A new Code of Practice designed to resolve waste soil issues on brownfield sites has led to innovative solutions in reusing and treating soils from multiple locations
The redevelopment of brownfield or contaminated land has been instrumental to the development industry for well over 10 years. It is now a key part of government policy, which has included challenging targets of up to 60% of new housing to be built on previously used land.
Key to the remediation contracting industry has been the ability to reuse soils on contaminated sites under an exemption from the Waste Management Licensing Regulations and the Environmental Permitting Regulations.
Changes to environmental legislation have also been very active. Recent and pending changes mean that existing exemptions have or will be shortly withdrawn.
Whilst exemptions are available under the new Environmental Permitting Regulations 2010, they are widely considered inappropriate for permitting the reuse of soils on remediation projects. Therefore, an alternative arrangement was required to avoid serious consequences for remediation in the UK.
This alternative was launched by CL:AIRE (Contaminated Land: Applications in Real Environment) in the form of an approved Code of Practice - the Definition of Waste: Development Industry Code of Practice (CoP).
This was introduced to resolve whether material to be reused on site was a waste or not. It sets out good practice for the remediation and development industry to use when:
- Assessing whether materials are classified as waste or not
- Determining when a treated waste can cease to be a waste for a particular use.
Whilst the CoP is primarily used to allow the appropriate reuse of materials on the site from which they were generated, it also provides a mechanism to enable the reuse of soils in the remediation and development of a number of sites that are in a cluster, and which can share a decontamination facility located on a single site.
The single site utilised for decontamination is referred to as a “hub” site. Other sites can then export soils to the hub for treatment under the environmental permit held by that facility.
These other sites are referred to as “donor” sites. Once deemed suitable for use the treated soils can then be exported back to any of the donor sites, reused at the hub site, or a combination both. They are then also referred to as a “receiver” site.
Arrangemanet in the UK
Remediation contractor VertaseFLI has recently worked on the largest cluster arrangement in the UK. The company was involved in a large remediation project in Coventry on behalf of Coventry City Council.
The work included bioremediation, ground water pump and treat, physical processing, dynamic compaction and large-scale remediation earthworks, and reinstatement beneath a pathway break. The council also had an interest in another contaminated project 12km away and which had a surplus of soils.
VertaseFLI was already using the CoP and saw an opportunity to bring the two sites together under a cluster arrangement. The main remediation site became the hub and receiving site, whilst other site became a donor site.
Over 14,000m3 of soils were imported onto the hub site for subsequent remediation and validation.
The cluster arrangement worked extremely well and brought significant environmental and financial benefits, which included reduction in lorry movements, the avoidance of landfill disposal charges and landfill tax, and the avoidance for the need to import fill.