This request directly complements a request made to DEFRA concerning a Parliamentary question by Adrian Bailey MP relating to quantities of white phosphorus in the sediment. The Environment Agency had been the source of DEFRA’s answer to the question. We asked a more exacting set of questions involving quantity of weight and not misleading percentages of overall weight.
WHAT DID WE ASK?
1. “Please provide details that you hold on file of annual site returns of the volume of waste deposited in the Rattlechain Tip/lagoon, Tividale West Midlands by Albright and Wilson and Rhodia.
2. Please include the charging band for these returns also and the annual fee for each year.
The quantities of waste deposited at the site for each category of waste permitted by the licence, held in our files, are as follows:-
a) Effluent treatment sludge
b) Inert solid waste contaminated with elemental phosphorus
c) Water contaminated with elemental phosphorus or phosphoric acid or sulphur
d) Inert solid wastes
Q2. There is no specific charge for the submission of the annual site returns
We wanted further clarification of these figures
(i) Could you confirm when your information held on file starts from in respect of the quantities of waste deposited at the site for each category of waste permitted by the licence, baring in mind that the company claims a year of “acquisition” of the site in 1948, but from my own private research when Albright and Wilson were a Ministry of Supply contracted factory the first year of use for the site was 1942.
“Our information held on the site begins from the issue of the licence in January 1978 until the site closed for the reception of waste in March 2006. We have no records on the types or quantities of wastes deposited in the site prior to the issue of the licence.”
(ii) Have you calculated the figures for each waste type by totting up the figures received from the companies from start of license to close of tipping in 2006?
(iii) Can you confirm the years when returns for Inert solid waste contaminated with elemental phosphorus 1,182.35 tonnes were filed until- e.g. from start of license until which date?
“The last reported deposit of this waste type was in October 1997.”
(iv) Can you confirm the years when returns for Water contaminated with elemental phosphorus or phosphoric acid or sulphur 3,550.96 tonnes were filed until- e.g. from start of license until which date?
“The last reported deposit of this type of waste was in October 1992.”
We also asked in this request
3. Please include any correspondence that you hold on file from the companies with the site returns.
They provided the following PDF file of correspondence. Read this here.
The letters themselves offer some incredulous statements made by Rhodia.
August 6th 2001 (context- after several bird deaths have been noted)
Rhodia ask to deposit 1,000 tonnes of “inert material” to “improve” the beach area.
Letter from EA dated October 10th 2001 allowing this with the proviso that it is “uncontaminated” material- but how would they be abe to confirm this?
There is then a statement made that Rhodia are not paying the full amount for waste tipping.
“However. the last few years site returns show that the annual volume of waste deposited is actually closer to 60,000 tonnes a year.”
Letter from Rhodia October 31st 2001
“I do not believe that we deposit 60,000 tpa of waste at the Rattlechain Mere. We actually deposit approximately 2,500 tpa of solid waste. The remaining 57,500 tonnes is water that is used as a transport aid for the solid waste.”
“The water is not waste, it is a transport aid used to help transport the solid waste to the Rattlechain.”
Reply from EA December 11th 2001
“In waste management licence SL31 the waste is described as effluent treatment sludge, and therefore it is this sludge that is the chargeable waste. In other words the fee relates to the waste that is being discarded and destined for disposal in the case of the solid part, and recovery for the liquid.”
So the Environment Agency DID have some significant information as this request demonstrates, but only chose to answer the parliamentary question in a curt way.
“0.01%” of white phosphorus in the overall waste referred to in the Defra answer to the Parliamentary question sounds a lot less than the “Inert solid waste contaminated with elemental phosphorus – 1,182.35 tonnes and Water contaminated with elemental phosphorus or phosphoric acid or sulphur 3,550.96 tonnes.” The Environment Agency were aware that this total was present in the lagoon sediments over just a 20 year period 1978-1997- as evidenced by their reply to this request.
Rhodia on the other hand, a multi billion euro company argued about how much tax they should be paying on the waste that was having a detrimental harmful effect on the wildlife on the site.