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Brownfield Briefing Presentation 07/02/2018

Asbestos: Practicalities of applying industry guidance for Identifying, Treating and Re-using Asbestos-contaminated Soil Ref: KR.BD.Misc.BBPres070218JJ.V1

Asbestos: Practicalities of Applying Industry Guidance for Identifying, Treating and Re-using

Asbestos-contaminated Soil

Joe Jackson – MD Keltbray Remediation

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Contents 1. Risk Assessment and Licensing / Notification 2. Waste Management 3. Remediation 4. Case Studies / Practical lessons

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1. Risk Assessment and Licensing / Notification

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A. Reviewing CAR-SOIL and other asbestos guidance and effectively using it as a tool to manage asbestos on-site: assessing the actual risk

B. Best practice where traces or very low levels are found –justifying risk minimisation techniques



Guidance and actual risks… Multiple guidance documents: • CAR2012 • CAR-SOIL • CIRIA C73 • CIRIA Pocket Guide • JIWG Decision-making Tool

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Guidance and actual risks cont… From an operational perspective – there are three key aspects to working in ACM* impacted soils… Getting the licensing / notification status right (contractor

accreditation) Correct Training / Medicals / PPE & RPE for Operatives Appropriate controls and reassurance monitoring But just as important – being able to justify the decision-making process.. *Asbestos Containing Materials

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Guidance and actual risks cont…

THE ABILITY TO IDENTIFY AND REACT TO CHANGING CONDITIONS

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COMPETENCE!



Guidance and actual risks cont… The key risks associated with ACM in soils are: Exceeding control limits Exposure of Asbestos fibres to Operatives /

Neighbours / Public etc. Incorrect waste classification (failure in duty of

care) Cross contamination (materials / plant etc.) Failure to comply with regulations Reputational damage

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Likelihood

LOW

HIGH



Guidance and actual risks cont… Exceeding control limits Experience shows that commonly the natural moisture content of Made Ground soils is generally not conducive to fibre release above the thresholds.. Failure to comply with regulations Easy to fall foul of these – especially in terms of operative competence and changing conditions

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Likelihood LOW

HIGH



Best practice where traces or very low levels are found –justifying risk minimisation techniques • Define licensing / notification status • Employ controls including:

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Qualified watching brief Dampening down Materials management and segregation Appropriate PPE / RPE Decontamination protocols

Reassurance air monitoring Dedicated ‘dirty’ working area

with appropriate signage and entry / exit procedures

Training & competence



Best practice where traces or very low levels are found –justifying risk minimisation techniques

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Known knowns / Known unknowns / Unknown unknowns

Start with this – Make contingency for this – Be vigilant for this



Exploring what to do if asbestos is found on-site at the remediation phase, but not identified in the SI?

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• Found or suspected… (reasonably foreseeable?) • Stop works • Check T’s & C’s of contract?? • Seek advice / establish notification / licensing status • Deploy appropriate notification / ASB5 etc and contractor with

suitable license • Risk management actions



2. Waste Management

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A. Practical classification of ACM impacted soils (including clarifying the correct classification of material with very low levels of asbestos fibres detected):

• at what level must this material be classed as hazardous? • what are the technical and legal implications of re-using waste soil classified as asbestos-contaminated – what exactly can be re-used, where? B. Giving confidence to receiving facilities with regards to managing asbestos



Practical classification of ACM impacted soils

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At what level must this material be classed as hazardous? Simple Answer: Two hazardous waste thresholds for ACM soils, as defined by WM3: 1. >0.1 % w/w asbestos fibers 2. Identifiable ACM fragments present (below these the waste is not hazardous)

BUT… look more closely



What is an ‘Identifiable’ ACM Fragment?

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“Any particle of a size that can be identified as potentially being asbestos by a competent person if examined by the naked eye” (Ref; WM3)




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What are the technical and legal implications of re-using waste soil classified as asbestos-contaminated – what exactly can be re-used, where? Careful of terms: • Waste may only be recovered (or disposed) at a facility with a

suitable permit • Non-Waste is potentially reusable under an MMP (as per DoWCoP) • Presence of ACM in soils would speak to the permit or risk

assessment / re-use criteria (site specific) • IT CAN BE DONE TECHNICALLY & LEGALLY




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What are the technical and legal implications of re-using waste soil classified as asbestos-contaminated – what exactly can be re-used, where?

Excavation, Transport, Potential fibre release, handling / treatment, burial off-site?

Re-use on site (subject to risk assessment)?



Giving confidence to receiving facilities with regards to managing asbestos

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Site investigation with appropriate sampling resolution

Robust audit trail (no re-testing) Robust segregation methodology Qualified watching brief to assess

any unexpected finds Effective treatment (if necessary) Validation of work areas

Correct and agreeable waste classification

Track record!



Giving confidence to receiving facilities with regards to managing asbestos cont..

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• Once ACM impacted = Always ACM impacted?

Is it appropriate to send soils from a known ACM site to a facility with zero tolerance??



3. Remediation

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A. Exploring the most suitable remediation techniques for asbestos fragments and fibres in soil

B. Assessing the longer-term risks of leaving asbestos in-situ – how is this monitored over time?



Exploring the most suitable remediation techniques for asbestos fragments and fibres in soil

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Remediation vs. Material Management



Remediation of ACM impacted soils

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• Picking / Complex sorting • Materials management • Re-use at depth • Encapsulation / Cover layer • Solidification?

Driven by the CSM and the selected re-use criteria – but must also consider onward activities (pile arisings etc).



Material Management of ACM impacted soils

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• Picking / Complex sorting • Soil washing? • Selective excavation • Re-use at depth • Encapsulation / Cover layer

Driven by the material balance on site and aiming to ‘de-classify’ from Hazardous to Non-Hazardous



Assessing the longer-term risks of leaving asbestos in-situ – how is this monitored over time?

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• CSM will identify the suitability of retention of ACM on

site. • ACM is unlikely to migrate without interference!

Therefore is safe on-site if appropriately covered. • Maintenance should focus on the cover system / anti-

dig layers - marker layers and be supported by the H&S file / O&M manual.

No substitute for an engineering solution!!



We should talk about this more in our industry…

4. Case Studies / Practical Lessons

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A. Notification status challenges B. Waste treatment and classification challenges C. How things can go wrong…



Notification status challenges

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Challenges… ? Limited data sets ? Large sites ? Provenance of material ? Unknown unknowns ? Overstating risks ? ‘Over’ Qualification / Management of basic trades vs. inability to react to changing conditions ? Contractual issues if a licensed contractor provides oversight only



Waste treatment and classification challenges

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Challenges • The needle in the haystack? • Interpretation of 'visually

identifiable'

• Acceptable levels of carry-over??

• Appropriate waste coding 17 vs 19



Waste treatment and classification challenges cont.

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Mitigating actions • Limit risk via batching • Detailed record-keeping • Stick to a single data set • Engage 3rd party verification • Photographic records • Never profess to produce

ACM fibre free soils!?!



How things can go wrong…

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Waste coding / application of Quality Protocol

Unacceptable carry-over Difficult to enforce against

(Management) Potential delay whilst enforcement

action pending Disruption to supply chain Legal advice to 'hand over' is at

odds with commercial agreements (it is our problem anyway)!


Asbestos: Practicalities of applying industry guidance for Identifying, Treating and Re-using Asbestos-contaminated Soil Ref: KR.BD.Misc.BBPres070218JJ.V1 29

…How to get it right! Commercially aware specialist contractor Robust audit trail of all decisions made Competence does not equal CATB and a medical…

Thank you! [email protected] 07889 809501 www.keltbray.com

mailto:[email protected]

http://www.keltbray.com/

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