’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.

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. BACKGROUND
MULROY ENVIRONMENTAL
1 Background
Who are we?
2 Petrol Station- Facts
• Based in Dundalk, County Louth (the Wee County)
3 Environmental Liability?
• Started in 2007
4 What’s in Petroleum
Fuel? Services
5 Environmental
• Due Diligence Site Investigation/Contaminated Land Risk
Site Assessment Assessment
6 Risk Assessment • Remediation/Bioremediation of Contaminated Soil & Water
7 Site Remediation • Waste Licence & Permit Applications
8 Reality Check • IPPC Licensing
9 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. BACKGROUND
MULROY ENVIRONMENTAL
1 Background
2 Petrol Station- Facts
Petroleum Sector Specific Services
3 Environmental Liability? • Phase I Audits (Non-Intrusive) – Service Inspections with
4 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 installation
6 Risk Assessment • Risk Assessment
7 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. PETROL RETAIL STATION - FACTS
1 Background • Huge variety!
2 Petrol Station- Facts
3 Environmental Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 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. PETROL RETAIL STATION - FACTS
2006 DOELG/ARUP Report on Petroleum Sector in
ROI
1 Background
2 Petrol Station- Facts
3 Environmental Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Number of retail sites in NI?
Slide 5

6. ENVIRONMENTAL LIABILITY?
- Why are they a threat to the environment?
- Why are they an environmental liability?
1 Background
2 Petrol Station- Facts
3 Environmental
Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Slide 6

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- Facts
3 Environmental
Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Slide 7

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
Product
3 Environmental leaking from
Liability?
vent line-
4 What’s in Petroleum
historic
Fuel?
overfilling
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Slide 8

9. ENVIRONMENTAL LIABILITY?
- Why are they a threat to the environment?
- Why are they an environmental liability?
WHAT CAN HAPPEN?
1 Background
2 Petrol Station- Facts
3 Environmental
Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Slide 9

10. ENVIRONMENTAL LIABILITY?
- Why are they a threat to the environment?
- Why are they an environmental liability?
THIS IS WHAT CAN HAPPEN!
1 Background
2 Petrol Station- Facts
3 Environmental
Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Approx. 1,000l UL Petrol
Contaminated 2574m3 or
1700 tonnes Slide 10

11. ENVIRONMENTAL LIABILITY?
- Why are they a threat to the environment?
- Why are they an environmental liability?
THIS IS WHAT CAN HAPPEN!
1 Background
2 Petrol Station- Facts
3 Environmental
Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Significant site
remediation costs!
Slide 11

12. ENVIRONMENTAL LIABILITY?
- Why are they a threat to the environment?
- Why are they an environmental liability?
THIS IS WHAT CAN HAPPEN!
1 Background
2 Petrol Station- Facts
3 Environmental
Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Slide 12

13. ENVIRONMENTAL LIABILITY?
- Why are they a threat to the environment?
- Why are they an environmental liability?
THIS IS WHAT CAN HAPPEN!
1 Background
2 Petrol Station- Facts
3 Environmental
Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment Evacuated
6 Risk Assessment houses
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Slide 13

14. WHAT’S IN PETROLEUM FUELS?
- Why are petroleum fuels a threat to the
environment?
1 Background
2 Petrol Station- Facts
What are petrol, kersone and diesel?
3 Environmental Liability? • Fractions of petroleum crude of various molecular
4 What’s in Petroleum weight – petrol (light) to diesel (middle) to lube oil &
Fuel? tars (heavy)
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Slide 14

15. WHAT’S IN PETROLEUM FUELS? –
Why are they a threat to the environment?
1 Background
2 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 float
5 Environmental
Site Assessment
• Various cocktails of aromatic, aliphatic heterocyclic
6 Risk Assessment
NSO & asphaltene compounds
7 Site Remediation • Gasoline contains over 500 different compounds
8 Reality Check
Gas
9 Changes to Legislation Chromatogram
& Licensing of Gasoline
Range Organics
Slide 15

16. WHAT’S IN PETROLEUM FUELS? –
Why are they a threat to the environment?
1 Background
2 Petrol Station- Facts
What is in petrol, kerosone and diesel that
3 Environmental Liability? make them dangerous?
4 What’s in Petroleum • Key components are proven carcinogens:
Fuel?
– Benzene – petrol can contain up to 1% benzene
5 Environmental
Site Assessment
– Polyaromatic Hydrocarbons e.g. naphthalene, etc
6 Risk Assessment – Toluene – neurotoxic
7 Site Remediation – MTBE – additive replaced Tetraethyllead as
8 Reality Check anti-knocking agent. Also acts as oxygenate to
9 Changes to Legislation boost Octane Number.
& Licensing
• Other components:
– Mineral Oil – Total Aliphatic Fraction (Paraffins)
Slide 16

17. ENVIRONMENTAL SITE ASSESSMENT
Why get an assessment done?
• Petrol retail company may have internal QA/QC requirements to get
1 Background an environmental assessment of all company owned retail sites
2 Petrol Station- Facts • Requirement of environmental insurance policy
3 Environmental Liability? • Company may require a risk assessment to assess the relative risk
from each site so that an environmental budget can be prioritized
4 What’s in Petroleum for the high risk sites
Fuel? • Owner or operators may suspect that there is a leak due to product
5 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) or
6 Risk Assessment approaching explosive risk
7 Site Remediation • Vapours may be detected by neighbours in off-site property which
may be exceeding the MEL or approaching explosive risk
8 Reality Check
• A UST or pipework may have failed a pressure test and site owner
9 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. ENVIRONMENTAL SITE ASSESSMENT
Due Diligence - Most common scenario
• A prospective Service Station purchaser/Developer submits a planning
1 Background application for:
2 Petrol Station- Facts – A new petrol station (i.e. raze and rebuild and continued petroleum
use); or
3 Environmental Liability? – A residential or mixed residential commercial development on petrol
4 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 refused
5 Environmental • Buyer carries out site investigation, Generic Quantitative Risk
Assessment (GQRA) and Detailed Quantitative Risk Assessment (DQRA)
Site Assessment if site is severely contaminated
6 Risk Assessment • Buyer draws up Remedial Action Plan (RAP) for site to break Source-
Pathway-Receptor link
7 Site Remediation
• Has a sit down with the vendor to give him/her the DQRA/RAP
8 Reality Check report/cost of clean-up. Negotiate on price reduction
9 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. ENVIRONMENTAL SITE ASSESSMENT
What kind of assessment?
• Phase I Audits (Non-Intrusive) – Client interview, operation
1 Background
assessment, service inspections with Environmental
2 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 Survey
5 Environmental (Intrusive)
Site Assessment
6 Risk Assessment
7 Site Remediation • Phase II Site Investigation -Supervision of drilling,
8 Reality Check
groundwater & gas well installation followed by a Risk
Assessment
9 Changes to Legislation
& Licensing
• Generic Quantitative Risk Assessment (GQRA)
• Detailed Quantitative Risk Assessment (DQRA)
• May also contain Remedial Action Plans (RAPs)
Slide 19

20. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits –
Environmental Sensitivity
1 Background • Desk Study:
2 Petrol Station- Facts
3 Environmental Liability? – Soil/subsoil, geology, hydrogeology (i.e. aquifer class and vulnerability, proximity
to water abstraction wells/source protection areas), GSI Borehole records
4 What’s in Petroleum within 500m of site – no records - may require door to door survey, aquifer class
Fuel? and vulnerability – on-line GSI & EPA
5 Environmental
– Hydrology (i.e. discharges to surface water catchment) & OPW
Site Assessment
6 Risk Assessment
– River Basin Management Districts Risk Assessment Reports for Groundwater &
7 Site Remediation Surface Water Bodies
8 Reality Check
9 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. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits –
Environmental Sensitivity
1 Background
2 Petrol Station- Facts
3 Environmental Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Subsoil Map
Vulnerability
Map
Slide 21

22. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits –
Environmental Sensitivity
1 Background
2 Petrol Station- Facts
3 Environmental Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Bedrock Map Source
Protection
Map
Slide 22

23. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits –
Operation Assessment
1 Background • Interview with site owner:
2 Petrol Station- Facts
3 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 increases
5 Environmental
– Underground Storage Tanks (USTs) - Product type, compartmentalized,
Site Assessment single or double skinned, concrete encasement, etc
6 Risk Assessment
– Stock Inventory - Manual dips or fuel gauges?
7 Site Remediation
8 Reality Check
– Decommissioned/disused UST's - Yes/No, completed with/without soil
9 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. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits –
Operation Assessment
1 Background
2 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
Concrete
6 Risk Assessment
Encased
7 Site Remediation
8 Reality Check
UST
9 Changes to Legislation discovered
& Licensing during
remediation
works
Slide 24

25. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits –
Operation Assessment
1 Background
2 Petrol Station- Facts • Interview with site owner:
3 Environmental Liability?
4 What’s in Petroleum – Above ground storage tanks (AST's) - Number? Volume? secondary
Fuel? containment?
5 Environmental
Site Assessment – Secondary containment sufficient – ‘110% or 25% Total Volume’ Rule?
6 Risk Assessment
7 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. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits –
Operation Assessment
1 Background
2 Petrol Station- Facts
3 Environmental Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment No bund Bunded…
7 Site Remediation
but…
8 Reality Check
9 Changes to Legislation
& Licensing
Slide 26

27. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits –
Operation Assessment
1 Background
2 Petrol Station- Facts
3 Environmental Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Ideal
Construction
Slide 27

28. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits –
Operation Assessment
1 Background
2 Petrol Station- Facts
3 Environmental Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Ideal
Construction
Slide 28

29. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits –
Operation Assessment
1 Background • Interview with site owner:
2 Petrol Station- Facts
3 Environmental Liability? – Stormwater Discharge – Surface water or groundwater (existing or
historical decommissioned soakaway?), history of downgradient surface
4 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 Assessment
6 Risk Assessment – Car wash facility - Present/absent, maintenance schedule (months),
discharging to dedicated interceptor or stormwater interceptor =>
7 Site Remediation emulsification of product
8 Reality Check
9 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. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits –
Operation Assessment
1 Background
• Interview with site owner:
2 Petrol Station- Facts
3 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 years
5 Environmental
Higher throughput >» Greater potential loss through overfilling
Site Assessment
6 Risk Assessment – Hardstanding:
• Concrete – impermeable
7 Site Remediation
• Tarmac – significant permeability
8 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. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits –
Operation Assessment
1 Background
2 Petrol Station- Facts
3 Environmental Liability? • Interview with site owner:
4 What’s in Petroleum
Fuel? – Previous confirmed significant product surface loss (including overfills) or
5 Environmental spillage within last 5 years – Volume? Cleaned up?
Site Assessment
6 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 Check
9 Changes to Legislation
– Stock Reconciliation – well managed computerised system with no
& Licensing
exceedances in previous 12 months?
Slide 31

32. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits – Field Investigation
1 Background • Site Inspection:
2 Petrol Station- Facts – All services should be regarded as paths of least
3 Environmental Liability? resistance & potential migration pathways (vapor and/or
4 What’s in Petroleum liquid)
Fuel? – Comprehensive service inspection – lift all service access
5 Environmental manholes:
Site Assessment • UST access chambers;
6 Risk Assessment • Fuel gauge, electric and telecommunications manholes – any
7 Site Remediation foam packing?;
8 Reality Check • Stormwater, carwash and interceptor access manholes – dip
9 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. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits – Field Investigation
• Site Inspection:
1 Background
2 Petrol Station- Facts – LIFT EVERY MANHOLE & TAKE VAPOUR READINGS
3 Environmental Liability? ON ALL CHAMBERS USING PHOTOIONISATION
4 What’s in Petroleum DETECTOR (PID) & LOG
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Slide 33

34. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits – Field Investigation
• Site Inspection:
1 Background
S
OM
2 Petrol Station- Facts
EC
3 Environmental Liability?
L
TE
4 What’s in Petroleum
B/
Fuel? ST
ES
O
5 Environmental RM
Site Assessment VE
N
T
L
6 Risk Assessment
U
LI
FO
7 Site Remediation N
E
8 Reality Check
N LINE
9 Changes to Legislation SUCTIO
& Licensing
PETROL STATION
SERVICES =
OFF-SITE SPAGHETTI
MIGRATION JUNCTIONS!
Slide 34

35. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits – Field Investigation
1 Background
2 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 thickness
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Slide 35

36. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits – Field Investigation
1 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 – water
5 Environmental
retention/integrity? external staining?
Site Assessment
– Condition of receiving surface drains or bodies
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Emulsified
product in
Land drain
Slide 36

37. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits – Field Investigation
1 Background • Site Inspection:
2 Petrol Station- Facts – Where leakage is suspected, inspection of street service
3 Environmental Liability? manholes subject to permission of LAs or owners
4 What’s in Petroleum – Inspection of local excavation works, culverts, basements
Fuel? in public houses if adjacent
5 Environmental – DON’T ASSUME IF IMMEDIATE NEIGHBOURS HAVE
Site Assessment NEVER COMPLAINED THAT THERE IS NO PROBLEM
6 Risk Assessment UNDERGROUND!
7 Site Remediation
8 Reality Check
9 Changes to Legislation
SOURCE – PATHWAY –TARGET
& Licensing
TARGET MAY BE 0.1KM – 2KM DOWN THE ROAD!
Slide 37

38. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits – Soil Vapour Survey
1 Background • Soil Vapour Survey (SVS):
2 Petrol Station- Facts – Detailed & ‘as-built’ drawings to aid in optimizing locations
3 Environmental Liability? – Services checked using Cable Avoidance Tool (CATSCAN)
4 What’s in Petroleum – Holes drilled using intrinsically safe pneumatic drill – get through
Fuel? hardstanding
5 Environmental – Probabar to achieve gas sampling depths @0.6m and 1.0m
Site Assessment – Ideally 10m herringbone grid
6 Risk Assessment – Max. & minimum readings taken
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Slide 38

39. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits – Soil Vapour Survey
1 Background
2 Petrol Station- Facts
3 Environmental Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 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. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits – Soil Vapour Survey
1 Background
2 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? site
5 Environmental
– Very good in detecting leaks from suction & fill lines
Site Assessment
6 Risk Assessment
– Up to 25 * 1.0m depth points in a day
7 Site Remediation – Minimal disruption to on-going business – cordon off of
8 Reality Check working area
9 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. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits – Soil Vapour Survey
1 Background • Soil Vapour Survey (SVS):
2 Petrol Station- Facts Disdvantages:
3 Environmental Liability? – Limit to depth – can obtain lower than 1.0m depths in soft
4 What’s in Petroleum subsoils but will slow project down – cost effectiveness!
Fuel?
– Even with water traps, Photo-ionisation detectors do not
5 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 in
8 Reality Check
permeable made ground where groundwater table is
9 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. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits – Soil Vapour Survey
1 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 Assessment
7 Site Remediation
8 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. ENVIRONMENTAL SITE ASSESSMENT
Phase I Audits – Overall Results
1 Background Site falls into one of 5 ‘Site Groups’:
2 Petrol Station- Facts 1. Evidence obtained of offsite odours or product, which
3 Environmental Liability? are associated with the site
4 What’s in Petroleum 2. Evidence obtained of significant sub-surface, on-site
Fuel? contamination but no hard evidence of offsite
5 Environmental contamination
Site Assessment 3. Probable on-site problems
6 Risk Assessment
4. Possible on-site problems or specific engineering
7 Site Remediation
concerns
8 Reality Check
5. No on-site problems
9 Changes to Legislation
& Licensing
GROUP 1 & 2 SITES ARE PRIORITISED FOR PHASE II
SITE INVESTIGATION & RISK ASSESSMENT
Slide 43

44. ENVIRONMENTAL SITE ASSESSMENT
Phase II Site Investigation (Intrusive)
1 Background
FIRST STEP – DRAW UP A CONCEPTUAL SITE MODEL (CSM)
2 Petrol Station- Facts
3 Environmental Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Slide 44

45. ENVIRONMENTAL SITE ASSESSMENT
Phase II Site Investigation (Intrusive)
1 Background
FOCUS ON KEY CONCEPT
2 Petrol Station- Facts
3 Environmental Liability?
SOURCE - PATHWAY -TARGET (OR RECEPTOR)
4 What’s in Petroleum
Fuel?  Must have all 3 to result in an exposure to a contaminant
5 Environmental
Site Assessment  If one is missing the chain is broken.
6 Risk Assessment
 In remediating or abating you’re trying to break that chain
7 Site Remediation
8 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. 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 EA
2 Petrol Station- Facts
 Source-Pathway-Target
3 Environmental Liability?  Conceptual Site Model
4 What’s in Petroleum  Suitability for end-use
 SI Standards:
Fuel?
 BS5930:1999 Code of practice for Site Investigations
5 Environmental  BS10175:2011 Investigation of Potentially Contaminated Sites
Site Assessment
 RA Guidance:
6 Risk Assessment  CLR 11. Model Procedures for the Management of Land Contamination
7 Site Remediation  EPA Code of Practice ‘Environmental Risk Assessment for Unregulated Waste
Disposal Sites’ in April 2007
8 Reality Check
9 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. ENVIRONMENTAL SITE ASSESSMENT
Phase II Site Investigation (Intrusive)
1 Background
GOLDEN RULES:
2 Petrol Station- Facts
3 Environmental Liability? 1. Log soils to BS5930:1999 Site Investigation – universal
4 What’s in Petroleum
language for geologists/engineers;
Fuel? 2. Design site investigation to be consistent with BS10175:2011
5 Environmental Investigation of potentially contaminated sites – Code of
Site Assessment practice….remember..the purpose of the site investigation is to
6 Risk Assessment get access to the media (soil, groundwater or gas). Look at
7 Site Remediation density of monitoring points (i.e. herringbone, etc);
8 Reality Check 3. Beware of cross-contamination…..hydraulic fluid, etc; and
9 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. ENVIRONMENTAL SITE ASSESSMENT
Phase II Site Investigation (Intrusive)
1 Background • Priority – get access to underlying made ground, subsoil
2 Petrol Station- Facts and groundwater if possible to take soil and/or
3 Environmental Liability? groundwater samples for laboratory analysis
4 What’s in Petroleum
• Window Sampling –
Fuel?
– Track mounted percussive rig – least disruption, limited
5 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 well
6 Risk Assessment
construction - problem of smearing in cohesive soils,
7 Site Remediation
works best in permeable sands/gravels
8 Reality Check
9 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. ENVIRONMENTAL SITE ASSESSMENT
Phase II Site Investigation (Intrusive)
1 Background • Window Sampling –
2 Petrol Station- Facts
3 Environmental Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation Soil
8 Reality Check Cores
9 Changes to Legislation
& Licensing
Headspace
Testing
Slide 49

50. ENVIRONMENTAL SITE ASSESSMENT
Phase II Site Investigation (Intrusive)
1 Background • Window Sampling –
2 Petrol Station- Facts – Can install shallow groundwater and gas monitoring wells
3 Environmental Liability? up to 6m total depth – most are 3.0-3.5m total depth
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Slide 50

51. ENVIRONMENTAL SITE ASSESSMENT
Phase II Site Investigation (Intrusive)
1 Background • If window sampling does not reach the groundwater table
2 Petrol Station- Facts and groundwater contamination is suspected
3 Environmental Liability? • If you found severe contamination – want to delineate extent
4 What’s in Petroleum of plume – vertically and horizontally – not possible with
Fuel? window sampling due to depth of contamination and bedrock
5 Environmental • A Detailed Quantitative Risks Assessment is required
Site Assessment
6 Risk Assessment YOU NEED A BIGGER RIG!
7 Site Remediation  Shell & Auger – good for depth & logging of soils, but slow
8 Reality Check
particularly on boulder tills, only to top of competent rock
9 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. ENVIRONMENTAL SITE ASSESSMENT
Phase II Site Investigation (Intrusive)
1 Background Shell &
2 Petrol Station- Facts Auger
3 Environmental Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Air
Rotary
Slide 52

53. RISK ASSESSMENT
MAINTAIN FOCUS ON KEY CONCEPT
1 Background SOURCE PATHWAY TARGET (OR RECEPTOR)
2 Petrol Station- Facts
3 Environmental Liability?
4 What’s in Petroleum Refine Conceptual Site Model (CSM)
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Slide 53

54. RISK ASSESSMENT
Refine Conceptual Site Model (CSM)
1 Background
2 Petrol Station- Facts
3 Environmental Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Slide 54

55. RISK ASSESSMENT
SOIL GENERIC ASSESSMENT CRITERIA FOR
1 Background PETROLEUM SITE GENERIC QRA
2 Petrol Station- Facts
3 Environmental Liability?
4 What’s in Petroleum
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Slide 55

56. RISK ASSESSMENT
DETAILED QRA –
1 Background
DERIVE SITE SPECIFIC TARGET LEVELS (SSTLs)
2 Petrol Station- Facts
3 Environmental Liability?
4 COMMON MODELS
4 What’s in Petroleum
Fuel?  Contaminated Land Exposure Assessment (CLEA) Model – Soil
5 Environmental Guideline Values, 2009 (Soil lab data);
Site Assessment
6 Risk Assessment  Risk Based Corrective Assessment (RBCA) Model (Soil & water
7 Site Remediation lab data);
8 Reality Check
9 Changes to Legislation  Environment Agency Remedial Targets Methodology 2006(8) –
& Licensing Controlled Waters.
 RISC-HUMAN Model (Site Specific DQRAs)
Slide 56

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 in
2 Petrol Station- Facts Portlaoise – accepts hydrocarbon contaminated soil with Mineral
Oil>500mg/kg
3 Environmental Liability?
 1 * Hazardous Waste Transfer Station – RILTA Faciity in
4 What’s in Petroleum Greenogue – accepts & exports hydrocarbon contaminated soil with
Fuel? Mineral Oil>500mg/kg
5 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 hydrocarbon
6 Risk Assessment contamination with TPH<1,000mg/kg (also only landfill which accepts
asbestos C&D waste
7 Site Remediation
 1 * Inert Waste Landfill which can accept only C&D. No hydrocarbon
8 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. 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 licence
2 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 use
4 What’s in Petroleum of Oxygen or Hydrogen Release Compounds (ORCs or HRCs) – no
Fuel? approval required
5 Environmental
 PATHWAY
Site Assessment
 Isolate the hazard – vapour cut-off walls, PRBs, capping, LF gas
6 Risk Assessment venting – significant groundworks & may require planning
7 Site Remediation  Dust suppression – landscaping/capping
8 Reality Check  Immobilise – lime stabilisation…however, getting into waste licence
activity
9 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. 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 where
2 Petrol Station- Facts there is often a dedicated Contaminated Land Officer…consultant telling the
3 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-site
5 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 is
6 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 1996
8 Reality Check
 Northern Ireland – Cost €6.9k Total– currently 4 mobile licences
9 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. REALITY CHECK
 DRIVERS
 Contaminated soil (i.e. Hazardous waste) disposal is too expensive in
1 Background Ireland.
2 Petrol Station- Facts  In most petrol retail remediation projects dig & dump is the only
3 Environmental Liability?
solution – built up areas, no space, etc.
 Contractors are afraid to dig in brownfield site…if it’s
4 What’s in Petroleum
contaminated it’s a waste & an offence to bury it!
Fuel?
5 Environmental
Site Assessment
6 Risk Assessment
7 Site Remediation
8 Reality Check
9 Changes to Legislation
& Licensing
Slide 60

61. CHANGES TO LEGISLATION & WASTE
LICENSING?
 Adopt key areas of Soil Framework Directive in new Contaminated Land
1 Background Regulations – shore up legal lacuna
2 Petrol Station- Facts
3 Environmental Liability?  EPA to take responsibility for non-historic waste brownfield sites
4 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 each
5 Environmental county (WMA Section 26 Register?)
Site Assessment  CLO to assess SI/RA reports, Remedial Plans, etc
6 Risk Assessment  CLO to process waste licence applications
7 Site Remediation
8 Reality Check  EPA review costs for fixed soil remediation waste licences and
9 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. THANK YOU!
Slide 62