Dalen mines in Brevik, best non-current location for special waste landfill

This is our consultation note to the Ministry of Climate and the Environment.

Ref. no. 16/1286 

The Norwegian Environmental Protection Association (NMF) has for a long time followed the discussion around the new location of the landfill for hazardous waste when the landfill on Langøya is full. However, we have not been so committed to the plans for Brevik as we have seen Brevik as a completely irrelevant alternative due to the fact that the landfill will be located in the middle of and under dense built-up areas. It is only recently that it has really dawned on us that the responsible authorities in Norway actually see Brevik as a real alternative, and have therefore, to our surprise, had to get involved.

Our work on the issue of landfill led us first to NOAH Langøya to investigate how they operated the current landfill. This is because we believe the current operation must and should be representative, even though the disposal method and location are very different at the current facility on Langøya and how it is planned to be operated in Brevik. For a number of years, NMF has recommended Langøya as a landfill for many of our compounds. This despite the fact that we have never been physically on Langøya until recently. We have simply trusted the environmental foundation Bellona and Frederic Hauge when they have done well for NOAH and their operation of the plant. NMF can now guarantee that we will never take Bellona's or Frederic Hauge's word for good fish as long as there is money involved, because we unfortunately have to admit that we have been thoroughly misled here. Whether Bellona's "blindness" is due to incompetence or whether 450,000 NOK from NOAH to Bellona a year makes the latter a little short-sighted, we will not, however, speculate, as both parts are equally critical in this context.

Our visit to Langøya began with a review of the operation, routines, geology etc. of the current landfill, followed by a tour of the island by NOAH's personnel. We also demanded an extra route where we could decide for ourselves where we were going and what we wanted to investigate. Our visit revealed major breaches of environmental safety, so serious that we found it necessary to report NOAH to the police for operating in breach of the given permit. This mainly concerns disposal in a facility that leaks poison into the environment, i.e. a facility that has not been closed and will not be closed either. (see review).

NMF is saddened to find that Norway's largest and most well-known special waste reception center is run in such a way that it only took us a 30-minute inspection and two hours of description of the operation to find several points in the operation that were so unsatisfactory and dangerous in short and particularly long term that we found it necessary to report the situation to the police and send a "report" to both the Directorate and the Ministry.

The mines in Brevik have long been pointed to as a possible successor to the landfill on Langøya, but since we assumed that the authorities would primarily emphasize people's safety and not focus on the finances of a privately owned company, we have, as previously mentioned, sat on the fence in anticipation that the Norwegian Environment Agency should find some alternatives that did not gamble with the local environment of 15,000 inhabitants who live close to, around and on top of what has been inexplicably pointed out as a suitable place to deposit some of the most dangerous waste in modern society. Waste which, with only minimal deviations, will be able to form large quantities of gas, and which will lie under the homes of all these people and disturb their night's sleep and faith in their own future for hundreds of years. Who wants to live on top of a special waste landfill?

It must also be taken into account that Brevik has for a long time been heavily burdened with industry, to the delight of the few who have had work in industry and to the greater frustration of all those who have only known the burden in the form of all imaginable industry-related ailments. Several of the residents of Brevik have expressed that they have long been looking forward to the intensity of the industry-related neighboring nuisances being reduced and perhaps finally being replaced by a far more gentle commercial operation that was not such a big nuisance for Brevik's residents. Now the opposite is about to happen, Brevik is inclined to maintain all the industrial problems the population has been looking forward to and getting rid of. Several say they would like to sell their houses and settle elsewhere, if it had been possible to sell homes located on top of what is likely to be Norway's largest reception for special waste, and a pilot project for a new type of special waste management none in Norway has experience with on a full scale and in a 10-50-100-500+ year perspective.

How can the Norwegian Environment Agency conclude that the population must settle for NOAH's assurances that the process is safe at all stages and in "all" the future, when they are unable to operate the landfill on Langøya according to the regulations, and with leaks and mass escapes from the facility. Operations on Langøya are far less complicated. How are people supposed to live with the idea of what, if and when things go wrong. Langøya is leaking, and there are several examples where the reception of special waste both at home and abroad of various types has had major accidents with enormous consequences. Who hasn't seen the pictures from the explosion in Sløvåg, where the "guaranteed" harmless washing water exploded? Where guarantees were also given both before and after the accident that everything was safe and nothing could go wrong because they had such good routines, routines that are never better than the potential for human failure. We would also like to add that even if the waste that exploded at Vest Tank in Sløvåg was not supposed to be received and that the facility made several mistakes in the process, this shows that you can never fully insure yourself against wrong reception, the mixing of foreign substances that can cause chemical reactions in the short or long term, shortcuts, language entanglements, human processing failures, etc. Fortunately, the Vest Tank facility was located in one of Norway's most densely populated municipalities with very few inhabitants in the immediate vicinity of the industrial area. What if this happened in the middle of Brevik? Or under Brevik, or…..

In the old mine tunnels in Brevik, you will not only have to worry about today's human failure, but also the possibility of old misjudgments and human failure during the operation of the tunnels several decades ago. Something that the Norwegian Road Administration was also aware of when they investigated the new E18 and route selection for it. The Swedish Road Administration concluded that it was safest to avoid tunnels in the area as it was uncertain where all the tunnels were located, what they could withstand in terms of weight, vibrations and the like. It is completely incomprehensible to us that the Norwegian Environment Agency can recommend the establishment of a special waste landfill in an area that the Swedish Road Administration made every effort to avoid for safety reasons. We also want to show that only a few decades ago there was a major collapse in the area where several of the mine shafts collapsed and a large area sank together up to 10m. How can one safely dispose of hazardous waste with the potential to form explosive and toxic gases in a long-term mining system that is so extensive that one does not know all the passages, cracks, seeps and waterways in the cracked limestone. There are also several groups that doubt the density of the limestone in the area as it is full of natural cracks in addition to burst cracks and weaknesses, this is also the same rock that you see leaking on Langøya, however it can be mentioned that the rock itself is relatively tightly isolated seen in the fact that the limestone does not let as much water through in itself, but this is of little help when the whole rock is full of cracks that let water through like a sieve.

Sources in Brevik also tell us that large quantities of water are flowing through the mines in the area, which NOAH's specialist officer also confirmed at the previously mentioned inspection and meeting on Langøya. There was also talk of putting the mine tunnels under water after the end of deposition, which we absolutely cannot accept as allowing water to constantly penetrate from the overlying mine tunnels will create overpressure in the lower parts so that all water that enters will push out and contribute to a spread of all the substances that are sought to be deposited. How the deposited masses will behave in the long term, no one can reasonably vouch for, and precisely for this reason we cannot see any good arguments for proven contribution to the spread of the landfill's toxic materials.

Norway's Environment Protection Association strongly advises against placing Norway's largest reception for special waste in a densely populated area such as Dalen gruver in Brevik, where people live around and above the landfill itself, with all the potential dangers this can cause to a not inconsiderable proportion of private people which most involuntarily becomes an integral part of NOAH's facility for handling Norway's largest toxic landfill.


Read the police report here.

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