The Ground
Investigation report submitted with this application is one which was conducted
in 2006 and submitted with the Wainhomes application to build houses on the
site.
Point No 1
The
Planning and Retail Statement for this current application states:-
- “Contaminated Land
8.46 A Ground Investigation was undertaken as part of the
previous application on the site.
That work remains valid and is enclosed with this
application. This shows that there are no constraints to development.”
At the time of preparation of the 2006 Ground Investigation
report the buildings were still
standing.
In complete contradiction of the above statement, the report
itself emphasizes the following:- ( I quote)
- “Our recommendations are based upon the premise that the site area is to developed on (sic) a residential manner…. However if the actual proposals adopted vary from these assumptions, then the recommendations made within this report may become inappropriate and require re-assessment.”
·
“At the time of the investigation
the site was occupied by a large industrial commercial building known as
Bradley Mill. The property was in full usage and clearly the operations being
undertaken have limited the areas available for investigation”
·
“The report has been prepared by
Site Check in association with Wilbourn Associates who have concluded that in their
professional opinion further investigation is required to determine the extent
of any potential environmental hazards which may affect the site”
- “The Site Check report also indicates the presence of a number of potentially contaminative usages within the vicinity. Of the greatest importance is the reference to Pennine Industries Ltd and Millenium Tool and Mould Ltd who are both located within this site. It is possible that these businesses and the previous usage of the mill structure may have generated potential contamination of the underlying soils…………”
- Boreholes:- … “The locations of the borehole were chosen by ourselves on the basis of those areas to which access could be readily gained and some limited investigations have been carried out within the existing buildings.”
·
Contamination:- “……Based upon historical site use a number of
potential contaminants have been considered which may be on site………It is clear that
further intrusive investigations will be required once all building and hard
standings have been removed……It is strongly our recommendation that the site be
subject to a fully detailed investigation undertaken by an experienced
environmental consultant once all areas of the site are available for intrusive
investigation.
·
“It is important to recognise that
various areas of this site were unavailable for investigation due to the
presence of buildings machinery and stored goods etc. Accordingly it is
recommended that further investigations should be undertaken once the site has
been cleared of all existing structure and hard standings. These further
investigations should be targeted to those areas where contamination has been
identified and to those areas where investigations have not extended to
date……….”
Point No 2
The report
was commissioned not by Wainhomes but by the owner of the site Mark Seddon in
view of the potential sale to Wainhomes.
It would
appear that the Mr Seddon failed to reveal to Site Check the following extremely relevant and damaging information, which has been testified to by
several ex -employees who worked on the site.
For several
years running up to 2006 there existed within the buildings an operational electroplating line. This comprised
four large tanks which contained the necessary chemicals for chromium and other
platings. These
were located roughly as shown on the diagram below.
This electroplating facility probably already existed when the current owners took possession of the site. Previously the site had been occupied by a manufacturer of vehicle exhaust systems.
Indeed, the site is still the registered offices of the NORTHERN WIRE PRODUCTS & ELECTROPLATING LIMITED (Company Registration No 01368367), two of whose directors are the current owners of the site although the status of the company is now ‘Non Trading’
The electroplating installation and tanks were dismantled and removed shortly before the Ground Investigation report was commissioned.
Anecdotally the contents of the tanks were disposed of ‘On Site’
Given the number of years that this plant was in operation a grave suspicion must be that contamination of that part of the site by these dangerous chemicals is almost inevitable.
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Point No 3
On the 2nd May 2009 three quarters of the buildings were completed destroyed by fire.
Although the outer cladding of the building was of modern materials the basic structure was still of 19th Century origins. From this and the previous uses of the mill, it is highly likely that there was a significant presence of Asbestos.
The fire and subsequent demolition would have distributed this across the whole site and beyond.
When the site owner subsequently started to transport the resulting rubble to his other property in Bradley Fold, the Environment Agency became involved and he was subsequently prosecuted.
Conclusion
In view of all of the above comments from the 2006 report and the new information about the electroplating plant not afforded to its authors, and the subsequent possible asbestos contamination,I insist that the 2006 report submitted by the applicants fails to meet Planning requirements in respect of thoroughness in identifying contamination over the whole of the site and that a new Ground Investigation Report must be carried out to fulfill the applicants environmental responsibilities.
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