section 2 - devon · 2.5.2 discussions with the former northam burrows ranger suggested that some...

SECTION 2

SITE SETTING

SECTION 2SITE SETTING

Combined Phase I and Phase II Investigation Prepared by PBHPE98123A for Devon County CouncilJanuary 2009 Page 4

2 SITE SETTING

2.1 Site Referencing Information

2.1.1 Site referencing information is provided within Table 2.1, and the site location isshown in Figure 1.

Table 2.1: Site Referencing Information

Name of Site Former Northam Burrows Landfill and Waste Recycling Centre

Address of Site Northam Burrows Country Park,

Burrows Lane,

Northam,

Devon,

EX39 1NQ

Size of Site Approximately 19 Hectares (190,000m2)

NGR 244810, 131420

Site Ownership Northam Burrows is owned by Torridge District Council (TDC),however, Devon County Council (DCC) retain liability for somesections of the disused landfill site.

Site Occupation Common Land, Disused landfill

Proposed Site Use Common Land

2.2 Site Setting and Surrounding Environment

Table 2.2: Site Setting and Surrounding Environment

Site Access The site is accessed from Burrows Lane over Appledore Bridge,down the former landfill / waste recycling centre access road. Apublic car park is located at the end of the track.

Site Boundaries The outer edges of the former landfill are marked more bydistinct changes in the surface flora than anything else. It isnoted that the western boundary roughly follows the area markedby white stones as the riding area.

The landfilled area itself lies within Northam Burrows CountryPark and is within an Area of Outstanding Natural Beauty(AONB). The area occupied by the landfill forms part of theNorth Devon Heritage Coast and is surrounded by Skern Site ofSpecial Scientific Interest (SSSI). The Burrows forms an integralpart of the newly designated United Nations Biosphere Reserve.

Ground Cover The landfill site is low lying, within a well established sand-dunesystem.

Site Topography &Elevation

The site is undulating in nature with general elevations ofbetween 5 meters above ordnance datum (mAOD) near thenorthern boundary to 10mAOD near the area of the former CivicAmenity (CA) Site



Table 2.2: Site Setting and Surrounding Environment

On-Site Plant &Equipment

None

Development to theNorth

The development to the north of the site is Northam CountryPark and the South West Coast Path. Beyond this is the estuaryof the Rivers Taw and Torridge.

Development to theEast

The development to the east of the site is the South West CoastPath and Skern mud flats. Beyond this is the estuary of theRivers Taw and Torridge. Appledore is located 1.5km to thesoutheast.

Development to theSouth

The development to the south of the site is Northam CountryPark, the South West Coast Path and the Royal North DevonGolf Club.

Development to theWest

The development to the west of the site is Northam CountryPark, the Royal North Devon Golf Club and the South WestCoast Path. Beyond this is the Bay of Bideford.

2.3 Historical Development & Potentially Contaminative Land Uses

2.3.1 The historical development of the site and its surrounding areas was evaluatedfollowing the inspection of a number of Ordnance Survey historical maps included inthe Envirocheck® Report (April 2008).

2.3.2 The maps are included in Appendix A of this report. The information obtained from areview of the historical maps, is summarised in Table 2.3:

Table 2.3: Historical Development

Dates Relevant Historical Information

1888

Scale 1:2,500

The site is located in Grey Sand Lake. Grey Sand Hill is located adjacentto the north eastern site boundary. There are patches of rough pastureand sand in the area. A track runs in a southeast-northwest direction tothe west of the site.

1890-1891

Scale 1:10,560

The site has remained the same. The track to the west of the site linksBideford and Appledore lifeboat house to the main roads to the south.Skern mud is located to the east of the site. The estuary of the Rivers Tawand Torridge can be seen to the north and east of the site. The low andhigh water marks are labelled on the map indicating that a large areaincluding the site would be under water at high tide but exposed at lowtide. It is possible that Grey Sand Lake is still under water at low tide.

A number of sand pits are located approximately 750m to the southwestof the site along with a Golf House. A small gas works is present justoutside Watertown 1km to the southeast of the site. Pebble Ridge runsalong the high water mark to the west of the site.

1904

Scale 1:2,500

The high water mark appears to have shifted to the east and the site isnow above the tide line, however, there is a small inlet between the siteand Grey Sand Hill that is still below the high water mark.





1905-1906

Scale 1:10,560

The site and the surrounding area have remained largely unchanged. TheGolf House is now labelled as a Links Course.

1932

Scale 1:2,500

The site is in an area of open ground with areas of rough pastureapproximately 100m to the west and areas of gravel located in thesouthern part of the site. Grey Sand Lake is now shown to be a small inletof high tide water in the eastern part of the site adjacent to Grey Sand Hill.

1932

Scale 1:10,560

The site and the surrounding area have remained largely unchanged. Thetrack leading to the lifeboat house is no longer marked.

1938

Scale 1:10,560

The site and the surrounding area have remained largely unchanged.

1961

Scale 1:2,500

The site is now shown to be in an area of marsh land called Grey SandLake. There are a number of drains marked in the area.

1963

Scale 1:10,560

The site and the surrounding area have remained largely unchanged. Atrack is now marked running from Appledore Bridge, southwest of Skern(muds and sands) leading up towards the southern part of the site. Anumber of drains appear to drain a large area to the south of the site.These drains lead into The Pill stream. A garage is now located in thearea where the gas works used to be approximately 1km to the southeastof the site.

1971

Scale 1:10,560


1982

Scale 1:10,000


1986

Scale 1:10,000


1993

Scale 1:2,500

The site layout resembles that of the present day. The site has beenlabelled as a Recycling Centre and a landfill site. There is a pond locatedadjacent to the southwest of the landfill site. A track runs in a north-southdirection up to the eastern side of the landfill site. Salt marshes aremarked to the southeast of the site. Areas of rough pasture are locatedapproximately 50-100m to the southwest and west of the site. Adjacent tothe north of the site are sand dunes.

1963-1994

Scale 1:10,000


1994

Scale 1:2,500


1999

Scale 1:10,000






2007

Scale 1:10,000


2.4 Site Reconnaissance

2.4.1 A site reconnaissance around the perimeter of the site and surrounding area wasundertaken by representatives from PB, DCC and Torridge District Council (TDC) on27 May 2008. At the time of the visit, weather conditions were cloudy.

2.4.2 During the visit it was noted that sheep were grazing in the area of the depositedwastes. Some limited waste was visible around the top of the elevated area in thenorth of the site. It appeared as if these areas had been eroded by sheep.

2.4.3 The ground was dry underfoot with some limited standing water present across thesmall lake to the northeast of the site. At the time of this visit the areas of standingwater did not appear to be impacted by visible leachate and no oily sheen or stainingwas visible.

2.4.4 Along the banking in the southeast of the site a large area of grass was noted to havedied back. It is understood from conversations with TDC that the area of grass hasnever taken properly. The area of die back is understood to have been extendingyear on year.

2.4.5 One of the current boreholes (believed to be NBBH2) monitored at the site waslocated and opened during the visit. Groundwater levels were approximately 2mBGLin the borehole.

2.4.6 The outfall at the southern end of the site that discharges into the Skern was dry atthe time of the visit but a small area of iron (Fe) staining was noted around andextending from the discharge point.

2.5 Consultation with former employees

2.5.1 During PB’s site visits consultation was undertaken with a former Northam BurrowsRanger and Landfill Operator.

2.5.2 Discussions with the Former Northam Burrows Ranger suggested that someuncontrolled tipping / night tipping of hazardous materials may have occurred at thesite. During this meeting the boundary and phasing of the tipping inferred by PB fromthe records already obtained was confirmed including the area of the ‘Tip Road’,running from Appledore Bridge across the Skern, is constructed at least in part onfoundations of refuse. Further historical plans and aerial photographs were alsoprovided and these are discussed in more detail in the relevant sections.

2.5.3 Discussions with the former Landfill Operator confirmed that general domestic andtrade wastes were frequently fly-tipped overnight at the site gate but claims that theseincluded hazardous wastes were refuted. The former Landfill Operator maintainedthat the waste received and disposed of in the site was that permitted by the wastemanagement license.



2.6 Consultation with Authorities

2.6.1 Information was supplied by DCC on the nature and volume of material tipped. Asummary of the information is provided below:

Notice: proposed refuse disposal tip: Northam Burrows, Northam, 1975:

2.6.2 The controlled wastes to be deposited include household waste, industrial waste andcommercial waste as defined in the Control of Pollution Act 1974.

Report for the Northam Burrows Advisory Committee, Northam Burrows WasteDisposal Tip, 25 March 1977

2.6.3 An investigation into the amount of material being brought to the existing tip identifiedthe approximate weekly average was:

75 loads of refuse

60 loads of trade

50 loads of inert

Communication between DCC Waste Disposal Authority (WDA) and CountyEngineering Planning Department, 1993.

2.6.4 In January 1993, evidence was identified of the sea/estuary encroaching behind thepebble ridge into the edge of the oldest tipping zones around Grey Sand Hill. A siteinvestigation was commissioned by the WDA to ascertain the nature of damage. TheCounty Engineering Planning Department was asked to consider the situation,geology and environment of the site and the adjacent estuary and to consider whetherthe circumstances are likely to lead to any additional or further erosion.

2.6.5 Communication on the 2 March 1993 identified that the ground survey wouldcommence on the 9 and 10 March 1993, along a 350m stretch of coastline usingauger boring exploratory holes. Communication dated 7 April 1993 informed the WDAthat:

due to the nature of the ground adjacent to the pebble ridge at the Burrows it wasnot possible to obtain useful information using boreholes (pebbles in the subsoilcaused refusal at shallow depths and no waste was found).

The works were subsequently changed to trial pitting, which commenced on 23March 1993, within areas of exposed waste and representative locations eastand west along the coast.

The exposed waste was found to be a thin layer of polythene wrappers extendingnot more than 500mm inland from the exposed edges.

It was suggested that the tip was fenced along this line and that windblownmaterials may have become trapped and subsequently covered naturally withsand or when the area was later landscaped.

This thin line of material was excavated and disposed of to a tip off site.



Letter from the County Waste Management Officer RE: Information on NorthamBurrows Landfill Site (23 July 1997).

2.6.6 This letter summarises events and a number of reports that have been carried out atthe site. Below is a summary of this letter, a full copy of the letter can be found inAppendix C:

Tipping started in the 1940s. At the time, the importance of the site for wildlifeand recreation would not have been recognised in the way it is today.

In 1984 planning permission was granted for the extension to the existing tip,including the submission of a restoration scheme and its implementation.

Landfill of household waste at Northam Burrows ceased upon expiry of theplanning permission in July 1994.

In June 1994 the temporary continued use of the Civic Amenity/Recycling Centre(CARC) for a further 2 years was granted.

The site licence dated 5 September 1977 specified that 28,000 tonnes of waste(household, commercial and industrial waste) per annum were to be tipped.

From modification to the site Licence in 1991, it was estimated the 60,000 tonnesof waste per annum would be received at this site.

The following approved difficult wastes, not uncommon in landfills, wereconsidered suitable for disposal in controlled quantities with the agreement of theSouth West Water Authority (SWWA):-

Alkalis

Non-toxic Metal Components

Inorganic Components

Other Inorganic Materials

Organic Compounds

Polymeric Materials and Precursors

Fuel, Oils and Greases

Fine Chemicals and Biocides

Filter materials, Treatment Sludge and Contaminated Rubbish

Miscellaneous Wastes, and

Animal and Food Wastes.

The site is underlain by the thin belt of ‘Storm Gravel Beach Deposits’ borderingthe Taw/Torridge estuary and to the south of this narrow belt of ‘present dayBlown Sand’.

The Blown Sand will be permeable but as it is not in contact with any aquifer,there is not a risk of aquifer pollution.

Any leachate generated would be subject to extremely high dilution factors andas such environmental pollution impact is considered minimal.



An extension to the existing refuse tip, dated 1979, stated that on termination offilling or as soon as practicable thereafter, completed areas of the site should belandscaped and reinstated.

Samples taken from the indigenous gravely soil which was set aside on the sitebefore waste disposal started were analysed as follows:-

Described as a very gravely fine sand with some silty content, of light olivebrown colour and a pH of 8.1,

the particle size content was:-

Sand 67%

Gravel 25%

Silt 8%

Inspection of 10/12/96 by Regulation Inspector

2.6.7 The inspection was undertaken in response to the letter of notification of a pollutionincident at the Northam Burrows Landfill Site from the County Environment Director tothe Waste Control Officer dated 6 January 1997.

2.6.8 The letter refers to a number of minor ocherous breakouts along the tarmac road eastof the Civic Amenity (CA) facility. The letter summarises two letter reports by BabtieEnvironmental (Site Inspection Visit Friday 13 December 1996 letter report by BabtieEnvironmental dated 9 January 1997 Ref: BEN015116/SJJ/SED/6,530,346) andNortham Burrows Landfill Site letter, dated 16 December 1996 Ref:S96/DCC\Northam\TPE-01.doc). The summary indicates that the oxidising ochreleaching from the soils is a natural occurrence that could be expected with themajority of soils available in a characteristically ‘Red Devon’, and that the occurrenceis insufficient to migrate from the site and represents no environmental threat.

Northam Burrows redundant Landfill Site letter dated 24 August 2000, from DevonCounty Council to the Director of Planning & Technical Services.

2.6.9 This letter details that Northam Burrows lies within DCC ‘C’ category: which are siteswhich have been restored but there remains some element of works yet to beundertaken. In the case of Northam Burrows this work was the removal of buildingsand cabins in the vicinity of the CA compound including removal and restoration of theCA area itself and that no further restoration works to the landfill site itself areproposed.

Application to surrender a Recycling Centre Site Licence – 2003

2.6.10 In 2003 an application was made to surrender the waste management licence atNortham Burrows. Information supplied in the licence identifies that the NorthamBurrows CA site operated between 1974 and 2002. It was established on the Landfillsite, which operated from 1938 to 1994. The site accepted general household bulkywaste, garden waste and some special wastes. It did not accept household refuse ofthe type normally collected through dustbin collections.

2.6.11 The site licence permitted use of tarmac or concrete for the surface of the site.However, in practice concrete and impermeable concrete was used throughout thesite.



2.6.12 Surface water from the green waste area and in the vicinity of the waste oil containerwas drained to a sealed tank. Drainage from non waste handling areas was drainedvia an interceptor to an authorised discharge point.

2.6.13 Wastes were brought into the site by members of the public. The site operator packedthe non recyclable elements of the waste into 35/40 yard roll-on-off containers.Recyclable materials were either placed in designated bays or in purpose built banks.All waste deposits were supervised by site personnel who checked to ensure nounauthorised wastes were delivered.

2.6.14 Waste oil was collected in a separate container, which was located in a separatebunded compound. Household chemicals delivered to the site were placed in a lockedcontainer accessible only to specifically trained personnel. Vehicle batteries and gascylinders were stored in a secure ventilated cage.

2.6.15 A contamination risk assessment associated with the CA site was carried outidentifying a number of pollution risks, targets, preventative measures and verificationthat no contamination was caused by the CA.

2.6.16 Full records of waste being handled on site between 1995 to the closure in 2002 wereincluded in the application. A summary of the total amount of material recycled fromthis site is given below:

1995 – 1996 – 1792.44 tonnes

1996 – 1997 – 1949.54 tonnes

1997 – 1998 – 1953.86 tonnes

1998 – 1999 – 2273.85 tonnes

1999 – 2000 – 2452.32 tonnes

2000 – 2001 – 2414.84 tonnes

2001 – 2002 – 2310.00 tonnes

2002 – 2003 – 1787.22 tonnes

2.6.17 The general type of material being recycled at the centre was iron (heavy and light),soil, paper, glass and compost.

2.6.18 Full details of the application are presented in Appendix C

Letter report – Reinstatement of Civic Amenity & Recycling Centre – NorthamBurrows, dated 9 May 2003.

2.6.19 This letter report has identified that the concrete used at the CA site was ‘standard’reinforced concrete slab without a membrane which is porous to petrol and phenols,etc. The report has stated that any liquids that may have seeped through the concretewould have left surface staining on the soil directly under the concrete and that a sitevisit carried out by the consultant identified that there was no visual evidence ofsurface staining.

2.6.20 The geology identified within this report is:



Underlying soils – predominantly sandy in nature (mainly wind blown)

Estuarine alluvium

2.6.21 This report states that any water-soluble contaminants would have been quicklydispersed.

2.6.22 This report has reviewed 6 soil samples taken at the site (as part of the application tosurrender the waste management licence). PB note that the results were screenedagainst the Inter Departmental Committee for the Redevelopment of ContaminatedLand (ICRCL) trigger levels (these figures were not given in the report). The reportstated that the ICRCL trigger levels had been withdrawn prior to the report beingwritten and the newly issued CLEA model was not “straight forward” and that SoilGuidance Values (SGV) value had not been released and therefore were not used.

2.6.23 The report concluded that:

The CA site would not be classified as contaminated under the ContaminatedLand Regulations.

No additional monitoring or sampling is justified.

The information provided should be sufficient to make an application to surrenderthe operating licence.

2.6.24 A summary of the lab data is given in Table 2.4.

Table 2.4: Summary of samples for the application to surrender the operating licence.

Units Sample ID Depth (m) Max Value

Total PetroleumHydrocarbons (TPH)C8-40 by GC-EZ Flash

mg/kg 0355462 0.1 868

Calcium mg/kg 0355464 & 0355465 0.3 & 0.1 >32000

Copper (Cu) mg/kg 0355465 0.1 75

Iron (Fe) mg/kg 0355465 0.1 >32000

Magnesium (Mg) mg/kg 0355464 0.3 7399

Manganese (Mn) mg/kg 0355465 0.1 1642

Nickel (Ni) mg/kg 0355463 & 0355464 0.1 & 0.3 28

Lead (Pb) mg/kg 0355462 0.1 77

Zinc (Zn) mg/kg 0355461 0.1 250

Ammoniacal Nitrogen asNH4-N mg/kg 0355461 0.1 24.1

Potassium (K) mg/kg 0355464 0.3 4158

Polycyclic AromaticHydrocarbon (PAH)Tot by GC-EZ Flash

mg/kg 0355465 0.1 104



Groundwater and Ground Gas Data

2.6.25 Four groundwater boreholes have been monitored by DDC at Northam Burrows since1996. The following data has been reviewed below: pH, Biological Oxygen Demand(BOD), Chemical Oxygen Demand (COD), Conductivity, Chloride (Cl-), Nitrite andNitrate. Where applicable this data has been reviewed against relevant EnvironmentalQuality Standards (EQS) or Drinking Water Standards (DWS). A summary of the datahas been presented in Appendix C.

2.6.26 The EQS values for pH are between 6 and 8.5. The analytical results suggest that themajority of the results are within this range, however, a few samples have been at apH of 8.5 and one sample measured a pH of 8.9 in NBBH1 on 11 October 2001.Since July 2004, the results are all within the EQS range. pH concentrations found inthe lakes adjacent to the landfill were generally found to be higher with a number ofexceedances above a pH of 8.5. The highest concentration recorded was 9.4 on 15March 2007. Typically leachate from aged domestic waste would contain a pH ofaround 7.5 (DOE 1993).

2.6.27 There are currently no EQS and DWS values for BOD and COD. A number of peaksin the concentrations of BOD and COD are noted. The peaks in concentration for bothCOD and BOD are commonly found in the same monitoring round. The highestconcentration of BOD and COD were generally found in NBBH2.

2.6.28 The data for NBBH1 indicates the highest elevation of BOD is 100 mg/l taken on 13September 2007 and the highest concentration of COD is 555 mg/l taken on 15November 2001.

2.6.29 The data for NBBH2 indicates the highest elevation of BOD is 120 mg/l taken on 13September 2001 and the highest concentration of COD is 1056 mg/l taken on 16August 1996.

2.6.30 The data for NBBH3 indicates the highest elevation of BOD is 50 mg/l taken on 10August 2000 and the highest concentration of COD is 271 mg/l taken on 11 October2001.

2.6.31 The data for NBBH4 indicates the highest elevation of BOD is 60 mg/l taken on 15September 2005 and the highest concentration of COD is 368 mg/l taken on 13February 2005.

2.6.32 The data for NBOF indicates the highest elevation of BOD is 120 mg/l and the highestconcentration of COD is 382 mg/l taken on 15 May 1996.

2.6.33 Typically leachate from aged domestic waste would contain BOD of around 260mg/land COD of around 1160mg/l (DOE 1993).

2.6.34 Chloride concentrations were identified to be potentially indicative of saline intrusionin the majority of samples taken. PB note that elevated Chloride may also beassociated with landfill. The highest concentration of Chloride was identified inNBBH2 at a concentration of 15838 mg/l on 16 October 1997. There is no EQS andDWS data for Chloride- in a marine environment due to the presence of highconcentrations of naturally occurring Chloride. Concentrations of Chloride found in theNortham Burrows Lake (NBL) were also high. Concentrations in the Northam BurrowsSmall Lake (NBSL) were found to be much lower.

2.6.35 The highest reading identified for conductivity was 16200 µS/cm taken on the 10September 1998. It is expected that conductivity is increased in brackish water.



2.6.36 Concentrations of nitrite were elevated above the DWS of 10µg/1 in a number ofsamples. The highest concentration was found to be in NBBH1 at 0.352 mg/l on 13June 2002. Concentrations of nitrite were also found to be elevated in NBBH2 andNBBH4 on the same day. Concentrations of nitrite were found to be elevated abovethe DWS value in NBBH4 on the 16 August 2007. Concentrations of nitrite in thelakes were generally found to be below the DWS value. Typically leachate from ageddomestic waste would contain nitrate of around 1mg/l (DOE 1993)

2.6.37 The DWS value for nitrate is 50 mg/l. All samples were found to be below this value.The highest concentration of nitrate was found to be in NBBH1 at a concentration of37.4 mg/l on 14 February 2002. Concentrations of nitrate in the lakes were generallyfound to be below the DWS value.

2.6.38 Concentrations of ground gas were also monitored from 2003 to present day. The EAhas published guidance that recommends appropriate environmental benchmarks forthe sub-surface migration of landfill gas offsite. The published benchmarks for carbondioxide (CO2) and methane (CH4) concentrations are 1.5% v/v and 1.0% v/v abovebackground, respectively. The monitoring data has identified that there were elevatedconcentration of methane and carbon dioxide in both monitoring wells NBG1 andNBG2 when compared to the EA benchmarks. However, over the last 2-3 years theseconcentrations have decreased to 0% v/v. Concentrations of oxygen were initially lowbut have increased as the concentrations of methane and carbon dioxide havedecreased. The highest concentration of methane was 72% on 12 October 2003 andthe highest concentration of carbon dioxide was 48% on 21 February 2003.

2.7 Previously Prepared Reports

2.7.1 A number of reports have been written concerning the Northam Burrows Landfill site.Below is a summary of the reports that are relevant to this investigation.

Northam Burrows Landfill Site Remediation Statement: July 1995, BabtieEnvironmental

2.7.2 In April 1995 Babtie Environmental was instructed by Devon Waste Disposal Authority(DWDA) to prepare a Remediation Statement for Northam Burrows Landfill Site. Thestatement included a site walk-over and a review of information supplied by DevonWaste Regulation Authority (DWRA).

2.7.3 The remediation statement was only concerned with the recently closed tipping areaand identified two potential options:

Option One – Clay Cap, and

Option Two – Permeable Cap.

2.7.4 Option two was identified as their preferred option and would entail using clean, inertmaterial to cover the landfill and the placing of topsoil and sandy topsoil to form asand-dune system compatible with this locality.

2.7.5 A review of the site details were presented in Appendix 1 of the Babtie report. Asummary of Appendix 1 as reported is detailed below:

The site is underlain by a thin belt of ‘Storm Gravel Beach Deposits’ and ‘presentday Blown Sand’.



The disposal site is located on an alluvial spit.

The wind blown sand will be permeable but as it is not in contact with anyaquifer, there is no risk of aquifer pollution.

Tipping has occurred at Northam Burrows landfill site since the 1940’s.

In 1984 planning permission was granted for the extension to the existing tip.

Landfill of household waste at Northam Burrow ceased upon expiry of theplanning permission in July 1994.

June 1994 the temporary continued use of the CARC for a further 2 years wasconsidered.

The site licence dated September 1977 specified that 28,000 tonnes of waste perannum were to be tipped during the operating life of the site.

Modification to the site licence in 1991 estimated that 60,000 tonnes of waste perannum would be received at the site.

The site disposal licence 1977 allowed for the disposal of household, commercialand industrial waste.

The following approved difficult wastes were considered suitable for disposal incontrolled quantities with the agreement of the SWWA:-

Alkalis

Non-toxic Metal Components

Inorganic Components

Other Inorganic Materials

Organic Compounds

Polymeric Materials and Precursors

Fuel, Oils and Greases

Fine Chemicals and Biocides

Filter materials, Treatment Sludge and Contaminated Rubbish

Miscellaneous Wastes, and

Animal and Food Wastes

The Babtie report reviewed available correspondence and identified the followingproblems associated with the site in the past:

Re-emergences of the waste in completed areas

Bare patches due to die back vegetation, reportedly caused by localised poordrainage

Fly tipping of rubbish, especially near the waste disposal facility at the CA site

Poor conditions of the site access road with many potholes



Litter being blown from the site into the surrounding Country Park

Damaged fencing

Incorrect storage of batteries at the CA site; and

Pooling of water within parts of the CA site.

2.7.6 Babtie also identified a number of concerns raised by consultees. These are listedbelow:

Correspondence from English Nature (now know as Natural England (NE))during June 1994 states that they do not consider Northam Burrows as a suitablelocation for a CA site:

Its presence has an adverse impact on wildlife due to disturbance from traffic;and

An ecological imbalance is also caused due to the high number ofscavenging birds attracted to the site.

English Nature also expressed concern (December 1994) that a reinstatementperiod covering 2 or 3 years would cause unacceptable disturbance to breedingand wintering birds.

The Devon Birdwatching and Preservation Society objected to the continued useof the area as a CA site because of its high status in terms of conservation value,landscape designations and remoteness from towns.

Graziers in the area have in the past been concerned over the loss of Burrowsgrazing land to sea encroachment.

It was suggested by Northam Burrows Advisory Committee on 19 December1994 that consideration should not be given to infilling the 8th green with inertwaste. (The green is leased by the Royal North Devon Golf Club and is ownedby TDC).

2.7.7 Babtie suggest that at the time of the report there was no evidence to suggest thepresence of leachate. It also noted that four boreholes immediately to the south andwest of the site were used for water quality monitoring. Surface waters were alsosampled on a regular basis (two seasonal lakes and a surface water drainage outfall).Monitoring data was made available as Appendix 3 of the Babtie report.

2.7.8 The report identified that the site drains freely into the Torridge Estuary and as suchany leachate being produced is likely to drain into the estuary and be diluted anddispersed.

2.7.9 The Babtie report presented data taken from a number of locations including the fourboreholes on site (NBBH1, NBBH2, NBBH3 and NBBH4). The data was taken from aperiod between 1991 and 1995. This data has been reviewed below and comparedagainst relevant EQS values.



Table 2.5: Concentrations and accidences of contaminants presented in the BabtieReport

Location Contaminants above EQSValues*

(All values in mg/l)

HighestConc. ofBOD (mg/l)

HighestConc. ofCOD (mg/l)

HighestConc. ofTOC (mg/l)

NBLSW pH (8.6, 9.0, 8.8),

Chloride (Cl-) (14 samples Max.24,500),

Conductivity (10 Samples Max.25,800),

Zinc (Zn) (0.041),

Cadmium (Cd) (0.0075).

91 1328 22.4

NBCON Chloride- (510). 3 39 -

NBBH1 Chloride- (10 samples Max.4,860),

Conductivity (7 samples Max.10,030),

Copper (Cu) (0.026),

Zinc (0.27, 0.13, 0.17),

Tin (Sn) (0.05),

Lead (0.26, 0.097, 0.078, 0.011),

Chromium (Cr) (0.031),

Fe (49, 37, 16.1),

Nickel (0.059, 0.023).

25 363 13.5

NBBH2 Chloride- (11 Samples Max.6880),

Conductivity (10 samples Max.16,100),

Lead (0.018),

Fe (1.36, 1.72),

Nickel (0.017).

46 365 35

NBBH3 Chloride- (450),

Zinc (0.011, 280),

Fe (1.12, 1.11).

8 57 6.5

NBBH4 Chloride- (5 Samples max. 1776),

Conductivity (5 Samples max.5070),

13 129 18.4



Table 2.5: Concentrations and accidences of contaminants presented in the BabtieReport

Location Contaminants above EQSValues*

(All values in mg/l)

HighestConc. ofBOD (mg/l)

HighestConc. ofCOD (mg/l)

HighestConc. ofTOC (mg/l)

Nitrite (0.19),

Zinc (0.17, 0.1),

Lead (0.038),

Fe (4.78, 7.36, 13.7).

NBSW pH (8.9, 8.6, 8.6),

Chloride- (15 Samples max.5180),

Conductivity (2510, 3020),

Copper (0.021),

Zinc (0.048),

Lead (0.013, 0.036),

Fe (11.1, 25.1, 2.11).

<69 542 103

TOC – Total Organic Carbon*EQS Values: pH acceptable between 6.0 and 8.5, Chloride- 250mg/l, conductivity 2500uS/cm, Zinc0.04mg/l, Cadmium 0.0025mg/l, Chromium 0.005mg/l, Copper 0.005mg/l, Sn 0.01mg/l, Lead 0.01 mg/l, Fe1mg/l, Nickel 0.015mg/l, nitrite 0.1mg/l.

2.7.10 Babtie’s review of the site inspection report for Waste Regulations (7 December 1993)identified that there was no evidence of landfill gas at the site.

2.7.11 A review of the gas monitoring data supplied as Appendix 4 of the Babtie reportindicated that monitoring was carried out on a weekly basis between 5 November1991 and 11 March 1993. The maximum concentration of methane recorded was0.0025% at location NBRD7 8G on 25 January 1993. All carbon dioxideconcentrations were below detection levels.

Other Reports

2.7.12 A number of reports have been made available to PB detailing the issues concerningcoastal erosion at Northam Burrows. A more detailed review of the issues concerningcoastal erosion is understood to be being undertaken by other consultants and will bereported separately. The reports made available on this subject are listed below:

Coastal Erosion at Westward Ho! N. Devon, Report to the Coast ProtectionCommittee (Special) of the Devon County Council by A. Stuart & R.J.S.Hookway, 1954;

Pebbleridge, Westward Ho! Coast Protection Act 1949, by Sir William Halcrowand Partners for Torridge District Council, January 1980;



Initial comments on the proposal to extend the area of rubbish tipping at NorthamBurrows Country Park, May 1991, Devon Birdwatching and Preservation Society.

Estuaries Management Plans Coastal Processes and Conservation Taw-Torridge Estuary: Recommendations; report prepared by the Coastal ResearchGroup, Department of Geography and Topographic Science on behalf of EnglishNature under contract no. F70-01-90. July 1993

Coastal Management and Coastal Erosion Westward Ho! and north Devon PartOne 1850 - 1993, by Peter Keene, Thematic Trails, The Geography Unit, OxfordBrooks University, Oxford OX3 0BP, 1995, ISBN 0 948444 23 1.

Coastal Management and Coastal Erosion Westward Ho! and north Devon PartTwo 1993 - 1995, by Peter Keene, Thematic Trails, The Geography Unit, OxfordBrooks University, Oxford OX3 0BP, 1995, ISBN 0 948444 23 1.

The Taw-Torridge Estuary: Geomorphology and Management, Report to Taw-Torridge Estuary Officers Group, By Professor J Pethick, February 2007.

2.8 Aerial Photographs

2.8.1 A PB Engineer visited the National Monument Record to view a number of aerialphotographs of the Northam Burrows. The photos ranged in date from the early1940’s through to the mid 1990s.

2.8.2 The earliest photo shows the site in 1945 where the construction of the road is in itsearly stages with the tip face approximately 100-150m from the entrance bridge. Thephotos from 1946 clearly show that the tip face has advanced further.

2.8.3 By the 1957 photo, the tipping face and the advancement of the tip road constructionare clearly visible. The photo indicates that material has been tipped up to where thebend in the current tip road starts. However, the main tipping face can be clearly seenfurther back. By 1959, the tip face can clearly be seen where the bend in the currentaccess road starts.

2.8.4 By an August 1960 photo the tip face can be seen advancing round the bend towardswhat is now known as Grey Sands Lake. The 1967 photos show the tip face past thecurrent Grey Sands Lake and advancing towards the main area of the landfill.

2.8.5 In a photograph from 1989, the tip had progressed into the final phase of tipping.Clear cells have been marked out for tipping. By a 1992 photo some of these cellshave been used for tipping but the work is still continuing.

2.8.6 A number of colour photos that were made available by DCC for PB to review,indicate that tipping occurred at a number of places within the last phase area. Thereis an indication that this may have been due to adverse weather conditions and thesite flooding.

2.9 Anecdotal Information

2.9.1 Anecdotal information was supplied to PB by DCC, including a number of email andletters raising issues associated with the Northam Burrows Land fill Site. This sectionincludes a review of this information.



2.9.2 Letter from the County Engineer and Planning Officer to the Secretary of the Collegebranch of the Devon Bird Watching and Preservation Society, Ref: MFW.P/DS/TR/2Torridge District: Northam Proposal to provide Civic Amenity and Recycling Centre(CARC) etc at Northam Burrows waste tip, Northam Burrows (Application Reference01/41/1336/93). 20 May 1993. The letter advises that the above application had beenformally withdrawn and that an Officers’ working party is being set up to look atalternative options for CARC provision to serve the Bideford/ Northam/ Appledore/Westward Ho! area upon closure of the Northam Burrows Tip.

2.9.3 Letter from the Chairman of Taw and Torridge Estuary Forum to the CountyEnvironment Director, Erosion of Refuse Tip on Northam Burrows dated 2 June 1995.The letter is concerned primarily with the potential effects of erosion and inundation ofthe landfill site. It identifies some key areas of weakness in the pebble ridge and thatwithin these areas the erosion is already reaching the landfill and that waste is beingexposed. This letter also indicated that a Toxic Waste Licence was issued; however, itwas unable to find any records of what toxic materials were dumped in this area butreferred to anecdotal reports suggesting pharmaceutical and hospital waste andasbestos.

2.9.4 Letter responding to the Chairman of Taw and Torridge Estuary Forum 2 June 1993letter from the County Environment Director, dated 16 June 1995. The CountyEnvironment Director informs the Chairman that tipping of domestic refuse atNortham Burrows had ceased, and that the County Council as Waste DisposalAuthority is responsible for restoration of the site. The letter goes on to explain that aninvestigation by trial pits clarified that the exposure of waste along the north-east sideof the former tip site was predominantly windblown waste, mainly polythene, whichhad been trapped against the former fencing, and subsequently cleared. The trial pitsconfirmed that the face of the former tip site was some distance inland at this point.This letter also highlighted that since 1974 the site accepted domestic refuse andsimilar trade/industrial waste and there is no evidence of toxic materials.

2.9.5 Letter from the County Environment Director to the Chairman of Taw and TorridgeEstuary Forum dated 12 June 2002. This letter indicates that on the 24 April 2002 theCounty Council’s Development Control Committee resolved that planning permissionbe granted for the retention of the CARC at Northam Burrows until 31 December2002, with the removal of all structures from the site and the implementation of arestoration scheme by 30 June 2003.

2.9.6 This letter also informed he Chairman of Taw and Torridge Estuary Forum that theaccess road to the Northam Burrows CARC did not form part of the application and isnot subject to any condition of that planning permission which would determine itsfuture use, i.e. ‘there is no planning requirement that it should be closed or breachedwhen the use of CARC ceases’.

2.9.7 With respect to concerns over the future of Northam Burrows – English Natures rolesand responsibilities. English Natures letter for the Public meeting 12 July 2002 states:

“English Nature are the statuary advisors to the government on matters of natureconservation. One of our duties is to advise anyone who owns or manages a Site ofSpecial Scientific Interest (SSSI) how to manage that site so that the plants, animalsand other features are protected from damage or destruction.

We are not the decision maker for matters concerning coastal flood defence, landfillsites or the CARC. The future strategy for coastal defence around Appledore andWestward Ho! is a matter for the District Council and Department for Environment,Food and Rural Affairs (DEFRA) to decide upon. The future of the landfill site is one



which the District Council, the Environment Agency and Devon County Council mustagree upon.

We cannot enforce or undertake removal of the landfill or the ‘tip road’, neither do wemake decisions regarding the manner in which Appledore and Westward Ho! areprotected from the sea. English Nature’s role is to ensure that the nature conservationvalue of the site is maintained or where appropriate, enhanced.”

2.9.8 Anecdotal information provided in an email from the County Waste ManagementOfficer DCC to the Service Manager and United Nations Educational, Scientific andCultural Organisation (UNESCO) Biosphere Co-ordinator DCC, on 31 May 2007;Subject: Taw Torridge Estuary – The Northam Burrows Redundant Landfill Site,provided detailed information on the site disposal license as outlined previously andgoes on to state:

“The predominance of material would have been household rubbish with smallerquantities of commercial and industrial waste. Anecdotal evidence suggests clinicalwastes and some industrial chemical were landfilled at Northam. There are variousgrades of clinical waste (for example, it is still possible to landfill low grades of clinicalwaste such as incontinent pads). I do not think body parts would have been permitted.On the chemicals front, if such containers had been brought in, I suspect they wouldhave long since corroded and the contents leaked away……… Alternatively, thecontainers would most likely have been crushed by the site compactor vehicles andthe drums fractured with the same result to their contents. Given the relative lack ofindustry in the Torridge area, the only likely source of such chemicals might havebeen the Appledore shipyard.”

2.9.9 Anecdotal information provided in an email from the County Waste ManagementOfficer DCC to the Chairman of the Taw Torridge Estuary Forum, from 2007; Subject:Northam Burrows Landfill for the attention of the Chairman Taw Torridge EstuaryForum provided detailed information on the site disposal license as outlinedpreviously and goes on to state:

The licence is typical of those issued at the time for sites which were designed on thedilute and disperse basis. The concept being that nature would deal with the wasteand render it benign over a period of between 30 and 100 years. There is goodevidence that this does work although the down side is that gases given off arevented to the atmosphere and leachate gets diluted by rain water and in this particularcase by sea water.”

2.9.10 A letter from the Campaign to Protect Rural England (CPRE) Torridge District Group,to the Chief Executive Officer TDC, dated 18 May 2007 outlines there concerns forNortham Burrows and states:

“We understand that the tip site contains “inert” domestic refuse, clinical waste fromhospitals and surgeries, and asbestos from Yelland Power Station.”

2.9.11 Letter from the Cornwall, Devon & Isles of Scilly Natural England (previously knownas English Nature) Team to Devon County Council Waste Management Section,dated 28 August 2007 regarding Northam Burrows SSSI, Site Investigation ofNortham Burrows Landfill suggests:

“………it is our view that the presence of the tipped material presents a barrier tosustainable coastal management………… Any strategy arising from theseinvestigations must fully take account of wider sustainability issues, as well as directenvironmental risks.



It is our understanding that the ‘Tip Road’, running from Appledore Bridge across theSkern, is constructed at least in part on foundations of refuse. We would stronglyrecommend that the footprint of the road be included within the scope of theinvestigation.”

2.9.12 Letter from Northam Town Council Town Clerk to Devon County Councils WasteManagement Section dated 28 August 2007, regarding the Site Investigation ofNortham Burrows Landfill states:

“…….I was the Deputy Engineer and Surveyor for the Northam Urban District Counciland from 1974 until about the early 80s I acted as the Divisional Surveyor for theCounty Council, who at the time managed the Northam Burrows Site. In 1971 tippingat the Grey Sands had only just commenced. The tip road had, for many years, beenthe tip and when this reached Grey Sands area in about 1969 a dam was constructedon the end of the road across to Grey Sands Point. This dam was constructed ofmaterial excavated in Appledore when the new shipbuilding dock was constructed. Inthe early days tipping was a free for all and this gradually changed as the CountyCouncil took a more controlled use of the site. Early on very little covering materialwas available and very little covering actually done. However, this changed and thecovering material was won on site by excavating into the sand and gravely materialsthat were available.”

2.9.13 An email from the Technical Officer Groundwater and Contaminated Land, EA, to theEA, Subject: “Buried batteries and other exciting stuff “notes:

“I understand that it took waste from Appledore shipyard (from a chap who claimed tohave driven the trucks). There was also supposedly several loads of batteries? Andreports of hospital waste ……….

…….there is a possibility that any leachate has the potential to contaminatesediments surrounding the site potentially acting as a sink of contamination. Somelimited sampling (not UKAS / MCERTS accredited analysis) did not show anyelevated metals compared to other sediments in the skern or on the opposite side ofthe Torridge. However, a selection of bioassay tests did demonstrate a significantaffect on algae from elutes derived from sediments in the main drainage channel fromthe site onto the skern, when compared to other sites in the skern and Torridge.

With regards to water quality monitoring from the installed wells, the location shouldbe designed to identify water quality and likely drainage pathways. Concentrations ofthe former saltmarsh drainage (which can be seen on historic maps / photos may givesome useful indications). I am also aware that some water level data is available frompiezometers installed near the site available from the Burrows Centre (and no doubtprovided by Mr Corin).

…….. Given the unknown history of the site, in addition to the scheduled analysis, Iwould recommend that a general identification Gas Chromatography-MassSpectrometry (GC-MS) screen is requested from the labs with reporting on anydetected peaks.”

2.9.14 To attempt to define the tipping history of the site a review of all anecdotal and otherinformation has been undertaken and the perceived tipping history is described inTable 2.6 below:



Table 2.6: Historical data using Anecdotal Information

Date Activity

1939 - 1969 It is thought that tipping started at Northam Burrows, commencing at thetip road moving towards the Grey Sands Hill area. Material used fortipping has been described as a “free for all”.

1969 It is reported a dam was constructed on the end of the road across toGrey Sands Point. It was thought that the dam was constructed frommaterial excavated in Appledore when the new shipbuilding dock wasconstructed.

1969-1978 Continued tipping within the Grey Sands area.

1974 It is understood that a review of sites for waste disposal was undertakenby Northam Urban District Council- Refuse delivered per annum isreported as; 3015 tons of collected domestic and trade waste and 2000tons of general factory rubbish (Total of 5015 tons); the remainingcapacity estimated at 302,500 cu.yds at this time.

1975 Planning permission granted for the refuse tip (Notification No.1/125/75/41/2, Notice No. DC/23/75). Wastes permitted are described asHousehold wastes, industrial wastes and commercial wastes.

1977 The site licence specified that 28,000 tonnes of waste per annum were tobe tipped.

1978 Application for extension of existing refuse tip over adjacent area to thenorthwest of the site (Notification No. 1/602/78/41/2, Notice No. DC/52/78.

1978-1984 Continued tipping of waste on 1st extended land (area to the northwest ofthe site).

1984 Application for a second extension to the tipping area in the southwestarea of the site, and re-siting of site offices and Civic AmenitiesCompound (Application number illegible please see Appendix C).

1984-1994 Continued tipping of waste on the 2nd extended area in the southwestarea of the site.

1991 It is believed that modifications to the Site Licence (Licence unavailable)estimated 60,000 tonnes of waste per annum would be received at thissite.

1994 Tipping is understood to have stopped

1994-2001 The site was continued to be used for Civic Amenity Compound andRecycling Centre

2001 Transfer of site ownership from Devon County Council to Torridge DistrictCouncil (File No. 281/22 & 22a, Document No. 84)

2001 Planning permission (Ref:TJL/A11700) granted to Devon County Councilby Torridge District Council for a further 5 years of use as a Civic AmenityCompound and Recycling Centre.

2001-2006 The site was continued to be used for Civic Amenity Compound andRecycling Centre, and was closed and the licence surrendered.

2.9.15 The schedule of events described in Table 2.6 have been used to develop a planshowing the identified dates and locations tipping took place (see Figure 2).

section 2 - devon · 2.5.2 discussions with the former northam burrows ranger suggested that some...

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