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Subject: Former site of Turner BrothersAsbestos (TBA) - an
Update and Next Steps
Report to: Cabinet
Status: Not For Publication
Date: 2 November2015
Cabinet Member: Cabinet Member for Culture,Health and
Wellbeing
Report of: Director of Neighbourhoods
Authors’ Email:
[email protected](’ã[email protected]
I PURPOSE OF THE REPORT
Authors: Andy GloverNicola RogersDavid Oakes
Tel: Tel: 01706 92410501706 92412401706 924324
1.1 The purpose of this report is to update members of Informal
Cabinet on the latestposition regarding asbestos contamination at
the site of the former TBA factory inSpodden Valley. The report
requests approval from Cabinet for funding tocommission an
independent site survey in partnership with the
owner’srepresentative (UKLP Estates (Rochdale) Ltd, referred to in
this report asUKLPER). It also suggests how the issue of the
remaining dangerous buildingson the site can be tackled; highlights
some of the potential financial implicationsand risks for the
authority; and discusses a number of other issues relevant to
anynext steps.
2 RECOMMENDATIONS
Members of Cabinet are requested to:
2.1 supportthe requestforfunding in section 7 belowto commission
(jointlywith thelandowner) a site survey which will increase the
owner’s and Council’sunderstanding of (i) the level of asbestos and
other ground contaminants acrossthe site area and (ii) any public
health risks arising from this; and
2.2 consider whether any agreement to joint-fund the site survey
should be madeconditional upon the landowner also agreeing to
remove any asbestos risk fromthe existing buildings on the TBA
site.
ROCHDALEBOROUGH COUNCIL
Comments from StatutoryOfficers:
Key Decision: Yes
Monitoring Officer: YesSection 151 Officer: Yes
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3 BACKGROUND
3.1 The site of the premises formerly known as Turner Brothers
Asbestos isapproximately 38 hectares in size and is located some 1
.8km north west ofRochdale town centre.
3.2 The former TBA Site has a long history of industrial use
dating back to the 19tIcentury. By the 1960’s the site had expanded
to its present day extent. In recentyears, some of the buildings on
the main factory side have been demolishedleaving the building
footprints. Asbestos ceased to be manufactured in the site inthe
1990’s, when the buildings were occupied by various small tenants
until theywere completely vacated after 2008. Since then the
buildings have become atarget for vandals and are in an advanced
state of disrepair.
3.3 In February 2013, a significant fire (suspected to be arson)
caused major damageto the structure of the old E Block Buildings.
These buildings have since beendemolished. A further fire occurred
in January 2014, the cause of which isunknown. Both these
fire-damaged buildings have now been demolished and arediscussed in
more detail in sections 9-14 below. In response to these
on-sitefires, and in order to ensure a co-ordinated response to
future incidents, a multi-agency protocol was adopted.
3.4 Members should note that this report will simply focus on
the need for a site surveyand will not address any options for
future development of the former TBA site.Any options for
development will need to take into account the information
gainedvia a site survey; once formulated they would ultimately need
to undergo thePlanning process (along with any consultation
required as appropriate).
4. ASBESTOS AND THE RISKS POSED
4.1 The Council’s Public Health section has been asked to
provide expertise regardingthe potential health impact of the
former TBA site. At this stage, without anyevidence regarding the
possible levels of asbestos remaining on this site or anyidentified
causal pathway it is intended to provide only summary information
onasbestos and known health effects. This will enable Cabinet to
gain a betterunderstanding of the broader issues and to provide
clarity and evidence-basedinformation around the challenges of
fully understanding any non-occupational risksof potential exposure
to asbestos.
4.2 Definition of asbestos and risks
4.2.1 The term Asbestos refers to a group of crystalline mineral
silicates that occurnaturally in rock. As asbestos is resistant to
heat it was widely used in constructionas well as in creating
asbestos fabric which was used for creating fire and heatproof
items of clothing and protective wear.
4.2.2 Three main types of asbestos were used in industry; a)
chrysotile (white asbestos),b) crocidolite (blue asbestos) and c)
amosite (brown asbestos). All three areclassified as known
carcinogens and cause serious risk to health. Crocidolite
andamosite are considered to be more dangerous.
4.2.3 Asbestos fibres that are airborne are invisible and
odourless (Sen, 2015) and nolevels are considered safe. The Health
and Safety Executive sets a control limit forworkers of 0.1
asbestos fibres per cubic centimetre of air (0.lf/cm3)but make
clearthat this is not a safe limit. The asbestos in schools
campaign group consider that
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anything above a benchmark of 0.0005f/mI pose a “significant”
risk (f/mi and f/cm3are equivalent units).
4.2.4 Currently in the UK, asbestos is the biggest cause of work
related deaths. Thereare four main types of disease caused by
asbestos exposure. Sen (2015) outlinesthe key features of each
which is summarised below.
a) Benign pleural disease including pleural plaques, diffuse
pleural thickening andbenign pleural effusion. These three diseases
can be asymptomatic and are notprecursors to malignant disease;
b) Malignant diseases which are malignant mesothelioma and lung
cancer;c) Malignant mesothelioma is a fatal and aggressive form of
cancer which is identified
as an industrial disease due to the high proportion caused by
asbestos exposure.The latency period between initial exposure and
disease is 15-60 years with a meanof forty years. Incidence is
increasing and current estimates are that there will be apeak of
around 2,500 cases in 2020; and
d) Smoking is associated with 90% of lung cancers but there is
evidence of a synergybetween smoking and asbestos which indicates a
much higher risk of lung cancerfor those with exposure to both.
4.2.5 Asbestosis (an interstitial lung disease) which is a form
of lung disease that causesinflammation and scarring. The latency
is from 20-40 years from exposure andthere is a dose-response
relationship meaning that those with more exposure aremore likely
to develop this disease. The severity of the disease is increased
bysmoking and progressing occurs in 40% of cases even after the
exposure has beenstopped.
4.3 Interpreting the Evidence
4.3.lThere are no systematic reviews that consider the potential
health risks resultingdirectly from a disused asbestos
manufacturing plant. The occupational risks anddomestic risks from
workers returning home with fibres are clear and wellevidenced.
Wider environmental risks that have been reviewed have focused
onactive asbestos industry, such as mining, or asbestos in situ in
older buildings, suchas schools. These are of limited value in
considering the risks associated with adisused site such as the TBA
site in Rochdale which includes woodland, andabandoned
buildings.
4.4 Confounding Factors
4.4.1 There are some significant complicating factors in
considering this type of risk.These are other issues that mean that
it is very difficult to determine how much riskthere is to the
population from the TBA site in Rochdale. Due to the
confoundingfactors discussed below it would be misleading and
inaccurate to carry out anyspecific disease analysis locally as it
would not be possible to accurately determinethe cause of any
variation in disease incidence due to the following factors:
a) Inability to distinguish between occupational, domestic and
environmentalexposure.
In addition to occupational exposure for workers directly
working at the factory,there are three confounding non-occupational
exposures 1) neighbourhoodexposure whilst the factory was working,
2) exposure to asbestos from otherpossible sources such as housing,
schools etc., 3) domestic exposure relating tofibres brought home
by workers on their bodies and clothes, t Dossibility that
local
...._. ..J. I
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So, it would be very difficult to accurately consider the risk
associatedwith the current TBA site as opposed to the other
exposures.
b) Latency of diseaseAs detailed above, the diseases caused by
asbestos exposure have a latencyperiod between exposure and the
development of disease. In the case ofmesothelioma, this can be as
long as sixty years. This means that current diseasein the
population could be associated with exposure as long ago as
1955.Therefore, the risks of current exposure are difficult to
determine via any diseaseanalysis.
c) Sample sizeThe rates of mesothelioma, in particular, are very
low and, therefore, it is difficult todetermine to a degree of
significance to any pattern locally.
d) Lack of information on levels of asbestos contaminationAs
there has been no full survey of the site, it is not known how
contaminated thesite is. Although there is no safe level of
exposure to asbestos, the currentinformation available does not
indicate how much asbestos there is in the site, orwhether this
might be a source of new exposures.
e) Population mobilityIn order to accurately consider the
population at risk, all residents of the local areawould need to be
traced and their other exposures tracked. This would be
verydifficult due to the potential presence of asbestos in other
buildings or places.
f) Smoking prevalenceAsbestos and smoking are both causes of
lung cancer. 22.7% of adults in theRochdale borough are still
smokers, and the smoking rate has been much higher inthe past. Even
now, this is significantly higher than the England average
(RochdaleHealth Profile, 2013). Lung cancer is a significant cause
of ill health and mortalityin Rochdale but in the main, this is
most likely to be smoking related disease.
4.5 Levels of disease in Rochdale Borough
a) Lung Cancer
The tables below indicate the incidence and mortality rates for
lung cancer inRochdale as compared to England and Greater
Manchester. Rochdale has ahigher rate than England for both
incidence and mortality but is not higher than theGreater
Manchester figures.
Age Standardised Incidence Rates per 100,000 - All Ages
IncidenceLung Cancer 2010-12
Males Females Persons
England 94.17 62.4 75.99
Greater Manchester 128.67 89.02 105.57
Rochdale 110.18 89.17 98.01Age Standardised Death Rates per
100,000 - All Ages Mortality LungCancer 2011-13
Males Females Persons
England 75.73 48.6 60.19
Greater Manchester 97.37 68.91 80.76
Rochdale 82.9 75.37 78.2
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b) Malignant Mesothelioma
From 2003 to 2014, there have been a total of 70 deaths from
malignantmesothelioma in Rochdale borough. This is a mean of 5.83 a
year (a median of 6).The crude rate locally for 2012-14 is 3.14 per
100,000 population which comparesto a crude rate for England of 4.0
deaths per 100,000 population (2012 data). Thenumbers of deaths are
small and therefore no conclusion can be made regardingthe
significance of this data.
4.6 Conclusions regarding asbestos and risk posed
a) There is no clear evidence from the literature review
regarding the health effectsfrom exposure from a disused asbestos
factory. The focus of risk analysis hasbeen on the occupational or
domestic. Therefore, the conclusion is that it is notpossible to
determine the potential for health harm from the TBA site based on
aliterature review;
b) The data regarding asbestos related disease and the potential
confounding factorsindicates that further analysis would be
unlikely to reveal any additionalinformation; and
c) A full site investigation would confirm the levels of
asbestos on site which maybeneficial in understanding how to assess
risk going forward
4.7 Air Quality Monitoring
4.7.1 Despite difficulties with establishing any wider health
risks to local communities,the Council is keen to act where it can
to better understand the risks (if any)posed by the site which may
arise from its industrial history. As a result, theCouncil has
commissioned a firm to undertake sampling around the perimeter
ofthe site, to gather data on whether asbestos levels in the air
are within expectedparameters.
4.7.2 The work is being undertaken by Bureau Veritas of
Didsbury. Monitoringequipment has been placed at 4 carefully
selected locations. These locationswill be secure (placed within
residents’ gardens with their full agreement), andbetween them will
cover the full circumference of the site. In order to act as
acomparator, an additional “control” unit has been housed on the
roof of NumberOne Riverside.
4.7.3 The exercise is due to commence in September 2015. Under
the agreedSample Analysis Plan, monthly samples will then be taken
over the next 12months until August 2016. A total of 5 samples will
be taken each month(including the control sample).
4.7.4 The full cost of this exercise will be borne by Rochdale
Council. At a meeting ofRochdale Township on 16 September 2015, it
was agreed that the outcome ofthe sampling will be shared with
Rochdale Township and other area forums suchas Spotland and
Falinge, Healey and Norden.
5 OWNERSHIP OF THE SITE I AGENCIES AND INTERESTED PARTIES
INVOLVED
5.1 The Land Registry confirms that the site is owned by Renshaw
Properties Ltd.This is an offshore company registered in the
British Virgin Islands and its solerepresentative in this country
is UK Land and Property (UKLPER).
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5.2 There are also a number of community-based groups which are
committed to thepreservation of the green open space surrounding
the former TBA site andcontinue to scrutinise the Council’s actions
and decision-making processes in thisregard. These groups
include:
• TBA Working Group (the nature of the relationship between this
Group and theCouncil has been the subject of some discussion with
the Portfolio Holder. Ithas been agreed that the Group will remain
at arm’s length from andunsupported by the Council, although
meetings will be held at Number OneRiverside subject to rental for
the room being paid); and
• Save Spodden Valley Group.
6. EXISTING SITE INFORMATION
6.1 A wide range of information about the former TBA site is
held by the site ownerand Rochdale Council. A full list of the
information gathered though a range ofstudies is attached as
Appendix 1. However, there are a number of gaps in theCouncil’s
knowledge base, as discussed in paragraph 7.1.1 below.
7. WHY IS A SITE SURVEY REQUIRED?
7.1 General aims
7.1.1 The historical information held to date is incomplete as
it has been gatheredover a number of years and relates to a series
of disconnected, previousinvestigations. The document attached as
Appendix 2 sets out a detailedexamination of the current gaps in
knowledge about the extent ofcontamination at the site. When all of
this fragmented information is broughttogether and examined, the
Council and site owner accept that there are gapsin the knowledge
and understanding of the site’s (asbestos) contamination risk.It is
therefore considered necessary to consolidate the available
information,
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and to supplement it through the commissioning of additional
intrusive siteinvestigations. This would enable the Council and
owner to gain a full anddetailed understanding of the site,
including:
(i) the level of asbestos and other contaminants present in the
ground; and
(ii) a risk assessment of health issues arising from the above
which may impacton the local community.
7.1.2 The overall objectives of the site investigation are to
identify and characterise allpotential contaminant linkages; draw
conclusions on their significance; andprovide a concise and robust
report with conclusions on the site’s status (withfull
justifications).
7.2 Council objectives
7.2.1 A site survey will assist in resolving further Council
objectives. For instance, theoutcome of the survey may oblige the
Council to take certain statutory steps,including recording the
site on the Register of Contaminated Land. (The site isnot
currently on the Register due to the lack of information from a
ground-based survey, although - as the home of a former producer of
asbestos-containing materials — it has been identified as requiring
inspection inaccordance with the Council’s Contaminated Land
Strategy under Part 2A ofthe Environmental Protection Act 1990 and
Statutory Guidance). The site hasbeen identified as a potential
concern since it is within close proximity tosensitive residential
properties and there are a number of known asbestosdumps within the
site vicinity. It is not known to what extent asbestos
fibredispersal is occurring from the factory buildings and former
landfills (if at all),and - if so - what risks they represent to
the surrounding receptors. Pt is this gapin knowledge which the
site survey would seek to fill.
Furthermore, a complete site investigation will assist the
DevelopmentManagement team to better understand the planning
implications which anyproposals for future development may have to
satisfy. This is a standardPlanning technique and is normal
industry practice. It is true that normally theburden of acquiring
a site investigation report would fall wholly to the
developer.However, by previously rejecting a planning application
(on the grounds of lackof information provided), and given the
particular demands of this site, theCouncil may now be committed to
a joint-funded approach.
7.2.2 In summary, of particular concern to the Council are the
requirements for:
a. an assessment of the release and migration of asbestos fibres
from dumps andthe derelict buildings and their capability of
reaching receptors;
b. an assessment of the risk to controlled waters to the
satisfaction of theEnvironment Agency;
c. an investigation to determine the presence of contaminants
and their risk; andd. an assessment of slope stability issues and
the identification of the presence
and location of mine shafts on site.
7.3 Other objectives
7.3.1 In addition, the site survey will also offer benefits to
the owner from theperspective of UKLPER. In particular, it will
enable UKLPER to betterunderstand the development potential of the
site. Whilst this is of secondary
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benefit for the Council, it will clearly be of real significance
for the land ownersand their representatives, and will assist in
enabling a final sustainable solutionfor the site to be found
8.1 In 2014, the Council embarked on a comprehensive tendering
exercise in relationto the site survey; this resulted in
confirmation that the site survey for the groundcontamination only
could be undertaken by a preferred contractor at a cost
of£246,541.71. This sum included optional items identified in the
revised submissionbut excluded work for:
• an assessment of the level of asbestos in the existing on-site
buildings; and• the cost for a baseline flood risk assessment to
identify any constraints to any
proposed development.
With a contingency of 15% (37,000), the total cost for this work
was estimated at£283,541 .71. On the assumption that the cost of
this survey would have beenshared equally with UKLPER, this would
bring the Council’s contribution to£141,771 .00 (including
contingency).
8.2 Under existing Procurement rules, it may be necessary to
recommence thetendering process for the site survey (which could
take up to 5-6 months tocomplete). However, officers understand the
need to ensure that anyprocurement exercise is streamlined as much
as possible.
8.3 On the positive side, the site survey provides an
opportunity for the Council(should it so wish) to ensure that any
asbestos risk posed by the existing buildingsis resolved at the
same time. The Council could require that (as a condition
ofagreeing to jointly fund a site survey) the landowners undertake
to remove allasbestos from the site buildings at their own expense.
This may or not result inthe demolition of the buildings; this
would be a matter for the landowner inchoosing how best to deal
with the asbestos risk, and is discussed in more detailin
paragraphs 10.3 and 11.1 below.
8.4 Any funding could also be conditional upon full contact
details of the individuals,directors or secretary of Renshaw
Properties Ltd being the Council,which should inc” i inc1”’ al b”’4
the UK. I
8.5 Should this report or any other financial information be
taken in open session toRochdale Township, Spotland Area Forum,
Scrutiny or Cabinet, this and any otherrelevant information would
need to be redacted due to its commercially sensitivenature.
8. TENDER PROCESS
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9. EXISTING BUILDINGS I SUPERSTRUCTURES — OVERVIEW
9.1 The former TBA site contains a number of existing buildings
which formed theprevious asbestos works. There are around a dozen
buildings within this complex,the structural condition of which has
deteriorated during a long period of disuse.The buildings have
suffered from vandalism and have been the target ofcontinuous and
sustained metal theft by thieves.
9.2 Historically, the buildings formed part of the asbestos
product manufacturingprocess over several decades, before being
left vacant by the last tenants in thelast 10 years or so. The
building fabric is believed to consist of asbestos-containing
materials (ACM5) in many areas, and there is also concern that
manyof the voids, ducts and shafts within the internal structure of
the buildings maycontain contaminated dust particles, which may
possibly present a risk to health ifthey become airborne (e.g. if
they are released into the air by a smoke plume froma fire).
9.3 Two of the buildings have been demolished in the last
two-years (by the owners)due to fires caused by unauthorised
trespassers gaining access into theseunsecured structures, causing
anxiety amongst local action groups who areconcerned that asbestos
fibres may have been released into the localatmosphere.
10. EXISTING BUILDINGS — PRESENT SITUATION
10.1 The last building fire at the site occurred in early 2014,
after which the landownerincreased on-site security with the
provision of two security guards who patrol thesite 24 hours-a-day,
365 days-a-year; this provision still exists today. The Councilhas
been in regular contact with the site manager, and he has confirmed
thatsince the introduction of security guards and motion detectors
on the site, theincidence of unauthorised access into the buildings
has significantly reduced topractically zero. This is supported by
the fact that the Council has not received anyfurther calls or
complaints from local residents or from the Police or Fire
andRescue Services since the last fire incident.
10.3 The level of asbestos contamination within the building
fabric and within any dustwhich may or may not exist within
internal ducts, voids and shafts etc, is unknownby the Council. To
our best knowledge, an asbestos survey of the buildings hasnot been
undertaken by the previous owners, or if one does exist, the
Council hasnot been made aware of any findings it may contain. The
Council has attempted togain this information from the present
landowners and their development agent(UKLPER) but without success.
This supports the need to commission an
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additional survey relating to the risk posed by the existing
on-site buildings, asdiscussed in paragraph 8.3 above.
11. EXISTING BUILDINGS — ANTICIPATED COSTS OF DEMOLITION
11 .1 During the demolition process of the previous fire damaged
building, BuildingControl approached specialist dem’i contractor-
on the likely costsof der II of the b’ ‘‘
12. EXISTING BUILDINGS — LEGAL ISSUES
12.1 The Council has taken legalits available enforcement
powers.
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13. EXISTING BUILDINGS — ENFORCEMENT OPTIONS
13.1 Building Control has three main enforcement options for the
site, should it benecessary to take action at this stage. These are
set out in detail in Appendix 3to this report.
14. EXISTING BUILDINGS — PROPOSED NEXT STEPS
14.1 Members may wish to consider whether to formu’’’ -‘
coniwith the outcome of Counsel’s advice
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15. Financial Implications
15.1 All known external funding sources have been explored from
both a UK and EUperspective , but there is no prospect of being
able to access these movingforward.
15.2 It should be noted that, on 6 November 2014, a formal
written approach wasmade by the Leader to DEFRA (as the relevant
government with responsibilityfor Contaminated Land); the purpose
of this was to explore whether any financialsupport for site
remediation would be available from central government.
Inparticular, the approach stressed the unique challenges for this
Council posed bythe size of the site and the potential nature of
contamination. On 16 February2015, a response was received from
Lord de Mauley (Parliamentary UnderSecretary of State for Natural
Environment and Science) confirming that noadditional financial
support would be forthcoming. In June 2015 a further letterwas sent
to DEFRA by the Member of Parliament for Rochdale, reiterating
theneed for dialogue on the way forward. At the meeting of Rochdale
Township on16 September 2015, the Leader of Rochdale Council
confirmed that a responsehad been received from the new Secretary
of State, who had indicated that(whilst no new money would be made
available) a meeting with DEFRArepresentatives would now be
possible.
15.3 The table below seeks to pull together a summary of the
possible financialimplications for the Council set out in the body
of the report:
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Asbestossurvey
Demolitionworks
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Remed iationof total site
16. Legal Implications
16.1 The Council has a duty to inspect land in its Borough under
the EnvironmentalProtection Act 1990 for the purpose of identifying
contaminated land. TheSecretary of State has issued specific
guidance which local authorities have toact in accordance with.
Previous inspections have been carried out however thefull extent
and degree of contamination is not known.
16.2 In order to protect the Council’s position and limit any
potential liability arisingfrom the commissioning of the site
survey and its report, the Council has chosento take independent
legal advice from Counsel. This is attached as Appendix 4(in a form
reduced to “question and answer” format for ease of reference).
Thish h thr hoyt the r rt asI
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17. Personnel Implications
17.1 There are no personnel implications arising from this
report.
18. Corporate Priorities
18.1 The importance of Place is stressed in the Council’s
Corporate Plan 2014/1 5.This includes a commitment to high quality
public space; accessible countryside;and places where people want
to live and stay.
19. Risk Assessment Implications
19.1 A detailed assessment of risks (and mitigating steps) is
set out in the tableattached as Appendix 5.
20. Equalities Impacts
20.1 Workforce Equality Impacts Assessment
There are no (significant) workforce equality issues arising
from this report.
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20.2 Equality Impact Assessments
There are no (significant) equality issues arising from this
report. The main conclusionis that the proposed site survey will
provide a holistic overview of the on-sitecontaminants, thereby
eliminating the gaps in knowledge arising from the previous adhoc
surveys which have taken place. This improved knowledge will then
allow a betterunderstanding of the risks posed by the site, as well
as arising from any subsequentremediation or development.
Background PapersDocument Place of Inspection
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Appendix IList of previous studies relating to the former TBA
site
Date Author I SubjectCommissioned by:
July 2006 Atkins Former Turner Brothers Asbestos Plant
AsbestosEnvironmental Review of Outline PlanningSubmission D44701:
Non-Technical SummaryReport (Doc ref: 077_30849)
July 2006 Atkins Non- Asbestos Environmental Review of
OutlinePlanning Submission D44701: Non-TechnicalSummary Report (Doc
ref: 077_308050)
April 2005 Encia Audit, Asbestos Disposal Areas at Spodden
Valleyand July & The Former Federal Mogul Factory Site,
Rooley2004 Moor Rd, Rochdale (Report No. 6134/2)
April 2008 ERM Former Federal Mogul Site, Rochdale,
ConceptualSite Model Report
Jan 2011 ERM Asbestos Ground Contamination Survey
(18January2011)
25 March Knight Frank Report2009
Feb 201 1 REFA Consulting Proposed Residential Development,
ShawcloughEngineers Road, Rochdale, Lancashire for Wain Homes
LMT
(GI Report 09095)
unknown TBA Composites Application for Substantial Change toLtd
Authorisation 17/94 under the 1990 EPA
Feb 1993 TBA Composites TBA Sealing Materials LMT EPA
Application forLtd Authorisation under IPC
Sept 1997 T&N Composites Automotive Heat & Vibration
Management Report
15 January URS Phase 1 Environmental Assessment of Federal2001
Mogul Systems Protection Group, Rochdale, UK
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(Report No. 1 4084-034-420!RL!MS!pI
Feb 2013 URS United Utilities Air test certificate
June 1994 Wimpey Desk Study ReportEnvironmental Ltd
July! August Wimpey SI Report1994 Environmental Ltd
15 July 2008 WSP Former Federal Mogul Site, Rochdale,
NonTechnical Summary for Conceptual Site ModelReport
23 January Tyler Grange Former Federal Mogul Site, Rochdale
Ecological2014 Appraisal
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Appendix 2
TBA — Gaps in knowledge
In 2006 Rochdale BC commissioned Atkins to carry out a peer
review of the planningsubmission relating to the redevelopment of
the former TBA Plant. The purpose of the peerreview was to assess
the environmental assessment works undertaken to date to assistRMBC
in assessing the application from the context of environmental
condition and whetherthe proposed redevelopment and remediation
options will render the site “suitable for use”under the current
Planning Regime and its associated guidance to land
contamination.
The peer review was based on information provided in support of
the outline planningapplication ref D44701 and receipt of a
supplementary ground investigation in June 2005.Additional
anecdotal information was also collated as part of this review.
Atkins did not undertake any ground investigations or laboratory
analysis as part of thisassessment, nor completed any generic or
detailed quantitative risk assessments.
The recommendations provided in the report were for the sole use
of Rochdale BC to assistthe Council in making its decisions
relating to the outline planning application for the site.
Atkins subsequently divided the project into asbestos and
non-asbestos relatedcontamination. Two reports were produced;
Asbestos Environmental Review (the asbestosreport) and Non-Asbestos
Environmental Review (the non-asbestos report)
The “asbestos report” is 179 pages and the non-technical summary
is 29 pages. The reportpresents a detailed review of asbestos
ground contamination issues at the site and withinexisting factory
buildings.
The “non-asbestos report” is 139 pages and the non-technical
summary is 26 pages. Thereport presents a detailed review of the
non-asbestos contamination issues at the site.
Information contained in both reports was assessed against UK
regulatory requirementscurrent at the time of writing, relating to
the assessment and redevelopment of contaminatedland.
In completing the peer review, Atkins were not requested to
assess the followingpotential environmental impacts:
• Traffic impacts on the local area;
• Review of detailed ecological surveys; and
• Risks posed by offsite sources of contamination.
The review and assessment was conducted under the Planning
Regime and issues pertainingonly to the Part IIA regime
(contaminated land regulation) were not considered or discussed
inthe reports.
Both the “asbestos” and “non-asbestos” reports covered;• Site
history
• Site characterisation
• Previous environmental Investigations
• Previous conceptual site models
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• Atkins conceptual site model
• Previous risk assessment methodologies
• Recommended detail risk assessment framework
• Remediation and redevelopment
• Conclusions and recommendations
“Asbestos” Report Findings;
Contaminant Sources
It is generally considered by Atkins that the presence of
asbestos contamination cannot beruled out across much of the site,
due to the various stages of industrial development acrossthe site
and the fact that emissions to air of dusts which are assumed to
contain asbestos, areknown to have occurred. The landscaped areas,
some of which have been generallyunchanged since the site first
manufactured asbestos products, may therefore have receivedairborne
deposits of asbestos for some time, which may now be entrained
within the uppersoil surface. Asbestos is likely to widespread in
the disposal areas in the Northern WoodlandZone and within the
vicinity of mineshafts.
Northern Woodland
Asbestos wastes up to 4.5 metres thick have been reported in the
Northern Woodland Zone,within the vicinity of the former Harridge
Mill (now demolished). The Northern Woodland Zonehas been the
subject of the greatest sample density. It should be noted that a
phase ofasbestos removal works took place in 1996. The current
status of asbestos contaminationis not reliably known.
Steep side slopes in the extreme northern portion of the
Northern Woodland Zone arepotentially unstable geotechnically, with
previous asbestos exposure being identified at thesurface as a
result of tree and woodland soil instability.
Lodge Zone
Localised occurrences of asbestos have been identified in the
Lodge Zone. Based on itshistory, the Lodge Zone will potentially
have the least asbestos contamination present,although sampling
density to date is low.
Hollows Wood Zone
Asbestos has been identified in the Hollows Wood Zone. Again,
sample density isconsidered to be low, and some areas have not been
sampled to date, particularly theexisting woodland areas.
Southern Zone
Several areas of potential asbestos contamination are considered
to be present in theSouthern Zone. It is possible that infilled
mill races (reservoirs) may contain asbestoscontamination.
Upper Tier Zone
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Significant ground disturbance has taken place as the factory
expanded in the central factoryarea. This may have resulted in
asbestos contamination being redeposited on the southernand eastern
fringes of the site (Upper Tier and Hollows Wood Zone).
Lower Tier Zone
Atkins understands that crushed concrete stockpiles were present
within the Lower Tier Zone.The precise source of the stockpile
materials is not known, but analysis indicated onestockpile
contained asbestos.
Central Factory Area
Some areas of the central factory area have not been
investigated, asbestos wastes mighthave been placed beneath floor
slabs of buildings when factories have expanded. Thesematerials may
have been placed along strip footings or used to provide general
fill to theunderside of concrete floor slabs.
General
The majority of site investigations for asbestos have not been
targeted on the potentialsources identified (with the exception of
the Northern Woodland Zone).
The investigations have not been sufficiently targeted with
regards the proposed end useof the site.
Very little near surface sampling (ie
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• More surface sampling is generally required across the site to
reflect theproposed end use and final site levels.
• Clarification of asbestos contamination is required in the
Northern WoodlandZone, since the majority of asbestos sampling and
analysis was conducted priorto asbestos removal works being
undertaken in 1996.
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• Additional asbestos sampling and analysis should be conducted
in areas of thesite where no redevelopment is proposed, such as
landscaped areas andwoodland areas. It is considered that the
density of sampling required in theseareas should reflect the
likely activities which may give rise to future soildisturbance
(and hence exposure).
• Soil classification data should be collected during future
investigations. Soiltype and moisture content may influence the
risk assessment process.
• Background air quality data should be collected for the site,
particularly in areasof the site where asbestos has previously been
identified. PCOM techniques areconsidered to be an appropriate test
method, but sample volumes should reflectthe benchmark air quality
standards which Atkins has proposed for the site inthe “asbestos
report”.
• Atkins recommends dusts should be sampled in key void areas in
existingfactory buildings known to have contained asbestos fibre
opening andprocessing operations.
“Non Asbestos” Report Findings;
For the purposes of the report, Environmental risk means the
risks posed to human health,controlled waters (groundwater, surface
waters) and built structures (buildings, services etc)from the
presence of non-asbestos contaminants.
It should also be noted that there are known ecological
receptors; badger sets were identifiedin the Upper Tier Zone on the
periphery of the development area and the protected woodlandis
immediately to the west around the mill ponds / Lodge Zone.
Contaminant Sources;
Several hydrocarbons sources have been identified in the Lower
Tier Zone, immediately eastof the River Spodden. These are
associated with fuel tanks, oil storage tanks and otherfactory
processes which might have utilized hydrocarbons;
A major hydrocarbon source was present in the Flexitallic Zone,
which was the location of asolvent recovery process plant.
Isolated sources of contamination have been identified
associated with former oil-fired andcoal-fired boiler houses
located across the site.
It is evident from site historical photographs, that major
earthworks, associated with theasbestos factory expansion, have
resulted in the deposits of natural, and possibly man
made,materials in the southern and eastern parts of the site. This
might have implications for thecurrent distribution of
contamination across the site.
It is generally considered that, due to the various stages of
industrial development across thesite, the presence of non-asbestos
contamination cannot be ruled out across much of the site.
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Northern Woodland Zone
Although known historically as the location where the majority
of asbestos waste tipping tookplace, may contain other non-asbestos
contaminants within the asbestos wastes themselves.
Central Factory Area
It is considered likely that the central factory area, which
makes up the Lower, Middle, Upper,Flexitallic and Southern Zones,
will contain the most likely sources of non-asbestoscontamination
within them.
Several historical sources of contamination were been identified
across the site which maypose a risk to the future users of the
site which have not been assessed to date;
• The historical presence of a gasometer within the Southern
Zone;
• Potential backfilled structures and depressions which may
contain made groundcontaining biodegradable materials. These
infilled areas might be a potential source ofground gases;
• Ash deposits associated with coal fired boilers and previous
allotments on site and
• Transformers present in the industrial areas.
Site Investigations
Several phases of intrusive site investigation have taken place
across the site. Generally,investigations commenced in 1994 within
the Northern Woodland Zone, and then haveconcentrated on the
central factory area. The intrusive site investigations most
relevant to theassessment of non-asbestos contamination have been
completed since 2004.
Atkins recommends the following issues need to be addressed:
• Further intrusive ground investigations and chemical analysis
are required toaddress identified data gaps.
• The investigation and sampling strategy should be designed by
considering thelikely environmental risks both during and post the
redevelopment works posedby the known and suspected sources of
contamination. This should take account ofrisks to human health,
built structures, controlled waters and hazards from groundgases
and vapours.
• In designing further site investigation and chemical analysis,
consideration must begiven to the need for several rounds of
sampling where contaminantconcentrations may vary with time and
site conditions (groundwater & groundgas I vapour)
Environmental Risk Assessment
Atkins recommends that before detailed risk assessments are
attempted, the followingissues need to be addressed to ensure the
assessments are sufficiently robust:
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• Collate soil analysis data into appropriate groups in
accordance with current UKguidance, based on an appropriately
developed set of zone specific CSMs. Statisticalanalyses in
accordance with current UK guidance should be undertaken to
identify anyanomalies in the data sets.
• When undertaking generic human health risk assessments, Atkins
recommends thatappropriate generic screening criteria for soils
should be derived using UKregulatory compliant methods.
• Detailed risk assessments for both human health and controlled
waters shouldbe completed to inform the need for remediation
works.
• Detailed risk assessments should be conducted using
appropriate numericalmodels which have either been produced in the
UK or have been made UK compliant.
Remediation and Redevelopment
In reviewing the remediation and redevelopment proposals
submitted, Atkins did not reviewother potential geohazards
associated with the sites redevelopment. These include:
• flood risks on the proposed development;
• artesian groundwater conditions which have been noted across
southern parts ofthe site; and
• geotechnical risks associated with redeveloping the site. This
may include but not belimited to the presence of previous mine
workings, mine shafts and any subsequentfoundation
requirements.
Recommendations;
Any remedial works to mitigate risks posed by the presence of
asbestos in the NorthernWoodland Zone should consider the possible
presence of non-asbestos contamination.
A more detailed ground gas risk assessment is required and this
should extend to theassessment of vapour risks from known
hydrocarbon sources on site.
The implications of risk of piled foundations on controlled
waters, should be consideredas part of a piling risk assessment.
This will require approval from the Environment Agency.
The Environment Agency provided comment on the potential for
floods to occur at the site andhas identified the need to conduct
more detailed flood risk assessments. This has not beenconsidered
further in the context of environmental risk, but may warrant
further review whenthe flood risk assessment is completed.
The reuse of materials on site for the purposes of redevelopment
may require approval fromthe Environment Agency for waste
management purposes. It may be necessary todemonstrate no adverse
environmental risks are associated with the redeposit of
materialsacross the site as part of any waste exemption
applications.
A series of remediation technologies have been proposed for the
treatment of knownhydrocarbon sources in the Flexitallic Zone.
Atkins’ agrees with the suitability of thetechnologies proposed in
treating the hydrocarbons identified in this zone, and
recommends
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that detailed proposals should be provided for the commercial
redevelopments in theFlexitallic Zone, to ensure the finalisation
of remediation technologies considers theassessment of both end use
and foundation risks respectively.
Appropriate validation reports should be submitted to RBC for
approval. In the case ofcontrolled waters, appropriate approvals
should be obtained from the EnvironmentAgency when remediating to
be protective of controlled waters.
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Appendix 3
EXISTING BUILDINGS — ENFORCEMENT OPTIONS
Building Control has three main enforcement options for the
site, should it be necessary totake action at this stage.
It is worth noting that the enforcement scenarios have already
been made available to theCouncil’s Legal team, and these, to a
l-”” the need tr””” ftQueen’s Co for further
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Appendix 5
Risks Associated with the former TBA site
Risk Issues MitigationGround contamination Historical
information held; RMBC commissioned the Atkins report to
fragmented with gaps in knowledge review the asbestos issues. It
identifiedand linkages known and likely sources of asbestos
Information held is that groundcontamination does not pose a
danger tohuman healthAll information is in the public domain
Presence of other contaminants Unknown; site survey and full
report wouldidentify other contaminants and risk
2 Slope stability Recognised potential of asbestos fibre Walk
over surveys to identify trees whichrelease from uprooted trees in
the are in danger of uprooting.northern woodland area Action by
landowner to remove such trees
and make good the surface3 Mine Shafts Local information to
suggest that Unknown; site survey and full report would
asbestos materials were dumped identify the location of the mine
shafts onwithin whilst site operational site
4 Derelict buildings Unknown quantities of asbestos and Since
fire in January 2014 security has beenremaining on site asbestos
containing material in the improved
fabric of the building and void spaces Land owner paying for
security paSecurity managed via local site repNo further fires on
siteFire damaged building demolishedNo reported incursions onto
site
Suffer fire or collapse;Accepted a fire or building
collapsewould increase the risk of fibrerelease but no evidence to
quantifythe extent of the increase Site specific multi agency
emergency plan
developedAbility to mobilise perimeter air samplingduring an
emergency incident
5 Human health The risk to human health involves Duty to manage
asbestos on site and toconsiderably more than simply the prevent
release from site falls to the landpresence of asbestos. There
needs to ownerbe a pathway / route to a receptor. Duty towards
employees is the responsibilityReceptors can be: of the employer.
Workers on site Atkins report says the risk from the site is
. Trespassers low and remains so until further information
. Residents about the pathway / route to the receptorsis
knownConsidered with public health and PHE acomparison of Rochdale
Borough’s healthdata with other similar urban areas for
theincidence of lung disease. Difficult toquantify given the
significant time lag forlung disease associated with asbestos
and
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the limitations of the data heldConsidered with public health
and PHE areview of current literature of health effectsassociated
with asbestos sites. Thepublications relate to occupational
exposureand therefore difficult to draw any
robustconclusionsPerimeter air sampling would act asreassurance to
understand the level ofexposure to asbestos fibres in the local
area.Funding has been identified via PublicProtection, Building
Control and Rochdale
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TownshipContamination of the river from Unknown; site survey and
full report wouldasbestos or other contaminants on identify and
quantify risksite
6 River Spodden
7 Site Ownership
8 Site Owner There is a client representative whose Client
representatives are a locally basedRepresentatives aim is to
maximise the development company
opportunity for the site Reps are in direct and regular contact
withThey have no authority to make site ownersdecisions Contact
maintained with RMBCThey have no autonomy regardingissues
raised
9 Pressure Groups Local pressure groups are committed Officer
attendance at meetingsto the preservation of green open Sharing all
RMBC information with thespace groups repsHigh level of scrutiny
Reps have been involved in the conditionsCritical of regulatory
agencies attached to the recent demolition of the fireRegular raise
issues at Township and damaged building.Area ForumsGovernance
Issues are unresolvedBelieve cannot deal with the site as“normal
industrial premises” due toits previous usage
10 Funding No RMBC budget to deal with issues Members are asked
in principal to consideron the site funding streams from other RMBC
budgets /
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No UK funding via Contaminated LandGrants SchemeEuropean
Regional Development Fundcriteria are not met therefore no ERDF
is available for the site
RMBC and client representative havedeveloped an invitation to
tender andevaluated responses for a site surveyand full report on
the ground
contamination on site.Tender based on 50 / 50 split fundingNo
funding has been identified byRMBC to deliver
Used Home and Communities Agency termsand conditions
Used HCA 29roved contractor list
11 Jointly procured sitesurvey
contingencies / capital programme
12 RMBC
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