Fingal Landfill Project OH(2) Sub No. I

Proposed Fingal Landfill - EPA Oral Hearing (27/O4/2OO9)

Brief of Evidence

Hyd rogeol og ical Risk Assessment

Fingal County Council

Louise Burden BSc, MSc, FGS, ARSM

Richard Graham BSc, MSc, FGS

Shane Herlihy BA(Mod), MSc, MBA, PGed, EurGeol

Wyatt Orsmsnd NHD, MSc, MIEI, Ceng

Larry O’Toole Final

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I

.-- Fingal Landfill Project Brief of Evidence

I BACKGROUND 8 INTRODUCTION

1 .l BACKGROUND

Louise Burden has a Masters Degree in Hydrogeology from the University of Birmingham and an Honours Bachelors Degree in Geology from the Royal School of Mines, Imperial College, London. Louise has over 10 years experience in Environmental Consultancy Ireland and the UK. Louise has specialised in risk based assessment of contaminated land with respect to human and groundwater receptors and also has experience of undertaking hydrogeologicat Environmental Impact Assessments for various projects. She is a Fellow of the Geological Society of London and a member of the International Association of H ydrogeologists.

Richard Graham has Masters Degrees in Hydrogeology and Exploration Geophysics from University of Birmingham and University of Leeds repesctively and Honours 8acheiors Degree in Geophysical Sciences from University of Southampton. He has over 13 years experience in Environmental Consultancy within the UK and specialises in quantitative hydrogeological risk assessment with respect to landfills and contaminated land. He is a fellow of the Geological Society of London.

Shane Herlihy is a Professional Member of the Institute of Geologists of Ireland (PGeo) and has a Masters Degree in Hydrogeology and Groundwater Resources from the University of London and an Honours Bachelor Degree in Earth Sciences from Dublin University. He is also a member of the International Association of Hydrogeologists. Shane has been active in the field of hydrogeology and groundwater for over 16 years, 14 of which have been as a hydrcgeological and environmental consultant. He has considerable experience in the assessment and investigation of hydrogeology and assessing the risks posed by contaminated land and proposed developments to groundwater.

Wyatt Orsmond is a Technical Director (Geotechnical) with RPS Consulting and Head of the Geotechnical Department. He has a National Higher Diploma (Civil), a Master of Science Degree in Engineering (geotechnical). He is a Chartered Engineer, a member of the IEl and Chairman of the Geotechnical Society of Ireland. Wyatt has worked in Ireland since February 2000. He has over 18 years experience in all aspects of Civil Engineering and is a specialist Geotechnical Engineer.

Larry UToole is a Chartered Member of the Institution of Engineers of Ireland and has an Honours Bachelors Degree in Civil Engineering from University College Dublin. He has 21 years experience of civil, environmental and geotechnical engineering and waste strategy and planning in Ireland and in the UK. He has specific expertise in landfill engineering which has incfuded the procurement of over 30 contracts for the extension, capping or remediation of landfills in Ireland and the UK. He has presented extensively on waste management issues including on waste policy and also technical aspects of waste facility siting, design and procurement.

1.2 OVERVIEW OF RISK ASSESSMENT A Hydrogeological Risk Assessment of the proposed Fingal Landfill was submitted to the €PA in February 2009 in response to their letter of 17th October 2008 requesting a "probabilistic quantitative risk assessment that evaluates the potential for leachate leakagelmigration to groundwater beneath the proposed facility". A copy of the letter is appended to this brief.

The Assessment was carried out in amrdance with the Environment Agency (England and Wales) Guidance on "Hydrogeo/ogical Risk Assessmenf for Landfills" (March 2003). The Guidance advocates a risk based tiered approach comprising, Problem Formulation, Risk Screening, Simple Risk Assessment and Complex Risk Assessment. The work conducted to satisfy the EPAs requirements, comprised a Complex Kisk Assessment. The lower tiers of assessment were previously undertaken as part of pre-planning studies and the EIA process and concluded that the proposed landfill does not present a significant risk to groundwater beneath the site.

The risk assessment process has been based on a source pathway receptor approach. The source is leachate within the proposed landfill. The primary receptor is groundwater within the locally important aquifer and Groundwater Body beneath the site. The pathway between the source and the receptor is migration through the engineered mineral liner and underlying clay subsoils.

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Fingal Landfill Project Brief of Evidence

The quantitative risk assessment was undertaken based on the information retrieved during extensive site investigations rarried out a5 part of the EIA process. The raw data was reviewed as part of the risk assessment process and was interpreted to form a conceptual model for the purpose of identifying and quantifying reasonable worse case risks to groundwater within the locally important aquifer beneath the site.

The conceptual model included a number of simplifying assumptions which erred towards representing a worse case scenario. The principal simplifying assumptions and their effect on the Risk Assessment model are described in Table 5.6 of the Risk Assessment report. Variability and uncertainty within the selection of input parameters was accounted for by use of stochastic analysis within risk assessment software tools to provide a probabilistic quantitative assessment.

Two modelling techniques (Landsim and the Environment Agency Tontarninant Fluxes from Hydrualic Containment Landfill Spreadsheet v1.0) were used to assess the potential risks to groundwater within the aquifer under different migration mechanisms (advection and diffusion), in order to account for the complex hydrogeological setting as described in Sections 2.5 and 4 of the risk assessment report. Each of the techniques used represent opposite ends of a spectrum of potential migration mechanisms that will operate at the site. This approach provides a robust risk assessment for the proposed landfill.

The results presented are for the 9 P percentile of the outcome of the model. This represents a certainty level of 95% that the actual concentrations will be less than the predicted concentrations. The 95" percentile therefore represents a reasonable worse case. This is in addition to the level of conservatism inherent in the simplifying assumptions listed in Table 5.6 of the risk assessment report.

The results of the assessment indicate that chloride and potassium are the only contaminants which may record detectable concentrations over the modelled lifetime of 20,000 yean from the start of land filling to record detectable concentrations within groundwater beneath the site. T h e results of the assessment are therefore consistent with the EIS in that leakage of leachate will have an imperceptible impact on groundwater beneath the site in that measurable on cent rations may be recorded but will have no significant impact on groundwater quality and the chemical status of the Groundwater 8ody.

2 CONCEPTUAL MODEL The canceptual site model for the risk assessment is presented in Section 4 of the risk assessment report. For further clarity the conceptual model is discussed further below.

2.1 GEOLOGY The site is underlain by three broad geological components

1. Glacial Tills comprising low permeability sandy gravely clay. 2. Sand and Gravel subsoil deposits which are localty present below the clays. 3. Bedrock comprising carboniferous limestones, siltstones and mudstones of the Loughshinny,

Naut and tucan formations.

Within the area of study covered by the intrusive investigations, the thickness of the clay varies from 4 to 27 m. However, within the proposed landfill footprint the thickness of the clay is typically 15 to 25 m. A minimum thickness of 10 m of low permeability clay will be maintained below the footprint of the landfill.

The sand and gravel deposits vary from being absent to having a thickness of greater than 10 rn beneath the low permeability clay.

The bedrock is highly fractured and there is a major fault zone trending north south to the east of the site. This fault zone is inactive.

2.2 HYDROGEOLOGY

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Brief of Evidence _ _ Fingal Landfill Project

The three bedrock formations underlying the footprint have been classified as being Locally Important Aquifers by the Geological Survey of Ireland (GSI).

The Quaternary sands and gravels which are locally present above the bedrock are not classified as a separate aquifer by the GSI. The sands and gravels do however provide additional storage to the underlying bedrock aquifer. The potentiometric surface within the gravel deposits is generally at the same elevation as the potentiometric surface in the bedrock indicating that there are no vertical gradients between the two units. The bedruck and the gravel are therefore considered to be in hydraulic continuity with each other and have been considered as a single hydrogeological unit separate to the overlying low permeability clay of the Glacial Tills. The aquifer unit considered in the assessment therefore comprises the fractured bedrock and the sand and gravel deposits where present. The principal receptor within the assessment is therefore groundwater within this aquifer unit which is classified as the Lusk Bog of the Ring Groundwater Body under the Eastern River Basin District in accordance with the Water Framework Directive. This water body has recently been classified poor status from over abstraction.

Groundwater within the aquifer unit is confined by the overlying low permeability clay, meaning that the potentiometric surface is above the top of the aquifer. The potentiometric surface within the aquifer unit is close to the current ground surface in the north-west of the proposed landfill foot print and artesian conditions exist along the northern boundary of the footprint. The saturation zone of the aquifer is located within the bedrock and sand and gravel deposits and does not include the overlying clay.

Water is present within the Glacial Tills. The water is contained within relatively more permeable horizons within predominantly low permeability clay these can range in scale from mm to m. Based on the site investigation data to date these are likely to be on a mm to cm scale. Vertical and lateral migration of water within the Glacial Tills is restricted by the low permeability nature of the clay and therefore any water occurring within in it is considered to be perched. This water is localised in extent and is not considered as a separate Groundwater Body under the Water Framework Directive. When screened over a vertical section an equifibrium water level is reached within standpipes in the clay. The stabilised water levels measured within standpipes in the clay range from approximately 56 m AOD in the north-west of the site to 31 m AOO in the south east of the site. These levels are generally above the base of the landfill. There is therefore a potential for water to seep into the landfill during construction or operation.

Migration of leachate through the HDPE and engineered mineral liner and the underlying clay will be controlled by the hydraulic conductivity of the engineered mineral liner and in-situ clay and the vertical gradients acting between water levels within the clay, the leachate head within the landfill and the potentiometric surface within the aquifer unit. Depending on local conditions and the relative vertical position of these levels the dominant transport mechanism will either be diffusion or advection as described in Section 4.2.3 of the Risk Assessment Report

The dominant transport mechanism will vary laterally and temporally throughout the lifetime of the site although in the long tern, as leachate levels within the landfill rise following cessation of management controls advective ffow will be the most important mechanism.

Both mechanisms have been considered independently within the risk assessment to represent the opposite ends of a spectrum of potential scenarios and to represent a reasonable worse case scenario for each mechanism.

3 3RD PARTY SUBMISSIONS

Submissions have been received, by the EPA, in relation to the risk assessment report from the fallowing 3d Parties:

1. Gemma Larkin 2. Thomas Larkin 3. Kevin Cullen 4. Declan White 5. Paddy Boyle and Paul Ashley

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Brief of Evidence Fingal Landfill Project

6. Dermot Sheridan 7. Shay Lunney 8. Minister of StateTrevor Sargent 9. Geolcgical Society of Ireland IQ. Greenstar and Golder Associates

The principle issues raised were as follows Hydrogeological conceptual model Definition of groundwater

Selection of Compliance points

The effect of a basal drainage blanket beneath the landfill liner Groundwater and surface water interactions

Selection of .risk assessment tools Effects of seismic activity and climate change Risks to horticultural Industry and Bog of the Ring Resource potential of the aquifer unit

These issues are addressed in the discussion below.

3.1 HYDROGEOLOGICAL CONCEPTUAL MODEL The conceptual model is described within the risk assessment report and has been clarified above.

The commentary submitted on behalf of Trevor Sargent states that the locally important aquifer comprises "highly fractured limestone bedrock and groundwater above the bedrock in the clay layer". This is not correct. The aquifer unit beneath the site only comprises fractured bedrock and the sand and gravel deposits where present. The low permeability clays are not classified as an aquifer by the GSI and the waters within them do not form a separate Groundwater B@dy under the Water Framework Directive.

Golder Associates and others are incorrect to refer to this as a "sub-water table" landfill particularly within the context of the Environment Agency Guidance on Hydrogeological Risk Assessment of Landfills. 'Sub-water table" landfills are those where the base of the landfill lies below the phreatic surface within an unconfined aquifer. The water within the clay subsoils occurs in relatively more permeable horizons within the clay which are vertically separated by low permeability sails which restrict the downward migration of water and has therefore teen describd as perched. It does not however form a continuous "perched water table". The proposed Fingal Landfill is located above a confined aquifer unit with a vertical separation of at least 10 m. The potentiometric surface Is above the base of the landfill in the northern portion of the site. This is not the same as being below the "water table".

In response to a requesf from Golder Associates Figures I and 2 present the measured stabilised levels in clay for two separate monitoring rounds together with the potentiometric surface contours for the aquifer unit for the corresponding dates.

3.2 DEFINITION OF GROUNDWATER

Article 2 of the Groundwater Directive 801681EEC and Article 2 of the Water Framework Directive 2000/60/EC give the following definitions

(a) "groundwater" means all wafer which is below the surface of the ground in the safuration zone and in direct contact with the ground or subsoil;

(b) "direct discharge" means the introduction into groundwater of substances in /ish I or 11 without percolation through the ground or subsoil; I (cl "indireci discharge" means the introduction info groundwater of subsfances in lists I or It atkr percolation through the ground OF subsoil;

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Fingal Landfill Project Brief of Evidence

The wafer within the subsoils does not form a continuous ‘saturation zone” beneath the landfill and therefore is not considered to meet the definition of groundwater within the directive. The saturation zone is located within the sand and gravel deposits and fractured bedrock which make up the aquifer unit beneath the site.

Water within the aquifer unit beneath the clay subsoils does meet the definition of groundwatet within the Groundwater Directive and Water Framework Directive and is therefore considered as the principal receptor within the conceptual model and risk assessment. Water within the low permeability clays is considered to act as a pathway.

The proposed landfill will not result in any ‘direct discharge” as it is an engineered facility designed in accordance with the Landfill Directive to prevent such discharges in the first place. Secondly, if any leakage from the landfill does occur, it will have ta permlate through the subsoil before it reaches groundwater in the Locally Important Aquifer below the site. As such, this is an ‘indirect discharge” according to the Groundwater Directive (Article 2c). The proposed facility will be designed in accordance with the Landfill Directive such that all “technical precautions necessary to prevent such discharges are observed” (as stated in the Groundwater Directive under Article 4(1).

Although the landfill will be located below the potentiometric surface of the underlying bedrock aquifer, at no place will the proposed landfill be in direct contact with groundwater in the underlying aquifer, as there will be a minimum of 10m thickness of natural low permeability subsoil below the landfill in addition to the engineered lining systems. Therefore it does not pose the potential to contravene the €U Groundwater Directive by permitting the release of List 1 Substances directly to groundwater.

3.3 DRAINAGE BLANKET Mr Cullen and others claim that the installation of a drainage blanket will impact on groundwater within the overburden and underlying aquifer unit beneath the site including the Bog of the Ring Water supply.

A drainage blanket will be installed where required to collect water released from the Glacial Till during construction in order that uplift does not occur beneath the liner, either during construction or subsequently during the initial stages of filling. Based on site investigations it is anticipated that only small quantities of water will be collected in the drainage blanket and this will be pumped until there is sufficient waste within the parhcular cell to resist uplift pressures on the base of the celt.

This situation differs to other existing landfills which have been constructed below a continuous water table within subsoils. Mr Cullen is suggesting that the presence of a drainage blanket beneath the landfill could potentially impact the bedrock aquifer and sand and gravel deposits where the potentiometric surface in the aquifer unit is above the drainage layer. Although, the vertical gradient in this case will be from the aquifer unit upwards towards the drainage blanket the rate of groundwater movement will still be limited by the low permeability nature of the subsoils as it would be for downward migration. Given the minimum 10 m thickness of the clay beneath the drainage layer and the relatively short active lifetime of the drainage layer, measurable hydraulic influence QI-I the aquifer is considered to be unlikely.

The presence of a drainage blanket beneath the landfill will have no effect on the Bog of the Ring water supply.

3.4 INTERACTION WITH SURFCE WATER

A submission from Paddy Boyle states that ”No Investigations were carried out on the possible contribution of groundwater to the local streams and the consequential risks. This is not correct. Surface water streams and connections with groundwater are considered within the risk assessment presented in Volume 5, Appendix H, Section 5 of the EIS. An inspection of all surface water courses within the study area was undertaken by Shane Herlihy as part of the EIA process in July 2006. This exercise was repeated by Louise Burden in November 2008 and again in April 2009. The surface water features within the study area can be divided into two categories

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Fingal Landfill Project Brief of Evidence

1. Drainage Ditches and Ephemeral streams which are shallow channels recharged by overland flow and interflow within subsoils.

2. Streams which form deeper incised channels and may be recharged from overland flow, interflow and groundwater baseflow.

The water features within the landfill footprint belong within the first category. These are shallow drainage ditches which illusttate the low permeability nature of the subsoils. The surveys conducted by RPS show these streams to have minimal flow which ceases in dry periods indicating that they do not receive a base flow from groundwater. These ditches will be removed during the construction of the proposed landfill and replaced with a suitably designed surface water drainage system which will intercept surface water run-off.

Two streams are present to the north of the proposed landfill footprint. These streams flow to the south-east and converge to the east of the footprint. Both streams are steeply incised to the north of the landfill. Exposed bedrock is present within the northern-most stream. The location of the bedrock has been compared with groundwater contours, obtained from over three years of groundwater monitoring data. The bedrock is located up hydraulic gradient of the landfill and therefore the groundwater base flow for the stream originates to the north-west of the landfill.

The more southerly stream which borders the north of the proposed footprint shows no evidence of rock outcrop in the vicinity of the landfill however it is likely that this stream also receives recharge from groundwater in the aquifer to the north-west (up gradient) of the site. The finished base of the landfill will be below both of these streams and no lateral pathways will exist.

3.5 COMPLIANCE POINTS

dolume 5, Appendix H, Section 5.2 of the EIS presented a preliminary risk assessment based on the source-pathway-receptor approach which identified the undedying aquifer unit, comprising fractured bedrock overlain by localised sand and gravel as the primary receptor with respect to potential migration of contaminants from the proposed landfill. Groundwater abstractions and spring fed streams down gradient of the landfill were identified as secondary receptors within the EIS. As previously mentioned the streams identified in the vicinity of the site receive recharge from groundwater upgradient of the site. There are no groundwater abstractions immediately down gradient of the site. Water within the clay subsoil is considered as a pathway not as a receptor.

The compliance points have therefore been considered as being within, and at the point of entry to, the aquifer unit to be protective of the primary and secondary receptors identified in the preliminary risk assessment.

3.6 SELECTION OF RISK ASSESSMENT TOOLS

The hydrogeological risk assessment was undertaken using risk assessment software tools to represent the conceptual model as previously discussed and outlined in detail in Section 4 of the Hydrogeological Risk Assessment report.

Two potential mechanisms of transport, diffusion and advection have been identified within the conceptual model and represented within the risk assessment.

The process of diffusion will operate when there are no downward vertical gradients between leachate in the landfill, water levels within the clay subsoils and or the potentiometric surface within the aquifer unit. The Environment Agency 'Contaminant Fluxes from Hydrualic Containment Landfill Spreadsheet v l . 0 is considered an appropriate tool to estimate potential contaminants ffuxes from the process of diffusion.

Diffusive ffuxes during hydraulic containment are largest when containment heads are smallest. Therefore the diffusion scenario has used a minimal head difference between water levels in the clay and leachate within the landfill whilst still maintaining hydraulic containment. Diffusion has only been modelled through the combined thickness of the 1 m thick engineered mineral liner and the minimum

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Brief of Evidenca Fingal Landfill Project - _

I O m of low permeability in-situ clay. The presence of the HDPE liner has been ignored. The diffusion scenario therefore represents a worse case for leachate leakage in situations where the levels in the surrounding subsoils are greater than that of the leachate.

The LandSim software, which was developed for the Environment Agency (Engalnd and Wales) to provide prabailistic quantitative risk assessments of the performance of landfills, was used to predict leachate concentrations and elevations during the operational phase of the site, including changes in infiltration, declining source term within leachate and deteriorating leachate control systems.

Dr Ashley points out there may be situations where the principal of hydraulic containment is not operating leading to the loss of leachate. This possibility was identified within the conceptual model and LandSim was used to measure advective fluxes from the landfill when there are vertical downward gradients between leachate in the landfill, water levels within the clay subsoils and the potentiometric surface within the aquifer unit.

In the advection scenario a head of leachate is assumed to act across the landfill and is the driving force for leakage of leachate out of the base of the landfill. The management controls are represented as creating a 1 m leachate head within the waste for the entire 30 year period of waste tipping and for an additional 30 year period following the completion of capping. This is a worse case assumption as due to the sloping base of the landfill the head of leachate will be considerably less than 1 m across a large proportion of the site. Beyond the theoretical 60 year management period, leachate heads rise creating larger advective flux of leachate out of the fandfill. These are predicted by the LandSim assessment for a total of 20,000 years.

Leachate breakout is predicted to occur during this period. The elevation of leachate at this point represents the maximum possible head to drive advection of leachate out of the site. The LandSirn assessment assumes this head will operate for the full remaining lifecycle of the landfill and represents a worse case potential magnitude of advection through the engineered liner.

In reality a combination of transport mechanisms will operate across the landfill and will vary both laterally and temporally. The selected tools cannot be run simultaneously since they use assumptions which are mutually exclusive. By using the two models separately the full spectrum of transport scanarios has been represented and a reasonable worse case has been modelled for each. This has provided a robust assessment which is highly protective of the groundwater within the aquifer beneath the site.

Golder Associates have raised a number of questions in relation to how LandSim model has addressed the following aspects:

Engineering controls during the lifecycle of the site The role of the drainage blanket Breakout of leachate through the cap

LandSim is designed to allow full lifecycle hydraulics io be considered for predicting impacts at the identified receptors. The principal control on hydraulics include:

Physical properties of waste Duration and magnitude of open waste infiltration Duration and magnitude of capping layer infiltration Duration and magnitude of leachate head controls Engineered liner permeability chamteristim both as laid and following degradation of HDPE

All these factors have been represented within the LandSim assessment based on site specific or expected engineered values.

The LandSim risk assessment accounts for the presence of a one-metre thick drainage blanket below the engineered mineral liner. It is represented within the risk assessment as an inert vertical pathway with no influence on contaminant attenuation. The diffusion assessment does not account for the presence of a drainage blanket as only the low permeability mineral pathway is assessed for diffusion.

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Fingsl Landfill Project Brief of Evidence

Breakout of leachate is not considered quantitatively within the risk assessment as it will be managed by passive engineering controls as a contingency as is the case far many landfill sites. The design of such engineering will be to remove any pathway that may allow uncontrolled or unacceptable releases of leachate out of the site and into surface water. Such engineering controls will be agreed with the €PA at the time of surrender of the licence.

3.7 The commentary submitted on behalf of Trevor Sargent suggests that the risk assessment should have taken account of seismic activity and severe weather events.

SEISMIC ACTIVITY AND CLIMATE CHANGE

The bedrock is highly fractured and there is a major fault zone trending north-south to the east of the site. This fault zone is inactive and therefore seismic activity has not been considered as significant factor in the hydrogeological risk assessment. This issue addressed in the May 2007 response to requests for further information by the EPA under Article 14(2)(b)ii of the Waste Management Regulations.

Allowance has been made for a 10% increase in rainfall as a result of climate change which will influence infiltration of water to the waste body. The impact of major precipitation event will primarily affect the surface water drainage system which will be designed with such events in mind. The effect on the hydrogeological system is likely to ha short term only and is therefore not considered as a significant factor within the quantitative probabilistic risk assessment.

3.8 RISKS TO HORTlCULTURAL INDUSTRY

The results support the conclusion of the EIS that the landfill will have an imperceptible impact on the primary receptor which is groundwater within the locally important aquifer. It therefore follows that the risk to any secondary receptors including groundwatet abstractions for use in the horticultural industry are similarly imperceptible.

The Bog of the Ring Water supply is separated from the proposed site by a groundwater divide and will therefore not be impacted by the proposed landfill. This subject has been addressed comprehensively in the EIA and waste licence application process.

3.9 RESOURCE POTENTIAL OF AQUJFER

Throughout this waste licence application process a number of parties have raised concerns about the potential resource value of the aquifer unit directly beneath the landfill. These have been extensively discussed as part of the request for further information under Article 14 and the previous Oral Hearing

The site is underlain by the Lusk-Bog of the Ring groundwater body. This groundwatet body has recently been confirmed as having poor status under the Water Framework Directive. Therefore significant further abstraction from this groundwater body is considered unlikely.

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17 October 2008

I am to refer to your 'application for a waste licence r e f e m 4 above. Having re& to the requimncnts of Council Directive 99BlBC on the I d 1 of waste'axict Cowid DireCtive 80/68/EEC of 17 Deoembm I979 an the protectkm of gm.md~&er @ b t pollution caused by certriin dqngerous substances, the &mi cdnsiders that fiather' infomation is required to ensure the proper determination of this matter. YOU are requested to prepam and submit further information in relation to the cwimmental xjsk assessment for the facility that was submitted in relation to the appIication. This informatio~ shall d d in particular with the folIowing matters: -

>-predicted leakage l ~ s s e ~ and attenuations factors (e-g dilulion, dispersion,

P receptors selected for assBsment (such as aquifers, abstraction wcUs). diffusion, sorption).

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