Article Contaminated Land

New Guidance from the Environment Agency

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Secondary Model Procedure for the Development of Appropriate Soil Sampling Strategies for Land Contamination  (Technical Report P5-066/TR)

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 
(Technical Report P5-065/TR)

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

Article Contaminated Land

Our man in Europe..

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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 Copenhagen. 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)

Article Contaminated Land

Report on Remediation and Waste Management Regulation Regime Seminar

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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;

  • The EA should not seek a Waste Management Licence for the movement of clean natural soil.
  • Geotechnical processes which generate material should not be classified as waste.
  • Minor re-grading will not normally require a Waste Management Licence (minor not defined).
  • Cover systems may require a Waste Management Licence.
  • Exemptions from Waste Management Licences will be granted for material processed through mobile plant or material that is less than 2500m3and remains at the site of origin.
  • Even if material has a use on site this does not preclude it from regulatory control.

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;

  1. 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.
  2. The Guidance appears to be at odds with the principles of risk assessment and sustainability in land development
  3. 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 also be found.