Asbestos in soil can be confusing at the best of times. There are different rules and regulations that apply to the removal, loading, transport, use, reuse and disposal. Within NSW, there are a number of different pieces of legislation that apply to asbestos in soil management. This can create some confusion when it comes to contaminated soil and site remediation. Just because something was okay to do on one site does not necessarily mean it is okay on another site.
Asbestos contaminated soils usually occur in the form of uncontrolled fill material or previous uncontrolled demolition of structures containing asbestos. Although other sources, such as naturally occurring asbestos (NOA) can also be found. With the remediation of asbestos in soils, the extent of remediation can be determined by a number of factors. Some projects may be allowed to remove to design levels and cap the contaminated material, whereas in some instances full site remediation may be required (such as during the sale of land or change of land use).
Asbestos contaminated soil is classified based on the presence of the following types of contamination:
Asbestos-Containing Material (ACM);
Fibrous Asbestos (FA); and
Asbestos Fines (AF).
Assessment - This should always be your first step. Engage the right person to undertake the initial assessment. When it comes to any removal / excavation of asbestos contaminated soil you will need an assessment report for the nature of asbestos contamination (for example friable, non-friable) and soil sampling for other contaminants that may be present (such as a waste classification or soil validation). If you do not have a report detailing the above, SafeWork will not accept the asbestos notification and the tip will not accept the waste soil. The extent of the assessment, number of samples and sampling methods will be largely dictated by the extent / volume of material and intended disposal or reuse. If the asbestos is mixed throughout a fill material layer, augering or test pitting should be undertaken to ascertain the depth of contaminated fill and classify different material layers.
Removal - The removal of asbestos contaminated soils is governed by the Codes of Practice. The removal method generally involves the mechanical removal (e.g. excavation) of soil, dust suppression methods, decontamination procedures (both personal and for plant/equipment), stockpiling and/or load out of material. The removal of asbestos impacted soil will require an appropriately licensed asbestos removal contractor to provide a ticketed supervisor and ticketed labourers to remove the material. Truck drivers and machine operators do not necessarily need to be ticketed asbestos removalists, but should be trained in asbestos awareness, on site PPE, decontamination and asbestos procedures.
Containment Cells - On site containment cells must first be approved by the relevant authorities (e.g. council, SafeWork NSW, EPA etc.). On site containment can involve the burial or stockpiling of asbestos impacted soils followed by the appropriate capping of the material. The cell should be documented, maintained and a site specific asbestos management plan should be implemented. This process is only accepted on certain sites.
Stockpiling - If you are stockpiling material for disposal you must make sure you do not transport asbestos impacted soil across lot boundaries without EPA permission/approval. When stockpiling asbestos soils for disposal, stockpile management procedures should be implemented (bunding, dust suppression, cover stockpiles etc.), the stockpiles should be separated from other waste, boundary tape/fencing and signage should be erected.
Transport - Transporters of asbestos waste and asbestos in soils do not need to be licensed asbestos removalists. They do however, need to make sure the removal contractor is licensed, waste material is appropriately wrapped or sealed for transport and that each load is tracked using EPA Waste Locate. Transporters of asbestos waste should ensure that they have asbestos liability cover on their insurances.
As you can tell, there are a number of factors at play when dealing with asbestos in soils. Costs can build quite rapidly and are generally not budgeted for. Asbestos in soils must be managed with consideration of human health impacts, short and long-term land use, and future developments. If you require assistance with asbestos in soils, contact HazChek.