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===== Quick and Cheap =====

I am afraid that the development of the South Tees site (4,500acres) in Redcar and Cleveland by Teesworks is being done quickly (reference to needing to do it quickly) and on the cheap([[https://www.teesworks.co.uk/news/mayor-welcomes-ukibs-107million-investment-into-south-bank-quay|Teesworks - 1st Infrastructure Bank Loan]]), which means it is likely to cause environmental if not also human health issues.  Yes a lot of money is being spent on the development, but that is only because there is a lot of land that is being developed.

In order to achieve a quick and cheap development many things are being done wrong, I think the pipes are a worrying example of just how wrong things are being done.
===== Not Remediation =====

I don't feel I can use the word remediation when talking about the current development of the South Tees site, as remediation means to clean up a contaminated site and the South Tees site even once factories are built will not be a clean site.  The South Tees site will be legally clean enough to house the storage, the factories, the logistics and the industry that is placed on it, but it will still be contaminated land.  This may be a reasonable approach in order to contain costs, but only if even though while still contaminated the land does not present an ongoing cause of environmental and human health damage.  Unfortunately the choices made mean it will continue to present an ongoing danger.
===== Making Contamination Safe =====

There are basically two ways in which the site could have been made safe.

The best long term approach is by cleaning the land, for a site such as South Tees this would cost the best part of £2 million per acre as was the case with the 93 acre Avenue Coke Works in Chesterfield which over 20 years was remediated for houses and a nature reserve ([[https://www.gov.uk/government/news/the-avenue-landscaping-and-remediation-project-one-of-the-uks-most-significant-brownfield-projects|The Avenue Landscaping and Remediation Project]]).  The cost could be less per acre if approach such as bioremediation were adopted, but would require a decade to make a significant difference to the site.

The alternative is a short term approach, which is what has been partially adopted by Teesworks, cleaning up the contamination on the surface and then encasing any buried contamination.  Teesworks is removing and crushing the slag which is the top few metres of South Tees site, in order to provide a stable base for new developments and then putting down a geomembrane covered with 30cm of clean soil, what is called capping, to stop any contamination getting to the surface ([[https://www.northeastfc.uk/index.php?page=R-2020-0357-OOM-Officer+Report#Chapter_H______a_href____Teesworks_Planning_R_2020_0357_OOM_R_2020_0357_OOM_South_20Industrial_20ES_20__20Vol_202_20__20Chapter_20H_20__20July_202020_pdf__class__external__Ground_Conditions_and_Remediation__a_|R/2020/0357/OOM - Ground Conditions and Remediation]]).

The approach to remediation was summarised and accepted by Redcar and Cleveland Borough Council's Contaminated Land officer in the official response to the planning application as:

"1/. Demolition of legacy structures and ground preparation operations including removal of relic subsurface obstructions (to ~2.5mbgl), vegetation clearance and infilling of voids.

2/. The option for selective excavation and disposal at the adjacent hazardous waste facility of limited ‘hotspots’ of contamination; and

3/. Site won and imported clean cover soils will be placed under a controlled methodology, mainly driven by geotechnical requirements, to form a 0.3m capping layer to physically break Made Ground contaminant linkages.

I have previously stated (R/2019/0427/FFM) that I am satisfied that this strategy adequately covers parts (a) (Site characterisation) and (b) (Submission of a Remediation Scheme) of the standard contaminated land condition for future commercial users of the site."

The very succinct but accurate summary highlights the reactive nature of the approach to remediation, the mixing up of geotechnical considerations, i.e. the need for stable ground to build on, with contamination concerns and the simplification of the complexities of the site.  While the capping layer could be said to break the Made Ground contaminant linkages between the soil and people using the site, it does nothing to break linkages between areas below ground, as this leaves any contamination below the geomembrane able to still travel into nearby land or into nearby watercourses (i.e. River Tees).  Also if you haven't cleaned up other areas of the site adjacent to the clean areas, then contamination from the still contaminated areas is able to recontaminate the cleaned areas.  However capping is a lot cheaper than either properly encasing the contaminated areas or properly cleaning the contaminated areas.

The summary also implicitly states that contamination still exists below the capping layer and as such I feel the site will still be contaminated land.
===== What's first should be last =====

So the whole clean up process is being done the wrong way around, but it will be cheaper now and quicker.  The most contaminated areas should have either been cleaned first or encased with a physical barrier that stops contamination from leaving the most contaminated areas, as is standard for such sites (for example, [[https://www.geolsoc.org.uk/~/media/shared/documents/groups/specialist/contaminated%20land/2019/napl%20uk%20context/presentations/sunshine%20on%20the%20tyne.pdf?la=en|Redhugh Gas Works, Newcastle]] and [[https://www.thesiriusgroup.com/projects/installation-situ-soil-mix-barrier/|St Anthony's Tar Works, Newcastle]]).  Teesworks has chosen instead to develop around the most contaminated areas, leaving the contamination in place as continuing sources of contamination (reference to site map).

The Dorman Long Tower demolition [[this>Teesworks/Planning/R-2021-0728-PND/R-2021-0728-PND-Demolition%20of%20Dorman%20Long%20Tower.pdf|method statement]] makes no mention of protecting the drains, despite being adjacent to one of the most contaminated areas on the whole site, South Bank Coke Ovens.

The [[this>Teesworks/Planning/R-2020-0281-PND/R-2020-0281-PND-STDC-HFO%20Tank%20Method%20Statement%20FOR%20ISSUE%20%28003%29.PDF|method statement]] for the demolition of the heavy fuel oil tanks next to the River Tees says "Any drainage outlets or interceptors to be capped by the client on completion of the works", surely they should have been capped before work started that involved demolition of structures that contained oil.  Flooding is a bigger concern than inadvertent contamination - "Drain points are to be identified prior to commencing and will be managed as works proceed to prevent flooding."  However under COSHH it is stated, "Fuel oil for plant will be stored in double bunded tanks, their location will take into account features such as drain systems.", so concern for human health is shown, but not for the environment.

The [[this>Teesworks/Planning/R-2021-0397-PND/R-2021-0397-PND-Outline%20Method%20Statement%20-%20South%20Bank%20Coke%20Oven%20Battery%20Plant%20-%20Rev0%20%28002%29.PDF|method statement]] for the demolition of the South Bank Coke ovens seemed to have thought about the problem with drains, "All drains within the exclusion zone will be sealed using sandbags to prevent demolition debris from entering and protected using a steel plates."  However, the aim appears to have been to stop demolition debris, not fluid from entering the drain.
===== Why pipes =====

The pipes should have been dealt with before any activities which might risk mobilisation of contamination.  The pipes present multiple risks of catastrophic transport of contamination, across the whole site but specifically to the River Tees and the precious marine environment.  Tees Valley Monitor amongst others have highlighted the risk specific channels across the site present ([[https://www.teesvalleymonitor.com/poison-earth-how-teesworks-exports-its-toxic-legacy|How Teesworks exports its toxic legacy]]).

Buried pipes present two major causes of spreading contamination, inside and outside them.  The inside of a pipe is designed to transport liquid from one area to another, often to drain water into a river, but also to transport liquid chemicals across a site.  The outside surface of a pipe also connects different areas of a site as it presents a break in the ground through which liquids can travel to wherever the pipe goes.

Reading the planning documents many pipes are known about across the 4,500 acres site, but also in its 170 years history there may well be many other pipes which have been forgotten about (history from masterplan or outline planning documents).

Aside from the Tees river, the site also has culverts and channels which could also be at one end of any pipes on the site.  There are also buried culverts.  All these connect to the river Tees (page 51 - [[https://www.northeastfc.uk/Teesworks/1911South-Tees-Master-Plan-Nov-19.2.pdf|South Tees Regeneration Masterplan]]).

Reading the planning applications the order in which work is to be carried out does not reference environmental concerns such as ensuring existing contamination is dealt with first, instead it is explicitly stated that contamination will dealt with only as it is exposed in the process of development (CEMP).
===== Warning about the pipes =====

The risks the pipe pose are explicitly outlined in responses to the MLA/2020/00506 marine license application. (CEFAS advice reference)
===== The explosions =====

The EA had originally stated that all decontamination should be completed before demolition started, this obviously wasn't adopted. (reference to EA advice)
===== Change in Process =====

After the initial explosive demolitions on the South Bank site, which purely required sand bags to be used as filter on top of drains (reference), subsequent explosive demolitions required that steel plates be fixed on top of drains to ensure that no water was allowed to drain (INCA advice).
===== Pipes killed the crabs =====

The pipes could have contributed to the mass marine die-off in many ways.

While as has been stated on multiple occasions that there was no Teesworks dredging happening before the crab die-off, there was lots of work going on the South Tees site, [[Teesworks - Timeline of groundworks including prior to October 2021]].  The South Tees site is surrounded on one side by the North Sea and one side by the River Tees, so any drainage from the site will enter either the river or the sea.

It was risky to not address the possibility of pipes acting as pathways for the measured contamination on the site to be spread as the site was disrupted by mechanical demolition, explosive demolition and heavy machinery used in development.

It was irresponsible not to find all the pipe outfalls and block them before work started - the change in advice after the first explosive demolitions suggested that something happened to make the contractors aware of this mistake.

It was lazy to block pipes when found on site rather than proactively identify pipes near to river, sea, channel or culvert and block their outfalls.

Leaving the pipes in place has left pathways for contamination to spread easily across the site whether inside or outside the pipe.

The precautionary approach would have been to either remove pipes across the site or to put barriers to stop any out flow from the pipes entering any of the water courses.