8: Validating what has been done
The purpose of validation is to check that the management option
for the contaminated land has been implemented correctly, so that
it will achieve the desired high level of protection of people
and the environment (principle
1, Section 2). The steps involved
are shown in Figure 5. The first two steps
are the carrying out of monitoring and surveys (see Section
8.1) and the evaluation of the results of these (see Section
8.2). These results should be communicated to stakeholders,
some of whom will be involved in deciding whether the option has
been implemented correctly (principle
2). Records should be kept of all validation activities (principle
5 and see Section 8.3).
8.1 MONITORING AND SURVEYS
Monitoring is usually required after the option has been implemented
as well as during it. There are specific requirements for monitoring
at nuclear-licensed sites. At defence sites MoD has to be satisfied
that work is completed in accordance with contractual conditions.
Completion surveys and independent monitoring can be required
by regulators, for example in order to discharge a planning condition,
or surrender a Pollution Prevention and Control permit (which
has replaced waste management licensing). In some circumstances
there will be a need for third party independent monitoring under
the conditions of a contract for the implementation of the option,
or because it has been agreed with stakeholders that this will
be done.
A description of typical of monitoring, planning and requirements
is given in Harris et al.
[1995], and approaches are recommended in EA
[2000a]. Guidance in Baker
et al. [2000] is also relevant. The post-implementation monitoring
should make use of, and be consistent with, the approach used
during implementation if possible. It is good practice to keep
stakeholders informed throughout the process.
8.2 EVALUATION OF RESULTS
The results of validation monitoring and surveys will be evaluated
by the site owner/operator, regulators and perhaps by other stakeholders.
The outcome could be agreement that the option has been fully
and correctly implemented, or a requirement for further implementation
work. The Land Quality Assessment described in Part IIA guidance
is a useful reference to determine that the state of the site
meets the intended objectives.
8.3 RECORD KEEPING
It is particularly important to keep records of validation monitoring
and surveys and of the evaluation of results. While each organisation
involved (site owner/operator, regulators, independent monitoring
organisations) will need to keep their own records, it is recommended
that one organisation takes the responsibility for holding a complete
set. It will usually be most appropriate for site owners/operators
to do this and to include material about regulatory and independent
validation in their own summary records (see Section
3.5.3).
Figure 5 Steps in Validation
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