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Manywells Landfill: determination, management & communication. Ann Barker Lead Officer Contaminated Land. Structure of presentation. Part IIA reminder Location and background Initial negotiations Assessment actions Determination Part IIA issues post-determination

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Manywells landfill determination management communication

Manywells Landfill:determination, management & communication

Ann Barker

Lead Officer Contaminated Land

Structure of presentation
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
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

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 from a disused sandstone quarry in Cullingworth

licensed waste disposal site 1994 to 2001

Photo-montage by local resident

Site overfilled by approx 90 000 cubic metres
Site overfilled by approx 90,000 cubic metres deserting the site

Uncontained leachate seeping to surface

The first view

Waste mass towers over surrounding land levels deserting the siteUnstable gradients

The first view…

Landfill gas migration onto public bridleway and into woods

Background deserting the site

  • 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
Initial negotiations : deserting the siteLegal 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
Initial negotiations: deserting the siteImplications 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…

Initial negotiations 2002
Initial Negotiations: 2002 deserting the site

  • 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
Leachate migration deserting the site

Groundwater potential migration pathway via compromised landfill liner
Groundwater: Potential migration pathway via compromised landfill liner

Cross Section

Waste deposits

Leachate saturated waste deposits

Leachate detection chamber

Leachate ingress to LDC

Main clay liner

Leachate detection layer

Rough Rock Flags (Bedrock & Minor Aquifer)

Site review controlled waters
Site review: Controlled Waters landfill liner

  • 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
Controlled Waters: significance? landfill liner

  • Surface water – leachate from breakout diluted on site and during run-off – no significantpollutant 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
Assessment Actions landfill liner

  • 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

Assessment actions landfill gas
Assessment Actions: Landfill Gas landfill liner

  • 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
Den Making in woodland landfill liner

Part iia manywells key points
Part IIA & Manywells – key points landfill liner

  • 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
Determination process landfill liner

  • 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 gas risk assessment
Determination Document: Gas risk assessment landfill liner

  • “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
Gas concentrations landfill liner

  • 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
Determination Document: Groundwater Risk Assessment landfill liner

  • “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.”

Part iia post determination issues
Part IIA: Post determination issues landfill liner

  • 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 issues1
Part IIA: Post determination issues landfill liner

  • Neighbouring land owners

  • Power generation company

  • Escrow fund - E.A. High Court action

  • Negotiations with Crown

  • Site ownership issues

Interaction with e a
Interaction with E.A. landfill liner

  • 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
The Technical Challenge 1: original option landfill liner


Remove 90,000 m3 of material

= 22,000 Wagon movements


  • Sustainability

  • Environmental Considerations

  • Cost

  • Short term fix solution?

    RISK and Where would it go?

Technical challenge 2
Technical Challenge 2: landfill liner

Control required for:

  • Leachate

  • Landfill Gas

  • Stability


Technical challenge 3 what were real problems
Technical Challenge 3: what were real problems? landfill liner

Significant Pollutant Linkages (SPLs)

  • What?

  • Where?

  • Why?

    SAFE site. HSE Involvement


2006 work
2006 WORK landfill liner

Leachate Containment

– drains, manholes, pumping

Landfill Gas

– flare, pipe network

Site Investigation

– 6 boreholes along spine of tip

Security and Safety

Assessment, Signing, Fencing and Control

Landfill Closure landfill liner

Landfill Processes landfill liner

Processes at Manywells landfill liner

Project team and project development
Project team and project development landfill liner

  • 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
Manywells Landfill Remediation Project landfill liner

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
Interim Works 2007/08 landfill liner

  • AIM – induce settlement through

    • Control of leachate

    • Generation of landfill gas

  • Site works October 07 – May 08

  • Value £594k

Interim works 2007 081
Interim Works 2007/08 landfill liner

  • 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
What we achieved 2008- landfill linerPumped 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
Waste Mass Temperature landfill liner

Borehole locations landfill liner



BH10 landfill liner





BH13 landfill liner





Gas concentrations1
Gas concentrations landfill liner

  • 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
The Plan landfill liner

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
Community Confidence in L.A. landfill liner



set up















Communications activity
Communications activity landfill liner

  • Communications with ward councillors

  • Members bulletin items

  • Neighbourhood Forum meetings

  • Community Newsletters since July 2006

  • Webpages –

  • Manywells Community Working Group- 5 meetings since Oct. 07

  • Communications Strategy- April 2008

Community working group site visit
Community Working Group landfill linersite visit

Community newsletter
Community Newsletter landfill liner

Posters landfill liner

Communications strategy
Communications Strategy landfill liner

Part iia communications summary
Part IIA: Communications Summary landfill liner

  • 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: landfill linerBest communcations/stakeholder engagement

Brownfield briefing award manywells community working group
Brownfield Briefing Award: landfill linerManywells Community Working Group

Manywells part iia
Manywells & Part IIA landfill liner


Part iia landfill site determination
Part IIA: Landfill Site Determination landfill liner

  • 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
Site remediation: practical points landfill liner

  • 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!

Thank landfill liner




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