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Information paper No. 5: Second edition
Department of the Environment and Heritage, October 2002
This paper replaces the first edition of Information Paper No. 5, published in August 1998, and the Update that was published in May 2001. It clarifies the requirements of the Hazardous Waste Act.
1. The Department of the Environment and Heritage is responsible for the implementation and administration of the Hazardous Waste (Regulation of Exports and Imports) Act 1989 (the Act). The Act implements Australia's obligations under the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal.
2. This paper has been prepared by the Department of the Environment and Heritage on the basis of advice from the Hazardous Waste Technical Group. The Group was established under the Act to provide advice to the Minister on the operation of the Hazardous Waste Act and related issues arising from Australia's implementation of the Basel Convention.
3. This paper is current as at August 2002 and updates and replaces all earlier guidance documents relating to whether wastes containing metals or metal compounds are regulated under the Act. While all reasonable efforts have been made to ensure the information contained in this paper is correct, the Commonwealth accepts no responsibility for its accuracy or completeness and the paper does not replace or supersede the provisions of the Act. Any suggestions on the content or clarity of the paper are welcome.
4. If you require further information on the Act, or this paper, please phone 02 6274 1411, facsimile 02 6274 1164 or email hwa@environment.gov.au.
Metal-bearing wastes are considered to be hazardous wastes if they contain antimony, arsenic, beryllium, cadmium, lead, mercury, selenium, tellurium or thallium (the "Basel metals") in concentrations that may damage human health or the environment.
The Department of the Environment and Heritage uses two tests to determine whether a particular waste contains hazardous concentrations of these metals. One test determines whether the waste is likely to release metals into the environment, while the other is designed to protect human health in the workplace. For a waste to be considered non-hazardous, it must pass both tests, as described in Part A.
Part B contains four specific examples.
Part C describes the technical rationale for the tests.
5. The object of the Act is to ensure that human beings and the environment, both within and outside Australia, are protected from the harmful effects of hazardous waste. Among other things, the Act regulates wastes containing any of the following nine metals and their compounds:
6. These may be referred to as Basel metals because they are regulated under the Basel Convention. All wastes that contain Basel metals are presumed to be hazardous unless they do not possess any of the hazardous characteristics listed in the Act and the Convention. The purpose of this paper is to explain how a particular waste, containing Basel metals, may be classified as hazardous or non-hazardous.
7. The paper is divided into three parts. Part A describes how to answer four questions to classify a waste that contains Basel metals or metal compounds. Part B contains four specific examples. Part C explains the technical rationale for selecting the particular tests and values used in Part A.
8. The Act also regulates wastes containing other metal compounds, namely:
Wastes containing these compounds are not considered in this paper and separate advice should be sought from the Department of the Environment and Heritage.
9. Note that hazardous wastes must not be diluted or mixed with other materials merely to reduce the concentration of Basel metals below the levels specified in this paper.
A decision tree, summarizing the four questions to determine whether a waste is or is not hazardous, is shown in Figure 1.
Figure 1. Decision tree
Question 1. Is the waste a specified metal waste listed in Table 1?
10. The Act does not regulate the metal wastes that are listed in Table 1 (unless they contain other hazardous materials).
TABLE 1. Specified metal wastes that are not regulated under the Act
Clean, uncontaminated metal scrap, including alloys, in bulk finished form (sheet, plate, beams, rods, etc) of:
|
| Galvanising slab zinc top dross (>90% Zn) conforming to the specification for continuous line galvanising slab zinc top dross, described as "Seal" by the Institute of Scrap Recycling Industries of the United States (ISRI), as modified below: "Shall consist of unsweated zinc dross removed from the top of a continuous line galvanising bath, in slab form with a minimum zinc content of 90 %. Shall be free of skimmings. Broken pieces under 5 cm in diameter shall not exceed 10 % of the weight of each shipment." |
| Galvanising slab zinc bottom dross (>92% Zn) conforming to the specification for continuous line galvanising slab zinc bottom dross, described as "Seam" by the Institute of Scrap Recycling Industries of the United States (ISRI), as modified below: "Shall consist of unsweated zinc dross removed from the bottom of a continuous line galvanising bath, in slab form with a minimum zinc content of 92 %. Shall be free of skimmings. Broken pieces under 5 cm in diameter shall not exceed 10 % of the weight of each shipment." |
| Zinc die casting dross (>85% Zn) conforming to the specification for prime zinc die-cast dross, described as "Shelf" by the Institute of Scrap Recycling Industries of the United States (ISRI), as modified below: "Shall consist of metal skimmed from the top of pot of molten zinc die-cast metal. Must be unsweated, unfluxed, shiny, smooth, metallic and free from corrosion or oxidation. Should be poured in moulds or in small mounds. Zinc shall be a minimum of 85 %. Broken pieces under 5 cm in diameter shall not exceed 10 % of the weight of each shipment." |
| Hot dip galvanisers slab zinc dross (batch) (>92 % Zn) conforming to the specification for hot dip galvanisers slab zinc dross (batch process), described as "Scrub" by the Institute of Scrap Recycling Industries of the United States (ISRI), as modified below: "Shall consist only of galvanisers unsweated zinc dross in slab form from hot dip galvanising (batch process) with a minimum zinc content of 92 % and shall be free of skimmings and tramp iron. Broken pieces under 5 cm in diameter shall not exceed 10 % of the weight of each shipment. Material from continuous galvanising operation is not acceptable." |
Question 2. Does the concentration of any Basel metal exceed the threshold value in Table 2?
11. Measure the concentration of each metal in the waste and compare the results with the threshold values in Table 2. If the concentrations of all Basel metals do not exceed the threshold values in Table 2, the waste is considered non-hazardous as far as the Basel metals are concerned and no further tests are necessary. If the concentration of any one Basel metal exceeds the threshold value, the waste may be hazardous and further analysis is required.
12. Advice on correct sampling procedures and dealing with variability in results should be sought from the Department of the Environment and Heritage
TABLE 2: Threshold values for Basel metals. Wastes are considered non-hazardous if concentrations do not exceed these values.
| Threshold value (mg/kg) | |
|---|---|
| Antimony | 6 |
| Arsenic | 14 |
| Beryllium | 14 |
| Cadmium | 4 |
| Lead | 20 |
| Mercury | 2 |
| Selenium | 20 |
| Tellurium | See note 1 |
| Thallium | 6 |
Note 1.
Threshold values have not been set for tellurium, for reasons described in Part C. Advice on waste containing tellurium should be sought from the Department of the Environment and Heritage.
Question 3. Does the concentration of any Basel metal exceed the maximum value in Table 3?
13. If the concentration of any Basel metal exceeds the maximum value in Table 3, the waste is considered hazardous and no further tests are necessary.
TABLE 3: Maximum values for Basel metals (see note 1). Wastes are considered hazardous if concentrations exceed one or more of these values.
| percent (w/w) | mg/kg (see note 2) | |
|---|---|---|
| Antimony (see note 3) | 0.25 | 2,500 |
| Arsenic | 0.3 | 3,000 |
| Beryllium | 0.1 | 1,000 |
| Cadmium (see note 3) | 0.1 | 1,000 |
| Lead (see note 3) | 0.5 | 5,000 |
| Mercury | 1.0 | 10,000 |
| Selenium | 1.0 | 10,000 |
| Tellurium | See note 4 | See note 4 |
| Thallium | 0.1 | 1,000 |
Note 1.
Where the National Occupational Health and Safety Commission (NOHSC) has published a different value for a particular metal compound, that value should prevail over the general value listed here. The full list published by NOHSC may be found at http://www.nohsc.gov.au/ohsinformation/nohscpublications/fulltext/techreports/nohsc10005_02.htm
Note 2.
Measurements may be expressed either on a dry weight or wet weight basis, depending on the nature of the material.
Note 3.
Values have been set by NOHSC for compounds of antimony, cadmium and lead, but not for the elements themselves. For present purposes, the values set for most compounds have also been applied to concentrations of the elements themselves.
Note 4.
Values have not been set by NOHSC for tellurium or tellurium compounds. Advice on waste containing tellurium should be sought from the Department of the Environment and Heritage.
Question 4. Does the concentration of any Basel metal in leachate exceed the maximum leachate value in Table 4?
14. If the concentrations of Basel metals lie between the threshold values in Table 2, but do not exceed the maximum values in Table 3, the waste is presumed to be hazardous. However, the Department of the Environment and Heritage may re-classify the waste as non?hazardous if leaching tests demonstrate that the metals are unlikely to leach out of the waste in hazardous concentrations.
15. A waste may be classified as non-hazardous, as far as Basel metals are concerned, if the concentrations of metals in the leachate do not exceed the leachate trigger values in Table 4.
16. For the leaching test, Australian Standard AS 4439.3-1997 (Standards Australia 1997), class 3a, should be used. An acceptable alternative is the Toxicity Characteristic Leaching Procedure (TCLP), which is generally used by Australian States and Territories to determine how a waste should be managed. The TCLP is based on the test promulgated in 40CFR (US Code of Federal Regulation), part 261, Appendix II, and is incorporated as test method 1311 in the "Test Methods for Evaluating Solid Waste Physical Chemical Methods", SW-846.
17. Advice on correct sampling procedures and dealing with variability in results should be sought from the Department of the Environment and Heritage.
TABLE 4. Maximum leachate values for Basel metals. Wastes are considered hazardous if the concentrations of one or more metals exceed these values.
| Maximum Leachate Value(mg/L) | |
|---|---|
| Antimony | 0.3 |
| Arsenic | 0.7 |
| Beryllium | 0.7 |
| Cadmium | 0.2 |
| Lead | 1 |
| Mercury | 0.1 |
| Selenium | 1 |
| Tellurium | See note 1 |
| Thallium | 0.3 |
Note 1.
Maximum permitted levels have not been set for tellurium, for reasons described in Part C. Advice on waste containing tellurium should be sought from the Department of the Environment and Heritage.
18. Four mining residues, A, B, C and D, contain arsenic, cadmium, lead, mercury and selenium. Each one may be classified as hazardous or non-hazardous using the process described in this paper.
Overall approach
19. The Department of the Environment and Heritage uses two types of tests to determine whether a particular waste contains hazardous concentrations of Basel metals. One type of test determines whether the waste is likely to release metals into the environment, while the other is designed to protect human health in the workplace. For a waste to be considered non-hazardous, it must pass both tests.
20. Wastes containing metals or metal compounds have the potential to release them into the environment, where they may cause damage to human health and ecosystems. This is most likely to occur if the waste comes into contact with liquids and generates toxic leachate. Such contact with liquids may occur, for example, if waste is spilt during handling or in transport accidents, or if storage sheds are damaged, or if waste is stored in the open, or if waste is disposed of, with or without other wastes, in a landfill. The potential to generate toxic leachate is estimated by using a leaching test, as described below.
21. Wastes containing metals or metal compounds also have the potential to damage human health through exposure in the workplace and the National Occupational Health and Safety Commission (NOHSC) has set concentration cut-off levels in the List of Designated Hazardous Substances (NOHSC:10005,1999).
22. The first step in the overall approach adopted by the Department of the Environment and Heritage is to exclude the specified metal wastes listed in Table 1. The Parties to the Basel Convention have agreed that these wastes are not regulated under the Convention.
23. The second step is to determine whether the waste contains so little metal that it will always pass a leaching test. The test uses 20 ml of leaching fluid per gram of waste so if, for example, a waste contains 20 mg/kg lead and it all leaches out, the concentration of metal in the leachate would be 20 mg per 20,000 ml, or 1 mg/L. That is, the concentration of lead could not exceed the maximum leachate value in Table 4. This calculation is the basis of the threshold values in Table 2.
24. If the concentration of metal exceeds the threshold values in Table 2, the next step would be to carry out a leaching test. However, this would not be worthwhile if the waste passed the test but was still regulated under the NOHSC concentration cut-off levels. So the third step is to determine whether the waste contains so much metal that it would be designated as hazardous in the workplace because it exceeds the maximum values in Table 3.
25. If the concentrations of metals fall between the threshold and the maximum values in Tables 2 and 3, the waste is presumed to be hazardous unless it passes a leaching test. It is necessary to choose which leaching test and which leachate trigger values to use, and this is discussed in the remainder of this paper.
Choosing a leaching test
26. The rationale for the leaching test is that it must ensure that human health and the environment are protected under a realistic worst-case scenario. Since metals leach more readily in acidic environments, this scenario is that wastes may be spilt, stored or disposed of in an acidic environment. Leaching tests are most commonly used to manage wastes that are to be disposed of in landfills, where a combination of water and organic matter can create acidic conditions. However, wastes can also come into contact with acidic environments if they are spilt or stored. Just within Australia, for example, wastes could encounter:
27. Use of an acid leachate also ensures that the leaching tests used by the Commonwealth under the Act are at least as stringent as the leaching tests used by State and Territory Governments to manage wastes within Australia. This is important because the Australian Government has obligations, under Articles 8 and 9 of the Basel Convention, to take waste back and dispose of it in Australia if it cannot be processed as planned or was exported illegally. Under the Act the Minister can meet these obligations by ordering exporters to take hazardous waste back and dispose of it in Australia. The Minister may also make similar orders in respect of hazardous waste that was imported illegally. Making these orders may not be possible if a waste is defined as hazardous by the relevant State or Territory, but not by the Commonwealth under the Act.
28. For these reasons, Australian Standard AS 4439.3-1997 (Standards Australia 1997), class 3a, should be used, or the Toxicity Characteristic Leaching Procedure (TCLP), as described in paragraph 17.
29. Maximum permitted concentrations for metals in leachate may be set in relation to specified water quality criteria after making allowance for dilution and attenuation. Leaching tests are generally used in conjunction with a Dilution and Attenuation Factor (DAF) of 100, based upon modelling that indicates that leachate from a landfill will generally be diluted and attenuated about 100 times at the closest likely point of extraction of groundwater.
Choosing maximum leachate values
30. Maximum leachate values may be set by reference to water quality criteria to protect either drinking water, or aquatic ecosystems, or both. The most recent water quality criteria available for Australia are the guidelines published by NHMRC/ARMCANZ (1996) for drinking water and by ANZECC/ARMCANZ (2000) for protection of aquatic ecosystems. They are set out in Table 5.
Table 5. Australian Water Quality Criteria.
| NHMRC/ ARMCANZ drinking water (mg/L) |
ANZECC/ARMCANZ fresh and marine water (see note 1) | ||
|---|---|---|---|
| fresh water mg/L | marine mg/L | ||
| Antimony | 3 | 9 Sb(III) | 270 Sb(III) |
| Arsenic | 7 | 24 As(III) 12 As(V) |
2.3 As(III) 4.5 As(V) |
| Beryllium | 7 (see note 2) | 0.13 | 0.13 |
| Cadmium | 2 | 0.2 | 5.5 |
| Lead | 10 | 3.4 | 4.4 |
| Mercury | 1 | 0.6 | 0.4 |
| Selenium | 10 | 11 | 3 |
| Tellurium | See note 3 | See note 3 | See note 3 |
| Thallium | 3 (see note 3) | 0.03 | 17 |
Note 1.
ANZECC/ARMCANZ trigger values for slightly to moderately disturbed ecosystems (95% species protection with 50% confidence)
Note 2.
No drinking water guideline has been set by NHMRC/ARMCANZ for beryllium. A drinking water guideline value of 7 mg/L has been estimated here using the Provisional Tolerable Intake of 1 mg/kg/day derived by Di Marco & Buckett (1996) and the formula and assumptions used by NHMRC/ARMCANZ.
Note 3.
Concentration cut-off levels have not been set by ANZECC/ARMCANZ or NHMRC/ARMCANZ for tellurium or tellurium compounds. Advice on waste containing tellurium should be sought from the Department of the Environment and Heritage.
Note 4.
No drinking water guideline has been set by NHMRC/ARMCANZ for thallium. A guideline of 3 mg/L has been estimated here using drinking water values that were developed for a number of thallium salts by Region 9 US EPA. They all lie between 2.6 and 3.3 mg/L and have been rounded off to 3 mg/L.
31. Possible maximum permitted concentrations for Basel metals in leachate, based on the ANZECC/ARMCANZ and NHMRC/ARMCANZ water quality criteria and using a DAF of 100, are set out in Table 6.
Table 6. Possible maximum leachate values for Basel metals, based on the water quality criteria in Table 5.
| NHMRC/ ARMCANZ drinking water (mg/L) |
ANZECC/ ARMCANZ freshwater (mg/L) |
ANZECC/ ARMCANZ marine (mg/L) |
|
|---|---|---|---|
| Antimony | 0.3 | 0.9 | 27 |
| Arsenic | 0.7 | 1.2 | 0.23 |
| Beryllium | 0.7 | 0.013 | 0.013 |
| Cadmium | 0.2 | 0.02 | 0.55 |
| Lead | 1 | 0.34 | 0.44 |
| Mercury | 0.1 | 0.06 | 0.04 |
| Selenium | 1 | 1.1 | 0.3 |
| Tellurium | No value | No value | No value |
| Thallium | 0.3 | 0.003 | 1.7 |
32. To decide which values to use, the Department of the Environment and Heritage considered three principles:
33. All Australian jurisdictions use leachate limits that are based on drinking water criteria and a DAF of 100 to determine how hazardous wastes should be managed. Three jurisdictions (Tasmania, Victoria and Western Australia) already use the NHMRC/ARMCANZ drinking water criteria. Three jurisdictions (the Australian Capital Territory, New South Wales and Queensland) use limits that are based on US EPA leachate values. South Australia uses a mixture of the criteria set by New South Wales and Victoria. The Northern Territory has not formally adopted any criteria for leachate limits.
34. Sound scientific and technical principles underpin both the drinking water and the fresh and marine water quality criteria, but the principles are simpler and better established for the drinking water criteria. They have a simpler end-point, protection of human health, which can be expressed as a single concentration based on extensive scientific information. By contrast, the fresh and marine water quality trigger values are based on more complex derivations. They are based mostly on data from single-species toxicity tests and they are assigned to one of three grades, described as high, moderate or low reliability trigger values, depending on the quantity and quality of the available data. The trigger values are calculated at four different protection levels, 99%, 95%, 90% and 80%, where each level signifies the percentage of species that is expected to be protected. The decision to apply a certain protection level to a specific ecosystem is the prerogative of local managers, but in most cases, the 95% protection level trigger values should apply to slightly to moderately disturbed ecosystems. However, higher or lower protection levels may be applied to reflect local circumstances. It is important to note that the ANZECC/ARMCANZ trigger values are for application to receiving waters and are therefore varied to suit site-specific water quality parameters such as pH and hardness.
35. The question of which maximum leachate values should ensure that both human health and the environment are protected is discussed below for each metal in turn. The fresh and marine water quality criteria are compared with the drinking water criteria
Antimony
36. Two forms of antimony are found in natural water: antimony (III) occurs under moderately oxidising conditions, whereas antimony (V) predominates in highly oxidising environments. Most of the ecotoxicological data are for antimony (III), and hence the trigger values are for antimony (III).
37. A freshwater low reliability trigger value of 9 mg/L was derived for antimony (III) from fish data using an assessment factor of 1,000. (Assessment factors (AF) are arbitrary multipliers that are applied as safety factors when there is uncertainty in the data.) This figure should only be used as an indicative interim working level: collection of more data would assist in revision of this figure.
38. In the absence of sufficient marine data, a marine low reliability antimony (III) trigger value of 270 mg/L was derived using an application factor of 1000, for use only as an indicative interim working level. Caution was advised if the freshwater figure is exceeded because the marine data are more limited.
39. The drinking water criterion for antimony, 3 mg/L, is lower than the trigger values for antimony (III) in fresh and marine waters, and use of the drinking water criteria should therefore ensure that the aquatic environment is also protected.
Arsenic
40. Several forms of arsenic occur in natural waters, depending upon the redox potential and pH, the two most common being arsenic (III) and arsenic (V).
41. For arsenic (III), a high reliability freshwater trigger value of 24 mg/L was derived using the statistical distribution method with 95% protection. For marine waters, an Environmental Concern Level of 2.3 mg/L was derived using an AF of 100. This figure could be adopted as a marine low reliability trigger value, to be used only as an indicative interim working level. Further review at a later revision may produce a more reliable trigger value.
42. For As (V), a freshwater high reliability trigger value of 12 mg/L was calculated using the statistical distribution method with 95% protection. This figure is above the chronic NOEC for one of the more sensitive algal species but was considered sufficiently protective for slightly-moderately disturbed ecosystems. There were insufficient data to derive a reliable marine trigger value. A low reliability marine trigger value of 4.5 mg/L for As (V) was derived using an AF of 200 on the lowest NOEC (No Observable Effect Concentration) (200 was used because the limited data were chronic). This should be used only as an indicative interim working level.
43. The drinking water criterion for total arsenic, 7 mg/L, is lower than the high reliability trigger values for freshwater of 12 and 24 mg/L for As(V) and As(III) respectively. However, it is higher than the low reliability trigger values for marine waters of 2.3 and 4.5 mg/L for As (III) and As (V) respectively. Use of the drinking water criterion should protect biota in freshwaters but may not be protective of the marine environment, for which there are few data available.
Beryllium
44. The acute toxicity of beryllium to freshwater fish is dependent on water hardness, with higher toxicity in soft water. Few acute data are available, however, and no chronic tests have been conducted with freshwater fish. Based on these limited data, an Environmental Concern Level of 0.13 mg/L has been suggested for beryllium using an assessment factor of 1000. This figure should only be used as an indicative interim working level. There were no marine data.
45. The drinking water criterion for beryllium, 7 mg/L, is much higher than the environmental concern level of 0.13 mg/L. Use of the drinking water criterion may not ensure that the freshwater environment is protected, but the available data for the freshwater environment are limited.
Cadmium
46. A total of 73 chronic data points were available for cadmium and were used to derive a high reliability freshwater trigger value of 0.2 mg/L for cadmium using the statistical distribution method at 95% protection. This figure applies to a low hardness of 30 mg/L as CaCO3.
47. A total of 175 chronic data points comprising 8 taxonomic groups, were available for cadmium in the marine environment. A high reliability marine guideline trigger value for cadmium of 5.5 mg/L was calculated using the statistical distribution method with 95% protection. Although the 95% protection level is used in Table 5, ANZECC/ARMCANZ recommended that the 99% protection level of 0. mg/L be used for slightly to moderately disturbed ecosystems to take bioaccumulation into account.
48. The drinking water criterion for cadmium, 2.0 mg/L, is higher than the trigger value for cadmium in freshwater, 0.2 mg/L, and higher than the 99% protection level value of 0.7 mg/L that ANZECC/ARMCANZ recommended for use in marine waters. The drinking water criterion may not be protective for freshwater ecosystems, nor for marine ecosystems if bioaccumulation is taken into account.
Lead
49. A high reliability freshwater trigger value for lead of 3.4 mg/L was calculated using the statistical distribution method at 95% protection. This applies to waters of low hardness, 30 mg/L as CaCO3. This figure was equal to the lowest single NOEC value but was less than the geometric mean for this species, and is considered acceptable for slightly to moderately disturbed ecosystems. A marine high reliability trigger value for lead of 4.4 mg/L was calculated using the statistical distribution method with 95% protection.
50. The drinking water criterion for lead, 10 mg/L, is higher than the trigger values for lead in fresh and marine waters, 3.4 and 4.4 mg/L respectively. Because the freshwater and marine trigger values are high reliability values, there is a risk that use of the drinking water criterion would not be protective for ecosystems.
Mercury
51. A freshwater high reliability trigger value of 0.6 mg/L was calculated for inorganic mercury using the statistical distribution method with 95% protection. Although the 95% protection level is used in Table 5, ANZECC/ARMCANZ recommended that the 99% protection level of 0.06 mg/L be used for slightly to moderately disturbed ecosystems to take bioaccumulation into account.
52. A marine high reliability trigger value of 0.4 mg/L was calculated for inorganic mercury using the statistical distribution method with 95% protection. Although the 95% protection level is used in Table 5, ANZECC/ARMCANZ recommended that the 99% protection level of 0.1 mg/L be used for slightly to moderately disturbed ecosystems to take bioaccumulation into account. The 99% figure of 0.1 mg/L is the same as that recommended by Canada to protect human consumers of fish. The drinking water criterion for mercury, 1.0 mg/L, is higher than the trigger values for mercury in fresh and marine waters. Because the freshwater and marine trigger values are high reliability values, there is a risk that use of the drinking water criterion would not be protective for ecosystems.
Selenium
A freshwater high reliability trigger value of 11 mg/L was calculated for Se (total) using the statistical distribution method at 95% protection. Although the 95% protection level is used in Table 5, ANZECC/ARMCANZ recommended that the 99% protection level of 5 mg/L be used for slightly to moderately disturbed ecosystems to take bioaccumulation into account. A marine low reliability trigger value of 3 mg/L was calculated for Se (total) using an AF of 100. This did not specifically consider bioaccumulation.
53. The drinking water criterion for selenium, 10 mg/L, is lower than the trigger value for selenium in fresh water, 11 mg/L, but higher than the low reliability trigger value of 3 mg/L for marine water. Use of the drinking water criterion should be protective for freshwater ecosystems but may not be protective for marine systems.
Thallium
54. A freshwater low reliability trigger value of 0.03 mg/L was derived from the Hyalella reproduction figure with an AF of 20 (because the data were chronic). A marine low reliability trigger value for thallium of 17 mg/L was calculated from the crustacean figure using an assessment factor of 20 (chronic figure). These figures should only be used as indicative interim working levels.
55. No drinking water criterion has been set by NHMRC/ARMCANZ for thallium but a guideline of 3 mg/L has been estimated here using drinking water values that were developed by Region 9 US EPA. This guideline is higher than the low reliability trigger value for freshwater, but lower than the low reliability trigger value for marine water.
56. The greatest risk is that use of the NHMRC/ARMCANZ drinking water criteria would not protect ecosystems against cadmium, where the drinking water criterion is ten times higher than the high reliability freshwater trigger value. Similarly, the drinking water criteria for lead and mercury are up to two to three times higher than the high reliability trigger values for marine and fresh waters.
57. The risk is much lower for antimony and arsenic, where the drinking water criteria are lower than the high reliability trigger values for freshwater. For the remaining metals the data are too poor to enable firm conclusions to be drawn.
58. Taking all these considerations together, the Department of the Environment and Heritage will continue to use, for the present, maximum leachate values for Basel metals based on drinking water criteria, as set out in Table 4. This maximises consistency between Commonwealth, State and Territory Governments.
59. However, it is a matter of concern that for cadmium, lead and mercury, use of maximum leachate values based on drinking water criteria may not ensure that the environment is protected in marine and fresh waters. The trigger values for these metals are all high reliability figures that are lower than the drinking water criteria. Consideration should be given in future editions of this guideline to the use of the marine and fresh water values in place of the drinking water criteria for these three metals.
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