In December 2017, the EPA issued a draft Guidance Note on Soil Recovery Waste Acceptance Criteria. This guidance document applies to soil recovery facilities which exceed the operational thresholds for waste facility permits as set out in the Third Schedule of the Waste Management (Facility Permit and Registration) Regulations 2007 (S.I. No. 821 of 2007) as amended. Facilities that exceed these thresholds are required to operate under a Waste Licence granted by the Environmental Protection Agency (the Agency).
Licensed soil recovery facilities are typically worked-out quarries that are in the process of being restored. They may also be sites where relatively large volumes of soil are being imported to raise natural ground levels. In both cases the soil recovery facilities are licensed to accept only uncontaminated natural soil and stone.
Unlike landfills, soil recovery facilities are not required to have an engineered basal liner, nor are they required to install an engineered cap following completion of restoration or land raising. As such there are no engineering controls to protect groundwater from contamination that may be present in soil used as backfill at these facilities. Because of this, it is important that precautions are taken by operators of these facilities, both prior to accepting soil from individual source sites and while soil is being received, to ensure that only uncontaminated soil and stone is accepted. It is best practice to monitor incoming materials so that the Licensee can determine if this material is uncontaminated and suitable for acceptance at their site.
Licences granted by the Agency for soil recovery facilities may include a condition requiring the licensee to propose maximum concentrations and/or trigger levels for relevant contaminants in soil and stone proposed for acceptance at the facility from non-greenfield sources. This document provides guidance on developing soil trigger levels that will be acceptable to the Agency, to comply with these conditions.
There are a number of licensed soil recovery facilities operating in Ireland that have received backfill material in the absence of soil trigger levels having been agreed with the Agency. In these cases, it is necessary that licensees demonstrate to the Agency either that the backfill received at the facility to date is compliant with soil trigger levels developed in accordance with this guidance, or that the existing facility is not causing environmental pollution.
In such cases, and in the absence of relevant parametric monitoring to demonstrate compliance with the trigger levels specified in the guidance doc, the licensee shall submit a proposal to the Agency to undertake a programme of soil sampling (assuming soil samples have not been retained or are unsuitable for testing) and laboratory analysis for approval. This proposal should specify how and where soil sampling is to be undertaken, as samples should be taken from a sufficient number of locations and range of depths to be fully representative of materials placed at the site.
If the results of this testing programme indicate that material has been used as backfill that exceeds the soil trigger levels for the facility, then the licensee shall complete a hydrogeological assessment that considers whether the facility is compliant with the European Communities Environmental Objectives (Groundwater) Regulations.
With the Closing date for comments on this draft guidance document just a month away (by 5pm, 16th March 2018), Verde Environmental Consultants can help you undertake a programme of soil sampling, and can work with you to complete a hydrogeological assessment. Our specialists are trained in the use of the appropriate classification tools and have an in-depth knowledge of the relevant legislation and guidance, which allows them to guide clients in establishing cost effective and sustainable soil management solutions.
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