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2.11.4 Record keeping – project files

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2.11.4.1 Site characterisation reporting

Site owners/operators should prepare comprehensive records of the nature and extent of the contamination, the process of deciding how to manage the contaminated site, implementing the chosen strategy, validation, and interactions with stakeholders throughout the process, as well as of any lessons learned and changes made during the implementation [CIRIA-2009].

Such records should also include descriptions of activities performed; data from the historical site assessment and monitoring and surveillance programmes; occupational health and safety records for the remediation workers; records of the types and quantities of waste produced and of their management and disposition; data from environmental monitoring; records of financial expenditures; records of the involvement of interested parties; records of any continuing responsibilities for the site; identification of locations that were remediated and those with residual levels of contamination remaining; specifications of any areas that remain restricted and the restrictions that apply; statements of any zoning and covenant restrictions or conditions; and statements of lessons learned [IAEA-2007a].

Failures in the implementation of remedial measures may arise from a lack of consensus among interested parties, often in the negotiations during the decision making process regarding the implementation of the remediation plan. While some conflicts between interested parties are apparent at the outset of the decision making process, others may arise much later, for example during discussions in which the actual implications of alternative decisions are made explicit. All conflicts and their resolution in the decision making process should be documented.

The organisation responsible for maintaining and updating the records should be clearly designated and the provision of the necessary resources and notification of the competent authority should be considered.

In order to achieve the objectives, at the project outset, plans should be made for record keeping which are compliant with the quality management programme used for the site characterisation works. Consideration should be given at an early stage as to the longevity of the materials and devices to be used to store data, since these factors have time and cost implications for project deliverables.

A ‘Project Records File’ (PRF) should be set up for each site so that information about contaminated land can be held in a formalised structure. The ‘Project Records File’ should be part of the record management system of the organisation that owns or operates the site and should be accessible to stakeholders.

An example of a ‘Project Records File’ and some additional information is available in Appendix H.

2.11.4.1 Site characterisation reporting

Delivery of investigation reports may be required for different purposes in order to serve different audiences. The reporting structure provided in Table 2.13 should be evaluated. Consideration should also be given to standardisation of the data format.

Table 2.13 Suggested reporting structure

Report Audience

Summary Report A brief non-technical summary of the whole investigation for a lay audience. Such a document is particularly useful to supply as part of stakeholder involvement.

Preliminary Investigation Report with Initial Conceptual Model To be completed prior to the next stage of investigation, and useful for circulation to all technically involved parties, and to supply with tender documents for the next site investigation stage.

Exploratory and Main Report It is recommended that reports from these investigations are split according to potential audiences.

Factual From a business point of view the commissioning organisation may wish to release factual information only to potential buyers or developers and allow them to place their own interpretation and cost analysis on the findings.

Interpretative The interpretative report can be produced giving details of the risk assessment and may be for a limited audience.

Supplementary Reports These reports tend to be short and target particular issues, and there is no particular merit in splitting the facts from the interpretation

Table 2.13 Suggested reporting structure