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ASBESTOS TIP CAPPING. CARR HEAD, PECKET WELL Pecket Well Residents' Newsletter 4 Tuesday, May 16, 2000 At the meeting held at Wadsworth Community Centre on 11 April with representatives from Calderdale Council a Wadsworth Parish Councillor along with some residents were disappointed to find that Technical Services had only brought plans for Option 5. Throughout the day, questions were asked of Calderdale with regard to monitoring and several other pertinent points which they could not fully answer. Also, one resident was unconvinced when told by the Environmental Health Department that Option 5 was the greenest solution. This meeting was held to 'reassure' the residents and it appears to have singularly failed to do so. Wadsworth Parish Council are meeting on Tuesday 23 May at 7.30 p.m., Town Hall, Hebden Bridge. It is vital that we, as residents, and any other interested party, attend this meeting to show objection to the current planning application and to get it withdrawn. Some residents have consulted private contractors specialising in operations to deal with contaminated land. Any proposals will be forwarded to Wadsworth Parish Council and Calderdale Council. They will also be outlined in this newsletter. After discussion with some of these contractors, who appear to think Calderdale's scheme (Option 5) is excessive, it is clear that there are other safer, less disruptive options available. One contractor pointed out that a suitable remedy can only be drawn up after a full site survey. So far Calderdale Council have not undertaken one. The contractor said that a scheme would be available whereby a full site survey would be funded by themselves on condition that the contract was granted to them. Before any proposal can be considered a full Environmental Impact Assessment must be carried out. Also a detailed site survey must be performed to determine the exact location, quantity, depth and spread of the contaminants. This should include a detailed hydrology report including a flood risk assessment and a report on the current levels of any water borne pollution from the site. After repeated denials by Calderdale Council that coal and quarry waste will not be used, in a letter dated 10 May from Mr. Dawson of Environmental Services it clearly states that, "non-contaminated coal and quarry waste could be used"! Please attend the meeting on Tuesday 23 May, your support is vital in getting this landfill site stopped ! If you have any contributions to the newsletter please telephone 845696 30th March 2000 In order to have an intelligent debate about this matter I believe we should firstly define what the problem is and not get deflected by tangential issues such as traffic movements. Whilst the latter will be an inconvenience to many, it is not the real problem. If we simply focus on the HGV issues then we are missing the point. The central issue is: what is the reason for deciding to cap this tip now, it having been there for many years? • Does the land in its present state represent a health hazard? • If so how long has it done so and when were the appropriate authorities aware of this situation? • Is impending legislation, such as the recently published 'Right to Roam' White Paper wherein it is proposed that Council owned lands become freely accessible to the public, driving this initiative? • Is there current legislation demanding the capping of existing asbestos/toxic metal dumps? • With ever escalating landfill taxes we can estimate that if the number of HGVs is 17500 then we are looking at approximately 350,000 tonnes of waste materials. The value therefore of a 'tax exempt' dump is currently in the region of £3.5m to whoever currently owns the waste. • A sum of £4.8m has been mentioned as the cost of this project. Who will pay this money and more importantly, who will get it? More importantly, what is it for? • Whilst not wanting to appear cynical the following questions need to be asked. Will any individual involved in the decision making process, their relatives, business or political associates or Company or Business, benefit financially from this project in any way? The key issues are therefore Health and Safety aspects regarding the current site and the financing of the proposed capping Project. Let us assume that it is a jolly good idea to cap the tip as no doubt those proposing to do so would argue. If legislation is not a 'driver' then it must be Health and Safety. If the latter then this is a tacit admission that the current tip is unsafe and represents a hazard to either those who enter and/or live adjacent to the site. If the answer to the above is that Legislation does not demand we cap the tip, neither does it currently represent a Health and Safety hazard whilst undisturbed, then there must be other reasons. And we wonder what they may be? Technical Issues. • Who will be the main Contractor for the Project and what experience base are they working from? • What stage is the project planning at, for example has there been a detailed site survey performed eg, bore holes, trenching, topography, hydrology? • Is there an estimate of cost prepared, has the project brief gone to competitive tender and if so to whom? • The site is not flat and for effective capping to a uniform depth of overburden will require some degree of grading. Can we be assured that in the process of grading the land prior to capping that toxic materials will not be released into the atmosphere or to water courses? • All vehicles leaving the site will need to be thoroughly decontaminated prior to rejoining the public highways. This is usually accomplished by portable automatic vehicle washers. Who will validate and police this process? What will happen to the contaminated wash waters, we trust they will not simply go into local water courses but be tankered away for correct disposal? • We note that 'coal and quarry waste' will be the materials used for capping. It is well documented that UK coal/coal waste contains organic and inorganic sulfur (thiophens and various metal sulfides, mainly iron). In the presence of water, certain microorganisms are capable of oxidising these sulfides to sulfate in the absence of oxygen. The nature of the capping material is rather important and whilst this is not the place to give a lesson in the metabolism of chemolithotrophic bacteria is deserves passing mention. There are essentially two sorts of bacteria capable of metabolising inorganic sulfur. Sulfate reducers who reduce sulfate to sulfide and hydrogen sulfide (bad eggs smell) and which in the presence of metals produce black metal sulfides. The others are the sulfur oxidisers who take sulfur, H2S or sulfide through to sulfate. They produce dilute sulfuric acid which dissolves other metals to form soluble metal sulfates, these then leach out of the soil with the ground water. This microbial process is the basis of massive commercial operations in the recovery of copper as blue copper sulfate solution from low grade copper sulfide ores. If there are other toxic metals in the dump (Zinc, Cadmium, Nickel,Lead) these will currently be in the form of insoluble sulfides and oxides. The action of acid will solubilise these metals and they will in time leach from the dump. Needless to say we would not want an highly acidic, toxic metals cocktail of leachate slowly draining from the site and thus coal waste is not a good idea. The term 'quarry waste' covers a multitude of sins. In this context does it mean the waste from a quarry or does it mean the waste from a quarrying operation. With the advent of flue gas desulfurisation to reduce emissions of sulfur oxides from coal burning power stations we have gone some way to curing acid rain. In the process we have instituted a massive quarrying operation for limestone (several million tonnes per annum) which has to be moved by road and rail to the power stations. There it is converted to calcium sulfate (gypsum) and C02, the latter having been locked away in limestone for a few 100's of millions of years now becomes a problem for the global warmers. The gypsum, a mineral formerly quarried for the manufacture of plaster is now in vast excess to consumption and has to be dumped. I assume that is what is meant by 'quarry waste'. Sulfates are very bad news for capping operations as I have already pointed out. Turning now to the traffic movements concerns. The suggested number of 17500 HGV implies a total volume of approx 200,000 M3. That is enough material to cover a site of 450mX450m to a depth of 1m. How big is the site? Over what timescale is the operation intended to last? Is it 24h, 16h or 8h, 7 days per week, 5 days or what? If say it is 50 movements per day at half hour intervals, 7 days per week then that will be a 350 day operation, round the clock, day in day out f or a year. In the ascent from Hebden to Pecket Well these vehicles will over the period produce between 2 and 6 tonnes of submicron carbon particulates for us to respire to say nothing of the several tonnes of carbon black eroded from their brake linings as they descend. We note that the Keighley Road was repaired last year after partially collapsing down the valley. One assumes that it will take the strain? In the case of asbestos and toxic metals/chemicals waste dumps we should leave them undisturbed if they currently present no hazard via atmospheric or water borne pollution. Obviously people, domestic animals and grazing animals should be prevented from entering the site and disturbing it but 'leave well alone' is the least cost, lowest hazard option with an inactive site. If it is actively polluting the environment at present then remediation by capping, collection of leachates etc is the recommended method. Even there I have my doubts in that the act of remediation may cause a degree of pollution which can exceed a danger threshold in the short term which is never attained if such action was not taken. QUESTIONS TO CALDERDALE COUNCIL AND WADSWORTH PARISH COUNCIL RE: CARR HEAD LANDFILL SITE 28 MARCH 2000 1. Does the land in its present state represent a health hazard?How long has it done so and when were the appropriate authorities aware of this situation? 2. Is there current legislation demanding capping of existing asbestos/toxic metal dumps?Is Impending legislation driving this initiative. (such as "Right to Roam" White Paper ) 3. Has there been a full Environmental Impact Assessment report?
5. EFFECTS OF THE SCHEME Who is the main contractor for this Project, what experience base are they working from? 6. What is the content of "coal and quarry waste" of what does it comprise? Where is it from ? Who will police and test the material throughout the project? 7, The use of such material in a capping operation will result in a highly acidic toxic metal mix of leachate draining from the site. What are the proposals in relation to this? 8. We are given to understand that the culverting of the stream would not be allowed permanently by the Environment Agency.Is this correct? What then will happen? 9. All vehicles leaving the site will need to be thoroughly decontaminated before rejoining the public highways in closed loop vehicle wash recycling systems (PPG 13,Ref. 5) Who will validate and police this process? How will the waste waters be correctly disposed of? 10 How will the large amounts of silt produced from this operation be prevented from polluting the watercourse? 1 l. Has there been a full traffic report? What is the proposed exact route or routes? Has the stress on traffic, the effect on the local economy and the large amounts of pollution caused by this operation been fully investigated? If so where is the report?
12. On form CDM 7 of the Feasibility Report - Risk Assessment Summary If the various activities shown (Specifically 100.1, 100.3, 400.1, 500.1, 500.2, 600.1, 600.2, 600.3, 600.6, 700.1, 700.2) create contamination that exceeds the recommended levels (i.e. Action levels) What are the proposed emergency procedures?
13. Option 5, of filling over tree stumps will cause "future settlement" (Vegetation rots away leaving a gas filled void). Option 6, which has robust drainage, terracing and support measures, causes too much disturbance of the contaminated land. Is the Council prepared to consider other, safer, cheaper options i.e. that proposed by Stuart Bradshaw ? Hebden Bridge Web Hebweb News |