1.2 The Springfield Mill Action Group (SMAG) was formed in May 1999 to promote the use of the Site as a wildlife site and as an alternative to proposed housing development. The Group have campaigned for the removal of the Site from the Register of Housing Land Supply in the new local plan and submitted a proposal for Springfield Mill Wildlife Site to Midlothian Council in July 1999.

1.3 SMAG commissioned the Turnbull Jeffrey Partnership on September 13th 1999 to undertake a more detailed proposal for the Springfield Mill Wildlife Site, following the award of a grant from Midlothian Council. In view of the complexities of the site, the Turnbull Jeffrey Partnership put together a study team comprising the following professionals;

• EAG Environ (land contamination specialists);
• Laurence Maran (Quantity Surveyor);
• Fred Noble (hydrology/drainage aspects)

1.4 The aim of the Springfield Mill Wildlife Site proposal is to preserve and enhance the value of Springfield Mill to wildlife and people. Key objectives set by the Group to realise this aim are;

• to increase the biodiversity of the site;
• to increase the amenity value of the site;
• to encourage community participation in the project and use of the site as an educational resource.

1.5 The principal matters which needed to be addressed by the study include;

• potential contamination on the site and the proposed treatment of these areas;
• assessment of the flooding risk associated with the North Esk and consideration of the role of the site in alleviating flooding elsewhere in the catchment;
• detailed proposals for the site including specifications for the works;
• detailed costs for all of the above, including the demolition of remaining structures on site.

1.6 A number of site investigations and surveys have been undertaken of the Springfield Mill site. Those of relevance to this proposal include:

• Springfield and Polton Mills – Feasibility Study for Rehabilitation (Lothian Regional Council Land Rehabilitation Unit 1987)
• Report on the Ground Contamination of Springfield Mill (WA Fairhurst commissioned by LEEL 1992)
• Phase One Habitat Survey (Scottish Wildlife Trust1999)
• Phase Two Habitat Survey(Scottish Wildlife Trust 1999)
• Arboricultural survey (Alan Hulme 1999)

1.7 The Group had also undertaken preliminary consultations with a demolition contractor to ascertain likely costs for demolition of structures, crushing of debris on the site and removal of some materials off site. These costs formed part of their initial proposal submitted in July 1999 to Midlothian Council.

1.8 Due to time and budget constraints, no new scientific testing or investigative survey of the site has been undertaken to inform these more detailed proposals for the wildlife site. A review of the existing survey information on the site has been undertaken by the specialists on the study team. Limitations in this survey information are identified as part of the review and some of the recommendations outlined in this study will be subject to more detailed survey should the proposal progress.

1.9 The principal tasks which have been undertaken by the study team include:

• Review of all available information on the site
• A survey of the site, generally estimating scale of buildings to be demolished, plotting areas of ‘cut and fill’, potential footpath bases and visual features etc
• Detailed discussions with a demolition/earthworks contractor in order to firm up outline costs
• An outline calculation of the volumes of fill likely to be generated with the aim of informing the landscape design exercise
• Review of hydrological information for the North Esk and flood risk analysis
• Review of contamination survey information and discussions with SEPA with regard to pollution issues
• Consultation with Scottish Power with regard to existing sub-station on site
• Consideration of conditions relating to potential grant aid sources with the aim of building any requirements into the design of the scheme, where relevant
• Consideration of any Health and Safety aspects relating to the site and potential public access to it.

2.2 The appraisal of the Site, its condition and its overall context within the North Esk valley, has allowed us to identify key issues to be addressed by a landscape strategy for the future creation of a wildlife site at Springfield Mill.

2.3 The appraisal undertaken has shown that the Site offers great potential for establishing a wildlife reserve due to its location within the North Esk valley, an area of high nature conservation and landscape value. The proposed use of the Site would conserve and enhance the existing features of nature conservation interest on the Site, such as woodland. The proposal would also increase the habitat diversity found within this section of the North Esk valley through provision of grassland and wetland features.

2.4 The Site has an interesting historical focus stemming from its origins as the designed policies associated with Glenesk House and long use for paper milling. The Site plays an important role in the context of the significant architectural and industrial heritage of the North Esk Valley. Conservation of elements of this heritage on the Site, offers opportunities for exciting interpretation and education in the future.

2.5 The industrial legacy of the Site has however resulted in ground contamination identified in the waste mound and the former gas works site. The legislation relevant to the proposed use of the Site as a wildlife reserve would merit less onerous treatment of potential pollutants than would land intended for construction of housing. With this in mind the risks of pollution to humans associated with the waste mound would not be significant if left intact.

2.6 The flooding history of this stretch of the North Esk is also an issue, which needs serious consideration, particularly in view of the potential for flooding damage further downstream.

2.7 At present the Site poses a health and safety risk in terms of the dereliction of existing buildings and unsafe piles of demolition rubble. Health and safety aspects therefore need to be considered in creating the wildlife site and in the treatment of existing features, which contribute to that risk.

2.8 In summary therefore, the key issues, which will need to be resolved in planning and creating the wildlife reserve, will be;

• the need to resolve potential future flooding problems, taking into account the importance of the Site within the North Esk Valley in potentially alleviating flooding downstream;
• treatment of contamination/prevention of pollution in accordance with current legislation;
• health and safety aspects, particularly in view of increased public use of the site and current legislation.

2.9 The following objectives have been set by the Group for the Springfield Mill Wildlife Site;

• increasing the biodiversity of the site in the long term;
• increasing the amenity value of the site;
• encouraging community participation in the project and the use of the Site as an educational resource.

2.10 In achieving these objectives in the long term, the key issues identified need to be resolved in planning works to be done on the Site.

2.11 In addition, funding will need to be sought for the scheme and works therefore need to be cost effective and the proposal achievable. This has a bearing on the planning of the wildlife site and the operations needed to create new habitats and other features.

2.12 The short term strategy for developing the Site as a wildlife reserve will be to address the key issues of flood prevention, treatment of contamination and health and safety aspects in the most cost effective and sustainable manner.

2.13 Given the history of flooding on the Site and downstream, it is essential that accommodation for possible future flood occurrences should be made available. The Site offers an important opportunity for this, being one of the few areas of low lying and undeveloped ground along this stretch of the North Esk valley. Measures to accommodate such flood occurrences would therefore assist in safeguarding other more sensitive built areas downstream.

2.14 As stated in the introduction to the Scottish Executive’s "National Planning Policy Guideline NPPG7 – Planning and Flooding"

NPPG7 goes on further to state (at paragraph 19):-

2.15 Having regard to the general advice given in NPPG7, the history of flooding in the locality and the location of the subject site, it can only be recommended that the site’s role in acting as a natural flood defence should be retained if not enhanced. In other words nature should be accommodated and areas surrounding the subject site should be protected in its retention as part of the flood plain. The Springfield Mill Action Group’s proposals offer a positive management and protection in this regard

2.16 In principle, this recommendation is best achieved if the existing low level areas are not altered, thus ensuring that the existing ‘wash land’ is safeguarded. In this regard it is essential that the two weirs close to the Site, are properly safeguarded and maintained to ensure that potential flooding of land at lower levels of the River North Esk is minimised.

2.17 In creating the ‘wash land’, excess fill material should be located to the south of the Site, adjacent to existing high level areas. This should include the relocation of existing spoil material which effectively forms a long bund parallel to the river where mill buildings have been demolished, as this would impede the ability of flood water to flow over the lower part of the Site.

2.18 In general terms the existing landform of the Site slopes in a series of tiers towards the river. References to the recorded levels information suggests that, if the northern part of the site is maintained at a level of 73.5m AOD, or less, it would result in a useful ‘wash land’ being made available, this probably extending up to about 20% to 25% of the Site.

2.19 The creation of a ‘wash land’ would also provide a suitable alternative ‘channel’ for the North Esk, albeit at a relative higher level to the existing river, should Hewan Bank suffer further slippage in the future blocking the existing course of the river.

2.20 While contamination was identified in the southern areas of the Site, including the waste mound and woodland, it is considered that this does not pose a significant risk to humans as it is well covered with mature vegetation. The recommended approach therefore will be to leave the contamination in situ and not disturb the vegetation cover.

2.21 There are three remaining issues of potential concern with regard to contamination on the Site however and these are:

• the presence of asbestos on the Site
• contamination associated with the former gas works site
• groundwater contamination and potential effects on the North Esk

The following recommendations to treat the known contamination on Site and to undertake further assessment to clarify whether treatment will be necessary are proposed:

2.22 The first requirement is to further investigate the Site in order to determine the extent of the asbestos contamination, and estimate the quantity and nature of the asbestos material present and assess any immediate health risks to current users at the site. An asbestos walkover survey to inspect demolition waste, and remove any asbestos from the stockpiles of rubble prior to any crushing of the material is advised. A full asbestos survey of the existing building prior to demolition should also be undertaken, and if any asbestos is found, a licensed contractor should remove it, and dispose of it in accordance with appropriate waste management legislation.

2.23 It is recommended that the demolition stockpile should not be disturbed, and in particular no crushing of the rubble should be undertaken until an asbestos survey has been undertaken, and precautions are taken to prevent exposure of workers and the public to asbestos.

2.24 The area of the former gasworks in the north west corner of the Site, adjacent to the river does not have sufficient cover to minimise any health risks to future users of the Site. It is therefore recommended that an additional barrier be provided on top of the soil contaminants. Such a barrier should be covered with about half a metre of capping materials, to provide a barrier to humans. There will be minimal costs, assuming the cap layer can consist of the crushed rubble from elsewhere on site.

2.25 The options for dealing with the soil contaminants, will however, be subject to regulatory approval from Midlothian Council Environmental Health Department, and SEPA. As indicated above, SEPA are likely to request further investigative works to show there is no risk of sub-surface movement of the contaminants and in turn no effect on internal water features or external controlled waters such as the river. If a properly engineered capping layer with associated drainage systems would need to be designed, supervised and properly installed, costs for capping would be considerably increased. Any need to remove contaminated spoil off site would also incur substantial costs above this. However, it would appear unlikely that this will be the case.

2.26 Further works are needed at the Site to address the impact of the contaminated land on the groundwater and river. The risks of contaminants leaching from the soil to the groundwater phase, impacting on internal water features (current and proposed pond) and eventually entering the river has not been fully assessed. There is in general a lack of reliable groundwater data in the investigation work conducted to date. In view of this, the following works are proposed:

• An initial investigation to assess the nature and extent of contamination in groundwater involving the excavation of a further five boreholes and analysis of selected soil and groundwater samples.
• A survey of the river bed, including sampling benthic invertebrates from upstream, midstream and downstream of the site is recommended. The benthic survey results will assist in assessing any impact of the site on the river fauna.

2.27 Depending on the nature of the contamination, further works to remediate the Site may be necessary. However, on the basis of the water quality analysis undertaken by SEPA which shows no adverse impact on the river downstream, it is considered unlikely that further measures will need to be undertaken, although it will be important to undertake additional groundwater and river survey to confirm this view.

2.28 Increasing bio-diversity of the Site

• retention of mature woodland on the Site with gradual management to replace sycamore with locally indigenous trees and understorey
• increase areas of open space within existing woodland
• management to eradicate invasive species on the Site
• provision of habitats for birds, bats and other small mammals
• creation of a variety of new habitats on currently derelict land

2.29 Increasing amenity value

• involvement of the local community in habitat creation and site management
• creating links to existing natural heritage sites/recreational routes in surrounding area
• provision of footpaths on the Site
• promotion of the Site as an educational resource (for example, schools, but also university departments researching land restoration techniques)

2.30 Encouraging Community Participation

• involvement of SMAG members in carrying out survey, planting and other habitat creation works on the Site
• involvement in locally operating businesses in funding/sponsorship or provision of materials
• involvement of Lothian Conservation Volunteers and Scottish Wildlife Trust training teams to encourage participation of local schools in habitat creation and to undertake work on the Site.

2.31 SMAG intend to liaise with Midlothian Countryside Ranger Service and Scottish Wildlife Trust to organise mini-beast hunts, wildlife clubs, pond and river dipping and plant forages

2.32 The landscape masterplan has been devised as a team effort with landscape architect, hydrologist and quantity surveyor working together to interpret the objectives set by SMAG and to resolve the key issues associated with the Site. The masterplan seeks to conserve and enhance existing features of landscape or nature conservation interest, accommodate flooding thus providing benefits to sensitive built areas downstream and has been planned to provide low cost reclamation of the Site.

2.33 An indicative masterplan is shown in Figure 2. Mature woodland would be retained on the southern part of the Site and managed in the long term to increase bio-diversity. Improvements to footpaths would be undertaken in this area and obvious fly tipped material would be removed. Bat boxes (to be confirmed with SNH) would be positioned on trees within this area (possibly in a defined area not likely to be disturbed by management operations and people).

2.34 Existing buildings would be demolished and spoil material shifted on the Site to create a ‘wash land’ area close to the river and higher mounded areas to the south. A barrier would be erected along the public road to secure the site, give it definition and preventing access for unauthorised vehicles. An additional parking area accommodating up to 6 vehicles would be provided within the Site to ease congestion on the road and improve access for visitors, such as school parties and the less able. A map and interpretation of the Site would be provided close to the main pedestrian entrance which would outline the historical context of the Site, its nature conservation interest, and footpath routes within the wider North Esk valley.

2.35 A simple footpath system would be created, based on existing concrete hardstanding and paths, providing a variety of circular routes around the Site through the different habitats created. Wheelchair access would be provided on the lower riverside path and around the newly created wetland habitats. The former pond would become a valuable wildlife habitat and educational resource with small pools and wetland habitats created in the depression.

2.36 Native tree and shrub planting would be undertaken in pockets over the Site, to provide a diversity of habitats for wildlife as well as a variety of spatial experiences for the user. The majority of the northern ‘reclaimed’ area would be seeded onto crushed spoil material with meadow grass and wildflowers. The area adjacent to the river would be used as a ‘wash land’ and would be subject to sporadic flooding from the North Esk. The river is an important feature of the site and to increase access to it, a viewing/access area would be created next to the bank, which could be utilised by visitors to the Site.

3.1 Many of the measures outlined in this method statement are indicated on Figure 3 – Outline Specifications.

3.2 An asbestos walkover survey will be undertaken to inspect demolition waste, and remove any asbestos from the stockpiles of rubble prior to any crushing of the material. A full asbestos survey of the existing mill building prior to demolition will also be undertaken.

3.3 Sound survey to determine species of bat within former mill building. Consultation with Scottish Natural Heritage on basis of survey report to obtain consents for demolition and discuss suitable mitigation measures.

3.4 Investigation to assess the nature and extent of contamination in groundwater involving the excavation of five boreholes in the vicinity of the former gas works site and analysis of selected soil and groundwater samples.

3.5 A survey of the river bed, including sampling benthic invertebrates from upstream, midstream and downstream of the site is recommended. The benthic survey results will assist in assessing any impact of the site on the river fauna. Consultation with SEPA to confirm measures to be used to reduce risk to humans of contaminants associated with the former gasworks site and whether any further measures need to be taken with regard to potential groundwater/river contamination.

3.6 All visible asbestos will be removed off Site by a licensed contractor and disposed of in accordance with appropriate waste management legislation.

3.7 Removal of all metal in these buildings and on site (where either loose or if metal reinforcement standing proud from concrete blocks etc)

3.8 Provision of an additional barrier on top of the soil contaminants in the area of the former gas works (see figure 3). Such a barrier should be covered with about half a metre of capping materials, to provide a barrier to humans. There will be minimal costs, assuming the cap layer can consist of the crushed rubble from elsewhere on site.

3.9 From demolished buildings and existing piled material along riverside to lower area in centre of site, as indicated on Figure 3.

3.10 The areas of brick and rubble may be used for planting directly, preventing the need to import expensive topsoil. The rubble will be passed through a stone crusher, reducing it to a granular material, and then used as a sub base or for capping. The fine dust, produced as a by-product from the crushing process, will then be spread as a 120mm top layer suitable for direct seeding. The brick and mortar rubble may contain phosphorus, potassium, magnesium and calcium making it a suitable growing medium.

3.11 Provision of nitrogen is important in establishing vegetation. The fixation of nitrogen by some plants offers a cheap and sustained source, so legumes and Alders will be included in the species. Areas of mounding will be seeded with a grass clover mix. Legumes must be inoculated by Rhizobium bacteria in order to fix nitrogen, which is absent from many derelict land sites. Clover seed may however be purchased ready-coated which gives greater reliability and convenience. The seedbed should be fine enough to allow seed to be covered to a depth of 10-20mm either by harrowing or by natural burial in crevices by rainfall. Rates of seeding 50-100kg/ ha should be used to allow for some losses due to overdeep and shallow burial.

3.12 Addition of fertiliser to the seed application frequently causes severely reduced germination of the legumes such as clover, which are essential to the long-term nutrition of the sward. With the exception of slowly soluble fertiliser, the application of fertiliser should be delayed vegetation has established, around six weeks after seeding.

3.13 Planting of native trees and shrubs will take place in approximately 20% of the reclaimed area of the Site to increase the wildlife habitats and provide visual enhancement. A 50:50 mix of nurse and climax species is advised with Alder included in the mix. Pockets for planting will be created within rubble and filled with a mix of organic material (imported) and crushed brick. Transplants and whips will be used, as they will give better long-term growth than larger stock.

3.14 The addition of mulch and nutrients at the time of planting will greatly aid the establishment of trees/shrubs. As the trees are being planted in coarse material, up to 240g of slow release fertiliser (e.g. Enmag) may be required per tree. Mulching will improve soil moisture conditions, reduce extremes of temperature and suppress weed growth. Granular material, possibly a wood chip mulch created from the thinnings of existing Sycamore on the Site, should be included at the time of planting and spread to a diameter of 0.7-1m around the tree and to a depth of 50mm.

3.15 Using existing hard standing as base, edges of concrete broken up blinded with crushed brick tilth / subsoil mix to form 1.5m wide path and seeded.

3.16 The scheme will be designed for minimal maintenance from the outset however, longer-term management will also be needed. The management programme can be divided into two phases; the establishment phase, years 0-5, and the long-term management stage from year 5 onwards. Both stages are important to the success of the planting and wildlife capabilities of the site.

3.17 Regular checks should be carried out to ensure the health of the plants and an application of fertiliser on planted areas on the reclaimed area in the third year will be important as the trees are growing on a skeletal material without soil cover.

3.18 Weed control is the single most important aspect of aftercare. If the weeds are not eliminated then the trees will be competing for moisture, nutrients and light. Weeds will be controlled at the start of the growing season and a 1 metre diameter weed free area left around the transplants.

3.19 Provision will be made for replacement of failed or vandalised stock during this period.

3.20 The existing mature woodland should be managed to create a mix of native species, with the systematic removal of invasive Sycamore. The newer planting may also require thinning at 8-10years and again at 15-25 years dependant on the species. Thinned timber could be utilised as wood chippings to provide material for upgrading footpaths in the existing woodland on the Site. Wood chippings could also provide a mulch for newly planted areas with the reclaimed part of the Site, where evaporation loss could be reduced.

4.2 The cost estimate outlined in the table above is exclusive of the following:

• VAT
• Landfill tax
• Professional fees
• Any Work to weir and Hewan bank

4.3 It has been assumed that volunteer labour is free of charge with materials and some supervision only being costed. While it is possible that some topsoil may be donated to the Site, no allowance has been made in the cost estimate for this.

A.2 The Site lies at the start of a 2.5km stretch of the river valley, which is largely inaccessible by vehicles with no public roads or bridging points and little habitation. This section of the valley is densely wooded, with sheer slopes down to the river.

A.3 Glenesk House and its policies originally occupied the Site with the first paper mill being located within these policies close to the North Esk in 1742. Although Glenesk House is not now in existence, many large specimen trees occur on the Site and date from plantings undertaken in the late 1800’s. The policies of Glenesk House included an ornamental pond and the depression of this is still visible on the Site.

A.4 During the early part of this century, Polton Village was a thriving industrial community with two working paper mills serviced by a railway. Waste material from the mills appears to have been dumped from the late 19^th century, on the western part of the Site creating a steep sided mound. This mound is now covered with mature sycamore woodland. The ornamental pond, which formed part of the designed landscape of Glenesk House, was also later used as a reservoir for industry on the Site.

A.5 Springfield Mill ceased production by the late 1960’s and the Site became the property of Lothian Region and Midlothian District Council in 1975. Prior to 1979, the main site offices and two warehouses were used by the District’s Technical Services and Housing Department and the Region’s Highway’s Department used part of the area for an open storage yard. The remainder of the buildings and yards on the mill site (some of which were in private ownership) were occupied by a variety of local businesses up until 1990. A number of derelict buildings were demolished around this time and areas of rubble and hard standing left on the Site.

A.6 The Site is currently derelict with two buildings remaining; a large former mill and part of a former terrace of stone faced buildings close to the river. The latter building houses an electricity sub-station and is owned by Scottish Power. An electricity connection still exists between the sub-station and the remaining large mill building on the Site. Scottish Power have been consulted with regard to the status of the sub-station and have confirmed (see Appendix A) that the owners of the Site would need to make a request to them to have the power disconnected to the mill, prior to any relocation or removal of the sub-station. A charge may be made by Scottish Power for removal or relocation of the supply, although it is understood that this fee may be waived if the Site were to be used as a wildlife reserve.

A.7 While the Site is no longer used for storage or industry and is effectively ‘derelict’, many local people currently use the area for walking and quiet recreation.

A.8 The Site can be split into the following distinct areas of landscape character:

• A steep sided mound and lower undulating area on the southern part of the Site, colonised by dense woodland, largely compromising sycamore and birch. Woodland on the eastern part of this area is younger than that occurring on the mound, although occasional mature exotic tree and shrub species also occur here. Building footings, walls and dumped materials are readily visible in this eastern undulating area;
• an area of dense willow/birch sedge and marsh occurring in the large depression of the former ornamental pond of Glenesk House;
• an open area of large scale derelict buildings, rubble heaps and hard standing colonised in part by pioneer species such as birch, grasses and ruderals;
• an area of land on the western fringes of the Site and close to the river bank, which appears to have been graded in the past 10 years.

These landscape character areas are illustrated in the following figure.

A.11 The derelict part of the Site provides both grassland and ruderal habitats. There is a variety of flora including spotted orchids, mullein, toadflax and a diversity of other plants which provide fodder for many insects among them butterflies such as the red admiral, peacock, small tortoiseshell and rare visitors such as the convolvulus hawk moth and the purple hair streak butterfly. The river walls provide a vantage for the resident kingfishers and the river itself is home to dippers, pied and grey wagtails, brown trout, eels and the plethora of invertebrates which inhabit any such healthy, fast flowing watercourse. Sand martins nesting in Hewan Bank and sparrow hawks also use the Site.

A.14 Historically, there has been a number of potentially contaminating activities at the Site including the following:

• A paper works (1742-1966) was located on the northern part of the site and was used to produce paper from rags and later the process changed to produce high grade paper from grass, straw and wood pulp. Potential contaminants may include traces of bleaching agents, pigments and dyes, metals, solvents, chlorinated organic compounds, and oils.
• A small-scale gas works associated with the mill was present on the northern part of the site (1862 until at least 1918). Potential contaminants may include coal tars and other hydrocarbons, cyanide, spent oxides, ammonia, sulphides, sulphates and heavy metals. In addition, asbestos was also extensively used in insulation materials in gas works in the past.
• Waste materials presumed to be from the paper works were deposited in a mound initially on the central part of the Site in 1894, extending to the south western area by 1908, and slightly eastwards by 1957. The contaminants arising may include heavy metals, lime, boiler ash, paper pulp and solid gasworks waste (i.e. coal, clinker, ash, lime and spent oxide)
• Since the mill closure in the 1960s, buildings have been sublet for paint spraying, vehicle repairs and wood stripping and to builders firms, and associated contaminants may include solvents, paints and wood treatment chemicals.
• An electricity substation is currently located on the northern part of the site, and there is a possibility that polychlorinated biphenyls (PCBs) may have been contained within the transformer unit.
• Suspected asbestos containing material has been identified in existing stockpiles of demolition rubble. The fabric of the existing buildings may additionally contain asbestos materials.
• areas of fly-tipped waste, including drums and paint containers, were observed during the site inspection and may cause localised contamination with oils or solvents.

A.15 In relation to the environmental setting of the site, the River North Esk forms the western and northern boundaries of the Site, and is prone to flooding across the low-lying parts of the site. A geological SSSI, Hewan Bank, is adjacent to the northwest of the site, and the nearest residential premises are adjacent to the eastern site boundary.

A.16 Two previous site investigations have been undertaken at the Site and are summarised as follows:

A.17 The Lothian Regional Council undertook an investigation in December 1985 to identify if the former Springfield and Polton mills could be rehabilitated for housing sites. The investigation comprised 6 boreholes and 6 trial pits, all excavated on the central and southern parts of the site, in the vicinity of the pond and the mound of spoil. Nine soil samples were analysed for a range of parameters including pH, moisture, total solids, total alkalinity, ash content, inorganics (sodium, potassium, and sulphate), and metals (lead, cadmium, zinc, aluminium, arsenic and mercury).

A.18 In 1992, WA Fairhurst & Partners undertook a desk study, site inspection and site investigation comprising thirty-two trial pits, two trial trenches and fourteen boreholes. In total, 119 soil and 15 groundwater samples were analysed for a range of parameters. The analysis included pH, calorific value, oxidising agents, inorganics (fluoride, sulphide, sulphite, sulphates, total nitrogen, ammonia, phosphates, cyanides), organics (toluene extractable matter, phenols, formaldehyde) and metals (arsenic, antimony, barium, cadmium, chromium, copper, lead, mercury, nickel and zinc). In addition, three samples of water were taken from the river and two samples from the pond, to assess any impact on surface water quality from leachate/run-off from the site.

A.19 The surveys confirmed the depth of fill varied between 0.3m-3.6m thick within the pond area, up to 15.25m within the mound area, and between 0.3-5.45m thick elsewhere. The fill comprises a clayey sand and gravel that contains lenses of paper waste, wood and other organic debris. In addition ash, coal, blaes, burnt shale, polythene, porcelain, brick, concrete and metal fragments are present within the fill. Alluvial deposits of sand and gravel, with bands of sandy clay underlay the fill. Groundwater appears perched within the fill at depths of between 0.65m – 3.6m bgl. Standing water was also measured at depths of between 1.6m – 14.7m bgl within the natural strata of sand and gravels. Groundwater elevation contour plots indicate groundwater movement is generally towards the river.

A.20 In view of the proposed use of the Site as a Wildlife Site, the analytical results from previous site investigations have been assessed against Interdepartmental Committee on the Redevelopment of Contaminated Land (ICRCL) Guidelines for landscaped areas and open space. These are less stringent controls than would be applied to land, which would be developed for housing.

A.21 Overall, soil contamination was not widespread across the site and was restricted to the former gasworks and two areas of buried waste namely in the mound and in land to the south of the former Glenesk house, with contaminants restricted to the fill material.

A.22 The groundwater at the Site has not been adequately assessed by the previous surveys, with the majority of water samples taken from trial pits for analysis, rather than from properly installed boreholes. In addition oil contamination was visually recorded on trial pit logs at five locations adjacent to the north of the mound. The contamination was described as discoloured black water, with an oily appearance, which could be indicative of leachate from the mound. No analysis for hydrocarbons was undertaken on these water samples.

A.23 The groundwater results have been assessed against the Dutch Intervention guidelines, which although they do not have legal status in the UK, are widely used for assessment purposes. In addition, leachate completion criteria have been used for assessment purposes, given the mound of waste at the Site. The river North Esk flows adjacent to the site and is likely to be in hydraulic continuity with the groundwater from the site. Environmental quality standards (EQS) and surface water classification guidelines have also been used for assessment, and essentially represent ‘clean’ levels. EQS are set for protection of aquatic life from dangerous substances and surface water classification guidelines are set for abstraction of drinking water supply.

A.24 Based on the findings of the site investigation, there are a number of risks posed by the Site in its current form. Contamination is present within fill materials at the Site and "pollutant linkage" may exist, as defined in the draft guidance on contaminated land. The regulations to implement the provisions of Part IIA of the Environmental Protection Act 1990 will shortly be laid, with the regime entering into force in April 2000. In this regard the following assessment of risks is presented;

Soil Contaminants

A.25 Chemical analysis results show the soil phase is contaminated with elevated levels of metals (lead, arsenic, barium, antimony, copper, nickel and zinc), toluene extract and sulphate. The contaminants are associated with the ash fill material and are localised on the western part of the site, in the vicinity of the mound, and former gas works site. The soil contaminants are unlikely to pose a risk to future users at the Site, provided the mature vegetation within the mound area is left in situ, which reduces the pathway for exposure, and that the gasworks area, where contamination was detected at shallow depth within the soil profile, has an additional layer of material to cover it.

Water Contaminants

A.26 The contaminant of greatest concern observed in groundwater was the indication of oily water in several of the trial pits located down gradient of the mound. Hydrocarbons are classed as a List I (black list) dangerous substance. Under section 30F of the Control of Pollution Act 1974, it is an offence to cause or knowingly permit any poisonous, noxious or polluting matter to enter any controlled waters without consent. Under the new Groundwater Regulations 1998, SEPA have powers to issue a notice to prevent or control indirect discharges of hydrocarbons to groundwater. Steps to further assess the hydrocarbon contamination in groundwater are likely to be required by SEPA, and if there is a significant risk of pollution, then clean up of the groundwater may be required.

A.27 Other water contaminants identified at the Site include elevated metals lead, copper and barium which are classed as List II (grey list) substances, and one excessively alkaline sample from within the mound. Risks to the environment associated with the elevated metal contaminants are on water resources and migration of contaminants into the River North Esk, adjacent to the Site. Elevated concentrations of metal in groundwater were measured above Dutch 1 Guideline values and up to ten times above the EQS. These metals can be harmful to the aquatic environment. There is, however, a dilution effect of the contaminants in groundwater upon entering the river. SEPA water quality data downstream which is based on both chemical and biological parameters, does not indicated that any adverse impact on the river has occurred to date, with the water being classed at the top end of A2 (good).

A.28 The remaining water parameters including phenols, sulphates, sulphide, nitrogen and cyanides, were detected at less elevated concentrations and were above EQS or drinking water standards, and are therefore not considered significant.

Asbestos

A.29 An extract reviewed from the Wimpey Geotechnical survey has identified asbestos to be present in small quantities within demolition spoil at the Site. Asbestos is a known human carcinogen, and the inhalation of airborne asbestos fibres can lead to possible adverse and irreversible carcinogenic health effects. There is no further information provided on the nature of the asbestos found, and thus a full assessment of the risks cannot be made. Currently, there is a requirement for all asbestos to be removed from buildings prior to demolition work. The mill buildings were demolished around ten years ago, and it is likely that under Health and Safety legislation, some form of requirement to remove asbestos in buildings would have been in place at that time.

Limitations of Previous Site Investigations

A.30 There are a number of limitations to the previous site investigations, which have been undertaken in the past. The principal limitations are the small number of water samples taken and insufficient coverage both in terms of sample locations and analysis. In particular, no assessment of the hydrocarbon contamination of the groundwater has been undertaken and the impact of contamination, if any, on the river has not been addressed.

A.31 In relation to the former gas works area, further work to delineate the hydrocarbon contaminants in this area and determine their nature may be required by SEPA.

A.32 No asbestos analysis has been undertaken on any of the soil samples, and the presence of PCBs in the soil in the vicinity of the electricity substation cannot be discounted. It should be noted that cleaning up of any PCB contamination associated with the substation would be the responsibility of Scottish Power.

Consultation with SEPA

A.33 Preliminary discussions with SEPA regarding the contamination at the site were held in order to gauge their views on the remedial requirements for the site. SEPA have not reviewed any data on the site and their comments have been based on telephone discussions alone. SEPA’s main concern is with the oil contamination in the groundwater, and they would require further details on the nature and extent of contamination prior to commenting on the remedial options. This would involve additional survey due to the limitations of previous site investigations.

A.34 In relation to the river water quality data supplied by SEPA, the overall water quality is classed as fair upstream and good downstream of the Site. SEPA were not aware of any pollution incidents from the site, however the aesthetic condition (visual observation) for down stream of the Site indicates there are trace list A contaminants, which includes, amongst others, oils. Further survey may also therefore be required to ascertain river quality to SEPA satisfaction.

A.35 The Site comprises an area of land just under 6 hectares (15 acres) in extent to the immediate west of the village of Polton. It is bounded on its northern and western sides by the River North Esk, which flows in an oxbow form to circle the Site. Levels vary across the site from a peak of just over 92.01m A.O.D. in its south western quadrant to just over 73m A.O.D. along the embankment to the river. The Site comprises one of the few areas of undeveloped level ground within this stretch of the river valley.

A.36 The river flows along the border of the Site discharging over an existing weir at the south western boundary and falls towards and under the Polton Road Bridge, which forms part of the eastern boundary of the Site. Immediately to the east of the bridge there is a further weir which controls the flow of the river in the immediate vicinity of the village.

A.37 To the north of the river, immediately opposite the Site, a steep bank known as Hewan Bank rises steeply (up to approximately 50m in height). The bank comprises a thick layer of sand lying over clay. There is a history of slippage of the bank given its unstable nature, which is vulnerable in times of storm or heavy rain. On 9 December 1979 after prolonged rainfall a huge landslide occurred completely blocking the North Esk with mud rocks and woody material to a depth of 8 metres. The toe of the slide swept across the river into the Mill complex demolishing part of the building used by Midlothian Council. "At this time Hewan Bank was covered in mature trees. In 1980 and again in 1985-86 at great expense a Manpower Services Commission squad cleared these to the damage of their damming the river in future slips. In recent years the bank has continued to slip.

From local information the site flooded again in the early ‘90’s’ but most landslides since the removal of the trees have been small. Large trees are now growing back.

A.38 Recent consultation with SEPA has established that they have assessed that flooding of the subject site occurs at a 1 in 6 year’s frequency, which readily confirms the instability of landform conditions in the locality and the need to monitor the situation.

A.39 The industrial heritage of the site has left an environment that contains hazards that could cause harm to the public. These hazards arise not only from Victorian industrial activity but also from recent abandonment and neglect and are associated with the following;

• waste and pollution from mill operations;
• debris arising from historic demolition/clearance which has been spread and covered;
• debris from recent demolition work in spoil heaps exposed on the surface;
• derelict structures and the remains of demolished buildings.

A.40 As the Site currently exists, the owner/occupier owes a duty to the public to guard against known risks. This duty would remain the same with the use of the Site as a wildlife reserve.

A.41 Health and Safety legislation imposes requirements to identify the hazards, carry out risk assessments and to develop proposals, which will eliminate risks where possible, and, where risks cannot be completely eliminated, put in place controls to reduce the residual risk.

A.42 Hazards likely to cause injury comprise:

• Collapse, slippage or erosions of unstable piles of debris
• Confined spaces under or between large units or debris
• Projecting metal bars and other sharp objects
• Unexpected sudden changes in levels
• Hidden strewn debris and voids

A.43 Health hazards comprise:

• Ground contamination
• Contaminated ground water and standing water after flooding
• Traces of asbestos in the existing demolition debris
• Potential harmful products from the decomposition of buried active waste

A.44 Prior to implementing any of the recommended proposals in this Report, the Client is obliged by the Construction (Design and Management) Regulations to appoint a Planning Supervisor to co-ordinate Health and Safety matters during the design, demolition and construction works. This ensures that safety will be considered at each stage of the design and construction process.