Environmental Hazards and Emergencies Department CRCE Chilton Bristol 2 Rivergate Temple Quay Bristol, BS1 6EH

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Dr Chitra Arumugam Avon, Gloucester and Wiltshire Public Health England Centre Public Health England

23 April 2013

Dear Dr Arumugam,

Re: Gloucestershire County Council Planning and Development Unit Application Number 13/0017/TWMAJM Location: Land adjacent to Page’s Lane, Church End, Twyning

Thank you for sending me the above planning application which has been sent to us by Gloucestershire County Council. There have been a number of concerns raised by local residents in regards to dust from the site and its impact on health and the alleged anthrax infected carcasses buried on the site.

Proposal

The application is for the extraction of 98,000 tonnes of sand and gravel and the restoration to agriculture, amenity and nature conservation use. The total area of the application is 4.28Ha and the entire development is predicted to be completed within 2.5 years. The land forms part of a field of arable agricultural land and located 1km south west of Twyning and 3km to north of Tewkesbury.

There are a number of residential properties in close proximity to the development and 10 have been identified within 100m with the closest property being located 45m from the soil stripping and storage area and 60m from the mineral extraction location

Dust

The applicant has referenced that dust may be generated but is expected to be coarse and not prone to dust generation. In addition the activity will be undertaken in a naturally moist environment and during excessive dry weather periods roadways and stockpiles will be sprayed with water.

The mineralogy report that accompanies the application was produced in 1984/1985 and notes that the results of chemical analysis from the 10 boreholes show the sand fraction to be at least 90% with majority of remainder comprising aluminium and iron oxides derive from its clay formation.

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This type of activity is likely to produce course dust with mineral component including aluminium, silicon, iron and calcium and particulates (PM10 and PM2.5). It is documented that dust (particulate matter) can be produced in high concentrations nearby to these sites undertaking this activity1. I have reviewed the planning application documents and have noted that the applicant has not included any detailed information relating to a monitoring regime required to assess the levels of dust being generated by on site activities, including the high volume of vehicle movement for the transport of extracted materials (which has been calculated as one vehicle every 5 minutes). Also, the application does not provide any detailed dust management plans which are critical in order to prevent dust generated on site migrating off site and depositing nearby with the potential to become a public health nuisance. Therefore the applicant should produce and have agreed a particulate and dust deposition assessment and management scheme to ensure that public health and amenity is protected. The scheme should identify potential dust generating activities and assess their impact including when soil stripping, extracting the minerals, movement of the mineral on site, processing of the mineral, wind erosion from dry, un-vegetated surfaces and vehicle movements.2 The Regulator should be satisfied that the dust management plan put in place mitigates against the identified potential risks for dust generation on site. Particulate matter (PM10) air pollution is associated with a range of effects on health including effects on the respiratory and cardiovascular systems, asthma and mortality. These effects are explored in detail in reports from the Department of Health’s independent expert Committee on the Medical Effects of Air Pollutants (COMEAP)3, and the Expert Panel on Air Quality Standards (EPAQS)4. Both short and long term exposure to particulates can cause the most serious health problems among those susceptible groups with pre-existing lung or heart disease and/or the elderly and children.5 A number of objections have been made to the Planning and Development Unit about the dust contributing to an already increased incidence of respiratory disease in the area. The Public Health Unit and Director of Public Health within Gloucestershire County Council should be able to confirm and quantify whether this location does have an increased incidence of respiratory disease and can assist the planning unit in responding to these concerns. Anthrax

Anthrax is a bacterial infection caused by the organism Bacillus anthracis. The disease occurs most often in wild and domestic animals in Asia, Africa, and parts of Europe: humans are rarely infected. The bacterium can exist in a form known as a spore which allows survival in the environment (for example, in the soil).6

Anthrax is not a chemical and therefore we would recommend you contact the Public Health England Specialist Pathogen Reference Unit in Porton Down, who are the

most appropriate qualified persons for advising on the risks posed by anthrax spores.

Public Health England does not hold any records on the location of historical burial pits and the Local Authority Contaminated Land Officer should be contacted to confirm whether they have any records of this. In the absence of any confirmed data we would suggest that a method statement is prepared to activate in the event of an agricultural animals carcass being identified during the excavation. There are three usual forms of human disease depending on how infection is acquired: cutaneous (skin), inhalation and ingestion. In over 95% of cases the infection is cutaneous, generally caught by direct contact with the skins or tissues of infected animals. Inhalation anthrax is rare and is caught by breathing in anthrax spores.6

The method statement should include a risk assessment that will assess the occupational and public exposure at and near the site and include a sampling methodology, identified remedial options and a management plan to minimise off site deposition. This will need to be reviewed and approved by the local Authority Contaminated Land Officer and Health and Safety Executive.

In addition, a risk communication protocol should be developed to inform and address any concerns that local residents near the site may have and provide appropriate reassurance to minimise any concerns relating to the site, especially in the case of observing workers in Personal Protective Equipment, which can prove to be worrying for some people.

Yours sincerely

Charlotte Landeg-Cox Environmental Public Health Scientist E [EMAIL ADDRESS]

Reference

1

Monitoring of particulate matter in ambient air around waste facilities, Technical Guidance Document M17. The Environment Agency, 2004.

2

Minerals Policy Statement 2: Controlling and Mitigating the Environmental Effects of Mineral Extraction in England, Office of the Deputy Prime Minister, 2005.

3 Committee on the Medical Effects of Air Pollutants (2001) Long term effects of particles on mortality.

4 Expert Panel on Air Quality Standards (EPAQS) 1995. Particles (London, TSO)

5Air Quality Expert Group ( 2005) Particulate Matter in the United Kingdom. Summary.

6 Health Protection Agency. Anthrax http://www.hpa.org.uk/Topics/InfectiousDiseases/InfectionsAZ/Anthrax/GeneralInformation/anthr010BackgroundInformation/

Linda Townsend Gloucestershire County Council Development Management Planning Shire Hall Westgate Street Gloucester GL1 2TH

18 July 2014

Dear Ms Townsend,

RE: Planning Consultation 13/10017/ TWMAJM for mineral extraction at Page Lane, Church End Twyning.

Thank you for your link to the DustScan Air Quality and Dust Assessment undertaken for Moreton C Cullimore (Gravels) Ltd in February 2014 which was undertaken in response to the initial comments 23rd April 2013. PHE’s Environmental Hazards division has reviewed the report and have made the following comments:

The air quality sections in this report relate to a desk top assessment using data from the DEFRA national annual estimated average background concentrations and the monitoring data from Crown Farm Quarry in Cheshire to calculate a predicted environmental concentration (PEC) of (16µg/m3). The PEC should be assessed by the Local Authority to ensure that it includes all potential local sources including commercial and agricultural and does not exceed Air Quality Standards in this locality. UK Air Quality Standards exist to be protective of all persons and therefore

would include sensitive receptors.

We continue to be concerned that local residents will be impacted by the dust being produced by activities at the site due to their close proximity and the intended activities however the assessment has included passive dust monitoring and a management plan for minimising off site impacts from the site and its activities. The directional gauge and deposition gauge monitoring cannot be used for assessing inhalation/exposure risk as although this type of monitoring can be useful in determining nuisance risk through the identification of types of particles present in the deposited material, the analysis does not provide any information in relation to particle size, deposition velocity nor the concentration in the atmosphere that would be used to assess any potential exposure risk to public health by comparison with health based standards and guidelines.

Avon, Gloucestershire and Wiltshire Public Health

England Centre

1st Floor, 2 Rivergate

Temple Quay, Bristol, BS1 6EH

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The activities on site may be exempt or have quantities below the threshold to require an environmental permit and therefore controlling the emission off the site or from activities needs to be controlled through other mechanisms and ensure adequate assessments or monitoring capabilities are considered and implemented.

On reviewing the assessment I have noted that:

A subjective assessment will be undertaken by the operator for visible dustemissions however more continuous or quantitative dust monitoring may berequired to provide an assessment in the event of substantiating dust beyond

the boundary of the site.

High levels of housekeeping needs to be maintained at the site at all times tominimise production of dust

Comprehensive baseline dust monitoring which was undertaken should not beused to define the baseline monitoring levels or used to set dust triggerthreshold levels because the excessively wet weather experienced during themonitoring period will not be providing the operator with an accurate baselineof the existing conditions.

Operator may wish to consider how they can engage with the community toensure any issues are identified early and addressed to prevent escalation ofcommunity concerns

A number of objections have been made to the Planning and DevelopmentUnit about the dust contributing to an already increased incidence ofrespiratory disease in the area. The Public Health Unit and Director of PublicHealth within Gloucestershire County Council should be able to confirm andquantify whether this location does have an increased incidence of respiratorydisease and can assist the planning unit in responding to these concerns.

In conclusion we continue to have concerns about the impact the activities and the site may have on local residents and have made the above observations for consideration by the applicant and the Local Authority

Please do not hesitate to contact me if you require anything further.

Yours sincerely

Dr Chitra Arumugam

Avon Gloucestershire and Wiltshire, Public Health England Centre

Cc: Sarah Scott, Consultant in Public Health Gloucestershire County Council, Shire Hall, Westgate Street, Gloucester, GL1 2TH

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