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Issues and Constraints
The most common works to be undertaken on Brownfield site are excavations, cut to formation, drainage, foundations, etc. Often this is made ground which is often blighted with contamination, the most frequent being asbestos materials relicts from historical demolition and associated construction works previously undertaken at the site.
The asbestos can be Asbestos Containing Materials (ACMs), typically cement bound asbestos, insulation board (non-bound), insulation (non-bound), etc.
The types and quantities can vary widely and can be encountered in an isolated part of the site or be pervasive across the development site.
Guidance
The main regulations governing the management and handling of asbestos is the Control of Asbestos Regulations 2012. An industry guidance (CAR-SOIL) produced by Cl:aire provides guidance directly relating to asbestos present in soils, “Interpretation for Managing and Working with Asbestos in Soil and Construction and Demolition Materials”.
This document provides a comprehensive guide particularly regarding licenced / non-licenced and notifiable / non-notifiable works.
Remediation Costs
The costs to remediate the solution to the satisfaction of the regulators can often be prohibitory depending on the remediation route taken. Remediation costs are dependent on types and quantities encountered.
For instance, the presence of any visible / identifiable ACMs (which contains 0.1% or more) within an excavated stockpile will render the whole stockpile Hazardous.
Equally asbestos fibres quantified in soils in excess of 0.1% are considered Hazardous.
Removal of either would require transporting under a Hazardous Waste Transfer Note under the appropriate European Waste Code (EWC), generally 17 06 05* Construction material containing asbestos.
Further consideration also needs to be paid to the presence of other contaminants within the soils. The waste would require a full WM3 assessment.
Offsite disposal costs generally being the greatest. Landfill options are decreasing with the move anyway from landfill to more sustainable solutions. In addition to the haulage rates and disposal cost, landfill tax costs need to be factored in. This may be viable in situations where small, isolated occurrences are reported.
A further option is Fixed Soil Treatment Facilities, some take soils containing ACMs, these are picked at the facility to enable local reuse as restoration material where incidental asbestos (typically fibres at < 0.001% and no ACMs present) is acceptable. The costs associated with the use of these facilities is much lower.
Some restoration sites may be able to accept non-hazardous soils impacted with asbestos; however, these will vary from site to site
The Envirotreat Solution
Envirotreat have undertaken numerous remediation projects where asbestos has been identified as concern and even a barrier to the development of the site. Through Envirotreat’s extensive experience and knowledge in dealing with these sites, a sustainable / cost effective solution can often be found.
Asbestos is inert and therefore does not pose a risk to groundwater, the risks are associated with Human Health. Envirotreat can manage these risks through:-
Full understanding of the extent and associated with the risk due to the presence of ACMs on the site – Envirotreat can offer a full (and targeted) site investigation to the satisfaction of the regulators. This can often lead to less contamination than originally envisaged in terms of area or that the type of asbestos and concentration present a lesser risk.
Envirotreat can produce an asbestos-contaminated land survey. This will detail the presence of asbestos-containing materials at the site and outline the types of asbestos, how much there is and where it is likely to be distributed. The survey will include any areas in which you have planned excavation or groundworks. If required, the survey will include trial pits and inspection to required depths. The survey will also include asbestos bulk sampling and asbestos in soil sampling/analysis.
An asbestos-contaminated land risk management plan. This will include your proposed works and will detail how the asbestos contamination to the land, soil or waste will be dealt with to reduce the risk as low as is reasonably practicable. This plan will usually include the process you will be using to remove the asbestos contamination. It will include specific plans of work, personnel, and control measures to be implemented. Control measures will consist of dust suppression, access control and demarcating asbestos contamination risk zones. The plan will also have an emergency procedure for potentially uncovering additional asbestos contamination to the land or soil.
Approved Remediation Strategy – Envirotreat can recommend cost effective remediation solution and where required gain necessary regulatory approval, this strategy often incorporates measures to address other identified contamination concerns.
Approved Remediation Method Statement – Envirotreat can prepare and gain regulatory approval for the actual onsite works, including control measures, monitoring, testing and validation.
Watching Brief – planning conditions often stipulate conditions relating to unexpected contamination (this may well be asbestos or other) – In addition to undertaking required enabling works (where required), Envirotreat can assist with qualified / experienced staff to monitor enabling works, undertaking necessary monitoring, testing and reporting, which would form part of the Validation (or verification) Report (a further planning condition requirement).
Onsite reuse – Envirotreat can manage this element of the works through comprehensive material management to ensure soils are reused onsite wherever possible.
Envirotreat have numerous case studies relating to these types of projects.
