What I think is being said is that SGV is based on the no observable
adverse effects concentration in soil. However, as Neil points out with
reference to the CLAN document, this does not equate to the legal
definition of serious harm in Part IIA. The SGV is much lower than the
level indicative of serious harm.
An Authority would be on shaky ground if it were to determine a site as
contaminated under part IIA because the contaminant concentration is
>SGV. It would have to be >>SGV to fail the legal test. However, there
is a tendency to play safe and adopt the SGV as the remedial target when
new development is being considered. This leads to a dual standard and
much uncertainty. The $64,000 question is just how far above SGV is
significant harm?
The concept raised by Steve is to acknowledge this and one of the ways
around it would be to create two levels, a level below which there is no
effect (SGV) and a level above which there would be significant harm.
The in between values would offer scope for setting a remedial target
taking into account other factors as well as just the number in the
table. Like, has anyone on the adjacent site actually suffered arsenic
poisoning so far?
We could call these two levels "trigger" and "action", but that would be
taking the P.
It is a serious problem, and one which BaP has highlighted. This is only
because BaP is trendy as a risk driver. There are many other substances
that are even "worse" than BaP and as we get used to looking at these
the problem will only get more acute. I wish the SGVTF the best of luck
in finding a way out of this.
Regards,
Kevin Privett.
Dr Kevin Privett
Principal Geo-Environmental Consultant
Hydrock Consultants Ltd
Over Court Barns
Over Lane
Almondsbury
Bristol
BS32 4DF
Tel: (01454) 619533
Fax: (01454) 614125
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-----Original Message-----
From: Contaminated Land Management Discussion List
[mailto:[log in to unmask]] On Behalf Of Neil
Parry
Sent: 06 February 2006 16:35
To: [log in to unmask]
Subject: Re: CLEAR GUIDANCE SOUGHT ON SOIL GUIDELINE VALUES
Steve
I don't agree with this note. The current situation with SGVs and Part
IIA is set out in Defra's CLAN2 document:
http://www.defra.gov.uk/environment/land/contaminated/pdf/Clan2-05-SGVs.
pdf
I think it would be dangerous to assume an SGV for BaP of 1mg/kg.
Do others agree?
Neil Parry
-----Original Message-----
From: Contaminated Land Management Discussion List
[mailto:[log in to unmask]] On Behalf Of Steve
Mather
Sent: 06 February 2006 15:15
To: [log in to unmask]
Subject: CLEAR GUIDANCE SOUGHT ON SOIL GUIDELINE VALUES
Dear All,
The following is an extract from the Eversheds Environmental Briefing
for
January 2006.
I don't recall seeing any announcements about this review?
"CLEAR GUIDANCE SOUGHT ON SOIL GUIDELINE VALUES
Following problems relating to the determination of sites by local
authorities
based on existing pollutant thresholds, it has been confirmed that a new
draft
of SGVs is being complied by the SGV task force set up by the Cabinet
office
and DEFRA. These will include values for both asbestos and
benxo-a-pyrene
(BaP), neither of which currently have SGVs.
In the absence of SGVs, local authorities have had to fall back on the
contaminated land exposure assessment (CLEA) model. This sets a limit of
1mg per kg of soil for BaP, which has caused problems since the level is
so
conservative that it has been said that almost half of gardens in the
country
would probably obtain results higher than this threshold.
It has been hinted that there is likely to be a band of values for the
new
SGVs
where greater care has to be taken."
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