Response 673765803

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Seeking your views

4. Please provide your comments on the environmental permit application received from Veolia ES Landfill Limited

Please provide your comments on the environmental permit application received from Willen Biogas Ltd (Required)
The site accepts hazardous soil above 30,000t/yr which exceeds the thresholds as nationally significant infrastructure in the hazardous waste sector are set out in the Planning Act. I cannot find evidence that the site has the correct planning consent as nationally significant infrastructure for hazardous waste treatment above 30,000t/yr. The 15% addition rates of compost to hazardous soil is far in excess of the levels required as a organic agent to stimulate biotreatment of soils by a competent specialist. This is merely dilution of hazardous waste. The result of this dilution means that Veolia could obtain analysis samples for the mixed waste that suggest the soil is non-hazardous, when in fact the waste is still a mixture of non-hazardous compost and hazardous soil. If the 15% addition rates are permitted then the criteria for non-hazardous soil should be reduced by 15% to ensure that the soils in the mixed waste are non-hazardous. If this is not implemented then Veolia will be disposing of hazardous waste in their restoration scheme with full approval of the Environment Agency. There are inconsistencies between describing 50,000t/yr in some documents and 40,000t/yr elsewhere. All these annual capacity figures are above 30,000t/yr threshold as per the NPS thresholds for nationally significant infrastructure. This threshold is described in Section 1.2.1 in the attached document.