wyg environment the legacy of illegal & … brownfield...waste management acts 1996 to 2005 2....

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WYG Environment

The legacy of illegal & unregulated waste disposal sites in Ireland.

For Engineers Ireland, Cork 10th March 2009


INTRODUCTION

• What do we mean by Waste Disposal Sites?

• Why deal with them? – Environmental & Legal Need

• How do we identify sites & actions? – EPA Methodology

• How do we prioritise actions? – EPA COP Risk Assessment

• How do we quantify the risk? – SIs & Reporting

• What can we do about it? – Remediation Options

• Who is going to pay for it? – Site Owner/Landfill Levy

• What did we do before? – Case studies


Common Sources of Waste & Land Contamination

•Our industrial past

� Town gas works

� Industrial works

� Railway Depots & Docklands

• Current activities

� Fuel and chemical storage

� Power stations and Scrap yards

� Asbestos Containing Materials

� Poor Environmental Management

�Domestic & C&D Waste Disposal Sites

• Illegal Waste Disposal Practices

What Are Waste Disposal Sites?


What Are Waste Disposal Sites?

Characteristics of waste disposal sites:

• Waste content is variable, comprising of one of more of thefollowing sources;

• Domestic, Municipal, Commercial, Medical, Construction &Demolition (C&D), Industrial, Hazardous, etc

• no record of waste sources, types, volumes or deposition history.

• scale of the waste deposition varies but is often large; 00’s or000’s of tonnes.

• used to ‘fill’ excavations, or depressions and also occur on theedges of roads, valleys on industrial ‘Brownfield’ sites,unmanaged ‘waste’ ground,

• Result in potential leachate, gas, H&S and land stability risksdepending on sensitivity of receiving & surrounding environment


What Are we talking about?

(Some obvious & Some hidden)


What Are we talking about?

•Many illegal sites have poor records with little history of activities.


Why deal with them?

• Environmental pollution - pH, BOD, COD, Heavy Metals, Hydrocarbons,Ammonia, Chloride, Methane, PCBs, Phenols, VOCs, etc,.

• Human Health Impact

• Nuisance – dust, odours, noise, rodents

• Legal reasons – third party impact

• Land Re-development Issues

• Can cause major issues for site re-development, especially onbrownfield sites which may have landfill waste in some are

• Inadequate environmental standards have now been addressed by newlicensing controls


Why deal with them?

• Irish & EU Legislation

1. Waste Management Acts 1996 to 2005

2. EPA Act 1992

3. Protection of the Environment Act 2003

4. Landfill Directive

5. Water Pollution Act 1977 revised 1990

6. Air quality Legislation

7. Habitats Directive

8. The EU Water Framework Directive (WFD)

9. Environmental Liability Directive


Why deal with them?

Key Communications Regarding the WMA:

• Ministerial Directions (WIR 04/05 & WIR 04/08) were issued undersection 60 of the WMA 1996 to 2005.

• To encourage an intensification of action against illegal waste activity

• To enhance the response of the LAs and EPA in ensuringenvironmental & human protection and prosecution of offenders

• It reminds LAs of their responsibilities (under section 22 of the WMA)to carry out an inventory and risk assessment of all unregulated /illegal waste disposal sites.

• (These directions are part of the governments response to the EuropeanCourt of Justice ruling in case C-494/01 that Ireland was not properlyimplementing the provisions of the 1977 waste framework directive).


Why deal with them?

The ministerial circulars advise and direct the LAs & EPA that -

• “The principal aim in dealing with illegal waste activity should be tosecure protection of the environment and human health.”

• They encourage LAs to pursue illegal holders of waste “looking tothe maximum potential sanctions available in law” including theapplication of the Landfill Levy to all illegal waste disposal activityafter June 2002.

• The aim of all actions is to make safe waste disposal sites, includingthe removal of waste, where required, as a consequence of riskbased assessment.

• They should develop an enforcement policy regarding unauthorisedwaste activity


How do we prioritise actions??

• In order to guide LAs in their completion of the Ministerial Direction andrequirements of the WMA and European Law the EPA issued a detailed

• Code of Practice (COP) Document - published by the EPA in April 2007

‘Env Risk Assessment for unregulated waste disposal sites’.

• The CoP sets out a risk based assessment procedure which is to beapplied to historical waste disposal facilities & illegal sites, in order to:

• Evaluate them in terms of level of risk to the environment,

• Ensure a consistent approach to environmental risk assessment bylocal authorities when assessing the environmental impact andremediation options for such sites,

• Aid in prioritising waste sites and remedial actions depending on theresults of the risk assessment.


How do we prioritise actions?

EPA COP Application

The COP details the approach to be taken in relation to unregulatedsites:

• Historic Unregulated waste disposal sites (closed landfills) thatwere operating between 1977 and 1997 without being in breech ofnational legislation: (Category 1 and Category 2 sites)

• Illegal landfills that were operating since 1997; (Category 3 sites)

• Areas of brownfield sites are often found to have been used forillegal waste disposal activities and if uncovered during a sites re-development can cause major issues in term of liabilities, timeline and costs of development, construction and environmentalmanagement.



EPA Figure 3 – Application of thecode of practice for illegal sites

Process divided into a number ofsteps;

Step 1: Identify Site

Step 2:Apply Tier 1 Assessment



Step 5:Remediation Option

Step 6:Reporting



• LAs are required to follow the methodologies set out in the COPfor the two waste disposal types (unregulated & illegal),

• while the risk assessment methodology is the same theapplication is different primarily because - Category 3 (illegal)sites: - if close to existing or planned residential development oreducational facilities, wetlands, environmentally designated areas(NHAs, SPAs, SACs) or places of special interest/high amenityareas then: -

• “In all of these cases, prior to embarking on the risk assessmentprocess, it is to be assumed that the waste shall be removedfrom the site except only where it can be shown that analternative solution provides greater protection to theenvironment and the health of the local population”.



RISK ASSESSMENT PROCESS (at core of EPA COP)

• Considers the likelihood of occurrence & consequences of theoccurrence of an event

• Means of determining and evaluating the nature, effect andextent of exposure a vulnerable receptor may experience inrelation to a particular hazard

• It informs and communicates the nature of risk

• The methodology is a structured, transparent and practicalprocess to aid decision making

• Risk screening is the process, using Source Pathway Receptor(SPR) linkages through developing a conceptual site model (CSM)


Risk Assessment/Pollutant Linkages/CSM

A B

Concrete

Containmentis harmful by

ingestion

PerchedWater Table

Clay

Aquifer

HAZARD - the product of the pollution potential of the substance

CONSEQUENCE - is the assessment(clinical, biological, legal, etc.) of theimpact of the HAZARD on a receptor, ifthe receptor is exposed to the HAZARD



• Source-Pathway-Receptor (SPR) model is used for COP.

• Describes the potential risk to the environment and human health.

• Risk assessment (RA) consists of up to 3 Tiers of investigation

• Depends on the perceived and increasing severity of the potentialrisk at any particular site.

• Tier 1 establishes setting; identifies risk potential & level of site data

• Tier 2 requires detailed site investigation & testing.

• Tier 3 entails detailed quantitative risk assessment.

• Each tier is used to determine and refine the nature and linkage ofthe SPR at any particular site and enables ranking to be completed.

• A Conceptual Site Model (CSM) is drawn up after Tier 1 and isrefined in Tier 3 after the site works of Tier 2.


How do we quantify the risk?

RISK ASSESSMENT - TIER 1

• Desk Study

• Existing site data/reports, interviews, Historic maps, aerial photos, etc.

• Published Information on the receiving environment, geology & soil maps,(GSI, RBDMPS, Duchas, EPA, OPW, NPWS etc.)

• Conduct Walkover Survey - Evaluate where possible:

• Nature & extent of the waste body (areal extent, depth, waste type, age)

• Emissions (gas, leachate)

• Receptors (dwellings, living organisms, wells, aquifer, rivers, ecologicalsystems)

• Compile Conceptual Site Model (CSM)

• Undertake Prioritisation of sites through SPR linkages – ranking matrix.



Protected Areas(ELD)



Development of good CSM critical part of Tier 1 Assessment



EPA COP - Source/Hazard (waste Body) S-P-R scoring matrix;



EPA COP Scoring System – 11 linkages identified

• Pathways;

• Leachate Vertical – Groundwater Vulnerability (Table 2a of COP)

• Leachate Horizontal – Groundwater Flow Regime (Table 2b)

• Leachate – Surface Water Drainage (Table 2c)

• Gas – Lateral Migration (Table 2d)

• Gas – Vertical Migration (Table 2e)

• Receptors (Tables 3a to 3e Leachate & Table 3f Gas)

• Human Presence, Protected Areas, Aquifer Category, PublicWater Supplies, Surface Water Bodies, Human Presence (gas)

• Each of the 11 possible S-P-R linkages are scored individually



EPA COP S-P-R Scoring System

• Scoring system based on the Source-Pathway-Receptor linkage and is derivedby amalgamating into a formula individual scores for each of the S-P-Raspects.

• Waste Site risks prioritised according to the overall score (numbers arenormalised to a rating of 100 by dividing the linkage score by max & x by 100)

• Sites with a score of:

• > 70% are classified as Class A (high Risk),

• 40 – 70% as Class B (Moderate Risk) and

• < than 40% as Class C (Low Risk).

• Tier 1 guides investigation required for possible Tier 2 investigations?



TIER 2 & TIER 3 INVESTIGATIONS• Investigate and provide detailed site information. Redefine the CSM.

Confirm S-P-R linkages and risk classification.

• i) Class C sites – Relatively low level tier 2 investigation – confirminitial CSM and risk classification, may comprise trial holes, gas andleachate monitoring in the waste body & at sensitive receptors.

ii) Class A & B sites – Detailed investigations to define the landfill(source), the pathways and the receiving environment (receptors).



TIER 2 & TIER 3 INVESTIGATIONS

• Site Specific Information required

Landfill areal extent, depth, type of waste, age of waste, cappinglayer, leachate and gas quantity/quality. Local geology,hydrogeology, permeabilities, drainage, physiography. Dwellings,wells, protected areas (NHA, SAC, SPA), rivers etc.

May comprise topographic surveys, trial pits, boreholes, geophysics,ecological surveys, sampling of leachate, groundwater, surface waterand gas etc.



• Trial Pit Investigations

(Necessary for completion of ‘EPA Waste Classification Paper Tool’ to identifyHazardous or non hazardous waste)


� Shallow Window Sampling� Hand Augering

■ Allows soil profiling, soil samples, gas monitoring in shallow subsurface■ Temporary borehole installation to facilitate shallow groundwater sampling

Small Scale Site Investigation Techniques



Tier 2 & 3 Investigations

• Site Investigation targets high risk areas identified in Tier 1 Assessment

• Geophysics, trial pits, boreholes (S&A & Rotary)

• Soil, Water and Gas Sampling

• On site sample screening

• Laboratory Analysis

• Site Survey

• Hydraulic tests




Geophysical Investigations



TIER 3 RISK ASSESSMENT

• The S-P-R linkages and their importance should have been confirmed by thesite investigations. In some cases, a linkage will have been deemed not toexist thus eliminating that particular risk, while conversely previouslyunknown linkages will have been identified which lead to a re-appraisal ofthe risk designation for the site.

• A quantitative risk assessment (QRA) is required for Class A and Class B sites

• Generic QRA – comparison of site specific concentrations with genericassessment criteria (screening levels)

• Detailed QRA – detailed QRA which uses site specific assessment criteriausing risk assessment tools and models (contaminant fate and transportmodels e.g. landSim, GasSim, RBCA, RAM)

• Information used to provide an evaluation of the overall risk of the site &revised completion of the scoring matrices to define priority of actions.


GasVolatilisation

DustDirectcontact

Contaminatedsediments

Residential use

Volatilisation

Leaching andinfiltration

Contaminated FillContaminated Fill

Contaminated

soils

Surface run-off

VolatilisationVolatilisation

Gas migration


Revised Conceptual Model



REPORTING• Detailed reports are required at each step of the process for each site

• A comprehensive report shall be submitted to the relevant competentauthority on the recommendations for site remediation. Upon completion ofworks a detailed verification report shall be submitted that shows that the S-P-R linkages have been broken and remediation has been successful.

• Tier 1 assessments – undertaken by staff that have participated in EPAtraining or have gone through the appropriate training material

• Tier 2 and Tier 3 assessments – undertaken by a suitably qualified, trainedand experienced person, who is a registered professional with charteredstatus (or equivalent) awarded by a relevant professional body, and who hassuccessfully conducted risk assessments at other sites.


What Can we do about it?

REMEDIATION STRATEGY

• The selection of suitable remediation options is dependent on the results ofthe Tier 1, 2 & 3 investigations and especially the QRA

• The Remediation option should be designed for intervention within the CSMand demonstrate that the S-P-R linkage has been broken

• The remediation proposals will be assessed through the administrative systemestablished under Section 22 as an integral part of the authorisation processand site specific measures will be set out in the licence/permit issued.

• Typical remediation measures for Class A sites may include removal of waste,landfill capping plans, drainage plans, leachate management plans (e.g. pump& treat), gas management plans (e.g. gas vent pipes or trenches, active gaspumping & flaring), landscaping and aftercare management and monitoring.



Excavate and Dispose of waste material to licensed site


In-Situ Remediation TechniquesSoil Remediation Techniques

• Capping/ Installation of Hardstanding

• Vertical Cut Off Barriers or Reactive Barriers

• Thermal Processes

• In-Situ Treatment

• Stabilisation/ Solidification (eg Titanic Quarter)




Cut off systems – gas & water


Groundwater Remediation Techniques• Pump & Treat

• Activated carbon adsorption

• Air stripping

• Combined air stripping and carbon adsorption

• Biological treatment

• Spray irrigation

• Neutralisation

• Precipitation

• Electrochemical

Level ControlPump

NAPL Layer

Water + NAPL




Capping


Reduced leaching tosurface andgroundwater

evapotranspiration

rainfall interceptionPublic benefits:

e.g. economicregeneration,landscapeimprovement,sport/recreation,provision of shade

Environmental benefits:

e.g. heat island reduction,atmospheric pollutant interception,urban biodiversity, dust reduction.

use of organicwastes

Phytostabilisation;contaminant breakdown

Brownfield land

GreeningUrban

Waste minimisationthrough re-use ofbrownfield ‘soil’ orremediated materials

GreenRemediation



Who is going to Pay for it?

• The waste producer (if they can be found?) - Polluter Pays

• Waste Carrier (if they can be found?)

• The site owner (buyer be ware) – (no one is found the tax payer??)

Additional Sanctions for Waste Sites

• Waste Management Landfill Levy Regulations (S.I. No. 402 of 2006)

• Waste deposited illegally post 1st June 2002 is liable for charge of€15 per tonne

• Post 28th July 2006 waste material is liable for €20 per tonne levy

• % of Money retained by LA is increased to 80% and shall beused for enforcement activities.

• Major incentive for LA to identify and chase illegal waste disposal.


Result of Implementation of EPA COP

• Identify all closed waste disposal sites in functional area

• Prepare register for all such sites - registered under Section 22 of theWMA 1996-2005.

• Carry out risk assessment on each site – Tier 1 to 3 as appropriate

• Prepare remediation plans and reports

• Apply for ‘consent’ from EPA (Category 1 and Category 2 landfills)

• Category 3 landfills will require a waste permit or waste licence inaccordance with current/existing legislation.

• Carry out remediation works & agree management plans

• Prepare verification reports showing either no risk to receptors orevidence of a break in the S-P-R linkage for success of remediation


Step 1: Site IdentifiedStep 1: Site Identified

• In-filled “Hollow” in field

• Site on farmland owned by the person who infilled

• Reports of waste being municipal in nature

• Site currently used for grazing of cattle

• Site extent approximately 0.6 hectares

• Waste depth ranged from 0.5m to 3.5m

• Estimated 20,000 tonnes of waste

What did we do before? - Case Study


Step 1: Desk StudyStep 1: Desk Study



Step 2: Conceptual ModelStep 2: Conceptual Model

• Site Walkover

• Initial Site Investigation

• Desktop Study

• Risk Assignment




SOURCE

Leachate

Landfill Gas

PATHWAY

Underlying

Soils

Atmosphere

Rock

Fissures

RECEPTOR

Atmosphere

Stream

Groundwater

Wells

Properties




Risk AssignmentRisk Assignment



Risk Assignment

Using Formulae:

Max Risk Assignment = 17.5% (SPR1)





Risk Assignment

Site Classified as LOWEST RISK (CLASS C)



Step 3: Detailed Site InvestigationStep 3: Detailed Site Investigation

• Trial Pits

• Boreholes (up and down gradient)

• Surface Water sampling (up and down stream)

• Sampling from trial pits and boreholes

• Gas flow and composition measurements




• Sampling of extraction wells in the vicinity (door to door survey)

• Topographical survey of waste area and immediate surrounds

• Ecological survey (if required)

• Geotechnical assessments



Step 4: Tier 3 Risk AssessmentStep 4: Tier 3 Risk Assessment

• Generic QRA

• Detailed QRA

• Assessment of Hydrogeological Risk – LandSim

• Assessment of Risk from Landfill Gas - GasSim



Total LFG

5% Less Than 10% Less Than 25% Less Than 50% Less Than 75% Less Than90% Less Than 95% Less Than

Year214021302120211021002090208020702060205020402030202020102000

Gas

Gen

erat

ed (m

3/hr

)

16

15

14

13

12

11

10

9

8

7

6

5

4

3

2

1

0

Step 4: Tier 3 Risk AssessmentStep 4: Tier 3 Risk Assessment



Step 5: Remediation OptionsStep 5: Remediation Options



Step 5: Remediation CompletionStep 5: Remediation Completion

• Site Supervision

• Construction Quality Assurance

• Validation

• Aftercare / Monitoring of Works



East Tip area of Haulbowline Island


East Tip

Naval Pitch

Cork Harbour


History of East Tip

• East of the naval property on Haulbowline Island is the East Tipwhich is an area of land reclaimed (approximately nine hectares)from the Spit Bank (shallow natural sand deposit) by infilling of:

- Various quarry fill (taken from a former limestone quarry on-siteused between 1865 and 1926) and wastes generated by the navaldockyards

- Process waste from the steelworks, mainly slag and scrap metal.Steel processing began in 1942. In 1995 the Irish government soldIrish Steel to Irish Ispat which ceased operations in 2001 Irish Ispat.

- Most of the East Tip waste is approximately 3mAOD with heaps upto 13mOAD. From investigations in 2005 its seen that the wasteranges from 4.0m to 12.5m in thickness.


Conceptual Model – Source, Pathway, Receptor


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wyg environment the legacy of illegal & … brownfield...waste management acts 1996 to 2005 2....

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