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3.2 Post Incident Site Clearance Planning

Following a CBRN incident the Consequence Management SCG and Site Clearance Group will be faced with a range of complex, site specific issues that will require careful consideration and agreement in the process of developing a coherent framework for the sustainable rehabilitation of the area affected. Key to this process will be the development and implementation of a decontamination and site clearance strategy, the planning and implementation of which will run in parallel with the Rescue and Assessment and Site Preservation stages but will then continue well after these stages have concluded, as indicated below:

One of the most important aspects of planning site clearance is establishing what end point is to be achieved, i.e. how much clean-up needs be carried out and what acceptable contamination levels will be left at the end of site clearance. A clear vision of the agreed end point will enable effective planning that can identify and prioritise workloads, enable costs to be estimated and allow important decisions on decontamination methods, disposal routes and monitoring processes to be made. A means to display competency of the decontamination procedures and achievement of the end point will also be required to achieve a return to normality and build both general public and stakeholder confidence in the planned re-use of the site.

It is important also that any planning for site clearance takes account of legislative requirements and any constraints they may place on starting assumptions and options available. If the legislative requirements are unknown or ignored at the planning stage the whole process may be subject to delay or require subsequent re-planning.

When any relevant investigation has been completed and the extent and nature of contamination is known, general clearance of the site will be authorised by the Consequence Management SCG in accordance with their strategy and the site clearance plan. This process may be phased, as different sectors are cleared of evidence or bulk debris is removed to a remote temporary examination site for further forensic investigation.

The Local Authority, in taking the lead role within the Site Clearance Group, shall co-ordinate the delivery of the site clearance. To support this process the local authority may engage specialist consultancy services, other responders and Government Agencies (e.g. those offered by the Government Decontamination Service), to act in a capacity of contract managers with responsibilities to manage contract procurement, performance and work measurement.

Overall Plan attainment leading to the safe return of the site to site owners and residents will remain the responsibility of Site Clearance Group under the strategic direction of the Consequence Management SCG. This could be a protracted process and neither of these groups should be fully stood down until the site clearance plan has been satisfactorily completed and a return to normality, where possible, has been achieved.

The Site Clearance Group will be responsible for making early progress with the tactical planning for site clearance, confronted with a range of complex issues such as:

• incident location and environment;
• media and public expectation management;
• people considerations;
• management of key resources;
• health and safety;
• site security and cordon management;
• sampling and monitoring of contamination;
• nature of CBRN contamination;
• remediation options;
• decontamination;
• waste management; and
• post site clearance monitoring

These issues are discussed further as follows:

(a) Incident Location and Environment

At the earliest opportunity the Consequence Management SCG, in consultation with the Site Clearance Group, should take steps to assess the full impact of the incident on human health, environment, residential and business communities, critical infrastructure, transport, and essential community and economic facilities, including:

• the nature and effects of the contamination on buildings and infrastructure e.g. water supplies, sustainable urban drainage systems, etc.;
• the scale and nature of the damage;
• arrangements for the demolition or shoring up of dangerous buildings;
• the procurement of equipment and other resources to maintain public safety needs;
• the identification of critical national infrastructure assets involved; and
• the environmental importance of the area.

The environment into which a chemical, biological or radiological agent/source has been released will have an important influence on the planning of a site clearance strategy. Facilities to cover the site, or parts of the site, may have to be considered to provide weather protection (wind/run-off effects) or to contain contaminated dust generated by the site clearance activities.

The economic, social, cultural and political importance of the area will have a significant bearing on the level of remediation and regeneration to be implemented. A heavily populated urban area may require considerable decontamination, remediation and monitoring effort over a long period to reassure residents and to restore public confidence. Even when the hazard from the substance is extremely low, community engagement will help to build trust in the site clearance process. The geology and hydrology of the area must also be considered as this may affect how the contamination progresses into the soil and groundwater.

In the event of livestock, animals and birds being affected, Animal Health will be invited to participate in the Site Clearance Group to give advice on appropriate measures and actions.

(b) Media and Public Expectation Management ¹⁶

Any emergency will inevitably result in widespread public interest and concern. Site clearance and the physical restoration of amenities and normal services will have to be managed effectively with due consideration given to the wishes and expectations of the community. The public is likely to accept and make allowances for a period of disruption whilst the response is ongoing provided they are kept informed of the plans. Expectations will rise as time progresses and tangible progress will be needed to build public confidence.

It should be anticipated that demands for information could overwhelm incident management arrangements and public relations functions. Communication Plans, should be developed by Strategic Co-ordinating Groups for implementation in such circumstances.

Following handover from the emergency services, and throughout the site clearance process, the Consequence Management SCG must ensure that resources are provided and managed in order that:

• an information management strategy is developed and implemented to ensure that information is coordinated and integrated across all responder agencies;
• media management needs are delivered in accordance with established and tested emergency planning arrangements;
• nothing is said by the Consequence Management SCG or the Site Clearance Group which could in any way compromise or contradict information generated by the Terrorism SCG;
• a spokesperson(s) to front television and radio interviews is identified and exposure protocols are known to all stakeholders;
• internal communication meetings are held at agreed frequency to address and agree internal and external information requirements and timescales;
• community representatives, e.g. elected members, are kept well informed;
• automated helpline and customer helpdesk facilities are established and adequately resourced and updated;
• public information messages are accurate, coordinated, timely and easily understood by the target audience;
• press and other information releases are agreed with other stakeholders;
• all options to reach and inform the public, including local authority website, newsletters, press articles, site boards, posters, community meetings, etc. are assessed and deployed where and when necessary;
• effective measures to respond promptly to queries, both verbal and written, from the media, stakeholders, elected members and other interested parties are available; and
• incident stand-down announcements are agreed and fully communicated.

Community engagement, before, during and after the site clearance process, will be essential to canvas opinion on remediation needs and strategies. Media and community feedback on the success of the public information and expectation management processes should also be invited to inform the post-incident review and improve the learning processes.

(c) People Considerations

Planning for site clearance should recognise the overall impact of the incident on the community and ensure that appropriate arrangements are made to support those affected and those whose families or friends may have been affected by the incident. As part of planning considerations and early deployment strategy, recognition must be given to the need to:

• support the safe rescue of trapped and injured persons;
• preserve evidence and support forensic recovery and investigation;
• maintain, as far as is practicable, the dignity of any fatalities and human remains;
• facilitate criminal and other investigations;
• support and minimise the impact on affected individuals and the community;
• aid the recovery of personal items, valuables and business documents, etc.;
• minimise the impact of the incident and remediation activities on the environment;
• value the positive contribution the community and community groups can make to the remediation process;
• assist, as far as is practicable, an early return to normal economic activities; and
• rebuild community morale, confidence and cohesion.

(d) Management of Key Resources

Dependent on the nature, scale and consequence of an incident, the delivery of effective response from the outset through to the completion of site clearance and remediation will inevitably place exceptional demands on resources of all responder organisations. Consideration should therefore be given to the conflicting demands of the immediate response, the longer recovery period and the maintenance of normal service.

Management considerations should seek to maximise gainful deployment of all available resources. Planning for site clearance should firstly recognise that it is a long term process and then concentrate on the development of a critical path, which identifies priority actions/activities. It must also identify critical resource needs, and take into account provision for ensuring adequate cover, rotation and rest periods for all staff involved. Site clearance planning should also take account of:

• health and safety requirements;
• staff briefing and de-briefing needs;
• Working Time Directive considerations;
• work exposure hours and shift arrangements;
• skills and competency needs;
• decontamination needs and available facilities;
• laboratory facilities;
• remuneration and allowances;
• accommodation needs;
• welfare facilities;
• discrimination; and
• implications for staff not involved.

A project management approach to decontamination and site clearance activities may prove useful in the event of an incident utilising companies with expertise and experience in this field. The benefit in using the project management approach would be enhanced by appointing project managers who can demonstrate competencies in risk assessment, contract management, and principles of environmental protection.

A valuable component of the site clearance strategy would also be a decision making flow chart which demonstrates the key stages from the planning stage through to final implementation stage. The flow charts may also illustrate the reducing impact of the initial incident and the reducing influence it has on the day-to-day decisions being taken.

(e) Health & Safety

An early priority in planning for site clearance is the preparation of a Health & Safety Plan ( HASP) which should include Safe Systems of Work that take full account of the site conditions and identify hazard control measures and procedures to maintain the health and safety of site staff, workers, contractors and the general public. There is obvious merit in developing a generic HASP, containing risk assessments, method statements COSHH assessments and permits to work, with sufficient flexibility to enable them to be amended to reflect the circumstances unique to the particular incident. The development of a generic HASP can be grouped into several headings as follows:

a) Assessment of Contaminants

At the earliest stage a baseline assessment should be made in terms of the identification, toxicity, quantity and location of contaminants present. This should be kept under review throughout the progression of the site clearance works.

b) Site Management

• a responsible person should be nominated to assume overall management of the site clearance activities;
• a meeting should be held, chaired by the responsible person, to inform site managers and operatives of their roles and responsibilities;
• the area surrounding the contamination should be sealed off with physical barriers;
• access and egress to the affected area should be effectively managed. Depending on the nature of the contaminant it may be necessary for the responsible person to invoke Permits to Work; and
• effective means of communication should be established between site operators and local management.

c) Staff Training

• it is essential that all personnel engaged in site clearance operations have the necessary competency levels to undertake their duties in a safe manner. Training records should be consulted to enable management to engage and deploy appropriate personnel;
• multi-agency scenario exercises should be conducted periodically to ensure that competency levels are achieved and maintained;
• post-incident debriefing sessions should be undertaken to highlight good working practices and opportunities for improvement; and
• experiences and lessons learned from 'real' CBRN and HAZMAT incidents throughout the UK should also be shared to help improve health and safety planning and awareness.

d) Medical Arrangements

• medical records of all site personnel should be maintained;
• channels of communication should be opened with hospitals at an early stage to ensure they have the necessary resources to deal with work casualties; and
• emergency First Aid provision should be available on site as an additional back-up.

e) Personal Protective Equipment

• the responsible person should, in consultation with informed others, specify, select and provide sufficient stocks of Personal Protective Equipment ( PPE) capable of effectively protecting site workers from being exposed to contaminants and other hazards;
• only personnel wearing appropriate PPE should be allowed to enter the site boundary; and
• arrangements must be put in place to ensure the appropriate cleaning and disposal of contaminated PPE.

f) Documentation

• Risk Assessments should be developed by the responsible person, in consultation with others, to identify the hazards present on site and the appropriate control measures. They should be made available to all site personnel. Due to the potentially dynamic nature of the site clearance activities the risk assessments may have to be reviewed regularly and at short notice. Site personnel should be informed of the findings of such risk assessments and instructed about changes to safe working practices;
• Method Statements supplement risk assessments and they outline, in sequential manner, how the work should be undertaken. This documentation can be developed during site briefing sessions, at which the responsible person will clarify the duties of specific personnel and the order in which activities will take place. Similar to risk assessments, Method Statements may have to be changed at short notice due to site conditions;
• COSHH Assessments should be made available for all contaminants. It may not be possible to develop specific assessments as the level and nature of the contamination may not be known at the outset. If this is the case, a precautionary approach should be adopted and it may be necessary to deploy air monitoring equipment with alarm mechanisms to highlight situations of imminent danger; and
• Permits to Work may need to be issued to control access to areas affected by the incident. The Permits of Work complement the risk assessments, Method Statements and COSHH assessments and they record details of personnel who have been permitted to access contaminated or unsafe areas and provide details of the precautionary measures they have adopted and the time spent within the affected area.

g) Plant and Equipment

All plant, equipment and tools used on site must be fit-for-purpose and well maintained.

h) Welfare Facilities

Bearing in mind the likely long duration of site clearance activities adequate welfare facilities will require to be provided and serviced on a daily basis.

i) Further Guidance

Advice and guidance in the preparation of the HASP should be obtained from the Health and Safety Executive ( HSE). Reference to HSE publications, e.g. HSG 66 "Protection of Workers and the General Public during the Development of Contaminated Land", ¹⁷ will also provide helpful information in the process of developing the Health and Safety Plan ( HASP).

(f) Cordon Management

After completion of the Rescue and Assessment and Site Stabilisation stages overall responsibility for maintaining security and public safety, in relation to both the immediate affected area and any wider contaminated areas, caused, for example, by particulate falling from plumes, will rest with the Consequence Management SCG. A key priority will be the maintenance of an exclusion zone to allow access for essential personnel only and to ensure that the public are kept at a safe distance.

The level and method of the protection required at any time will depend on the nature of the contaminant and the risk it presents to the public. The nature of decontamination and remediation activities within the affected areas will also dictate security and site protection needs. It is likely that the Police will continue to perform a supporting role in maintaining the cordons and controlling public order during the site clearance activity but additional support and resources are likely to be needed from security contractors and other responders, as follows:

• contracts with fencing or hoarding contractors (e.g. suppliers of Heras Fencing or equivalent) will need to be developed, covering erection, repair and decommissioning of the cordons;
• security alarms, Perimeter Intrusion Detection Systems ( PIDS), security lighting and video detection systems may have to be considered to detect, deter and delay potential intruders to the restricted area(s);
• a pass control system may require to be implemented by the local authority;
• an adequate response force, capable of receiving, responding and dealing with security alarms and breaches may have to be established; and
• public information arrangements utilising, for example, the local media and flysheets, posters and site information boards, explaining the need and extent of the site restrictions may be required and regularly updated throughout the site clearance operations.

A high priority should be to eliminate or substantially reduce the 'hot' and 'warm' zones and achieve a progressive reduction in the size of the total cordon in the shortest possible time, taking into consideration decontamination issues.

(g) Sampling and Monitoring of Contamination

Site clearance and recovery decisions and actions must be based on a clear understanding of the risks to public health and the environment. A sampling and monitoring strategy, which identifies priorities and the types and scale of monitoring required, before, during and after site clearance, must be developed and implemented. Specialist monitoring skills and equipment will have to be resourced and secure data reporting regimes put in place.

There are a number of key requirements driving the nature and level of monitoring, as follows:

• to determine if contamination has arisen after the incident;
• to delineate the extent and nature of any contamination;
• to determine risk to human health and the environment and need for counter measures;
• to track transient changes to the area(s)/receptors affected;
• to inform and influence the clean-up and recovery strategy;
• to demonstrate that decontamination actions have achieved target levels;
• to determine if emergency countermeasures can be lifted; and
• to provide long-term reassurance.

Monitoring must be conducted in a competent manner by expert scientific staff supported by trained sampling, despatch and laboratory resources. Poor detection, sampling and analysis can give rise to ineffective decontamination processes that can, potentially, undermine the downstream management decision processes.

Ultimately, the survey and monitoring process must be both defensible and understandable to the various stakeholders and regulators and supported where considered essential by the Consequence Management SCG.

(h) Nature of CBRN Contamination

It is unlikely that the exact nature and extent of any contaminant will be known at the start of the emergency phase. A risk assessment process, including dynamic, detailed and tertiary risk assessments will be implemented by the Fire and Rescue Service, in conjunction with the Police and other specialist agencies, to improve the knowledge and underpin the strategy to be developed. Key considerations in the event of contamination include:

(i) Chemical release:

This involves the release of hazardous chemical substances into the environment (air, land or soil). Chemical agents can occur as solids, liquids, aerosols, vapours or gases depending on their innate characteristics and their environment. Many of them exert pharmacological effects, which may range from being rapid and obvious (e.g. cyanide) to insidious and/or long term (e.g. carcinogenic or genotoxic).

From the point of view of response and remediation, the key characteristics are the persistence and toxicity of the released chemical or cocktail of chemicals. Key considerations are as follows:

(ii) Biological release:

This involves release into the environment of viruses, bacteria, fungi, other micro-organisms or toxins derived from living organisms. Under appropriate circumstances they can reproduce, sometimes very rapidly, and may infect or colonise host species of plants, animals and humans. Some microbes are pathogenic, i.e. they cause disease in these hosts as a side effect of infection and some are transmissible, i.e. the microbe can pass directly from host to host causing disease as it goes.

From the point of view of response and remediation, the key characteristics are the persistence of the agent and its potential to cause disease in host populations. The potential to cause disease is complex and multi-factorial depending on the microbe's infectious dose, its virulence and transmissibility. Key considerations are as follows:

(iii) Radiological release:

This involves the release into the environment of radioactivity. There exists a wide range of radionuclides and these can differ markedly in the way in which they decay, in their behaviour in the body and the environment and in their radioactive half-life. Radioactive emissions can be divided into three types: alpha, beta and gamma and each present different risks. The health effects resulting from exposure to radiation can be considered in two categories: stochastic (i.e. relatively low exposures creating risk of health effects in later life) and deterministic (i.e. high exposures causing direct injuries including death).

From the point of view of response and remediation, international experience has demonstrated that the long-term management and rehabilitation of contaminated areas is not a narrow radiological issue that can be dealt with largely or solely by technical means. Rather, it is a broader issue of governance which must address all affected dimensions including health, environmental, economic, social, cultural, ethical, political and public expectation. The need to develop policy and broadly applicable arrangements for management and rehabilitation of contaminated areas is now recognised. The development of a coherent framework, including direct involvement of the public, specialists and local professionals, representative bodies (e.g. farmers union) will be required to achieve effective and sustainable rehabilitation of living and working conditions in contaminated areas.

The " UK Recovery Handbook for Radiation Incidents: 2005" ¹⁸ has been jointly developed by a number of government agencies to guide decision makers through the available recovery options following an incident where radioactive material is dispersed in the environment. The handbook is intended to assist organisations that would be part of the Recovery Working Group to plan the response to an incident and make decisions on recovery options in the first few months after the incident occurs. The main focus of the "handbook" is to give guidance that is relevant for an accidental release from a nuclear site or weapons transport accident. However, many recovery options will also be relevant to other radiation incidents.

SEPA is responsible under the Radioactive Substances Act 1993 (as amended) and associated Exemption Orders for regulating the keeping and use of radioactive material and the accumulation and disposal (including removal from one place to another) of radioactive waste in Scotland. SEPA does this by granting registrations and authorisations that contain limitations and conditions aimed at minimising the creation of radioactive waste and its adverse affect on human health and the environment.

The Health and Safety Executive ( HSE) is responsible under the Ionising Radiation Regulations 1999 for the regulation of exposure to ionising radiation arising from work activities. This includes the exposure of workers involved in site clearance following a CBRN incident.

The Food Standards Agency ( FSA) is responsible under the Food Standards Act 1999 for protecting public health from risks which may arise in connection with the consumption of food and, as part of this role, will implement, as necessary, restriction orders under the Food and Emergency Protection Act 1985 ( FEPA).

The Department for Transport ( DfT) is responsible under the Radioactive Material (Road Transport) Regulations 2002 for regulating the transport of radioactive material by road. This includes radioactive material being transported following a CBRN incident.

Key considerations area as follows:

(i) Remediation Options

When the nature and extent of the damage and contamination has been established a site clearance strategy will require to be developed by Site Clearance Group, with the aim of reducing the contamination to a pre-determined level that is considered reasonably practicable and meets public health and environmental safety criteria. Sampling, monitoring and prioritisation of the work activities will be a key aspect of this strategy.

The decision whether to remediate, and to what extent remediation is required, is complex and based on many factors. However, in all cases there is a need to balance the risk to society and the environment from any residual contaminant against:

• the cost, practicability and likely effectiveness of decontamination;
• the ease with which the effectiveness of decontamination can be verified;
• the human health hazards and environmental effects of the use of decontaminants;
• the human health hazards and environmental effects of site clearance;
• the resulting impact on the environment e.g. the long term impact on ground water and the potential for this to impact on human health;
• political need; and
• the views of residents and other users of the area.

In general terms, there are five main options with respect to remediation, but not all of these options are available for every site or all contaminants:

• to decontaminate the affected area and return it to its original use;
• to decontaminate the affected area and change its use to reflect the level of residual hazard;
• to change the use of the affected area to reflect the level of residual hazard posed by the contaminant;
• to seal off the area temporarily, using anti-intruder fencing or equivalent, and allow the contaminant to disperse or breakdown naturally aided by weather conditions; and
• to seal off the area permanently, taking no further action, preventing access.

(j) Decontamination

(i) General

The determination of the decontamination strategy will be undertaken by a number of agencies including the Health Board, HPS and SEPA in conjunction with the Local Authority. In planning for site clearance every effort should be made to determine decontamination end point levels and the CMSCG should seek clear advice from the STAC and the Site Clearance Group on this matter. Consideration must also be given to the potential for further spread or exposure to contamination through the implementation of any recovery option.

The extent of decontamination that is considered to be reasonably practicable will vary according to the precise situation and the value, importance and intended re-use of the site. The Government Decontamination Service ( GDS) will be available, if requested by the Local Authority, to give advice about decontamination strategy and tactics and on the availability of contractors capable of carrying out the work. Having set such levels, it is equally important that performance measures can be implemented to demonstrate that decontamination has been successful and to quantify any residual contamination across the whole site. The risk associated with any residual contamination will determine the need for further decontamination effort, the subsequent use of the area and the rate of return to use by previous owners/users of the site.

If minimum standard levels are considered not feasible, or safe levels can not been defined, a recommendation will be made by the Consequence Management SCG to the Scottish Government as to the future use of the site and the public protection measures necessary.

(ii) Inhabited Areas

Contamination in inhabited areas can create a range of complex urban remediation challenges due to its impact, or potential impact on public health, the environment, economics and its effect on nearly all sectors of the population. Inhabited areas can include a number of land use types which may form part of an affected area after a CBRN incident. Such land use types may include the following:

• residential, e.g. individual houses, housing estates and small settlements;
• service and employment, e.g. offices, shopping centres, schools and factories;
• recreational, e.g. playing fields, parks and sports facilities;
• transport, e.g. roads, pavements, car parks and railways;
• woods and forests;
• outdoor and open spaces, e.g. gardens, drives and patios; and
• the general countryside.

Each of the above land use types may be contaminated to a varying extent and a framework for assessing and making decisions on the best decontamination and recovery options should be developed by the Site Clearance Group in consultation with STAC.

(iii) Water Environment

Water bodies, including groundwater, wetlands, rivers, lochs, reservoirs, transitional waters and coastal waters, which have been contaminated as a result of a CBRN incident, must be included in any site clearance plan. SEPA will give advice and regulatory guidance on appropriate remediation measures based on the nature, scale and consequence of the pollution.

Clean surface water and contaminated waste waters must be separated, where practicable, to minimise risk of pollution and to reduce tankering and treatment costs. The disposal of contaminated water should be in accordance with the current protocol within the Water UK document entitled 'Disposal of Contaminated Water' and associated legislative control.

Contaminated surface water from the site together with waste water derived from the response activities e.g. fire-fighting, decontamination, etc., must, as far as is reasonably practicable, be contained and not allowed to drain into public or private drainage systems. In situations where the emergency services' primary concern is the immediate danger to life or public health, this issue may be regarded as being of secondary importance. However, it should be noted that a public health risk may be created if contaminated run-off water is not controlled and allowed to drain freely into local drainage systems. In addition, it may cause specific health risk to Scottish Water staff working on the sewerage system.

Run-off which escapes from the site or from the decontamination process should be assumed to be a potential source of contamination and is likely to present a risk to public health or have an adverse affect on the environment. Site flushing to sewers, culverts, watercourses or sustainable urban drainage systems should therefore be avoided. In any event SEPA and Scottish Water must be consulted to ensure that mitigation measures form an integral part of the overall impact assessment process and that appropriate control measures are implemented. Industrial and recreational users of the affected water environment, including groundwater, surface water and coastal water (including beaches), should be advised and kept informed of contaminated discharges and the likely effects on their continued use.

(iv) Soil and Land

Where the contamination of land or soil occurs, as an immediate and direct consequence of a CBRN incident, a well designed scheme to remediate the contaminated area is essential in providing confidence to all interested parties that the risks associated with soil contamination have been managed properly. Considerations must include:

• Public health;
• Public perception; and
• Public expectation.

The local authority and SEPA will work together to develop a soil remediation scheme taking account of the following three preferred routes for dealing with contaminated soil:

• Route 1: treat the soil on site

In some circumstances, it may be possible to treat the soil on site to a standard such that there is no longer a requirement for it to be removed.

• Route 2: dispose of soil at licensed waste management facility

Where it has been decided that the soil must be removed from the site because it presents a risk, it must be taken to an appropriately licensed waste management facility or approved temporary holding site. Engagement with residents in the locality of the licensed waste management facility may be appropriate as this will help address any community concerns about disposal consequences.

• Route 3: Re-use soil under exemption

In circumstances where soil is to be removed from the site because it is surplus to the regeneration of the site and does not present a risk to the environment and/or users of the site, the waste soil may be directed to an activity which is registered as exempt from waste management licensing. In particular, it should be 'disposed of without endangering human health and without risk to water, air, soil, plant or animals and without causing nuisance through noise or odours.

(v) Air

A CBRN incident and the associated response/remediation measures will have the potential to cause emissions of pollutants to air over a potentially wide area. Emissions are likely to escape from a number of pathways, including:

• through direct atmospheric deposition from an explosive device;
• where an affected process has been compromised (e.g. a secondary explosion resulting in a plume of pollutants being discharged to atmosphere);
• through fugitive emissions of pollutants released by the remediation and site clearance work (e.g. disturbance of dust and fibres); and
• from associated combustion and fires (e.g. plume of smoke being discharged to atmosphere).

In the event of any such incident, practicable control measures approved by the local authority and/or SEPA, must be implemented on site to ensure that hazardous materials are identified and contained and that adequate control measures are exercised to minimise their release to air.

(k) Waste Management

The effective waste management during the site clearance process will prove to be a complex and challenging issue for the Site Clearance Group. SEPA, as the waste regulatory authority in Scotland, will give advice to the Group on such matters.

A CBRN incident scene may include one or more of the following, all of which may be contaminated:

• building rubble;
• clinical decontamination waste;
• buildings, roads, pavements, playing fields, gardens, land, etc.;
• contaminated surface water run-off;
• a multiplicity of waste types;
• abandoned vehicles, including emergency services vehicles that may need to be recovered;
• abandoned and contaminated personal effects;
• abandoned and contaminated building contents;
• contaminated waste arising from mass decontamination activities, including disrobe packs, clothing and personal effects;
• dead birds and animals;
• food products;
• soil; and
• plants and trees.

In considering how waste controls will apply to these materials, there are likely to be two phases as follows:

Emergency phase and evidence gathering - Section 33(7) of the Environmental Protection Act 1990 provides a statutory defence for waste management activities that are undertaken in an emergency to avoid danger to human health. There are similar statutory defences for the transport and consignment of special (i.e. hazardous) waste and in relation to the requirement to use registered waste carriers in an emergency. These statutory defences only apply in circumstances where all reasonably practicable steps are taken to minimise pollution and prevent harm to human health. SEPA, in having regard to these statutory defences, would not seek to apply full statutory waste management controls to CBRN incidents during the emergency or early evidence gathering phase of the response (other than controls required for the management of radioactive substances ¹⁹). In order to ensure that pollution is avoided and/or minimised and that human health is protected, SEPA will give advice and support to ensure that good practice and duty of care principles are followed, where practicable, with respect to the transportation, handling and storage of these materials.

Post-Emergency Phase and Compliance with the Waste Controls - Once the initial emergency and evidence gathering phase is past, SEPA will expect compliance with the full statutory waste management controls. The storage and transportation of waste, which may be contaminated or otherwise, is therefore deemed to be within the scope of the waste management legislation and its regulatory regime.

It is important that the distinction between the 'Emergency Phase' and the 'Post-Emergency Phase' is understood by the Site Clearance Group and taken into account in the critical 'roadmap' for site clearance.

Underpinning Waste Management Objectives:

The main driver of waste policy in Europe and the UK, including Scotland, is the requirement to ensure that waste does not cause harm to human health or the environment. The explicit objective is to ensure that waste is recovered or disposed of without endangering human health and without using processes or methods which could harm the environment, and in particular:

• without risk to water, air, soil and plants and animals;
• without causing a nuisance through noise or odours; and
• without adversely affecting the countryside or places of special interest.

It is essential, where practicable, that hazardous and non-hazardous waste materials are segregated to enable maximum recovery and re-use. Reducing the quantity of waste can help to conserve raw materials, keep down recovery and disposal costs and reduce the demand for scarce treatment, recovery and landfill capacity.

Experience has shown that, in the event of a major incident, there is likely to be a need to identify and establish an intermediate temporary storage site, or sites, between the site of the incident and the ultimate final destination(s) of the waste. Such sites may be required to aid forensic investigation of the waste as well as sorting and sieving away from the incident scene. In some cases storage of all or part of the evidence and/or waste at the temporary site may last for months or years pending conclusion of the investigations and agreement on acceptable final disposal outlets. ^w

In planning the movement of waste, consideration needs to be given to the full range of transport options that might have to be procured and deployed. The following issues should be addressed:

• arrangements for procuring suitable containers and vehicles;
• arrangements for access, parking, fuelling and maintenance of vehicles;
• driver health and safety needs (e.g. PPE, hygiene advice, training, etc.) and the needs of others such as loaders and un-loaders;
• registrations required for carrying waste;
• loading and off-loading arrangements;
• vehicle cleaning requirements;
• legislative requirements; and
• communication strategy.

During the site clearance planning and implementation phases SEPA representatives on the Site Clearance Group will give support and advice on the complex waste management issues including waste classification, consignment documentation and duty of care obligations. It should be noted that responsibility for providing advice on the transport of radioactive material and for the regulation of the transport of radioactive material is the responsibility of the Department of Transport.

SEPA may also provide details of permitted waste disposal routes (e.g. landfill sites) and treatment facilities in Scotland and elsewhere in the UK including advice on available capacities and engineering suitability.

If a risk is identified, the public health monitoring requirements at the intermediate temporary storage site(s) and the final disposal sites(s) will be monitored by the local health authority supported by HPS.

(l) Post Site Clearance Monitoring of the Site

On completion of site clearance the local authority, will require to undertake a programme of monitoring to verify if decontamination practices have been fully effective and that end point concentrations have been achieved, and remain so over a period of time. The programme should be authorised by the Consequence Management SCG.

Analytical techniques used for verification must be sufficiently sensitive to detect residual levels of contamination. Depending on the nature of the incident, such survey programmes may be costly and extend for years after the event. However, the need for sound analytical data, corroborated independently if necessary, must be recognised as essential for the protection of public health and the environment and, importantly, to re-building confidence in the community.

THIS CHAPTER TO BE REVIEWED BY DECEMBER 2009

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