Environmental Protection Unit Contaminated Land Inspection Strategy London Borough of Hillingdon Contaminated Land Inspection Strategy, 2001 Executive Summary Part IIA of the Environmental Protection Act 1990 provided a new statutory regime for the identification and control of contaminated land. Local Authorities have a duty to produce a written inspection strategy for the identification of contaminated land within their area. Following the consultation on the draft inspection strategy revisions have been made to create this strategy document to be adopted by the Council as of July 2001. The presence of a contaminant on land does not always mean that the land will be identified as contaminated land within the Council’s inspection strategy. For a piece of land to be identified as ‘contaminated land’ all of the following elements have to be identified: Source: a contaminant, which is in, on, or under the land that has the potential to cause significant harm to a receptor; Receptor: a target for the contaminant, these include living organisms, controlled waters, ecosystems, and property; and Pathway: one or more routes by which a receptor can become exposed to a contaminant. The main purpose of this inspection strategy document is to outline how the Council will identify areas of the Borough where both receptors and contaminants are present and determine the likelihood of significant harm or the pollution of controlled waters being caused via a particular pathway. The Environmental Protection Unit (EPU) will be responsible for implementing the Council’s contaminated land inspection strategy and to carry out its contaminated land enforcement duties. The Council will work in partnership with external agencies and other interested parties, whenever possible, in dealing with the issue of identification and remediation of contaminated land. A corporate approach will be taken in dealing with remediation and regeneration of contaminated land to ensure that objectives on sustainability are met. The first step towards this was the consultation on the draft inspection strategy document. The land within the London Borough of Hillingdon has a great diversification of use, from agriculture to aviation. There are large residential areas, recreational areas, areas of surface and groundwater, a number of important nature sites, good quality agricultural land, ancient monuments, listed buildings, and educational and commercial areas within the Borough that are ‘receptors’ and need to be protected. The Council’s priorities in relation to contaminated land are listed below in priority order. The Council’s Priorities for dealing with Contaminated Land: 1. To protect human health 2. To protect controlled waters 3. To protect designated ecosystems 4. To prevent damage to property 5. To prevent any further contamination of land 6. To encourage voluntary remediation 7. To encourage re-use of brownfield land As part of the inspection strategy, data is being gathered on receptors and potential contamination sources from internal records and external bodies. All of the information gathered is being evaluated and stored by a computer mapping system, known as Geographical Information System (GIS). The information will be assessed to find out where i London Borough of Hillingdon Contaminated Land Inspection Strategy, 2001 contaminated land might exist in the Borough and determine the risks, using Agency and Government guidance. For detailed risk assessment work specialist environmental consultants will be used. The GIS database will eventually record all contaminated land information in the Borough. Within its statutory duties the Council must identify contaminated land that may be a special site for which the Environment Agency is the enforcing authority and provide regular information to the Agency for their national report on contaminated land. The Agency has statutory duties to provide the Council with guidance to assist the Council in it’s contaminated land duties. Therefore, a close co-operation between the Council and the Agency is proposed in this strategy document. The general steps involved in carrying out inspection strategy discussed in this document are summarised below. General Steps of the Contaminated Land Inspection Strategy: 1. To identify areas of land within the Borough that may be contaminated by reviewing historical land use, carrying out site investigations, risk assessments etc.; 2. To formally designate contaminated land and special sites (where the Environment Agency is the enforcing authority); 3. To bring about the remediation of land so that it is “suitable for use” through voluntary remediation wherever possible, and by serving remediation notices; 4. To maintain a public register containing contaminated land information; 5. To review the possibly contaminated/previously investigated areas and the inspection strategy from time to time in light of new information; and 6. To provide the Environment Agency with local land contamination information. The Council is proposing a rolling inspection programme for the identification of contaminated land over a five year period, commencing in July 2001, looking at urgent sites, Council owned land and controlled waters. The Borough has also been split into 4 areas to be systematically inspected over a four year period, starting in January 2002. The time estimates will be reviewed dependent upon the amount of contaminated land found in the Borough. The inspection programme will be implemented in a rational, ordered and efficient manner. Transparency in the implementation of the strategy will be achieved by publishing the strategy document, keeping a public register and providing information on request subject to the Environmental Information Regulations (1992). The Council has a duty to use the Part IIA legislation to secure the remediation of contaminated land. The Government’s intention is that any remediation required under Part IIA ensures that the land is ‘suitable for use’. Therefore the Council must ensure that the circumstances of any land are such that, in its current use (as defined in the guidance) it is no longer contaminated land, and the effects of any significant harm or pollution of controlled waters are remedied. It is always open to the person responsible for the contamination (appropriate person) to carry out remediation on a broader basis for redevelopment. Hillingdon has historically had a number of contaminative land uses including a diverse range of industries, mineral extraction and waste disposal by landfilling. A number of sites have been successfully remediated and redeveloped in the Borough in the last 25 years. It is the aim of the strategy to continue in a similar manner by encouraging the voluntary remediation, redevelopment and regeneration of contaminated sites to make the Borough environment “clean, healthy, stimulating and sustainable” for the people of Hillingdon. ii London Borough of Hillingdon Contaminated Land Inspection Strategy, 2001 Acknowledgements Thank you to all the people both within the Council and externally, who provided advice, information and consultation responses to help the Environmental Protection Unit write this strategy. Thanks are due to Alistair Norton and Nicky Ingrey of the North-east Thames Branch of the Environment Agency, and Richard Wood and the other members of the West London Contaminated Land Group for their support during the drafting of the strategy. Special thanks to Library Services, Planning Services and Corporate IT/Map Research for providing information and technical support during the drafting of the strategy. In particular, Carolynne Cotton, Gwyn Jones, Jayn Newman, Mike Gill, Mike Kraus, Andrew Scate and Fung Yee Cheung. iii London Borough of Hillingdon Contaminated Land Inspection Strategy, 2001 Table of Contents Executive Summary i Acknowledgements iii Table of Contents iv List of Figures vi List of Boxes vi List of Maps vi Chapter 1: Introduction 1 1.1 Part IIA of the Environmental Protection Act (1990) 1 1.2 The London Borough of Hillingdon 2 1.3 Implementation of the Legislation 3 1.4 Land use Planning Policies 3 1.5 Development of the Strategy 3 1.6 Involvement of Community Groups, Businesses and Others 3 1.7 Strategic Approach to Inspection 4 Chapter 2: Characteristics of the London Borough of Hillingdon 6 2.1 About the Borough 6 2.2 Current Land use Characteristics 7 2.3 Industrial History 7 2.4 Nature Conservation Areas 8 2.5 Protected Property 9 2.6 Groundwater and Surface Water Protection 10 2.7 General Geological and Hydrogeological Characteristics 10 2.8 Areas of Naturally Metal Enriched Soils 11 2.9 Details of Local Authority Ownership of Land 11 2.10 Known information on Contamination and Remedial action already taken 12 2.11 Redevelopment History and Controls 13 Chapter 3: Aims, Objectives & Priorities of the Inspection Strategy 15 3.1 Aims of the Strategy 15 3.2 Objectives 15 3.3 Milestones 17 3.4 Review of work already done 18 3.5 Inspection Programme 18 3.6 Dealing with Urgent Sites 20 3.6.1 Council Owned Land 20 3.6.2 Threat to Controlled Waters 20 3.7 Priority Order of Inspection 20 3.8 General Priority Actions of the Council 21 Chapter 4: Information Collection, Evaluation and Management 22 4.1 Information Collection 22 4.1.1 Information of Potential Receptors 22 4.1.2 Information on Sources of Potential Contamination 22 4.1.3 Gaps in Information 22 4.2 Information and Complaints 25 4.2.1 Anonymously supplied Information 25 iv London Borough of Hillingdon Contaminated Land Inspection