Developing on Brownfield sites (land with a previous industrial used) is a key priority of the government regeneration policy, and as a result much of Doncaster’s contaminated land is being remediated (cleaned up) via the planning process.
Land contamination is an important planning consideration for new developments. The guidance for planning authorities on contamination is contained in Planning Policy Statement: Planning and Pollution Control (PPS23). PPS23 states land for development needs to be suitable for its proposed use, and if contamination is such that it may cause harm the potential risks must be identified and appropriate remedial steps taken to address the situation. If a site is believed to be contaminated Doncaster Council will apply conditions to planning consents to ensure the site is investigated and if, required, remediated and that any such works are validated.
The below information has been produced to provide developers with a general guide to what is expected from them should they choose to develop a site which may be contaminated in the Doncaster Borough.
Where development is proposed on a site that is known to be contaminated, or where contamination is likely to be present because of its existing or previous use, a Land Contamination Assessment should be submitted, in the form of a Phase 1 Desk Study and Phase 2 Site Investigation Report as defined below. Depending upon the findings of the Land Contamination Assessment it may be appropriate to submit a Remediation Strategy and Validation Report, these are also defined below. Applicants should consult the current government guidance and, or may wish to contact the Pollution Control Section for further clarification of what is required.
Where a sensitive end use such as; housing, schools, nurseries, allotments, children’s play areas and playing fields, the application should be supported by a Contaminated Land Assessment in the form of a Phase 1 Desk Study, as defined below. Depending upon the findings of the Land Contamination Assessment it may be appropriate to submit a Phase 2 Site Investigation Report, Remediation Strategy and Validation Report.
Where minor/household applications are not supported by a Contaminated Land Assessment sufficient evidence must be provided to indicate that there is no contamination likely to be present on the site.
Site location, description and plan
Site walkover to identify if there are any obvious signs of contamination with photographs of potential problem areas
Planning history for the site
Coal, mining and quarry works for the vicinity
Site specific Environment Agency information e.g. groundwater abstractions, pollution incidents, water quality classification, landfill sites.
Previous site use from 1850’s to date, including changes in land/building usage
Review of surrounding land use
Geology, topography, hydrology for the site and adjoining land
Details of any storage tanks on or under the site
Local Authority information on private water supplies, Part A2/B installations, etc
Review of previous site investigation works/remediation works
Conceptual Model outlining actual and potential risks, identifying all source, pathways and receptors
Review of limitation and uncertainties of model
Recommendations and conclusions
The information listed above is the minimum that is expected and reports that do not include this information will be returned for further works to be done.
If the Phase 1 indicates a risk of contamination then a Phase 2 investigation will be required.
Overview of Phase1
Site description and map
Intrusive sampling strategy in accordance with BS10175, including:
Sampling methodology with justification for sampling points/depths and period
Sample location map
Analytical strategies and justification
Details of quality assurance and accreditations
Comprehensive discussion of contamination found, including:
Visual, olfactory, analytical and monitoring data
Full characterisation of ground conditions (soil, gas, water)
Qualitative and quantitative risk assessment based on proposed development to include an appraisal of actual and/or potential contaminated sources, pathways and receptors taking into account likelihood of occurrence. The contaminated land exposure assessment (CLEA) model and its associated soil guideline values (SGVs) should be used to determine which contaminates pose a unacceptable risk to human health, similar appropriate guidance should be used for the protection of controlled waters and other ecological receptors. The use of ICRCL for risk assessment purposing will not be accepted. Non UK risk assessments tools will be considered on a site-specific basis but must be adapted to be comparable with current UK guidance
Revised conceptual model
Recommendations: this maybe for further intrusive investigation, or clear details of proposed remediation, both must have clear time scales.
The information listed above is the minimum that is expected and reports that do not include this information will be returned for further works to be done.
It may be possible to combine the Phase 1 and 2 reports however they should be separate sections as listed above with a Phase 1 and Phase 2 review.
If the Phase 2 sampling results and updated risk assessment indicate a risk from contamination a remediation strategy must be submitted with the planning application, demonstrating how the site will be made ‘suitable for use’. General recommendations made in the Phase 2 report are not an acceptable substitute for a remediation method statement.
Aims and objectives of the remediation works
Details of required remediation, including proposed site clean up criteria,
Site management and contingency procedures for dealing with unexpected contamination
Review of remedial options with the preferred option(s) justified by cost-benefit analysis
Details of environmental and amenity controls, protective and/or monitoring measures, e.g. dust, mud, noise and odour
Timetable of works including scale of contamination to be remediated with plans and drawings
Details of required consents and, or licenses
Specific detail should be provided for any gas protection measures, cover/capping systems and protection measures for service pipes/cables
Where dig and dump is used the quantity of material taken from site should be declared with details of disposal including waste transfer notes
Details of validation to demonstrate remedial objectives have been met, including:
Once remediation has taken place a validation report must be submitted to confirm the objectives of the works have been met and that the site no longer poses an unacceptable risk to human health or the environment.
This report should include evidence with discussion on substantiating data to confirm that the works agreed in the approved Remediation Strategy have been implemented. Any significant deviations from the approved Remediation Strategy (e.g. due to unexpected contamination) must be included in this report.
If post remediation monitoring / validation indicates a problem then further investigations should be undertaken and additional remediation maybe required.
If you would like any further advice please contact:
Doncaster Council Pollution Control
PO Box 257
Council House
College Road
Doncaster
DN 1 1RN
Telephone 01302 737579
E-mail geraldine.annis.potter@doncaster.gov.uk
Disclaimer: This information is intended to serve as an informative and helpful source of advice. It should be noted that legislation, guidance and practical methods are subject to change, this infomation should therefore be read in conjunction with the most current and appropriate guidance and legislation.