health overview and scrutiny committee · 2009-06-09 · site, which use lasers to detect dust...

Health Overview and Scrutiny Committee Wingmoor Farm Task-Group

ITEM 10.1

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Gloucestershire Health Overview and Scrutiny Committee Wingmoor Farm Task-Group

1. Introduction 1.1 The Wingmoor Farm task-group was commissioned in response to concerns

raised by the County Councillor for the Cleeve electoral division, and concerns raised by the Cheltenham and Tewkesbury Patient and Public Involvement Forum (now disbanded). Both were concerned about the possible negative impact that the site might have on the health of local residents, and felt that the Health Overview and Scrutiny Committee (HOSC) should investigate the issue. As this issue cut across the remit of several scrutiny committees, the HOSC sought advice from Scrutiny Management and Audit Committee (SM&AC) about how this work should be taken forward. SM&AC agreed that a task-group should be set up under the leadership of HOSC, but that the membership should be drawn from across the scrutiny function. The task-group would report its findings to HOSC.

1.2 The initial phase of the task-group’s work took place between February 2006

and February 2007. This phase involved gathering evidence from a range of stakeholders about how the site was monitored and any possible health impacts. This phase was completed in February 2007 at which point the task-group considered producing its final report. However, the group was informed that the Primary Care Trust was undertaking a Health Impact Assessment (HIA) on the Wingmoor Farm site, and that this would be completed by June 2007. The group therefore decided to delay reporting until it had examined the findings of the HIA.

1.3 This report does not make reference to the findings of the HIA as it was not

completed in time for it to be considered by the task group. 2. Terms of Reference 2.1 The terms of reference for the investigation are as follows:

• To understand existing monitoring arrangements at the Wingmoor Farm waste management sites, and what current monitoring arrangements demonstrate. Monitoring arrangements refer to the following three categories:

o Operations – monitoring lorry movements/numbers, monitoring the operation of plant/activity on the sites, monitoring the level of waste disposed of at the sites etc.

o Environment – Monitoring air, water and soil quality o Health – Monitoring the frequency of various illnesses in the area

surrounding Wingmoor Farm, compared to average etc. • To gain clarification of the responsibilities of the different organisations

involved in the monitoring of the waste management sites. • To understand the range of possible health conditions that could be linked

to waste management sites, the extent to which evidence supports a link between waste management sites and ill health, and the local health context.

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• To report findings and make appropriate recommendations. 3. Phase 1 – February 2006 to February 2007 3.1 Methodology 3.1.1 The task-group was made up of 5 County Councillors, and one co-opted

member representing the Cheltenham and Tewkesbury Patient and Public Involvement Forum (now disbanded). The membership was as follows: • Councillor Mike Skinner (Chairman) • Councillor Phil Awford • Councillor Bill Crowther • Councillor Deryck Nash • Councillor Margaret Nolder • Christine Donald, Chair of the Cheltenham and Tewkesbury Patient and

Public Involvement Forum (now disbanded) 3.1.2 The task-group held an initial meeting with Carolyn Roberts, Associate Dean

of the Faculty of Education, Humanities and Sciences at the University of Gloucestershire to explore the feasibility of using the University to undertake research to support the work of the task-group. Following these discussions it was concluded that the task-group did not need to go into the level of technical detail that would require this level of support. However, the meeting was useful in helping to clarify the task-group’s terms of reference.

3.1.3 The following witnesses attended task-group meetings to present information

to the task-group and answer questions: • Gloucestershire County Council Planning Officers • The Environment Agency • Cheltenham and Tewkesbury Primary Care Trust • Gloucestershire Primary Care Trust (following the merger of the three

previous PCTs) • The Health Protection Agency • Safety in Waste and Rubbish Disposal (SWARD) – The local residents

campaign group • Grundons Waste Management Limited – the site operators

3.1.4 Written comments were also invited from the following organisations:

• Bishops Cleeve Parish Council • Elmstone Hardwicke Parish Council • Stoke Orchard Parish Council • Woodmancote Parish Council

3.1.5 The task-group also discussed the Primary Care Trust’s Neighbourhood

Health Profile, and went on a visit to the Wingmoor Farm site. 3.2 Concerns raised by witnesses 3.2.1 Concerns raised by SWARD included:

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• Noise, disturbance and pollution caused by traffic movements associated with the site.

• Noise from the machinery operating on the site. • Levels of dust leaving the site • Large number of flies in the area due to the site, and also concern about

the levels of pesticides that might be being used to control this. • Potential impact of Air Pollution Control (APC) residues and the dioxins

contained within this waste. • Whether the steam created when APC residue is landfilled contains any

dangerous dust particles. 3.2.2 Parish Councils

• Woodmancote Parish Council raised concerns about the levels of traffic movements associated with the site, and the associated pollution and potential increase in problems such as asthma.

• Stoke Orchard Parish Council commented that it was not aware of any historical, immediate, actual, or implied health threat but did comment on the general nuisance caused by the site for local residents. The key concerns related to land fill gas and road safety issues as a result of soiled roads.

• Elmstone Hardwicke and Bishops Cleeve Parish Councils did not respond to the group’s invitation to provide evidence.

3.3 Monitoring Activity (based on information available during 2006) 3.3.1 Under the Pollution Prevention Control (PPC) rules the operators of waste

disposal sites are responsible for the monitoring of the site themselves. The PPC permit states what monitoring must be undertaken and sets trigger levels. If the trigger levels are exceeded the operator must inform the Environment Agency. The Environment Agency does also undertake its own checks including spot checks, planned audits, and reviews of the operator’s data.

3.3.2 Emissions to surface water are measured from one monitoring point on the

site, and ground water is monitored from 6 points. In addition dust monitoring is undertaken 24 hours a day, 7 days a week. There are 4 Topaz Units on the site, which use lasers to detect dust particles, and dust scan monitors (sticky pads) are located around the site to provide information on the direction from which the dust is coming. Uniquely to Wingmooor Farm the Environment Agency has also placed its own dust scan monitors in and around Bishops Cleeve to measure the levels of dust entering the village.

3.3.3 Grundons also undertakes Health and Safety and Occupational Health

monitoring to ensure that the health of staff working on the site is protected, and the Environmental Health Department at Tewkesbury Borough Council have undertaken some monitoring of nitrogen dioxide levels from traffic.

3.3.4 Levels of activity – The waste license for the hazardous waste site at

Wingmoor Farm permits Grundons to dispose of 150,000 tonnes of hazardous waste per annum. Annual throughput at the site has consistently been

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significantly below this level. The ash conditioning plant that handles Air Pollution Control residues is licensed to handle up to 75,000 tonnes per annum, but again throughput has consistently been below this level.

3.3.5 Ground Water monitoring – The 2005 annual report for the hazardous waste

site showed that limits for heavy metals in ground water had been exceeded on one occasion over the course of the year. There was no clear explanation for this and it was considered to be a spurious result. Elevated chloride levels had also been detected but both the Environment Agency and Grundons have indicated that there is evidence to show that this is related to historic contamination rather than activity by Grundons. The Environment Agency have also indicated that high levels of carbon dioxide were found in the bore holes, but this was believed to be due to natural causes, and that ammonia was also present at fluctuating levels but that this was also likely to be due to historic contamination.

3.3.6 Air Quality Monitoring – The 2005 annual report highlighted 46 examples of

limits being exceeded over the course of the year. These incidents were investigated and 1 was due to a nearby bonfire, one was due to activity on neighbouring land, and the rest were as a result of the monitors picking up mist. Both Grundons and the Environment Agency were confident that this was the explanation for the results. According to the Environment Agency the results of the offsite ‘sticky pad’ monitoring were inconclusive but they were satisfied that there were no serious problems.

3.3.7 Health and Safety monitoring – Monitoring shows that dust levels on the site

are 10% of the occupational limit in the dry summer months and only 3% in the wet winter months. All the results indicted that dust levels were low and were at a safe level for those working at the site. The Health and Safety Executive did voluntary tests to examine worker exposure to dioxins and concluded that those working on the site were not exposed to levels greater than the current recommended level, and that exposure was lower than in several other industries such as steel works. It has been suggested that if workers on the site are not at risk then those living near the site whose exposure will be much lower should also be safe.

3.3.8 Occupational Health monitoring – Individual members of staff working for

Grundons are given occupational health assessments, involving a range of different tests. These investigations have demonstrated that there is no evidence of any Grundons’ worker being exposed to harm as a result of working at Wingmoor Farm.

3.3.9 Risk Assessments – A 2001 Environmental Risk Assessment concluded that

Wingmoor Farm had no adverse effects on neighbourhoods around the site. This risk assessment looked at the worse possible case scenarios and still concluded that the site was safe. Annual dust monitoring reports since 2001 have validated the findings of the risk assessment.

3.3.10 Traffic Pollution – Tewkesbury Borough Council’s Environmental Health

Department have undertaken some monitoring of nitrogen dioxide levels from

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traffic. This monitoring did not reveal any incidents where acceptable levels were exceeded. This monitoring has now ceased.

3.4 Impact on Health 3.4.1 According to the Health Protection Agency and the Primary Care Trust the

findings of various international studies into the health impact of living near to landfill sites, and hazardous waste landfill sites, are inconclusive. The task-group did look at the findings from a small number of studies itself, which appeared to support the conclusion reached the HPA and PCT.

3.4.2 Cheltenham and Tewkesbury Primary Care Trust produced a Neighbourhood

Health profile in 2005 to look at the health of the local population compared to elsewhere in the county. Some of the key findings were as follows: • The birth rate was the same as for the rest of the county and incidents of

low birth weight were lower than for the rest of the county. • Rates of respiratory disease matched patterns seen across the county. • Cancer rates in the areas were no higher than would be expected. • Coronary Heart Disease rates were below average. • Infant mortality rates were the same as for the county as a whole. • There was no evidence of any unusual cluster formations of congenital

abnormalities around the site. • Data was not available to allow the PCT to look at asthma rates, but

research had not linked asthma to landfill sites in particular, although it had linked asthma to air pollution issues related to traffic.

3.4.3 Health and Safety Monitoring and Occupational Health Monitoring of staff

working on the site had concluded that staff working on the site were not exposed to levels of dioxins that were above the recommended levels, and that there was no evidence of any Grundon’s worker being exposed to harm as a result of working on the site. Exposure to harm for those living near the site should be lower than for those working on the site itself, suggesting that there should not be any impact on the health of local residents.

3.5 Conclusions at the end of Phase 1 3.5.1 At the end of phase 1 in February 2007 the task-group was able to reach the

following conclusions: • SWARD had expressed considerable concerns about the site and had

argued that a lack of evidence of harm should not be taken as evidence of no harm. The disposal of waste, particularly hazardous waste, is an emotive issue and so residents concerns are understandable.

• A great deal of monitoring was being undertaken at the Wingmoor Farm site, and whilst it would be possible to call for additional monitoring, it was clear that the monitoring arrangements met, and in some cases exceeded, all of the minimum requirements.

• Organisations including Grundons, the Primary Care Trust, the Health Protection Agency, and the Environment Agency consistently noted that

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the evidence available suggested that Wingmoor Farm had no discernable off site impact.

• The Neighbourhood Health Profile suggested that Wingmoor Farm was not adversely affecting the health of local residents and national research on the impact of landfill sites on health was inconclusive.

• There was not any strong evidence to suggest that the site was causing harm, although this did not necessarily prove that the site was harmless.

• Further evidence was required to help the group reach a firm conclusion and at the time of the last meeting in February 2007, members looked forward to receiving the findings of the Primary Care Trust Health Impact Assessment.

Appendix to SWARD Comments and Feedback on HIA Final Draft

- 2 - Appendix to SWARD comments and feedback: HIA Final draft February 2009

Examples of Breaches of PPC Permits at Grundon Sites extracted from Public register Schedule 1 = Notification by operators of abnormal emissions and serious environmental effects. NB:Comments are operator’s own CCS Scores: CCS Category Description

1 A non-compliance which has a potentially major environmental effect. 2 A non-compliance which has a potentially significant environmental effect 3 A non-compliance which has a potentially minor environmental effect 4 A non-compliance which has no potential environmental effect

OPRA Score = previous EA scoring system (4 = most serious) Inspection Reports = routine inspections carried out by Environment Agency CAR = Compliance Assessment Report carried out by Environment Agency GW = groundwater monitoring boreholes GM = landfill gas monitoring DM = dust monitor Wingmoor Farm Hazardous Landfill: BU3671 Emissions to Air Date Nature of Breach Document Outcome / Comments 21/09/04 Very strong odour of downwind of cell

and outside site boundary EA Site Inspection Report OPRA Score 3

21/09/04 Cell B, Phase 4 Odour from phenolic compounds 4 hours duration approximately

Schedule 1 The site staff immediately refused further loads of the odorous waste. This is a declaration as required by Condition 5.1.1.5 of the Permit. Instructions have been issued to site staff and Technical staff to refuse all wastes declared as odorous. Site


staff have been instructed to refuse access to any waste they consider may cause odour. Waste acceptance procedures will be reviewed to reflect these instructions.

2/12/05

1 x landfill gas - breach of CO2 levels at 2 monitoring points Trigger level=1.5%

EA Report to Liaison Forum

12/05 1 was detection of asbestos on internal monitor. No fibres were detected at site perimeter (no emission).

19/12/06 Carbon dioxide: GM31: 5.6% Schedule 1 Continued monitoring of Sample Point as per Permit Conditions and analysis of results in order to determine potential trends.

15/02/07 Carbon dioxide: GM33 4.7 %volume

Schedule 1 Continued monitoring of sample point as per permit conditions and analysis of results in order to determine potential trends. No methane recorded at well.

15/04/07 DM1 PM10s 262.2ug/m3 (24-hr average) 07:37:00 – 08:07:00

Schedule 1 Breach possibly caused by a steam engine on main train line or other offsite event. DM1 is closest the line and wind direction was SW. The emission was two abnormal 30min readings within otherwise low figures. The day in question was a Sunday and the site was not operational.

26/06/08 GM36F, GM38F : 4.7%, 5.9% (limit 4.4%)

Schedule 1 Continued monitoring of Sample Points as per Permit Conditions and analysis of results in order to determine potential trends. Boreholes GM36F and GM38F are newly installed boreholes not bordering any disposal cell. No Methane recorded at borehole and


in-waste spiking shows negligible CO2 readings. CO2 therefore believed to be naturally occurring.

12/09/08 GM35F: CO2: 6.0%, GM36F: CO2: 8.4%; GM38F: CH4: 0.5%, CO2: 11.7%

Schedule 1 Continued monitoring of Sample Points as per Permit Conditions and analysis of results in order to determine potential trends. No Methane recorded at boreholes GM35F and GM36F. Boreholes GM35F, GM36F and GM38F are newly installed boreholes not bordering any disposal cell. CH4 and CO2 not detected during in-waste spike point monitoring of disposal cell at Wingmoor Farm West landfill. CO2 therefore believed to be naturally occurring and no scoring is expected. Testing of background levels to be undertaken in the near future for western perimeter of site.

11/11/08 E1) - Landfill Gas - (Table S4.5) - Breaches of trigger levels have been recorded for points GM35F, GM36F and GM38F. Schedule 6 notifications were received for these breaches.

CAR1 CCS 4

Grundon Audit March 2007: 4.3

To continue the reducing of dust emissions from site* * our emphasis

This has included the purchase of two atomisers for use close to the tipping face to reduce dust emissions.


Wingmoor Farm Hazardous Landfill: Emissions to Water Date Nature of Breach Document Outcome / Comments 13/10/05

1 x surface water breach- BOD (Trigger level=5mg/l) Suspended solids (Trigger level=50mg/l)


13/10/05 22/11/05

2 x groundwater Breach of chloride levels Trigger level=250 mg/l


22/11/05 7/12/05

2 x groundwater Breach of ammonia levels Trigger level=0.6mg/l


06/06/06 Mecoprop in groundwater 0.527µg/l Schedule 1 Continued monitoring of Sample Point as per Permit Conditions and analysis of results.

06/06/06 Nickel in groundwater 32.7µg/l GW7 Schedule 1 18/07/06 Ammoniacal Nitrogen in groundwater :

GW8 1.74µg/l Schedule1 Continued monitoring of Sample

Point as per Permit Conditions and analysis of results in order to determine potential trends

01/08/06 Chloride in groundwater GW7 256 mg/l

Schedule 1 Continued monitoring of Sample Point as per Permit Conditions and analysis of results.

01/08/06 Lead in groundwater GW1: 139µg/l; GW2: 51.9µg/l; GW10: 172µg/l Nickel in groundwater GW1: 227µg/l; GW2: 98.9µg/l; GW10: 258µg/l Zinc in groundwater GW1: 519µg/l; GW2: 241µg/l; GW4: 150µg/l; GW10: 761µg/l Cadmium in groundwater GW1: 11.3µg/l; GW10: 10.5µg/l Mecoprop in groundwater GW3: 0.822µg/l



01/08/06 Ammoniacal Nitrogen in groundwater GW8: 1.87 mg/l Chloride in groundwater GW7 351mg/l

Schedule 1 Continued monitoring of Sample Point as per Permit Conditions and analysis of results in order to determine potential trends

01/09/06 Chloride GW5 3010 mg/l Schedule 1 Continued monitoring of Sample Point as per Permit Conditions and analysis of results. Historical data indicate naturally occurring high chloride levels at this borehole.

10/11/06 Chloride GW1 329 mg/l Amm. Nitrogen GW8 1.01 mg/l

Schedule1 Continued monitoring of Sample Points as per Permit Conditions and analysis of results in order to determine potential trends

01/12/06 Nickel GW1 30 µg/l Schedule1 Very low level reading recorded. Continued monitoring of Sample Points as per Permit Conditions and analysis of results in order to determine potential trends.

08/06/07 Ammoniacal Nitrogen in groundwater GW8: 1.3 mg/l Chloride in groundwater GW8 275 mg/l

Schedule1 Continued monitoring of Sample Points as per Permit Conditions and analysis of results in order to determine potential trends

06/07/07 Ammoniacal Nitrogen in groundwater GW8: 3.48 mg/l Chloride in groundwater GW8 264 mg/l

Schedule 1 Continued monitoring of Sample Points as per Permit Conditions and analysis of results in order to determine potential trends

10/08/07 Ammoniacal N GW8 3.48 mg/l Schedule1 Continued monitoring of Sample Points as per Permit Conditions and analysis of results in order to determine potential trends

07/09/07 Ammoniacal N GW8 1.22 mg/l Schedule1 Continued monitoring of Sample Points as per Permit Conditions and analysis of results in order to determine potential trends


Wingmoor Farm Hazardous Landfill: Management Date Nature of Breach Document Outcome / Comments

24/11/ 05 Bunding of APC cell EA Report to Liaison Forum CCS3

26/01/07

Bund height surrounding waste cell low – due to weather conditions.


22/02/07 Bund height still low – due to weather conditions


12/03/07 Bund height being addressed EA Report to Liaison Forum

10/05/08 C2 - During the visit a load of asbestos was accepted for disposal at the site. The relevant procedure states that:

“ Prior to all vehicles leaving the disposal site a high pressure jet wash will be used to clean off the back of the vehicle and they will be checked to ensure they are not contaminated with asbestos. The vehicles will also pass through the high pressure wheel/vehicle cleaning wash system.”

The procedure was not followed during the visit, following tipping the back of the vehicle was not cleaned.

CAR1 CCS 3

04/08/08 Review of Monitoring report submitted under condition 4.2.2. (Apr - Jun 2008)

Monitoring is mainly being undertaken as required by the permit with the exception of the following issues which should be addressed for future returns

G1) Leachate levels (Table S4.1) - Monitoring point LF21 is marked as unable to reach each month. Action - confirm what actions are being

BU3671IY/04082008 CCS 4


undertaken to address this for future monitoring.

G1) Surface water (Table S4.2) - measurements of pH should be recorded monthly but is only included once for the quarter. Action - include within future monitoring

G1) Groundwater (Table S4.3) - Dichloropropane - sample results are stated as <1ug/l, the limit is 0.1ug/l. Action - confirm why analysis is not being undertaken to the required level and what action is being undertaken to address this.

APC Treatment Plant NP3831ST Management Date Nature of Breach Document Outcome / Comments 24/11/05 Cracked concrete around APC silos EA Report to Liaison Forum CCS 3 13/01/06 Cracked concrete around APC silos EA Report to Liaison Forum CCS3 07/02/06 Cracked concrete around APC silos EA Report to Liaison Forum CCS3 23/03/06 Cracked concrete around APC silos EA Report to Liaison Forum CCS3 04/06 Cracked concrete around APC silos EA Report to Liaison Forum CCS3 05/06 Cracked concrete around APC silos EA Report to Liaison Forum CCS3 07/06 Cracked concrete around APC silos EA Report to Liaison Forum CCS3 23/08/06 Concrete around APC plant requires

repair and is subject to an improvement condition.

CAR Ref :APC02 CCS 3

24/11/06 Concrete around APC plant requires repair and is subject to an improvement condition.

CAR Ref: APC03 CCS 3


CAR Ref:APC04 CCS 3



CAR Ref:APC05 CCS 3


CAR Ref:APC06 CCS 3

27/04/07 Concrete around APC plant requires repair and is subject to an improvement condition

CAR Ref:APC07 CCS3

25/05/07 Concrete around APC plant requires repair and is subject to an improvement condition

CCS3


CAR Ref:APC08 CCS 3

05/08/2008 Review of Hazardous waste consignee returns: Identified acceptance of a waste streams not included on the permit. A copy of the Consignment note for this movement was reviewed as part of the recent audit. The CN confirmed the waste was accepted at the site under EWC code 11 01 06 which was not permitted. For this movement the pre acceptance and acceptance procedures failed to ensure that the waste stream was permitted under the permit before being accepted.

Review of data CAR Ref: 05082008/NP3831ST

16/08/08 Breach of operating techniques – Pre acceptance and acceptance procedures & Site operations do not accord with the sector guidance note (detail included within separate audit report)

Audit - Review of pre acceptance and acceptance procedures & site operations CAR Ref: NP3831ST/160808

CCS2


Wingmoor Quarry YP3439SM Emissions to air Date Nature of Breach Document Outcome / Comments 2/12/05

1 x landfill gas - breach of CO2 levels at 3 monitoring points Trigger level=1.5%

Report to Liaison Forum

08/09/06 Carbon dioxide GM9 :7.9% volume, GM13 : 9.5% volume

Schedule 1

15/02/07 Carbon dioxide: GM9 7.8% volume Schedule 1 Continued monitoring of sample point as per permit conditions and analysis of results in order to determine potential trends. No methane recorded at well.

01/06/07 Carbon dioxide Gm 9 11.5% volume Schedule 1 Continued monitoring of sample point as per permit conditions and analysis of results in order to determine potential trends. No methane recorded at well.

02/07/02 Carbon dioxide Gm 8.4% volume Schedule 1 15/08/07 Carbon dioxide Gm13 12.2% volume Schedule 1 Continued monitoring of sample

point as per permit conditions and analysis of results in order to determine potential trends.

Wingmoor Quarry YP3439SM Odour Date Nature of Breach Document Outcome / Comments 24/11/2005 Landfill, associated odour. No covers

were in place on the leachate wells situated on the current tipping cell.

EA PPC Compliance Report CCS3

28/04/06 Some localised odour associated with the deposited waste, with appropriate cover being applied during visit.

Under normal circumstances the above issues under the PPC permit would attract a CCS score of either 3 or 4. Nationally there is a temporary hold on applying these scores as many PPC permits, including these ones, are currently subject to review.


16/07/08

C4 Localised odour of landfill gas along the haul road to the tipping face. Additional clay was placed on this area following the previous inspection. Additional clay to be placed further along the road to fully address the issue. Odour from vent on abstraction well on former east site. Operator to identify what measures can be adopted to address the odour from the vent.

CAR Ref: 5/160708/YP3439SM

CCS4

Wingmoor Quarry YP3439SM Emissions to Water Date Nature of Breach Document Outcome / Comments

07/12/05

2 x Groundwater - breach of Mecoprop levels Trigger level = 0.4ug/l

Report to Liaison Forum

13/07/06 Chloride GW5 1750 mg/l Schedule 1 Continued monitoring of Sample Point as per Permit Conditions and analysis of results.

18/07/06 Mercury GW2 0.117µg/l Schedule 1 Continued monitoring of sample point as per permit conditions and analysis of results in order to determine potential trends.

01/08/06 Lead GW1: 139µg/l; GW2: 51.9µg/l; GW10: 172µg/l Nickel GW1: 227µg/l; GW2: 98.9µg/l; GW10: 258µg/l Zinc GW1: 519µg/l; GW2: 241µg/l; GW4: 150µg/l; GW10: 761µg/l Cadmium GW1: 11.3µg/l; GW10: 10.5µg/l Mecoprop GW3: 0.822µg/l

Schedule 1 Continued monitoring of sample point as per permit conditions and analysis of results in order to determine potential trends. Preliminary indications suggest that September 2006 readings for all boreholes are below permitted threshold limits for above parameters.


01/09/06 Mercury GW8 Mecoprop GW3


05/01/07 Mecoprop GW3 0.947µg/l Zinc GW5: 340µg/l; ,GW9 340µg/l; Mercury GW10 0.0622µ

Schedule 1

Levels detected are extremely low. Continued monitoring of sample point as per permit conditions and analysis of results in order to determine potential trends. No noticeable trends to date.

02/02/07 Ammoniacal-N GW3 3.24mg/l Zinc GW5, GW9 GW5: 240µg/l; Mecoprop GW3 0.883µg/l

Schedule 1 Levels detected are extremely low. Continued monitoring of sample point as per permit conditions and analysis of results in order to determine potential trends. No noticeable trends to date.

11/05/07 Zinc GW2, GW5, GW9 0.111 mg/l; 0.573; 0.554 mg/l Ammonical Nitrogen GW3 5.11 mg/l Mecoprop GW3 0.826


08/06/07 Ammoniacal-N GW3 4.17 mg/l Zinc GW9 0.48 mg/l MecopropGW3 0.796 ug/l


06/07/07 Ammoniacal-N GW3 4.10 mg/ Mecoprop GW3 0.793 ug/l Zinc GW5 0.895 mg/l


10/08/07 Ammoniacal-N GW3 3.93 mg/l Mecoprop GW3 0.778 ug/l Zinc GW5 0.235 mg/l Zinc GW9 1.30 mg/l


07/09/07 Ammoniacal-N GW3 4.46 mg/l Mecoprop GW3 1.18 ug/l Mecoprop GW10 1.69 mg/l Zinc GW9 489 ug/l



Wingmoor Quarry YP3439SM Leachate Date Nature of Breach Document Outcome / Comments

23/03/06 Internal bund for the site had suffered slope failure. This resulted in the loss of one of the cells leachate wells. Current instability prevented close inspection of damaged well. It is likely that this failure has the potential to result in uncontrolled release of landfill gas. Although not occurring at the time of inspection it is possible that further failure of the bund will result in leachate breakout.

EA PPC Compliance Report & Schedule 1

CCS 3.

13/03/07 Leachate detected on southern side of cell

EA report to Liaison Forum

Wingmoor Quarry YP3439SM Management Date Nature of Breach Document Outcome / Comments

23/03/06 Management EA PPC Compliance Report CCS 3

12/03/07 Exposed waste on tip face EA Inspection soil cover applied during visit


Wingmoor Farm East BU4309 Emissions to water Date Nature of Breach Document Outcome / Comments

13/07/06 Chloride in groundwater GW5 1750 mg/l Schedule 1 Continued monitoring of Sample Point as per Permit Conditions and analysis of results. Historical data indicate naturally occurring high chloride levels at this borehole.

01/08/06 Chloride GW5 2230 mg/l Schedule 1 Continued monitoring of Sample Point as per Permit Conditions and analysis of results. Historical data indicate naturally occurring high chloride levels at this borehole.

12/12/06 Chloride GW5 2740 mg/l Schedule 1 Continued monitoring of Sample Point as per Permit Conditions and analysis of results. Historical data indicate naturally occurring high chloride levels at this borehole, most likely due to local geological conditions.



09/02/07 Chloride GW51280 mg/l Continued monitoring of Sample Point as per Permit Conditions and analysis of results. Historical data


indicate naturally occurring high chloride levels at this borehole, most likely due to local geological conditions.



06/0707 Chloride GW5 2190 mg/l Schedule 1 Continued monitoring of Sample Point as per Permit Conditions and analysis of results. Historical data indicate naturally occurring high chloride levels at this borehole, most likely due to local geological conditions.

17/08/07 Lead GW3 0.0548 mg/l Chloride GW5 1740

Schedule 1 Continued monitoring of Sample Points as per Permit Conditions and analysis of results. Historical data indicate naturally occurring high chloride levels at borehole GW5, most likely due to local geological conditions.


Wingmoor Farm East BU4309 Emissions to air Date Nature of Breach Document Outcome / Comments

2/12/05 1 x landfill gas Breach of CO2 levels

Trigger level=1.5%


15/02/07 Carbon dioxide: GM13 6.2% Schedule 1 Continued monitoring of Sample Point as per Permit Conditions and analysis of results in order to determine potential trends. No Methane recorded at well.

1/06/07 Carbon dioxide: GM14 5.7% Carbon dioxide: GM15 6.4%

Schedule 1 Continued monitoring of Sample Point as per Permit Conditions and analysis of results in order to determine potential trends. No Methane recorded at well.

02/07/07 Carbon dioxide: GM13 9.0% Carbon dioxide: GM14 6.3% Carbon dioxide: GM15 5.3%

Schedule 1 Continued monitoring of Sample Point as per Permit Conditions and analysis of results in order to determine potential trends. No Methane recorded at well.

23/08/07 Carbon dioxide: GM12 7.1% Carbon dioxide: GM13 13.7% Carbon dioxide: GM14 10.4% Carbon dioxide: GM15 9.8%

Schedule 1 Continued monitoring of Sample Points as per Permit Conditions and analysis of results in order to determine potential trends. No Methane recorded at well. Weekly monitoring of wells as per Working Plan indicate a recent decrease in CO2 levels at these boreholes since 23/08/07, in line with natural seasonal trend.


Wingmoor Farm East BU4309 Odour Date Nature of Breach Document Outcome / Comments

28/04/06 Some localised odour associated with the deposited waste, with appropriate cover being applied during visit.

EA Report to Liaison Forum Under normal circumstances the above issues under the PPC permit would attract a CCS score of either 3 or 4. Nationally there is a temporary hold on applying these scores as many PPC permits, including these ones, are currently subject to review.


Wingmoor Quarry Permit YP3439SM and Wingmoor East Permit BU4309 were consolidated and the new Permit was issued on the 26th September 2007, Permit FP3137UB. Wingmoor Quarry Permit FP3137UB (Previously YP3439SM & BU4309) Date Nature of Breach Document Outcome / Comments

26/11/07 C2 - Cover on the active cell was not in accordance with working procedure EN/LO/GEN/012. During the audit no problems were identified with regard to odour, scavenging animals, litter or dust. As a consequence the site receives a CCS score of 3.

C3 - The weighbridge changed a declaration from a company importing waste to state that it had been pre-treated. Although it is believed that the change in information was correct it is evidently not for the landfill to make this alteration. As a consequence the weighbridge operator failed to follow procedure. For this the site has been awarded a CCS score of 4.

During the audit engineering at the site was found to be compliant. Some localised odour was found on site and should be subject to further investigation by the site. During the audit no odour was detected on the site boundary or off the site.

CAR3/261107/MP3439SM CCS 3 CCS4


05/03/08

Leachate well L10 – pipework not gas tight. Localised odour identified around well. Localised odour also identified on haul road site to investigate cause.

EA Routine inspection CAR Ref: 2/050308/3439SM

CCS3

19/03/08 - During the inspection leachate wells on the active cell were fitted with purpose built caps to prevent gas from escaping. One of these caps had however been damaged and was allowing gas to escape from the well. Once identified during the inspection the cap was replaced. Procedures should be reviewed to ensure that temporary seals (caps) placed on the leachate wells are regularly inspected to ensure that future damage is quickly identified. Procedures should also check that all temporary caps are checked to ensure that they have sealed correctly. The use of a damaged cap has been awarded a CCS score of 3.

E3 - Although not involved in the audit it was noted that water was being discharged from the site with a high solid content. This discharge was given a CCS score of 3. Discharge was stopped while officers were on site.

F1 - During the audit landfill gas odour was detected by officers on the site boundary. This odour was faint and down wind of the active cell. Potential sources of odour are discussed in the audit. Odour at the site boundary has been given a CCS score of 3

CAR Ref: 19/03/2008/MP3439UM CCS 3


21/05/08 C2 - Dust was building up on the haul road to the tipping face particularly around the corners where vehicles appeared to be travelling too fast. Measures for control of dust include the use of a bowser to dampen the road to ensure areas outside of the boundary are not affected. A bowser was observed on Wingmoor Farm West however there was no evidence that the Quarry haul road had been recently dampened.

The problem was raised with the site manager who agreed to direct the bowser to these areas and re-enforce the speed limits with those drivers who had recently tipped at the site.

F1 - Emissions of landfill gas were evident in the following temporary capped areas of the site.

- along the haul road to towards the current tipping face

- Corner of the area previously referred to as Wingmoor East landfill above the construction of the new tipping cell.

Odour was not detected off site however action is needed to address these emissions to prevent amenity impacts.

CAR Ref:4/190508/YP3439SM CCS4

04/08/08 Review of Monitoring report submitted under condition 4.2.2. (Apr - Jun 2008)

Monitoring is mainly being undertaken as required by the permit with the exception of the following issues which

CAR ref FP3137UB/04082008


should be addressed for future returns

G 4 & - E2) - The leachate level (Table S4.1) within monitoring point L3Q was recorded as 39.39m AOD in April. The relevant limit is 39m AOD. Monitoring for May and June was below the trigger level. No Schedule 6 notification was received for this trigger level breach.

G4) - Groundwater (Table S4.4) - Dichloropropane - sample results are stated as <1ug/l, the limit is 0.1ug/l. Action - confirm why analysis is not being undertaken to the required level and what action is being undertaken to address this.

E1) - Landfill Gas - (Table S4.5) - Breaches of trigger levels have been recorded for points GM12F, GM013F, GM14F and GM15F. Schedule 6 notifications were received for these breaches.

Landfill Gas (Table S4.10) - No results have been provided for Landfill gas monitoring at the Manifolds on the gas collection system. Action - include within future monitoring

For the actions relating to Groundwater (Table S4.3) please submit a response by 15 August 2008

CCS4 CCS4 CCS4 CCS4


30/10/08 General Site visit and meeting to discuss

Landfill Gas Projects

Discussed proposals within email dated 21 October 2008 for surface emissions monitoring and use of separate flare on site for a trial period to determine the quality and flow of gas from separate areas of the site.

Action - Surface emissions monitoring - submit proposals for locations of monitoring points

Flare trial - Investigate alternative options for obtaining gas data as discussed. Submit revised proposals to the Agency.

During the visit the flare proposed to be used as part of the trial was operating. Permission to utilise this flare has not been provided.

A1) Separate flare connected and operating on site. Operation of this flare is not authorised by the permit and permission to undertake a trial had not been granted.

E1) Tables S4.2 and S4.3 details the permitted point source emissions from the installation. The additional flare has the potential to cause impact off site & is not an authorised emission point.

F1) Odours of landfill gas were detected on site downwind of the flare. The flare appeared to have extinguished during the visit and was venting landfill gas to atmosphere. Appropriate measures must be taken to prevent emissions from landfill gas from the site.

CAR Ref 30102008/YP3439SM

CCS 3 CCS 4 CCS4


ODOUR INCIDENT AT WINGMOOR FARM September 2004


ODOUR INCIDENT AT WINGMOOR FARM LANDFILL AND RESPONSE At 14:36 on Tuesday the 21st September 2004 the Environment Agency received a call from a member of the public reporting “very bad chemical smell from the landfill”. This report was followed by two further reports at 14:45 and 14:47. Agency officers contacted the landfill to make them aware that the EA had received complaints. Officers then drove to the site. On travelling along Stoke Orchard Road agency officers became aware of a strong phenolic odour when level with the entrance to the Wingmoor Farm site. They arrived on site around 16:00. When Environment Agency Officers inspected the waste cell they found that all waste that had been accepted by the site had been covered with APC. Despite the cover a strong phenolic odour was still evident. The officers spoke to the site’s manager. They were informed that contaminated soils accepted by the site had been the cause of the problem and that the landfill had put a stop to any more of this material being accepted. It was also agreed between the manager of the site and the Environment Agency officers that more cover was needed and this was instigated while the officers were on site. Reports of the smell continued to be received by the Environment Agency through the evening of the 21st September 2004. By around 18:20 reports stated that the smell had lifted. At around this time the Environment Agency also received enquiries from members of the public who had not been around to detect the smell but had been informed by neighbours, that a smell had existed earlier in the day. Some of the calls received on the 21st September 2004 reported that the odour had caused headaches, sore throats and tingly tongues. As a result of these reports the Environment Agency contacted Tewkesbury Environmental Health and attempted to contact the Primary Care Trust. This was done on the 21st September 2004. Reports continued to be received on the 22nd September 2004 with regard to the cause of the odour from the 21st September. Two reports from members of the public did say that they could detect the smell from the landfill. During the afternoon of the 22nd September 2004 an Agency officer returned to the site. Odour was not detectable downwind of the waste cell. Further reports were received from members of the public on the 23/09/2003 linking odours to the landfill. On all these occasions, Agency Officers did detect odours but the source of these odours was found not to be the landfill.

Environment Agency


REDACTED INCIDENT CONTROL LOG FOLLOWING ODOUROUS WASTE DEPOSITED AT GRUNDONS LANDFILL Date Name Address Phone Details

21/09/04 14.36hrs

******** * Huxley Way, Bishops Cleeve, Chelt, Glos, GL52 7XU

*********** NIRS REPORT 267681 “Very bad chemical smell possibly coming from landfill”

21/09/04 14.45

********* * Huxley Way, Bishops Cleeve, Chelt, Glos, GL52 7XU

*********** NIRS REPORT 267690 “Very bad smell possibly coming from Grundon site, caller would like a call back” Is prepared to make a statement.

21/09/04 14.47

********* * Huxley Way, Bishops Cleeve, Chelt, Glos, GL52 7XU

*********** NIRS REPORT 267690 “Strange smell coming from landfill today”

21/09/04 15.17hrs

********* Tewks BC PC Env Health *********** NIRS REPORT 267713 “TCP type smell in Voxwell area, BC, due east of landfill area. Wind from west. EHO colleague has attended following one or two public complaints and checked out malvern View Business Park, no problems found. Concerned smell may be due to chemical load received at landfill. If problem persists they will attend tomorrow.”

21/09/04 15.18hrs

********** * Huxley Way, Bishops Cleeve, Chelt, Glos, GL52 7XU

*********** NIRS REPORT 267690 “Chemical small in the air around Bishops Cleeve, possibly from landfill” Is prepared to make a statement.

21/09/04 16.25hrs

********** * Vilverie Mead, Bishops Cleeve, Chelt, Glos, GL52 7YY

*********** NIRS REPORT 267729 “Chemical small in the air, it was strongest as the caller drove past the landfill” Is prepared to make a statement


21/09/04 18.21

********** * Meadoway, Bishops Cleeve, Chelt, Glos, GL52 8NB

*********** NIRS REPORT 267759. “Awful smell came from Landfill between 15.00 – 16.00hrs today. Is lifting now. Is prepared to make a statement.

21.09/04 ********** As above *********** Following NIRS report. ********** very upset wanted to know what her baby had been exposed to as she was crying. Wanted to do a press release and wanted to know what to say. NG confirmed he would call back.

21/09/04 ********** EA *********** JR/NG informed SB of incident. Informed that SWARD wanted to do a press release, what could we say? SB confirmed we were ok to release initial details of incident.

21/09/04 ********** *********** Left message with standby officer for EHO to give NG a ring on mobile.

21/09/04 ********** *********** No answer.

21/09/04 18.35

********** Following NIRS report JR called. Reporting smell, JR fedback info from incident.

21/09/04 18.45

********** Following NIRS report JR called. Reporting he had been informed about smell by next door neighbour, JR fedback info from incident.

21/09/04 19.00hrs

********** ********** Following NIRS report JR called. Reporting a smell, JR fedback.


22/09/04 07.58

********** *************** email Wanted a briefing on the incident and asked for 4 questions to be answered.

NG replied to email with brief reply. Confirmed a full response would follow

22/09/04 Jeremy Reilly faxed PP at the waste labs

Nottingham waste lab Wanted to know if Grundons should have known if this material would have given rise to a strong odour.

22/09/04 09.07hrs

********** ********** Walking child in Bishops Cleeve. Child noticed odour and ************* noticed odour and wanted to report to EA

22/09/04 09.07hrs

********** ********** Had heard about the odour and wanted to know what it was. Had not smelt it.

22/09/04 09.47hrs

********** * Linworth Road, Bishops Cleeve, Chelt, GL52 8PA

********** NIRS REPORT 267802 “The smell has been very bad again for the last 36/48 hours from the landfill site” An asthmatic who ‘suffered’. Is prepared to make a statement.

22/09/04 09.43hrs

********** * Crown Drive, Bishops Cleeve, Chelt, GL52 8EF

NIRS REPORT 267802 “Very bad smell from landfill site again”

09.51 ********** ********** Called left message JR returned call. Wanted to chat with someone. That already spoke to ******** last night but wanted a bit more information

22/09/04 09.58

********** Email from TBC with list of complainants from the 21st. sent to Craig House, forwarded to Nick Green & Jeremy Reilly


22/09/04 10.45hrs

********** No address given ********** Wants to know what happened at Grundons yesterday - re: 'leakage'.

10.08 ********** Clerk of Bishops Cleeve ********** Had received numerous calls from local residents about the smell. Most of them have either already notified TBC or the EA. Gave his personal number FOR EMERGENCY USE ONLY *********

10.10 *********** Has found where the material originated. EWC 07/01/99. “Manufacture for sale or use of bulk organic chemicals. The first load was due to move on the 15/09/04 and the quantity to be moved was 140 tonnes to be moved in 20 t lorries making 7 loads. The waste has originated from Walters UK Ltd, Nanggarw Road, Caerphilly, CF83 2BF. Described as “Contaminated Pulverised Flue Ash with crushed drums. Total VOC <1000mg/kg, tph 22,000mg/kg “hydrocarbon contamination” Contact for the waste *****************

10.40 ********** Tewks BC Env Health ************ Called for update, NG gave him details of what we know. PK asked for a copy of the soil analysis for their reference. NG faxed at 11.30

10.40 Jeremy Reilly contacting Wales EA EO

JR called Ceri Jones – EO Cardiff – Informed that the waste originated from a former 1960’s haz landfill. Took fly ash and chemicals etc from Monsanto. Most of the material went to Trecatti Landfill before 16/07/04. Approx. 6,700 loads went into this landfill. The material that went to Grundons was a “Hot spot” they had not anticipated. Residents around this old landfill being remediated in the local area have complained of headaches. The Health Protection Agency are involved in monitoring etc

10.58 JR/NG spoke to Stuart Baker Updated SB on current position


11.00 Jeremy Reilly contacted PCT spoke to receptionist

************* *******not available but left message for her to call on JR’s mobile

11.54 to 12 JR called ********* *** Meadoway, Bishops Cleeve, Cheltenham, GL52 8NB

************* Explain to EA that it has happened before. She also requested that she be sent a copy of the permit and press release.

12.50 NG called ********** She is at work, can be contacted at 15.45hrs tonight

12.50 JR called ********** ************ Phone engaged

22/09/04 12.40hrs

********* Clerk Bishops Cleeve PC

*********** or ***********

Can still smell a slightly obnoxious smell, which he believes, is from Grundons. He lives at Woodmancote, apparently discussed with Nick yesterday. LW told him that the EA was visiting the site again this pm and would advise him of situation.

22/09/04 13.10hrs

********** Smelt the smell yesterday on the way to Huxley Avenue. Reporting this today. Had to take her inhaler, as the smell was so bad.

22/09/04 13.48

Mark Mcaree EA ****** Confirmed material was hazardous. Stopped going into Trecatti Landfill on the 16th Juy 2004.

22/09/04 15.00

NG called ********* ************ NG called, left message on answerphone.

22/09/04 15.12

*************** Wanted an update of what happened yesterday as there were lots of rumour goi9ng round the village. NG informed him of incident and early findings. **** asked if this would make any affect on the PPC decision made last week. Put ***** through to Natasha (Harvey Bradshaw’s PA)


22/09/04 16.30

*********** * Ashlea Maeadows GL52 7 WG

Did smell something yesterday chemical type odour but was difficult to tell, Has not smelt it today. Is very concerned about the whole situation.

22/09/04 16.49hrs

*********** Councillor Has not felt very well today, is going to see his doctor. Will give us a statement of ill effects.

23/09 G Tyler, PCT To give info to Toyin Ejidokun, consultant in communicable diseases. (JR) Information faxed through.

23/09 13:15

************ Letter can be released. Also given contact of EHO, ******** – *********. All this information passed to the PCT. (JR)

23/09/04 ************ ** Ratcliff Lawns, Southam, Cheltenham, GL52 3PA

*********** Very strong smell and flies from landfill. LW discussed with her – smells like manure according to ********. Different to the other day. SEE SR’s COMMENTS BELOW

23/09/04 ************ ** The Holt, Bishops Cleave, Chelt, GL52 8NQ

*********** Strong smell from landfill – “vile, foul, gagging smell” this afternoon. Different to smell the other day but definitely not manure. LW discussed with her. Conversation developed into general concerns about the landfills, Hazardous Waste. Role of the Agency etc. SHE WANTS A CALL BACK ASAP TO DISCUSS THE PERMIT, IN PARTICULAR HAZARDOUS WASTES TAKEN AT GRUNDONS. SEE SR’s COMMENTS BELOW.

23/09/04 18.43

Steve Roberts - visit to the area.

EA Stoke Orchard Road and the Wingmoor Quarry site entrance strong smell of ammonia from farm manure spreading on fields to the NW. Wind direction from the NW.


23/09/04 18.43

Steve Roberts EA Southam village –Acrid smell attributable to a bonfire burning plastic materials. Localised on the north side of the Race Course.

23/09/04 20.15hrs

**********

* Marlborough Close, Bishops Cleeve, Cheltenham, Gloucestershire GL52 8TJ

************ Strong smell from landfill this evening. Call taken by********– standby officer. Feedback given by LW on 24/09/04, to ******. Informed her that smell from spreading manure not the landfill.

23/09/04 19.40hrs

**********

* Murray Close Bishops Cleeve Cheltenham Gloucestershire GL52 8XE

************ Strong smell from landfill, different to the other day. Report to ********, Standby Officer. LW attempted feedback on 24/09/04 but no answer.

24/09/04 ********** * Harpfield Road Bishops Cleeve Cheltenham Gloucestershire GL52 8ED

************ Telephoned to ask what the smell was earlier in the week. She said it had been a ‘bleachy’ smell. She complained that her horses had irritated eyes on the Tuesday and she attributed this to the smell from the landfill. I advised her that we did not have expertise or evidence to confirm this and advised she seek advice from a vet. She also said that her daughter had complained of a sore throat as had people in the local butchers. I advised her of what had happened at Grundons on Tuesday and that the waste was no longer being received and the EA is investigating the matter. She asked to kept informed.

24/09/04

********** – in the vicinity of landfill

EA No odour detected in area of Bishops Cleeve landfills – 8.40am to 09.30am.


24/09/04 Ms Toyin Ejidokun PCT ************* JR received call from Ms Toyin Ejidokun. TE is concerned that EA had information regarding smell generated by this material but failed to prevent it coming to the Grundons site. TE would like a meeting with the EA and the Health Protection Authority. JR passed on message for Stuart Baker to call Ms TE.

24/09/2004 13.15

*********** * Birchfield Road Bishops Cleeve Cheltenham Gloucestershire Gl52 8LB

************ Strong ammonia smell thought to be from landfill. GD spoke to the informant to feedback.. Established that he was referring to an odour separate to the Tuesday incident. He described it as ‘like ammonia’ and he was sneezing. Informed him that source was likely to be farmer spreading manure. Told him his health concerns should be referred to GP.

24/09/2004 14.04

*********** * Springbank Road Cheltenham Gloucestershire GL51 0NH

************ GD spoke to informant and established that she was reporting Tuesdays incident retrospectively. She had seen the 'Echo' and wanted it to tbe logged that she had noticed the smell on tuesday afternoon. It was strong near the shops. She has a cold which she attributes to her visit to the Bishops Cleeve area on Tuesday. Furthermore her ‘Grandson was sent home from school on the same day because he was ill’. GD explained that an odour escape had occurred on Tuesday but the offending waste has now been sealed within the landfill. Recommended that she contact her GP for advice with regard to her health.

27/09/2004 15:47

*********** Not given Not given Caller reports that black smoke is coming from Grundons landfill. Incident inspected and fire was found not to be on land opposite the Grundons site.


28/09/2004 14:33

*********** Report that there is a landfill gas adour. This was detected off site immediately down wind of the site.

28/09/2004 *********** * Woodstern Way *********** Report of a smell like burning brake lines coming from the Grundons site. JR was on site at time of the complaint and was unable to detect such an odour. Visited ******* within 30-45 minutes of the complaint. On arrival at his address no smell was evident. ****** was determined to attribute the smell to Grundons.

29/09/2004 Jeremy Reilly called ******of Celtic contractors

*********** Speak to ******** of Celtic contractors *********. He informs me that the material has been sent to Purton Landfill. He believes that all the material had been accepted at that site.

29/09/2004 Jeremy Reilly called ***********

*********** Speak to ******** and enquire about monitoring that was conducted at the Caerphilly site. I am informed that the contractors carried out the monitoring and that this was later confirmed by the council

29/09/2004 JR speaks ********** Wallingford

*********** Had problems with the same material being accepted at Purton Landfill. Send letter from the Welsh region and also information from surveys conducted by Environmental Health.


Wingmoor Farm Forum - Liaison Group 17 July 2007 Briefing on Outcome of Odour Incident Investigation We (the Environment Agency) have completed the investigation into the odour incident that occurred at Wingmoor Farm West Landfill on 21 September 2004. We have written to Grundons to let them know that we will not be taking enforcement action against them for this incident. I would like to explain the reasons why there has been a delay in completing the investigation and notifying you about the outcome. As you are aware, this was a complex investigation covering a waste producer in Wales, the Grundons site in the Midlands and another landfill site in Swindon. This meant we had to collect the evidence gathered by three different Regions to get the overall picture. The law is very clear where it requires that the waste producer must tell any person who transports or disposes of their waste about the nature of their waste and any measures needed to handle it. In this case we found that the waste producer had failed to provide Grundons with adequate information about the odorous nature of the waste. The PPC permit for Wingmoor Farm West require the Operator to take appropriate measures to prevent or reduce odour emissions from the site. Three loads from the Castelgate development in Caerphilly were received at the Wingmoor Farm Landfill site during the morning of 21 September without causing problems. A further eight loads arrived at the site between 1337 and 1422. We believe one or more of these loads caused the odour complaints. Our investigation established that Grundons took immediate steps to cover the material after it was deposited and contacted the waste producer and rejected further loads that were on the way to the site. We decided that Grundons had taken all appropriate measures to reduce further odours and had complied with their PPC permit. The permit also requires the operator notifies us without delay about such an incident. The Environment Agency and Grundons had a difference of opinion about whether they had breached this condition of the permit. Grundons also questioned the legal status of warning letters. It is this difference that has caused the delay in letting you know about the outcome of the investigation. In order to resolve this disagreement, solicitors were involved and Counsels opinion was obtained. Dr John Adams, the Area Manager, reviewed the evidence and considered the Counsel’s opinion. He has decided that it is not clear whether there had been a clear opportunity for Grundons to Notify the Environment Agency whilst they were concentrating on dealing with the incident to minimise its impact. The Environment Agency maintains its view that it has the right to issue warning letters. I should like to point out that the Environment Agency has learned some very important lessons about this incident. In particular, we have better communication between our Regions about difficult or rejected loads. We have also reviewed the way we handle large, complex investigations that involve more than one Region. I appreciate that this is the first time that you have heard the outcome of this investigation. I am happy to answer any questions now, however, given time constraints of this meeting I would like to ask whether you would like me to arrange a meeting to provide any further information you require or give a fuller brief on the investigation.


Stuart Baker Environment Manager


Incidents reported to the Environment Agency in 2008 for the area surrounding

the Bishops Cleeve/Stoke Orchard landfills.


Incidents reported to the Environment Agency for the area surrounding

the Bishops Cleeve/Stoke Orchard landfills. January to March 2008.

Date Time Report Details Informant location

4th January 16.20hrs Very bad smell from the Grundon's site

No attendance, operators informed, no abnormal operations

Deans Way Bishops Cleeve

5th January 08.43hrs Reporting a strong methane odour as he drove past the Grundon Waste Site on Stoke Road in Bishop's Cleeve.

No attendance. Stoke Road. Bishops Cleeve

7th January 09.11hrs Complaint about the waste tip in Bishops Cleeve - the stench coming from there is absolutely appalling over last two weekends, and it's getting worse.

No attendance. Banady Lane, Stoke Orchard

18th January 15.40hrs Odour complaint - Wingmoor Farm - bad now - when gusting 5/10 normal smell

No attendance. Stoke Road. Bishops Cleeve

22nd January 09.16hrs Reporting a bad stench coming from Bishop's Cleeve, smell is an 8 today.


27th January 23.26hrs Bad smell from Bishops Cleeve landfill site this evening, terrible stench at the moment, just noticed. Not asking for a call back.

No attendance. Huxley Way, Bishops Cleeve

30th January 16.02hrs Grundon Landfill smelling very bad this morning and this evening (30/01/2008).

No attendance. The Highgrove, Bishops Cleeve

6th February 17.13hrs Odour complaint - Bishops Cleeve site - bad now 4/10 normal smell. Happening several times a week at present - could be smelt from Tesco's site.

No attendance Huxley Way, Bishops Cleeve

7th February 09.30hrs Odour complaint. Stoke Orchard tip at Bishops Cleeve. Smell was really bad last night. For logging only.

No attendance. No location

8th February 17.51hrs Awful smell from Grundon’s or the tip.



18.01hrs Horrendous smell of rotten food from one of the waste sites

No attendance. Mill Lane, Stoke Orchard

10th February 18.29hrs Disgusting stomach turning smell from landfill site nearby.

No attendance. Elmstone Hardwicke

11th February 09.35hrs Odour complaint - Bishops Cleeve - bad yesterday 7/10 - only 2/10 this morning

No attendance. Stoke Road, Bishops Cleeve

11.15hrs Can smell landfill gas smell. Has been around over the weekend and happening now.

Operator attended, identified bitumen odour. Agency Officer attended no odours detected

Bayshill Lane, Cheltenham

12th February 09.44hrs Odour at the Landfill site at Stoke Rd Bishops Cleeve. Is smelling very bad

Officer attended but could only detect a chicken manure smell

Stoke Road, Bishops Cleeve

10.29hrs Caller called to say the site on Stoke Orchard rd in Bishops Cleeve is a 9/10

Rosehip Way, Bishops Cleeve

10.32hrs Odour complaint - Bishops Cleeve - bad today 8/10.

Station Road, Bishops Cleeve

10.39hrs Landfill smelling very badly over weekend, last night and now. Very strong smell, can smell when windows and doors are closed.

Minster Close, Bishops Cleeve

11.16hrs Odour complaint - Bishops Cleeve - bad now 8/10 normal smell - since 8am

Gatcombe Park, Bishops Cleeve

13th February 08.46hrs Odour complaint - Bishops Cleeve - bad now and overnight 8/10 normal smell gassy sickly smell

No attendance. Rosehip Way, Bishops Cleeve

11.56hrs Reporting landfill smell present now at her property. 12am until midday yesterday, from 11am until now today

No attendance. Bayshill Lane, Cheltenham

17th February 01.48hrs Odour complaint - Bishops Cleeve - bad now and overnight 8/10 normal smell gassy smell.

No attendance. Huxley Way, Bishops Cleeve

10.41 Odour complaint about Wingmoor Farm landfill site: usual smell, 9/10 this morning, has been very bad every day since last Sunday

No attendance. Lowdilow Lane, Elmstone Hardwicke

18th February 09.49hrs Odour complaint - Bishops Cleeve - bad now 10/10 normal smell - started about 15mins ago

No attendance.


10.01hrs Odour complaint - Bishops Cleeve - bad now, 8/10

No attendance.

The Withers, Bishops Cleeve


23.01hrs Smell from Bishops Cleeve, a plastic type smell, has been re-occurring quite a lot recently, about a 4 out of 10 this evening. On Saturday it was gassy smell mixed with a burning type smell.

No attendance.

Huxley Way, Bishops Cleeve

11.59hrs Odour complaint about Wingmoor Farm landfill site: usual smell, 9/10 this morning

No attendance.

Lowdilow Lane, Elmstone Hardwicke

19th February 08.46hrs Odour complaint - Woodmancote - bad now (not his job to rate the smell) Believe this to be Grundons.

No attendance.

Britannia Way, Bishops Cleeve

20th February 09.11 Strong smell of eggs from the nearby landfill site

No attendance.

Britannia Way, Bishops Cleeve

25th February Site audit undertaken at Cory Wingmoor Landfill 24th February 18.16hrs Bishops Cleeve landfill site,

possibly Wingmoor farm. Started 45 minutes ago. Burning plastic smell. Rated a five out of ten.

No attendance.


26th February 21.09hrs Methane/ gas type smells ( rated at 3 out of 10 ) emitting from the Bishops Cleeve landfill/waste site

No attendance.


28th February 10.22hrs Complaining about landfill gas smell from Wingmoor Farm. Was a 9/10 at 6am this morning now gone.

No attendance.


17.55hrs Smelling gas type smells (rated at 7 out of 10) emitting from the Bishops Cleeve landfill/waste site.

No attendance.

Murray Close, Bishops Cleeve

1st March 17.31hrs Smell from Wingmoor Farm landfill sire in Bishops Cleve - about a 4 out of 10, just started. It's a gassy type smell.

No attendance.


5th March 11.00 – 13.00hrs

Site inspection undertaken at Grundon Wingmoor Farm Landfills & APC treatment facility.

5th March 19.21hrs Odour complaint - Bishops Cleeve - 3/10 normal smell.

No attendance.

Blackberry Grove, Bishops Cleeve

10th March 19.35hrs Odour complaint - Bishops Cleeve - bad now 7/10 normal smell (on average odour is bad twice a week)

No attendance Haycroft Close, Bishops Cleeve

20.39hrs Odour complaint - Bishops Cleeve - bad 4/10 normal gassy smell

No attendance Huxley Way, Bishops Cleeve

12th March 15.19hrs There is a very strong smell of burning bakerlite from the Wingmoor Farm direction again

No attendance Stoke Road, Bishops Cleeve


13th March 12.52hrs Caller had a visitor to his house this a.m. who drove past Wingmoor farm site and noticed a horrible smell which he wished to report.

No attendance Stoke Road

20.33hrs Absolutely disgusting sulphur type smell from the landfill site - rated 10 out of 10 at least. Please call back

Officer attended next day, no odours detected off site.

Farriers Reach, Bishops Cleeve

20.36hrs Gassy smell from tip this evening

Stoke Road, Bishops Cleeve

20.38hrs Absolutely disgusting sulphur type smell from the landfill site - rated 10 out of 10 at least.

Minster Close, Bishops Cleeve

14th March 09.26hrs Very bad smell coming from Bishop's Cleeve, it is a 7/8

Officer on site between 12.00 – 14.30hrs. No odours detected.


17th March 22.16hrs Caller is reporting that the landfill at Wingmoor Farms is very bad has said that is an ongoing problem. It was a 8/9 out of ten in the bedroom.

No attendance Orchard End, Elmstone Hardwicke

20th March 12.44hrs Very bad smell coming from the Bishop's Cleeve waste site, it is a 6/10.

No attendance Rosehip Way, Bishops Cleeve

26th March 20.31hrs Reporting that smell from Stoke Orchard Tip in Bishops Cleeve at Wingmoor farm. Says its 8/9 out of 10 every time air goes cold and no cloud cover it gets bad.

No attendance Hanson Gardens, Bishops Cleeve

27th March Site audit undertaken at Cory Wingmoor Landfill 27th March 16.33hrs Odour Compliant - Bishops

Cleeve - bad now 7/10 normal smell

Officers on site all day undertaking odour assessments as part of audit. Wind blowing towards the SW, Bishops Cleeve effectively up wind.

Yarlington Close, Bishops Cleeve

17.44hrs Wingmoor farm is smelling 5/6 out of 10

No attendance Kingsclere Drive, Bishops Cleeve


April-June 2008


12/04/2008 15.03hrs Smell from Bishop's Cleeve, it is a 2/3, it was smelling all last night and today.

Only 1 compliant received. No attendance, operators informed no abnormal occurrence on site


29/04/2008 18.39hrs For logging purposes...complaint of odour...Stoke Orchard landfill...Cheltenham

No attendance. Operators informed next day. No issues identified.

Elmstone Hardwicke

05/05/2008 20.04hrs Landfill gas complaint of methane rated 10 out of 10 tonight.

Standby officer contacted informants. Operators contacted next day. No issues identified on site.

Elmstone Hardwicke

20.12hrs Smell from Stoke Orchard/Bishops Cleeve this evening, in the last hour.

Elmstone Hardwicke

07/05/2008 09.38hrs Horrible smell from landfill. Has been bad for around 5 days.

When informant called by Officer, odour not present. No attendance required. Operators informed.

Elmstone Hardwicke

16/05/2008 19.09hrs Landfill at Stoke Orchard, Cheltenham smelling badly tonight.

Report logged for information only. Only 1 call that evening. No attendance undertaken.

Elmstone Hardwicke


18/05/2008 17.27hrs ******** called to report the smell of landfill gas emanating from the Wingmoor Farm landfill site - wind direction has been N Westerly over the last 8 days and periodically each of the 8 days the site has smelt - when the odour is detectable it is rated as a 6 or 7 out of 10. Please pass this information onto EA Officer Nick Green as He is pretty fed up with the site now.

Standby Officer took call. Passed to Nick Green next day. Inspection undertaken on the 19th weather patterns changed, no odours detected.

Elmstone Hardwicke

19/05/2008 10.51hrs Landfill odour has been bad over the weekend, not been able to enjoy sitting in the garden. At work at the moment so cannot confirm if odour is present now.

See above box Elmstone Hardwicke

24/05/2008 19.46hrs Bad smell from the Bishops Cleeve landfill site rated quite strong in last hour like phenols of burning waste.

Operator informed. No fire incidents. No attendance.

Delphinium Drive, Bishops Cleeve.

27/05/2008 20.12hrs Smell from Bishops Cleeve landfill site, described as a chemical type smell rather than landfill smell - described as the smell you get when you open a plastic smell. Rated as a 6/10 and also came and went on and off last week too.

See notes section at the bottom of this report.

Honeysuckle Way, Bishops Cleeve.


14/06/2008

08.33hrs 21.49hrs 22.05hrs

Strong smell from the Bishops Cleeve landfill site last night 9/10. Smell from one the waste sites in Bishops Cleeve rated a 4 out of 10. Bishops Cleeve landfill smelling tonight. Rated a 7/10.

Notifications passed to Operators.

Kingsclere Drive, Bishops Cleeve. Rosehip Way, Bishops Cleeve. Huxley way, Bishops Cleeve.

16/06/2008 21.04hrs Very strong burning

rubber /chemical smelling coming from Wingmoor farm waste site, Cheltenham.

Operators confirmed no source of fire or waste type that could produce specified odour. See notes at the bottom of this report.

Cutsdean Close, Bishops Cleeve

17/06/2008 12.51hrs Last Thursday (12th June) between 10pm and 12am there was a terrible stench from the Wingmoor Landfill site. Always present when there is a North wind.

No attendance required.

Cheltenham Town Centre.

27/06/2008 21.13hrs Stoke Orchard tip smelling tonight (or Grundons). Rated a 5/10. Last time it was "toxic vapour". Overheated electric wiring is what it smells like.

Standby officer contacted informant who confirmed that the smell had been coming and going. Operators informed next day, no issues identified. See notes at the bottom of this report.

Wood Stanway Drive, Bishops Cleeve.


July to September 2008.


03/07/2008 16.28hrs Bishops Cleeve landfill site smelling this afternoon.

Operators informed of incidents. Grundon drove around Bishops Cleeve area but could not detect any odours.

Rosehip Way, Bishops Cleeve.

16.42hrs Bishops Cleeve landfill site smelling this afternoon. The smell is an 8 out of 10

Haylea Road, Bishops Cleeve.

07/07/2008 14.23hrs Bishops Cleeve landfill site smelling today. Started in the morning, rated a 7

Officer attended. No odours detected during assessment.

Gatcombe Close, Bishops Cleeve.

08/07/2008 15.14hrs Reporting a smell of petrol in the air. Thinks it might be coming from the waste sites there but is not sure.

Operators contacted. Not thought to be landfill

Lyndley Chase, Bishops Cleeve

17/07/2008 12.31hrs Strong smell from the Wingmoor L/F site - smell is a chemical type smell 3/10

Operators informed. Grundon drove around Area, no smell detected.

Stoke Park Close, Bishops Cleeve

16.07hrs Bishops Cleeve landfill site smelling today, it is a 6/7 out of 10. It is a sweet smell.

Operators informed. Grundon drove around area. Agricultural Silage smell identified.

Meadoway, Bishops Cleeve

26/07/2008 08.14hrs reporting slight odour coming from Grundons waste site, Stoke Orchard , Bishops Cleeve. ( only 2 or 3 out of 10 at the moment).

No action taken. Low odour reported. Only 1 call.

Delphinium Drive, Bishops Cleeve

30/07/2008 17.44hrs Is reporting Wingmoor Farm smelling. 7/10 It was just the same this time yesterday.

Operators informed. Weather data checked. Wind direction opposite from site to location.

Hillside Gardens, Woodmancote

17.55hrs Is reporting smells from Wingmoor Farm or Cory's 8/10 was the same yesterday.

24/08/2008 10.45hrs Complaint about infestation of flies. believe from the local Landfill site at Elmstone Hardwicke

Both operators informed. Both Grundon & Cory sprayed as normal on the Sunday. Reports produced from contractor during spray. Low activity recorded at both sites


31/08/2008 10.04hrs Wingmoor farm landfill site smelling at 6am this morning rated a ten.

Both operators contacted on 1st October. No issues identified over weekend.



12/09/2008 08.23hrs There's a really bad smell coming Stoke Orchard recycling plant, like methane.

Operators contacted Cory site manager was already around area at 08.00hrs, no odour identified. Cold foggy, still morning.

Dean Lane, Stoke Orchard

22/09/2008 10.28hrs Called to report that Stoke Orchard tip has smelt appallingly all weekend, Friday night, Saturday night and Sunday night.

Operators informed. No issues identified on sites. No further action

Elmstone Hardwicke.

24/09/2008 19.27hrs Report from Cory Environmental Area Manager that landfill fire has been reported by member of public. Site staff on route to site.

Numerous updates from Operators. Incident managed as according to emergency procedures. 21.00hrs – Operators confirmed fire was out.

Cory Environmental Wingmoor Landfill site.

October to December 2008.


15/10/2008 16.34hrs Strong smell in the area this afternoon, caller believes it is coming from the Bishops Cleeve landfill site.

No attendance by Agency. Reporter considerable distance from site. Only call on day

Frank Brookes Road, Cheltenham

24/10/2008 18.01hrs Bishops Cleeve landfill site smelling 9/10 Gas smell

Attendance by Agency Officer, confirmed that the Grundon Quarry site was smelling. See note 1


30/10/2008 10:00 Inspection at Wingmoor Quarry landfill EA Attendance

06/11/2008 16.45hrs There's a really bad smell coming Stoke Orchard recycling plant, 9/10.

Operators contacted, Wind blowing from sites to Stoke Orchard. Cory were undertaking screening of compost on that day. No other obvious sources present.

Dean Lane, Stoke Orchard

17.20hrs Very strong smell coming Stoke Orchard waste recycling plant.

Mill Lane, Stoke Orchard

12/11/2008 17.07hrs Foul rotting rubbish smell coming from Grundons site at Bishops Cleeve

Officer attended, not substantiated

Huxley Way, Bishops Cleeve.

19/11/2008 16.51hrs Very strong smell coming Stoke Orchard waste recycling plant, 8/9 out of 10.

Operators contacted, no source of odour

Banady Lane, Stoke Orchard

21/11/2008 10:00 Site Visit to Grundons as part of ongoing review of landfill gas management EA Attendance

23/11/2008 00.28hrs Stench from the tip is quite awful. Rated a 9 out of 10. A rotting food type of smell,

No attendance. Operators contacted next day, no issues on site

Mill Lane Stoke Orchard

27/11/2008 10.00hrs Very strong smell coming from Stoke Orchard waste recycling plant on Sunday, Tuesday and today, 9 out of 10.

No attendance – Not smelling when called back. Information passed to sites. No issues identified.

Banady Lane, Stoke Orchard


28/11/2008 16.40hrs Report the foul rotting rubbish smell coming from Grundons site at Bishops Cleeve, it is a 10 out of 10

No attendance, not smelling when called. Operators informed, no issues identified.

Deans Way, Bishops Cleeve

03/12/2008 16.39hrs Bishops Cleeve landfill site smelling 9/10 Also they have sent out road sweepers which have flooded the road in water this is turning to Ice on the road and is going to be very dangerous.

Road sweeper was in operation but not using water. Road by stoke Orchard very icy. Very cold weather.

Deans Way, Bishops Cleeve

5/12/2008 15:00 Site visit for PPC Compliance team leader to view the sites. EA Attendance

06/12/2008 09.00hrs Very strong smell possibly coming from Stoke Orchard waste recycling plant can not be sure. 9 -10 out of 10

No attendance, operators informed, wind blowing in opposite direction.


11/12/2008 15.49hrs Caller reporting the smell from Grundon waste site it can be smelt from the bottom of her garden the smell is also very strong along Stoke Lane, has been very bad since late last night and is still the same today.

Officer attended. Substantiated odour from Grundon site. Actions implemented to investigate and remediate. See note 1


12/12/2009 12.00 – 16.00hrs

Inspection at Cory Wingmoor facility. EA attendance.

19/12/2008 15.57hrs Bad Odour report regarding landfill site Stoke Orchard, reporter living 1.5 miles away from site. Windows shut no smell in house.

No odour when called. No attendance

Kayte Lane, Bishops Cleeve

25/12/2008 09.51hrs Caller reporting a landfill gas smell in the area which he thinks is coming from The Wingmoor Farm complex. Absolutely terrible last night all evening not only in the area of the callers property very bad. Stretched on Tewkesbury Road and into Cheltenham. Again this morning outside conditions have changed, now east breeze so its moving it towards callers house.

No attendance Elmstone Hardwicke

30/12/2008 18.07hrs Caller reporting a bad odour from a landfill in the area, not sure which one. It started at about 16.30. Gassy smell not indoors.

No attendance Elmstone Hardwicke

Note 1. The operator is undertaking a number of different actions as part of a review of the management of landfill gas at Wingmoor Quarry. These include the submission of an updated landfill gas risk assessment, surface emissions monitoring and investigations into upgrading the existing engine.


Examples of Quarterly Operator Performance Summary Reports Presented at Wingmoor Liaison Forum


S. Grundon (Waste) Ltd Wingmoor Waste Management Site Operator Performance Summary – July to Sept 2008 Wingmoor Treatment Plant Permit: NP3831ST (APC Plant only)

Compliance Assessment Permit Breach 04/08/08 Review of monitoring report CAR Ref: NP3832ST/040808

Review of monitoring report for Apr – Jun 08. Monitoring undertaken as required. No issues identified

Review of data CAR Ref: 05082008/NP3831ST

Review of Hazardous waste consignee returns: Identified acceptance of a waste streams not included on the permit. A copy of the Consignment note for this movement was reviewed as part of the recent audit. The CN confirmed the waste was accepted at the site under EWC code 11 01 06 which was not permitted. For this movement the pre acceptance and acceptance procedures failed to ensure that the waste stream was permitted under the permit before being accepted. Recommendations regarding the procedures are included within the full audit report relating to waste acceptance for the site. Operator to review both the classification and EWC code for this waste stream. The waste stream may be classified as non hazardous waste and a different EWC code (11 01 11 or 11 01 12) may be more appropriate following this assessment.

Audit - Review of pre acceptance and acceptance procedures & site operations CAR Ref: NP3831ST/160808

• C2 Breach of operating techniques – Pre acceptance and acceptance procedures & Site operations do not accord with the sector guidance note (detail included within separate audit report)

Wingmoor Quarry Permit FP3137UB (Non-hazardous) (Previously YP3439SM & BU4309)

Compliance Assessment Permit Breach 16/07/08 Routine inspection CAR Ref: 5/160708/YP3439SM

• C4 Localised odour of landfill gas along the haul road to the tipping face. Additional clay was placed on this area following the previous inspection. Additional clay to be placed further along the road to fully address the issue.

• Odour from vent on abstraction well on former east site. Operator to identify what measures can be adopted to address the odour from the vent.

22/07/2008 – Amendments to working plan

Agreement to updates to the working plan. Changes related to updates of the monitoring sections following the installation of additional points.


04/08/08 Review of monitoring report CAR Ref: FP3137UB/040808

• C4 Breach of leachate level within one borehole. Scored for both the breach and failure to notify the Agency as required.

• C4 Breach of Landfill gas trigger levels in June. Details on previous meetings Schedule 6 summary

• C4 Monitoring not provided for landfill gas at the manifolds of the gas collections system as required by the permit.

• Analysis is not being undertaken to the required level for Dichloropropane within Groundwater samples.

Review of waste summary returns CAR Ref: 05082008/FP3137UB

Review of waste returns for Apr- Jun. The returns were received within the required time. No issues identified with the return

Wingmoor Farm (West) Permit BU3671 (Hazardous)

Compliance Assessment Permit Breach 21/07/2008 Changes to Procedure for Handling and Disposing of Asbestos received on 15 July 2008

• Agreement given to changes to sections 2, 5 and 12. These relates to the location of the disposal area within the cell and recording of these deposits.

• Agreement not given for changes to sections 7 and 10 relating to use of a pressure washer during disposal and to wash the back of the vehicle following tipping. Currently the pressure washer should be used for all loads. Proposal to amend to

• use during asbestos disposal operations if the material is identified as being potentially dusty and

• the body and back of vehicles delivering asbestos are first checked to ensure they are clean and not contaminated with asbestos. If necessary a pressure jet wash will then be used to clean off the back of the vehicle.


Review of Monitoring Report CAR Ref: BU3671IY/04042008

• C4 Breach of landfill Gas trigger levels in June as detailed on previous meeting Schedule 6 summary

• C4 Discrepancies within monitoring data 1. pH not provided monthly for surface water, 2. Point GM23 missing from landfill gas

monitoring – reported on Non hazardous landfill permit, point covers both sites

3. Atmospheric pressure missing from in waste spike monitoring results 4. Temperature missing from Groundwater results

• Analysis is not being undertaken to the required level for Dichloropropane within Groundwater samples.

Review of data CAR Ref: 05082008/BU3671IY

Review of Hazardous waste consignee returns. Identified acceptance of 2 waste streams not included on permit.

Copies of the consignment notes for these movements were reviewed. 10 01 09 - sulphuric acid - the EWC code on the CN was 11 01 09 which is permitted at the site. Data entry error on the HW returns 13 01 10 - mineral based non-chlorinated hydraulic oils - this waste stream was accepted at the Bishops Cleeve treatment plant not the landfill - Data entry on HW returns. This waste stream will be coded as 13 05 07 for future movements to the treatment plant. No breach of Permit recorded as wastes were not accepted to the landfill.

Review of WAC data 11/08/2008

Review of WAC data for conditioned APC residues for May 07 to February 08 to determine whether WAC limits are being achieved. Breaches for lead (2 samples) and DOC (2 samples) were identified. Number of actions on operator by to

• Review action taken following these breaches • Confirm analysis being undertaken for organic

parameters • Confirm why Schedule 6 notifications were not

submitted and take action to correct this for future breaches

• Justify compliance sampling regime for waste stream

Response to actions ongoing 16/09/08 Routine inspection CAR Ref: 160908/BU3671IY

Site Visit – No issues


Schedule 6 Notifications received – April to June 2008

Monitoring & Data Performance Review

Wingmoor Quarry Permit MP3531UM (variation no FP3137UB) (Non-hazardous)

(Previously YP3439SM & BU4309) Date of Emission Breaches identified –

Monitoring & data

Operators Comments Environment Agency Assessment

11 July 08 Landfill Gas Monitoring - CO2 above limit at 1 monitoring locations (GM13F Limit 4.0% - measured value of 6.5%)

Continued monitoring of Sample Points as per Permit Conditions and analysis of results in order to determine potential trends. No Methane recorded at well. CO2 believed to be naturally occurring. Recent spiking along this section of boundary has shown no significant CO2 emissions.

No Methane (CH4) present. CO2 level only slightly over trigger. Monitoring from 2005 to present indicates similar trends during summer months. Await monitoring from next month. Previous months monitoring recorded same locations over trigger.

8 Aug 08 Landfill Gas Monitoring - CO2 above limit at 2 monitoring locations (Limit 4.0% - measured value of GM13F - 5.6% and GM15F -4.9%)

Continued monitoring of Sample Points as per Permit Conditions and analysis of results in order to determine potential trends. No Methane recorded at well. CO2 believed to be naturally occurring. Recent spiking along this section of boundary has shown no significant CO2 emissions.

5 Sept 08 Landfill Gas Monitoring - CO2 above limit at 2 monitoring locations (GM15F Limit 4.0% - measured value of 4.2% and GM9Q Limit 7.7% measured value of 12.3%)

Continued monitoring of Sample Points as per Permit Conditions and analysis of results in order to determine potential trends. No Methane recorded at well. CO2 believed to be naturally occurring. Recent spiking along boundary has shown no evidence of CO2 emissions.

No Methane (CH4) present. CO2 level only slightly over trigger. Monitoring from 2005 to present indicates similar trends during summer months.


Wingmoor Farm (West) BU3671Y (variation no GP3538MM) (Hazardous) Date of Emission Breaches identified –

Monitoring & data

Operators Comments Environment Agency Assessment

02 June 08 Breach of suspended solids (Limit 50mg/l - measured value of 70mg/l)

Sample taken following significant rainfall during previous few days. No discharging from upstream discharge point SW2DPF prior to or during sampling. Suspended solid levels believed to be caused by natural run-off processes from undeveloped land at rear of site.

Agree with operators assessment

18 July 08 Landfill Gas Monitoring - CO2 above limit at 2 monitoring locations (Limit 4.4% - measured values of 6.0% and 6.4%)

Continued monitoring of Sample Points as per Permit Conditions and analysis of results in order to determine potential trends. No Methane recorded at boreholes. Boreholes GM36F and GM38F are newly installed boreholes not bordering any disposal cell. CO2 not detected during in-waste spike point monitoring of disposal cell at Wingmoor Farm West landfill. CO2 therefore believed to be naturally occurring

No Methane (CH4) present. CO2 level only slightly over trigger. Monitoring from 2005 to present indicates similar trends during summer months. Await monitoring from next month. Previous months monitoring recorded 4 locations over trigger, 1 has returned to compliance.

15 Aug 08 Landfill Gas Monitoring - CO2 above limit at 3 monitoring locations (Limit 4.4% - measured values of 4.8%, 6.3% and7.3%)

Continued monitoring of Sample Points as per Permit Conditions and analysis of results in order to determine potential trends. No Methane recorded at boreholes. Boreholes GM35F, GM36F and GM38F are newly installed boreholes not bordering any disposal cell. CO2 not detected during in-waste spike point monitoring of disposal cell at Wingmoor Farm West landfill. CO2 therefore believed to be naturally occurring.

As above

12 Sept 08 Landfill Gas Monitoring - CO2 above limit at 3 monitoring locations (Limit 4.4% - measured values

Continued monitoring of Sample Points as per Permit Conditions and analysis of results in order to determine potential

As above – awaiting results of weekly CH4 monitoring


GM35F 6.0%, GM36F 8.4%; GM38F 11.7% & CH4: 0.5% - limit 0.5%

trends. Boreholes GM35F, GM36F and GM38F are newly installed boreholes not bordering any disposal cell. CH4 and CO2 not detected during in-waste spike point monitoring of disposal cell at Wingmoor Farm West landfill. Despite background readings having not yet been established, as agreed with the EA and in line with section 9.2.2 of the Working Plan, weekly monitoring of CH4 at GM38F to commence until CH4 levels drop below 0.5%. No CH4 recorded at any other external borehole across site. The data available regarding site operations past and present, borehole drilling and installation, and landfill waste acceptance criteria indicate that the presence of both CH4 and CO2 is due to non-site related processes, and therefore no detrimental scoring against the site is expected. As agreed with the EA, review of results from these new boreholes to be undertaken once seasonal trends are understood, and background levels will be determined thereafter

Reported Incidents Please see NIRS table for reported incidents


CORY Environmental Ltd

Wingmoor Landfill Operator Performance Summary – October to December 2008 Cory Wingmoor Landfill PPC Permit: XP3633XP

Compliance assessments Permit Breach/comments

12/12/2008 – Inspection of facility CAR Report Ref: I/121208/XP3633XP

• No issues identified. • Low odour present

12/06/2008 – Review of operator monitoring report July to September 2008. CAR Report Ref: RDR/150109/XP3633XP

• Breach for Carbon dioxide in boreholes. No methane present and therefore considered natural. CCS 3 scored.

• Breach of groundwater triggers for ammonia and potassium. Limits slightly above triggers. CCS 3 scored

• Breach of notifications. Breaches in groundwater triggers have not had schedule 6 submissions. CCS 3.

• Breach of reporting requirements. Phenol & mercury determinants missing from submission. Operator asked to submit.

Failures in Schedule 6 submissions and missing monitoring data is due to change in Company procedures in managing monitoring.

WML: 48037 Composting, Wood chipping & Fridge Storage

Site Inspections Licence Breach 12/12/2008 None identified

PPC Permit: XP3633XP Schedule 6 Notifications received – October to December 2008

Monitoring & Data

Date of Emission

Breaches identified – Monitoring & data

Operator Comments Environment Agency assessment

There have been no notifications submitted


Reported incidents Please see separate document.

Bishops Cleeve Neighbourhood Health Profile October 2005

S:\GENERAL\Scrutiny Committee - Health\reports\Meetings 2009\13th March 2009\Item 10 HIA Appendix A Bishops Cleeve Health Profile - October 2005.doc 1

In response to the concerns raised by local people about the impact on their health of a local hazardous waste landfill site, Cheltenham & Tewkesbury Primary Care Trust (PCT) has undertaken a review of the evidence of the health experience of local people compared with elsewhere in the county. In this profile we have addressed in more detail two areas which have been of continuing local concern; cancers and congenital malformations. However it should be noted that studies from elsewhere do not currently suggest a link between landfill and cancers and the evidence on the association between landfill and congenital malformations is inconsistent and inconclusive. Locally we have looked for both statistically significant clusters and trends over time. The Bishops Cleeve Neighbourhood Health Profile presents a series of data items and compares them with results for larger areas for example Cheltenham & Tewkesbury PCT, Tewkesbury LA or Gloucestershire as a whole. This analysis is available to the public and may be quoted, re-used and freely published on websites. For the purposes of the profile we looked at the population living in the urban area of Bishop's Cleeve (including Woodmancote) as mapped by Ordnance Survey. The postcodes for this area were captured by GIS technique and compared with the Exeter database of people registered with a General Practice. Where this wasn’t possible an approximation of electoral ward based data to the urban area was used. Population Profile

In December 2004 there were 12 996 residents of the urban area of Bishops Cleeve. The structure of the population was similar to the rest of the PCT and county. Analysis of the data shows that there are fewer young people in their late teens and early twenties but higher proportions of those in their thirties and forties and also of those aged 70 years and over. There is no evidence for a higher prevalence of infants and young children in the area. Population Structure

Bishops Cleeve Tewkesbury LA C&T PCT Glo’shire

0-4 yrs 3.88 3.97 3.91 3.99 05-14 yrs 11.44 11.95 10.89 11.96 15-24 yrs 10.05 10.91 13.23 12.19 25-44 yrs 28.09 26.36 29.18 27.23 45-64 yrs 25.42 27.47 24.75 26.36 65-74 yrs 10.06 9.69 8.49 8.92 75-84 yrs 7.78 6.85 6.66 6.62 85+ yrs 3.27 2.79 2.88 2.73 All ages 100.00 100.00 100.00 100.00 Source: Exeter database extract – January 2005

Appendix A



Comparison of Age Profile of Bishops Cleeve Residents with other aress

0

5 10 15

20 25

30 35

0-4 05-14 15-24 25-44 45-64 65-74 75-84 85+

Percentage of total population

Bishops Cleeve Tewkesbury LA C&T PCT Gloshire

Housing , Economic and Deprivation Indicators

The Gloucestershire MAIDeN database records the key characteristics of social, economic and service data (including health) for each electoral ward in Gloucestershire using nearly two hundred local indicators. By combining data and information relating to wards, wide-ranging community profiles can be produced. A review of indices of deprivation in 2004 suggests that Bishops Cleeve is situated in one of the least deprived areas of the PCT and county particularly in regard to health deprivation and disability. Births, Pregnancy and Life Expectancy

The number of live births per 1,000 women in Tewkesbury is the same as Gloucestershire as a whole (source: ONS). Life expectancy of a woman at birth is 81 years, the same as the county average. Life expectancy for men is 77 years which slightly exceeds the county average of 76 years. Tewkesbury Glo’shire Birth rate: per 1000 women aged 15-44 resident in the area

56

56

Source: Government Actuary Department Data on births in the profile area are difficult to interpret due to the small numbers (31 babies were born with low birth weight in both 1995 – 1999 and 2000 – 2003) which makes the results difficult to interpret. However the local rate for low birth weight babies was less than the PCT or County rates in both periods.



Low Birth Weight Rate per 1000 live births

1995 - 1999 2000 - 2003

C&T PCT 64.2 67.4 W Glos PCT 74.8 74.0 Cots Vale PCT 61.1 57.8 Gloucestershire 67.7 67.2 Bishops Cleeve 45.1 62.4

Source: ONS Mortality Rates

All causes: The all causes mortality rate for local residents has been markedly lower than that for residents of the PCT and the county since 1996 and has changed little over time. The wide confidence intervals for the Bishops Cleeve data indicated by the vertical black lines with arms on the bar charts are an indication of the uncertainty arising from the use of small numbers for these analyses. There is a 95% chance that the true value lies between the arms of the black line.

Trends in mortality from all causes (all ages)

0.0

100.0

200.0

300.0

400.0

500.0

600.0

700.0

800.0

1996-1998 1997-1999 1998-2000 1999-2001 2000-2002 2001-2003 2002-2004

period

Age

sta

ndar

dise

d ra

te p

er 1

00,0

00 p

opn

B'ps Cleeve

C&T

County

Source: ONS The dataset data was analysed in more detail for particular groups of diseases where studies have suggested a potential link or residents had raised a particular concern. Respiratory disease: The rates of respiratory disease from all causes (excluding cancer) reflect the pattern and level seen overall in the PCT and county. Although there is a small excess in the last period 2002 – 2004, the wide and overlapping confidence interval suggests that this is unlikely to be a significant finding.



Trends in mortality from respiratory disease in <75s

0.0

20.0

40.0

60.0

80.0

100.0

120.0

140.0

160.0

1996-1998 1997-1999 1998-2000 1999-2001 2000-2002 2001-2003 2002-2004

period

Age

sta

ndar

dise

d m

orta

lity

rate

per

100

,000

po

pn a

ged

<75

B'ps Cleeve

C&T

County

Source: ONS Cancer: The South West Public Health Observatory (SWPHO) was asked for expert advice in analysing cancer registration data to assess whether local people have experienced higher rates of cancer than would be expected. They were able to look at data from 1987 to 2002. There are many different types of cancer with a variety of risk factors. Some such as breast cancer are linked with more affluent lifestyles, some are linked with smoking and less affluent lifestyles others with age, family history, diet or occupation. Comparisons were made with the population of Tewkesbury, the PCT, the County and national rates of disease. The incidence of cancer was not higher or lower than would be expected based on national rates and was not statistically different from the other areas. There were no significant changes over the time period. Residents of Bishops Cleeve were not found to experience a higher risk of cancer than Gloucestershire as a whole. Mortality from cancers approached PCT and County norms. Although the mortality rate for 2002 – 2004 exceeded the rate for the PCT the actual number of deaths recorded in this period declined by 7 to 99. Further analysis by specific types of cancer was not undertaken due to small numbers. No deaths from cancer were recorded for children or young people up to the age of 24 for the period 1994 – 2004.



Trends in mortality from cancer in <75s

0.0

20.0

40.0

60.0

80.0

100.0

120.0

140.0

160.0

1996-1998 1997-1999 1998-2000 1999-2001 2000-2002 2001-2003 2002-2004

Period

Age

sta

ndar

dise

d m

orta

lity

rate

per

100

,000

po

pn a

ged

<75

B'psCleeveC&T

County

Coronary Heart Disease: Deaths from coronary heart disease have not been linked with landfill sites but have been included as a general indicator of health in the community. Local rates including the upper confidence intervals are generally below both PCT and County rates.

Trends in mortality from CHD in <75s

0.0

20.0

40.0

60.0

80.0

100.0

120.0

140.0

160.0

1996-1998 1997-1999 1998-2000 1999-2001 2000-2002 2001-2003 2002-2004

Period

Age

sta

ndar

dise

d m

orta

lity

rate

per

100

,000

po

pn a

ged

<75

B'ps Cleeve

C&T

County

Source: ONS Infant mortality: The number of deaths of infants up to 1 year old per 1000 live births exceeded the PCT and County rates in 1995-1999 but was less than or equal to them in 2000-2003. This represents a decrease of 3 in the actual number of deaths between the two periods from 1995 -1999 to 2000 – 2003. Infant mortality rate (deaths <1 year per 1000 live births) 1995- 1999 2000 - 2003 Bishops Cleeve 7.3 4.0 C&T PCT 4.7 5.7 County 5.5 4.0



Source: ONS Stillbirths: The stillbirth rate for Bishops Cleeve is also based on very small numbers but does not exceed the rates in other PCTs or the County as a whole. Stillbirth rate (per 1000 total births)

Source: ONS Hospital Admission Rates

We looked at hospital admission rates for all respiratory illnesses. These were lower in the profile area when compared with the PCT and the County with the exception of under 75s in 2002-2004, however this comparison was affected by the very low rates experienced by residents of Cotswold and Vale PCT at that time. The experience of profile area residents experience was still better than both residents of Cheltenham & Tewkesbury PCT and West Gloucestershire PCTs for the same period. Analysing the data further by elective or emergency admissions did not alter the findings. Direct Age standardised hospital admission rates: all admissions (Confidence intervals) Bishops

Cleeve C&T C&V WG County

Respiratory disease: all ages 2000-2002

755.6 (686.6 - 847.4)

1006.0 (982.9 – 1035.8)

932.4 (912.2 – 957.8)

1124.5 (1103.9- 1150.9)

1027.1 (1014.9-1042.6)

Respiratory disease: all ages 2002-2004

1000.5 (730.6 – 1117.5)

1077.7 (828.8 – 1109.0)

965.6 (707.7- 991.9)

1134.3 869.6 – 1160.7 0

1064.6 807.1- 1080.7 0

Source: ONS Other Health Indicators

We looked at other areas of concern for local residents where the level of evidence is less robust.

PCT 1995-1999 2000-2003 Cheltenham &Tewkesbury 5.6 4.4

West Glo’shire 5.1 5.3 Cotswold Vale 5.1 3.5 Bishops Cleeve 2.9 0.0 County 5.2 4.5



Congenital Abnormalities: As this is an area of particular concern to local residents the South West Congenital Abnormality Register was also asked for expert advice in interpreting the data available. In 1998 - 2002 less than 5 congenital abnormalities were recorded in the 5-year period in the GL52 postcode area compared with 193 in the county as a whole. Analysis of data from 2002 – 2004 does not indicate any unusual cluster formation. Voluntary registers are under reported but the very low numbers and the types of abnormality recorded do not suggest a need for further investigation. Asthma: Asthma was reported as a particular concern of local residents. However this is an illness which can be difficult to define and record with certainty resulting in errors in data collection. We have obtained some initial anonymised data from local General Practices and also looked at Quality Management Analysis System data which was routinely collected for the first time for 2003/4. Asthma prevalence has not been linked with landfill sites in particular but has been implicated in issues around air pollution e.g. from traffic. The quality of the data obtained for 2003 - 2004 are not sufficient to draw robust conclusions at present but practices with a high proportion of profile area residents provided data on prevalence which was comparable with that of other practices in the PCT. The quality of these data is likely to improve in the next collection round and could represent a useful source for monitoring in the future. Air Quality: Air Quality data was obtained from Tewkesbury Local Authority. Monthly Nitrogen Dioxide level monitoring adjacent to Stoke Road in the vicinity of Wingmoor Farm since December 2003 has been unremarkable and has not exceeded levels which would trigger further monitoring. Conclusion

People living in the Bishops Cleeve area generally experience levels of ill health which do not differ markedly from people living in other areas of Gloucestershire when a range of established health indicators and other less robust sources of evidence are compared. The PCT is committed to responding to the public's concerns regarding the health impact on the community of the local hazardous waste landfill site. It is apparent from the evidence available on landfill sites and expert advice from the HPA that well managed and regulated landfill sites should not represent a public health hazard, however it is important that the public is reassured. Consequently the PCT intends to participate fully in a national programme of surveillance involving all hazardous waste landfill sites which is being developed by the HPA in conjunction with the Universities of Birmingham and Cardiff. In addition, the PCT will focus on working with the Environment Agency, the Operators and others in the Liaison Group to ensure that emissions from the site are monitored and kept to a minimum. In the absence of conclusive evidence on the risk from such



hazardous waste landfill sites the PCT considers that this is the best way to protect the Public Health. Glossary

C&T – Cheltenham and Tewkesbury C&V – Cotswold and Vale WGlos – West Gloucestershire Glo’shire – Gloucestershire Contact Details

Dr Shona Arora Director of Public Health Cheltenham & Tewkesbury PCT Unit 43 Central Way Arle Road Cheltenham GL51 8LX Tel: 01242 548 812 E-mail: [email protected]

APPENDIX B

Community Health Impact Assessment of the

Wingmoor Waste Treatment and Landfill Sites Bishop’s Cleeve, Cheltenham, Gloucestershire

Bishop’s Cleeve Community Health Impact Assessment

Steering Group

MARCH 2009

© NHS Gloucestershire Community HIA – Wingmoor Sites Main Report March 2009

2

Prepared by Caryn L Hall, NHS Gloucestershire on behalf of the Bishop’s Cleeve Community Health Impact Assessment Steering Group All rights reserved. Reproduction, copy, transmission or translation of any part of this publication may only be made under the following conditions:

with the prior written consent of NHS Gloucestershire for quotation in a publication referencing this report under the terms set out below.

This publication is copyright, but may be reproduced by any method without fee for informative purposes but not for resale. As the Steering Group wishes to know how widely the report is disseminated, formal permission is required for all such uses, but will be granted expeditiously. For copying in any other circumstances or for re-use in other publications, prior written permission must be obtained from NHS Gloucestershire.


3

Contents Page

Contents 3 List of Figures 5 List of Tables 7 Abbreviations and Glossary 8 Acknowledgements 9 1.0 Executive Summary 11 2.0 Introduction 11

2.1 Community Health Impact Assessment 11 2.2 Steering Group 13 Health Impact Assessment Process – to note 14

2.3 Identification of Key Health Issues 14

3.0 Assessing the Impacts to the Community 16 3.1 Stress 16 3.2 Emissions to Air 19

3.3 Environment Agency Audit Findings 19 3.4 Dust 20 3.5 Air Pollution Control Residues 22 3.6 Odours and Gases 25

3.7 Traffic 27

3.8 Noise and Vibration 28 3.9 Air Quality and Pollution 31 3.10 Vehicle Movements 35

3.11 Communication 38 3.12 Health monitoring and Assessment 40

3.13 Cumulative Effects including Planning and Strategic 42

Considerations 4.0 Overarching themes arising from the Health Impact Assessment 43 5.0 Key Areas for Action 45 6.0 Conclusion 48 7.0 Comments and Feedback 50


4

Page

8.0 Additional Information 51 8.1 Background – the Wingmoor Sites 51

8.2 Waste 52 8.3 Landfill and Legislation 52 8.4 Planning Considerations and Processes 54 8.5 Permits and Hazardous Waste 55 8.6 Monitoring of Landfill Sites 57

9.0 Other Agencies and Groups as Stakeholders to the Wingmoor 58

Sites 9.1 Tewkesbury Borough Council 58 9.2 Gloucestershire Health Overview and Scrutiny Committee 58 9.3 Bishop’s Cleeve Parish Council 58 9.4 Gloucestershire Local Involvement Network 58 9.5 Safety in Waste and Rubbish Disposal 59 9.6 Health Protection Agency 59 9.7 Wingmoor Liaison Forum 60

References 61 Appendices Appendix A: Plan Identifying Location of the Wingmoor Sites 65 Appendix B: Bishop’s Cleeve Parish Council summary of responses to 66

the Wingmoor Farm Licence Extension Questionnaire Appendix C: Grundon Proposed Afteruse – Public consultation results 67


5

List of Figures Page

Figure 1: Model of Socio-economic Determinants of Health 12


6

List of Tables Page

Table 1: Nitrogen Dioxide Results for Stoke Orchard Road, 32

Bishop’s Cleeve Table 2: Road traffic count for Thursday 6th September 2007 35

Between 07.00 and 19.00, Stoke Orchard Road, Bishop’s Cleeve


7

Abbreviations and Glossary APC Air Pollution Control (residues) ADE Average Human Daily exposure CHaPD Chemical Hazards and Poisons Division CLEA Contaminated Land Exposure Assessment COMEAP Committee on the Medical Effects of Air Pollution DEFRA Department for Environment, Food and Rural Affairs DH Department of Health DT Department for Transport EA Environment Agency EC European Community EEC European Economic Community EIA Environmental Impact Assessment EPAQS Expert Panel on Air Quality Standards EPHTP Environmental Public Health Tracking Programme EU European Union EWC European Waste Catalogue FoE Friends of the Earth GCC Gloucestershire County Council GIS Geographical Information System GP General Practitioner HGV Heavy Goods Vehicle (over 3.5 tonnes) HIA Health Impact Assessment HOSC Health Overview and Scrutiny Committee HPA Health Protection Agency IPPC Integrated Pollution Prevention Control LINk Local Involvement Network LRF Local Resilience Forum MRF Materials Recovery Facility NHS National Health Service PAH Polycyclic aromatic hydrocarbons PCB Polychlorinated biphenyls PCDD Polychlorinated dibenzo-p-dioxins PCDF Polychlorinated dibenzofurans PCT Primary Care Trust PM10 Particulate Matter less than 10 microns/micrometres in diameter PPG Planning Policy Guidance RSS Regional Spatial Strategy SpT Specialist Trainee in Public Health SWARD Safety in Waste and Rubbish Disposal SWPHO South West Public Health Observatory TBC Tewkesbury Borough Council TRL Transport Research laboratory µg/m

3 Micrograms per cubic metre

UK United Kingdom USA Updating and Screening Assessment WAC Waste Acceptance Criteria WAP Waste Acceptance Procedures WHIASU Welsh Health Impact Assessment Support Unit WHO World Health Organization


8

Acknowledgements NHS Gloucestershire wishes to acknowledge the work of the Steering Group for their dedication in the production of the community Health Impact Assessment. Thanks are also extended to those who gave their co-operation in the provision of key information used to inform the Steering Group in producing this report.


9

1.0 Executive Summary 1.0.1 A community Health Impact Assessment (HIA) of the Wingmoor sites

took place between December 2006 and February 2009 (with an unplanned break between August 2007 and October 2008). The potential impacts of the sites on the physical and mental health and wellbeing of the community were examined both in terms of relevant published literature and from information collected as part of the process.

1.0.2 A Steering Group was established with representatives of county,

borough, parish councils, national and local interest groups and local residents. The Group undertook the responsibility of driving the process of undertaking the community HIA.

1.0.3 The Group identified the key impacts to health they wished to

investigate. Stress was determined as the overarching impact that the Group wished to examine in detail. The issues that the Steering group identified included: • Fear for the potential effects of harm • Fear for the potential effects of harm from the operations at and

around the site not least to babies, young children and other vulnerable groups including the proximity of the sites to residential properties

• Loss of quality of life, loss of amenity and potential reduction in

house prices

• Lack of control over the processes within the site and the way it operates (a feeling of helplessness)

• Concern about the future

1.0.4 The Group looked at the evidence for potential causative factors,

mitigation that was being undertaken and identified and undertook a gap analysis. This process led the Group to look at issues specifically relating to emissions to air, traffic, communication, health monitoring and assessment, cumulative effects and planning and other strategic considerations.

1.0.5 The Group established that for those areas that were examined in

detail, from the information that was available to the Group, currently there was no definitive evidence to demonstrate that health has been affected by living near the Wingmoor sites. However, the Group would strongly emphasise that there were a number of key findings arising from the report that specifically identified gaps in the current knowledge that are essential to further inform this area.


10

1.0.5 The Group has therefore identified a number of key actions and timescales for a variety of key agencies to undertake, namely; • NHS Gloucestershire (Gloucestershire Primary Care Trust) • Health Protection Agency • Wingmoor Site Operators • Gloucestershire County Council • Gloucestershire Local Resilience Forum • Tewkesbury Borough Council • Environment Agency • Government Office of the South West • Gloucestershire Health Overview and Scrutiny Committee • Wingmoor Liaison Forum These actions are critical to further inform the knowledge of health impacts and outcomes and would assist in establishing baselines.

1.0.6 It is clear that the community has very real concerns about the

Wingmoor sites and these need to be given due appropriate consideration by those involved with the sites. The Group has been realistic and recognises that there are limitations on what can be achieved when looking at complex processes such as these. The group has therefore identified that additional work is required and that this community HIA report should really be seen as a “first stage” in a process that needs to and must be continued.

1.0.7 The final draft of the HIA report was sent out for comment and

feedback - technical and typographical errors were amended within the main body of the report. Additional comments and feedback are to be found in a separate document appended to the report.


11

2.0 Introduction 2.0.1 The nature of the waste treatment plant and landfill sites at Bishop’s

Cleeve in Gloucestershire (referred to in this report as the Wingmoor sites and shown on the plan in Appendix A) has changed over time and the community has seen the operations increase and change in the type and amounts of waste taken. It is believed that the increases and changes at the sites have taken place without the full knowledge and understanding of the potential health effects to the community who are living near the Wingmoor sites.

2.02 The size of Bishop’s Cleeve and those living in the proximity of the

Wingmoor sites is not inconsiderable - there are 15,059 resident registered people (as at December 2008) who live within a 3km zone around the sites. Wards that are in close proximity to the Wingmoor sites are as follows along with their resident registered populations (as at January 2009)

Ward Population

Cleeve Grange 2054 Cleeve Hill 4254 Cleeve St. Michael’s 4298 Cleeve West 4508 Coombe Hill 4599 Oxenton Hill 1620 Swindon Village 6018

Note

2.0.4 It should be noted that at the commencement of the HIA the initial proposal was to look in detail at the concerns arising relating to the hazardous waste operations, however, during the process of the HIA it became clear that it was not possible to separate out the impacts of each site so the Steering Group chose to look at the Wingmoor sites in totality.

2.1 Community Health Impact Assessment 2.1.1 In response to continued concerns raised by residents through the

Wingmoor Liaison Forum which was established in 2004, the Primary Care Trust (PCT) agreed to facilitate a community HIA, this was to be overseen by Dr Shona Arora – Director of Public Health for the PCT (now known as National Health Service Gloucestershire – NHS Gloucestershire) and led by Caryn L Hall – at the time a Specialist Trainee (SpT) in Public Health.

2.1.2 A community HIA is a more responsive process to community concerns

and considers health and wellbeing in the context of the wider determinants of health. An HIA looks at issues that would ordinarily be considered to be outside of the standard remit covered by processes such as planning applications and permit applications. This does not of course exclude areas that would be covered within other regulatory processes such as noise, dust, etc.


12

2.1.3 Many factors can affect the health of communities and the health of individuals in communities. Those factors which influence people’s health are known as the wider determinants of health. In looking at the wider determinants the Steering Group used the diagram below as a guide as to what influences health and so what the HIA may potentially cover – this includes dimensions relating to housing, the natural and built environment, employment, access to services, social factors and individual lifestyle factors.

Source: Dahlgren and Whitehead, 1991 Figure 1 - Model of Socio-Economic Determinants of Health

2.1.4 The World Health Organization (WHO) describes an HIA as;

“…a combination of procedures, methods and tools by which a policy, programme or project may be judged as to its potential effects on the health of a population and the distribution of those effects within the population” (WHO, 1999).

2.1.5 In other words, it provides a more systematic yet flexible framework

that can be used to consider prospectively or retrospectively the wider effects of local and national policies, initiatives or developments and how they, in turn may affect people’s health. Some of the effects may be positive whilst others can be negative. The aim is to identify or make recommendations as to how positive impacts can be maximised and if there are negative impacts to identify how these can be either removed or mitigated.

2.1.6 The description is also useful as it suggests that there is more than one

approach possible to undertaking an HIA. It also highlights the health


13

inequalities dimension as developments can affect different groups within a given population in different ways (WHIASU, 2005).

2.1.7 Reducing health inequalities is an important issue identified nationally

(DH, 2003) and locally in the Local Area Agreement (Gloucestershire Conference, 2008). HIA has been identified by the Department of Health (DH) as a potential way to reduce health inequalities.

2.1.8 A community and collaborative HIA potentially provides a forum with

which people can express concerns and fears that they believe may have not been covered or considered by other regulatory frameworks for example through planning applications. This process can assist those decision makers to understand the concerns of the community not just in terms of a quantified approach but also though a qualitative approach.

2.1.9 It is proposed that the community HIA will be disseminated to those

who have influence for the future at the Wingmoor sites as well as all those who have an interest in the sites.

2.2 Steering Group 2.2.1 Advertisement flyers were posted in and around various locations in

Bishop’s Cleeve by the PCT (NHS Gloucestershire) to “recruit” residents and other local persons to the Steering Group that was to be established. An article about the work also appeared in the Gloucestershire Echo. The Wingmoor Liaison Forum were also advised of the work proposed. Those who were interested completed an expression of interest form and submitted this to the PCT (NHS Gloucestershire). The Steering Group was subsequently formed.

2.2.2 The Steering Group comprised the following; All 3 tiers of local government – county, district and parish

• Cllr Ceri Jones, County Councillor, resident in postcode GL50 • Cllr Peter Richmond, Borough Councillor, resident in postcode

GL52 • Cllr Susan Hillier-Richardson, Borough Councillor, resident in

postcode GL52 • A Bishop’s Cleeve Parish Councillor, resident in postcode GL52 Local residents • A sixth former from Cleeve School, resident in postcode GL52 • A mother of primary school age children, resident in postcode GL52 Local resident representing Gloucestershire Local Involvement Network (LINk) • Barbara Stevens, resident in postcode GL52 Local residents’ group • Barbara Farmer, Safety in Waste and Rubbish Disposal (SWARD),

resident in GL52 Local representative of national environmental interest group – Friends of the Earth (FoE)


14

Caryn L Hall – NHS Gloucestershire (Gloucestershire PCT) acted as facilitator to the Steering Group

The Bishop’s Cleeve Parish Councillor and sixth former both provided valuable input into the HIA at the commencement of the process but were unable to remain with the Steering Group for the final few meetings.

A further local resident from the Gloucestershire Older Persons Assembly attended the initial meeting but withdrew for personal reasons (resident in postcode GL52).

The FoE representative was involved in the initial Steering Group but was unable to participate with the process in the latter stages of the work, but has input to the comments and feedback.

The initial “training” meeting commenced with presentations from the following:

Stuart Baker – Environment Agency (EA) on regulation at the site Dr Bruce Bolam – SpT at North Somerset PCT on association and causation Toni Robinson – Grundon landfill and development manager Caryn L Hall – NHS Gloucestershire (Gloucestershire PCT) outlined what an HIA was, the proposed process for Gloucestershire and some mutually agreed ground rules for the group.

Health Impact Assessment Process – to note 2.2.3 The Steering Group wish to add that the delay in producing this report

(between August 2007 and October 2008) was attributed to an absence of the facilitator from NHS Gloucestershire due to secondment. NHS Gloucestershire recognises that this had led to a delay in the production of the report and subsequent requirement to work within timescales set by the Health Overview and Scrutiny Committee (HOSC) and advises that for future work of this nature they would seek to ensure continuity of the process.

2.2.4 Some activities planned by the Steering Group at the commencement

of the process for example a number of community events and focus groups to elicit wider views of the community with respect to the Wingmoor sites, have not taken place.

2.3 Identification of Key Health Issues 2.3.1 The meetings of the Steering Group identified a wide ranging number

of health impacts that they perceived could be an outcome of living in close proximity to the Wingmoor sites. These included;

• Respiratory illness particularly asthma • Ear, nose and throat illnesses • Skin conditions


15

• Issues relating to birth defects and short and long term impacts on children’s health

• Sleep and rest disturbance 2.3.2 The Group also identified that as well as potential physical illness being

a cause of concern, stress was also a key area relating to concerns about the impact of the Wingmoor sites and as such was an overarching health issue.

2.3.3 The specific areas that the group considered as potentially leading to

the health issues listed above arise from concerns about;

Emissions to air arising from - dust and particulates, air pollution control (APC) residues, odours and gases and the cumulative effects of these emissions. Traffic - noise and vibration, vehicle movements including the risks of road traffic collisions, air quality and pollution.

2.3.4 These key factors are dealt with in detail as outlined. The Group aimed

to assess the impacts in terms that the community can understand and as such technical jargon and technical information have been minimised. To the rear of the report there are a number of sections that contain some of the more technical information so this can be read in conjunction with the main body of this report.


16

3.0 Assessing the Impacts on the Community 3.1 Stress 3.1.1 The Steering Group identified that the main over-riding concerns raised

by the community related to “stress” or “anxiety”. This was explained further with phrases including “the constant drip, drip of worry from living near the sites” and “nagging feeling at the back of your mind” and “not knowing exactly what is going on and what you are exposed to”.

3.1.2 Stress is the way that you feel when pressure is placed on you.

Everyone reacts differently to stress, and some people may have a higher threshold than others. Too much stress often leads to physical, mental, and emotional problems. In the United Kingdom (UK), anxiety and depression are the most common mental health problems, and the majority of cases are caused by stress (NHS, 2008).

3.1.3 Stress such as that caused by the worry over the future of the local

environment can leave people vulnerable to psychological or minor psychiatric problems, which shows correlations with living in underprivileged areas (Harrison, Barlow and Creed, 1998).

3.1.4 The issues that the Steering Group identified included:

• Fear for the potential effects of harm from the operations at and around the Wingmoor sites not least to babies, young children and other vulnerable groups including the proximity of the sites to residential properties

• Loss of quality of life, loss of amenity and potential reduction in house prices

• Lack of control over the processes surrounding the site and the way it operates (a feeling of helplessness)

• Concern about the future 3.1.5 These fears have been prompted by a number of incidents over the last

few years, including: • a mechanical breakdown which resulted in the release to air of

approximately 2 tonnes of untreated APC residues in fifteen seconds (2004),

• the release of phenol vapour over a wide area when discharging contaminated soils. (Grundon’s client had not accurately disclosed the contents),

• breaches of the permit, e.g. dust blowing across the hazardous waste cell; non permitted liquid waste being poured into the hazardous cell and inadequacies in waste acceptance and control systems procedures; dust created because of inadequate damping in the hazardous cell; APC leaving the tipping area because of inadequate moisture content in bagged waste and failure to test for this (2004 &2005: EA Inspection reports: 140305, 28904, 25104, 251104),


17

• several fires on the Cory household waste site (2006), • foul smells from the Cory site over a wide area after flooding (2007).

3.1.6 When considering the distance from the boundary of the Wingmoor

sites to residential areas it is relevant to note the 5th March 1997 proposal of the Commission on the draft Landfill Directive. This was informed by the initial results of the EUROHAZCON projects on birth defects associated with landfill sites and included specific minimum distances from such areas. These were a minimum separation of 0.5 km in the case of municipal waste landfills and 2km in the case of hazardous waste landfills. The final published Directive (Directive 99/31/EEC) stated in Annex 1 for General Requirements for all classes of landfills; 1 . Location 1.1 The location of a landfill must take into consideration

requirements relating to: o the distances from the boundary of the site to residential

and recreation areas, waterways, water bodies and other agricultural or urban sites;

o the existence of groundwater, coastal water or nature protection zones in the area;

o the geological and hydrogeological conditions in the area; o the risk of flooding, subsidence, landslides or avalanches on

the site; o the protection of the nature or cultural patrimony in the area.

1.2 The landfill can be authorised only if the characteristics of the site with respect to the abovementioned requirements, or the corrective measures to be taken, indicate that the landfill does not pose a serious environmental risk.

3.1.7 Loss of amenity includes the issues that relate to flies, gulls, dust, the

roads, noise and smells that affect the enjoyment of homes that are in the proximity of the Wingmoor sites. Many of these issues are explored in more depth in other sections as well as this one.

3.1.8 Within site operations, the site operator Grundon has been granted a

derogation by the EA enabling them to landfill hazardous waste that does not meet the European Union (EU) Waste Acceptance Criteria (WAC) levels.

3.1.9 A Department for Environment, Food and Rural Affairs (DEFRA) survey

undertaken in 2003 found that the value of houses situated less than a quarter of a mile away from a landfill site was an average of £5500 lower than the value of a similar house not situated near a landfill site. For those houses over a quarter of mile from a site but under half a mile the value was an average £1600 lower (DEFRA, 2003).


18

3.1.10 There are methods for measuring stress in humans – one method

involves taking samples of cortisol for analysis. This is not a method that could reasonably be replicated (for ethical and medical reasons) for assessing the levels of stress in the community in Bishop’s Cleeve and surrounding areas arising from living near the Wingmoor sites. However, there are a number of other recognised tools to assess psychological stress in the community.

3.1.11 There is currently no data available on the mental health and wellbeing

of the residents who might be affected by the Wingmoor sites. It is understood that NHS Gloucestershire is currently undertaking a psychological needs assessment across Gloucestershire. The Steering Group would welcome the potential for the specific effects identified in this report to be taken into consideration during this piece of work.

Stress Key Action NHS Gloucestershire must undertake a study to determine the potential effects of the Wingmoor sites on the physical and mental health and wellbeing / stress of local residents (to include asthma) who live in proximity to the Wingmoor sites, to be completed in 2009. 3.2 Emissions to Air


19

3.2.1 An area of major concern that the Steering Group identified relates to emissions to air from the site itself. This included more specifically general dust arising from the site, APC residue materials and odours and gases.

3.2.2 In particular the Steering Group sought information on the potential

cumulative and combined health effects of emissions. Hansen et al and Carpenter et al (in South West Public Health Observatory (SWPHO) 2002) identified that in most waste, a mixture of different contaminants will be present. Little is known about the toxicity of combinations of contaminants, or whether their interaction is to increase toxicity or to modify it.

3.2.3 Assessment of the potential health hazard of mixtures is a challenging

task for toxicology. The risks may be additive or there may be interaction effects that make the risks higher or lower than that predicted by analysing individual contaminants separately. There may be no interaction at all, with each acting independently. Nor is there an adequate understanding of the effects on toxicity of the changes which occur when chemicals migrate through soil or water. Unlike laboratory conditions where animals are exposed to one chemical at known doses, people's exposure to waste sites is typically complex with many agents and multiple pathways (SWPHO, 2002).

3.3. Environment Agency Audit Findings 3.3.1 In 2008 the EA mounted a national campaign to audit sites within the

hazardous waste treatment and storage sector. The report stated within the scope of the national audit that, “The hazardous waste treatment and storage sector has had a history of serious accidents and incidents over recent years. In many cases these incidents arose due to incompatible or poorly characterised wastes being mixed or stored together”. It further stated that, “Operators have stated that they would be priced out of the field if only they fully complied and others did not and that the Agency should also be targeting producers” (EA, 2008).

3.3.2 Grundon was included within this national audit. The Group welcome

the EA audit that was part of a national audit of all hazardous waste plants, but note that there were several actions that Grundon needed to undertake in order to achieve full compliance with their permit. The report identified a total of eleven recommendations for Grundon to undertake within a specific timescale. This timescale has not been met and the EA have agreed to lengthen the period within which compliance is reached.

Emissions to Air Key Actions The Environment Agency must undertake research with regard to the effects to health of the “cocktail effect” of wastes that enter landfill sites. 3.4 Dust


20

3.4.1 The Steering Group have particular concerns relating to the amount, type and levels of dusts that can potentially arise from the Wingmoor sites and where they arise from.

3.4.2 Dust is observed to be present in significant quantities on the

immediate roads, hedges, verges and in residents’ homes, causing loss of amenity. The Steering Group is concerned with regard to the potential health impact of dust from inhalation of fine particles and in particular to APC residues that may be present in the dust.

3.4.3 Dust is generally regarded as particulate matter between 1 and 75

microns in diameter. 3.4.4 Dust control forms part of the waste permit for landfill sites and as such

is regulated by the EA. In 2004 in response to concerns from the community, the EA commissioned DustScan Ltd to undertake directional dust monitoring offsite in addition to that undertaken by the operator as part of their permit. Monitoring has taken place annually since 2005. However, no interpretation or analyses of the dust samples has taken place, despite repeated requests for this to be undertaken through the auspices of the Wingmoor Liaison Forum.

3.4.5 The Steering Group believe that an overarching report that brings

together the data to establish trends should be undertaken. The Group further believe that there should be some interpretation taken of the results and that further monitoring and analyses needs to be undertaken (to establish the amount and type of dust) in order to produce a summary that can be used. The EA in January 2009 advised through the Wingmoor Liaison Group that they had recently requested full geochemical analyses and interpretation to be undertaken on the samples.

3.4.6 Grundon have advised the Steering Group that they are sponsoring a

Knowledge Transfer Project, research project, developing dust monitoring methodologies. Wingmoor Farm East (operated by Grundon) is being used as the study site. It is hoped that the research project will develop into a PhD research paper in the future. The research is due to produce a report on the methodologies in late 2009. Statistical manipulation of data collected thus far has just begun, therefore, there are no results to report at this stage. The Steering Group welcome this initiative and that Grundon have also committed to presenting the findings of the research work to the Wingmoor Liaison Forum, once the studies have been completed.

3.4.7 The Steering Group wrote to each of the three operators – May Gurney, Cory Environmental and Grundon requesting details of their dust suppression methodologies.

Cory Environmental gave a very considered and in depth response to this request and the Group felt reassured by this response as to the


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actions being taken. The responses from Grundon and May Gurney were less in depth and this did not provide the reassurances that the Group were seeking from a more in depth response.

Dust Key Actions The Environment Agency must undertake to complete the analyses of the dust monitoring carried out by DustScan Ltd to commence in 2009 or as soon as is practicable. The results of the analyses must be made publically available and sent to the Wingmoor Liaison Forum. These analyses must be undertaken annually thereafter following monitoring. 3.5 Air Pollution Control Residues


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3.5.1 The Steering Group have significant concerns about APC residues being deposited at the site due to the nature of its waste and its potential impacts on health particularly with reference to respiratory illness.

3.5.2 APC is a by-product of waste incinerators. The waste is created as a

result of the treatment of the combustion gases. The gases are cleaned by adding lime to neutralise any excess acid, then finely divided carbon is added to remove the dioxins and heavy metals. Filters are used within the process to remove fine particles, lime and carbon. APC is therefore a mixture of fly ash, carbon and lime (EA, 2002). Fly ash contains high concentrations of heavy metals, polychlorinated dibenzo-p-dioxins (PCDD), polychlorinated dibenzofurans (PCDF), polycyclic aromatic hydrocarbons (PAH) and other organic materials (Yoshida et al, 2003) including brominated dioxins and furans.

3.5.3 Between 1996 and 2000 88% of APC residues arising went directly to

landfill (EA, 2002). Between 1996 and 2000 eighteen sites received 313,646 tonnes of APC wastes. Bishop’s Cleeve landfill received the majority of APC residues - 157,099.

3.5.4 A literature review identified little information on the potential health

effects of this particular material, although one paper has identified that this waste can have significant toxicity to mammalian cells (Huang et al, 2008). The Group strongly support the approach proposed by Sir Austin Bradford Hill in his 1965 address to the Royal Society of Medicine;

“All scientific work is incomplete whether it be observational or experimental. All scientific work is liable to be upset or modified by advancing knowledge. This does not confer upon us a freedom to ignore the knowledge we already have, or to postpone action that it appears to demand at a given time” (Hill, 1965).

3.5.5 A recent study (Macleod et al, 2006a and 2006b) raises issues that

concern the Group. The study modelled human exposures to APC residues from municipal incinerators in England following their disposal to landfill. The study indicated that modelled exposures to dioxin, fine particulates and heavy metals were likely to be several orders of magnitude greater for “receptors” (this means local residents including children) around the Wingmoor site than for other sites referenced in the paper. The report did not model other substances which are known to be constituents of fly ash such as Polychlorinated Biphenyls (PCB). The Group acknowledge that the levels estimated in the paper are still within the air quality standards/objectives where set.

3.5.6 The report also identified that “average daily human exposure (ADE) to

the critical receptor was estimated to be 0.8pg TEQ/kg bw/day, which is twice the health criteria value derived for dioxins”. The most sensitive


23

receptor identified in the paper was considered to be a female child aged 0 – 6 in a residential setting where the family consumes its own home grown produce. The report advises that this estimated modelled data has used a model (the Contaminated Land Exposure Assessment (CLEA) model) that has not been externally validated for dioxins and that the results are tentative and demand qualification.

3.5.7 The Authors of the report identified that further work and investigation

was required to be undertaken but the Group is not aware of any further research work having been undertaken. The Group would express concern that this report was not published until 2006. It is understood that the work was undertaken in 2002 primarily to inform the 2002 EA report. The Group would question why the paper took four years to be made publically available and why the agencies involved in the paper including the EA and HPA had not shared the full results earlier.

3.5.8 The Steering Group acknowledges that the paper advises that a

generic risk screening approach was developed for the potential pollutant linkages that exist at landfill sites accepting APC residues. The study used theoretical modelling concentrations that were “conservative” in nature, which were intended as a generic screen of exposures. The paper also recommended caution in using the data to infer anything other than generalised conclusions. The Group acknowledge that it has extracted key specific data from the report that is of particular interest to their area of work but would advise that the full report can be read as referenced.

3.5.9 The Steering Group has an additional concern with regard to the

grazing of animals near the Wingmoor sites as dust from the sites may travel onto adjacent agricultural land where animals are grazing and lead to ingestion by animals that could then enter the food chain. The Group are aware that recently sheep were removed from the land and replaced by alpacas. Grundon have advised that this action was taken for the following reason. “Regulation 11(2) of the Animal By-Products Regulations 2005 prohibits the importation of catering waste or other animal by-products on to any premises where any livestock is kept. This had implications for a large number of landfill sites across England & Wales and landfill operators requested further guidance from the State Veterinary Service [now known as animal health] on whether livestock are permitted to be located on restored areas of a landfill. The State Veterinary Service policy advice included a requirement that: Livestock must be separate from landfill premises, with separate entrance / exit that can be reached directly from the public highway without having to enter the landfill premises”.

It is noted that this particular scenario/receptor was not considered by the Macleod paper.


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3.5.10 The Steering Group are aware that there is potential for an increase in

the number of incinerators to be built in the UK to address the need to deal with increasing levels of waste. This raises concern for the Group as this would lead to increasing levels of APC residues being produced with a subsequent need to landfill these in a designated hazardous landfill site – of which there are now only 12 in the UK.

Air Pollution Control Residues Key Actions The Environment Agency must commit to carrying out the recommendations of the findings of the Macelod study relating to air pollution control residues. 3.6 Odours and Gases


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3.6.1 The Steering Group raised concerns about potential odours and gases that could arise from the Wingmoor sites and the effects these could potentially have on health - particularly in relation to respiratory illness and asthma, as well as the potential effect they could have on residential amenity. Furthermore there are concerns about the potential health effects of gulls and flies that are attracted to the Wingmoor sites and any potential health impacts arising from their control.

3.6.2 The EA regularly receives complaints from residents regarding odours

experienced in close proximity to the site. This complaint data is presented on a quarterly basis to the Wingmoor Liaison Forum. The EA have a duty to investigate complaints of this nature.

3.6.3 It is accepted in general that air pollutants can play a part in causing

someone who already has asthma to suffer from an asthma attack, however what is not certain is whether exposure to air pollution can cause someone to suffer from asthma that did not previously have the condition. The Committee on the Medical Effects of Air Pollution (COMEAP) looked at this area in 1995 (DH, 1995) and is currently reviewing this area once again. Asthma prevalence has been implicated in issues around air pollution e.g. from traffic (Cheltenham & Tewkesbury PCT, 2005). Until recently asthma prevalence had not been specifically linked with landfill sites. However a 2007 study (Ma et al, 2007) and subsequent published paper (Carpenter et al 2008) reports that the findings of the study demonstrated a significantly elevated risk of asthma and infectious respiratory disease to children in relation to residence near hazardous waste sites,

3.6.4 Validated and published data from March 2008 has shown that

Gloucestershire as a county has higher levels of asthma (6.2%) compared to England as a whole (5.7%). Basic asthma data has been collected in England by General Practitioner (GP) practices since 2006. Due to the geographical spread of residents in Bishop’s Cleeve across seventeen GP practices it is not easy to produce robust and definitive data to show the percentage of people in the proximity of the Wingmoor sites who are diagnosed with asthma.

3.6.5 However, data extracted from January 2009 has shown that the GP

resident registered population who live within a 3km radius of the Wingmoor sites (approximately 15,000 people of all ages) have higher levels of asthma (7%) when compared with the validated and published county data from March 2008. When statistical calculations are used to establish the significance of this, the true figure lies between 5.95 and 8.1%. The higher level also shadows the findings that the county level overall appears to be increasing. Whilst this is the best data currently available and certainly merits further investigation, NHS Gloucestershire would also exercise caution in relying on this data to draw firm conclusions as ‘like for like’ data is not being compared.


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3.6.6 NHS Gloucestershire are aware of the continued concerns with respect to asthma in the population near the Wingmoor sites and propose to continue to refine and review the data particularly with reference to the distance of population from the sites and with respect to the vulnerable population surrounding the sites i.e. younger and older population. NHS Gloucestershire will report this back to the Wingmoor Liaison Forum when this additional published and validated data is available.

3.6.7 NHS Gloucestershire is able to collate data on the number of people

with respiratory disease and the Bishop’s Cleeve Neighbourhood Health Profile from 2005 identified that the rates of respiratory disease from all causes (excluding cancer) reflected the pattern and level seen overall in the PCT and county. This data as previously discussed is however, in need of updating. The Steering Group would also wish to see, where data exists the following health conditions included in the health profile: birth defects and reproductive disorders; cancers (selected sites); immune function disorders; kidney dysfunction; liver dysfunction; lung and respiratory diseases; and neurotoxic disorders as recommended by the United States Agency for Toxic Substances and Disease registry for landfill health assessment.

Odours and Gases Key Actions NHS Gloucestershire must undertake a comparative update of the Bishop’s Cleeve Neighbourhood Health Profile every 3 years commencing in 2009. NHS Gloucestershire must undertake a study to determine the potential effects of the Wingmoor sites on the physical and mental health and wellbeing / stress of local residents (to include asthma) who live in proximity to the Wingmoor sites to be completed in 2009.


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3.7 Traffic 3.7.1 The Steering Group is concerned with a number of issues relating to

traffic particularly with reference to Stoke Orchard Road and the A435 By-Pass.

• Noise and vibration from vehicles travelling to the Wingmoor sites

and the number of movements that are taking place and the ensuing potential pollution that this would cause and potentially affecting health of residents.

• That the roads are inappropriate for the amount and type of traffic that were travelling along them.

• That no alternative access to the Wingmoor sites has been considered.


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3.8 Noise and Vibration 3.8.1 The Steering Group advised that there are concerns relating to the

noise and vibration arising from the volume and type of traffic to and from the Wingmoor sites.

3.8.2 Noise is most usually defined as unwanted sound. This definition

provides one of the core aspects of assessing noise; it deals with a subjective response – unwanted, to an objective reality - sound.

3.8.3 WHO in 1999 identified that the adverse health effects of community noise, which includes road traffic noise, can give rise to sleep disturbance, hearing loss, cardiovascular and physiological effects, speech intelligibility and communication interference and potentially performance of some other functions and can give rise to noise annoyance (Berglund et al, 1999).

3.8.4 The EU Directive on the assessment and management of

environmental noise (Directive 2002/49/EC) requires EU Member States to establish action plans to control and reduce harmful effects of noise exposure. The UK introduced this Directive into UK law through the Environmental Noise (England) Regulations 2006 (SI 2006/2238) which came into effect on 1st October 2006. For 2007 this requires certain geographical areas (known as agglomerations) to map and monitor environmental noise and for other specific areas to map noise arising from specific noise sources such as airports, major roads (roads which have more than 6 million vehicle passages a year) and railways (major railways with more than 60,000 train passages a year. For Gloucestershire this includes railway in Gloucester and some major ‘A’ roads and the M5 motorway in the county. Gloucestershire airport was originally included but subsequently removed by an amendment to the legislation.

3.8.5 A National Noise Strategy (covering environmental and neighbourhood

noise) was to be launched in early 2008 to progress this work further – this has to date not been published.

3.8.6 There are no specific noise limits on noise arising from transport such

as cars and other road vehicles however, detailed traffic noise assessment, monitoring and mitigation design for new road schemes can be carried out and entitlement to noise insulation established under the Noise Insulation Regulations. Noise assessment work is carried out in accordance with the Department for Transport (DT) publication, Calculation of Road Traffic Noise methodology (DT, 1988)

3.8.7 Noise impacts from traffic calming measures are considered as part of the design process, for example the ‘rumble strips’ on the A435 approach to the pedestrian crossing. Consideration can be given to the provision of quiet surfacing for new roads and where resurfacing or maintenance is being carried out.


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3.8.8 Where planning is an issue for mineral, waste disposal and recycling sites, noise control conditions of consent are imposed on all sites where dwellings or other noise sensitive premises could be affected by the activities. These often include limits on the level of noise that is allowed at the nearest property and may require routine monitoring by the Operator.

3.8.9 Where planning is an issue, impacts on new residential development

from existing road traffic noise are determined in accordance with advice contained in Planning Policy Guidance (PPG 24) Planning and Noise (Department of Communities and Local Government, 1994).

3.8.10 Where residential development is proposed in combination with a major

new road, the local authority would normally carry out any noise exposure assessment work.

3.8.11 Extensive studies by the Transport Research Laboratory (TRL)

involving heritage and listed buildings in heavily trafficked locations, as well as simulated trial conditions on more modern structures, have found that traffic vibration is not the primary cause of damage to buildings. The conclusions are that vibration from traffic may result in existing weaknesses being exacerbated.

3.8.12 The levels of noise and vibration are currently not known arising from

the vehicle movements along Stoke Orchard Road and the A435 By-Pass (where traffic comes from the north, south and the east) as TBC has confirmed that it has not undertaken any monitoring.

3.8.13 The Steering Group wrote to TBC requesting that they provide

information on how noise and vibration monitoring may be able to be undertaken to establish a baseline of the current levels experienced along Stoke Orchard Road and the A435. TBC have advised that they have no statutory powers to monitor noise and vibration arising from the traffic and that the EA as the statutory body who determines permits for the site would have responsibility to ensure traffic did not cause a nuisance. The EA have subsequently advised that they have not undertaken any noise or vibration monitoring relating to the site and traffic.

3.8.14 TBC advise that it may still be possible to control the traffic using the

development by requiring a ‘Section 106 agreement’ to ensure traffic routes are drawn up so as to protect amenity. This would fall under the responsibility of GCC who would determine any future planning applications submitted.


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Noise and Vibration Key Actions Gloucestershire County Council must undertake to use ‘quiet surfaces’ on the key roads that surround the Wingmoor sites. The Environment Agency must undertake noise monitoring of the Wingmoor sites and associated traffic to establish a baseline to be completed in 2009.


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3.9 Air Quality and Pollution 3.9.1 Residents are concerned about the potential health effects arising from

the volume and type of traffic to and from the Wingmoor sites. 3.9.2 It is known that traffic generates pollution from vehicle fumes – these

are a complex mix of bi-products formed by the combustion process of the engine. They contain hundreds of pollutants more significantly including:

• Benzene • Lead • Carbon monoxide • Nitrogen dioxide • Ozone • Sulphur dioxide • Particles (often referred to as particulates or PM10)

3.9.3 The potential health effects from inhaling vehicle fumes include asthma, bronchitis, heart conditions and other respiratory disorders. Although the individual health risks of air pollution are relatively small, the public health consequences are considerable (Kunzil et al, 2000).

3.9.4 In the UK, motor vehicles are responsible for 46-61% of nitrogen dioxide in outside air and 25% of PM10 emissions (Department of the Environment 1999). However, emission regulations are becoming more stringent (Department of the Environment, 1997). Congestion is known to exacerbate emissions per vehicle (Barratt et al, 1996) although we do not know the impact of congestion on these particular roads. Air pollution is associated with a rise in hospital admissions and deaths (Anderson et al, 1995), morbidity and mortality (DH, 1998). In the UK transport is responsible for 25% of CO2 emissions, with road transport accounting for around three quarters of this 25% (TRL, 2008). A recent study has shown that long term exposure to fine particle air pollution is an important risk factor for lung cancer (Pope et al, 2002). The conclusion must be that the total effect is probably greater than sum of the parts (WHIASU, 2002).

3.9.5 The concept of Local Air Quality Management was introduced under

Part IV of the Environment Act 1995 Section 82 of this act placed a duty on all local authorities to review air quality in their area with respect to a number of Air Quality Objectives. The Air Quality Objectives were subsequently formalised in the Air Quality Regulations 1997, 2000 and 2002. Air Quality Objectives can be defined as the Government’s medium term objectives. They are based on Air Quality Standards set by the Expert Panel on Air Quality Standards (EPAQS) and are the maximum acceptable level of a pollutant in the air that will not present a risk to the health of the most vulnerable groups in the population.


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3.9.6 The pollutants with standards set are particles (PM10), nitrogen dioxide, sulphur dioxide, carbon monoxide, benzene, 1,3-butadiene and lead. However, it is interesting to note that the standards do not include PM2.5 particulates which have recently given rise to concern amongst the public.

3.9.7 Local authorities therefore have a duty to monitor their area for air

quality and take action if it is found that air quality will exceed the standards set. As part of this process, by the end of April 2009 all local authorities are required to undertake an Updating and Screening Assessment (USA). This review of air quality means a consideration of the levels of pollutants in the air for which objectives are prescribed in Regulations and estimations of likely future levels. An assessment of air quality is the consideration of whether estimated levels for the relevant future period are likely to exceed the levels set in the objectives.

3.9.8 TBC has undertaken air quality monitoring of nitrogen dioxide using

passive diffusion tubes on Stoke Orchard Road in Bishop’s Cleeve between 2004 and 2005. The results are shown in the table.

Date 2004

Nitrogen Dioxide µg/m

3

Date 2005

Nitrogen Dioxide µg/m

3

January 11.99 January 21.50 February 21.22 February 28.22 March 23.49 March 22.61 April 16.50 April 19.00 May 15.89 May 12.45 June 14.84 June 17.45 July 18.46 July 19.57 August 12.89 August 13.86 September 15.10 September 20.00 October 15.05 October 20.92 November 29.81 November 26.72 December 25.78 December 26.61 Annual Average 18.42 Annual Average 20.74 Bias Correction 1.00 Bias Correction 1.00 Annual Average 19.42 Annual Average 21.74 Annual Target Objective 40.00

Annual Target Objective 40.00

Source: Tewkesbury Borough Council

Table 1: Nitrogen dioxide results for Stoke Orchard Road, Bishop’s Cleeve

3.9.9 The results of the monitoring show the annual average for nitrogen

dioxide to be well below both the EU and UK annual average target objective value i.e. 40µg/m

3. As a result of this the monitoring tubes


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were withdrawn and placed elsewhere. It is therefore not known if the increased annual average indicated an upward trend since 2005.

3.9.10 It is recognised that the methodology for this type of monitoring is not

without its limitations and it has been demonstrated that results from tubes such as these can vary as much as +50% and -50% so their accuracy is limited. In addition the potential pollutants emitted from vehicles are wider than nitrogen dioxide alone and so monitoring has not taken place for these other pollutants.

3.9.11 It is also recognised that as technology advances the potential for

vehicles - even larger lorries - to reduce their emissions through the use of alternative technologies and fuels should be explored at the earliest opportunity.

3.9.12 The Steering Group understand that levels of traffic have increased

since the monitoring took place and believe that additional monitoring should now be taking place. The Steering Group wrote to TBC recommending that passive tube monitoring be re-established for nitrogen dioxide and additional tubes be placed out. TBC have advised that they will re-instate the tube that was previously in place but have not advised that additional tubes will be utilised.

3.9.13 The Steering Group also requested that real time monitoring be

undertaken for a wider range of pollutants so that a more accurate baseline picture could be established of the full impact of traffic on air quality in the area. TBC have advised that they would undertake real time monitoring if the passive tube monitoring indicated that the concentration levels were potentially to exceed the EU and UK annual average target objective value.

3.9.14 The Steering group enquired as to whether predictive modelling of

traffic emissions and source apportionment could be undertaken by TBC. TBC have responded and advised that …”this is possible but it would first be necessary to have conducted real time pollutant and traffic monitoring in order to provide quantified data for the pollutant of interest and associated traffic flow. The cost of such an exercise would be in the order of £20,000 over the period of a year. The Authority would need a valid reason for such expenditure and more importantly would only do so on the basis of indicative monitoring showing a potential exceedance. Previous indicative monitoring by use of the diffusion tube has not supported this view”.

3.9.15 In addition the Steering Group have recommended to TBC that they

give consideration specifically to the Bishop’s Cleeve area and the locality surrounding the Wingmoor sites when undertaking its USA for 2009. TBC have advised that the detailed information relating to the USA has not been published and landfill sites might not fall within the consideration.


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3.9.16 Dr Tim Chatterton a specialist in air quality from the University of West of England has advised that air quality modelling is feasible but that there are significant costs associated with this.

3.9.17 The Steering Group looked at a recent paper from the Chemical

Hazards and Poisons Division (CHaPD) at the Health Protection Agency (HPA) (Mohan et al, 2009) kindly given to the Steering Group in advance of its publication in the Journal of Air and Waste Management Association and entitled “Evaluation of methodologies for exposure assessment to atmospheric pollutants from a landfill site”. The aim of the research was to evaluate the potential for using atmospheric dispersion modelling and Geographical Information Systems (GIS) for exposure assessment to atmospheric emissions from landfill sites.

3.9.18 The paper concluded that atmospheric dispersion modelling and GIS

can be applied to exposure assessment around a landfill site for epidemiological analysis. It illustrated that there is no simple relationship between predicted concentrations of atmospheric pollutants around such a site and location relative to the site. The analysis showed that using distance as a proxy for exposure around such sites is unlikely to represent individual or population exposure adequately. The paper identified that it is possible to improve on such basic estimates of exposure by a combination of dispersion modelling with population data and the known biology of postulated health effects to design optimum sampling procedures. The paper recommended that future epidemiological studies should consider applying similar approaches to those outlined in the paper to improve understanding of the health consequences of landfill site operation (Mohan et al, 2009).

Air Quality and Pollution Key Actions Tewkesbury Borough Council must recommence passive tube monitoring for nitrogen dioxide on Stoke Orchard Road and also introduce monitoring on the A435 Bishop’s Cleeve By-Pass in May 2009 or as soon as is reasonably practicable. The results must be made available in a timely manner to the Wingmoor Liaison Forum so that they are publically accessible. Tewkesbury Borough Council must undertake real time air quality monitoring and analysis at Stoke Orchard Road, Bishop’s Cleeve and the A435 Bishop’s Cleeve By-Pass to establish an accurate baseline of the impact of traffic on air quality in the area to commence in 2009. Comparative annual air quality monitoring and analysis thereafter must be undertaken to identify trends. Tewkesbury Borough Council must undertake to give specific consideration to the Bishop’s Cleeve area and the locality surrounding the Wingmoor sites when undertaking its Updating and Screening Assessment on air quality for 2009.


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3.10 Vehicle Movements 3.10.1 The Steering Group is concerned about the number of vehicle

movements and also the potential for road traffic collisions involving vehicles carrying hazardous waste, in particular APC residues. Vehicles pass not only through the Bishop’s Cleeve area but through Gloucestershire as a whole. The consignments can travel through many counties as a significant proportion of the waste that travels to the Wingmoor sites arises from outside the county. Due to the increases and changes at the Wingmoor sites over the years the full picture has never been obtained as to the number of vehicle movements as a whole to all the sites.

3.10.2 The Steering Group is concerned that each time a planning application

is received relating to any of the sites at Wingmoor, the totality of vehicle movements are not considered, only the vehicle movements relating to the individual site in question. The Group believe it is important to “take a step back” and for GCC to examine the current impacts of vehicle movements as a whole on the Stoke Orchard Road and the A435 By-Pass.

3.10.3 Accident data obtained from GCC for the dates January 2003 to

October 2008 showed no significant accidents involving vehicles related to the movement of waste to and from the Wingmoor sites, which the Group found reassuring.

3.10.4 Traffic count data obtained from GCC is shown below.

Mode of Transport

Number count Stoke Orchard Road to roundabout

Number count roundabout onto Stoke Orchard Road

Pedal cycle 13 0 Motor cycle 51 43 Car 2744 2985 Bus 6 10 Light Goods Vehicle

536 558

Goods Vehicle 1 239 216 Goods Vehicle 2 94 110 TOTAL

3683

3922

Source: Gloucestershire County Council

Table 2: Road traffic count for Thursday 6th September 2007 between 07.00 & 19.00hrs, Stoke Orchard Road, Bishop’s Cleeve

Definitions Car – with or without a trailer Bus – bus/coach Light Goods Vehicle – vehicles under 3.5 tonnes e.g. smaller vans, transits and pick ups Goods Vehicle 1 - vehicles over 3.5 tonnes, 3 axles or less & rigid. Some large vans fall into this category Goods vehicle 2 - as for goods vehicle 1 above, but 4 or more axles, rigid or articulated and with a trailer


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3.10.5 The data shows that 659 heavy goods vehicle (HGV) movements are made on Stoke Orchard Road in a 12 hour period. This equates to 55 in an hour – so approximately 1 HGV movement every minute. Where these vehicles are travelling to and from is not known but the Group believe this is a significant amount of large vehicles to be travelling along a ‘B’ road with residential properties alongside it. (An HGV is defined as those vehicles over 3.5 tonnes maximum permissible gross weight).

3.10.6 Grundon at its’ recent public consultation day identified that around 100

HGVs per day visit the Wingmoor Farm East site (mostly between the hours of 07.00 and 17.00hrs). This equates to around 200 movements along Stoke Orchard Road. The non hazardous operation at the site represents over 85% of vehicle movements of which nearly half are skips generally from Cheltenham and Tewkesbury. 75% of all waste brought to the site is delivered by third parties (Grundon, 2009).

3.10.7 The data produced by Grundon does not show how many vehicle

movements are made to and from the site in total i.e. to include all vehicles including those not classed as HGVs. The data does show that approximately one third of total HGV movements along Stoke Orchard Road can be attributed to traffic travelling to and from Wingmoor Farm East operated by Grundon.

3.10.8 It is not known how many goods vehicles (not just HGVs) in total visit each of the operations that make up the Wingmoor sites or how many vehicles in total travel to and from the Wingmoor sites as a whole.

3.10.9 Most members of the Steering Group were aware of the

Gloucestershire Local Resilience Forum (LRF) – a group established in April 2005 as a requirement of the Civil Contingencies Act 2004. The group had in effect been meeting prior to this as the Major Incidents Co-ordinating Group. The original group was established in 1990 in recognition of the need for integrated emergency management procedures. It has provided a forum for the co-ordination of a multi-agency response to major emergencies in Gloucestershire (GCC, 2008a).

3.10.10A sub-group entitled the LRF Risk Assessment sub-group provides

information to assist the LRF in drawing up its’ Community Risk Register. The Gloucestershire Community Risk Register has been created for two reasons. Firstly, to re-assure the people and communities of Gloucestershire that an assessment of potential hazards has been made or considered. Secondly, to satisfy the requirements outlined in the Civil Contingencies Act, 2004 and its associated statutory guidance (GCC, 2008a). The register currently does not hold any reference to the Wingmoor sites.


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3.10.11The Steering Group wrote to the Chair of the LRF Training Group requesting that consideration was given to undertaking an exercise around the subject of a road traffic collision in Bishop’s Cleeve involving a vehicle carrying waste to the hazardous waste landfill site. The Chair has agreed to offer support to a training event of this nature to take place in the autumn of 2009.

3.10.12The Steering Group have written to the Chair of the Risk Assessment

sub-group of the LRF requesting that the sub-group consider that the Wingmoor sites and associated activities are placed on the community risk register. This request is to be considered at a meeting of the Risk Assessment sub-group taking place on the 18th February 2009.

Vehicle Movements Key Actions Gloucestershire Local Resilience Forum must undertake in autumn 2009 an exercise around the subject of a road traffic collision in Bishop’s Cleeve involving a vehicle carrying hazardous waste to ensure that an appropriate response is in place. Gloucestershire Local Resilience Forum Risk Assessment sub-group must undertake to give due consideration that the Wingmoor sites and associated activities are placed on the community risk register. Gloucestershire County Council must actively undertake to take into account the cumulative effects of the combined Wingmoor sites operations including traffic management when considering any future planning application.


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3.11 Communication 3.11.1 The number of operators, agencies and statutory bodies that have to

be contacted to elicit information regarding the Wingmoor sites is vast and for a lay person or member of the local community this does lead to significant barriers. Frequently there are miscommunications and often the Steering Group feel that information is not always made available in a proactive and accessible manner. This can lead to mistrust, and poor perceptions of the operators, agencies and statutory bodies. It appears to the Group that there is no single impartial authoritative ‘one stop-shop’ channel of communication available to the wider community.

3.11.2 The Group acknowledge that effective communication to communities

poses many challenges particularly when dealing with complex processes and highly technical areas of work. However, engagement and involvement of the wider community through operators, agencies and statutory bodies is essential.

3.11.3 The Group acknowledge that Cory and Grundon both produce newsletters – these are distributed to those who are on their own mailing lists but this does not have the effect of reaching the wider community.

3.11.4 In 2004 the Wingmoor Liaison Forum (and its predecessor titles) was

established. This group consists of a wide range of stakeholders relative to all the activities and sites at Wingmoor including the operators, county, borough and parish elected representatives, GCC officers, the EA, the PCT, HPA and national and local interest groups.

3.11.5 In Spring 2007 Bishop’s Cleeve Parish Council in their parish council

newsletter which was distributed through a local newspaper, undertook a questionnaire in respect of the proposed licence extension at Wingmoor Farm that would be likely to be undertaken in 2009. The results of the questionnaire identified that the majority of people who responded (n=193) did not wish the Grundon site to have planning consent to extend the site beyond 2009. Additional responses to 2 further questions are contained in the summary sheet at Appendix B.

3.11.6 In January 2007 Grundon distributed 8000 community consultation

leaflets to specified areas. The leaflet sought responses from the local community on how the site [at Wingmoor Farm East] should be restored, post restoration management, use of existing buildings and operational timescales. The results were evaluated by the Empirical Research group at the University of Reading. 547 people responded to the leaflet. The results were shown to the public at the consultation day in January 2009 are shown at Appendix C.


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Communication Key Actions Operators of the Wingmoor sites must take a joined up approach with clear lines of responsibility to ensure that the community is provided with timely, clear, readily accessible information about their site including the exact nature of wastes accepted, presented in an easy to read and understand format, to commence April 2009. Operators must identify and share with the community how their site operations as a whole impact on the local community and how they are minimising those impacts, to commence April 2009. The Health Protection Agency must lead, in collaboration with key stakeholders, a community consultation event that will ensure the views of the local community are captured with respect to the issues raised in this report.


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3.12 Health Monitoring and Assessment 3.12.1 The Steering Group expressed concern that there is no process in

place to enable the health of the community near the Wingmoor sites to be monitored in a proactive way – a surveillance system in effect. This would be in particular relating to respiratory illnesses including asthma, skin conditions and carcinogenic effects. The Group particularly would like to see this in place for children.

3.12.2 The Group are aware that residents who lived in the vicinity of the

chemical explosion at Sandhurst, Gloucestershire are having their health monitored with respect to cancers for the next 20 years. The Group therefore wish to see a regular monitoring/surveillance process to be established for the local community that is in the proximity of the Wingmoor sites.

3.12.3 The current planning processes do not formally require an HIA to be

undertaken in its own right. Health is considered as part of an overarching environmental assessment and this only applies to certain types of development. The Steering Group believe that an HIA should be an integral part of any planning application where landfill and waste treatment sites are involved. The HIA should also have a very strong community engagement element so that the voice of the community is taken into account. If planning consent is granted, after this time there should be an ongoing review of the HIA on a regular basis.

3.12.4 CHaPD at the Centre for Radiation, Chemical and Environmental

Hazards at the HPA has recently proposed that an Environmental Public Health Tracking Programme (EPHTP) be established by the HPA. This programme is defined as;

“the ongoing collection, integration, analysis, and interpretation of data about environmental hazards, exposure to environmental hazards, and human health effects potentially related to exposure to environmental hazards. It includes dissemination of information learned from these data”.

The programme is as yet not funded to proceed.

Health Monitoring and Assessment Key Actions NHS Gloucestershire must undertake a long term prospective cohort study of new born babies in the area surrounding the Wingmoor sites in order to identify any specific health issues to commence in 2009. The Health Protection Agency must resource and implement the proposal to introduce an Environmental Public Health Tracking Programme to commence in 2009 or at the earliest opportunity. The Environmental Public Health Tracking Programme must report their findings at regular intervals to the appropriate fora so that residents are made aware of any findings.


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Gloucestershire County Council must ensure that planning applications are accompanied by a formal health impact assessment and human health risk assessment as part of a wider ranging environmental impact assessment, when future applications for planning consent are submitted. The community must be directly involved in these processes. Regular ongoing reviews of the HIA and human health risk assessment must take place.


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3.13 Cumulative Effects including Planning & Strategic Considerations 3.13.1 The Steering Group believe that an area that is overlooked by several

agencies is the “cumulative effect” relating to the Wingmoor sites. 3.13.2 GCC consider planning applications on the individual application before

them, the EA consider each individual permit separately and the HPA comment on each individual permit on which they are consulted.

3.13.3 The Steering Group feel it is imperative that these agencies examine,

review and consider both the current and potential cumulative effects of the Wingmoor sites as a whole on the local community.

3.13.4 The Regional Spatial Strategy (RSS) is a key document that provides a

regional level planning framework for the next 15 to 20 years (South West Regional Assembly, 2008). This document has been reviewed by the Steering Group. The document does not go into great detail relating to waste and more specifically hazardous waste. The Group believe that there has been a presumption that the sites at Wingmoor will continue to operate. The document does not identify whether alternative options for sites has been explored. The group therefore feel that a strategic review of waste and more specifically hazardous waste in the South West has not been examined in sufficient detail.

3.13.5 The RSS outlines the proposal to undertake an extension of 5000

homes to an area North West of Cheltenham. The area that this covers would significantly increase the resident population within proximity to the Wingmoor sites.

Cumulative Effects including Planning and Strategic Considerations Key Actions Gloucestershire County Council must actively undertake to take into account the cumulative effects of the combined Wingmoor site operations including traffic management when considering any future planning application. The Environment Agency must actively take into account the cumulative effects of the combined landfill site operations at Wingmoor when considering any future permit applications. Government Office of the South West must undertake to review the planning position in the South West region with regard to waste treatment and landfill sites and in particular sites that handle hazardous waste.


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4.0 Overarching themes arising from the Health Impact Assessment 4.0.1 The Steering Group identified that there are a number of common and

overarching emerging themes that have arisen out of the work that require focus.

4.0.2 There is limited health data collected and made available on a

proactive basis which relates specifically to the local community that live in close proximity to the Wingmoor sites.

4.0.3 There is a perceived lack of transparency in the information available to

the public and communities – it being available in a number of different formats and from a wide range of agencies. The belief is that the processes that sit around accessing information in a clear readily accessible format are bureaucratic and the terminology and language used are often not suited to a lay reader. This leads to concerns that things are being “hidden”.

4.0.4 The general feeling is that the community is not being listened to

adequately and that the very real perceptions brought to the note of regulators, operators and other agencies are not taken seriously. It is felt that a number of perceptions could readily be allayed by suitable responses and co-operation with those involved at the Wingmoor sites.

4.0.5 There is a wide range of data being gathered and collated by a wide

range of agencies. This is not being brought together in an organised and centralised manner and assessed as a whole. This does not enable cumulative and trend data to be able to be assessed/analysed and interpreted.

4.0.5 The Steering Group believe that the change by regulators since the

introduction of Integrated Pollution Prevention Control (IPPC) permits from “regulating” of waste sites to “self regulation” by operators of these sites has reduced public confidence in the effectiveness of the regulatory process.

4.0.6 The Steering Group believe there is no clear vision at a national and

regional level for how hazardous waste is to be handled and disposed of. This also leads the Steering Group to perceive that consideration has not been given at a strategic level as to whether alternative site locations have been considered to potentially relocate the Wingmoor sites due to their close proximity to housing and the community.

4.0.7 There is an overarching belief that there has been “development creep”

at the Wingmoor sites, which due to the nature of planning processes means that the sites cannot contextually be considered as a whole when planning applications are made.

4.0.8 Insufficient research is being undertaken in the UK relating to landfill

sites and waste treatment plants and more specifically hazardous


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waste landfill sites and their potential effects on health. The aim of this research should be to produce a robust and improved evidence base.

4.0.9 That actions undertaken by agencies are not always followed through

even when recommendations are made for further work, actions or research need be undertaken.


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5.0 Key Areas for Action This report makes a number of key and pressing key areas for action to a variety of agencies:

5.1 NHS Gloucestershire (Gloucestershire Primary Care Trust) 5.1.1 NHS Gloucestershire must undertake a study to determine the potential

effects of the Wingmoor sites on the physical and mental health and wellbeing / stress of local residents (to include asthma) who live in proximity to the Wingmoor sites to be completed in 2009.

5.1.2 NHS Gloucestershire must undertake a comparative update of the

Bishop’s Cleeve Neighbourhood Health Profile every 3 years commencing in 2009.

5.1.3 NHS Gloucestershire must undertake a long term prospective cohort

study of new born babies in the area surrounding the Wingmoor sites in order to identify any specific health issues to commence in 2009.

5.2 Health Protection Agency 5.2.1 The Health Protection Agency must lead, in collaboration with key

stakeholders, a community consultation event that will ensure the views of the local community are captured with respect to the issues raised in this report.

5.2.2 The Health Protection Agency must resource and implement the

proposal to introduce an Environmental Public Health Tracking Programme to commence in 2009 or at the earliest opportunity. The Environmental Public Health Tracking Programme must report their findings at regular intervals to the appropriate fora so that residents are made aware of any findings.

5.3 Wingmoor Site Operators 5.3.1 Operators of the Wingmoor sites must take a joined up approach with

clear lines of responsibility to ensure that the community is provided with timely, clear, readily accessible information about their site including the exact nature of wastes accepted, presented in an easy to read and understand format to commence April 2009.

5.3.2 Operators must identify and share with the community how their site

operations as a whole impact on the local community and how they are minimising those impacts to commence April 2009.

5.4 Gloucestershire County Council 5.4.1 Gloucestershire County Council must ensure that planning applications

are accompanied by a formal health impact assessment and human health risk assessment as part of a wider ranging environmental impact assessment, when future applications for planning consent are submitted. The community must be directly involved in these processes. Regular ongoing reviews of the health impact assessment and human health risk assessment must take place.


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5.4.2 Gloucestershire County Council must actively undertake to take into

account the cumulative effects of the combined Wingmoor site operations including traffic management when considering any future planning application.

5.4.3 Gloucestershire County Council must undertake to use ‘quiet surfaces’

on the key roads that surround the Wingmoor sites. 5.5 Gloucestershire Local Resilience Forum 5.5.1 Gloucestershire Local Resilience Forum must undertake in autumn

2009 an exercise around the subject of a road traffic collision in Bishop’s Cleeve involving a vehicle carrying hazardous waste to ensure that an appropriate response is in place.

5.5.2 Gloucestershire Local Resilience Forum Risk Assessment sub-group

must undertake to give due consideration that the Wingmoor sites and associated activities are placed on the community risk register.

5.6 Tewkesbury Borough Council 5.6.1 Tewkesbury Borough Council must recommence passive tube

monitoring for nitrogen dioxide on Stoke Orchard Road and also introduce monitoring on the A435 Bishop’s Cleeve By-Pass in May 2009 or as soon as is reasonably practicable. The results must be made available in a timely manner to the Wingmoor Liaison Forum so that they are publically accessible.

5.6.2 Tewkesbury Borough Council must undertake real time air quality

monitoring and analysis at Stoke Orchard Road, Bishop’s Cleeve and the A435 Bishop’s Cleeve By-Pass to establish an accurate baseline of the impact of traffic on air quality in the area to commence in 2009. Comparative annual air quality monitoring and analysis thereafter must be undertaken to identify trends.

5.6.3 Tewkesbury Borough Council must undertake to give specific

consideration to the Bishop’s Cleeve area and the locality surrounding the Wingmoor sites when undertaking its Updating and Screening Assessment on air quality for 2009.

5.7 Environment Agency 5.7.1 The Environment Agency must actively take into account the

cumulative effects of the combined landfill site operations at Wingmoor when considering any future permit applications.

5.7.2 The Environment Agency must undertake to complete the analyses of

the dust monitoring carried out by DustScan Ltd to commence in 2009 or as soon as is practicable. The results of the analyses must be made publically available and sent to the Wingmoor Liaison Forum. These analyses must be undertaken annually thereafter following monitoring.


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5.7.3 The Environment Agency must commit to carrying out the recommendations of the findings of the Macelod study relating to air pollution control residues.

5.7.4 The Environment Agency must undertake research with regard to the

effects to health of the “cocktail effect” of wastes that enter landfill sites. 5.7.5 The Environment Agency must undertake noise monitoring of the

Wingmoor sites and associated traffic to establish a baseline to be completed in 2009.

5.8 Government Office of the South West 5.8.1 Government Office of the South West must undertake to review the

planning position in the South West region with regard to waste treatment and landfill sites and in particular sites that handle hazardous waste.

5.9 Gloucestershire Health Overview and Scrutiny Committee 5.9.1 The Health Overview and Scrutiny Committee must undertake to

ensure that the key areas of action identified in this report are monitored regularly to ensure that the actions are being undertaken by the identified agencies.

5.10 Wingmoor Liaison Forum 5.10.1 The Wingmoor Liaison Forum must undertake to ensure that the key

areas of action identified in this report are monitored regularly to ensure that the actions are being undertaken by the identified agencies.

6.0 Conclusion


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6.0.1 The Steering Group has examined the potential impacts to health from

the Wingmoor sites, with a particular focus on stress and the specific relevant potential causal factors that might give rise to this. It is known that too much stress can lead to physical, mental, and emotional ill health including anxiety and depression. Based on those areas of community health for which data exists, the Steering Group have found no definitive evidence to suggest that the health of the community has been affected by the Wingmoor sites. However, the Group would strongly emphasise that there has often been no definitive data or answers to the areas that have been explored in detail. This does not negate the considerable concern expressed by those in the community who live near the Wingmoor sites. A lack of definitive evidence based research itself should not mean that operations should not be examined in more detail where concerns have been identified. The Group identified many gaps where further research and knowledge is required to inform and establish a baseline of evidence. Based on this, the Group believe that a “precautionary principle” should be exercised on the basis of concerns relating to health.

6.0.2 The Steering Group feel overwhelmingly that they wish to be seen as

an equal partner and for their views to be validly taken into account. They seek an active dialogue that avoids technical jargon, expresses issues with clarity and most importantly they wish to be listened to. The Group wish for all statutory agencies, other key stakeholders and operators to work together to enable this to happen.

6.0.3 The Group understands the need for waste treatment plants and landfill

sites and that the Wingmoor sites undertake this role. They also recognise and understand that operators of the Wingmoor sites have a legal framework within which they have to operate. However, the Wingmoor sites do not appear to have developed in a strategic, cohesive manner and their cumulative effects do not appear to have been given due consideration. The Group reflected on whether operations of the nature undertaken at the Wingmoor Sites would be permitted to open and operate so close to a community if a new application were to be received today in light of current knowledge and the concerns of the community.

6.0.4 The Group have had a valuable insight into the varied statutory

agencies involved with the Wingmoor sites. However the varied division of roles and responsibilities of these agencies means that it is often unclear as to who, if anyone, is able to take a ‘lead role’ and bring all the varied information together to inform all those involved. It appears to the Group that the development and expansion of the Wingmoor sites has not been undertaken in a strategic manner. Statutory agencies therefore have been highlighted as needing to demonstrate and operate a more joined up approach to dealing with the Wingmoor Sites. This needs to be more proactive with clear lines


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of responsibility to enable strategic oversight, co-ordination and accountability to operate.

6.0.5 The Steering Group have specified a number of key areas of action

which are for each agency to consider. The Group require that those Agencies identified with actions should respond to their relevant key actions and provide an update by 1 March 2010 through the auspices of the Wingmoor Liaison Forum.


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7.0 Comments and feedback 7.0.1 The final draft of the report is to be circulated to the following so that

comment and feedback for accuracy on the report can be made before it is finally published in full for the public.

• Bishop’s Cleeve Parish Council - Clerk • Cory Environmental (Gloucestershire Ltd) • Elmstone Hardwick Parish Council - Clerk • Environment Agency – Tewkesbury Office • Gloucestershire County Council – planning, transport and waste

departments within Environment Directorate • Gloucestershire Health Overview Scrutiny Committee - Chair • Gloucestershire Health Overview and Scrutiny Wingmoor Task

Group - Chair • Gloucestershire Local Involvement Network - Chair • Gloucestershire Local Resilience Forum – Chairs of the training

group and risk assessment group • Government Office of the South West - Regional Strategies,

Housing and Planning Directorate • Gotherington Parish Council - Clerk • GP surgeries contributing to asthma data analysis • Grundon Waste Management Ltd – Reading and Oxfordshire

offices • Health Protection Agency – Gloucestershire office and Chemical

Hazards and Poisons Division of the Health Protection Agency - Birmingham and London offices

• May Gurney Ltd – Gloucester office • NHS Gloucestershire – Director of Public Health • South West Public Health Observatory • Southam Parish Council - Clerk • Stoke Orchard Parish Council - Clerk • Safety in Waste and Rubbish Disposal • Swindon Parish Council - Clerk • Tewkesbury Borough Council – Chief Executive, Pollution Control

and Councillors for relevant wards • Uckington Parish Council - Clerk • Woodmancote Parish Council - Clerk


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8.0 ADDITIONAL INFORMATION 8.1 Background – the Wingmoor Sites 8.1.1 The Wingmoor sites that are the subject of the HIA are located at

Wingmoor Farm, Stoke Orchard Road, Bishop’s Cleeve, Cheltenham, Gloucestershire GL52 7DG.

8.1.2 The Grundon site is approximately 50 hectares in size and takes inert

waste, hazardous waste, non-hazardous waste and stable non-reactive hazardous waste to landfill. Grundon have been operating at this specific site since 1989. Grundon have planning permission to use the site until 2009, after which time a new planning permission would be required. It is understood that Grundon submitted a new pre application consultation to GCC October 2008 to cover the:

“Proposed continuation of mineral extraction and restoration through

the importation of wastes. Extraction of sand, gravel and clay; restoration of land to the profile approved in 1995 (Planning Permission Ref: 95/8446/1099), through the importation of non-hazardous and hazardous wastes; operation of the waste treatment plant; operation of a plant to produce a lightweight aggregate; use of the landfill gas control system and associated landfill gas engines, and use of ancillary infrastructure, such as weighbridges, sand and gravel processing plant, and office and mess facilities required for the operation and restoration of the site”.

8.1.3 A treatment plant also is sited at Wingmoor Farm and operated by

Grundon. This plant takes in APC residues and mixes them with leachate and water to make them suitable for landfill.

8.1.4 In addition at the site known generically as Wingmoor Farm there are

other operators who each operate a separate site and have different planning consents and permits.

8.1.5 Grundon also operate the site that is known as Wingmoor Quarry,

having purchased it from Gloucester Sand and Gravel in November 2001. This site currently takes non-hazardous landfill. Planning consent exists on this site to operate a materials recovery facility (MRF) until the end of December 2008.

8.1.6 Cory Environmental (Gloucestershire) Ltd operates a non-hazardous

waste site at Wingmoor Farm West. This site takes municipal solid waste from individual households and commercial businesses. The site also undertakes composting and recycling at the site.

8.1.7 May Gurney Ltd operates the household recycling centre on behalf of

GCC at Wingmoor.


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8.1.8 The split between hazardous and non-hazardous waste occurred in 1996 so all sites have previously accepted waste some of which would currently be described as hazardous waste.

8.1.9 It is acknowledged that the community is currently living with a legacy

from the 1990s when increased tonnages were permitted at the sites and housing was permitted to be developed in close proximity of the sites – the closest being approximately 50m from one site.

8.1.10 There are significantly fewer landfill sites in the UK that take hazardous

waste due to changes in legislation. It is understood from the EA website that there are less than 20 sites in the UK that accept hazardous waste – therefore a significant amount of hazardous waste accepted at Wingmoor is from outside the county and the region.

8.2 Waste 8.2.1 Waste is a complex mixture of different substances and objects, only

some of which are intrinsically hazardous to health. However, any type of waste has the potential to affect health depending on the collection system used, the location where waste is generated, and the waste management strategy employed.

8.2.2 Waste management is broader than just the disposal of waste. It

includes the generation, collection, processing and transport of waste as well as the minimisation of the production of waste and the re-conceptualising of waste as a resource. The public health impacts are influenced by the overall waste management strategy adopted locally, regionally and nationally. The waste management options chosen by decision makers could have an impact on health both directly and indirectly (SWPHO, 2002).

8.2.3 Two key documents can be referred to for Gloucestershire these are;

Joint Municipal Waste Management Strategy 2007 – 2020 (Gloucestershire Waste Partnership, 2007) http://www.recycleforgloucestershire.com/joint_strategy/assets/JMWMS.pdf and The Waste Core Strategy – this is in development at this current time but Issues and Options and the Preferred Options documents have been published and can be found at http://www.gloucestershire.gov.uk/index.cfm?articleid=13349

8.3 Landfill and Legislation 8.3.1 One definition of landfill by Tubb and Iwugo (in SWPHO, 2002)

identified that landfill is the dumping of waste on the land. The term landfill includes a wide spectrum of sites ranging from managed, engineered, regulated sites to illegal, uncontrolled dumps. Currently, in a typical UK municipal landfill, waste is deposited in a pre-constructed cell in an engineered site. The base is impermeable clay or is lined with


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a plastic, rubber or composite layer covered by earth. At the end of each day, the waste is covered with an inert material such as soil. When the cell is full, it is covered over with a layer of inert material. During operation, a fence is built around the site to prevent the wind from blowing material off site. A drainage system is built to collect water runoff and leachate. An energy recovery system can be constructed to collect gas which can either be used to generate electricity or can be flared.

8.3.2 The Landfill Directive (99/31/EEC) regulates the operation of landfill

sites in the UK. To protect human health, the Directive identifies what can be disposed of to landfill. It requires treatment prior to landfilling except for inert wastes and requires aftercare of closed landfills.

8.3.3 The benefits of landfill are:

• It has been a cheap way to dispose of waste by dumping it in disused quarries and abandoned industrial sites.

• Waste is used to backfill quarry before reclamation. • Landfill gas contributes to renewable energy supply.

The disadvantages of landfill are: • Water pollution from leachate and runoff. • Air pollution from the anaerobic decomposition of organic matter

producing methane, carbon dioxide, nitrogen, gases, sulphur, and volatile organic compounds.

• It is not a sustainable option. (SWPHO, 2002)

8.3.4 The Landfill Directive is helping to bring about a change in the way we dispose of waste in this country. It aims to reduce the pollution potential from landfilled waste that can impact on surface water, groundwater, soil, air, and also contribute to climate change.

8.3.5 In England and Wales the directive is applied under the Landfill

(England and Wales) Regulations 2002 (and subsequent amendments) and must be fully implemented by July 2009. The directive sets demanding targets to reduce the amount of biodegradable municipal landfilled waste.

8.3.6 The EA is the regulatory body responsible for implementing the Landfill

Directive in England and Wales. They do this in a variety of ways such as the permitting of waste management facilities and administration of the Landfill Allowance Trading Scheme.

8.3.7 The Environment Agency is responsible for regulating landfills, waste

treatment facilities and large industrial processes by permits. They monitor compliance with these permits including how waste is being managed through routine inspections and periodic audits. Records are kept of waste received and produced by these activities. This allows them to track the source of the waste and ensure that waste is being handled properly.


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8.3.8 Historically, decisions on the types of waste acceptable at landfills were

entirely based on site-specific risk assessment. Licences controlled the quantities and types of waste to be accepted and often, in the case of hazardous waste, specified maximum loading rates for particular wastes or components substances. Landfill operators had to have systems (acceptance procedures) in place to ensure that incoming waste was within those limits. Those producing waste or delivering waste for landfill had an obligation under the duty of care to ensure that the waste was properly described. This is still the case.

8.3.9 The Landfill Directive says that individual landfills accept only

hazardous waste or non-hazardous waste or inert waste. This has ended the practice of co-disposal since July 2004. The move to dedicated landfills for hazardous waste has dictated tighter controls over site engineering and 'quality' of the waste going into the sites. It has also led to a substantial reduction in the number of sites that are able to take hazardous waste. Wingmoor Farm being one of now designated sites to take hazardous waste.

8.4 Planning Considerations and Processes 8.4.1 The RSS is a key document that provides a regional level planning

framework for the next 15 to 20 years. It covers the Environment, Infrastructure, Transport, Housing, Economic development, Agriculture, Minerals and Waste. Section 7 of the draft South West RSS identifies the regional approach to how waste management including hazardous and other wastes should be addressed (South West Regional Assembly, 2008).

8.4.2 Land where waste disposal occurs has to hold planning permission as

well as holding a permit from the EA. The planning process for landfill and waste sites is undertaken by GCC through its Development Control Team who deal with all minerals and waste developments in the county.

8.4.3 Specifically relating to the Grundon site GCC have advised the

following;

The substantive planning permission for the mineral extraction, backfilling and landraising with non-hazardous and hazardous wastes and associated activities will cease in May 2009. The site has not been completed in accordance with the approved profiles and there is still void space remaining, Grundons would like to increase the amount of time taken to complete the landfill operation to the formerly approved profiles Grundons intend to submit a planning application to continue mineral extraction and restoration of the site through landfilling for a further 20 years.

The Mineral and Waste Planning Authority considers that this development falls under Schedule 1 of the above Regulations and


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therefore the Environmental Impact Assessment (EIA) is mandatory. The proposal falls under the description of development, ‘the carrying out of development to provide for: 9.Waste disposal installations for the incineration, chemical treatment (as defined in Annex IIA to the Council Directive 75/442/EEC(a) under heading d9) or landfill of hazardous waste (that is to say, waste to which Council Directive 91/689/EEC9b) applies).

The applicant has submitted a scoping report detailing what it considers should be contained within the EIA and the Mineral Planning Authority has adopted a scoping opinion.

Once an application is submitted GCC have to consult statutory consultees such as the EA, and publicise the application via a news advertisement, site notice and neighbour consultations. As the application will involve an EIA, the Secretary of State will have to be notified of the application.

The County Council has 16 weeks within which to determine the application once received (GCC, 2008b)

8.4.4 The Group feels that there is “democratic deficit” in how communities

can feed into the planning process with respect to waste and in particular hazardous waste.

8.5 Permits and Hazardous Waste 8.5.1 All landfills are “permitted” and regulated by the EA. The EA issue

sites with a licence to operate under the Environmental Permitting Regulations 2007 (previously the Pollution, Prevention and Control (England and Wales) Regulations 2000 which implemented the European IPPC Directive (96/61/EC). This was introduced across Europe to improve the standard of environmental protection.

8.5.2 The Directive covers:

• the disposal of waste by landfill • waste treatment and storage facilities that dispose of >10 tonnes of

hazardous waste per day • facilities that treat >50 tonnes of non-hazardous waste per day, and • some hazardous waste recovery operations that treat >10 tonnes of

hazardous waste per day.

8.5.3 An Environmental Permit for these types of facilities will also be a permit implementing aspects of other directives including the Waste Framework Directive, Hazardous Waste Directive, Waste Oils Directive and PCB Directive.

8.5.4 Waste can only be accepted at a landfill site if they meet the WAC for

that type of site. There are also stringent waste acceptance procedures (known as WAP). The management and treatment of APC


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residues at Wingmoor does not meet the EU WAC requirements and as a result the operator has been granted a derogation from the EA to exceed the limits.

Waste materials fall into three categories. These are fully defined within the legislation and are:

• Inert waste (e.g. bricks, concrete, waste glass) • Non hazardous waste (e.g. general household waste) • Hazardous waste - shows one or more of fourteen hazards (e.g.

flammable, toxic, corrosive etc.)

8.5.5 Hazardous waste is defined by Article 1 (4) of the Hazardous Waste Directive i.e. it is waste on the European Waste Catalogue (EWC) having hazardous properties. The EWC was implemented in 2002 and the definition of the EWC code for any waste will ultimately classify the waste stream and therefore determine the type of landfill at which it can be disposed.

8.5.6 Some examples of hazardous waste include:

• Demolition waste • Filter cakes • Contaminated soils • Fluorescent tubes • Television monitors • Absorbents and filter materials • Contaminated packaging • Sludges • Fly ash which is hazardous • Asbestos – fibrous and bonded

8.5.7 The Grundon Wingmoor Farm landfill site can currently accept up to

120,000 tonnes of hazardous waste per year on the site. In 2005 it accepted 63,000 tonnes of waste at the site. Grundon advised the Steering Group that they accept waste at the site in the following proportions

• 30% APC residues • 45% Contaminated soils • 10% Road planings • 5% Filter cakes • 5% Refractory ceramics

8.5.8 APC residues are a by-product of municipal waste incinerators. The

waste is created as a result of the treatment of the combustion gases. The gases are cleaned by adding lime to neutralise any excess acid, then finely divided carbon is added to remove the dioxins and heavy metals. Then filters are used within the process to remove the fine


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particles, lime and carbon and this is the APC residues (a mixture of fly ash, carbon and lime) (EA, 2002).

8.5.9 The Group expressed concerns with respect to other wastes that have

been placed at the Wingmoor sites. The EA has advised the Steering Group, following an enquiry to them that the waste management licence was modified in June 2001 to allow the hazardous waste site to accept carcases of animals to be disposed of due to the foot and mouth outbreak. Grundon advise through the EA that 13,000 tonnes of carcases were accepted between April and November 2001. Sheep, cattle, pigs and goat carcases that arose from the “buffer zones” around affected sites were disposed of (these were the animals culled as a precautionary measure). No infected animals were placed in the landfill but pyre ashes from incinerated animals were landfilled at Wingmoor.

8.6 Monitoring of Landfill Sites 8.6.1 The EA are the responsible body for regulating the permit and

monitoring the site. The EA issue permits through the legislation described above. Permits contain a number of conditions which are designed to prevent harm to human health and pollution of the environment. The EA are responsible for ensuring that these conditions are met. They do this by carrying undertaking the following actions:

• regular announced and unannounced inspections; • Undertake monitoring of emissions • require operators to inform the EA if they exceed any of the

emission limits set in the pollution control permit, or if they fail to comply with any operating conditions;

• investigate non-compliance with the pollution control permit issued; • taking enforcement action if needed, including prosecuting serious

breaches or potentially revoking the permit. 8.6.2 About 1.5 per cent of pollution incidents reported in 2006 occurred at

landfill sites (EA, 2009)


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9.0 Other Agencies & Groups as Stakeholders to the Wingmoor Sites 9.1 Tewkesbury Borough Council 9.1.1 Local district councils usually have the remit for enforcing noise and

vibration that might cause nuisance to neighbours. TBC have advised that they have no control over noise and vibration from vehicular traffic when considering action under nuisance legislation. TBC also do not hold responsibility for noise arising from waste and landfill sites where the EA have issued a permit.

9.2 Gloucestershire Health Overview and Scrutiny Committee 9.2.1 The primary role of the GCC HOSC is to focus on health improvement

by working in partnership and bringing together the Council's responsibilities for well-being and reviewing, whilst also, constructively challenging and monitoring local services provided and commissioned by the NHS including equality of provision.

9.2.2 The Committee is responsible for

• Focusing on health issues from the public's perspective • Acting as a lever to improve the health and those services that

impact on the health of local people • Working in partnership with other agencies • To address issues of health inequalities between different groups in

the community. (GCC, 2008c)

9.2.3 In 2006 in response to community concerns GCC HOSC established a

sub-group – “The Wingmoor Farm Task Group”. This group is undertaking a review of the Wingmoor sites.

9.3 Bishop’s Cleeve Parish Council 9.3.1 Bishop’s Cleeve Parish Council is divided into three wards – Cleeve St

Michaels’, Cleeve West and Cleeve Grange. There are 15 parish councillors in total.

9.3.2 The Parish Council is a statutory consultee for planning applications for

their geographical area and a sub committee that deals with planning application consultations responds with their comments on this basis.

9.4 Gloucestershire Local Involvement Network 9.4.1 LINks were introduced in 2007 in the Local Government & Public

Involvement in Health Act to give local communities a stronger voice in the process of commissioning and delivering health and social care. Every local authority in England that has a responsibility for health and social care services must have a LINk.

9.4.2 A LINk is made up of individuals, community groups, and organisations

who will help to shape, develop and improve health and social care


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services. LINk is an independent body that has a much wider remit than the former Patient and Public Involvement Forums that it replaces.

9.5 Safety in Waste and Rubbish Disposal 9.5.1 SWARD is a residents’ group with a paid-up membership of over 270

households in Bishop’s Cleeve, Woodmancote, Stoke Orchard, Uckington, Elmstone Hardwicke, Brockhampton, Gotherington and Cheltenham.

9.5.2 SWARD was formed in 2001 when a local resident raised concerns

over the contents and type of waste in the landfill site adjacent to her home. The first public meeting was arranged and held in February 2001. From that meeting SWARD membership has increased over time.

9.6 Health Protection Agency 9.6.1 The HPA was established in 2003 – the functions of the Agency are "to

protect the community (or any part of the community) against infectious diseases and other dangers to health". Within the HPA CHaPD sits within the Centre for Radiation, Chemical and Environmental Hazards.

9.6.2 CHaPD is a central source of advice to DH and DEFRA and its

agencies on the health effects of chemicals in waste and provides expert advice to the HPA, NHS, Regulators and the public on the public health aspects of waste management.

9.6.3 CHaPD works with key partners to develop evidence based positions.

Publications on waste management include statements and reviews on municipal waste incineration, substitute fuels in cement kilns, and landfill sites. The division has also provided input to the WHO review of population health and waste management (HPA, 2008).

9.6.4 In addition the HPA supports PCTs in fulfilling their responsibilities as

statutory consultees within the IPPC regime by providing advice and guidance in responding to consultations. The health response to a consultation covers the following elements

• To offer a view on the potential health impact of emissions and

activities of a particular installation (based on the information provided in the application) and to place any risks into a local context for example does the operator demonstrate a high level of protection for human health? This may also include consideration of the level of a public health nuisance reported in relation to the installation.

• To identify any existing local health issues that may be associated

with the installation or its location, e.g. are there any local health problems that could be related to, or exacerbated by, the installation?


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• To identify any future health issues that could be associated with

the installation or its location, e.g. are there any problems or issues on the horizon that the Regulator needs to take into consideration?

• To provide reassurance to the local community, e.g. reassurance

that an installation will not present a significant risk to human health. (HPA, 2004)

9.6.5 Dr Patrick Saunders, Head of Environmental Health and Risk

Assessment in CHaPD at the Centre for Radiation, Chemical and Environmental Hazards at the HPA have recently proposed that an Environmental Public Health Tracking Programme be established by the HPA. This programme is defined as;

“the ongoing collection, integration, analysis, and interpretation of data about environmental hazards, exposure to environmental hazards, and human health effects potentially related to exposure to environmental hazards. It includes dissemination of information learned from these data”.

This programme is currently seeking the resources in order for it to be implemented.

9.7 Wingmoor Liaison Forum 9.7.1 The Wingmoor Liaison Forum (and its predecessor titles) has been

meeting since 2004. The group consists of a wide range of stakeholders relative to all the activities and sites at Wingmoor. The PCT and the HPA have both attended meetings of the Wingmoor Liaison Forum to provide health input into the meetings.

9.7.2 In October 2005 the then Cheltenham and Tewkesbury PCT (now NHS

Gloucestershire) produced a neighbourhood health profile of Bishop’s Cleeve in response to concerns raised by the local people about the impact on their health of the hazardous waste landfill site. The profile identified that people living in the Bishop’s Cleeve area generally experience levels of ill health which do not differ markedly from people living in other areas of Gloucestershire when a range of established health indicators and other less robust sources of evidence are compared.

References


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Air Quality (England) (Amendment) Regulations 2002 (SI 2002/3043)

Air Quality (England) Regulations 2000 (SI 2000/928)

Air Quality Regulations 1997 (SI 1997/3043) Anderson et al (1995) Health effects of an air pollution episode in London: December 1991. Thorax 1995; 50: 1188-93. Barrat B et al (1996) Air quality in London 1995: the third report of the London Air Quality Network. Tunbridge Wells, South East Institute of Public Health Berglund B et al (1999) Guidelines for community noise. Geneva: WHO

Carpenter et al (1998) Human health and chemical mixtures : an overview. Environmental Health Perspectives 1998; 106,Supp 5:1263-1270 Carpenter et al (2008) Asthma and Infectious Respiratory Disease in Relation to Residence near Hazardous Waste Sites. Annals of the New York Academy of Sciences 2008; 1140(1): 201-208 Cheltenham and Tewkesbury Primary Care Trust (2005) Bishop’s Cleeve Neighbourhood Health Profile

Council Directive 96/61/EC of 24 September 1996 on Integrated Pollution Prevention and Control Council Directive 99/31/EEC of 26 April 1999 on Landfill Council Directive 2002/49/EC of 25 June 2002 on the Assessment and Management of Environmental Noise

Council Directive 91/689/EEC of 12 December 1991 on Hazardous Waste

Dahlgren, G. Whitehead, M (1991) Policies and Strategies to promote social equity in health. Stockholm: Institute of Future Studies Department of Communities and Local Government (1994) Planning Policy Guidance (PPG 24) Planning and Noise. London: HMSO Department of the Environment (1997) The United Kingdom Air Quality Strategy. London: The Stationery Office Department for Environment, Food and Rural Affairs (2003) A study to estimate the disamenity costs of landfill in Great Britain. London: DEFRA Department of the Environment, Transport and the Regions (1999) The Air Quality Strategy for England, Scotland, Wales and Northern Ireland. London: The Stationery Office

Department of Health (1995) Committee on the Medical Effects of Air Pollutants. Asthma and Air Pollution. London: HMSO


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Department of Health. Committee on the Medical Effects of Air Pollutants (1998) Quantification of the Effects of Air Pollution on Health in the United Kingdom. London: The Stationery Office Department of Health (2003) Tackling Health Inequalities – A Programme for Action. London: The Stationery Office

Department for Transport (1988) Calculation of road traffic noise. London: HMSO

Environment Act 1995, Ch 25. London: HMSO

Environment Agency (2002) Solid residues from Municipal Waste Incinerators in England and Wales. A report on an investigation by the Environment Agency

Environment Agency (2008) Wingmoor waste treatment plant audit August 2008, Grundon Waste Management.

Environment Agency (2009) Landfill [Internet]. Available from : http://www.environment-agency.gov.uk/research/library/data/34423.aspx [Accessed 14th January 2009]

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Gloucestershire Conference (2008) The Gloucestershire Local Area Agreement 2008 – 2011. Gloucester: Gloucestershire County Council

Gloucestershire County Council (2008a) Local Resilience Forum [Internet]. Available from: <http://www.gloucestershire.gov.uk/index.cfm?articleid=3335> [Accessed 21 December 2008]

Gloucestershire County Council (2008b) E-mail correspondence from Sarah Pearse dated 18 December 2008

Gloucestershire County Council (2008c) Health Overview and Scrutiny Committee [Internet]. Available from: <http://www.gloucestershire.gov.uk/index.cfm?articleid=7495> [Accessed 21 December 2008]

Gloucestershire Waste Partnership (2007) .Joint Municipal Waste Management Strategy 2007 – 2020 [Internet]. Available from: <http://www.recycleforgloucestershire.com/joint_strategy/assets/JMWMS.pdf> [Accessed 21 December 2008]. Grundon (2009) Wingmoor Farm East: Integrated Waste Management Facility


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Hansen et al (1998) Public health challenges posed by chemical mixtures. Environmental Health Perspectives 1998 Dec:106(Suppl 6): 1271-80

Harrison J et al (1998) Mental Health in the north west region of England: association with deprivation. Social Psychiatry and Psychiatric Epidemiology 1998; 33: 124-8

Hazardous Waste (England and Wales) Regulations 2005 (SI 2005/894)

HPA (2004) Integrated Pollution Prevention Control (IPPC) Chemical Hazards and Poisons Division: Current Position [Internet] HPA board paper Thursday 12 February Presented by Professor Stephen Palmer. Available from: <http://www.hpa.org.uk/web/HPAwebFile/HPAweb_C/1194947402304> [Accessed 21 December 2008]

Health Protection Agency (2008) Waste [Internet]. Available from: <http://www.hpa.org.uk/webw/HPAweb&Page&HPAwebAutoListName/Page/1202115571251> [Accessed 21 December 2008]

Hill AB (1965) The environment and Disease: Association or Causation? Proc R Soc Med; 58: 295-300

Huang WJ et al (2008) Cytotoxicity of municipal solid waste incinerator ash wastes toward mammalian kidney cell lines. Chemosphere; 71 (10): 1860-1865 Kunzil N et al (2000) Public health impact of outdoor and traffic-related air pollution: a European assessment. Lancet 2000; 356: 795-801. Landfill (England and Wales) Regulations 2002 (SI 2002/1559) Ma et al (2007) Asthma and infectious respiratory disease in children – correlation to residence near hazardous waste sites. Paediatric Respiratory Reviews 2007; 8(4): 292-298 Macleod et al (2006a) Modeling human exposures to air pollution control (APC) residues released from landfills in England and Wales. Environment International 2006; 32: 500-509

Macleod et al (2006b) Erratum to “Modelling human exposures to air pollution control (APC) residues released from landfills in England and Wales“ [Environment International 32 (2006) 500-509]. Environment International 2007; 33: 1123

Mohan R et al (2009) Evaluation of methodologies for exposure assessment to atmospheric pollutants from a landfill site. Journal of Air and Waste Management Association. In Press

National Health Service (2008) NHS Choices: Stress [Internet]. Available from:


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<http://www.nhs.uk/Conditions/Stress/Pages/Introduction.aspx?url=Pages/what-is-it.aspx> [Accessed 21 December 2008]

Pollution, Prevention and Control (England and Wales) Regulations 2000 (SI 2000/1973)

Pope et al (2002) Lung cancer, cardiopulmonary mortality and longterm exposure to fine particulate air pollution. JAMA; 287(9): 1132-1141 South West Public Health Observatory (2002) Waste management and public health: the state of the evidence. South West Public Health Observatory: Bristol

South West Regional Assembly (2008) Draft Regional Spatial Strategy for the South West 2006 to 2026

Transport Research Laboratories (2008) Reducing the environmental impact of transport [Internet]. Available from: <http://www.trl.co.uk/content/overview.asp?pid=68> [Accessed 21 December 2008]

Tubb A, Iwugo K. (2000) Organisation of municipal solid waste management system. Bristol: University of West of England

Welsh Health Impact Assessment Unit (2002) A Health (Inequality) Impact Assessment of the St.Mellons Link Road Development. Wales: Bro taf Health Authority Welsh Health Impact Assessment Support Unit (2005) Health Impact Assessment of the Proposed Extension to Margam Opencast Mine. Wales: National Public Health Service for Wales World Health Organization (1999) World Health Organization Health Impact Assessment: main concepts and suggested approach. Copenhagen: WHO

Yoshida RY et al (2003) Association between oxidative stress levels and total duration of engagement in jobs with exposure to fly ash among workers at municipal solid waste incinerators. Mutagenesis; 18(6): 533-7

APPENDIX A


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Source: Grundon Wingmoor Farm and Surrounding Area

Wingmoor Farm East (Grundon ownership)

Wingmoor Farm West (Cory Environmental) APPENDIX B

1 Western access to Wingmoor Farm 2 Eastern access to Wingmoor Farm 3 Restored land 4 Waste treatment facility 5 MRF (Materials Recovery facility) 6 Access to Wingmoor Farm West and The Park industrial site 7 Household Waste Recovery Centre 8 Composting facility 9 Cheltenham North Rugby Club 1 0 Malvern View Business Park 11 The Park industrial site 12 Key Wildlife Site


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Bishop’s Cleeve Parish Council Wingmoor Farm Licence Extension Questionnaire

Summary of Responses Should planning consent be given beyond 2009? Area A Area B Area C Yes 2% 8% 7% No 98% 92% 93% Have your family been affected by? Area A Area B Area C Total Traffic 17% 20% 20% 19% Noise 18% 13% 9% 14% Dust/dirt 22% 21% 25% 23% Smells 24% 26% 26% 25% Insects/flies 19% 18% 15% 17% None of the above

0% 2% 5% 2%

What concerns you and your family? Area A Area B Area C Total Traffic 17% 17% 16% 17% Noise 16% 14% 11% 14% Dust/dirt 18% 19% 20% 18% Smells 18% 18% 20% 19% Health problems

17% 17% 20% 18%

Visual impact 14% 14% 12% 13% None of the above

0% 1% 1% 1%

Notes 193 Responses Responses by area A–31% B-32% C-37% Areas A Wingmoor Farm to the A435 bypass B A435 bypass to the Cheltenham Road C Cheltenham road to the GWR railway line

Autumn 2007

APPENDIX C Wingmoor Farm East:

Integrated Waste Management facility


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Afteruse Proposed Afteruse – Public Consultation In January 2007, Grundon distributed 8,000 community consultation leaflets to an area covering postcodes GL52, 3, 7, 8 and 9 (east of M5 and north of A4019 and GL50 4 (north of Swindon Lane at Swindon Village). The leaflet described the range of operations at the site against the background of the waste hierarchy. It explained why the site life would need to be extended to complete the extraction of minerals and restore the site to the agreed restoration profile. At that time, the anticipated site life was 2035 – which has now been brought forward to 2028. The leaflet included a feedback form, which sought responses form the local community on how the site should be restore, post restoration management, use of existing buildings and operational timescales. The responses were evaluated by the Empirical Research Group at the University of Reading. The Group suggested the questionnaire was easy to comprehend and there was no evidence to suggest that residents had difficulty completing the survey. The findings can be summarised as follows: Introduction 547 questionnaires were returned, but many of them were not completed in full and many comments did not relate to the question or proposition being posited in the survey. The highest rates of response were from postcodes GL52 8 and 4 and the lowest from GL51 9. Most respondents have lived in their village for 15 years or less and have known about the landfill site for about 10 -12 years. Restoration Phasing 97% wanted the area closest to Bishops Cleeve completed first. Restored Land Use The highest approval was given to wildlife, conservation and conversion to woodland uses. There was a low level of approval for recreational and leisure usage, with no notable trends in the preferences for agricultural uses. Post Restoration Management Less than 20% of the local community were interested in becoming involved in conservation or habitat management for biodiversity on the site. Respondents thought the RSPB, Gloucester Wildlife Trust, the Forestry Commission and the Woodland Trust might all be appropriate bodies to manage the restored site. Existing Buildings – The Timber Framed Barn Most respondents expressed a strong preference for the timber framed barn to be dismantled and relocated at the edge of the site for re-use.


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Existing Buildings – Options for Use of Resited Buildings There were very few responses to this question and not many provided usable information. A combination of wildlife and leisure amenity was balanced by preferences for education and agriculture. Cycle Path There was a strong response to this question and 79% of the respondents supported the proposed cycle path. Very few people currently cycle (regularly) from Bishops Cleeve to Stoke Orchard – generally because the current route is thought to be unsafe. Operational Timescales Of those respondents who indicated a preference, just over half thought the site should be finished as quickly as possible, irrespective of vehicle movements. 80% did not want the site life to be extended indefinitely to reduce vehicle movements, but 68% of respondents wanted a compromise between the two options. Waste Hierarchy 98% of respondents supported recycling.

APPENDIX C

Community Health Impact Assessment of the

Wingmoor Waste Treatment and Landfill Sites Bishop’s Cleeve, Cheltenham, Gloucestershire

SUMMARY OF COMMENTS AND FEEDBACK SUBMITTED REPORT

Bishop’s Cleeve Community Health Impact Assessment

Steering Group

MARCH 2009

2

Prepared by Caryn L Hall, NHS Gloucestershire on behalf of the Bishop’s Cleeve Community Health Impact Assessment Steering Group All rights reserved. Reproduction, copy, transmission or translation of any part of this publication may only be made under the following conditions:

with the prior written consent of NHS Gloucestershire for quotation in a publication referencing this report under the terms set out below.

This publication is copyright, but may be reproduced by any method without fee for informative purposes but not for resale. As the Steering Group wishes to know how widely the report is disseminated, formal permission is required for all such uses, but will be granted expeditiously. For copying in any other circumstances or for re-use in other publications, prior written permission must be obtained from NHS Gloucestershire.

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COMMENTS AND FEEDBACK RECEIVED IN RESPONSE TO COMMUNITY HEALTH IMPACT ASSESSMENT DRAFT REPORT Introduction This document is a supplementary document to the Community Health Impact Assessment of the Wingmoor Waste Treatment and Landfill Sites, Bishop’s Cleeve, Cheltenham, Gloucestershire. The comments and feedback contained in this report reflect those that were received from the agencies as identified in section 7.0 of the main report who were contacted with a copy of the draft report in order that they may give comments and feedback. A timescale was set to receive responses. The Steering Group gave due consideration to all the comments and feedback made, where they were received prior to the deadline. Where factual errors or inaccuracies were identified these have been amended in the main report. Due to these changes, some of the comments and feedback contained in this document will not now necessarily reflect the paragraph numbers referred to.

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Cllr Allen Keyte Tewkesbury Borough Councillor for Oxenton Hill Ward Lead Member Financial Strategy I am a little disappointed at the make up of the Steering Group. It does not look representative of anything at all and certainly not the community as a whole. The Wingmoor Forum itself is a little more representative. I have followed the progress of Wingmoor from the beginning (when I was a County Councillor). I believe that overall the sites are quite well run and cause a generally low level of inconvenience to the public. I would also make the following points: 1. If the presence of the tips impacts house prices, then it did this when people bought their homes. I own a property which I rent out in this area and I have noticed not great difference in value from other areas. 2. I am an asthmatic and so am aware of many of the issues. I have not felt that the impact of the tips ever had any impact on my health even when I lived closer to them. I am not aware of any scientific evidence which shows that asthma can be created by manmade causes. 3. The tips are regularly monitored by the Environment Agency and few problems appear evident. I do not understand why there has been an insistence on this Public Health assessment, given this situation, and I would like to know the costs of producing this report which is very light on evidence and high on personal opinions? 4. The Grundon site is shortly to be considered for extention of itrs life by perhaps another 20 years. If that permission is granted, which looks highly likely under planning law and government policies, can we then cause an end to these constant attacks and rely on the relevant agencies to look after the public interest?

5

Cllr Judith Wray Chair Woodmancote Parish Council Woodmancote Parish Council acknowledge receipt of the draft report. We appreciate all the hard work that has gone in to producing a very concise document. I, as Chairman of the Parish Council have one comment detailed below: When the Council together with others had meetings with Grundon we expressed our concern about vehicles leaving the site. When HGV's leave the site they are generally sprayed with water. The vehicle enters the spraying area, is sprayed and then leaves the site. I had occasion to follow some of these vehicles and found that water had remained in puddles in the open 'flatbed' area of the HGV which discharged along the road for some considerable distance. It is my thought that this water contained contaminates which then transferred to wheels of vehicles and, when dry became airborne covering a much wider area than contained in the report. We did express these concerns to Grundon. I would like to see this addressed specifically.

6

Andrew Gravells County Councillor Chairman of Health Overview Scrutiny Committee Thanks for sight of the Wingmoor Report. I can't see anything in the Report that needs amending by HOSC.

7

Frances Robertson Friends of the Earth Community HIA Steering Group representative The make up of the Steering Group is described by listing who was on it but it might be clearer to explain that it was representative as it was made up of: All 3 tiers of local government – county, district and parish Local residents Local resident representing the patient forum Local residents’ group – SWARD Local rep of national environmental interest group – Friends of the Earth It reflected the membership of the Wingmoor Liaison Forum and took evidence from other organisations including the Environment Agency and the waste operator – Grundon. The report does not include the information regarding the level of involvement by the Gloucestershire Friends of the Earth (FoE) representative. The FoE rep was involved in the initial Steering Group but after a gap of 18 months the Steering Group was invited to attend a series of meetings at relatively short notice in December 2008 and the FoE rep was unable to participate due to work commitments (as the role is voluntary). Additional meetings in January and February took place whilst the FoE rep was away on extended holiday. The gap in the process is not explicitly explained on page 12. The delay in producing the report was not because the staff member was away but in fact the process stopped for over 12 months and then the report was drawn up over a matter of 2-3 months (Dec 08- Feb09) to meet the GCC HOSC timetable. This huge gap followed by short notice meetings and hasty drafting of the report has meant that some issues have not been covered by the report and the language of the report is at times seemingly pejorative. For example, the report uses the word “perception” a lot. Perception is a very widely interpreted word with a wide range of definitions. However, in common usage in English it is often taken to mean that it is “only” someone’s idea or impression (the latter being offered as a synonym to perception by dictionaries) rather than being something that is true or actual. For example, in 3.1.5 the statement that the loss of amenity as “perceived” by the Steering Group is erroneously stated. In fact the loss of amenity was “described” as being related to flies, gulls, etc etc. and there is no “belief” involved as to whether it was affecting people’s enjoyment of their homes, the information available to the Steering Group was that it quite clearly does affect their enjoyment and is not a matter of faith. In 4.0.4 the paragraph refers to “very real perceptions” and then that “a number of perceptions could readily be allayed”. This use of perceptions is unhelpful and would better if the word “concerns” is substituted. There are very real concerns that have been

8

underpinned by very real experiences and which should be outlined in this report. As well as the inappropriate usage of “perception” there is also a lack of historic detail regarding the incidents that have actually taken place at Wingmoor and been the subject of public record. For example, none of the issues or breaches of PPC/Environmental Permits at the sites, as reported to the Wingmoor Forum have been described in this report. One such issue was where dust from the Wingmoor Site was described in written reports by the regulator (Environment Agency) as “blowing about” on the site. This was not a “perception” or a matter of belief by the community but a matter of formal record by the environmental regulator. Also local residents had video evidence of dust rising from the site which was real and not “perceived”. Similarly there were breaches of the PPC permit for the APCR silos and other issues raised at the Forum that are not referred to in this report. It is also astonishing that a serious incident where there were phenolic emissions from the site that were smelt across the whole village of Bishops Cleeve is not mentioned. The latter incident resulted in an investigation where local residents were interviewed by a special team from the EA, followed by 3 years of investigation during which time the residents had no idea what the outcome might be nor what potential impact on their health could be. These were genuine causes for concern or indeed “fear”, the incident was not imagined and the stress suffered by residents as a result of this real pollution incident is not even referred to. In 3.6 there is reference to “potential” odours and gases but nothing to explain that the residents have already been subjected to these. The description of the Wingmoor Sites – Section 8 – is not clear. It is not clear whether 8.1.1 to 8.1.4 are quotes or a précis of information provided to the report writer. It does not clearly explain, and indeed 8.1.4 does not properly explain, the situation. As I understand the situation, the hazardous waste treatment plant only takes APCR (not primarily) and mixes the residues with water and / or leachate from the site. The management and treatment that takes place does not meet the EU Waste Acceptance Criteria (WAC) requirements but rather the operator has been granted a 3 times derogation as they are unable to meet the EU WAC. This yet again does not provide the community with confidence and contributes to the concerns that the site is unable to operate to the best standards to meet the EU requirements. This does not accord with paragraph 8.5.4 which states that waste can only be accepted at a site if it meets the WAC - whereas in fact the operator has been able to get a derogation so as to allow them to exceed the criteria. The EA Audit of August 2008 is referred to but the findings not appended – they need to be added not least because Grundon has failed to comply not only with the permit but also with the audit recommendations. This is yet another example of why residents are, understandably, concerned about impacts on them. There is no reassurance in the permitting system if not only can they breach the permit, but then having been told to take action to meet the permit, when they fail to do

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so they simply get given more time to comply – i.e. they are allowed to continue to operate in breach of their permit. I think the HIA process has been a very difficult exercise for all concerned. The timetable went out the window, the involvement of the stakeholders was variable due to both the gap in the process as well as personal and professional reasons. The haste with which the HIA report has been drawn up over the last 3 months has meant that there are some drafting errors / improvements which I would normally have flagged up during the consultation process prior to the report being finalised but which it has not been possible to do. I have however covered what I consider to be the most serious omissions from this report as well as the inappropriate impression given where the word “perception” is used. The report has been prepared for the Steering Group but due to this hasty drafting process and the need to meet the GCC HOSC timetable still has omissions. However, with the above exceptions, I understand the omissions have generally been identified and indicated as meriting further investigation and / or action. Like my Steering Group colleagues I am grateful for the process being undertaken and regret that the lack of staff allocated to this process has led to this somewhat “stop/start” approach and the failure for, for example, for the wider stakeholder consultation event to have already taken place. I look forward to further investigation being undertaken and reported upon in a timely manner.

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Cllr Jack Richardson Tewkesbury Borough Councillor Bishops Cleeve St Michael’s I would like to congratulate you and your team on the production of a balanced, informative and detailed report. There are several issues that I wish to draw to your attention. 1 3.1 Stress I believe that stress is also caused by the perceived lack of monitoring, reports about dust escape that are not published or not produced quickly enough. It states in paragraphs 3.3.1 and 3.3.2 that in an EA audit report the operators were not working within the conditions set out in their permit. Operators stated that if they did follow the conditions they would be priced out of the market. This statement indicates that operators do not fear the EA. It may be that operators believe that the EA have very little power or that the EA will not use the power that they have been given. Grundons have failed in that they failed to follow the recommendations within the timescale. Their punishment is that they have been given more time to actually follow the law and work within the conditions set out in the permit. I would like to suggest that another key action point should be added at this point in the report. It should state that the EA must publish in the press the main points of their reports, the actions that the operator is to undertake and what action the EA will take if the operator fails to achieve full compliance. This recommendation incorporates the statement 2.1.7 and 2.1.8 which cover potential ways to reduce health inequalities by making information available to communities and planning authorities to help them make decisions. 2 The key point at the end of 3.4 it states that dust monitoring should be carried out annually. I think this action point should state that it will take place once a year at different times and no warning will be given to the operators of the site. 3 In point 3.5.9 it explains the action taken about the sheep on the land and the reasons why this action was taken. Why are farm animals allowed to graze in the field just over the road? 4 The key action point at the end of 3.12 states that the community must be directly involved in these processes. In the spirit of points 2.17 and 2.1.8 I feel that it should state exactly how the community should be involved. 5 The key action points at the end of 3.13 should include consideration of where the waste is coming from. It would considerable increase the carbon footprint and health dangers to many communities of the waste coming to Wingmoor if it

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passed suitable sites on its journey. It is also important to know where the waste is coming from eg I would be upset if waste form the French warship being dismantled on the Tees ends up in the Wingmoor site.

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Ted Fryer Representative Safety in Waste and Rubbish Disposal Thank you for the copy of the draft final version of this report. SWARD welcomes this opportunity for the community’s concerns to be gathered and recommendations to be made. We are disappointed that, due to the halting of the HIA process between July 2007 and October 2008, the final report has been produced to a very tight timescale. Consequently, some activities and research we would like to have seen included are missing and therefore we submit the following comments and additions: Page 1 Title Page The Executive Summary at 1.0.6 makes it clear that “this community HIA report should really be seen as a first stage in a process that needs and must be continued”. SWARD agree with this and therefore we believe that the title page should reflect this by showing “Part 1” underneath the title. Part 2 would be the outcome of Section 5 Key Actions. Page 3 Appendices We include an additional appendix of evidence, from the Environment Agency Public Register including complaints about odour, that has raised community concerns (Appendix 1). Page 8 Executive Summary. We believe that this is not sufficiently comprehensive to alert the reader to the concerns of residents. Many Councillors and Officers will be hard pressed to find the time to read the whole report and therefore there should be pointers in this Summary to items which they may wish to examine further. For those reading the whole report the Executive Summary is always a handy resumé of the substance they have read. Thus we submit that the Executive Summary should read as follows. Our additions are shown in bold italics: 1.0 Executive Summary 1.0.1 A community Health Impact Assessment (HIA) of the Wingmoor sites

took place between December 2006 and February 2009, with a break between July 2007 and October 2008. The potential impacts of the sites on the physical and mental health and wellbeing of the community were examined both in terms of relevant published literature and from information collected as part of the process.

1.0.2 A Steering Group was established with representatives of county,

borough, parish councils, national and local interest groups and

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local residents. The Group comprised a variety of representatives who undertook the responsibility of driving the process of undertaking the community HIA.

1.0.3 The Group identified the key impacts to health they wished to investigate.

Stress was determined as the overarching impact that the Group wished to examine in detail.

The issues that the Steering Group identified included:

Fear for the potential effects of harm from the operations at and around the site not least to babies, young children and other vulnerable groups

Loss of quality of life, loss of amenity and potential reduction in

house prices

Lack of control over the processes within the site and the way it operates (a feeling of helplessness)

Concern about the future

These fears have been prompted by a number of accidents and incidents such as those shown at Section 3.1.4 and in our Appendix.

1.0.4 The Group established that for those areas that were examined in detail,

from the information that was available to the Group, currently there was no definitive evidence to demonstrate that health has been affected by living near the Wingmoor sites.

The Group would strongly emphasise that there were a number of key findings arising from the report that specifically identified gaps in the current knowledge that are essential to further inform this area. See Section 2.3.1

1.0.5 The Group has therefore identified a number of key actions for a variety of

key agencies to undertake, namely: NHS Gloucestershire (Gloucestershire Primary Care Trust) Health Protection Agency Wingmoor Site Operators Gloucestershire County Council

Gloucestershire Local Resilience Forum Tewkesbury Borough Council

Environment Agency Government Office of the South West

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Gloucestershire Health Overview and Scrutiny Committee The Group has set a timescale to form the second part of this HIA

(shown at Section 5). This is imperative to further inform the knowledge of health impacts and outcomes and will assist in establishing baselines.

1.0.6 It is clear that the community has very real concerns about the Wingmoor

sites and theseneed to be given due appropriate consideration by those involved with the sites. The Group has been realistic and recognises that there are limitations on what can be achieved when looking at complex processes such as these. The group has therefore identified that additional work is required and that this community HIA report should really be seen as a “first stage” in a process that needs to and must be continued. This is why this document has been called “Part 1”.

1.0.7 The final draft of the HIA report (Part 1) was sent out for comment and

feedback - technical and typographical errors were amended within the main body of the report. Additional comments and feedback are to be found in a separate document appended to the report.

Page 9 2.0.2 SWARD believe that readers should be aware of the Eurohazcon

recommendations and therefore propose an additional paragraph here as follows:

When considering the distance from the boundary of the site to

residential areas it is relevant to note the 5th March 1997 proposal of the Commission on the draft Landfill Directive. This was informed by the initial results of the EUROHAZCON projects on birth defects associated with landfill sites and included specific minimum distances from such areas. These were a minimum separation of 0.5 km in the case of municipal waste landfills and 2km in the case of hazardous waste landfills such as this one.

Page 14 3.1 Stress SWARD recommends the addition of specific examples of accidents and incidents on which the concerns in this section are based:

These fears have been prompted by a number of accidents and incidents over the last few years, such as: ● the explosion of a load of waste on discharge into the landfill, sending a huge plume of smoke over Bishop’s Cleeve. (Grundon’s client had not accurately described the contents)

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● a mechanical breakdown which resulted in the release to air of approximately 2 tonnes of untreated APC residues in fifteen seconds (2004) ● the release of phenol vapour over a wide area when discharging contaminated soils. (Grundon’s client had not accurately disclosed the contents) (2004)The Environment Agency took formal statements from complainants and it took three years to conclude the investigation and report the conclusions to the community in 2007) ● breaches of the PPC permit, e.g. dust blowing across the hazardous waste cell; non permitted liquid waste being poured into the hazardous cell and inadequacies in waste acceptance and control systems procedures; dust created because of inadequate damping in the hazardous cell; APC leaving the tipping area because of inadequate moisture content in bagged waste and failure to test for this (2004 &2005: EA Inspection reports: 140305, 28904, 25104, 251104) ● several fires on the Cory household waste site (2006) ● foul smells from the Cory site over a wide area after flooding (2007)

Also of concern is the self monitoring system of the PPC permitting regime, in view of past disregard for environmental regulations, e.g. Grundon’s conviction for deliberately polluting a water course (Environmental Data Services – ENDS report 328, May 2002, Page 54) Page 25 3.8.13 SWARD believes the EA should be asked to institute noise and vibration monitoring. Therefore, we submit adding at the end of this paragraph: The Environment Agency should be asked to institute noise and vibration monitoring for a three month period in the first instance. Page 39 Section 5.0 Key Areas for Action We submit a redraft of this Section, showing timescales by which Part 2 of this HIA must be completed:

5.1 NHS Gloucestershire (Gloucestershire Primary Care Trust) 5.1.1 NHS Gloucestershire must undertake a study to determine the potential

effects of the Wingmoor sites on the physical and mental health and wellbeing / stress of local residents (to include asthma) who live in proximity

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to the Wingmoor sites to be completed in 2009. To be published 1st October 2009

5.1.2 NHS Gloucestershire must undertake a comparative update of the Bishop’s

Cleeve Neighbourhood Health Profile every 3 years commencing in 2009. First update to be published 1st October 2009.

5.1.3 NHS Gloucestershire must undertake a long term prospective cohort study

of new born babies in the area surrounding the Wingmoor sites in order to identify any specific health issues to commence in 2009. First interim report to be published 1st October, 2009

5.2 Health Protection Agency 5.2.1 The Health Protection Agency must lead, in collaboration with key

stakeholders, a community consultation event that will ensure the views of the local community are captured with respect to the issues raised in this report. Consultation event to be held during 2009 (excluding July and August; holiday period) and Report to be published by 1st October, 2009.

5.2.2 The Health Protection Agency must resource and implement the proposal

to introduce an Environmental Public Health Tracking Programme to commence in 2009 or at the earliest opportunity. The Environmental Public Health Tracking Programme must report their findings at regular intervals to the appropriate fora so that residents are made aware of any findings. First report to be published 1st October, 2009.

5.3 Wingmoor Site Operators 5.3.1 Operators of the Wingmoor sites must take a joined up approach with clear

lines of responsibility to ensure that the community is provided with timely, clear, readily accessible information about their site including the exact nature of wastes accepted, presented in an easy to read and understand format to commence April 2009. To be published 1st July, 2009.

5.3.2 Operators must identify and share with the community how their site

operations as a whole impact on the local community and how they are minimising those impacts to commence April 2009. First report to be published 1st July, 2009.

5.4 Gloucestershire County Council 5.4.1 Gloucestershire County Council must ensure that planning applications are

accompanied by a formal health impact assessment and human health risk assessment as part of a wider ranging environmental impact assessment (including the council’s local validation list requirement for a statement on emission of airborne particles) when future applications for planning consent are submitted. The community must be directly involved in these processes. Regular ongoing reviews of the health impact

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assessment and human health risk assessment must take place. To take effect from 1st April, 2009, and a review to be presented quarterly thereafter (i.e. First day of July, October, January and April).

5.4.2 Gloucestershire County Council must actively undertake to take into

account the cumulative effects of the combined Wingmoor site operations including traffic management when considering any future planning application. To take effect from 1st April, 2009, with a report each quarter (first day of July, October, January, April) on any such action taken in the previous three months.

5.4.3 Gloucestershire County Council must undertake to use ‘quiet surfaces’ on

the key roads that surround the Wingmoor sites. To take effect from 1st April, 2009, with a report on 1st July, 2009, indicating a programme of resurfacing and estimated time scheduling.

5.5 Gloucestershire Local Resilience Forum 5.5.1 Gloucestershire Local Resilience Forum must undertake in autumn 2009 an

exercise around the subject of a road traffic collision in Bishop’s Cleeve involving a vehicle carrying hazardous waste to ensure that an appropriate response is in place. Report to be published by 1st November, 2009.

5.5.2 Gloucestershire Local Resilience Forum Risk Assessment sub-group must

undertake to give due consideration that the Wingmoor sites and associated activities are placed on the community risk register. Report by 1st July, 2009, on the exercise of that consideration and whether these activities have been placed on the community risk register.

5.6 Tewkesbury Borough Council 5.6.1 Tewkesbury Borough Council must recommence passive tube monitoring

for nitrogen dioxide on Stoke Orchard Road and also introduce monitoring on the A435 Bishop’s Cleeve By-Pass in May 2009 or as soon as is reasonably practicable. The results must be made available in a timely manner to the Wingmoor Liaison Forum so that they are publically accessible. First report to be published by 1st July, 2009, and quarterly thereafter (i.e. First day of October, January, April and July).

5.6.2 Tewkesbury Borough Council must undertake real time air quality

monitoring and analysis at Stoke Orchard Road, Bishop’s Cleeve and the A435 Bishop’s Cleeve By-Pass to establish an accurate baseline of the impact of traffic on air quality in the area to commence in 2009. Comparative annual air quality monitoring and analysis thereafter must be undertaken to identify trends. First progress report to be published by 1st July, 2009, and quarterly thereafter (i.e. First day of October, January, April and July).

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5.6.3 Tewkesbury Borough Council must undertake to give specific consideration to the Bishop’s Cleeve area and the locality surrounding the Wingmoor sites when undertaking its Updating and Screening Assessment on air quality for 2009. Progress Reports to be published on the first day of July, October, January, April each year, commencing 1st July, 2009.

5.7 Environment Agency 5.7.1 The Environment Agency must actively take into account the cumulative

effects of the combined landfill site operations at Wingmoor when considering any future permit applications. Reports on such work on permit applications to be published on the first day of July, October, January, April each year, commencing 1st July, 2009.

5.7.2 The Environment Agency must undertake to complete the analyses of the

dust monitoring carried out by DustScan Ltd up to and including 2008 ,to commence in 2009 or as soon as is practicable. The results of the analyses must be made publicly available and sent to the Wingmoor Liaison Forum. These analyses must be undertaken annually thereafter following monitoring. First progress report to be published on 1st July, 2009, and 1st April in subsequent years.

5.7.3 The Environment Agency must commit to carrying out the

recommendations of the findings of the Macelod study relating to air pollution control residues. First progress report to be published by 1st July, 2009, and quarterly thereafter.

5.7.4 The Environment Agency must undertake research with regard to the

effects to health of the “cocktail effect” of wastes that enter landfill sites. First progress report to be published by 1st July, 2009, and quarterly thereafter.

5.7.5 The Environment Agency must undertake noise and vibration

monitoring for a three month period in the first instance. First progress report to be published 1st October, 2009.

5.8 Government Office of the South West 5.8.1 Government Office of the South West must undertake to review the

planning position in the South West region with regard to waste treatment and landfill sites and in particular sites that handle hazardous waste. First progress report to be published by 1st July, 2009, and quarterly thereafter.

5.9 Gloucestershire Health Overview and Scrutiny Committee 5.9.1 The Health Overview and Scrutiny Committee must undertake to ensure

that the key areas of action identified in this report are monitored regularly to ensure that the actions are being undertaken by the identified agencies.

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First monitoring report to be published by 8th July, 2009, and quarterly thereafter (i.e. the eighth day of October, January, April and July).

Page 43 6.0.5 Key Actions We believe this is not sufficiently robust, and does not reflect the urgency of such work expressed earlier in the report. A year could well cause agencies to place it at a low priority, thus delaying results which could inform consideration of the anticipated submission of an application for life extension of the Grundon site. This is why we suggested a redraft of Section 5. To reflect that redraft, we suggest the following redraft for this paragraph: 6.0.5 The Steering Group have specified a number of key areas of action

which are for each agency to consider. The Group require that those Agencies identified with actions should respond in line with the timescales shown in Section 5, through the auspices of the Wingmoor Waste Forum.

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Alan Watson Public Interest Consultants for SWARD General Comments and Summary: It is encouraging that this health impact assessment has been attempted and a draft report produced. The results are, however, rather disappointing at this stage. A reader unfamiliar with the area would glean little detailed information about the problems faced by the village from the current report. Nor would they understand why there was such a high level of concern about the landfill sites. In those cases where quantitative evidence is included, such as for asthma, where the local rate is higher than for Gloucestershire and much higher than for the average incidence across England the draft report appears to play the findings down and, incorrectly, claims that “asthma prevalence has not been linked with landfill sites”. The current conclusions and recommendations are essentially a “wish list” for further information that would normally have been included in the HIA – and particularly one that has taken more than two years to produce. The long break, between July 2007 and October 2008, during which the NHS facilitator was on secondment to another post, seriously damaged the continuity of the process, undermined the effectiveness of the group and reduced confidence in the outcome. This was further compounded by the rush to complete the report in the period from December 2008 which precluded full discussion about the content and style of the report. It is recommended that:

• the changes to the text in the SWARD submission by Ted Fryer should be incorporated.

• in the light of the slow progress and limited collection of health and emissions related data that the working group should label the current report ‘Part 1’

• those involved, both directly and indirectly, should commit to return to the HIA to review progress on the information collection.

• the introductory section of the HIA should include at least part of the current Section 8, suitably amended to make it clear that there have been a number of longstanding amenity issues associated with the site; a large number of breaches of Environmental Permits by the site operators relating to operational issues; waste acceptance; groundwater contamination; landfill gas; and so on over a number of years. There have also been a number of significant incidents. Some of these incidents and permit breaches are detailed in the appendix to this review.

• The language and content of the report should be re-visited in relation to the concerns discussed in this response – the HIA should at least be more discussion and background evidence in relation to the reasons that further

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information has been sought as this is likely to be ensure a more positive response from the responsible authorities than an unsupported request for work that will require the commitment of time and resources.

• The ATSDR list of seven priority health conditions (birth defects and reproductive disorders; cancers (selected sites); immune function disorders; kidney dysfunction; liver dysfunction; lung and respiratory diseases - to include Asthma; and neurotoxic disorders) should provide a foundation for future pro-active monitoring of community health.

• That, taking into account the many outstanding uncertainties over the health effects of the landfill sites, the Planning Authority should respond to the views expressed by the overwhelming majority (92%-98%) of those replying to the community questionnaire who said that planning permission should not be extended beyond 2009.

Aims, Objectives and Progress: The definition of Health Impact Assessment in the report is that taken from the WHO Gothenburg Consensus Paper: 'a combination of procedures, methods and tools by which a policy, a program or project may be judged as to its potential effects on the health of a population and the distribution of effects within the population'. The current report doesn’t meet this definition as the information required to judge the potential effects of the landfill site – and the distribution of effects - is largely missing. The HIA similarly fails to meet other commonly used definitions of Health impact assessment which include [1]:

'the estimation of the effects of a specified action on the health of a defined population'. Scott Samuel ‘a method of evaluating the likely effects of policies, initiatives and activities on health at a population level and helping to develop recommendations to maximize health gain and minimize health risks. It offers a framework within which to consider, and influence the broad determinants of health'.

Scottish Office 'a combination of procedures or methods which enable a judgement to be made on the effect(s)-positive or negative of policies, programmes or other developments on the health of a population or on parts of the population where health are concerned' .

National Assembly for Wales Cole et al [2] outlined a screening algorithm for the determination of whether to conduct a health impact assessment and this is included at the end of this response.

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The screening algorithm can be used to show largely what has been done in the ‘substantive’ HIA to date – key issues like the sufficiency of resources and data have resulted in the long delay and the outcomes being mainly a list of requests for others to collect health and environmental data. No indication is given of how any of this data, were it to be collected, would be processed and used. The earlier submission by Ted Fryer recommends the addition of deadlines and a tighter specification of what is expected from the authorities and this is essential if the process is to move forward to Part 2 more smoothly than we have seen with Part 1. On the evidence available to date it is difficult to be optimistic that most of the requests will be dealt with in a positive fashion. In the majority of cases the authorities involved could – and should – have provided the information over the protracted HIA process. Whether the authorities now choose to participate willingly over the coming months to fulfil those requests will be an acid test of their commitment to the process and to community HIA in general. It is recommended that in the light of the slow progress and limited collection of health and emissions related data that the working group should label the current report ‘Part 1’ as suggested by Ted Fryer. The report emphasises that the “process that needs and must be continued“ not least because of the many compromises that have been necessary due to the long gap in the process – which was entirely beyond the control of the Steering Group. All those involved, both directly and indirectly, should commit to return to the HIA to review progress on the information collection which will, we hope, be provided in accordance with the timelines proposed by Ted Fryer. It must be emphasised that the failure to make more progress is not the fault of the working group but rather of those authorities who should be committing appropriate resources to the process – particularly the HPA and the PCT. Similarly the provision, in a timely fashion, of adequate data is almost all the responsibility of the various regulatory, administrative and regulatory authorities. It is inexcusable, for example, that the DustScan dust sampling data which has been collected since 2004 has not been reviewed by the Environment Agency for this HIA. It begs the question why public money was spent to collect it if there has been no analysis to date. Presumably the reason was to placate local concerns by appearing to be doing something? For the Environment Agency only to analyse the data in the closing month of this stage of the HIA process – an offer that appears to have been made in an attempt to divert even stronger criticism – indicates a disappointing lack of commitment to the HIA process. This issue is an important one and is discussed in more detail below.

APPENDIX C

© NHS Gloucestershire Community HIA – Wingmoor Sites, Responses March 2009

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Information about the Landfill Site: The Wingmoor Farm landfill site is one of only seventeen merchant hazardous waste landfill sites in England and Wales1 and has probably had the highest profile of all the merchant sites still operating given the importation to Gloucestershire of incinerator residues from London and other distant sources. These incinerator ashes are particularly hazardous wastes which, as explained below, are unsuitable for landfill without treatment because of their high levels of leaching. Wingmoor is also, amongst the few landfill sites that accepted these wastes, the landfill generating the highest off site concentrations of dioxins and heavy metals [3]. The layout of the report and much of the content was largely in the hands of the NHS facilitator whose secondment during this process resulted in a long delay followed by the tight timescale for putting the final draft together. This has left a number of loose ends, omissions and misunderstandings that need to be clarified. The introductory information on the landfill site, for example, is included almost as an afterthought or appendix on page 45 at the end of the substantive draft HIA report. It is vital that the reader understands what the concerns are and what gives rise to them at an early stage in reading the report if it is to be meaningful and it is strongly recommended that at least part of Section 8 “Additional Information to inform”2 should be moved forward to the introduction3. The details that are included at present give hardly any indication of why there could be any potential problem that has resulted in sufficient concern to justify the current HIA. This effect is emphasised by the tone and language used in the report. The use of the slightly pejorative word ‘perceived’ is one example. This is particularly striking in para 2.03 of the introduction which says “health impacts of the Wingmoor sites ... perceived or otherwise“. The clear inference is that ‘otherwise’ would represent a real effect and ‘perceived’ is an imagined one consequently the reader tends automatically to associate the

1 The Environment Agency web site lists:

• 17 Sites whose operators have been granted permits to be Merchant landfills (commercial) for Hazardous Waste.

• 7 Sites whose operators have been granted permits to be Restricted Landfills (non-commercial) for Hazardous Waste.

• 49 Sites whose operators have been granted permits to construct separate cells for asbestos, gypsum & high sulphate wastes and other Stable, Non-Reactive Hazardous Wastes

A spreadsheet listing all these is available from the Agency web site < http://www.environment-agency.gov.uk/static/documents/Business/Permitted_landfills_accepting_haz_waste_and_gyspum_-_Jan_2009.xls> Accessed 27th February 2009 2 This title seems rather tautological – information is normally provided to inform… 3 I presume that the current para 8.1.3 should not be numbered – it is the description of the application referred to the previous paragraph.


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health “perceptions” of the community with imagined ailments and impacts rather than real ones. It is therefore recommended that the introductory section of the HIA should include at least part of the current Section 8, suitably amended to make it clear that there have been a number of longstanding amenity issues associated with the site; a large number of breaches of Environmental Permits by the site operators relating to operational issues; waste acceptance; groundwater contamination; landfill gas; and so on over a number of years. There have also been a number of significant incidents with off-site consequences which have made the operations on the site difficult to ignore even by those living in the village and out of sight of the daily operations. Some proposals for changes and additions to the text have been provided by Ted Fryer and an appendix outlining some of these incidents and reports has been included with this response. The background evidence supporting this will also be available on the SWARD web site at www.swardbishopscleeve.co.uk/. Some of the missing information is pertinent to the concerns of the community and the resulting stress and anxiety. The HIA does not even mention, for example, that the air pollution control residues that are being landfilled do not meet the leaching criteria specified in the Landfill Directive and associated Regulations and that the operator has had to be been granted an exemption to allow leaching levels three times greater than the normal statutory limit. In spite of this there is evidence that the wastes do not always comply even with the higher maximum threshold of leaching provided for by the exemption. Identification of Key Issues: The disposal of wastes in landfill sites has caused increasing concerns over the past ten to fifteen years about possible adverse health effects for populations living nearby, particularly in relation to those sites where hazardous waste is dumped. Whilst studies on the health effects of landfill sites were initially carried out mainly in North America in the past decade more research has been done in the UK and Europe. The majority of studies evaluating possible health effects on residents living near landfill sites have investigated communities near one specific waste disposal site (single-site studies), frequently in response to concerns, as here, from the public about reported contamination from the site or responding to reported clusters of disease. A smaller number of multi-site studies have addressed the risks of living near waste sites, independent of whether the sites caused concern. The HIA makes hardly any reference to the increasing library of literature reporting epidemiologic studies on landfill. Nor is this work obviously linked to


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the list of conditions identified at para 2.3.1 which attempts to summarise (some) of the health impact the steering group “perceived could be an outcome of living in close proximity to the Wingmoor site”:

• Respiratory illness particularly asthma • Ear, nose and throat illnesses • Skin conditions • Issues relating to birth defects and short and long term impacts on

children’s health • Sleep and rest disturbance

There is no indication of how this list was determined nor of what was omitted. They do not, however, represent the totality of the concerns expressed by SWARD. Respiratory illness particularly asthma Most of the concern even on this abbreviated list at para 2.3.1 are not re-visited or discussed in detail at any other stage in the HIA. Only respiratory illness and asthma receive any significant further discussion and that is rather dismissive. The report says “Asthma prevalence has not been linked with landfill sites”. It is not clear who was responsible for this claim but they had evidently not reviewed the literature with the care that would be expected because there are at least two papers in the relatively small literature associated with health effects of landfill sites which show a significant increase in asthma is associated with living close to a hazardous waste site:

1. A 2007 study “Asthma and infectious respiratory disease in children - correlation to residence near hazardous waste sites” showed show statistically significant elevations in the rates of hospital discharge for both asthma and infectious respiratory disease (the authors comment that the “highly significant elevations in rates of hospital discharges that we found for both diseases suggests that an even stronger association may exist between exposure and disease if we could refine the measure of exposure or use individual level data) in children who live near hazardous waste sites after adjustment for a variety of factors, including median household income, an indicator of socioeconomic status. This relationship is stronger for waste sites containing POPs4, but is also significant for hazardous waste sites that do not contain POPs.

2. Another paper by the same group was published in 2008: “Asthma and Infectious Respiratory Disease in Relation to Residence near Hazardous Waste Sites” [4], which demonstrates a significantly elevated risk of asthma (rate ratio (RR) = 1.09) after adjustment for median household income, race, gender and urban or rural residence.

4 POP is Persistent Organic Pollutant – a class of chemicals which includes dioxins/furans and PCBs.


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They also reported an increase in infectious respiratory disease (RR = 1.15), and COPD (RR = 1.19) in individuals living in a zip code with a POP5 waste site.

It does not inspire confidence in the scientific rigour of the drafting of the report (or, presumably, the quality of the technical advice given to the steering group) when a linkage like that between asthma and the landfill literature is wrongly dismissed – especially as both studies even included “Asthma” and “Hazardous Waste Sites” in the title and so are straightforward to find in even a basic literature search. The report says that the incidence of asthma is 7% for those living within a 3km radius of the Wingmoor sites (approximately 15,000 people of all ages) compared with the rate for Gloucestershire as a county of 6.2% and England as a whole 5.7%. This is, however, dismissed by the comment that “statistical calculations that are applied to this suggest that this is not a significant finding (the true figure lies between 5.95 and 8.1%)”. No calculation is included nor are any confidence levels provided. The obvious follow-up question of “why should residents of rural Gloucestershire have a statistically higher incidence of asthma than the English average ?”(on the basis that the lower confidence limit for residents around the Wingmoor site still exceeds the English average) does not appear to have been asked. Nor, it appears, have the health professionals sought to overcome the local difficulties of residents using different GPs to plot distribution more accurately than a single course 3km band around the landfill. If “Due to the geographical spread of residents in Bishop’s Cleeve across several GP practices it is not easy to produce robust and definitive data to show the percentage of people in the proximity of the landfill site who are diagnosed with asthma“ then it is presumed that the same would apply to any other ailment for which GPs keep records. In those circumstances the Health authorities perhaps ought to be more forthright about the failures of their data collection and recovery systems and admit that they are unable to provide any useful information at present to confirm or refute whether there are any elevated levels of health problems for practically any condition. If this is really the case then residents would be right to be genuinely anxious that practically no matter how bad any hypothetical health effect might be they cannot rely upon the health authorities ever to be able to establish that there are elevated levels6 – and thus would be unable to protect them and their families. The failure has been demonstrated in practice by, for example, the Shipman case. None of the systems in place were capable of detecting even 200 premature deaths at the hands of Dr Shipman. In these circumstances it is perhaps not surprising that lesser impacts would easily pass un-noticed. 5 POP is Persistent Organic Pollutant – a class of chemicals which includes dioxins/furans and PCBs. 6 Unless, possibly, there is a requirement to report the condition to a central registry but given the unreliability of the registry of birth defects, as discussed below, even this would give little grounds for optimism that a cluster could be identified.


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Additional Possible Health Outcomes: In the United States the ATSDR (Agency for Toxic Substances and Disease Registry) had identified a list of seven priority health conditions which might possibly be caused by waste sites back in 1992. These are:

• birth defects and reproductive disorders; • cancers (selected sites); • immune function disorders; • kidney dysfunction; • liver dysfunction; • lung and respiratory diseases; and • neurotoxic disorders.

The particular vulnerability of children and pregnant women was also noted as a consideration. Birth Defects: These conditions would provide a useful basic starting point for the reviews that are requested of the health authorities by this HIA but they should supplement rather than divert attention from the request to review data on birth defects. The ATSDR outcomes are not concerns that would have been picked up by the 2005 Bishops Cleeve Neighbourhood Health Profile [5] which generally considered less specific and more easily measured endpoints such as mortality and life expectancy. Even the birth defects considerations only included low birth weight. Low birth weight and residential proximity to PCB-contaminated waste sites have been linked [6]. The authors found that even after adjusting for sex of the infant, mother's age, race, weight, height, education, income, marital status, and smoking, there was still a statistically significant 6% increased risk of giving birth to a male infant of low birth weight for those living near a PCB-contaminated site. However Morgan et al [7], albeit in a much smaller study with fewer births, investigated the risk of low birth weight near 10 English hazardous waste landfill sites included in a the earlier EUROHAZCON study which reported an increased risk of congenital anomalies [8]. The authors found a small and not statistically significant increase in risk of LBW (OR = 1.03, 95% confidence interval = 0.98-1.08) within 3 km of hazardous waste landfill sites. Their findings suggest that EUROHAZCON results for congenital anomalies should not be extrapolated to a wider range of pregnancy outcomes but should be evaluated separately for each. It is odd that birth Defects receive so little discussion in the draft – they are mentioned only when they are raised as a concern by the steering group and as an action on the Gloucestershire Primary Care Trust. There is no further detail about the background literature and epidemiology relating to this important issue despite that the fact that there are now a large number of published papers demonstrating association between hazardous waste landfill sites and birth defects. Most, but not all, of these report an increase in certain


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birth defects associated with residence close to the hazardous waste sites. [7, 9-21]. One likely issue that may affect the likelihood of finding impacts is raised by Professor Dolk, the lead author of the EUROHAZCON study who later [22] wrote “For congenital anomalies, it may be peak exposures in short time windows of fetal development that matter”. The reason is that if the effects are real then the likely cause is exposure to teratogenic chemicals7 at a crucial developmental stage. This inevitably leads to an element of chance and additional uncertainty – seeing the effect would require the unfortunate co-incidence of a pregnancy at a crucial stage together with exposure, possibly at higher than usual levels, of emissions including teratogens. Although many in the industry have tried to dismiss these studies by claiming that such clusters can be found by chance the number of studies showing elevated levels of birth defects increases the concerns that the results are real. Armstrong [23] noted in any case that the “data suggest that strong localised clusters in congenital anomalies are uncommon, so clusters around specific putative environmental hazards are remarkable when observed”. It is therefore surprising that this issue was not discussed in more detail in the text. Unfortunately even if the data on local births collected to date had been reviewed it is doubtful that it would necessarily have been very helpful. It is well known that there are serious inadequacies in the reporting system and registry data and Boyd et al [24] concluded: “The surveillance of congenital anomalies in England is currently inadequate because ascertainment of affected live and stillbirths by the national register is very low (40%), varying by defect, region, and hospital and because NCAS currently does not include data on terminations of pregnancy after prenatal diagnosis of fetal anomaly” Again it is disappointing that there are such fundamental faults in the data collection system. These processes really do need to be improved if public confidence in the ability of the health services to protect their interests in relation to environmental contamination is not to be seriously undermined. Vrijheid [25] wrote in an editorial of the Journal of Occupational and Environmental Medicine this month that whilst the last decade has seen several large, regional and nationwide, studies of adverse birth outcomes the assessment of exposures have not significantly advanced beyond distance-based measures over that period. The basic problem with this approach is that it tends to dilute exposures by including those who are not exposed with those who are. Professor Dolk explains [22]: “Misclassification of exposure or poor exposure classification is often cited as a reason to disregard the results of studies such as EUROHAZCON which find evidence of an excess of disease near a waste disposal or treatment site. 7 A teratogen is a chemical which may interfere with the normal development of a fetus and result in the loss of a pregnancy , a birth defect , or a pregnancy complication


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However, misclassification of exposure generally leads to underestimation, not overestimation, of relative risks. This is quite intuitive — if the distinction between the exposed and unexposed is so poor that it is almost random, any real problem among the true exposed would be unlikely to be detected. Misclassification does not make observation of a spurious excess risk where there is in fact none more likely. Thus, this argument would lead us to conclude that the real risks maybe higher than those revealed by the study”. Vrijheid concludes “The only way to better inform both the public and professionals of the real hazard to the unborn fetus, is by improving our understanding of landfill exposures and of the causes of adverse birth outcomes”. One way of doing this is by using computer modelling, as recommended by Mohan [26] . This approach has been adopted by Macleod et al [3] in relation to landfill sites used for the disposal of fly ash and APC residues, including the Wingmoor hazardous landfill site. Macleod et al. “Modeling human exposures to air pollution control (APC) residues released from landfills in England and Wales” The Macleod study was not a “generic analysis of ash disposal in the UK” as claimed in the draft at para 3.5.8. The paper is clear that the modelling of four of the sites, including Wingmoor farm (incorrectly labelled Wigmore) used “site specific emission terms” as shown on the table of results below. Had the data and model been entirely generic there would have been no difference between the landfills. By using site specific modelling data and emission terms it can be seen in extracted Table 7 below that the emissions from Wingmoor farm are much greater than from the other sites. Nor is this assessment entirely ‘conservative’ as the HIA says. The Macleod paper certainly does not consider a ‘worst case’ scenario and higher exposure through, for example, ‘Pica’ or ‘Geophargia’ (soil eating disorders). These risks were not addressed. Neither PCBs nor other dioxin-like substances, such as brominated dioxins were included. Dioxin-like Compounds Till [27] found that by using bioassay techniques the true dioxin like toxicity of incinerator fly ashes is two- to fivefold higher than the chemical analysis of dioxins and PCBs alone would indicate. This is likely to be due to other halogenated dioxins and similar chemicals in the ash that are not measured when using conventional analytical techniques. The consequence is that the fly ash could be much more hazardous than Macleod assumed.


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The conclusions of the review for Bishops Cleeve was that:

The predicted annual mean concentration of PM10 s in airborne dust from the landfill at the nearest property was 1.8 µg m-3, which is significantly lower than the Air Quality Strategy Objective of 40 µg m-3. If windblown PM10s, as the smallest and most easily transported particles are assumed to be the only route for inhalation exposure then, for an adult who inhales 20 cubic metres of air per day, even if all the air pollution control residues were at the highest reported concentration of 5,800 ng/kg ITEQ dioxins, this would imply a negligible contribution to daily exposure for an adult through inhalation of 0.2 pg ITEQ dioxins.

But respiration is not the main exposure route. The results of the exposure assessment were:

The average daily human exposure (ADE) to the critical receptor was estimated to be 0.8 pg TEQ/kg bw/day, which is twice the health criteria value derived for dioxins (0.4 pg TEQ/kg bw/day; Defra and Environment Agency, 2003). Based on this initial assessment, it would be useful to explore this exposure assessment further using more realistic parameters and to refine the CLEA model to allow for the derivation of soil guideline values for PCDD/PCDFs and this is currently under consideration.

The assessment only considers the marginal impacts from the landfill site and does not add them to the existing pollution burden. The impacts that would be predicted from the increase in PM alone can be calculated from DEFRA [28] data reviewing the air quality strategy:


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A 1.8 µg/m3 increase in PM10 would be expected to cause an average shortening of the life of the average person exposed by c 4 weeks. DustScan: The Environment Agency directional dust monitoring is undertaken using DustScan directional dust gauges. These use the ‘sticky pad’ method of dust sampling, where dust in an airflow is intercepted by a cylindrical adhesive surface for subsequent quantification. These monitors have been operational since September 2004, with five of the gauges relocated in January 2006 at the request of the Environment Agency. It seems barely credible that after four and a half years of data collection there is still no interpretation available to inform the HIA. The Environment Agency has decided in January 2009 to seek “full geochemical analysis and interpretation of the samples” but it would have been far more helpful if they had done so in a timely manner so that the results could have been incorporated in the report – especially as they have been aware of this need since 2006! The failure of the principle regulator to take appropriate and timely action in relation to the HIA certainly undermines public confidence in their role and reinforces anxiety about the possible impacts of the landfills. “the majority of dust travels 100 – 200m before being deposited" [29] We have only recently received the DustScan data as it had not been placed on the public register and the Environment Agency was asking SWARD to pay £75 to supply of the results. A brief inspection of the output shows, however, that there is cause for concern and that the detailed assessment ought to have been included as part of the HIA. In September – October 2008 for example, some of the most recent results


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appear to implicate the landfill sites as significant sources of dust:

The results from near the gate at the Wingmoor farm entrance show that nuisance values are exceed during this period. Even if this were only an occasional phenomena it would not be an acceptable situation. A recent inspection of the Wingmoor public register held by the Environment Agency revealed a reference to two reports apparently prepared by consultants for Grundon that appear to have reviewed dioxin emissions from the site and are claimed to include reassuring conclusions. Neither of these reports was on the public register but both are clearly important and should have been supplied to the Steering group for consideration as part of the HIA:

• Applied Environmental Research Centre Ltd. 2002. Assessment Of Dioxin Filter Samples, Wingmoor Farm Landfill, Bishops Cleeve.

• AMEC Earth & Environmental. 2007. Detailed Assessment of Potential Public Health Impacts of APC Residue

A request has been made to the Environment Agency for copies and when they have been provided then SWARD will review them.


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Stress There are differing degrees of willingness to be exposed to risk according to whether the exposure is voluntary or involuntary. Entirely voluntary activities such as rugby or skiing carry a high risk of injury with the possibility of permanent disability, but the risk of the activity can be balanced against the enjoyment of taking part. Workplaces such as mines and steelworks carry health risks and, although the choice of whether or not to work in such industries may be limited by the lack of other job options, people may decide to take the risk because they will be paid for doing so. When exposure is completely involuntary and there are no benefits to balance the equation, people are much less willing to accept even relatively small risks. [30]. There are a range of factors which are acknowledged to increase stress. According to the Department of Health [31], risks are generally more worrying and less acceptable if perceived:

1. to be involuntary (e.g. exposure to pollution) rather than voluntary (e.g. dangerous sports or smoking);

2. as inequitably distributed (some benefit whilst others suffer the consequences);

3. as inescapable by taking personal precautions; 4. to arise from an unfamiliar or novel source; 5. to result from man-made rather than natural sources; 6. to cause hidden and irreversible damage (e.g. through onset of illness

many years after exposure); 7. to pose some particular danger to small children or pregnant women or

more generally to future generations; 8. to threaten a form of death (or illness/injury) arousing particular dread; 9. to damage identifiable rather than anonymous victims; 10. to be poorly understood by science; 11. as subject to contradictory statements from responsible sources.

All of these perceptions, with the possible exception of no. 9, apply to the Wingmoor landfill sites. Stress is produced by the psychosocial environment, contributing to health inequalities by raising concentrations of cortisol in the body, leading to high blood pressure [32]. Psychological distress has been reported as a predictor of fatal ischaemic stroke in men [33] and increases the risk of coronary heart disease [34]. Exercise can limit the damaging effects of stress and produce feelings of wellbeing, but may not be possible for many local people who are sick, disabled or elderly [30]. [35] linked individual-level survey data with data from the US. Census and the Toxic Release Inventory and found that residential proximity to industrial activity has a negative impact on mental health. This impact was both direct and mediated by individuals 'perceptions of neighborhood disorder and personal powerlessness. Whilst the impact was even greater for minorities and the poor than for whites and wealthier individuals their results suggested


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that public health officials need to take seriously the mental health impacts of living near industrial facilities. In a study by Vandermoere [36] the mental health of the exposed residents was much worse than in the matched group. The probability of distress did not co-vary with independently assessed or perceived danger of the contaminants, but with residents’ sense of participation in consultation over the contamination problem, and with interaction of the latter with a perceived need for decontamination. This suggests that a disbelief in the necessity of risk mitigation, along with a perceived lack of participation, can be more stressful than actual and perceived contamination. An example of why this study is particularly relevant is referred to at para 3.11.4 of the draft and arose in January 2007. Grundon sent out a "community consultation questionnaire" of which 547 were returned completed. Despite requests for access to the results via the Wingmoor Liaison Forum, these were made public only two years later at the public exhibition on 31st January 2009. The exhibition gave a brief summary of responses to the questions, which concerned the order of phasing restoration and the land use after restoration but included nothing about residents experiences of current operations at the sites. Many residents had included additional letters and comments and Grundon informed SWARD that there had been “too many“ additional comments to present at the exhibition. Appendix B of the draft HIA records that “many of the comments did not relate to the question or proposition being posited in the survey”. This is not surprising if people want to say something different or don’t accept the framework that Grundon was trying to impose upon them. No summary was provided to give an overview of these comments. SWARD believe that the high number of responses indicates the level of public interest in the operations at the sites and the failure to publicise the extra comments sent in by residents is indicative of Grundon's reluctance to acknowledge the level of local concern and experiences of disamenity. In these circumstances many of the public feel alienated and frustrated that the consultation are simply a PR exercise as the company shows no interest in taking their comments into account. What the community questionnaire demonstrated unequivocally was that the overwhelming majority (92%-98%) of those replying said that planning permission for the landfill should not be extended beyond 2009. Bearing in mind the amenity impacts that have been faced by residents over the years; the ‘light at the end of the tunnel’ by 2009 that the current time limited planning permission offered; and the many outstanding uncertainties over the health effects of the landfill sites as discussed above the Planning Authority should now respond to the views so strongly expressed by the residents. If they do then the HIA will have served a vital function.


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ENDNOTES: 1. Kemm, J., J. Parry, and S. Palmer, Health Impact Assessment:

Concepts, theory, techniques and applications. 2004: Oxford University Press.

2. Cole, B.L., et al., Methodologies for realizing the potential of health impact assessment. American Journal of Preventive Medicine, 2005. 28(4): p. 382-389.

3. Macleod, C., et al., Modeling human exposures to air pollution control (APC) residues released from landfills in England and Wales. Environment International, 2006. 32: p. 500–509.

4. Carpenter, D.O., J. Ma, and L. Lessner, Asthma and Infectious Respiratory Disease in Relation to Residence near Hazardous Waste Sites. Annals of the New York Academy of Sciences,, 2008. 1140(1): p. 201 - 208.

5. Cheltenham & Tewkesbury Primary Care Trust (PCT), Bishops Cleeve Neighbourhood Health Profile October 2005. 2005.

6. Baibergenova, A., et al., Low birth weight and residential proximity to PCB-contaminated waste sites. Environ Health Perspect, 2003. 111(10): p. 1352-7.

7. Morgan, O.W., M. Vrijheid, and H. Dolk, Risk of low birth weight near EUROHAZCON hazardous waste landfill sites in England. Arch Environ Health, 2004. 59(3): p. 149-51.

8. Dolk, H., et al., Risk of congenital anomalies near hazardous-waste landfill sites in Europe: The EUROHAZCON study. Lancet (North American Edition), 1998. 352(9126): p. 423-427.

9. Geschwind, S.A., et al., Risk of Congenital Malformations Associated with Proximity to Hazardous Waste Sites. Am. J. Epidemiol., 1992. 135(11): p. 1197-1207.

10. Palmer, S.R., et al., Risk of congenital anomalies after the opening of landfill sites. Environmental Health Perspectives, 2005. 113(10): p. 1362-1365.

11. Johnson, B.L., A review of the effects of hazardous waste on reproductive health. American Journal of Obstetrics and Gynecology, 1999. 181(1).

12. Mueller, B.A., et al., Fetal deaths and proximity to hazardous waste sites in Washington State. Environmental Health Perspectives, 2007. 115(5): p. 776-780.

13. Elliott, P., et al., Birth outcomes and selected cancers in populations living near landfill sites. 2001, Report to the Department of Health, The Small Area Health Statistics Unit, Department of Epidemiology and Public Health, Imperial College: London.

14. Berry, M. and F. Bove, Birth weight reduction associated with residence near a hazardous waste landfill. Environ Health Perspect, 1997. 105(8): p. 856-61.

15. Dolk, H., et al., Risk of congenital anomalies near hazardous-waste landfill sites in Europe: the EUROHAZCON study. The Lancet, 1998. 352(9126): p. 423-427.


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16. Vrijheid, M., et al., Chromosomal congenital anomalies and residence near hazardous waste landfill sites. The Lancet, 2002. 359(9303): p. 320-322.

17. Vrijheid, M., et al., Hazard potential ranking of hazardous waste landfill sites and risk of congenital anomalies. Occup Environ Med, 2002. 59(11): p. 768-776.

18. Elliott, P., et al., Risk of adverse birth outcomes in populations living near landfill sites. Bmj, 2001. 323(7309): p. 363-8.

19. Elliot, P., et al., Risk of Congenital Anomalies in Relation to Geographic Density of Landfill Sites in England [ISEE/ISEA 2006 Conference abstracts]. Epidemiology; Suppl S114, 2006. 17(6).

20. Elliott, P., et al., Geographic density of landfill sites and risk of congenital anomalies in England. Occup Environ Med IN PRESS, 2008: p. oem.2007.038497.

21. Elliott, P., et al., Geographic density of landfill sites and risk of congenital anomalies in England. Occup Environ Med, 2009. 66(2): p. 81-89.

22. Dolk, H., Methodological Issues Related to Epidemiological Assessment of Health Risks of Waste Management, in Issues in Environmental Science and Technology, No. 18 Environmental and Health Impact of Solid Waste Management Activities, R. Hester and R. Harrison, Editors. 2002, Royal Society Chemistry. p. 195-210.

23. Armstrong, B., et al., Geographic variation and localised clustering of congenital anomalies in Great Britain Emerging Themes in Epidemiology, 2007. 4(1 %M doi:10.1186/1742-7622-4-14): p. 14.

24. Boyd, P.A., et al., Congenital anomaly surveillance in England--ascertainment deficiencies in the national system. Bmj, 2005. 330(7481): p. 27-.

25. Vrijheid, M., Landfill sites and congenital anomalies - have we moved forward? Occup Environ Med, 2009. 66(2): p. 71-.

26. Mohan, R., et al., Evaluation of methodologies for exposure assessment to atmospheric pollutants from a landfill site Journal Air and Waste Management Association IN PRESS, 2009.

27. Till, M., et al., Dioxinlike components in incinerator fly ash: a comparison between chemical analysis data and results from a cell culture bioassay. Environ Health Perspect, 1997. 105(12): p. 1326-32.

28. AEAT, An Evaluation of the Air Quality Strategy ED50232 January 2005. 2005, DEFRA.

29. SLR Consulting Ltd, Review of Particulate Matter Monitoring Locations, Wingmoor Farm Waste Treatment Facility, Gloucestershire SLR Reference 403.0013.00019 December 2006. 2006.

30. Lester, C. and M. Temple, Health impact assessment and community involvement in land remediation decisions. Public Health, 2006. 120(10): p. 915-922.

31. Department of Health, Communicating About Risks to Health: Pointers to Good Practice. 1997. p. 27.

32. Brunner, E., Socioeconomic determinants of health: Stress and the biology of inequality. Bmj, 1997. 314(7092): p. 1472-.


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33. May, M., et al., Does Psychological Distress Predict the Risk of Ischemic Stroke and Transient Ischemic Attack?: The Caerphilly Study. Stroke, 2002. 33(1): p. 7-12.

34. Stansfeld, S.A., et al., Psychological distress as a risk factor for coronary heart disease in the Whitehall II Study. Int. J. Epidemiol., 2002. 31(1): p. 248-255.

35. Downey, L. and M.V. Willigen, Environmental Stressors: The Mental Health Impacts of Living near Industrial Activity. Journal of Health and Social Behavior, 2005. 46(3): p. 289-305.

36. Vandermoere, F., Psychosocial health of residents exposed to soil pollution in a Flemish neighbourhood. Social Science & Medicine, 2008. 66(7): p. 1646-1657.


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Steve Roscoe Technical Director Grundon Thank you for the opportunity to comment on the draft community health impact assessment prepared by the Steering Group. We understand that at this stage you require comments on factual matters. We believe there are a number of inaccuracies in the draft report that should be corrected or clarified before publication. We reserve the right to make additional comments on the report’s recommendations when it has been published. There are four matters that we believe bear generally on the issue of factual accuracy and consequently on the weight that a reader can reasonably attach to its conclusions. We attach as an appendix a list of other, mostly more detailed points, but some of these are also quite fundamental. The four main points are concerned with the HIA methodology being fully reported, transparency of the membership of the Steering Group, the evidence it has collected to support the conclusions, and the relationship between the reports conclusions and recommendations and Grundon operations. In respect of the first matter it is normal practice in such documents to set out the project brief, changes to that brief, public consultations undertaken and data gathering exercises within the local community to support the HIA. Without the support of such factual evidence the document cannot claim to be an HIA of the local community. In respect of the second matter, we think it highly desirable that all members of the steering group are identified in the report by name, and that any affiliations they have that could be regarded as having a bearing on their approach to the subject matter of the report are clearly stated. The term local resident needs to be narrowed, by reference to a specific geographical area. These changes would, we believe, follow convention for reports that seek to influence the use of public funds and which seek to speak for the community rather than simply put a partial view. Unless you are aware of a particular reason not to follow convention in this case, we think the normal standards of transparency should apply. The third point is related to the first and is equally important. In several places the report states or implies that the Steering Group is representative of the community and therefore speaks with knowledge of the community’s views. No evidence is produced in the report to support this proposition. In our view, it is important that, where the report switches from stating the views of the Steering Group to purporting to put forward the views of the wider community, the evidence that the Group has gathered to justify that change of perspective is included in the report.


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We draw attention to this point because some bold statements are made in the report on behalf of the community. For example, one of the key paragraphs in the report (paragraph 1.06) says: it is clear that the community has very real concerns about the Wingmoor sites. Little or no evidence is offered in the report that the community, as distinct from the Steering Group, harbours any concerns. Paragraph .2.4 indicates that events to obtain the wider views of the community have not taken place. The choice would appear to be either to include the evidence supporting the conclusion that the community holds the stated view, or to amend the report to clarify that it is in fact the view held by the Steering Group. The final overall point is that the report is, in several places, confused about whether the individual conclusions refer to Grundon operations or to Cory or to both. We draw attention to our appended comment on paragraph 2.0.4. It would be appreciated if the Steering Group could review all such references so that when we submit our comments on the published report, we are able to concentrate on matters concerning Grundon operations. In anticipation that the Steering Group might find it helpful, we attach a location plan that could be included in the report. An electronic version can be supplied. We also attach copies of the exhibition boards from the public exhibition held by Grundon on the 31st January. These could be are appended to the HIA report to help explain the details of the operations at Wingmoor Farm East. An electronic version can be provided. If anything is unclear or if you need clarification, please do not hesitate to ask. Appendix to letter dated 27th February 2009 from Grundon Grundon Detailed Factual Comments 1.0.6 See comments in covering letter concerning the accuracy of the first sentence of this paragraph. 2.0.1 The last sentence states the Steering Group’s belief that the expansion of the sites has taken place without the full knowledge and understanding of the potential health effects to the community who are living near the Wingmoor sites . Whilst that may be the steering group’s belief, we consider that it has based its view on a less that comprehensive understanding of the planning and regulatory processes, that require public consultation and of local democratic decision making within a framework of National and European legislation, and also of the timeline of key decisions. The difficulty that arises is that the report gives the impression the waste operations at Wingmoor Farm have encroached upon the residential properties within Bishops Cleeve. In fact the opposite is the case. The area of the landfill site closest to the western periphery of Bishops Cleeve has been in mineral operation since the early 1960 s and waste operations since the late 1970 s.


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In the interest of factual accuracy and balance, we consider that this impression should be corrected. 2.02 To our knowledge publicly available data is insufficiently detailed to allow population totals to be defined this accurately within a defined radius. We ask that a map be provided showing the area and a source of the statistics provided. This is a typical example of the methodology issue raised by our covering letter in not including and referencing data sources. 2.03 See covering letter. There is a significant step between the group of people described in this paragraph speaking for themselves and a Steering Group speaking on behalf of the wider community, which needs to be explained in the report. 2.04 See covering letter. There is a striking inconsistency between the two sentences in this paragraph. If, as the first sentence claims, it is clear that it was not possible to separate the (Cory and Grundon) sites, then the consequence is that they can only be dealt with together. It is logically impossible to do what the second sentence says was in fact done, i.e., to place a key focus on part of one of them. This is not merely semantics, but goes to the heart of the validity of several of the report’s conclusions. 2.1 This section solely describes what an HIA might comprise, but there is no statement of what was actually done, so that the reader can be sure that this is indeed an HIA. This is an obvious and basic requirement that must be inserted in the report. See also 2.2.3/4. 2.1.2 The statement: HIA looks at issues that would ordinarily be considered to be outside of the standard remit covered by processes such as planning applications and permit applications is not an accurate representation of the position. The primary objective of the environmental permitting procedure is to control activities that could harm the environment or human health. The Environmental Permitting Core Guidance (2008) makes it clear that the term protect the environment should be read to include the environment and human health, wherever it occurs in the Guidance. Thus as part of an application for an Environmental Permit it is required that an assessment of the potential impact on the environment and human health is undertaken. The consideration of health effects, including the perception of unacceptable risk are issues that require consideration as part of the planning process, including the determination of planning applications, where case law demonstrates that they are a material consideration. This policy position is outlined in Planning Policy Statement 23: Planning and Pollution Control and Planning Policy Statement 10: Planning for Sustainable Waste Management. 2.1.9 This is an example of the confusion in the report about which site is being referred to, and requires clarification. The document is again described


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as a community HIA however it contains no evidence of such consultation and evidence gathering which should be attached as an appendix. 2.2.2 See covering letter. It is noted that the steering group was originally formed of 12 members when it was first formed in 2006, each member should have a brief CV to include experience and interests. The report suggests that this reduced to 10 and eventually reduced to 7. Please clarify together with timelines of those involved. 2.2.3/4 These paragraphs describe what was not done, highlighting the absence of any description of what was actually done. 2.3.1/2/3 The Group is quoted as identifying a wide range of impacts and narrowed this down to two specific areas. This process needs to be supported in the methodology, in particular the evidence and data gathering stages, and how the wider community inputted into such conclusions. 3.3.1/2 The report should explain that the Environment Agency audit was to check compliance with the waste pre acceptance procedures and acceptance procedures at the waste treatment facility. It was not a general audit or in association with air quality as the report implies. The inclusion of general EA comments from the second sentence onwards in 3.3.1 associates these by default to the Wingmoor treatment plant and is of no relevance to the actual audit of that plant and therefore should not be included in the HIA. If it is felt necessary to include such an extract it needs to be put into context properly in a separate paragraph. 3.4.6 The position should be clarified in the Steering Group s report. Grundon are sponsoring a KTP (Knowledge Transfer Project) research project, developing dustmonitoring methodologies. Wingmoor Farm East is being used as the study site. It is hoped that the research project will develop into a PhD research paper in the future. The KTP research is due to produce a report on the methodologies in late 2009. Statistical manipulation of data collected thus far has just begun. Therefore, there are no results to report at this stage. A copy of the abstracts relating to the work that has so far been produced is attached. The Steering Group s report should acknowledge that Grundon have already committed to presenting the findings of the research work to the Wingmoor Liaison Forum, once the studies have been completed. The last sentence of this paragraph is confused, and doubtless will be confusing to others, and should also be deleted. Adams Hendry are Grundon’s consultants preparing the planning application and environmental statement. 3.5.6 to 3.5.8 These paragraphs discuss the Macleod (2006) report. They present an unbalanced impression of the report’s conclusions. If the Steering Group wishes to use the conclusions of the report, several of which are directly relevant to the Group’s concerns, it should do so in a more balanced way. The report s conclusions are:


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Conclusions A generic risk screening approach was developed for the potential pollutant linkages that exist at landfill sites accepting APC residues. Potential exposures were modelled using data from the literature, not site monitoring data. The results provide an indication of the relative magnitude of the risks posed. They are generic, and do not reflect all exposure circumstances at all locations. The following conclusions demand qualification given the assumptions adopted. 1. Seven important pollutant linkages were identified with medium and high risk to human health. These considered the atmospheric transport and subsequent direct and indirect exposure to nearby workers and residents. The key pollutant linkages were potentially present at 4 of the 6 landfill sites studied. 2. Direct exposure through ingestion and inhalation are the critical exposure pathways. 3. Dust does not appear to be of major concern given the deposition rates modeled. However, it would be prudent to control dust release through the enforcement of control measures in the permit conditions and working plans. 4. The main APC landfill site (N40% of the total APC residues disposed in 2000 2001) was found not to cause significant release of APC residues that reached the nearby receptors. The predicted annual mean of PM10 at the nearest sensitive human receptor was 1.8 g/m3, significantly lower than the air quality strategy objective of 40 g/m3. 5. The long term accumulation of dioxins from deposited dust are tentative and warrant further study. Indications in this work are that indirect exposures require more detailed investigation. 6. On the basis of this preliminary analysis, the disposal of APC residues at landfill sites does not appear to pose significant harm to nearby human receptors. However, this assessment was made using a restricted data set and more information is required to fully understand the nature of the hazard. 7. Future work will have the opportunity to utilise updated research on APC residues and their characteristics (WRc, 2004). Conclusions 3-6 inclusive would appear to be particularly pertinent to the Steering Group s remit. 3.5.9 The issue regarding the removal of sheep from the site, has been explained to the Wingmoor Liaison Forum on two occasions. It is therefore important that this statement is corrected, as follows: Regulation 11(2) of the Animal By-Products Regulations 2005 prohibits the importation of catering waste or other animal by-products on to any premises where any livestock is kept. This had implications for a large number of landfill sites across England & Wales and landfill operators requested further guidance from the State Veterinary Service on whether livestock are permitted to be located on restored areas of a landfill. The SVS policy advice included a requirement that: Livestock must be separate from landfill premises, with separate entrance / exit that can be reached directly from the public highway without having to enter the landfill premises.


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Grundon were unable to comply fully with this requirement and therefore removed the flock of sheep resident on site. Alpacas are allowed to graze the restored landfill as they are not defined as livestock for the purposes of the Regulations and do not enter the food chain. 3.9.17/8 The HIA is using a draft and unpublished report to reach recommendations. We are not sure if the report has been peer reviewed at this stage or of the weight to be given to the report. If such unpublished data is to be used it should be appended to the report in full. 3.11.1 This section does not present an accurate picture of the current position. For example, it omits mention of the Wingmoor Farm Liaison Group that has been meeting regularly since 2004 and includes representatives from both Cory and Grundon. In the interests of transparency, see covering letter, it should acknowledge that at least five members of the HIA steering group are also members of the liaison forum, as is the HIA facilitator from Gloucestershire PCT, Caryn Hall. Grundon also prepare a newsletter for when new things are happening at the site, or when applications are due to be submitted or go on public consultation. These are disseminated to a wide audience. To paint a fairer picture the report might also acknowledge that Grundon held a public exhibition regarding the proposed continuation of operations at Wingmoor Farm East. It also held an exhibition in 2005 to inform the public over changes to the classification of landfills as a result of changes in legislation and had participated in a site liaison committee prior to 2004. It should also note that the forth-coming planning application will be accompanied by an environmental statement, the scope of which has been agreed by GCC. As noted above, a copy of the exhibition boards has been provided with these comments. It is suggested that they are appended to the report to complete the picture regarding the forth-coming planning application and details regarding Grundon’s site. 8.1.2 The assertion that Grundon’s facility is the main operation at Wingmoor Farm is not borne out by the facts. Grundon’s and Cory s operations are of a comparable scale and physical extent, as is illustrated on the attached map. This statement should therefore be corrected.


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Cllr Mike Skinner Chair Wingmoor Task Group (HOSC sub group) I would support and expect to see an update Bishop’s Cleeve Neighbourhood Health Profile undertaken by NHS Gloucestershire as a matter of priority so that comparisons can be made with the earlier published version from October 2005.


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Paul Hern Environmental Health Tewkesbury Borough Council I have read the report and suggest following: Page 27 Para 3.9.9 delete from "..are all below" up to "..a maximum.." then insert "..show the annual average for ntirogen dioxide to be well below both the EU and UK annual average target objective value i.e...." Page 28 para 3.9.13 last line delete "...maximum annual target." insert "...EU and UK annual average target objective value."


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Jo Walker Director, Environment Directorate Gloucestershire County Council Gloucestershire County Council recognises the concerns of the community group captured in the report. Gloucestershire County Council is subject to a number of recommendations. There is concern about the lack of GCC representation and the use of the word "must" in the recommendations. GCC will consider the recommendations within the full evidence base and within the context of any policy, statutory and budgetary implications.


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Dr Chitra Arumugam Consultant in Communicable Disease Control Health Protection Agency, Gloucestershire I refer to the draft Community Health Impact Assessment of the Wingmoor Sites, Bishop’s Cleeve, Gloucestershire received on the 13th February 2009. The report provides a valuable insight into the concerns of the community and outlines key areas of work. The draft report tasks the Health Protection Agency with two key actions: 5.2.1 The Health Protection Agency must lead, in collaboration with key stakeholders, a community consultation event that will ensure that views of the local community are captured with respect to issues raised in this report.

5.2.2 The Health Protection Agency must resource and implement the proposal to introduce an Environmental Public Health Tracking Programme (EPHT) to commence in 2009 or at the earliest opportunity. The EPHT must report their findings at regular intervals to the appropriate fora so that residents are made aware of findings. This letter represents the collective views of all consultees within the Health Protection Agency. In respect to point 5.2.1 the Health Protection Agency may not be the most appropriate body to lead a community consultation event to capture the views on issues raised in the report. The Agency was established in 2003 to provide independent advice to Government, the NHS and other agencies on chemical, biological and radiological hazards. It aims to protect the health of the UK population by identifying, preparing for and responding to health threats and setting standards for health protection. The agency provides advice and support to the Primary Care Trust and Local Authority, which have more direct community links and established mechanism for public engagement. With respect to point 5.2.2, the Health Protection Agency is committed to developing a national Environmental Public Health Tracking system (EPHT), which will examine the relationship between environmental exposures and environmentally related disease. It involves the ongoing collection, integration, analysis and interpretation of data about environmental hazards and exposures. A pilot EPHT has been successfully undertaken in the UK, based on a methodology developed by the Centre for Disease Control in the USA. Information gathered would be appropriately directed to minimise health impact from environmental hazards. The Agency is currently seeking funding to develop a national EPHT system. It is estimated that if current bids are successful the programme could be established and operational within 3 years. We would be welcome an opportunity to discuss the Community Health Impact Assessment report with the Primary Care Trust in more detail and consider mechanism for addressing some of the broader community


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concerns. Please do not hesitate to contact me if you have any further questions or require any additional information.


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Dr Shona Arora Director of Public Health NHS Gloucestershire NHS Gloucestershire welcomes the completion of the community HIA. With respect to the specific key areas of action identified for NHS Gloucestershire we would respond as follows; 5.1.1 NHS Gloucestershire must undertake a study to determine the

potential effects of the Wingmoor sites on the physical and mental health and wellbeing / stress of local residents (to include asthma) who live in proximity to the Wingmoor sites to be completed in 2009.

NHS Gloucestershire has already commenced giving this key action point due consideration and will look to confirm the specific actions it is able to undertake through the auspices of the Wingmoor Liaison Forum. 5.1.2 NHS Gloucestershire must undertake a comparative update of the

Bishop’s Cleeve Neighbourhood Health Profile every 3 years commencing in 2009.

NHS Gloucestershire has already commenced an update of the Health Profile, and this will be complete before the end of 2009 at the very latest. 5.1.3 NHS Gloucestershire must undertake a long term prospective cohort

study of new born babies in the area surrounding the Wingmoor sites in order to identify any specific health issues to commence in 2009.

NHS Gloucestershire needs additional time to give this particular key action area due consideration due to the complexities of what would be involved, and to assess whether or not this would be feasible in the context of good research methodology. NHS Gloucestershire would propose to advise through the auspices of the Wingmoor Liaison Forum as to the specific actions that it would look to action with respect to this particular action point.


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Mike Griffiths Chairman Uckington Parish Council Uckington Parish Council representative at the Bishops Cleeve Forum 1.0.1 ‘the community’ has not been defined i.e. the communities and their populations, within a determined radius of the land fill sites should be listed, to include Stoke Orchard, Elmstone Hardwicke, Swindon Village and Brockhampton. See Para 2.02 below: 2.02 Mentions a population of 15,059 people who live within a 3km zone. 3.5.9 Grazing of animals near the landfill sites There are animals grazing the fields up to the perimeters of ALL the sites. In particular in Uckington where there is a milking herd. Also grain crops can be cultivated in these fields, which presumably also go in to the food chain. 3.6. Odours and Gases I can confirm that this village suffers serious concerns about the continuous exposure of landfill gas. I have on a regular basis, along with other villagers reported to the Environment Agency; Gloucestershire County Council, Environment Directorate, Tewkesbury Borough Council, Environmental Health Department; Cory Liaison Group and the Landfill Forum, the constant nuisance from the odours. To the extent I now submit a diary of these smells, from around the site, to as far away as the centre of Cheltenham, and at Cheltenham General Hospital. 3.6.1 The Effects of Gulls There is a continuing monitoring of the relationship between Gloucester landfill and the urban gull colonies in Gloucester and elsewhere in the Severn Estuary Region on both sites. Omissions The Effect of Fly Nuisance Here in the villages of Elmstone Hardwicke and Uckington, we have over many years suffered very badly with flies. In particular the summer of 2003, was horrendous. We have a letter from Tewkesbury Borough Environment Department, telling us to fit shutters to our doors and windows to prevent flies entering the house. At that time we worked with the Environment Agency, and Cory, who invited a study with ADAS, under the supervision of Barbara Bell, Principal Environmental Consultant, ADAS Consulting Ltd, to analyse the type of flies, and where they were coming from in the locality. Flies have been collected from households in the village, weekly for several years, with reports compiled by Cory Environmental. It should be noted that all the sites are continuously spraying the exposed landfill material with insecticide to minimize the impact of flies.


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However, we do not know what insecticides are being used, or their impact on the health of the surrounding communities. 3.10 10 A Risk Assessment What procedures and advice are in practice for a major incident happening on the sites, i.e. fire, escaping of gas, explosion, escaping and dispersal of toxic ash across the surrounding communities or landfill leachate into any watercourse? 3.10.11 An exercise should include a road traffic collision on any of the County’s roads, particularly in built up areas, where the vehicles carrying the toxic waste are travelling. 3.13 Cumulative Effects Including Planning and Strategic Considerations 3.13.4 Omission The RSS identified an area of land to the south of the Wingmoor Farm landfill sites, known as area of search 3F as the proposed new urban extension of Cheltenham, suitable for the development of 5000 houses to be built by 2026. The RSS states that: - 4.1.3 The North West of Cheltenham provides considerable potential to extend the town in the area are not subject to flood risk and other environmental constraints. Omission No mention has been made of the County’s waste management strategy for the future, and in particular the possibility that an incinerator could be sited at Wingmoor Farm. 7.0 COMMENTS AND FEEDBACK 7.0.1 Omission Swindon village and Brockhampton Parish Council

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Gloucestershire Health Overview and Scrutiny Committee

13th March 2009

Community Health Impact Assessment Wingmoor Sites, Bishop’s Cleeve, Gloucestershire

1 Introduction 1.1 The purpose of this report is to present to HOSC the completed

community health impact assessment (HIA) undertaken in relation to the Wingmoor waste treatment and landfill sites, Bishop’s Cleeve.

1.2 This report will also further inform the work of the Wingmoor Task

Group. 2 Background 2.1 NHS Gloucestershire has been aware of community concerns with

regard to the Wingmoor sites for several years. In October 2005 in response to the concerns raised by local people about the impact on their health of a local hazardous waste landfill site the then Cheltenham & Tewkesbury Primary Care Trust undertook a review of the evidence of the health experience of people in Bishop’s Cleeve compared with elsewhere in the county.

2.2 The Bishop’s Cleeve Neighbourhood Health Profile (Appendix A)

identified that people living in the Bishop’s Cleeve area generally experienced levels of ill health which did not differ markedly from people living in other areas of Gloucestershire when a range of established health indicators and other less robust sources of evidence are compared.

2.3 The main body of current scientific evidence where it exists shows that

whilst it is technically possible to detect the presence of health hazards in waste sites and health impacts among people working or living nearby, there are many problems demonstrating the relationship between exposure and the health impacts observed. The main limitations of epidemiological investigations are the small sample size, lack of exposure information, lack of toxicological data about mixtures of chemicals and the lack of specific indicators of adverse health effects. Given these limitations, there will always be a high level of uncertainty about the health risks to people exposed to hazards from waste management sites.

2.4 In response to continued concerns raised by local residents through

the Wingmoor Liaison Forum NHS Gloucestershire agreed to facilitate a community HIA.

ITEM 10.2

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3 Community HIA 3.1 A community HIA is very different in its approach to a more traditional

HIA as it is a more responsive process to community concerns and considers health and wellbeing in the context of the wider determinants of health. It potentially provides a forum with which people can express concerns and fears that they believe may have not been covered or considered by other regulatory frameworks for example through planning applications or permitting processes. This does not of course exclude areas that would be covered within other regulatory processes such as noise, dust, etc.

3.2 This process can assist decision makers to understand the concerns of

the community not just in terms of a quantified approach but also though a qualitative approach.

3.3 NHS Gloucestershire agreed to facilitate this process to enable the

community to complete a community HIA. The report that has therefore been produced is the work of the Steering Group and facilitated by NHS Gloucestershire.

4 Methodology 4.1 Following local advertisement a Steering Group was established to

take forward the HIA process. The Steering Group comprised representatives of all three tiers of local government – county, borough and parish, local residents, a local resident representing Local Involvement Network (LINk), a local resident’s interest group and a local representative of a national environmental interest group – Friends of the Earth.

4.2 The Group identified the key impacts to health they wished to

investigate. Stress was determined as the overarching impact that the Group wished to examine in detail. The issues that the Steering group identified included: • Fear for the potential effects of harm

• Fear for the potential effects of harm from the operations at and

around the site not least to babies, young children and other vulnerable groups

• Loss of quality of life, loss of amenity and potential reduction in

house prices

• Lack of control over the processes within the site and the way it operates (a feeling of helplessness)

• Concern about the future

4.3 The Group looked at the evidence for potential causative factors,

mitigation that was being undertaken and identified and undertook a gap analysis. This process led the Group to look at issues specifically relating to emissions to air, traffic, communication, health monitoring and assessment, cumulative effects and planning and other strategic considerations.

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5 Key Findings 5.1 The Steering Group identified that there were a number of common

and overarching themes that have arisen out of the work that require focus.

5.2 There is limited health data collected and made available on a

proactive basis which relates specifically to the local community that live in close proximity to the Wingmoor sites.

5.3 There is a perceived lack of transparency in the information available to

the public and communities – it being available in a number of different formats and from a wide range of agencies. The belief is that the processes that sit around accessing information in a clear readily accessible format are bureaucratic and the terminology and language used are often not suited to a lay reader. This leads to concerns that things are being “hidden”.

5.4 The general feeling is that the community is not being listened to

adequately and that the very real perceptions brought to the note of regulators, operators and other agencies are not taken seriously. It is felt that a number of perceptions could readily be allayed by suitable responses and co-operation with those involved at the Wingmoor sites.

5.5 There is a wide range of data being gathered and collated by a wide

range of agencies. This is not being brought together in an organised and centralised manner and assessed as a whole. This does not enable cumulative and trend data to be able to be assessed/analysed and interpreted.

5.6 The Steering Group believe that the change by regulators since the

introduction of Integrated Pollution Prevention Control (IPPC) permits from “regulating” of waste sites to “self regulation” by operators of these sites has reduced public confidence in the effectiveness of the regulatory process.

5.7 The Steering Group believe there is no clear vision at a national or

regional level for how hazardous waste is to be handled and disposed of. This also leads the Steering Group to perceive that consideration has not been given at a strategic level to identify alternative waste treatment and landfill sites within the region that may be located further away from housing and local communities.

5.8 There is an overarching belief that there has been “development creep”

at the Wingmoor sites, which due to the nature of planning processes means that the sites cannot contextually be considered as a whole when new planning applications are made.

5.9 Insufficient research is being undertaken in the UK relating to landfill

sites and waste treatment plants and more specifically hazardous waste landfill sites and their potential effects on health. The aim of this research should be to produce a robust and improved evidence base.

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5.10 That actions undertaken by agencies are not always followed through even when recommendations are made for further work, actions or research need be undertaken.

5.11 Group has therefore identified a number of key time specific actions for

a variety of key agencies to undertake, namely; • NHS Gloucestershire (Gloucestershire Primary Care Trust) • Health Protection Agency • Wingmoor Site Operators • Gloucestershire County Council • Gloucestershire Local Resilience Forum • Tewkesbury Borough Council • Environment Agency • Government Office of the South West • Gloucestershire Health Overview and Scrutiny Committee • Wingmoor Liaison Forum

5.12 Steering Group identifies that these actions are critical to further inform

the knowledge of health impacts and outcomes and would assist in establishing baselines. The key actions can be identified in Section 6.0 of the main report at Appendix 2 to this report.

6 Conclusion 6.1 NHS Gloucestershire is committed to responding to the public's

concerns regarding the potential health impacts on the community of the Wingmoor sites. It is apparent from the evidence available on landfill sites and expert advice from the HPA that well managed and regulated landfill sites should not represent a public health hazard, however it is important that the public is reassured.

6.2 The community HIA report is a very useful piece of community

evidence and intelligence that can be used to inform work around local planning and policy formulation which might not otherwise have been collated except through the auspices of a community HIA. The report is therefore able to be used by all those with an interest or other stakehold in the Wingmoor sites.

7 Recommendations

HOSC is requested to; • Note the report. • Give due consideration to the key actions identified by the report.

8 Appendices

Appendix A Bishop’s Cleeve Neighbourhood Health Profile Appendix B Community Health Impact Assessment of the

Wingmoor sites, Bishop’s Cleeve – Completed full report Appendix C Community Health Impact Assessment of the

Wingmoor sites – Summary of comments and feedback submitted report (this report also has its’ own appendix - Appendix 1).

Caryn L Hall, March 2009

health overview and scrutiny committee · 2009-06-09 · site, which use lasers to detect dust...

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