Julian,
I would agree with Steve. This is a typical scenario that could be avoided by adequate QA/QC of imported materials, specifically testing prior to import.
To me it would depend on how much material has been imported already. If it's a lot the sustainability angle is likely to come into to play as it would take a great deal of time, money and energy to remove and replace.
I would also take more samples to allow minimal statistical analysis to be applied. If sample mean is still under 2 mg/kg then happy days [do not quote me on this as this is my stick my finger in the air & gut feeling figure at the moment] if its above, then for me, someone is in the deep stuff under the planning regime.
Regards
Dave
David Jackson
Land Quality Officer
Wakefield Council
Communities | Environmental Health
Newton Bar | Leeds Road | Wakefield | WF1 2TX
t 01924 306924
e [log in to unmask]
w www.wakefield.gov.uk/landquality
-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Stephen Moreby
Sent: 01 March 2011 16:32
To: [log in to unmask]
Subject: Re: Benzo (a) Pyrene in imported topsoil
Julian
It's unlikely the soil represents a significant risk to health (in the SPOSH sense) and PPS23 says that's 'the minimum' requirement for new development, but that might not be the right basis to consider the issue.
Is this a 'contaminated' site being redeveloped under planning ? If so is there a remediation strategy, and if so what is the remediation criteria for BaP ? Even if there is a stated remediation criteria of (say) 1.0ish, I wouldn't automatically refuse to accept soils at 2.0ish - but I would ask the developer to justify why they believe it's acceptable to exceed their own remedial criteria. I'd also 'have a chat' about their QA/QC processes.
I had a similar situation a few years ago, and I asked the developer to justify their proposals in detail (including considering the amount of data they had and ALARP issues), but to be fair they did so, and I accepted BaP numbers around the values you're talking about. There were already people occupying the properties though, and the harm caused by going back in to replace soil would have been significant!
In an ideal world the Remedial Strat would describe what should be done in the event of a validation failure - additional sampling, DQRA, remove and replace etc. Most don't, and I suppose therefore it's subject to discussion.
Interested to hear any other views.
> Steve Moreby
> Contaminated Land Officer
>
> Environmental Health and Regulatory Services
>
> Gloucester City Council T 01452 396 312
> Herbert Warehouse F 01452 396 340
> The Docks
> Gloucester
> GL1 2EQ
>
> [log in to unmask]
> www.gloucester.gov.uk
-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Julian Puzyna
Sent: 01 March 2011 15:55
To: [log in to unmask]
Subject: Benzo (a) Pyrene in imported topsoil
Hello everybody
I am in a typical situation where soil that was imported to a site has turned out to contain excessive concentrations of our old friend BaP. The suppliers testing was pointless and probably referred to a sample that was tested years ago.
The problem is that the concentrations were not huge, only two samples have been tested so far giving concentrations of 1.23mg/kg (SOM=6.6%) and 2.06mg/kg (SOM=4.8%). Double ratio plots on the results indicate a coal ash source (more results are needed to confirm this) however this does not help define a site specific value for this site.
These concentrations on their own are enough for me to advise that the soil should be removed but is this the best course of action?
Julian Puzyna
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