Sponsored by: Aspect Environmental
The PFAS Evolution in Mining
Amidst rising operating costs and a shortage of skilled workers, mining companies are constantly looking for ways to increase efficiency, save costs, and retain talent while mitigating safety hazards.
he group of chemicals known as per- and poly-fluoroalkyl substances (PFAS) have become an environmental management challenge over the last decade. Commonly associated with aqueous film forming foam (AFFF) which contained PFAS, PFAS have been detected throughout Australia (and globally) in soils, water and as airborne particulate.
Environmental contamination by PFAS has resulted in billions of dollars spent at a global scale on identification, classification, remediation and rehabilitation. Environmental contamination arising from PFAS has been the subject of substantive legal proceedings with examples including class actions against the manufacturers of PFAS containing chemicals (3M Company) in the United States of America and users of AFFF, the Commonwealth of Australia (Department of Defence) . While there has been rapid development in analytical techniques for detection of PFAS in a range of media, coupled with an equally rapidly developing regulatory framework in response, a steep learning curve for mitigation, remediation, rehabilitation and long-term management of PFAS impacted sites remains.
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PFAS and Mining
Public concerns relating to the impacts of PFAS commonly arise from legacy use of AFFF on Australian Department of Defence estates and airports. The use of AFFF in mining is largely overlooked as a source of environmental PFAS contamination. In New South Wales PFAS containing AFFF was used for more than 30 years on mine sites by Mines Rescue Pty Ltd (Mines Rescue) for liquid fuel fires and in training operations . In 2002 PFAS containing AFFF was phased out by Mines Rescue, following the lead of NSW and other States . However, it has been documented that stockpiled PFAS containing AFFF continued to be utilised throughout Australia after this phase out . Preliminary (Stage 1) contaminated site assessments of Mines Rescue training facilities in Newcastle (NSW), the Hunter Valley (NSW) and Lithgow (NSW) have identified PFAS in soils, surface waters and groundwaters exceeding site assessment criteria .
The utilisation of PFAS containing chemicals in mining extended beyond fire-fighting and emergency response. Additional uses included ore recovery (flotation) in metal mining (e.g. copper and gold), improved oil and gas recovery from wells (oil and gas industry), fuel solvents and fuel evaporation inhibitors . The diverse and often poorly documented applications of PFAS in mining means that there are many opportunities for these chemicals to become an unforeseen management challenge as PFAS regulations tighten.
What are the Implications of PFAS Regulation for the Mining Industry?
As Australian and international regulations adjust the lens to focus on broader industrial sources, including the mining sector, there is a need for owners, investors and operators to be aware of how PFAS impacted environments can affect project objectives, environmental and operational performance. The team at Aspect, including Dr Paul Harvey, are actively tracking the evolution of this regulatory framework to assist clients in formulating appropriate risk-based responses.
Performance implications include:
- Liability – understanding who is responsible for managing PFAS impacts on- and off-site. Poorly managed PFAS impacted environments may expose landowners and/or occupiers to liability on title and in management, cleanup or disposal obligations.
- Cost – managing PFAS may present a financial burden that often exceeds the basic cost of PFAS remediation. There may be requirements to compensate stakeholders including neighboring properties or businesses impacted by PFAS .
- Time – appropriately managing PFAS impacted environments is often time-consuming, particularly given current regulatory and social sensitivity. This can cause significant delays to approvals, licences, permits, project milestones, objectives and operational performance while the nature, scale and extent of an issue is determined.
- Extent – understanding the extent of PFAS impacts often requires validation testing, monitoring and reporting.
- Regulation – the PFAS regulation and legislative framework is rapidly evolving. In the absence of knowledge and a strategic framework, risk is uncontrolled.
- Corporate Social Responsibility – due to the prominence of PFAS in the public domain, managing public perceptions and expectations can be a challenge. You need to have visibility of the risk and a strategy in place before it goes social
Early identification of PFAS impacted environments during pre-acquisition, due diligence, review of a site’s aspects/impacts register, management or site compliance review can reduce the risk, time and potential financial burden in managing PFAS presence.
Aspect seeks to provide clients advice that facilitates understanding of the roles and responsibilities of owners, operators, contractors and stakeholders to:
- identify and quantify risk
- maintain local (site) control to provide management of beneficial site outcomes
- enhance confidence in site awareness, understanding and capability in managing site issues.
Preparing the Mining Sector for PFAS
As we continue to understand more about the PFAS risk we must be positioned and informed to enable adaptation of relevant management strategies. Consideration and planning for any PFAS implications on site enables a proactive and effective management approach to be implemented. This enables avoidance or reduction of long-term management implications or legacy PFAS issues that may present a contingent liability for your operation.
Dr Paul Harvey