BU3 Standard Operating Procedure – Health, Safety and Environment

Historically Contaminated Soil

Table of Contents
1 PURPOSE...........................................................................................................................2

2 SCOPE................................................................................................................................2

3 DEFINITIONS......................................................................................................................2

4 PROCEDURE......................................................................................................................2
4.1 General Information....................................................................................................................... 2
4.2 Identification of Aspects & Potential Impacts..................................................................................3
4.3 Specialist Investigation.................................................................................................................. 3
4.4 Remediation Plan........................................................................................................................... 4
4.5 Remediation Methods.................................................................................................................... 4
4.6 Management of Remedial Works...................................................................................................4
4.6.1 Restricted Access.............................................................................................................................. 4
4.6.2 Excavation of Contaminated Soil...................................................................................................... 5
4.6.3 Transportation of Contaminated Soil................................................................................................. 5
4.6.4 Stockpiling of Contaminated Soil On-Site.......................................................................................... 5
4.6.5 Washdown of Machinery................................................................................................................... 5
4.7 Monitoring, Measurement & Performance......................................................................................6
4.8 Non-compliance & Reporting......................................................................................................... 6
4.9 Responsibilities.............................................................................................................................. 6

5 REFERENCES....................................................................................................................7

6 ATTACHMENTS..................................................................................................................7

Revision Details Next Review: Aug 2010

Rev. Date Revision Status Checked Approved
01 31/8/09 First issue, template provided by LCI HSEQ Dept. Peter Finch

Note: Check with Document Control or LCI Controlled Servers before use that this is the current
version.

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PURPOSE
To effectively manage the historical contamination of soils at project sites. This procedure provides information
on site assessment, remediation planning, and remediation options.

SCOPE
This procedure applies to all projects where soil contamination is identified in a project’s aspects / impact
register as an issue.
It does not cover contaminated groundwater management. Safety and health aspects of land contamination
are outlined in BU3-OHS-SOP-012 Workplace Contamination Controls.

DEFINITIONS
Acceptable level: The threshold concentration value below which the concentration of a
contaminant is generally considered acceptable – levels may be specified in
law or regulations.
ANZECC: Australian and New Zealand Environment and Conservation Council.
Contaminated Site: Means a site at which substances occur at concentrations above acceptable or
background (normally occurring) levels and pose or are likely to pose an
immediate or long-term hazard to human health or the environment.
High Risk Means types of industries, activities and land uses known to cause site
Industries / activities: contamination, eg, landfill sites, service stations, mine site waste, engine
works, and chemical manufacture, formulation and storage.
JSEA: Job Safety and Environmental Analysis.
Local Authority: Official authority in a particular political jurisdiction with responsibility for
contaminated land management, for example, Environmental Protection
Agency, Planning Agencies.
Mobility: The ability of particles and substances to move, either by random motion or
under the influence of fields or forces.
NHMRC: National Health and Medical Research Council.
Pathway: Route taken by the contaminant to a receptor.
Receptor: Means a receiver (somebody or something) of pollution, eg National Park,
people, animals.
Remediation: The clean-up or management of pollution or contamination of soil by various
on / off site methods.
Stabilising: Converting contaminants to a less mobile and / or less toxic form, typically by
chemical reaction.
Solidifying: Means locking contaminants in solidified matrix.

PROCEDURE
1.1 General Information
Historically contaminated land poses a risk to environmental amenity. Land contamination may have
occurred as a result of poor environmental management practices and / or accidental chemical spills during
former industrial, mining or manufacturing activities conducted at the project site.
Common contaminants which may be encountered are:
 toxic metals - lead, cadmium, arsenic, beryllium, mercury from industrial processes;

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 hydrocarbons – petrols, diesel fuels, oils, lubricants from leaking underground storage tanks, former
workshop areas, refuelling sites (service stations / fuel depots); and
 solid waste - asbestos, domestic waste from landfills, dumps etc.
Soil is generally considered to be contaminated if acceptable levels of chemicals are exceeded and have the
potential to cause harm to human health or the environment - information about these levels may be
obtained from the local authority, or from international references (See Section 6).
Sites contaminated by unexploded ordinances, radioactive substances and biologically pathogenic materials
are usually considered to be contaminated sites by definition.
The fundamental objectives of all contaminated land work are the protection of the environment and the health
of site workers, as well as, the safeguarding of public health and safety.

1.2 Identification of Aspects & Potential Impacts

In order to reduce the environmental impact of project activities, it is important to first identify activities that
have the potential to significantly impact on the environment.
In this respect:
 The Project Environmental Management Plan (PEP) and Environmental Aspects Impact Registers (Risk
Assessments) must be completed for all Projects to identify potential impacts and hence prompt specific
actions to manage and reduce impacts.
 Job Safety & Environmental Analysis must be conducted to identify any potential impacts associated
with tasks that are not covered within the Aspect Impact Register and PEP.
 Note must be made of any Environmental Impact Assessments or specialist site investigations (often
conducted by the Client), any historical data about former land uses, and any national registers of
known contaminated sites that may be available from regulatory bodies or Environmental Protection
Agencies.
Soil pollution from historical land contamination should be considered as a possible risk when previous land
uses have involved high risk commercial activities. Examples include: former landfill sites, fuel/service
stations, mine-site waste areas, engine works, and places of chemical manufacture.

1.3 Specialist Investigation

If historical land contamination has been identified as a potential project risk, a full investigation of the site
should be undertaken to assess the significance of environmental impact. This is usually the responsibility of
the Client and is performed by environmental technical experts, using local authority guidelines where they
exist.
Examples of the information and analysis typically required of the special investigation includes:
 the provision of an accurate historical record of previous land use;
 review of local geology and hydrology;
 scientific sampling and analysis of the soil;
 identity of the sources of contamination;
 extent of remediation required;
 leachability and mobility of contaminants;
 identity of critical receptors – eg, local community;
 health and environmental risk assessment; and
 potential for groundwater contamination and possibility of off-site migration.

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1.4 Remediation Plan

The specialist should provide a remediation plan for the site when investigations have confirmed that
contamination exists. This may be a separate document to the investigation or a part of the same document.
The plan helps to mitigate the environmental impact of site contaminants by providing guidance about:
 location of contamination;
 remediation methods suitable for the site and proposed land use;
 site-specific remediation criteria for particular contaminants to guide clean-up activities;
 the extent of remediation required, including volume of soil to be excavated and treated;
 recommendations for either on or off-site remediation or a combination of both.
The plan should also outline strategies to protect the public from exposure to contaminant sources during
remediation activities. A public communication strategy may need to be developed for affected community
groups, especially those known to have public concerns (real or otherwise) about the site land-use history, or
where offensive/chemical odours/vapours are expected during assessment and remediation activities.
The plan shall comply with local authority requirements for managing contaminated soils, where they exist.
Relevant information from the specialist investigation and remediation plan should be incorporated into the
Project Environmental Plan.

1.5 Remediation Methods

The appropriate remediation methods for the site should be outlined in the Remediation plan. Risk from
contaminated soil can generally be managed by implementing controls for the contaminant itself, its pathway
and identified receptors:
 Contaminant management – involves reducing, removing, modifying and destroying the contaminant.
Techniques include, disposal to landfill, bioremediation, solidifying and stabilising the contaminant, soil
venting and washing, and steam stripping of contaminants.
 Pathway management – includes preventing contaminant movement either by removing or destroying it
or by barricading its pathway. Techniques include construction of slurry walls, using buildings to reduce
potential for migration or exposure to contaminants, impermeable vertical / horizontal barriers to prevent
leachate infiltration and surface run-off.
 Receptor management – includes protecting the sensitive receptors from exposure. Techniques include
restricting site access and land-use and dust control from contaminated stockpiles.
Contaminated soil may be treated on-site or taken off-site for treatment and / or disposal, depending upon the
specific plan for the site.

1.6 Management of Remedial Works

1.6.1 Restricted Access
Access to the site should be restricted to help contain the contamination source (s) and prevent cross-
contamination of unaffected areas. Depending up its location, the nature of the project and local
requirements, the area should following controls should be considered:
 Fencing / barricading and signage;
 Controlled access points;
 Authorised personnel only;
 Possible access permit requirements;
 Prevent public access / thoroughfare;
 Alternative routes.

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1.6.2 Excavation of Contaminated Soil

As a part of remedial works, contaminated soil will typically be excavated and transported to a temporary
stockpile (awaiting final relocation and treatment) or taken directly off-site (either for disposal or treatment).
The following controls help to manage the environmental impact of excavation activities:
 Obtaining permits to dig / excavate and review site plans for local underground services / objects where
required;
 Removing contaminated material in a damp condition to reduce the potential for dust generation and
adverse air quality issues;
 Reinstating excavations with clean or remediated fill that has been tested to ensure contaminants are at
acceptable levels;
 Monitoring air quality during excavation activities.

1.6.3 Transportation of Contaminated Soil

The following controls help to manage the environmental impact of transporting contaminated soils around and
off-site:
 Fine spray of water and / or cover loads to prevent dust emissions and spillage whilst in transit;

 Travel via pre-determined routes, that minimise possible exposure of sensitive receptors to
contaminated materials;

 Obtain appropriate environmental permits for transportation and disposal off-site of contaminated
materials, or ensure sub-contractors have these;

 Trucks are to be roadworthy and loads within legal limits – avoid any spillage of contaminated soil, but
particularly in public areas.

1.6.4 Stockpiling of Contaminated Soil On-Site

The following are a list of controls to help manage the environmental impact of stockpiling contaminated soils
on-site:

 At some sites, bunded areas with impervious structures may be required depending on material &
legislative requirements;

 Erect appropriate signage to indicate whether or not the material is to stay on-site or be taken off-site;

 Conduct regular inspections of stockpile locations – check that uncontaminated soil has not been stored
on a stockpile for contaminated soils;

 Manage run-off from stockpiles to prevent downstream contamination – erect berms surrounding the
stockpile if necessary;

 Prevent further pollution - do not locate stockpiles near storm drains and watercourses;

 Employ dust suppression techniques to prevent on and off-site air pollution, eg, tarpaulins covering
stockpile.

1.6.5 Washdown of Machinery

All machinery involved in excavating, transporting and stockpiling contaminated soil is to be washed down in
designated areas prior to leaving contaminated areas and going off-site. Provision should be made for the
collection and disposal of contaminated water and waste and this operation should be agreed with the Client,
and the local authority (if necessary).
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1.7 Monitoring, Measurement & Performance

In order to monitor any environmental impacts arising from activities to remediate contaminated soils, a formal
program needs to be developed and implemented that relates to the significant impacts identified from due
diligence assessments, Environmental Impact Assessments, Aspects Impacts Register or JSEA’s developed
during the project life cycle. In this respect all Projects must comply with the following Procedures:
 BU3-HSE-PRO-002 Legal Compliance;
 BU3-HSE-PRO-003 HSE Performance
 BU3-HSE-PRO-007 HSE Audit; as well as,
 Any specific legislative requirements of the country in which the project is being undertaken.
Depending upon the exact nature of the project, a typical site environmental monitoring program should
consider the following activities:
 Scheduled and random inspections of the contaminated site area to check practical compliance with the
requirements of this and associated procedures and instructions;
 Confirmatory sampling of soil at the site, or taken away for treatment, should be undertaken to verify the
site has been cleaned-up to the expected standard – that is, it no longer poses an unacceptable health
or environmental risk. If sampling shows unacceptable threshold levels of contaminants still exist,
additional remedial work will need to be undertaken. Testing must be conducted by a reputable
laboratory.
 Monitoring of the volume of contaminated soil excavated and removed from site, and if contaminated by
hazardous materials, also record information about the name of the carrier, date left site and destination
– check requirements for tracking contaminated waste materials from its source to destination location
with local waste authorities.

1.8 Non-compliance & Reporting

Where the monitoring or auditing programmes have identified non-compliance to either internal or external
requirements, including the Remediation Plan, the following procedures must be complied with:
 BU3-HSE-PRO-002 Legal & Compliance;
 BU3-HSE-PRO-011 HSE Incidents Management;
 BU3-HSE-PRO-012 HSE Report.
Any deficiencies in systems and practices, suggestions for continuous improvement and non-conformances
that are identified during audits and inspections shall be formally recorded, their implications assessed, and
corrective actions prioritised and acted upon.
The Project Manager is responsible for ensuring close-out of actions arising from audits and inspections.

1.9 Responsibilities
 The Client is responsible for undertaking specialist investigations and assessments of historically
contaminated sites and sharing relevant information with contractors engaged to undertake activities on
site.
 Project Manager is responsible for ensuring compliance with regulatory and contractual obligations and
informing the Client if further contamination is uncovered during project works.
 Shift Supervisors are responsible for co-ordinating implementation of this procedure to employees.
 Environmental Representative is responsible for providing training in the procedure, monitoring and
reporting on the day-to-day operation of the procedure, regular auditing of the operations and updating the
procedure. He/She also shall insure that all employees and sub-contractors are aware of the requirements
to manage contaminated land.

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REFERENCES
 BU3-HSE-PRO-001 -
 BU3-HSE-PRO-002 -
 BU3-HSE-PRO-007 -
 BU3-HSE-PRO-011 -
 BU3-HSE-PRO-012 -
 BU3-OHS-SOP-012 -
HSE Risk Management
HSE Legal Compliance
HSE Audits
HSE Incidents Management
HSE Reports
Workplace Contamination Controls

ATTACHMENTS
Nil

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