part 2, chapter 15 appendix 15.10 minehead on-site...

Part 2, Chapter 15 Appendix 15.10

Minehead On-site Treatment of

Domestic Foul Sewage

York Potash Ltd

York Potash – Preliminary Design

On-site Treatment of Domestic Foul Sewage at Dove’s Nest

REP-P2-FD-002

Rev1 | 26 September 2014

This report takes into account the particular

instructions and requirements of our client.

It is not intended for and should not be relied

upon by any third party and no responsibility

is undertaken to any third party.

Job number 234376-32

Ove Arup & Partners Ltd

Admiral House Rose Wharf

78 East Street

Leeds LS9 8EE

United Kingdom

www.arup.com

York Potash Ltd York Potash – Preliminary DesignOn-site Treatment of Domestic Foul Sewage at Dove’s Nest

REP-P2-FD-002 | Rev1 | 26 September 2014

J:\230000\234376-00\0 ARUP\0-12 WATER\0-12-08 REPORTS\01 DOMESTIC FOUL DRAINAGE\2014-09-26 ON-SITE TREATMENT OF DOMESTIC FOUL SEWAGE AT DOVE'S

NEST REV1\REP-P2-FD-002 ON-SITE TREATMENT OF DOMESTIC FOUL SEWAGE AT DOVE'S NEST 140926 REV1.DOCX

Contents

Page

1 Introduction and Guiding Principles 1

1.1 Introduction 1

1.2 Scope and objectives 1

1.3 Documents Referenced 2

1.4 Accompanying Drawings 2

1.5 Design Guidance 3

2 Consultation 3

2.1 Responses to 2013 planning application 3

2.2 Pre-planning meetings 8

3 Proposed Development 9

3.1 Description 9

3.2 Development phases 9

3.3 Sources of domestic foul sewage 9

4 Sewage estimates 13

4.1 Anticipated worker data 13

4.2 Sewage estimation assumptions 14

5 Treatment Plant Requirements 15

5.1 Balancing tank 15

5.2 Primary tank 15

5.3 Biozones 15

5.4 Humus tank 15

5.5 Sand filter 16

5.6 Power supply 16

5.7 Operation and Maintenance Regime 16

6 Water Quality in Sneaton Thorpe Beck 17

6.1 Existing Catchment Status 17

6.2 H1 Environmental Assessment 17

6.3 Water Framework Directive 18

Appendices

Appendix A

Consultation Records





Appendix B

Water Quality Data

Appendix C

Site Masterplan

Appendix D

WPL Treatment Plant Details

Appendix E

WFD Catchment Status and Target

Appendix F

H1 Assessment





Page 1

1 Introduction and Guiding Principles

1.1 Introduction

Arup has been engaged by York Potash Ltd (YPL) to provide assistance in preparation of a planning application for development of a working polyhalite (potash) mine extending across an area of approximately 25,300Ha within the North York Moors National Park Authority (NYMNPA). The majority of above ground development is due to occur at the Dove’s Nest site (located approximately 6km southwest of Whitby) and will primarily consist of a mine-shaft with mine-head building, offices and welfare buildings.

The current planning application is scheduled to be submitted in mid-2014 and follows a previous submission made in 2013. The original 2013 application was withdrawn for amendment prior to a decision being concluded by NYMNPA. Comments on the 2013 planning submission were however obtained from the NYMNPA and other consultees and are being considered in development of the 2014 application.

As part of the proposed development, consideration needs to be given to the management of domestic foul sewage generated at the Dove’s Nest site. Previous investigations undertaken by Atkins have determined that there is no locally accessible public sewer in the immediate vicinity of the site capable of accepting the estimated sewage volumes likely to be generated. In 2013, Atkins prepared a number of technical notes investigating options to connect to the Yorkshire Water main sewer but concluded that due to pre-existing capacity constraints this was not viable.

Atkins proposed the use of an on-site package treatment plant designed to treat all domestic foul sewage generated on site, with any treated effluent discharged to Sneaton Thorpe Beck. This option was presented in the 2013 planning application and comments were provided by the Environment Agency (EA), NYMNPA and AMEC (acting on behalf of NYMNPA).

1.2 Scope and objectives

The scope of this report is to re-examine the on-site treatment option developed by Atkins and update it as required for the purposes of developing a viable design for planning application purposes. This work required includes:

• Review of existing development proposals at the Dove’s Nest site and estimation of foul sewer infrastructure requirements.

• Summarise the key issues raised by the relevant authorities in relation to the 2013 planning application and examine how these issues have since been progressed or resolved.

• Review the concept designs developed by Atkins / WPL for development of a new on-site package treatment plant and identify any design amendments necessary to comply with comments on the 2013 application and/or revised development proposals.





Page 2

• Update the H1 Assessment of water quality impacts in the receiving watercourse using latest datasets for flow and quality.

At the request of the EA and AMEC (acting on behalf of NYMNPA), a Whole Life assessment of foul sewage disposal options has been undertaken to rule out the option of an off-site connection to the Yorkshire Water sewer network. This is the subject of a separate evaluation report, REP-P2-FD-001.

1.3 Documents Referenced

Document Ref Document Title

4 June 2013 Atkins Technical Note – Foul Discharge – Environmental Objection

23 July 2013 Atkins Technical Note – Foul Sewer Connection

August 2013 Atkins Technical Note – Foul Water Treatment

5115159-TR/005 Atkins H1 Assessment (4 June 2013)

RA/2013/124384/02 EA planning response letter (15 May 2013)

NYMNPA draft planning conditions (Version 11)

P006915 Yorkshire Water response letters (22 June & 19 July 2013)

AMEC Review of Environmental Impact Assessment (18 July 2013)

Cartwright Pickard Design Access Statement (17 December 2012)

0000-APP-SES-CALC-001 YPL

YPL Anticipated worker demands

FWS Baseline water quality monitoring data for DNSW1

AMEC Review of Arup Report (August 2014)

RA/201/129240/01 EA Review of Arup Report (15 August)


Flow Monitor Installation Report (Enviromontel, 29/08/2014)

Interim Report 1 (Enviromontal, flow survey data retrieved for the period 28/08/2014-11/09/2014) (16/09/2014)

Sneaton Thorpe Beck River Survey Interim 1 plots (16/09/2014)

Westerdale NYM Weather data for August 2014 (15/09/2014)

Westerdale NYM Weather data for September 2014 (15/09/2014)

EA WFD Classification for Rigg Mill Beck- GB104027068140 (02/09/2014)

Whitby Weather Data (http://www.wunderground.com) (26/09/2914)

Table 1.1 Documents Referenced

1.4 Accompanying Drawings

Drawing Number Drawing Title

YP-P2-CX-031 Site General Arrangement, MTS Scheme Final Phase (REV6)

DD-111-898 WPL - Primary Settlement Tank

DD-111-945 WPL - Biozone

DD-111-911 WPL – Humus Tank





Page 3

DD-140-180 WPL – Sand Filter

Table 1.2: Accompanying Drawings

1.5 Design Guidance

Document reference Document title

BS EN:12056 Gravity Drainage systems inside buildings: Part 2 Sanitary pipework, layout and calculation

British Water: Flows & Loads 4 - Sizing criteria, Treatment capacity for sewage treatment systems

Environment Agency EQS guidelines

http://cdn.environment-agency.gov.uk/geho0810bsxl-e-e.pdf

Environment Agency Chemical Standards

http://evidence.environment-agency.gov.uk/ChemicalStandards

The River Basin Districts Typology, Standards and Groundwater threshold values (Water Framework Directive) (England and Wales) Directions 2010

UK environmental standards and conditions (UKTAG) 2008

Table 1.3: Design guidance documents

2 Consultation

2.1 Responses to 2013 planning application

In 2013, YPL submitted a planning application for the proposed development but later withdrew the application for amendment. Through the assessment process, comments were provided by NYMNPA, EA and AMEC (acting on behalf of NYMNPA). For the purposes of this study, comments pertaining to the proposed on-site foul sewage treatment option have been extracted and summarised in Table 2.1 with responses on how these conditions either have or will be addressed in the proposed development.

Additionally, the EA provided a letter response to the 2013 application dated 15th May 2013. Atkins subsequently prepared a file note addressing the issues raised. A copy of this file note has been provided in Appendix A. Comments raised by the EA have therefore not been summarised in Table 2.1.

Ref Source Key issue Comment Response

1 AMEC York

Potash Project;

Review of

Environmental

Impact

Assessment

Flow

balancing

“..given the capacity required for the

welfare facilities (population-equivalent of

around 800 people), these would include

toilets, kitchen, laundry and shower

facilities and operate on a 24/7 shift

pattern, there will be significant peaks and

troughs in foul flows which may pose

A flow balancing tank has been included in

the concept design to ensure that peak

discharges from the site can be regulated to

ensure the capacity of the treatment works

is not exceeded. Daily sewage volume is

estimated at 68m3. A 30m3 balancing tank

will be provided with facility for

emergency tanker access should the plant





Page 4

difficulties for effluent treatment and

management”

need to be temporarily shut-down for

repairs / maintenance.

2 AMEC York

Potash Project;

Review of

Environmental

Impact

Assessment

Achievable

effluent

quality

“Concerns have been raised by the

Environment Agency over whether the

package treatment plant can provide final

effluent quality predicted. Additional

information regarding the design

specification of the proposed package

treatment plant, and examples of other

similar existing plants which ….achieve the

aspired effluent quality, should have been

provided.”

Further to submission of the 2013

application, WS Atkins has provided case

study data, developed by the proposed STW

supplier, demonstrating that the proposed

plant can consistently achieve the stated

effluent quality on an on-going basis.

3 AMEC York

Potash Project;

Review of

Environmental

Impact

Assessment

Routing of

treated

effluent prior

to

discharging

to Sneaton

Beck /

Facility for

effluent

quality

monitoring

“Concerns were also raised about the

originally proposed means of managing

treated effluent between the package

treatment plant and Sneaton Thorpe Beck

i.e. by directing it through the SuDS prior

to discharge. However, this has been

resolved by the WS Atkins technical note

dated 4 June 2013, which confirmed that

the proposals no longer included a

discharge to the proposed attenuation

ponds for polishing.

The current masterplan shows discharge

from the proposed STW discharged directly

to Sneaton Thorpe Beck.

It is understood that the previous concerns

raised pertained to confirming the effluent

quality during operation without influence

from surface water drainage. A chamber

will be constructed on the outfall from the

STW to Sneaton Thorpe Beck for

compliance monitoring.

The design has been modified to ensure that

surface water drainage from the remainder

of the site is isolated from STW effluent

discharge to Sneaton Beck.

4 AMEC York

Potash Project;

Review of

Environmental

Impact

Assessment

Impact of

proposed

STW on

water quality

in Sneaton

Beck / WFD

status

“..it would appear from the H1 assessment

that the proposed discharge can only meet

the Imperative Limit for ammoniacal

nitrogen under the Freshwater Fish

Directive (1 mg NH4/l), but would not get

close to achieving the Guideline limit (0.2

mg NH4/l). At the moment, the limited

sample data available suggests that the

Sneaton Thorpe Beck does not meet the

Guideline limit, although the sampling was

undertaken on a different tributary of the

watercourse, than the one which would be

discharged into by the proposed package

plant. Assuming that the two watercourses

have similar baseline water quality… this

would constitute deterioration from the

current situation. Therefore.. it would seem

apparent that the proposals will not

contribute towards an improvement in the

The H1 assessment demonstrated that based

on the proposed treated effluent quality, the

receiving watercourse would achieve

ammoniacal nitrogen concentrations <1mg/l

throughout the year and therefore comply

with the Imperative Limit. As highlighted

by AMEC, the existing watercourse does

not meet the guideline limit of 0.2mg/l

ammoniacal nitrogen. Under the proposed

scheme, ammonium in the beck shall

remain below the Imperative Limit

therefore is not considered to represent a

significant deterioration of the water body.

It is accepted that construction of the

proposed on-site treatment plant will not

result in an improvement to the WFD water

body.

At this time and based on consultations to

date, it is assumed that the EA will grant

discharge consent for 2mg/l ammonium.





Page 5

current Poor Status of the WFD water body

”

Should the EA choose to impose a more

stringent discharge requirement, the

proposed on-site treatment process will be

amended to achieve this.

5 AMEC York

Potash Project;

Review of

Environmental

Impact

Assessment

Impact of

proposed

STW on

water quality

in Sneaton

Beck / WFD

status

“At 0.93 l/s, the effluent discharge will

increase low flow discharge in the Beck at

the discharge point by almost 50% (est Q95

flow is 2l/s). On this basis it cannot be seen

how YP’s conclusions regarding the effects

can be justified”

The relevance of the discharge from the on-

site treatment plant representing up to 50%

of the Q95 base-flow is unclear. The key

issue is the water quality in the watercourse

and the impact which the effluent will have

on the overall water quality of the water

body. Increasing the Q95 flow baseflow in

the beck could be argued as delivering an

improvement to the watercourse, helping

further support aquatic life during dry

periods so long as overall water quality

remains within an acceptable range.

6 AMEC: Review

of Environmental

Impact

Assessment –

Executive

Summary

Impact of

proposed

STW on

water quality

in Sneaton

Beck / WFD

status

“..it is apparent the proposals (to construct

a package treatment plant) would increase

the low flow discharge in the (Sneaton)

Beck at the discharge point by almost 50%,

and they would not contribute towards an

improvement in the current Poor Status of

the WFD waterbody. AMEC therefore

considers that as currently designed, the

proposed package treatment plant has the

potential to have ‘significant’ adverse

effects on the receiving downstream

watercourse.”

Relevance of increased baseflow is

questioned as per Point 5.

It is accepted that the proposed treatment

facility will not result in an improvement in

the existing water quality in the beck during

low flow conditions (Q95 flows and

below). However under these conditions

water quality in the beck would still meet

the Imperative Limit for Cyprinid Water as

defined under the Freshwater Fish

Directive.

Construction of the plant will not prevent

the water body from attaining “good

ecological status” in the future as the

Imperative limit will continue to be

achieved. Construction of the plant will not

result in a downgrading of the water body

from “poor” to “bad”.

On this basis, the claim that the proposed

works would have “significant adverse

effects on the receiving downstream

watercourse” is rejected. It is suggest that

the works will have “minor adverse

effects”.

7 NYMNPA: Draft

Planning

conditions

Baseline

water quality

monitoring

“No development shall commence until a

Foul Drainage Scheme has been submitted

to and approved in writing by the Local

Agreed that no development shall

commence until an approved Foul Drainage

Scheme has been submitted and approved.

However this detailed Foul Drainage

Scheme will not be presented at the





Page 6

Planning Authority. The scheme shall

include:-

b)Water quality and quantity monitoring of

Sneaton Thorpe Beck with a frequency of

no less than once every fortnight, over a

minimum period of a year. Monitoring shall

include flow rates, suspended solids,

biological oxygen demand, Ammonia,

Phosphates, pH, alkalinity and

temperature. Monitoring results shall be

included in full within the Foul Drainage

Scheme;”

planning application stage. A concept Foul

Drainage Scheme is presented as part of the

current planning application.

Baseline water quality monitoring for

Sneaton Thorpe Beck has been undertaken

over a period spanning from January 2013

to August 2013. Details are included in

Appendix B. This is discussed further in

Section 7.

8 NYMNPA Draft

Planning

conditions

Design

details

“c) Full details of the package treatment

plant to be provided, including the make,

model and size;”

The proposed plant is a HiPAF treatment

unit produced by WPL. Details of the

proposed treatment infrastructure are

discussed in Section 6.

9 NYMNPA Draft

Planning

conditions

Design

details

“d) Full details of any pre/post-package

treatment plant balancing;”

Tanks to be provided upstream of STW for

flow balancing. Sand filters have been

incorporated in the design for tertiary

treatment prior to discharge to Sneaton

Thorpe Beck. No post-package plant

balancing is proposed.

10 NYMNPA Draft

Planning

conditions

Design

details

“e) Full details of the size and design of the

proposed tertiary treatment;”

Refer to drawing YP-P2-CX-031 REV2 for

General Arrangement of the final site

showing the proposed STW. Detailed

drawings for individual components of the

STW are provided in Appendix C.

11 NYMNPA Draft

Planning

conditions

General

arrangement /

site layout

“f) A plan showing the proposed location of

the package treatment plant, any pre or

post treatment balancing, the proposed

tertiary treatment and the outfall to Sneaton

Thorpe Beck;”

See response to point 10 above.

Sand filter to be used for tertiary treatment

12 NYMNPA Draft

Planning

conditions

Adoption &

maintenance

of new assets

“g) Evidence that Yorkshire Water have

been approached regarding the adoption of

any non-mains foul treatment infrastructure

using the legal mechanisms contained

within the Water Industries Act shall be

provided;”

Discussions with Yorkshire Water will be

progressed during post-planning application

stage. Yorkshire Water will be consulted

early in detailed design to determine any

specific requirements they have with

regards design of the plant, specific

treatment technologies proposed, access

and egress etc.





Page 7

13 NYMNPA Draft

Planning

conditions

Design

details for

new outfall

“h) Full details of the proposed outfall to

Sneaton Thorpe Beck, including details of

erosion protection measures;”

Should discharge velocities from the STW

outfall warrant the introduction of scour

protection measures, appropriate protection

shall be provided. The requirement for

scour protection will be evaluated at

detailed design phase.

14 NYMNPA Draft

Planning

conditions

Future

expansion &

flow

balancing

“i) Details of how the foul drainage

infrastructure will be managed to ensure it

functions effectively throughout the lifetime

of the mine, including variations in flows

resulting from the initial creation and

growth of the mine, and from the ongoing

pattern of shift work;”

Three foul sewer generation scenarios have

been considered, namely construction,

6.5Mtpa production and 13Mtpa

production. The concept design for the

plant has been based on the ultimate

13Mtpa production phase.

The treatment plant design will be modular

in nature, facilitating the construction of

additional primary settlement tanks,

biozones, and humus tanks should waste

treatment demands on site increase beyond

the currently forecast 13Mtpa demands. A

balancing tank (30m3) will be provided at

the head of the works to accommodate

peaks in demand at shift changes.

15 NYMNPA Draft

Planning

conditions

Adoption &

maintenance

of new assets

“j) Details of the ongoing maintenance of

the foul drainage infrastructure in

accordance with the British Water Code of

Practice for Maintenance of Small Waste

Water Treatment Systems;”

Responsibility for the on-going

maintenance of the proposed infrastructure

will be determined subject to the outcome

of discussions with Yorkshire Water to

have the proposed plant adopted (see Point

No. 12)

Should the plant be adopted, YW will

operate and maintain the plant taking

responsibility for complying with relevant

discharge conditions and effluent quality

parameters.

Should discussions with YW result in the

STW not being adopted, YPL shall enter

into a service agreement with a suitably

qualified specialist contractor, registered as

a British Water accredited qualified service

engineer. This contractor will be instructed

to maintain the facility in accordance with

the relevant British Water Code of Practice.





Page 8

16 NYMNPA Draft

Planning

conditions

Programme “k) A timetable for the implementation of

the Foul Drainage Scheme. Development

shall thereafter proceed only in strict

accordance with the approved Foul

Drainage Scheme and the timetable

included within it. Any non-mains system

shall thereafter be managed and

maintained in accordance with the

approved Foul Drainage Scheme

throughout the lifetime of the development”

A timetable for development of the site and

associated foul drainage infrastructure will

be produced and included within the Foul

Drainage Scheme report. This document

will be prepared as detailed project

planning advances and more certainty

surrounding precise development

timescales is obtained.

17 NYMNPA Draft

Planning

conditions

Land

Drainage

consent

“Consent under the Land Drainage Act

1991 will be required from North Yorkshire

County Council for any works, including

the construction of the foul and surface

water system outfall, to Sneaton Thorpe

Beck or any other ordinary watercourse”

An application for consent under the Land

Drainage Act will be prepared in advance

of construction works commencing, post-

planning application.

Table 2.1 Summary of pre-planning consultation with NYMNPA & AMEC

2.2 Pre-planning meetings

Meetings were held with the EA, NYMNPA and AMEC on 17th February 2014 and 1st September 2014 to discuss a range of issues pertaining to water, wastewater, drainage and groundwater management for the proposed development. The meeting sought to re-confirm any concerns previously raised and to provide further details to these agencies on how these issues will be addressed in the 2014 planning submission. A copy of the meeting minutes is provided in Appendix A.

As per the EA’s planning response letter dated 15th May 2013 (Appendix A), the EA reiterated the requirement for YPL to demonstrate that connection to the existing main sewer network is not viable before agreeing to construction of an on-site treatment plant where effluent would be discharged to Sneaton Thorpe Beck.

The EA stated that as part of the assessment, a Whole Life Cost assessment with an appraisal period of 100 years was required comparing on-site treatment option with a connection to the Yorkshire Water mains sewer. At the meeting NYMNPA and the EA noted that cost is only one factor to be considered in the evaluation and stated that the assessment should be based on practicality, viability and sustainability.

The scope of this report does not include that evaluation of on-site and off-site options. The evaluation of options is reported separately in REP-P2-FD-001.





Page 9

3 Proposed Development

3.1 Description

The proposed development at the Dove’s Nest site can be split into two key areas, namely buildings associated with the minehead and the proposed office / miners’ welfare / facility building. In addition a security gatehouse will be provided in close proximity to the miners’ facility building.

Concept layout plans for the miner’s facility have been prepared by Cartwright Pickard Architects. An indicative site layout plan is provided in Appendix D.

3.2 Development phases

A number of development phases are anticipated during the life of the proposed mine. The key development phases include:

• Construction phase: Site clearance, access roads, primary drainage infrastructure, bulk earthworks, construction of the mine shaft and associated buildings, construction of the miners’ facility building and security gatehouse, construction of the proposed on-site package treatment plant.

It is assumed that under this phase, the appointed contractor will be responsible for providing adequate welfare facilities for all site staff including sewage collection and disposal facilities.

• 6.5Mtpa production: Annual production of potash of up to 6.5Mtpa. Under this scenario, the treatment plant will be operational and support up to 299 persons on site per 24 hour period (YPL Anticipated worker demand).

• 13Mtpa production: Annual production of potash of up to 13Mtpa. Under this scenario, the treatment plant will be operational and support up to 481 persons on site per 24 hour period (YPL Anticipated worker demand).

3.3 Sources of domestic foul sewage

The proposed Sewage Treatment Works (STW) will be designed primarily to treat domestic foul sewage generated from the miners’ welfare facilities, security gatehouse and wastewater generated by underground workers.

At this time, no details are available pertaining to the proposed minehead buildings and the requirement for foul sewage collection facilities as part of this development. It has been assumed that above ground day workers in the minehead building will make use of the facilities in the miners’ welfare building.

Foul sewage generated within the mine shaft during shifts will be collected and transported to the surface in cassettes. Foul sewage generated by underground workers will be added to the treatment plant at a designated discharge point, located in proximity to the proposed STW.





Page 10

3.3.1 Miners’ welfare building

Concept architectural layouts for the proposed miners’ facility and security gatehouse building have been prepared by Cartwright Pickard Architects and have been used as the basis of determining the anticipated water and foul sewer demands for these buildings.

The miners’ welfare building will comprise office space, training facilities, male & female wash rooms and changing rooms, canteen (with industrial kitchen), equipment stores, medical centre, a small laboratory and plant rooms. Table 3.1 summarises the domestic waste producing assets proposed.

Amenity Number of

installations

British Water

“Sizing criteria,

Treatment capacity

for sewage

treatment systems”

BS EN 12056 “Gravity Drainage systems inside

buildings: Part 2 Sanitary pipework, layout

and calculation”

Sewage

per

appliance

per use

(litres)

Total

sewage

per use

(litres)

Discharge Units

per appliance

(table 2,

assuming

system I)

Frequency

factor (table

3, congested

use & special

use)

Peak flow

per

appliance

using DU

method (l/s)

Toilets 35 10 350 2.5 1.0 9.4

Urinals 12 5 60 0.5 1.0 2.5

Washbasins 48 - - 0.5 1.0 4.9

Showers (Female) 6 40 240 0.6 1.2 2.3

Showers (Male) 104 40 4,160 0.6 1.2 9.5

Totals 95 4,810 13.6

Table 3.1 Summary of sewage generating appliances in Miners’ facility building (excluding

canteen)

Details of the proposed on-site canteen have not yet been developed. However this will be sized to accommodate up to 554 people (the anticipated 13Mtpa production worker demand). Based on British Water guidelines, it has been assumed that up to 50l/person/day of sewer flows will be generated.

Table 3.1 has estimated peak sewage generation from the miners’ facility building using two different methods:

• British Water “Sizing criteria, Treatment capacity for sewage treatment systems”





Page 11

• BS EN 12056: Part 2 “Gravity Drainage systems inside buildings: Part 2 Sanitary pipework, layout and calculation”

Both are established methods used for estimating sewage volumes and peak sewage flow rates. The British Water guidelines consider the total sewage volume generated by an activity (e.g. a shower on average consumes 40l of water). BS EN 12056 uses the discharge unit method which considers the joint probability of all appliances being utilised at the same time to estimate the peak instantaneous flow rate of sewage generated.

Both sets of information are useful in understanding the required sewage pipe sizing, balancing tank requirements, treatment plant capacity and peak water demand on-site.

From Table 3.1, it can be seen that the critical sewage generation scenario is when the showers operate (male & female) together generating up to 4,400 litres of sewage. The discharge unit method indicates that peak discharge from the showers could reach up to 11.8 l/s. Review of the estimates derived using the British Water data and the BS EN12056 would suggests an average shower duration of 6.5 minutes, which intuitively appears sensible.

It is however acknowledged that the typical water usage data provided in the British Water guidance document may not be fully reflective of the requirements for mine workers. Precise water demands and sewage generation data from the mining industry may need to be examined further during detailed design.

3.3.2 Security Gatehouse

The gatehouse building will contain a security control centre, small kitchen / dining area and toilet facilities. Based on the current layout, the gatehouse is assumed to have 2No. toilets, 2No. washbasins and 1No. kitchen sink. Table 3.2 summarises anticipated sewage generation at the gatehouse.

Amenity Number of

installations

British Water

“Sizing criteria,

Treatment capacity

for sewage

treatment systems”

BS EN 12056 “Gravity Drainage systems inside

buildings: Part 2 Sanitary pipework, layout

and calculation”

Sewage

per

appliance

per use

(litres)

Total

sewage

per use

(litres)

Discharge Units

per appliance

(table 2,

assuming

system I)

Frequency

factor (table

3, congested

use & special

use)

Peak flow

per

appliance

using DU

method (l/s)

Toilets 2 10 20 2.5 1.0 2.3

Washbasins 2 - - 0.5 1.0 1.0

Kitchen sink 1 15 15 0.8 1.0 0.9





Page 12

Totals 25 35 2.6

Table 3.2 Summary of sewage generating appliances in security gatehouse building

From Table 3.2, it can be seen that the peak flow generated from the security gatehouse building may reach up to 2.6l/s with a peak sewage volume of 35 litres per use. The magnitude of the peak flow is much lower than from the miner’s facility building and therefore not likely to be a determining factor in the design or the on-site STW.





Page 13

4 Sewage estimates

4.1 Anticipated worker data

The 2013 planning application considered use of the site by up to 800 workers per day and applied an industrial consumption rate of 90 l/person/day, as per British Water’s publication “Flows and Loads – 4, Sizing criteria, Treatment Capacity for Sewage Treatment Systems”. For the 2013 application, detailed breakdowns of anticipated worker numbers were not available therefore necessitating the use of broad industry based estimates. At this time, a more detailed breakdown of anticipated worker types and shift patterns are available facilitating a better understanding of the likely demands and rates of foul sewage generation.

Information supplied by YPL has been used to estimate the daily anticipated sewage volumes. The anticipated peak worker profile for the site over a 24hour period is summarised in Table 4.1.

Two production scenarios are presented in this table, namely the 6.5Mtpa and 13Mtpa production scenarios. As discussed in Section 3.3.1, the proposed treatment works have been designed to accommodate the ultimate 13Mtpa production capacity.

Worker

assignment

Arrival

time

Depart

time

Time

on site

(hrs)

Staff

No.

6.5Mtp

a

Staff

No.

13Mtpa

Individual

usage

(l/per/day)

Total

usage

6.5Mtpa

(l/day)

Total

usage

13Mtpa

(l/day)

Average

flow

6.5Mtpa

(l/s)

Average

flow

13Mtpa

(l/s)

Mine

Management

07:30 17:00 9:30 50 65 100 5,000 6,500 0.146 0.190

Office based 08:00 17:00 9:00 5 5 100 500 500 0.015 0.015

Days only 06:45 16:30 9:45 47 66 153 7,207 10,120 0.205 0.288

Production

(Miners)

- - 24:00 135 255 153 20,700 39,100 0.240 0.453

Infrastructure - - 24:00 38 66 153 5,827 10,120 0.067 0.117

Shaft workers 06:45 19:30 12:45 18 18 153 2,760 2,760 0.060 0.060

Security - - 24:00 4 4 100 400 400 0.005 0.005

Cleaners 15:00 19:00 4:00 2 2 50 100 100 0.007 0.007

Totals 299 481 42,493 69,600 0.492 0.806

Table 4.1 – Sewage flow generation based on proposed worker numbers





Page 14

Based on the 6.5Mtpa production scenario, a total sewage volume of approximately 43m3 is estimated, increasing to 68m3 for the 13Mtpa production scenario. The proposed STW is therefore designed based on the upper bound 68m3/day estimate.

Based on user demand data provided in Table 5.1 and guidance provided in British Water treatment sizing guidance, Biological Oxygen Demand (BOD) loading for the 13Mtpa scenario is 28.5kg/day with Ammonium loading of 3.5kg/day. These parameters have been used to establish the treatment plant sizing required.

4.2 Sewage estimation assumptions

In developing anticipated sewage generation data, the following assumptions have been made. These will be verified during detailed design but at this time are considered representative of the likely demands:

• All staff (underground workers and office staff) will have access to the proposed on-site canteen facility, located within the miners’ facility building. As per British Water guidance, it is assumed that this will increase sewage flow per person by up to 50l/person/day.

• Underground workers will generate up to 30l/person/shift of foul sewage. This will need to be transported to the surface and will be added to the treatment works via a designated discharge point. Under the 13Mtpa scenario, up to 395 underground workers will produce approximately 12m3 of sewage per 24 hour period. It is assumed wastewater will be transported to the surface every 8 hours, each dump equating to 4m3.

• Underground workers are assumed on average to generate a further 60l/person/shift of foul sewage when on the surface (through toilet use, hand-washing & showers). It is assumed that all underground workers will take a shower upon completion of a shift (40l/person) and up to 1/3 of these underground workers will also take a shower prior to commencing their shift.

• Office based and security workers are assumed to produce up to 50l/person/shift, as per British Water guidelines. It is assumed that no office based workers will take a shower on-site.

It has been established that the average sewage flow generated under the 6.5Mtpa scenario will be 0.49l/s increasing to 0.81l/s in the 13Mtpa production scenario. However these values are time averaged over 24 hours and do not represent the peak flows to be discharged from the development.

The proposed STW will be designed with a flow balancing tank at the head of the works, designed to ensure peaks in discharge are routed through the STW at a flow rate of 0.81 l/s. It is anticipated that consented discharge to Sneaton Thorpe Beck will be granted on the basis of a maximum permitted volumetric discharge per day but that on average flows will be maintained at the 0.81 l/s discharge rate.





Page 15

5 Treatment Plant Requirements

Concept designs for the proposed on-site package treatment plant were prepared by WPL Ltd in December 2013. As part of this assessment, further clarification has been sought from WPL to confirm the design parameters and anticipated performance of the plant. As the overall daily loading (sewage volume, BOD & NH4) has not changed significantly, the previously proposed treatment chain remains suitable for the current scheme.

5.1 Balancing tank

Due to the variable shift patterns proposed and peak flows arising from emptying the underground worker’s sewage tanks, it is anticipated that significant peaks in sewage generation are likely to occur. Up to 85 underground workers finish shift at the same time resulting in increased sewage generation through showers, toilet use and general washing facilities.

Providing a consistent throughput to the STW is important to maintain the biological bacteria required for the plant operation and to ensure compliance with the consented discharge is achieved.

A flow balancing tank is proposed at the head of the STW to ensure that an average flow through the works is consistently achieved. It is estimated that a 30m3 balancing tank is required under the 13Mtpa production scenario. Pumps installed in the balancing tank will be used to regulate the flow through the STW within a specified design range.

5.2 Primary tank

A below ground primary settlement tank will be provided at the head of the works, immediately downstream of the proposed balancing tank. Concept designs developed by WPL suggest a single tank sized 8.9m long x 3m deep x 2.86m wide will be sufficient (see drawing DD-111-898, Appendix C). The primary tank will be fed by pumps installed within the proposed balancing tank.

5.3 Biozones

2No. below ground biozones formed in Glass Reinforced Plastic (GRP) will be provided for the biological treatment of the sewage. The biozones will be constructed in parallel with upstream valve work to allow each biozone to be isolated for repair and maintenance without impacting on the plant performance.

Each biozone is proposed to measure 4.8m long x 3m deep x 2.86m wide and will host an engineered bacterial culture designed for digestion of the organic fraction of the wastewater (see drawing DD-111-945, Appendix C).

5.4 Humus tank

A humus settlement tank will be provided for the collection and removal of sludge material generated during the process. The below ground tank will be 5.5m long x 3m deep x 2.86m wide (see drawing DD-111-911, Appendix C). Based on the 13Mtpa production scenario, it is estimated that this tank will require emptying on





Page 16

a 54 day timetable. Extracted sludge will be transported to a suitable treatment works (such as Whitby WwTW) for further thickening and disposal.

5.5 Sand filter

Further to discussions with the Environment Agency during development of the 2013 application, tertiary treatment will be provided in the form of a VSF04 Sand Filter. This replaces the requirement for treated effluent to pass via bio-remediation ponds before discharging to Sneaton Thorpe Beck.

The below ground sand filter will be formed in GRP and will measure 3.05m diameter x 3.05m deep incorporating a backwash pump (see drawing DD-140-180, Appendix C).

5.6 Power supply

A number of pumps, blowers and compressors are required as part of the treatment process. These items and associated control & instrumentation systems will require a suitable power supply to be provided to the STW compound. Based on the anticipated power requirements on site, a 3 phase (415V AC) power supply is required.

5.7 Operation and Maintenance Regime

The operating regime includes extracting sludge from the humus tank every 54

days, to be transported to a suitable sludge handling facility. Maintenance

contracts will be established which typically enable attendance at the site within 3

hours to carry out any required maintenance. In the eventuality of plant

shutdown, there will be a high level alarm to alert the site and a rolling emergency

contract will ensure that emergencies are dealt with immediately and if need be a

tanker can be used to extract the waste every day.

Of the main components of the treatment plant listed above, there will be two

biozones run in parallel therefore one can be taken offline for repairs, while the

other one is kept online without affecting the process. The balancing tank has a

capacity of 30m3, which is equivalent to retaining the raw sewage for 12 hours;

therefore when repairs need to be carried out on any other components, the

balancing tank can be emptied and then the valves closed while the repairs and

maintenance are carried out. If work needs to be carried out on the balancing tank

itself, temporary tanks can be brought on to site through maintenance

contracts.Therefore maintenance and repair of the components can be carried out

and mitigation measures put in place so as not to affect the performance of the

plant.





Page 17

6 Water Quality in Sneaton Thorpe Beck

Concerns have been raised by the EA, NYMNPA and AMEC regarding the potential for the proposed on-site STW to impact on water quality within the Sneaton Thorpe Beck. The issues raised by these parties have been summarised in Table 2.1.

6.1 Existing Catchment Status

Table 6.1 below indicates the concentrations of ammonia required for different WFD classifications. The existing catchment classification is ‘Poor’ but with a current target of ‘Good ecological status’ byr 2027, and a possible aspiration to achieve ‘High ecological status’ in parts of the catchment. In assessing the impact of the proposed discharge on water quality in the receiving watercourse, the key determinand in the sewage effluent is the concentration of Ammoniacal Nitrogen, the benchmarks for which are included in table 6.1 below:

WFD Benchmarks Ammonia concentrations in the watercourse

Moderate > 0.6 mg/l

Good 0.2 – 0.6 mg/l

High < 0.2 mg/l

Table 6.1: Benchmarks for ammonia concentrations required for WFD status

6.2 H1 Environmental Assessment

As part of the 2013 application, Atkins produced a H1 Assessment demonstrating that the proposed treated effluent would not impact significantly on water quality in Sneaton Thorpe Beck. The proposed treatment plant will produce treated effluent achieving less than or equal to 10mg/l suspended solids, 10mg/l BOD, and 2mg/l NH4. Appendix D contains examples of two other WPL treatment plants and sample data from the plants in operation, showing the ammonia levels in the effluent, all of which are below 2 mg/l.

At the time of the 2013 application, limited baseline water quality monitoring data was available for Sneaton Thorpe Beck, limiting the confidence in the baseline values used for the H1 assessment.

Further baseline water quality data for Sneaton Thorpe Beck is now available, spanning from January 2013 to August 2013 (Appendix B). This data suggests that baseline ammonium concentrations are broadly consistent with those previously used for the H1 assessment.

In total, 34No readings were taken over the survey period. 7No. of these readings recorded baseline ammonium levels in the beck above Freshwater Fish Directive guideline of 0.2mg/l. 12 No. readings were recorded with concentrations below 0.015mg/l.





Page 18

The average ammonium concentration measured across the monitoring period was 0.83mg/l. However this is heavily influenced by a peak reading of 15mg/l recorded on 24 July 2013. The second highest peak is 1.2mg/l and it is therefore considered that this reading may be an outlier.

Removing this peak reading from the record data series, the average baseline concentration drops to 0.155mg/l, and it is this value that is used in the H1 Assessment. Appendix F provides a summary of the H1 Assessment.

The initial H1 assessment was carried out using a channel flow rate of 2 l/s derived from statistical low flow analysis. On the 28th of August 2014, Royal Haskoning employed a sub-contractor to install 3 flow monitor sensors in Sneaton Thorpe Beck. Observed flow data collected from these flow monitors is used in the latest H1 Assessments. The results of the revised H1 Assessments are included in Appendix F.

6.3 Water Framework Directive

The Water Framework Directive (WFD) places statutory requirements on those responsible for UK watercourses, to preserve and enhance the health of those watercourses. The WFD aims for all UK water bodies to achieve “Good Ecological Status” by 2027 unless they can be demonstrated as exempt on the grounds of disproportionate cost or technical feasibility.

Under the WFD, any proposed development is required to primarily:

a) Ensure that the development does not result in deterioration of the water body

b) Ensure that the development does not prevent the future attainment of a "Good ecological status" or higher

It is accepted that construction of the proposed on-site treatment plant will not result in an improvement to the WFD water body as concentrations of ammonium are likely to increase.

Similarly, it is considered that introduction of the proposed STW will not form an obstacle to the water body achieving “high ecological status”.

Based on consultations to date, it is assumed that the EA will grant discharge consent for 2mg/l ammonium. However should the EA choose to impose a more stringent discharge requirement, the proposed on-site treatment process can be expanded to achieve this i.e. it is viable to achieve higher levels of ammonium removal if required.

Appendix A

Consultation Records

5115159_TN001 Addressing EA concerns with Foul water discharge_Issue 1

Technical note

Project: York Potash To: Environment Agency

Subject: Foul Discharge - Environmental Objections

From: Peter Thorn

Date: 4 Jun 2013 cc:

The following submission has been prepared to address concerns expressed by the Environment Agency in their letter reference RA/2013/124384/02, dated 15

th May 2013 regarding the foul discharge from the York

Potash development at the Doves Nest Farm. The concerns were also discussed during a meeting between York Potash, Atkins and the Environment Agency of 28

th May 2013. The outcomes of this meeting have been

taken into account in this response.

Financial Cost of Connecting to Mains Sewer Versus Non Mains Alternative

“The financial cost of connecting to a mains sewer must be compared against the whole-life costs of the non-mains alternative, including all direct, indirect and ongoing running costs of the complete foul drainage system. In this case we would expect the lifetime of the project to be at least a hundred years.“

Yorkshire Water Services (YWS) are currently investigating the capacity of existing sewer network close to the site - with a response expected within the next three weeks. Should this be favourable, this option shall be reviewed in greater detail at the detailed design stage.

Impact of Sewer Mains Connection to the Surrounding Area

“Environmental costs could include constructional impacts, impacts on the receiving environment, the sustainability implications of any pumped discharges, and the impacts of any improvement works to existing sewers or sewage treatment works. The submitted Design Principles document mentions that in this case “major disruption” would result through installing a new sewage pipe in the National Park, however this assessment is not substantiated with supporting information and is not informed by appropriate information from Yorkshire Water regarding the likely connection point and the nature/extent/cost/impacts of any improvement works which may be necessary.”

Yorkshire Water Services (YWS) are currently investigating the capacity of existing sewer network close to the site - with a response expected within the next three weeks. Should this be favourable, this option shall be reviewed in greater detail at the detailed design stage.

Difficulties Associated with Effluent Treatment and Management

“The proposed welfare facility would accommodate a population-equivalent of around 800 people and would include toilets, kitchen, laundry and shower facilities. Given that the mine will operate 24/7 we also understand that the workforce will operate a shift pattern. This will mean there will be significant peaks and troughs in foul flows which may pose difficulties for effluent treatment and management. Given these factors and the likely sensitivity of the receiving watercourses, Sneaton Thorpe Beck (and Rigg Mill Beck/Long Mill Beck downstream) – given their size and because they are already impacted by the historical proliferation of non-mains foul drainage in the area – it is essential that any non-mains option is shown to be suitable.“

As stated within the Foul Water Treatment – Design Principles presented in Appendix B of the revised H1 assessment:

“The flows will be balanced by an underground tank of approximately 30 m3 volume to account for the three

peak times of flow during shift changes. The flows will be pumped at a constant rate by submersible pumps into the treatment plant. Peak higher flows will be passed forward to the treatment plant in order to prevent overflow from the tank into watercourses.”

It should also be noted that no laundry facilities are to be provided at the site, as discussed in the meeting between Atkins, York Potash and the Environment Agency of 28

th May 2013.


Technical note Clarification of the Sewage Treatment Process to Meet Agreed Discharge Consent

“The supporting documentation proposes a final effluent quality of 10mg/l Biological Oxygen Demand, 10mg/l Suspended Solids and 2mg/l Ammonia which seems considerably higher quality than the guaranteed effluent quality normally expected from a package treatment plant. It is also asserted that the proposed reed bed will provide yet further improvements to the effluent quality. It should be noted that the package treatment plant brochure included with the original Environmental Statement makes clear that such a plant is capable of treating „up to‟ this quality and only with the addition of tertiary treatment such as a reed bed. It therefore seems that incorrect assumptions have been made about the plant‟s ability to treat to this standard. In order for us to accept this indicative quality for the purposes of assessing its impact on Sneaton Thorpe Beck, we will need additional information about the design specification of the proposed package treatment plant and examples of other similar existing plants which demonstrate their ability to routinely achieve the aspired effluent quality. Alternatively, a more realistic indicative quality could be assumed, but the predicted impacts on Sneaton Thorpe Beck, particularly in relation to Water Framework Directive objectives, would need to be re-visited.“

The foul drainage treatment process has been revisited in line with the Environment Agency concerns. The foul effluent now discharges via a sand filter prior to discharging into the Sneaton Thorpe Beck and is separate from the SuDS. The expanded details of the proposed process are outlined within the Foul Water Treatment - Design Principles in Appendix B of the revised H1 assessment and are shown on drawing 5115159/P/C/600. It should be noted that at this stage the majority if not all components of the sewage treatment, including the storage tank, main biological treatment and tertiary sand filter, are anticipated to be buried within the earthworks to form the platform of the welfare facility or below existing ground level so as to minimise visual impact. In addition, they will be sited in the existing woodland for further screening.

It is understood from the meeting that the Environment Agency are comfortable that a system of flow balancing, biological treatment and sand polishing should be able to meet the discharge requirements as laid out in the revised H1 assessment enclosed. However, examples of similar schemes with tertiary treatment are being obtained and will be issued separately to provide the Environment Agency with further confidence in the proposed treatment.

The review of the impact on the receiving watercourse as presented in the revised H1 assessment report 5115159/TR005 confirms that the amended process meets the criteria outlined within the previous H1 Assessment. The revised report is enclosed with this submission..

Addressing Foul Effluent Discharge Concerns

“Furthermore we have concerns about the proposed means of managing treated effluent between the package treatment plant and Sneaton Thorpe Beck. At present, it is proposed to discharge the effluent into an attenuation pond which has a primary purpose of receiving and attenuating surface water run-off. Whilst discharging treated foul effluent into this pond may provide additional opportunity for settlement, we are concerned that there could be a build up of nutrients within the attenuation pond causing odour, environmental nuisance and eutrophication of the pond. We are also concerned that during periods of intense/prolonged rainfall, settled foul pollutants may be flushed out of the pond into Sneaton Thorpe Beck. These impacts may contribute to WFD objectives failing to be met. The combining of foul and surface water systems also presents difficulties for the permitting and regulation of this operation. The compliance point may need to be at the discharge to Sneaton Thorpe Beck, which would have a variable quantity and quality given the fluctuations in surface water inputs. The permit discharge volume would also need to be based on the combined foul and surface water quantities which would incur additional unnecessary cost on the fee for the permit. If the compliance point was to be prior to discharge into the attenuation pond, the prescribed qualities could not take into account any beneficial effects of the attenuation pond or reed bed. If the benefits of the reed bed are important to the discharge quality, we would need to see the reed bed located prior to the attenuation pond such that its polishing effect can be accounted for in any permit. Whilst we note paragraphs 7.53 and 7.54 explaining that the foul effluent will not be added to the SUDS until the final stage of the SUDS management train, there does still seem to be considerable uncertainty about what is actually proposed. For the above reasons we would like further clarity about what is actually proposed and expect to see the foul and surface water systems separated for the above environmental and permitting reasons.”


Technical note Further to discussions at the meeting of 28

th May 2013, following treatment from the tertiary treatment plant,

the foul effluent will discharge directly into Sneaton Thorpe Beck as detail on drawing 5115159/P/C600 rather than to the wetland associated with the SuDS.

Summary

In summary, each of the points raised by the Environment Agency have been addressed in this submission to provide confidence that planning may be granted with respect to foul drainage at the proposed mine site. It is expected that the planning will include conditions to deal with foul drainage including detailed design of the final treatment, with justification of the need to treat on site and argument as to why discharge to Yorkshire Water’s foul drainage network should discharge to sewer not be taken forward.

Sufficient information should now have been provided to give the Environment Agency confidence that a sewage treatment plant can be build at the site to accommodate the predicted effluent and meet the anticipated discharge quality required for the permit. Such a plant, were it to be needed, would be regulated under an environmental permit.

Ms Jane Davies North York Moors National Park Development Control The Old Vicarage Bondgate Helmsley York YO62 5BP

Lateral, 8 City Walk, Leeds. LS11 9AT

Our ref: RA/2013/124384/02 Your ref: NYM/2013/0062/MEIA Date: 15 May 2013

Dear Ms Davies,

THE WINNING AND WORKING OF POTASH (POLYHALITE) BY UNDERGROUND METHODS FROM 25,300 HECTARES OF LAND TOGETHER WITH CONSTRUCTION OF MINE INCLUDING SINKING OF 2 NO. DEEP SHAFTS, RETENTION/DISPOSAL/REMOVAL/LANDFORM MODIFICATION OF ASSOCIATED SPOIL, CONSTRUCTION OF BUILDINGS INCLUDING WELFARE/OFFICE BLOCK AND MINEHEAD PRIMARY PROCESSING BUILDINGS, ACCESS ROADS AND CAR PARKING, HELICOPTER EMERGENCY LANDING SITE, ATTENUATION PONDS AND LANDSCAPING RESTORATION AND AFTERCARE. LAND BENEATH THE EASTERN SIDE OF THE NORTH YORK MOORS NATIONAL PARK TOGETHER WITH MINEHEAD AT LAND AT DOVES NEST FARM AND HAXBY PLANTATION, SNEATON. We have examined the submitted planning application, its supporting Environmental Statement and the additional information provided in response to the National Park Authority‟s EIA Regulation 22 request for further information.

The Environment Agency OBJECT to the planning application submitted on the basis that inadequate information has been provided about the development proposed; the impacts it may have on the environment; and the mitigation measures proposed. In particular, inadequate information has been provided in relation to the following matters:-

1. Groundwater Protection - The impact the sub-surface elements of the development will have on groundwater and its associated springs, watercourses, abstractions and habitats;

2. Foul Drainage Disposal - The impact the proposed foul drainage discharge from the welfare facilities will have on Sneaton Thorpe Beck and adjacent watebodies.

Groundwater Protection

Our Role - We are a statutory body responsible for the protection and management of groundwater resources in England and Wales. We have a duty to maintain and protect the quality and quantity of groundwater resources for current and future uses.

As part of this role we are responsible for ensuring that groundwater-dependent terrestrial ecosystems are not unacceptably affected as a result of development, in accordance with the Environmental Impact Assessment Regulations, the Groundwater Directive and the Water Framework Directive. In this instance, given that the groundwater-dependent terrestrial ecosystems in question also lie within the designated site, the development‟s impact on these habitats will also be considered by the Habitats Regulations Assessment. You should therefore expect that both ourselves and Natural England will provide comments on this specific impact. Please note however that whilst there is overlap on this particular facet of groundwater protection between the Environment Agency and Natural England, given that the two organisations are steered by different legislation, there may be legitimate differences in the focus of our respective concerns and the level of detail and certainty which may be needed to overcome any objection.

Our Position - We object to the proposed development as submitted because an inadequate risk assessment of the development‟s impact on groundwater flows has been provided. The information submitted has also failed to demonstrate that the risks posed to the water environment can be satisfactorily managed through mitigation.

Impermeable construction below the groundwater table such as sheet-piles, grout cut-off walls, sub-water table structures, and tunnel shafts can obstruct groundwater flow. The hydrology and hydrogeology at this location is susceptible to the impact of changes in groundwater flow as identified in the York Potash Groundwater Model produced by ESI (Report reference: 61415R1, April 2013).

The Hydrogeological Risk Assessment produced by FWS (Report reference: 1433/April 2013) has concluded that following the construction of the mine, the changes in groundwater flow paths and the reduction of infiltration recharge around the Main Plant area will cause an unacceptable impact on the Doves Nest Spring. To overcome this impact, mitigation will clearly be required. Unfortunately, detailed mitigation designs have not been provided.

The submitted groundwater model has not fully characterised the groundwater regime at the site, and as a result has a number of limitations. The hydrogeology at the site is complex, with several shallow aquifers underlying the site, whilst also being located on a natural groundwater flow divide. In particular:-

The groundwater model used estimated spring flow volumes;

The groundwater model only used three months of data;

The groundwater model has used solely high water level conditions;

In the absence of seasonal data, no sensitivity analysis was carried out to model drought conditions;

The model has amalgamated the shallow aquifers - the model is not multi-layered to represent true hydrogeological conditions;

There are significant unknowns in the conceptual model on which the groundwater model was based;

Calibration of the data has been difficult due to limited data and limitations of the chosen approach.

Overcoming Our Objection - We are currently objecting because insufficient information has been provided to allow us to come to an informed view as to the development‟s impact on groundwater. In accordance with our Groundwater Protection: Principles and Practice we will maintain our objection until we receive a satisfactory risk assessment demonstrating that the risks to groundwater posed by this development can be satisfactorily managed. In particular, the submitted Hydrogeological Impact Assessment has not submitted sufficient information to demonstrate:-

Maintenance of groundwater fed watercourses and spring-fed flows;

Protection of licensed and un-licensed abstractions;

Protection of groundwater-dependent terrestrial ecosystems.

A mitigation measure has been proposed to augment water supply to the catchment areas of the Doves Nest Farm Spring and reduce groundwater mounding to the south west of the site through the use of a groundwater drainage system. No detailed design for this mitigation measure has been provided, nor any information regarding how it will be managed on an ongoing basis. Mitigation measures should be designed such that they will remain effective during a worst case scenario, for example during times of drought or flood.

An adequate hydrogeological and hydrological assessment will need to be submitted which demonstrates that the development will not result in unacceptable impacts as a result of the development‟s obstruction of groundwater flows. If this cannot be achieved we are likely to maintain our objection to the application. The impact assessment should include any design measures to mitigate the identified risks.

Foul Drainage

Our Role – We are a statutory consultee on proposals involving non-mains foul drainage disposal. As a consultee we are steered by the foul drainage hierarchy and must ensure that any impacts on the water environment are acceptable. As competent authority for the Water Framework Directive (WFD), we look to ensure that WFD objectives are not compromised by foul drainage proposals. We also have responsibility to control effluent discharges through the Environmental Permitting Regulations. For discharges that require Environmental Permits we work to ensure that there is adequate information provided at planning stage to satisfy us that what is proposed will be environmentally acceptable and capable of subsequently attaining an Environmental Permit.

Our Position - Consideration of foul drainage disposal is steered principally by DETR Circular 03/99 which sets out a hierarchy of disposal options. At the top of this hierarchy is disposal to mains foul sewer. We therefore welcome York Potash‟s commitment (as stated in ES11 add 7.51) to a thorough investigation of the mains sewerage options, which must include use of the various legal mechanisms under section iv of the Water Industries Act in relation to connection, requisition and adoption. The Environment Agency‟s Pollution Prevention Guidance Note 4, and guidance on effluent disposal in sewered areas should be followed in carrying out and reporting back on such investigation.

The Environment Agency‟s general approach is that where mains sewerage is available and it is reasonable to expect a connection to be made, an Environmental Permit for a non-mains foul drainage option would not be issued. Consideration of „availability‟ would include the proximity of the mains sewer and any need for the sewers or treatment works to be expanded or enlarged, along with an assessment of any environment impacts resulting from such works. The question of whether it is „reasonable‟ to expect a connection to be made is undertaken on a case-by-case basis and depends on several factors, including the financial and environmental costs of getting to the sewerage network.

The financial cost of connecting to a mains sewer must be compared against the whole-life costs of the non-mains alternative, including all direct, indirect and ongoing running costs of the complete foul drainage system. In this case we would expect the lifetime of the project to be at least a hundred years.

Environmental costs could include constructional impacts, impacts on the receiving environment, the sustainability implications of any pumped discharges, and the impacts of any improvement works to existing sewers or sewage treatment works. The submitted Design Principles document mentions that in this case “major disruption” would result through installing a new sewage pipe in the National Park, however this assessment is not substantiated with supporting information and is not informed by appropriate information from Yorkshire Water regarding the likely connection point and the nature/extent/cost/impacts of any improvement works which may be necessary.

Based on the information provided with the application, there is insufficient information to adequately rule out a mains sewer connection. Our position is that provided the applicant is able to demonstrate that a satisfactory non-mains disposal option is available and which would, in principle, be capable of being permitted by the Environment Agency, we would be content to cover this issue with an appropriately worded planning condition, which would first require the applicant to further explore the feasibility of a mains connection. You should satisfy yourselves that you would be content with such an approach as if not, significant additional information to rule in/out a mains connection would be necessary prior to determination. Notwithstanding the above, at present we do not feel we have sufficient certainty that a non-mains disposal option would be environmentally acceptable and that an

Environmental Permit could be granted. As such we are currently objecting on these grounds.

The proposed welfare facility would accommodate a population-equivalent of around 800 people and would include toilets, kitchen, laundry and shower facilities. Given that the mine will operate 24/7 we also understand that the workforce will operate a shift pattern. This will mean there will be significant peaks and troughs in foul flows which may pose difficulties for effluent treatment and management. Given these factors and the likely sensitivity of the receiving watercourses, Sneaton Thorpe Beck (and Rigg Mill Beck/Long Mill Beck downstream) – given their size and because they are already impacted by the historical proliferation of non-mains foul drainage in the area – it is essential that any non-mains option is shown to be suitable.

The supporting documentation proposes a final effluent quality of 10mg/l Biological Oxygen Demand, 10mg/l Suspended Solids and 2mg/l Ammonia which seems considerably higher quality than the guaranteed effluent quality normally expected from a package treatment plant. It is also asserted that the proposed reed bed will provide yet further improvements to the effluent quality. It should be noted that the package treatment plant brochure included with the original Environmental Statement makes clear that such a plant is capable of treating „up to‟ this quality and only with the addition of tertiary treatment such as a reed bed. It therefore seems that incorrect assumptions have been made about the plant‟s ability to treat to this standard. In order for us to accept this indicative quality for the purposes of assessing its impact on Sneaton Thorpe Beck, we will need additional information about the design specification of the proposed package treatment plant and examples of other similar existing plants which demonstrate their ability to routinely achieve the aspired effluent quality. Alternatively, a more realistic indicative quality could be assumed, but the predicted impacts on Sneaton Thorpe Beck, particularly in relation to Water Framework Directive objectives, would need to be re-visited.

Furthermore we have concerns about the proposed means of managing treated effluent between the package treatment plant and Sneaton Thorpe Beck. At present, it is proposed to discharge the effluent into an attenuation pond which has a primary purpose of receiving and attenuating surface water run-off. Whilst discharging treated foul effluent into this pond may provide additional opportunity for settlement, we are concerned that there could be a build up of nutrients within the attenuation pond causing odour, environmental nuisance and eutrophication of the pond. We are also concerned that during periods of intense/prolonged rainfall, settled foul pollutants may be flushed out of the pond into Sneaton Thorpe Beck. These impacts may contribute to WFD objectives failing to be met.

The combining of foul and surface water systems also presents difficulties for the permitting and regulation of this operation. The compliance point may need to be at the discharge to Sneaton Thorpe Beck, which would have a variable quantity and quality given the fluctuations in surface water inputs. The permit discharge volume would also need to be based on the combined foul and surface water quantities which would incur additional unnecessary cost on the fee for the permit. If the compliance point was to be prior to discharge into the attenuation pond, the

prescribed qualities could not take into account any beneficial effects of the attenuation pond or reed bed. If the benefits of the reed bed are important to the discharge quality, we would need to see the reed bed located prior to the attenuation pond such that its polishing effect can be accounted for in any permit.

Whilst we note paragraphs 7.53 and 7.54 explaining that the foul effluent will not be added to the SUDS until the final stage of the SUDS management train, there does still seem to be considerable uncertainty about what is actually proposed. For the above reasons we would like further clarity about what is actually proposed and expect to see the foul and surface water systems separated for the above environmental and permitting reasons.

Overcoming Our Objection - We will either need additional information about the design specification of the proposed package treatment plant and examples of other similar existing plants which demonstrate their ability to routinely achieve the aspired effluent quality; or alternatively, the predicted impacts on Sneaton Thorpe Beck (and adjacent waterbodies) will need to be re-visited based on a more realistic indicative quality. This will need to include an assessment in relation to Water Framework Directive objectives. The proposed system will also need to be amended to separate the foul and surface water systems.

Major Development Test

We are aware that the proposed development must be subject to the „major development‟ test on the basis that the NPPF states that planning permission „should be refused‟ for major developments in National Parks „except in exceptional circumstances‟ and „where it can be demonstrated they are in the public interest‟. We understand that „consideration of such applications should include an assessment of:-

The need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;

The cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and

Any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated‟.

It is not for the Environment Agency to undertake the major development test but we would like to offer the following comments in respect to the second part of the test, which may assist your consideration. Our more detailed comments below on the environmental impacts of the proposal should also inform your consideration of the third part.

We engaged with York Potash early in the process of formulating the current proposal for the potash mine. An issue on which we made comments was the location of the minehead in respect to the protection of groundwater. We expressed a clear preference for the minehead to be steered away from any areas of principal aquifers or source protection zones, on the basis that these would be more vulnerable than the secondary aquifer on which the minehead is now proposed.

Principal aquifers are layers of rock or drift deposits that have high inter-granular and/or fracture permeability - meaning they usually provide a high level of water storage. They may support water supply and/or river base flow on a strategic scale. In most cases, principal aquifers are aquifers previously designated as major aquifer. Source Protection Zones (SPZs) surround groundwater sources such as wells, boreholes and springs which are used for human consumption. The zones show the risk of contamination from any activities that might cause pollution in the area. The closer the activity, the greater the risk.

Please note that we are likely to have objected in principle had the minehead been proposed within a Source Protection Zone 1. Whilst we would not necessarily have objected in principle had the minehead been proposed within other Source Protection Zones or on the Corallian Limestone principal aquifer further south, the degree of risk to the groundwater resource would have been considerably higher. As such we welcome that the minehead proposed has successfully avoided these more sensitive locations.

Next Steps

Given that we are currently objecting due to the lack of information, our preference would be for determination of the application to be deferred in order to allow York Potash to assemble the necessary information.

Should the National Park Authority be minded to grant planning permission contrary to our current objections, we request to be re-consulted and given the opportunity to comment on the inclusion of planning conditions.

We would be pleased to meet with York Potash and their relevant consultants at the earliest opportunity to discuss the additional information needed. Natural England will also need to be involved in any such meeting.

Other Matters

Notwithstanding the above objections we have also considered the proposed development in respect to surface water, pollution prevention, mining waste, subsidence and ecology (excluding groundwater-dependent terrestrial ecosystems). We have no objections in respect to these matters provided a number of detailed planning conditions are included on any planning permission which may subsequently be granted. Surface Water CONDITION: No development shall take place until a Surface Water Drainage Scheme for the site, based on sustainable drainage principles and an assessment of the hydrological and hydrogeological context of the development, has been submitted to and approved in writing by the local planning authority. The drainage strategy should demonstrate the surface water run-off generated up to and including the 1 in 100 critical storm will not exceed the run-off from the undeveloped site following the corresponding rainfall event. The scheme shall include:-

a. The attenuation of the discharge to Sneaton Thorpe Beck to a

maximum of 21.3 litres per second;

b. Sufficient attenuation storage for up to and including the 1 in 100 year

storm event plus a 30% allowance for climate change, and surcharging

the drainage system can be stored on the site without risk to people or

property and without overflowing into the watercourse. This calculation

shall account for any additional drainage from spoil mounds with the

total attenuation storage equating to a minimum of 11,150m3;

c. Attenuation basins shall be designed and constructed such that water is

not held above natural ground level;

d. Details of the outfall to Sneaton Thorpe Beck, including the provision of

a penstock, erosion protection measures and measures to ensure

velocities are limited to no more than 0.4 metres per second;

e. Details of how the whole surface water drainage system will be

designed so as to maximise its biodiversity benefits;

f. The provision of drains at the toe of the spoil mounds;

g. Details of a rainwater harvesting system;

h. The provision of permeable surfacing on areas where the risk of

pollution is low;

i. Details of the reedbed;

j. Details of how clean roofwater shall be discharged to ground;

k. Details of how the entire surface water drainage system will be

maintained and managed throughout the lifetime of the development,

including the construction phase;

l. A timetable for the implementation of the Surface Water Management

Scheme, including during the construction phase.

Development shall thereafter proceed only in strict accordance with the approved Surface Water Management Scheme and the timetable included within it. REASON: To ensure a satisfactory means of surface water management. To reduce the risk of flooding. To ensure erosion in Sneaton Thorpe Beck is not increased. Pollution Prevention

CONDITION: Prior to the commencement of development a Construction Environmental Management Plan (CEMP) shall be submitted to and approved in writing by the Local Planning Authority. The CEMP shall include:

a. Details of the size, location and design of any site compounds, including

how any potentially polluting materials will be stored to minimise the risk of

pollution;

b. All fuel/oil to be stored in proprietary tanks with integral bunding with a

capacity equal to not less than 110% of the capacity of the tank. Such

tanks shall be located on a bunded, impervious hardstanding with a

capacity of not less than 110% of the largest tank or largest combined

volume of connected tanks;

c. All replenishment of tanks and containers and all refuelling of vehicles, plant and equipment shall take place within that bunded, impervious hardstanding;

d. Details of a protocol to deal with any pollution that may occur during the course of construction e.g. provision of spill kits close to storage areas/compounds. Train staff on how to use these correctly;

e. Plant and wheel washing is carried out in a designated area of hard standing at least 10 metres from any watercourse or surface water drain;

f. Run-off from plant, wheel and boot washing collected in a sump, with settled solids removed regularly and water recycled and reused where possible;

g. A Strategy for recycling/disposing of waste resulting from construction works;

h. Details of how the requirements of the approved CEMP will be

disseminated to all relevant staff/contractors throughout the construction period.

Development shall thereafter proceed only in strict accordance with the approved CEMP. REASON: To reduce the risk of pollution to ground and surface waters. CONDITION: Surface water draining from areas of hardstanding shall be passed through an oil interceptor or series of oil interceptors, prior to being discharged into any watercourse, pond or soakaway. The interceptor(s) shall be designed and constructed to have a capacity compatible with the area being drained, shall be installed prior to the occupation of the development and shall thereafter be retained and maintained throughout the lifetime of the development. Clean roof water shall not pass through the interceptor(s). Vehicle washdowns and detergents shall not be passed through the interceptor. REASON: To reduce the risk of pollution to the water environment CONDITION: All downpipes carrying rain water from areas of roof shall be sealed at ground-level prior to the occupation of the development. The sealed construction shall thereafter be retained throughout the lifetime of the development. REASON: To prevent the contamination of clean surface water run-off.

CONDITION: Inspection manholes shall be provided on all foul and surface water drainage runs such that discharges can be inspected/sampled if necessary. All manhole covers shall be marked to enable easy recognition. Foul will be marked in red. Surface water will be marked in blue. Direction of flow will also be denoted. Where more than one discharge point is proposed, manholes will also be numbered accordingly to correspond with their respective discharge point. REASON: To allow pollution incidents to be more readily traced. CONDITION: During the construction period all surface water run-off shall be passed though a settlement facility or settlement facilities prior to being discharged into any watercourse or soakaway. The facility/facilities shall be retained and maintained until such a time that construction works are complete. REASON: To prevent silty water from entering the water environment. To protect water quality and biodiversity. Mining Waste

The Mining Waste Directive (MWD) applies to the management of waste arising from prospecting, extraction, treatment and storage of mineral resources, and is therefore applicable to elements of the proposed mine. In England and Wales the permitting requirements as set out in article 7 of the MWD have been transposed through the Environmental Permitting (England and Wales) Regulations 2010 (EPR), for which the Environment Agency is the Competent Authority. The requirements in the MWD for approval and review of a Waste Management Plan (WMP) will also be delivered by an Environmental Permit. The WMP must describe techniques for the minimisation, treatment, recovery and disposal of extractive waste, taking account of the principle of sustainable development. Based on the information provided with the application it appears that a bespoke Environmental Permit for non hazardous, non inert mining waste will be needed. The information also provides us with sufficient confidence that the proposed development is likely to be capable of attaining such a permit in due course. It should be noted that other elements of the wider project including the proposed de-watering and drying plant and storage areas on Teesside may also fall under the Mining Waste Directive / Environmental Permitting Regulations. It may therefore be desirable for these constituent parts to controlled under a single permit for the whole operation, although it should be possible to issue a Permit for the initial mine operations then to subsequently add other relevant elements of the project to the same permit as and when necessary. Pyritic Mudstone – As part of the construction of the mine it is expected that pyritic mudstone will be extracted as part of the mine waste. When exposed to the atmosphere, pyritic mudstone has the potential to cause pollution to surface water run-off and groundwater unless carefully managed. As part of the proposed development it will be necessary to manage this waste such that there is no risk of pollution from run-off or leachate from this material. The Environmental Permit needed from the Environment Agency will secure any measures needed to control the management of this waste and any associated pollution risk. As such we feel there is no need to secure any further controls on any planning permission.

Subsidence

Information supporting the planning application indicates that no subsidence is predicted as a result of the mineral extraction proposed. We understand that the National Park‟s consultant, Amec, will be scrutinising this prediction and ensuring the evidence supporting this assertion is robust and fit-for-purpose. Should the National Park have any concerns about the suitability of subsidence evidence, we request to be informed at the earliest opportunity. In any case, the prediction of „no subsidence‟ relies upon mineral extraction being undertaken in the specific manner described in the documentation. We request that a condition be included on any permission granted, ensuring works proceed only in strict accordance with the methodology described. We support proposals to constrain mineral extraction operations in the coastal zone (1.5km from mean low water springs in-land) in the interests of protecting coastal processes including coastal erosion and tidal flooding. We would support a condition securing these safeguards. CONDITION: No mineral extraction shall commence until a Subsidence Monitoring Strategy has been submitted to and approved in writing by the Local Planning Authority. The Strategy shall include:-

Monitoring locations which shall include any affected watercourses,

floodplains, flood defences, gauging stations, source protection zones,

and the coastal zone;

A methodology for monitoring;

Details of any infrastructure needed to facilitate monitoring;

A timetable for implementing the monitoring strategy, including the

construction of any monitoring infrastructure.

The approved Subsidence Monitoring Strategy shall thereafter be implemented, with the results and an explanatory report submitted to the Local Planning Authority no less frequently than once every quarter. If the subsidence monitoring detects that subsidence has occurred, the Local Planning Authority shall be notified and mineral extraction shall cease within no more than one month of the monitoring taking place. No more than 8 weeks after subsidence is detected a Subsidence Remediation Strategy shall be submitted to and approved in writing by the Local Planning Authority. The Subsidence Remediation Strategy shall include:-

A comprehensive investigation into the extent of subsidence which has

occurred;

An assessment of the impacts the subsidence has caused;

Measures to mitigate the subsidence impacts identified;

Proposals to revise the mineral extraction methodology to ensure no

further subsidence occurs;

Proposals for more detailed subsidence monitoring in the area affected

by subsidence.

Mineral extraction shall only re-commence:-

Once the remedial measures set out in the approved Subsidence Remediation

Strategy have been implemented;

In accordance with the revised extraction methodology set out in the approved

Subsidence Remediation Strategy;

Subject to the detailed subsidence monitoring set out in the approved

Subsidence Remediation Strategy.

REASON: To ground-truth predictions that operations will result in no subsidence. To ensure that mineral extraction ceases quickly if subsidence is being caused. To ensure any resultant impacts are fully investigated and mitigated for. To ensure any subsequent mineral extraction is undertaken so as to avoid further subsidence. To ensure that subsequent mineral extraction is closely monitored. Ecology

CONDITION: Prior to the commencement of any development on site, a scheme for the ecological enhancement of the site shall be submitted to, and approved in writing by the LPA. The scheme shall include:

The provision of wetland habitat, as outlined in 4.3 of the Revised Non-Technical Summary and 9.119 of the Environmental Statement by Turley Associates.

Development shall thereafter proceed only in strict accordance with the approved scheme and the timing/phasing arrangements set out therein. REASON: In order to protect and enhance the biodiversity value of the development site. Informatives

Should planning permission be granted, we also request the inclusion of the following Informatives:- 1. INFORMATIVE: Consent under the Land Drainage Act 1991 will be required from

North Yorkshire County Council for any works, including the construction of the

foul and surface water system outfall, to Sneaton Thorpe Beck or any other

ordinary watercourse.

2. INFORMATIVE: The Environmental Protection (Duty of Care) Regulations 1991 for dealing with waste materials are applicable for any off-site movements of wastes. The developer as waste producer therefore has a duty of care to ensure all materials removed go to an appropriate permitted facility and all relevant documentation is completed and kept in line with regulations. The developer must apply the waste hierarchy in a priority order of prevention, re-use, recycling before considering other recovery or disposal options. Government Guidance on the waste hierarchy in England can be found here - http://www.defra.gov.uk/publications/files/pb13530-waste-hierarchy-guidance.pdf.

3. INFORMATIVE: An Environmental Permit from the Environment Agency will be

required under the Environmental Permitting Regulations for any foul drainage

discharge to ground or surface waters.

http://www.defra.gov.uk/publications/files/pb13530-waste-hierarchy-guidance.pdf

4. INFORMATIVE: If the applicant intends to abstract more than 20 cubic metres of

water per day from a surface water source (e.g. stream or drain) or from

underground strata (via borehole or well) for any particular purpose then an

abstraction licence will be needed from the Environment Agency. There is no

guarantee that a licence will be granted as this is dependent on available water

resources and existing protected rights.

5. INFORMATIVE: The Construction Environment Management Plan should include

measures consistent with the following guidance:-

a) Environment Agency Pollution Prevention Guideline 1: General Guide to the Prevention of Pollution;

b) Environment Agency Pollution Prevention Guideline 5: Works and Maintenance in or near water;

c) Environment Agency Pollution Prevention Guideline 6: Working at Construction and Demolition Sites;

d) Ciria C532 Control of Water Pollution from Construction Sites – A Guide to Good Practice (2001);

e) Ciria C692 Environmental Good Practice on Site (third edition).

6. INFORMATIVE: Any sub-surface grouting works must be undertaken in accordance with:-

a. Environment Agency Regulatory Position Statement MWRP-RPS-108 Civil engineering activities involving grouts or other media for the purpose of sealing or ground stabilisation;

b. Eurocode 7 BS EN 12715 (200) Execution of Special Geotechnical Work: Grouting, and 12716 Jet Grouting;

c. CIRIA C515 Groundwater control – design and practice ISBN 0 86017 515 4; and

d. Practical Handbook of Grouting, soil, rock and structures. James Warner, P.E. published by Wiley ISBN 978 0 471 46303 0.

The Pipeline

We consider that sufficient information has been submitted with the application regarding the potash pipeline to inform the assessment of the minehead‟s cumulative impacts under the EIA Regulations and Water Framework Directive. However, we reserve the right to request additional information regarding the pipeline design, construction, environmental impacts and mitigation measures, when any application for a Development Consent Order is submitted. We have concerns about the cumulative impacts of the pipeline‟s numerous watercourse crossings on Water Framework Directive objectives, but feel these are insufficiently related to the impacts of the minehead to warrant consideration at this stage. We are however likely to request additional information and robust mitigation/compensation measures at DCO stage.

Conclusion

We object to the application submitted due to the provision of inadequate information in relation to groundwater protection and foul drainage disposal. We would be pleased to meet with York Potash and their consultants at the earliest opportunity to offer guidance on the information which needs to be provided. If appropriate, we would also welcome an opportunity to discuss planning conditions in greater detail with yourselves and other key parties. Should you require any additional information or clarification, please don‟t hesitate to contact me on the details below. Yours sincerely Sam Kipling Sustainable Places - Planning Specialist Direct dial 0113 819 6386 Direct e-mail [email protected] Environment Agency Lateral, 8 City Walk, Leeds. LS11 9AT National Customer Contact Centre: Telephone: 03708 506 506 Email enquiries to: [email protected]

mailto:[email protected]

17th February 2014 PB1110/C/303688/Lond

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HASKONINGDHV UK LIMITED

INDUSTRY, ENERGY & MINING

A company of Royal HaskoningDHV

Minutes Present : Trevor Parkin (Amec)

Stephen Anderton (Amec) Dom Ainger (Arup) Nick Ferro (Arup) Darren Stewart (BWB) Claire Flanagan (EA) Jonny Kendall (EA) Sam Kipling (EA) Dave Piercy (EA) James Senior (EA) Richard Izatt-Lowry (FWS) Mark Hill (NYMNPA) Steve Graham (RHDHV) Phil Williamson (RHDHV)

Absent : James Barrie (YPL) Date : 17th February 2014 Copy : Aisling O’Dowd (NLP)

Sian John (RHDHV) Our reference : PB1110/C/303688/Lond Subject : York Potash Minehead Hydrology - Drainage

Strategy

ID Agenda item Actions 1 Introductions

Introductions were made by all attendees. Apologies were conveyed from James Barrie (York Potash Limited) who was unable to attend.

2 Update on project Phil Williamson (PW) introduced the purpose of the meeting – initially agreed to discuss runoff rates and the approach to the drainage strategy with the Environment Agency (EA), but evolved due to the National Park Authority (NPA) attendance to cover all ‘water’ issues at the minehead site. PW provided a historical introduction to the York Potash Project (YPP) for the benefit of EA attendees. Developments on the site design were discussed and timelines for submission of the Environmental Statement (end of June) were confirmed.

17th February 2014 PB1110/C/303688/Lond 2/5

ID Agenda item Actions

3 Surface water hydrology baseline as presented in BWB Baseline

Surface Water Hydrology Report Darren Stewart (DS) provided an overview of the BWB Baseline Surface Water Hydrology Report, confirming that the one presented to the EA is due for update following the various work streams that are currently underway, however, the principles of the approach are still relevant to the discussion required with the EA. DS confirmed that the approach for the technical report that permeable areas would be assumed to have a minimum flood protection for a 1 in 20 year event. DS requested that the EA are satisfied with this approach. Stephen Anderton (SA) verbally stated that they agree with this approach. Jonny Kendall (JK) to co-ordinate a formal response (deadline as 21 days from receipt of the documentation – 3rd March 2014). Trevor Parkin (TP) stated that DS should anticipate the worst case scenario for the drainage based on the phasing plans. Dave Peircy (DP) suggested that phasing plan designs look to minimise the phase duration that the 1 in 20 condition at the minehead site is operational. SA agreed that Amec would use a similar modelling approach (IH124) for calculation of the runoff rates. The EA stated that they would expect a precautionary approach, and therefore the most conservative model (FEH24). Current thinking in the EA (to be followed by guidance to be published) recommends this. DS confirmed that he considered this approach but the minehead catchment is too small and therefore the resolution of the model would be lost. The EA confirmed they would expect to see a robust comparison of the models and justification for selection of the model that DS progressed. The EA will comment formally on the runoff rates in the baseline report following the meeting. JK to co-ordinate a formal response to the presented runoff rates.

JK JK

4 Groundwater / surface water interface Discussions regarding the groundwater and surface water interface were not covered specifically, but were discussed repeatedly throughout the meeting when relevant.

5 De-watering activities



Richard Izatt-Lowry (RIZ) discussed the proposed de-watering activities at the minehead site, and provided an update on what work streams are underway to provide accurate data on the quantities of water likely to be discharged during construction and operation. James Senior (JS) and Claire Flanagan (CF) stated that any license for abstraction / discharge will require a maximum figure for de-watering, within a realistic worst case. RIZ agreed. RIZ raised the question regarding re-infiltration of groundwater. JS confirmed the principal was ok provided de-minimus constraints regarding water quality was met i.e. that re-infiltrated groundwater matches the quality of groundwater that it is pumped into. JS confirmed that the residual risk is potential deterioration in status of the water body.

6 Water supply Dom Ainger (DA) confirmed that Arup are currently undertaking a body of work to ascertain the requirements for water supply; and are liaising with Yorkshire Water to ascertain if this can be supplied through the existing mains network or if works are required to upgrade the supply. PW confirmed that any services works would be included within the ES.

7 Doves Nest Spring RIZ and DS discussed the potential impact of the landscape earthworks on the Doves Nest Spring, in that the spring will be buried by the works. This is likely to result in a removal of that supply of water discharged into the Sneaton Thorpe Beck. TP and JS stated that the overall change to discharges into the river is not the issue, but the assessment of the change to the receptor as well. DS stated that baseline monitoring of the Doves Nest Spring is underway, however there is no baseline monitoring of the Sneaton Thorpe Beck, and therefore it is difficult to gauge the potential impact of removal of that source. Low-flow modelling has been undertaken to establish what proportion of the Doves Nest Spring flow contributes to the Beck. DS questioned TP regarding one of the comments in Amec’s critique of the ES that Amec did not agree with the statistical approach to low-flow modelling. DS would like clarification as to the appropriate approach – if baseline monitoring of Sneaton Thorpe Beck is required. DS to liaise with PW to submit a technical query.

DS / PW



8 Proposed surface water drainage design

Nick Ferro (NF) presented the Arup concept designs for the surface water drainage system at the minehead site, and discussed the parameters as presented in the BWB report. No immediate queries were raised. EA to submit a formal comment following the meeting. JK to co-ordinate formal response to surface water drainage concept design. SA stated that all landscaped soil excavations should be treated as non-permeable areas, in particular to relation to any capped material that will be stored in those areas. DA and NF stated that Arup’s phasing plans and the drainage strategy will treat these areas as permeable due to the design – a depth of permeable soil will be placed on the capped material to enable permeability. SA raised concerns regarding the design of the surface water swales and their potential to convey predicted flows. SA stated that he would expect to see detailed designs to accompany the ES. PW to discuss production of designs with YPL and Amec following meeting. Mark Hill (MH) requested consideration of SuDs and in particular the SuDS Approval Body at North Yorkshire County Council, which has been operational for 15 months. DS / SG to investigate consultation.

JK PW DS / SG

9 Foul drainage DA provided a summary of the work done to date regarding foul water drainage design and the ongoing packages of work.

10 Overall water balance Discussions of the overall water balance had been covered over the course of the meeting. DA confirmed that Arup are tasked with pulling together this body of work to feed into the ES chapter.

11 Water Framework Directive (WFD) PW provided an overall statement that the WFD be considered within the ES. A stand-alone technical report would be produced, and would be covered in a separate chapter in the ES. PW covered the scope of the technical study. PW to liaise with JK regarding obtaining an EA contact to consult on WFD.

PW



TP asked whether any potential impacts on the geomorphological condition of the Sneaton Thorpe Beck would be covered under the WFD assessment. PW confirmed it would not, as it is not classed as an EA Main River. PW to progress baseline geomorphological study of the Sneaton Thorpe Beck.

PW

12 Any other business Sam Kipling (SK) requested details of who to contact with respect to organising a payments for pre-planning advice arrangement. PW to forward contact details of NLP. No other business was raised by any other attendees.

PW

Environment Agency

Coverdale House Aviator Court, York, North Yorkshire, YO30 4GZ. Customer services line: 03708 506 506 www.gov.uk/environment-agency

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Ms Sian John Royal Haskoning Bretton Centre (Rightwell House) Rightwell Bretton Peterborough PE3 8DW

Our ref: RA/2014/129240/01-L01 Your ref: PB1110/R/303521/Hayw Date: 15 August 2014

Dear Ms John, YORK POTASH PROJECT - MINEHEAD FOUL DRAINAGE PROPOSALS. LAND AT AND AROUND DOVES NEST FARM, SNEATON. I refer to the receipt of the following two documents in relation to the foul drainage proposals from the York Potash minehead site:- Foul Drainage Whole Life Assessment On-site Treatment of Domestic Foul Sewage We would like to provide the following comments. Foul Drainage Whole Life Assessment As part of any subsequent application for an Environmental Permit for the discharge of treated foul effluent into Sneatonthorpe Beck, detailed information would need to be provided to demonstrate that it would be unreasonable to connect to the public sewer. The information currently provided in the Foul Drainage Whole Life Assessment would be insufficient for the public sewer option to be ruled out. The letter from Yorkshire Water dated 19 July 2013, stating that there is a lack of capacity in the treatment works and confirming that York Potash would be required to pay for an upgrade of the works, is not sufficient evidence to rule out the public sewer option. You will need to undertake the following steps in order to rule out the public sewer option as part of any Environmental Permit application:-

1 Formally approach the sewerage undertaker regarding a connection under section 98 or section 106 of the Water Industry Act 1991, as appropriate.

2 Serve notice for connection under section 98 or section 106 of the Water Industry Act 1991 if the sewerage undertaker has refused connection.

3 Provide details of the reasons given by the sewerage undertaker if it has refused connection under section 106 of the Water Industry Act 1991 and confirmation that they have appealed against this decision. OR: Provide details of the undertakings, security and payment required by the sewerage undertaker under section 98 of the Water Industry Act 1991. They must provide these together with confirmation that the applicant considers these to be reasonable and does not intend to appeal against them.

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2

4 Demonstrate that it is not reasonable to connect to the public foul sewer.

5 Where it is not reasonable to connect to the public foul sewer, demonstrate that they have considered requesting that the sewerage undertaker adopt their proposed system.

A lack of capacity, or a lack of plans to improve capacity in the sewer is not a valid reason for a sewerage undertaker to refuse connection under Section 106 of the Water Industry Act 1991. Where a sewerage undertaker refuses to allow connection under s106 on the grounds of lack of capacity, the discharger may appeal to Ofwat. We may refuse to issue an Environmental Permit in such circumstances. It has been established that the general presumption against consenting discharges from private sewage treatment works in areas served by a public sewer should apply and is justified, even in areas where the public sewer is overloaded. Our emerging guidance indicates that the proposed 68 cubic metres per day discharge is equivalent to around 90.6 residential properties. The larger the development, the greater the maximum distance to the sewer would be. For a single property, the indicative maximum distance deemed acceptable is 30m. This distance is multiplied by the number of properties the proposed development is equivalent to. In this case this results in an indicative maximum distance of 2.71km. Option 1 (gravity connection to Whitby sewage treatment works) is around 2.9km away and is therefore just outside what we would normally consider to be a sewered area. However, because the difference is so small (190m) and because the figures used are indicative, we would still expect full justification that the steps of the Water Industry Act (1991) outlined above have been undertaken. Our guidance provides indicative values for the maximum amount deemed to be acceptable for connection to sewer, based on the scale of the development. In this case, our guidance suggests the maximum cost we would expect the applicant to pay in order to connect to the foul sewer is approximately £980,400. Indicative values are also provided for the laying of new drains/sewers which have a typical cost of approximately £135 per metre. In this case, the indicative cost of laying a new sewer over the 2.9km to Whitby would be £391,500. Assuming the foul flows to be conveyed to sewer will not constitute trade effluent, it is our understanding that it would be for Yorkshire Water to provide any necessary additional capacity at their own cost. Whilst the estimated capital cost of the proposed package treatment system is shown as £165,000 and that this is clearly less than the ~£391,500 it would cost to connect to mains sewer, the cost to connect to sewer falls well short of the maximum cost we would deem reasonable for this development. In our view, there is currently insufficient information to discount Option 1 on the basis of either distance or cost. We would certainly require York Potash to formally approach Yorkshire Water under the relevant sections of the Water Industry Act above, as part of the permitting process. In contrast, we are content that sufficient information has been provided to discount Option 2 on the basis of distance. We have previously taken the approach that this more detailed consideration of the public sewer option may be deferred to the permitting stage and/or covered by a planning condition, provided the non-mains alternative has been demonstrated to be a feasible option. However, we understand that the National Park Authority consider that while the public sewer option remains a potential option, any environmental impacts

Cont/d..

3

associated with it must be addressed in the Environmental Statement. It will be for the National Park Authority to decide whether they feel sufficient information has been provided to rule out the public sewer option in the context of the planning application. However, we will continue to provide our advice to them regarding the implications of this supporting information for the permitting process. On-site Treatment of Domestic Foul Sewage We would like to provide the following comments:- Discharge Volume We are concerned that the report is overly focused on water quality and that it seems to imply that water quantity and water quality are unconnected. Statements are made in the report that suggest the treated foul drainage could deliver “an improvement to the watercourse, helping further support aquatic life during dry periods”. This appears to be unsubstantiated and we are sceptical about the likely validity of such a claim. The report should also acknowledge the potential disbenefits of increased volume in relation to factors such as hydro-morphology and increased scour. WFD / Water Quality The report appears to take the approach that WFD ‘deterioration’ has only occurred if the classification of a water body decreases. Whilst the report seems to acknowledge that the development will worsen the existing water quality, it argues that it is acceptable based on the fact that it is only minor deterioration and not significant. Calculations throughout the report assume a treatment level of 2mg/l ammonia. This is a very high level of treatment to provide from a package treatment works and we consider that it will be very challenging to consistently maintain this standard. The case studies referred to in the report should be appended to it. The assumption of a 2mg/l limit for ammonia is, in itself, a concern as the statement is made that a more stringent limit could be complied with if the EA deemed it necessary for the receiving watercourse. The more stringent the limit required for a watercourse, the more serious the impact in the case of a plant failure. On this basis, we are unlikely to be comfortable with a 68mᶟ/day discharge where an ammonia limit of <2mg/l was deemed necessary to protect the watercourse. The report states that Sneatonthorpe Beck does not meet the WFD status of 0.6mg/l (Good) and therefore focuses on the Imperative limit of 1mg/l. It is of concern that the report introduces water quality data that demonstrates an average of 0.83mg/l which is derived from a data set containing an outlier result of 15mg/l. The report goes on to state that removal of this outlier from the data set produces an average of 0.15mg/l with a total of twelve individual readings being below 0.015mg/l. The report has therefore demonstrated that good ecological status (ammonia) is perfectly viable for this water body. The focus in the report should therefore be on achieving this (0.6mg/l), not simply maintaining the 1mg/l limit keeping the watercourse at poor status. The report does refer to water quality improvements but states that they would only be achievable if “works are taken to remediate pre-existing water quality issues downstream of the development”. No mechanism for addressing these issues as part of the development appears to be proposed. If such improvements are deemed necessary to allow the treated foul discharge to go ahead, the report will need to provide greater detail and propose mechanisms for securing these improvements through planning.

End

4

In relation to the previous York Potash application we previously undertook preliminary modelling that suggested that the limits put forward in the supporting documentation were likely to be acceptable. These limits were:- 10mg/l BOD 2mg/l Ammonia This modelling will need to be re-visited in light of the latest water quality and WFD data. We may be willing to do this as part of pre-permit discussions. We would also like to highlight that the document refers to the requirement for a reed bed to be added on to the treatment plant to achieve these limits. In the information provided, the treatment techniques are listed as:- Balancing tank Primary Tank Biozone Humas Sand filter There is no reed bed listed in the proposed treatment system. Details of this should be included, or further information to explain if the reed bed is no longer deemed necessary. Conclusions There is currently insufficient information to rule out a public sewer connection for an Environmental Permit application. It will be for the National Park Authority to determine whether sufficient information has been provided to rule this option out, for the purposes of the planning application. If this work is to be progressed, the steps of the Water Industry Act, outlined in this letter, will need to be commenced. The report has focused on the deterioration clause of WFD in the wrong manner and suggests that by not causing Sneatonthorpe Beck to fall from ‘poor’ to ‘bad’, that this is in itself a demonstration of ‘no deterioration’. ‘Good’ is the minimum target for all watercourses and the Esk Catchment has a target agreed with the catchment hosts of ‘High’. Data provided in the report demonstrates that ‘Good’ status can be achieved. We would need to see evidence from the developer that the treatment plant would not impact Sneatonthorpe Beck at a 0.6mg/l limit not at the 1mg/l limit used and, where necessary, demonstration of the mechanisms to be used to make long-term improvement of water quality in this catchment. Should you require any additional information or clarification, please don’t hesitate to contact me on the details below. Yours sincerely Mr Sam Kipling Sustainable Places Planning Specialist Direct dial 0113 819 6386 Direct fax 0113 819 6299 Direct e-mail [email protected]

01 September 2014 PB1110/C/303405/Leeds

1/1

HASKONINGDHV UK LIMITED

INDUSTRY, ENERGY & MINING

A company of Royal HaskoningDHV

Minutes

Present : Sam Kipling – EA (SK)

Justin Jones – EA (JJ)

Michelle Furmston – EA (MF)

Matthew Hunt – RHDHV (MHunt)

Steve Graham – RHDHV (SG)

Ian Dennis – RHDHV (ID)

Dom Ainger – Arup (DA)

Steve Anderton – AMEC (SA)

Mark Hill – NYMNPA (MHill)

Apologies : James Barrie – YPL

Trevor Parkin – AMEC

Duncan Fyfe – EA

Copy : Aisling O’Dowd - NLP

Sian John - RHDHV

Phil Williamson – RHDHV

Date : 01 September 2014

Our reference : PB1110/C/303405/Leeds

Subject : York Potash Minehead –Foul Drainage Proposals

- Review Meeting


1 Introductions

Introductions were made by all attendees.

SK & MHunt introduced the purpose of the meeting; to address

comments received from the EA and NYMNPA (via AMEC) on the

Arup reporting for foul disposal water options, namely;

Whole Life Assessment of Disposal Options for Domestic Foul

Sewage from the Dove’s Nest Site (Rev00 - 6 June 2014)

and;

On-site treatment of Domestic Foul Sewage at Dove’s Nest Farm

(Rev00 - 6 June 14)

2 Whole life assessment of options

DA reviewed the background, content and conclusions from report in

question.

Discussion of EA comments received:

SK queried level of Yorkshire Water (YW) consultation carried out; DA

confirmed that YW had been contacted via their formal pre-application

enquiry system. Their preliminary response was brief, and further

01 September 2014 PB1110/C/303405/Leeds 2/1


enquiries were made to obtain the current information appended to the

report, confirming high level breakdown of upgrades required and

indicative £6mil cost estimate. DA confirmed that this does not include

any upgrade costs for Whitby WWTW.

JJ questioned the route and infrastructure upgrade detailed in the YW

response, in particular the number of pumping stations requiring

upgrade and whether foul water from Dove’s Nest Farm would need to

be pumped into Whitby Town Centre and back out again. JJ also

questioned whether Whitby STW is actually at full capacity, based on

the returns provided by YW for compliance purposes. DA will follow

up current lines of communication with YW to get further clarification

and breakdown of costs. SK offered to assist with consultation if EA

influence is required and should be cc’d into future correspondence

with YW

SK discussed the guidance referred to in the EA response. It is due to

be released w/c 8 September 2014. This is for internal (EA) use but

will be issued on request. SK will issue to the YPL team when

available; SG/ID to send a reminder request on 8th

SG queried the wording in the response regarding the discounting of

any YW upgrade costs from the YPP option 1 capital cost. MF will

revisit the wording of response in light of discussions.

SK / SA discussed concerns with the evaluation criteria included in the

MCA (section 4 & section 7) and also the weighting and scoring matrix

used in the report. SK to revise response to clarify queries with Matrix.

DA agreed to address comments and revisit scoring in the options

evaluation.

SK noted that the response letter will be revised to include further

detail and clarification of responses. (this was offered as uncharged

advise and will be provided by CoP Fri 5 Sept).

MHill noted that sewer upgrades along roads are generally not

considered to be sensitive. Transport receptors are likely to be at the

greatest risk of impact, but in the event that the proposed scheme

requires amendment to incorporate mains connection, discussion

would be required as to the necessary scope of environmental

assessments. MH confirmed the project team belief that the additional

information from YW discussed above – whether received before the

project is submitted for planning approval or not - is not likely to alter

the proposed scheme.

DA

SK/SG/ID

SK/MF

SK

DA

SK



3 On-site treatment assessment

JJ provided EA input on behalf of Duncan Fyfe (EA WFD lead).

JJ and MF noted that although the overall quality of the Rigg Mill Beck

water body is poor, the general aim of achieving High Ecological

Status has been agreed with the Catchment Hosts (Yorkshire Esk

Rivers Trust and NYMNPA). The catchment is currently at poor status

as a result of barriers to fish passage and sediment-associated

phosphate concentrations, but ammonia is not poor. The standard for

high status should therefore apply.

JJ and MF stated that their main concern is whether the proposed

package treatment plant will be able to deliver the required ammonia

concentrations. MF will update the WIMS modelling (by CoP Fri 5

Sept) that was used to derive the 2 mgl-1 ammonia to reflect the latest

water quality monitoring information that has been collected by YPL.

SG / ID will provide these data to MF via SK if they are not already

held by the EA.

JJ explained that the physico-chemical status of the water body is

assessed against a single monitoring point at the downstream end of

Cock Mill Beck near Ruswarp. A 10% deterioration in ammonia

concentrations at this sampling point is deemed to be acceptable.

JJ confirmed that compliance should focus on ammonia rather than

suspended solids and BOD. In this context, it is considered

acceptable to assume that BOD is closely related to ammonia.

SK, JJ and MF discussed potential alternative options, including

moving the discharge point further downstream into a reach where it is

likely to have less impact, and injecting waste water into the poor

quality groundwater aquifer. MHunt confirmed that these additional

approaches are not being proposed as part of the scheme, and

consequently impact assessments associated with them will not be

contained within the ES. The possibility of adding a reed bed as a final

treatment stage was also discussed.

SK and SA expressed concern that the potential hydromorphological

impacts of any discharges into Sneaton Thorpe Beck had not been

considered. ID confirmed that these impacts had been considered in

the EIA and WFD compliance assessment. Although some minor

impacts may be possible in the small headwater streams that receive

the discharge, the geomorphological characteristics of the watercourse

mean that they would be confined to these short reaches (a very steep

bedrock-controlled reach will prevent morphological adjustment

propagating downstream).

MF

SG / ID



4 Any other business

SK and MHunt closed and thanked all for attendance and comments.

Environment Agency

Coverdale House Aviator Court, York, North Yorkshire, YO30 4GZ. Customer services line: 03708 506 506 www.gov.uk/environment-agency

Cont/d..

Ms Sian John Royal Haskoning Bretton Centre (Rightwell House) Rightwell Bretton Peterborough PE3 8DW

Our ref: RA/2014/129240/02-L01 Your ref: PB1110/R/303521/Hayw Date: 5 September 2014

Dear Ms John, YORK POTASH PROJECT - MINEHEAD FOUL DRAINAGE PROPOSALS LAND AT AND AROUND DOVES NEST FARM, SNEATON. Following our recent meeting on Monday 1 September 2014, we took an action to provide clarification on a number of points discussed at the meeting. We would therefore like to provide the following comments:- Mains Connection We would like to be provided with a more detailed description of the route foul effluent would be expected to take from connection in Sneaton to the waste water treatment works at Whitby. The email from Robert Illingworth of Yorkshire Water dater 9 April 2014 (Appended to the Whole Life Assessment document) cites various pumping stations which he suggests would need upgrading to accommodate the increased flows. We would like to better understand why each pumping station needs upgrading. Based on our understanding of how the network operates in this area, it appears to be unlikely that all the infrastructure cited would need to be upgraded. If Yorkshire Water have any information about existing flows at the pumping stations and why it is thought to be necessary to upgrade them, that would be useful. Yorkshire Water should be asked if they are able to provide a broad indication of how the £6m costs would be split across the various items cited. This itemization would allow you to undertake a degree of sensitivity testing of the results. Furthermore, as we regulate the waste water treatment works at Whitby under an Environmental Permit, our records indicate that there is sufficient head-room in the existing Environmental Permit for the treatment works to accommodate the additional flows. Yorkshire Water should therefore be asked why they consider it necessary to upgrade the works. Water Framework Directive Status The target of ‘High’ Ecological Status was set by the Catchment Host with support from the Environment Agency for the Esk Operational Catchment (i.e. not necessarily

Cont/d..

2

including the coastal streams operational catchment part of the Esk management catchment). As yet the Host and partners have not agreed upon whether this target applies to all the water bodies within the operational catchment or just some of them. At the very least it will apply to those water bodies where pearl mussels are present – these notably include the main channel of the Esk and Glaisdale Beck. We may wish to include all Esk Operational Catchment water bodies to allow for future and further planned reintroductions. If at some stage the Catchment Host, working with the Salmon and Freshwater Pearl Mussel Recovery project group, decide which water bodies are to be at ‘Good’ and which at ‘High’, it is more than likely that we will still be looking to achieve ‘High’ Status for the key elements of Fish and Ammonia and to reduce or eliminate all sources of sediment – all of which are vital elements or key pressures upon the mussels. Until the Catchment Host assigns specific WFD targets to specific water bodies within this wider catchment, a precautionary approach should be taken with the target of ‘High’ set. Water Quality Modelling It has not been possible for us to undertake further water quality monitoring in time for it to be included with this letter, due to an issue with the data needed to inform this work. We will endeavour to do this as soon as possible, and will follow-up as soon as this is available. Foul Drainage Treatment Capacity A query was raised at the meeting regarding who would be expected to meet the costs associated with upgrades to the sewerage network that are needed as a result of the development. Our view is that if the upgrades are needed at the treatment works, then the water company would be expected to cover these costs. If the necessary upgrades are to the network such as pipes or pumping stations, then it would be for the developers to meet the cost. A full breakdown of each sewer pipe and pumping station that requires an upgrade is needed, along with the flow that will pass through, to determine if the upgrade is necessary. The developer can only be expected to pay to upgrade the network to allow their discharge to be passed through for treatment, not to allow any other extra volumes predicted to be needed by the water company in future. If the water company want to undertake a more extensive upgrade to allow other planned developments to be accommodated in the network, the developers would need to enter into negotiations with the water company over what a proportionate contribution to the cost would be. Capacity Solutions In your discussions with Yorkshire Water it may be worth exploring whether the need for additional capacity could be avoided by balancing the foul discharges from your site to match with periods of low demand in the existing network. For example, foul flows during the day could be held back in balancing tanks, with discharges during the day restricted to a very low level, then at night time when other demands on the network are low, discharging at an increased rate. We also request the Yorkshire Water are asked to provide further information regarding their upcoming Asset Management Plans. These may include proposals to remove surface water inputs into the existing sewer network which would have the effect of

Cont/d..

3

creating additional capacity in the system. Given that it will be a number of years before foul discharges from the welfare facilities commence, and a further period after that before they are at their greatest, it might be that this gradual increase of foul flows matches well with Yorkshire Water’s plans for creating additional capacity through the removal of surface water from the system. Options Appraisal Following the recent meeting, we would like to provide the following comments regarding the criteria chosen to appraise the three identified options, and the weighting afforded to them. It should be noted that this methodology would not necessarily be appropriate for an Environmental Permit application and is being considered in the context of the subsequent planning application. Water Quality: We agree that this is an important factor which should be afforded significant weight, but disagree that each of the three options should be given equal scores. We do not think it is reasonable to score a non-mains discharge in the upper reaches of a sensitive catchment in which there are isolated populations of fish and where there is little dilution, on a par with a Yorkshire Water discharge in the lower reaches of a larger, more robust catchment, with high levels of dilution. Furthermore, a mains connection may also facilitate allowing other properties on non-mains drainage in the catchment to connect to the sewer. This would not only remove the environmental risks posed by a discharge to Sneatonthorpe Beck, but would also serve to help improvements to the existing water quality. Impact on Sewer Systems: We do not consider that this is a relevant factor which should be considered here. There is no suggestion that a discharge will be made to the sewerage network without the necessary improvements being made. As such it is reasonable to assume that the improved sewer system will not be detrimentally affected. Environmental Risk: We agree that this is an important factor which should be afforded significant weight, but disagree that each of the three options should be given equal scores. Our records strongly suggest that private sewage treatment works do not perform as well as public ones and are less likely to comply with their Environmental Permits. Our compliance figures for England and Wales, for the five-year period of 2000-2004, show that in each of those years between 94% and 96% of sewage treatment works operated by sewerage undertakers and regulated by a numeric discharge consent complied with the conditions of that discharge consent. By comparison, the compliance rate for privately operated sewage treatment works regulated by a numeric discharge consent ranged from 59% to 62%. Furthermore, if you add in the sensitivity of Sneatonthorpe Beck because of its lack of dilution and the presence of isolated populations of fish above natural barriers downstream, not only is it reasonable to assume that the non-mains option is less likely to comply with the conditions of its Environmental Permit (particularly a very tightly constrained one), but the receiving environment is less likely to cope with a non-compliance event. If isolated fish populations are destroyed in a non-compliance event, it will be impossible for them to rejuvenate naturally. Buildability: Whilst we consider it reasonable to assign a low score to option 2 in relation to this factor, we see little reason why option 1 should score as badly. The information suggests that the 2.9km connection can be readily achieved along existing

End

4

highways. Because other network improvements would be undertaken by Yorkshire Water, it does not seem appropriate to account for these aspects in this appraisal. Land ownership: As option 1 would be constructed along the public highway, it is unclear why this would encounter any land ownership constraints. Capital Cost / Whole Life Cost: Given the uncertainties we have raised about the figures currently informing this criterion, it is difficult to comment further. Before it is finalised, further clarity is needed on the nature and extent of the necessary upgrades. Non-Mains Options At the meeting we suggested that further consideration could be given to an additional foul drainage disposal option. This would involve the on-site treatment of foul effluent but the discharge of treated effluent further downstream of the mine site, at a point where there is greater dilution and below any particularly sensitive ecology such as isolated populations of fish. We also advised that it would be of benefit to incorporate a reed-bed in the design as an additional treatment stage, to provide additional polishing to the effluent. Planned Maintenance As discussed at the meeting, it would be useful for the documents to include an explanation of how you will deal operationally with planned maintenance to replace essential components to the private treatment works, in order to avoid pollution to the watercourse. Should you require any additional information, please don’t hesitate to contact me on the details below. Yours sincerely Mr Sam Kipling Sustainable Places Planning Specialist Direct dial 0113 819 6386 Direct fax 0113 819 6299 Direct e-mail [email protected]

Appendix B

Water Quality Data

DOVES NEST SURFACE WATER DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW 1DETS Lab No. 475298 476516 481524 481152 482619 485238 488034 490415 493479 494620 497658 498734 500995Date 09/01/2013 15/01/2013 24/01/2013 31/01/2013 06/02/2013 13/02/2013 20/02/2013 27/02/2013 06/03/2013 13/03/2013 20/03/2013 26/03/2013 04/04/2013

Determinand Units

Field MeasurementspH 7.70 6.97 7.75 7.21 7.72 8.76 7.45 6.75 7.76 7.86 7.5 7.72 7.01

T oC 5.3 3.8 1.5 4.7 2.5 1.9 3.6 4.4 3.7 0.0 2.7 0.9 2.6EC mS 0.56 1.60 0.50 0.43 0.68 0.45 0.43 0.40 0.46 0.44 0.54 0.44 0.35

Laboratory ResultsArsenic, Dissolved ug/l 0.47 0.33 0.38 0.42 0.32 0.27 0.29 0.18 0.25 0.17 0.99 0.2 0.47Calcium, Dissolved mg/l 47 59 28 29 31 32 32 34 33 40 38 34 37Cadmium, Dissolved ug/l 0.032 0.034 0.15 0.14 0.089 0.032 0.047 < 0.030 < 0.030 < 0.030 0.75 < 0.030 < 0.030Chromium, Dissolved ug/l 1.6 < 0.25 0.29 0.34 0.53 0.29 < 0.25 < 0.25 < 0.25 < 0.25 < 0.25 < 0.25 0.26Hexavalent Chromium ug/l < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10Copper, Dissolved ug/l 0.85 0.93 3 0.98 1.3 1.4 1.3 0.4 < 0.40 0.62 9.2 0.72 1.3Lead, Dissolved ug/l 0.22 < 0.090 0.11 < 0.090 0.15 0.11 < 0.090 < 0.090 0.18 < 0.090 1 < 0.090 0.17Magnesium, Dissolved mg/l 7.8 9.1 6 5.7 5.9 6.5 7.1 7.9 7.8 8.8 4.8 7.8 8.5Mercury, Dissolved ug/l < 0.010 < 0.010 0.013 < 0.010 < 0.010 < 0.010 < 0.010 < 0.010 < 0.010 < 0.010 0.045 < 0.010 < 0.010Nickel, Dissolved ug/l 3.3 3.3 53 2.5 2.4 6.9 6.1 1.4 1.3 1.8 5.9 1.7 1.7Potassium, Dissolved mg/l 7 44 5 4.9 23 3.3 4.3 2.1 1.9 6.5 39 3.7 2.2Sodium, Dissolved mg/l 43 140 40 46 59 34 31 26 34 47 59 32 28Zinc, Dissolved ug/l 2.8 3.2 10 4 4.6 22 5.5 2.2 < 1.3 7.1 37 4.1 7.2Chloride mg/l 98 460 100 110 150 90 79 77 74 100 150 82 90Nitrite as NO2 mg/l < 0.035 < 0.035 < 0.035 < 0.035 < 0.035 < 0.035 < 0.035 < 0.035 < 0.035 < 0.035 < 0.035 < 0.035 < 0.035Nitrate as NO3 mg/l < 0.94 < 1.24 < 0.81 < 0.81 < 1.29 < 0.89 < 0.10 < 0.10 < 0.10 < 0.10 < 1.60 < 0.10 0.9Conductivity uS/cm 530 1550 466 405 657 468 440 401 447 480 654 428 424Ammoniacal Nitrogen as N mg/l 0.034 0.034 0.066 0.25 0.12 0.26 < 0.015 0.061 0.017 0.028 0.21 0.22 0.06Suspended Solids mg/l 24 16 < 5.0 38 44 < 5.0 19 29 56 10 52 33 < 5.0pH 7.6 7.5 7.2 7.4 7.4 7.6 7.9 7.4 7.6 7 7 6.3 7.4Aliphatic C5-C6 ug/l < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1Aliphatic C6-C8 ug/l < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1Aliphatic C8-C10 ug/l < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1Aliphatic C10-C12 ug/l < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic C12-C16 ug/l 8.2 3.8 < 1.0 7.2 < 1.0 4.4 3.8 < 1.0 1 < 1.0 < 1.0 < 1.0 2Aliphatic C16-C21 ug/l 7.3 3 < 1.0 4.9 < 1.0 12 3 < 1.0 6.2 < 1.0 < 1.0 < 1.0 19Aliphatic C21-C35 ug/l < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic C5-C7 ug/l < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 6.2 < 0.1 < 0.1 < 0.1Aromatic C7-C8 ug/l < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1Aromatic C8-C10 ug/l < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1Aromatic C10-C12 ug/l < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 2.9 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic C12-C16 ug/l < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 1.2 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic C16-C21 ug/l < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 4.6 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aromatic C21-C35 ug/l < 1.0 1.8 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Aliphatic C5-C35 ug/l 16 < 10 < 10 12 < 10 17 < 10 < 10 < 10 < 10 < 10 < 10 21Aromatic C5-C35 ug/l < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10TPH Ali/Aro ug/l 16 10 < 10 12 < 10 26 < 10 < 10 < 10 < 10 < 10 < 10 21Acenaphthene ug/l 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01Acenaphthylene ug/l < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01Anthracene ug/l 0.14 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01Benzo(a)anthracene ug/l 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 0.01Benzo(a)pyrene ug/l < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 0.01 < 0.01 < 0.01 < 0.01 < 0.01Benzo(b)fluoranthene ug/l < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01Benzo(k)fluoranthene ug/l < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 0.01 < 0.01 < 0.01 < 0.01 < 0.01Benzo(g,h,i)perylene ug/l < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 0.03 < 0.01 < 0.01 < 0.01 < 0.01Chrysene ug/l < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 0.02Dibenzo(a,h)anthracene ug/l < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 0.08 < 0.01 < 0.01 < 0.01 < 0.01Fluoranthene ug/l 0.19 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 0.02 < 0.01 < 0.01 < 0.01 0.01Fluorene ug/l 0.05 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01Indeno(1,2,3-c,d)pyrene ug/l < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01Naphthalene ug/l 0.03 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 0.04 < 0.01 < 0.01 < 0.01 0.02Phenanthrene ug/l 0.68 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01Pyrene ug/l 0.13 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 0.02 < 0.01 < 0.01 < 0.01 0.01PAH ug/l 1.3 < 0.20 < 0.20 < 0.20 < 0.20 < 0.20 < 0.20 < 0.20 0.22 < 0.20 < 0.20 < 0.20 < 0.20Benzene ug/l < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 6.2 < 1.0 < 1.0 < 1.0Ethylbenzene ug/l < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Toluene ug/l < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0Xylene ug/l < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0

\\Global\europe\Leeds\Jobs\230000\234376-00\0 Arup\0-12 Water\0-12-08 Reports\01 Domestic Foul Sewer\Appendices\Appx B - Water Quality Data\B1_Doves Nest Surface Water Monitoring.xls 1 of 3

DOVES NEST SURFACE WATERDETS Lab No.Date

Determinand Units

Field MeasurementspH

T oCEC mS

Laboratory ResultsArsenic, Dissolved ug/lCalcium, Dissolved mg/lCadmium, Dissolved ug/lChromium, Dissolved ug/lHexavalent Chromium ug/lCopper, Dissolved ug/lLead, Dissolved ug/lMagnesium, Dissolved mg/lMercury, Dissolved ug/lNickel, Dissolved ug/lPotassium, Dissolved mg/lSodium, Dissolved mg/lZinc, Dissolved ug/lChloride mg/lNitrite as NO2 mg/lNitrate as NO3 mg/lConductivity uS/cmAmmoniacal Nitrogen as N mg/lSuspended Solids mg/lpHAliphatic C5-C6 ug/lAliphatic C6-C8 ug/lAliphatic C8-C10 ug/lAliphatic C10-C12 ug/lAliphatic C12-C16 ug/lAliphatic C16-C21 ug/lAliphatic C21-C35 ug/lAromatic C5-C7 ug/lAromatic C7-C8 ug/lAromatic C8-C10 ug/lAromatic C10-C12 ug/lAromatic C12-C16 ug/lAromatic C16-C21 ug/lAromatic C21-C35 ug/lAliphatic C5-C35 ug/lAromatic C5-C35 ug/lTPH Ali/Aro ug/lAcenaphthene ug/lAcenaphthylene ug/lAnthracene ug/lBenzo(a)anthracene ug/lBenzo(a)pyrene ug/lBenzo(b)fluoranthene ug/lBenzo(k)fluoranthene ug/lBenzo(g,h,i)perylene ug/lChrysene ug/lDibenzo(a,h)anthracene ug/lFluoranthene ug/lFluorene ug/lIndeno(1,2,3-c,d)pyrene ug/lNaphthalene ug/lPhenanthrene ug/lPyrene ug/lPAH ug/lBenzene ug/lEthylbenzene ug/lToluene ug/lXylene ug/l

DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW1 DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW 1502844 504873 506585 508931 511895 515484 516843 518538 521183 523665 526785 528330 531480 535223 536817

11/04/2013 17/04/2013 23/04/2013 30/04/2013 09/05/2013 16/05/2013 20/05/2013 29/05/2013 05/06/2013 12/06/2013 20/06/2013 25/06/2013 03/07/2013 11/07/2013 17/07/2013

Low flow Low flow

7.82 6.98 7.93 7.17 5.6 n/a 7.62 7.75 7.73 7.61 7.9 8.32 7.47 7.85 6.08

3.4 6.5 7.1 6.1 7.9 8.8 9.3 7.5 9.2 8.7 0.47 10.1 11.4 11 13.10.44 0.56 0.54 0.41 0.21 0.37 0.32 0.47 0.49 0.27 10.6 0.59 0.51 0.5 0.43

< 0.16 < 0.16 0.34 < 0.16 < 0.16 0.23 0.23 0.23 0.91 < 0.16 < 0.16 0.17 < 0.16 0.19 0.2642 40 50 44 40 35 36 46 450 43 52 50 42 41 46

< 0.030 0.03 < 0.030 < 0.030 < 0.030 0.039 < 0.030 < 0.030 0.12 < 0.030 < 0.030 < 0.030 < 0.030 < 0.030 < 0.030< 0.25 < 0.25 < 0.25 < 0.25 < 0.25 < 0.25 4.7 < 0.25 0.56 < 0.25 < 0.25 < 0.25 < 0.25 < 0.25 0.27< 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 13 < 10 < 10 < 10 < 100.8 0.77 < 0.40 < 0.40 < 0.40 1.2 2.6 2 1.7 0.4 < 0.40 < 0.40 0.7 < 0.40 5.3

< 0.090 0.11 < 0.090 < 0.090 0.094 < 0.090 0.24 0.26 < 0.090 < 0.090 < 0.090 < 0.090 0.18 < 0.9000 0.629.1 9 11 9.7 9.1 8.4 7.6 9.9 9 10 13 10 9.7 0.77 9.2

< 0.010 0.082 < 0.010 < 0.010 < 0.010 < 0.010 < 0.010 < 0.010 < 0.010 < 0.010 < 0.010 < 0.010 < 0.010 < 0.010 < 0.0100.62 0.64 1.6 0.9 1 1.9 2.7 1.1 9.7 1.3 0.84 1.2 0.61 57 32.4 11 16 4.9 3.4 9.8 24 6.1 4 2.8 2.8 6.6 2.7 2.4 4.332 37 50 30 28 33 33 34 28 28 36 35 27 2.3 283 5 3 < 1.3 5.5 3.3 3 3.1 5.5 5.5 8.6 3 < 1.3 180 28

89 130 250 100 110 18 86 120 110 110 110 120 120 110 100< 0.035 < 0.035 < 0.035 < 0.10 < 0.10 < 0.035 < 0.035 < 0.035 < 0.035 < 0.035 3.4 < 0.035 < 0.035 < 0.035 < 0.035< 0.10 < 0.10 < 0.10 < 0.10 2 0.59 2.3 0.1 < 0.10 < 0.10 < 0.10 0.38 < 0.10 < 0.10 < 0.10

433 560 564 454 480 524 480 530 494 480 467 567 516 527 507< 0.015 1.2 < 0.015 < 0.015 0.041 < 0.015 0.035 < 0.015 < 0.015 < 0.015 < 0.015 0.074 < 0.015 0.023 0.019< 5.0 66 27 < 5.0 1100 < 5.0 < 5.0 49 13 73 6 < 5.0 390 29 267.6 7.1 7.5 7.4 6.5 7.8 7.1 7.3 7.9 7.7 6.9 7.4 7.6 7.7 7.8

< 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1< 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1< 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 2 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 3.4< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 1.9< 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1< 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1< 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 3.4 < 1.0 < 1.0< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 2.9 < 1.0 2.9< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 66 < 1.0 < 1.0 < 1.0 < 1.0 1.2 < 1.0 < 1.0< 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10 < 10< 10 < 10 < 10 < 10 < 10 < 10 < 10 66 < 10 < 10 < 10 < 10 < 10 < 10 < 10< 10 < 10 < 10 < 10 < 10 < 10 < 10 66 < 10 < 10 < 10 < 10 < 10 < 10 < 10

< 0.01 < 0.01 < 0.01 < 0.01 < 0.03 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.04 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.02 < 0.01 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.010.01 0.01 0.01 < 0.01 < 0.04 < 0.01 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.05 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.02 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.03 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.010.02 < 0.01 < 0.01 0.02 < 0.08 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.010.03 < 0.01 0.04 < 0.01 < 0.03 < 0.01 0.03 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.06 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 0.01 0.01 < 0.07 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.04 < 0.01 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 0.02 0.02 < 0.01 < 0.05 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.06 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 0.01 < 0.01 < 0.085 < 0.01 0.06 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 0.02 < 0.01< 0.01 < 0.01 0.02 0.02 < 0.06 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.20 < 0.20 < 0.20 < 0.20 < 0.20 < 0.20 < 0.20 < 0.20 < 0.20 < 0.20 < 0.20 < 0.20 < 0.20 < 0.20 < 0.20< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0


DOVES NEST SURFACE WATERDETS Lab No.Date

Determinand Units

Field MeasurementspH

T oCEC mS

Laboratory ResultsArsenic, Dissolved ug/lCalcium, Dissolved mg/lCadmium, Dissolved ug/lChromium, Dissolved ug/lHexavalent Chromium ug/lCopper, Dissolved ug/lLead, Dissolved ug/lMagnesium, Dissolved mg/lMercury, Dissolved ug/lNickel, Dissolved ug/lPotassium, Dissolved mg/lSodium, Dissolved mg/lZinc, Dissolved ug/lChloride mg/lNitrite as NO2 mg/lNitrate as NO3 mg/lConductivity uS/cmAmmoniacal Nitrogen as N mg/lSuspended Solids mg/lpHAliphatic C5-C6 ug/lAliphatic C6-C8 ug/lAliphatic C8-C10 ug/lAliphatic C10-C12 ug/lAliphatic C12-C16 ug/lAliphatic C16-C21 ug/lAliphatic C21-C35 ug/lAromatic C5-C7 ug/lAromatic C7-C8 ug/lAromatic C8-C10 ug/lAromatic C10-C12 ug/lAromatic C12-C16 ug/lAromatic C16-C21 ug/lAromatic C21-C35 ug/lAliphatic C5-C35 ug/lAromatic C5-C35 ug/lTPH Ali/Aro ug/lAcenaphthene ug/lAcenaphthylene ug/lAnthracene ug/lBenzo(a)anthracene ug/lBenzo(a)pyrene ug/lBenzo(b)fluoranthene ug/lBenzo(k)fluoranthene ug/lBenzo(g,h,i)perylene ug/lChrysene ug/lDibenzo(a,h)anthracene ug/lFluoranthene ug/lFluorene ug/lIndeno(1,2,3-c,d)pyrene ug/lNaphthalene ug/lPhenanthrene ug/lPyrene ug/lPAH ug/lBenzene ug/lEthylbenzene ug/lToluene ug/lXylene ug/l

DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW 1 DNSW 1540458 541087 544351 546576 551344 551064

24/07/2013 30/07/2013 08/08/2013 15/08/2013 21/08/2013 30/08/2013

Low flow Low flow Low flow Low flow Low Flow Good flow

6.93 7.61 7.38 7.36 7.39 6.13

13.1 12.9 12.2 13.5 12.7 13.90.43 0.49 0.53 1.24 0.53 0.57

< 0.16 0.21 0.29 0.24 < 0.16 < 0.1645 43 39 83 42 44

< 0.030 0.14 < 0.030 < 0.030 < 0.030 < 0.030< 0.25 < 0.25 < 0.25 5.5 < 0.25 < 0.25< 10 < 10 < 10 < 10.0 < 10 < 10

< 0.40 0.84 1.1 1.5 5.4 < 0.40< 0.090 < 0.090 < 0.090 < 0.090 0.2 0.48

9.8 11 10 14 9.6 10< 0.010 < 0.010 < 0.010 < 0.010 < 0.010 < 0.010< 0.50 0.92 1.6 1.7 2 1.5

1.7 4.3 3.3 93 3 2.726 27 14 72 40 31

< 1.3 13 20 23 120 15140 120 140 320 130 120

< 0.035 < 0.035 < 0.035 < 0.035 < 0.035 < 0.0350.31 0.45 3.3 < 0.10 < 0.10 < 0.10483 536 550 1390 555 54815 0.36 0.092 0.057 < 0.015 < 0.01510 74 30 20 11 327.9 8 7.8 7.4 7.9 8

< 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1< 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1< 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0< 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1< 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1< 0.1 < 0.1 < 0.1 < 0.1 < 0.1 < 0.1< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0< 10 < 10 < 10 < 10 < 10 < 10< 10 < 10 < 10 < 10 < 10 < 10< 10 < 10 < 10 < 10 < 10 < 10

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01< 0.20 < 0.20 < 0.20 < 0.20 < 0.20 < 0.20< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0< 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0


Appendix C

Site Masterplan

www.arup.com

78 East Street, Leeds, LS9 8EE

Admiral House, Rose Wharf,

Highways

York Potash Ltd

Proposed Minehead

York Potash

Site General Arrangement

1:2000

234376-00

/ /060314 CW AG PS

Issue for comments

01

YP-P2-CX-031

Tel +44(0 101/100 113 242 8498 Fax +44(0 101/100 113 242 8573

MTS Scheme

\Glo

bal\euro

pe\L

eeds\J

obs\2

30000\2

34376-0

0\0 Aru

p\0-2

0 C

AD\0

_Dra

win

gs\Y

P-P

2-C

X-0

31.d

gn

/ /0314 CW AG PS

Issue for comments

02 13

/ /280314 CW AG PS

03

Issue for comments

/ /110414 CW AG PS

Issue for comments

04

/ /5 040714 CW AG PS

Issue

6

Operation Masterplan

Issue

/ /6 120914 KK CW AG

Issue

BM

X

Overhead Line F

ence B/W 1.3

m

Fence B/W 1.3

m

Assumed Boundary Position

Unable to Survey

(Overgrown)

Sto

ne W

all

Sto

ne W

all

Sto

ne W

all

BS

Drain

BS

214.6m

B 1

416

210.3m

BS

Honeysuckle

205.4m

215.8m

Und

Red Gate

Cattle Grid

BS

210.0m

Sneaton T

horpe Beck

B 1

416

Collects

Pond

Spreads Collects

Spring

Doves’ Nest Farm

Spring

Sinks

Tra

ck

206.7m

Belt Plantations

BS

BS

Whinny Wood

FBDrain

Collects

Drain

209.1m

208.5m

Farm

Honeysuckle

Und

BS 190.2m

Cattle Grid

207.9m

203.9m

RAIK

ES’ L

AN

E

Wind Pump

206.7m

Pond

Drain

Soulsgrave Farm

200.3m

Drain

Tank

Drain

Pond

Whinny Wood

Drain

Haxby Plantation

Drain

Drain

Drain

Issues

Sneato

nThorp

e B

eck

Drain

Haxby Plantation

214.0m

213.4m

210.9m

210.3m

LOUSY HILL LANE

205.4m

Drain

Red Gate

210.0m

Und

BS

220.1m

215.8m

216.7m

Cattle Grid

1.9

8m F

W

BS

BS

Drain

Drain

Belt Plantations

211.5m

214.0m

Drain

214.6m

Drain

Drain

Area Of Trees

Not Surveyed

185

EP

186

Overh

ead Lines

Marsh Land

187

187

187

EP

EPpost

EP

Overh

ead Lines

188

188

188

188

188

Trees Not

Surveyed

Fallen Trees

TP

EP

Overhead Line

189

189

189

189

189

189

EP

190

190

190

190

190

190

190

190

Trees Not

Surveyed

Fallen Trees

191

191

191

191

191

191

191

191

Marsh Land

Trees Not

Surveyed

192

192

192

192

192

192

192

192

Trees Not

Surveyed

EP

193

193

193

193

193

193

193

193 193

Area Of Trees

Not Surveyed

194

194

194

194

194

194

194

194

194

194

Fence B/W 1.3

m

Trees Not

Surveyed

Overhead

Lines

195

195

195

195

195

195

195

195

195

195

Trees Not

Surveyed

Trees Not

Surveyed

post

196

196

196

196

196

196

196

196

196

196

Trees Not

Surveyed

197

197

197

197

197

197

197

197

197

197

197

197

198

198

198

198

198

198

198

198

198

198

198

198

198

Building

Fence B/W 1.3

m

Overhead Line

post

invt 198.77

Bushes

Fence B/W 1.3

m

Spring

199

199

199

199

199

199

199

199

199

199199

199

Bushes

Bushes

200

200

200

200

200

200

200

200

200

200

200

Spring

Doves Nest Farm

Not Surveyed

201

201

201

201

201

201

201

201

201

201

201

Post

& Wire F

ence Ht 1

m

Trees Not

Surveyed

202

202

202

202

202

202

202

202

202

202

202

202

202

202

post

TP 202.15

Tra

ck

Tra

ck

Trees Not

Surveyed

Trees Not

Surveyed

203

203

203

203

203

203

203

203

203

203

203

EP

SAP203.18

Alotment

post

Fence B/W 1.3

m

STYLE

204

204

204

204

204

204

204

204

204

204

204

204

204.12

EP

Overhead Lines

SAP204.16

204.22SAP204.27

post

205

205

205

205

205

205

205

205

205

205

205

205

205

-OR15.000

206

206

206

206

206

206

206

206

206

206

206

206

206

206

Trees Not

Surveyed

Post & Wire Fence

Ht 1m

EP

207

207

207

207

207

207

207

207

207

207

207

207

207

207

DitchDitch

Post & Wire F

ence Ht 1

m

StayStay

Concrete

Fence B/W 1.3

m

208

208

208

208

208

208

208

208

208

208

Trees Not

Surveyed

TP 208.29

Soff 208.31

MH

Trees Not

Surveyed

peg

post

Area Of Trees & Bushes

Not Surveyed

Mound

Trees Not

Surveyed

209

209

209

209

209

209

209

209

209

209

Post & Wire F

ence Ht 1

m

Are

a Of T

rees & B

ushes N

ot S

urv

eyed

post

210

210

210

210

210

210

210

Post & Wire F

ence Ht 1

m

Post & Wire Fence

Ht 1m

peg

invt 210.76

Fence B/W 1.3

m

invt 210.95

211

211

211

211

211

211

211

211

211

211

Wall

Trees Not

Surveyed

Trees Not

Surveyed

J

Area Of Trees

Not Surveyed

Wall

Area Of Trees & Bushes

Not Surveyed

Wall

Wall

Wall

212

212

184.0

m

185.0

m

186.0

m

188.0

m

188.0

m

188.0

m

188.0

m

188.0

m

189.0m

189.0

m

190.0m

190.0m

190.0

m

190.0

m

192.0

m

192.0

m

192.0

m

194.0

m

194.0m

194.0

m

194.0

m

194.0

m

196.0

m

196.0

m

196.0

m

198.0

m

198.0

m

198.0m

200.0

m

200.0

m

200.0

m

200.0m

200.0

m

200.0

m

202.0

m

202.0m

202.0

m

202.0m

202.0m

202.0

m

204.0

m

204.0

m

204.0m

204.0

m

204.0m

204.0

m

206.0

m

206.0m

206.0m

206.0

m

206.0m

206.0

m

206.0m

206.0

m

207.0

m

207.0m

207.0

m

208.0

m

208.0m

208.0

m

208.0

m

208.0

m

208.0

m

209.0

m

209.0

m

209.0

m

210.0

m

210.0

m

210.0

m

210.0

m

210.0

m

211.0

m

211.0m

212.0

m

212.0

m

212.0

m

213.0

m

214.0

m

214.0

m

215.0

m

215.0m

216.0

m

N

210.0m

2014-04-18 MTS Contour model.

1. Proposed contours are based on Estell Warren

Notes:

shaft.

ventilation

Exhaust

Treatment Plant.

Package Sewage

Foul Water

boundary

Land ownership

drainage wetland.

Surface water

drainage wetland.

Surface water

drainage wetland.

Surface water

attenuation pond.

Surface water drainage

attenuation pond.


attenuation pond.


B1416 Sneaton Lane

Welfare Site

Fire water storage tank

storage tank

Domestic potable water

harvesting tank

Potential roof water

MTS access shaft.

(at shaft locations)

200.7 mAOD

Main Shaft Platform at

drainage wetland.

Surface water

drift portal.

Men and materials

3m high Environmental barrier

2.4m high black mesh fencing

buildings

around mine shaft head

Clearance zone required

Surface water drainage wetland

Surface retention pond

Other development areas

Building layout

contours

Proposed site earthwork

Proposed layout

Topographical survey

Extents of works

Land ownership boundary

Key:

of the attenuation pond.

diverted in the vicinity

power cable to be

Existing overhead

barrier.

fence / environmental

Proposed acoustic

associated fan house.

Intake ventilation shaft and

building.

Backup generator

Gatehouse

B 1416

B 1

416

(below ground level).

Petrol interceptor

ground level).

supply tanks (below

Incoming water

level).

(below ground

Oil interceptor

compound.

Substation

and settlement tanks.

water treatment area

Non domestic waste

borehole.

water recharge

Non domestic waste

ground level).

supply tanks (below

Incoming water

A1

Do not scale

Job No

Discipline

Drawing No Issue

Job Title

Client

' Arup

Issue Date By Chkd Appd

Drawing Status

Scale at A1

A B C D E F G H I J K

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

Appendix D

WPL Treatment Plant Details

INLET

375

SCHEMATICSECTIONAL VIEW

60

AIR SCOUR INLET

ULTRASONIC CABLE GLANDSABOVE AIR CONNECTION

50

OUTLET

924

BOLTED GRP CONSTRUCTION

INTERNAL: LIGHT BLUE 16 C 33 TO BS4800EXTERNAL: DARK GREEN 14 C 39 TO BS4800

PLAN VIEW(LID REMOVED)

PUMP BACKWASH RETURNSHOWN IN STANDARD POS,NSEE ORIENTATION DIA.ON CUSTOMER G.A. FORACTUAL POS,N

524

3000

AIR SCOUR INLET& CABLEING

160041

522

50

340

6 300

S

AND

200

3040

2255

40 M

IN.

INITIAL

341

360

LOW LEVEL LATCH

1280

1178/45°

628/45°

1225

2450

1225

691

REF

1070

125

600

1000

FAX: (02392) 242624TEL: (02392) 242600

e-mail: [email protected]

DESIGN

CHECKED

DRAWN

ISSUE DATE CHANGE

c This drawing is the copyright of WPL ltd

INITIAL

HAMPSHIREWATERLOOVILLE

P07 7UX

1 & 2 ASTON ROAD

IF IN DOUBT, ASKDRAWING NUMBER

DRAWING NUMBER

DIM'S IN

MATERIAL

FINISH

SCALE

TOLERANCES

PAPERSIZEmm TITLEA4

DO NOT SCALE

WPL LIMITED

DCG

PD

A 06.09.96 NEW DRAWING

DD-140-180

DD-140-180

1600DIA SAND FILTERASSEMBLY GAVSFO4

DK GREEN 14 C 39 TO BS4800

N.T.S.

+/- 10mm

GRPINTERNAL: BLUE 16 C 33 TO BS4800

B 17.04.97

FEDC

03.03.0920.02.0228.04.9806.05.97

PUMP/AIR.WATER CONNS CHANGED

ADD NON RETURN & VALVEFIT ULTRASONIC SENSORUPDATE DESIGN REVIEWAIRPIPE WORK CHANGED

MLPB

PDPD

PD

Envirochem Analytical Laboratories Ltd. Unit 12 The Gardens, Broadcut, Fareham. PO16 8SS. Tel: 01329 287777

Client: WPL Ltd

Address: Units 1 & 2 Aston Road, Waterlooville, Hampshire, PO7 7UX

Site details: Beaconsfield Date Sampled: Time sampled: not stated by client

Envirochem Job Number: Date Received: Time Received: 13:00

note: all results in mg/l unless stated Sheet 1 of 1

Sample Results Remarks

Lab

sam

ple

no.

Cli

ent

Ref

Sam

ple

Loc

atio

n /

Det

ails

Wat

er T

yp

e

Am

mon

ia

BO

D

Susp

end

ed S

olid

s

che-1 NGR SU 9507188463 Beaconsfield Effluent 1.3 4.8 <10

Method Number: Colourimetric — 6.10

Potable water — — —

Ground Water — — —

Effluent Water — — 500

Detection Limit 0.2 2 10

Accreditation Analytes marked U are analysed under the scope of our UKAS accreditation Analytes marked u are subcontracted and analysed under the scope of their UKAS accreditation

Limits: Potable Water: Schedule 1 , The Surface Waters (Abstraction for Drinking Water)(Classification) Regulations 1996. and SE water supply PCVs

Ground Water: Intervention values above which pollutants should generally be treated. From Dutch Ministry of Housing 2000

Effluent water: Guide maxima for common substances.

Conforming samples: All results labelled with an asterisk (*) are non-conforming due to incorrect sample storage or handling. The result may be invalid.

Comments: (all comments are beyond the scope of our accreditation)

Analyst(s): K. O'Connor Authorised by:

Date completed: 23rd August 2013

Date Issued: 23rd August 2013

1300425 15-Aug-13

15-Aug-13


Client: WPL Ltd


Site details: Beaconsfield Date Sampled: Time sampled: not stated by client

Envirochem Job Number: Date Received: Time Received: 15:30



Lab

sam

ple

no.

Cli

ent

Ref

Sam

ple

Loc

atio

n /

Det

ails

Wat

er T

yp

e

Am

mon

ia

BO

D

Susp

end

ed S

olid

s

che-1 — Beaconsfield Effluent 0.35 4.1 <10

Method Number: Colourimetric — 6.10

Potable water — — —

Ground Water — — —

Effluent Water — — 500



Limits: Potable Water: Schedule 1 , The Surface Waters (Abstraction for Drinking Water)(Classification) Regulations 1996. and SE water supply PCVs

Ground Water: Intervention values above which pollutants should generally be treated. From Dutch Ministry of Housing 2000

Effluent water: Guide maxima for common substances.

Conforming samples: All results labelled with an asterisk (*) are non-conforming due to incorrect sample storage or handling. The result may be invalid.

Comments: (all comments are beyond the scope of our accreditation)

Analyst(s): K. O'Connor, A. Pinkney Authorised by:

Date completed: 14th August 2013

Date Issued: 14th August 2013

1300400 06-Aug-13

06-Aug-13


WATER ANALYSIS REPORT

Client: WPL Ltd


Site details: Moto Winchester Date Sampled: 28th March 2012

Envirochem Job Number:



Lab

sam

ple

no.

Cli

ent

Ref

Sam

ple

Lo

cati

on

/

Det

ails

Wat

er T

yp

e

Am

mon

ia

Susp

end

ed s

oli

ds

BO

D (

tota

l)

che-1 Moto Winchester 28.03.2012 (14:30) Effluent 1.2 < 5 7.1

Method Number: Colourimetric 6.10 -



Analyst(s): K. O'Connor Authorised by:

Date completed: 4th April 2012

Date Issued: 4th April 2012

1121777



Client: WPL Ltd


Site details: Winchester Date Sampled: 25th May 2012

Envirochem Job Number:



Lab

sam

ple

no.

Cli

ent

Ref

Sam

ple

Lo

cati

on

/

Det

ails

Wat

er T

yp

e

Am

mon

ia

Susp

end

ed s

oli

ds

BO

D (

tota

l)

che-1 Winchester 25/05/2012 Effluent 1.1 < 5 5.4




Analyst(s): K. O'Connor, S.Bessant Authorised by:

Date completed: 4th June 2012

Date Issued: 6th June 2012

1203846



Client: WPL Ltd


Site details: Winchester Date Sampled: 4th July 2012 15:00

Envirochem Job Number: Date Received : 4th July 2012 16:30



Lab

sam

ple

no.

Cli

ent

Ref

Sam

ple

Loc

atio

n /

Det

ails

Wat

er T

yp

e

Am

mon

ia

Susp

end

ed s

olid

s

BO

D (

tota

l)

che-1 04/07/2012 Winchester - final Effluent 0.57 2.3 < 2



Accreditation Analytes marked U are analysed under the scope of our UKAS accreditationAnalytes marked u are subcontracted and analysed under the scope of their UKAS accreditation

Analyst(s): K. O'Connor, S. Bessant Authorised by:

Date completed: 10th July 2012

Date Issued: 11th July 2012

1206523

Appendix E

WFD Catchment Status and Target

Catchment: Esk and Coast RBD: 4

Waterbody Category and Map Code.: River - R22 Surveillance site: Yes

Waterbody ID and Name: Rigg Mill Bk/Long Mill Bk catch (trib of Esk)GB104027068140

National Grid Reference: NZ 91232 06523

Current Overall Status Poor

(For Protected Area Objectives see Annex D)Good by 2027Status Objective (Overall):

Status Objective(s): Good Ecological Status by 2027

Disproportionately expensive, Technically infeasible Justification if overall objective is not good status by 2015:

Protected Area Designation: Freshwater Fish Directive

SSSI (Non-N2K) related: No

Hydromorphological Designation: Not Designated A/HMWB

Reason for Designation:

GB510402703400Downstream Waterbody ID:

Ecological Status

Current Status (and certainty that status is less than good)

Poor (Very Certain)

Biological elements

Element Current status (and certainty of less than good)

Predicted Status by 2015

Justification for not achieving good status by 2015

Fish Poor (Very Certain) Poor Disproportionately expensive (P1a), Technically infeasible (B2p, S2b)

Supporting conditions




Quantity and Dynamics of Flow Morphology

Supports Good Supports Good


Chemical Status


Does not require assessment

Environment Agency, Annex B Humber River Basin District, December 2009

46

http://maps.environment-agency.gov.uk/wiyby/wiybyController?topic=wfd_rivers&layerGroups=default&lang=_e&ep=map&scale=3&x=245788.08970000013&y=253938.9215#x=491232&y=506523&lg=1,5,6,7,&scale=4


Waterbody Category and Map Code.: River - R23 Surveillance site: No

Waterbody ID and Name: River Esk from Sleddale Beck to RuswarpGB104027068150

National Grid Reference: NZ 83232 05798

Current Overall Potential Moderate

(For Protected Area Objectives see Annex D)Good by 2027Status Objective (Overall):

Status Objective(s): Good Ecological Potential by 2027, Good Chemical Status by 2027

Disproportionately expensive, Technically infeasible Justification if overall objective is not good status by 2015:

Drinking Water Protected Area, Freshwater Fish Directive Protected Area Designation:

SSSI (Non-N2K) related: No

Hydromorphological Designation: Heavily Modified

Flood Protection, Recreation, Urbanisation, Wider Environment Reason for Designation:

GB510402703400Downstream Waterbody ID:

Ecological Potential


Moderate

Biological elements




Fish Not Required (MS) Moderate (Uncertain) Moderate

Invertebrates High High

Supporting elements




Ammonia (Phys-Chem) High High

Dissolved Oxygen High High

pH High High

Phosphate High High

Temperature Good Good

2,4-dichlorophenol High High

High 2,4-dichlorophenoxyacetic acid Arsenic

Copper

Dimethoate

Iron

Linuron

Mecoprop

Permethrin

Toluene

Zinc

Ammonia (Annex 8)

High

High

High

High

High

High

High

High

High

High

High

High

High

High

High

High

High

High

High

High

High


47

http://maps.environment-agency.gov.uk/wiyby/wiybyController?topic=wfd_rivers&layerGroups=default&lang=_e&ep=map&scale=3&x=245788.08970000013&y=253938.9215#x=483232&y=505798&lg=1,5,6,7,&scale=4


Supporting conditions




Quantity and Dynamics of Flow


Ecological Potential Assessment

Element Justification for not achieving good status by 2015


Current status

Moderate Mitigation Measures Assessment

Moderate Disproportionately expensive (M2c), Technically infeasible (M3a, M3b)

Mitigation Measures that have defined Ecological Potential

Mitigation Measure Status

Appropriate channel maintenance strategies and techniques - woody debris In Place

Appropriate channel maintenance strategies and techniques - minimise disturbance to channel bed and margins Appropriate techniques to align and attenuate flow to limit detrimental effects of these features (drainage)

In Place

Not In Place

Chemical Status


Fail (Quite Certain)


48


Chemical elements




1,2-dichloroethane

Atrazine

Benzene

High

High

High

High

High

High

High

HighBenzo (a) and (k) fluoranthene Benzo (ghi) perelyene and indeno (123-cd) pyrene Benzo(a)pyrene

ModerateModerate (Quite Certain) Disproportionately expensive (C1a)

High

High High

HighCadmium And Its Compounds Fluoranthene

Hexachlorobenzene

Hexachlorobutadiene

Hexachlorocyclohexane

Lead And Its Compounds

High

High

High

High

High

High

High

High

High

High

High

HighMercury And Its Compounds Napthalene

Nickel And Its Compounds

Pentachlorophenol

Simazine

Tributyltin Compounds

Trichlorobenzenes

Trichloromethane

Trifluralin

High

High

High

High

High

High

High

High

High

High

High

High

High

High

High

High

High

HighAldrin, Dieldrin, Endrin & Isodrin Carbon Tetrachloride

DDT Total

para - para DDT

Tetrachloroethylene

Trichloroethylene

High

High

High

High

High

High

High

High

High

High


49

Appendix F

H1 Assessment

Technical Note

\\GLOBAL\EUROPE\LEEDS\JOBS\230000\234376-00\0 ARUP\0-12 WATER\0-12-08 REPORTS\01 DOMESTIC FOUL DRAINAGE\2014-09-26 ON-SITE TREATMENT OF DOMESTIC FOUL

SEWAGE AT DOVE'S NEST REV1\APPENDICES\APP F- H1\TN-P2-FD-001 FOUL DISCHARGE H1 ASSESSMENT 140926 REV0.DOCX

Page 1 of 8 Arup | F0.15

Admiral House Rose Wharf

78 East Street

Leeds LS9 8EE

United Kingdom

www.arup.com

t +44 113 242 8498

f +44 113 242 8573

Project title York Potash – Preliminary Design Job number

234376-32

cc File reference

TN-P2-FD-001

Prepared by Milly Hennayake

Date

26 September 2014

Subject i

Domestic Foul Sewage Effluent and Water Quality Impact Assessment

1 Introduction

As part of the proposed development, consideration has been given to the management of domestic foul sewage generated by welfare/office facilities at the Dove’s Nest site. Previous investigations undertaken by Atkins in 2013, and refined by Arup in 2014, concluded that an off-site connection to public sewer is not viable (discussed elsewhere).

The use of an on-site package treatment plant is proposed, designed to treat all domestic foul sewage generated on site, with treated effluent discharged to Sneaton Thorpe Beck. This option was presented in the 2013 planning application and comments were provided by the Environment Agency (EA), North York Moors National Park Authority (NYMNPA) and AMEC (acting on behalf of NYMNPA).

In 2014, Arup re-examined the on-site treatment option developed by Atkins, updated it as required for the current development proposals and produced a report describing the proposed sewage treatment processes and assessing the impact on water quality in the receiving watercourse. Comments on this report were received from the EA and AMEC in August 2014, and a meeting held on 1st September 2014 to discuss remaining concerns held by the EA.

This technical note presents an update to the H1 assessment undertaken by Atkins in 2013, using expanded datasets for flow and water quality in Sneaton Thorpe Beck.

1.1 Documents Referenced

Document Ref Document Title

4 June 2013 Atkins Technical Note – Foul Discharge – Environmental Objection

5115159-TR/005 Atkins H1 Assessment (4 June 2013)

REP-P2-FD-002 Rev0

Arup report ‘On-site Treatment of Domestic Foul Sewage at Dove’s Nest’ (June 2014)

AMEC Review of Arup Report (August 2014)

Technical Note

234376-32 26 September 2014




RA/201/129240/01 EA Review of Arup Report (15 August)


Flow Monitor Installation Report (Enviromontel, 29/08/2014)

Interim Report 1 (Enviromontel, flow survey data retrieved for the period 28/08/2014-11/09/2014)

Standards referred to:

The River Basin Districts Typology, Standards and Groundwater threshold values (Water Framework Directive) (England and Wales) Directions 2010

UK environmental standards and conditions (UKTAG) 2008

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/298245/geho0810bsxl-e-e.pdf

2 Flow Data for Sneaton Thorpe Beck

For the H1 Assessment undertaken in 2013, the only flow data available for Sneaton Thorpe Beck

was derived from statistical low flow analysis, giving a 95%ile low flow of 2 l/s.

In order to better inform the Environmental Impact Assessment being undertaken by Royal

Haskoning, three flow monitors were installed in Sneaton Thorpe Beck on the 28th of August by

Enviromontel Special Projects. The installation points for the flow monitors were chosen to best

represent the typical flow conditions in the Beck and are shown in Error! Reference source not

Figure 1: Location plan of flow monitors in Sneaton Thorpe Beck



Technical Note

234376-32 26 September 2014




Figure 3: Hydrograph showing flow data for FM 02

found.. FM 01 is located immediately downstream of the proposed discharge of treated foul

sewage effluent. FM02 is located at the approximate location where Doves Nest Spring joins the

Beck, and FM03 is located a further 500m downstream.

Data is collected from the flow meters every fortnight. At the time of writing, observed flow data

was available for the period 28/08/2014-11/09/2014, as summarised in Enviromontel’s Interim

Report 1. Interim Report 2 will be available shortly after 25/09/2014 following the second retrieval

date.

Based on the first two weeks of monitoring, Figure 2 below is a hydrograph of the flow data for

FM01, which illustrates that the flow is generally between 5-7 l/s, when values are recorded; NULL

values occur when the depth of flow is below 10mm.

Of the three flow monitors, FM02 had the most consistent readings as shown in Figure 2.


Technical Note

234376-32 26 September 2014




FM03 recorded consistent data until 06/09/2014, when it is assumed the monitor was obscured by debris (observed during retrieval). The sudden drop-off can be seen in Figure 4. Consequently, all data for FM03 after 04:40am on the 6th of September is deemed unreliable, and was omitted from analysis.

For the purposes of calculating average flows and depths, Enviromontel discounted any NULL values, hence the variance between the flow and depth values generated from the hydrographs (NULL values included) and the final values shown below in Table 1 (discounting all NULL values).

Sensor: Average Flow

(l/s)

Peak Flow

(l/s)

Average Depth

(mm)

Peak Depth

(mm)

FM01 6.203 16.1 26.44 48

FM02 94.9 116.6 59 83

FM03 126.16 204.8 62.67 79

Table 1: Flow and depth values from flow monitors in Sneaton Thorpe Beck

The flow data generally shows very little variation over the 2 weeks 28/08/2014-11/09/2014, due to

the fact that it was a very dry fortnight. As part of the flow survey, rain gauges were installed on

11/09/2014 in the immediate vicinity of the monitoring points. For the first 2 weeks of the survey,

however, the nearest available rain gauge data comes from weather stations at Westerdale (25km

west of the site) and Whitby (6km north of the site). Observed rainfall data from these weather

stations are shown below in Table 2.


Technical Note

234376-32 26 September 2014




Date

Rain (mm)

Westerdale Station (Lat. 054

26 00; Long. 000 58 00)

Whitby Weather Station

(http://www.wunderground.com)

28- Aug 1.2 0.5

29-Aug 0.8 0

30-Aug 0.0 0

31-Aug 0.0 0

01-Sep 0.4 1.0

02-Sep 0.0 0

03-Sep 0.0 0

04-Sep 0.0 0

05-Sep 0.0 0

06-Sep 7.8 3.8

07-Sep 0.0 0

08-Sep 0.0 0

09-Sep 0.0 0

10-Sep 1.2 0

11-Sep 0.0 0

Table 2: Rainfall data for Westerdale Station and Whitby

The hydrographs show a small response to the minor rainfall events on 30-Aug and 06-Sep, quickly

returning to what can be considered to be the base flow in these reaches of Sneaton Thorpe Beck.

Given the very dry conditions experienced over the course of the flow monitoring period to

11/09/2014, the average flows summarised in Table 1 have been used to carry out an updated H1

Assessment.

3 Water Quality Data for Sneaton Thorpe Beck

The dataset for water quality in Sneaton Thorpe Beck is larger than it was at the time of Atkins’ H1 assessment in 2013, as a result of sampling and testing carried out in 2014 by FWS. The expanded dataset was reported in the Arup report of June 2014. No further water quality data has been collected since.

The water quality monitoring carried out to date has not included any BOD measurements; therefore the effects of the proposed sewage effluent discharge have been estimated based on an assumed background concentration of BOD in the watercourse of zero.

Technical Note

234376-32 26 September 2014




4 H1 Assessment

An updated H1 assessment has been carried out by Arup using both statistical and observed flow data in Sneaton Thorpe Beck, and applying the following input parameters:

1. The average background concentration of ammonia in Sneaton Thorpe Beck was calculated excluding the 15 mg/l outlier from the water quality dataset

2. Where the water quality sample for ammonia in Sneaton Thorpe Beck was recorded as <0.015 mg/l it was taken to be 0.015 mg/l

3. The treated sewage effluent flow rate will be 0.81 l/s

4. The sewage treatment plant will produce an effluent with ammonia concentrations at 2 mg/l (though iterating with lower values has been done in some scenarios to determine the point at which targets would be achieved)

5. The benchmark value for ammonia was taken as 0.6 mg/l, commensurate with the current WFD target in the Sneaton Thorpe Beck/Rigg Mill catchment for ‘Good ecological status’ by 2027.

The tables below are derived from the results of the H1 assessment tool. The process contribution

(PCwater) of the determinant is calculated and then compared to the relevant environmental

benchmarks. The predicted environmental contribution (PEC) indicates the ammonia levels in the

Beck after the foul sewer discharge. If the percentage of the PEC value over EQS (the

environmental standard) is over 70% then further modelling needs to be carried out.

4.1.1 Statistical Low Flow Analysis

Channel Flow Rate from Statistical Low Flow Analysis = 2 l/s

Determinant Benchmark EQS

(µg/l)

PCwater

(µg/l)

PCwater

as % of

EQS

>4%

EQS

Background

Concentration

(µg/l)

PEC

(µg/l)

PEC as %

of

EQS/EAL

>70%

PEC

2mg/l in

effluent 0.6 mg/l 600 576.51 96.09 Yes 155 687 114 Yes

1.7mg/l in


1mg/l in

effluent 0.6 mg/l 600 288.26 48.04 Yes 155 399 66.5 No

BOD

(10mg/l) 5 mg/l 5000 2882.56 57.65 Yes 0 2883 57.7 No

Table 3: Results from H1 Assessment for Statistical Low Flow Analysis

The results of the H1 assessment illustrate that with a flow rate of 2 l/s in the Beck, the contribution of the

sewage effluent exceeds 70% of EQS, prompting more detailed modelling to determine the exact impact.

The EA are currently undertaking this more detailed modelling (results not available at the time of writing).

The above results also demonstrate that if a concentration of ammonia in the effluent of 1.7 mg/l would be

required to achieve the benchmark PEC of 600 µg/l.

Technical Note

234376-32 26 September 2014




4.1.2 Observed Flow at FM01 (NULL values included)

Average channel flow rate from observed data = 2.903 l/s


(µg/l)

PCwater

(µg/l)

PCwater

as % of

EQS

>4%

EQS

Background

Concentration

(µg/l)

PEC

(µg/l)

PEC as %

of

EQS/EAL

>70%

PEC

2mg/l in


1mg/l in


BOD

(10mg/l) 5 mg/l 5000 2181.52 43.63 Yes 0 2182 43.7 No

Table 4: Results of H1 Assessment for Observed Flow Rate of 2.903 l/s

The results of the H1 assessment illustrate that when the ammonia concentration in the effluent is 2

mg/l, the benchmark PEC of 600 µg/l is achieved, but the contribution of the effluent to the overall

concentration of ammonia in the Beck exceeds 70%, so further modelling would be required.

4.1.3 Observed Flow at FM01 (NULL values excluded)

Average channel flow rate from observed date = 6.2 l/s


(µg/l)

PCwater

(µg/l)

PCwater

as % of

EQS

>4%

EQS

Background

Concentration

(µg/l)

PEC

(µg/l)

PEC as %

of

EQS/EAL

>70%

PEC

2mg/l in


1mg/l in


BOD

(10mg/l) 5 mg/l 5000 1155.49 23.11 Yes 0 1155 23.2 No

Table 5: Results of H1 Assessment for Observed Flow Rate of 6.2 l/s

The results of the H1 assessment illustrate that when the ammonia concentration in the effluent is 2 mg/l, the benchmark PEC of 600 µg/l is achieved, and the contribution of the effluent to the overall concentration of ammonia in the Beck is <70%, so no modelling would be required.

In order to achieve a PEC of 200 µg/l (the WFD benchmark for ‘High’ ecological status) the ammonia concentration in the sewage effluent would have to be <1mg/l, therefore requiring additional treatment/polishing downstream of the package treatment plant.