Points to be raised by SCEPP at the ACTLG on 20 January 2010

1. Arrangements for Operational Site Safety

1.1. What are the arrangements for the Site Safety Team?
1.2. Is Health & Safety a department in its own right or is it part of the Site Safety
Team?
1.3. Who is the named person responsible for managing deviations from the safety plan
and the environmental quality plan?
1.4. Why is there no provision for the Site Safety Team to include appropriately
qualified chemists?
1.5. What are Entec’s capabilities in the relevant toxicology?
1.6. What are the arrangements of external, independent monitoring of safety and
quality assurance on the site?

2. Air and Ground Quality Monitoring

2.1. May we see the current plan for the location and type of air quality monitoring
stations?
2.2. How will the air quality readings be analysed? Are the levels monitored
continuously or at intervals? Will the monitoring of readings take place on or off
site? We are concerned that short-lived but nonetheless hazardous peaks in
contaminant levels will be concealed within the averaging of levels over longer
reporting periods.
2.3. What are the procedures for reacting to peaks in the levels of hazardous
contaminants?
2.4. If chemical samples are not analysed on site, what will be the response time for
analysis and how will this affect the site response to unexpected peaks in the level
of airborne contaminants?
2.5. Are there areas of excessive contamination that might require a reassessment of the
remediation plan?
2.6. Please describe the arrangements for ‘sniff testing’ and the efficacy of such tests.

3. Contractual Arrangements
3.1. We understand that under the contractual arrangement between EMDA and VSD,
the principal consideration is the timely completion of the work. Whilst recognising
the importance of timely completion, we are concerned that this arrangement will
encourage short cuts at the expense of safety. Delays in the remediation work are,
we believe, inevitable and we would expect to see a provision for this is in the
contract. What are the exceptional weather and environmental conditions set out in
the contract that will allow the contractor to apply for an extension, or that would
trigger an otherwise acceptable delay in the work?

4. Operations and Site Discipline

4.1. The Corby Report frequently refers to the careless disruption and release of
contaminated dust from roadways and waste stockpiles, largely uncontrolled by
damping, sheeting and good site discipline.
4.2. Please confirm that there will be adequate water bowsers on site.
 4.3. Please confirm that sweepers will be of a type that contains dust, rather than a ‘JCB
with a roller sweeper on front’.
4.4. Please confirm that the tipping lorries will be fitted with integral roller tarpaulin
sheeting devices, rather than using loose sheeting methods.
4.5. Please confirm that there will be adequate wheel washing facilities for vehicles
leaving the site and that the wash waste will be treated as potentially harmful
material.
4.6. Please describe how site discipline will be monitored and enforced.
4.7. The Corby Report refers to bad practice by digging and dumping operators,
resulting in loads being ‘dropped from a great height, generating substantial
quantities of dust’.
4.7.1. Please confirm that contaminated materials will be handled appropriately.
4.7.2. Please confirm that the site will employ only drivers and machine operators
trained to work in the exceptional conditions on the Avenue site and that they
will be observed to ensure correct observance of safety procedures.

5. Construction and Desorption

5.1. The Corby Report refers to the use of contaminated material being used to construct
haul roads within the site, without regard to arisings of contaminated dust or
leachates. Please confirm that excavated material will not be used as ballast or
dressing on internal haul roads.
5.2. Our experience of industrial chimneys/gaseous waste stacks is that they are rarely
less than 65m high. We remain concerned that the 40m stack height proposed for
the desorption unit will be too low to ensure the adequate dispersal of waste gases.
Please confirm that the 40m stack will allow the safe dispersal of potentially
hazardous material in every configuration of wind flows over the stack.