Guidebook for dealing with the incidental discovery of ground and groundwater pollution during construction work

The need

The industrial revolution and old waste management practices have left behind a large number of sites with polluted ground whose condition is not necessarily known. In recent years, French policy for spatial planning has promoted rebuilding the city over the city (ALUR Act) by encouraging the reuse of industrial wasteland in order to limit urban expansion in natural or agricultural areas. This context is conducive to the discovery of new, previously forgotten or unknown polluted areas during development projects or works involving the digging and extraction of earth. However, the discovery of ground pollution during construction often causes it to be stopped, leads to additional costs and a possible deterioration of the project owner's image. Moreover, this pollution can involve a risk both in terms of health (for unsuspecting workers and sometimes even for local residents) and from an environmental point of view.

The possibility of accidental discoveries of ground pollution is generally taken into account and anticipated:

• at the national level, through the risk prevention policy implemented by the MTE: inventories of (potentially) polluted sites (BASIAS, BASOL), oil spill waste storage sites or former French uranium mining sites (MIMAUSA);
• at the local level, by some local authorities through Urban Historical Inventories (IHU);
• in the field, where some major operators and private companies have implemented a policy of prevention and training for their staff in order to anticipate or manage cases of unexpected pollution discoveries as best they can. In addition, the regulations governing Installations Classified for the Protection of the Environment (ICPE) provide for securing and restoring these when they are no longer in operation. In addition, when intervening on these industrial sites, operators and companies are made aware of the prevention measures, the risks of pollution and the actions to be taken to deal with it.

However, most construction work is done outside the ICPE context, does not involve land development projects and takes place on sites where here is no reason to suspect pollution on private or public land, whose owners are not very aware of pollution issues). Moreover, at the local level, the importance attached to preventive measures varies from one operator to another and the actions to be taken are not well known by some of those intervening on the site, particularly individuals. Some of the pollution discovered incidentally during construction work may therefore be poorly managed and/or ignored.

The management of accidentally discovered pollution can be made even more difficult due to it not having been expected and to the different kinds of pollution (presence of buried waste in a garden, pollution of water from a well, leakage from an oil tank, etc.), as well as to the context of the work (carrying out a geotechnical or geothermal survey, redeveloping a plot of land, creating infrastructure networks or carrying out archaeological excavations) that led to the pollution being detected.

The results

As part of its public policy support missions, to help prepare for and manage the accidental discovery of pollution, BRGM, in collaboration with the members of a special task force (FNTP, EDF, EPF Normandie, Mairie de Paris, CEREMA and UPDS), has drawn up a good practice guidebook intended for all the players concerned and mainly for small and medium-sized companies and individuals.

This guidebook follows the different steps involved in anticipating, identifying and managing pollution which has been discovered accidentally:

• preparation of a building site: sources of information on environmental quality, possible preliminary studies, concepts of risk prevention and tools and measures that can be implemented within companies to forestall or deal with accidental discoveries;
• indications of the presence of pollution: the principal types and characteristics of the main pollutants and associated organoleptic observations;
• immediate actions to be taken if pollution is discovered, in relation to the safety of people, observations to be made, people to be contacted, etc;
• the measures to be taken, in line with the national methodology for managing polluted sites and soils;
• the role of the different actors involved, communication and the importance of keeping track of the pollution.

The guidebook includes several documents:

• course of action to be taken in the event of an accidental discovery of pollution:
  • flowchart for professionals,
  • flowchart for individuals.
• information form (Annex 1), the main purpose of which is to keep a record of the pollution discovered and the management measures implemented. It is completed by the project owner.
• Prevention and management of accidental pollution discoveries - Literature review in France and abroad.

All these documents, as well as an explanatory video, are available on the InfoTerre - Polluted sites and ground website.

Using the results

This guide is intended for all those who may be directly or indirectly confronted with the problem of accidental discovery and management of pollution in the context of construction work, whether they be owners, project owners (public/private) or professionals. To make the guidebook easier to read, a distinction has been made between sections that are common to both companies and individuals and those specifically intended for companies.

The partners

The partners in the working group led by BRGM to draw up the guidebook:

• CEREMA
• EDF
• EPF Normandie
• FNTP
• Mairie de Paris
• UPDS