The promises

A Newport council 'Questionnaire for Parents' stated:
“Both the Compton Webb site and the stadium site . . . will be cleaned up to national environmental standards to ensure that they are safe. This will be a condition of planning permission.” 
However, it is not clear that any of the planning conditions attached to the planning permission referenced any national environmental standards.

Page 2 of the July 2000 newsletter for parents stated:
"The construction of re-developed schools at the Glebelands will only be supported if the land is 100% safe.”
However, it is not clear that, following land remediation, anyone has so far declared the land to be '100% safe'. Indeed, construction of the school commenced despite the fact that the Remediation Strategy, as of February 2011, has still not been completed fully.

Page 2 of the July 2000 newsletter for parents also stated:
“This decontamination work would be carried out under the watchful eye of the Environment Agency, Countryside Council for Wales and other independent organisations.”
However, there is no evidence to suggest that the Environment Agency, the Countryside Council for Wales or any other independent organisation kept a watchful eye on the decontamination work. 

Page 2 of the July 2000 newsletter for parents also stated:
“The condition of the land will be monitored regularly after the work is done.”

The Planning Application Schedule dated 25 October 2000 for 'Deemed Consent' planning application 00/0768 stated, under the heading 'Land Contamination':
“. . . it is considered that these works and associated monitoring over the long term, can ensure that contaminants on the site are removed or made safe to recognised standards”.

Newport council’s press release of 3rd July 2002 stated:
“Planning permission will only be granted if the developers meet the stringent conditions that have been given, including the detailing of processes used to make the site safe and future monitoring of the site.”

However, despite these promises, it appears that no programme for monitoring the condition of the land has been established.  As a minimum, the regular monitoring of Lotery's Reen should have been required because this reen was not lined as required by the Remediation Strategy or, therefore, as required by Condition 06 to planning permission 00/0768.


Lack of engagement of Statutory Bodies

Page 2 of Parents' Newsletter - Issue 2, July 2000 stated:
“This decontamination work would be carried out under the watchful eye of the Environment Agency, Countryside Council for Wales and other independent organisations.”

The very few number of site visits reported in Section 10.2 of the Remediation Validation Report indicates that Newport council failed to meet its promise that  “This decontamination work would be carried out under the watchful eye of the Environment Agency, Countryside Council for Wales and other independent organisations.”.

Indeed, it is not clear that either Environment Agency Wales (EAW), or the Countryside Council for Wales, or other independent organisations had kept a ‘watchful eye’ over the decontamination work.  There is no evidence that any of these organisations were ever purposefully engaged in monitoring the progress of the remediation works.  According to the Remediation Validation Report, the only site visit made by EAW was when Vinci Construction notified EAW about a pollution incident affecting Lotery’s Reen at the start of remediation works.

Section 10.2 of the Remediation Validation Report ‘Site Visits’ merely notes:
“Visits to site were undertaken by Mr Andrew Williams of NCC Environmental Health Public Protection Department on the 23rd June and 10th September to inspect the ongoing remedial works on site. EAW were consulted by Vinci Construction Limited regarding the potential leachate breakout event into Lotery’s Reen. Two representatives visited site on the 23rd June to collect samples and assess the situation. No further visits were undertaken and no further action was taken.”

In view of the complex nature of the remediation works; the lack of EIA; the site’s proximity to controlled waters; and the large volume of PCB contamination discovered on site during remediation works, It is surprising that the UK authorities have not commented about the clear lack of vigilance during remediation works by the Environment Agency, the Countryside Council for Wales, or by other independent organisations.


Control of contaminated material

Section 8.2 of the Remediation Strategy and Page 5 of the Method Statement (‘PCB Removal and Disposal’, 189573-MS025, Rev 0)  required stockpiled material to be covered with sheeting.  The Method Statement also stated that contaminated material held in one tonne bulk bags will need the bags to be closed tightly and held with cable ties.

No such protection measures were ever observed by local residents.  Stockpiled material was never seen to be covered, and the ‘one tonne’ bags were never observed to be closed tightly – being left open to the elements, including during periods of wind and rain.

Indeed, Sections 6.2 ‘Methodology’ and 6.3 ‘Excavation’ of the Remediation Validation Report make no mention of covering stockpiled contaminated material, or covering stockpiled material awaiting testing or validation.

Here are some pictures taken by local residents showing dozens of open-topped one tonne bags containing contaminated material and parts of corroded drums.   Note that huge quantities of toxic waste were being dealt with during these operations - far more than was expected.  Over 700 drums of toxic waste (over 2,000 tonnes of material) were recovered from this site.


 

The following colour pictures (Plates 37 and 38) from the Remediation Validation Report show uncovered stockpiled material awaiting validation, as well as more open-topped, one tonne bags.





Air quality monitoring

Section 8.1 of the Remediation Validation Report notes that
“Weekly air quality monitoring was undertaken during the active removal of PCB waste and associated soils.” and Section 8.5 notes “Site boundary asbestos air monitoring was undertaken by Manestream Limited at three locations on site . . . on a weekly basis during the remediation works”,
concluding,
“The monitoring results indicate that all samples taken were reported at <0.01 fibres/ml and deemed satisfactory.”

Local residents still feel that the frequency and scope of air monitoring (for asbestos only, at a frequency of only once per week) was woefully inadequate.  In view of the cocktail of contaminants known to be in the made ground, it remains deeply worrying why air quality monitoring did not test for a much wider range of toxic materials on a continuous basis or, as a minimum, several times during each working day.

When, during the summer of 2008, the number of severely corroded drums of polychlorinated biphenyls (PCBs) to be removed from the site had increased from an expected number of 20 drums to over 700 drums, the increased excavation activity on the site resulted in changes to the PCB Removal Method Statement to reduce the cost of disposal – but not a corresponding amendment to the air monitoring regime to address the increased risk from airborne pollutants.

In a letter dated 6th August 2008, Newport council’s Head of Education Services (Resources & Planning) wrote:
“The method being used for monitoring for the presence of asbestos fibres on a weekly basis has been approved by the United Kingdom Accreditation Service (UKAS) and is commonly used on remediation sites.”
However it is now known that this was not the case.  The method used for monitoring for the presence of asbestos fibres was never approved by the United Kingdom Accreditation Service.


The doubts
 

	It was images like those shown above, and the concerns about the perceived lack of effective air quality monitoring that led, in August 2008, to renewed calls for Environmental Impact Assessment and, ultimately, the formation of the Glebelands Alliance to seek justice in the planning and environmental matters raised by this development.
Members of the Glebelands Alliance highlighting the need for an Environmental Impact Assessment (EIA) (photo: Dave Yates)

An article headed 'Stop work on new 'toxic' school site' - with pictures of the open topped one-tonne bags - also appeared in the 11 August 2008 edition of the South Wales Argus.

Reports about the lack of EIA for the Glebelands development were also mentioned in the following editions of the ENDS Report:
ENDS Report 404, September 2008: School set for former PCB landfill site without EIA
ENDS Report 412, May 2009: Agency confirms it was not consulted on EIA
ENDS Report 417, October 2009: Battle over school plan for toxic site intensifies
ENDS Report 422, March 2010: Inquiry reveals Glebelands’ impact assessment failures
ENDS Report 427, August 2010: EIA regulations to be amended for England