’Environmental Site Investigation and Due Diligence in the Current Market.’ APEA Presentation15 11 12

1,885 views

Published on

’Environmental Site Investigation and Due Diligence in the Current Market.\’ Presentation given to Association of Petroleum and Explosives Administration (APEA) in Omagh, County Tyrone on the 20th October, 2012 and in Mitchelstown, County Cork on the 15th November, 2012.

0 Comments
2 Likes
Statistics
Notes
  • Be the first to comment

No Downloads
Views
Total views
1,885
On SlideShare
0
From Embeds
0
Number of Embeds
147
Actions
Shares
0
Downloads
34
Comments
0
Likes
2
Embeds 0
No embeds

No notes for slide

’Environmental Site Investigation and Due Diligence in the Current Market.’ APEA Presentation15 11 12

  1. 1. Environmental Site Investigation &Due Diligence in the Current Market Padraic Mulroy, BSc., MSc., MIEI, MIPSS, CSc, SiLC Managing Director Mulroy Environmental APEA Petroleum Seminar Firgrove Hotel Mitchelstown County Cork 15th November 2012
  2. 2. BACKGROUND MULROY ENVIRONMENTAL1 Background Who are we?2 Petrol Station- Facts • Based in Dundalk, County Louth (the Wee County)3 Environmental Liability? • Started in 20074 What’s in Petroleum Fuel? Services5 Environmental • Due Diligence Site Investigation/Contaminated Land Risk Site Assessment Assessment6 Risk Assessment • Remediation/Bioremediation of Contaminated Soil & Water7 Site Remediation • Waste Licence & Permit Applications8 Reality Check • IPPC Licensing9 Changes to Legislation • Wastewater Treatment Plant Design for Single, Small & Licensing Community, Commercial & Industrial Development • Site Suitability Assessment • Environmental Impact Assessment • Sludge Management Expertise • Environmental Monitoring Slide 2
  3. 3. BACKGROUND MULROY ENVIRONMENTAL1 Background2 Petrol Station- Facts Petroleum Sector Specific Services3 Environmental Liability? • Phase I Audits (Non-Intrusive) – Service Inspections with4 What’s in Petroleum Environmental Sensitivity Assessment Fuel? • Phase I Audits with Soil Vapour Surveys (Intrusive)5 Environmental • Phase II Site Investigation: Site Assessment • Supervision of drilling, groundwater & gas well installation6 Risk Assessment • Risk Assessment7 Site Remediation • Generic Quantitative Risk Assessment (GQRA)8 Reality Check • Detailed Quantitative Risk Assessment (DQRA)9 Changes to Legislation • Remedial Action Plans (RAPs) & Licensing • Remediation Supervision: • Dig & dump • Groundwater clean-up/NAPL removal/Soil Vapour Extraction/Dual Phase, etc • Post-remediation Close-out/Validation Reports Slide 3
  4. 4. PETROL RETAIL STATION - FACTS1 Background • Huge variety!2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation Old Roadside & Licensing Service Station Motorway Service (Old single skinned Station USTs partially (Double skinned under public road) USTs & pipework) Slide 4
  5. 5. PETROL RETAIL STATION - FACTS 2006 DOELG/ARUP Report on Petroleum Sector in ROI1 Background2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Number of retail sites in NI? Slide 5
  6. 6. ENVIRONMENTAL LIABILITY? - Why are they a threat to the environment? - Why are they an environmental liability?1 Background2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Slide 6
  7. 7. ENVIRONMENTAL LIABILITY? - Why are they a threat to the environment? - Why are they an environmental liability?1 Background WHAT IS BELOW GROUND LEVEL?2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Slide 7
  8. 8. ENVIRONMENTAL LIABILITY? - Why are they a threat to the environment? - Why are they an environmental liability?1 Background WHAT IS BELOW GROUND LEVEL?2 Petrol Station- Facts Product3 Environmental leaking from Liability? vent line-4 What’s in Petroleum historic Fuel? overfilling5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Slide 8
  9. 9. ENVIRONMENTAL LIABILITY? - Why are they a threat to the environment? - Why are they an environmental liability? WHAT CAN HAPPEN?1 Background2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Slide 9
  10. 10. ENVIRONMENTAL LIABILITY? - Why are they a threat to the environment? - Why are they an environmental liability? THIS IS WHAT CAN HAPPEN!1 Background2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Approx. 1,000l UL Petrol Contaminated 2574m3 or 1700 tonnes Slide 10
  11. 11. ENVIRONMENTAL LIABILITY? - Why are they a threat to the environment? - Why are they an environmental liability? THIS IS WHAT CAN HAPPEN!1 Background2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Significant site remediation costs! Slide 11
  12. 12. ENVIRONMENTAL LIABILITY? - Why are they a threat to the environment? - Why are they an environmental liability? THIS IS WHAT CAN HAPPEN!1 Background2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Slide 12
  13. 13. ENVIRONMENTAL LIABILITY? - Why are they a threat to the environment? - Why are they an environmental liability? THIS IS WHAT CAN HAPPEN!1 Background2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment Evacuated6 Risk Assessment houses7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Slide 13
  14. 14. WHAT’S IN PETROLEUM FUELS? - Why are petroleum fuels a threat to the environment?1 Background2 Petrol Station- Facts What are petrol, kersone and diesel?3 Environmental Liability? • Fractions of petroleum crude of various molecular4 What’s in Petroleum weight – petrol (light) to diesel (middle) to lube oil & Fuel? tars (heavy)5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Slide 14
  15. 15. WHAT’S IN PETROLEUM FUELS? – Why are they a threat to the environment?1 Background2 Petrol Station- Facts What are petrol, kerosone and diesel?3 Environmental Liability?4 What’s in Petroleum • Light Non-aqeous phase Liquids (NAPLs) – 0.8kg/l Fuel? density – they float5 Environmental Site Assessment • Various cocktails of aromatic, aliphatic heterocyclic6 Risk Assessment NSO & asphaltene compounds7 Site Remediation • Gasoline contains over 500 different compounds8 Reality Check Gas9 Changes to Legislation Chromatogram & Licensing of Gasoline Range Organics Slide 15
  16. 16. WHAT’S IN PETROLEUM FUELS? – Why are they a threat to the environment?1 Background2 Petrol Station- Facts What is in petrol, kerosone and diesel that3 Environmental Liability? make them dangerous?4 What’s in Petroleum • Key components are proven carcinogens: Fuel? – Benzene – petrol can contain up to 1% benzene5 Environmental Site Assessment – Polyaromatic Hydrocarbons e.g. naphthalene, etc6 Risk Assessment – Toluene – neurotoxic7 Site Remediation – MTBE – additive replaced Tetraethyllead as8 Reality Check anti-knocking agent. Also acts as oxygenate to9 Changes to Legislation boost Octane Number. & Licensing • Other components: – Mineral Oil – Total Aliphatic Fraction (Paraffins) Slide 16
  17. 17. ENVIRONMENTAL SITE ASSESSMENT Why get an assessment done? • Petrol retail company may have internal QA/QC requirements to get1 Background an environmental assessment of all company owned retail sites2 Petrol Station- Facts • Requirement of environmental insurance policy3 Environmental Liability? • Company may require a risk assessment to assess the relative risk from each site so that an environmental budget can be prioritized4 What’s in Petroleum for the high risk sites Fuel? • Owner or operators may suspect that there is a leak due to product5 Environmental losses showing up in the wet-stock inventory Site Assessment • Vapours may be detected by staff in the retail shop or other on site buildings which may be exceeding the Work Exposure Limit (WEL) or6 Risk Assessment approaching explosive risk7 Site Remediation • Vapours may be detected by neighbours in off-site property which may be exceeding the MEL or approaching explosive risk8 Reality Check • A UST or pipework may have failed a pressure test and site owner9 Changes to Legislation may suspect a leak has occurred but no evidence has showed up – & Licensing proactive approach! • A substantial overfill has occurred and site owner may want to determine the extent of soil and/or groundwater contamination Slide 17
  18. 18. ENVIRONMENTAL SITE ASSESSMENT Due Diligence - Most common scenario • A prospective Service Station purchaser/Developer submits a planning1 Background application for:2 Petrol Station- Facts – A new petrol station (i.e. raze and rebuild and continued petroleum use); or3 Environmental Liability? – A residential or mixed residential commercial development on petrol4 What’s in Petroleum retail site (i.e. change of use) • Draws up contract with vendor to purchase site in event of success or to Fuel? walk away if contamination is too severe or planning is refused5 Environmental • Buyer carries out site investigation, Generic Quantitative Risk Assessment (GQRA) and Detailed Quantitative Risk Assessment (DQRA) Site Assessment if site is severely contaminated6 Risk Assessment • Buyer draws up Remedial Action Plan (RAP) for site to break 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 advise • Planning permission obtained – Sale goes through • Remediation carried out as 1st Phase/Enabling Works • Close-out/Remediation Validation Report produced following completion of remediation Slide 18
  19. 19. ENVIRONMENTAL SITE ASSESSMENT What kind of assessment? • Phase I Audits (Non-Intrusive) – Client interview, operation1 Background assessment, service inspections with Environmental2 Petrol Station- Facts Sensitivity Assessment (i.e. Desk Study)3 Environmental Liability?4 What’s in Petroleum Fuel? • Phase I Audits - all of the above + Soil Vapour Survey5 Environmental (Intrusive) Site Assessment6 Risk Assessment7 Site Remediation • Phase II Site Investigation -Supervision of drilling,8 Reality Check groundwater & gas well installation followed by a Risk Assessment9 Changes to Legislation & Licensing • Generic Quantitative Risk Assessment (GQRA) • Detailed Quantitative Risk Assessment (DQRA) • May also contain Remedial Action Plans (RAPs) Slide 19
  20. 20. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Environmental Sensitivity1 Background • Desk Study:2 Petrol Station- Facts3 Environmental Liability? – Soil/subsoil, geology, hydrogeology (i.e. aquifer class and vulnerability, proximity to water abstraction wells/source protection areas), GSI Borehole records4 What’s in Petroleum within 500m of site – no records - may require door to door survey, aquifer class Fuel? and vulnerability – on-line GSI & EPA5 Environmental – Hydrology (i.e. discharges to surface water catchment) & OPW Site Assessment6 Risk Assessment – River Basin Management Districts Risk Assessment Reports for Groundwater &7 Site Remediation Surface Water Bodies8 Reality Check9 Changes to Legislation – Proximity of NHAs/SPA/SACs – On-line NPWS & Licensing – Proximity of residences, public houses or commercial premises (with cellars) – Review of historical mapping (previous uses?) – on-line OS & NMS – Review of available engineering, topographical & services drawings (i.e. previous uses of site, old tank farm locations, etc) – all drawings are relevant Slide 20
  21. 21. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Environmental Sensitivity1 Background2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Subsoil Map Vulnerability Map Slide 21
  22. 22. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Environmental Sensitivity1 Background2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Bedrock Map Source Protection Map Slide 22
  23. 23. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Operation Assessment1 Background • Interview with site owner:2 Petrol Station- Facts3 Environmental Liability? – Site Age? Raze & rebuild with soil remediation?4 What’s in Petroleum – Tank inventory - maximum age – any single skinned USTs >20-25 years Fuel? old? => risk increases5 Environmental – Underground Storage Tanks (USTs) - Product type, compartmentalized, Site Assessment single or double skinned, concrete encasement, etc6 Risk Assessment – Stock Inventory - Manual dips or fuel gauges?7 Site Remediation8 Reality Check – Decommissioned/disused USTs - Yes/No, completed with/without soil9 Changes to Legislation testing, decommissioned (i.e. product removal?, washed and/or degassed, & Licensing left empty or water-filled, foam or concrete filled or removed from site) – UST pressure testing - Yes/No, Satisfactory/unsatisfactory result – UST overspill protection - Yes/No – USTs installed on bedrock- Yes/No Slide 23
  24. 24. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Operation Assessment1 Background2 Petrol Station- Facts • Interview with site owner: Forgotten UST not on drawing!3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental 30 year old Site Assessment Concrete6 Risk Assessment Encased7 Site Remediation8 Reality Check UST9 Changes to Legislation discovered & Licensing during remediation works Slide 24
  25. 25. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Operation Assessment1 Background2 Petrol Station- Facts • Interview with site owner:3 Environmental Liability?4 What’s in Petroleum – Above ground storage tanks (ASTs) - Number? Volume? secondary Fuel? containment?5 Environmental Site Assessment – Secondary containment sufficient – ‘110% or 25% Total Volume’ Rule?6 Risk Assessment7 Site Remediation – History of secondary containment – installed after AST installation?, block wall or reinforced concrete walls, concrete lining, retain water,8 Reality Check bund integrity testing – pass of fail?9 Changes to Legislation & Licensing – Location of fill points – inside or outside bund? – Apertures or pipework (other than suction lines) running through bund? Slide 25
  26. 26. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Operation Assessment1 Background2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment No bund Bunded…7 Site Remediation but…8 Reality Check9 Changes to Legislation & Licensing Slide 26
  27. 27. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Operation Assessment1 Background2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Ideal Construction Slide 27
  28. 28. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Operation Assessment1 Background2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Ideal Construction Slide 28
  29. 29. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Operation Assessment1 Background • Interview with site owner:2 Petrol Station- Facts3 Environmental Liability? – Stormwater Discharge – Surface water or groundwater (existing or historical decommissioned soakaway?), history of downgradient surface4 What’s in Petroleum water contamination (fish kills?), Local Authority Section 12 Notices? Fuel? – Stormwater Interceptor - Present/absent, age, sufficient capacity,5 Environmental rainwater diverted?, evidence of product within the stream, river? Site Assessment6 Risk Assessment – Car wash facility - Present/absent, maintenance schedule (months), discharging to dedicated interceptor or stormwater interceptor =>7 Site Remediation emulsification of product8 Reality Check9 Changes to Legislation – Carwash Interceptor - Present/absent, age, discharge to foul sewer or & Licensing storm? maintenance schedule (months), evidence of foaming on adjacent surface water bodies? – On-site wastewater treatment system – Yes/No, accepting carwash water? Sufficient capacity – Garage or maintenance facility – Yes/No, disposal of waste lube oil? Interceptor used as receptacle? Slide 29
  30. 30. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Operation Assessment1 Background • Interview with site owner:2 Petrol Station- Facts3 Environmental Liability? – Volume Throughput of Product:4 What’s in Petroleum • <5,000m3 - over previous 5 years Fuel? • 5,000 – 15,000m3 - over previous 5 years • >15,000m3 - over previous 5 years5 Environmental Higher throughput >» Greater potential loss through overfilling Site Assessment6 Risk Assessment – Hardstanding: • Concrete – impermeable7 Site Remediation • Tarmac – significant permeability8 Reality Check • Cobblelock (on sand bed – no protection)9 Changes to Legislation • Surface quality - extent of cracks, negligible/localised/significant & Licensing – Evidence of surface contamination - None/minor/localised/significant Slide 30
  31. 31. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Operation Assessment1 Background2 Petrol Station- Facts3 Environmental Liability? • Interview with site owner:4 What’s in Petroleum Fuel? – Previous confirmed significant product surface loss (including overfills) or5 Environmental spillage within last 5 years – Volume? Cleaned up? Site Assessment6 Risk Assessment – Previous confirmed significant product loss from UST or other underground structure (e.g. pipeline) within last 5 years – Volume?7 Site Remediation Cleaned up?8 Reality Check9 Changes to Legislation – Stock Reconciliation – well managed computerised system with no & Licensing exceedances in previous 12 months? Slide 31
  32. 32. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Field Investigation1 Background • Site Inspection:2 Petrol Station- Facts – All services should be regarded as paths of least3 Environmental Liability? resistance & potential migration pathways (vapor and/or4 What’s in Petroleum liquid) Fuel? – Comprehensive service inspection – lift all service access5 Environmental manholes: Site Assessment • UST access chambers;6 Risk Assessment • Fuel gauge, electric and telecommunications manholes – any7 Site Remediation foam packing?;8 Reality Check • Stormwater, carwash and interceptor access manholes – dip9 Changes to Legislation interceptor chambers to determine product thickness & Licensing • Foul sewers & on-site septic tanks & percolation areas • Rainwater pipework access chambers • Water main & fire hydrant lines Slide 32
  33. 33. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Field Investigation • Site Inspection:1 Background2 Petrol Station- Facts – LIFT EVERY MANHOLE & TAKE VAPOUR READINGS3 Environmental Liability? ON ALL CHAMBERS USING PHOTOIONISATION4 What’s in Petroleum DETECTOR (PID) & LOG Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Slide 33
  34. 34. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Field Investigation • Site Inspection:1 Background S OM2 Petrol Station- Facts EC3 Environmental Liability? L TE4 What’s in Petroleum B/ Fuel? ST ES O5 Environmental RM Site Assessment VE N T L6 Risk Assessment U LI FO7 Site Remediation N E8 Reality Check N LINE9 Changes to Legislation SUCTIO & Licensing PETROL STATION SERVICES = OFF-SITE SPAGHETTI MIGRATION JUNCTIONS! Slide 34
  35. 35. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Field Investigation1 Background2 Petrol Station- Facts • Site Inspection:3 Environmental Liability? – Use your nose and eyes but trust more in science –4 What’s in Petroleum • Photo-ionisation Detectors (PIDs) – pick up VOCs to ppb; and Fuel? • Interface Probe for measuring product thickness5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Slide 35
  36. 36. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Field Investigation1 Background • Site Inspection:2 Petrol Station- Facts – Any visible evidence (i.e. staining, vegetation die-back,3 Environmental Liability? etc) present;4 What’s in Petroleum – Quality of hardstanding/surface material; Fuel? – Condition of bunding on ASTs – water5 Environmental retention/integrity? external staining? Site Assessment – Condition of receiving surface drains or bodies6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Emulsified product in Land drain Slide 36
  37. 37. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Field Investigation1 Background • Site Inspection:2 Petrol Station- Facts – Where leakage is suspected, inspection of street service3 Environmental Liability? manholes subject to permission of LAs or owners4 What’s in Petroleum – Inspection of local excavation works, culverts, basements Fuel? in public houses if adjacent5 Environmental – DON’T ASSUME IF IMMEDIATE NEIGHBOURS HAVE Site Assessment NEVER COMPLAINED THAT THERE IS NO PROBLEM6 Risk Assessment UNDERGROUND!7 Site Remediation8 Reality Check9 Changes to Legislation SOURCE – PATHWAY –TARGET & Licensing TARGET MAY BE 0.1KM – 2KM DOWN THE ROAD! Slide 37
  38. 38. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Soil Vapour Survey1 Background • Soil Vapour Survey (SVS):2 Petrol Station- Facts – Detailed & ‘as-built’ drawings to aid in optimizing locations3 Environmental Liability? – Services checked using Cable Avoidance Tool (CATSCAN)4 What’s in Petroleum – Holes drilled using intrinsically safe pneumatic drill – get through Fuel? hardstanding5 Environmental – Probabar to achieve gas sampling depths @0.6m and 1.0m Site Assessment – Ideally 10m herringbone grid6 Risk Assessment – Max. & minimum readings taken7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Slide 38
  39. 39. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Soil Vapour Survey1 Background2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation Mean: 1.05 ppm & Licensing Median: 1 ppm Max: 4 ppm 40 Min: 0 ppm 35 30 Frequency 25 20 15 10 5 0 More 50 100 200 250 350 400 500 10 150 300 450 Range in soil vapour values (ppm) Slide 39
  40. 40. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Soil Vapour Survey1 Background2 Petrol Station- Facts • Soil Vapour Survey (SVS):3 Environmental Liability? Advantages:4 What’s in Petroleum – Inexpensive way of delineating a contaminant plume on Fuel? site5 Environmental – Very good in detecting leaks from suction & fill lines Site Assessment6 Risk Assessment – Up to 25 * 1.0m depth points in a day7 Site Remediation – Minimal disruption to on-going business – cordon off of8 Reality Check working area9 Changes to Legislation – Can be used at boundary to determine if off-site & Licensing migration of vapours is occurring in shallow soils – Aid in determination of suitable locations for window sampling investigation points and groundwater and/or monitoring wells Slide 40
  41. 41. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Soil Vapour Survey1 Background • Soil Vapour Survey (SVS):2 Petrol Station- Facts Disdvantages:3 Environmental Liability? – Limit to depth – can obtain lower than 1.0m depths in soft4 What’s in Petroleum subsoils but will slow project down – cost effectiveness! Fuel? – Even with water traps, Photo-ionisation detectors do not5 Environmental perform well during high moisture/cold environments Site Assessment with ‘Zeroing’ required between each reading –6 Risk Assessment technology’s achilles heel!7 Site Remediation – Works well where subsoil is relatively permeable and in8 Reality Check permeable made ground where groundwater table is9 Changes to Legislation & Licensing greater than 1m below ground level – In low permeability soils where point source leak is at depth (i.e. from UST), may not detect in the upper 1m Slide 41
  42. 42. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Soil Vapour Survey1 Background • Soil Vapour Survey (SVS):2 Petrol Station- Facts Disdvantages:3 Environmental Liability? – PIDs react well to BTEX compounds (i.e. mono-aromatics)4 What’s in Petroleum but wont detect diesel vapours – need to use in Fuel? conjunction with Draeger tubes – however cost!5 Environmental – In winter conditions where soil is cold and saturated, Site Assessment SVSs should not be carried out - Henry’s Law!6 Risk Assessment7 Site Remediation8 Reality Check FALSE NEGATIVE RESULTS - SITE IS OK?9 Changes to Legislation & Licensing COLD WEARTHER SVS - WASTE OF MONEY! BE PATIENT - WAIT FOR GOOD DRY WEATER Slide 42
  43. 43. ENVIRONMENTAL SITE ASSESSMENT Phase I Audits – Overall Results1 Background Site falls into one of 5 ‘Site Groups’:2 Petrol Station- Facts 1. Evidence obtained of offsite odours or product, which3 Environmental Liability? are associated with the site4 What’s in Petroleum 2. Evidence obtained of significant sub-surface, on-site Fuel? contamination but no hard evidence of offsite5 Environmental contamination Site Assessment 3. Probable on-site problems6 Risk Assessment 4. Possible on-site problems or specific engineering7 Site Remediation concerns8 Reality Check 5. No on-site problems9 Changes to Legislation & Licensing GROUP 1 & 2 SITES ARE PRIORITISED FOR PHASE II SITE INVESTIGATION & RISK ASSESSMENT Slide 43
  44. 44. ENVIRONMENTAL SITE ASSESSMENT Phase II Site Investigation (Intrusive)1 Background FIRST STEP – DRAW UP A CONCEPTUAL SITE MODEL (CSM)2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Slide 44
  45. 45. ENVIRONMENTAL SITE ASSESSMENT Phase II Site Investigation (Intrusive)1 Background FOCUS ON KEY CONCEPT2 Petrol Station- Facts3 Environmental Liability? SOURCE - PATHWAY -TARGET (OR RECEPTOR)4 What’s in Petroleum Fuel?  Must have all 3 to result in an exposure to a contaminant5 Environmental Site Assessment  If one is missing the chain is broken.6 Risk Assessment  In remediating or abating you’re trying to break that chain7 Site Remediation8 Reality Check  Remove the Source (dig out the contamination, GW pumping, etc)9 Changes to Legislation & Licensing  Close off the pathway (Cap the waste/Cut-off wall, PRB, etc)  Protect the receptor (relocate) Slide 45
  46. 46. ENVIRONMENTAL SITE ASSESSMENT Phase II Site Investigation (Intrusive)1 Background  Good news for British Consultants - process is identical to UK – Irish EPA have taken guidance from UK EA2 Petrol Station- Facts  Source-Pathway-Target3 Environmental Liability?  Conceptual Site Model4 What’s in Petroleum  Suitability for end-use  SI Standards: Fuel?  BS5930:1999 Code of practice for Site Investigations5 Environmental  BS10175:2011 Investigation of Potentially Contaminated Sites Site Assessment  RA Guidance:6 Risk Assessment  CLR 11. Model Procedures for the Management of Land Contamination7 Site Remediation  EPA Code of Practice ‘Environmental Risk Assessment for Unregulated Waste Disposal Sites’ in April 20078 Reality Check9 Changes to Legislation  EPA recognise there is a legal gap and a guidance gap with regard to non-historic & Licensing waste brownfields i.e. brownfield petrol retail sites  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 46
  47. 47. ENVIRONMENTAL SITE ASSESSMENT Phase II Site Investigation (Intrusive)1 Background GOLDEN RULES:2 Petrol Station- Facts3 Environmental Liability? 1. Log soils to BS5930:1999 Site Investigation – universal4 What’s in Petroleum language for geologists/engineers; Fuel? 2. Design site investigation to be consistent with BS10175:20115 Environmental Investigation of potentially contaminated sites – Code of Site Assessment practice….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 3. Beware of cross-contamination…..hydraulic fluid, etc; and9 Changes to Legislation 4. Make sure laboratory suite is correct for type of contaminants & Licensing found on site e.g. TPH-Core Working Group Slide 47
  48. 48. ENVIRONMENTAL SITE ASSESSMENT Phase II Site Investigation (Intrusive)1 Background • Priority – get access to underlying made ground, subsoil2 Petrol Station- Facts and groundwater if possible to take soil and/or3 Environmental Liability? groundwater samples for laboratory analysis4 What’s in Petroleum • Window Sampling – Fuel? – Track mounted percussive rig – least disruption, limited5 Environmental to max of 5-6m (normally 3.0-3.5m), access to Site Assessment groundwater may not be possible if SWL is lower, for well6 Risk Assessment construction - problem of smearing in cohesive soils,7 Site Remediation works best in permeable sands/gravels8 Reality Check9 Changes to Legislation – Takes a ‘window core sample’ of soil profile & Licensing – Biggest advantage - manoeuvrability and small head height for getting under canopies – Biggest disadvantage - it struggles in stiff soils and will refuse on boulders and stiff made ground – Suitable for Generic Quantitative Risk Assessment & sometimes for DQRA Slide 48
  49. 49. ENVIRONMENTAL SITE ASSESSMENT Phase II Site Investigation (Intrusive)1 Background • Window Sampling –2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation Soil8 Reality Check Cores9 Changes to Legislation & Licensing Headspace Testing Slide 49
  50. 50. ENVIRONMENTAL SITE ASSESSMENT Phase II Site Investigation (Intrusive)1 Background • Window Sampling –2 Petrol Station- Facts – Can install shallow groundwater and gas monitoring wells3 Environmental Liability? up to 6m total depth – most are 3.0-3.5m total depth4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Slide 50
  51. 51. ENVIRONMENTAL SITE ASSESSMENT Phase II Site Investigation (Intrusive)1 Background • If window sampling does not reach the groundwater table2 Petrol Station- Facts and groundwater contamination is suspected3 Environmental Liability? • If you found severe contamination – want to delineate extent4 What’s in Petroleum of plume – vertically and horizontally – not possible with Fuel? window sampling due to depth of contamination and bedrock5 Environmental • A Detailed Quantitative Risks Assessment is required Site Assessment6 Risk Assessment YOU NEED A BIGGER RIG!7 Site Remediation  Shell & Auger – good for depth & logging of soils, but slow8 Reality Check particularly on boulder tills, only to top of competent rock9 Changes to Legislation & Licensing  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 reliable for VOCs – most expensive but access to groundwater is nearly guaranteed if the budget can pay for depth Slide 51
  52. 52. ENVIRONMENTAL SITE ASSESSMENT Phase II Site Investigation (Intrusive)1 Background Shell &2 Petrol Station- Facts Auger3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Air Rotary Slide 52
  53. 53. RISK ASSESSMENT MAINTAIN FOCUS ON KEY CONCEPT1 Background SOURCE PATHWAY TARGET (OR RECEPTOR)2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Refine Conceptual Site Model (CSM) Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Slide 53
  54. 54. RISK ASSESSMENT Refine Conceptual Site Model (CSM)1 Background2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Slide 54
  55. 55. RISK ASSESSMENT SOIL GENERIC ASSESSMENT CRITERIA FOR1 Background PETROLEUM SITE GENERIC QRA2 Petrol Station- Facts3 Environmental Liability?4 What’s in Petroleum Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Slide 55
  56. 56. RISK ASSESSMENT DETAILED QRA –1 Background DERIVE SITE SPECIFIC TARGET LEVELS (SSTLs)2 Petrol Station- Facts3 Environmental Liability? 4 COMMON MODELS4 What’s in Petroleum Fuel?  Contaminated Land Exposure Assessment (CLEA) Model – Soil5 Environmental Guideline Values, 2009 (Soil lab data); Site Assessment6 Risk Assessment  Risk Based Corrective Assessment (RBCA) Model (Soil & water7 Site Remediation lab data);8 Reality Check9 Changes to Legislation  Environment Agency Remedial Targets Methodology 2006(8) – & Licensing Controlled Waters.  RISC-HUMAN Model (Site Specific DQRAs) Slide 56
  57. 57. SITE REMEDATION BREAK THE S-P-T CHAIN SOURCE  Remove – Dig & dump but where does it go?  No Hazardous Waste landfills but…1 Background  1 * Hazardous Waste Treatment (Bioremediation) - ENVA Facility in2 Petrol Station- Facts Portlaoise – accepts hydrocarbon contaminated soil with Mineral Oil>500mg/kg3 Environmental Liability?  1 * Hazardous Waste Transfer Station – RILTA Faciity in4 What’s in Petroleum Greenogue – accepts & exports hydrocarbon contaminated soil with Fuel? Mineral Oil>500mg/kg5 Environmental  1 * Non-Hazardous Waste Landfill which can accept hydrocarbon contamination with Mineral Oil<500mg/kg & Total 17 PAH<100mg/kg Site Assessment  1 * Non-Hazardous Waste Landfill which can accept hydrocarbon6 Risk Assessment contamination with TPH<1,000mg/kg (also only landfill which accepts asbestos C&D waste7 Site Remediation  1 * Inert Waste Landfill which can accept only C&D. No hydrocarbon8 Reality Check contamination.9 Changes to Legislation  Cost of disposal of Hazardous Waste/hydrocarbon contaminated & Licensing 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 57
  58. 58. 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 Petrol Station- Facts  Removing hydrocarbons from groundwater (e.g. pump & treat, dual- phase extraction, etc) may require just a LA Discharge Licence.3 Environmental Liability?  Soil Vapour Extraction (e.g. petrol retail station remediation) or use4 What’s in Petroleum of Oxygen or Hydrogen Release Compounds (ORCs or HRCs) – no Fuel? approval required5 Environmental  PATHWAY Site Assessment  Isolate the hazard – vapour cut-off walls, PRBs, capping, LF gas6 Risk Assessment venting – significant groundworks & may require planning7 Site Remediation  Dust suppression – landscaping/capping8 Reality Check  Immobilise – lime stabilisation…however, getting into waste licence activity9 Changes to Legislation & Licensing  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 58
  59. 59. REALITY CHECK  DRIVERS  Brownfield Developers need reasons not to go for a greenfield site…one of those reasons has to be a financial one!1 Background  Most Irish LAs lack expertise in contaminated land unlike UK LAs where2 Petrol Station- Facts there is often a dedicated Contaminated Land Officer…consultant telling the3 Environmental Liability? regulator what questions she/he should be asking.4 What’s in Petroleum  Often Irish LAs request the assistance of the EPA or hire external consultant/expert….this takes correspondence and….time Fuel?  Following SI and RA, if dig & dump solution too expensive and on-site5 Environmental remediation is option (i.e. enough space & time), Pre-waste Licence Site Assessment Application Process needs to be initiated. Applying for a Waste Licence is6 Risk Assessment prohibitive on a number of fronts:7 Site Remediation  Republic - Cost €16k (i.e. €10k application fee + €6k surrender fee) – as yet no applicants since WMA 19968 Reality Check  Northern Ireland – Cost €6.9k Total– currently 4 mobile licences9 Changes to Legislation  Time to acquire licence – no fixed time for process & Licensing  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 59
  60. 60. REALITY CHECK  DRIVERS  Contaminated soil (i.e. Hazardous waste) disposal is too expensive in1 Background Ireland.2 Petrol Station- Facts  In most petrol retail remediation projects dig & dump is the only3 Environmental Liability? solution – built up areas, no space, etc.  Contractors are afraid to dig in brownfield site…if it’s4 What’s in Petroleum contaminated it’s a waste & an offence to bury it! Fuel?5 Environmental Site Assessment6 Risk Assessment7 Site Remediation8 Reality Check9 Changes to Legislation & Licensing Slide 60
  61. 61. CHANGES TO LEGISLATION & WASTE LICENSING?  Adopt key areas of Soil Framework Directive in new Contaminated Land1 Background Regulations – shore up legal lacuna2 Petrol Station- Facts3 Environmental Liability?  EPA to take responsibility for non-historic waste brownfield sites4 What’s in Petroleum  Second a qualified EPA staff member to work as a Contaminated Land Officer (CLO) for a number of LAs (e.g. regional waste region – 2-3 LAs) Fuel?  CLO to draw up Contaminated Land register of non-historic waste for each5 Environmental county (WMA Section 26 Register?) Site Assessment  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 consider introduction of mobile licence applications as per NI & Licensing  EPA provide fixed timescale for waste licence applications WHY? ……DEVELOPERS DON’T LIKE IF’S & UNKNOWNS!  GIVE THEM REASONABLY ACCURATE NUMBERS & TIMELINES! Slide 61
  62. 62. THANK YOU! Slide 62

×