WHAT DID WE ASK?
“I am requesting whether you hold a copy of Rhodia’s closure plan for the hazardous waste site known as Rattlechain Lagoon, Tividale West Midlands, and if you could send this to me.
WHY DID WE ASK THIS?
This was important information, submitted by the company to The Environment agency in 2006, as it detailed what Rhodia’s plans were for the site in the future, and ultimately what their intentions were for the site in terms of potential remediation.
WHAT DID THEY KNOW?
“Thank you for your email of 05 July 2010 requesting information for the above. The response to your request has been sent by post on 14 July because the documents were too large to send by email (33.1MB).”
NB. I received the response to this request by post as they had my address. This was a strange reason offered for not making the content of the request public knowledge- ie by providing it for others to read on the WDTK website. There may well be local residents interested in reading the background to the closure plan for the site for example. 33.1 mb is not too large to send by email when broken down into the constituent parts of the closure plan. WE WILL PROVIDE SOME OF THEM HERE ON THIS WEBSITE, OR SUMMARISE WHAT THEY REPORT.
The enclosed information concerning Rattlechain lagoon (mere) site closure plan and PPC Permit Application No EP 3839 PZ, submitted by Rhodia, consisted of,
- ESID REPORT- Environmental Setting and Installation Design Report a 42 page report.
- HSE Procedure P44 Rattlechain Landfill site procedures– a 19 page report.
- HSE Procedure P3 Accident reporting and investigation Procedure (ARIP)-a broad 43 page theory/pastoral care type report which does not relate directly to the rattlechain lagoon site.
- Hydrogeological Risk assesment– a 20 page report.
- Landfill gas risk assessment– a 13 page environment agency template form completed by Rhodia.
- Stability risk assessment– a 33 page report.
- Closure report template- An EA 6 page template form which has to be completed by the site owner wishing to submit a closure report after being served with a closure notice.
- and Landfill area site plan- an A3 undetailed area map showing the lagoon area in black.
WE QUERIED ?
“Could I ask however why you sent this information to me by post when these separate documents could have been scanned seperately?”
Once again it appeared that The Environment Agency External relations wanted to avoid replying to my question publicly via WDTK, and so replied to my own email address. As the WDTK website allows uploads (for requested info asked via the website only), we uploaded the EA response. Read it here.
WHAT DOES THIS MEAN?
We are not technical experts, nor do we profess to understand all of the information supplied. However, this is all part of the plan for closing down hazardous waste sites with a murky past such as this. There is much theory, and much can be hidden in scientific equations which look good and convincing on paper,but very little practicality in how the problem of this site can be dealt with apart from burying it.
It general it was quite interesting to read that no attempt had been made to determine white phosphorus concentrations in the sediment during these 2006 submissions and from the Hydrogeological risk assesment that “It is thought that some drums containing wastes up to 1% phosphorus may have been dumped annually until approximately 1995.”
It was also interesting to read that “additional chemical wastes may have also comprised a selection of acids, including sulphuric, hydrochloric and fluorosilicic”; information not previously released by Rhodia.
Their assessment of landfill gas generation was laughable bordering on the incredibly dangerous.
Since the submitting of this original Closure plan in 2006, the reports were updated following the 2013 works at the site- which was in order to formally “close” the site. The original plan was therefore considered not to be as robust as Rhodia and their consultants URS considered it to be.