FOI REQ 8 Dredging lagoon- Further Risk assessment

rattlechain lagoon proposed dredging further risk assessment information

BACKGROUND

 The Health Protection Agency human health risk assessment carried out on this white phosphorus contaminated lagoon at John’s Lane,stated .
“THE HPA RECOMMEND THAT IF ANY FURTHER WORKS ARE UNDERTAKEN AT THE SITE WHICH ARE LIKELY TO INVOLVE SUBSTANTIAL MOVEMENT OF SOIL OR SEDIMENT THAT FURTHER MONITORING AND RISK ASSSESSMENT WOULD BE ADVISABLE TO ENSURE THERE IS NO HEALTH RISKS TO THE RESIDENTS OF
THE ADJACENT HOUSING ESTATE OR MEMBERS OF THE PUBLIC USING THE FOOTPATHS.”

The proposed works at the lagoon involve dredging the smaller lagoon, which their study was found to contain higher levels of white phosphorus than in the so called “contaminated” larger lagoon. This is not surprising given that the smaller lagoon was constructed out of the original single marl pit which had already been filled with waste before any licensing regime commenced. The permit licence also barred waste being deposited into this smaller lagoon after 1978.  The unclassified waste material in this smaller lagoon is to be dredged and white phosphorus still persists in the sediments from before 1978,( that is waste that was deposited before The Deposit of Poisonous Waste Act 1972 and The Control Of Pollution Act 1974).  This waste is to be transfered into the larger lagoon, SO WHAT FURTHER ASSESSMENTS HAVE BEEN MADE?

WHAT DID WE ASK?

 “I am requesting what recorded information the agency has been given or holds regarding risk assessment concerned with this operation.
Can it be confirmed what amounts of material are to be dredged or have the agency been given any estimates of waste to be dredged during this proposed operation?
Has the agency been given any or requested an environmental risk assessment regarding wildlife at the lagoon in respect of these proposed works?”

WHAT DID THEY KNOW?

A reply was received.

  • “We have not seen the monitoring strategy or any risk assessments to date.”
  •  “The Environment Agency has asked Rhodia to review and update the site post-closure plan to take account of the improvement works and to include monitoring for phosphine gas so this can be controlled should emissions occur.”
  • “The Environment Agency has not been given any figures or estimates of the quantities of materials to be dredged in either part of the lagoon.”

 

  • “The Environment Agency has neither requested nor been given an environmental risk assessment regarding wildlife at the Lagoon during the period of the works”
  • “The works are due to start before the wildfowl breeding season and it is expected they will be discouraged from breeding by the daily activities at the site.”

 

WHAT DOES THIS MEAN?

To us this follows the same pattern of allowing this business to proceed in the manner which they choose, and not one which is based upon external regulation. The EA cannot test for phosphine gas, so are reliant on figures being presented to them based on self regulation.

There is also the impression that local management continually fail to ask relevant questions related to this site. It should be noted that Sandwell swanwatch revealed the history of the two lagoons, and that there had originally been one single dumping pool. If this had not been the case, the smaller lagoon would probably have been left as it was, untested for white phosphorus and convenient for the company when it came to “remediation” or “monitoring” of the site.

The relaxation of the regulations behind the permit are what Rhodia are really seeking from this exercise, a step nearer lancing the boil of bad publicity that this toxic site continues to cause them and selling the site off.

There appears to be little hope for the wildlife on the site from  this EA response. They mention the breeding season. We were concerned and still are about their mere survival from being poisoned by redistributed white phosphorus from dredging activities, not their sex lives. Unfortunately the EA previously hopelessly failed to consider environmental risks to wildfowl when they told Albright and Wilson/Rhodia to redistribute the sediment  which led to deaths. Nothing appears to have been learned.

 

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