7: Implementing the chosen management option

The steps in implementing the chosen management option are shown in Figure 4 and are discussed in turn below. The most important key principles during implementation are principles 1, 2 and 5. Principle 1 underlies everything that is done and is applied particularly through appropriate operational health, safety and environmental protection procedures (see Section 7.4). Compliance with principle 2 entails reporting on progress and plans (see Section 7.5). Compliance with principle 5 means that records should be kept throughout implementation (see Section 7.6).

7.1 PLANNING THE IMPLEMENTATION

Detailed planning of the practical implementation of the option should be completed before work starts. Planning is especially important for large projects and those that take place on large or complex sites. Much guidance is available on this topic, for example Harris et al. [1995], Barry et al. [1996], DETR [2000a], EA [2000a] and HSE [1999]. This section is only concerned with issues within the scope of the guidance.

The planning should develop a systematic approach to implementing the chosen option (‘who, where, what and when’) using appropriate procedures. Issues to consider include the interdependence of the option with other activities on the site, the staffing and their roles and responsibilities, financial resources, waste management routes and contingencies. Performance measures, such as residual contaminant concentrations, should be made clear, as should quality assurance indicators that demonstrate that procedures were followed. Contingency measures should be specified (e.g. if contamination is found to be more extensive or at higher concentrations than expected), if necessary on the basis of a risk assessment (which should be separate from assessments undertaken in the identification of the preferred option, although it may draw on them).

Figure 4 Steps in Implementation of the Selected Option/Strategy

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Waste management is likely to be a very important consideration if large quantities of contaminated material are to be excavated. Responsibility for waste that is generated should be clearly specified. Non-radioactive contaminated material in solid form will need to be disposed of at an appropriate landfill (municipal, inert or hazardous waste landfill). Depending on its characteristics, current options for the management of solid radioactive waste are disposal to municipal landfills under ‘Exemption Orders’, disposal to specified landfills under the ‘Controlled Burial’ regime, disposal to the UK national facility at Drigg, or storage (see HSE [2001b], Environment Agency [2002b]). Waste could also be disposed of on-site, if an authorisation is held under RSA. The route available is largely dependent on the radionuclide concentrations, although the volume may also be a significant factor. The requirements for waste management should have been considered in the choice of land management option. At the planning stage the arrangements for their use should be put in place; it should be noted that this may take some time (many months for disposals to Drigg).

The documented plan will provide a specification for the site owner/operator or contractor to implement the option. If contractors are used, they can also assist in the planning stage. It is desirable to keep external stakeholders informed about the plans that are being developed (see Figure 1).

7.2 CONTRACTUAL STRATEGY AND CONTRACT MANAGEMENT

Guidance on contract strategy is primarily required for defence sites and is discussed in further detail in Appendix B. For these sites the contract is a key document that describes the responsibilities and methods to be applied. The planning stage should address the requirements and roles and responsibilities of contractors and others in the implementation of the option. It is important to agree contingencies should the contamination be found to be more significant than expected. The contract should also address health and safety requirements, specific targets and monitoring requirements. Adversarial forms of contract should be avoided. Hold points and milestones will help to ensure that the implementation of the option is undertaken in a stepwise way and that key stages of the plan are met on time and completed satisfactorily.

7.3 MONITORING

A sampling, monitoring and testing programme will be required during the implementation of the chosen option. For example it will be necessary to ensure that any imported materials conform to specifications, and to sentence any extracted material. The monitoring and collection of samples during the implementation of the option will also provide important data for the validation phase of the management of the contaminated land. The SAFEGROUNDS Site Characterisation Guidance identifies the main elements of a monitoring programme [Baker et al. 2000], as well as referring to supporting guidance.

Within the monitoring programme, instrumentation and its detection limits should be specified. Prior to commencement, the monitoring instruments should be checked and calibrated. (This is a requirement under the IRRs for radiological instruments.) The areas and volumes over which measurements are averaged should be specified and documented. The monitoring can be carried out by those implementing the chosen option (e.g. the site owner and/or the contractor) or by an independent organisation.

The regulatory organisations have sponsored a number of pieces of work to assist them in assessing proposed monitoring programmes [HSE and EA refs to be added]. These may also be useful to site owners/operators and contractors.

7.4 OPERATIONAL HEALTH, SAFETY AND ENVIRONMENTAL PROTECTION

All actions must be carried out in conformance with regulations under the Health and Safety at Work etc Act. These include the IRRs, COSHH and CDM. Nuclear-licensed sites will have operational procedures in place that should cover all of the requirements of relevant regulations. At defence sites it may be necessary to establish suitable procedures. A Radiation Protection Advisor (RPA) should be engaged for this purpose and any other RPAs that have been involved should be consulted. Additional guidance is available from Barry et al. [1996], Harris et al. [1995], HSE [2001b], HSE [1999a] and HSE [1991].

Environmental protection should be considered. Regimes for environmental protection will already be established at nuclear-licensed sites. For other sites, guidance on objectives and methods is available from Harris et al. [1995], for example.

7.5 REPORTING PROGRESS, UPDATING PLANS

It is good practice to keep external stakeholders, particularly local authorities and local people, informed of progress during implementation of major contaminated land operations. At nuclear-licensed sites regular progress reports to Local Liaison Committees provide a means of doing this. At defence sites special mechanisms may need to be devised. Progress reporting should include any changes to implementation plans, or to the option being implemented. Option modifications may be required as a result of what is found during implementation or, if the implementation period is long, because of changes in circumstances.

7.6 RECORD KEEPING

Records are best kept throughout the process of implementing the option, not completed retrospectively at the end. Relevant records are likely to include surveys, working methods and other operational records. Important information includes residual contaminant concentrations and distribution, any groundwater contamination, the physical characteristics of the site, the quantity and characteristics of any waste that was removed and any ongoing requirements (for monitoring, etc). It is important to record any deviation from the planned implementation of the option. These records form key quality assurance documentation. Guidance on quality assurance in relation to contaminated land is presented in DOE [1997].

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