Hi Matt



I like Roberts suggestions.  As far as ALARP is concerned the P stands for practical not possible, so from a sustainability point of view I think there is a bit of overkill and I would suggest that while a precautionary approach is always welcomed, if the level of risk does not suggest a danger to human health why support that level of remediation?  If it relates to planning application with submitted report in support, than probably no need to go for the site investigation condition, based on this information alone. If submitted in support of existing site investigation condition, I would be happy to recommend discharge.



Simon Downs MPhil.DIC M.CIWEM

Contaminated Land & Private Water Supply Officer



Environment & Neighbourhood Quality

East Hampshire District Council, Penns Place, Petersfield, GU31 4EX

01730 234332

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-----Original Message-----

From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Robert Tyler

Sent: 23 November 2016 11:03

To: [log in to unmask]

Subject: Re: Lead - Using allotments “low” risk criteria as a “minimal” risk criteria for residential



Hi Matthew,



With such situations I'm always slightly cautious about saying that the developer shouldn't undertake the recommended remediation as it is up to them based on their consultants advice and broadly it is for the regulator to ensure that a scheme is fit for purpose - this scheme is obviously more than fit for purpose!



In such situations I do usually point out to developers where a scheme may be excessive and suggest that they may want to seek clarification in terms of screening criteria and/or the approach to remediation and that this could result in cost savings.



Thanks



Robert



Robert Tyler

Principal Pollution Control Officer - Land, Air & Water



London Borough of Hackney

Health and Community Services

PO Box 70210

E8 9EJ

Tel: 020 8356 4827



For further information on Land, Water and Air issues see:  http://www.hackney.gov.uk/pollution-2.htm



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2. Relating to Planning and Olympics Issues: The responsibility to properly address contaminated land issues, including safe development and secure occupancy, and irrespective of any involvement by this Authority, lies with the owner/developer of the site.



-----Original Message-----

From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Matthew Axton

Sent: 23 November 2016 09:58

To: [log in to unmask]

Subject: Lead - Using allotments “low” risk criteria as a “minimal” risk criteria for residential



Hi All,



Following on from the conversations around RMS last week -



I have a consultant submitting reports in my LA area who is quoting the S4ULs and C4SLs in their reports as usual, but, when nothing exceeds the usual screening values, they state the following - "One of the samples tested was above the most conservative associated UK criteria for lead but was below the C4SL criteria for residential land use." - max value was 130mg/kg.  They made a similar statement for BaP - "One of the samples tested was above the most conservative associated UK criteria for benzo(a)pyrene but was below the LQM and C4SL criteria for residential land use." max value was 0.94mg/kg.  There are also very low levels of Total TPH in a couple of locations (maximum 97mg/kg).   I should say that the site is residential, 11 samples were tested in total, and the consultant has recommended site wide remediation and 600mm clean cover.



When I asked for clarification on these "most conservative associated UK criteria", I was told that: "We have adopted the C4SL allotments “low” risk criteria of 80 mg/kg in soil as the “minimal” risk level criteria for residential, which represents a precautionary approach".  No clarification was received on the BaP.



I've not seen any other consultant take this approach and I personally think that it is scientifically flawed as the exposure pathways to calculate the allotment and residential settings are not directly transferable.  I thought I would see what the industry thinks before I respond...



Thanks in advance,



Matt





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