The legacy of illegal & unregulated waste disposal sites in Ireland. For Engineers Ireland, Cork 10 th March 2009

Transcription

1 WYG Environment The legacy of illegal & unregulated waste disposal sites in Ireland. For Engineers Ireland, Cork 10 th March 2009

2 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

3 What Are Waste Disposal Sites? 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

4 What Are Waste Disposal Sites? Characteristics of waste disposal sites: Waste content is variable, comprising of one of more of the following 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 or 000 s of tonnes. used to fill excavations, or depressions and also occur on the edges of roads, valleys on industrial Brownfield sites, unmanaged waste ground, Result in potential leachate, gas, H&S and land stability risks depending on sensitivity of receiving & surrounding environment

5 What Are we talking about? (Some obvious & Some hidden)

6 What Are we talking about? Many illegal sites have poor records with little history of activities.

7 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 on brownfield sites which may have landfill waste in some are Inadequate environmental standards have now been addressed by new licensing controls

8 Why deal with them? Irish & EU Legislation 1. Waste Management Acts 1996 to EPA Act Protection of the Environment Act Landfill Directive 5. Water Pollution Act 1977 revised Air quality Legislation 7. Habitats Directive 8. The EU Water Framework Directive (WFD) 9. Environmental Liability Directive

9 Why deal with them? Key Communications Regarding the WMA: Ministerial Directions (WIR 04/05 & WIR 04/08) were issued under section 60 of the WMA 1996 to To encourage an intensification of action against illegal waste activity To enhance the response of the LAs and EPA in ensuring environmental & 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 European Court of Justice ruling in case C-494/01 that Ireland was not properly implementing the provisions of the 1977 waste framework directive).

10 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 to secure protection of the environment and human health. They encourage LAs to pursue illegal holders of waste looking to the maximum potential sanctions available in law including the application of the Landfill Levy to all illegal waste disposal activity after June The aim of all actions is to make safe waste disposal sites, including the removal of waste, where required, as a consequence of risk based assessment. They should develop an enforcement policy regarding unauthorised waste activity

11 How do we prioritise actions?? In order to guide LAs in their completion of the Ministerial Direction and requirements 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 be applied 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 by local authorities when assessing the environmental impact and remediation options for such sites, Aid in prioritising waste sites and remedial actions depending on the results of the risk assessment.

12 How do we prioritise actions? EPA COP Application The COP details the approach to be taken in relation to unregulated sites: Historic Unregulated waste disposal sites (closed landfills) that were operating between 1977 and 1997 without being in breech of national 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 for illegal waste disposal activities and if uncovered during a sites redevelopment can cause major issues in term of liabilities, time line and costs of development, construction and environmental management.

13 How do we prioritise actions? EPA Figure 3 Application of the code of practice for illegal sites Process divided into a number of steps; Step 1: Identify Site Step 2:Apply Tier 1 Assessment Step 3:Apply Tier 2 Assessment Step 4:Apply Tier 3 Assessment Step 5:Remediation Option Step 6:Reporting

14 How do we prioritise actions? LAs are required to follow the methodologies set out in the COP for the two waste disposal types (unregulated & illegal), while the risk assessment methodology is the same the application is different primarily because - Category 3 (illegal) sites: - if close to existing or planned residential development or educational facilities, wetlands, environmentally designated areas (NHAs, SPAs, SACs) or places of special interest/high amenity areas then: - In all of these cases, prior to embarking on the risk assessment process, it is to be assumed that the waste shall be removed from the site except only where it can be shown that an alternative solution provides greater protection to the environment and the health of the local population.

15 How do we prioritise actions? RISK ASSESSMENT PROCESS (at core of EPA COP) Considers the likelihood of occurrence & consequences of the occurrence of an event Means of determining and evaluating the nature, effect and extent of exposure a vulnerable receptor may experience in relation to a particular hazard It informs and communicates the nature of risk The methodology is a structured, transparent and practical process to aid decision making Risk screening is the process, using Source Pathway Receptor (SPR) linkages through developing a conceptual site model (CSM)

16 Risk Assessment/Pollutant Linkages/CSM HAZARD - the product of the pollution potential of the substance A B Concrete Containment is harmful by ingestion CONSEQUENCE - is the assessment (clinical, biological, legal, etc.) of the impact of the HAZARD on a receptor, if the receptor is exposed to the HAZARD Perched Water Table Aquifer Clay

17 How do we prioritise actions? 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 potential risk 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 of the SPR at any particular site and enables ranking to be completed. A Conceptual Site Model (CSM) is drawn up after Tier 1 and is refined in Tier 3 after the site works of Tier 2.

18 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, ecological systems) Compile Conceptual Site Model (CSM) Undertake Prioritisation of sites through SPR linkages ranking matrix.

19 How do we quantify the risk? Protected Areas (ELD)

20 How do we quantify the risk? Development of good CSM critical part of Tier 1 Assessment

21 How do we quantify the risk? EPA COP - Source/Hazard (waste Body) S-P-R scoring matrix;

22 How do we quantify the risk? EPA COP - Source/Hazard (waste Body) S-P-R scoring matrix;

23 How do we quantify the risk? 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, Public Water Supplies, Surface Water Bodies, Human Presence (gas) Each of the 11 possible S-P-R linkages are scored individually

24 How do we quantify the risk?

25 How do we quantify the risk? EPA COP S-P-R Scoring System Scoring system based on the Source-Pathway-Receptor linkage and is derived by amalgamating into a formula individual scores for each of the S-P-R aspects. Waste Site risks prioritised according to the overall score (numbers are normalised 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?

26 How do we quantify the risk? 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 confirm initial CSM and risk classification, may comprise trial holes, gas and leachate 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).

27 How do we quantify the risk? TIER 2 & TIER 3 INVESTIGATIONS Site Specific Information required Landfill areal extent, depth, type of waste, age of waste, capping layer, 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 water and gas etc.

28 How do we quantify the risk? Trial Pit Investigations (Necessary for completion of EPA Waste Classification Paper Tool to identify Hazardous or non hazardous waste)

29 How do we quantify the risk? Small Scale Site Investigation Techniques Hand Augering Shallow Window Sampling Allows soil profiling, soil samples, gas monitoring in shallow subsurface Temporary borehole installation to facilitate shallow groundwater sampling

30 How do we quantify the risk? 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

31 How do we quantify the risk? Geophysical Investigations

32 How do we quantify the risk? TIER 3 RISK ASSESSMENT The S-P-R linkages and their importance should have been confirmed by the site investigations. In some cases, a linkage will have been deemed not to exist thus eliminating that particular risk, while conversely previously unknown linkages will have been identified which lead to a re-appraisal of the 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 generic assessment criteria (screening levels) Detailed QRA detailed QRA which uses site specific assessment criteria using risk assessment tools and models (contaminant fate and transport models 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.

33 How do we quantify the risk? Revised Conceptual Model Volatilisation Residential use Contaminated sediments Volatilisation Surface run-off Direct contact Contaminated soils Dust Gas migration Volatilisation Gas Contaminated Fill Leaching and infiltration

34 How do we quantify the risk? REPORTING Detailed reports are required at each step of the process for each site A comprehensive report shall be submitted to the relevant competent authority on the recommendations for site remediation. Upon completion of works 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 EPA training or have gone through the appropriate training material Tier 2 and Tier 3 assessments undertaken by a suitably qualified, trained and experienced person, who is a registered professional with chartered status (or equivalent) awarded by a relevant professional body, and who has successfully conducted risk assessments at other sites.

35 What Can we do about it? REMEDIATION STRATEGY The selection of suitable remediation options is dependent on the results of the Tier 1, 2 & 3 investigations and especially the QRA The Remediation option should be designed for intervention within the CSM and demonstrate that the S-P-R linkage has been broken The remediation proposals will be assessed through the administrative system established under Section 22 as an integral part of the authorisation process and 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 gas pumping & flaring), landscaping and aftercare management and monitoring.

36 What Can we do about it? Excavate and Dispose of waste material to licensed site

37 What Can we do about it? In-Situ Remediation Techniques Soil Remediation Techniques Capping/ Installation of Hardstanding Vertical Cut Off Barriers or Reactive Barriers Thermal Processes In-Situ Treatment Stabilisation/ Solidification (eg Titanic Quarter)

38 What Can we do about it? Cut off systems gas & water

39 What Can we do about it? Groundwater Remediation Techniques Pump & Treat Activated carbon adsorption Air stripping Combined air stripping and carbon adsorption Biological treatment Spray irrigation Neutralisation Precipitation Electrochemical Water + NAPL NAPL Layer Pump Level Control

40 What Can we do about it? Capping

41 What Can we do about it? Green Remediation Public benefits: e.g. economic regeneration, landscape improvement, sport/recreation, provision of shade evapotranspiration rainfall interception Urban Brownfield Reduced leaching to surface and groundwater Greening land Environmental benefits: e.g. heat island reduction, atmospheric pollutant interception, urban biodiversity, dust reduction. Phytostabilisation; contaminant break down use of organic wastes Waste minimisation through re-use of brownfield soil or remediated materials

42 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 1 st June 2002 is liable for charge of 15 per tonne Post 28 th July 2006 waste material is liable for 20 per tonne levy % of Money retained by LA is increased to 80% and shall be used for enforcement activities. Major incentive for LA to identify and chase illegal waste disposal.

43 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 the WMA 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 in accordance with current/existing legislation. Carry out remediation works & agree management plans Prepare verification reports showing either no risk to receptors or evidence of a break in the S-P-R linkage for success of remediation

44 What did we do before? - Case Study Step 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

45 What did we do before? - Case Study Step 1: Desk Study

46 What did we do before? - Case Study Step 2: Conceptual Model Site Walkover Initial Site Investigation Desktop Study Risk Assignment

47 What did we do before? - Case Study Step 2: Conceptual Model

48 What did we do before? - Case Study Step 2: Conceptual Model

49 What did we do before? - Case Study Step 2: Conceptual Model SOURCE PATHWAY RECEPTOR Leachate Landfill Gas Underlying Soils Atmosphere Rock Fissures Atmosphere Stream Groundwater Wells Properties

50 What did we do before? - Case Study Step 2: Conceptual Model

51 What did we do before? - Case Study Step 2: Conceptual Model

52 What did we do before? - Case Study Step 2: Conceptual Model Risk Assignment

53 What did we do before? - Case Study Step 2: Conceptual Model Risk Assignment

54 What did we do before? - Case Study Step 2: Conceptual Model Risk Assignment Using Formulae: Max Risk Assignment = 17.5% (SPR1)

55 What did we do before? - Case Study Step 2: Conceptual Model Risk Assignment Site Classified as LOWEST RISK (CLASS C)

56 What did we do before? - Case Study Step 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

57 What did we do before? - Case Study Step 3: Detailed Site Investigation 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

58 What did we do before? - Case Study Step 3: Detailed Site Investigation

59 What did we do before? - Case Study Step 3: Detailed Site Investigation

60 What did we do before? - Case Study Step 3: Detailed Site Investigation

61 What did we do before? - Case Study Step 4: Tier 3 Risk Assessment Generic QRA Detailed QRA Assessment of Hydrogeological Risk LandSim Assessment of Risk from Landfill Gas - GasSim

62 What did we do before? - Case Study Step 4: Tier 3 Risk Assessment Total LFG Gas Generated (m3/hr) Year % Less Than 10% Less Than 25% Less Than 50% Less Than 75% Less Than 90% Less Than 95% Less Than

63 What did we do before? - Case Study Step 5: Remediation Options

64 What did we do before? - Case Study Step 5: Remediation Options

65 What did we do before? - Case Study Step 5: Remediation Completion Site Supervision Construction Quality Assurance Validation Aftercare / Monitoring of Works

66 East Tip area of Haulbowline Island

67 East Tip Cork Harbour Naval Pitch

68 History of East Tip East of the naval property on Haulbowline Island is the East Tip which 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-site used between 1865 and 1926) and wastes generated by the naval dockyards - Process waste from the steelworks, mainly slag and scrap metal. Steel processing began in In 1995 the Irish government sold Irish Steel to Irish Ispat which ceased operations in 2001 Irish Ispat. - Most of the East Tip waste is approximately 3mAOD with heaps up to 13mOAD. From investigations in 2005 its seen that the waste ranges from 4.0m to 12.5m in thickness.

69 Conceptual Model Source, Pathway, Receptor

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