Cottonmount Landfill Stable Non Reactive (SNR) Asbestos Cell Volume 2 NON TECHNICAL SUMMARY December 2012 SLR Ref: 419.00034.00473
INTRODUCTION 1. This Non Technical Summary (NTS) has been produced by SLR Consulting Limited (SLR) on behalf of Biffa Waste Services Limited (the applicant) as a separate document to accompany the planning submission, being a mandatory part of the Planning Application & Environmental Statement (PA&ES). 2. The NTS is part of a package of documents being submitted to DOE Planning in support of a planning application in respect of land at Cottonmount Landfill, Mallusk. 3. The planning application is for a Stable Non-Reactive (SNR) cell within the confines of the existing landfill development area at Cottonmount Landfill, Mallusk, Newtownabbey. The nature of the planning application is such that it falls within the scope of The Planning (Environmental Impact Assessment) Regulations (Northern Ireland) 2012, however the hazardous waste in this case is limited to asbestos and wastes contaminated with asbestos only. It does not therefore mean that a new hazardous waste landfill site is being developed. Previously, asbestos waste could be landfilled with general waste but under current legislation it must handled separately and placed in a separately engineered cell which is what is proposed in this application. 4. The Stable Non-Reactive cell within the existing licensed non hazardous Cottonmount landfill will be capable of accepting asbestos waste and waste contaminated with asbestos. This Stable Non Reactive (SNR) cell will be similar to their existing facilities which Biffa successfully manage at Redhill (Surrey) and Eye (Peterborough) in the UK and other similar facilities which they have operated previously on other sites in Hertfordshire, Leeds, Warwickshire and elsewhere. Biffa therefore have considerable experience in successfully managing this type of material. APPLICATION SUBMISSION PACKAGE 5. This summary comprises Volume 2 of a multi volume submission to accompany the planning application. In addition to the formal planning application forms and certificates, the full submission comprises: Volume 1: Planning Application & Environmental Statement (PA&ES); and Volume 2: Non Technical Summary (NTS). 6. The PA&ES supports the planning application and considers the proposal in the context of relevant local planning policies and includes an assessment of environmental effects of the proposed development by setting out the results of the Environmental Impact Assessment (EIA). It is intended to provide DOE Planning with sufficient information to determine the planning application having due regard to the protection of the local amenity and the environment as a whole. Cottonmount SNR Vol 2 P a g e 1 SLR Consulting Limited
7. This NTS provides, in non-technical language, a brief summary of the proposals and the likely significant effects that the proposed development would have on the environment. THE APPLICANT 8. Biffa was founded over 100 years ago by the Biffa family as a haulage business. Today, Biffa is the UK's leading nationwide integrated waste management business that provides collection, treatment, recycling and technologically-driven energy generation services. Biffa provide an essential service to satisfy the business needs of their commercial, industrial and public sector customers throughout the UK and help them to meet their legal obligations and corporate responsibility commitments. Through the expertise of their people and investment in technology they promote and deliver sustainable waste management solutions with a focus on treating and utilising waste as a resource. 9. In 2010/11 Biffa handled over 13.6 million tonnes of waste and handled or collected for recycling over 2.1 million tonnes of waste. It has the largest Commercial and Industrial waste collection network in the UK, with more than 60 depots nationwide, over 1,300 collection vehicles and the most advanced route planning and optimisation systems in use in the sector. They also collect waste from nearly 2 million households through the UK. 10. Further information on Biffa can be found on their website at www.biffa.co.uk. THE SITE 11. The development site for the SNR cell is located within the footprint of the existing quarry and landfill complex that covers a total area of 56 hectares within the district of Newtownabbey Borough Council. 12. Cottonmount Landfill lies approximately 15 km to the north-west of Belfast City Centre. From the direction of Belfast, Cottonmount Landfill is accessed via Junction 4 of the M2 motorway which runs approximately 3 km to the east of the site. The motorway runs generally parallel to Mallusk Road some 1 km to the north east. Direct access to the site is achieved from an existing well established access via the B95 Glengormley to Mallusk Road which runs parallel to the site. Cottonmount SNR Vol 2 P a g e 2 SLR Consulting Limited
Figure 1 Site Location within Cottonmount Landfill 13. The area in the vicinity of the proposed development site is characterised by generally rural land-uses and landscape to the south, west and north. To the south east lies the village of Mallusk, beyond which is the Mallusk Industrial Estate that extends to some 1,500 hectares of industrial and commercial development, located approximately 1.3 km east of the site. 14. The proposed SNR cell at Cottonmount Landfill will be located within the currently permitted area which is under Biffa s control for the existing nonhazardous landfill site at Cottonmount. The landfill site is regulated under PPC Cottonmount SNR Vol 2 P a g e 3 SLR Consulting Limited
Permit Variation Number P0090/05A/V1 issued in 2008 by the Northern Ireland Environment Agency (NIEA). 15. Section 2 within the PA&ES (Volume 1) provides further information on the application site. THE PROPOSED DEVELOPMENT 16. To enable the applicant to maintain flexibility in the final design and layout, and to allow the SNR cell to be incorporated into the developing landfill, a floating cell design has been identified as the most appropriate solution to the location of the SNR cell at Cottonmount. The intended proposed development area for the SNR will be located within a restricted isolated area in the south-western corner of the site within the existing licensed site boundary. The proposed SNR cell will be located within the application area however the final design will not be fixed under pre construction; this approach is typical of cells of this nature within operational landfills and has been successfully adopted by Biffa at their similar facilities in England. 17. The proposals are to develop a separate engineered cell within the confines of the consented landfill area, to be able to accept asbestos waste and waste containing asbestos. As this cell is specifically for asbestos waste it does not change the classification of the site as a whole as a non-hazardous site. The remainder of the landfill site will continue to accept non hazardous waste which does not include asbestos. 18. The Landfill Site is currently permitted to accept 325,000 tonnes per annum of non-hazardous waste and 75,000 tonnes per annum of inert wastes. These proposals will not increase the overall inputs to the site or increase the utilized void space at the site. The proposal will simply enable the applicant to use allocated non hazardous void space for stable non reactive (SNR) waste. The general operations of the landfill will remain unchanged. 19. SLR Consulting have submitted a PPC permit variation application to include the operation of the SNR cell as a disposal activity at the existing landfill. The PPC permit variation application will detail how Biffa will accept and dispose waste without causing significant harm to the environment (water, air and land) or human health. 20. The proposed operating hours would be the same as currently existing for the landfill site. The development proposal would not impact upon the approved restoration scheme for the landfill site. 21. As previously stated, this Stable Non Reactive (SNR) cell will be similar to existing facilities which Biffa successfully manage at Redhill (Surrey) and Eye (Peterborough) in the UK and other similar facilities they have operated. Biffa therefore have considerable experience in successfully managing this type of material. Cottonmount SNR Vol 2 P a g e 4 SLR Consulting Limited
22. A full description of the proposed development is included in Section 3 of the PA&ES (Volume 1). Figure 2 Proposed SNR Cell Layout Cottonmount SNR Vol 2 P a g e 5 SLR Consulting Limited
PLANNING POLICY 23. The Government is committed to a plan led system, with the Development Plan forming the basis of all planning decisions. Legislation confers a presumption in favour of development proposals which accord with the Development Plan, unless material considerations indicate otherwise. The planning application will therefore be determined in accordance with prevailing policies at national and local level. 24. Through the application process, it has been able to demonstrate that the development proposals would not conflict with the stated aims and policies of the Development Framework. The prevailing policies at a European, national, regional and local level all support the reduction in the quantities of waste being directed towards landfill and if disposal cannot be avoided, for the safe disposal of waste including the asbestos wastes proposed in the development scheme. 25. The proposed development is considered to be fully consistent with the general thrust of Government Policy to ensure that if waste, under the hierarchy is destined for landfill disposal, is disposed of safely. There are no overriding planning constraints specific to the site, and the project would not conflict with development plan policies. NEED FOR THE DEVELOPMENT 26. Biffa currently operates the existing landfill at Cottonmount and has identified the site as an excellent location to make further investment to expand its business serving existing and future customers. Northern Ireland currently has relatively few facilities for the treatment or disposal of stable non reactive (SNR) wastes such as asbestos and the development of the SNR cell at Cottonmount is in a strategic location for Biffa and their customers. 27. Although disposal of SNR asbestos waste does occur in Northern Ireland, there remains a heavy reliance on Great Britain to meet its facility needs. It is important that Northern Ireland remains or becomes self-sufficient in the treatment and disposal of wastes including stable non reactive (SNR) hazardous wastes in order to meet with local demand and provide an economically feasible option for disposal. This major shortfall in the capacity to treat and dispose of SNR waste safely will inevitably lead to storage problems, an increase in illegal disposal (including fly-tipping) and rising public concern about health and environmental impacts. 28. Cottonmount landfill is currently licensed to accept non-hazardous waste. The development proposals seek to provide a separate cell within the confines of the consented landfill area, thus allowing the disposal of asbestos wastes which are classed as stable non-reactive (SNR) wastes and which can be disposed of within non-hazardous landfill sites. The remainder of the site will continue to accept non-hazardous wastes which do not contain asbestos. Cottonmount SNR Vol 2 P a g e 6 SLR Consulting Limited
AIR QUALITY 29. An assessment of the air quality impacts associated with the proposed SRC at the existing Cottonmount landfill site has been undertaken. The assessment has considered: dust; Air Quality Strategy Pollutants from vehicle exhausts; and asbestos fibres during the operational phase. 30. In considering the potential impacts, it is important to keep in mind that the SNR cell would also be regulated by a PPC Permit issued by the Northern Ireland Environment Agency (NIEA). The PPC permit variation application will detail how Biffa will accept and dispose of the waste without causing significant harm to the environment (water, air and land) or human health. These assessments have been submitted to NIEA. 31. The assessment of dust has found that there is no change in the risk of impact between the proposed and currently consented landfill scheme and mitigation measures would continue to be required (primarily during earthworks). 32. There is not predicted to be significant additional traffic associated with the asbestos cell and therefore impacts associated with vehicle exhaust emissions are not considered to be an issue. 33. In terms of asbestos fibres from the asbestos cell during operation, the PPC Permit variation would not be approved by the NIEA unless they are satisfied that operations would not cause significant pollution to the environment or harm to human health. LANDSCAPE AND VISUAL IMPACT 34. The application site for the SNR cell is located within the boundary of the existing permitted and consented landfill operation at Cottonmount and it is apparent that there is precedent for such a development at the site. 35. The existing site is currently a relatively flat area that has been previously excavated although the immediate surroundings comprise active landfill and quarrying activity, and ancillary built infrastructure in the form of landfill netting, site offices and internal haul roads. The proposed development will not increase landfill void space within the existing permitted and consented landfill boundary, but will substitute a small amount of existing consented non hazardous void space with capacity for asbestos waste. 36. The proposals would not alter the existing permitted final restoration scheme of the landfill and would not be visible when viewed externally from the site due to the location of the proposed facility within the quarry void, surrounded by active quarry and landfill operations. Cottonmount SNR Vol 2 P a g e 7 SLR Consulting Limited
37. The proposals will blend in with the existing on site development (landfill and quarrying operations) and will not be out of character with the site operations and would not cause an unacceptable landscape or visual impacts. HIGHWAYS & TRANSPORTATION 38. The traffic and transport implications of the proposed SRC have been assessed in accordance with recognised standards guidance issued by the Department of the Environment (DOE) Planning Service s Transport Assessment Guidelines for Development Proposals in Northern Ireland (October 2006) and the guidelines for the Environmental Assessment of Road Traffic (IEA, 1993). 39. During the operation of the SNR cell it is anticipated that 5 trips per day will arise, based on an average payload of 20t per lorry. This equates to less than one heavy goods vehicle trip every two hours throughout the day. The inputs to the SNR cell will replace existing trips associated with the importation of nonhazardous waste materials to the existing landfill, and are therefore already present in the baseline operation of the highway network. 40. The assessment has considered the local highway network in the context of geometry and safety risks, and the assessment has concluded that there is no existing adverse safety risk associated with either the geometry of the network or the existing operation of the landfill site. 41. The assessment concludes that the magnitude of the change in traffic flows and its significance are immaterial and indiscernible in the context of highway capacity and safety, being that they are well within the baseline day-to-day traffic flow fluctuations that can expected. NOISE 42. The PA&ES has considered the potential impact of the SNR cell on noise sensitive receptors in close proximity to the site. 43. The current proposal will not increase imported tonnages to the site, but will replace existing consented tonnage for non-hazardous waste with stable non reactive (SNR) waste. There will be no increase in on-site activity nor will the proposals result in a significant increase in traffic movements to and from the site. The location of the SNR cell within the quarry void, surrounded by active quarry and consented landfill operations will ensure there will be no noticeable noise emissions from the proposed SNR cell. 44. The proposed operations will be broadly identical to the existing and will utilise the same plant and machinery throughout the current working hours. Cottonmount SNR Vol 2 P a g e 8 SLR Consulting Limited
HYDROGEOLOGY AND HYDROLOGY NON TECHNICAL SUMMARY 45. The proposals are for the development of an SNR cell for disposal of asbestos and wastes contaminated with asbestos only. It does not therefore mean that a new hazardous waste landfill site is being developed. Previously, asbestos waste could be landfilled with general waste but under current legislation it must handled separately and placed in a separately engineered cell which is what is proposed in this application. The geology of the site has been described, having regard to published data and site investigations. The site is located within an area of Tertiary basalt which is classified as moderately permeable. Cottonmount landfill is primarily underlain by a bedrock aquifer classified as of moderate productivity and fracture flow. The site is not underlain by a superficial aquifer but has the highest groundwater vulnerability rating of 5. 46. The application site lies within the catchment of the Flush River, a tributary of the Ballymartin Water. The Flush River flows in a north easterly direction and is located approximately 450 m to the south east of the application site. 47. A permit variation application to include the operation of the SNR cell as a disposal activity at the existing landfill has been submitted to NIEA. An updated Revised HRA is required every 4 years and NIEA requested the Revised RHRA be submitted at this time to update the HRA and support the permit variation application to include the Stable Non Reactive (asbestos) cell. The Revised HRA concluded that the proposed and installed landfill engineering systems and precautions at Cottonmount Landfill continue to operate effectively and comply with the relevant requirements of the Groundwater Regulations (Northern Ireland) 2011. 48. It is concluded that, with the implementation of the proposals and the continuation of the approved landfill engineering system there would be a no impact on the surrounding environment. ECOLOGY 49. The application area for the SNR cell is located wholly within the existing active Cottonmount Landfill boundary, within the footprint designated for future cell development. The application area has been quarried and the site is being landfilled and restored in a phased approached. Landfill cell engineering operations for the adjoining cells are currently taking place within this area of bare ground which is subjected to daily disturbances. 50. The development site is not subject to any statutory or non-statutory designations. Due to the proposal not requiring the development of any additional land but rather for the modification of waste stream in existing permitted waste cells, an extended Phase 1 Habitat Survey or other specialist surveys was not necessary however an ecological review was undertaken and addressed: habitat loss and fragmentation; Cottonmount SNR Vol 2 P a g e 9 SLR Consulting Limited
disturbance; dust; increase in pest species; and restoration. 51. The review has found that the proposed operations will be broadly identical to the existing. The proposals would lead to no loss of habitat or protected species as all development will take place within existing active consented landfill and would not involve any physical extension of the facility or increase in void space. The SNR cell development is unlikely to have significant ecological impact on the existing baseline conditions within the application site, or on the wider surrounding area, over and above the impacts already experienced spatially from the existing landfill. Accordingly the current proposals are considered to have no adverse ecological impacts. CULTURAL HERITAGE 52. The nature of the site within an active quarry and landfill is such that the potential for archaeological record has been excavated as a result of the quarrying operations. Due to the location of the SNR cell within an area of consented landfill and below the level of the surrounding terrain there would be no indirect impacts on heritage features around the area. 53. The proposed development would not impact upon cultural heritage and therefore not conflict with any legislation or planning policies related to archaeology and the built heritage. CONCLUSIONS 54. The proposals are for a Stable Non-Reactive (SNR) cell within the confines of the existing landfill development area at Cottonmount Landfill, Mallusk. This Stable Non-Reactive cell will be capable of accepting asbestos waste and waste contaminated with asbestos. 55. To enable the applicant to maintain flexibility in the final design and layout the final design will not be fixed under pre construction; this approach is typical of cells of this nature within operational landfills and has been successfully adopted by Biffa at their similar facilities in England where they have considerable experience in successfully managing this type of material. 56. These proposals will not increase the overall inputs to the site or increase the utilized void space at the site. The proposals will simply enable the applicant to use allocated non hazardous void space for stable non reactive (SNR) waste. The general operations of the landfill will remain unchanged. 57. The PA&ES has not identified any significant impact from the proposed development. The SNR cell would also be regulated by a PPC Permit issued by the Northern Ireland Environment Agency (NIEA). The PPC permit variation application will detail how Biffa will accept and dispose of the waste without Cottonmount SNR Vol 2 P a g e 10 SLR Consulting Limited
causing significant harm to the environment (water, air and land) or human health. Cottonmount SNR Vol 2 P a g e 11 SLR Consulting Limited