6 Conclusions

Assessment of the Impact of an EC Directive on Priority Substances under the WFD on the Current Regulation of Contaminated Sites

A proposal for an EC Directive on Priority Substances under the Water Framework Directive was put forward by the European Commission in July 2006. An initial assessment has been carried out on whether one or more of the priority substances (PS) can be expected to constitute a risk of exceeding the Environmental Quality Standards (EQSs) in surface waters due to losses from contaminated sites and soils. The final Daughter Directive also establishes EQSs for a group of eight substances called "other pollutants" (Annex I, Part B). These substances have been included in the analyses and assessments of this study.

Furthermore, an assessment has been carried out on which of the priority hazardous substances (PHS), in case of a soil and groundwater contamination, needs to be handled if it should be decided to stop losses of PHSs to the aquatic environment completely. This document is based on the assumption that losses of the PHS's ought to be stopped. In reality this implies that measures should be taken by Denmark with the purpose of stopping the losses. By aiming to stop the losses through the necessary measures, Denmark will fullfill its obligation as stated in the Water Framework Directive.

The assessment is based on a screening of the following:

Use and production - both present and historical
Physical-chemical properties
Toxicity
Will the contaminations be detected in the framework of common practice
and legislation.

Based on the screening it was assessed that the following 6 priority substances in case of a soil and groundwater pollution were at risk of exceeding the EQS in surface waters:

HCH/lindane
Nonylphenol
Octylphenol
Tributyltin and compounds
Trichlorobenzene
Trichloromethane

Of these the following are classified as PHSs:

HCH/lindane
Nonylphenol
Tributyltin compounds.

Based on an estimate of the need for dilution to comply with the EQSs and assumptions on dilution in the groundwater body together with different types of geology in Denmark, an estimate on type and number of relevant sites polluted with the six priority substances and posing a risk of exceeding the EQSs were given. It was seen that for each of the 6 priority substances except tributyltin compounds less than 30 smaller sites and a few larger sites were expected. For tributyltin the number was around 500 larger sites, primarily winter store places for yachts and shipbuilding yards.

Regarding the number of sites contaminated with the PHSs HCH, nonylphenol and tributyltin compounds it was estimated that a total of approx. 50 smaller sites and 500 larger sites needs to be remediated in order to stop losses of the PHSs to the environment.

Regarding whether the identified substances and types of contaminates are of general problem is was assessed that especially - if not only - tributyltin compounds among the priority substances may constitute an environmental issue of general character in relation to the Daughter Directive. As this assessment is based on generalized assumptions and done within a statistical framework, specific investigations or monitoring of surface waters would be necessary in order to evaluate the actual risks posed by these sites.