Submitted as part of Rhodia’s original closure plan, this URS report states in its executive summary
“It is understood that Rhodia requires a simple Hydrogeological Risk Assessment (HRA) and stability assessment of the site as part of a future PPC application, in accordance with guidance issued by the Environment Agency.”
The assessment claims that the Environment agency met with either Rhodia and or the consultants on September 1st 2004 and that the regulator told them “the HRA should comprise simple hydrogeological calculations and not a full complex hydrogeological model.”
These reasons and the conclusions for this are deeply flawed. Crucial to the understanding of this document are a series of complicated progressive European Union legislation, which has over the course of time been supplemented by further guidance and legislation. Both environmental consultants and their clients hide behind this legislation which is neither helpful nor protective to those who are presented with a minefield when trying to question the limited data that are presented in reports such as this. The report talks of “List I and List II substances”– but what exactly are they talking about here?
NB listed in List II substances
(e) inorganic compounds of phosphorus and elemental phosphorus;
URS, based on the EA guidance state in the assessment, that a full hydrogeological assessment wasn’t needed as
- “The site is considered to be in an area of relatively low environmental sensitivity, being constructed into clay bedrock.” WE DISPUTE THIS
- “List II substances only were detected in the lagoon supernatant, concentrations of which are typically below consent limits for the discharge of this water to a nearby canal. The presence of these substances may also be attributed to an off-site source.” WE DISPUTE THIS
- “Previous investigations have not indicated a significant impact to groundwater down-hydraulic gradient of the site.” WHAT INVESTIGATIONS AND WHO CARRIED THESE OUT?
We have stated throughout on this website that the claimed depths of this lagoon presented by Rhodia’s consultants are not accurate at all. The historic depths of the site in the 19th Century was claimed at “100 yards deep.” Clay extraction from the pit had started around 1846. Though there were various periods when the rattlechain brickworks are listed as “disused”- It was nonetheless still not extracting marl from newer dug pit to the East until 1946. We strongly believe until someone proves us wrong with direct evidence that the supposed floor of the lagoon- The Etruria marl, is a false bottom of extracted material from this newly dug 1946 pit- as well as other material spoil from adjacent colliery workings. We believe this based on planning history for the site, which no environmental consultants of Rhodia nor anyone else have ever bothered to look into.
In the report consisting of 20 pages, URS present a very one sided view of the site, its previous investigations and a “conceptual site model”. This model shows the two lagoons and the manner in which waste was deposited into the “main lagoon” and filtered through the causeway path to what it calls “the clean side” lagoon. The report refers to “the clean side” lagoon throughout, which as we have proven is a total nonsense, given that it was created artificially from the one single previous main lagoon in the early 1960’s. The smaller pool is as contaminated, if not more so than the main lagoon, given that all of the waste deposited within its area would have been carried out before site licensing was introduced.
This site model looks at sources, pathways and receptors in connection with the lagoon. The historic white phosphorus dumping activities along with other chemicals of origin from Trinity Street should not be diluted with reference to the Mintworth owned adjacent site. This is the aim of URS and Rhodia to explain pollution that they cannot account for, yet they can offer no hard evidence that any pollution is actually arising from this landfill to the East.
Also deceptively drawn are the barrels and scrap metal located at the bottom of the site, out of reach and sight from anything else. They know that this information is misleading, given the fact that barrels were sunk historically with rifle fire, after disposal of waste had commenced. This was certainly still taking place in the early 1990’s when barrels were still being taken to the site. Metal barrels were also visible at surface level at the lagoon in 2004, in both the small and large lagoon. WE SAW THEM. Barrels were also retrieved from near surface level by contractors during the 2013 works.
Also recommended by URS was quarterly monitoring of boreholes on site , decreasing to once per annum after intial screening. This does not appear to have happened systematically based on records submitted by Rhodia to URS in the the revised hydrogeological risk assessment updated in 2013.
This 2004 report was reviewed by John Davis of the environment agency in conjunction with works that were taking place at the site in 2013. Some nine years on there had been no changes or updates. His comments can be read HERE.
Of this original 2004 assessment he states the following
“The report identifies the likely hood that groundwater quality and lagoon water quality is potentially being influenced by off-site sources. The aim of this report should be to clearly characterise the waste body and consider then any risks to identified receptors. So any future review of this report should seek to make a distinction between contaminants from the Permitted/deposited waste and any resultant risks (which is the key aim of the report) and to the complexity of the site setting consider the influence of contaminants from on site made ground and off site sources in the context of the site. Additionally, any future review of this report would update the “technical precautions” & “requisite surveillance” sections in the light of an agreed monitoring regime and future engineering works at the site.”
IT MUST BE QUESTIONED WHY IT TOOK ANYONE FROM THE ENVIRONMENT AGENCY AND RHODIA TEN YEARS TO CHANGE THIS HYDROGEOLOGICAL RISK ASSESSMENT, AND WHY THE ENVIRONMENT AGENCY HAD ORIGINALLY FAILED TO ASK THE CONSULTANTS URS TO CARRY OUT A MORE DETAILED AND FACTUAL ASSESSMENT.