each stockpile (or stockpile area);
date, time and volume moved;
dimensions of the excavation and material encountered;
any visible observations of potential contamination such as staining of the soils or odours from
the material;
3
classification of any imported material used for backfilling; and
given the unknown location of the potential discarding of laboratory chemicals, we recommend
validating the extent of excavations through the retrieval and analysis of surface soil samples at
each side of the excavation.
Please let me know if you would like a proposal to complete the additional assessment recommended
above.
Should you have any queries, please don't hesitate to contact me on 0439 034 900.
Kind regartds,
Ross
---- On Tue, 08 Oct 2019 09:20:53 +0930
Helen Platell <xxxxxxxx@xxxxxxxxxxxxxxx.xx.xxx.xx> wrote ----
Hi Ross,
Please see email below from the EPA and let me know what else we may need to do. It may be that we
need to do and if we need more extensive testing for other chemicals But we are moving the soil from the
BH 1, 2 and 3 now. We are moving it in a separate pile on school grounds. The area will be mulched and
flagged off for the time being.
We will also take soil off of the area of BH 4, 5 and 6 and will keep it in another sperate pile on school
grounds.
We have not touched the area of BH 5,6 or 7 except to whipper snip the grass.
I have a list of chemicals used over the years but have no idea if they were also disposed of in the
garden. Let me know what you think is necessary.
Regard,
Helen Platell, JD | Principal
I live and work on Peramangk land
27 Sims Rd | PO Box 318 | Mt Barker SA 5251
P: 08 8391 0411 | F: 08 8391 2386
xxxxxxxx@xxxxxxxxxxxxxxx.xx.xxx.xx
www.mtbarkerwaldorf.sa.edu.au
4
STRENGTH GRACE AND SKILL
From: Mark Lucas <xxxxxx@xxxxxxxxxxxxxxx.xx.xxx.xx>
Sent: Tuesday, 8 October 2019 7:05 AM
To: Helen Platell <xxxxxxxx@xxxxxxxxxxxxxxx.xx.xxx.xx>
Subject: FW: EPA enquiry [DLM=For‐Official‐Use‐Only]
Hi Helen
This is the email back from the EPA
Regards
Mark
Mark Lucas | Business Manager 27 Sims Rd | PO Box 318 | Mt Barker SA 5251
P: 8391 0411 | F: 8391 2386
www.mtbarkerwaldorf.sa.edu.au
STRENGTH GRACE AND SKILL - FOR LIFE
From: Cuenca, Edward (EPA) [mailto:xxxxxx.xxxxxx@xx.xxx.xx]
Sent: Thursday, 3 October 2019 2:11 PM
To: Mark Lucas <xxxxxx@xxxxxxxxxxxxxxx.xx.xxx.xx>
Subject: RE: EPA enquiry [DLM=For-Official-Use-Only]
For Official Use Only
3 October 2019
Hi Mark,
The EPA Site Contamination Branch undertook a review of the report and the following comments were
raised:
Based on the email trail the prompt for the limited soil investigation appears to be the issue around the
discard water and lead flashing. The report refers broadly to “uncontrolled discarding of laboratory chemicals” – suggesting the potential
for other chemical / waste types to be disposed of. The consultant states that sampling was undertaken targeting the garden areas with input from school
staff. There a few areas of potential areas of uncertainty / data gaps which relate to:
whether the sampling locations targeted all known discard areas
whether site layout has changed over time which might change where lab chemicals were discarded
whether the chemical analytes tested were properly representative of the (all) lab chemicals discarded
5
potential for any run‐off to have entered any surface water channels / waterways.
These matters could be addressed through a desktop / background study and clearer documentation of the
historical practices within the report. You may wish to convey this message to the consultant for more clarification.
Regards,
Edward Cuenca Senior Enviromental Adviser Waste Assessment
Regulation | Compliance
Environment Protection Authority
Phone #: (08) 8204 2004
GPO Box 2607 Adelaide SA, 5001 Australia
This email message may contain confidential information, which also may be legally privileged. Only the intended recipient(s) may access, use, distribute or copy this
email. If this email is received in error, please inform the sender by return email and delete the original. If there are doubts about the validity of this message, please
contact the sender by telephone. It is the recipient’s responsibility to check the email and any attached files for viruses. From: Mark Lucas [mailto:xxxxxx@xxxxxxxxxxxxxxx.xx.xxx.xx]
Sent: Wednesday, 25 September, 2019 9:02 AM
To: Cuenca, Edward (EPA) <xxxxxx.xxxxxx@xx.xxx.xx>
Subject: RE: EPA enquiry [DLM=For-Official-Use-Only]
Hi Edward
Please find the Final Report attached including Attachment 6. If you could please advise if there is anything
else that we need to do.
Regards
Mark
Mark Lucas | Business Manager 27 Sims Rd | PO Box 318 | Mt Barker SA 5251
P: 8391 0411 | F: 8391 2386
www.mtbarkerwaldorf.sa.edu.au
STRENGTH GRACE AND SKILL - FOR LIFE
6
From: Cuenca, Edward (EPA) [mailto:xxxxxx.xxxxxx@xx.xxx.xx]
Sent: Monday, 23 September 2019 5:16 PM
To: Mark Lucas <xxxxxx@xxxxxxxxxxxxxxx.xx.xxx.xx>
Subject: RE: EPA enquiry [DLM=For-Official-Use-Only]
For Official Use Only
Hi Mark,
Thank you for your email. Can I please check if Attachment 6 was appended to the report?
Regards,
Edward
From: Mark Lucas [mailto:xxxxxx@xxxxxxxxxxxxxxx.xx.xxx.xx]
Sent: Monday, 23 September, 2019 12:29 PM
To: Cuenca, Edward (EPA) <xxxxxx.xxxxxx@xx.xxx.xx>
Subject: RE: EPA enquiry [DLM=For-Official-Use-Only]
Hi Edward
Please find attached a draft report from RFE Consulting regarding the soil testing we had performed. Could
you please advise if there is anything further that we need to do.
Thank You
Mark
Mark Lucas | Business Manager 27 Sims Rd | PO Box 318 | Mt Barker SA 5251
P: 8391 0411 | F: 8391 2386
www.mtbarkerwaldorf.sa.edu.au
STRENGTH GRACE AND SKILL - FOR LIFE
From: Cuenca, Edward (EPA) [mailto:xxxxxx.xxxxxx@xx.xxx.xx]
Sent: Monday, 9 September 2019 10:18 AM
To: Mark Lucas <xxxxxx@xxxxxxxxxxxxxxx.xx.xxx.xx>
Subject: RE: EPA enquiry [DLM=For-Official-Use-Only]
For Official Use Only
9 September 2019
Hi Mark,
7
In addition to the email below, the EPA requires that chemically contaminated soil must be disposed of
properly in an EPA licenced facility. Depending on the levels of contamination, treatment may be required
prior to disposal. Treatment and/or disposal activities are undertaken by the facility that you chose to
engage with.
Please direct all your enquiries to me with regards to this matter. I’m more than happy to respond any of
your questions.
Regards,
Edward
Edward Cuenca Senior Adviser (Waste) Assessment
Regulation | Compliance
Environment Protection Authority
Phone #: (08) 8204 2004
GPO Box 2607 Adelaide SA, 5001 Australia
This email message may contain confidential information, which also may be legally privileged. Only the intended recipient(s) may access, use, distribute or copy this
email. If this email is received in error, please inform the sender by return email and delete the original. If there are doubts about the validity of this message, please
contact the sender by telephone. It is the recipient’s responsibility to check the email and any attached files for viruses. From: Kiley, Tania (EPA)
Sent: Wednesday, 4 September, 2019 4:25 PM
To: 'xxxxxx@xxxxxxxxxxxxxxx.xx.xxx.xx' <xxxxxx@xxxxxxxxxxxxxxx.xx.xxx.xx>
Cc: Thomas, Shaun (EPA) <xxxxx.xxxxxx@xx.xxx.xx>
Subject: EPA enquiry [DLM=For-Official-Use-Only]
For Official Use Only
Dear Mark
The EPA is in receipt of your email. An officer will contact you about the potential soil contamination as
soon as possible.
In regards to the chemical disposal, the EPA is not able to recommend who accepts the waste though the
education department or school should have preferred waste disposal contractors for disposal of such
wastes (or wastes generally). I suggest that you make contact with them in the first instance and if they
can’t accept the wastes they should be able to point you in the right direction. It is best to contact them
directly as different companies will accept different wastes at different times depending on capacity.
8
Regards
Tania
Tania Kiley Principal Adviser Assessment
Regulation | Compliance Branch
Environment Protection Authority
Work Phone (08) 820 41753 Work Fax (08) 8124 1463
211 Victoria Square Adelaide 5000
This email message may contain confidential information, which also may be legally privileged. Only the intended recipient(s) may access, use, distribute or
copy this email.
From: Mark Lucas <xxxxxx@xxxxxxxxxxxxxxx.xx.xxx.xx>
Sent: Wednesday, 4 September, 2019 3:31 PM
To: EPA:Information <xxxxxxxxxxxxxx@xx.xxx.xx>
Cc: Helen Platell <xxxxxxxx@xxxxxxxxxxxxxxx.xx.xxx.xx>
Subject: Advice on Incident
To Whom it May Concern
There are two issues that we would like advice on and if required who it should be reported to:
1. An investigation into an incident during a science experiment has revealed that water, that melted lead
from roof flashing has been poured into, has been poured onto a garden bed at the conclusion of the
experiment. The investigation further revealed that this has been happening for approx. 15 years.
2. The same person was also responsible for ensuring that the chemicals/substances used were correctly
labelled and stored which was also not occurring. There are some containers with no label (eg: jam jars,
bottles etc) and we are unsure as to how they should be disposed of. Attached is a list, including quantities,
of what we have been able to identify and we would like to know where/how they can be disposed of.
As a result of the above situations we have had the soil in the area tested and we are currently awaiting the
test results. We also want to dispose of all chemicals that were being used in the science lab and start afresh
ensuring that the person who is now responsible for the lab adheres to the requirements for labelling,
handling and storage of such items.
Thank You for any assistance you are able to provide.
Regards
9
Mark Lucas | Business Manager 27 Sims Rd | PO Box 318 | Mt Barker SA 5251
P: 8391 0411 | F: 8391 2386
www.mtbarkerwaldorf.sa.edu.au
STRENGTH GRACE AND SKILL - FOR LIFE
10
RFE0048 - Mt Barker Waldorf School
Soil Classification of Surface Soils Outside Science Centre
Soil Classification Summary Table
In--situ assessment
Heavy Metals
e
#
ID
h
m
m
LE
istur
iu
iu
P
er
o
Batc
m
m
p
M
M
senic
ro
p
ate
ercury
c
ickel
SA
Lab
D
%
Ar
Cad
Ch
Co
Lead
M
N
Zin
Waste Fill* (mg/kg)
20
3
400#
60
300
1
60
200
Intermediate** (mg/kg)
200
30
12%#
2,000
1,200
30
600
14,000
Intermediate leachate (AS4439.3-1997) (mg/L)
5
0.1
-
10
5
0.1
2
250
BH01_0.0
673774
27-Aug-19
12
3
< 0.4
21
39
13
< 0.1
5.7
33
BH02_0.0
673774
27-Aug-19
27
3.1
1.1
24
19
15
< 0.1
10
300
BH03_0.0
673774
27-Aug-19
17
5.6
< 0.4
49
110
23
< 0.1
10
92
BH04_0.0
673774
27-Aug-19
22
3.2
< 0.4
20
15
12
< 0.1
< 5
42
BH05_0.0
673774
27-Aug-19
23
6.1
0.6
34
18
24
7.6
8.4
57
BH06_0.0
673774
27-Aug-19
15
6.4
< 0.4
90
9.9
18
0.6
5.8
21
BH07_0.0
673774
27-Aug-19
32
3.9
< 0.4
20
9.7
13
0.2
5.3
22
QA/QC
Intra-laboratory duplicate samples
BH02_0.0
673774
27-Aug-19
27
3.1
1.1
24
19
15
< 0.1
10
300
DUP B
673774
27-Aug-19
26
3.1
1.2
25
20
16
< 0.1
10
370
Relative Percentile Difference (%)
3.8
0.0
8.7
4.1
5.1
6.5
0.0
20.9
DRAFT
Equipment Rinsate Blank
RB01
673774
27-Aug-19
-
<0.001
<0.0002
0.001
<0.001
<0.001
<0.0001
<0.001
<0.005
* - Waste Fill criteria as defined in Part 1 of the
Environment Protection Regulations (2009)
** - Intermediate criteria as set out in SA EPA (2010) Current criteria for classification of waste
# - Criteria for Chromium III adopted
