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Good Afternoon
All
To
set the scene:
“I
have a former military site which has outline permission under which I have
imposed our standard condition:
Prior to the commencement of the works hereby approved, a
detailed site investigation shall be undertaken to establish whether the land
(which includes any surface or ground water present on or under the site) is
contaminated. Details of the method of the proposed investigation must be
agreed in advance, in writing, with the local planning authority. The
results of the said investigation, including details of any contamination
present, shall be submitted to the planning authority together with a scheme of
remediation works to address those areas. Timescales shall also be
submitted. The proposed method of remediation must be approved in writing
with the planning authority before remediation can commence. The approved
scheme shall be carried out in full to the satisfaction of the Authority within
the agreed timescale. Upon completion of the remediation scheme, a
further survey of the affected areas shall be carried out by the Applicant and
a report including the results must be submitted to the Authority.
Should the Planning Authority decide that further
remediation works are necessary, both parties will agree, in writing, what
additional clean up works are required together with an appropriate timescale
for these works. Upon completion, the Authority needs to be satisfied
that pollutants or their effects have been adequately identified.
All investigations and analysis must be carried out by
suitably qualified and experienced persons.”
This includes
the requirement that the proposed investigation must be approved in advance
together with a scheme of remediation. However, the initial intrusive
investigation carried out did not match the proposals put forward beforehand
and did not fully characterise the site. Since then there has been a lot
of dialogue about the proposals for future investigation work which is still
flawed.
More
recently a further detailed planning application has been submitted and I have
been asked for my comments. Rather than continue the dialogue back and
forth about the proposals for further investigations, I would like to impose a
more specific condition. Has anyone done so in the past? The problems
are:
Insufficient sampling points
An unjustifiable screening level for TPH
Insufficient tests taken to produce statistically significant
results for PBET tests for Arsenic.
TPH by Risk assessment model - Flawed use of toxicology
relating to equivalent carbon bandings to try and produce SSAC for carbon
bandings.
The EA also have concerns that possible contaminants
such as PCBs may be overlooked.
Lack of speciation of PAH
All thoughts
appreciated.
May thanks
in advance
Kay
Kay
Wilcox
Technical
Officer
Health
and Housing
Pollution
Team
Breckland
Council
Elizabeth
House
Dereham
NR19
1EE
Tel:
01362 656334
Fax:
01362 656266
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