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The Environment Agency,
Permitting Support Centre,
EP Team,
Quadrant 2,
99 Parkway Avenue,
Sheffield,
S9 4WF.
23 June 2011
Dear Sir/Madam,
This is a letter from EcoIvy, which campaigns on behalf of the residents of Ivybridge who object to the proposed Viridor landfill at New England Quarry. Application number EPR/PP3133FC/A001.
I have laid out the response in the same order as the Environment Agency permit application has been submitted.
Section 6 Operation Techniques
OT2 Odour
There are three main areas of concern regarding unpleasant odours from this proposed landfill. Landfill gases, leachate and incoming waste.
2.1.2 Leachate
Leachate produced by the landfilled waste will be extracted from collection wells within the waste and then be transported elsewhere. The application does not give an indication of how the leachate will be extracted and what the expected volumes will be. Nor does it specify where the leachate will be transported to and the method of disposal. The leachate will be produced by waste classed as directive waste and will have hazardous properties (H15). This will require specialist transportation and disposal.
2.1.3 Received Waste
Viridor states the landfill site will receive low volumes of waste. However predictions are based on an average fill rate of 33,000 tonnes per annum (tpa) but could increase to 60,000 tpa, with a breakdown as follows:
• Un-burnable MSW – 20,000 tpa;
• Incinerator Bottom Ash – 4,500 tpa;
• Commercial and Industrial Waste – 8,500 tpa.
Over the life of the landfill the total of waste that will be dumped in NEQ void will be 970,000 tonnes that cannot be quantified as a “low volume”. At least 500,000 tonnes will be un-burnable MSW straight to landfill.
Viridor suggests none of these waste streams are considered likely to be an odour risk. This is misleading when you consider the waste stream that will be brought to the site. Some of that will include waste from human and animal healthcare, processing meat, fish and other foods of other animal origin, wastes from anaerobic treatments including digestate and waste from sewage cleaning. The company has suffered from odour problems at its Heathfield site near Newton Abbott.
If the EFW process line becomes inoperable, Viridor then proposes that all of the waste will then go straight to landfill.
3.2 Temporary Odorous Activity
Concerning the delivery of particularly odorous wastes, Viridor suggests pre-booking of this waste as a solution. I, and waste experts I have consulted, fail to see how pre-booking this waste stream will make it smell any less offensive for the residents living 220 meters away from this site.
3.3 Viridor states that for the disposal of high odour waste streams they will minimise the storage and transport of odorous waste but then go on to say in Section 3.5 that high odour waste deposition shall, where possible, occur during periods of favourable weather conditions. EcoIvy would like the Environment Agency to seek clarification of this point and forward the response on to us.
3.10 Minimising Disturbance to Previously Impacted Waste
Disturbance of previously impacted waste creates offensive odours and should be avoided but due to the New England site being a quarry, waste will have to be dumped on top of previously filled waste. In some cases Viridor states that this will be after a significant period of dormancy, this is far from ideal and indicates this is a poor choice of site for landfill.
3.11 Landfill gas infrastructure
A gas abstraction network will be installed in order to maintain gas control to help prevent fire explosions and landfill membrane rupture. This will be connected to an on-site gas compound for gas flaring. EcoIvy believes that given international, national and local concerns about climate change it is totally unacceptable to allow gas flaring at New England Quarry. If this scheme is to proceed, there must be plans put in place to use this gas as a resource to produce energy.
3.15 Odour Management Sprays
I find it surprising that if Viridor feel the risk of odour is so low they are also proposing to use masking and odour neutralising agents on the site. Pollution control experts I have consulted are concerned these agents may get into surface water and would like to know if they could have any detrimental effect on the environment, wildlife or River Yealm.
4.2.1 Subjective Odour Surveys
I was deeply concerned to read about the odour management inspections which use the so-called “sniff test”. Compliance with this type of monitoring will be highly subjective and open to wide interpretation and abuse. I am worried that the site manager will only be informed and the cause investigated if the odour has significant off site impact.
OT3 Surface Water Management Plan
Having reviewed this section EcoIvy remains unconvinced Viridor will be able to manage separation of rainfall and dirty water for the entire duration the landfill remains active.
3.2
The use of attenuation ponds provides a direct link to the Yealm. They are inadequately small buffers between the landfill drainage systems and the River. The ponds themselves are not sufficiently sealed to provide protection to the river if contaminated. The proposed monitoring system via visual checks is flawed and inadequate to ensure drainage is compliant with permitted standards.
EcoIvy requests that the Environment Agency asks Viridor to provide us with examples of what constitutes a non-immediate problem which results in a defect in the drainage system to be left unrepaired for up to 28 days.
Non Technical Summary
7.2Hydrogeological Risk Assessment February 2011
On reviewing the Hydrogeological Risk Assessment I – and experts who we have consulted - have grave concerns over contamination of the river Yealm.
EcoIvy have concerns about the compliance points for both hazardous substances and non-hazardous pollutants, for example one of theses is sited directly below the NEQ site and so allows for the immediate dilution in groundwater.
Viridor states that there may be other, physical receptors further away from these points, and that compliance with the regulations will ensure that other receptors are adequately protected. EcoIvy requests that the EA asks Viridor how this will be ensured.
It seems to us that the landfill leachate mitigation after construction mostly consists of infrequent monitoring and that using compliance points as a monitoring system is wholly inadequate and dangerous. The damage from hazardous leachate will already be done.
6.0
Viridor concludes in their application for an EA permit that the results of a risk assessment have established that the installation will potentially pose a hazard to ground and surface water quality. The company has said consequently arrangements must be made to collect contaminated leachate and any contaminated water that is generated by the site.
Viridor proposes that the installation will require a geological barrier and artificial sealing liner of sufficient thickness and attenuating properties to avoid the release of hazardous pollutants which
minimises the release of non-hazardous pollutants. Experts we have consulted argue that leachate is notoriously difficult to control in land-fill sites and constructing one that starts below the ground water level and progresses up through the strata to the surface is a deeply flawed solution.
Simply minimising the release of non-hazardous but not inert pollutants is also inadequate. DEFRA's 2011 Waste Hierarchy Evidence Summary states that eutrophication may be caused by leachate or effluent from the waste disposal system. This triggers excessive growth (and death) of plants and algae which can lead to decreased oxygen levels in water, creating conditions which cannot support diverse life. This means that there are real concerns about the river Yealm which is 50 meters from the NEQ landfill site. There is a risk of membrane rupture during construction and Viridor have concerns of rupture during waste deposition. This does not include the deterioration of the liner properties over time, something that the EA has admitted is a problem to EcoIvy in the past.
In addition to the main river, several tributaries are located within 1km of the site including a small stream which flows along the northern boundary, and a second stream which joins the Yealm from the east, approximately half way along the site boundary. The ground water is in hydraulic continuity with the river Yealm and there is a low ground water high river discharge rate, however ground water flow is towards the river Yealm from the landfill site.
There is a secondary aquifer on the landfill site and there are five groundwater extraction sites within 3km of the landfill site boundary.
OT4 Waste List
In the waste list submitted by Viridor the list is a mix of categories. Although this waste is not classed as hazardous it is not inert waste either. This is unsuitable for landfill at a site as environmentally sensitive as NEQ. The options for waste management have been ranked in a waste hierarchy according to their approximate environmental benefit and dis-benefit in the revised Waste Framework Directive 2008.
Prevention
Preparing for reuse
Recycling
Other recovery
Disposal (landfill)
The UK needs to apply this hierarchy as a priority order in waste prevention and management legislation and policy. I have examined a few streams of waste destined to be dumped in the quarry and compared them to the recommendations from the DEFRA Waste Hierarchy evidence Summary 2011 below.
Food waste should be diverted from landfill wherever possible. Food waste degrades to the potent greenhouse gas methane over a short space of time in landfill. Even where methane is captured for flaring or energy recovery, the overall impact is still extremely negative.
Conventional plastics will degrade very slowly, if at all, in landfill conditions. However, they are lost to the resource economy and take up landfill space. Overall, landfill remains the bottom of the waste hierarchy. Plastics which are designed to degrade may or may not breakdown in landfill
depending on their properties and the landfill conditions. There is a lack of research into this at present, but if the materials do decompose they are likely to lead to emissions of methane. Even if a proportion of this is captured much will also escape into the atmosphere.
Both these should be diverted from landfill wherever possible. As they degrade in landfill, they can emit methane. Even where some or most of these emissions are captured for flaring or energy recovery, the overall impact is still negative.
Metals may rust in landfill and break down, or may remain in situ. As there is no opportunity to recover value, landfill remains at the bottom of the waste hierarchy.
No energy can be recovered from waste glass. Some value may be recovered if the incinerator bottom ash can be used, for example in construction, but the benefits are negligible and Viridor has incinerator ash on the waste list for landfill anyway. As an inert material, glass does not degrade in landfill. However, it is lost to the resource economy and takes up landfill space.
Finally garden waste should be diverted from landfill wherever possible as it emits methane when it degrades. Even where some of this is captured for flaring or energy recovery, the overall impact is still negative.
The proposed landfill at NEQ will contribute to climate change caused by emissions of greenhouse gases including carbon dioxide, nitrous oxide and methane. Climate Change is an issue of global concern. In the UK, the Climate Change Act 2008 sets out an objective to reduce carbon dioxide emissions 80% by 2050 against a 1990 baseline.
Section 6 Operational Techniques overview
4.8.3 Noise
Noise pollution is inevitable in managing a landfill site, whether it is from the movement of HGVs, plant vehicle reversing bleepers or uploading and compaction of waste. Mitigation offered by the applicant is that these activities will happen at specific times. I fail to see how this will reduce the noise. Although Viridor suggest silencers may be fitted to some vehicles in accordance with manufacturers’ instructions, the company offers no solution to the huge amount of heavy goods vehicles that will be entering and leaving the landfill site.
4.8.4 Pests
It goes without saying that Birds, vermin and insects will be attracted to landfill site especially one in such a rural location. The mitigation offered by the applicant is that the tipping area for waste will be kept to a minimum, although once again mitigation plans seem to be inadequate.
4.8.5 Litter
I have concerns about litter from this landfill which is a threat to wildlife. Viridor assures us that it will cover light waste as soon as possible to reduce the risk of littering but shall only clear up litter from affected areas outside the site when practicable. Once again this is inadequate, given the sensitive nature of the local habitat.
Traffic
As Viridor did not win the bid for the South West Devon Waste Partnerships waste contract, it does not have the household waste to burn or landfill. Viridor cannot tell us where the 970,000 tonnes of waste for landfill will originate and be transported from. As a result their predictions of what the waste will consist of are inaccurate as they are pure speculation. This also has huge implications for traffic across the county and possibly further afield as waste may have to be imported. The Jacob's report for DEFRA 2010 shows as there is not enough commercial and industrial waste in Devon. The access through the village of Lee Mill is already under strain and cannot support further increases in traffic especially the vehicles needed to support a 970,000 tonne landfill.
Waste Local Plan
Viridor's proposals for the NEQ site violate Devon County Councils Waste Local Plan 2006 SH17. Under considerations for the site, the plan states their should be no further encroachment into the flood plain and any proposed extensions should be away from the watercourse.
Environmental Impact and other concerns
I am concerned that the revised plans have widened and lengthened the access road to the NEQ site and it would encroach further into ancient woodland. This obviously cannot just be replaced.
The plans to drain the quarry void will destroy foraging sites for twelve species of bat.
The NEQ site to the river Yealm provides a wildlife corridor for recently returned breeding otters and many threatened birds. This will be destroyed or at the very least put at risk. I feel the proposed nature conservation mitigation is completely insufficient.
Devon County Council has just had further environmental information given to them, I would like the Environment Agency to ensure that they pass this additional information onto EcoIvy.
The New England Quarry has many characteristics that make it a unique and valuable wildlife area. The north eastern corner of the site and much of the woodland to the north, south and east has been designated as Mackarell Parks, Southwood Woods and Strashleigh Ham County Wildlife Sites (CWS) for the presence of ancient woodland. The north western corner of the site has also been designated as New England Fields County Wildlife Site for the presence of marshy grassland habitats.
Much of the quarry void has also been designated as a Regionally Important Geological and
Geomorphological Site (RIGS) due to the presence of gabbro intrusions into Middle Devonian slate. Several other non-statutory wildlife sites are present within 2km of the site boundary, these are predominately ancient woodland and neutral grassland sites.
The Dartmoor National Park is located approximately 3.6km to the northeast of the proposed
landfill and the South Devon Area of Outstanding Natural Beauty (AONB) is located approximately 2.3km to the south.
In summary New England Quarry is the totally wrong choice of site for a nearly one million tonne waste landfill for so many reasons. The Environment Agency has a unique opportunity to protect this delicate ecosystem and that of the river Yealm.
Finally we have the technology to vastly increase recycling rates so much of the material that Viridor proposes to land-fill could be reused or recycled.
Yours sincerely,
Charlotte Mills
On behalf of EcoIvy and the residents of Ivybridge.
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