Template for comments and secretariat observations
Document: DPC - BS 10175:2001 Revision -
Date: August 2010
Solihull DPC Event Collated Comments
2
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Clause No./
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Introduction
Pg2
item a)
ge
Bring in line with CLR11 terminology & add for clarity
Introduction
Pg 2
3rd
Paragraph
Ge
Bring in line with CLR11 terminology & add for clarity
Introduction
Pg3
2nd Para
ed
Reads clearer
The conceptual model is first formulated through
means of by the Phase 1 investigation (desk
study), which focuses subsequent investigations, if
these are necessary, to meet the objectives of the
overall investigation.
Section 1
Pg3
2nd Para
te
Best practice guidance (CIRIA C682) distinguishes
between ground gas (i.e. bulk gases) and VOCs in soil
gases (i.e. VOCS)
In order to obtain scientifically robust data on soil,
groundwater, surface water and ground gas and/or
VOCs in soil gases.
3.1 Accuracy
Pg4
1st para
ed
Grammar
lLevel of agreement between true value and
observed value
3.2
Conceptual
Model
Pg5
1st para
te
Best practice guidance (CIRIA C682) distinguishes
between ground gas (i.e. bulk gases) and VOCs in soil
gases (i.e. VOCS)
characteristics of a site that are relevant to the
occurrence and potential effects of ground
contamination, usually presented in a textual
and/or diagrammatic form that describes the
nature and sources of contamination; the ground,
groundwater, ground gases & VOC in soil gases
that could be present; the environmental setting;
potential migration pathways; and potential
receptors
3.5 harm
Pg5
1st para
ge
To provide clarity that property does not explicitly just
mean buildings
adverse effect on the health of living organisms, or
other interference with ecological systems of which
they form part, and, in the case of humans,
property (e.g. buildings, live stock, crops)
details of the historical uses of the site and the
potential for the presence of contaminants; (the
potential source)
The results of the investigation delineate all known
aspects of the site that could impinge upon or
affect contaminant-pathway-receptor (pollutant
linkage) scenarios, which are defined within the
conceptual model.
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Template for comments and secretariat observations
Document: DPC - BS 10175:2001 Revision -
Date: August 2010
Solihull DPC Event Collated Comments
2
(3)
4
5
(6)
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7.6.2.7 Sampling
depths
Pg26
4th para
Note 1
te
Users should be made aware that choice/selection of field
screening tools requires careful consideration. Often
requiring calibration using conventional laboratory
methods & appropriate training on their use/limitations
before site use. Perhaps make reference to 8.4 & Annex
G more explicit
The use of on-site testing or detectors (such as
photo ionization detectors (PIDs) detect volatile
organic compounds) (see 8.4) can aid the
determination of sampling depths. However users
should ensure that field screening tools are
suitable for purpose & may need to first calibrate
results using conventional laboratory testing
before reliance
7.6.3.1.1
General
Pg27
1st Para
te
Water samples ideally should not be collected until the
well is developed to ensure that additives (water flush)
added during the drill propose or any debris that may
have entered has been removed following development
7.6.4.2.1 Sampling
Strategy
Pg31
Last Para in
this section
te
VOCs in soil gases may require specific installations to
which the generic 50mm BH does not provide. (I.e.
special materials, narrow wells/implants). It is believed
that the energy institute is generating guidance on this &
the subject is discussed in CIRIA C682
It is not best practice to obtain water samples for
chemical testing during the drilling of boreholes for
the same reason. Where a borehole intersects the
water table a sample should be obtained from a
monitoring well installed after the completion of
drilling (see 8.3.3.2) & well development?
Investigations for gases derived from the
decomposition of organic matter generally use
monitoring wells to enable on-site monitoring with
portable instruments and the collection of samples
for laboratory analysis (see 8.3.4). (Soil vapour
monitoring
points
may
require
specific
installations)
7.6.4.2.2
Methods of soil
gas examination
Pg31
1st Para
te
The document states that off site analysis should include
parameters not determined on site such as nitrogen &
hydrogen. DO labs really test nitrogen or is it really a
mathematical subtraction equation (i.e. what’s left is
reported as nitrogen)
Where non-specific detectors are used
monitoring indicates elevated concentrations,
data should be confirmed by off-site analysis.
off-site analysis should include parameters
determined on-site, such as nitrogen
hydrogen.
7.6.4.2.2
Methods of soil
gas examination
Pg 31
3rd Para
ge
It is important to point out that the users of on site
monitoring equipment should ensure that monitors are fit
for purpose (i.e. PIDS often do not help with extremely
toxic VOCs I.e. its detection limit is not good enough), For
other monitors some are not intrinsically safe, some do
not work in oxygen deficient samples etc…
Portable instruments are used…..…. e.g. flame
ionization detectors (FID) or photo-ionization
detectors (PID), However users should ensure that
monitoring equipment is suitable for purpose,
capable of achieving suitable detection limits and
suitable in atmospheres being tested
or
site
The
not
and
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CEN electronic balloting commenting template/version 2001-10
Template for comments and secretariat observations
Document: DPC - BS 10175:2001 Revision -
Date: August 2010
Solihull DPC Event Collated Comments
2
(3)
4
5
(6)
(7)
Clause No./
Subclause No./
Annex
(e.g. 3.1)
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Commentary on
7.6.4.2.4
Pg 32
4th Para
ge
Suggested added text for clarity
Suggested monitoring periods and frequency of
monitoring can be found in C665 [45]. The
suggested monitoring periods and frequency of
monitoring are dependent on the generation
potential of the ground gas source and the
sensitivity of the development. But should
inevitably by governed by the Conceptual Site
Model
Commentary on
7.6.4.2.4
Pg32
5th Para
te
Ground sealing is often the biggest factor in gas
emissions. See CIRIA 665. Important to include this
statement
Monitoring during a period of sharply falling
atmospheric pressure is considered to be of
importance in relation to potential gas emissions,
together with events of potential ground sealing
(water pooling at surface).
7.6.4.3.2 Methods
of soil gas
examination for
VOCS
Pg33
1st Para
te
Similar to earlier comments
It is important to point out that the users of on site
monitoring equipment should ensure that monitors are fit
for purpose (i.e. PIDS may require specific lamps to
measure certain VOC species or may not help with
extremely toxic VOCs (I.e. its detection limit is not good
enough),
Sample collection may be undertaken using
pumps to collect gas within gas containers or onto
sorbent material to enable laboratory identification
and analysis.
Alternatively, semi-quantitative
screening may be undertaken, for example, using
photo-ionization detectors (PIDs) or flame
ionization detectors (FID). In-situ testing is also
available to provide real time data during probing.
It is however important to ensure that the
instruments are capable of monitoring for the
species of VOC suspected.
7.8.1 General
Pg 34
Item a)
ge
More clarity is required on this state. What does it mean
or what is required?
QA/QC procedures…….and should take into
consideration the following:
a) the qualifications and experience of personnel
carrying
out
the
work
(particularly
investigators);
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Document: DPC - BS 10175:2001 Revision -
Date: August 2010
Solihull DPC Event Collated Comments
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(3)
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(6)
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8.3.4 Gas
Samples
Pg54
4th Para
ge
The reader should be made aware that gas sampling can
be a specialised area. For example certain vessels for
gas monitoring are commonly re-used & may need to pre
purging (by the lab) or in the field before capturing the
sample, flow rates for pumps often require specific
calibration & so on
A cautionary note is worth adding. See suggested text
Samples of soil gas for analysis for permanent
gases (for example, methane, oxygen or carbon
dioxide) should be transferred to a pressurized
metal cylinder (for example, stainless steel or
aluminium) using hand pumps. Equipment for this
purpose is often quite specialised & requirements
should be clearly understood & necessary advice
on sampling requirements obtained before use
8.6 Sample
labelling,
preservation &
handling
Additional
NOTE:
ge
Additional cautionary note warranted on possibly
shipping/transportation requirements for certain
substances
(flammables, Asbestos, radioactive, biological, corrosive
etc)
Additional Note: Certain sample types require
certain permits and/or packaging rules.
For
example samples suspected of radioactive
hazards or asbestos etc.
8.7 Sampling
Report
Pg 54
2nd Para
ed
Possible Correction
This section mentions BS5930. Should this also mention
ISO EN 14688???
The ground strata should be logged on-site during
the formation ……. recording the strata should
conform to the categories used in, BS5930 or ISO
EN 14688…….. Descriptions of made ground
should be formed in accordance with BS5930 or
ISO EN 14688, 41.4.5.
9.5.1 Soil Samples
Pg58
5th Para
ge
Suggestion: Could a table be provided on max holding
times & ideal testing times for critical determinands in an
Annex?
When the sample is unstable and cannot readily
be stabilized, preparation and analysis should be
carried out as soon after collection as possible.
9.5.2 Water
samples
Pg59
1st para
te
Is it always Nitric Acid?
The need for physical pre-treatment prior to
analysis is dependent on the nature of the sample
and the purpose of the analysis; for example, for
the determination of metals in solution, filtration is
necessary typically using a 0.45 µm filter. This
should be carried out on-site, followed by
acidification of the filtrate with nitric acid with
appropriate fixing agent.
Are not some determinands best fixed with other fixing
agents? Also sometimes is fixing/filtering best done
by lab under certain circumstances?
Annex
Example 1
te
RSK has concerns thay grid spacing used within the
example 1is or may be construed as the 'gold standard'
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Template for comments and secretariat observations
Document: DPC - BS 10175:2001 Revision -
Date: August 2010
Solihull DPC Event Collated Comments
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(3)
4
5
(6)
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A
by regulators.
The same goes for 7.6.2.5 - sampling density is too
prescriptive.
1
Annex G1
Pg81
ge
Can the document make it more explicit for the
need to calibrate on site testing data with lab data
etc?
4.1 General
Pg8
Under Note
ge
Under new developments the approved building control
inspector has responsibilities under Part C of the Building
Regs to ensure H&S of the users of the
premises/building. The approved inspector should also be
included in the list of persons who should be consulted.
When the investigation is carried out in connection
with a planning application……., the resulting
report will be submitted to the local authority’s
planning department and/or contaminated land
officer (CLO) acting as the primary regulator in the
context of the planning process. The approved BC
inspector should also be consulted, where
relevant. In these situations, early consultation
with the CLO and/or approved BC inspector
(where relevant) is recommended to ensure that
the detailed investigation strategy is considered
adequate to satisfy the needs of the regulator in
the process of risk assessment
Sampling
ADDITION
ge
There is no guidance provided with respect to sampling
strategies for stockpiles, heaps, mounds, embankments.
This is a common occurrence on Brownfield Sites & UK
guidance is noticeably absent. THIS IS AN AREA THAT
IS DESPARATELY NEEDED
Add section in document
ge
The standard should be more in line with CLRII i.e.
preliminary risk assessment includes outline e.g. point xi
is all of i-xiv.
Reporting
Investigation
I fully agree with the 'Phase' approach to the terminology a much better approach than at present. However, for
One solution to resolve this could be a slight
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many (smaller) sites, I consider there would be no phase
2 investigation and hence after Phase 1 you would go
straight to Phase 3. This is likely to cause confusion and,
no matter what is written in the introduction of the Phase
3 report, a hunt for a non-existent Phase 2 report. One
solution to resolve this could be a slight rewording of the
terminology. Please see 'proposed change by the MB'
column'.
rewording of the terminology, as follows:
- Desk Study and site reconnaissance = Phase 1
Appraisal (not investigation) - given that no
physical investigation of the site is undertaken at
this stage. Only an appraisal of the desk study
info, etc. is undertaken.
- Exploratory investigation (Phase 2 of the revised
draft BS 10175) = Phase 1 Investigation.
- Main investigation = Phase 2 investigation, and
so on. Using this terminology, a Phase 1 appraisal
could be followed by a Phase 2 investigation with
no confusion.
Investigation
Table 1 &
Clause 5.6
Investigation
Investigation
Clause 5.3,
Para 2
te
Table 1 and Clause 5.6 lumps verification/validation
sampling and testing in with supplementary
investigations. I disagree with this. Supplementary
investigations are undertaken prior to development, to
clarify conceptual models, remedial strategies etc.
However, verification and validation are undertaken
during/after development and after agreement of the
conceptual model with regulators etc.
te
Should it be suggested that for each phase, additional
investigations could be undertaken, eg. Phase 2a, Phase
2b etc.
te
Clause 5.3, para 2 infers that a site reconnaissance is not
always needed. I believe that a reconnaissance of the site
and surrounding area by an experienced practitioner (and
not a junior) is a crucial element to any good
investigation. Therefore the BS should strongly
recommend a site reconnaissance as good practice. I
I suggest that Supplementary Investigations
should be Phase 3 Investigations (please see my
previous point above), with verification and
validation sampling and testing as Phase 4
Investigations.
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Date: August 2010
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understand that this is not always possible, for good
reasons, but it should clearly be recommended. If a site
reconnaissance is not undertaken, this should be stated
and an explanation given for digressing from 'good
practice'.
Investigation
te
Is the list in Clause 6.2.1.2.3 supposed to be exhaustive
or just examples (if the latter, this should be stated)?
Important sources omitted include services info (which
can provide hydrological/gas migration pathways), mine
entries (ditto), geological memoirs and Aquifer Properties
manuals.
Investigation
te
The draft BS formalises the Phased approach to
contaminated site investigation. Table 6 lists and
describes ground investigation techniques however this
could be expanded, based on the
benefits/application/cost of each technique, to describe
the most appropriate use within the phased approach. Insitu techniques, for example those related to CPT
investigation, are ideally suited to both Phase 2
exploratory investigation using a grid based sampling
strategy, or a Phase 4 supplementary investigation to
delineate the extent of a contamination plume. This
should be stated with examples given.
The CPT cone has been combined with several screening
sensors to provide a combined with several screening
sensors to provide a combination of detailed lithological
information of subsurface soils and to detect the majority
of organic compounds.
The main screening sensors attached to the CPT cone
are:
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CEN electronic balloting commenting template/version 2001-10
Template for comments and secretariat observations
Document: DPC - BS 10175:2001 Revision -
Date: August 2010
Solihull DPC Event Collated Comments
2
(3)
4
5
(6)
(7)
Clause No./
Subclause No./
Annex
(e.g. 3.1)
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MIP-CPT - MIP (Membrane Interface Probe) is used for
the in-situ screening of CHC and VOC in both the
saturated and vadose zone.
ROST-CPT - The ROST (Rapid Optical Screening Tool)
is used as an in-situ tool for screening of hydro carbon
derived contamination in soil and ground water.
Both the above probes are in regular use in many
countries and have Standard Practiced Designations from
ASTM, D 7352-07 and D 6187-97 respectively.
In addition an XRF-CPT sensor has been designed and
manufactured for the real time measurement of heavy
metals in the subsurface. This sensor is presently
undergoing field trials and is expected to be operational in
early 2011.
Fieldwork
Fieldwork
Table 6, 7 &
8
ge
The BS should make it clear that gas spikes are fine as
part of the Phase 1 exploratory investigation (see above),
but should never be used on their own as part of the
Phase 2 main investigation. More rigorous and longer
term monitoring is required if a risk assessment is to be
undertaken.
te
From a contractor's viewpoint Tables 6, 7 and 8 would
benefit from an assessment of the specific time
constraints of each technique e.g. progress through
common geologies. This would aid consultants/clients to
better judge the on-site progress of investigations and
plan works accordingly in advance. The current
assessment using words of generic words such as 'slow'
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Template for comments and secretariat observations
Document: DPC - BS 10175:2001 Revision -
Date: August 2010
Solihull DPC Event Collated Comments
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(3)
4
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(6)
(7)
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Subclause No./
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(e.g. 3.1)
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or 'rapid' is inappropriate as it will bias certain techniques
for consideration at different stages of investigation. As a
contractor we also believe that developments in health
and safety requirements and considerations for certain
techniques such as trial pitting (entering pits? Shoring?)
need to be specifically assessed in these tables.
Sampling and
analysis
ge
Recommendations are provided in the BS for sampling
frequencies for main investigations. However, no
recommendations for sampling frequency are given for
verification/validation works. I appreciate that this can be
site specific sometimes, but guidelines could be given for
this.
te
As a contractor and consultancy Fugro notes that when
operating as contractor; often unsuitable periods of time
will pass between sample collection and scheduling by a
supervising engineer (consultant). This may in extreme
cases extend to over a month with the sample-on-hold at
an analytical lab. Without instruction for stabilisation this
is unsuitable and, specifically in the case of organic
determinants, results in bias results. The draft BS, whilst
stating on pp 61 that samples must be transported to the
analytical lab as quickly as possible, does not go so far as
to place time constraints on testing. In this way the
document does not truly reflect the current approach of
the industry in terms of consultant-contractor relationship.
Reporting
te
Interpretive reports should include statistical analysis of
test results (in an annex) where appropriate along with an
explanation of the risk assessment rationale. I have found
that the inclusion of sensitivity analyses in separate
sections/annexes is also useful for many investigations.
Reporting
te
Limitations in the investigation and data should be clearly
stated in a separate section.
Sampling and
analysis
pp.64
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ge
There is some inconsistency in the definition of
'contamination' with respect to natural contaminants. Note
2 in Clause 3.3 suggests that 'naturally enhanced
concentrations of harmful substances'[ is contamination.
However, Clause 4.1 (para 2) and Clause 5.2 (para 1)
suggest it is different to 'man-made contamination'. This
could cause confusion.
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