The Environment Protection Authority (EPA) draft revised Excavated Natural Material Resource Recovery Exemption (ENM Exemption) is attached. The draft contains a number of welcomed amendments to the ENM exemption including:
- Reduced sampling frequency for smaller volume materials
- Removal of chlorinated hydrocarbons
- Changes to metals and pH levels
- Introduction of individual BTEX concentrations
- Use of hot spot separations for in-situ sites
ASBG has prepared a submission which asks for faster and lower cost assessment of ENM materials at smaller quantities, i.e. < 500t. Recommended approaches include
- On-the-spot testing by human senses and field testing equipment
- Use of a reduced set of chemical testing where history can demonstrate certain tests are not required
- Use of third parties to undertake on-the-spot testing for smaller ENM quantities
- Use of maps to identify areas where certain testing must be undertaken and others where less testing is needed
- A scientific testing criteria for asbestos