an argument for a gis contaminated land inventory for the republic of ireland
DESCRIPTION
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.TRANSCRIPT
ICT and Environmental Regulation: Developing a Research Agenda,Whitaker Institute
Ryan Institute National University of Ireland Galway
AN ARGUMENT FOR A GIS CONTAMINATED LAND
INVENTORY FOR THE REPUBLIC OF IRELAND
Thursday 20 June - Friday 21 June 2013
Padraic Mulroy,BSc., MSc., MIEI, MIPSS, CSc, SiLC
Managing DirectorMulroy Environmental
Slide 2
Who are we?• Based in Dundalk, County Louth (the Wee County)• Started in 2007
Services• Due Diligence Site Investigation/Contaminated Land Risk
Assessment• Remediation/Bioremediation of Contaminated Soil &
Water• Waste Licence & Permit Applications• IPPC Licensing• Wastewater Treatment Plant Design for Single, Small
Community, Commercial & Industrial Development• Site Suitability Assessment• Environmental Impact Assessment• Sludge Management Expertise• Environmental Monitoring
BACKGROUND
MULROY ENVIRONMENTAL1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 3
EXTENT OF CONTAMINATED LAND IN REP. 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 deposits
1. 'Contaminated Land' Report of the Parliamentary Office of Science & Technology (1993).
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 4
EXTENT OF CONTAMINATED LAND IN GREAT BRITAIN
• Regular comparison to the birthplace of the Industrial Revolution – Great Britain with >100,000 potential contaminated sites 1
1. 'Contaminated Land' Report of the Parliamentary Office of Science & Technology (1993).
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 5
CONTAMINATED LAND INVENTORY FOR REP. OF IRELAND?
IRISH EPA STUDY 1999• Historical Sites
– Old Gas Works 50-80– Closed Landfills 265 (OEE figures?)– Closed Mine sites 128 (38 with Tailings
Ponds, 11 recent/present
high risk)– Old Fertiliser Plants 4-6– Closed Tanneries 10 -12
• Current Operational Sites– Existing Landfills 76 LA 50 Private
(Registration ongoing)
– 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? 1
1. CARACAS, Risk Assessment for Contaminated Sites in Europe, Volume II, Policy Framework, Brogan et al, 1999
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 6
CONTAMINATED LAND INVENTORY FOR REP. OF IRELAND?
• NI Environment Agency DATABASE
– >14,000 Potentially Contaminated Sites estimated in 2011
– Continual updating - & continuously revised upwards from 11,825 in March 2009
• High Risk - 8199• Medium Risk - 1811• Low Risk - 1599• Uncategorised - 216
– 30 land use categories
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 7
CONTAMINATED LAND INVENTORY FOR REP. OF IRELAND?
>14,000
>2,500??
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 8
EXTENT OF CONTAMINATED LAND IN THE NETHERLANDS
• 2004 - National List of Polluted Sites 425,000 Potentially Contaminated Sites.
SOURCE FOR CONTAMINATED LAND
INVENTORY
17%
3%
80%
Remediations & On-goingSite I nvestigations
OngoingRemediations/ Af tercare
I ndustrial/ CommercialActivites known to causecontamination
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 9
EXTENT OF CONTAMINATED LAND IN THE NETHERLANDS
DUTCH 2009 CONTAMINATED LAND
INVENTORY STATUS
42%
31%
16%
2% 2%7%
Suspect but not yet fullyinvestigated
Af ter pilot testing ofselected sector sites setto low priority
On-going Remediations &Af tercare
Completed SI and foundremediation not required
OngoingRemediations/ Af tercare
Completed af terremediation
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 10
EXTENT OF CONTAMINATED LAND IN THE IRELAND
Population:NI - 1.8mRep. of I – 4.6m Netherlands – 16.8m
Contaminated Inventory:NI - 14kRep. of I – ??k Netherlands – 425k
14,000
425,000
30,000?
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 11
CONTAMINATED LAND INVENTORY FOR REP. OF IRELAND?
WHO IS CORRECT?IRISH EPA OR NIEA
• 2006 DOELG/ARUP Report on Petroleum Sector
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 12
CONTAMINATED LAND INVENTORY FOR REP. OF IRELAND?
WHO IS CORRECT? IRISH EPA OR NIEA
• GSI SURGE Project, 2011 – Dublin Historic Industry Database - >2000 sites identified
• In EPA inventory there is an absence of information on following 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
(abandoned LA 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 Plan
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 13
CONTAMINATED LAND INVENTORY FOR REP. OF IRELAND?
WHO IS CORRECT? IRISH EPA OR NIEA
Town Gas Plants/Coal Tar in BI
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 14
CONTAMINATED LAND INVENTORY FOR REP. OF IRELAND?
WHO IS CORRECT? IRISH EPA OR NIEA
Town Gas Plants/Coal Tar37 in NI138 in Rep. of I 2
2. Mulroy Environmental Inventory using OSI on-line historical mapping
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 15
Why have a Contaminated Land Inventory in Ireland?
• Will help in identifying property which may be have been contaminated in the past by commercial or industrial activity
• Primary benefit in carrying out Due Diligence work on behalf of clientele wishing to assess risk to property for sale
• Allows assessment of not just site’s history but also history of neighbouring property which may be a risk to the property for sale (i.e. from incoming migration from off-site contamination)
• Buyer or buyer’s solicitor may then decide to approach environmental consultant to assess the site by either:– Phase I Site Audit (Non-intrusive SI); or– Phase II Site Investigation (Intrusive) – If evidence of
contamination is found during initial site audit
• Good practice – assess the cost of sorting out a potential problem – have another look at the asking price.
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 16
Current practice?
• Vendors relying on solicitors who may not have expertise to identify where a potential risk may exist
• Relying on vendor to furnish buyer with historical record of site – may not have any record
• Site may have changed hands a number of times• Site may have been leased to high risk operation with
no record• May be no evidence of previous use (e.g. Disused
Underground storage tanks (USTs), Aboveground Storage tanks (ASTs), bunds, pumps, etc
• Subsurface contamination – ‘out of sight…out of mind’ • Previous site investigation/environmental engineering
reports may be of poor standard with not enough detail • May not analysed for correct laboratory suite – relevant
to industrial sector (e.g. azodyes in textile facilities, etc)
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 17
Example - How it can go wrong
• Client is buying former commercial land adjacent to river with mixed retail use built in late 1960s. Wants to build residential apartment complex with underground carparking. On the ‘surface’ no indication of underlying problem
• Part of site on periphery formerly occupied by Petrol Retail Site – demolished overhead features (i.e. kiosk, pumps, ASTs, etc) but no information given on decommissioning/removal of USTs
• Ground floor unit formerly leased to Dry Cleaner operation for 3 years. No record.
• Site was partially built on:– Former railway depot property where railway
sleepers were treated; and– Former Brick manufacturer
• Central heating pipes contain asbestos lagging
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 18
Example - 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 be submitted as part of planning application.
• If LA don’t know, extent of problem becomes evident on excavation of formerly infilled material for construction of underground carpark. Developer alerted by contractor of floating petroleum type product within pit and on adjacent river and solvent odours in soil excavated under slab at another location.
• Where does the contaminated soil go? Hazardous? Costs? Budget amendment. C & D Waste Management Plan to be revised and approved by LA.
• Initial Demolition Phase halted due to discovery of asbestos lagging – delay/postponement in contractor’s work may lead to future claim against developer.
• Site Investigation/Risk Assessment now requested by LA to formulate Remedial Plan
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 19
Example - How it can go wrong
• Soil must remain on site until classified – space?• Project Management – delays, contractors to be
notified• EPA may need to be notified/consulted by LA• Forced into ‘dig and dump’ solution - expensive• Groundwater treatment – may require Discharge
Licence from LA• Existence of Dry Cleaning solvent in soil (i.e. PCE or
PERC) requires site investigation to assess DNAPL contamination to underlying aquifer – groundwater monitoring boreholes. Off-site migration?
• Existence of shallow creosote contamination (i.e. PAHs and phenols) in soil from former railway yard requires excavation and disposal as hazardous waste
• Ash present at high volumes in shallow soil from former brick manufacturer has heavy metal and PAH contamination - disposal at non-hazardous landfill
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 20
Where 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
which may be contaminated
UK Local Authority Contaminated Land Inventories• Example - Fife Council – 7,000 Sites collated using STM
GeoEnviron/ArcGIS
NIEA Contaminated Land Database• 30 Categories – What are they? 48 DOE Industrial Profile Guidance
Documents
Dutch Contaminated Land Database• XX? Categories – What are they?
Landmark Information Group• Private firm providing desk study & mapping services to legal &
environmental consultancy firms in UK
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 21
Where 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)– Tanneries
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 22
Where 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 establishments
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 23
Where do you start? - Learn from NI, UK, Dutch & USA
Sources of Information
• EPA Section 22/Historic Landfills List & Section 26 Hazardous Waste 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 & Dangerous
Waste 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 Trades
Directories/Gazeteer of Ireland, 1900, 1903, 1914, 1920, 1929 & 1965
• Griffith Valuation – information of land-use and uses of individual buildings
• Valuation Office Registers• Local histories & archives
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 24
Where do you start? – OSI Historic Mapping
1 Background
2 Extent of CL
3 ROI 1999 Inventory
4 NI Current Inventory
5 Dutch 2009 Inventory
6 Comparison
7 Why bother?
8 Current Practice
9 How it can go wrong
10 Where do you start?
Slide 25
THANK YOU!