STIRLING COUNCILTHIS REPORT RELATESTO ITEMON THE AGENDAENVIRONMENTAL QUALITYCOMMITTEETECHNICAL SERVICES7 TH November 2002 NOT EXEMPTLOWER POLMAISE LANDFILL SITE; WASTE MANAGEMENT LICENCEFINANCIAL IMPLICATIONS OF COMPLIANCE1 PURPOSE1.1 To inform the Environmental Quality Committee of the additionalfinancial resources required to operate Lower Polmaise Landfill Sitegiven the modified waste management licence conditions recentlyissued by the Scottish Environment Protection Agency (SEPA).1.2 To seek the support of the Committee with regards to the funding ofthe additional expenditure for the current (2002/2003) and the twofollowing financial years.2 SUMMARY2.1 The revised Conditions will now cover the remaining life and ongoingoperation of the Site up to and including closure.2.2 Following the application made in November 2001 SEPA, on 17 th June2002, issued Stirling Council with a modified Waste ManagementLicence for the operation of the Lower Polmaise Landfill Site. Due tothe delay in receiving the updated licence it was not possible toassess the financial implications at an earlier stage.2.3 The change in conditions was primarily driven by EuropeanLegislation on the management and closure of ‘dilute and disperse’landfill sites such as Lower Polmaise.2.4 The licence conditions have been modified to allow an extension forthe acceptance of wastes to the disposal facility for an additionalmaximum two-year period; until 16 th June 2004.2.5 Further modifications to the original licence have been imposed whichare designed to reduce the impact the landfill operation has on theenvironment in the period prior to closure of the site.2.6 The level of additional expenditure being incurred to protect theCouncil in the ongoing use of Lower Polmaise as a Landfill Site is out-N:\DEMSUPP\NewDecisions\Environmental\Reports\EQ20021107POLMAISEREP367.doc
2with the current resources of the Committee; application is thereforebeing made to the next meeting of the Resources Committee for itsconsideration.2.7 These operational changes will involve committing significantadditional resources, in terms of both revenue and capital, to ensurecompliance with the statutory conditions;Capital; In the region of £2,155,000 over two financial yearsRevenue; £567,000 over three financial years3 RECOMMENDATIONS3.1 That the Environmental Quality Committee supports the application tothe Resources Committee, on 21 st November 2002, for the financing,from balances, of the anticipated additional expenditure of £189,000for the current financial year, 2002-2003.3.2 That the Committee agrees that the anticipated additional expenditureof £283,000 for 2003-2004 and £71,000 for 2004-2005 should beconsidered as part of the Council’s Revenue Budget process for therespective years.3.3 That the Committee approves of the Capital Expenditure of some£2,155,000, required to ensure closure of Lower Polmaise Landfill Sitein compliance with conditions set out by SEPA, being progressed as abid to the Capital programme.3.4 That the Committee receives regular update reports on the progressof matters relating to the ongoing operation and imminent closure andrestoration of the Landfill Site.4 CONSIDERATIONSBackground4.1 The European Union (EU) Landfill Directive is designed to improve theenvironmental quality associated with the operation of landfill sites.4.2 The Directive also seeks to phase out the continued operation of noncontainmentsites such as Lower Polmaise. This is because of thepotential threat to underlying groundwater systems as well as thepotential for substantial gas (methane) emissions and theircontribution to global warming.4.3 As a result of the EU Landfill Directive, the new site operatingconditions focus on improvements in two key areas;• The environmental quality, including the Health and Safety of bothemployees and the public, relating to the ongoing (day to day)operation of the site.
4Capital Investment Requirements4.5 Capital funding requirements are essentially based around the controlof Leachate and Gas management as well as the associated capping/restoration operations. A more detailed breakdown of the Cappingand Restoration Costs is given at Appendix 2.The costs are summarised as follows:Capping/Restoration; Estimated to be in the region of£2,120,000Gas Management;To be quantified following RiskAssessmentLeachate Treatment; £34,400A clearer indication of the capital need for both Capping/Restorationand Gas Management will be available in November 2002 followingacceptance of the Working Plan by SEPA.Site Licence Conditions; Independent Verification4.6 Technical Services engaged consultants WS Atkins to give anindependent assessment of the modified licence conditions. Theassessment was to consider the legalities of the new licence demandsand the achievability of some of the conditions in relation to statedtime deadlines detailed.4.7 WS Atkins have confirmed that the demands from SEPA are legallyjustified.4.8 However, some of the operational deadlines are consideredimpracticable to achieve, and a recommendation is made thatTechnical Services engage with SEPA to develop a managementplan. This plan will demonstrate that the Council will work towardsbeing compliant with the licence conditions as best it can, although notperhaps in accordance to the stated deadlines.4.9 If SEPA is not willing to allow the Council to approach in this manner,it could be that the deadlines must be complied with and this would beat considerable extra cost to the Council. The costs indicated arebased on SEPA taking a tolerant approach to the Councils compliancewith the new conditions.Health and Safety4.10 With the intensified regulatory focus on the site operation,management has adopted a more systemised and processdocumented process approach to the various landfill operations. This,in line with recent advice from the Health and Safety Executive, hashighlighted a need for a permanent employee presence on sitespecifically dealing with safety issues. A fulltime Technical Officer has
5been employed within Waste Service to proactively consider healthand safety responsibilities, as well as a full time operative to managesite traffic appropriately.4.11 Lower Polmaise v. Private Landfill SiteThe current cost of disposing of waste at Lower Polmaise, as well asthe cost of the additional licensing conditions imposed by SEPA, iffully complied with, and as set out in 4.4 and Appendix 1, are shown inthe table below:Table 1 – Continued Use of Lower Polmaise £000Total (gross) expenditure on disposal at LowerPolmaise (excluding Landfill Tax)Income generated form external customersCurrent net cost of disposing of waste at LowerPolmaise (prior to notification of additional licensingburdens)Cost of additional licence conditions imposed bySEPA745(362)383283Revised cost of operating Lower Polmaise 666Cost per tonne (excluding Landfill Tax) £10.974.12 The most likely alternative means of disposal, if Lower Polmaise wereto be closed now, would be to transport the municipal solid waste(MSW) to the Avondale landfill site at Polmont which is operated byShanks. This would involve the transportation of waste by refusecollection vehicles (RCVs) directly to Avondale, a distance ofapproximately 15 miles in each direction and would involve theacquisition of additional RCVs. Based on an assumed gate price atAvondale of £12 per tonne, the cost of this option would be as follows:Table 2 – Disposal at Privately Operated LandfillSiteGate fee for disposal at privately-operated landfill site(based on 60,700 tonnes of MSW)Additional collection and transportation costs£000745800Cost of disposing of waste at private site 1,545Cost per tonne (excluding Landfill Tax) £25.454.13 Any gate fee for disposal at Avondale would need to be the subject ofnegotiation with Shanks, but, based on the calculations above, theleast expensive option for waste disposal in the short-term would
6clearly be the continued use of Lower Polmaise during the remainingperiod of its licence. In reality, there would be a lead-time of severalmonths to put alternative arrangements in place anyway, so theadditional costs of the alternative would be incurred next financialyear.Spending Requirements For 2002/03, 2003/04 and 2004/054.14 The modified licence conditions were formally served on the Councilon 17 th June 2002. These conditions are legally binding and requirecompliance by the Council. However, SEPA have indicated that ashort time scale is being offered to the Council to allow for adjustmentto the stricter licence conditions.It is now assumed that full licence compliance must be adhered totherefore the proposed spending regime is now being committed to.For financial year 2002/03 8 months remain, therefore approximately2/3rds of the additional £283,100 is required for additional spending,amounting to £188,733For financial year 2003/04 the full £283,100 would be required atcurrent costs.For financial year 2004/05 3 months will be needed to take the site toclosure in June 2004, which amounts to 1/4th of £283,100; i.e.;£70,775 at current costs.Summary of additional revenue requirements;YearAdditional Revenue Needs2002/03 £188,7332003/04 £283,1002004/05 £70,7755 POLICY IMPLICATIONS5.1 Sustainability; The entire process is essentially geared towardsimproving the whole landfill operation and moving towards sustainabledevelopment in waste management.6 CONSULTATIONS6.1 Policy Executive6.2 SEPA6.3 Finance and Information Services.
77 RESOURCE IMPLICATIONS7.1 The paper details the resource needs to enable the Council to legallycontinue to operate Lower Polmaise Landfill Site. The financialimplications are as set out in the body of the report.8 BACKGROUND PAPERS8.1 Waste Management Licensing Regulations 19948.2 “Clackmannanshire and Stirling – Waste Management StrategicStudy” – Aspinwall & Co, December 19988.3 Report to Environmental Quality Committee, 17 June 1999 entitled“Draft National Waste Strategy”.8.4 National Waste Strategy, Scotland- November 19998.5 “Waste Transfer Stations Station- Outline Design Options” – EnvirosAspinwall, August 20008.6 Report to Environmental Quality Committee, 17 August 2000 entitled“Forth Valley Area Waste Plan, Progress Report”.8.7 Report to Stirling Council on 7 December 2000 entitled “Forth ValleyArea Waste Group, the Next Steps”.8.8 “No Option But Change” – Shaping the future of Waste Managementin the Forth Valley- Forth Valley Area Waste Plan- Issues Paper,December 20008.9 The EC Landfill Directive 20018.10 Draft Forth Valley Area Waste Plan- June 20018.11 Policy Executive; 10 th April 2002; Technical Services; Waste DisposalPlanning8.12 Policy Executive; 12 th June 2002; Technical Services; WasteManagement; Update Report8.13 Paper by WS Atkins Consultants Limited dated 12 July, 2002 – StirlingCouncil Lower Polmaise Landfill Facility Review of Licence Conditions– Statement on Proposed Strategy.8.14 Policy Executive; 9 th October 2002; Lower Polmaise Landfill Site;Waste Management Licence Financial Implications of Compliance.
8Author(s)Name Designation Tel No/ExtensionAndrew CassellsHead of Partnerships, Waste& Environmental Care01786 442664Approved byName Designation SignatureArthur NichollsDirector of TechnicalServicesDate 4 November, 2002 Reference REP367EQ
9APPENDIX 1Additional Costs; Identified in line with Specific Licence ConditionsA detailed assessment of the additional costs required to maintain compliance andcross referenced with the specific licence conditions is given in the following table;ThemeLicenceConditionActionAdditional CostRoad maintenance Section 2.1 Construct and maintain roads to a standard stipulated inthe licence£34,000Daily Waste Cover Section 4.3 and4.7To provide and lay down the necessary volume of dailycover material at the end of each working day.£51,000Litter Control Section 5,.8 To provide litter collection squads as and when required. £3,250Pest Control Section 5.7 To provide full cover with a pest deterrent during alltipping times.£1,950Access RoadDust suppressionSection 2.1 and5.5Section 5.4To provide a full time vehicle and man to maintain theaccess roads to an acceptable standard and alsosuppress dust during times of dry whether.£8,000 tractor£4,500 wheel wash£20,700 man powerLeachate Treatment andmonitoring needsSection 5.1Section 7To provide technical needs associated with the operationof the treatment plant. Ultimately to maximise itsoperation. To also carry out ongoing monitoring ofvarious stipulated issues£22,750 Revenue£34,400 CapitalIntermediate Cover Section 4.8 To cover completed waste cells in accordance with thesite licence to minimise precipitation egressGas Control Section 5.2 A risk assessment is required to be carried out prior toSeptember 30th 2002 to ascertain the gas control needs.Capital development costs to be ascertained inconjunction with the capping/restoration plan.£95,000£20,000included in 2002/03revenue.Capital needs to bequantifiedFinal Capping andRestorationSection 4.13A capping/restoration plan must be submitted to SEPAby 30 th September 2002 following. This will detail thecapital spend needed to complete the site to its finalprofile.Capital costs TBA.Indications are that thiswill cost in excess of£2MHealth and SafetyHealth and Safetyat Work ActDue to recent pressures made by the Health and SafetyExecutive it is necessary to commit improved resourcesto cater for the Councils responsibilities£19,150 Officer£10,800 Traffic ControlGreen waste handling EC LandfillDirectiveTOTAL AdditionalRevenue RequiredDue to expected increase volumes of green waste it isnecessary to apply improved resources to cater for theincrease.£12,000£283,100 perannum
10APPENDIX 2LOWER POLMAISE LANDFILL SITE; WASTE MANAGEMENT LICENCEFINANCIAL IMPLICATIONS OF COMPLIANCE; RESTORATION ANDAFTERCARE; CAPITAL EXPENDITUREAdditional information detailing capital spending needs for restoration and aftercare.Lower Polmaise landfill is expected to close in June 2004. At this point in time it willrepresent a waste mass of approximately 3 million cubic meters of waste masscovering an area of approximately 30 hectares. The site will still hold the wastemanagement licence with its associated conditions of closure, restoration andaftercare.The following restoration and aftercare needs are detailed:• Profiling- The final waste mass must be profiled and contoured in a mosteffective manner to encourage the dispersement of surface water to discouragethe possibility of surface water accumulation and associated contamination orpercolation.• Capping- Six months after the cessation of the deposit of wastes a 1.0mm thickoverlapped geosynthetic membrane may be used for capping which shall becovered by a depth of 900mm of subsoils or equivalent material. This minimisesprecipitation percolation and associated leachate production. This system mustcomply with stipulated quality assurance controls.• Gas control-The synthetic capping system must incorporate the needs toeffectively capture landfill gasses. The site licence requires “active” managementof landfill gasses. These must be collected and either flared off to theatmosphere, or there exists the opportunity to capture energy by combusting thegas in a controlled manner.NB If the conditions of Polmaise represent an attractive proposition to particular“alternative energy generation organisations” it might be the case that capitalinvestment could be available from private investment.These 3 stages must be delivered in an integrated plan. The delivery largelyrepresents capital costs and these are broken down very roughly as follows:Profiling : £ 50,000 Contouring materials and machineryCapping : £1,890,000 300,000m2 @ £6.30Gas (flaring to atmosphere) £ 180,0006 x £30,000 gas flare unitsTOTAL £2,120,000NB These figures are very approximate and will be detailed in November 2002 oncethe Working Plan has been accepted by SEPA.