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Inspection Strategy For Contaminated Land Inspection Strategy for Contaminated Land – Reviewed July 2006 Regeneration Directorate Public Health & Environmental Protection Division CONTAMINATED LAND INSPECTION STRATEGY First Published June 2001 Revised July 2006 Next Revision July 2007 Inspection Strategy for Contaminated Land – Reviewed July 2006 CONTENTS Page No. 1. INTRODUCTION 1. 1 1. 2 1. 3 1. 4 General Policy of the Local Authority. Regulatory Context. Development of the Strategy. Objectives of the Strategy 1 5 8 9 2. CHARACTERISTICS OF THE CITY 2. 1 2. 2 2. 2. 4 2. 5 2. 6 2. 7 2. 8 2. 9 Geographic location, history and description, population distribution. Current land use characteristics. Key property types. Hydrogeologial/key water resource/protection issues, broad geological characteristics. Current knowledge of land contamination. Ground investigations on privately owned land. Specific local features. Redevelopment history and controls. Industrial history of the City. 10 11 13 15 21 21 23 23 26 3. AIMS OF THE STRATEGY 3. 1 3. 2 3. 3 3. 4 The City Council’s priorities. Current Investigations and Remedial Actions.

Identification and prioritisation of ‘unknown’ sites. Liaison and information exchange. 27 28 33 35 4. PRIORITY ACTIONS AND TIME SCALES 4. 1 4. 2 Site Prioritisation Complaints 36 36 5. PROCEDURES 5. 1 5. 2 5. 3 5. 4 5. 5 Internal management arrangements for inspection and identification. Consideration of City Council owned land. Information collection. Information and complaints. Information evaluation. 37 37 37 38 40 6. LIAISON AND COMMUNICATION STRATEGIES 6. 1 6. 2 6. 3 Statutory Consultees. Communication with owners, occupiers and other interested parties.

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Communication following site specific investigations. 41 41 42 Inspection Strategy for Contaminated Land – Reviewed July 2006 7. PROGRAMME FOR INSPECTION 7. 1 Arrangements for carrying out detailed inspections. 42 8. REVIEW MECHANISMS 8. 1 8. 2 Triggers for undertaking further investigations at sites. Review of the Strategy Document. 46 46 9. INFORMATION MANAGEMENT 9. 1 9. 2 9. 3 9. 4 9. 5 9. 6 9. 7 General principles. The Public Register. Administration. Use of information by other City Council Divisions/Directorates. Confidentiality of Information. Dealing with requests for information.

Provision of information to the Environment Agency. 47 47 47 47 48 48 48 49 49 49 49 REFERENCES LEGISLATION AND GUIDANCE STATUTORY CONSULTEES OTHER NON-STATUTORY CONSULTEES Inspection Strategy for Contaminated Land – Reviewed July 2006 1. 1. 1 INTRODUCTION Newcastle City Council is required to inspect its district for contamination under the provisions contained in Part IIA of the Environmental Protection Act 1990. This document sets out how the Authority will take a “strategic” approach to the inspection of its area and reviews the previous inspection strategy published in June 2001.

The City Council’s corporate policy towards land contamination is contained in a number of policy documents; these can be summarised as follows:• The City Council’s ‘Visions and Values’ sets the priorities for the organisation. The main is to create a vibrant, inclusive, safe sustainable and modern European city. This will be achieved by building on the heritage, cultural and economic strengths of Newcastle and a sense of identity and civic pride. Improve the quality of life for the people in our communities and play a leading role in the sustainable growth and prosperity of the region.

The objectives of this policy relevant to the input of land contamination involve the following specific deliverables: Build and support safe and clean neighbourhoods and communities while managing the environment effectively and sustainably. Create and attractive city for people today and tomorrow, with a welcoming natural and built environment and an accessible transport system Work to improve all housing, health and well-being across the city and promote inclusion and equality, and seek to help those individuals and communities most in need.

The Values – the way we will work to pursue these aims are: Be open, accountable, listening and responsive Put the customer and citizen at the heart of everything we do, delivering services in a caring and sensitive manner Manage resources in a coordinated way and with an emphasis upon sustainability Value the contribution of partners, employees and citizens, trusting each other and working collaboratively. See diversity of our people and communities as a strength Focus upon continuous improvement in the pursuit of excellence, setting and achieving clear prioritise and embracing new opportunities. The Newcastle Plan sets out the long term plans for making the City a modern prosperous and vibrant place to live. Crucial to the plan are regeneration programs through Local Neighbourhood Renewal Strategies focussing on six key themes; land contamination work inputs to two of these to improve health and social care and the environment. The plan contains two main parts, the Local Neighbourhood Renewal Strategy which says what will be done to improve three areas – the ‘East End’, ‘West End’ and ‘North and Outer West’. The second part of the plan called the ‘Community Strategy’ details what will happen in other areas of the City • The emerging Sustainability Charter for Newcastle upon Tyne measures sustainability in three broad fields of the economy, the environment and social issues. Land contamination inputs through the positive encouragement of the use of “Brownfield Sites” for future building of both houses and industrial/office use. More specifically inputs are through: For the good of society through; improving health and well being while reducing inequalities in health, ensuring that everyone has the opportunity of living in a decent affordable home For the environment through; better use of resources, educing the amount of waste, protect and enhance the quality of the City’s ground and surface waters, the protection and enhancement of biodiversity, protection and enhancement of the quality and diversity of the City’s rural and urban land and landscapes. For the economy through; ensuring high and stable levels of employment so everyone can share and contribute to general prosperity and achieving high and sustainable levels of economic growth. The Newcastle City Council Environmental Policy will deliver the environmental aspects of the charter, those relevant to land contamination are: Making better use of resources.

Reducing the amount of waste and increasing the amount recycled. Protecting and enhancing the quality of the City’s ground and surface waters Protecting and enhancing the City’s biodiversity. Protecting and enhancing the quality and diversity of the City’s rural and urban landscapes. • The Best Value Performance Plan BVPP is a statutory document in which the council is required to publish all performance information. The BVPP draws together the Corporate Strategic Plan and Cabinet Portfolio information.

It also contains details of all statutory performance indicators (BVPIs) and reports on any review and Service improvement plans. The contribution to the BVPP by land contamination covers such areas as: Remediation of contaminated land, promotion of sustainable developments, especially in new developments, environmental impact assessments for childrens play areas, schools and nurseries, working with Newcastle University on research projects and providing advice on new developments. Best Value Performance Indicators.

There are two BVPIs which relate to land contamination, these were published in 2005 and have a first reporting date of 31 March 2006. BVPI 216a details ‘the number of sites of potential concern’ which have been found. These sites can be either found via the Contaminated Land Inspection Strategy or through the development control process. The figure is composed of the total number of sites we are aware of, • 2 where detailed information is not yet available and the number of sites where such information is available.

BVPI 216b is the number of sites where sufficient detailed information is available to decide whether remediation of the land is necessary, as a percentage of all ‘sites of potential concern’ • The City Council’s ‘Unitary Development Plan’ encourages the re-use of contaminated land, recognising its contribution towards urban regeneration and reduction in the need to use new sites outside the built up area. The plan places conditions upon the development of such ‘brown field’ sites requiring site investigations and agreed remediation strategies.

Current Government Policy requires that 60% of new developments will take place on ‘Brown field’ sites by 2008. The City is currently achieving a figure of over 80% The Local Development Framework will gradually replace the UDP over several years. The LDF is not a single document, but a folder or portfolio, breaking the plan down into a number of Local Development Documents LDDs which can be individually produced, monitored and renewed to respond more quickly and flexibly to changing circumstances and needs.

There are two types of LDDs: Development Plan Documents (DPDs), which are form parts of the statutory development plan, subject to independent testing by a planning inspector Supplementary Planning Documents (SPDs) which undergo a parallel but simpler and quicker statutory process, and have lower status. They present further information and guidance, and can be reviewed and replaced more quickly. Development Plan Documents will be written in regard of land contamination and other environmental matters.

Enforcement Policy • The City Council has signed the “Enforcement Concordat” produced by the Better Regulation Unit, Cabinet Office. The principles of the Concordat are as follows:The primary function of central and local government enforcement work is to protect the public, the environment and groups such as consumers and workers. At the same time, carrying out enforcement functions in an equitable, practical and consistent manner helps to promote a thriving national and local economy. We are committed to these aims and maintaining a fair and safe trading environment.

The following are the principles of Good Enforcement to which the authority will strive to achieve. • • • Standards Clear standards are prepared and published setting out the level of service and performance the public and business people can expect to receive. 3 Openness Information and advice will be provided in plain language and the rules applied and disseminated as widely as possible. Helpfulness The service will need to be as helpful as possible. Contact names and telephone numbers will be provided and staff will strive for a courteous and efficient service.

Complaints about the Service A clear published complaint procedure has been published. Proportionality The cost of compliance will be minimised as much as possible by ensuring any action taken is proportionate to the risks. Consistency Duties will be carried out in a fair, equitable and consistent manner. Controls are in place to ensure consistency of action. Enforcement Issues in relation to land contamination Wherever possible the authority will try to achieve the remediation of land on a voluntary basis.

This may apply in particular, where:(a) The owner of the land has a programme for carrying out the remediation of a number of different areas of land for which he is responsible and which aims to tackle those cases in order of environmental priority. The land is already subject to development proposals. “The appropriate person” brings forward proposals to develop the land in order to fund the necessary remediation. “The appropriate person” wishes to avoid being served with a “Remediation Notice”. (b) (c) (d)

However where these issues do not apply and the Authority identifies “contaminated land”, a remediation notice will be served when appropriate. Where the land is in the ownership of Newcastle City Council a ‘Remediation Statement’ will be written. Public Access to Information. The Authority will provide information and advice in plain language on the rules which it applies and disseminate these as widely as possible. It will be open about how it sets about its work, consulting business, voluntary organisations, charities, consumers, etc. It will discuss general issues, specific compliance failures or problems with anyone experiencing difficulties notwithstanding these aims. A considerable quantity of information relating to land contamination is held on computers, and the Authority is aware of its obligations under the Data Protection Act 1984. The City Council is required by the Environmental Information Regulations 2004 and the Freedom of Information Act 2001 to supply information where requests for such are made. It is anticipated most enquires regarding land contamination would fall into the definition of ‘environmental information’ and as such would be covered by the former regulations.

Consultation and Involvement of Community Groups and Business The relevant stakeholders were involved throughout the consultation process of the first Contaminated Land Inspection Strategy. Extensive liaison and consultation regularly takes place with relevant stake holders and interested parties on a site by site basis. The Council will ensure that full consultation is carried out before any remedial measures are adopted on sites determined as Contaminated Land through the Part IIA process. 1. 2 Regulatory Context Contaminated land legislation developed since the early 1990’s.

The 1993 White Paper entitled “Paying for our Past”, resulted in the Environment Act 1995 amending The Environmental Protection Act 1990. A further period of consultation followed. Enabling legislation, regulations and statutory guidance finally came into force in April 2000. Statutory Guidance DETR Circular 02/2000 details the Act’s requirements for local authorities to inspect their own areas from time to time for the purpose of identifying contaminated land, provides information relating administration of the new regime and advice as to deciding if land should be classified as a “special site”.

The Guidance requires the Local Authority to take a “strategic approach” to the inspection requirement. The Strategy for Contaminated Land should be:(a) (b) (c) (d) Rational, ordered and efficient. Be proportionate to the seriousness of any actual or potential risk. Seek to ensure that the most pressing and serious problems are located first. Ensure that resources are concentrated on investigating areas where the authority is most likely to identify contaminated land; and Ensure that the local authority efficiently identifies requirements for the detailed inspection of particular areas of land. e) These requirements have prompted the development of this strategy. The Roles of the City Council and the Environment Agency Local Authorities have been given the primary regulatory role under the Part IIA regime. Local Authorities have historically had responsibility for dealing with land 5 contamination as a “statutory nuisance” and are also lead authorities on land use planning. The City Council has a duty: (a) (b) (c) To cause its areas to be inspected to identify contaminated land.

To ensure remediation of contaminated land. To determine whether any particular site meets the statutory definition of contaminated land. To consult the Environment Agency on pollution of controlled waters. To designate Special Sites which transfer to the agency. To act as the enforcing authority for all contaminated land, unless the site meets the definition of a “special site”. “Special Sites” are defined in The Contaminated Land (England) Regulations 2000. For these sites, the Environment Agency acts as the enforcing authority.

To maintain a register of contaminated land remediation. (d) (e) (f) (g) The Environment Agency has a responsibility to: (a) (b) (c) (d) (e) To provide information to local authorities on land contamination. To ensure the remediation of special sites. To maintain a register of Special Sites remediation. To prepare a report on the state of contaminated land. To provide advice to local authorities on identifying and dealing with pollution of controlled waters. To provide advice to local authorities on the remediation of contaminated land. f) Definition of Contaminated Land Contaminated Land is defined at Section 78A(2) of Part IIA of the Environmental Protection Act 1990. “Contaminated Land” is any land which appears to the Local Authority in which area it is situated to be in such a condition, by reason of substances in, on or under the land, that:(a) Significant harm is being caused or there is a significant possibility of such harm being caused; or Pollution of controlled waters is being, or is likely to be caused. ” (b) 6

Section 78 (5) requires the regulatory authority to act in accordance with guidance issued by the Secretary of State in determining significance and likelihood. Dealing with Contaminated Land If an area of contaminated land has been identified, the approach for dealing with it will be the same regardless of whether the Local Authority or the Environment Agency is the regulator. There are four main stages to this approach. (a) To establish who is the “appropriate person” to bear responsibility for the remediation of the land.

To decide what remediation is required and to ensure that this occurs, through:Reaching a voluntary agreement Serving a remediation notice, if agreement cannot be reached Carrying out work themselves, in certain circumstances. To determine who should bear what proportion of the liability for meeting the cost of the work. To record certain information regarding regulatory action on a public register. (b) • • • (c) (d) Pollutant Linkages and Risk Assessment For a site to meet the definition of contaminated land, a pollutant linkage must be established.

A pollutant linkage consists of three parts:(a) (b) A source of contamination in, on or under the ground. A pathway by which the contaminant is causing significant harm (or which presents a significant possibility of such harm being caused). A receptor of type specified in the Circular 02/2000 Chapter A. (c) SOURCE PATHWAY RECEPTOR The receptors recognised as being potentially sensitive are:a). Human beings – disease, death, serious injury, gene mutation, birth defects or the impairment of reproduction function. 7 b). • • • • • • • c).

Ecological Systems, or living organisms forming part of such a system within certain protected locations such as:Sites of Special Scientific Interest (SSSI’s) National Nature Reserves Marine Nature Reserves Special Areas of Conservation (SAC’s) Special Protection Areas Candidate SAC’s RAMSAR sites Property in the form of buildings – This includes structural failure, substantial damage or substantial interference with any right of occupation. Scheduled Ancient Monuments may be regarded as substantially damaged when the damage significantly impairs the historic, architectural, traditional or archaeological interest.

Controlled Waters – entry into controlled waters of poisonous, noxious or polluting matter or any solid waste. Formally there was no guidance on what constituted ‘pollution’, 2/2000 advised that in the cases of very small quantities of a contaminant it would be necessary to consider what it would be reasonable to require. Section 86 of The Water Act 2003 has now amended Part IIA so that it only applies where ‘significant’ pollution of controlled waters is being caused or there is a significant possibility of such pollution being caused. Property in the form of: Crops e. g. iminished yield, loss of value etc. Produce grown domestically, or on allotments for consumption. Livestock Wild animals which are the subject of shooting or fishing rights. d). e). • • • • Substantial loss occurs where a sizeable proportion of the animals or crops are dead or otherwise no longer fit for their individual use. Food is no longer fit for its purpose when it fails to comply with the provisions of the Food Safety Act 1990. Where diminution in yield or loss in value is caused by a pollutant linkage, a 20% diminutive or loss should be regarded as a benchmark.

A conceptual site model attempts to estimate if the components of source pathway receptor could form a pollution linkage to exist or appear likely to exist; a risk assessment would then be undertaken to determine the likelihood of significant harm being caused. Land can only be determined as being contaminated land where pollution linkage is shown to exist and that there is significant harm or a significant possibility to harm being caused to the receptor. 8 1. 3 Development of the Strategy Local authorities are required to take a strategic approach to inspecting land in its area for contamination.

The statutory guidance requires that the approach adopted should:a) b) c) d) Be rational, ordered and efficient; Be proportionate to the seriousness of any actual or potential risk; seek to ensure that the most pressing and serious problems are located first; ensure that resources are concerned on investigating in areas where the Authority is most likely to identify contaminated land, and; Ensure that the local authority efficiently identifies requirements for the detailed inspection of particular areas of land. e) This strategy aims to fulfil the requirements of the above.

The draft Contaminated Land Strategy was completed in June 2001. Internally, consultation with the Authority’s Contaminated Land Working Party, the Cabinet Member for Environment, Public Health and Safety and the Environment and Public Protection Select Committee was sought. Formal consultation with :- The Environment Agency, English Nature, Ministry for Agriculture, Fisheries and Food, English Heritage and One North East was made. Informal consultation with other bodies, for example Newcastle and North Tyneside Health Authority and Newcastle University was also made.

The final version of the strategy document was published and submitted to the DETR and Environment Agency in June 2001. This current edition was revised in July 2006 1. 4 Objectives of the Strategy The objectives of the Strategy Document are:a) To meet the requirement to produce a Contaminated Land Inspection Strategy. To provide a framework in which the nature and extent of contaminated land within the City can be identified and assessed in a rational, ordered and efficient manner.

To ensure that the most serious problems are dealt with first by a process of prioritisation of potentially contaminated land. To inform stakeholders of the action to be taken by Newcastle City Council to address the problems of contaminated land. b) c) d) 9 e) To lead to the provision of information to the Environment Agency for its report on contaminated land. 2. 2. 1 CHARACTERISITICS OF NEWCASTLE CITY COUNCIL Geographic Location, History and Description, Population Distribution Geographic Location The City of Newcastle upon Tyne is the regional capital of North East England.

It is situated on the north bank of the River Tyne estuary, approximately eight miles from the river’s confluence with the North Sea. The City Council’s administrative area covers some 11,348 hectares and is approximately triangular in shape with the southern boundary being formed by the River Tyne. Brief history and description From the mid eighteenth century until the Second World War industrial development was of immense importance to Newcastle and the North East of England in general. The period of industrial activity was long and reached its height at the beginning of the twentieth century.

The area’s prosperity was centred upon the lucrative coal trade. The river-based economy of the region saw the development of many industries based on the coal industry. In the seventeenth and eighteenth centuries the area became a centre for glass and pottery production. In the first half of the nineteenth century the alkali and general chemical industry thrived on riverbank sites. Later in the nineteenth century, predominantly on riverbank sites, developed the heavy industrial economy which survived until the post-war period.

The three staple industries of the last great industrial period were coal, shipbuilding and heavy engineering (particularly marine and railway engineering and armaments manufacture). It was the importance of the coal industry which led to the development of the Tyne as a major shipbuilding centre and as the area in which railways and locomotive engines were developed. The City was a centre for lead manufacture with at least five lead works located within the City’s boundaries. Lemington Iron Works 10 Armstrong Whitworth’s Elswick Works Population The population of the City is approximately 273,000.

Much of the City Council’s administrative area is covered by mixed land use for industry and housing. There are outlying villages separate from the urban area, principally Throckley, Newburn, Walbottle, Dinnington, Hazlerigg and Brunswick Village. The population of the City has declined over a number of years with the principal cause net outward migration. About half the net loss is long distance and is mainly job related, while the remainder is more local and is principally housing led. The Authority’s ‘Newcastle Plan’ seeks to reverse this process of long term population decline. . 2 Current Land Use Characteristics Much of the City Council’s land area is taken up by residential housing. The City Centre area is mainly occupied by retail and commercial activities, although an increasing number of housing developments are being encouraged. Land scheduled for industrial purposes is situated mainly along riverside areas, principally Walker Riverside and the industrially reclaimed area of Newburn Haugh. Considerable areas of agricultural land occupy the western and northern areas of the district. The airport occupies a large area of land west of Kingston Park.

The Northern Development Area comprising of ‘Newcastle Great Park’ located to the north of Kingston Park is currently under development and is to consist of housing and commercial use on this ‘Greenfield’ site. 11 Newcastle City Council Land Ownership The City Council owns considerable areas of land, details of the holdings are kept in the ‘Land Terrier’, providing a historic record of how the Council has acquired/disposed of land. The holdings consist of housing, highways, recreation and leisure facilities, education and land held for the purpose of regeneration, development and environmental improvement.

These holdings include:117 Schools made up of :16 – Nursery Schools 21 – First Schools 2 – Infant Schools 2 – Junior Schools 52 – Primary Schools 9 – Middle Schools 12 – Secondary Schools 10 – Special Schools 63 Allotment sites. 36 Playing fields (not attached to school premises). 35,486 Houses. Protected Locations (Natural Habitats) It is the City Council’s intention to widen the Biodiversity of its area through a Biodiversity Action Plan (BAP). Newcastle has a wide range of wildlife habitats.

Some have a particular value and are formally recognised at a national, regional or local level. These recognised sites are given special protection. The City Council is committed to promoting proper management and enhancement of nature conservation resources, including the creation of new habitats. This strategy identifies polluted mine water from former collieries as being strategically important for remediation. The treatment of these discharges is intended to be through the creation of a passive wetland treatment system. Wetlands are identified in the BAP as a priority habitat.

Funding has been unsuccessfully sought through the Landfill Tax Credit Scheme to remediate contaminated mine waters from the former Isabella Colliery in Newburn, by means of a reed bed system, it is a long term aim to re-visit this problem and remediate when resources become available Circular 2/2000, Part 3 recognises ‘Harm’ only to receptors listed in Table A of the document. In the case of living organisms and Ecosystems, only two categories of limited protections exist with the City Councils area: Sites of Special Scientific Interest and Local Nature Reserves.

SSSI’s are of national importance for their flora, fauna or features of geological interest, the designation is made under the Wildlife and Countryside Act 1981. Newcastle has five SSSI’s:Big Waters. 12 Brenkley Meadows Gosforth Park Hallow Hill Prestwick Carr There is one Local Nature Reserve designated: Denton Dene. However, a further seven are to be designated shortly, Big Waters, Callerton Pond, Havannah Colliery, Lemington Gut, Paradise Tidal Mudflats Sugley Dene, Walbottle Brickworks and Walbottle/Throckley Dene.

Gosforth Park SSSI In addition to the sites that have received statutory designations there are twentyone sites of Nature Conservation Importance (SNCI’s) and thirty-six Sites of Local Conservation Interest (SLCI’s). Twenty-two ‘Wildlife Corridors’ are also identified within the UDP. 13 2. 3 Key Property Types Property in the Form of Buildings The City Council’s area is predominately urban with ‘buildings’ of residential, commercial and industrial usage being widespread.

The area, being underlain by a previously worked shallow coal field is potentially subject to building damage or ‘building effect’ through settlement etc. Deep mining ceased over thirty years ago Exposed Remains of The Northumberland Lead Works during the Remediation of Byker City Farm and its effect now is likely to be minimal, however, consideration always has to be given to potential mine gas emissions and the potential of subsidence from shallow workings Historic Environment Newcastle has an extensive and generally well preserved historic environment.

Hadrian’s Wall passes east/west through the City and is uncovered in several locations, the original Norman Keep which gave the City its name, is well preserved, as are some sections of the City’s medieval wall. There are approximately 1600 Listed Buildings in the City Council area. The City has nine Conservation Areas:Central Leazes Framlington Place Summerhill Brandling 14 South Jesmond Northumberland Gardens St. Nicholas Hospital Jesmond Dene There are fourteen Scheduled Ancient Monuments:Gardener’s Houses Settlement, Dinnington.

Two Rectangular Camps, Hazlerigg Dewley Hill Newcastle Swing Bridge Newcastle upon Tyne Castle Newcastle upon Tyne Wall Hadrian’s Wall, Vallum and associated works. Salter’s Bridge, Gosforth Old Tyne Bridge Land Arches St. Mary’s Well, Jesmond St. Mary’s Church, Jesmond Blackfriars, the remains of a Dominican Friary The ‘Camera’ of Adam of Jesmond Chapel south of Low Gosforth House. The City Council is committed to investigate and preserve archaeological remains where these are found during the remediation of determined Part IIA sites.

During the remediation of the Byker City Farm site, an archaeological watching brief was employed throughout the works. The remains of the Northumbrian Lead Works have been substantially enhanced during the excavation and will add to the interpretation of the industrial heritage of the Lower Ouseburn Valley Property in the Form of Agricultural Land etc Agricultural lands surround the City on the north and western fringes. The land use is predominantly arable, although some pastoral farming is operational in the southern part of the area. The Town Moor is a central area of moor/grassland surrounded by urban development.

The land is used for both animal grazing and recreation. The Town Moor is owned by the City Council with the ‘herbage rights’ being managed by the Freemen of the City. The Town Moor was the site of historic coal mining operations and has been open cast worked on at least two occasions in the twentieth century. 2. 4 Hydrogeological/Key Water Geological Characteristics Resource/Protection Issues, Broad There are no groundwater abstractions within the area used for drinking water supplies, and therefore no Groundwater Protection Zones have been made by the Environment Agency.

There are two ground water abstractions for industrial use in the north of the area at Brunswick Village and North Gosforth. The ground water level in the coal measures has not yet recovered to its natural state, following the cessation of the Coal Authority’s Minewater Pumping 15 Programme. Groundwater levels are currently rising and it is not known what their eventual level will be. Rising groundwaters could result in the emergence of potentially polluted minewater outlets in the area, or increased flow in the existing outfalls.

The Environment Agency’s Groundwater Vulnerability map for the Tyne & Tees area is classifies the Coal measures underlying the City as a “minor aquifer”. Minor Aquifers have variable permeability, they rarely provide large quantities of water for abstraction but are important for local supplies and supplying base flows of rivers. The “Minor Aquifer” classification is further subdivided in Newcastle, the urban area being classified as “U” and the more rural fringe as ‘low’ A “U” classification gives the aquifer a high vulnerability classification; this is given as fewer observations than elsewhere have been made for the aquifer.

The rural fringe to the City is given the classification “low”, these are of low leaching potential and reflect the area being overlain by drift deposit of boulder clay. This boulder clay also extends under much of the urban area. The Environment Agency’s current policy regarding groundwaters, to only comment on development proposals in Groundwater Source Protection Zone 3, means that they will have little input into such works in Newcastle at the current time. The main watercourses in the area are the River Tyne and the Ouse Burn. The Tyne is tidal throughout the City.

The quality of the tidal estuary is improving and the river supports a large population of migratory salmonoids. The Ouse Burn originates at Callerton Pond and has its confluence with the River Tyne at Byker, the burn is tidal for several hundred metres. It is culverted for 665m where it passes under the City Stadium landfill site. The General Quality Assessment (GCA) shows the burn to be C (fair). There are many smaller culverted streams flowing under the City, some of these are combined with sewer systems, others discharge into the River Tyne. Examples of these urns are Pandon Burn, Skinner Burn, Lort Burn. 16 Pandon Burn Culvert, uncovered during recent construction works, Broad Chare The Construction of the Ouseburn Culvert 1907 17 Broad Geological Characteristics The landscape of the area was shaped before and during the last glaciation and has been modified only slightly since that time. Approximately ninety percent of the area is covered with drift deposits of glacial or later origin. These deposits are principally boulder clays, mixed clay and sand, laminated clays and silts. Sandstone rock outcrops occur at Byker and the ridge between Benwell and Elswick.

The drift geology is shown on figure 1 The solid geology of the area consists of approximately 800m of coal measures resting conformably on the underlying Millstone grit. The coal measures are classified according to the Westphalian stages. The sequence of rocks through the coal measures is rhythmic, with mudstone succeeded in turn by sandstone and coal. The average depth of this cycle of rocks is above twelve metres in thickness, but can be reduced when one of the rocks is either thinner or missing. The solid geology is illustrated on figure 2.

The coal measures have been extensively mined, with the thickest seams almost exploited to exhaustion. For example, the High Main Coal, the thickest and most consistent coal seam in the area is worked to 75-90% extraction rate. The thinner seams are much less worked and there is thought to be potential for further mining, particularly through open cast operations, if favourable economic conditions prevail in the future. Currently there is one open cast coal mine in operation within the City’s boundaries at Fox Culvert in the North of the district. 18 2 1 City_boundaryb. hp Dr ift_G eology Alluv ium (G ravel, Sand and S ilt) Glaciofluvial D eposits , U ndiffer entiated (G ravel, Sand and Silt) Glaciolac ustr ine D eposits, U ndifferentiated ( C lay and Silt) Glaciolac ustr ine D eposits, U ndifferentiated ( Silty C lay) Glacial Sand and Grav el (Sand and G ravel) Head, U ndifferentiated ( D iam ic ton) Lac us trine D eposits, U ndiffer entiated (S and, S ilt and C lay) Peat ( Peat) Pelaw C lay (C lay) Riv er T errace D eposits, U ndifferentiated ( Grav el, Sand and Silt) Till (D iam icton) Tidal R iver or C reek D epos its (C lay, Silt, Sand and G ravel) Dr ift G eology Not M apped ( U nk now n Lithology)

Figure 1. Newcastle upon Tyne. Drift Geology (British Geological Survey) 19 City_boundaryb. shp Solid_G eology Low er Coal M easures Form ation (Undivided C yclic S edim entary R ocks) Low er Coal M easures Form ation (Sandstone) Middle Coal M easures Form ation (Undivided C yclic S edim entary R ocks) Middle Coal M easures Form ation (Sandstone) Mull D yke-S w arm (D olerite) North B ritain P alaeogene Dyke S uite (D olerite) Stainm ore G roup (Mudtone, S iltstone and S andstone) Stainm ore G roup (Sandstone) Upper C oal M easures Formation (U ndivided Cyclic S edim entary R ocks)

Figure 2. Newcastle upon Tyne. Solid Geology (British Geological Survey) 20 2. 5 Current Knowledge of Land Contamination Newcastle City Council, with its legacy of industrial history, had been active in the field of land contamination investigation and remediation for some time. There is extensive information relating to many sites within the Authority’s area. Much of this information has been brought together in the form of a comprehensive database on the Geographical Information System.

Prior to the first Contaminated Land Inspection Strategy, information concerning land contamination was been built up mainly from ground investigations carried out by the City Council itself and from privately funded ground investigations often on areas of land subject to development proposals. The first Contaminated Land Inspection Strategy, published in June 2001 initiated a strategic approach towards the inspection of contaminated land and work has been on-going since this date to both identify sites for inspection and inspect potential sites.

Previous Ground investigations of City Council owned land The City Council owns various sites which have had former industrial or otherwise potentially contaminated uses. There has been an on-going programme to investigate these sites by desk top studies and where necessary intrusive investigation. Some of the investigatory works have been funded within the Council’s existing budget while, others have been funded through DEFRAs Supplementary Credit Approvals and Contaminated Land Capital Projects Programme; Other sites are investigated by developers as part of the process of sale.

Since 1997 the following sites have been investigated by means of DEFRA (and its predecessors) funding:a). City Stadium Site This site is located in City’s Shieldfield Area and was intended for use as an athletics track. The site was a former landfill operating from 1907 until 1951, built over the culverted Ouseburn. The land was partially occupied by the Ouseburn Leadworks prior to its infill. b). Former IRD Site This site is located on the Fossway in the Byker area of the City. It was used as a research and development site for Parsons Engineering.

Prior to its industrial use the land formed part of a larger quarry site, mining outcrops of sandstones at Byker Hill. The quarries were landfilled by Newcastle City Council during the early to mid 20th Century, the waste being incinerated on site prior to disposal. c). St. Anthony’s Tar Works The site is situated on the Walker Riverside Park and was used for the manufacture and distillation of coal tars. Following demolition and partial clearance of the tar works facilities evidence of visible tars and oils together with dissolved hydrocarbons became noticeable in the adjacent river.

The underlying sands and gravels beneath the site have been found to be heavily contaminated with tars and oils. 21 d). Millers Dene This is the site of a former war time and post war landfill site currently used as a recreational field. e). Lower Ouseburn The Ouseburn has a long industrial history which has included, glassworks, lime burning, lead processing, engine manufacture and scrap yards. The investigation concentrated on the Byker Farm area which is situated on the site of the former Northumbrian Leadworks. A window sample borehole being taken at Byker Farm f). Denton Dene Investigation of the landfilled valley of Denton Burn.

The area has been subject to a long mining history and was landfilled during the 1950s and early 1960s. The site is now used for public open space, recreational fields, sports centre, boys club and working mens club. g). Various Allotment Sites Investigation of various allotment sites identified by Newcastle University in their preliminary study of the City’s Allotments which had received ash from the Byker Heat and Power plant. 22 In addition to the investigation of these sites, the City Council also operates a landfill gas monitoring programme at former landfill sites throughout the City Council’s area.

Currently the following sites are being monitored on a monthly basis:Daisy Hill, Walker City Stadium, Shieldfield Denton Dene, Denton Iris Brickfields, Rothbury Terrace, Heaton Throckley Park 2. 6 Ground Investigations on Privately Owned Land Ground investigations are carried out on privately owned land across the City . These may either have been prompted by the owner wishing to know the condition of the land and any liabilities attached to it, or they may be as part of a “risk assessment” of the land prior to development.

In the latter case, where the investigation is prompted by a planning condition, the Authority is provided with a copy of the land report, These reports are also entered onto the Landmark Geographical Information System (GIS) data base. Reports may also be provided where the owner of the land seeks the advice of the City Council. 2. 7 Specific Local Features Information regarding natural geochemistry of soils within the City Council area is limited. The British Geological Survey of Regional Geochemistry North East England, records the Tyneside area as ‘Absent Data’.

However, reference is made to the contribution to regional geochemistry by industrial contamination, stating that levels of copper, zinc, nickel, tin and vanadium are often enhanced. Within the City Council area in addition to the elements cited above, enhanced levels of lead are also recorded, particularly in the areas around former lead works. During much of Nineteenth Century Newcastle was one of the main lead processing centres of the UK. The industry developed primarily due to its proximity to the North Pennine Orefield, a major world producer of lead during the Nineteenth Century.

Some enhanced lead levels may also be due to years of vehicle emissions, previous use of lead paint, lead water pipes, coal fire ash etc. Colliery waste is common within the City Council area, either as original spoil heaps or as landfill where the heaps have been remediated and used as landfill. Raised concentrations of the following elements are often recorded from coal and shales contained in the deposits:- arsenic, beryllium, cobalt, copper, lead, vanadium, zinc, gallium, potassium, rubidium. 2. 8 Redevelopment History and Controls

The City’s economy has changed from one of primarily manufacturing to a service sector industries; this has had a major impact in those areas formerly used for manufacture. These areas were mainly located along the river frontages. 23 Redevelopment of the riverside areas has been carried out by both the former Tyne and Wear Development Corporation and the City Council. In particular the Quayside areas and the Newcastle Business Park form large areas of such redevelopment. Redevelopment of former industrial sites, including collieries has been carried out by the City Council, the former Tyne and Wear County Council and other agencies.

Tyne and Wear County Council operated from 1974 -1986 and redeveloped, Walker Riverside, Newburn Countryside Park, Coronation Pit and Walbottle Waggonway. Redevelopment of a number of former Colliery Sites has been carried out by the City Council; these include Percy Pit, Havannah Colliery and Brenkley Colliery. The Ouseburn Partnership, together with the City Council has been instrumental in the on-going work to the Lower Ouseburn. Tyne and Wear Development Corporation operated between 1987 and 1999 carrying out a number of redevelopment projects including the Riverside Business Park, the East Quayside and St. Peters Basin.

The organisation continued the development of Walker Riverside following the cessation of Tyne & Wear City Council. One North East, the successor of English Partnership and English Estates, remediated Newburn Haugh, one of the largest regeneration sites in the UK. Government targets for development require Local Authorities to achieve 60% of all new developments to be on ‘Brown Field’ sites by 2008. Newcastle City Council is currently achieving around 80%, exceeding its additional LPSA 2001 –2004 target of 75%. Development Controls Development Controls are contained within the City Council’s ‘Unitary Development Plan’.

The following matters are taken into account in determining all applications. • The requirement that where the development plan is material to the application it shall be determined in accordance with the plan unless material considerations indicate otherwise. Government advice given in relevant planning policy guidance, development control policy notes, circulars and ministerial statements. The need for efficiency and speed in the development control process. The general public interest, including public representations so far as they are of importance from a planning oint of view. Any applicable statutory duties and limitations, and Any applicable supplementary planning guidance and development brief. • • • • • 24 Investigation and reclamation of known or potentially contaminated land will be encouraged, particularly where contamination is a constraint to development or causes a known or potential risk to health. The re-use of contaminated land contributes towards urban regeneration. The City Council will encourage the treatment of contaminated land, including the use of derelict land grant.

Planning Policy Pollution (POL6) states:“Developers are required to undertake a thorough site investigation where a site is, or may be contaminated. The investigation must identify the nature of contamination together with the remedial measures required to treat or remove it in accordance with the best practicable environmental option appropriate to the proposed development and the nature of the site. Development will not be allowed to commence until these measures have been completed, unless they are effected as part of the actual development process.

Planning Policy Statement 23 Planning and Policy Control (PPS23) details the national guidelines in regard of development and land contamination. Historic desk top studies and conceptual site models are normally required with planning applications. Developers will normally be required to carry out site investigations of land which is known or suspected to be contaminated prior to planning permission being granted. On land where there is only slight or potential contamination a condition may be imposed requiring site investigations before development begins on site.

In all cases any contamination must be treated or removed prior to development. Chemical and organic pollution will be treated, so far as is possible, on site. Leachate will be prevented from migrating from polluted sites prior to its treatment. Developers will be required through planning conditions to provide a validation report which details the remedial work carried out and has an assessment by a suitably qualified person that the site is sustainably suitable for use. The Building Regulations 2000 Approved Document C makes requirements for buildings in relation to land contamination.

The requirements have been extended to include land around a building in addition to that under it. Remedial measures taken have been expanded to include chemical, biological and physical treatment processes. The Building Regulations are enforced by the City Council’s Building Control Section and where land contamination is an issue staff from the Public Health and Environmental Protection Divisions Contaminated Land Section and Building Control Officers will work closely together to avoid repetition. The City Council’s Newcastle Plan encourages the regeneration of ‘Brown Field’ sites where contamination may be present.

Such redevelopment aids the remediation of ‘contaminated land’ within the City boundaries and develops derelict/under utilised sites. There is close liaison between the City Council’s Planning and Transportation Division and Public Health and Environmental Protection Division concerning planning applications on potentially contaminated land. The Environment Section of Public Health and Environmental Protection views all planning applications made to the Authority. 25 2. 9 The Industrial History of the City Coal has been mined on the banks of the Tyne since at least the thirteenth century.

By the seventeenth century Newcastle was a nationally important town based on the wealth created by the coal trade. From that time, the development of early railways and the building of timber ships to transport coal became major activities of the area. Colliery waggonways and railways leading to the River Tyne became a principal feature of the landscape. By the nineteenth century, however, much of the major coal extraction of the area was taking place away from Newcastle and the river as the South East Northumberland Coalfield was exploited.

Much of the early industrial development of Newcastle took place to the west of the town centre. Early waggonways brought coal to staithes at Lemington. At Lemington there was a concentration of industries which began in the late eighteenth century, including the Northumberland Glass Works and the Tyne Iron Works. At Newburn, industrialisation took place in the mid-nineteenth century fostered by the building of the Newburn, Scotswood and Wylam Railway.

To the east of the town centre the centre of industrial development was in the Ouseburn where the early glass industry had begun in the seventeenth century and the Lower Ouseburn valley became a centre for a variety of steam powered industries. The most significant individual industrial sites within the city were those on the riversides, particularly the mighty Armstrong Works at Elswick and the concentration of shipyards at Walker. Newcastle was one of the most important locations for the manufacture of lead throughout the nineteenth and early twentieth centuries.

The riverside industries of the late eighteenth century and early nineteenth centuries, particularly the Tyneside Chemical industry, were overlain by shipyards, repair yards and engineering works which themselves have now been superseded service industries. F Elswick Lead Works 26 St Anthony’s Lead Works. Walker Riverside 3. AIMS OF STRATEGY The principal and overriding aim of this strategy is to identify land falling within the Part IIA definition of ‘Contaminated Land’ lying within the City’s boundaries, i. e. where a pollution linkage between contaminant and receptor is likely to exist.

It is recognised, both by the City’s industrial heritage and through geotechnical investigations already carried out by the Authority and Developers that significant areas of land with elevated levels of contaminants exist. 3. 1 The City Council’s Priorities The investigation of potentially ‘contaminated land’ sites will be a considerable task. It is therefore logical that resources are targeted at those areas where it is perceived that the greatest risk, or harm, is likely to exist. The Authority will prioritise sites in accordance with receptors and land use, with human health being the highest priority.

The following prioritisation will be followed:1. (a) (b) (c) (d) Human Health Allotments Children’s play areas, Nurseries, First and Primary Schools. Recreational fields, Middle and Secondary schools. Homes with gardens. 27 (e) 2. 3. 4. 3. 2 Agricultural land. Controlled Waters Ecosystems (only SSSIs are relevant in Newcastle) Buildings. Current Investigations and Remedial Actions A number of investigations are on-going and have lead to remedial actions taking place. These actions are largely funded through DEFRA’s Contaminated Land Capital Projects Scheme and are outlined below.

St. Anthony’s Tar Works St Anthony’s Tar Works operated between 1920 and 1981. There have been several investigations of the site and two previous failed remedial schemes, the last being a pumped treatment system developed in 2000. The site is currently being investigated again with an in depth study of ground water movements, tidal variations and contaminate concentrations, quantities and location being carried out as a joint project between Ove Arup and Partners, the City Council and Queens University Belfast.

The site is extremely complex and the current investigation has so far made great progress towards the understanding of these complexities. It is hoped that having completed the site assessment further funding will be available for feasibility for effective site remediation and eventual remediation should this be required/possible. Coal tars entering the River Tyne at the former St Anthony’s Tar Works 28 Drilling investigatory boreholes on the foreshore. St Anthony’s Tar Works b). Millers Dene and Walkergate Nursery School

The site investigation of Millers Dene identified raised arsenic concentrations and potential dangerous exposed landfill materials –glass, sharp items of metal etc in the grounds and play area of Walkergate Nursery School. Action is took place 2001 and the site was validated and is now suitable for use. c). Byker City Farm A site investigation of the former Byker City Farm carried out in 2000 identified heavy metal contamination in the soils of the former lead works which were of such concentration that further investigations were warranted.

In house investigation of the surface soils revealed unacceptably high concentrations of lead in the surface soils and the site was subsequently determined as ‘Contaminated Land’ under Part IIA of the Environmental Protection Act 1990. Funding was successfully applied for under DEFRA’s Contaminated Land Capital Projects Fund and the site was remediated between 2002 and 2004. The site remediation took the form of disposal of contaminated soils from the site and the 29 capping with a gravel capillary break layer, a clay cap and clean top soil.

Extensive archaeological investigations were carried out during the work in an attempt to locate Hadrians Wall and study the industrial archaeology of the site. The site has recently been developed as The Ouseburn Farm and has now re-opened for public use. Former Byker City Farm. Placement of Capillary Break Layer and Clay Cap d). Allotments A number of City Council Allotment Sites received ash from the Byker District CHP which burned waste derived fuel. The ash was used to form paths within the gardens. Analysis of the ash identified raised concentrations of dioxins and heavy metals.

Newcastle University carried out a preliminary investigation of sites which required further investigation and these are now being inspected by the Contaminated Land Team and Newcastle University staff seconded to the section. The investigations have greatly helped the City Council to develop advanced risk assessment methods which have lead it to become a leader in the field of such risk assessment techniques. Should allotments be found where ‘significant harm’ or ‘significant possibility of significant harm’ is identified, then appropriate action will be taken.

Walker Road Allotments and Branxton Allotments were identified for remediation through this process. 30 e). Walker Road Permanent Allotments Investigations at Walker Rd Permanent Allotments were carried out firstly by Newcastle University to ascertain if the site had been adversely affected by deposition from the adjacent Byker Combined Heat and Power Plant. The site received no Byker Ash. At the time of the investigations the site was in a serious state of terminal decline with low levels of occupancy and frequent damage caused by anti social behaviour.

Walker Road Allotments prior to remediation. The investigations revealed raised concentrations of heavy metals and some organic compounds. Desk top investigations of the site showed that it had previously been the site of a sandstone quarry which had been subsequently landfilled and several small historic collieries. One on-site colliery spoil heap had combusted and burnt for several years prior to the investigations. 31 Walker Road Allotments. remediation works in progress The site was determined as Contaminated Land and remediated between 2003 and 2006.

Remediation was carried out by importing clean soils with some mixing with on-site soils carried out. The former landfill was capped with compacted clays. The remediated site has former a model allotment site and is now fully occupied Walker Road Allotments. Completion of the site remediation 32 f). Branxton A and B Allotments The City Council carried out an in-house investigation of these two allotment sites and identified them as contaminated land. A successful application under DEFRA’s Contaminated Land Capital Projects Fund has been made and the remediation of the sites is hoped to commence in October 2006. ). Nurseries, Childrens Play Areas, First and Primary Schools. These sites are identified through the contaminated land inspection strategy where the present use land use conflicts with a past use. Such coincidence identifies the site for inspection. Initially a desk top is carried out, followed by a site walk over and then an appropriate form of physical site investigation if necessary – soil sampling, land fill gas monitoring etc. The progression of the work is dependant upon resource availability. 3. 3 Identification and Prioritisation of ‘Unknown’ Sites

It is recognised that areas of ‘contaminated land’ may exist within the City which are not currently known. The aim of the Authority is to identify potential sites and prioritise them according to the criteria set out in 3. 1. Use of Landmark Database The Authority has sets of historic Ordnance Survey maps in digital format, these are used with the Council’s Geographical Information System (GIS), Arc View, with the Landmark Information Database of historic potentially contaminated sites – former industrial locations, landfill sites etc.

We have carried out considerable research to identify further potentially contaminated land source areas and these have been included on this constantly evolving data base. The historic Ordnance Survey maps are from six separate time periods (or epochs) in 1:2500 and 1:10000 scales 1856 1898 1921 1936 1950(s) 1960-70s A limited coverage of Town Series maps of a scale 1:500 are held for the City Centre and its environs for the epochs 1862, 1896 and 1908. Mapping technology was not as accurate during these times as it is currently, therefore each set of maps has been ‘‘geo-rectified’’ to allow them to be overlain onto current maps.

The historic land use database identifies areas of potentially contaminated land from analysis of historic Ordnance Survey maps, following Department of the Environment (now DETR) data on the identification and classification of potentially contaminated 33 land uses. The information is constantly evolving as more knowledge is gained and more research carried out. The City Council has historic aerial view coverage of its area from the post war era (1947 – 1950) this forms an invaluable resource and greatly adds to the map resources. British Geological Survey 1:10000 digital maps are also held.

These have solid and drift data together with borehole locations, faults, coal seams etc Identification of Receptors Information on the location of ‘receptors’ and the subsequent mapping of their locations cannot be purchased as an ‘off the shelf’ product. The location of present day receptors – schools, play areas, allotments etc is held within relevant Directorates of the City Council and is used where this strategy identifies a priority receptor to investigate. The receptors with the highest prioritisation i. e. allotments, children’s play areas, nurseries, first and primary schools have been mapped and are currently being investigated.

Prioritisation of Sites Sites are prioritised according to a Source-Pathway-Receptor approach as required by Circular 2/2000 and subsequent guidance. The highest priority sites, on a receptor basis, have been identified first for inspection. Layers of maps containing contaminated sites through the available epochs are laid over a layer containing ‘receptors’. Shape files of receptor sites – nurseries, play areas etc have been sources internally in the City Council. Where a former contaminated site coincides with a receptor, scores for the receptor this indicates a site for further investigation.

The first phase of the site prioritisation involving allotments, children’s play areas, nurseries, first and primary schools has been completed. 34 Prioritisation of Sites SOURCES RECEPTORS EPOCH 1 (QUARRY & LANDFILL) EPOCH 2 (MINE & SPOIL) COMBINED 2006 (ALLOTMENTS GARDENS) COINCIDENCE OF CONFLICTING LAND USE – AREA FOR INVESTIGATION 3. 4 Liaison and Information Exchange Internal information exchange within the Local Authority’s relevant Directorates will be made, including Public Health and Environmental Protection, Planning and Development Control, Ecology, Historic Environment, Education, Neighbourhood Services and City Property.

Representatives from other disciplines will be invited to participate as and when appropriate. Liaison with the County Archaeologist and reference to the County Sites and Monuments Record will occur where a site is of historic importance. The Authority has good links and working partnerships with the Environment Agency, the Health Protection Agency, Food Standards Agency, and the University of Newcastle and Queens University Belfast. These bodies and other relevant bodies and agencies will be consulted when appropriate. 35 4. 4. 1 PRIORITY ACTIONS AND TIME SCALES Site Prioritisation

Sites will be prioritised according to the methodology previously outlined. The intention is to carry out the following inspection programme. However it must be stressed that the time scales given for completion may change according to the number of sites which are identified, the remediation required and the resources available for investigation/remediation. Allotments Children’s Play Areas, Nurseries, First and Primary Schools Recreational Fields, Middle and Secondary Schools Homes with gardens Agricultural Land Controlled Waters, Ecosystems, Buildings March 2009 March 2010 March 2012 March 2015 March 2017 March 2020 . 2 Complaints In addition to the above prioritisation, complaints received from stakeholders or other sources, or sites which come to light by other means and have clear evidence of contamination / receptor linkage, will be investigated even though they may lie outside the above prioritisations. 36 5. PROCEDURES 5. 1 Internal Management Arrangements for Inspection and Identification. The Regeneration Directorate’s Public Health and Environmental Protection Division has the overall responsibility for the implementation of Part IIA The Environmental Protection Act 1990.

The responsibility for the day to day work is the responsibility of the Team Manager for the Contaminated Land section who reports to an Environment Team Leader within the Division. The Head of Public Heal

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