Wednesday, 23 June 2010

Eric & Treby Estate: Site Contamination

The Eric & Treby Estate is contaminated.  It's not alone.  Significant areas of land in urban London in the nineteenth and early twentieth century are also contaminated because they used to be home to industries with practices which are now not allowed.

The standards required for building land now are much higher than they used to be in the past because we now understand more about how dangerous some contaminants can be for people's health.

This post outlines what is a complex topic.  We've had to learn about it and what follows relates to a meeting with Tower Hamlets Planning and reading the detailed reports and proposals

Planning Conditions submission - Site Contamination

Before any work on the site can commence - other than site investigation works - the client and contractors have to satisfy the Planners that they can meet the planning conditions.  One of these relates to investigating the contamination of the site and making good.

The latest submission from the architects for EastendHomes to Tower Hamlets Council Planning Department, concerning the satisfaction of the planning conditions, concerns Site Contamination and Site Remediation.

If you click the link to PA/10/01093 - Approval of Details - Site Remediation (re planning conditions relating to planning permission PA/09/2065) you can see all the evidence which is being presented to the Council about:
  • desk top analysis of previous contaminating industries on the site.
  • evidence from 36 bore holes of the soil conditions and what has been found under the ground (this also affects what sort of arrangements need to be made for foundations)
  • identification of the areas which need site remediation works
  • proposals as to how the site will be cleaned up (the Site Remediation Strategy) and what quality controls will be put in place to contain dispersal of the contamination.
This is complex scientific area - but the evidence is there for you to see and comment on should you so wish.

What used to be on the Eric & Treby site

Herts and Essex Site Investigations have undertaken a survey.  They are a firm of Geotechnical and Geo-Enviromental consultants, who provide soil surveys for a wide clientele.

Their report (Phase III Remediation Strategy) indicates that they have found widespread contamination from Arsenic, Nickel, Lead and PAF contaminated soils at the Eric & Treby Estate.

The site history (page 4 para 1.2) recorded in the report is extremely ungrammatical which gives rise to concern as to the author's command of English in relation to reading and site investigation as well as writing.

The report indicates (without citing the evidence found) that the site has previously been home to a Rope Works and a chemical works.  This is why Ropery Street is so called.

This is a very likely source of the contaminants.

The very large quantity/depth of what is essentially rubble on the site is probably due to either bomb damage (this was an area which was targeted in the Blitz of 1940) or is the rubble from the demolition of older residential properties and/or factories.

Which are the sites which need remedial works?

Page 18 of the Phase III Remediation Strategy provides a plan of all the areas of soft landscaping requiring works.  As you can see it's a lot of land.  There are also more detailed plans for each site showing the area requiring remediation on top of the proposed soft landscaping.

Sites requiring remediation works

Appendix 1 Sheet 2 shows the contamination locations - and also all the proposed sample locations which were not done and for which there is no report.
Example:  The Recipe Street Garden - created without any remediation works - has registered Arsenic, Nickel, Lead and poly-aromatic hydrocarbons above the allowable levels identified in the Site Remediation Strategy (the latter can cause can cause cancer, mutation in and abnormal physiological development)
What needs to be done - the Site Remediation Strategy 

This is what the experts HESI are saying and recommending in relation to the areas of soft landscaping
Possible site Remediation Measures
Site Soils
  • Confirmation that the entire site area is contaminated and that remedial measures are required to remove risk to all areas of soft landscaping
  • Likely removal of soils within the site to remove the risk to human health
  • alter the chemical state of the site soils to reduce the impact of the end use soils on the proposed receptors
Phase 11 Remediation Strategy - Site at Eric and Treby estates (para 2.5 page 8) 
The site has been classed as contaminated by Arsenic, Nickel, Lead and PAH with concentrations, whilst in place, are not significant although will require cleaning facilities and protective clothing in order to remove risk on a temporary basis to the workforce
Site Remediation Strategy Phase III Page 9 para 3.1
YET AGAIN(!) we have a plan which makes absolutely no reference to the protection of the public on a multi-site development within a high density residential area.

The identified risk based on the information gained suggests that the contamination within the site is likely to cover the whole site and, as such, all areas within the site should be considered as contaminated.....The risk within the site has been identified as within areas proposed for soft landscaping where excavation of the areas should be undertaken to remove the risk to human health
Site Remediation Strategy Phase III Page 9 para 3.1

The Remediation Strategy is incomplete as to proposed areas requiring excavation/remediation.  Paragraph 3.2 refers to a non-existent Table 1

Measures to remediate soil include:
  • Half a metre of soil needs to be removed under the communal areas of soft landscaping
  • 0.9 metres of soil should be removed from the area of private gardens due to the scope for people  to use the gardens to grow vegetables for eating.
  • All excavation sites will need to be photographed to provide evidence of the depth of the soil removal
  • After removal of soils, new soil will need to be imported and the quality of the imported soil will need to be tested.
For some unknown reason no bore holes were sunk in Brokesley Street and this is not identified as a site.  In fact it's unclear whether it has even been investigated.  The area at the rear will be used for gardens and may well also need to be excavated.  We'll be commenting on this aspect in our formal comments on the planning submission and in relation to the disturbance of the roots of the very old lime tree. 

Land Gas:  Testing is ongoing and there are no proposals as yet. 

Foundations: The report recommends foundations of at least a metre.  This is because large parts of the site are covered by rubble.  One can speculate that this might either be due to bomb damage during the war (ie the reason why large parts of Tower Hamlets have newer housing)

Capping is identified as an effective way of dealing with the sites which will be built on.

Decontamination Facilities:   Washing/cleaning facilities are to be provided attached to the office facilities for all contractors and visitors.  Everybody will be required to wash and decontaminate clothing/boots before departing from the contaminated sites

It's unclear how they get to the washing/cleaning facilities along public streets and pavements to get to the cleaning facilities for the decontamination.  Perhaps the expert advisers don't think it matters if the streets and pavements are contaminated with whatever has to be removed by cleaning? We think it does!

Site Verification Plan:  Telford Homes are to prepare a site verification plan according to Model Procedures for the Management of Contaminated Land as required by the HESI
It's entirely unclear whether this site verification plan has been prepared and completed prior to the opening of the Recipe Street Garden - a site identified as requiring remediation works.
We're not happy with the cavalier approach to Site Remediation Works demonstrated to date.  Having met with the Planners last Friday, we're happy that planning conditions can contain the contamination.  However we're not happy that actions to date have complied with the proposed actions for a Remediation Strategy.  Mile End Residents Association will be making detailed comments to Tower Hamlets Planning. 

One issue we intend to focus on is the quality control over and the validation of remediation works prior to new soft landscaping being opened to the public.  We will want to know how exactly the Recipe Street Garden has complied with the plan and, if necessary, we will be asking for an Enforcement Investigation.

Commenting on the proposal to meet the planning condition

MERA will be submitting a formal comment on the quality of the investigation , the report and the proposals

You also have the right to comment if you so wish.  

If you want to comment on the current planning submission PA/10/01093 - Approval of Details - Site Remediation you can do so by commenting online here Comment On Application or by writing to the Council

We suggest you read the documents first

The deadline for comments is 28th June 2010.

If you have any queries please contact MERA
If you have a comment please leave it below
Email MERA with photographs of your concern

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