PLANNING APPLICATION REVIEW OF SHANKS PONTYPOOL …

Golder Associates (UK) Ltd

Cavendish House, Bourne End Business Park, Cores End Road, Bourne End, Buckinghamshire, SL8 5AS, UK Tel:[+44] (0) 1628 851851 Fax: [+44] (0) 1628 851852 www.golder.com

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Dear Richard

Parsons Brinckerhoff (PB), on behalf of Torfaen County Borough Council (TCBC), completed a review of the air quality chapter of the environmental statement prepared in support of planning application P/12/00100 relating to the development of an Anaerobic Digestion Waste Management Facility in Pontypool to be operated by Shanks Waste Management Limited (Shanks) (report reference 3512412A_001 dated 25 September 2012). In particular, the review focused on the odour dispersion model prepared by Golder Associates (UK) Ltd (Golder). The review concluded that, in general terms, the methodology used in the odour dispersion modelling is appropriate; however, it requested clarification/justification of some assumptions. Golder provided a response by letter dated 4 October 2012, a rebuttal to which was provided by PB (report reference 3512412A_002 dated 26 October 2012).

Our subsequent response is provided here.

Response to general commentary:

PB has accepted that any minor failure will not undoubtedly result in a significant increase in odour emission but states that “however, from experiences elsewhere, minor failures in bio-filter system [sic] often results in significant increases in odour releases”. Shanks have recognised that minor failures have the potential to results in odour releases; indeed this is the reason behind the inclusion of redundancy measures in the bio-filter design for the Pontypool facility. As outlined in the Odour Management Plan (Version A.1) provided to the Environment Agency Wales for the Environmental Permit (EP) application, the bio-filter system design includes an active management system which allows continuous monitoring of pressure, flow, VOC and relative humidity. This will ensure that any failure, however minor, will be immediately flagged and appropriate actions can be taken prior to the system experiencing adverse effect which may result in an increase in odorous emissions. The system will also be fitted with a back-up fan and be linked to a 20 m3 buffer tank for irrigation water (a 2 day supply). There will be two biofilter lines each capable of treating the normal operational load of the process under normal operation both of these will operate in parallel. Extraction flows will be distributed equally between the two via one of a duty standby inverter controlled dual fan set with full dual redundancy. Either fan can be direct driven in the event of an inverter failure. Each bio-filter is preceded by a wet pre-scrubber system to remove water soluble components for example Hydrogen Sulphide Ammonia and some volatile fatty acids. The scrubber also serves to maximise the relative humidity of the biofilter input.

PB comments on the “late proposal of including pre-mixing within the combined stack” to assist in plume homogeneity. Golder would note out that the pre-mixing was always part of the design and was set out in Chapter 11 of the Environmental Statement.

6 November 2012 Project No. 12514190097.501/2

Mr Richard Marshall Senior Environmental Health Officer Torfaen Borough Council Ty Blaen Torfaen New Inn Pontypool NP4 0LS

RESPONSE TO PARSONS BRINCKERHOFF REBUTTAL OF GOLDERS’ RESPONSE TO ITS PLANNING APPLICATION REVIEW OF SHANKS PONTYPOOL ANAEROBIC DIGESTION FACILITY

Mr Richard Marshall 12514190097.501/2

Torfaen Borough Council 6 November 2012

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PB states that “with exception to the presentation of the OMP, no new evidence or approach in how Shanks intends to manage the facility has been presented within the Golder response”. It is understood that this question relates to Shanks’ operational procedures which falls under the remit of the EP application. Shanks have provided extensive procedural information to the Environment Agency Wales in response to its recent Schedule 5 Notice; for which TCBC will be a consultee.

PB has shown concern as to the potential for odorous emissions from the door lock system. For clarification, further information is provided on the operation of an interlocking door system. In essence there is an outer door which comprises a manually operated roller shutter door (this is also the security door). There is then a second outer door and an inner door, both of which are automated fast-acting roller shutter doors. The interlocking system means that the inner fast acting doors cannot open whilst either of the outer ones are open and vice versa. In the event of either fast acting door failing, the manual outer door can be closed. Therefore there is no time when all three doors are open and odorous emissions can occur. PB refers to a 5 minute delay on the outer doors leading to up to 4hrs 20 when the doors are open per day. As detailed above, due to the interlocking system, at no point are all three doors open.

Golder and Shanks both agree that a permit does not provide a guarantee that significant odour releases and/or odour complaints will not occur. The intention of Golders’ statement was to identify that Environmental Permitting is the regulatory regime that releases of odour will be managed under, and under which enforcement action would be taken if required. With respect to the reference to “numerous odour complaints” at Cumbernauld, for clarity it is noted that the Operator is Energen Biogas Ltd in which Shanks is a Joint venture partner and the complaints to the site have been found to be associated with a single source – the bio-filter. This has been managed by the Operator and no enforcement action has been required. The biofilter design has been revised at Pontypool to manage odours more effectively.

PB states that a bio-filter monitoring system is already in place at the Cumbernauld site and that complaints have still been forthcoming. This is not the case; the system has not yet been completed at the site. It is noted that the design for Pontypool includes continuous monitoring for VOC and TNMHC.

PB has identified omissions in the Odour Management Plan (OMP). Golder can confirm that this has been addressed in the EP application and a revised OMP has been provided to the Environment Agency Wales in response to the Schedule 5 Notice for which TCBC will be a consultee. A copy has been attached to this response for clarity.

Response to commentary provided in Table 1:

Potential Odour Pathways. There is no specific requirement to model fugitive emissions in the Defra guidance document1 cited by PB. Instead, the odour impact assessment report guidelines state that a ‘full list of emissions sources should be identified along with how those emissions could reach sensitive receptors’. Shanks/Golder has indeed identified the possibility of fugitive emissions during the operational phase of the development; but has also proposed adequate mitigation measures to minimise these emission sources (e.g. the installation of the air lock doors, the location of all process operations in an enclosed building and under negative pressure etc.) such that they become insignificant and therefore do not require to be included in the model.

In particular, PB refers to the ‘HGVs accessing the site, using the process weighbridge…’ As previously described, incoming waste feed stocks will arrive at the Site in closed waste vehicles from kerbside collections and commercial sources. Vehicles will remain closed during access and weighing processes. The type of vehicles used and the containment methods will be the responsibility of the waste carrier, but will be required to conform with Shanks’ site operational procedures such as the odour management plan.

1Good Practice and Regulatory Guidance on Composting and Odour Control for Local Authorities, Appendix B. Defra, March 2009

Mr Richard Marshall 12514190097.501/2

Torfaen Borough Council 6 November 2012

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PB also refers to ‘emissions occurring from open external doors (4 doors, each alarmed after 5mins delay, 52 vehicle movements per day, equates to 4hrs 20mins of doors open per day’ As described above, there is no time when all three doors [on the main process building] are open simultaneously for significant odorous emissions to occur. The calculation of ‘up to 4hrs 20mins when the doors are open per day’ is in error. The waste reception and handling building will be held under negative pressure (via the extraction to the AHU), such that air will not be able to escape through an open door, and will be fitted with a 3 door air-lock system on all points of access for waste delivery vehicles to further minimise the potential for to air the building through open doors.

As such, following the mitigation measures proposed, it is considered that fugitive emissions from the installation will be insignificant. Therefore they have not been included in the model.

Odour Emissions. An emission concentration of 1,500 OU/m3 was used in the model. This is twice the specification of that in the contractual limit for the equipment to be operated which allows for 95% removal in the biofilter. This is based on Shanks’ experience at other facilities. Measurements have been taken at the output to the biofilter at Cumbernauld and this was approximately 1,100 OU/m3. Additional measurements are currently being taken and can be provided in support of the use of this emission rate. The assumptions made in respect of inlet concentration were made on the basis of measurements of odour in plants operating in the UK and the Netherlands generally between 3,800 and 9,000 OUe/m3. An inlet concentration of 100,000 OUe/m3 was assumed for the storage tank extraction which constitutes 5 % of the total inlet flow. An inlet concentration of 15,000 OUe/m3 was taken as a pessimistic design basis

Odour Emission Rates. As noted in our letter dated 4 October, there are no composting processes undertaken at the ADF site. All relevant transient events (i.e. reception, storage and pre-treatment) will be undertaken within the main building and therefore any fugitive emissions from these processes will be subject to the AHU extraction and treatment system prior to release into the environment through the point source release, as well as mitigated through the use of the interlocking door system. It is queried whether this question is based on inappropriate guidance (i.e. that for composting) which in this case is not applicable and/or relevant to the application.

General Comments

We trust that this information is sufficient to close out the queries, however, should you have any more questions or concerns, please do not hesitate to contact either of the undersigned via the Golder Nottingham Office (01159 371111). Yours sincerely

GOLDER ASSOCIATES (UK) LTD

Rebecca Hodkinson Timothy Fill Senior Environmental Consultant Reviewer Author: Rebecca Hodkinson/RF/TF/xx CC: Ray James, Shanks Attachments: Odour Management Plan, Version A.1

October 2012

PONTYPOOL ANAEROBIC DIGESTION FACILITY - ENVIRONMENTAL PERMIT APPLICATION

Appendix E - Odour Management Plan

REP

OR

T

Report Number. 12514190097.559/A.1

Distribution:

Shanks Waste Management Ltd - 1 copy (pdf) Environment Agency Wales - 1 copy (pdf) Golder Associates (UK) Ltd - 1 copy

Submitted to:Shanks Waste Management Ltd Dunedin House Auckland Park Mount Farm Milton Keynes Buckinghamshire MH1 1BU

ODOUR MANAGEMENT PLAN

October 2012 Report No. 12514190097.559/A.1 i

Table of Contents

1.0 INTRODUCTION ........................................................................................................................................................ 1

1.1 Report Context ............................................................................................................................................. 1

1.2 Objectives ..................................................................................................................................................... 1

1.3 Site Location ................................................................................................................................................. 1

2.0 ODOUR SOURCES PATHWAYS AND RECEPTORS .............................................................................................. 1

2.1 Odour Source Inventory ................................................................................................................................ 1

2.2 Odour Release Inventory .............................................................................................................................. 2

2.2.1 Potentially Odorous Point Source Releases ........................................................................................... 2

2.2.2 Potentially Odorous Fugitive Releases ................................................................................................... 2

2.2.3 Odour Release Pathways ....................................................................................................................... 2

2.3 Sensitive Receptors ...................................................................................................................................... 4

3.0 ODOUR MODELLING ............................................................................................................................................... 4

4.0 DETAILED ODOUR CONTROL MEASURES ........................................................................................................... 5

4.1 Limiting Odorous Materials ........................................................................................................................... 5

4.2 Storage ......................................................................................................................................................... 6

4.3 Operating Parameters .................................................................................................................................. 6

4.4 Odour Abatement Plant ................................................................................................................................ 6

4.5 Maintenance and Monitoring Requirements ................................................................................................. 6

4.6 Odour Action Plan and Routine Contingency Measures ............................................................................... 7

4.7 Abnormal Conditions .................................................................................................................................... 7

4.8 Emergency Conditions .................................................................................................................................. 8

5.0 GENERAL CONTROL MEASURES .......................................................................................................................... 9

5.1 Site Daily Olfactory Monitoring ..................................................................................................................... 9

5.2 Complaints Response ................................................................................................................................. 10

6.0 MANAGEMENT RESPONSIBILITIES ..................................................................................................................... 10

6.1 Organisation ............................................................................................................................................... 10

6.2 Review of Odour Management Plan ........................................................................................................... 11


October 2012 Report No. 12514190097.559/A.1 1

1.0 INTRODUCTION

1.1 Report Context This Odour Management Plan (OMP) has been prepared in support of the Environmental Permit application (hereafter referred to as the ‘application’) being made by Golder Associates (UK) Ltd (Golder) on behalf of Shanks Waste Management Ltd (Shanks) for the development of a new waste management facility at the Pontyfelin Industrial Estate, New Road, Pontypool (hereafter referred to as the “Site”). It has been updated based on the comments received from the Environment Agency via a Schedule 5 Notice dated 4 October 2012.

The proposed facility will comprise a 90,000 tonnes per annum (tpa) capacity Anaerobic Digestion Waste Management Facility (ADF), including biogas fuelled generating plant. The proposed ADF will treat municipal and commercial industrial organic rich food related waste, for the purposes of increasing recycling and recovery.

The principal objective of the OMP is to outline the procedures that will be followed to ensure that potential sources of odour are managed at the Site. This OMP has been written in line with Environment Agency (Agency) Horizontal Guidance H4 – Odour Management issued March 2011 and as such also reflects the requirements of an OMP as stipulated in DEFRA guidance document Odour Guidance for Local Authorities issued March 2010.

1.2 Objectives The OMP has been designed to assist Shanks in meeting the following objectives:

To employ appropriate methods, including monitoring and contingencies to control and minimise odour pollution;

To prevent the occurrence of unacceptable odour pollution; and

To reduce the risk of odour releasing incidents or accidents by anticipating them and planning accordingly.

1.3 Site Location The Site is located at the southern end of the Pont-y-Felin Industrial Estate, approximately 2 km to the south of Pontypool.

The Site is located in a mixed industrial, rural and residential setting, although there are residential receptors located in relatively close proximity. The closest of these is Pont-y-Felin House, located on Pont-y-Felin Lane, approximately 110 m to the northeast of the proposed Site, at a similar elevation. The village of Lower New Inn is located in an elevated position further to the northeast of the Site. The closest residential properties in this village, on Warwick Close, are located approximately 260 m from the Site.

2.0 ODOUR SOURCES PATHWAYS AND RECEPTORS

2.1 Odour Source Inventory The definition of odour ‘sources’ within this OMP includes both materials used on Site which may release odours and process plant items (e.g. biofilters, digestate storage) where odours may be generated.

The potentially odorous sources are identified as follows:

Waste reception at the Process Hall - the points at which solid waste is unloaded from vehicles, and liquid waste is pumped from tankers;



Storage of waste in the Process Hall – solid waste is emptied from vehicles into one of the six available bays in the Process Hall;

Storage of waste outside the Process Hall – liquid waste is unloaded into one of four 54 m3 (pre-pasteurisation) storage tanks;

Treatment of waste outside the Process Hall – following pasteurisation which is applied to the solid waste that has been de-packaged, crushed and screened, the solid and liquid waste is stored in one of two 292 m3 storage tanks whilst it awaits the digestion process. The waste is pumped to one of two 4,000 m3 digesters for treatment, then into a third 4,000 m3 tank;

Treatment of waste within the anaerobic digesters – pressure relief valves are in place. Emissions of odour could occur during shut down or maintenance of the digesters;

External storage of digestate – if de-watering of the digestate is not permitted; the external 5,000 m3 tank (that could otherwise be used for the waste water treatment plant) will be used to store digestate; and

Emissions from the bio-filter – the bio-filter will comprise modified peat or inorganic support material amenable to recycling.

2.2 Odour Release Inventory Transfer of odours from the Site could occur through release to air from the processes and sources given in Section 2.1 (also shown in Drawing EP4 Site Layout Plan), and subsequent atmospheric dispersion. Odour releases identified have been separated into point source (i.e. intentional, forced releases) and fugitive (i.e. unintentional and/or passive releases) below.

2.2.1 Potentially Odorous Point Source Releases

Bio-filter units – if the correct conditions are not maintained (e.g. moisture level) then the bio-filter material (wood bark) can become odorous; and

Emissions from the common wind shield stack.

2.2.2 Potentially Odorous Fugitive Releases

Emissions from spillages of incoming liquid or solid waste;

Emissions from vehicles transporting liquid or solid waste to the ADF or taking solid digestate from the ADF (if de-watering is permitted);

Emissions from anaerobic digesters during shut down or maintenance, via pressure relief valves;

Emissions from loss of containment of liquid waste or digestate from the external storage/treatment tanks (if de-watering is not permitted); and

Emissions from loss of containment of waste in the Process Hall.

Shanks will maintain a detailed odour inventory for the Site which identifies areas/equipment that have the potential to generate odour releases, along with quantities, holding times, and checks. The inventory will be kept up to date as changes are made on the Site.

2.2.3 Odour Release Pathways The aim of this OMP is to control odour generation at Site such that local receptors do not experience significant odours at their properties. The transfer of odours off-Site and towards local residential and commercial properties occurs through release to air and subsequent atmospheric dispersal of the emissions to air.



The prevailing wind direction across Site is from the southwest. This is taken from the wind rose information obtained for the purposes of the Atmospheric Dispersion Modelling (ADM). The nearest meteorological station to the Site is located at the Rhoose Recording Station, Cardiff International Airport which is located approximately 40 km southwest of the Site. Data for years 2007 – 2011 were obtained for the ADM; a copy of the windrose information is provided in Figure OMP1 below for clarity.

A number of sensitive receptors are located downwind of the Site under prevailing wind conditions (see section 2.3 below) and therefore measures will be put in place to control both point source and fugitive odour releases to atmosphere.

2007 2008

2009 2010

2011



2.3 Sensitive Receptors Shanks has identified the following likely sensitive receptors, based on previous experiences when operating the facility that used to be present on the Site:

Residential properties located at Lower New Inn approximately 260 m to the northeast of the Site;

Ponty-y-Felin House, located approximately 110 m to the northeast of the Site;

Members of the public who are walking along the roads and footpaths adjacent to the Site; and

Members of the public driving on the Pont-y-Felin Road.

The sensitivity of the above receptors to odour is dependent upon the nature of the receptor, for example a user of a footpath will be a transient user and therefore the impact of odour is of short duration. However, odour impacting residential receptors, and local business premises (during normal working hours) may be long-term and will therefore be a more significant nuisance.

The weather conditions also have the potential to impact the sensitivity of receptors. Receptors located downgradient of the prevailing wind direction are most sensitive. The prevailing wind direction across the Site is understood to be from the southwest to the northeast. Distance is also a key factor in the dispersion of odours and therefore the key sensitive receptors have been identified as those located within 1 km of the Site.

3.0 ODOUR MODELLING Odour modelling was carried out as part of the ADM for the purposes of the planning application. This is detailed in full in Section 11.7.2 of Appendix ES11.2 and summarised below for clarity.

The ADM predicted that the operation of the bio-scrubber and bio-filter at full input capacity will result in a maximum 98th %ile hourly average odour concentration of 0.56 OUE/m3 at the Site boundary. The assessment concluded that the potential odour impact beyond the Site boundary will be significantly reduced due to effective dispersal of releases from the 30 m high stack and therefore the residual impact of odours emitted from the AHU will be of negligible significance.

A copy of the odour contour plot from the ADM is provided below in Figure OMP2 for reference. The plot shows that emissions are well below the applicable assessment level (1.5 OUE/m3).



4.0 DETAILED ODOUR CONTROL MEASURES The following sections detail procedures on the following:

Limiting odorous materials;

Storage;

Operating parameters;

Odour abatement plant; and

Other maintenance and monitoring requirements.

4.1 Limiting Odorous Materials The Site is a waste management facility, therefore it has the potential to generate odour from the storage of the raw waste materials prior to treatment and the treatment process itself. These activities are integral to the process; however, measures are taken to minimise any odour resulting from the acceptance of waste, for example, waste acceptance procedures are in place to ensure that the Site has sufficient storage capacity to receive the waste and the waste reception area has been designed to store three days’ equivalent waste delivery to allow for weekends and bank holiday periods. Full waste acceptance procedures are provided in Appendix A of the permit application.



4.2 Storage All solid waste will be stored and processed within the Process Hall which is a fully enclosed building. As described in Section B: Process Description, the waste reception bays are fitted with external fast acting roller-shutter doors which will open to allow access for delivery vehicles and close once the vehicle is inside. Once closed, a second fast-acting roller-shutter door will open, providing access to the tipping area. This design ensures that the risk of odour migration is minimised.

In addition, the Process Hall is maintained at a sub-atmospheric pressure through the mechanical extraction of air in order to facilitate the containment and treatment of odour and bio-aerosols. To mitigate odour nuisance further, the air extracted from the Process Hall is treated via a wet scrubber and bio-filter before being discharged to atmosphere via the Site stack. Further details of this system are provided in Section E: BAT Assessment and in Chapter ES3 of the planning application, a full copy of which is provided in Appendix K.

Waste will be delivered in fully contained vehicles which will reduce the likelihood of odour nuisance from the vehicles. Unsuitable waste will be stored within a covered skip in the quarantine area and disposed off Site to an appropriately licensed facility suitable for the specific waste type.

Waste within the reception bays will be transferred as soon as possible for treatment; however, if for any reason it has to be stored in the waste reception bays, it will only be kept there for a maximum of 2 days prior to processing or removal to an appropriately licensed facility; this will limit the potential for odour generation from the storage of the waste.

All storage areas are inspected on a daily basis and cleaning and maintenance is undertaken as required.

4.3 Operating Parameters Each shift has a shift manager who ensures that the treatment process is operating under ‘normal’ conditions. The Site is committed to producing a digestate that is compliant with the PAS110 and ADQP standards, and meeting animal by-products regulations (ABPR) for management of incoming waste, and is committed to operating the process efficiently, accurately and smoothly. This means that the likelihood for accidents or incidents, or abnormal conditions which could lead to an odour release is limited.

4.4 Odour Abatement Plant As detailed in Section 3.2 above, all solid waste is stored and processed within the Process Hall which is a fully enclosed building that is kept under sub-atmospheric pressure. The air extracted from the Process Hall is treated via a wet scrubber and bio-filter before being discharged to atmosphere via the Site stack. The bio-filter material receives the extracted air from a wet scrubber that is used to remove ammonia and dust first, via a dryer which subsequently removes moisture (condensate).

The bio-filter relies on microbial populations present in the moist organic filter media to remove odour and bioaerosols. It is a widely accepted form of emission control at waste management facilities. The bio-filters are irrigated in order to maintain the microbial population and optimum conditions; the filters include a drainage system such that any residual irrigation water is re-circulated into the process.

The scrubber and bio-filter will be subject to regular inspection and maintenance in line with manufacturer guidelines.

4.5 Maintenance and Monitoring Requirements The Site completes daily checks covering elements such as the cleaning of storage and treatment areas, and a general external Site walkover. Although the primary aim of these daily checks is to ensure that operational procedures are being followed, this also provides an opportunity to assess the control and management of odours.

The Site has a thorough maintenance programme which covers all plant at the Site. This ensures that the treatment process operates efficiently and thus reduces the likelihood of malfunction which could lead to an odour release.



During shutdowns lasting up to three days, the management of waste materials will be carefully planned to ensure that the storage of the waste during the shutdown period does not result in an odour release. For longer planned shutdowns, waste will not be received at all. Shutdowns will provide an opportunity to thoroughly clean the process areas, including all equipment and storage areas. These procedures will minimise the likelihood of odour release during shutdown.

The bio-filter system includes an active management system which allows continuous monitoring of pressure, flow and relative humidity. This will ensure that any failure, however minor, will be immediately flagged and appropriate actions can be taken prior to the system experiencing adverse effect which may result in an increase in odorous emissions. The system will also be fitted with a back-up fan and be linked to a 20 m3 buffer tank for irrigation water (a 2 day supply). The bio-filter is preceded by a wet pre-scrubber system to remove hydrogen sulphide. This will have dual redundancy by means of dual hydraulic circuits and pumps which will also maximise the inlet relative humidity up to 100% at the bio-filter.

4.6 Odour Action Plan and Routine Contingency Measures In the event that a significant odour associated with the plant is identified, the following action plan will be instigated:

Inspection of the plant to determine if any abnormal incidents have occurred (e.g. leaks, plant failures) and/or further investigation to determine the cause of the odour release;

If the odour source is arising from the Process Hall, check that air extraction system is functioning properly and that there has been no compromising of waste containment measures;

If the odour source is arising from maintenance works, check that the wind direction is blowing odours away from local receptors. If not, and if practicable, reschedule or safely curtail the maintenance operations until the wind direction enables the work to be undertaken without creating a nuisance to local residents;

If the odour source is stemming from damage to a tank or duct resulting in an odorous release to atmosphere (e.g. infrastructure failure), inspect the storage and treatment tanks and ductwork to determine the release source, shut off valves to stop the release and make repairs;

If the odour source is from general housekeeping, sweep up/rinse away any build up of waste materials or digestate, and conduct olfactory (‘sniff test’) monitoring to ensure that all significant odour sources have been addressed; and

If odour source is stemming from the bio-filters, check that the irrigation system is operating as normal, make repairs if required, and undertake olfactory (‘sniff test’) monitoring to ascertain if repair has stopped emissions.

The key elements of the action plan which are applicable regardless of where the odour incident occurs are as follows:

Investigate the pollution incident and its cause;

Bring the process back under control;

Temporarily or permanently establish or reinstate emissions control; and

Minimise exposure or annoyance effects.

4.7 Abnormal Conditions There is the potential for abnormal conditions to occur which could lead to an odour release. The following are examples of potential abnormal conditions:



Roller shutter door failure:

Control: Fully enclosed waste acceptance area is fitted with a system of airlocks on access points i.e. the two roller shutter doors. In the event of failure of a roller shutter door, the other door will be kept shut until failed door is fixed.

De-packing and Screening Plant failure (in excess of 3 days):

Control: If designated storage areas become full then waste will be transferred for off-site treatment/disposal.

Failure of any mechanical processes:

Control: Temporary cessation of the process if required (unless bypass is available) while repairs are undertaken. If cessation of process is in excess of 3 days, waste will be transferred for off-site treatment/disposal.

Production process operating abnormally leading to excessive odour from the point sources:

Control: Plant regularly maintained and operated within set procedures and operational limits.

Extreme weather conditions such as intense heat, long periods of hot weather or significant periods of cold weather:

Control: During periods of very hot weather extra inspections will be undertaken of the storage and treatment areas to identify if there is a likelihood of an odour release; and

Control: Temperature control of internal waste storage areas. During periods of extreme cold weather, drainage pathways, both internal and external will also be inspected to check for blockages to reduce risk of flooding.

Start up and shut down before and after prolonged outages:

Control: During an outage any waste or part-treated materials will be removed from the treatment areas, and these will be thoroughly cleaned.

In addition to the points above, it is noted that meteorological conditions may also directly affect the operation of the ADF. If such circumstances occur, the following measures will be implemented:

If the ambient temperature is significantly elevated for a prolonged period:

Maintain a consistent temperature of feed water to the Bio-filter; and

Undertake additional cleaning and general housekeeping to ensure that no odorous materials are left externally to the Process Hall.

If the ambient temperature is significantly low (extreme cold weather) for a prolonged period:

Check lagging is in place on all required ductwork and tanks to reduce the risk of freezing within the system; and

Undertake additional housekeeping and infrastructure checks to make sure that ducts/valves have not frozen and/or started to leak as a result of freezing.

4.8 Emergency Conditions There is the potential for emergency conditions to occur which could lead to an odour release. Potential emergency conditions and ways in which they would be mitigated are as follows:



Major spill: e.g. solid waste delivery vehicle accidentally spilling large volume of a strong smelling material. This would lead to a significant fugitive release either within or outside of the Process Hall:

Action: Spill would be immediately cleaned up to prevent the odour becoming a significant release.

Loss of treatment process control/overload:

Action: Cease waste feed, or limit to an appropriate level in order to minimise flow through the treatment plant;

Shut down all non-critical processes and investigate reason for loss of process control; and

Regain full process control prior to commencing operations again.

Fire:

Action: Cease treatment (if safe to do so) and evacuate buildings. When safe to return to the buildings and as appropriate, undertake full clean down and thoroughly check the systems for fire damage. Once systems are returned to fully operational state, commence operations.

Flooding:

If flood waters enter (or are likely to enter) Site, sound fire alarm and evacuate all personnel;

Alert emergency services;

If safe to do so, begin controlled shutdown of plant, equipment and utilities;

If safe to do so (and only once roll call complete) allow staff to leave site in own vehicles; and

Follow instructions from emergency services.

5.0 GENERAL CONTROL MEASURES

5.1 Site Daily Olfactory Monitoring The Site Manager will be responsible for designing and implementing an appropriate monitoring regime for odour measurement. As part of this, Shanks will undertake a daily olfactory assessment of identified external treatment process areas and downwind boundary locations, having particular regard to the direction of sensitive receptors. The daily walkover ‘sniff test’ will be carried out by a designated member of staff not regularly involved in odour generating operations (i.e. unlikely to have become desensitised to the smells) and will follow the general format of the Agency H4 ‘FIDOR’ olfactory assessment method, with Site specific alterations as detailed below.

The FIDOR acronym is a useful reminder of the factors that will determine the degree of odour pollution:

Frequency of detection;

Intensity as perceived;

Duration of exposure;

Offensiveness; and

Receptor sensitivity.

Of these parameters, the frequency and duration of the odour will be assessed from the results of the daily odour monitoring records.



The intensity of the odour will be categorised as given in the H4 Guidance:

1) No detectable odour;

2) Faint odour (barely detectable, need to stand still and inhale facing into the wind);

3) Moderate odour (odour easily detected while walking and breathing normally);

4) Strong odour (bearable, but potentially offensive odour – will clothes/hair smell?);

5) Very strong odour (potentially offensive odour that will make clothes/hair smell); and

6) Extremely strong odour (very offensive level of odour - possibly causing nausea).

The offensiveness of the odours generated on Site is considered to fall in the Moderately Offensive category outlined in the H4 guidance. Data from the daily monitoring will be used to identify processes on Site which may need attention and so instead of further detail on offensiveness level, a note will be made as to the ‘type’ of odour.

Receptor sensitivity will not be assessed on an individual basis as the odour monitoring will be limited to on-Site sniff testing. As such, the ‘receptor sensitivity’ will be taken as standard – any identified odour with the potential to generate off-Site odour will be counted as significant.

The date, time and duration of the assessment shall be recorded, together with the above descriptors. The results of the olfactory monitoring will be recorded on a daily odour monitoring report form (based on the form given in Appendix 1 to the H4 guidance).

In the event that an odour complaint is received, additional odour monitoring and assessment shall be undertaken by the designated staff member (or nominated deputy).

5.2 Complaints Response If odour complaints are received from members of the public either directly to Site or via the Agency or the Local Authority, these will be investigated immediately during normal operating hours or immediately first thing on the next working day if received out of hours. Upon receiving a complaint an odour complaint report form’ (based on that given in Appendix 1 of the H4 guidance) will be completed and escalated to the appropriate person for action and recording on the Shanks system.

Upon receiving a complaint the Site Manager (or designated deputy) will inform the Agency via email. In assessing the complaint, Shanks will consider whether:

The process is under control; or

Odour containment abatement measures have failed

Results from the investigation of complaints will be reviewed and actions taken as necessary. The odour controls implemented and the OMP will be reviewed and amended if necessary following the outcome of the complaints investigation. Measures taken to look into the complaint, identify the source and rectify the situation will be communicated to the complainant in line with Shanks’ complaints handling procedure.

6.0 MANAGEMENT RESPONSIBILITIES

6.1 Organisation A Management Organogram is presented in Appendix I of the permit application. The Operations Manager and Facility Manager have responsibility for odour management at the Site. The Management Organogram also identifies those within the company who have direct impact on odour control, for example the assistant ADF Manager, Supervisors and Operators.



It is recognised that all employees have a responsibility to maintain odour control; and as such odour minimisation training will be undertaken. All employees will be aware of potential odour releases and relevant mitigation measures that are related to their individual jobs.

6.2 Review of Odour Management Plan The OMP will be reviewed on an annual basis and will also be reviewed following any of the following:

A change in the treatment process;

Introduction of any new odour abatement;

Introduction of a new odour source to the Site (for example new raw material);

Modification to buildings for example extensions;

Change in operational layout of the Site for example a change in the location of treatment operations, change in location of waste storage area etc.;

Receipt of a justifiable complaint; and

Failure of odour abatement measures.


October 2012 Report No. 12514190097.559/A.1

Report Signature Page

GOLDER ASSOCIATES (UK) LTD

Rebecca Hodkinson Timothy Fill Senior Environmental Consultant Reviewer

Date: 25 October 2012

Author: Rebecca Hodkinson/RF/TF/ab

Company Registered in England No.1125149

At Attenborough House, Browns Lane Business Park, Stanton-on-the-Wolds, Nottinghamshire NG12 5BL

VAT No. 209 0084 92

Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation.

Golder Associates (UK) Ltd

Cavendish House

Bourne End Business Park

Cores End Road

Bourne End

Buckinghamshire

SL8 5AS

UK

T: [+44] (0) 1628 851851

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