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Remediation
and the Waste Management Regulation Regime By Rob Frost and Hugh
Mallett (Enviros Aspinwall) Background To
bring the UK into line with the EC Waste Framework Directive the Environment
Agency (EA) has issued guidance on the application of waste management licences
to remediation. This guidance states that contaminants are "waste" as they
have been "abandoned" or "control of them has been lost". Because the soil is not discrete from the contaminants that
too will be considered waste. In particular circumstances uncontaminated natural
arisings from service and foundation excavations on development sites could also
be considered waste. The implications of this are that most, if not all,
development sites will either require an exemption from Waste Management
Licensing or will operate under a Waste Management Site Licence. Position Paper The
consequences of this guidance are significant in terms of remediation and the
redevelopment of brownfield sites. The
AGS therefore published a Position Paper setting out the industry's concerns
(AGS web site) and this paper formed the Agenda for the Seminar with the EA,
held at the Institute of Civil Engineers and attended by over 70 delegates. Seminar The
scene was set by Peter Witherington (Chair of the Contaminated Land Group) who
outlined the main concerns described in the Paper. David Baker (House Builders Federation) then described how
the EA Guidance and its interpretation could severely dent the Government
targets for redevelopment (60% of new homes on brownfield sites). Paul
Needham of the EA Waste Division then described the EA position with regard to
the EC Directive and its interpretation in their Guidance.
He responded specifically to the AGS Position Paper; An
animated Question and Answer session followed during which the EA failed to
satisfactorily respond to the concerns raised in the Position Paper.
The main conclusions of delegates were that; i)
The Guidance appears to be
designed to move remedial strategies away from encapsulation and towards in situ
or ex situ on site treatment of soils. ii)
The Guidance appears to be at odds
with the principles of risk assessment and sustainability in land development. iii)
There is an unresolved
incompatibility in the EA's position which requires that the same Waste
Management controls are equally applicable to "landfill as they are to the
remediation/ redevelopment of marginally contaminated soils. Following
the Seminar three actions have been undertaken by the AGS; 1.
The AGS was invited to join the "Single Remediation Working Group".
This Group has support from both DEFRA and the EA and has as its prime
objective the definition of a dedicated regime for remediation.
Simon Edwards (Merebrook) is the AGS representative and the Group had its
first meeting in December. 2.
The AGS has written to the Environment Agency with an offer to assist in
their forthcoming revisions of the Guidance on Waste Management. 3.
A written response to the Position Paper has been received from the EA
which will now be up-dated. Members
with an interest and/ or experiences associated with Waste Management Licensing
and remediation are encouraged to share information with the Contaminated Land
Group. This will be vital in ensuring that the Single Remediation
Working Group can properly address industry's concerns in this most important
area of our work. A
copy of the AGS
Position Paper can be found on the website.
A flow chart to help decide 'Is it Waste' can be also be found. What is a SILC? What are the
qualifications for becoming a SILC?
The
story to date: When will applications be
open to everyone?
Is there anything else to
know? Further information about SILC accreditation or Land Condition Records can be obtained from the IEMA website www.iema.net Note by: Peter Rodd, JacobsGIBB representative on the AGS Committee and Contaminated Land Working Group who attended a meeting of the ISO/TC 190 Committee in Snekkersten, Denmark as the UK representative The BSI asked the AGS to propose a representative to serve on their TC 190 EH/4 committee that is involved in the harmonisation of standards in the EC and internationally for Soil Quality. The standards being worked on are largely aimed at soil in the soil science sense but soil is defined as all material above bedrock thus geotechnical and contamination issues are also addressed. The BSI required an expert in the physical properties of soil and I was proposed and accepted. I attended the next meeting of the EH/4 committee in September 2001 and was asked to go to the annual meeting of ISO/TC190, in early October, to represent the BSI and attend the sessions of SC5 (considering physical properties of soil) and its working groups. JacobsGIBB allowed me the time to attend the Meeting in Snekkersten, a small town about 30 - 40 miles north of Ciopenhagen. I chose my route to the meeting via Malmo and then by rail over the new double decker bridge (road over rail) between Sweden and Denmark. To my surprise the train went through to Snekkersten (one stop before the end of the line at Helsingor, home to Hamlet's Castle) without the need to change. The first session attended was for SC5/WG3 looking at standards for water content. The working group was dealing with two standards. One of these; BS ISO 11461: 2001, Soil Quality - Determination of soil water content as a volume fraction using coring sleeves - Gravimetric method, had been recently issued as a full standard and was not discussed. The second document, ISO/DIS 16586, Soil Quality - Determination of soil water content as a volume fraction on the basis of known dry bulk density - Gravimetric method, is at a late stage of development. (DIS - Draft International Standard). Comments from member countries were discussed and adopted where appropriate. One issue was a conflict between the two documents - BS ISO 111461 contains a note suggesting that drying at 105oC for samples containing significant organic mater will not greatly affect the result, ISO/DIS 16586 suggests it will. This will be resolved when the recently issued standard comes up for review. The next session attended was for SC7/WG6. The working group is considering three standards; ISO/AWI 21268-1 Soil Quality - Leaching procedures for subsequent chemical and ecotoxicological testing of soil and soil materials - Part 1: Batch test using a liquid to solid ratio of 2 l/kg dry matter, Part using 10 l/kg and Part3: Up-flow column test. A large part of the session was taken up with a presentation of results using different extraction procedures. The use of end-over-end shaker or a roller table did not seem to affect the results and so the use of either will be permitted. There did, however, appear to be a system error between the extraction procedures used by the laboratories. As a result further work is required before the standards can move forward. The chairman also asked for feedback from the member countries on the type of containers they recommend. (feedback to PGR please). (Note feedback on the items discussed should be sent to Peter
Rodd pgr@mpg-ctrl.com New
Guidance from the Environment Agency Prepared by Monitor Consultants for the Environment Agency and the DETR, the Secondary Model Procedures describe the procedural approach for specific activities that support, or are part of, risk assessment, the evaluation and selection of remedial measures, and the implementation of risk management measures (which are intended to be covered in the primary model procedures). Technical Aspects of
Site Investigation - Volumes I and II Supporting technical guidance for specific activities that are part of the activities covered by the primary and secondary procedures. The above documents are available from: Environment Agency R&D Dissemination Centre, c/o WRC Frankland Road, Swindon, Wilts SN5 8YF Tel: 01793 865 000 Fax: 01793 514 562 email publications@wrcplc.co.uk |
