DODGY REGULATION
In this post I wanted to look and delve more closely into Sandwell council’s “regulation” of this site whilst it was still being used to deposit waste and subsequently after waste had ceased to be delivered to the site.
A reminder of the key dates concerning this site, as held and publicly published by The Environment Agency is shown below.
The original licence SL32 was passed by The West Midlands County Council on 4/6/1978.
There is a curious and so far unexplained “modification” of this licence which is referred to which occurred on 7th August 1979. I have not been able to find out what this is, or how it impacted on the licence, and Sandwell council did not supply it with the FOI request which is rather strange.
West Midlands County Council were dissolved in 1986, with responsibility then being taken on by local authorities.
The first modification made under Sandwell council control is undated, and also unsigned, which is also highly unusual, unless that is, it was supplied with a deliberately redacted document.
No name or date.
This changed the boundaries of the site as follows, which also means that waste outside of this boundary, tipped before licensing, and after licensing could contain toxic waste outside of this current boundary- i.e the site that Solvay claim to be remediating. This means that there has been no assessment, at least by them of surrounding land since this licence was supposedly surrendered.
The council claimed that the original plan was not held, but here it is for comparison.
As appearing on planning application DC/5064
The original boundary to the sports field is shown, and also reference to the new A&W concrete boundary fence.
The second modification does not even refer to this amendment, which is also bizarre, as though the council had forgotten or deliberately avoided even mentioning the realigned boundary with their own land!
This was passed on 25th January 1990, and added three licence conditions to the licence 37-39. In context, the last supposed deposit of waste according to the EA, (and under SMBC regulatory control) occurred after this on 31/3/1990, (see above table).
Condition 36 imposed landfill gas monitoring within three months of the issue date.
Of course, tipping apparently ceased on the site within this timeframe.
Condition 37 appears to be entirely dependent on the results of condition 36, and it is highly questionable therefore if these were even supplied to SMBC, who claim they don’t hold any, which is either bullshit, or the idiot who amended this licence did not bank on Albright and Wilson ceasing to tip at the site.
Condition 38 appears to cover such a scenario, calling on ceasing of waste tipping if no design for monitoring had been given within six months. Albright and Wilson however appear to have bypassed this by stopping tipping anyway, so was any monitoring scheme for landfill gas ever conducted by them at the site? If so , why do SMBC claim to not have any info on the scheme which they imposed?
Landfill gas and types of gases were not identified very well in this modification, and should have mentioned hydrogen sulphide, as well as phosphine. Were these ever monitored for, as it seems unlikely?
A further condition 40 was added on 29/11/91 for the 1st December 1991, and was the standard hazardous waste board, which appears to have been rolled out across all the current hazardous waste area sites and required the licence number.
Some three years later on 19/4/94, the licence was apparently surrendered, but no surrender notice appears to exist according to SMBC, which is also bullshit.
Sandwell council clearly have some questions to answer about the circumstances of monitoring for landfill gas from this site, and why they do not claim to hold any records, when it was their legal duty to do so?
DODGY NEW PONDS
I don’t believe the creation of these pools has anything to do with collecting surface water.
The waste dumping history of Albright and Wilson reveals that they used this site allegedly from 1938 , and as we know Rattlechain “since 1942”.
The other known canal side site at The Netherton Branch appears to have been used around the start of the 1920’s, which means that there is another site somewhere between the wars that this company were using for phosphorus contaminated waste.
Though no phosphorus wastes were allowed after licensing, we simply do not know if any went into the Gower Tip at any point, and the fact that the site appears to have been in the footprint of a flooded former marl hole, strengthens the prospect that it was used for this purpose.
The pool is within the Gower Tip area in 1946.
There is an account in the book “Making and Moving in Langley” recalling waste being dredged from collection of the Albright and Wilson Canal arm, and into The G0wer Tip using “tubs” and then a pump.
This obviously raises questions as to what was buried when the water at this site disappeared, and when exactly this took place? “Attenuation ponds” would come in very handy converting phosphorus waste into breakdown products if exposed to air, particularly if the site was to be capped afterwards, thus highly likely to generate phosphine gas. There is reference to testing for phosphine gas at the site, but no explanation as to why this was being carried out given the supposed claimed wastes tipped there under the licence. They do not mention elemental phosphorus.
Maybe the effort to raise the site levels is what this “remediation” is really about. Just don’t try to hoodwink the public with nonsensical pointless schemes when the method implies something more insidious.