’environmental site investigation and due diligence in the current market.’ apea ...

APEA Petroleum SeminarFirgrove Hotel MitchelstownCounty Cork

Environmental

Site Investigation &

Due Diligence in the Current Market

15th November 2012

Padraic Mulroy,BSc., MSc., MIEI, MIPSS, CSc, SiLC

Managing DirectorMulroy Environmental

Who are we?• Based in Dundalk, County Louth (the Wee County)• Started in 2007

Services• Due Diligence Site Investigation/Contaminated Land Risk

Assessment• Remediation/Bioremediation of Contaminated Soil &

Water• Waste Licence & Permit Applications• IPPC Licensing• Wastewater Treatment Plant Design for Single, Small

Community, Commercial & Industrial Development• Site Suitability Assessment• Environmental Impact Assessment• Sludge Management Expertise• Environmental Monitoring

BACKGROUND

MULROY ENVIRONMENTAL1 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

Petroleum Sector Specific Services• Phase I Audits (Non-Intrusive) – Service Inspections with

Environmental Sensitivity Assessment• Phase I Audits with Soil Vapour Surveys (Intrusive) • Phase II Site Investigation:

• Supervision of drilling, groundwater & gas well installation

• Risk Assessment• Generic Quantitative Risk Assessment (GQRA)• Detailed Quantitative Risk Assessment (DQRA)

• Remedial Action Plans (RAPs)• Remediation Supervision:

• Dig & dump• Groundwater clean-up/NAPL removal/Soil Vapour

Extraction/Dual Phase, etc• Post-remediation Close-out/Validation Reports

BACKGROUND

MULROY ENVIRONMENTAL

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


PETROL RETAIL STATION - FACTS

• Huge variety!

Old Roadside Service Station

(Old single skinned USTs partially under

public road)

Motorway Service Station

(Double skinned USTs & pipework)

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


PETROL RETAIL STATION - FACTS

2006 DOELG/ARUP Report on Petroleum Sector in ROI

Number of retail sites in NI?

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


ENVIRONMENTAL LIABILITY?- Why are they a threat to the environment?- Why are they an environmental liability?

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check



WHAT IS BELOW GROUND LEVEL?1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


ENVIRONMENTAL LIABILITY?

- Why are they a threat to the environment?- Why are they an environmental liability?

WHAT IS BELOW GROUND LEVEL?

Product leaking

from vent line-

historic overfilling

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check



WHAT CAN HAPPEN?1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check



THIS IS WHAT CAN HAPPEN!

Approx. 1,000l UL Petrol Contaminated 2574m3

or 1700 tonnes

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




Significant site remediation

costs!

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check



THIS IS WHAT CAN HAPPEN!1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




Evacuatedhouses

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


What are petrol, kersone and diesel?• Fractions of petroleum crude of various

molecular weight – petrol (light) to diesel (middle) to lube oil & tars (heavy)

WHAT’S IN PETROLEUM FUELS?

- Why are petroleum fuels a threat to the environment?

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


What are petrol, kerosone and diesel?

• Light Non-aqeous phase Liquids (NAPLs) – 0.8kg/l density – they float

• Various cocktails of aromatic, aliphatic heterocyclic NSO & asphaltene compounds

• Gasoline contains over 500 different compounds

WHAT’S IN PETROLEUM FUELS? –

Why are they a threat to the environment?

Gas Chromatogram of Gasoline Range Organics

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


What is in petrol, kerosone and diesel that make them dangerous?

• Key components are proven carcinogens:– Benzene – petrol can contain up to 1% benzene– Polyaromatic Hydrocarbons e.g. naphthalene,

etc– Toluene – neurotoxic– MTBE – additive replaced Tetraethyllead as

anti-knocking agent. Also acts as oxygenate to boost Octane Number.

• Other components:– Mineral Oil – Total Aliphatic Fraction (Paraffins)

WHAT’S IN PETROLEUM FUELS? –

Why are they a threat to the environment?

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


Why get an assessment done?

• Petrol retail company may have internal QA/QC requirements to get an environmental assessment of all company owned retail sites

• Requirement of environmental insurance policy• Company may require a risk assessment to assess the relative

risk from each site so that an environmental budget can be prioritized for the high risk sites

• Owner or operators may suspect that there is a leak due to product losses showing up in the wet-stock inventory

• 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 approaching explosive risk

• Vapours may be detected by neighbours in off-site property which may be exceeding the MEL or approaching explosive risk

• A UST or pipework may have failed a pressure test and site owner may suspect a leak has occurred but no evidence has showed up – proactive approach!

• A substantial overfill has occurred and site owner may want to determine the extent of soil and/or groundwater contamination

ENVIRONMENTAL SITE ASSESSMENT

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check



Due Diligence - Most common scenario

• A prospective Service Station purchaser/Developer submits a planning application for:

– A new petrol station (i.e. raze and rebuild and continued petroleum use); or

– A residential or mixed residential commercial development on petrol retail site (i.e. change of use)

• Draws up contract with vendor to purchase site in event of success or to walk away if contamination is too severe or planning is refused

• Buyer carries out site investigation, Generic Quantitative Risk Assessment (GQRA) and Detailed Quantitative Risk Assessment (DQRA) if site is severely contaminated

• Buyer draws up Remedial Action Plan (RAP) for site to break Source-Pathway-Receptor link

• Has a sit down with the vendor to give him/her the DQRA/RAP report/cost of clean-up. Negotiate on price reduction

• Once price agreed & ‘Contract of Sale’ agreed, PA submitted • 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

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


What kind of assessment?

• Phase I Audits (Non-Intrusive) – Client interview, operation assessment, service inspections with Environmental Sensitivity Assessment (i.e. Desk Study)

• Phase I Audits - all of the above + Soil Vapour Survey (Intrusive)

• Phase II Site Investigation -Supervision of drilling, groundwater & gas well installation followed by a Risk Assessment• Generic Quantitative Risk Assessment (GQRA)• Detailed Quantitative Risk Assessment (DQRA)• May also contain Remedial Action Plans (RAPs)


1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


Phase I Audits – Environmental Sensitivity

• Desk Study:

– Soil/subsoil, geology, hydrogeology (i.e. aquifer class and vulnerability, proximity to water abstraction wells/source protection areas), GSI Borehole records within 500m of site – no records - may require door to door survey, aquifer class and vulnerability – on-line GSI & EPA

– Hydrology (i.e. discharges to surface water catchment) & OPW

– River Basin Management Districts Risk Assessment Reports for Groundwater & Surface Water Bodies

– Proximity of NHAs/SPA/SACs – On-line NPWS

– 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

– Review of previous environmental Phase I, II or Remediation Validation reports


1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




Subsoil Map

Vulnerability Map

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




Bedrock Map Source Protection

Map

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


Phase I Audits – Operation Assessment

• Interview with site owner:

– Site Age? Raze & rebuild with soil remediation?

– Tank inventory - maximum age – any single skinned USTs >20-25 years old? => risk increases

– Underground Storage Tanks (USTs) - Product type, compartmentalized, single or double skinned, concrete encasement, etc

– Stock Inventory - Manual dips or fuel gauges?

– Decommissioned/disused UST's - Yes/No, completed with/without soil testing, decommissioned (i.e. product removal?, washed and/or degassed, 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


1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check



• Interview with site owner: Forgotten UST not on drawing!


30 year old

ConcreteEncased

USTdiscovered

during remediatio

nworks

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




– Above ground storage tanks (AST's) - Number? Volume? secondary containment?

– Secondary containment sufficient – ‘110% or 25% Total Volume’ Rule?

– History of secondary containment – installed after AST installation?, block wall or reinforced concrete walls, concrete lining, retain water, bund integrity testing – pass of fail?

– Location of fill points – inside or outside bund?

– Apertures or pipework (other than suction lines) running through bund?


1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




No bund Bunded…but…

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




Ideal Construction

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




– Stormwater Discharge – Surface water or groundwater (existing or historical decommissioned soakaway?), history of downgradient surface water contamination (fish kills?), Local Authority Section 12 Notices?

– Stormwater Interceptor - Present/absent, age, sufficient capacity, rainwater diverted?, evidence of product within the stream, river?

– Car wash facility - Present/absent, maintenance schedule (months), discharging to dedicated interceptor or stormwater interceptor => emulsification of product

– Carwash Interceptor - Present/absent, age, discharge to foul sewer or 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?


1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




– Volume Throughput of Product:• <5,000m3 - over previous 5 years• 5,000 – 15,000m3 - over previous 5 years• >15,000m3 - over previous 5 yearsHigher throughput >» Greater potential loss through overfilling

– Hardstanding:• Concrete – impermeable• Tarmac – significant permeability• Cobblelock (on sand bed – no protection)• Surface quality - extent of cracks, negligible/localised/significant

– Evidence of surface contamination - None/minor/localised/significant


1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




– Previous confirmed significant product surface loss (including overfills) or spillage within last 5 years – Volume? Cleaned up?

– Previous confirmed significant product loss from UST or other underground structure (e.g. pipeline) within last 5 years – Volume? Cleaned up?

– Stock Reconciliation – well managed computerised system with no exceedances in previous 12 months?


1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


Phase I Audits – Field Investigation

• Site Inspection:– All services should be regarded as paths of least

resistance & potential migration pathways (vapor and/or liquid)

– Comprehensive service inspection – lift all service access manholes:

• UST access chambers;• Fuel gauge, electric and telecommunications manholes –

any foam packing?;• Stormwater, carwash and interceptor access manholes –

dip interceptor chambers to determine product thickness• Foul sewers & on-site septic tanks & percolation areas• Rainwater pipework access chambers• Water main & fire hydrant lines


1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check



• Site Inspection:

– LIFT EVERY MANHOLE & TAKE VAPOUR READINGS ON ALL CHAMBERS USING PHOTOIONISATION DETECTOR (PID) & LOG


1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


OFF-SITE MIGRATION


• Site Inspection:


STORM

STORMVENT LINE

FOUL

SUCTION LINESUCTION LINE

ESB/

TELE

COM

SPETROL STATION

SERVICES = SPAGHETTI JUNCTIONS!

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check



• Site Inspection:– Use your nose and eyes but trust more in science –

• Photo-ionisation Detectors (PIDs) – pick up VOCs to ppb; and• Interface Probe for measuring product thickness


1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check



• Site Inspection:– Any visible evidence (i.e. staining, vegetation die-

back, etc) present;– Quality of hardstanding/surface material;– Condition of bunding on ASTs – water

retention/integrity? external staining?– Condition of receiving surface drains or bodies


Emulsified product inLand drain

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check



• Site Inspection:– Where leakage is suspected, inspection of street service

manholes subject to permission of LAs or owners– Inspection of local excavation works, culverts,

basements in public houses if adjacent– DON’T ASSUME IF IMMEDIATE NEIGHBOURS HAVE

NEVER COMPLAINED THAT THERE IS NO PROBLEM UNDERGROUND!

SOURCE – PATHWAY –TARGET

TARGET MAY BE 0.1KM – 2KM DOWN THE ROAD!


1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


Phase I Audits – Soil Vapour Survey

• Soil Vapour Survey (SVS):– Detailed & ‘as-built’ drawings to aid in optimizing locations– Services checked using Cable Avoidance Tool (CATSCAN)– Holes drilled using intrinsically safe pneumatic drill – get

through hardstanding– Probabar to achieve gas sampling depths @0.6m and 1.0m – Ideally 10m herringbone grid– Max. & minimum readings taken


1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




05

10152025303540

10

50

100

150

200

250

300

350

400

450

500

More

Range in soil vapour values (ppm)

Frequency

Mean: 1.05 ppmMedian: 1 ppmMax: 4 ppmMin: 0 ppm

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




• Soil Vapour Survey (SVS):Advantages:– Inexpensive way of delineating a contaminant plume

on site– Very good in detecting leaks from suction & fill lines– Up to 25 * 1.0m depth points in a day– Minimal disruption to on-going business – cordon off

of working area– Can be used at boundary to determine if off-site

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

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




• Soil Vapour Survey (SVS):Disdvantages:– Limit to depth – can obtain lower than 1.0m depths in

soft subsoils but will slow project down – cost effectiveness!

– Even with water traps, Photo-ionisation detectors do not perform well during high moisture/cold environments with ‘Zeroing’ required between each reading – technology’s achilles heel!

– Works well where subsoil is relatively permeable and in permeable made ground where groundwater table is 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

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




• Soil Vapour Survey (SVS):Disdvantages:– PIDs react well to BTEX compounds (i.e. mono-

aromatics) but wont detect diesel vapours – need to use in conjunction with Draeger tubes – however cost!

– In winter conditions where soil is cold and saturated, SVSs should not be carried out - Henry’s Law!

FALSE NEGATIVE RESULTS - SITE IS OK?

COLD WEARTHER SVS - WASTE OF MONEY!BE PATIENT - WAIT FOR GOOD DRY WEATER

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check



Phase I Audits – Overall Results

Site falls into one of 5 ‘Site Groups’:1. Evidence obtained of offsite odours or product,

which are associated with the site2. Evidence obtained of significant sub-surface, on-

site contamination but no hard evidence of offsite contamination

3. Probable on-site problems4. Possible on-site problems or specific engineering

concerns5. No on-site problems

GROUP 1 & 2 SITES ARE PRIORITISED FOR PHASE II SITE INVESTIGATION & RISK ASSESSMENT

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check



Phase II Site Investigation (Intrusive)

FIRST STEP – DRAW UP A CONCEPTUAL SITE MODEL (CSM)

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




FOCUS ON KEY CONCEPT

SOURCE - PATHWAY -TARGET (OR RECEPTOR)

Must have all 3 to result in an exposure to a contaminant

If one is missing the chain is broken.

In remediating or abating you’re trying to break that chain

Remove the Source (dig out the contamination, GW pumping, etc)

Close off the pathway (Cap the waste/Cut-off wall, PRB, etc)

Protect the receptor (relocate)

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




Good news for British Consultants - process is identical to UK – Irish EPA have taken guidance from UK EA Source-Pathway-Target Conceptual Site Model Suitability for end-use SI Standards:

BS5930:1999 Code of practice for Site Investigations BS10175:2011 Investigation of Potentially Contaminated Sites

RA Guidance: 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

EPA recognise there is a legal gap and a guidance gap with regard to non-historic 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

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




GOLDEN RULES:1. Log soils to BS5930:1999 Site Investigation – universal

language for geologists/engineers; 2. Design site investigation to be consistent with

BS10175:2011 Investigation of potentially contaminated sites – Code of practice….remember..the purpose of the site investigation is to get access to the media (soil, groundwater or gas). Look at density of monitoring points (i.e. herringbone, etc);

3. Beware of cross-contamination…..hydraulic fluid, etc; and4. Make sure laboratory suite is correct for type of

contaminants found on site e.g. TPH-Core Working Group

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




• Priority – get access to underlying made ground, subsoil and groundwater if possible to take soil and/or groundwater samples for laboratory analysis

• Window Sampling –– Track mounted percussive rig – least disruption,

limited to max of 5-6m (normally 3.0-3.5m), access to groundwater may not be possible if SWL is lower, for well construction - problem of smearing in cohesive soils, works best in permeable sands/gravels

– Takes a ‘window core sample’ of soil profile– 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

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




• Window Sampling –

HeadspaceTesting

SoilCores

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




• Window Sampling –– Can install shallow groundwater and gas monitoring

wells up to 6m total depth – most are 3.0-3.5m total depth

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




• If window sampling does not reach the groundwater table and groundwater contamination is suspected

• If you found severe contamination – want to delineate extent of plume – vertically and horizontally – not possible with window sampling due to depth of contamination and bedrock

• A Detailed Quantitative Risks Assessment is required

YOU NEED A BIGGER RIG! Shell & Auger – good for depth & logging of soils, but

slow particularly on boulder tills, only to top of competent rock

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

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check




Shell & Auger

Air Rotary

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


RISK ASSESSMENT

MAINTAIN FOCUS ON KEY CONCEPTSOURCE PATHWAY TARGET (OR RECEPTOR)

Refine Conceptual Site Model (CSM)

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


RISK ASSESSMENT

Refine Conceptual Site Model (CSM)

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


RISK ASSESSMENT

SOIL GENERIC ASSESSMENT CRITERIA FOR PETROLEUM SITE GENERIC QRA1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


RISK ASSESSMENT

DETAILED QRA – DERIVE SITE SPECIFIC TARGET LEVELS (SSTLs)

4 COMMON MODELS

Contaminated Land Exposure Assessment (CLEA) Model – Soil Guideline Values, 2009 (Soil lab data);

Risk Based Corrective Assessment (RBCA) Model (Soil & water lab data);

Environment Agency Remedial Targets Methodology 2006(8) – Controlled Waters.

RISC-HUMAN Model (Site Specific DQRAs)

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


SITE REMEDATIONBREAK THE S-P-T CHAIN

SOURCE Remove – Dig & dump but where does it go? No Hazardous Waste landfills but…

1 * Hazardous Waste Treatment (Bioremediation) - ENVA Facility in Portlaoise – accepts hydrocarbon contaminated soil with Mineral Oil>500mg/kg

1 * Hazardous Waste Transfer Station – RILTA Faciity in Greenogue – accepts & exports hydrocarbon contaminated soil with Mineral Oil>500mg/kg

1 * Non-Hazardous Waste Landfill which can accept hydrocarbon contamination with Mineral Oil<500mg/kg & Total 17 PAH<100mg/kg

1 * Non-Hazardous Waste Landfill which can accept hydrocarbon contamination with TPH<1,000mg/kg (also only landfill which accepts asbestos C&D waste

1 * Inert Waste Landfill which can accept only C&D. No hydrocarbon contamination.

Cost of disposal of Hazardous Waste/hydrocarbon contaminated 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

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


SITE REMEDATION BREAK THE S-P-T CHAIN

SOURCE Treat soil on-site e.g. windrow, ex-situ soil biopiling, soil,

washing, etc – requires a waste licence Removing hydrocarbons from groundwater (e.g. pump & treat,

dual-phase extraction, etc) may require just a LA Discharge Licence.

Soil Vapour Extraction (e.g. petrol retail station remediation) or use of Oxygen or Hydrogen Release Compounds (ORCs or HRCs) – no approval required

PATHWAY Isolate the hazard – vapour cut-off walls, PRBs, capping, LF gas

venting – significant groundworks & may require planning Dust suppression – landscaping/capping Immobilise – lime stabilisation…however, getting into waste

licence activity

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.

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


REALITY CHECK DRIVERS

Brownfield Developers need reasons not to go for a greenfield site…one of those reasons has to be a financial one!

Most Irish LAs lack expertise in contaminated land unlike UK LAs where there is often a dedicated Contaminated Land Officer…consultant telling the regulator what questions she/he should be asking.

Often Irish LAs request the assistance of the EPA or hire external consultant/expert….this takes correspondence and….time

Following SI and RA, if dig & dump solution too expensive and on-site remediation is option (i.e. enough space & time), Pre-waste Licence Application Process needs to be initiated. Applying for a Waste Licence is prohibitive on a number of fronts:

Republic - Cost €16k (i.e. €10k application fee + €6k surrender fee) – as yet no applicants since WMA 1996

Northern Ireland – Cost €6.9k Total– currently 4 mobile licences Time to acquire licence – no fixed time for process 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.

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


REALITY CHECK DRIVERS

Contaminated soil (i.e. Hazardous waste) disposal is too expensive in Ireland.

In most petrol retail remediation projects dig & dump is the only solution – built up areas, no space, etc.

Contractors are afraid to dig in brownfield site…if it’s contaminated it’s a waste & an offence to bury it!

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


CHANGES TO LEGISLATION & WASTE LICENSING?

Adopt key areas of Soil Framework Directive in new Contaminated Land Regulations – shore up legal lacuna

EPA to take responsibility for non-historic waste brownfield sites 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) CLO to draw up Contaminated Land register of non-historic waste for

each county (WMA Section 26 Register?) CLO to assess SI/RA reports, Remedial Plans, etc CLO to process waste licence applications

EPA review costs for fixed soil remediation waste licences and consider introduction of mobile licence applications as per NI

EPA provide fixed timescale for waste licence applications

WHY? ……DEVELOPERS DON’T LIKE IF’S & UNKNOWNS! GIVE THEM REASONABLY ACCURATE NUMBERS & TIMELINES!

1 Background




Fuel?

5 Environmental

Site Assessment

6 Risk Assessment

7 Site Remediation

8 Reality Check


THANK YOU!

’environmental site investigation and due diligence in the current market.’ apea ...

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