SUMMARY GUIDANCE ON
IMPLEMENTATION OF REMEDIATION PROJECTS
Version 1.1 - Aug 2014
IMPLEMENTATION OF REMEDIATION PROJECTS
This guidance addresses processes for implementation of remediation projects,
from the point of view of the implementing agent or authority. Projects will have to
be consistent with the specific procedures of national authorities and/or with donor
requirements but broadly similar approaches would generally apply to all projects.
The Note provides a possible agenda for discussions on the preparation and
implementation of the project.
KEY POINTS
Deciding on the Project Management approach is a critical early step. Once the overall
scope and scale of the remediation project is agreed, a decision has to be made on
whether the project will be implemented with the team's own resources or will be
contracted out. The choice of approach determines the skills and resources needed
within the project management team.
Planning to address the site requires:
Definition of the nature and extent of contamination (remedial investigation)
Identification and evaluation of practical remediation options (feasibility study)
Development of a workplan
Preparation of a long-term stewardship plan
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Preparation for remediation, once the overall workplan has been agreed, should cover:
Ensuring ongoing local involvement
Clear responsibilities and lines of communication
Agreement on specific remediation project objectives
Confirmation of funding and completion of contracting
Confirmation of legal and regulatory clearances
Definition of implementation, oversight and close-out procedures
Agreement on project action plan for all involved parties
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Execution of the remediation covers the core physical works which deal with the
contamination and which restore or secure the site in order to achieve the agreed
remediation objectives. Key steps in this would include:
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Possession of the site and containment and/or preparatory works as required
Preparation of any on- or off-site storage/disposal facilities
Initial/urgent engineering works
Further technical investigations as needed
Implementation in stages, as appropriate
Documentation of work completed
GAHP Guidance Notes provide information on international good practices and regulations in remediation.
They are prepared to assist GAHP members in dealing with practical problems of remediation of polluted sites
and are intended to assist readers to identify key points that should be taken into account in reviewing or
approving any proposal. Guidance notes reflect the views of individual GAHP specialists and of invited outside
experts and do not necessarily represent the views of any specific government or agency. Additional
background and material may be found on the GAPH website.
IMPLEMENTATION OF REMEDIATION PROJECTS
Version 1.1 - Aug 2014
INTRODUCTION AND SCOPE
This Guidance is designed primarily to support discussions with the key people responsible for preparing and
implementing a contaminated site remediation project, in a context where administrative procedures and
specific technical requirements are not well defined. These people may be local authority or government
officials, community or NGO leaders, or other institutions or organisations (public or private) who have
committed to practical actions to address a problem site.
This note provides a possible agenda for discussions between the project team leadership and responsible
authorities, financing agencies and representatives of local bodies. It is not a comprehensive
implementation manual.
It is assumed that the site in question has been identified as contaminated to an unacceptable level and that
decisions have been taken that the site is a priority for remediation. (Separate guidance is provided on
identification and prioritisation of contaminated sites.)
DECIDING THE PROJECT MANAGEMENT APPROACH
Implementation of the project will be strongly affected by the number of different parties and organisations
involved and by the existing relationships between them. A mapping of relevant and interested parties
should be made at an early stage. Apart from those directly engaged in design and implementation,
aspects such as access, approvals, clearances, community engagement, etc may all require different parties
to be involved. Larger projects, particularly those involving public funding, will probably require formalised
and documented implementation agreements with key parties.
The financial resources available will clearly have a major bearing on design and implementation options.
It is usually necessary to work within a tight budget and to achieve the highest level of remediation possible
with a constrained budget. Decisions have to be made and agreed about the scope of the project and the
type of interventions. For example, whether the project can address all the problems across the site and
achieve complete remediation, or whether it will be focused on isolating/resolving the worst areas and
providing an interim remedial solution. Agreement on acceptable interim remedial measures may be an
effective way to achieve significant and important improvements in the first phase of interventions. At this
point, it will normally be possible to clarify the practical technologies that may be applicable and to identify a
shortlist of possible remediation schemes.
Decisions also have to be made on broader interventions which will accompany the physical site works,
such as community education campaigns, health interventions, enforcement/support in relation to polluting
activities, capacity building etc. All of these should be targeted at supporting the long term objective of
protecting and improving community health and the local environment.
Select the project management structure. Once the overall scope and scale of the interventions have
been agreed, the fundamental strategic choice is between carrying out the physical work with the lead
agency's own resources or using a contract approach. This will depend not only on the resources and
skills available but also on the sources of funding and any institutional requirements that may accompany
these.
Implementation with own resources may be preferable if:
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The implementing team and local partners have relevant technical experience and access to
equipment.
The remediation approach is simple and straightforward.
The funding is available and adequate
There is strong local support and no identified bureaucratic or political obstacles
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Contracting out the main implementation activities is likely to be appropriate if:
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The lead agency is a government entity whose standard practices include contracting of technical
works
Key funders such as government agencies and international donors have procurement rules which
require competitive bidding.
The remediation requires advanced approaches for investigations or implementation, for which
outside technical expertise is required
The amount of the funding or the scale of the works requires the transparency which contracting can
bring.
Even in a contracted out approach, there will be important components of the overall remediation process
which remain to be carried out by the project team.
A critical consequence of this, which is not always recognised, is that when the works are contracted the
skills required of the overall implementing body must relate to tendering procedures and contractual
management rather than technical implementation. However, the project team should also have relevant
technical expertise to ensure adequate oversight of the contractor. This note does not address these skills.
This guidance note addresses the key steps in planning and executing a remediation project. These steps
are generally common to both own-managed and contracted approaches although the details will vary from
project to project.
PLANNING TO ADDRESS THE SITE
Once the overall implementation approach is determined, then the necessary structures and personnel need
to be put in place, with the necessary authority to make the relevant decisions. A named Project Manager
should be appointed to carry out the routine processing of project preparation, reporting as appropriate to a
Steering Committee and/or a Stakeholder Group. Implementation of physical remediation works would
include the following steps.
Define the nature and extent of contamination. The initial site screening will already have set out the
broad characteristics of the site(s) and the identifiable impacts. This screening includes establishing a
Conceptual Site Model (CSM) which identifies the sources, pathway and people potentially impacted. The
CSM provides the basis for the initial risk assessment, which allows the site to be ranked against others in
terms of priority for intervention.
At this project preparation stage, the initial information should be reviewed, gaps in data or understanding
identified, and further site specific investigations and tests carried out as required to refine the CSM. A walkover of the site and surrounding areas by an experienced specialist will provide additional information and
confirmation of key factors. The availability of on-line geographical and mapping tools means that a
reasonably accurate base map can be prepared for most sites with limited resources. Hand-held GPS allows
key features on the ground to be located to within a few metres. Simple field testing is adequate for defining
bounds for areas of high pollution (with some check samples being tested in local laboratories). Sites with
groundwater contamination will require that test wells be installed and sampled. Technical support from
qualified professionals is usually necessary and often available through the relevant government agencies or
local technical or scientific institutes.
On the basis of this information, the sources and pathways are better defined and a more detailed risk
assessment should be carried out. This risk assessment will provide the basis for discussion and agreement
of relevant standards and targets. In terms of the immediate intervention to reduce immediate health risks or
acute environmental damage, interim levels may be appropriate to use if achievement of desirable long term
levels requires resources which realistically are not available in the short term.
Identify, evaluate and select remedial options. The initial assessment of the site and discussions over
the scope of the project and the funding required/available will normally have identified a small number of
technical approaches which could be practical and affordable at the specific site. Key parameters governing
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selection of plausible options are the size, location and other physical characteristics of the site, and the
financial and human resources available. Other important factors that need to be taken into account are the
potential values and use of the site, the biodegradablity or the persistence of the main pollutants, and
whether transport off site, especially via groundwater, is a major issue. (Separate guidance on remediation
technology is being prepared.)
At this stage, the acceptable technical approaches have to be refined and agreed. Relevant technical
expertise will be required to support this identification of technical preferences but extensive studies are not
always necessary in order to take initial action to deal with urgent problems. The level of detail required for
the technical documentation at this stage depends greatly on the implementation approach adopted.
For a small and simple project led by an experienced project manager, it may be sufficient to have a good
estimate of the quantities/scale involved and confirmation of the availability and costs of the necessary
equipment. For a large complex project, which is to be contracted out to qualified and experienced firms, the
relevant approach may be to set out realistic performance criteria to be achieved and to leave the details to
be proposed and agreed during the contracting process. A mid-scale project is likely to be the most
complicated to implement if it requires the technical details to be worked out in advance, in a way which can
be implemented by contractors who may have limited relevant experience. In this case, specialist technical
advice will be required during the preparation and contracting process.
In many cases, collection and removal from the site of highly contaminated material may be an option but
this will often be constrained by the availability and cost of approved secure disposal facilities. Investigation
of the feasibility and cost of using existing approved facilities is often an important early step in consideration
of technical options.
Develop the work plan. Once the overall approach and the management structure have been determined,
a work plan needs to be developed. The work plan is a clear, time-bound summary of the actions required
by each party for the successful remediation of the site. It will focus on the physical actions which are the
core of a remediation intervention but must also address related institutional controls and social mobilisation
actions which may be part of the overall solution. To the extent that there is a specific health intervention
included in the overall process, this should also be included in the plan, with the necessary coordination
clearly defined.
Prepare a long-term stewardship plan. In conjunction with the work plan for the remediation project, a
long term strategy and plan should be prepared and agreed for the control and maintenance of the site going
forward (at whatever level is appropriate). This should set out the responsibilities and the resources
required (and available) to ensure that the benefits of remediation are sustained in the long run.
Where related environmental management controls on industry or artisanal activity are required to ensure
that the contamination does not re-occur, the necessary commitments and resources from the relevant
authorities need to be put in place, as part of this remediation project.
PREPARATION FOR REMEDIATION
Ensure effective local involvement. Remediation projects under GAHP are targeted at serious urgent
problems, where immediate action is justified. The urgency must be confirmed by evidence of real risk and
by a local constituency for the intervention. There may be objections or resistance to the project and these
must be clarified and addressed through a broad based committee, stakeholder group or similar mechanism.
This may be a formal structure, such as a committee established by the authorities or it may be an ad-hoc
group set-up to help address the specific problem.
This has to be more than just a consultation process. It needs to involve the various groups who can
influence decisions and undertake specific actions, in support of the agreed objectives. The committee
should typically comprise representatives of local authorities and community groups, the agencies
responsible for different aspects, the business community, technical institutions with capabilities relevant to
the project, and any national authorities which have relevant authority or jurisdiction over the problem.
There must be a strong facilitator – preferably a “champion” who is recognized as a fair proponent of finding
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practical solutions. The role of the group is to implement an effective solution. It may begin with
recriminations but the mandate of the facilitator is to move the participants to agreement on what each can
do to support a practical resolution.
Reach agreement on remediation priorities: The Project Manager, working with the committee, must
begin by generating agreement on the priorities for the present phase of remediation process. This will be
based on the updated investigation and information on the site and the resources available.
Set project specific remediation objectives and design the intervention. Specific, monitorable
remediation design objectives should be developed and agreed for the project. There may be a wide range
of different perceptions of problems, risk and solutions. It is important at this stage to reach agreement on
immediate objectives and on the timeframe and process to be used in achieving those objectives. This will
often be focused on removing a specific perceived health or environment threat or on securing/improving a
particular site. Depending on the scale of the problem and the resources available, it may not be realistic to
plan for full remediation of all the site(s) in the first project and it may be necessary to set achievable interim
remediation objectives. In that case, the interim nature of the outcomes must be made clear and a strategy
must be set out for moving towards full remediation. The timeframe for reaching remediation objectives
should be realistic, taking into account downtime due to weather, equipment breakdown, and unforeseen
conditions such as discovery of unknown hazards.
There will inevitably be some gaps in the data available for a legacy site. Polluters are inherently unwilling to
measure and report levels of contamination. Impacts on health or on the environment are difficult to
measure directly and so appropriate proxy measures (such as levels of exposure or contamination) are
used. In the absence of “scientific proof” of cause and effect, the approach adopted for the remediation is
that of risk assessment. It is important that this approach be spelt out clearly and be accepted by all the
stakeholders. It cannot be guaranteed that no possible risk will remain after initial remediation, but it should
be emphasized that the intervention will reduce the risk significantly.
In circumstances where there are a number of sites to be addressed or where there are other strong directly
competing priorities, it will be important to have a clear and documented decision to proceed, setting out
objectives, constraints and resources committed or anticipated for the implementation. If implementation of
the works is subject to certain decisions and/or availability of financial or other resources, then these caveats
should be noted and monitored.
Longer term aims, such as redevelopment or complete remediation, can be discussed in parallel but lack of
consensus on these aims should not be a reason for delaying necessary short term interventions. Further
work required to complete full remediation can be outlined and a broad strategy agreed for moving forward to
achieve this.
Confirm financing. The project will not have progressed to this implementation stage without agreement
having been reached on the sources and scale of funding for both the preparation and the implementation.
However, there are often difficulties and delays in the actual provision of agreed financing and it is a critical
task for the project manager to confirm the availability of the funds and to adjust the project plans for any
shortfalls or increases. Adjustments to the project plans resulting from shortfalls should be communicated to
the stakeholders so expectations established earlier can be downgraded to match actual outcome.
(Options for FINANCING REMEDIATION are discussed in separate guidance.)
Define implementation and oversight procedures. The physical clean-up of the sites(s) must be
implemented under clear and open process and procedures; the works must be carried out in an efficient
and equitable way; and the results must be demonstrated to achieve the specified design objectives. The
procurement and financial management systems used will vary with the scale of the project and the
institutional context but whatever system is used should meet these criteria.
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Establish clear process and procedures and apply these in an open manner.
Select the contracting process to balance efficient use of resources with high levels of local and
appropriate inputs. Provision of resources directly to the project by those responsible for the
pollution is encouraged.
Supervise the implementation at the appropriate level of detail. On-site quality control is often the
best way to ensure efficient and effective remediation works.
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Monitor and report on the parameters established in under the design objectives and provide
commentary on the achievement of the objectives
Require a project completion report summarising the aims, activities and outcomes
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Obtain legal and regulatory clearances. Remediation activities, even if undertaken for worthy health and
environmental reasons, still need to satisfy, or to be exempted from, the necessary legal and regulatory
requirements. Delays in implementation can be caused by failure to deal with issues such as access rights,
formal environmental approvals, hazardous materials regulations, statutory planning consents and so on. If
the site or the pollution caused is the subject of legal proceedings, then any consequences for those
proceedings of starting remediation needs to be assessed and addressed as necessary. One task in the
initial preparation should therefore be to determine all relevant legal considerations and to ensure that
necessary notifications, waivers and/or approvals are all in hand.
Agree specific priority actions. Effective remediation will involve the participation and cooperation of a
number of the parties involved and therefore agreement on an action plan will require discussion and
negotiation. The technical team should provide clear options for consideration, including estimates of cost
effectiveness.
However, the final plan must be broadly accepted and cooperative if it is going to be
implemented successfully. This is a key role for the project committee, where the pros and cons of the
different options should be discussed, and their implications in terms of risk and costs for each party clearly
understood.
EXECUTION OF REMEDIATION
Once the remediation process has been defined and started, the full scale implementation can then be put in
process. This note cannot address all of the many aspects of an implementation project but points to be
taken into consideration include:
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Possession of the site
Define “hot spot” or high priority areas within in the site
Preparation of any on- or off-site storage/disposal facilities
Community education and health monitoring, as appropriate
Preparatory and urgent engineering works as required
Further technical investigations if needed
Implementation in stages, as appropriate
Documentation of work completed
Long term social or health monitoring programmes
Final review/acceptance of site and implementation of monitoring
Possession of the site. An immediate first step will often be to gain access to and possession of the site.
Even if access has been provided for investigations, it is important to ensure that there is practical access
and no objections to occupation of the site for remediation activities. Requirements for access and egress of
heavy machinery and loaded vehicles must be decided and agreed with local residents who may be affected.
If the area to be remediated is part of a larger site, then the working area needs to be clearly delineated and
access restricted. Ideally some form of fencing would be used to control movement onto or across the site.
Security, either through physical measures or provision of guards, is likely to be necessary if equipment and
fuel are stored on site. This will normally be the responsibility of the contractor.
Confirm or define “hot spot” areas. Once the site is available, the areas of high level contamination
which are the priority for remediation should be confirmed or defined and marked out. Initial understanding
of locations, depths and quantities can be refined and any necessary adjustments made to the working plan.
Even with good site investigation, it is unlikely that all the details of the contamination will have been
identified.
Some areas may be designated for different remedial actions (for example some areas may be treated insitu while others are excavated) and these different areas should be clearly marked out.
Preparation of disposal facilities. Preparation of disposal facilities, particularly if these are off-site, should
be commenced as early as possible, in order to confirm feasibility and to identify any unforeseen constraints
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or difficulties. Fencing and control of an off-site disposal area should be carried out in a similar manner to
the main remediation site.
Community education and health monitoring. Where education or health campaigns are part of the
overall set of interventions, it may be effective to launch these at around the same time as the physical
works, in order to take advantage of local interest and publicity. Public information processes may also
usefully be launched at this point in order to gain additional support for the interventions and to reduce
concerns about any inconvenience caused during the construction work.
Preparatory or urgent engineering works. Once the site is secured, the first stages of engineering works
can be commenced. These could include upgrading access and clearing the site. At this point, any urgent
engineering work should be done, such as securing derelict buildings and making safe any unstable slopes,
ponds holes etc. At this initial phase, only experienced staff and contractors should be working on the site.
Further technical investigations as needed. Once the site is contained and secure, it will be possible to
carry out any additional technical investigations that have been identified as necessary. These are likely to
include investigations which require mechanical equipment, such as trial pits or boreholes.
If the initial site review after taking possession has identified important differences from the earlier
investigations and understanding, then a considered decision should be made as to that further site
investigation would be justified, in terms of overall cost management, as opposed to continuing with the
original plan and accepting the need for some additional works.
Implementation in stages, as appropriate. Implementation of the project should follow the defined
contractual approach and the agreed programme of work.
In cases where the precise extent of the
contamination across the site cannot be determined or where there are a number of different areas of
contamination, the work should be planned and implemented in stages, allowing for checking of each area
as completed.
Finishing up of details is always a challenge and therefore time and resources must be allowed to ensure
that the work is fully completed as planned.
Documentation of work as completed. Good records should be kept during implementation of samples
taken, contaminated material removed, and new fill or construction. All of the records should be carefully
geo-referenced and must be completed and checked at the end of implementation.
In particular, any areas which were not fully remediated or which have been identified for future additional
remediation works must be surveyed, marked and recorded in an agreed fashion.
Long term social or health monitoring programmes. Completion of the physical works is often not the
end of the remediation intervention. Any associated social programmes or health monitoring systems should
be put in place before the project is closed. In particular, any institutional measures which are relevant to the
long term security and success of the remediation, such as controls over access or use of land, must be put
in place.
Final review and acceptance of site and implementation of monitoring. At the end of the physical
works, after any outstanding "snags" have been identified and resolved, there should be a formal process of
reviewing the implementation against the contractual commitments and against the overall objectives. Any
off-site works - particularly any off-site disposal facility - must be also be reviewed, documented and signed
off as part of the completion of the remediation.
Any remaining issues which need to be resolved, especially those relating to the future use and
management of the site, must be discussed with the relevant parties and the responsible authorities.
Decisions and agreements should be recorded. All relevant site documentation and contractual records
must be copied as needed and carefully archived with the respective parties.
A final step in acceptance is to test the monitoring system (both hardware and procedures) and to formally
hand over responsibility to the party assigned.
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