DIFFERENT STORIES OF WHAT IS CONTAINED IN RATTLECHAIN WASTE- THE WISHEY WASHY ACCOUNTS SUPPLIED BY ALBRIGHT AND WILSON AND RHODIA
There are many document sources submitted by Albright and Wilson/Rhodia or their consultants and agents relating to the history of waste dumping at the site. Taken collectively, both the history of the company involvement with the site and its contents have become a woven tale of inconsistencies, lies and deceptions. Also unhelpful are the blurring of the terms “phosphorus”, “phosphate”, “phosphatic muds or “Phosphatic sludges”, which could be misinterpreted to mean “total phosphorus”- to which they certainly do not refer. All references to “phosphorus”, “phosphatic muds” and “phosphatic sludges” only relate to elemental or white/yellow phosphorus P4.
Another misleading “strawman” offered by the company relates to the dumping of more recent waste streams, as opposed to the more toxic chemicals present in the historically dumped waste, which persists, poisons, and which are of most concern.
“Effluent arisings from across the site were treated to produce a slurry. The effluent treatment slurry was a slurry of calcium phosphate in water.”
Tom Dutton Rhodia Health and Safety Manager in a letter to Adrian Bailey former MP.
At the time of the Cremer and Warner report in 1991, Albright and Wilson told the consultants “a number of waste drums, perhaps in the region of 100 per year, are also understood to be disposed of in the lagoon. C and W understand from A&W that these are rolled over the edge of the road near the turning circle and into the lagoon.”
These assumptions are basic in the extreme and are hardly credible as a basis for a scientific investigation that followed. The lack of clarity concerning quantities, description and nature of deposited waste only helps to protect the interests of Rhodia when it comes to remediation strategies.
(ii) Compliance Inspection of Rattlechain Landfill Site page 49 however, Albright and Wilson told the inspectors “Solids (typically 5 -10% of the sludge) settle out, allowing the liquid to clarify.” Though the exact makeup of this mixture is not verified independently “.. as a result, a layer of calcium phosphate several metres thick lines the pit. This has a permeability similar to Bentonite clay.”
In a letter from their solicitors Eversheds acting for Rhodia to the Head of Planning and Development services at Sandwell council dated 19/6/2003- they object to Development at the adjacent sewage works ref DC/03/40538
“Our client has operated the Rattlechain Landfill site (Rhodia/Albright and Wilson lagoon), adjacent to the Northern boundary of the proposed development site for the disposal of chemical waste since 1948.”
Under Application DC/04/42440 To Sandwell Council “Application for certificate of Lawfulness for an existing use or operation or Actions in breach of a planning condition”, under Class B2 (General Industrial Process), Question 9 asks the applicant
“When was the use or activity begun, or the operation substantially completed?”
Under Tom Dutton’s signature for the application the answer is given as
“Use for this activity has been continuous since approximately 1947, by the present operators Rhodia Consumer Specialities Ltd, who formerly operated under the name Albright and Wilson Ltd.”
Having asked for other reports under the Freedom of Information Act Concerning Rattlechain, The Environment Agency supplied swanwatch with several reports which constitute Rhodia’s closure plan for the site. These reports themselves offer more conflicting versions of events and quantities of chemicals.
In all reports Rhodia’s appointed environmental consultants were URS.
In the Hydrogeological Risk assessment on page 4 at 1.1.2 they comment
“The site is a former brick pit and has been operated since 1947 by Rhodia, and its antecedents, for disposal of calcium phosphate slurry generated by the wastewater treatment plant located on Rhodia’s manufacturing site in Oldbury.
Historically , a variety of waste types were reportedly deposited, including chemical drums containing wastes with upto 1% phosphorus may have been dumped annually until approximately 1995.”
In the ESID report (Conceptual model Environmental setting and installation design report) URS state in the Executive summary at Paragraph 3
“The site has operated as a waste lagoon since the 1940’s and receives several tankers of phosphatic slurry daily from the Rhodia site in Oldbury. Historically the Northern section of the site formed part of the Rattlechain Brickworks, with the Groveland colliery and associated brick pit in the West.”
At page 3 paragraph 1 1.2 Introduction “Installation Details.”
“Historically a variety of waste types were deposited, including chemical drums containing phosphatic muds. It is thought that some drums containing wastes with up to 1% phosphorus, may have been dumped annually until 1995. The historical disposal of solid material such as chemical waste and scrap machinery has also been reported. URS 2002.”
On page 4 At 2.1 The development of the Installation 2.1.1Historical development
“Following the demise of the brick industry, many of the local quaries were used as waste disposal sites, including the site itself, which became a waste lagoon receiving phosphatic waste since the 1940’s.
Given the statement “The site has operated as a waste lagoon since the 1940’s”, this puts into some dispute the idea that this site was a dry pit until Albright and Wilson turned up and started to dump their own factory waste and not the Ministry of Supply wastes of war already referred to.
Such vagueness as “chemical waste” is not made any easier to understand by the reluctance of Rhodia to put the report referred to “Restoration options for the Rattlechain Sludge Lagoon URS 2002” in the public domain. They have been asked to do so by Swanwatch and have failed to respond to the email in writing. They have also not shown the document to The Environment Agency who have confirmed so in a Freedom of Information Request.
The URS Site Stability Risk Assessment phase 1 of the lagoon under “1.2 Site description and history” pages 4/5 at paragraph 7 states;
“Prior to 1948, the site was used as a clay pit and brickworks. In 1948 the site was purchased by Albright and Wilson (A&W) and has been used for the storage of the waste calcium phosphate.”
It continues “The waste is considered to comprise predominantly of inert calcium phosphate, however historically some elemental phosphorus was also present. To reduce the potential for a reaction between the phosphorus and the air, the waste is stored under water. This reduces the potential for the release of toxic fumes.
Anecdotal evidence also suggests the potential presence of drums of chemicals, contaminated brickwork and scrap machinery.”
On pages 13 of the same document 1.4.5, there is some slight expansion.
“It is understood that Albright & Wilson originally purchased the site in 1948 for the disposal of chemical waste resulting from the manufacture of phosphate. The principal waste stream was calcium phosphate containing small nodules of elemental phosphorus. However additional chemical wastes may have also comprised a selection of acids, including sulphuric, hydrochloric and fluorosilicic.
Anecdotal evidence also indicates the disposal of chemical drums containing phosphatic muds, possibly containing elemental phosphorus. It has been estimated that 100 drums per annum were disposed of into the lagoon, ceasing around 1995 (URS ‘Options Study Restoration of the Rattlechain Lagoon’, 2002). In addition to the drums of chemicals it is our understanding that some phosphorus and acid contaminated brickwork, and scrap machinery has also been disposed of in the lagoon.
At 1.4.6 page 14 “Capping system model”
“The presence of some elemental phosphorus in the waste makes it necessary to avoid the contact of the waste with air, as this may result in a chemical reaction accompanied by the release of toxic fumes.”
This range of concentrated acids were not tested for by Cramer and Warner, though they did report high concentrations of Fluorosilcic acid. For some reason Albright and Wilson did not disclose this information to Cramer and Warner, so why did Rhodia disclose this to URS, and yet fail to disclose it in other subsequent reports that they have put in the public domain?
In another URS report “Rattlechain Lagoon Bird Management Plan” page 3
“2.2 Waste disposal history” paragraph 1 and 2 states
“Albright & Wilson originally purchased the site in 1948 for the disposal of chemical waste. Anecdotal evidence also indicates the disposal of chemical drums containing phosphatic muds, possibly containing elemental phosphorus. It was estimated that 100 drums per annum were disposed of into the lagoon, ceasing around 1995. Reports also included the disposal of approximately 500 tonnes of phosphorus contaminated brickwork and 1000 gallons of sulphur and phosphorus mixtures’ a year, the exact nature of which are unknown. Historically, phosphatic sludges were transported as slurry to the lagoon via narrow boat on the adjacent canal. Liquid wastes were transported as slurry to the laggon using the pipework located on the Northern embankment. The disposal of solid waste including drums of chemical waste and scrap machinery has also been reported. It is assumed much of the solid waste was tipped into the lagoon from the northern and southern embankments.”
Up until 2005, disposal of calcium phosphate was by road tanker with up to loads per day (20m3/load) deposited into the lagoon. The waste typically comprised of 2-5% solids combined in an aqueous medium to aid pumping.”
A more recent site investigation to which Rhodia have so far refused to supply any further information concerning the sediment was again conducted by URS and a sub contractor Lankelma, embarrassingly for Rhodia it sheds new light on what the company were actually paying URS to do and summarises in a way that cannot be bettered- the actual truth behind the spin. Following this link now reveals that this article has been withdrawn and a blank space is in its place “article withdrawn.” So why is this then? Rather suspicious we feel. We think it was a good article, so here it is in full CLICK BELOW.