Appropriate Due Diligence of Brownfield Sites in Irelnd - In The Current Market
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Appropriate Due Diligence of Brownfield Sites in Irelnd - In The Current Market

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The Northern Ireland Environment Agency carried out an inventory of potentially contaminated land and have stated in 2011 that they have indentified a number in excess of 14,000 sites. This number ...

The Northern Ireland Environment Agency carried out an inventory of potentially contaminated land and have stated in 2011 that they have indentified a number in excess of 14,000 sites. This number was revised upwards from 12,000 in 2009. Mulroy Environmental carried out an \'in-house\' inventory of key industrial sectors. This in-house inventory suggests that the NIEA contaminated land database number is correct. As such, it is likely that the Rep. of Ireland has over twice the number of potentially contaminated sites as that of Northern Ireland i.e. >30,000.

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Appropriate Due Diligence of Brownfield Sites in Irelnd - In The Current Market Presentation Transcript

  • 1. Appropriate Due Diligence OfBrownfield Sites in Ireland – In The Current Market Padraic Mulroy,BSc., MSc., MIEI, MIPSS, CSc, SiLC Managing Director Mulroy Environmental Contaminated Land Technical Briefing, Royal Marine Hotel, Dun Laoghaire, Co. Dublin 16th May 2012
  • 2. BACKGROUND MULROY ENVIRONMENTAL1 Background2 Extent of CL Who are we?3 Management of • Based in Dundalk, County Louth (the Wee County) Contaminated Land • Started in 20074 Existing Legislation5 Site Investigation Services6 Risk Assessment • Due Diligence Site Investigation/Contaminated Land Risk7 Site Remediation Assessment8 Reality Check • Remediation/Bioremediation of Contaminated Soil & Water9 Changes to Legislation • Waste Licence & Permit Applications & Licensing • IPPC Licensing10 Contaminated Land • Wastewater Treatment Plant Design for Single, Small Inventory? Community, Commercial & Industrial Development • Site Suitability Assessment • Environmental Impact Assessment • Sludge Management Expertise • Environmental Monitoring Slide 2
  • 3. EXTENT OF CONTAMINATED LAND IN REP. OF IRELAND • Have we understated the extent of (potentially) contaminated land in Ireland?1 Background • Was Ireland bypassed by the Industrial Revolution?2 Extent of CL • An agrarian economy? Minor mineral deposits3 Management of Contaminated Land4 Existing Legislation5 Site Investigation6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 3
  • 4. EXTENT OF CONTAMINATED LAND IN REP. OF IRELAND • Comparison to the birthplace of the Industrial Revolution – Great Britain with >100,000 potential1 Background contaminated sites 12 Extent of CL3 Management of Contaminated Land4 Existing Legislation5 Site Investigation6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? 1. Contaminated Land Report of the Parliamentary Office of Science & Technology (1993). Slide 4
  • 5. MANAGEMENT OF CONTAMINATED LAND There are 6 ways that contaminated land gets1 Background remediated or managed in Ireland:2 Extent of CL3 Management of Contaminated Land 4. The land is part of a redevelopment project (i.e. LA grant planning permission with remediation of4 Existing Legislation site in post planning condition);5 Site Investigation 5. The site is part of a Waste or IPPC regulated6 Risk Assessment facility;7 Site Remediation 6. The land is cleaned up as a result of responsible8 Reality Check corporate action (i.e. no enforcement needed);9 Changes to Legislation & Licensing 7. The land is contributing to a local water quality10 Contaminated Land issue (i.e. subject to Section 12 Notice from LA); Inventory? 8. The land is the subject of a human or animal health issue (i.e. subject to Section Notice from HSE (e.g. asbestos); and 9. Party found liable under Environmental Liability Regulations. Slide 5
  • 6. MANAGEMENT OF CONTAMINATED LAND Due Diligence - Most common scenario: • Developer submits a planning application for a residential or1 Background mixed residential commercial development on brownfield site2 Extent of CL • Draws up contract with vendor to purchase site in event of success or to walk away if contamination is too severe or3 Management of planning is refused Contaminated Land • Buyer carries out site investigation, Generic Quantitative Risk4 Existing Legislation Assessment (GQRA) and Detailed Quantitative Risk Assessment5 Site Investigation (DQRA) if site is severely contaminated • Buyer draws up Remedial Action Plan (RAP) for site to break6 Risk Assessment Source-Pathway-Receptor link7 Site Remediation • Has a sit down with the vendor to give him/her the DQRA/RAP8 Reality Check report/cost of clean-up. Negotiate on price reduction9 Changes to Legislation • Once price agreed & ‘Contract of Sale’ agreed, PA submitted & Licensing • LA may employ external consultant to review or asks EPA for advise10 Contaminated Land • Planning permission obtained – Sale goes through Inventory? • Remediation carried out as 1st Phase/Enabling Works • Close-out/Remediation Validation Report produced following completion of remediation Slide 6
  • 7. EXISTING LEGISLATION1 Background2 Extent of CL3 Management of Contaminated Land4 Existing Legislation5 Site Investigation6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 7
  • 8. EXISTING LEGISLATION  There is NO definition for Contaminated Land in Irish Legislation  Environmental Pollution definition in Section 4(2) of EPA Act, 1992:1 Background2 Extent of CL (2) In this Act “environmental pollution” means the direct or indirect introduction to an environmental medium, as a result of human activity,3 Management of of substances, heat or noise which may be harmful to human health or Contaminated Land the quality of the environment, resulting in damage to material property, or impair or interfere with amenities and other legitimate uses4 Existing Legislation of the environment and includes:5 Site Investigation6 Risk Assessment  “air pollution” for the purposes of the Air Pollution Act 1987;7 Site Remediation  the condition of waters after the entry of polluting matter within the8 Reality Check meaning of the Local Government (Water Pollution) Act 1977;9 Changes to Legislation & Licensing (c) in relation to waste, the holding, transport, recovery or disposal of waste in a manner which would, to a significant extent, endanger human health10 Contaminated Land or harm the environment and, in particular: Inventory? (i) create a risk to the atmosphere, waters, land, plants or animals; (ii) create a nuisance through noise, odours or litter; or (iii) adversely affect the countryside or places of special interest; (d) noise which is a nuisance, or would endanger human health or damage property or harm the environment. Slide 8
  • 9. EXISTING LEGISLATION  Suggested definition for Contaminated Land:1 Background “any land which appears to the local authority in whose area it is situated to be in such condition, by reason of substances in, on or2 Extent of CL under the land that: significant harm is being caused or there is a significant possibility of such harm being caused, or pollution of3 Management of controlled waters is being, or is likely to be, caused.” Contaminated Land (section 78A(2) Part IIA Environmental Protection Act 1990)4 Existing Legislation5 Site Investigation ‘significant possibility of significant harm (SPOSH)6 Risk Assessment7 Site Remediation  Brownfield Sites: “real property, the expansion, redevelopment, or reuse of which may8 Reality Check be complicated by the presence or potential presence of a hazardous9 Changes to Legislation substance, pollutant, or contaminant.”, US EPA & Licensing10 Contaminated Land  Land with concentrations of substances above natural background values…..geochemistry of area? Inventory?  Land which is generally regarded as posing a ‘risk’ to our environment  What is risk?…..What’s acceptable?…Who bears it? Slide 9
  • 10. SITE INVESTIGATION  Good news for British Consultants - process is identical to UK – Irish EPA have1 Background taken guidance from UK EA2 Extent of CL  Source-Pathway-Target  Conceptual Site Model3 Management of  Suitability for end-use Contaminated Land  SI Standards:4 Existing Legislation  BS5930:1999 Code of practice for Site Investigations  BS10175:2011 Investigation of Potentially Contaminated Sites5 Site Investigation6 Risk Assessment  RA Guidance:7 Site Remediation  CLR 11. Model Procedures for the Management of Land Contamination  EPA Code of Practice ‘Environmental Risk Assessment for Unregulated Waste8 Reality Check Disposal Sites’ in April 20079 Changes to Legislation  EPA recognise there is a legal gap and a guidance gap with regard to non-historic & Licensing waste brownfields10 Contaminated Land Inventory?  EPA initiated a workshop with Ireland’s contaminated land consultants/ experts to determine how to best proceed. Main outcome of process was:  Draft Framework for the Management of Contaminated Land and Groundwater at EPA Licensed Facilities Slide 10
  • 11. SITE INVESTIGATION Draft Framework for the Management of Contaminated Land and Groundwater at EPA Licensed Facilities1 Background2 Extent of CL3 Management of Contaminated Land4 Existing Legislation5 Site Investigation6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 11
  • 12. SITE INVESTIGATION Draft Framework for the Management of Contaminated Land and1 Background Groundwater at EPA Licensed Facilities2 Extent of CL3 Management of Contaminated Land4 Existing Legislation5 Site Investigation6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing * Also Groundwater Monitoring Template Report can be provided with10 Contaminated Land Stage 1 to 3 Inventory? Broadly in line with:  CLR 11. Model Procedures for the Management of Land Contamination  EPA Code of Practice ‘Environmental Risk Assessment for Unregulated Waste Disposal Sites’ in April 2007 Slide 12
  • 13. SITE INVESTIGATION DUE DILIGENCE SCENARIO1 Background My client is a residential developer and he wants to buy a brownfield site2 Extent of CL that is not a historic landfill or a former EPA licensed facility.3 Management of Contaminated Land What approach should a consultant have?4 Existing Legislation Conceptual Site Model (CSM) Sketch5 Site Investigation6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 13
  • 14. SITE INVESTIGATION1 Background FOCUS ON KEY CONCEPT2 Extent of CL3 Management of Contaminated Land SOURCE PATHWAY TARGET (OR RECEPTOR)4 Existing Legislation5 Site Investigation6 Risk Assessment  Must have all 3 to result in an exposure to a contaminant7 Site Remediation  If one is missing the chain is broken.8 Reality Check  In remediating or abating you’re trying to break that chain9 Changes to Legislation & Licensing  Remove the Source (dig out the contamination, GW pumping,10 Contaminated Land etc) Inventory?  Close off the pathway (Cap the waste/Cut-off wall, PRB, etc)  Protect the receptor (relocate) Slide 14
  • 15. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION1 Background2 Extent of CL  Comprehensive Desk Study3 Management of  Most Important – 1st Draft of Conceptual Site Model (CSM) Contaminated Land  Provide early recognition of the characteristics of the site and potential geohazards;4 Existing Legislation  Avoid money being wasted on inappropriate intrusive ground investigations;5 Site Investigation  Provide information on on-site operations and therefore possible contaminants and6 Risk Assessment anticipated areas of contamination;7 Site Remediation  Facilitate appropriate scoping of the later stages of the site investigation;  Aid the formulation of efficient designs for subsequent works (e.g.: foundations,8 Reality Check retaining walls, tunnels, slope stabilization works, etc);9 Changes to Legislation  Provide early warning of possible delays to programme and/or budget implications; & Licensing  Part of current good practice for phased site investigations (see BS5930 and10 Contaminated Land BS10175); Inventory?  Assist health and safety and geoenvironmental management; and  An essential tool for risk assessment and risk management Slide 15
  • 16. SITE INVESTIGATION MAINTAIN FOCUS ON KEY CONCEPT1 Background SOURCE PATHWAY TARGET (OR RECEPTOR)2 Extent of CL3 Management of Contaminated Land Refine Conceptual Site Model (CSM)4 Existing Legislation5 Site Investigation6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 16
  • 17. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION1 Background2 Extent of CL Comprehensive Desk Study – Historic Mapping Review3 Management of Contaminated Land4 Existing Legislation  Review all available historical mapping – not just that available online5 Site Investigation6 Risk Assessment  OSI only provides electronic mapping of:7 Site Remediation  1st Edition of 6’’ Mapping (1834-45); and8 Reality Check  1st Edition of 25’’ (1:2,500) Mapping (1863-1913)9 Changes to Legislation => data gap between & after & Licensing10 Contaminated Land  NI OSI have digitised all historical mapping which enable comprehensive Inventory? review of site’s history Slide 17
  • 18. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION - Historic Mapping Review CASE STUDY - BELFAST FORMER INDUSTRIAL SITE1 Background2 Extent of CL 50K3 Management of DISCOV. Contaminated Land4 Existing Legislation5 Site Investigation6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 18
  • 19. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION - Historic Mapping Review CASE STUDY BELFAST FORMER INDUSTRIAL SITE1 Background2 Extent of CL 6’’ 2nd Ed.3 Management of Contaminated Land 18314 Existing Legislation5 Site Investigation6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 19
  • 20. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION - Historic Mapping Review CASE STUDY BELFAST FORMER INDUSTRIAL SITE1 Background2 Extent of CL 25’’ 3rd Ed.3 Management of Contaminated Land 19014 Existing Legislation5 Site Investigation6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 20
  • 21. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION - Historic Mapping Review CASE STUDY BELFAST FORMER INDUSTRIAL SITE1 Background2 Extent of CL 25’’ 4TH Ed.3 Management of Contaminated Land 19314 Existing Legislation5 Site Investigation6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 21
  • 22. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION - Historic Mapping Review CASE STUDY BELFAST FORMER INDUSTRIAL SITE1 Background2 Extent of CL 25’’ 1st Ed.3 Management of Contaminated Land I.G.4 Existing Legislation 19615 Site Investigation6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 22
  • 23. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION - Historic Mapping Review CASE STUDY BELFAST FORMER INDUSTRIAL SITE1 Background2 Extent of CL3 Management of Former Contaminated Land Site4 Existing Legislation Layout5 Site Investigation 1968-6 Risk Assessment 19907 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 23
  • 24. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION - Historic Mapping Review CASE STUDY BELFAST FORMER INDUSTRIAL SITE1 Background2 Extent of CL3 Management of Former Contaminated Land Site4 Existing Legislation Layout5 Site Investigation 19906 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 24
  • 25. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION - Historic Mapping Review CASE STUDY BELFAST FORMER INDUSTRIAL SITE1 Background2 Extent of CL3 Management of Current Contaminated Land OS4 Existing Legislation 1:1,0005 Site Investigation Scale6 Risk Assessment Mapping7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 25
  • 26. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION - Historic Mapping Review CASE STUDY BELFAST FORMER INDUSTRIAL SITE1 Background2 Extent of CL3 Management of Google Contaminated Land Aerial4 Existing Legislation Photo5 Site Investigation 20106 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 26
  • 27. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION - Historic Mapping Review CASE STUDY BELFAST FORMER INDUSTRIAL SITE1 Background2 Extent of CL3 Management of Google Contaminated Land Street4 Existing Legislation View5 Site Investigation Photo6 Risk Assessment 20107 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 27
  • 28. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION1 Background2 Extent of CL3 Management of Comprehensive Desk Study Contaminated Land  Vendor should release all available environmental, site4 Existing Legislation investigation and engineering reports/drawings, BH5 Site Investigation logs/drillers logs, etc.6 Risk Assessment  Former or Discharge or Waste Permits – compliance record,7 Site Remediation may require visit to LA office, review of prosecution notices;8 Reality Check  Environmental Health Reports, H & S history, fire accident9 Changes to Legislation & Licensing or significant spillage incidents, etc10 Contaminated Land  No drawings are not relevant e.g. old underground service Inventory? drawings, as built drawings, services underground CCTV survey videos, etc Slide 28
  • 29. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION1 Background2 Extent of CL Comprehensive Desk Study3 Management of  Reports on Site Investigation Phase I, Phase II, Groundwater Contaminated Land Monitoring, Generic Quantitative Risk Assessments ( GQRA),4 Existing Legislation Detailed Quantitative Risk Assessments (DQRA), Vapour Intrusion/5 Site Investigation Migration Risk Assessment6 Risk Assessment  Remedial Action Plan drawn up by vendor for prospective buyer?7 Site Remediation  Site may have been remediated – In-situ and/or ex-situ? Close-out8 Reality Check Remediation Validation Report?  Site may have had aboveground/underground storage tanks (ASTs/9 Changes to Legislation & Licensing USTs) removed – any contaminated soil removed? Proof of removal C1 forms?10 Contaminated Land  Documentation may be included as an Annex with ‘Sale of Contract’ Inventory?  Is the vendor withholding information? Consultant’s call? Full disclosure by vendor – ‘Caveat emptor’ – buyer beware Slide 29
  • 30. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION1 Background Comprehensive Desk Study2 Extent of CL  Soil, subsoil, geology, hydrogeology, hydrology/flood history – on-line3 Management of information and mapping from GSI, EPA, OPW(www.floodmaps.ie), etc Contaminated Land4 Existing Legislation  Groundwater quality data for nearby public wells;5 Site Investigation  GSI Borehole records within 500m of site – no records - may require door6 Risk Assessment to door survey, aquifer class and vulnerability7 Site Remediation  River Basin Management Districts Risk Assessment Reports for8 Reality Check Groundwater & Surface Water Bodies9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 30
  • 31. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION1 Background Site Walkover (Phase I Audit)2 Extent of CL3 Management of  Topography: indications of slope instability, spoil heaps or Contaminated Land signs of ground subsidence4 Existing Legislation  Geology: exposures of soils and rocks which can be5 Site Investigation examined and sampled.6 Risk Assessment7 Site Remediation  Surface water signs of flooding; springs; waterlogging. &8 Reality Check groundwater:9 Changes to Legislation  Vegetation: signs of vegetation die-back or restricted & Licensing10 Contaminated Land vegetation as a result of contamination of the ground; Inventory? presence of invasive species such as Japanese Knotweed; trees which may cause shrinkage and swelling of clay soils.  Ecology: indicators of protected species, newts, badgers, bats, nesting birds. Slide 31
  • 32. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION1 Background Site Walkover (Phase I Audit)2 Extent of CL  Contamination: indications of spills, disturbed ground, areas3 Management of of fill or spoil heaps, old fuel or oil tanks. Contaminated Land4 Existing Legislation  Structures: settlement of existing structures or the use of5 Site Investigation asbestos; indicators of archaeological value.6 Risk Assessment  Local Knowledge: anecdotal information on past uses of the7 Site Remediation site or past problems in the area.8 Reality Check  Access & Services: information such as access for site9 Changes to Legislation equipment and location of buried or overhead services. & Licensing  Advice on undertaking walk-over surveys has been provided10 Contaminated Land by the UK Department of the Environment (CLR 2, 1994a) and Inventory? the Building Research Establishment (BRE Digest 348, 1989). See also CLR 3, CLR 11, BS5930 and BS10175. Slide 32
  • 33. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION1 Background Site Investigation (SI)2 Extent of CL  Do you have enough information from the vendor to accurately put together3 Management of a Remedial Action Plan (RAP) and approximate Clean-up Costs for your client? Contaminated Land  What does your client (the buyer) want to do?4 Existing Legislation  Clean up a former Town Gas Plant and develop into residential units with back gardens? ‘Heavy industry’ to ‘Residential with potential plant’5 Site Investigation uptake Most sensitive use! Site Specific Target Levels (SSTLs) may be6 Risk Assessment prohibitive.7 Site Remediation  Clean up/redevelop an old petrol station into new petrol retail station – no change in use. Achieve ‘Suitability for Use’. However, need to consider8 Reality Check proximity of adjacent residences/property9 Changes to Legislation  If an SI is required will vendor co-operate on access? Disruption to on-site & Licensing operations? Compensation?10 Contaminated Land  If you are installing groundwater and/or gas monitoring boreholes you are Inventory? providing the site with valuable infrastructure? Share the costs? Vendor gets consultant’s report? Question of consultant’s independence?  Public Liability Insurance cover for consultant and drilling contractor Slide 33
  • 34. SITE INVESTIGATION PRELIMINARY SITE INVESTIGATION Site Investigation (SI)1 Background  Vendor agrees to access.......what SI technique will give the best return2 Extent of CL of information?3 Management of  Trialpit investigation – best technique for assessing soil contamination Contaminated Land up to 3.5-4.0m bgl but reinstatement is a problem on hardstanding - vendor may not allow4 Existing Legislation  Gas Spike Survey – ideal for detection of landfill gas from suspected5 Site Investigation domestic/putrescible waste, quick & no ground disturbance6 Risk Assessment  Soil vapour survey – good for detecting shallow contamination in petrol7 Site Remediation retails sites…but beware of doing in cold weather  Window sampling – least disruption, limited to max of 5-6m (normally8 Reality Check 3.0-3.5m), access to groundwater may not be possible if SWL is lower,9 Changes to Legislation for well construction - problem of smearing in cohesive soils, work best & Licensing in permeable sands/gravels10 Contaminated Land  Shell & Auger – good for depth & logging of soils, but slow particularly on boulder tills, only to top of competent rock Inventory?  Air Rotary – great for speed and depth but destroys sample. Main advantage is capacity to install monitoring boreholes within bedrock… quickly and efficiently. But soil is shredded/macerated & soil samples cant be tested reliably for VOCs Slide 34
  • 35. SITE INVESTIGATION DETAILED SITE INVESTIGATION1 Background2 Extent of CL Why?3 Management of 4. Found severe contamination – want to delineate extent of Contaminated Land plume – vertically and horizontally;4 Existing Legislation 5. Found type of contamination which was not expected5 Site Investigation based on site history (e.g. DNAPLs or sinking product) –6 Risk Assessment more comprehensive laboratory suite7 Site Remediation8 Reality Check 6. Firm up on design for proposed remediation solution – carry out pump tests to determine permeability of9 Changes to Legislation & Licensing overburden/bedrock10 Contaminated Land Inventory? Slide 35
  • 36. SITE INVESTIGATION SITE INVESTIGATION PRACTICES1 Background2 Extent of CL GOLDEN RULES:3 Management of  Log soils to BS5930:1999 – universal language for Contaminated Land geologists/engineers;4 Existing Legislation  Design site investigation to be consistent with5 Site Investigation BS10175….remember..the purpose of the site investigation is to6 Risk Assessment get access to the media (soil, groundwater or gas). Look at7 Site Remediation density of monitoring points (i.e. herringbone, etc);8 Reality Check  Beware of cross-contamination…..hydraulic fluid, etc; and9 Changes to Legislation & Licensing  Make sure laboratory suite is correct for type of contaminants10 Contaminated Land found on site e.g. textile industry azodyes/amines wont get Inventory? picked up by the standard sVOC analysis. EA/NHBC Guidance for the Safe Development of Housing Affected by Contamination R & D 66., 2000 Slide 36
  • 37. RISK ASSESSMENT MAINTAIN FOCUS ON KEY CONCEPT1 Background SOURCE PATHWAY TARGET (OR RECEPTOR)2 Extent of CL3 Management of Contaminated Land Refine Conceptual Site Model (CSM)4 Existing Legislation5 Site Investigation6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 37
  • 38. RISK ASSESSMENT Refine Conceptual Site Model (CSM)1 Background2 Extent of CL3 Management of Contaminated Land4 Existing Legislation5 Site Investigation6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 38
  • 39. RISK ASSESSMENT SOIL GENERIC ASSESSMENT CRITERIA FOR GENERIC QRA1 Background  UK Department of Environment, Food and Rural Affairs (DEFRA) - Contaminated2 Extent of CL Land Exposure Assessment (CLEA) Model – Soil Guideline Values, 2009 - Residential3 Management of with plant, Allotment and Industrial/Commercial for sandy loam soil and 6% soil Contaminated Land organic matter (SOM) (12 SGVs);4 Existing Legislation  LQM/CIEH Generic Assessment Criteria for Human Health Risk Assessment, 2nd5 Site Investigation Edition, 2011 – Residential Land-use, Allotment Land-use and Commercial Land-Use at 6% Soil Organic Matter (82 SGVs);6 Risk Assessment7 Site Remediation  EIC/AGS/CL:AIRE Soil Generic Assessment Criteria for Human Health, 2010 (35 SGVs);8 Reality Check9 Changes to Legislation  National Institute of Public Health and the Environment of The Netherlands - & Licensing The Soil Protection Guidelines (Dutch Criteria) – Intervention and Target Values - Dutch standards are widely used by Irish LAs & consultants. Overly conservative as10 Contaminated Land derived for Dutch soils which are predominantly sandy; Inventory?  Waste Acceptance Criteria at Murphy Environmental Waste Facility (WA 129-02|) in Hollywood, Co. Dublin – Hazardous Waste Limit.  Discussion on deriving our own standards but…. Slide 39
  • 40. RISK ASSESSMENT1 Background DETAILED QRA –2 Extent of CL DERIVE SITE SPECIFIC TARGET LEVELS (SSTLs)3 Management of Contaminated Land  Contaminated Land Exposure Assessment (CLEA) Model – Soil4 Existing Legislation Guideline Values, 2009 (Soil lab data);5 Site Investigation  Risk Based Corrective Assessment (RBCA) Model (Soil & water6 Risk Assessment lab data);7 Site Remediation8 Reality Check  Environment Agency Remedial Targets Methodology 2006(8) –9 Changes to Legislation Controlled Waters. & Licensing10 Contaminated Land  RISC-HUMAN (Site Specific DQRAs) Inventory? Slide 40
  • 41. SITE REMEDATION BREAK THE S-P-T CHAIN SOURCE  Remove – Dig & dump but where does it go?1 Background  No Hazardous Waste landfills but…  1 * Hazardous Waste Treatment (Bioremediation) - ENVA Facility in2 Extent of CL Portlaoise – accepts hydrocarbon contaminated soil with Mineral3 Management of Oil>500mg/kg Contaminated Land  1 * Hazardous Waste Transfer Station – RILTA Faciity in4 Existing Legislation Greenogue – accepts & exports hydrocarbon contaminated soil with Mineral Oil>500mg/kg5 Site Investigation  1 * Non-Hazardous Waste Landfill which can accept hydrocarbon6 Risk Assessment contamination with Mineral Oil<500mg/kg & Total 17 PAH<100mg/kg7 Site Remediation  1 * Non-Hazardous Waste Landfill which can accept hydrocarbon contamination with TPH<1,000mg/kg (also only landfill which accepts8 Reality Check asbestos C&D waste9 Changes to Legislation  1 * Inert Waste Landfill which can accept only C&D. No hydrocarbon & Licensing contamination.10 Contaminated Land  Cost of disposal of Hazardous Waste/hydrocarbon contaminated Inventory? soil:  Celtic Tiger price - €65-€125 depending on contaminants  Today’s Recession price - €45 becoming cheaper.  No need for future MNA  Excavation does not require licence but maybe planning permission and acceptable Waste Management Plan Slide 41
  • 42. SITE REMEDATION BREAK THE S-P-T CHAIN  SOURCE  Treat soil on-site e.g. windrow, ex-situ soil biopiling, soil, washing,1 Background etc – requires a waste licence2 Extent of CL  Removing hydrocarbons from groundwater (e.g. pump & treat, dual-3 Management of phase extraction, etc) may require just a LA Discharge Licence. Contaminated Land  Soil Vapour Extraction (e.g. petrol retail station remediation) or use4 Existing Legislation of Oxygen or Hydrogen Release Compounds (ORCs or HRCs) – no approval required5 Site Investigation6 Risk Assessment  PATHWAY7 Site Remediation  Isolate the hazard – vapour cut-off walls, PRBs, capping, LF gas8 Reality Check venting – significant groundworks & may require planning  Dust suppression – landscaping/capping9 Changes to Legislation & Licensing  Immobilise – lime stabilisation…however, getting into waste licence activity10 Contaminated Land Inventory?  TARGET  Remove the target if plume has fled the site and source removal is too late e.g. public water supply wells  Last solution to off-site vapour intrusion of petrol into residences- buy residence. Slide 42
  • 43. SITE REMEDIATION Expect the unexpected……….1 Background2 Extent of CL3 Management of Contaminated Land4 Existing Legislation5 Site Investigation6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 43
  • 44. REALITY CHECK  DRIVERS  Brownfield Developers need reasons not to go for a greenfield site…one of1 Background those reasons has to be a financial one!2 Extent of CL  Most Irish LAs lack expertise in contaminated land unlike UK LAs where there is often a dedicated Contaminated Land Officer…consultant telling the3 Management of regulator what questions she/he should be asking. Contaminated Land  Often Irish LAs request the assistance of the EPA or hire external4 Existing Legislation consultant/expert….this takes correspondence and….time5 Site Investigation  Following SI and RA, if dig & dump solution too expensive and on-site6 Risk Assessment remediation is option (i.e. enough space & time), Pre-waste Licence Application Process needs to be initiated. Applying for a Waste Licence is7 Site Remediation prohibitive on a number of fronts:8 Reality Check  Republic - Cost €16k (i.e. €10k application fee + €6k surrender fee) –9 Changes to Legislation as yet no applicants since WMA 1996 & Licensing  Northern Ireland – Cost €6.9k Total– currently 4 mobile licences10 Contaminated Land  Time to acquire licence – no fixed time for process Inventory?  Proof is in the pudding – In 15 years, only 6 (Fixed) Waste Licences were issued to soil remediation projects  Ultimately developers may get cold feet. Hiring specialist remediation contractors and long lead in-time, project management issues, etc.  Waste licence application process is statutory process which involves public & newspaper notice with public consultation…..scare potential home buyers away…public perception of brownfield redevelopment. Slide 44
  • 45. REALITY CHECK  DRIVERS  Contaminated soil (i.e. Hazardous waste) disposal is too expensive in1 Background Ireland.2 Extent of CL  In most petrol retail remediation projects dig & dump is the only3 Management of solution – built up areas, no space, etc. Contaminated Land  Contractors are afraid to dig in brownfield site…if it’s4 Existing Legislation contaminated it’s a waste & an offence to bury it!5 Site Investigation6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 45
  • 46. CHANGES TO LEGISLATION & WASTE LICENSING?  Adopt key areas of Soil Framework Directive in new Contaminated Land1 Background Regulations – shore up legal lacuna2 Extent of CL  EPA to take responsibility for non-historic waste brownfield sites3 Management of  Second a qualified EPA staff member to work as a Contaminated Land Contaminated Land Officer (CLO) for a number of LAs (e.g. regional waste region – 2-3 LAs)4 Existing Legislation  CLO to draw up Contaminated Land register of non-historic waste for each5 Site Investigation county (WMA Section 26 Register?)  CLO to assess SI/RA reports, Remedial Plans, etc6 Risk Assessment  CLO to process waste licence applications7 Site Remediation8 Reality Check  EPA review costs for fixed soil remediation waste licences and9 Changes to Legislation & Licensing consider introduction of mobile licence applications as per NI10 Contaminated Land  EPA provide fixed timescale for waste licence applications Inventory? WHY? ……DEVELOPERS DON’T LIKE IF’S & UNKNOWNS!  GIVE THEM REASONABLY ACCURATE NUMBERS & TIMELINES! Slide 46
  • 47. CONTAMINATED LAND INVENTORY FOR REP. OF IRELAND? IRISH EPA STUDY 1999 • Historical Sites1 Background – Old Gas Works 50-80 – Closed Landfills 265 (OEE figures?)2 Extent of CL – Closed Mine sites 128 (38 with Tailings Ponds, 11 recent/present3 Management of high risk) Contaminated Land – Old Fertiliser Plants 4-6 – Closed Tanneries 10 -124 Existing Legislation5 Site Investigation • Current Operational Sites6 Risk Assessment – Existing Landfills 76 LA 50 Private (Registration7 Site Remediation ongoing) – Mining/Minerals site in operation ca. 7 (MWD)8 Reality Check – Chemical Industry 150 –1609 Changes to Legislation – Petroleum import terminals (IPIA) 22 & Licensing – Petrol Stations 900 –1200 – Tanneries 310 Contaminated Land – Dockyards 14-16 – Military Sites 1 Inventory? – Railways Depots 80-100 – Scrap yards/dismantlers 180 –200 – Airports with maintenance 2 • Estimated Total of 2,000-2,500 – Ireland’s small scale industry? 1 1. CARACAS, Risk Assessment for Contaminated Sites in Europe, Volume II, Policy Framework, Brogan et al, 1999 Slide 47
  • 48. CONTAMINATED LAND INVENTORY FOR REP. OF IRELAND? • NI Environment Agency DATABASE1 Background2 Extent of CL3 Management of Contaminated Land – >14,000 Potentially Contaminated Sites4 Existing Legislation estimated in 20115 Site Investigation6 Risk Assessment – Continual updating - & continuously7 Site Remediation revised upwards from 11,825 in March8 Reality Check 20099 Changes to Legislation & Licensing • High Risk - 819910 Contaminated Land • Medium Risk - 1811 Inventory? • Low Risk - 1599 • Uncategorised - 216 – 30 land use categories Slide 48
  • 49. CONTAMINATED LAND INVENTORY FOR REP. OF IRELAND? WHO IS CORRECT?1 Background IRISH EPA OR NIEA2 Extent of CL3 Management of Contaminated Land • 2006 DOELG/ARUP Report on Petroleum Sector4 Existing Legislation5 Site Investigation6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 49
  • 50. CONTAMINATED LAND INVENTORY FOR REP. OF IRELAND? WHO IS CORRECT? IRISH EPA OR NIEA1 Background • In EPA inventory there is an absence of2 Extent of CL information on following industrial/commercial3 Management of sectors: Contaminated Land – Oil Depots (i.e. Diesel/Kerosene only) – 250-300?;4 Existing Legislation – Dry Cleaners (768 EPA Solvent User Database);5 Site Investigation – Garages/Mechanic Workshops – 7,500?;6 Risk Assessment – Car Panel Beaters/Solvent Paint Workshops -100?;7 Site Remediation – Military Firing Ranges (i.e. Ballistic Berms) – 20?;8 Reality Check – Local Authority Designated Derelict Property9 Changes to Legislation (abandoned LA housing & halting sites) -500? & Licensing10 Contaminated Land • LA Section 22 Inventory – Inventory? • 344 Confirmed LA-owned Landfills; and • 97 Private/Illegal/Pre-1997 LFs ……… but no information on Section 26 ‘Hazardous Site Subset’ referred to in National Hazardous Waste Management Plan Slide 50
  • 51. CONTAMINATED LAND INVENTORY FOR REP. OF IRELAND? WHO IS CORRECT? IRISH EPA OR NIEA1 Background2 Extent of CL3 Management of Contaminated Land4 Existing Legislation Town Gas Plants/5 Site Investigation Coal Tar in BI6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 51
  • 52. CONTAMINATED LAND INVENTORY FOR REP. OF IRELAND? WHO IS CORRECT? IRISH EPA OR NIEA1 Background2 Extent of CL3 Management of Contaminated Land4 Existing Legislation Town Gas Plants/5 Site Investigation Coal Tar6 Risk Assessment 37 in NI7 Site Remediation 138 in Rep. of I 28 Reality Check9 Changes to Legislation & Licensing10 Contaminated Land Inventory? Slide 52 2. Mulroy Environmental Inventory using OSI on-line historical mapping
  • 53. THANK YOU! Slide 53