Manywells Landfill:determination, management &
communication
Ann BarkerLead Officer Contaminated Land
Structure of presentation• Part IIA reminder• Location and background• Initial negotiations• Assessment actions• Determination• Part IIA issues post-determination• Resources Interaction with E.A. • Technical challenges• Leachate, temperature and gas• Community confidence and communications• Conclusion and recommendations
Part IIA: Reminder• Backstop! • Only to be used where other regimes are not
applicable• Requires viable potential or actual significant
pollutant linkage• Based on risk assessment• Forensics - the polluter pays – search for
appropriate persons
Manywells: location
1994: A new waste disposal landfill site is born, formed from a disused sandstone quarry in Cullingworth
Photo-montage by local resident
Commissioned and operated as a licensed waste disposal site 1994 to 2001
Photo-montage by local resident
Site operator, Wastepoint Ltd, went bankrupt in 2001, deserting the site
Manywells became an “orphan” site
Site overfilled by approx 90,000 cubic metres
Uncontained leachate seeping to surface
The first view…Waste mass towers over surrounding land levels
Unstable gradients
Landfill gas migration onto public bridleway and into woods
Exposed waste seen from bridle path
Background• Operational waste management issues
– Odour– Flies
• January 2002– Contact from Minerals & Waste planners & E.A.– Site leachate not controlled– Multi-Agency meeting– Joint site visit– Huge public concern, political pressure to resolve
• January 2003– Site determination
Initial negotiations : Legal situation January 2002
• NOTE: Early days in Part IIA implementation!• Site owner/operator bankrupt – therefore does not legally
exist• Property inc. waste management licence held by liquidators• Then disclaimed as ‘onerous property’ under Insolvency
Act• Ownership of site reverted to Crown• Escrow fund (for restoration) tied to licence (E.A./site
owner)• Planning – nothing to be achieved by enforcement – query
re. Crown liabilities• Power generation company on site
Initial negotiations: Implications January 2002
• Waste Management legislation not applicable
• Part IIA action recommended by E.A. re. controlled waters – potential Special site?
• BUT - “Inspection Strategy for Contaminated Land in the Bradford District” Dec. 2001 – identified inspection priorities…
Inspection Strategy: Site Specific Priority Factors
Initial Negotiations: 2002• Legal Counsel’s opinion – non-determination
defensible where no significant pollutant linkage identified
• But if E.A. stopped pumping leachate then SPL could occur…?
• Therefore Assessment actions continued
Leachate migration
Groundwater: Potential migration pathway via compromised landfill liner
Cross Section
Waste deposits
Main clay liner
Leachate detection layer
Leachate saturated waste deposits
Leac
hate
det
ectio
n ch
ambe
rLeachate ingress to LDC
Rough Rock Flags (Bedrock & Minor Aquifer)
Site review: Controlled Waters• Source/Contaminants
– Leachate breakout on edges of site with run-off over surface across industrial estate
– Groundwater – leachate migration potential via compromised main liner
• Potential pollutant linkages & receptors:– Surface water – via drainage systems via
sewerage to Manywells Beck– Groundwater – E.A. Landsim modelling
Controlled Waters: significance?• Surface water – leachate from breakout diluted on
site and during run-off – no significant pollutant linkage
• Groundwater – potential pathway due to percolation of leachate via thin basal clay liner – potential significant pollutant linkage
• Note – NO proven significant pollutant linkages
Assessment Actions• Conceptual site model (CSM) drafted in-
house– No proven significant pollutant linkages
identified – No risk to human health identified
• Determination based on controlled waters resisted
Conceptual Site Model: a starting point
Assessment Actions: Landfill Gas• BUT concern about landfill gas identified• IMC consultants - commissioned to review and
report on potential risks from landfill and mine gases
• Potential threat to human health – potential gas migration through fractures in the rocks into– Woodland areas used for informal play by children
(including dens)– Hollows in field where livestock shelter in poor
weather conditions
Den Making in woodland
Part IIA & Manywells – key points• Other regimes?
– Waste management regime – failed
– Planning regime – failed
• Viable significant pollutant linkages?
– Surface water - pathway to Manywells Beck – not ‘significant’ due to leachate dilution before leaving site
– Groundwater - pathway – potentially ‘significant’ over time
– Landfill gas – potentially ‘significant’ low likelihood but extreme impact on human health possible in certain conditions
Determination process
• Note: Not many examples of determination documents available in 2002
• Collation of evidence to confirm SPL• Basic Risk Assessment• Map/plan • Format/Layout
= Determination document
Determination Document: Page 1
Determination Document: SLP1
Determination Document: SPL2
Determination Document: Gas risk assessment
• “Therefore the Council has concluded that the proven presence of landfill gas in the ground surrounding the site, the identification of potential pathways and the presence of identified receptors are sufficient to conclude that there is a significant possibility of significant harm being caused.”
Gas concentrations• Methane up to:
– 58%v/v in borehole outside site boundary
– 14% v/v in dry-stone wall adjacent to boundary
– 8%v/v in pinholes in hollows in field
• Carbon dioxide up to:– 42%v/v borehole outside site boundary– 24%v/v in dry-stone wall adjacent to
boundary– 30%v/v in pinholes in hollows in field
Determination Document: Groundwater Risk Assessment
• “Therefore the Council has concluded that:– the proven presence of landfill leachate in the leachate
detection layer below the basal liner,
– the modelled permeability of the secondary liner which may provide a pathway to groundwater, and,
– the presence of groundwater beneath the site and of a licenced abstraction point, Manywells Spring, are sufficient to conclude that this land is in such a condition by reason of substances, in, on or under the land that pollution of controlled waters is likely to be caused.”
Determination Document: Map
Part IIA: Post determination issues• Initial remediation solution – removal of
98K tonnes material from site – practical issues
• ‘Project management’ – with PCO/EHO & EHM (not key area of expertise)
• E.A. still involved in site pumping leachate therefore division of responsibilities
Part IIA: Post determination issues
• Neighbouring land owners
• Power generation company
• Escrow fund - E.A. High Court action
• Negotiations with Crown
• Site ownership issues
Resources: SCA / SCE(R) / CLCP2002/2003 Intrusive Investigation - landfill gas/leachate £15,000
2003-2004 Remediation – landfill gas/leachate, interim SPL management
£128,000
2004-2005 Urgent works to comply with H&S. Consultancy on remedial options
£144,000
2005-2006 Remediation – gas/leachate, interim SPL management
£188,000
2006/2007 Remediation – gas/leachate. Interim SPL management etc.
£637,000
2007/2008 Remediation – MWH on project team. Solution developed. Temp cap & large boreholes
£465,000
2008/2009 Remediation – Modelling and final design works, access road planning application
£381,000
2009/2010 &
2010/2011
Bid - not including ‘ineligible costs’. £2,000,000
Interaction with E.A.• Waste management licence – disclaimed• Local E.A. waste management and Part IIA
officers involved in discussions from start• Special site status investigated• National Capital Programme assessor involved
from early in project• Ongoing contact and meetings with assessors
The Technical Challenge 1: original option
Proposal:-
Remove 90,000 m3 of material
= 22,000 Wagon movements
Issues:-• Sustainability• Environmental Considerations• Cost• Short term fix solution?
RISK and Where would it go?
Technical Challenge 2:
Control required for:
• Leachate• Landfill Gas• Stability
RISK
Technical Challenge 3: what were real problems?
Significant Pollutant Linkages (SPLs)• What?• Where?• Why?
SAFE site. HSE Involvement
REQUIRED CLEARER DEFINITION OF THE PROBLEM TO INFORM THE SOLUTION
2006 WORK
Leachate Containment – drains, manholes, pumping
Landfill Gas – flare, pipe network
Site Investigation– 6 boreholes along spine of tip
Security and SafetyAssessment, Signing, Fencing and Control
Landfill Closure
Landfill Processes
Processes at Manywells
Project team and project development• Early 2007 project team expanded• Office of Government Commerce (OGC)
Environmental Advice and Services shortlist• Expression of Interest• Supplier Day• Tender and Tender Evaluation Quality and Price• Appointment of MWH
• Partnering – establishment of 6 working groups
Manywells Landfill Remediation Project
Our aim is…
‘To deliver a safe and sustainable solution with an acceptable landform to a timescale which is minimally disruptive to local communities’.
… by using good project management and effective communications
Interim Works 2007/08
• AIM – induce settlement through
– Control of leachate
– Generation of landfill gas
• Site works October 07 – May 08
• Value £594k
Interim Works 2007/08• Site investigation - locate liner and leachate leaks• Temporary clay cap - reduce water ingress• Vertical drains - promote drainage of waste mass
and improve gas production.• Improve collection and control of landfill gas • Formalise leachate drainage• Increased Defra funding allowed some reshaping
and deep drainage trenches
What we achieved 2008- Pumped Leachate Volumes
Monthly average
April 2007 to March 2008 258m3
April 2008 to Dec 2008 470m3
December 2008 431m3
January 09 (some frozen time) 420m3
June 09 275m3
Waste Mass Temperature
Borehole locations
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Gas concentrations• Boreholes outside site
– Some reduction in gas concentrations due to rebalancing of gas field, new flare etc
– Further improvement expected when new infrastructure installed and more gas drawn away from perimeter
• Boreholes on site– Increase in gas concentrations and volumes as waste dries
out and methano-genesis restarts– New flare requires energy input to ensure operation– Still monitoring effects of site works– Long term gas production unknown– Power generation potential under review but power
generation infrastructure may not be viable
The Plan Key Works• Redistribution of the waste mass to provide stable slopes
and an acceptable landform• Tying the existing liner to a new clay cap• Infrastructure – Leachate ‘dirty’ water under cap +
pumping• Infrastructure – Gas wells, heads, pipework and flare• Infrastructure – ‘Clean’ water system above cap• Soils and planting. Key to success of remediation and the
restoration of the site
Community Confidence in L.A.
2002 2003 2004 2005 2006 2007 2008
Community meetings
with consultants
MCWG set up
LO
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HIG
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2009
Communications activity• Communications with ward councillors• Members bulletin items• Neighbourhood Forum meetings• Community Newsletters since July 2006• Webpages – www.bradford.gov.uk/manywells • Manywells Community Working Group- 5
meetings since Oct. 07• Communications Strategy- April 2008
Community Working Groupsite visit
Community Newsletter
Posters
Communications Strategy
Part IIA: Communications Summary• Establish good communications early – it takes
some time but saves a lot more in the long run
• Get key contacts in community involved
• Tell the community what is going on even when nothing seems to be happening on the site
• Note – significant resource implications if done right – not eligible costs for CLCP
Brownfield Briefing Award: Best communcations/stakeholder engagement
Brownfield Briefing Award:Manywells Community Working Group
Manywells & Part IIA
TO CONCLUDE…!
Part IIA: Landfill Site Determination• Recommendations:
– Part IIA is a last resort – do not go there unless you have no options!
– Ensure you get good legal advice– Check Land Registry - ensure defensible
boundary line around the determined area– If orphan site
• Separate regulatory role from project manager role
• Project management skills are essential
Site remediation: practical points• Flexibility• Circumstances change, • There is more than one right answer, • Control and manage expectations of rapid action • Bring in additional expertise where necessary• Funding issues – not just CLCP• Risk associated with regulatory action• Landfill sites are organic beings – no two are the
same!
Every site needs ‘hands-on’ management