Remediation Strategy Report

Remediation Strategy
South London Mail Centre, Nine Elms, London
July 2014
Waterman Energy, Environment & Design Limited

Pickfords Wharf, Clink Street, London SE1 9DG,
www.watermangroup.com
\\Nt_server\transfer\WEED - Reformatted Reports\EED Report - Preliminary Environmental Risk
Assessment.dotm
Client Name: Royal Mail Group

Document Reference: EED13002-100.S.2.2.10.CWS
Project Number: EED13002-100
Quality Assurance – Approval Status

This document has been prepared and checked in accordance with
Waterman Group’s IMS (BS EN ISO 9001: 2008 and BS EN ISO 14001: 2004)
Issue Date Prepared by Checked by Approved by

First May 2013 Carl Slater Freddie Alcock Simon Handy
Second October 2013 Freddie Alcock Carl Slater Simon Handy
Third November 2013 Freddie Alcock Carl Slater Simon Handy
Fourth April 2014 Freddie Alcock Carl Slater Simon Handy
Fifth July 2014 Freddie Alcock Carl Slater Simon Handy
Comments
Our Markets
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Disclaimer
This report has been prepared by Waterman Energy, Environment & Design Limited, with all reasonable
skill, care and diligence within the terms of the Contract with the client, incorporation of our General
Terms and Condition of Business and taking account of the resources devoted to us by agreement with
the client.
We disclaim any responsibility to the client and others in respect of any matters outside the scope of the
above.
This report is confidential to the client and we accept no responsibility of whatsoever nature to third
parties to whom this report, or any part thereof, is made known. Any such party relies on the report at its
own risk.
Contents
1. Introduction .................................................................................................................................1
1.1 Objectives ........................................................................................................................1
1.2 Context of Document .......................................................................................................1
1.3 Regulatory Context ..........................................................................................................2
1.4 Constraints .......................................................................................................................4
2. Remediation Strategy .................................................................................................................5
2.1 Site levels .........................................................................................................................5
2.2 Works Phasing .................................................................................................................5
2.3 Enabling Works – Buildings, Fuel Station and Services ..................................................5
2.4 Archaeological Recording ................................................................................................5
2.5 Further Ground Investigation ...........................................................................................6
2.6 Removal of Redundant Gas Pipework .............................................................................6
2.7 Removal of Structures and Obstructions .........................................................................6
2.8 Heathwall Sewer and Southwestern Storm Relief Sewer ................................................6
2.9 Former Groundwater Abstraction Wells ...........................................................................6
2.10 Impact of residual contaminants on the River Thames....................................................7
2.11 Impact of residual contaminants on Embassy Gardens ..................................................7
2.12 Contaminated Soils ..........................................................................................................7
2.12.1 Treatment of Soil ......................................................................................................7
2.12.2 Soil excavation depths .............................................................................................7
2.13 Final Placement of Soils as part of Remediation Works ..................................................8
2.13.1 Basement Footprints, Service Corridor and Attenuation Tanks ...............................8
2.13.2 Areas outside of the footprint of the proposed basements, attenuation tanks and
service corridor .........................................................................................................9
2.14 Cover Layer ......................................................................................................................9
2.15 Management of Materials ..............................................................................................10
2.15.1 Licensing Issues .....................................................................................................10
2.16 Management of Shallow Groundwater...........................................................................11
2.17 Unforeseen Contamination ............................................................................................11
2.18 Imported Materials .........................................................................................................11
2.19 Protection of Workers and the General Public ...............................................................11
2.20 Management of odours ..................................................................................................11
2.21 Monitoring ......................................................................................................................12
2.22 Unexploded Ordnance ...................................................................................................12
2.23 Laboratory Testing and Accreditation ............................................................................12
2.24 Statutory Approvals ........................................................................................................12
3. Validation Report ......................................................................................................................13
4. Development Mitigation Measures .........................................................................................14
4.1 Permit to Dig System .....................................................................................................14
4.2 Areas of Soft Landscaping .............................................................................................14
4.3 Buried Services ..............................................................................................................14
4.4 Surface Water Drainage ................................................................................................14
4.5 New Foundations ...........................................................................................................14
4.6 Ground Gas and Vapour Protection Measures to new Buildings and Structures ..........15
Tables
Table 1: Reports pertaining to the redevelopment of the SLMC ................................................1
Contents
EED13002-100 S 2 2 10 CWS
Table 2: Summary of criteria controlling soil reuse in the footprint of proposed underground
structures. ....................................................................................................................9
Table 3: Criteria controlling soil reuse outside the foot print of proposed buildings, attenuation
tanks and the service corridor. .....................................................................................9
Appendices
Appendix A Figures
Appendix B Site Specific Target Criteria
Contents
EED13002-100 S 2 2 10 CWS
1. Introduction
1.1 Objectives
Waterman Energy, Environment & Design Limited (“Waterman”) was instructed by M3 Consulting on behalf
of Royal Mail Group to prepare a Remediation Strategy for ground contamination for the proposed
redevelopment of the South London Mail Centre in the Nine Elms district of London (hereafter termed “the
Site”). The Site currently consists of an operational delivery office, collection hub, vehicle service workshop,
vehicle parking and refuelling facilities and a large concrete plinth which occupies the central area. The
plinth is what remains following the recent demolition of the Mail Centre building. Plans showing the current
and proposed layout of the Site are presented in Appendix A.
The Remediation Strategy puts the focus on removal of sources of contamination and contaminative
infrastructure that could further and/or prolong the impact the on water quality beneath the Site This is
intended to have the effect of reducing the mass of contamination underlying the Site and thereby
significantly improving the subsurface contamination status of Site and surrounding areas. With the
exception of managing water to facilitate safe and well managed excavations specific groundwater
remediation will not be a component of the remedial works.
The objective of this document is to describe the overarching strategy that will govern how the remedial
works are delivered during the works. For operational reasons during the remediation works the Site has
been divided into Phase 1 and Phase 2. Remediation works will commence in the Phase 1 area and will
be directly followed by remediation works in the Phase 2 area. The Remediation Strategy outlined in this
document relates to both the Phase 1 and Phase 2 areas, i.e. the whole Site. A plan showing the Phase 1
and Phase 2 areas of the Site is presented in Appendix A.
A portion of the Site which is currently within the Royal Mail demise and will form a new road referred to as
New Mill Lane will be remediated prior to the rest of the Site. This work will be carried out by Ballymore in
agreement with the Environment Agency and Wandsworth Council.
This document should be read in conjunction with the reports listed in the following table.
Table 1: Reports pertaining to the redevelopment of the SLMC
Report Title Author Year Reference

Generic Quantitative Environmental Risk Waterman July 2013 EED Reference
Assessment EED13002-100
5.2.6_JC
Controlled Waters Detailed Qualitative Risk Waterman September 2013 Reference
Assessment EED13002-
100_7.2.5_FA
Environmental Management Plan Waterman July 2014 EED13002-100-R-
8-1-5-SR
1.2 Context of Document

This Remediation Strategy document has been prepared to facilitate discharge of the relevant section of
Planning Condition 41 of Planning Permission 2011/2462.
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This document was been prepared using information presented in the Generic Environmental Risk
Assessment Report (Reference EED13002-100 5.2.6_JC), the Controlled Waters Detailed Quantitative
Risk Assessment Report (Reference EED13002-100_7.2.5_FA) and following a meeting with the
Environment Agency and Wandsworth Council held on the 3 October 2013. The latter reports relate to the
whole Site and were prepared following an intrusive site investigation completed in July 2013. Both reports
have been submitted to Wandsworth Council in relation to Condition 41 of Planning Permission 2011/2462.
During the site investigation, completed in 2013, access to several areas of the Site was not available due
to Royal Mail operations. Therefore as part of the remediation of the Site, and as referenced in Section 2.5
of this document, supplemental site investigation will take place. The locations of the individual
supplemental site investigation positions have been agreed with the Environmental Agency and
Wandsworth Council and are presented in Appendix A.
On completion of the supplemental site investigation an interpretive report detailing the findings of the work
will be prepared and submitted to Wandsworth Council in relation to Condition 41. Also, if required, the
Remediation Strategy will be updated to reflect how previously unforeseen contamination will be
remediated. The updated Remediation Strategy will be submitted to Wandsworth Council in relation to
Condition 41. Remediation in the areas covered by the supplemental site investigation will not take place
without approval from Wandsworth Council and the Environment Agency.
1.3 Regulatory Context

The Site is to be redeveloped for a residential led development which will include basements, internal public
realm areas surfaced with hard-standing, soft landscaped areas and tree pits. A feature of the
redevelopment of the Nine Elms area will be the creation of a Linear Park. The park will connect sites from
Battersea Power Station to Vauxhall Cross, incorporating the SLMC, with a continuous corridor of
landscaped open space and park land. There will be no private gardens at ground level.
Planning Condition 41 of Planning Permission 2011/2462 states that:
“Prior to the development a site investigation shall be undertaken for land and groundwater contamination
that fully categorise site conditions over the full extent of the of the site area. The results of the
investigation(s) shall be used to assess risks to future occupiers of the site to controlled water and to the
wider environment. The assessment shall be based on criteria relating to the residential use of the
developed site. A report detailing the investigation results and risk assessment shall be submitted to the
approval of the Council prior to the commencement of the development. If the assessment indicates that
there may be unacceptable risks to future users and/or controlled water, then a detailed remediation
strategy that addresses these risks shall be submitted for approval by the Council. The approved scheme
of remediation and/or mitigation shall be implemented as part of the redevelopment of each plot forming
part of the development shall not be permitted until these measures have been undertaken to the
satisfaction of the Council for that developed area.”
The National Planning Policy Framework (NPPF) sets out Government planning policy for England and
how this is expected to be applied to development. Paragraphs 120 to 122 of Section 11 – Conserving and
enhancing the natural environment of the NPPF relate to contaminated land matters and state the following:
“To prevent unacceptable risks from pollution and land instability, planning policies and decisions should
ensure that new development is appropriate for its location. The effects (including cumulative effects) of
pollution on health, the natural environment or general amenity, and the potential sensitivity of the area or
proposed development to adverse effects from pollution, should be taken into account. Where a site is
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EED13002-100 S 2 2 10 CWS
affected by contamination or land stability issues, responsibility for securing a safe development rests with
the developer and/or landowner.
Planning policies and decisions should ensure that:
 the site is suitable for its new use taking account of ground conditions and land instability, including from
natural hazards or former activities such as mining, pollution arising from previous uses and any
proposals for mitigation including land remediation or impacts on the natural environment arising from
that remediation;
 after remediation, as a minimum, land should not be capable of being determined as contaminated land
under Part IIA of the Environmental Protection Act 1990; and
 Adequate site investigation information, prepared by a competent person, is presented.
In doing so, local planning authorities should focus on whether the development itself is an acceptable use
of the land and the impact of the use, rather than the control of processes or emissions themselves where
these are subject to approval under pollution control regimes. Local planning authorities should assume
that these regimes will operate effectively. Equally, where a planning decision has been made on a
particular development, the planning issues should not be revisited through the permitting regimes operated
by pollution control authorities.”
In order to assess the contamination status of the Site, with respect to the proposed end use, it is necessary
to assess whether the Site could potentially be classified as “Contaminated Land”, as defined in Part IIA of
the Environmental Protection Act 1990 and Contaminated Land Statutory Guidance 2012. This is assessed
by the identification and assessment of potential pollutant linkages. The linkage between the potential
sources and potential receptors identified needs to be established and evaluated.
To fall within this definition, it is necessary that, as a result of the condition of the land, substances may be
present in, on or under the land such that:
a) significant harm is being caused or there is a significant possibility of such harm being caused; or
b) significant pollution of controlled waters is being caused, or there is significant possibility of such
pollution being caused.
It should be noted that DEFRA has advised (Ref. Section 4, DEFRA Contaminated Land Statutory
Guidance 2012) Local Authorities that land should not be designated as “Contaminated Land” where:
a) the relevant substance(s) are already present in controlled waters;
b) entry into controlled waters of the substance(s) from land has ceased; and
c) it is not likely that that further entry will take place.
These exclusions do not necessarily preclude regulatory action under the Environmental Permitting
(England and Wales) Regulations 2010, which make it a criminal offence to cause or knowingly permit a
water discharge of any poisonous, noxious or polluting matter to controlled waters. In England and Wales,
under The Water Resources Act 1991 (Amendment) (England and Wales) Regulations 2009, a works notice
may be served by the regulator requiring appropriate investigation and clean-up.
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1.4 Constraints
This assessment was undertaken in accordance with the scope agreed between Waterman and Royal Mail
Group and the Professional Services agreement and Framework Agreement.
The benefit of this report is made to Royal Mail Group.
Waterman has endeavoured to assess all information provided to them, but makes no guarantees or
warranties as to the accuracy or completeness of this information.
The scope of this strategy includes an assessment of the presence of asbestos containing materials in the
ground at the Site but not within buildings or structures or below ground structures (basements, buried
service ducts and the like).
The conclusions resulting from this study are not necessarily indicative of future conditions or operating
practices at or adjacent to the Site.
The Remediation Strategy is based on the findings and recommendations of the Generic Quantitative
Environmental Risk Assessment report for the Site completed in July 2013 and the Controlled Waters
Detailed Quantitative Risk Assessment completed in September 2013. The environmental assessment
comprised a review of documentation and information pertaining to the Site, including recent ground
investigations undertaken by ESG and previous intrusive ground investigations undertaken by others.
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2. Remediation Strategy
2.1 Site levels

The Finished Ground Level of the Site following development will be approximately 4.0m AOD. It should
be noted that this level may be subject to alteration subject to final detailed design. For the purpose of this
document depths will be reported relative to mAOD. The formation level is assumed to be 3.5m AOD. A
plan showing basement depths relative to the individual buildings is provided in Appendix A. Proposed
basement depths vary between 1.5m to -0.5m AOD. It should be noted that basement depths are indicative
only. A service corridor and attenuation tanks is proposed to be provided on the Site the base of which will
be 1.5m AOD. The attenuation tanks base, service corridor and basement slab thicknesses are assumed
to be 0.5m.
A plan showing the approximate location of the basements, service corridors and attenuation tanks is
presented in Appendix A.
2.2 Works Phasing

The remedial works will comprise two phases. Phase 1 will consist of the western two thirds of the Site,
and Phase 2 will consist of the remaining area to the east. The Phase 2 area is currently occupied by the
Delivery Office and vacant possession of this area will not be achieved until 2017. A plan showing both
phases is presented in Appendix A. Given that the remedial strategy focuses on the removal of
contaminated soil and contaminative structures it is considered not necessary to install a barrier to
hydraulically separate Phase 2 from Phase 1. Moreover significant migration of contamination from Phase
2 to Phase 1 would not be expected to occur given the groundwater flow direction is north towards the River
Thames.
2.3 Enabling Works – Buildings, Fuel Station and Services

In Phase 1 the Collection Hub and the Vehicle Workshop will demolished prior to the remediation works
commencing. All floor slabs and surfacing will be removed and foundations will be grubbed out. This will
include grubbing out of foundations to former below ground structures to a depth of 1.5m mAOD to facilitate
construction of new foundations, services and other below ground works. Where possible demolition
materials will be processed and reused on Site.
The fuel station will be decommissioned and all fuel removed from Site for recycling as part of the Phase 2
works. The fuelling island, fuel tanks and associated pipework will be removed from Site following
degassing by a specialist contractor.
Buried services, substations or other statutory undertakers plant will be made safe and capped off at the
site boundary to facilitate the remediation works. Redundant service pipelines and cables will be removed
following confirmation they are dead. Where pipes exit the Site, they together with any permeable pipe
bedding materials, will be sealed up at the Site boundary.
2.4 Archaeological Recording

Archaeological recording and investigations will be undertaken to facilitate the remediation works in
accordance with the Written Scheme of Investigation (WSI) as agreed with English Heritage. The WSI has
been submitted separately to Wandsworth Council under planning condition 37 application 2011/2462. The
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archaeological investigation will be carried out as part of the remediation contract. Archaeological work will
be carried out prior to other work commencing which may damage any archaeological remains.
Archaeological investigation works will be supervised by a suitability qualified archaeologist.
2.5 Further Ground Investigation

Further investigations will be undertaken to fill in gaps in the existing information available for the Site. This
will include investigation of the following areas:
 building footprints following demolition; and
 former gasworks structures not previously investigated.
The investigations will be specified and managed by a suitably qualified Environmental Consultant following
agreement of the scope with Wandsworth Council and the Environment Agency. The findings of the
investigations will be used to further define the remedial methodology in these areas. A plan showing areas
where additional investigation will be carried out is presented in Appendix A.
2.6 Removal of Redundant Gas Pipework

Redundant cast iron gas mains will be investigated for the presence of liquids and tars prior to disturbance.
Should they be found to contain liquids or tars, these will be pumped out prior to excavation of the redundant
cast iron gas mains.
2.7 Removal of Structures and Obstructions

Below ground structures that require removal will be investigated for the presence of liquids and tars prior
to disturbance. Should they be found to contain liquids or tars, these will be pumped out prior to excavation
of the below ground structures.
Below ground structures will be removed across the whole Site to a depth of 1.5m AOD. In areas of
proposed basements and service corridor below ground structures will be removed to a depth of -1.0m
below the top of the proposed basement slab. The details of remaining obstructions will be recorded and
surveyed in to the National Grid and reduced levels recorded.
The base to the two former gas holder bases (No 2 Gas Holder and No 3 Gas Holder) will be broken out
following removal of the contents, dewatering and cleaning of the walls and base.
2.8 Heathwall Sewer and Southwestern Storm Relief Sewer

Topographic and condition surveys of the Heathwall Sewer and the Southwestern Storm Relief Sewer will
be carried out to confirm the depth and condition of the sewers. The Southwestern Storm Relief Sewer is
known to be at a depth of approximately 10m below current ground surface and therefore within the London
Clay Formation. The Heathwall Sewer is at a depth of approximately 5.0m below current level.
If there is evidence of significant ingress of contamination then discussion will be held with Thames Water
as to the appropriate method of remediation whilst maintaining the integrity of the sewer and its operation.
2.9 Former Groundwater Abstraction Wells

Investigations will be carried out to attempt to locate the former groundwater abstraction wells on the
southern boundary of the Site and to determine their status. If found the wells will be decommissioned and
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capped off in accordance with Environment Agency guidance note “Good practice for decommissioning
redundant boreholes and wells” (2012).
2.10 Impact of residual contaminants on the River Thames

The issue of off-site migration of contaminants impacting on the River Thames has been assessed by
undertaking a Detailing Quantitative Risk Assessment (DQRA). The findings of the assessment are
reported report reference EED13002-100-R-7.1.5.FA. The DQRA assumed that whilst the Alluvium and
Kempton Park Gravel aquifers underlying the Site and in the area down groundwater gradient of the Site
are controlled waters that they are pathways for the migration of contamination to the River Thames. On
this basis the DQRA concluded that the River Thames was not at significant risk of contamination following
completion of the development. It is considered that removal of contamination sources and contaminative
structures will improve groundwater quality in the Kempton Park Gravels and Alluvium aquifers and will
further reduce the risk to the River Thames.
2.11 Impact of residual contaminants on Embassy Gardens

Currently a sheet pile wall is installed on the Embassy Gardens site close to its boundary with the South
London Mail Centre. The sheet pile wall was installed as a control measure during the remediation of the
Embassy Gardens site and this will remain in place permanently protecting the site from any residual
contamination.
2.12 Contaminated Soils
2.12.1 Treatment of Soil

Locations that contain significant amounts of tar or significantly elevated concentrations of contamination
have been identified and soils in these areas will require treatment. Where excavated soils are significantly
contaminated they will be subject to treatment to render them acceptable for re-use on the Site or disposal.
This will include soils excavated to facilitate removal of obstructions, redundant gas mains or other services,
from within gas holder bases or other below ground structures. A plan showing the location of contamination
exceedances and historic infrastructure is provided in Appendix A.
Treatment of soil on Site is likely to be ex situ and to include both chemical and physical methods so
materials can be placed and compacted to an appropriate earthworks specification. However, in situ
treatment of soils may also be utilised to immobilise contaminants that are potentially mobile but would not
be required to be excavated to facilitate removal of obstructions.
It is expected that a certain amount of material will required to be disposed offsite as hazardous waste. This
will comprise residue from remedial and or treatment activities. Material deemed too contaminated to be
subject to successful remediation will be subject to a process to reduce as much as possible the amount of
hazardous waste being removed from the Site.
2.12.2 Soil excavation depths

Where contaminated material is required to be excavated this will be undertaken in a controlled and phased
manner to ensure that any contamination encountered is contained during the works. Excavation works
will adhere to the guidelines set out in the Environment Agency's Pollution Prevention Guidelines (PPG's),
particularly PPG5: Works In, Near or Liable to Affect Watercourses.
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Above the water table the necessity to excavate contaminated soil will be governed by Site Specific Target
Criteria (SSTC) which have been generated to protect the River Thames from the contaminants of concern,
a document explaining the derivation of the SSTC is presented in Appendix B. Where validation testing
indicates that contaminants are below the relevant site specific criteria the excavation depth will be deemed
sufficient providing the requirement in relation to buried obstructions have been met.
Where an excavation has reached the groundwater and the results of the validation testing show an
exceedance(s) a visual assessment of the excavation by a suitably qualified environmental engineer will
take place. This inspection will record the nature of the exposed soils including details of the visual
appearance of the soils e.g. discolouration, oily sheens and any malodour e.g. fuel odours, coal tar.
Following the inspection if required the excavation will continue by up to 1.0m below the groundwater table.
Groundwater levels on the Site were recorded between 1.02mAOD and -0.87mAOD, with the average
groundwater depth recorded at 0.26mAOD. For the purposes of excavation, reaching groundwater shall
be considered to have occurred when the Contractor and Supervisor both agree that groundwater has been
intercepted in an excavation and is in line with the site investigation information for that area of the Site.
Water within structures will not be considered as groundwater.
As mentioned previously the results of the DQRA have indicated that contaminant concentrations in
groundwater flowing off Site are not significantly impact the River Thames. Therefore the Remediation
Strategy focuses on source removal as the primary remedial method as opposed to groundwater
remediation. On this basis it is considered that removing soil to a depth of 1.0m below groundwater level
is sufficient with respect removing soils that could potentially contribute to further degradation or prolong
the impact on groundwater quality beneath the Site.
This methodology ensures a cost effective approach to the excavation of contamination at depth avoiding
scenarios where extensive stepped excavations or installation of temporary works would be required to
remove this contamination, when this material has been shown not to pose a significant risk to the River
Thames.
2.13 Final Placement of Soils as part of Remediation Works

The remedial concentrations governing the placement of soils will depend on the specific location the soil
is being placed following remediation and the proposed end use of that part of the Site. A summary of the
minimum requirements controlling soil suitability is presented in the following tables. A conceptual
subsurface model of the Site following remediation is presented in Appendix A.
2.13.1 Basement Footprints, Service Corridor and Attenuation Tanks

Material placed within footprints of the future basements the service corridor and attenuation tanks will be
such that, when excavated it can be used elsewhere on Site and/or is classified as inert* or non-hazardous*.
Material placed below the water table in these areas will be classed as inert* and will have to meet Site
specific criteria to protect the River Thames. If material excavated from these areas is proposed to be
reused on Site it has to meet the criteria for material in that area. A conceptual subsurface model of the
Site following remediation is presented in Appendix A.
Table 2 summarises the minimum criteria for soils intended to be placed in the footprints of the basements,
service corridors and attenuation tanks.
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Table 2: Summary of criteria controlling soil reuse in the footprint of proposed underground structures.
Depth Waste Criteria to protect Material Type

Classification identified receptor
3.5m to 2.5m AOD Inert* or non- Site specific criteria to Flint gravel/ granular
hazardous* protect River Thames material
2.5m to 1.5m AOD. Inert* or non- Site specific criteria to No particular

hazardous* protect River Thames requirements
1.5m AOD to the base Inert* Site specific criteria to Flint gravel/other
of excavation protect River Thames granular material
*As defined by waste classification assessment undertaken in accordance with Environment Agency
guidance; Waste acceptance at landfills, Guidance on waste acceptance procedures and criteria
(November 2010).
2.13.2 Areas outside of the footprint of the proposed basements, attenuation tanks and
service corridor
Soil outside the footprint of the proposed basements, attenuation tanks and service corridors will be
required to meet with the remedial target concentrations for the Site. The criteria for these areas are
summarised in Table 3.
Table 3: Criteria controlling soil reuse outside the foot print of proposed buildings, attenuation tanks and the
service corridor.
Depth Criteria to protect identified receptor Material Type
3.5 to 2.5m AOD Human Health for Residential End-use Flint gravel/other granular
material
Site specific criteria to protect River
Thames
2.5m to 1.5m AOD. Site specific criteria to protect River No particular requirements
Thames
1.5m AOD to the base of Inert* Flint gravel/other granular

excavation material
*As defined by waste classification assessment undertaken in accordance with Environment Agency
guidance.
Groundwater levels on the Site were recorded between 1.02mAOD and -0.87mAOD, with the average
groundwater depth recorded at 0.26mAOD. For the purpose of backfilling only, a nominal groundwater
depth across the site is 0.5mAOD will be assumed. This will reduce potential complications associated
with varying and fluctuating groundwater levels that may arise when backfilling takes place.
2.14 Cover Layer

Notwithstanding the above a cover layer will be provided across the whole Site. The purpose of the cover
layer is to provide a vertical zone for follow contractors to work within when constructing roads, shallow
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services, soft landscaping etc. during the redevelopment works. The design will also take into consideration
the requirement for the Site to be trafficable as a construction Site.
The finished surface of the Site on completion of remedial works will be at the formation level (3.5m AOD)
with the exception of proposed locations the basements, attenuation tanks and service corridors. In these
areas, where material is expected to be removed from the Site as part of the development, levels can be
lower such that do not pose a risk to health and safety as a result of steep or collapsing faces. These areas
will not be at such a level that groundwater is exposed. Also the requirement for the cover layer and the
requirements as outlined in Table 2 will be remain applicable in these areas.
As backfilling takes place the Contractor shall place a marker layer at depth of 2.5mAOD in areas outside
the footprint of the buildings, attenuation tanks and service corridors. The marker layer shall comprise
bright orange barrier fencing which shall be laid with a minimum 200mm overlap (sideways) and a minimum
1000mm overlap (end of roll).
Following completion of the remedial works a permit to dig system would be operated for any deep
excavations that would penetrate the marker layer.
2.15 Management of Materials

The generation of stockpiles of excavated material will be minimised as far as is reasonably practical. Any
soils that are stockpiled on Site will be managed in a controlled manner, with different material types
segregated and clearly labelled. Each stockpile will be identified according to assumed or confirmed
categorisation, source, type and deposition date, and details of any chemical analyses. Stockpiles will be
physically separated to avoid cross contamination and temporary road access provided for placement and
loading. Stockpiles will be positioned on impervious surfaces to collect drainage and prevent loss of
entrained water and leachate to ground.
Mitigation measures will be employed to minimise wind whip from stockpiled materials. The Contractor will
determine the methods for appropriate handling and storage of materials which may include damping down
and covering of stockpiles where necessary.
Excavated soils will be reused wherever possible. Reuse of excavated soils on the Site will be subject to
use of appropriate protocols (see Licensing section below) and soils being chemically and geotechnically
suitable for the location they are to be placed. Where soils require treatment to facilitate their reuse this
will be subject to the protocols described in the licensing section below.
For waste soils that require removal off Site, waste classification analysis will be undertaken to confirm the
correct waste classification of the material and identify a suitable licensed facility to accept the waste.
Copies of all relevant licences for the disposal / treatment site will be provided prior to the waste being
taken off Site.
Full records of the quantities of materials disposed off Site and the receiving facilities will be kept during
the works. In addition, consignment notes for the materials will be collated.
2.15.1 Licensing Issues

A Site Waste Management Plan (SWMP) will be prepared for the remediation works and this will cover the
management of excavated materials and their removal from Site.
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The reuse, movement and/or treatment of soils on the Site will be completed in accordance with the
CL:AIRE The Definition of Waste: Development Industry Code of Practice April 2011. Alternatively a waste
exemption or permit will be obtained from the Environment Agency for this reuse activity.
Where secondary aggregates are brought onto the Site or generated on the Site (e.g. crushing operations)
these will be completed in accordance with the WRAP Quality Protocol for the production of aggregates
from inert waste. Alternatively a waste exemption or permit will be obtained from the Environment Agency
for this reuse activity.
2.16 Management of Shallow Groundwater

Shallow groundwater within the Made Ground, Alluvium and Kempton Park Gravels will be managed in a
controlled manner. The Site will be provided with a water treatment plant during the remediation works and
any shallow groundwater that requires pumping from excavations will be directed to the treatment plant. It
is anticipated that the water treatment plant will discharge the treated effluent to surface water sewer,
subject to approval from Thames Water and/or the Environment Agency.
2.17 Unforeseen Contamination

Should unforeseen contaminated materials or liquids or underground tanks be encountered, works will
cease in the affected area and the status of the contamination will be assessed. An addendum remediation
method statement for dealing with the materials, liquids or underground tanks encountered will be prepared.
This will include the collection of verification samples and chemical testing to demonstrate that the material
has been effectively remediated.
2.18 Imported Materials

All imported materials used on Site will be from a known source and appropriate for their intended use.
Chemical certification shall be provided for all materials imported to Site. The sampling programme for the
imported materials will be agreed with Wandsworth Council and the Environment Agency.
2.19 Protection of Workers and the General Public

The health and safety of all construction workers will be managed appropriately during the works providing
appropriate welfare facilities, decontamination facilities and personal protective equipment (PPE) and
respiratory protective equipment (RPE) commensurate with the contaminants present on the Site and the
activities being undertaken.
Appropriate mitigation measures and segregation of the works (including hoardings, damping down, odour
suppression and road sweeping) will be undertaken to ensure the general public are protected throughout
the duration of the works.
An environmental management plan (EMP) for the remediation works will be submitted to Wandsworth
Council for approval under planning condition 36 planning application 2011/2462. This will include liaison
with local residents with respect to the programme nature of the works.
2.20 Management of odours

Odour management measures will be provided during the earthworks phase to suppress the anticipated
odours from disturbance of soils contaminated with coal tars, fuel hydrocarbons and VOC’s. This will
Page 11 of 15
EED13002-100 S 2 2 10 CWS
include damping down, boundary mist sprays and curtains and use of odour suppression sprays. Air
monitoring will be undertaken to measure the effectiveness of the odour mitigation measures.
There is potential for further mitigation measures to be required, such as provision of an odour tent for
management and treatment of contaminated soils. This could include a fan-forced air-extraction system
that would push expelled air through an odour scrubber before release from the tent.
2.21 Monitoring
Monitoring with respect to sensitive environmental receptors will be undertaken during the works. This will
include the following:
 Noise;
 Vibration;
 Dust; and
 Odour.
2.22 Unexploded Ordnance

All intrusive works will take into account the potential for Unexploded Ordnance (UXO) to be encountered,
following the recommendations of the Threat Assessment undertaken for the Site.
2.23 Laboratory Testing and Accreditation

UKAS and MCerts accredited laboratories will be used for the chemical analysis of soils and groundwater
as required.
2.24 Statutory Approvals

All necessary approvals from the statutory authorities, including Wandsworth Council and Environment
Agency, will be obtained for the works undertaken.
A Validation Report will be submitted to Wandsworth Council, in accordance with planning condition 41,
application 2011/2462 at the appropriate time.
The works will be carried out and comply with all current applicable standards, codes, regulations, planning
conditions, guidance notes, legislation and health and safety conditions.
Page 12 of 15
EED13002-100 S 2 2 10 CWS
3. Validation Report
A Validation Report providing a record of the remediation works described above will be prepared. As a
minimum the Validation Report will include the following information:
 Location and volumes of treated soils retained on the Site including records under the relevant
protocols for their reuse;
 Location and volumes of recovered concrete from demolition or grubbing out retained on the Site
including records under the relevant protocols for their reuse;
 Remedial works undertaken to boundaries and adjacent surface water drainage;
 The source of any material imported onto Site, chemical test results, volumes of materials imported
and confirmation of cover layer thickness;
 The source of any imported materials and chemical test results, volumes of imported materials and
locations they have been placed on Site;
 Details of any unforeseen contamination encountered during the works and subsequent remedial
actions;
 Summary of consignment notes and chain of custody documents relating to the disposal of soils,
groundwater and asbestos containing materials from the Site;
 Locations and depths of the tops of obstructions left in place following remedial works; and
 Relevant approvals from Wandsworth Council and the Environment Agency for the works carried
out.
Page 13 of 15
EED13002-100 S 2 2 10 CWS
4. Development Mitigation Measures
The mitigation measures described below will be incorporated into the design of the proposed development.
4.1 Permit to Dig System

A permit to dig system would be operated for any construction works that are scheduled to penetrate the
cover layer. This will ensure that risks to construction workers, groundwater and the proposed construction
are considered and managed appropriately.
4.2 Areas of Soft Landscaping

Certified clean topsoil/subsoil will be placed in areas of soft landscaping acting as a cover layer thereby
breaking the source receptor linkage between any residual made ground and future Site users and
providing a clean growth medium for new planting.
The topsoil/subsoil to be used will be certified as suitable for use prior to being imported to the Site and will
be from a known source (preferably natural inert). A minimum of three samples of soil per source will be
submitted for analysis to confirm its suitability.
Chemical certification shall be provided for all materials imported to Site. The sampling programme for the
imported materials will be agreed with Wandsworth Council.
The topsoil/subsoil will be at least 0.6m in thickness with tree pits being provided with an appropriate
thickness of topsoil/subsoil dependant on the type of tree. The thickness of the growth layer will be verified
following placement to demonstrate compliance.
4.3 Buried Services

Clean service corridors will be provided for all new underground services. In particular, drinking water
supply pipes will be resistant to the residual ground conditions present on Site and will meet the
requirements of the “Guidance for the selection of water supply pipes to be used in brownfield sites”
(published by the UK Water Industry Research in 2011) and Thames Water.
4.4 Surface Water Drainage

The development will include a positive surface water drainage system that will intercept rainwater and
surface water run-off and prevent infiltration across the Site. This will prevent leaching and mobilisation of
residual contamination beneath the Site.
4.5 New Foundations

A Foundation Works Risk Assessment will be prepared for new foundations in accordance with “Piling and
penetrative ground improvement methods on land affected by contamination; Guidance on pollution
prevention” (Environment Agency 2001). This will assess the risk posed by new foundations eg piles and
will set out the approach to ensuring that the new foundations do not result in mobilisation of any residual
contamination on the Site.
Page 14 of 15
EED13002-100 S 2 2 10 CWS
4.6 Ground Gas and Vapour Protection Measures to new Buildings and Structures
Initial assessment of the ground gas regime for the Site indicates that it conforms to a Characteristic
Situation 2 (low risk) after “Assessing risks posed by hazardous ground gases to buildings” (published by
CIRIA in 2007). Gas protection measures will be incorporated into any proposed buildings on Site to break
the potential source receptor linkage between the future Site users and ground gas.
Vapour protection measures will also be incorporated into any proposed buildings on Site to break the
potential source receptor linkage between the future Site users and ground gas.
Given that all the main buildings will include a basement car park that will be provided with a ventilation
system to deal with vehicle exhaust fumes ground gas protection measures will not be required to these
buildings. However, drained cavities to the basement walls and any store rooms or other rooms within the
basement will need to be ventilated.
Other buildings without basements will be provided with ground gas protection measures comprising
protective measures commensurate with the building use in accordance with the guidance provided in
CIRIA 2007 or BS8485. This is envisaged to comprise passive measures incorporating vapour proof and/or
gas proof membranes and passively ventilated below slab layers or voids with all joints and penetrations
sealed.
Page 15 of 15
EED13002-100 S 2 2 10 CWS
Appendix
EED13002-100 S 2 2 10 CWS
Appendix A Figures
EED13002-100 S 2 2 10 CWS
Energy, Environment & Design
N
Project Details EED13002-100: South London Mail Centre
Figure Title Figure A3: Development Plots
Figure Ref EED13002-100_GR_SI_11A

Date July 2013
File Location \\nt-lncs\weedl\projects\eed13002\100\graphics\si\issued figures
© WATERMAN ENERGY, ENVIRONMENT & DESIGN

Reproduced from the Ordnance Survey maps with the permission of the Controller of Her Majesty’s Stationery Office,© Crown copyright, Waterman Energy, Environment & Design, Pickfords Wharf, Clink Street, London SE1 9DG. Licence number 100048868. www.watermangroup.com
Growth Medium Topsoil and Subsoil
Sub Base
Human health for residential use and site

specific criteria to protect The River Thames
Site specific criteria to protect The River Thames
Inert and / or non-hazardous and site specific

criteria to protect The River Thames
Inert and site specific criteria to protect

The River Thames
Basement Basement Basement Unexcavated Material
London Clay
Notes:
1. Unexcavated material to be validated to confirm

that excavation is not required. Validation to meet
site specific criteria to protect The River Thames.
2. Final formation level to be suitable for

construction traffic.
Remains of Gas Holder
3. Inert and non-hazardous is as defined by waste
classification assessment undertaken with
Environmental Agency guidance.
4. This figure is for indicative purposes only.

Details of the information shown here may be altered.
Historic Borehole
(if found to be grouted)
0 50m 100m 150m 200m 250m 300m 350m 400m
Approximate Groundwater 1.0m Below FL Formation Level (FL) SECTION PLAN
1.0m Above Approximate

Groundwater Removal of Obstructions
Contamination Hotspots and Finished Ground Level (FGL)

Contaminative Structures Removed
Figure Title Figure 14: Site Section B - B Site Conceptual Model
Figure Ref EED13002-100_GR_SI_14B

Date October 2013

Growth Medium Topsoil and Subsoil
Sub Base
Human health for residential use and site

specific criteria to protect The River Thames
Site specific criteria to protect The River Thames
Inert and / or non-hazardous and site specific

criteria to protect The River Thames
Inert and site specific criteria to protect

The River Thames
Basement Basement Service Basement Unexcavated Material

Corridor
London Clay
Notes:
1. Unexcavated material to be validated to confirm

that excavation is not required. Validation to meet
site specific criteria to protect The River Thames.
2. Final formation level to be suitable for

Remains of Gas Holder construction traffic.
3. Inert and non-hazardous is as defined by waste

classification assessment undertaken with
Environmental Agency guidance.
4. This figure is for indicative purposes only.

Details of the information shown here may be altered.
0 50m 100m 150m 200m
Approximate Groundwater 1.0m Below FL Formation Level (FL) SECTION PLAN
1.0m Above Approximate

Groundwater Removal of Obstructions
Contamination Hotspots and Finished Ground Level (FGL)

Contaminative Structures Removed
Figure Title Figure 15: Site Section A - A Site Conceptual Model
Figure Ref EED13002-100_GR_SI_15A

Date October 2013

Appendix B Site Specific Target Criteria
EED13002-100 S 2 2 10 CWS
Site Specific Target Criteria
April 2014
Waterman Energy, Environment & Design Limited

Pickfords Wharf, Clink Street, London SE1 9DG,
www.watermangroup.com
\\Nt_server\transfer\WEED - Reformatted Reports\EED Report - Preliminary Environmental Risk
Assessment.dotm
Client Name: Royal Mail Group

Document Reference: EED13002-100-R.4.1.2-FA
Project Number: EED13002
Quality Assurance – Approval Status

This document has been prepared and checked in accordance with Waterman Group’s IMS (BS EN ISO 9001: 2008, BS EN ISO
14001: 2004 and BS OHSAS 18001:2007)
Issue Date Prepared by Checked by Approved by

4.1.1 March 2014 Freddie Alcock Carl Slater Carl Slater
4.1.2 April 2014 Freddie Alcock Carl Slater Carl Slater
Comments
Our Markets
Property & Buildings Transport & Infrastructure Energy & Utilities Environment
Disclaimer
This report has been prepared by Waterman Energy, Environment & Design Limited, with all reasonable
skill, care and diligence within the terms of the Contract with the client, incorporation of our General
Terms and Condition of Business and taking account of the resources devoted to us by agreement with
the client.
We disclaim any responsibility to the client and others in respect of any matters outside the scope of the
above.
This report is confidential to the client and we accept no responsibility of whatsoever nature to third
parties to whom this report, or any part thereof, is made known. Any such party relies on the report at its
own risk.
Contents
1. Introduction .......................................................................................................................................... 2
1.1 Objectives ................................................................................................................................. 2
1.2 Constraints ................................................................................................................................ 2
2. Methodology used to determine SSTC ............................................................................................. 4
2.1 Selection of Contaminants of Concern ..................................................................................... 4
2.2 ConSim ..................................................................................................................................... 7
2.1 Physical and Chemical Parameters used in ConSim ............................................................... 8
3. Output of ConSim Model .................................................................................................................... 9
4. Conclusions .......................................................................................................................................10
Tables
Table 1: Reports Pertaining to the Site ................................................................................................... 2
Table 2: Summary of soil leachate concentrations in comparison to GAC ............................................. 4
Table 3: Summary of groundwater concentrations in comparison to GAC ............................................. 5
Table 4: Risk Assessment Input Criteria ................................................................................................. 8
Table 5: Output from ConSim Model ...................................................................................................... 9
Table 6: Confirmed SSTC .....................................................................................................................10

Contents
EED13002-100-R-4.1.2-FA
1. Introduction
1.1 Objectives
Waterman Energy, Environment & Design Limited (Waterman) was instructed by M3 Consulting on behalf
of the Royal Mail Group to prepare a specification (EED13002-100.S.5.3.1- CWS) for the proposed
remedial works at the South London Mail Centre. Site Specific Target Criteria (SSTC) for the remediation
of soil will be included as part of the Remediation Specification. The SSTC will comprise a list of dry soil
concentrations for the contaminants of concern.
These target criteria will be used:
 to govern the concentrations of the contaminants of concern permitted in site won material intended to
reused on Site during the remediation works, and
 as validation criteria for the sides and bases of excavation when contaminated material is be
excavated above a depth of -1.0m AOD.
With respect to soil being imported on to the Site a separate set of criteria will apply. These are
presented in specification document EED13002-100.S.5.3.1- CWS.
This document will set out the following:
 the appropriate contaminants of concern for which site specific remediation criteria will be generated;
 methodology used to derive the criteria; and
 a list of the SSTC relevant to the Site.
This document should be read in conjunction with the Controlled Waters Detailed Quantitative Risk
Assessment (EED13002-100-R.7.2.5_FA) which outlines the Conceptual Site Model for the Site following
development. This Conceptual Site Model is also considered to be applicable to deriving the SSTC for
remedial work. This document should also be read in conjunction with the Remediation Strategy
(EED13002-100-S.2.2.5_CWS) which describes the overarching remedial strategy of the proposed
works. A list of all reports pertaining to the Site is provided in Table 1. This report is written assuming the
reader is familiar with the contents of these reports and concepts described therein.
Table 1: Reports Pertaining to the Site

Author Title Reference
Waterman EED Ground Investigation Strategy, South London Mail EED13002-100-R.3.1.3_FA
Centre
Waterman EED Generic Quantitative Environmental Risk EED13002-100-R-5.1.6_JC
Assessment, South London Mail Centre
Waterman EED Controlled Waters Detailed Quantitative Risk EED13002-100-R.7.2.5_FA
Assessment
Waterman EED Remediation Strategy EED13002-100-S.2.2.5_CWS
A Site location plan and Site plan is identified in Appendix A.
1.2 Constraints
This work was undertaken in accordance with the Deed of appointment between Waterman and Royal
Mail Group.
The benefit of this report is made to the Royal Mail Group.
Waterman has endeavoured to assess all information provided to them during this investigation, but
makes no guarantees or warranties as to the accuracy or completeness of this information.

Page 2
EED13002-100-R-4.1.2-FA

Page 3
EED13002-100-R-4.1.2-FA
2. Methodology used to determine SSTC
2.1 Selection of Contaminants of Concern

The contaminants of concern are contaminants whose onsite concentrations are such that they have the
potential to impact the water quality of the River Thames. A review of the results of chemical analysis on
both soil and groundwater samples during the Generic Quantitative Environmental Assessment (GQRA)
has been carried out to determine the contaminants of concern. The results of the analysis have been
compared against the Generic Assessment Criteria relevant to the protection of a water body such as the
River Thames.
Where the results of chemical analysis have indicated a particular determinand is not elevated relative to
the GAC a SSTC concentration will not be generated on the basis that for Site won material these
determinands are not relevant in terms of potential impact on the River Thames. This rationale is
considered to be justifiable as the Site investigation purposely targeted contaminative infrastructure and
areas of the Site where contaminative activities were expected to have taken place.
Therefore the results of the chemical analysis should have detected those determinants that are at such
concentrations they are considered to be contaminants relative to the River Thames. A summary of the
results of comparison of contaminant concentrations in soil leachate and groundwater samples are
presented in tables 2 and 3.
Table 2: Summary of soil leachate concentrations in comparison to GAC

Maximum
Number of
Contaminant GAC Concentration
Exceedances
(units as per GAC)
Arsenic 50ug/l 32 None
Boron 1000ug/l 230 None
Barium 1000ug/l 530 None
Cadmium 5ug/l 0.5 None
Chromium 250ug/l 28 None
Copper 28ug/l 340 1
Lead 250ug/l 130 None
Mercury 1ug/l 0.2 None
Nickel 200ug/l 8 None
Zinc 500ug/l 383 None
Sulphate 400ug/l 920 4
Cyanide (free) 5ug/l 2260 12
Ammonia 21ug/l 15000 8
Benzene 8ug/l 33 None
Toluene 40ug/l <25 None
Ethyl Benzene 50ug/l 55 None
m/p Xylenes 30ug/l 117 None
o Xylene 30ug/l 71 None
Phenol 7.7ug/l 5.5 None
Naphthalene 2.4ug/l 329 2

Page 4
EED13002-100-R-4.1.2-FA
Anthracene 0.1ug/l 270 6
Fluoranthene 0.1ug/l 240 10
Benzo(b)fluoranthene 0.03ug/l 350 2
Benzo(k)fluoranthene 0.03ug/l 155 1
Benzo(a)pyrene 0.05ug/l 243 1
Indeno(1,2,3-cd)pyrene 0.002ug/l 204 4
Benzo(ghi)perylene 0.002ug/l 207 4
Table 3: Summary of groundwater concentrations in comparison to GAC

Maximum
Number of
Contaminant GAC Concentration
Exceedances
(units as per GAC)
Arsenic 50ug/l 368 3
Boron 1000ug/l 310 0
Barium 1000ug/l 170 0
Cadmium 5ug/l 1.6 0
Chromium 250ug/l 15 0
Copper 28ug/l 36 1
Lead 250ug/l 16 0
Mercury 1ug/l 1 0
Nickel 200ug/l 35 0
Zinc 500ug/l 37 0
Sulphate 400ug/l 1750 10
Cyanide (free) 50ug/l 24.3 18
Ammonia 21ug 295,000 67
Benzene 8ug/l 61,700 29
Eythelbenzene 50ug/l 4,556 25
Toluene 40ug/l 2,159 20
mp Xylene 30ug/l 12,000 34
o Xylene 30ug/l 24,000 31
Phenol 7.7ug/l 155,234.8 37
Naphthalene 2.4ug/l 22,000 30
Anthracene 0.1ug/l 211 53
Fluoranthene 0.1ug/l 425 62
Benzo(b)fluoranthene 0.03ug/l 129 70
Benzo(k)fluoranthene 0.03ug/l 117 65
Benzo(a)pyrene 0.05ug/l 91.6 65
Indeno(1,2,3-cd)pyrene 0.002ug/l 57.8 75
Benzo(ghi)perylene 0.002ug/l 41.6 75

Page 5
EED13002-100-R-4.1.2-FA
From a review of the results of leachate and groundwater analysis exceedances were recorded in the
following contaminants.
 Arsenic
 Copper
 Sulphate
 Cyanide (free)
 Ammonia
 Benzene
 Toluene
 Phenols
 Naphthalene
 Anthracene
 Fluoranthene
 Benzo(b)fluoranthene
 Benzo(k)fluoranthene
 Benzo(a)pyrene
 Indeno(1,2,3-cd)pyrene
 Benzo(ghi)perylene
These compounds are generally considered typical of the contamination expected following the operation
of a gas works and with the exception of copper and arsenic these contaminants were encountered
across the area of the Site subject to investigation.
Copper was found above the relevant GAC in only one groundwater sample and one leachate sample
and therefore the exceedances are not considered to be representative of copper concentrations in the
groundwater body underlying the Site and the capacity for the material on the Site to cause copper
contamination. Therefore given the copper concentrations detected in the soil leachate and groundwater
it is considered not to be a contaminant of concern.
With respect to Arsenic 3No. exceedances were recorded in groundwater samples collected from BH24
(368ug/kg April 2013, 57ug/kg May 2013 and 97ug/kg June 2013). Arsenic concentrations in other
groundwater samples and all leachate samples were below the GAC. A review of the results of chemical
analysis on dry soil concentrations indicates that the concentration of arsenic ranges from 1.70mg/kg to
36mg/kg with an average concentration of 10.75mg/kg. Regarding arsenic concentrations in soil samples
collected from BH24 these were recorded as 12.70mg/kg at 1.0m bgs and 14.30mg/kg at 4.50mbgs.
These concentrations are considered to be low considering the history of the Site. It is considered that
the results of dry soil, groundwater and leachate analysis indicate that arsenic contamination is not
widespread across the Site and that the soil underlying the Site is not a potential source of groundwater
contamination. Therefore arsenic is not considered to be a contaminant of concern. With respect to the
concentrations detected at BH24 any groundwater removed from excavations during the works will be
subject to treatment to ensure concentrations of contaminants meet the limits as specified in the
discharge consent.

Page 6
EED13002-100-R-4.1.2-FA
2.2 ConSim
The risk assessment tool ConSim was used to assess the potential impact contaminants in the
groundwater body underlying the Site may have on the River Thames. The benefit of ConSim is that is
can accept ranges of data and run a simulation for more than one contaminant at once.
To assess the potential impact of the contaminants on the River Thames the “Level 3” assessment was
used. This predicts the fate and transport of contaminants within the saturated pathway and their
concentrations at a specified receptor. The results of the assessment are presented as the likelihood of
the contaminant being above a certain concentration at the receptor. ConSim calculates results of user
entered time slices, to reflect a steady state scenario and results presented are for a maximum of
1000,000 year time slice.
The Site has been modelled as a single mass of soil with the receptor being set at a distance of 108m to
the north. This equates the closest point at which the River Thames is from the Site. This is considered
to be a conservative approach as the output of the model run at this distance will be applied to the whole
Site regardless of location relative to the River Thames.
An unsaturated thickness of 2.0m to 0.01m (minimum required) has been included in the model. The
inclusion of the unsaturated zone acknowledges that fact that not all material will required to be remove to
the depth of groundwater as part of the remedial works. Moreover where material has been removed to
the depth of groundwater there is a requirement that fill material from the groundwater level to 1.0m
above groundwater level shall comprise inert material.
The findings of the intrusive investigation carried out on site indicated that by in large aerobic conditions
prevailed in the unsaturated zone, therefore the model has been run assuming this scenario. Six rounds
of ground gas monitoring were carried out on 31 boreholes on Site. The results of the monitoring
indicated that methane was generally not detected above the limit of detection. Methane above the limit
of detection was only recorded in BH18 (1.7%) on two occasions and in BH31 (0.2% – 0.3%) on two
occasions. Therefore the assuming biodegradation in the unsaturated zone is considered appropriate in
terms of running the model.
The model has also been run assuming that biodegrading is not taking place in the aquifer. As discussed
in report EED13002-100-R-7.2.5.FA there was evidence to suggest that biodegradation was taking place
in the groundwater body therefore running model ignoring biodegradation is also see as a conservative
approach.
The model has been run without consideration of the back ground concentrations this is considered to fit
with the overall strategy of the remediation which is based on source removal as oppose to the
remediation of the groundwater body underlying the Site. Therefore the SSTCs derived from the output
of the model will ensure that the site won material reused as part of the remediation works will not pose a
risk to the quality of the River Thames this will result in a significant reduction of the contaminant loading
on the groundwater body underlying the Site.
A copy of the ConSim files are provided on CD accompanying this report.

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EED13002-100-R-4.1.2-FA
2.1 Physical and Chemical Parameters used in ConSim
To enable the quantitative risk assessment to be undertaken, specific parameters are required. Where
available Site specific data has been used, however, some, generic literature based values have also
been used. Data used is presented in Table 4.
Table 4: Risk Assessment Input Criteria

Parameter Value Units Information Source
Dry bulk density 1.7 to 2.4 g/cm³ Literature vales
Ranges of values bases on result of

Moisture content 4.2 to 41.6 %
laboratory analysis
Aquifer Thickness 2.1 to 12 m Range based on findings of SI
Ranged based used to model the fact

that not all material will be excavated
Unsaturated zone above the groundwater across the site
0.01 – 2.0 m
thickness and also that when backfilling 1.0m from
the groundwater level to 1.0m inert
material only shall be used
Based on 5% annual rainfall between

Infiltration 32 mm/yr
2000 and 2013 (Heathrow Airport)
FOC of soil source 3.13 % Calculated from on-Site measurements
FOC of soil in
3.13 % Calculated from on-Site measurements
unsaturated zone
FOC of aquifer
1.47 % Calculated from on-Site measurements
material
Hydraulic gradient 0.025 Flow Line A - Calculated from on-Site measurements

of water table 0.003 Flow line B Calculated from on-Site measurements
Hydraulic
0.0319 – 1.47 m/d Derived from Site permeability tests
conductivity
Effective porosity of
0.28 fraction RTM porosity calculator
aquifer material
Longitudinal dispersivity 10% of scale at

10.8 (north off Site) m
borehole BH1
Dispersivity
Lateral dispersivity 1% of scale at
1.08 (north off Site) m
borehole BH1

Page 8
EED13002-100-R-4.1.2-FA
3. Output of ConSim Model
The results of the output from Consim using the above input parameters are presented in Table 3.
Table 5: Output from ConSim Model

Source
Contaminants of concentrations
Concern GAC mg/l mg/kg Contaminants at receptor in relation to time slice (mg/l)
1yrs 20yrs 300yrs 5,000yrs 10,000yrs 100,000yrs 1,000,000yrs
NH4+ 0.021 0.80 0 0 0.0191 3.76E-10 0 0 0

Benzene 0.008 100 0 0 0.005 1.23E-12 0 0 0
0.00025 0.0051
Cyanide 0.001 (0.005 – 95%ile)* 0.1 0 (0) 0 (0) 0 (0) (0.0032) (0.0021) 0 (0) 0 (0)
Ethylbenzene 0.05 500 0 0 4.52E-22 1.40E-6 4.60E-12 0 0
Naphthalene 0.0024 50 0 0 0 0 0.0004 8.29E-9 0
Phenol 0.0077 30 0 0 0.00036 1.50E-18 0 0 0
Sulphate 400 5000 0 0 246.72 90.09 2.9 0 0
Toluene 0.04 100 0 0 0 0.00014 3.7E-08 0 0
Anthracene 0.0001 1000 0 0 0 0 0 0 0
Fluoranthene 0.0001 1000 0 0 0 0 0 0 0
Benzo(b)fluoranthene 0.00003 1000 0 0 0 0 0 0 0
Benzo(k)fluoranthene 0.00003 1000 0 0 0 0 0 0 0
Benzo(a)pyrene 0.00005 1000 0 0 0 0 0 0 0
Indeno(1,2,3-cd)pyrene 0.000002 1000 0 0 0 0 0 0 0
o-Xylene 0.03 500 0 0 0 0 0 4.07E-23 0
m/p-Xylene 0.03 500 0 0 0 0 1.70E-6 7.9E-8 0
Benzo(ghi)Perlyene 0.000002 1000 0 0 0 0 0 0 0

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EED13002-100-R-4.1.2-FA
4. Conclusions
Based on the output of ConSim model the SSTC are presented in Table 6
Table 6: Confirmed SSTC
Contaminants of Concern SSTC mg/kg

NH4+ 0.80
Benzene 100
Cyanide 0.1
Ethylbenzene 500
Naphthalene 50
Phenol 30
Sulphate 5000
Toluene 100
Anthracene 1000
Fluoranthene 1000
Benzo(b)fluoranthene 1000
Benzo(k)fluoranthene 1000
Benzo(a)pyrene 1000
Indeno(1,2,3-cd)pyrene 1000
o-Xylene 500
m/p-Xylene 500
Benzo(ghi)Perlyene 1000
These values will therefore govern the concentrations of the contaminants of concern admissible in site
won material only intended to reused on Site during the remediation works and as validation criteria for
the sides and bases of excavation when contaminated material is be excavated.

Page 10
EED13002-100-R-4.1.2-FA
GLOSSARY
For the purpose of this report, the following terms and definitions apply (see BS 10175:2001).
Accuracy Level of agreement between true value and observed value.

Conceptual Exposure Textual and or schematic hypothesis of the nature and sources of contamination, potential migration
model pathways (including description of the ground and groundwater) and potential receptors, developed on
the basis of the information from the preliminary investigation and refined during subsequent phases of
investigation and which is an essential part of the risk assessment process.
Note 1: The conceptual exposure model is initially derived from the information obtained by the
preliminary investigation. This conceptual model is used to focus subsequent investigations, where these
are considered to be necessary, in order to meet the objectives of the investigations and the risk
assessment. The results of the field investigation can provide additional data that can be used to further
refine the conceptual model.
Contamination Presence of a substance which is in, on or under land, and which has the potential to cause significant
harm or to cause significant pollution of controlled water.
Note 1: There is no assumption in this definition that harm results from the presence of the
contamination.
Note 2: Naturally enhanced concentrations of harmful substances can fall within this definition of
contamination.
Note 3: Contamination may relate to soils, groundwater or ground gas.
Controlled water Inland freshwater (any lake, pond or watercourse above the freshwater limit), water contained in
underground strata and any coastal water between the limit of highest tide or the freshwater line to the
three mile limit of territorial waters.
Note 1: See Section 104 of The Water Resources Act 1991.
Harm Adverse effect on the health of living organisms, or other interference with ecological systems of which
they form part, and, in the case humans, including property.
Hazard Inherently dangerous quality of a substance, procedure or event.
Pathway Mechanism or route by which a contaminant comes into contact with, or otherwise affects, a receptor.
Precision Level of agreement within a series of measurements of a parameter.
Receptor Persons, living organisms, ecological systems, controlled water, atmosphere, structures and utilities that
could be adversely affected by the contaminant(s).
Risk Probability of the occurrence, magnitude and consequences of an unwanted adverse effect on a
receptor.
Risk assessment Process of establishing, to the extent possible, the existence, nature and significance of risk.
Sampling Methods and techniques used to obtain a representative sample of the material under investigation.
Soil Upper layer of the earth's crust composed of mineral parts, organic substance, water, air and living
matter.
Note 1: In accordance with BS 10175:2001 the term soil has the meaning ascribed to it through general
use in civil engineering and includes topsoil and subsoil; deposits such as clays, silt, sand, gravel,
cobbles, boulders and organic deposits such as peat; and material of natural or human origin (e.g. fills
and deposited wastes). The term embraces all components of soil, including mineral matter, organic
matter, soil gas and moisture, and living organisms.
Source Location from which contamination is, or was, derived.
Note 1: This could be the location of the highest soil or groundwater concentration of the contaminant(s).
Uncertainty Parameter, associated with the result of a measurement that characterizes the dispersion of the values
that could reasonably be attributed to the measurement.

Glossary
EED13002-100-R-4.1.2-FA
EED13002-100-R-4.1.2-FA
EED13002-100 S 2 2 10 CWS
EED13002-100 S 2 2 10 CWS

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Remediation Strategy

South London Mail Centre, Nine Elms, London

Waterman Energy, Environment & Design Limited

Client Name: Royal Mail Group

Quality Assurance – Approval Status

Issue Date Prepared by Checked by Approved by

Table 1: Reports pertaining to the redevelopment of the SLMC

Report Title Author Year Reference

1.2 Context of Document

1.3 Regulatory Context

2.1 Site levels

2.2 Works Phasing

2.3 Enabling Works – Buildings, Fuel Station and Services

2.4 Archaeological Recording

2.5 Further Ground Investigation

2.6 Removal of Redundant Gas Pipework

2.7 Removal of Structures and Obstructions

2.8 Heathwall Sewer and Southwestern Storm Relief Sewer

2.9 Former Groundwater Abstraction Wells

2.10 Impact of residual contaminants on the River Thames

2.11 Impact of residual contaminants on Embassy Gardens

2.12 Contaminated Soils

2.12.1 Treatment of Soil

2.12.2 Soil excavation depths

2.13 Final Placement of Soils as part of Remediation Works

2.13.1 Basement Footprints, Service Corridor and Attenuation Tanks

Depth Waste Criteria to protect Material Type

2.5m to 1.5m AOD. Inert* or non- Site specific criteria to No particular

Depth Criteria to protect identified receptor Material Type

1.5m AOD to the base of Inert* Flint gravel/other granular

2.14 Cover Layer

2.15 Management of Materials

2.15.1 Licensing Issues

2.16 Management of Shallow Groundwater

2.17 Unforeseen Contamination

2.18 Imported Materials

2.19 Protection of Workers and the General Public

2.20 Management of odours

2.22 Unexploded Ordnance

2.23 Laboratory Testing and Accreditation

2.24 Statutory Approvals

4.1 Permit to Dig System

4.2 Areas of Soft Landscaping

4.3 Buried Services

4.4 Surface Water Drainage

4.5 New Foundations

Figure Title Figure A3: Development Plots

Figure Ref EED13002-100_GR_SI_11A

© WATERMAN ENERGY, ENVIRONMENT & DESIGN

Growth Medium Topsoil and Subsoil

Human health for residential use and site

Site specific criteria to protect The River Thames

Inert and / or non-hazardous and site specific

Inert and site specific criteria to protect

Basement Basement Basement Unexcavated Material

1. Unexcavated material to be validated to confirm

2. Final formation level to be suitable for

4. This figure is for indicative purposes only.