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518 Assessing risks to groundwater from contaminated soils

Soil Use and Management (2006) 21, 518–526 DOI: 10.1079/SUM2005344

Assessing risks to groundwater from contaminated soils


J.W.N. Smith

Abstract. The regulatory regime for contaminated soils and groundwater in the UK is risk based. Indeed,
the definition of contaminated land in UK law requires the presence, or likelihood, of significant pollution or
harm before affected land meets the statutory test of being contaminated land. In dealing with contamination,
a risk management approach is used that also requires the consideration of wider land-use planning priorities,
the costs and benefits of remedial action, and the goal of achieving sustainable development. A parallel risk-
based framework is adopted for polluted groundwater. The risk assessment process adopted for contaminated
groundwater in the UK follows a tiered structure. A simple conceptual model is developed from desk study
and site reconnaissance. This model is then used as the basis for designing a site investigation programme,
the sampling being undertaken to test assumptions within the model as well as to develop it further. The
Environment Agency (England & Wales) has developed a package of tools to aid this tiered approach. This
paper describes the integrated risk assessment and risk management processes for contaminated groundwater
in the UK, with emphasis on the tools and methods developed. It explains the importance of a conceptual
understanding (or model) to all tiers of risk assessment and subsequent risk management.

Keywords: Risk assessment, groundwater, contaminated soils

I N T RO D U C T I O N site reconnaissance information. This model is then used


as the basis for designing a site investigation pro-
T he Environment Agency (England & Wales) has duties
to protect controlled waters (including groundwater)
and to ensure that its actions contribute to the goal of
gramme, for which the sampling is done to test assump-
tions within the model as well as to develop it further.
It is essential that the assessor is clear why the risk
achieving sustainable development. The Scottish Environ-
assessment is being undertaken, that is to say, which
ment Protection Agency (SEPA) has similar responsibilities
questions the assessment must answer. The data and
for Scotland. With respect to contaminated groundwater,
information collected should aim to reduce uncertainty
the Environment Agency has adopted a risk-based
in those aspects to which the particular decision is most
approach to its assessment and management, in line with
sensitive. Consequently, the model should be built-up by
government recommendations (DETR et al. 2000; Kearney
collecting information on the processes and conditions
2003; DEFRA & Environment Agency 2004).
that most affect the fate and behaviour of hazardous
The key to making good decisions in relation to assessing
substances within each as part of the source – pathway –
and then managing risks from polluted groundwater is a
receptor linkage.
sound understanding of the site, aquifer and the physical,
The Environment Agency has developed a package of
chemical and biological processes occurring therein. This
risk assessment tools to aid this tiered approach. They
understanding is termed a conceptual model and is the cor-
include screening level groundwater vulnerability maps
nerstone upon which risks are assessed and a risk manage-
(National Rivers Authority 1995a) and source protection
ment strategy developed. The development of a conceptual
zones (National Rivers Authority 1995b), a framework for
model – which draws together details about the site, scien-
evaluating risks to groundwater (the remedial targets
tific understanding on relevant processes in the subsurface,
methodology; Environment Agency 1999) and simple ana-
and public/private priorities and objectives for land and
lytical models using deterministic and probabilistic com-
water-use planning – is an essential tool for understanding
puter models of pollutant fate and behaviour, such as
the problem in the widest context.
CON SIM (Environment Agency 2003). Finally, where
The risk assessment process adopted for contaminated
necessary, complex risk assessment methods are used and
groundwater follows a tiered structure. A simple concep-
the Agency has developed a new code to better simulate
tual model is initially developed from desk study and
conditions commonly found in UK aquifers, that is, their
variable conductivity and storage with depth throughout
Environment Agency, Science Group, Olton Court, 10 Warwick Road,
Olton, Solihull B92 7HX, UK. Tel: þ44 (0)121 708 4753. Fax: þ 44
(Environment Agency 2002; Environment Agency &
(0)121 708 4637. E-mail: jonathan.smith@environment-agency.gov.uk British Geological Survey 2002).
J.W.N. Smith 519

Alongside methods for groundwater, techniques for in the UK, with emphasis on the tools and methods devel-
assessing the risks to human health from chronic and acute oped. It explains the importance of a conceptual under-
exposure to contaminants, risks to ecosystems and property standing (or model) to all tiers of risk assessment and
have been developed. The Contaminated Land Exposure subsequent risk management.
Assessment (CLEA) model, for example, is the recently
launched approach for assessing chronic risks to human
health from contaminated soil, which should be integrated R I S K A S S E S S M E N T F R A M E WO R K
into whole-site decisions (DEFRA & Environment Agency
2002; Martin et al. 2003). The UK framework for environmental risk assessment and
The objectives of remediation are to manage unacceptable management is shown in Figure 1. The main stages within
risks to health or the environment. Effectiveness, durability each tier of risk assessment are as follows.
and practicability, the likely costs and benefits, and contri- . Hazard identification, which is identification of contami-
bution to achieving sustainable development, are all con- nant sources, pathways and receptors, taking into
sidered in selecting a remedial option. Methods for account the actual or intended use of the site and its
assessing the likely costs and benefits of groundwater reme- environmental setting.
diation have been developed (Environment Agency 1999, . Consequence assessment, which incorporates the three
2000c) which take account of societal (external) costs rather stages of identifying possible consequences, and assessing
than just the private costs to a developer or landowner. the likely magnitude and likelihood of those conse-
Using these approaches in tandem it is possible to find an quences. This process requires consideration of the
optimal level of remediation and thus the best ‘environmen- plausibility of source –pathway –receptor linkages and
tal balance’ that is achievable using remedial techniques. determination of the potential for adverse impacts.
This paper describes the integrated risk assessment and . Risk estimation, which assesses the significance of any
risk management processes for contaminated groundwater risk(s) of adverse effects that identified receptor(s) will

Problem formulation: Review / revise conceptual


develop conceptual model as data is collected and
model system uncertainties reduced

Stages within each


Tiered risk assessment tier of risk assessment

Hazard
identification
Tier 1: Risk
Risk prioritization
screening
identification of
consequences

Magnitude of
Tier 2: Generic consequences
quantitative risk
assessment
Probability of
consequences

Significance of
Tier 3: Detailed this Risk
quantitative risk
assessment

Options appraisal

Economics Technology

Social issues Management

Risk management

Collect data, iterate processes and monitor

Figure 1. A framework for environmental risk assessment and management. (Based on DETR Environment Agency & Institute for Environment and
Health 2000).
520 Assessing risks to groundwater from contaminated soils

suffer if they come into contact with, or are otherwise and information. The process is iterative and at each stage
affected by, contaminant sources under defined conditions. of the assessment the model should be revisited to test
Risk estimation takes account of information on the likeli- whether previous assumptions remain valid and whether
hood, nature and extent of exposure (or of other hazardous the collection of new information supports, or requires
conditions) in making a judgement on the significance of amendment of, the model.
any adverse consequences that could occur. Note that the For assessment of risks to groundwater, the greatest risks
expression of risk may be in qualitative (i.e. the likelihood are normally associated with contamination that is in a
of serious pollution is low or high) or (more rarely) quanti- mobile or leachable form. Chemical analysis of potentially
tative terms. Following the assessment of risk the results contaminated soils often focuses on the concentration of
are taken forward to decide whether risk management contaminant as a ‘total contaminant concentration’ (i.e. the
(remedial) actions are necessary to reduce any unaccepta- total mass of contaminant within a soil sample). There are
ble risks by whatever method is considered best. instances where this is important information for the con-
. Risk management concerns evaluation of the need for risk sideration of risks to water quality, such as during assess-
management action (i.e. risk reduction or control ment of material on riverbanks, in flood plains, or in highly
measures) and takes into account the nature and scale of fissured aquifers. However, in most instances it is more
risk estimates, any uncertainties associated with the important to assess the fraction of contamination that is
assessment process and, where further action is required, soluble in water, and have regard to the fact that some con-
the objectives and attendant broad costs and benefits. tamination may have by-passed the soil that has been
sampled. At this early stage, consideration should be given
The first three processes take place within each of the to the potential for pollution of water, by considering the
tiers shown (Figure 1). However, the level of resource and physical and chemical properties of those contaminants that
effort expended at each tier increases in response to the are most likely to be present, given the previous uses of the
significance of the risk or uncertainty in the decision. site. By considering these issues early, it is possible to focus
Where only insignificant risks are identified, or the out- the site characterization and analytical testing on the areas
come of a particular occurrence can be predicted with a and substances most likely to be significant.
high level of certainty, a robust decision may be made with The key tools used for screening risks to groundwater
minimal data at tier 1. As the severity of possible pollution from polluted sites are set out in the Policy and practice for
or harm increases, or the prediction is increasingly uncer- the protection of groundwater (Environment Agency 1998). It
tain, the assessment process moves to higher tiers, which introduces concepts of groundwater vulnerability and
also necessitates additional data collection and analyses. source zone protection as a basis for prioritizing both pro-
The following sections describe the methods and tools tective and remedial actions for groundwater. Geological
used at different risk assessment tiers to test and refine the strata in England and Wales have been divided into three
conceptual model of the site and its surroundings, and to classes: major aquifers, minor aquifers, and non-aquifers
understand the key processes that influence the ultimate on the basis of their hydrogeological properties. The classi-
decision on the significance of risks of water pollution. fication essentially reflects the strategic water resource
value of different geological formations, but should be sub-
Tier 1 – risk screening ject to local hydrogeological conditions.
The initial tier (risk screening) largely relies on desk-based Major aquifers are described as ‘highly permeable for-
study and an initial site reconnaissance visit, without mations usually with the known or probable presence of
detailed sampling or intrusive investigation to establish significant fracturing. They may be highly productive
whether there are conditions or circumstances on a site that strata of regional importance, often used for large potable
could give rise to unacceptable risks. Its aim is to allow the abstractions’.
assessor to develop an initial understanding, or conceptual Minor aquifers are defined as strata with high intergra-
model, of the site and its surroundings, which will provide nular permeability, or are variably porous/permeable but
the basis for subsequent stages of assessment. It is essentially without significant fracturing. They generally only support
qualitative in terms of both information collation and impact locally important abstractions, or baseflow to watercourses.
prediction. Where risk screening indicates that there are Non-aquifers are formations with negligible per-
very unlikely to be unacceptable risks (e.g. because there are meability that are generally regarded as not containing
no identified receptors in the vicinity of a contaminated groundwater in exploitable quantities.
site), then risk screening facilitates prioritization of further Superimposed over the aquifer classification are data on
action, both in terms of its urgency and its detail. soil and drift geology, which take account of the leaching
The development and continued refinement of a concep- potential of the soils. Where an aquifer is overlain by a
tual model is fundamental to the successful and robust thick clay soil, the potential for contaminants to reach the
assessment of risks (Environment Agency 2001). The groundwater is reduced. Combined, these produce seven
model should allow the assessor to visualize the site, any classes of aquifer vulnerability, which have been presented
contamination and the mechanisms by which a pollutant on 53 maps at 1:100 000 scale covering England and Wales.
might migrate, or receptors be exposed. The model should If it is found, for example, that the hydrogeology around
evolve throughout the risk assessment and management a contaminated site is such that the contaminants do not
process. It should never be developed and then ‘left on a pose a significant risk to the water environment, then
shelf ’ unchanged, despite the gathering of additional data resources would be directed towards more sensitive sites.
J.W.N. Smith 521

This could be, for example, because the formation is of low there is an unacceptable risk. In the case of contaminated
permeability with no water resource value (a non-aquifer) groundwater this normally relies on direct comparison of
and there are no dependent surface waters or ecosystems groundwater monitoring data or soil leachability testing
locally. However, where the site is identified as underlain with relevant water quality standards and guidelines.
by a sensitive aquifer, it would be prioritized for further Direct comparison of measured water chemistry or soil
investigation and assessment . leachability with water quality standards assumes there is
A similar approach can be taken for screening potential no dilution, attenuation or retardation of contaminant con-
sources of contamination. Rather than investigate all con- centrations between the source (soluble/mobile soil con-
taminant sources with equal priority, emphasis is placed on taminants) and the receiving water body. This fails to
those sites that are known (or suspected) to have been used recognize any attenuation processes between the contami-
for activities that involved highly polluting and mobile sub- nant source and the point at which the standard strictly
stances, or sites where operations are known to have been applies (e.g. a drinking water standard applies at the point
polluting or poorly controlled. Site characterization should of supply – the tap – not the aquifer from which it was
be focused on particular areas of concern, taking account of abstracted). As a result, direct comparison is invariably
the historic use and layout of each site. the most conservative of the available assessment
The second basis for assessing the sensitivity of ground- approaches. Subject to the sufficiency of the data, provided
water is the proximity of the site to an abstraction point, the concentrations of soluble/mobile contaminants do not
typically a borehole, well or spring. The catchments of exceed the relevant generic assessment criteria, it can be
about 2000 public water supply abstractions and other large concluded that the substances pose no significant risks to
or sensitive sources (e.g. brewery abstractions) have been the receiving water body, or users of that water. Where the
modelled and had source protection zones published. concentrations of soluble/mobile contaminants exceed the
Three zones are produced for each abstraction: inner (SPZ relevant criteria, further action, either risk remediation or
I), outer (SPZ II), and total catchment (SPZ III) zones (see more complex risk assessment that more accurately rep-
Figure 2). resents the conceptual model, is warranted. Generic assess-
Modelled source protection zones are based on the pre- ment criteria typically used in the UK are listed in Table 1.
dicted travel time of groundwater within the saturated To reach a judgement at tier 2, data are needed on the
aquifer to an abstraction point. The SPZ I is based on a concentration of pollutants in the affected groundwater,
50-day travel time and is a small zone immediately around and on the local use of the groundwater for human abstrac-
the borehole. The 50-day period is selected to allow for tion, or support of other environmental systems. This
degradation of typical microbiological contaminants in requires refinement of the initial model through more
groundwater, such as those in discharges of sewage effluent. detailed site characterization and assessment, usually on the
The SPZ II is based on a 400-day travel time and is basis of further desk-based research and limited exploratory
designed to provide protection of the borehole from reason- site investigation.
ably degradable chemicals. The entire catchment of the Methods of assessing contaminant leaching character-
abstraction (SPZ III) indicates the extent of the aquifer istics, such as the recent British Standard (British Stan-
that contributes water to the abstraction. dards Institute 2004) and European Standard (European
Committee for Standardization CEN) and sorption charac-
teristics (Environment Agency 2000a, 2004) are valuable for
Tier 2 – generic quantitative risk assessment understanding the likely mobility of contaminants. These
The second tier uses generic risk assessment criteria to methods aid in deciding whether substances with hazardous
establish whether, on the basis of conservative assumptions, properties also pose a possible risk to receptors, because
they are able to migrate to a point at which exposure of
those receptors could occur.

Tier 3 – detailed quantitative risk assessment


At tier 3 more complex tools are used to represent or simu-
late the conceptual model, so that site-specific risks are
quantified. This requires more data collection to reduce
uncertainties and refine the conceptual model. Figure 3
presents illustrative models of pollutant processes and the
surrounding hydrogeologic environment.
This phase should address the nature, likely location and
behaviour of contaminants and possible interactions with
defined receptors, with the aim of establishing quantitat-
ively the nature of a linkage between potential sources – path-
ways–receptors. A preliminary indication of the potential
for chronic and short-term risks to health and the
Figure 2. Schematic illustration of source protection zones (SPZs I, II environment can also be formed, assuming information is
and III) and abstraction point (†). (Reproduced courtesy of UK Ground- available on the nature, concentration and location of
water Forum.) contaminants.
522 Assessing risks to groundwater from contaminated soils

Table 1. Possible generic assessment criteria for use in groundwater risk assessment.
Contaminant property Technical issues Relevant generic assessment
to consider criteria (water quality standards)

Poisonous Potential to cause harm to EU/UK Drinking Water Standards; WHO


living organisms (health) guideline values; EU/UK
(including humans) by exposure Environmental Quality Standards
to toxins. Implies requirement
to consider relevant dose

Noxious Potential to cause nuisance WHO (appearance, taste & odour)


or harm, e.g. by taste, guideline values; taste and odour
odour or discoloration threshold data

Polluting Potential to cause environmental Environmental Quality Standards;


detriment (to water quality and ecosystems) presence of solid waste

Solid waste matter Amenity and aesthetic detriment Suspended solid threshold limits
or harm to aquatic organisms
(e.g. by attrition of fish gills or
reduced light to aquatic flora)
EU ¼ European Union; WHO ¼ World Health Organization.

Risk estimation approaches, such as the remedial targets To include this in an assessment, more complex tools are
methodology (Environment Agency 1999) and relatively normally required.
simple models including CON SIM (Environment Agency Complex models are used to describe the fate and trans-
2003), may be used to predict the impact of a contaminant port of contaminants in the environment, particularly
source on the receptor. A variety of different outputs can where predictions are needed in both space and time. This
be obtained depending on the techniques used. approach allows for a high degree of site specificity, since a
The remedial targets methodology describes a staged large number of the input values can be varied to reflect
approach to the quantification of risks to the water environ- actual or likely site conditions. However, it requires special-
ment that fits within the generic and detailed quantitative ist expertise and extensive data on the characteristics of the
risk assessments depicted in Figure 1. The initial assess- source, pathway and receptor.
ment relies solely on comparison of measured groundwater Noting the complexity of hydrogeological systems in the
quality or soil leachability results with generic standards as UK, the Environment Agency has developed a code to
described previously. Subsequent work may take account of allow better representation of the aquifer conditions.
dilution of contaminants at the water table and of attenu- Recent work (Environment Agency 2002; Environment
ation processes within both the unsaturated and saturated Agency & British Geological Survey 2002) allows simu-
zones (Figure 4). In order to progress through this struc- lation of vertical variation in hydraulic conductivity
ture, additional data are required and, as the conceptual through an aquifer for modelling of regional applications.
model is refined, more complex risk analysis can be justi- Assessors should select a model or analytical technique
fied. The overall level of acceptable risk (i.e. the environ- that is capable of producing usable results which are suffi-
mental objective set for each receptor) remains constant ciently accurate to allow necessary decisions to be made,
through this process. However, as confidence in the model and is appropriate to the scale of the problem and the qual-
increases, steps may be taken to better assess the likely ity of the available data. Assessment techniques may vary
impacts on receptors, and therefore the necessity for risk from simple comparison, through deterministic and prob-
management action. abilistic methods based on analytical solutions, to complex
Simple models provide some scope for varying input numerical hydrogeological models.
values according to known or assumed site conditions,
thereby avoiding some of the inherent conservatism associ-
R I S K M A NAG E M E N T
ated with the direct comparison approach. For example,
they permit dilution and attenuation effects to be taken Having established that the presence of contamination is
into account in establishing the concentration of contami- such that it causes an unacceptable risk to health or the
nants likely to be present at a receptor located at some dis- environment, it is necessary to undertake some form of
tance from the contaminant source. If the output of these remedial action to mitigate these risks. Within the UK’s
models indicates that the whole or part of the site is likely risk-based framework, the goals of remediation are to
to pose unacceptable risks to the water environment, asses- remove unacceptable risks, and consequently the terms
sors again have the option of further refining risk estimates remediation and risk management are directly interchange-
using more complex models or evaluating the best form of able. Remediation includes any action that leads to
remedial action. Simple models and analytical tools often reduction or control of risk, not simply traditional
only provide a ‘snapshot’ of the system and do not provide engineering or process-based technologies that ‘clean-up’
predictions over time or assessment of time-variable factors. contaminated media.
J.W.N. Smith 523

.0

.5
20 .0

19
19 .5
SITE 18 .0
18
19.75
BHA
20
19.4
TANK BHB

19.8
BHC

17.5
19.7 19.35 18.9 Water supply
borehole

19.1

Flow direction

18.25

18.25 Groundwater level in metres AOD


Groundwater level contour in metres AOD

STORAGE
TANK
BHA BHB
MADE GROUND BHC

1 Receptor
SAND & GRAVEL

4 3
Vapour
Groundwater 4 water table
Flow 2
4 5

SANDSTONE AQUIFER 5
Floating product
(LNAPL) Dissolved
contaminant

CLAY-AQUITARD

Processes
1 Sorption of contaminant onto sand and gravel

2 Dissolution of NAPL into groundwater

3 Volatilisation

4 Degradation-anaerobic at centre of plume


-aerobic at edge of plume
5 Dispersion (spreading of plume)

Figure 3. Illustrative conceptual model in plan (upper) and cross-sectional (lower) views of contaminated site and selected pollutant fate and behaviour
processes. AOD ¼ above ordnance datum; BH ¼ borehole; LNAPL ¼ light non-aqueous phase liquid. (Based on Environment Agency 2001.)

The conceptual model developed previously for risk remediation method. This approach is illustrated by gui-
assessment purposes is equally valuable in developing a risk dance on monitored natural attenuation (Environment
management strategy, since information on site-specific Agency 2000b), which aims to create a seamless decision-
conditions and any natural contaminant flux-reducing making process from initial identification of contamination
processes are also necessary when selecting the best problems, to selection of the optimal remedial approach.
524 Assessing risks to groundwater from contaminated soils

Recharge

In practice the "receptor"


Receptor can be a surrogate borehole
Soil zone source
or other agreed compliance

Leaching of contaminants point

Predicted plume

I: Compliance point - soil zone


Concentration

Remedial target concentration = CT


Target concentration (CT)

Distance down gradient from source

II: Compliance point - groundwater below site

Site This will usually be required


where there is no existing
groundwater pollution

Remedial target concentration = DF x CT


Concentration

effect of dilution
Dilution

Target concentration (CT)

Distance down gradient from source

III: Compliance point - down gradient of site

Site
Remedial target concentration = DF x AF x CT

Dilution
effect of dilution
Concentration

Attenuation line describing decrease in


contaminant concentrations due to
Attenuation degradation, sorption, dispersion

Target concentration (CT)

Distance down gradient from source

Figure 4. Tiered approach to risk estimation for groundwater. (After Environment Agency 1999.)
J.W.N. Smith 525

Desk study, develop initial conceptual model, undertake site investigation

Confirm source – pathway – receptor linkages, test and revise

Human health Water quality Air quality, buildings,


ecology etc.

Human toxicological data Environmental standard Relevant standard

Soil guideline Remedial targets


values and site- method and
specific CLEA
model ConSim
Other remedial targets
based on risk to air quality,
plants, buildings etc.
Provisional remedial objective Remedial target

Comparison of remedial target for each S-P-R linkage, taking into account likely
costs and benefits, sustainability, technological limitations and mitigating factors

Whole-site remedial objective(s)

Figure 5. Integration of assessment for all receptors is key to whole-site decision-making.

Within the UK framework a number of aspects must be Environment Agency’s goal is to maximize societal ben-
considered during selection of remedial options: efits, which implicitly includes minimizing environmental
– effectiveness of remedial action damage, both from the original groundwater pollution,
– durability of action and from any remedial works proposed (Environment
– practicability of action Agency 2000c).
– likely costs and benefits
– other management and social issues.
Within the three central decision processes indicated in
Figure 5 (for human health, water quality and other recep- C O N C LU S I O N S
tors), a tiered approach is taken so that the level of resource This paper describes the approach and tools applied in the
and complexity of decision-making used is proportionate to UK for assessing and managing risks to the water environ-
the broad level of risk associated with each hazard. The ment from contaminated soils. It emphasizes the objective
tiered structure shown in Figure 1 could be shown within of attaining risk-based remedial solutions that balance the
each of these three steps. environmental benefits achieved with their costs; with the
Identifying the best environmental balance is key to ultimate goal of selecting a sustainable solution to the pro-
ensuring that remedial works contribute to sustainable blems of polluted groundwater.
development. For example, in some jurisdictions, attain- The recommended approach follows a continuous pro-
ment of maximum concentration limits similar to drinking cess that, at its core, relies on understanding the site and
water standards across aquifers (including the source areas processes acting on contaminants, as described and docu-
within contaminated sites) is a mandated goal, regardless of mented. This understanding should be challenged and
the risk reduction this brings, or the environmental damage tested as knowledge and data increase through the risk
that may be caused by undertaking a long, energy intensive assessment process. It is key that any assumptions are
remediation. It is often stated of remediation that 80% of reviewed as new information comes available, so that
the benefit can be achieved with 20% of the financial costs, decisions are made on the basis of best knowledge.
and the remaining 20% benefit can only be realized by
spending 80% of the cost. The same argument can be
made with respect to environmental costs of remediation,
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