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An Argument for a GIS Contaminated Land Inventory for The Republic of Ireland
 

An Argument for a GIS Contaminated Land Inventory for The Republic of Ireland

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In an inventory of contaminated land sites carried out by the Irish EPA in 1999 and presented in a CARACAS publication, the number of contaminated land sites in Ireland was conservatively estimated at ...

In an inventory of contaminated land sites carried out by the Irish EPA in 1999 and presented in a CARACAS publication, the number of contaminated land sites in Ireland was conservatively estimated at a relatively modest 2,000 to 2,500. This number was derived from an inventory of contaminated land sites in the petroleum retail sector, at various industrial sites, at closed landfill sites, timber treatment yards, scrap yards, railway yards and former gasworks sites. In comparison, the number of contaminated land sites in the UK is estimated at possibly over 100,000. It is stated that the number of brownfield sites or facilities with contaminated land legacies in Ireland is significantly less in Ireland than those of most other more industrialized European countries such as the UK, due to Ireland’s relative late arrival into the industrial age. The Northern Ireland Environment Agency (NIEA) carried out an inventory of potentially contaminated land and have stated in 2011 that they have identified a number in excess of 14,000 sites. This number was revised upwards from 12,000 in 2009. Mulroy Environmental carried out an 'in-house' inventory of key industrial sectors. This in-house inventory suggests that the NIEA contaminated land database number is correct. As such, it is likely that the Rep. of Ireland has over twice the number of potentially contaminated sites as that of Northern Ireland i.e. >30,000.

The value of having an inventory of potentially contaminated land available to the public appears to have been underestimated within the Republic of Ireland. A review of the introduction of environmental legislation in the Republic over the past 20 years (particularly the Waste Management Act, 1996) would indicate that there is an unease within the regulators at the introduction of a freely available inventory. The primary reason for this would appear to be a fear within regulators of drawing the wrath of the property development and real estate sectors due to ‘property blight’. A secondary reason would appear to be legal ambiguity over the true purpose of Sections 22 and Section 26 of the Waste Management Act, 1996.

The value of having a publically administered GIS based system which would list properties that have been potentially contaminated in the past can not be argued against. This list would ideally draw on the extensive experience of the UK Environmental Agency with regard to work previously carried out on various industrial sectors (i.e. the EA have drawn up a list of 30 industrial profiles). This would provide potential buyers with a clear indicator of whether a Phase I Site Audit should be carried out by an environmental consultant as part of Pre-purchase Due Diligence work. The scenario of an investor or developer purchasing a property in the Republic of Ireland that has, after contract completion turned out to have contamination is very common. This is a scenario that can be avoided.

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    An Argument for a GIS Contaminated Land Inventory for The Republic of Ireland An Argument for a GIS Contaminated Land Inventory for The Republic of Ireland Presentation Transcript

    • ICT and Environmental Regulation: Developing a Research Agenda,Whitaker InstituteRyan InstituteNational University of Ireland GalwayAN ARGUMENT FOR A GISCONTAMINATED LAND INVENTORYFOR THE REPUBLIC OF IRELANDThursday 20 June - Friday 21 June 2013Padraic Mulroy,BSc., MSc., MIEI, MIPSS, CSc, SiLCManaging DirectorMulroy Environmental
    • Slide 2Who are we?• Based in Dundalk, County Louth (the Wee County)• Started in 2007Services• Due Diligence Site Investigation/Contaminated Land RiskAssessment• Remediation/Bioremediation of Contaminated Soil & Water• Waste Licence & Permit Applications• IPPC Licensing• Wastewater Treatment Plant Design for Single, SmallCommunity, Commercial & Industrial Development• Site Suitability Assessment• Environmental Impact Assessment• Sludge Management Expertise• Environmental MonitoringBACKGROUNDMULROY ENVIRONMENTAL1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 3EXTENT OF CONTAMINATED LAND INREP. OF IRELAND• Have we understated the extent of (potentially)contaminated land in Ireland?• Was Ireland bypassed by the Industrial Revolution?• An agrarian economy? Minor mineral deposits1. Contaminated Land Report of the Parliamentary Office of Science & Technology (1993).1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 4EXTENT OF CONTAMINATED LAND INGREAT BRITAIN• Regular comparison to the birthplace of theIndustrial Revolution – Great Britain with >100,000potential contaminated sites11. Contaminated Land Report of the Parliamentary Office of Science & Technology (1993).1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 5CONTAMINATED LAND INVENTORY FORREP. OF IRELAND?IRISH EPA STUDY 1999• Historical Sites– Old Gas Works 50-80– Closed Landfills 265 (OEE figures?)– Closed Mine sites 128 (38 with TailingsPonds, 11 recent/presenthigh risk)– Old Fertiliser Plants 4-6– Closed Tanneries 10 -12• Current Operational Sites– Existing Landfills 76 LA 50 Private(Registrationongoing)– Mining/Minerals site in operation ca. 7 (MWD)– Chemical Industry 150 –160– Petroleum import terminals (IPIA) 22– Petrol Stations 900 –1200– Tanneries 3– Dockyards 14-16– Military Sites 1– Railways Depots 80-100– Scrap yards/dismantlers 180 –200– Airports with maintenance 2• Estimated Total of 2,000-2,500 – Ireland’s small scale industry? 11. CARACAS, Risk Assessment for Contaminated Sites in Europe, Volume II, Policy Framework, Brogan et al, 19991 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 6CONTAMINATED LAND INVENTORY FORREP. OF IRELAND?• NI Environment Agency DATABASE– >14,000 Potentially Contaminated Sitesestimated in 2011– Continual updating - & continuouslyrevised upwards from 11,825 in March2009• High Risk - 8199• Medium Risk - 1811• Low Risk - 1599• Uncategorised - 216– 30 land use categories1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 7CONTAMINATED LAND INVENTORY FORREP. OF IRELAND?>14,000>2,500??1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 8EXTENT OF CONTAMINATED LAND INTHE NETHERLANDS• 2004 - National List of Polluted Sites 425,000 Potentially Contaminated Sites.SOURCE FOR CONTAMINATED LANDINVENTORY17%3%80%Remediations & On-goingSite InvestigationsOngoingRemediations/AftercareIndustrial/CommercialActivites known to causecontamination1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 9EXTENT OF CONTAMINATED LAND INTHE NETHERLANDSDUTCH 2009 CONTAMINATED LANDINVENTORY STATUS42%31%16%2% 2%7%Suspect but not yet fullyinvestigatedAfter pilot testing ofselected sector sites setto low priorityOn-going Remediations &AftercareCompleted SI and foundremediation not requiredOngoingRemediations/AftercareCompleted afterremediation1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 10EXTENT OF CONTAMINATED LAND INTHE IRELANDPopulation:NI - 1.8mRep. of I – 4.6mNetherlands – 16.8mContaminatedInventory:NI - 14kRep. of I – ??kNetherlands – 425k14,000425,00030,000?1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 11CONTAMINATED LAND INVENTORY FORREP. OF IRELAND?WHO IS CORRECT?IRISH EPA OR NIEA• 2006 DOELG/ARUP Report on Petroleum Sector1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 12CONTAMINATED LAND INVENTORY FORREP. OF IRELAND?WHO IS CORRECT? IRISH EPA OR NIEA• GSI SURGE Project, 2011 – Dublin Historic IndustryDatabase - >2000 sites identified• In EPA inventory there is an absence of information onfollowing industrial/commercial sectors:– Oil Depots (i.e. Diesel/Kerosene only) – 250-300?;– Dry Cleaners (768 EPA Solvent User Database);– Garages/Mechanic Workshops – 7,500?;– Car Panel Beaters/Solvent Paint Workshops -100?;– Military Firing Ranges (i.e. Ballistic Berms) – 20?;– Local Authority Designated Derelict Property (abandonedLA housing & halting sites) -500?• LA Section 22 Inventory –• 344 Confirmed LA-owned Landfills; and• 97 Private/Illegal/Pre-1977 LFs……… but no information on Section 26 ‘Hazardous Site Subset’referred to in National Hazardous Waste Management Plan1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 13CONTAMINATED LAND INVENTORY FORREP. OF IRELAND?WHO IS CORRECT? IRISH EPA OR NIEATown Gas Plants/Coal Tar in BI1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 14CONTAMINATED LAND INVENTORY FORREP. OF IRELAND?WHO IS CORRECT? IRISH EPA OR NIEATown Gas Plants/Coal Tar37 in NI138 in Rep. of I 22. Mulroy Environmental Inventory using OSI on-line historical mapping1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 15Why have a Contaminated Land Inventory in Ireland?• Will help in identifying property which may be have beencontaminated in the past by commercial or industrialactivity• Primary benefit in carrying out Due Diligence work onbehalf of clientele wishing to assess risk to property forsale• Allows assessment of not just site’s history but also historyof neighbouring property which may be a risk to theproperty for sale (i.e. from incoming migration from off-site contamination)• Buyer or buyer’s solicitor may then decide to approachenvironmental consultant to assess the site by either:– Phase I Site Audit (Non-intrusive SI); or– Phase II Site Investigation (Intrusive) – If evidence ofcontamination is found during initial site audit• Good practice – assess the cost of sorting out a potentialproblem – have another look at the asking price.1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 16Current practice?• Vendors relying on solicitors who may not have expertise toidentify where a potential risk may exist• Relying on vendor to furnish buyer with historical record ofsite – may not have any record• Site may have changed hands a number of times• Site may have been leased to high risk operation with norecord• May be no evidence of previous use (e.g. DisusedUnderground storage tanks (USTs), Aboveground Storagetanks (ASTs), bunds, pumps, etc• Subsurface contamination – ‘out of sight…out of mind’• Previous site investigation/environmental engineeringreports may be of poor standard with not enough detail• May not analysed for correct laboratory suite – relevant toindustrial sector (e.g. azodyes in textile facilities, etc)1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 17Example - How it can go wrong• Client is buying former commercial land adjacent toriver with mixed retail use built in late 1960s. Wantsto build residential apartment complex withunderground carparking. On the ‘surface’ no indicationof underlying problem• Part of site on periphery formerly occupied by PetrolRetail Site – demolished overhead features (i.e. kiosk,pumps, ASTs, etc) but no information given ondecommissioning/removal of USTs• Ground floor unit formerly leased to Dry Cleaneroperation for 3 years. No record.• Site was partially built on:– Former railway depot property where railway sleeperswere treated; and– Former Brick manufacturer• Central heating pipes contain asbestos lagging1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 18Example - How it can go wrong• Client ‘blinded’ by the price and buys the site.• At pre-planning stage - Local authority notifies client of‘varied’ brownfield history of site and requires SI/RA to besubmitted as part of planning application.• If LA don’t know, extent of problem becomes evident onexcavation of formerly infilled material for construction ofunderground carpark. Developer alerted by contractor offloating petroleum type product within pit and on adjacentriver and solvent odours in soil excavated under slab atanother location.• Where does the contaminated soil go? Hazardous? Costs?Budget amendment. C & D Waste Management Plan to berevised and approved by LA.• Initial Demolition Phase halted due to discovery ofasbestos lagging – delay/postponement in contractor’s workmay lead to future claim against developer.• Site Investigation/Risk Assessment now requested by LAto formulate Remedial Plan1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 19Example - How it can go wrong• Soil must remain on site until classified – space?• Project Management – delays, contractors to benotified• EPA may need to be notified/consulted by LA• Forced into ‘dig and dump’ solution - expensive• Groundwater treatment – may require DischargeLicence from LA• Existence of Dry Cleaning solvent in soil (i.e. PCE orPERC) requires site investigation to assess DNAPLcontamination to underlying aquifer – groundwatermonitoring boreholes. Off-site migration?• Existence of shallow creosote contamination (i.e.PAHs and phenols) in soil from former railway yardrequires excavation and disposal as hazardous waste• Ash present at high volumes in shallow soil fromformer brick manufacturer has heavy metal and PAHcontamination - disposal at non-hazardous landfill1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 20Where do you start?Don’t invent the wheel - Learn from international experience!UK DOE Contaminated Land Report (CLR) Guidance• CLR No. 3. Documentary Research on Industrial Sites• CLR No. 5. Information Systems for Land Contamination• CLR No. 6. Prioritization and Categorization Procedure for Sites whichmay be contaminatedUK Local Authority Contaminated Land Inventories• Example - Fife Council – 7,000 Sites collated using STMGeoEnviron/ArcGISNIEA Contaminated Land Database• 30 Categories – What are they? 48 DOE Industrial Profile GuidanceDocumentsDutch Contaminated Land Database• XX? Categories – What are they?Landmark Information Group• Private firm providing desk study & mapping services to legal &environmental consultancy firms in UK1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 21Where do you start? - Learn from NI, UK, Dutch & USA• UK Contaminated Land Register, 1991– Brickworks– Chemical works and chemical manufacturing business– Dry cleaning premises– Fish farms– Petrol Stations– Garages/panel beaters– Gas Works– Glass Manufacturing– Industries making or using wood preservatives– Metal Surface Treatment and Metal Product Manufact.– Mining & extractive Industries– Munitions production & distribution– Paper & printing works– Railway Land (especially depots)– End-of-life vehicle facilities (i.e. scrapyards)– Tanneries1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 22Where do you start? - Learn from NI, UK, Dutch & USA• USEPA Lists, 1998– Analytical & Clinical Laboratories– Chemical manufacturing and Formulation Industries– Construction and Demolition Industries– Education Institutions (Science laboratories?)– Furniture Manufacturers and Re-finishing Operations– Laundries & Dry cleaners– Metals & Metal Product Manufacturing– Papers and Paper-Product Industries– Pesticide Application and End-use (e.g. sheep dip)– Photography and Printing– Textile Manufacturing– Vehicle and Equipment maintenance (i.e. garages) ***– Wholesale & Retail establishments1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 23Where do you start? - Learn from NI, UK, Dutch & USASources of Information• EPA Section 22/Historic Landfills List & Section 26 HazardousWaste Sites• GSI SURGE Project, 2011 – Dublin Historic Industry Database• EPA/GSI Mine Database• Directory of Active Quarries, Pits and Mines in Ireland, 1994• Register of Toxic & Waste Disposal Sites (Toxic & DangerousWaste Regulations, 1982)• Derelict Sites Registers (Derelict Site’s Act, 1982)• Register of Dangerous Places – Sanitary Services Act, 1964• Compass Directories• Thom’s Almanac & Official Directory 1844-1960• Thom’s Dublin Directory, 1961 to present• Thom’s Commercial Directory, 1961 to present• Bassett’s Directories – county specific• Dublin Trade Directories – Directory of Dublin Industrial Estates,1991• Trade Directories – ‘Dublin, Leinster & Connaught TradesDirectories/Gazeteer of Ireland, 1900, 1903, 1914, 1920, 1929 &1965• Griffith Valuation – information of land-use and uses of individualbuildings• Valuation Office Registers• Local histories & archives1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 24Where do you start? – OSI Historic Mapping1 Background2 Extent of CL3 ROI 1999 Inventory4 NI Current Inventory5 Dutch 2009 Inventory6 Comparison7 Why bother?8 Current Practice9 How it can go wrong10 Where do you start?
    • Slide 25THANK YOU!