Options
1. Try re-using the materials on site - it will not be classified as
waste if you follow the procedures in the EA's guidance document
"Brownfield Land - Definition of Waste" - copy attached.
2. Treat the material through a crusher / screening plant using the WRAP
protocol for production of secondary aggregates. Set a specification
that either ignores pH or says pH > 11.5 is ok. Make sure you are happy
that the materials is not environmentally harmful at its point of use.
Using the protocol correctly means that the treated material is not
longer a waste and therefore the Landfill Regs and Haz Waste Regs do not
apply.
3. Re-visit your sampling / analytical procedures with your lab.
Regards
John Martin
Director
TerraConsult
Bold Business Centre, Bold Lane, Sutton, St Helens, Merseyside WA9 4TX
Tel: 01925 291111
Fax: 01925 291191
Mob: 07718 631 922
http://www.terraconsult.co.uk
-----Original Message-----
From: Contaminated Land Management Discussion List
[mailto:[log in to unmask]] On Behalf Of
Lawrence Bowden
Sent: 11 April 2008 11:08
To: [log in to unmask]
Subject: Re: remediation
Morning All,
Another Friday teaser!
We currently have a site where, as with many redevelopments, the crushed
concrete from the former development has been reused on site in the
interest of sustainability gaining BREAM points etc.
The issue is that chemical testing of the arisings for piles, ground
beams etc has shown the material to be Hazardous based on the elevated
pH (>pH11.5) of the material thus classing it as H8 Corrosive / Irritant
under the Hazardous Waste Regs. The classification of the material as
hazardous based on high pH is, one assumes, purely based on the fine
crushed concrete being selected for the pH testing yielding a high pH
due to the alkaline mineralogy, though this may not be representative of
the site condition nor sustained over a long period (i.e. an initial
flush).
This is posing significant difficulties on this site as the cost of
disposing of the surplus material as hazardous from the site is
obviously very high.
Does this mean that on any site where crushed concrete may be used in
the interest of sustainability these issues are going to arise? and that
such an approach should be avoided?
Any thoughts will be welcomed, especially if anybody has any suggestions
as to how to get round the problems on the current site.
Thanks
Lawrence
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