Asbestos in Soil, Site Investigation, Remediation and Construction Works

Some of the issues we should all be aware of……… Presented by Steve Edgar 30 November 2017

■ VertaseFLI are one of the most experienced Contaminated Land and Brownfield Contractors in the UK.

■ Experience of a wide range of contamination and techniques including asbestos, organics, radiological contamination, metals and deleterious materials such as landfill waste.

■ We have a highly trained, mobile and experienced technical team and workforce operating from offices in the North and South of the UK.

A bit about VertaseFLI

Working With: Major Contractors Quarrying and Mining Industry Consulting Engineers Water and Waste Water Industry Developers Waste Management Housebuilders General Manufacturing Petro-chemical Environmental Consultants PLC Retailers Local and Central Government Chemical Companies

■ Historically demolition and refurbishment surveys looked solely at asbestos within buildings/structures. Often below ground structures and the actual ground etc. are ignored. Structures by Asbestos Surveyors, Asbestos in soils by Consulting Engineers.

■ Those undertaking D&R surveys are not usually experienced “in the ground”.

■ Those undertaking site investigations are often unaware of CAR 2012 and have little or no experience of asbestos management and may not even be insured for working with it.

■ Sites have often undergone a number of phases of development/build particularly on chemical works. In the past the burial of asbestos in “graves” was commonplace.

■ Finding “asbestos graves” can be complicated and unreliable particularly with the constraints of the site.

■ Site investigations are often done “pre-demo” restricting access further.

■ Laboratory techniques have improved significantly over recent years meaning that asbestos is “Flipping everywhere”!

■ Asbestos exposure, the regulations and requirements are poorly understood within the contaminated land industry and wider.

■ Contaminated land is poorly understood by the asbestos industry.

■ Pretty much all made ground is impacted with asbestos to some degree.

■ Licensed contractors and surveyors don’t understand regulation or practicalities in relation to works in the ground.

What's the problem with Asbestos and soils?

A: Client

B: Contractors working in the ground

C: Geo-environmental Consultant

D: Asbestos surveyor

E: HSE

F: Main Contractor

Sometimes it “falls between two stools”

So, who is actually responsible?

The Truths

■ Most clients are NOT getting it right

■ Most main contractors are NOT getting it right

■ Many specialist contractors are NOT getting it right

■ Many consultants are NOT getting it right

Can you handle the truth?

How often are you breaking

the Law?

Sorry………..Couldn't help it………….

A famous singer once sang…… “There must be 50 ways to leave your lover” Well here are 10 ways to get it wrong with asbestos in soils

When should I think about Asbestos in soils?

■ Should we expect to find ACM on site?

■ In short yes for pretty much all brownfield sites. This means that CAR2012 principles will be in play from this presumption. It is also worth noting that accepted demolition methods may leave behind some debris in C&D materials where this ACM has low or trace levels of asbestos. This can give problems for use and sale of crush. See REG 25. Because its accepted doesn’t mean you can ignore it!

So if I’m thinking about it…. How should it be described?

■ Accurately. It may not be recognisable as AIB, or chrysotile or insulation. Those logging samples should be competent and experienced in describing and describe accurately to assist in particular with licensing and preparing POW’s. Examples could be:

■ Soil contaminated with asbestos sheeting/board

■ Soil containing loose fibrous asbestos debris

■ PLEASE DISPENSE WITH EURO CODE!

■ THIS COULD MAKE THE DIFFERENCE IN TERMS OF LICENSED WORK OR NOT!

No 1: Do I know if I’m working within the Asbestos Regs? Reg 2

■ What actually constitutes asbestos work?

■ Work with asbestos is defined in CAR 2012. For soil and C&D materials the following list includes but is not limited to asbestos work.

– Demolition of structures above ground – Demolition of structures below ground – Land remediation works – Excavations and earthworks – Ground improvement such as piling – Foundation installation – Producing secondary aggregates for us on or off site – Maintenance works such as utility works, landscaping, fencing erection – Ground investigations and surveys – Monitoring activities

■ So pretty much everything!

And therefore…….

Typical Asbestos works?

Demolition of structures

above ground

Demolition of

structures below ground

Land

remediation works

Landscaping,

fencing erection

Producing secondary

aggregates for use on

Foundation installation

Ground

investigations and surveys

Monitoring

activities

Ground improvement such as piling

Excavations and

earthworks

Maintenance works

such as utility works

Placing 6F2 piling mats

Civils works

Crushing and

screening

Site turnover

All asbestos or suspected asbestos is covered by CAR 2012 regardless of whether it is in a building or in the soil.

Some judgement is required and full and thorough investigation and sampling is key, however if the above is done correctly then “trace levels” of

asbestos may fall outside the scope of CAR 2012.

Ah but at what concentration is it present?

But when is the concentration so low that this is not the case?

Do trace levels of asbestos in C&D Materials

fall in or out of the regulations?

No 2: Competence

“ a person, or employee who has received adequate information, instruction and training for the task being done and can demonstrate an adequate and up to date understanding of the work, required control measures

and appropriate law.”

“sufficient practical experience to apply this knowledge effectively”

This is different to a “normal” Risk Assessment and is in addition to assessing the usual construction risks. People carrying out this assessment:

■ Must involve employees both in a general sense (H and S committees etc.) and also preferably on a case by case basis.

■ The person assessing the risks must have appropriate knowledge, training, expertise and experience. They should understand the risks from the ground!

■ They need to understand how the work will be undertaken.

■ Be able to assess other non asbestos risks.

■ Be able to estimate the expected level of exposure to decide if the control limit will be exceeded.

■ It needs to be suitable and sufficient. Think about what activity is being done. Horses for courses!

■ You should be asking your consultants and contractors for a copy of these!

No 3: No ARA or POW (for SI, remediation or groundworks)

Geo-Environmental companies and contractors alike get this wrong all the time!

■ Adequate to safeguard themselves and others and to carry out their work effectively.

■ In house or external.

■ It needs to cover the mix of asbestos/remediation/site investigation/contaminated land not just one or other.

■ Competence – Not a course alone

■ Starting with training, and there are 3 types of training

– Asbestos Awareness – Non-licensed work inc NNLW – Licensed work

■ ASBESTOS AWARENESS IS TRAINING ON HOW TO AVOID DISTURBING

ASBESTOS ONLY!

■ If work is planned to DISTURB asbestos this [CAT A] is not sufficient

■ TNA also needs to be considered also as does holding an accurate record of training undertaken. There isn't a single course that delivers this!

No 4: Reg 10 IIT

No 5: Not controlling works (Reg 12 & 13) or preventing the spread (Reg 16)

Some facts about work with ACS:

■ All asbestos has to be removed from site.

■ Anything containing ACM is Haz.

■ You can’t dispose of soils without hand picking them first.

■ You can’t re-use asbestos contaminated soils on site.

■ You can’t leave asbestos contaminated soils in place on a development.

■ All ACM needs to be removed before re-use.

■ All disposal works are essentially licensed work.

No 6: Not understanding the disposal and re-use of materials

ALL COMPLETE NONSENSE!

■ On completion you need to be able to prove that – You have proof that the spread of asbestos has been controlled. – You’ve met/complied with the remediation strategy. – You have no asbestos left at the surface! (Inc. after SI). – You have some form of clearance or validation report/certificate.

■ You know what measures need to be taken by onward constructers. e.g does your piling mat have asbestos in it?

No 7: Validation/Clearance/Work Records

No 8: Not understanding remediation and re-use options

INCREASING COMPLEXITY

Bioremediation

Screening

Crushing

Mixing

and blending

Detailed risk assessment

Management

methods Re-location

on site

Off site disposal

Direct re-use

Hand

picking

Stabilisation

Soil

washing

Thermal

Treatment

Engineering

methods

Cover

Cement sheet

Loose fibres in the soil

AIB burial pit

Load of insulation

Few bits of AIB in soil

Haz waste levels of cement board

Non-haz levels of AIB

No visible ACM

Haz waste level of AIB

Haz waste levels of loose fibres

No 9: Is my work Licensed or NNLW or NLW?

Can you re-use soils containing asbestos?

No 10: Understanding the other rules

My 6F2 has asbestos in it, off to landfill then?

Which of these is the correct remediation target?

A: 0.1% B: 0.1f/cm3

C: 0.01mg/kg D: 0.001% E: <0.010f/ml

Thank You! Steve Edgar Director – VertaseFLI e: sedgar@vertasfli.co.uk t: 07973981780