21/6/11
Environment Agency,
Permitting Support Centre,
Environment Permit Team,
Quadrant 2,
99 Parkway Avenue,
Sheffield
S9 4WF.
psc@environment-agency.gov.uk
Re: Viridor’s Environmental Permit application for landfill of non-hazardous waste at New England
Quarry, Lee Mill, Devon. ref EPR/PP3133FC/A001
Response by South Hams Friends of the Earth
Dear sir/madam,
South Hams Friends of the Earth believes that the Environmental Permit for landfill at New England
Quarry should be refused because the environmental impact on the surrounding area and beyond
would be unacceptable; the waste source and waste composition cannot be clearly identified which
has serious implications for the assumptions made in this permit application; there is inadequate
consideration in this permit application relating to emissions, especially emissions related to landfill
gas flaring and landfill leachate.
1. The surrounding area:
1.1 The application states that there are no European or International statutory nature conservation
sits within a 2km radius which would be affected by the creation of a landfill site. This is a
ridiculously small area to consider when the some of the detrimental effects are airborne; Natural
England for example recommends a 15km radius be considered for significant developments.
However, under the Habitats Directive, location for landfill sites is relevant and the number of
nationally and locally significant sites within a 5km radius should be taken into account and a
precautionary approach adopted.
1.2 The New England Quarry site has the River Yealm running through it which could be
compromised by leachate and surface water runoff. The estuary of the River Yealm is an SSSI
which flows into the Plymouth Sound SAC. The River Yealm already has licensed discharges into it
and is already classified as under stress. Further discharges, especially accidental or unintended
discharge (such as leachate from the landfill, dust from construction, HGVs or waste, air pollution
from the incinerator), could adversely affect the river quality and ultimately the marine environment.
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1.3 The New England Quarry site contains Ancient Woodland part of which will be destroyed by the
access road which will be built to serve the proposed incinerator and landfill site. Ancient Woodland
is as the name implies. It cannot be recreated and must be protected.
1.4 The New England Quarry void itself is a Regionally Important Geological and Geomorphological
site as well as being a foraging and roosting site for nine different species of bat and forms a
significant part of a wildlife corridor which follows the River Yealm to Dartmoor.
1.5 The South Hams Area of Outstanding Natural Beauty is 2.3 km from the site.
1.6 Dartmoor National Park SAC which contains several SSSIs is 3.6 km from the site.
1.7 The Erme estuary SSSIs are 4km from the site.
1.8 The Yealm estuary SSSIs are 4.6 km from the site.
1.9 The Plymouth Sound and Estuaries SAC is 7km from the site.
1.10 The population of Lee Mill is less than I km from the site and Ivybridge is just over 3km from
the site.
1.11 There will be a negative cumulative effect on local people and on internationally, nationally and
regionally important wildlife and nature conservation sites from:
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the existing A38 trunk road, less than 1km from the site,
the New England Quarry EfW Incinerator (should it receive planning permission and an
Environmental Permit),
Hemerdon Quarry,
the Langage Power Plant and
the proposed Plymouth Devonport North Yard EfW Incinerator
These are in addition to this landfill site and all within a 10km radius.
2. Waste Sources:
2.1 The South West Devon Waste Partnership, which covers the unitary authorities of Torbay,
Plymouth and the District Councils of South Hams, Teignbridge and West Devon, awarded the PFI
contract for waste disposal to MVV Environment Devonport and not to Viridor. Viridor’s application
for its EfW Incinerator and landfill sites have been based on receiving 270,000 tonnes per annum of
residual municipal solid waste. The fact that they did not get the waste contract means that they will
not be processing the waste arising from the SWDWP area. This raises questions about the source
and composition of the waste they intend to incinerate and landfill.
2.2 Viridor states in the Landfill Design Report, section 2.1:
“It is anticipated that the landfill will accept approximately 33,000 tpa of waste. Given the nature of
the wastes, a density of 1 tonne per cubic metre has been assumed, on this basis, the landfill void is
anticipated to be used at a rate of 33,000m3 per annum”
Given that they do not know where the waste will come from, or what its constitution will be,
assumptions about the nature of the wastes cannot be justified. Household waste and commercial
and industrial waste have different compositions, different calorific values and will result in different
amounts of material being unsuitable for incineration which will be destined for landfill. The
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proportion and weight of biodegradable materials cannot be assessed if the source is not identified.
Viridor says that the nature of materials landfilled is unlikely to generate significant amounts of
methane, but there is no evidence to support this.
2.3 Recycling typically removes waste with high calorific values from the waste stream. In 2009/10
household recycling rates in the SWDWP area of Devon were 52.51%, in Plymouth 31.04% and in
Torbay 35.7%. Defra’s 2010 Commercial and Industrial waste survey in December 2010 found that
in Devon (this is the whole of Devon and not just the SWDWP area) 470,000 tonnes of C&I waste
was generated and 57% is currently recycled. Viridor’s figures for C&I waste arisings, in their
Revised Planning Supporting Statement, refer to 1,132,000 tonnes of C&I waste for Devon:
considerably higher than 470,000 tonnes for the SWDWP area alone and Viridor’s figures are not
based on Defra’s most recent (2010) statistics. It is therefore doubtful whether there is enough high
calorific waste to fuel all the EfW incinerators currently proposed for Devon.
2.4 It is probable that the landfilled waste will constitute a greater proportion of the collected waste
as recycling rates increase and waste is increasingly unsuitable for EfW use.
2.5 The landfill application is for 33,000tpa of waste with a potential for accepting 60,000tpa of
waste. This is almost double, presumably because the more high calorific value waste that is
removed, the less there is to incinerate the less efficient the EfW process becomes and the more
waste is landfilled. This means that the application is not for a landfill of 970,000 tonnes, but for a
landfill of potentially 1.8 million tonnes. This is unacceptable.
2.6 In the permit application the waste operation 2b2 is categorised as “use of waste in
construction”. There seems to be some confusion about this as Viridor states in the Non-Technical
Summary that: ”The landfill will accept rejects from the EfW facility and any IBA that cannot be
recovered, as well as all wastes destined for the EfW in the instance that both lines are closed for
maintenance”.
According to the EfW incinerator Revised Planning Application R19 responses, we are told that “Unprocessable” wastes (R19.99/4) includes things like mattresses, large animal carcases, inert wastes
and malodourous wastes which will go to landfill. The response to question R19.99 point 1 says:
“Unburnt waste will be directed to the landfill either as a result of rejects from incoming waste or
during plant shutdown periods.”
This is not inert waste. It will give off greenhouse gases and it will smell.
3. Emissions:
3.1 The New England Quarry site is in an environmentally sensitive area. The already stressed
River Yealm runs through the site and the Dartmoor SAC which is at critical levels for acid
deposition is close by. The cumulative effect of this incinerator and landfill gas emissions to air are
unknown. Taking into consideration the other proposed threats to people and the environment – i.e.
the Langage power plant, Hemerdon Quarry, the A38, The Devonport EfW incinerator – the risks
are considerable and have not been modelled.
3.2 The Landfill Gas Risk Assessment gives a waste breakdown for the landfill which refers to
20,000tpa of domestic waste, 4,500tpa of IBA and 4250tpa each of commercial and industrial
waste. These figures have no base in reality, because the entire NEQ application has been
predicated on treating the MSW of the SWDWP which they will not be treating because they were
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not awarded the contract. Consequently the entire Landfill Gas Risk Assessment has no credible
evidence base and is worthless.
3.3 The landfill gas management plan is non-existent because Viridor maintains that there will be no
landfill gases even though the source of the waste they will be treating and its biodegradable
content is unknown.
3.4 There is no proposal to capture landfill gas and Viridor’s solution is to flare it. Landfill gas flares
emit volatile organic compounds as carbon as well as Nitrogen dioxide, sulphur dioxide, benzene
and particulates. It is a noisy process and can have a detrimental visual impact. There is no
information about this in the planning application and little in the EP application.
3.5 The flow and composition of the input gas needs to be monitored especially as the portion of the
biodegradable waste in this case is unknown. There is little information about this in the application.
3.6 The danger of explosions especially inside buildings where landfill gas might accumulate is
significant. Landfill gas continues to be generated for hundreds of years. None of these things have
been considered as there is no landfill gas management plan.
3.7 The landfill gas control hierarchy puts power generation at the top, above gas flaring, and this
should be the case with NEQ.
3.8 Other emissions to air which have not been fully considered include: dust from lorries and from
waste; noise from lorries and landfill gas flaring; and smells from waste, landfill gases and vehicle
fumes. Because the origin and type of waste is not known these things cannot be accurately
modelled.
4 Leachate:
4.1 The NEQ site is classified as a minor aquifer and the groundwater in the quarry is in hydraulic
continuity with the river Yealm which means that some of the groundwater enters the river. At any
time during construction contaminated water from the landfill cells could discharge into the river
Yealm.
4.2 Viridor claims there is a market for IBA, but this has yet to be demonstrated especially as the
landfill has been designed to accept IBA. The pollutants in IBA are many and significant including
chloride, cadmium, lead, mercury and zinc compounds. After the weathering process, IBA will be
landfilled. Landfilling is for ever. These toxins will last for ever. Will the landfill liners last forever?
Putting dangerous waste into a big hole near a stressed river is environmentally irresponsible.
4.3 Any compromising of the landfill liners over the years the landfill is operational and beyond will
result in discharge into the River Yealm running through the site.
4.2 Leachate from waste unsuitable for incineration could be anything as the composition of the
waste stream is unknown. It could include toluene, xylene, naphthalene. Again this could leach into
the ground or river.
4.3 Water from the landfill cells will be discharged into attenuation ponds. This process creates a
risk of flooding into the river Yealm and its tributaries running along the northern edge of the site
and to the east of the site.
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4. 4 Leachate will be pumped into a leachate storage tank and will be tankered off site for treatment.
There is not enough information about this storage tank and the attendant risks.
4.5 Surface water runoff, especially in the light of increased rainfall due to climate change, could be
significant, could contribute to flooding and could contain pollutants from waste, lorries, dust and
vermin. Surface water run off could end up anywhere, but probably in the river Yealm.
5. Conclusion:
5.1 This landfill site is necessary because of the proposed incinerator. It is there to take IBA, a byproduct of incineration, and wastes unsuitable for incineration. Incineration creates toxic emissions
to air, and ultimately to land and water.
5.2 Waste incineration is an outmoded, climate damaging technology. It is far better environmentally
to increase recycling rates and use a combination of Mechanical Biological treatments and
Anaerobic Digestion for residual waste. That which would be landfilled at the end of this process is
less harmful than that which would be landfilled at the end of the incineration process.
5.3 Defra’s 2007 Waste Strategy has moved away from incineration as a preferred method of waste
disposal. The waste hierarchy outlined in PPS10 places incineration low on the priorities list. To
build new incinerators which lock councils into 25 year contracts when recycling rates are steadily
rising is extremely short sighted.
5.4 You are the Environment Agency. Care for our environment. Refuse an Environmental Permit
and give the community and the environment a fighting chance.
Kate Wilson
South Hams FoE
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