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GFE GF Environmental Limited

8 Alcotts Green Sandhurst

Gloucester GL2 9PE

T +44 (0) 1452 730240 F +44 (0) 1452 730240

[email protected] www.gf-environmental.co.uk

GF Environmental Ltd

22nd April 2014

Re: An Assessment of the Potential Impact on Local Wildlife Sites of Pollutant Emissions from Proposed Power Generation Developments to be Built on the Welland Waste Management Site Near Theddingworth

Introduction Welland Waste Management Ltd (WWM) has applied for planning permission to build a Thermophilic Aerobic Digestion (TAD) Facility on the Pebble Hall site to the south-west of Theddingworth, Leicestershire. An application has also been submitted to modify the planning permission for a Renewable Energy Generation Facility (REGF) on adjoining land on the WWM site. Consultation comments received from Northamptonshire County Council requested additional information on the potential cumulative impact of pollutant emissions from the proposed TAD facility and REGF on local wildlife sites, situated with 2km of the proposed development site. The following wildlife sites were identified using the MAGIC website1.

1. Unnamed Deciduous Woodland BAP Priority Habitat; 2. Spring Hollow Deciduous Woodland BAP Priority Habitat; 3. Nichol’s Hill Spinney Deciduous Woodland BAP Priority Habitat; 4. Hothorpe Hill Barn-Hill Spinney Deciduous Woodland BAP Priority Habitat; 5. Unnamed Deciduous Woodland BAP Priority Habitat 2; 6. National Inventory of Woodland & Trees Habitat; and, 7. Damside Spinney Deciduous Woodland BAP Priority Habitat.

The location of these local wildlife sites in relation to the proposed development site are shown in the following map, reproduced from the MAGIC website.

The location of the Welland Waste Management site is denoted by the red star.

1 http://www.natureonthemap.naturalengland.org.uk/MagicMap.aspx

1 2

5

3

4

6

7


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Basis for Assessment The potential cumulative impact on local ecological habitat sites, due to emissions from the proposed TAD facility and REGF, has been assessed in terms of the maximum process contributions for the following pollutants in relation to their respective Critical Levels, and associated time averaging periods, as specified in Table B4 of Environment Agency Horizontal Guidance Note H1 Annex F:

• Oxides of nitrogen (NOX) 30 µg m-3 as an annual average; • Oxides of nitrogen (NOX) 75 µg m-3 as a daily average; • Sulphur dioxide (SO2) 20 µg m-3 as an annual average; • Ammonia (NH3) 1 µg m-3 as an annual average for lichens and bryophytes; • Hydrogen fluoride (HF) <5 µg m-3 as a daily average; and, • Hydrogen fluoride (HF) <0.5 µg m-3 as a weekly average.

The assessment also considered the potential cumulative impact of emissions from the proposed TAD facility and REGF on the local wildlife sites in relation to site-specific critical loads for nitrogen and acidity deposition, obtained from the UK Air Pollution Information System (APIS) website2.

Critical Levels Assessment An assessment of the impact of emissions from the proposed TAD facility and REGF on local wildlife sites has been undertaken in relation to the above Critical Levels. The results are presented in the following table.

Table 1 Critical Levels Assessment for Oxides of Nitrogen (NOX) and Sulphur Dioxide (SO2)

Annual NOx PC (µg m-3)

% Critical Level

Daily NOx PC (µg m-3)

% Critical Level

Annual SO2 PC (µg m-3)

% Critical Level

Unnamed Deciduous Woodland BAP Priority Habitat 1.7 6% 26 35% 0.4 2%

Spring Hollow Deciduous Woodland BAP Priority Habitat 1.1 4% 18 24% 0.3 1%

Nichol’s Hill Spinney Deciduous Woodland BAP Priority Habitat 0.6 2% 9 11% 0.1 1%

Hothorpe Hill Barn-Hill Spinney Deciduous Woodland BAP Priority Habitat 0.4 1% 6 8% 0.1 1%

Unnamed Deciduous Woodland BAP Priority Habitat 2 3.2 11% 65 87% 0.8 4%

National Inventory of Woodland & Trees Habitat 1.1 4% 36 48% 0.3 1%

Damside Spinney Deciduous Woodland BAP Priority Habitat 4.1 14% 36 47% 1.0 5%

As can be seen in the above table, the annual average NOX Process Contribution is between ~1% and ~11% of the annual NOX Critical Level at the above local wildlife sites. The APIS website indicates that the existing annual average NOX concentration in the vicinity of the Welland Waste Management site is 11.3 µg m-3. Therefore, the Predicted Environmental Concentration due to emissions from the proposed TAD facility and REGF is likely to be ~12 to ~15 µg m-3, and well within the critical level value of 30 µg m-3. Accordingly, process contributions in relation to the annual NOX critical level can be screened out as insignificant at the above locations.

Annual average SO2 process contributions were all ~1% to ~5% of the 20 µg m-3 Critical Level, with an estimated background concentration of ~1.4 µg m-3, there is little risk of exceeding the annual average critical level for SO2.

The daily average NOX Process Contributions were estimated to be between ~10% to ~90% of the Critical Level value of 75 µg m-3. With an estimated annual average background concentration of ~11 µg m-3, there is little risk of exceeding the annual average critical level for NOX at all but Receptor 5, where a marginal exceedence could potentially occur. However, it should be borne in mind that the assessment is based upon a series of worst case assumptions with NOX emissions at the maximum emission limit value for the TAD facility and REGF. When operational, emissions of NOX will be well

2 http://www.apis.ac.uk/search-by-location


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below the emission limit values prescribed in the respective environmental permits for each of the two facilities.

The corresponding process contributions for ammonia and hydrogen fluoride are based upon an assumed ammonia concentration in the emissions to atmosphere of 2 mg Nm-3, and for HF emissions from the REGF at the IED ELV of 1 mg Nm-3. The results are presented in the following table.

Table 2 Critical Levels Assessment for Ammonia (NH3) and Hydrogen Fluoride (HF)

Annual NH3 PC (µg m-3)

% Critical Level

Daily HF PC

(µg m-3)

% Critical Level

Weekly HF PC

(µg m-3)

% Critical Level

Unnamed Deciduous Woodland BAP Priority Habitat 0.02 2% 0.13 2.6% 0.06 12%

Spring Hollow Deciduous Woodland BAP Priority Habitat 0.01 1% 0.09 1.8% 0.04 7%

Nichol’s Hill Spinney Deciduous Woodland BAP Priority Habitat 0.01 1% 0.043 0.9% 0.017 3%

Hothorpe Hill Barn-Hill Spinney Deciduous Woodland BAP Priority Habitat 0.004 0.4% 0.031 0.6% 0.013 3%

Unnamed Deciduous Woodland BAP Priority Habitat 2 0.03 3% 0.33 6.5% 0.17 34%

National Inventory of Woodland & Trees habitat 0.01 1% 0.18 3.6% 0.03 7%

Damside Spinney Deciduous Woodland BAP Priority Habitat 0.04 4% 0.18 3.6% 0.08 15%

As can be seen, Process Contributions of ammonia and hydrogen fluoride are well below their respective Critical Levels at all of the above local wildlife sites, and can be screened out as insignificant. The assessment for ammonia was based upon the lower critical level of 1 µg m-3 for lichens and bryophytes.

Deposition Assessment Relative to Site-Specific Critical Loads Critical load data for nitrogen deposition at the local wildlife site locations were obtained from the APIS website and are summarised in Table 3.

Table 3 Baseline Critical Loads for Nitrogen Deposition

Receptor Critical Load (kgN/ha/yr) Baseline Condition (kgN/ha/yr)*

“Headroom” (kgN/ha/yr Low Limit High Limit Low Limit High Limit

Unnamed Deciduous Woodland BAP Priority Habitat 10 20 44.4 -34.4 -24.4

Spring Hollow Deciduous Woodland BAP Priority Habitat 10 20 44.4 -34.4 -24.4

Nichol’s Hill Spinney Deciduous Woodland BAP Priority Habitat 10 15 44.4 -34.4 -24.4

Hothorpe Hill Barn-Hill Spinney Deciduous Woodland BAP Priority Habitat

10 15 44.4 -34.4 -24.4

Unnamed Deciduous Woodland BAP Priority Habitat 2 10 20 44.4 -34.4 -24.4

National Inventory of Woodland & Trees habitat 10 20 44.4 -34.4 -24.4

Damside Spinney Deciduous Woodland BAP Priority Habitat 10 20 44.4 -34.4 -24.4

Note: Negative values denote that the critical load is currently exceeded

As can be seen, the data from the APIS website indicate that the Critical Load for nitrogen deposition is currently exceeded at all of the above ecological habitat receptor locations. However, there is no information available in the literature on whether the ecological habitats are suffering significant harm as a result of the current exceedence of the critical load for nitrogen deposition.

The situation for acidity deposition is somewhat different, as shown in Table 4.


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Table 4 Baseline Critical Loads for Acidity Deposition

Receptor Name Acidity Critical Load (keqN/ha/yr)

Background (keqN/ha/yr)

Headspace (keqN/ha/yr)

Acidity Critical Load (keqS/ha/yr)

Background (keqS/ha/yr)

Headspace (keqS/ha/yr)

Unnamed Deciduous Woodland BAP Priority Habitat

2.65 3.17 -0.52 2.29 0.29 2.0

Spring Hollow Deciduous Woodland BAP Priority Habitat

2.65 3.17 -0.52 2.29 0.29 2.0

Nichol’s Hill Spinney Deciduous Woodland BAP Priority Habitat

2.65 3.17 -0.52 2.29 0.29 2.0


8.67 3.17 5.5 8.31 0.29 8.0

Unnamed Deciduous Woodland BAP Priority Habitat 2

2.9 3.17 -0.27 2.54 0.29 2.3

National Inventory of Woodland & Trees habitat 2.9 3.17 -0.27 2.54 0.29 2.3

Damside Spinney Deciduous Woodland BAP Priority Habitat

2.65 3.17 -0.52 2.29 0.29 2.0

As can be seen, the data indicate that the critical load for acid deposition (keqS/ha/yr) is currently not exceeded at any of the above locations, although the critical load for acid deposition as N is marginally exceeded at most locations..

The ADMS model was configured to estimate deposition of NO2, NH3, SO2, HCl and HF at the local wildlife sites, due to emissions from the proposed TAD facility and REGF.

The deposition velocities for NO2, SO2, NH3 and HCl were taken from AQTAG 063, while the corresponding value for HF was obtained from a literature reference (see below).

Table 5 Deposition Velocities Used in Calculations

Substance Deposition Velocity (mm/s) Nitrogen Dioxide (Grassland) 1.5 Nitrogen Dioxide (Woodland) 3.0 Sulphur Dioxide (Grassland) 12.0 Sulphur Dioxide (Woodland) 24.0 Ammonia (Grassland) 20.0 Ammonia (Woodland) 30.0 Hydrogen Chloride (Grassland) 25.0 Hydrogen Chloride (Woodland) 60.0 Hydrogen Fluoride (Grassland)* 2.0 Note: * Reference: Fluorides in the Environment, Weinstein, LH and Davison, AW, CABI Publishing (2004)

Nitrogen Deposition

An assessment of nitrogen deposition was undertaken in relation to site-specific Critical Loads data, obtained from the APIS website, and summarised in Table 3. Nitrogen deposition rates associated with emissions from the proposed TAD facility and REGF were calculated according to the method recommended by the Environment Agency in AQTAG 06, and as used by Laxen and Marner in a study carried out in support of the development of the Dorset and Poole, Local Waste Plan4. The method involves the calculation of the annual deposition rate from the annual Process Contribution and the deposition velocity for NO2 using Equation 1.

3 AQTAG 06, Technical Guidance on Detailed Modelling Approach for an Appropriate Assessment for Emissions to Air, Ji Ping Shi, Environment Agency Air Quality Monitoring and Assessment Unit, 20th April 2010. 4 An Assessment of Possible Air Quality Impacts on Vegetation from Processes Set out in the Bournemouth, Dorset & Poole Waste Local Plan, Air Quality Consultants Ltd, April 2005


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Equation 1 Calculation of Deposition Rate

Laxen and Marner commented that NOX deposits to vegetation mainly via uptake of nitrogen dioxide through stomata, and that nitric oxide does not deposit at a significant rate. Environment Agency guidance recommends using a factor of 70% for the conversion of NOX to NO2 to provide a worst case basis for assessment of long term impacts5. Accordingly, this conversion rate was used as the basis for calculating the nitrogen deposition rates associated with emissions of NOX and NH3 from the proposed TAD facility and REGF. Only dry deposition was considered by Laxen and Marner as wet deposition effects, close to the point of release, are considered to be much less significant than dry deposition mechanisms.

Wet deposition of the emitted pollutants this close to the emission source will be restricted to wash-out, or below cloud scavenging. For this to occur, rain droplets must come into contact with the gas molecules before they hit the ground. Falling raindrops displace the air around them, effectively pushing gasses away. The low solubility of nitrogen dioxide and nitric oxide means that any scavenging of these gases will be a negligible factor.

The results from the nitrogen deposition rate calculations are summarised in the following table and are based upon emissions of NOX and NH3 from the proposed TAD facility and REGF.

Table 6 Process Contribution to Nutrient Nitrogen Deposition at Local Wildlife Sites

Receptor Name Deposition (kgN/ha/yr)

Deposition (kgN/ha/yr) (PC as % Lower Critical

Load) Unnamed Deciduous Woodland BAP Priority Habitat 0.5 5% Spring Hollow Deciduous Woodland BAP Priority Habitat 0.3 3% Nichol’s Hill Spinney Deciduous Woodland BAP Priority Habitat 0.2 2% Hothorpe Hill Barn-Hill Spinney Deciduous Woodland BAP Priority Habitat 0.1 1%

Unnamed Deciduous Woodland BAP Priority Habitat 2 0.9 9% National Inventory of Woodland & Trees Habitat 0.3 3% Damside Spinney Deciduous Woodland BAP Priority Habitat 1.2 12%

The results show that nitrogen deposition attributable to emissions of NOX and NH3 from the proposed TAD facility and REGF plant is predicted to be less than 10% of the site-specific Lower Critical Load, apart from the nearest downwind receptor location (Damside Spinney), where the Process Contribution represents ~12% of the Critical Load. Despite the fact that the Critical Load for nitrogen deposition is currently exceeded at the above locations, the magnitude of the Process Contribution is small and is probably not measurable with any reasonable degree of accuracy, and can probably be screened out as insignificant.

It should also be noted that exceedence of a Critical Load is not a quantitative estimate of damage to a particular habitat, but represents the potential for damage to occur. There is no evidence in the available literature to indicate that the above local wildlife sites are suffering as a consequence of nitrogen deposition from nearby sources. Accordingly, on this basis, the incremental increase in nitrogen deposition attributable to emissions of NOX and NH3 from the proposed TAD facility and REGF is small and is unlikely to have a measurable effect on the integrity of the above ecological habitat sites.

Acid Deposition

An assessment of acidity deposition was undertaken based upon Critical Load data for acid deposition from the APIS website. The assessment followed the same procedure that was used in the assessment of nitrogen deposition, and the results are summarised in Table 7.

5 http://webarchive.nationalarchives.gov.uk/20140328084622/http://www.environment-agency.gov.uk/static/documents/Conversion_ratios_for__NOx_and_NO2_.pdf

€

Deposition Rate µg m-2s-1( )= Deposition Velocity m s-1( ) × Concentration µg m-3( )


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Table 7 Process Contribution to Acid Deposition at Local Wildlife Sites

Receptor Name

Increase in Acidity Deposition Due to

Emissions of NOX & NH3

(keqN/ha/yr)



(% Critical Load)


Emissions of SO2, HCl & HF (keqS/ha/yr)

Increase in Deposition Due to Emissions of

SO2, HCl & HF (% Critical Load)


0.03 1.3% 0.1 6%


0.02 0.8% 0.1 4%


0.01 0.4% 0.05 2%


0.01 0.1% 0.03 0.4%


0.06 2.2% 0.3 11%

National Inventory of Woodland & Trees habitat

0.02 0.7% 0.1 4%


0.08 3.1% 0.1 6%

The above results show that acidic deposition attributable to emissions of NOX and NH3 from the proposed TAD facility and REGF is predicted to be between <1% and ~3% of site-specific Critical Load values, and are probably not measurable with any reasonable degree of accuracy. The situation is slightly different where the process contributions are of a similarly low value, but as the critical load value is lower, the process contributions represent a greater percentage of the critical load.

Nevertheless, there is no evidence in the available literature to indicate that the above ecological receptors are currently suffering as a consequence of acid deposition from nearby sources, accordingly, acidity deposition at the above local wildlife sites can be screened out as insignificant.

Conclusions The results from a detailed assessment of the impact of emissions from the proposed TAD facility and REGF on nearby local wildlife sites showed that critical levels and site-specific critical load values for nitrogen deposition are currently exceeded at the receptor locations considered.

Maximum process contributions for NOX, SO2, NH3 and HF were well below their respective critical levels and were screened out as insignificant. Similar conclusions were drawn for maximum process contributions to nitrogen and acidity deposition in relation to relevant site-specific critical load.

There is no evidence available in the literature to indicate that current exceedences of critical levels and critical loads are causing observable or measurable harm to the local wildlife sites in the vicinity of the Welland Waste Management site. Accordingly, it is concluded that emissions from the proposed TAD facility and REGF are unlikely to have a significant impact on local wildlife sites in the vicinity of the development site.

Via e-mail Geoff Fynes

EHO RESPONSE

EHO Response 16 April 2014 1

Response to Daventry District Council’s Environmental Health Officer on the

Proposed TAD Facility at Pebble Hall, Theddingworth

Introduction

This document seeks to provide a response to the consultation comments made by Daventry District’s Senior Environmental Officer. While it is acknowledged that Daventry District Council do not object the TAD application, this statement seeks to clarify some issues raised in the response.

Drainage

Once planning permission has been granted and the Applicant is in active discussions with the Environment Agency regarding the Bespoke Environmental Permit, the Applicant will fill out the FDA/1 (Foul Drainage Assessment Form) in order to determine whether mains drainage is unacceptable.

Dust

The Highway Authority has confirmed that there will be a reduction in traffic as a result of this proposal thus reducing the risk from dust as a result of vehicle movements. However, the Applicant is happy to accept a condition to add a water bowser to the site for use when necessary.

Air Quality

Harborough District Council and Daventry District Environmental Health Officer have raised concerns in relation to the air quality within Theddingworth village. Attached is a supplementary statement assessing the impact on Theddingworth Village and concluding that there will be no adverse effect. Gareth Rees, the Contaminated Land Officer at Harborough District Council, has confirmed that this information “is sufficient to address concerns regarding air quality in Theddingworth”.

Odour

The Applicant has prepared a summary note on odour, which is appended to this note. This was submitted to Northamptonshire County Council in order to bring together information into one document on the odour control mechanisms proposed for the TAD facility. Concerns have been raised relating to the adequacy of the existing building for a closed air system.

The processing and reception building will be insulated with “cold store” type panels. These will further enhance the building to become air tight. The applicant would be happy to accept a condition

requiring the building to be made airtight and a smoke test to be carried out prior to the commencement of development. This would significantly reduce the possibility of odour leaking from the building. It is not proposed at this stage to fit the building with a double door/air lock system. The building will be fitted with a fast acting roller shutter door. The door will open in 12 seconds, the vehicle will enter in 30 seconds and the door will close in 12 seconds. This will make each opening less than 1 minute. As there will only be 32 trips per day associated with the TAD operations, the doors will be open for no more than 32 minutes each day, spread out over the 11 hour working day. It is understood that good odour management is essential to ensuring that no odour nuisance is caused. This will be controlled through the Environmental Permit. The Applicant is willing to accept the condition relating to complaints but requests that the wording of the proposed condition is alter to include the word “substantiated”.

EHO RESPONSE

EHO Response 16 April 2014 2

“In the event that substantiated complaints regarding odour, noise, lighting and/or dust (including bioaerosols) are received…” The Applicant would like to confirm the following:

All materials will be delivered in covered vehicles. No putrescible or food based waste will be placed in the quarantine skip, which will be

covered at all times.

The end product from the TAD system will be stored under cover. All plant and machinery will be serviced and maintained in accordance with the

manufacturer’s instructions.

The doors to the building will be closed at all times unless allowing access/egress of delivery vehicles.

Noise

A revised report by Sound Barrier Solutions, dated 20th March 2014, has been submitted as part of the application. It is hoped that this, along with the covering letter, also dated 20th March 2014, will alley the concerns raised in the consultation response. It should be noted that the proposed noise barrier has now been withdrawn from the proposed development. This is due to the fact that its purpose was to reduce noise generated from the HGV traffic. As the proposed HGV traffic will be less than the consented amount, the barrier is not considered necessary. If the planning authority still considers it to be necessary, it could be required under a planning condition.

Advanced Organics Ltd, Longmoss, Geeston Road, Ketton, Rutland, PE9 3RH – 07595 828 950 Company No. 8392843

Northampton County Council

Planning Services Department

Floor 3

Guildhall Road Block

County Hall

Northampton

NN1 1DN

Attention – Mr Peter Moor and Mr Phil Watson

Date - 8th April 2014

Ref - 13.00117.WASFUL

Subject – Odour Control Measures Proposed as Part of the Planning Application for the

TAD Facility to be built at Pebble Hall Farm, near Theddingworth, Leicestershire.

The following odour abatement features have been included in the proposed design,

1. Inherently Low Odour Process

a. Aerobic digestion is a considerable less odourous process than anaerobic

processes. It does not involve methane gas production or the very strong

odours associated with failures of anaerobic digestion processes.

b. Double Barrier Design – The first barrier is that all the digestion processes are

enclosed in stainless steel vessels which are directly vented to the odour

control system. The second barrier is the airtight ‘panel lined’ building which

will be kept under negative pressure by means of an extraction that will emit

treated air through biofilters.

c. A low volume, low odour dried fertiliser product is produced rather than

large quantities of liquid digestate which have to be stored and subsequently

spread to land giving odour risk potential across a wide area. The dried

product will be stored undercover at all times.

d. No odourous feedstock material will be stored outside.

2. Inherently Low Odour Feedstocks.

a. The target feedstocks are out of date packaged foods which will enclose their

odour during storage on site until they are processed by the depacking

machine.

b. Target feedstocks are from the commercial sector where they will be

collected from site promptly and will not have time for odour to develop.

ADVANCED ORGANICS LTD


3. Remote Location

a. The proposed site is a generous 660m separation distance away from the

nearest sensitive receptor thus providing considerable dispersion of any

odours.

b. Favourable topography - The prevailing winds will blow any odourous

emissions into the local hillside where there will be considerable absorption.

This hillside is in line with the sensitive receptors and will give them

additional protection from odours.

4. Negative Pressure Building with Fridge Panel Internal Cladding

a. Airtight fridge panelling offers a high degree of sealing and to the best of our

knowledge we will be the only food waste building in the UK offering this

high standard of sealing against fugitive emissions. The high degree of sealing

ensures the negative pressure can be maintained. The building will be made

airtight and a smoke test to be carried out prior to the commencement of

development.

b. Duty/standby/assist fans ensure the reliability of the system in the event of a

fan breakdown or unusually high odours

c. The system has been designed with advice from ADAS to provide 2 air

changes per hour.

d. Rapid open (2.5m/s) and closing (0.8 m/s) insulated doors to prevent odour

escape. No processing or unloading will take place when doors are open.

e. The fan system will be controlled to ensure a negative pressure is

maintained.

f. The doors to the building will be sealed at all times unless allowing

access/egress of delivery vehicles

5. Odour Management Plan

a. Industry odour experts ADAS have developed the sites initial Odour

Management Plan (OMP) to incorporate industry best practice.

b. All plant and machinery will be serviced and maintained in accordance with

the manufacturer’s instructions.

c. No odourous material will be stored outside.

d. The doors to the building will be sealed at all times unless allowing

access/egress of delivery vehicles.

6. Odour Control System

a. Designed with the assistance of ADAS with 4 off 6m x 7m x 2.5m bays of

biofilter media with a generous residence time of 60 secs.


b. Modular construction to allow for media change in individual biofilter

modules without interrupting odour abatement through the remaining

modules.

c. The odour control system will have a maintenance contract to ensure it is

operating correctly.

7. Vehicle Odour Control

a. The operation will have an inherently low number of road movements thus

minimising the potential smell from odourous loads.

b. All loads will be delivered in covered vehicles.

c. Odourous loads will be refused at source to prevent odorous loads travelling

to site.

d. All loads will be packed using pallets or sealed food waste boxes to prevent

odour release in transit and a high proportion of wastes will be within sealed

“point of sale” packaging.

8. Sealed Drainage System

a. A sealed drainage system returns all liquors to the process. There is therefore

no odour risk associated with effluent treatment processes.

9. Waste Packaging Compactor

a. The high performance depacking system produces a clean dry material with

little odour. This material is compacted and stored in a closed compactor

vessel within the negative pressure building. The compactor will be typically

emptied on a daily basis giving little opportunity for odours to develop

through decay.

b. No putrescible or food based waste will be placed in the compactor skip,

which will be covered at all times.

10. Option to Combust to Odourous Air

a. There is an option to combust odourous air through the engines to assist the

biofilter.

b. Combustion of air will guarantee to destroy all odours.

11. External Liquid digestate Storage tanks vented to building

a. Small quantities of potentially odorous air from inside the digestate storage

tanks will be vented by breather pipes back into the odour controlled process

building.


12. Organic Biocide used for Cleaning Systems

a. The building will be regularly washed down using a steam cleaner in addition

to an organic biocide degreasing agent that kill bacteria, break down fats and

prevents the build-up of smells in small crevasses.

13. Future Odour Control Design Flexibility

a. Should it be deemed necessary in the future the site could readily

accommodate

i. Air Interlock door system

ii. Local odour suppression using chemical odour control agents e.g. a

Mistair system

iii. Local ionised air odour destruction systems such as Terminodour

system.

iv. Tertiary wet scrubber systems before or after the biofilter to remove

volatiles and bacteria

14. Acceptance of EHO Odour Conditions

a. The operators will accept the odour conditions as specified in the EHO email

comments of the 22/8/13 and 11/3/14 including the requested condition

clauses similar to those suggested below,

b. Complaints Clause

“- In the event that complaints regarding odour, noise, lighting and/or dust

(including bioaerosols) are received by the Local Planning Authority from any

sensitive receptor, and thereafter notified to the operator, an assessment of

the complaint shall be undertaken by the operator. A report on the findings,

with proposals for removing, reducing or mitigating identified adverse effects

resulting from the operation, and a programme for the implementation of

remedial measures and works to be undertaken shall be submitted to the

Local Planning Authority no later than five working days from the receipt of

the complaint, unless a later date is otherwise agreed in writing by the Local

Planning Authority.”

And,

c. Planning Authority Approval of Odour Management Plan

“Prior to the commencement of operations involving the importation of waste

to the site a management plan of measures proposed to control

odour,(including bioaerosols) shall be submitted to, and approved in writing

by the Planning Authority. The measures as approved shall thereafter be


implemented, along with any subsequent remedial measure agreed under the

requirements of condition ??? (above) of this permission by the Planning

Authority.”

Should you require any further information on the odour abatement system or any other

systems please do not hesitate to contact us.

Yours sincerely

Mike Jordan

Advanced Organics Ltd

The Stables Long Lane

East Haddon Northampton

NN6 8DU

T: 01604 771123 [email protected]

www.gpplanning.co.uk

Mrs Gill Pawson BSc MA MRTPI MCIWM Ms Lucy Booth BSc MA CMLI Mr Christian Smith DipTP MRTPI

GP Planning Ltd Registered in England Number 6019666

Registered Office Mill House, Long Lane, East Haddon, Northamptonshire, NN6 8DU

Response to Harborough District Council’s Objection to the Proposed TAD Facility at Pebble Hall, Theddingworth This note seeks to provide a response to Harborough Distrcit Council’s objection to the proposed TAD facility at Pebble Hall Farm, Theddingworth. The objection comprises two paragraphs which are quoted and then commented on in turn. The first paragraph of the objection states that:

HDC objects to the proposal on the basis of the intensification of use, including increases to the size of buildings on site, and subsequent adverse impact on character of the countryside, including the setting of Theddingworth church, contrary to Core Strategy CS/11 and CS/17.

The main TAD activities can be accommodated inside the existing building, only requiring a small extension to the building. This will not have a adverse impact on the character of the countryside as the extension has been designed to fit in with the appearance of the existing building. The extension will be partially screened by the existing bund and the proposed and existing landscaping on the north side of the Pebble Hall building complex will in time fully screen it from views from the north. Pebble Hall is an existing and permitted waste/ industrial site and therefore a small extension on this site is not considered inappropriate. The setting of Theddingworth church will not be adversely affected by the TAD proposals. There are no direct views from the church of the site due to the intervening buildings. However, the views from the edge of Theddingworth have been considered in the application and there are no significant views of the proposed TAD building. The second paragraph of the objection staes that:

Concerns are raised about increased vehicular movement, particularly HGV's and larger vehicles. Whilst the total number of vehicles is controlled, the type of vehicles does not appear to be. A Traffic Regulation Order is referred to but there is no certainty that this can be achieved. The hours of delivery commence at 7am thus HGVs could travel to site prior to this causing noise and disturbance to residents in villages, contrary to Core Strategy CS/11. A routeing agreement is referred to but the only route is through several neighbouring villages and it is hard to see how this can be avoided. If approval is forthcoming would like to see the number, type of vehicles and hours of delivery controlled more strictly and liaison with nearby villages regarding routeing agreement.

The proposed building for the TAD has planning permission for B8 use (storage and distribution). It therefore has the potential to generate between 66 and 404 vehicle movements per day (although it is acknowledged that the whole site is limited to 240 vehicle movements per day). The proposed use of the building for the TAD facility will generate 32 vehicle movements per day (16 in and 16 out) and will therefore reduce the amount of traffic associated with the building significantly. 16 vehciles over a 11 hour working day is not excessive.

mailto:[email protected]

http://www.gpplanning.co.uk/

15/04/2014 2

It has been accepted by Leicestershire County Councils Highway Authority the the level of traffic as a result of this proposal will decrease. There will therefore be less HGV vehicle movments than the permitted B8 use. The Traffic Regulation Order has been proposed as part of the application and could be conditioned. In addition, the hours of delivery could be conditioned and moitored using data from the ATC at the access. Any travelling through local villages will only be done so using the strategic highway network. Theddingworth Church is located on an A road and the amount of traffic will be reduced as a result of this application and therefore there will be no impact on the church. Overall, the amount of traffic associated with the site will be reduced and there will be no impact on Theddingworth Church through visual impact or traffic.

PROPOSED TAD FACILITY:

PEBBLE HALL, THEDDINGWORTH

SEP response 14/04/17 1

RESPONSE TO ISSUES RAISED BY THE COUNTY COUNCIL’S SENIOR ENVIRONMENTAL PLANNER: 10 APRIL 2014 N.B. The response from the SEP is dated 10 April 2013, but as it relates to Planning Application Number 13/00117/WASFUL, it is assumed that it should have been dated 2014.

Ecological Impact

An assessment of the proposed impact on local wildlife sites of pollutant emissions from the proposed TAD has been prepared, and is attached to this note. It concludes that the emissions from the proposed TAD and REGF facilities are unlikely to have a significant impact on local wildlife sites in the vicinity of the development site.

Landscape and Visual Impact

The lack of impacts has been clearly demonstrated in the section 4.10 of the Planning Statement. A person standing outside the properties of Woodside Bungalow and Farm will not see the depth of the proposed extension to the building, even without leaves on the intervening vegetation, due to the screening provided by the lie of the land. The cross section drawing GPP-WWM-PH-13-09 submitted with the planning application clearly shows that from these properties the farm buildings are screened by the intervening landform. An extension to the existing screening bund and the additional landscaping that has been proposed, following a site meeting with the SEP, are illustrated on Drawing GPP-WWM-TAD-14-09 v2. This plan was submitted to the Council in February. The plan shows that the screening bund will be extended along the full length of the existing building and it will be planted with shrubs; the combined effect will to soften the appearance of the bund and to provide a physical containment to the TAD site. The existing woodland planting on the bank down to the River Welland is now established and being maintained, as described in a statement submitted to the Council by Katie Burfitt. In any event it is not being relied upon to screen the development (see comments above). The ongoing management of existing planting and, in the event that planning permission is granted for the TAD and/or the REGF schemes, the future planting will be under the direction of Katie Burfitt. This should ensure that the planting is carried out to maximize its chances of establishment and growth. The increase in habitats in the locality of the site is good for the wildlife of the area, enhancing wildlife corridors and providing a large area of new woodland/shrub habitat. The Applicant will have to manage any vermin that may be attracted to the development due to the presence of food waste, however, this management will only involve action inside the buildings, as required by a condition of the Environmental Permit. With respect to the use of feathered stock in the planting specifications, this has not been required in the past therefore was not proposed in the new specifications. A revised specification could be submitted, if required by the Local Planning Authority. The noise barrier referred to in the Sound Barrier Solutions report no longer forms part of the noise mitigation measures required by this scheme, therefore its landscape impacts have not been further considered.

PROPOSED TAD FACILITY:

PEBBLE HALL, THEDDINGWORTH

SEP response 14/04/17 2

External Lighting

The submitted plans of the TAD building show the proposed lighting positions. Other lights will be removed. Lights will be aligned to face downwards, to illuminate the yard in the vicinity of the doorways, above which the lights are to be placed. This will minimize the impact of the lights beyond the site boundary. The lights will be switched off at the end of the working day and not left on overnight.


8 Alcotts Green Sandhurst

Gloucester GL2 9PE

T +44 (0) 1452 730240 F +44 (0) 1452 730240

[email protected] www.gf-environmental.co.uk


22nd April 2014

Re: An Assessment of the Potential Impact on Local Wildlife Sites of Pollutant Emissions from Proposed Power Generation Developments to be Built on the Welland Waste Management Site Near Theddingworth

Introduction Welland Waste Management Ltd (WWM) has applied for planning permission to build a Thermophilic Aerobic Digestion (TAD) Facility on the Pebble Hall site to the south-west of Theddingworth, Leicestershire. An application has also been submitted to modify the planning permission for a Renewable Energy Generation Facility (REGF) on adjoining land on the WWM site. Consultation comments received from Northamptonshire County Council requested additional information on the potential cumulative impact of pollutant emissions from the proposed TAD facility and REGF on local wildlife sites, situated with 2km of the proposed development site. The following wildlife sites were identified using the MAGIC website1.

1. Unnamed Deciduous Woodland BAP Priority Habitat; 2. Spring Hollow Deciduous Woodland BAP Priority Habitat; 3. Nichol’s Hill Spinney Deciduous Woodland BAP Priority Habitat; 4. Hothorpe Hill Barn-Hill Spinney Deciduous Woodland BAP Priority Habitat; 5. Unnamed Deciduous Woodland BAP Priority Habitat 2; 6. National Inventory of Woodland & Trees Habitat; and, 7. Damside Spinney Deciduous Woodland BAP Priority Habitat.

The location of these local wildlife sites in relation to the proposed development site are shown in the following map, reproduced from the MAGIC website.

The location of the Welland Waste Management site is denoted by the red star.

1 http://www.natureonthemap.naturalengland.org.uk/MagicMap.aspx

1 2

5

3

4

6

7


Page 2 of 6


Basis for Assessment The potential cumulative impact on local ecological habitat sites, due to emissions from the proposed TAD facility and REGF, has been assessed in terms of the maximum process contributions for the following pollutants in relation to their respective Critical Levels, and associated time averaging periods, as specified in Table B4 of Environment Agency Horizontal Guidance Note H1 Annex F:

• Oxides of nitrogen (NOX) 30 µg m-3 as an annual average; • Oxides of nitrogen (NOX) 75 µg m-3 as a daily average; • Sulphur dioxide (SO2) 20 µg m-3 as an annual average; • Ammonia (NH3) 1 µg m-3 as an annual average for lichens and bryophytes; • Hydrogen fluoride (HF) <5 µg m-3 as a daily average; and, • Hydrogen fluoride (HF) <0.5 µg m-3 as a weekly average.

The assessment also considered the potential cumulative impact of emissions from the proposed TAD facility and REGF on the local wildlife sites in relation to site-specific critical loads for nitrogen and acidity deposition, obtained from the UK Air Pollution Information System (APIS) website2.

Critical Levels Assessment An assessment of the impact of emissions from the proposed TAD facility and REGF on local wildlife sites has been undertaken in relation to the above Critical Levels. The results are presented in the following table.

Table 1 Critical Levels Assessment for Oxides of Nitrogen (NOX) and Sulphur Dioxide (SO2)

Annual NOx PC (µg m-3)

% Critical Level

Daily NOx PC (µg m-3)

% Critical Level

Annual SO2 PC (µg m-3)

% Critical Level

Unnamed Deciduous Woodland BAP Priority Habitat 1.7 6% 26 35% 0.4 2%

Spring Hollow Deciduous Woodland BAP Priority Habitat 1.1 4% 18 24% 0.3 1%

Nichol’s Hill Spinney Deciduous Woodland BAP Priority Habitat 0.6 2% 9 11% 0.1 1%

Hothorpe Hill Barn-Hill Spinney Deciduous Woodland BAP Priority Habitat 0.4 1% 6 8% 0.1 1%

Unnamed Deciduous Woodland BAP Priority Habitat 2 3.2 11% 65 87% 0.8 4%

National Inventory of Woodland & Trees Habitat 1.1 4% 36 48% 0.3 1%

Damside Spinney Deciduous Woodland BAP Priority Habitat 4.1 14% 36 47% 1.0 5%

As can be seen in the above table, the annual average NOX Process Contribution is between ~1% and ~11% of the annual NOX Critical Level at the above local wildlife sites. The APIS website indicates that the existing annual average NOX concentration in the vicinity of the Welland Waste Management site is 11.3 µg m-3. Therefore, the Predicted Environmental Concentration due to emissions from the proposed TAD facility and REGF is likely to be ~12 to ~15 µg m-3, and well within the critical level value of 30 µg m-3. Accordingly, process contributions in relation to the annual NOX critical level can be screened out as insignificant at the above locations.

Annual average SO2 process contributions were all ~1% to ~5% of the 20 µg m-3 Critical Level, with an estimated background concentration of ~1.4 µg m-3, there is little risk of exceeding the annual average critical level for SO2.

The daily average NOX Process Contributions were estimated to be between ~10% to ~90% of the Critical Level value of 75 µg m-3. With an estimated annual average background concentration of ~11 µg m-3, there is little risk of exceeding the annual average critical level for NOX at all but Receptor 5, where a marginal exceedence could potentially occur. However, it should be borne in mind that the assessment is based upon a series of worst case assumptions with NOX emissions at the maximum emission limit value for the TAD facility and REGF. When operational, emissions of NOX will be well

2 http://www.apis.ac.uk/search-by-location


Page 3 of 6


below the emission limit values prescribed in the respective environmental permits for each of the two facilities.

The corresponding process contributions for ammonia and hydrogen fluoride are based upon an assumed ammonia concentration in the emissions to atmosphere of 2 mg Nm-3, and for HF emissions from the REGF at the IED ELV of 1 mg Nm-3. The results are presented in the following table.

Table 2 Critical Levels Assessment for Ammonia (NH3) and Hydrogen Fluoride (HF)

Annual NH3 PC (µg m-3)

% Critical Level

Daily HF PC

(µg m-3)

% Critical Level

Weekly HF PC

(µg m-3)

% Critical Level

Unnamed Deciduous Woodland BAP Priority Habitat 0.02 2% 0.13 2.6% 0.06 12%

Spring Hollow Deciduous Woodland BAP Priority Habitat 0.01 1% 0.09 1.8% 0.04 7%

Nichol’s Hill Spinney Deciduous Woodland BAP Priority Habitat 0.01 1% 0.043 0.9% 0.017 3%

Hothorpe Hill Barn-Hill Spinney Deciduous Woodland BAP Priority Habitat 0.004 0.4% 0.031 0.6% 0.013 3%

Unnamed Deciduous Woodland BAP Priority Habitat 2 0.03 3% 0.33 6.5% 0.17 34%

National Inventory of Woodland & Trees habitat 0.01 1% 0.18 3.6% 0.03 7%

Damside Spinney Deciduous Woodland BAP Priority Habitat 0.04 4% 0.18 3.6% 0.08 15%

As can be seen, Process Contributions of ammonia and hydrogen fluoride are well below their respective Critical Levels at all of the above local wildlife sites, and can be screened out as insignificant. The assessment for ammonia was based upon the lower critical level of 1 µg m-3 for lichens and bryophytes.

Deposition Assessment Relative to Site-Specific Critical Loads Critical load data for nitrogen deposition at the local wildlife site locations were obtained from the APIS website and are summarised in Table 3.

Table 3 Baseline Critical Loads for Nitrogen Deposition

Receptor Critical Load (kgN/ha/yr) Baseline Condition (kgN/ha/yr)*

“Headroom” (kgN/ha/yr Low Limit High Limit Low Limit High Limit

Unnamed Deciduous Woodland BAP Priority Habitat 10 20 44.4 -34.4 -24.4

Spring Hollow Deciduous Woodland BAP Priority Habitat 10 20 44.4 -34.4 -24.4

Nichol’s Hill Spinney Deciduous Woodland BAP Priority Habitat 10 15 44.4 -34.4 -24.4


10 15 44.4 -34.4 -24.4

Unnamed Deciduous Woodland BAP Priority Habitat 2 10 20 44.4 -34.4 -24.4

National Inventory of Woodland & Trees habitat 10 20 44.4 -34.4 -24.4

Damside Spinney Deciduous Woodland BAP Priority Habitat 10 20 44.4 -34.4 -24.4

Note: Negative values denote that the critical load is currently exceeded

As can be seen, the data from the APIS website indicate that the Critical Load for nitrogen deposition is currently exceeded at all of the above ecological habitat receptor locations. However, there is no information available in the literature on whether the ecological habitats are suffering significant harm as a result of the current exceedence of the critical load for nitrogen deposition.

The situation for acidity deposition is somewhat different, as shown in Table 4.


Page 4 of 6


Table 4 Baseline Critical Loads for Acidity Deposition

Receptor Name Acidity Critical Load (keqN/ha/yr)

Background (keqN/ha/yr)

Headspace (keqN/ha/yr)

Acidity Critical Load (keqS/ha/yr)

Background (keqS/ha/yr)

Headspace (keqS/ha/yr)


2.65 3.17 -0.52 2.29 0.29 2.0


2.65 3.17 -0.52 2.29 0.29 2.0


2.65 3.17 -0.52 2.29 0.29 2.0


8.67 3.17 5.5 8.31 0.29 8.0


2.9 3.17 -0.27 2.54 0.29 2.3

National Inventory of Woodland & Trees habitat 2.9 3.17 -0.27 2.54 0.29 2.3


2.65 3.17 -0.52 2.29 0.29 2.0

As can be seen, the data indicate that the critical load for acid deposition (keqS/ha/yr) is currently not exceeded at any of the above locations, although the critical load for acid deposition as N is marginally exceeded at most locations..

The ADMS model was configured to estimate deposition of NO2, NH3, SO2, HCl and HF at the local wildlife sites, due to emissions from the proposed TAD facility and REGF.

The deposition velocities for NO2, SO2, NH3 and HCl were taken from AQTAG 063, while the corresponding value for HF was obtained from a literature reference (see below).

Table 5 Deposition Velocities Used in Calculations

Substance Deposition Velocity (mm/s) Nitrogen Dioxide (Grassland) 1.5 Nitrogen Dioxide (Woodland) 3.0 Sulphur Dioxide (Grassland) 12.0 Sulphur Dioxide (Woodland) 24.0 Ammonia (Grassland) 20.0 Ammonia (Woodland) 30.0 Hydrogen Chloride (Grassland) 25.0 Hydrogen Chloride (Woodland) 60.0 Hydrogen Fluoride (Grassland)* 2.0 Note: * Reference: Fluorides in the Environment, Weinstein, LH and Davison, AW, CABI Publishing (2004)

Nitrogen Deposition

An assessment of nitrogen deposition was undertaken in relation to site-specific Critical Loads data, obtained from the APIS website, and summarised in Table 3. Nitrogen deposition rates associated with emissions from the proposed TAD facility and REGF were calculated according to the method recommended by the Environment Agency in AQTAG 06, and as used by Laxen and Marner in a study carried out in support of the development of the Dorset and Poole, Local Waste Plan4. The method involves the calculation of the annual deposition rate from the annual Process Contribution and the deposition velocity for NO2 using Equation 1.

3 AQTAG 06, Technical Guidance on Detailed Modelling Approach for an Appropriate Assessment for Emissions to Air, Ji Ping Shi, Environment Agency Air Quality Monitoring and Assessment Unit, 20th April 2010. 4 An Assessment of Possible Air Quality Impacts on Vegetation from Processes Set out in the Bournemouth, Dorset & Poole Waste Local Plan, Air Quality Consultants Ltd, April 2005


Page 5 of 6


Equation 1 Calculation of Deposition Rate

Laxen and Marner commented that NOX deposits to vegetation mainly via uptake of nitrogen dioxide through stomata, and that nitric oxide does not deposit at a significant rate. Environment Agency guidance recommends using a factor of 70% for the conversion of NOX to NO2 to provide a worst case basis for assessment of long term impacts5. Accordingly, this conversion rate was used as the basis for calculating the nitrogen deposition rates associated with emissions of NOX and NH3 from the proposed TAD facility and REGF. Only dry deposition was considered by Laxen and Marner as wet deposition effects, close to the point of release, are considered to be much less significant than dry deposition mechanisms.

Wet deposition of the emitted pollutants this close to the emission source will be restricted to wash-out, or below cloud scavenging. For this to occur, rain droplets must come into contact with the gas molecules before they hit the ground. Falling raindrops displace the air around them, effectively pushing gasses away. The low solubility of nitrogen dioxide and nitric oxide means that any scavenging of these gases will be a negligible factor.

The results from the nitrogen deposition rate calculations are summarised in the following table and are based upon emissions of NOX and NH3 from the proposed TAD facility and REGF.

Table 6 Process Contribution to Nutrient Nitrogen Deposition at Local Wildlife Sites

Receptor Name Deposition (kgN/ha/yr)

Deposition (kgN/ha/yr) (PC as % Lower Critical

Load) Unnamed Deciduous Woodland BAP Priority Habitat 0.5 5% Spring Hollow Deciduous Woodland BAP Priority Habitat 0.3 3% Nichol’s Hill Spinney Deciduous Woodland BAP Priority Habitat 0.2 2% Hothorpe Hill Barn-Hill Spinney Deciduous Woodland BAP Priority Habitat 0.1 1%

Unnamed Deciduous Woodland BAP Priority Habitat 2 0.9 9% National Inventory of Woodland & Trees Habitat 0.3 3% Damside Spinney Deciduous Woodland BAP Priority Habitat 1.2 12%

The results show that nitrogen deposition attributable to emissions of NOX and NH3 from the proposed TAD facility and REGF plant is predicted to be less than 10% of the site-specific Lower Critical Load, apart from the nearest downwind receptor location (Damside Spinney), where the Process Contribution represents ~12% of the Critical Load. Despite the fact that the Critical Load for nitrogen deposition is currently exceeded at the above locations, the magnitude of the Process Contribution is small and is probably not measurable with any reasonable degree of accuracy, and can probably be screened out as insignificant.

It should also be noted that exceedence of a Critical Load is not a quantitative estimate of damage to a particular habitat, but represents the potential for damage to occur. There is no evidence in the available literature to indicate that the above local wildlife sites are suffering as a consequence of nitrogen deposition from nearby sources. Accordingly, on this basis, the incremental increase in nitrogen deposition attributable to emissions of NOX and NH3 from the proposed TAD facility and REGF is small and is unlikely to have a measurable effect on the integrity of the above ecological habitat sites.

Acid Deposition

An assessment of acidity deposition was undertaken based upon Critical Load data for acid deposition from the APIS website. The assessment followed the same procedure that was used in the assessment of nitrogen deposition, and the results are summarised in Table 7.

5 http://webarchive.nationalarchives.gov.uk/20140328084622/http://www.environment-agency.gov.uk/static/documents/Conversion_ratios_for__NOx_and_NO2_.pdf

€

Deposition Rate µg m-2s-1( )= Deposition Velocity m s-1( ) × Concentration µg m-3( )


Page 6 of 6


Table 7 Process Contribution to Acid Deposition at Local Wildlife Sites

Receptor Name



(keqN/ha/yr)



(% Critical Load)


Emissions of SO2, HCl & HF (keqS/ha/yr)

Increase in Deposition Due to Emissions of

SO2, HCl & HF (% Critical Load)


0.03 1.3% 0.1 6%


0.02 0.8% 0.1 4%


0.01 0.4% 0.05 2%


0.01 0.1% 0.03 0.4%


0.06 2.2% 0.3 11%

National Inventory of Woodland & Trees habitat

0.02 0.7% 0.1 4%


0.08 3.1% 0.1 6%

The above results show that acidic deposition attributable to emissions of NOX and NH3 from the proposed TAD facility and REGF is predicted to be between <1% and ~3% of site-specific Critical Load values, and are probably not measurable with any reasonable degree of accuracy. The situation is slightly different where the process contributions are of a similarly low value, but as the critical load value is lower, the process contributions represent a greater percentage of the critical load.

Nevertheless, there is no evidence in the available literature to indicate that the above ecological receptors are currently suffering as a consequence of acid deposition from nearby sources, accordingly, acidity deposition at the above local wildlife sites can be screened out as insignificant.

Conclusions The results from a detailed assessment of the impact of emissions from the proposed TAD facility and REGF on nearby local wildlife sites showed that critical levels and site-specific critical load values for nitrogen deposition are currently exceeded at the receptor locations considered.

Maximum process contributions for NOX, SO2, NH3 and HF were well below their respective critical levels and were screened out as insignificant. Similar conclusions were drawn for maximum process contributions to nitrogen and acidity deposition in relation to relevant site-specific critical load.

There is no evidence available in the literature to indicate that current exceedences of critical levels and critical loads are causing observable or measurable harm to the local wildlife sites in the vicinity of the Welland Waste Management site. Accordingly, it is concluded that emissions from the proposed TAD facility and REGF are unlikely to have a significant impact on local wildlife sites in the vicinity of the development site.

Via e-mail Geoff Fynes

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