A Stakeholder’s Perspective on Contaminated Land Management - Dealing with Contaminated Sites: From Theory Towards Practical Application - page 1063

the ability to reuse materials. Opportunities to reuse treated and untreated soils are
decreased and the burden on landfill and the use of primary, quarried, replacement
intensified.
The revised Waste Framework Directive will be transposed by December 2010.
The new Directive's focus on recycling and reuse means that all materials including
soils may be more clearly defined as by-product rather than waste, and there is more
certainty about when materials cease to be a waste. It has also sought to address
some specific issues around soil as waste. For example it counters the Van Der
Walle ruling excluding unexcavated contaminated soil from waste control. It also
allows excavated uncontaminated soil from construction processes to be reused on
the site of origin outside waste control. NICOLE is hopeful that appropriate and
consistent transposition of the new Directive will improve the current complexity
and inconsistency that prevails.
24.6 The Power of Natural Processes
Experiences with subsurface remediation worldwide have made clear that our soci-
ety is not able to achieve a complete removal of contaminants in the subsurface
within time frames of a few decades. Moreover, a complete removal is in most
cases technically impossible and the costs of full removal are often not in line
with the benefits and risks involved. In addition the complete removal of con-
tamination could be contrary to the general idea of a smaller footprint in all
human activities (c.f. remediation in a sustainable context. Therefore remediation
should not be considered as an end goal in its own right, but rather as a neces-
sary effort in maintaining the useful properties of land - a non-expandable good.
Fortunately, it is possible to make use of the naturally occurring processes in the
subsoil. Natural Attenuation (NA) is increasingly recognized as a process that can
result in gradual loss of contamination, especially in plume areas of contaminated
sites.
In 2000, NICOLE set up a data sharing program for industrial sites to investi-
gate the possibilities for Monitored Natural Attenuation (MNA). Eight industrial
partners and their consultants carried out investigations at their sites as part of a
NICOLEMNA demonstration project. The results were reviewed by 12 independent
reviewers from universities and authorities. The general outcome was that MNA
is applicable and effective at many sites. This demonstration project underlined
the fact that MNA is a cost-effective option that can be used to obtain satisfac-
tory results. MNA is often not a standalone option, although it could be. In many
approaches it is part of a risk-based site management plan. It is the view of NICOLE
that MNA should be incorporated into the various soil and groundwater policies
as one of the tools to manage historical soil and groundwater contamination and
to support the objectives. Generally speaking it is necessary that natural degrada-
tion processes are taken into account in Risk Management solutions. (Monitored)
Natural Attenuation is described in detail in Peter et al. ( Chapter 22 of this topic).