Over the past year, waves of dead and dying sea creatures from crabs to porpoises have washed up on the North East’s beaches. Local fishers, backed up with scientists’ evidence, blame chemical pollution from the Tees, dredged up and dumped at sea. A top concern is Teesworks, the former SSI steelworks site now being demolished to make way for regeneration and the new Teesside Freeport.
Many are asking: if pollution has had this effect on marine life, what is the cost to public health?
Wall of silence
Dr Eleanor Sutherland is a GP in Guisborough near Redcar. She also surfs at Saltburn. Her worry about the implications of dredging during the Teesworks project led her to write to the parliamentary environment food and rural affairs committee’s October hearing on the die-offs. She wrote:
“What concerns me most, is the lack of evidence out there that anyone has actually undertaken a robust public health risk assessment before proceeding with the dredging.”
She set out to find who was responsible and was referred from the Environment Agency (EA) to the Health Security Agency (HSA) to Teesport Public Health and back to the EA. And found nothing.
In Redcar, Sally Bunce, a former police officer, rescues seals with British Divers Marine Life Rescue. She tried to find information on the likely human health impact of the controlled-explosion demolitions on the Teesworks site. After repeated efforts to reach Tees Valley Combined Authority (TVCA) and Redcar and Cleveland Borough Council (RCBC ) by phone and email she was none the wiser. She said, “Questions are met with a time wasting wall of silence which makes finding the truth an impossible task”.
After I tried the same agencies with similar success, I went through a selection of the 100-plus planning applications on Teesworks lodged with Redcar and Cleveland Council. The documents show the bare minimum has been done to assess the likely health impact of the Teesworks regeneration.
There’s no argument that the Tees is heavily polluted, with a legacy in the water and on the banks of 170 years of iron, steel and coke production and now at Teesmouth with the largest chemical production complex in UK.
In 1970, Redcar Council reported that 500 tonnes of industrial waste a day was being discharged into the river. Much of it is still in the riverbed. Then there is today’s waste from modern industry and sewage. According to the Rivers Trust, Northumbrian Water Ltd dumped untreated waste into the river 120 times in the past year. The EA has classed the Tees as “chemically failing”.
The Teesworks site is also toxic. The closure in 2015 of the SSI steelworks at Redcar rang the death knell for Teesside’s steel industry. A report to the government from the Health and Safety Executive (HSE) flagged up the derelict plant’s public health and environmental risks.
The 2,400-acre Teesworks land along the river’s southern bank is still subject to COMAH – control of major accident hazards, part of the HSE. Any company registered as COMAH has to reduce the risks to its workers and the public. But the more dangerous upper tier registered establishments like Teesworks “will have greater quantities of dangerous substances that additional requirements are placed on them in the regulations”, according to COMAH.
The redundant plant is described on the COMAH register as having contaminants “hazardous to the aquatic environment” and “toxic to aquatic life”. There’s also a risk of fires from “contaminated fire water containing dangerous substances to sewer, freshwater, estuarine waters, coastal waters, land or groundwater”.
The government granted the public body South Tees Development Corporation (STDC) £276mn for remediation. The total bill will be £482mn. According to the site’s regeneration masterplan of November 2019, “Full scale de-contamination is neither proposed nor financially viable”.
The remediation strategy declares the masterplan “will be based on a do minimum/do necessary approach”. The plan is a radical departure from the conventional “precautionary principle” which takes a cautious approach to innovations that could potentially cause harm.
The remediation planned will not transform poisoned ground into harmless soil. The work lies in calculating how a pollutant could come into contact with “receptors” (people, water, environment etc) and then finding a way of breaking that “linkage” or chain of contact. It could be done in part by “capping” – simply burying it under the landscaping and buildings of the new Teesside Freeport of which Teesworks will form one half.
The plans are for industrial and commercial use. “Residential dwellings would likely be unsuitable for the site”, says the masterplan.
None of the Redcar planning documents covers the entire site, which is split into multiple zones for separate development. Even within the zones, some areas are excluded from the applications. They include the 75-acre Highfield licensed hazardous and non-hazardous landfill and the 170-acre Sirius Minerals Plc landfill lagoon. The SSI High Tip facility containing 3.7 million cubic metres of waste was due to be remediated in 2014 by SSI for the EA but the clean-up never happened.
The masterplan suggests using these on-site landfills for dumping waste – much of it hazardous – from the Teesworks remediation.
Under blue skies, the blow-down in October of the BOS Tower, using 1.6 tonnes of explosives, was the largest explosion in the UK for 75 years. At the same time in nearby residential Dormanstown, the air quality monitor for particulate matter 10 (PM10) spiked to 50 micrograms per cubic metre from 7.5 an hour before. PM10 particulates – which are less than ten micrometres in diameter – are regarded as the most toxic.
None of the ten Teesworks demolition blow-downs had human health risk assessments, and planning permission was not required.
To demolish a site, developers must submit a prior notice: demolition (PND) application with the planning office. In the PNDs that have been filed for the Teesworks site, the planning officers waived the need for Environmental Impact Assessments (EIAs), which have a section on the possible effect on human health. For each PND officer report, a standard sentence is used to explain the EIA waiver:
“The demolition works would not result in significant environmental impacts that would require the works to be supported by an EIA with the significance not being beyond the local area.”
The officer reports also claimed the impact including on the local population, “is considered to be temporary in nature due to the project being for demolition while any impacts are also only considered to be of a local nature”.
All the explosive demolitions were in the most polluted parts of the Teesworks site, near old iron, steel and coke production. They were all subject to upper tier COMAH regulations. In response to our enquiry, the Environment Agency replied:
“All operators of COMAH sites have a clear responsibility to conduct a full assessment before any demolition to ensure that the works do not increase the risks of a major environmental accident. The steelworks site has historically been classed as a COMAH site due to the quantities of hazardous materials held in parts of the site, however the risk of these materials causing a major environmental accident is very low.”
Supporting the PND for the Foundry demolitions (planning ref: R/2021/0608/PND) is an ecological screening assessment (ESA) produced by INCA, the local Industry Nature Conservation Association. INCA is unique in its reliance for finance on Teesside industry. Teesworks is one of INCA’s industrial members and often commissions them for ecological impact reports. The financial conflict of interest was not declared in the PND.
In its ESA, INCA advised that an EIA is not needed yet they have no expertise in the assessments of human health impact that are part of the EIA. Nevertheless, the officer’s report used the INCA conclusion to justify waiving the EIA.
The other stages of regeneration – remediation, construction and end use – do need planning approval.
The reports supporting the planning applications are variously the generic quantitative risk assessment (GQRA); detailed quantitative risk assessment (DQRA); remediation strategy; and the EIA which is summarised in the environmental statement (ES). Any of these should assess the likely human health effect of a plan.
Land west of Warrenby
The documents for ‘Land West of Warrenby, Teesworks’ (planning ref: R/2022/0755/CD) were a condition for approving remediation of the site. (planning ref R/2021/1048/FFM).
The 996-page combined contaminated land quantitative risk assessment (QRA), DQRA and GQRA by consultants ARCADIS, showed that risks on-site come from made ground – mainly from the old slag heaps used to reclaim land – and the former industrial uses of the site.
The study reported that 84 “contaminants of concern” were found in the soil, but only two exceeded the safety levels of the generic assessment criteria (GAC). These were two PAHs – carcinogenic polycyclic aromatic hydrocarbons. There were no GAC levels available to compare the results for 23 toxins in the soil – including cyanide, asbestos and volatile organic compounds (VOCs). The report concluded that contaminants in the soil above the screening criteria for human health were: asbestos fibres, cyanide and PAHs.
Cyanide was not considered an active threat, the report said, and at over 0.5 metres below ground level, PAHs could be left in place. This begs the question: will the site have no foundations, basements or service pipes?
ARCADIS advised that while there are toxins at high levels, little remediation is needed. Protection from asbestos and PAHs in the soil would be provided by a layer of “growing medium” during landscaping. Only tar and NAPLs (non-aqueous phase lipids classed as persistent organic pollutants) in the made ground would be removed.
The risk to water resources was found to be greater than the danger to human health. Groundwater contaminants were metals, hydrocarbons including PAH and TPH (total petroleum hydrocarbons) inorganics including cyanide, thiocyanate, ammoniacal nitrogen, and sulphate. Some 33 contaminants in the groundwater failed the water quality standard – including lead, mercury and zinc.
For soil leachate, 20 contaminants were found above the water-quality limit including cyanide, lead and mercury.
The North Sea was reported as vulnerable to metals, inorganics, TPH, PAHs, tar and NAPL.
“Based on the screening”, the report advised, “further consideration of selected metals and inorganics TPH and PAH is required.”
The report did not consider the effect of water pollution on human health.
South Bank South industrial zone
In the western part of Teesworks, there’s the vast South Bank South industrial zone outline application for industry, offices and parking (R/2020/0357/OOM). In its bulky environmental statement, public health was not considered beyond the health and safety of the workers on site arising from ground contamination, noise, and air quality. It concluded:
“No other significant environmental effects relating to human health are considered and therefore a standalone chapter has not been prepared as part of this Environmental Statement.”
The ARCADIS DQRA for the application excluded human health as they claimed this was assessed in the GQRA. But the GQRA was not included with the planning application and there is only a summary of it in the DQRA.
The DQRA recommended that based on the GQRA findings, “the potential human health risks could be reassessed further when a redevelopment scenario and proposed site levels have been fully defined” and “…further human health assessment has …..not been undertaken at this stage”.
The report suggested ways of mitigating the health impact they had not assessed:
“The potential risk to human health can likely be managed by pathway management systems [preventing contact with contaminants], such as simple cover systems, hardstanding, positioning of on-site buildings and suitable vapour membranes, or by target localised removal of soils.”
The DQRA reported concentrations in the soil of asbestos, arsenic, lead, benzene, dibenzofuran, 1.2 dichloroethane and PAHs exceeding the GAC safety level. NAPL and tar were found mostly in the made ground.
The DQRA list of contaminants of concern in the groundwater showed that 19 exceeded the standard for environmental quality.
South Bank Quay
The northernmost part of the South Bank South land parcel tested positive for cyanide. This area borders the South Bank Quay redevelopment on the riverbank. (planning ref: R/2020/0684/ESM). The wharf is being rebuilt, its berths and the riverbed capital – dredged for better shipping access.
River sediment tests taken at the quay by consultants Haskoning in their EIA report for Tees Valley Combined Authority (TVCA) showed levels above Defra’s Cefas dangerous Action Level 2 of mercury, cadmium, zinc, chromium, copper, lead, nickel, arsenic, and PCBs (carcinogenic, human-made polychlorinated biphenyl, banned since the 1980s).
The sediment is too poisonous to be deposited in the open sea. We have no idea whereabouts on land the toxic sludge is being dumped.
The sediment contaminants that registered at between Cefas Action Levels 1 and 2 were: hydrocarbons, organotins, and PAHs (especially naphthalene, fluoranthane, fluorene, pyrene and phenanthrene).
The deep capital dredging, which has already begun, will expose the older levels of riverbed contamination to the river water above.
The South Bank Quay Strategy report by Arcadis found asbestos, arsenic and PAHs in the soil above GAC levels. Only materials containing NAPL and tar should be removed, it advised.
The Haskoning EIA report for TVCA was not submitted with the South Bank Quay application but its human health risk assessment was included in the environmental statement. It focused purely on air quality, noise and vibration and concluded that the risk to human health was negligible and no mitigation measures were required.
The toxic soil, water and sediment were excluded from the health risk assessment.
The report stated: “Given the scale of the development it was not considered necessary to undertake a full human health assessment.”
These are the pollution findings for just three planned projects. The planning portal shows many more developments in the pipeline.
Dr Simon Gibbon is a local retired industrial research chemist who used to swim in the sea until the pollution became too risky. He has created a website for easier access to Teesworks documents. He pointed out a failure in sample-testing the ground and sediment. Given the long and chaotic history of uncontrolled pollution, there’s no telling if a test patch will have the same result as unsampled spots nearby.
There’s another loophole in the screening process. If for example a creek is classified as polluted beyond salvation, it is excluded from the pollution assessment as it has ‘low sensitivity’. For instance, the environmental statement for South Bank industrial zone mentions that the Cleveland Channel, “is understood to be filled with highly contaminated water and sediments. As such, the sensitivity of these water bodies is considered to be very low”.
Then there’s the problem of excluding water quality from the human health impact assessment. They are pigeon-holed into separate chapters. The risk of polluted water harming swimmers and children on the beach or via poisoned sea life entering the human food chain, has not been addressed.
In the planning documents I read, there was no assessment of total pollution at Teesworks or on Teesside. In a gesture to consider the cumulative local contamination, the Haskoning report on South Bank listed 20 new or recent planning applications. But that didn’t take into account other sources: legacy industrial contaminants, sewage discharge, current industrial pollution including from the Teesside chemical complex.
The health risk
Where does this leave public health? What we don’t know is the total health effect of contamination on Teesside. In the dusty air, the water, even the food chain.
The pollution has already reached the table. Picking gangs have arrived on Redcar’s Majuba beach, collecting the sick and dead crabs, lobsters and more recently mussels, and taking them to restaurants in Sheffield.
Let’s not forget the health and safety of the site workers. In September 2019, two contractors died in a fireball blast while preparing the derelict coke ovens for demolition. More recently, an excavator at South Bank Quay toppled into the Tees with its driver inside after the platform collapsed. He found an air pocket and managed to smash his way out after a minute underwater.
It would be easy to discount concerns about public health – after all where is the proof? In raised levels of visits to the GP and A&E? But this is a time of Covid and pressure on the NHS, would new health problems be noticed?
Some pollutants don’t have an immediate effect. A particle of asbestos in the lung can remain dormant for years before it triggers cancer.
Then there’s the worst case scenario: epigenetics or inherited changes in gene expression. Epigenetic transgenerational inheritance can persist for generations. If a mother suffers physical stresses like pollution near the start of her pregnancy, protein ‘switches’ can activate harmful genes in the early foetus, triggering, for example, diabetes and heart disease.
The need to know
Those of us from Teesside know about pollution. We only have to look at those chemical sunsets, blazing with every colour in the periodic table. But we don’t know the precise combination of ingredients in this chemical cocktail or the specific health risks of the combined contamination.
Many are calling for a pause to dredging until the scientific evidence is confirmed for the cause of the sea-life deaths. We could go further: pause all activity at Teesworks until a complete pollution audit and public health risk assessment is made for the whole Teesworks site.
But this won’t happen. Teesworks and the freeport are the pet project of Conservative TVCA mayor Ben Houchen, hellbent on getting the development up and running in double-quick time.
The company that owns Teesworks, also called Teesworks Ltd, likes to keep its secrets. Formerly 100% owned by the STDC, 90% of Teesworks land and valuable scrap assets was gifted to DCS Industrial, jointly controlled by local developers Chris Musgrave and Martin Corney.
We don’t even know how big the Teesworks site is. The Teesworks Ltd website claims the area is 4,500 acres, yet it also declares that Teesside Freeport, of which it forms a part, is also 4,500 acres. But the freeport includes amongst others the airport, docks, PD Ports, and ICI Wilton.
On Musgrave’s own website the Teesworks size is given as 2,600 acres. But the land purchase totalled 2,400 acres. Seeking clarification, I rang the TVCA media office who handle Teesworks’ press.
The line went dead.