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Assessing a Former Sheepdip Site Associated with Natural Mineralisation: A Case Study
Hugh Crawley, Gutteridge Haskins and Davey Pty Ltd; Daniel Walters, Environment ACT, ACT Dept of Urban Services; Bengt von Schwerin, Earthsciences Pty Ltd; Norm Bateson, Reengineering Australia EXECUTIVE SUMMARY During the late 1990s, the ACT government and community groups became aware that urban development in all areas of Canberra had encroached on the sites of a number of former sheepdips. The primary chemicals of concern associated with sheepdips are arsenic and organochlorine based. The Department of Urban Services carried out a rigorous study of records and identified a number of sites where houses had been built at the former location of sheepdips. These sites were prioritised, investigated, assessed and, where required, remediated. During the first stage of sampling and analysis of one of these sites, more elevated concentrations of arsenic were identified. In accordance with established policy, the government offered to buy out the affected properties. Further investigation revealed that the concentrations were more wide spread and not related to proximity to the clearly identified former sheepdip. A review of the broader data available from the computer information obtained during the screening for arsenic and organochlorines showed that the elevated levels of arsenic were associated with commensurate elevated levels of other analytes. Examination of the distribution of the analytes and the nature of the soils in the area confirmed that naturally occurring mineralisation underlay the investigation site. Lead became the principal element of concern for potential health and environmental impacts. After review by the Scientific Expert Advisory Group, the site was given a Clean Bill of Health. The Scientific Expert Advisory Group was formed by the Government to advise the Minister on all matters relating to the risks, presented by the Site, to human health and to the environment. The Scientific Expert Advisory Group included experts in toxicology, geology, hydrogeology, geochemistry, soil science, community health, risk assessment and a representative of the affected community. As well as the community representative and the principal consultant, the invited members were drawn from: the National Research Centre for Environmental Toxicology, Australian Geological Survey Organisation; Actew Corporation; Centre for Australian Regolith Studies, Australian National University; CSIRO; and the ACT Department of Health and Community Care. The authors draw a comparison with the current approach where statutory audits are conducted by Environmental Auditors, Contaminated Sites. This paper describes the site assessment process, the health risk assessment and the methods used to keep the affected community informed and involved during the project.

KEY WORDS Contamination, Sheepdip, Expert Group, Mineralisation, Community Consultation, Arsenic, Risk Assessment INTRODUCTION Canberra is generally little affected by contamination of soil as, after European settlement, the land has been used predominantly for grazing purposes before development as the National Capital. Canberra has grown in a planned manner with the objective of having best practice standards. There is little heavy industry or processing likely to leave a legacy of contamination. The region is suitable for prime fine wool production. Early politicians have described Canberra as being a good sheep farm ruined. Before the advent of pour-on systems, husbandry of sheep flocks included the control of external parasites, such as lice, ked, itch mite and similar, traditionally through dipping or spraying using persistent chemicals, including arsenic, phenolic and organochlorine based pesticides. Canberra has a unique system of land tenure with the Government owning the land and leasing it for periods up to 99 years. The successive governments have been the owner, developer, marketer, and local council for all land. In the lead up to the 1996 Territory elections, proposed planning changes to encourage infill development of a number of identified sites were debated strongly by the community and candidates. One of these sites contained a former, but still existing, sheepdip which received prominence in the debate. Preliminary investigation of this structure and its surround revealed concentrations of arsenic and organochlorine based pesticides well in excess of the guidance values contained in tables published by ANZECC/NHMRC in Australian and New Zealand Guidelines for the Assessment and Management of Contaminated Sites (1992). It was clearly apparent that similar concentrations could have remained, or have even been spread, during the development of Canberra and that there could be hazards to health and the environment at these locations. An urgent but thorough investigation of all information, particularly: anecdotal; survey and land tenure plans; and a comprehensive sequence of aerial photographs, showed that throughout the ACT there have been in excess of 100 sheep dips. Less than 20 of these were in the urban area with 13 being in residential locations. The numbers of sheepdips included lined or unlined plunge dips from as early as the late 1800s and more recent spray dips. On some farms more than one sheepdipwas used. The pesticides used have also included organophosphate and pyrethroid based solutions but these are short lived in the environment. As well as the health and environmental hazards presented by the sheepdips, the Government recognised that property values would be adversely impacted for those leases containing, or near to, an identified former sheepdip. The Government also recognised that those people involved would be subject to anxiety arising from the perceived involuntarily risks they were being exposed to. The approach should quickly and expertly identify the properties and individuals at risk and have a clear strategy for minimising the anxiety. To this end the Government established the Contaminated Sites Unit to be the single point of contact and responsibility. A single point of contact community liaison officer and clear information for eachresident was provided. The strategy included: a detailed program of assessment; sampling and

analysis using recognised consultants selected for their expertise and ability to provide best value for money advice in assessment and risk analysis; and remediation at Government expense of those properties that were suitable. In some instances, where demolition was likely, this included government purchase of properties demonstrated to be affected. The program included 12 sheepdip sites and was well advanced when a thirteenth site was identified. This paper describes the issues associated with the thirteenth site after relatively routine operations were established through the investigation and management of the previous sites. APPROACH TO RISK MANAGEMENT Discovery During a second look at the records, including a lengthy study of the maps and aerial photos held by the Department, in November 1995, the Contaminated Sites Unit became aware of the former sheep dip at the Case Study Site (Site). There were apparently two dip structures built at this site. One was a plunge dip built in the 1950s and the subsequent dip was a spray dip. The ACT Legislative Assembly Standing Committee on Planning and the Environment had independently been told of the Site during its enquiry. Investigation Staging Investigation of the sheep dip was started as a matter of urgency. The site was added as a variation to a contract that was in the field at that time. Investigation commenced in November 1995 as soon as sampling plans could be developed and the variation approved. The investigation was conducted according to the principles contained in the Australian and New Zealand Guidelines for the Assessment and Management of Contaminated Sites (1992). The core of these Guidelines is Site Specific Risk Assessment where each site is considered independently. The risk to human health, the environment, and to other beneficial uses is considered. Management of a proven contaminated site can vary from site to site and is dependent on the land use and off site effects. The sampling was carried out in three stages. Based on the experience gained from the previous investigations of sheepdip sites, the first stage covered an area of land which was typical of the extent of any effects found at other typical sites. Analysis of samples was targeted at arsenic and organochlorine based pesticides. Results of the analysis indicated that the concentration of arsenic (the major constituent of early sheep dip formulations) increased at the edge of the investigation area. The investigation area was increased (Stage 2) to try and define the limit of the elevated levels of arsenic. When the results of analysis indicated that levels of arsenic continued to be elevated at the edge of this investigation area, and in view that naturally occurring mineralisation was now suspected, the area was further expanded and investigated (stage 3). Stage 3 also included deep bores in areas of the previous stages where the level of arsenic in the samples was highest. It also included analysis for a suite of other elements. The data from previous stages was extended by obtaining information from the Analytical Laboratory for an extended suite of heavy metals. This information was held on the computer records for the analysis but had not been reported as it was not requested in the request for analysis.

Figure 1

Figure 1 shows the distribution of arsenic concentration on the surface. The figure also shows the street locations and the boreholes. Attachment A summarises the findings of all stages of sampling and analysis, for up to seven heavy metals, of 1500 samples from 450 boreholes. Stage 3 provided conclusive information that the concentrations found were not typical of sites contaminated by sheep dip operations and were most likely caused by naturally occurring mineralisation. The effect of the former sheep dip could not be identified. Concerns The Contaminated Sites Unit responded to two types of concern: the expressed concern, where actions were targeted to answer particular issues raised by residents; and anticipated concern, where actions were taken proactively ahead of future concerns. The main areas of potential concern which were considered were: effects on population health; effects on environmental health; and effects on property values. Addressing all of these concerns was difficult and a number of strategies were employed. Calculations The Consultants carried out a detailed health risk assessment based on the information obtained from the field investigation, the study into biotoxicity of the soils in the study area and the current and potential uses of the land. The health risk assessment was one of the inputs considered by the Scientific Expert Advisory Group. Other studies were conducted to try to distinguish between sheep dip and natural concentrations of substances. Following these studies the Scientific Expert Advisory

Group concluded: It is not possible to categorically distinguish between arsenic arising from the sheep dip activities or that which is naturally associated with the rocks and soil. However, from a public health perspective, the source of the arsenic is not relevant, whether it is from sheep dip or natural sources. The Scientific Expert Advisory Group also concluded, based on the extensive available information (including concentration, bioavailability, toxicity, the Acceptable Daily Intake for metals, and urine and blood testing), there is no evidence that the sheep dip site and the gossan underlying the investigation area has posed, or poses, a public health risk. Certainties & Uncertainties The findings of the study of the Site are based on information obtained from the analysis of samples and from a risk assessment protocol which has been developed to consider population health. Compare with criteria Of the metals investigated, only arsenic, lead, zinc and chromium were found to exceed the proposed health investigation levels published by ANZECC (1992) and Imray and Langley (1996). This finding caused some concern until the full methodology of the guideline was used. However, modifying the assumptions made in setting the investigation levels by including site specific factors, the Scientific Expert Advisory Group reported that heavy metals such as those found in the study area commonly bind strongly to soil particles and any introduced additions typically concentrate in the surface horizons where they were added. The bioavailability of arsenic and lead in the soil samples from the Site has been determined by animal studies and found to be low. Under the present environmental conditions the arsenic present in its natural form is held within the rocks and soil and is unlikely to become more readily bioavailable. Control The most positive strategy for managing risk is to control the risk. At this Site this involved gaining an understanding of the nature of all risks which might be presented, acting on the high priority items and restricting any hazardous activities. In order to understand the risks, the government formed the Scientific Expert Advisory Group to advise it. Early in the investigation, before all scientific information was available and when community outrage was at its highest, the Government took action to restrict any hazardous activity by taking the precautionary step of buying out some residents living on affected properties and allowing them to move to new properties. When the government had sufficient scientific information to confirm that the concentrations of the heavy metals would not present a risk to the health of the population, all offers which had not been taken up were withdrawn.

SCIENTIFIC EXPERT ADVISORY GROUP Because the findings of all stages of investigation indicated that concentrations of a number of substances were above the investigation levels contained in the Australian and New Zealand Guidelines for the Assessment and Management of Contaminated Sites Contaminated Sites Unit sought expert independent opinion to advise it and to consider the hypothesis that the source of the contamination may have been from other than a sheep dip. Following advice to the Contaminated Sites Unit from a range of experts, the Minister for the Environment, Land and Planning, Mr Gary Humphries, thought it advisable to invite these experts and others together as a group to critically review all the scientific information available and to advise him on the actions which the Government should take to fully consider the risks to residents in the area. The Expert Group included representatives nominated by the residents of the Site. The Expert Group was asked to consider two focus questions: initially finally How do we go about determining the risk to Canberra residents of living near sites where significant quantities of arsenic are present?; and Based on the outputs of the tasks the Scientific Expert Advisory Group recommended, can the Group now determine the risk to residents of living near, or on, a site where significant quantities of arsenic and other heavy metals are present?

The Scientific Expert Advisory Group made recommendations for a number of actions, including that the investigation be expanded to include other parameters in the exposure equation. Selected samples were chosen for the National Health and Medical Research Councils National Research Centre for Environmental Toxicology (NRCET) to carry out a study of the biotoxicity of the soils in the area. The findings and recommendations of the Scientific Expert Advisory Group were:
CONCLUSIONS

The Expert group concluded that: Based on the extensive available information (including concentration, bioavailability, toxicity, the Acceptable Daily Intake for metals, and urine and blood testing), there is no evidence that the sheep dip site and the gossan underlying the investigation area has posed, or poses, a public health risk. This conclusion is based on the following findings of the Expert Group: There is a gossan underlying the study area. A gossan is the weathered part of sulphide bearing mineralisation. Gossans are known sources of arsenic and other base metals. They occur throughout the ACT and the south-eastern region of Australia. The major source of the arsenic at the Site is naturally occurring within the rocks and soil. There is also likely to be arsenic in the soil in some parts of the study area as a result of their earlier use as a sheep dip.

The Expert Group has a general understanding of the content and distribution of the metals across the study area and with depth. The metal concentrations generally increase with depth, which supports the existence of a natural source. Heavy metals such as those found in the study area commonly bind strongly to soil particles and any introduced additions typically concentrate in the surface horizons where they were added. The bioavailability of arsenic and lead in the soil samples from the Site has been determined by animal studies and found to be low. Under the present environmental conditions the arsenic present in its natural form is held within the rocks and soil and is unlikely to become more readily bioavailable. Noting the small number of samples obtained by voluntary contributions with some from an area which contained high levels of arsenic in the soil, home produce (including eggs) showed no elevated levels of arsenic. Samples of other vegetation (e.g. grass, flowers, herbs) showed differing concentrations of arsenic and lead. The result confirms conservative factors used in the health risk assessment. The predictions of the risk assessment are borne out by other analyses which were conducted in the community. For those residents tested: urinary concentrations of arsenic lay within, or marginally above, the normal range for spot testing and none exceeded recommended health action levels 95% of the blood-lead samples were below the NH&MRC objective of 0.48 mol/L (i.e. 10 g/dl) and none were above the health action level of 1.2 mol/L (i.e. 25 g/dl) of the nine children (i.e. <16 years old) resident on the study area all had bloodlead levels less than or equal to half of the NH&MRC objective. There is no overall excess of cancer in the postcode area compared to the ACT as a whole. Of the metals investigated only arsenic, lead, zinc and chromium were found to exceed the proposed health investigation levels published by ANZECC (1992) and Imray and Langley (1996). The proposed health investigation levels for chromium and zinc were exceeded in four soil samples and one soil sample, respectively. It is not possible to categorically distinguish between arsenic arising from the sheep dip activities or that which is naturally associated with the rocks and soil. However, from a public health perspective, the source of the arsenic is not relevant, whether it is from sheep dip or natural sources. There is little evidence that the former sheep dip site has contributed significantly to the distribution of arsenic in the investigation area. This conclusion is supported by the distribution of other metals which have been linked to a natural origin.

The assessment of risk, presented by soils in the study area, to human health uses the same risk assessment framework irrespective of whether the risk being considered is from substances introduced by man or occurring naturally. There is no evidence from urine and blood tests of any adverse effect on human health from arsenic or lead within the study area. Recommendations The Expert Group recommended that, in light of the findings of the recent investigations: the Government could state that the Site is suitable for residential purposes; and no ongoing site or health monitoring is required. However, if requested by concerned residents, the Expert Group recommended that the Government give sympathetic consideration to any requests for health monitoring and testing home grown produce. Communication The communication with all the participants was complex. It involved identification and notification of, and feedback to, participants together with appropriate documentation. This case was particularly vexed as, at the outset, there was insufficient information to make scientifically based decisions while, at the same time community outrage was at its highest. The Contaminated Sites Unit Community Liaison Officer has provided a continuing link between the residents and the Department providing many services and information. Acceptance The residents representative accepted the findings of the Scientific Expert Advisory Group on behalf of the affected community. There have been a number of public statements by residents expressing their pleasure that the Site is not a contaminated site. In one instance where anxiety levels remained, the CSU has provided ongoing services such as independent counselling in an attempt to resolve the concerns. COMPARISON WITH CONTAMINATED SITES AUDITOR APPROACH At the time that this investigation was conducted, the ACT had no contaminated sites legislation or process for independent expert review of the investigation, assessment, remediation and validation of land contamination. The issues and concerns presented by this Site required a broad range of expertise not normally expected of any individual or organisation. The Victorian EPA was developing its Contaminated Sites Auditor strategy and this was gaining credibility. The Expert Group approach provided a wider range of expertise, an opportunity for community representation in the debate and the associated sharing of information that this multi site, residential challenge presented. The standing of Environmental Auditors, Contaminated Sites, has grown since this project and the issue of certificates and statements has regulatory standing. The Expert Group worked well in this case and would be a useful mechanism to complement the Auditor in complex circumstances.

CONCLUSION The level of understanding of contamination issues has advanced. The National Environment Protection Measure, the Australian Standard Guide to the sampling and investigation of potentially contaminated soil Parts 1 and 2 and a number of environmental policies and specific guidelines now provide greater certainty to the process. The ACT now has Contaminated Sites regulation through the Environment Protection Act 1999 and Planning Authorities have planning policies which require certificates or statements of environmental audit. The Case Study Site was successfully managed, from the initial lack of knowledge and the anxiety this raised for the affected people through to understanding and acceptance. The homes that were bought out were effectively returned to the market and confidence in the suburb has returned. The lessons learned included: Involve the affected people as individuals in collaboration from the outset. Use recognised and accepted frameworks and guidelines. Develop and communicate a common awareness of the process, the potential for risk, the approval processes, timing and the costs. Honesty in dealings, listening to concerns, explain the findings, research all potential options. Use the best independent expert advice. Recognise that the cause being investigated is not the only possible source of contaminants, specialised investigation such as speciation and toxicology provides telling information. Devote resources, time and money to dealing with the people. Provide politicians and other decision makers with frank and fearless advice, particularly about the time things take. Ensure clear information for each resident. ACKNOWLEDGEMENTS The authors wish to thank the ACT Government and their employers for giving permission to publish this paper. We acknowledge the input of the experts who contributed to the study and the residents who were involved during the study. REFERENCES In keeping with agreements made with residents, this paper does not refer to the location of the Case Study Site or any report containing the location. This paper is based on the findings of the Scientific Expert Advisory Group, the consultants contributing to the study, the ANZECC/NHMRC and other references current at 1995/96.

CONTACT Hugh Crawley Gutteridge Haskins and Davey Pty Ltd (GHD) 02 6245 1917 02 6253 1911 [email protected]

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SHEEP DIP INVESTIGATION Comparison of Concentrations of Analytes in Soil (Read in association with the individual plots for each analyte and depth) Attachment A

WARNING All contours are the computer generated interpolation of the available data and should be interpreted with caution. All interpretation beyond the bore holes is unreliable.