Report Reference: AU/KCE/MM/1561/01Scoping February 2011

PROPOSALS FOR THE SCOPE AND CONTENT OF AN APPLICATION FOR PLANNING PERMISSION AND AN ENVIRONMENTAL IMPACT ASSESSMENT FOR AN EXTENSION IN TIME AND AREA FOR THE LANDFILL DISPOSAL OF HAZARDOUS WASTE AND LOW LEVEL RADIOACTIVE WASTE, AN EXTENSION IN TIME FOR THE OPERATION OF THE SOIL TREATMENT FACILITY AND OTHER ASSOCIATED DEVELOPMENT AS MORE PARTICULARLY DESCRIBED IN THIS REPORT AT THE EAST NORTHANTS RESOURCE MANAGEMENT FACILITY, STAMFORD ROAD, NORTHAMPTONSHIRE

Report reference: AU/KCE/MM/1561/01scoping February 2011

Baddesley Colliery Offices, Main Road, Baxterley, Atherstone, Warwickshire, CV9 2LE Tel. (01827) 717891 Fax. (01827) 718507

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CONTENTS

1. Executive summary

2. Introduction

3. The site

4. The proposed development

5. Planning context

6. Assessment of effects

7. The structure of the planning application and Environmental Statement

TABLES

Table 1 The Development Plan

FIGURES

Figure 1 The site location (drawing reference AU/KCE/02-11/15951)

Figure 2 The current site layout and application boundary (drawing reference AU/KCE/02-11/15952)

Figure 3 Proposed western extension (drawing reference AU/KCE/02-11/15950)

Figure 4 Schematic preliminary restoration plan (drawing reference AU/KCE/02-11/15953

Figure 5 The proposed noise monitoring locations (drawing reference AU/KCE/02-11/15954)

APPENDICES

Appendix A List of consultees

Appendix B Proposed structure of the Planning Application and Environmental Statement

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1. Executive summary

1.1 Augean PLC is the operator of the East Northants Resource Management Facility and is planning to submit a planning application for an extension in the life of the site including an extension in the landfill area to the west of the current landfill. The planning application will be accompanied by an Environmental Impact Assessment. In this document the elements of the proposed development are set out in general terms together with the scope of the environmental impact assessments which it is anticipated will be carried out. The opinions of Northamptonshire County Council and their consultees are sought on the proposed scope of the assessments that will be included in the Environmental Impact Assessment.

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2. Introduction

2.1 Augean PLC operates the East Northants Resource Management Facility (RMF) in Northamptonshire. The facility comprises an active hazardous waste landfill and soil treatment facility with clay extraction operations and associated infrastructure. The landfill is one of only seven in England and Wales which can accept a wide range of hazardous wastes. It is the only hazardous landfill site in the East Midlands and there are no sites accepting a similar range of wastes in the East of England, the South East, London or the West Midlands. The soil treatment facility is one of only two facilities in England and Wales providing a range of treatments. The planning consent for the landfill site states that it shall be progressively restored and completed not later than 31 August 2013 and the planning consent for the soil treatment facility states that it shall cease operating by 31 August 2013.

2.2 In July 2009 a planning application was submitted to Northamptonshire County Council for the landfill disposal of low level radioactive waste in cells 4B, 5A and 5B at the East Northants RMF in addition to the consented hazardous waste. The application was refused in March 2010. Augean PLC has appealed against the decision and a Public Inquiry into the decision was held in October and November 2010. A decision on the appeal is expected to be made on or before 24 May 2011.

2.3 The remaining void space in the landfill for hazardous waste at the beginning of 2010 was approximately 560,000m3. It is now extremely unlikely given the current market conditions that the landfill will be completed by 2013. It is estimated that in the current market the probable rate for the deposition of hazardous waste is between 100,000 tonnes and 120,000 tonnes per annum which would mean that the site could be completed to the current permitted levels between mid 2015 and mid 2016.

2.4 Since 2007 Augean has made representations to the Northamptonshire Minerals and Waste Development Framework for the development of an extension to the permitted void in an area to the west of the current landfill. An extension in the landfill void is necessary to provide a continuing facility for the disposal of hazardous wastes in the medium to long term.

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2.5 Augean PLC is preparing an application for submission to Northamptonshire County Council for planning permission to extend operations at the facility. The proposed development will comprise:

 A time extension of approximately 3 years to complete clay extraction and landfilling of the consented landfill by the end of December 2016 with an associated time extension to the end of December 2016 for the life of the soil treatment facility.

 An extension of the landfill to the west of the current landfill creating additional void which will provide approximately 10 years of life. The proposed extension is within the boundary of the extant planning consent.

 Filling of the void with hazardous waste and potentially low level radioactive waste

 The extraction and stockpiling of clay to provide engineering material for use in the construction of an engineered containment system at the site, the exportation of clay for use in engineering the nearby Augean Thornhaugh Landfill Site and for general sale.

 The extension of the life of the soil treatment facility located in the north west of the site to December 2026 and a change in the orientation of the storage area associated with the treatment facility.

 The restoration of the site to woodland and grassland by the end of December 2026.

2.6 The proposal for the disposal of low level radioactive waste is included in the scoping exercise although a final decision on whether to include it as part of the proposed development will not be made until the outcome of the scoping exercise and completion of other preliminary assessment work.

2.7 The proposed development comprises a Schedule 1, section 9 development under The Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 as amended. In accordance with the regulations an Environmental Impact Assessment will be undertaken and the report of the impact

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assessment, which will comprise an Environmental Statement, will be submitted with the planning application.

2.8 MJCA are commissioned by Augean PLC to undertake the Environmental Impact Assessment. In this report the approach to the application and the proposed scope of the Environmental Impact Assessment (EIA) are explained. The purpose of this report is to set out in general terms the elements of the proposed development and to explain the scope of the assessments which will be carried out as part of the EIA of the proposed development. The detailed designs of the elements of the proposed development are being progressed. The design development process is iterative and will continue throughout the consultation period up to the submission of the application. The opinions of Northamptonshire County Council (NCC) and their consultees are sought on the proposed scope of the assessments that will be included in the EIA. This document has been prepared based on discussions with Augean PLC and Northamptonshire County Council, and the Environment Agency, and based on the experience of MJCA.

2.9 This report together with a request for a scoping opinion will be submitted to NCC. The scoping report will be circulated by NCC to the statutory consultees together with a wider range of consultees for their comments and the comments of the consultees will be incorporated in the formal scoping opinion issued by NCC. The East Northants RMF operations are the subject of Environmental Permits issued and regulated by the Environment Agency. Any extension to the waste management operations at the site will be the subject also of an Environmental Permit.

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3. The site

3.1 The East Northants RMF lies approximately 1.7km east south east of Duddington and 2.6km north of Kings Cliffe village in the East Northamptonshire district of Northamptonshire (Figure 1). The setting is generally rural with the majority of the land surrounding the site comprising open farmland or woodland. The application site occupies approximately 32 hectares and is within the boundary of the area which is the subject of the current planning consents (Figure 2). The land in the planning application area is owned by Augean PLC.

3.2 The site comprises an active hazardous waste landfill including restored and partially restored landfill areas together with a soil treatment facility. A gas management and surface water management compound including a flare stack are located in the north western corner of the site. Site infrastructure including the site access, waste reception facilities, car parking areas, site offices, welfare facilities, storage areas, laboratories and wheel and vehicle body washing facilities are in place at the site (Figure 2).

3.3 The current landfill comprises 5 phases of landfilling with each phase of landfilling subdivided into two. Landfilling operations are complete in Phases 1, 2 and 3 which substantially have been capped. Currently landfilling operations are being carried out in Cell 4A and Cell 4B. Phase 5 has yet to be developed. Soil has been stripped from the western area of the site to the west of the landfill area and this area is used currently for the soil treatment facility including a concrete pad and for the storage of clay and overburden.

3.4 The current highway access to the East Northants RMF will continue to be used for the proposed development. The access is from Stamford Road which is an unclassified road that runs adjacent to the eastern boundary of the East Northants RMF from the A47 to the north to Kings Cliffe to the south. The access road enters the reception area adjacent to and south east of the landfill.

3.5 To the east of the site and Stamford Road are Westhay Cottages and Westhay Farm which is operated as a haulage yard and a farm with associated agricultural and commercial buildings. To the south of the site are farm buildings and open agricultural land. To the west of the landfill area there is open agricultural land and

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North Spinney Wood. The boundary of the operational training airfield at RAF Wittering is located approximately 800m to the north east of the application site.

3.6 Adjacent to the northern boundary of the site is Collyweston Great Wood. To the east north east of the site is an area of woodland known as Easton Hornstocks. Parts of the Collyweston Great Wood and Easton Hornstocks comprise a Site of Special Scientific Interest (SSSI) and a National Nature Reserve (NNR). No public rights of way cross the site.

3.7 The site formerly was known as Slipe Clay Pit and has a history of mineral and waste development. In July 2006 planning permission reference EN/05/1264C was granted for a hazardous waste landfill and associated operations which permits the importation of up to 249,999 tonnes of hazardous and inert waste materials to the site per annum. On 19 September 2006 planning permission reference EN/06/01517/CRA was granted for the installation and operation of a gas flare and a surface water pumping station in the north west of the site. On 10 January 2008 planning permission reference number 07/00048/WAS and 07/01838/NCC was granted for the installation and operation of a soil treatment facility.

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4. The proposed development

4.1 The full details of the proposed development will be set out in the planning application documents. The main elements of the proposed development are described in section 2 in summary they will comprise a time extension for the consented landfill and soil treatment facility to December 2016, an extension in the landfill area to the west of the currently consented landfill creating approximately an additional 10 years of life, infilling with hazardous and potentially low level radioactive waste (LLW), a time extension for the operation of the soil treatment facility to 2026 and restoration of the site to woodland and grassland.

4.2 The remaining void at the site as at the beginning of 2010 was approximately 560,000m3. Based on anticipated waste input rates of 120,000tpa the remaining void will not be filled until between mid 2015 and mid 2016 hence an extension of time for the completion of the site to the consented restoration profile of approximately 3 years beyond the currently permitted end date of August 2013 to the end of December 2016 is necessary.

4.3 It is proposed that a void extension is created to the west of the current landfill area (Figure 3). The limit of extraction of the proposed western extension has been determined based on the land under the control of the applicant together with other constraints at the site such as the available clay, the presence of boundary features and the locations of proposed mitigation planting and existing facilities such as the gas flare, surface water management facility and the soil treatment facility. The additional void will allow site operations to continue to provide a facility for the disposal of hazardous waste and potentially for the disposal of LLW for approximately 10 additional years which including completion of the current consented landfill is up to the end of December 2026.

4.4 The landfill site will be designed and operated based on the principle of engineered containment with low permeability basal, perimeter and capping seals constructed to an engineering specification. It is proposed that clay is extracted during the development of the site and together with currently stockpiled clay is used in the construction of the clay containment system for the landfill cells. Clay will be exported from the site to the nearby Augean PLC landfill site at Thornhaugh where

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there is a need for clay for use in the construction of the engineered lining system. The remaining clay will be exported for general sale. Inert wastes will be imported and used for restoration purposes.

4.5 The currently permitted total waste importation rate to the site is up to 249,999 tonnes per annum. The currently permitted total amount of waste materials imported to the soil treatment facility is 100,000tpa. The waste input rates to the landfill extension area and to the soil treatment facility for which permission will be sought will be determined based on the results of analysis of the traffic impact assessment and a review of the anticipated arisings of and required capacities for the relevant wastes. Consideration will be given to the need to accommodate the potential for variable input rates as a result of peaks in waste production from particular activities which may generate large quantities of arisings over short periods. The currently permitted void and the extension will be filled with hazardous waste.

4.6 The current Environmental Permit for the landfill operations specifies the types of hazardous waste permitted for importation and deposition at the site. To ensure that only permitted wastes are deposited within the landfill Augean PLC operates a rigorous set of waste acceptance criteria. As part of its ISO 14001 Environmental Management System Augean PLC has formal procedures to ensure only permitted wastes are deposited. Procedures for pre-acceptance assessment, waste acceptance criteria and the reception, inspection and verification of waste are also formalised and rigorously enforced. Any waste that arrives at the site that has not been subject to the pre-acceptance and booking procedure is rejected or quarantined and the Environment Agency immediately informed.

4.7 LLW is waste that contains small amounts of radioactivity. The waste typically comprises construction and demolition waste such as rubble, soils, crushed concrete, bricks and metals from the decommissioning of nuclear power plant buildings and infrastructure, lightly contaminated miscellaneous wastes from maintenance and monitoring at these facilities such as plastic, paper and metal and wastes from manufacturing activities, science and research facilities and hospitals where radioactive materials are used.

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4.8 The radioactivity of the waste that will be accepted at the site is minimal. LLW comprises radioactive waste with a radioactive content not exceeding 4,000 becquerels per gram (Bq/g) of alpha activity or 12,000 Bq/g of beta or gamma activity however the waste which it is proposed will be disposed of at the East Northants RMF will be limited to that which has a level of radioactivity of up to 200 Bq/g. This means that only LLW with the lowest 5% of radioactivity will be accepted at the site.

4.9 The soil treatment facility for hazardous wastes currently is located in the north west of the site with the storage area orientated in a north-south direction. The facility includes consent for a soil washing plant, an immobilisation unit, a laboratory/office and an area for bioremediation. The plant are located on an impermeable concrete pad. It is proposed that the plant will remain in the current location but the storage area will be relocated to the west of the plant rather than to the south to synchronise better with the landfill phasing (Figure 3). The area of hardstanding will be extended up to a total area of approximately 2 hectares. The operational period of the soil treatment facility is restricted in the soil treatment planning consent to the same operational period as the landfill site which is to 31 August 2013. It is proposed that the operational period of the soil treatment facility is extended up to the end of December 2026.

4.10 The provisional proposal for the final landform is for a single mound falling slightly from east to west which flows round to the south to fill the western extension area as shown on Figure 4. The current approved restoration scheme is for the planting of native woodland along parts the northern, eastern and southern sides of the restored landform to integrate with the surrounding established woodland cover. It is currently proposed that the majority of the site will be returned to meadow grassland with a hedgerow at the site boundaries and running north to south in the centre of the site. Alternative options for the restoration and landscaping of the site will be reviewed as part of the consultation and design development process together with the outcomes of the landscape and visual impact assessments.

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5. Planning context

5.1 As part of the application for planning permission it is necessary to consider the planning context of the development comprising the current planning status of the site, land use planning polices relevant to the proposed development, national, regional and local policies for the disposal of hazardous waste, low level radioactive wastes and the treatment of soils, the need for the development and the alternatives to the development that have been considered.

5.2 An analysis of the relevant national, regional and local planning policies will be undertaken. The Development Plan for the site is presented in Table 1. Submitted documents which are part of the Northamptonshire Minerals and Waste Development Framework but are not currently part of the development plan will be analysed.

Table 1

The Development Plan

Plan Status

East Midlands Regional Plan Adopted March 2009

Northamptonshire County Council Minerals and Adopted June 2010 Waste Development Framework: Core Strategy

Northamptonshire Waste Local Plan Adopted March 2006

North Northamptonshire Core Spatial Strategy Adopted June 2008

East Northamptonshire District Local Plan Adopted November 1996

1 Policy for the Long Term Management of Solid Low Level Radioactive Waste in the United Kingdom (2007) Defra

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August 2010 and the UK Strategy for the Management of Solid Low Level Radioactive Waste from the Non-Nuclear Industry (consultation draft dated December 2010).

5.4 The need for the disposal of hazardous and low level radioactive wastes and the need for the treatment of hazardous waste will be considered. Data on the current and future arisings of hazardous waste for treatment and disposal and of LLW for disposal will be reviewed and presented. The suitability of the site will be assessed with reference to national and regional policy documents and to the Development Plan where appropriate.

Alternatives

5.5 The main alternatives considered in relation to the proposed development will be described in the Environmental Statement. The main alternatives considered will comprise the options for alternative management methods for hazardous waste and LLW, the disposal of hazardous waste and LLW at sites other than the East Northants RMF, the development by Augean PLC of sites other than East Northants RMF for the disposal and treatment of hazardous waste and LLW, the disposal of alternative waste types at the site, the options for a different extension area design and profile and the alternatives for the proposed timescales. A ‘Do Nothing’ or ‘No Project’ scenario will be determined against which the environmental effects can be assessed.

5.6 Planning policy will be analysed, need will be assessed and the alternatives will be evaluated. The environmental impacts of the development will be assessed and the analyses, evaluations and assessments will be drawn together to demonstrate the way in which the development complies with the relevant policies.

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6. Assessment of effects

6.1 Operations at the site including the hazardous waste landfill and landfill gas flaring and the soil treatment facility are the subject of three planning permissions and two Environmental Permits. As part of the applications for the current and previous planning permissions and Environmental Permits for the development at the site a number of studies were undertaken to establish the baseline environment at the site and to assess the impacts of the currently permitted development. The risks to the environment were assessed prior to the grant of planning permissions and the Environmental Permits. As evidenced by the grant of planning permissions and the Environmental Permits the impacts on the environment at that time were considered acceptable based on the control measures in place.

6.2 The baseline for the Environmental Impact Assessment is the currently permitted activities at the site. The baseline for the landscape and visual impact assessment will comprise a completed landfill profile which will be prepared based on current anticipated input rates up to mid 2013. The EIA for the proposed development will comprise an assessment of the additional impacts or those that may change due to the extension in time of the consented landfill, the extension of the void, the continued importation of hazardous waste and the importation of LLW for disposal, the extraction, stockpiling and exportation of clay and the extension of the life of the soil treatment facility. The cumulative impacts of all the relevant activities will be assessed. It is anticipated that the key issues which must be assessed in order to determine the environmental impacts of the proposal are the potential effects associated with impacts on people including health and socio-economic impacts, air quality, ecology, water resources, landscape and visibility, noise, transport and amenity.

6.3 As the proposed development area already is disturbed and all soils have already been stripped it is considered that there is no need to assess the impacts on soil quality and resources and on cultural heritage at the site. The impacts on the wider cultural heritage of the area will be assessed together with the impacts associated with the introduction of soils for use in the restoration of the site. The principles of the development together with the proposed method of developing, operating and managing the site will be described in the application document. The infrastructure

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of the proposed development together with the landscaping and restoration proposals will be presented. Wherever there is uncertainty over the detail of final designs in order to ensure that a robust environmental impact assessment is carried out reasonable worst case assumptions will be made regarding the potential environmental emissions and aspects of the proposed development. The information presented and assessed will be sufficient for development control purposes and for the assessment of environmental impact. Further detailed impact assessments will be carried out in accordance with the pollution control regime and submitted to the Environment Agency for approval as part of the application for the Environmental Permit for the extension to the site.

People

6.4 The potential impact of the proposed development on human health will be assessed. Assessments of the risks to the public and workers at the site will be undertaken. The assessment of the risks to human health as a result of the treatment and disposal of hazardous waste will be based on the identification of potential exposure pathways and an assessment of the mitigation measures proposed as an intrinsic part of the design and operation of the landfill site and treatment plant. The exposure pathways will include direct exposure to wastes, atmospheric exposure pathways such as gases and dust as well as aqueous exposure pathways such as surface water and groundwater.

6.5 An assessment of the potential impacts due to disposal by landfill of LLW will be carried out based on an appropriately adapted version of the SNIFFER methodology2 for assessing the suitability of the disposal of LLW in controlled landfills. The SNIFFER methodology is that specified by the Environment Agency for the assessment of the impact on people and the environment of LLW deposited in landfill sites and will form the main component of the application for an Environmental Permit for the disposal of LLW. As part of the application to the Environment Agency for an Environmental Permit an assessment of direct radiation dose to workers is carried out to determine the maximum dose rate at a number of distances from the waste. The assessment is based on the Microshield software

2 Development of a Framework for Assessing the Suitability of Controlled Landfills to Accept Disposals of Solid Low Level Radioactive Waste, 2006. SNIFFER (Scotland and Northern Ireland Forum For Environmental Research)

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package3. The results of the exposure assessments will be compared with statutory exposure limits and design criteria together with those presented in Environment Agency guidance.

6.6 The land uses surrounding the site will be determined including likely proposed development. The potential for direct and indirect impacts on surrounding land uses will be assessed together with the land use consequences of any identified impacts. The cumulative effect of waste disposal activities on the well-being of the local community including any significant adverse impacts on environmental quality, social cohesion and inclusion or economic potential will be assessed. Air quality

6.7 Gaseous and particulate emissions may be released from the deposited waste, from the treatment plant, from mobile plant and vehicles which may without mitigation have an impact on local air quality, contribute to the greenhouse effect or may have a potential impact on health. The emissions from the landfill and the treatment plant will continue to be controlled and monitored in accordance with an Environmental Permit. Locally available data supplemented by meteorological office data, if necessary comprising rainfall data together with data on wind speed and direction will be collated together with local air quality statistics. The information will provide the basis for assessment of effects on air quality. The potential impacts on air quality due to traffic movements will be assessed. The potential for the generation of landfill gas from the wastes deposited at the site and the potential emissions from the waste treatment plant will be assessed. Receptors sensitive to the potential migration of landfill gas, including adjoining agricultural land, will be identified from the baseline studies. Based on the geology and hydrogeology of the site and surrounding area together with the presence of services at and in the vicinity of the site, potential pathways for the lateral migration of landfill gas from the site will be identified. Based on the potential pathways available for gas migration, the proximity of receptors and the landfill management methods to be implemented at the site, the likely effect of landfill gas generation at the site and the risks associated with gas migration towards buildings and structures will be assessed together with potential effects on vegetation and wildlife. A qualitative assessment will be carried out of the potential impacts associated with the non radiological emissions to air as part of the proposed development. A radiological assessment of

3 Microshield v7.02, Grove Software Inc, 2007.

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the emissions to air from the release of gas from the waste will be undertaken using the SNIFFER methodology. Appropriate mitigation measures will be identified and incorporated into the proposal.

Ecology

6.8 In accordance with the Institute of Environmental Assessment guidance4, the site and immediately adjoining areas have been the subject of a Phase 1 Habitat Survey and search for protected species under the Wildlife and Countryside Act 1981. Particular consideration was given to species that are afforded special protection through the Wildlife and Countryside Act 1981 (as amended) and Protection of Badgers Act 1992, and under the Conservation (Natural Habitats, &c.) Regulations 1994 (Statutory Instrument No 2716). These species include badger, great crested newts, all bat and several bird species. Consideration was also given to the presence of Red Data Book species, priority Biodiversity Action Plan (BAP) species and birds of conservation importance/concern (as defined by the Joint Nature Conservation Committee building on the work of the RSPB et al). Great crested newts are present at the site and as part of the current site ecological management activities a licence for their translocation to a suitable area has been granted by Natural England. These works will have been completed by the time the application is submitted and will be summarised in the description of the ecological baseline for the site.

6.9 The results of ecological surveys of the site and surrounding area together with biological and geological records for the site and surrounding land held by national and local wildlife and conservation bodies will be analysed to establish the location of designated sites of nature conservation and geological conservation value at or in the vicinity of the site. The Phase 1 Habitat Survey and analysis of documentary sources including records of past site surveys will be used to define the current baseline ecological conditions at and in the immediate vicinity of the proposed development and to identify the need for any further ecological surveys. The local Biodiversity Action Plan will also be examined.

4 Institute of Environmental Assessment (1995): Guidelines for baseline ecological assessment. E & FN Spon.

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6.10 The importance of the biological populations and habitats recorded during the ecological surveys will be assessed. The ecological information collated will be used as appropriate in the design of the scheme and site landscaping with particular regard to opportunities to complement and enhance existing habitats in the locality. Based on the review of the existing information, surveys undertaken and the proposed design and operation of the site, the direct and indirect ecological effect of the proposals will be assessed. Particular attention will be paid to the likely effects on local and designated areas of nature conservation interest. Where likely significant effects are predicted the design and operation the proposal will be revised as appropriate to avoid or mitigate the impact.

6.11 An assessment of the radiological impact of the disposal of LLW at the site on a range of species will be carried out based on the tiered assessment in the ERICA methodology (Environmental Risk from Ionising Contaminants: Assessment and Management)5 specified by the Environment Agency.

Water resources

6.12 A study will be undertaken of the geology, hydrogeology and hydrology of the site and the surrounding land based on site investigations and published information and information obtained from the Environment Agency. Discussions will be continued with the Environment Agency to identify and resolve any concerns they may have regarding the site and the extent of works necessary to address these. Based on the information collated the baseline groundwater and surface water conditions will be established. A surface water and groundwater monitoring action plan is in place in accordance with the Environmental Permit. Based on the results of the study of the baseline geology, hydrogeology and hydrology including the results of site investigations and reviews of water quality data, an assessment will be made of the potential effect of the proposed development on groundwater and surface water resources. Separate hydrogeological risk assessments of the potential non-radiological and the radiological impacts will be prepared and submitted with the application to support the EIA.

5 https://wiki.ceh.ac.uk/display/rpemain/ERICA [Accessed 10 December 2010]

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6.13 Based on the site design and proposed operations an assessment of the potential for the discharge of contaminants from the site and the effect of the discharge of rainfall runoff from the site will be undertaken. Recommendations for management measures to ameliorate any significant effects on groundwater or surface water will be provided as necessary and incorporated within the design.

Flood risk assessment

6.14 The location of the site in an area of low flood risk will be confirmed. The potential effect of the proposal on flood flows resulting from surface water runoff during storm events and the associated flood risk in nearby watercourses will be considered. Allowance will be made for the potential effect of climate change on the intensity of storm events.

Landscape and visibility

6.15 A landscape and visual impact assessment will be conducted for the proposed development in accordance with the ‘Guidelines on the Landscape and Visual Impact Assessment’ Second Edition produced by the Landscape Institute and the Institute of Environmental Management and Assessment, 2002 and best practice and professional experience. The study area for the project will be based on a circle with a maximum radius of 6 km which will be centred on the current site boundary. This distance is based on the usual extent of potentially significant visual effects. A full landscape and visual description of the existing baseline landscape resource will be prepared with reference to site surveys, relevant technical literature, maps and plans of the proposed development. The potential landscape and visual effects to be considered will include landscape effects comprising change in the elements, characteristics, character and qualities of the landscape as a result of the development as well as visual effects comprising change in the character of available views and changes on the amenity of the viewers as a result of the development. The assessment will also consider any cumulative effects.

6.16 Effects on the landscape include potential direct and indirect effect on landscape receptors, such as landscape elements and features, as well as the effects upon the general landscape character and its quality, condition and value. In assessing the landscape effects, consideration will also be given to the capacity of the

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landscape to absorb change. This may be considered with reference to existing landscape and visual characteristics, including the presence of existing development, the scale of the landscape, topography and the presence of screening elements such as tall vegetation and built form.

6.17 Consideration will also be given to the nearby presence of other local landscape and visual receptors and other relevant factors including areas of particular landscape character including existing footpaths, cycleways and local roads; historic and designed landscapes or tourist destinations together with features of local interest; landscape planning policies; the presence of other existing infrastructure; settlements within the study area; and existing land use and management constraints.

6.18 The visual assessment will be based on a Zone of Visual Influence (ZVI) that will be centred on the highest element of the proposed development. The ZVI enables the maximum extent of the visual envelope of the site to be determined and then subsequent adjustment is made to take account of existing vegetation that would provide visual screening. Visual receptors are then comprehensively recorded and categorised according to their visual sensitivity.

6.19 Consideration will be given to the number of viewpoints needed for the assessment. The assessment will consist mainly of a viewpoint analysis of the proposals which will include the predicted effects from the construction of the landfill, the subsequent operational period and the restored landform following the incorporation of the proposed landscape mitigation measures and restoration design. The assessment will include consideration of any lighting of the site that is necessary during hours of darkness.

Noise

6.20 Unless mitigation measures are implemented noise from operations at the site may have the potential to affect the quality of life of nearby residents, workers and wildlife. Noise may be generated by plant and vehicles, the extraction of clay, the construction of engineered cells, the placement of waste and the operation of the treatment plant and infrastructure.

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6.21 A noise monitoring scheme is in place at the site currently in accordance with the planning permission. It is proposed that additional background noise monitoring will be undertaken at up to five representative locations in the vicinity of the site (Figure 5). The locations will be agreed with the local Environmental Health Officer. The background noise levels will be used to provide a baseline against which will be evaluated the effect of noise generated by the site operations including noise from traffic. The baseline data will allow appropriate operational noise limits for the site to be determined based on Planning Policy Guidance Note 24 Planning and Noise (1994). Noise predictions for both the construction and operational phases of the proposed development will be undertaken in accordance with current Government guidance (Minerals Planning Statement 2, British Standard BS5228 Noise and Vibration on Construction and Open Sites and BS4142 Rating Industrial Noise Affecting Mixed Residential and Industrial Areas). These will be based on the predicted plant complement, together with the proposed hours of working and the mitigation measures incorporated into the proposal. The assessment of noise will include potential effects upon wildlife including from white noise.

Traffic and transport

6.22 Traffic travelling to and from the site has the potential to have an impact on the local environment through noise, air quality, safety or congestion. A transport assessment will be undertaken. It is proposed that a meeting is held with the Highway Authority to agree the detailed scope of the transport assessment. Upon agreement of the scope, traffic data for the agreed area of study will be collated and the traffic generation and routing will be assessed. The assessment will be carried out in accordance with the Institute of Environmental Assessment “Guidelines for the Environmental Assessment of Road Traffic”.

6.23 Information will be presented on the traffic movements and routing to and from the site in respect of the current and future operations at the site and including any known changes in traffic movements that will occur such as those associated with proposed developments in the vicinity. Available traffic flow data and accident data obtained from the Highway Authority will be presented. Based on the information collected and site observations the effects will be assessed. The effect of noise generated by traffic will be included in the noise assessment. Subject to discussion

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with the Highways Authority it is anticipated that the main focus of the assessment will be Stamford Road. The effects of traffic upon air quality will be assessed.

6.24 The assessment will consider the achievement of safe and convenient access by site workers and visitors by all modes of transport and opportunities for minimising the number and impact of motorised journeys.

Amenity

6.25 Odour can arise from waste management operations accepting biodegradable waste or wastes with inherent chemical odours. Hazardous waste and LLW contain minimal quantities of biodegradable waste. The environmental impacts with respect to the potential for odour emissions as a result of the chemical nature of some wastes will be assessed taking into account the odour management controls which will be incorporated in the design and management of the landfill and treatment facility.

6.26 Hazardous waste and LLW which contain minimal quantities of putrescible material are unlikely to attract vermin such as foxes, rats, flies and birds. It is unlikely that vermin will infest sites operated in accordance with good landfill practice as habitats suitable for the breeding of vermin are minimised. The current and proposed methods of operational control including the method of containing the waste and covering of waste will reduce the attractiveness of the site to vermin. An assessment will be carried out of the potential environmental impacts associated with vermin. An assessment will be carried out of the potential for intrusion into the site by animals and the effects of transmission of landfilled materials through intrusion.

6.27 Dust emissions if not managed can have an environmental impact and affect nearby agriculture and the quality of life of local communities. Dust emissions may be generated by soil and overburden handling, clay extraction, cell construction, waste handling, particulate emissions, vehicle movements, capping of cells and the placement of restoration materials. A qualitative assessment of the impact of dust will be undertaken in accordance with guidance in Mineral Policy Statement 26 and

6 Minerals Policy Statement 2 - Controlling and mitigating the environmental effects of mineral extraction in England.

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published by the Department of the Environment7. A dust management and monitoring plan is currently in use at the site in accordance with the current planning permission and Environmental Permit. A quantitative radiological assessment will be carried out of the potential for the migration and impact of particulates as a result of the acceptance and disposal of LLW at the site.

6.28 An assessment of the likely effects of litter will be carried out based on a qualitative assessment including professional and operational experience of nuisance issues. The nature of the waste imported and the methods of containment mean it is unlikely that significant quantities of litter will be generated.

7 Department of the Environment. 1995. The environmental effects of dust from surface mineral workings.

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7. The structure of the planning application and Environmental Statement

7.1 The application for planning permission and the Environmental Statement will comprise several volumes. The proposed structure of the application and Environmental Statement is presented at Appendix B.

7.2 Volume 1 will comprise the planning application which will consist of the planning application forms, the description of the proposed development, a review and analysis of the relevant planning polices, an assessment of need for the proposed development, the Design and Access Statement and the Statement of Community Consultation. Volume 2 will comprise the Environmental Statement which will be sub-divided into three parts. Part 1 will include a Non Technical Summary, a description of the site, the approach to the EIA, screening and scoping and a description of the population and public rights of way at and surrounding the site. The Non Technical Summary will also be made available as a separate document. Part 2 will comprise a description of the proposed development, the proposed method of operating and managing the site and the alternatives considered. Sufficient detail will be provided for development control and to facilitate the assessment of impacts. Part 3 will comprise the assessment of environmental impacts associated with the proposed development. The text will be supported by figures. Detailed technical reports will be appended to the Environmental Statement. Supporting documents will be submitted as necessary.

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FIGURES

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0m 500 1000 1500 2000 2500m

Key / Notes

Proposed application boundary

Final KR MM LH 15/02/11

Rev Status Drn App Chk Date

Site EAST NORTHANTS RESOURCE MANAGEMENT FACILITY

Client

AugeanPLC specialists in waste management Title The site location

Scale Figure 1 1:50,000@A4 Drawing Ref AU/KCE/02-11/15951 Baddesley Colliery Offices, Reproduced scale mapping by permission of Ordnance Main Road, Baxterley, Atherstone, Warwickshire, CV9 2LE. Survey R on behalf of The Controller of Her Majesty's Telephone : 01827 717891 Stationery Office. C Crown copyright 2006. All rights reserved. Technical advisers on environmental issues Fax : 01827 718507 Licence number 100017818.

WS010001/ENRMF/CONSAPPCRF 209 Key / Notes

Boundary of the East Northants 300400 Resource Management Facility (planning permission reference Collyweston Great Wood EN/05/1264C)

Track Track Proposed planning application N boundary

Approximate location of the 300300 Track currently consented landfill cell

Track Pond boundaries Ward Bdy Drain Und

Ward Bdy SD 76.2m Boundary of the soil treatment facility (planning permission Surface water references 07/00048/WAS and management lagoon 07/01838/NCC)

300200 Boundary of the area the subject of the planning application for the disposal of LLW

Current haul roads Soil treatment area concrete pad 79.6m Woodland Landfill Phases 1, 2 and 3 300100 Water areas Westhay Cottages

BM 83.97m

1 Existing gas flare compound

2 3

84.4m

300000 Cell 4A

Reservoir Cell 5A (covered)

Site entrance

83.8m

Cell 5B Weighbridge 299900 Cell 4B

Offices Final KR MM LH 15/02/11 Generator Site offices Canteen Rev Status Drn App Chk Date Welfare Site EAST NORTHANTS RESOURCE MANAGEMENT Quarantine FACILITY area Client

299800 AugeanPLC specialists in waste management Pond Title Wheelwash Steel The current site layout and application Haul road containers Laboratory and boundary storage shed Scale Figure 2 1:3,000@A3 Drawing Ref AU/KCE/02-11/15952 Reproduced scale mapping by permission of Ordnance 299700 Survey R on behalf of The Controller of Her Majesty's 0m 30 60 90 120 150m Stationery Office. C Crown copyright 2006. All rights reserved. Licence number 100017818.

500500

500600

500700

500800

500900

501000

501100

501200 501300 Baddesley Colliery Offices, Main Road, Baxterley, Atherstone, Warwickshire, CV9 2LE. Telephone : 01827 717891 Technical advisers on environmental issues Fax : 01827 718507

WS010001/ENRMF/CONSAPPCRF 210 Key / Notes

Proposed planning application boundary Track Track Approximate limit of working of the western extension

Approximate phase boundaries N for the current permitted landfill 300300 Track Soil treatment plant storage Track Pond Ward Bdy Drain Und area

76.2m Ward Bdy SD Existing building

New building or structure

Approximate route of haul roads

Surfaced section of internal haul road 300200 Approximate location of permanent newt fencing

Water areas

Soil treatment area Proposed water areas concrete pad 79.6m Approximate area of existing hardstanding

300100 Phase 1 Proposed extension to area of Phase 2 hardstanding

BM 83.97m Existing bund

1 2

3 Proposed bund

84.4m Woodland

300000

Reservoir Existing gas flare compound (covered) Phase 3

Phase 5 Phase 4 Screening bund

83.8m Visitors' car park

299900 Offices Generator Note: Site offices Drawing based on survey reference Mess facilities 44475-01-10-009K.LSS Store Laboratory and storage shed

299800 Pond Final KR MM LH 15/02/11

Wheelwash Relocated App Extended pond to Drum bay and Rev Status Drn Chk Date quarantine area weighbridge Discharge/monitoring provide storage pond Site Relocated EAST NORTHANTS RESOURCE MANAGEMENT cabin FACILITY Client

AugeanPLC specialists in waste management 299700 Title Proposed western extension

500500

500600

500700

500800

500900

501000

501100

501200 501300 Scale Figure 3 1:3,000@A3 0m 30 60 90 120 150m Drawing Ref AU/KCE/02-11/15950

Baddesley Colliery Offices, Main Road, Baxterley, Atherstone, Warwickshire, CV9 2LE. Telephone : 01827 717891 Technical advisers on environmental issues Fax : 01827 718507

WS010001/ENRMF/CONSAPPCRF 211 Key / Notes

Proposed planning application boundary Track Track

90 Contours (mAOD) N Track Existing woodland 300300

Track Pond Ward Bdy Drain Und

Ward Bdy Existing agriculture SD 76.2m

Existing hedgerow

Existing storage area 80.0 80.0

300200 80.0 80.0

80.0 80.0

80.0 80.0 82.0

80.0

78.0 Existing gas flare compound

78.0 82.0

80.0 82.0

84.0

82.0

84.0

84.0 78.0 82.0 80.0

86.0 82.0

82.0 84.0

78.0

82.0

84.0

80.0 78.0 86.0

84.0

86.0

84.0 82.0

86.0

88.0 88.0

78.0 84.0

80.0 82.0 86.0

88.0 78.0

86.0 Proposed hedgerow

82.0

84.0 78.0 78.0 88.0 80.0 82.0 90.0

86.0

90.0 88.0

86.0 90.0

84.0

88.0 79.6m 90.0 88.0 86.0

90.0 86.0

92.0

92.0 Proposed meadow grassland

92.0 88.0

84.0

92.0

86.0

88.0

300100 88.0 90.0

90.0 Proposed woodland 82.0 92.0

86.0 92.0

90.0 92.0 BM 83.97m

92.0 Surface water ponds 1

88.0

92.0 84.0

86.0

88.0 90.0 84.4m

90.0 92.0

90.0 90.0 300000 92.0 90.0 90.0

90.0 Reservoir (covered) 88.0 90.0

88.0

86.0

90.0 88.0 90.0 88.0 90.0 88.0 88.0 83.8m

88.0 84.0 88.0 86.0 88.0 88.0 86.0 86.0 299900 88.0 88.0 86.0

88.0 86.0

86.0

86.0 84.0 84.0 84.0 86.0 84.0 84.0 Final KR MM LH 15/02/11 82.0 86.0 80.0

86.0 86.0 84.0 Rev Status Drn App Chk Date 80.0 82.0 82.0 86.0 82.0 86.0 84.0 Site 299800 86.0 EAST NORTHANTS RESOURCE 86.0 86.0 82.0Pond 82.0 MANAGEMENT FACILITY 80.0 84.0 82.0 84.0

84.0 82.0 84.0 Client 82.0 82.0 82.0

86.0 80.0 80.0 86.0

AugeanPLC specialists in waste management 80.0

86.0 Title

82.0 80.0

84.0 Schematic preliminary restoration plan 80.0 80.0

78.0

80.0 Scale 80.0 80.0 Figure 4 299700 86.0 1:3,000@A3 78.0 Drawing Ref AU/KCE/02-11/15953 86.0 78.0 84.0

82.0 80.0 80.0 Reproduced scale mapping by permission of Ordnance

78.0 80.0

76.0

500500

500600

500700

500800

500900

501000

501100 78.0 Baddesley Colliery Offices, 84.0 80.0 76.0 Main Road, Baxterley, Atherstone, 78.0 78.0 Warwickshire, CV9 2LE. Telephone : 01827 717891 Technical advisers on environmental issues Fax : 01827 718507

WS010001/ENRMF/CONSAPPCRF 212 Key / Notes

Proposed planning application boundary

Cuckoo Lodge Approximate location of a N proposed noise monitoring point

Property at the south east of Duddington

Westhay Cottages

Westhay Farm

Final KR MM LH 15/02/11

Rev Status Drn App Chk Date

Site EAST NORTHANTS RESOURCE MANAGEMENT FACILITY Westhay Lodge Client

AugeanPLC specialists in waste management Title The proposed noise monitoring locations

Scale Figure 5 1:25,000@A4 Drawing Ref AU/KCE/02-11/15954 Reproduced scale mapping by permission of Ordnance Survey R on behalf of The Controller of Her Majesty's Stationery Office. C Crown copyright 2006. All rights reserved. Licence number 100017818. 0m 250 500 750 1000 1250m Baddesley Colliery Offices, Main Road, Baxterley, Atherstone, Warwickshire, CV9 2LE. Telephone : 01827 717891 Technical advisers on environmental issues Fax : 01827 718507

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APPENDICES

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APPENDIX A

LIST OF CONSULTEES

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LIST OF CONSULTEES

List 1: Statutory consultees – Organisations

The Health and Safety Executive The Environment Agency The relevant Strategic Health Authority The Commission for Architecture and the Built Northamptonshire Teaching Primary Environment Care Trust Natural England The Equality and Human Rights Commission The Historic Buildings and Monuments The Commission for Sustainable Commission for England Development The relevant fire and rescue authority The Commission for Rural Communities Northamptonshire Fire and Rescue Service The relevant police authority The Highways Agency Northamptonshire Police Authority The relevant parish council, or, where the The relevant Highways Authority application relates to land Wales or Scotland the relevant community council King’s Cliffe Parish Council The relevant local resilience forum The relevant waste regulation authority Northamptonshire Local Resilience Northamptonshire County Council Forum The Forestry Commission The Health Protection Agency

List 2: Statutory consultees – County, Unitary and District Councils

Counties/Unitaries Districts/Boroughs Northamptonshire County Council East Northamptonshire District Council Peterborough City Council Corby District Council Rutland Unitary Authority Huntingdonshire District Council Cambridgeshire County Council South Kesteven District Council Lincolnshire County Council Kettering District Council Leicestershire County Council Wellingborough District Council Warwickshire County Council Oxfordshire County Council Buckinghamshire County Council Milton Keynes Unitary Authority Bedford Unitary Authority

List 3: Other relevant stakeholders

King’s Cliffe Local Liaison Group Wakerley Parish Council Apethorpe Parish Council Woodnewton Parish Council Barrowden Parish Council Yarwell Parish Council Collyweston Parish Council Waste Watchers Duddington with Finshade Parish Council Transition King’s Cliffe Easton on the Hill Parish Council Howard Farms Nassington Parish Council PC Howard Ltd Thornhaugh Parish Council RAF Wittering Tixover Parish Council Northamptonshire Wildlife Trust Wansford Parish Council

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APPENDIX B

PROPOSED STRUCTURE OF THE PLANNING APPLICATION AND ENVIRONMENTAL STATEMENT

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APPENDIX B

Provisional contents list for the planning application

and Environmental Statement

VOLUME 1 APPLICATION FOR PLANNING PERMISSION

Application forms

Description of the proposed development

Planning history

Planning context

Need for the development

Design and Access Statement

Statement of Community Consultation

VOLUME 2 ENVIRONMENTAL STATEMENT

Non-Technical Summary

Part 1

1. Introduction

2. Approach to the Environmental Impact Assessment

3. Screening and Scoping

4. Site location and description

5. Properties and population including public rights of way

6. Geology, hydrogeology and hydrology

7. Meteorology

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Part 2

8. Principles of the development

9. Current operations at the site

10. Site infrastructure

11. Proposed site operations

12. Sequence of working

13. Restoration

14. Alternatives

Part 3 – ASSESSMENT OF EFFECTS

15. Introduction of the assessment of environmental effects

16. Population

17. Air quality

18. Ecology

19. Water resources

20. Landscape and visibility

21. Noise

22. Cultural heritage

23. Transport

24. Amenity

25. Cumulative effects

26. Conclusions

Figures and Appendices

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PROPOSALS FOR THE SCOPE AND CONTENT OF THREE SECTION 73 APPLICATIONS TO VARY PLANNING PERMISSION CONDITIONS AND AN ENVIRONMENTAL IMPACT ASSESSMENT FOR AN EXTENSION IN TIME FOR THE LANDFILL DISPOSAL OF HAZARDOUS WASTE AND POTENTIALLY LOW LEVEL RADIOACTIVE WASTE, AN EXTENSION IN TIME FOR THE OPERATION OF THE SOIL TREATMENT FACILITY AND OTHER ASSOCIATED DEVELOPMENT AT THE EAST NORTHANTS RESOURCE MANAGEMENT FACILITY, STAMFORD ROAD, NORTHAMPTONSHIRE

Report reference: AU/KCE/MM/1583/01S73scoping February 2011

Baddesley Colliery Offices, Main Road, Baxterley, Atherstone, Warwickshire, CV9 2LE Tel. (01827) 717891 Fax. (01827) 718507

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CONTENTS

1. Executive summary

2. Introduction

3. The site

4. The proposed development

5. Planning context

6. Assessment of effects

7. The structure of the planning application and Environmental Statement

TABLES

Table 1 The Development Plan

FIGURES

Figure 1 The location of the East Northants Resource Management Facility (drawing reference AU/KCE/02-11/15959)

Figure 2 The current site layout (drawing reference AU/KCE/02- 11/15960)

Figure 3 The currently permitted restoration plan (Scott Wilson drawing number D107125_LV_001 E)

APPENDICES

Appendix A List of consultees

Appendix B Proposed structure of the Section 73 Applications and Environmental Statement

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1. Executive summary

1.1 Augean PLC is the operator of the East Northants Resource Management Facility and is planning to submit three applications to vary planning permission conditions to extend the life of the landfill site for the disposal of hazardous waste and potentially Low Level Radioactive Waste and to extend the life of the soil treatment facility. The applications will be accompanied by an Environmental Impact Assessment. In this document the elements of the proposed variations to the three planning permissions are set out in general terms together with the scope of the environmental impact assessments which it is anticipated will be carried out. The opinions of Northamptonshire County Council and their consultees are sought on the proposed scope of the assessments that will be included in the Environmental Impact Assessment.

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2. Introduction

2.2 In July 2009 a planning application was submitted to Northamptonshire County Council for the landfill disposal of low level radioactive waste (LLW) in cells 4B, 5A and 5B at East Northants RMF in addition to the consented hazardous waste. The application was refused in March 2010. Augean PLC has appealed against the decision and a Public Inquiry into the decision was held in October and November 2010. A decision on the appeal is expected to be made on or before 24 May 2011. It is anticipated that if the decision is made to grant permission for the disposal of LLW the permission will specify that the disposal shall cease not later than 31 August 2013.

2.3 The remaining void space in the landfill at the beginning of 2010 was approximately 560,000m3. It is now extremely unlikely given the current market conditions that the landfill will be completed by 2013. It is estimated that in the current market the probable rate for the deposition of waste is between 100,000 tonnes and 120,000 tonnes per annum which would mean that the site could be completed to the current permitted levels between mid 2015 and mid 2016.

2.4 Applications will be made in accordance with Section 73 of the Town and Country Planning Act 1990 (as amended) not to comply with certain conditions of the planning permissions. Three Section 73 applications will be made comprising variations to two extant planning permissions and a variation of the permission for

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the deposition of LLW in Cells 4B, 5A and 5B should the permission be granted by the Secretary of State. The proposals will seek to:

1. Extend the lifetime of the hazardous waste landfill operations

2. Extend the lifetime of the soil treatment facility which is tied in to the landfill operations

3. Extend the lifetime of the potential LLW landfill operations

2.5 It is considered that the proposals to extend the lifetime of the site activities comprise development which should be subject to an environmental impact assessment under The Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 as amended. In accordance with the regulations an Environmental Impact Assessment will be undertaken and the report of the impact assessment, which will comprise an Environmental Statement, will be submitted with the three Section 73 applications.

2.6 MJCA are commissioned by Augean PLC to undertake the Environmental Impact Assessment. In this report the approach to the applications and the proposed scope of the Environmental Impact Assessment (EIA) are explained. The purpose of this report is to set out in general terms the elements of the proposed development and to explain the scope of the assessments which will be carried out as part of the EIA of the proposed development. The opinions of Northamptonshire County Council (NCC) and their consultees are sought on the proposed scope of the assessments that will be included in the EIA. This document has been prepared based on discussions with Augean PLC, Northamptonshire County Council, the Environment Agency and based on the experience of MJCA.

2.7 This report together with a request for a scoping opinion will be submitted to NCC. The scoping report will be circulated by NCC to the statutory consultees together with a wider range of consultees (Appendix A) for their comments and the comments of the consultees will be incorporated in the formal scoping opinion issued by NCC.

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3. The site

3.2 The site comprises an active hazardous waste landfill including restored and partially restored landfill areas together with a soil treatment facility. The soil treatment facility for hazardous wastes currently is located in the north west of the site with the storage area orientated in a north-south direction. The facility includes consent for a soil washing plant, an immobilisation unit, a laboratory/office and an area for bioremediation. The plant are located on an impermeable concrete pad. A gas management and surface water management compound including a flare stack are located in the north western corner of the site. Site infrastructure including the site access, waste reception facilities, car parking areas, site offices, welfare facilities, storage areas, laboratories and wheel and vehicle body washing facilities are in place at the site (Figure 2).

3.5 To the east of the site and Stamford Road are Westhay Cottages and Westhay Farm which is operated as a haulage yard and a farm with associated agricultural

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and commercial buildings. To the south of the site are farm buildings and open agricultural land. To the west of the landfill area there is open agricultural land and North Spinney Wood. The boundary of the operational training airfield at RAF Wittering is located approximately 800m to the north east of the East Northants RMF site.

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4. The proposed development

4.1 As explained in section 2 the remaining void at the site as at the beginning of 2010 was approximately 560,000m3. Based on anticipated waste input rates of 120,000tpa the remaining void will not be filled until between mid 2015 and mid 2016 hence an extension of time for the completion of the site to the consented restoration profile of approximately 3 years beyond the currently permitted end date of August 2013 to the end of December 2016 is necessary.

4.2 The soil treatment facility is tied to the life of the current consented landfill. Contaminated residue produced from the treatment process is disposed of at the landfill.

4.3 In accordance with Section 73 of The Town and Country Planning Act 1990 (as amended) it is proposed to apply to vary the relevant conditions of the two current planning permissions and the planning application for the disposal of LLW if a decision is made to grant the permission.

4.4 It is proposed to vary conditions 32 and 33 of planning permission reference EN/05/1264C for the hazardous waste landfill and associated operations to allow the current hazardous waste landfill operations to continue to December 2016.

4.5 It is proposed to vary condition 22 of planning permission reference 07/00048/WAS and 07/01838/NCC for the soil treatment facility to allow current operations to continue to December 2016.

4.6 Should appeal reference APP/K2800/A/10/2126938/NWF for the refusal of planning application reference 09/0053/WAS be allowed by the Secretary of State it is proposed to vary the relevant condition(s) to extend the period for the landfill of LLW to December 2016.

4.7 As part of the applications to vary the conditions there will be no change to the currently permitted total waste importation rate to the site of 249,999 tonnes per annum or the currently permitted total amount of waste materials imported to the soil treatment facility of 100,000tpa. There will be no change to the permitted vehicle movements associated with the site.

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4.8 As part of the applications to vary the conditions there will be no changes to the permitted site operations and activities other than to extend the time period over which they will be carried out and there will be no change to the currently permitted restoration and aftercare scheme for the site (Figure 3).

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5. Planning context

5.1 As part of the variation applications it is necessary to consider the planning context of the development comprising the current planning status of the site, land use planning polices relevant to the proposed development, national, regional and local policies for the disposal of hazardous waste, low level radioactive wastes and the treatment of soils, the need for the development and the alternatives to the development that have been considered.

Table 1

The Development Plan

Plan Status

East Midlands Regional Plan Adopted March 2009

Northamptonshire County Council Minerals and Adopted June 2010 Waste Development Framework: Core Strategy

Northamptonshire Waste Local Plan Adopted March 2006

North Northamptonshire Core Spatial Strategy Adopted June 2008

East Northamptonshire District Local Plan Adopted November 1996

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5.3 The policy for the long term management of LLW is set out in the Defra document published in March 20071 and the strategies for the management of LLW from the nuclear and the non-nuclear industries are set out in the UK Strategy for the Management of Solid Low Level Radioactive Waste from the Nuclear Industry dated August 2010 and the UK Strategy for the Management of Solid Low Level Radioactive Waste from the Non-Nuclear Industry (consultation draft dated December 2010).

5.4 The need for the disposal of hazardous and low level radioactive wastes and the need for the treatment of hazardous waste will be considered. Data on the current and future arisings of hazardous waste for treatment and disposal and of LLW for disposal will be reviewed and presented. The suitability of the site with reference to national and regional policy documents and to the Development Plan has already been confirmed by the grant of the extant planning consents.

Alternatives

5.5 The main alternatives considered in relation to the proposed development will be described in the Environmental Statement. A ‘Do Nothing’ or ‘No Project’ scenario will be determined against which the environmental effects can be assessed.

1 Policy for the Long Term Management of Solid Low Level Radioactive Waste in the United Kingdom (2007) Defra

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6. Assessment of effects

6.2 As the proposed development area already is disturbed and all soils have already been stripped it is considered that there is no need to assess the impacts on soil quality and resources and on cultural heritage at the site.

6.3 The footprint of the site and planning permission boundaries will not change as a result of the variation applications. As the currently permitted waste types and the waste importation rate to the site will not change, the currently permitted total amount and nature of waste materials imported to the soil treatment facility will not change and the operational methods implemented at the site will not change as a result of the variation applications it is considered that it will not be necessary to assess the potential impact associated with air quality.

6.4 The baseline for the Environmental Impact Assessment is the currently permitted activities at the site. The EIA for the proposed development will comprise an assessment of the additional impacts or those that may change due to the proposed extension in time for the operation of the consented landfill, the continued importation of hazardous waste and the potential importation of LLW for disposal, the extraction, stockpiling and exportation of clay and the extension of the life of the soil treatment facility. The cumulative impacts of all the relevant activities will be assessed. It is anticipated that the key issues which must be assessed in order to determine the environmental impacts of the proposal are the potential effects associated with impacts on people including health and socio-economic impacts, ecology, water resources, amenity, landscape and visibility, traffic and noise.

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People

6.5 The potential impact of the proposed extension in time of the site activities on human health will be assessed. Any changes to the risks to the public and workers at the site as a result of the proposed extension in time will be determined. The assessment of the risks to human health as a result of the treatment and disposal of hazardous waste will be based on the identification of potential exposure pathways and an assessment of the mitigation measures proposed as an intrinsic part of the design and operation of the landfill site and treatment plant. The exposure pathways will include direct exposure to wastes, atmospheric exposure pathways such as gases and dust as well as aqueous exposure pathways such as surface water and groundwater.

6.6 An assessment of the potential impacts due to disposal by landfill of LLW as a result of the proposed extension in time will be carried out based on the risk assessments carried out as part of the application for planning consent. As part of the application to the Environment Agency for an Environmental Permit an assessment of direct radiation dose to workers has been carried out to determine the maximum dose rate at a number of distances from the waste. Any changes to the results of the exposure assessments as a result of the proposal to extend the operational life of the site will be compared with statutory exposure limits and design criteria together with those presented in Environment Agency guidance.

6.7 The potential for direct and indirect impacts on surrounding land uses as a result of the proposed extension in time of the site activities will be assessed together with the land use consequences of any identified impacts. The cumulative effect of the extended timescale of the waste disposal activities on the well-being of the local community including any significant adverse impacts on environmental quality, social cohesion and inclusion or economic potential will be assessed.

Ecology

6.8 In accordance with the Institute of Environmental Assessment guidance2 the site and immediately adjoining areas have been the subject of a Phase 1 Habitat Survey and search for protected species under the Wildlife and Countryside Act 1981.

2 Institute of Environmental Assessment (1995): Guidelines for baseline ecological assessment. E & FN Spon.

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Particular consideration was given to species that are afforded special protection through the Wildlife and Countryside Act 1981 (as amended) and Protection of Badgers Act 1992, and under the Conservation (Natural Habitats, &c.) Regulations 1994 (Statutory Instrument No 2716). These species include badger, great crested newts, all bat and several bird species. Consideration was also given to the presence of Red Data Book species, priority Biodiversity Action Plan (BAP) species and birds of conservation importance/concern (as defined by the Joint Nature Conservation Committee building on the work of the RSPB et al). Great crested newts are present at the site and as part of the current site ecological management activities a licence for their translocation to a suitable area has been granted by Natural England. These works will have been completed by the time the application is submitted and will be summarised in the description of the ecological baseline for the site.

6.9 The results of ecological surveys of the site and surrounding area together with biological and geological records for the site and surrounding land held by national and local wildlife and conservation bodies will be analysed to establish the location of designated sites of nature conservation and geological conservation value at or in the vicinity of the site. The Phase 1 Habitat Survey and analysis of documentary sources including records of past site surveys will be used to define the current baseline ecological conditions at and in the immediate vicinity of the waste management activities and to identify the need for any further ecological surveys. The local Biodiversity Action Plan will also be examined.

6.10 The importance of the biological populations and habitats recorded during the ecological surveys will be assessed. Based on the review of the existing information, surveys undertaken and the proposed extension in time at the site, the direct and indirect ecological effect of the proposals will be assessed. Particular attention will be paid to the likely effects on local and designated areas of nature conservation interest. If likely significant effects are predicted the method of operations will be revised as appropriate to avoid or mitigate the impact.

6.11 As part of the current planning application and Environmental Permit application an assessment of the radiological impact of the disposal of LLW at the site on a range of species has been carried out based on the tiered assessment in the ERICA

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methodology (Environmental Risk from Ionising Contaminants: Assessment and Management)3 specified by the Environment Agency. Any changes to the results of the assessment as a result of the proposal to extend the operational life of the site will be assessed.

Water resources

6.12 The understanding of the geology, hydrogeology and hydrology of the site and the surrounding land based on site investigations and published information and information obtained from the Environment Agency will be confirmed. Discussions will be continued with the Environment Agency to identify and resolve any concerns they may have regarding the proposal to extend the time for the operation of the site. Based on the information collated the baseline groundwater and surface water conditions will be reviewed. A surface water and groundwater monitoring action plan is in place in accordance with the Environmental Permit. Based on the results of the study of the baseline geology, hydrogeology and hydrology including the results of site investigations and reviews of water quality data, an assessment will be made of the potential effect of the proposed extension in the operational life of the site activities on groundwater and surface water resources.

6.13 Based on the site design and proposed extension in time of site operations an assessment of any changes to the potential for the discharge of contaminants from the site and the effect on any discharges of rainfall runoff from the site will be undertaken. Recommendations for further or amended management measures to ameliorate any significant effects on groundwater or surface water will be provided as necessary and incorporated in the site operations.

Flood risk assessment

6.14 The location of the site in an area of low flood risk will be confirmed. The potential effect of the proposed extension in the operational period for the site activities on flood flows resulting from surface water runoff during storm events and the associated flood risk in nearby watercourses will be determined. Allowance will be made for the potential effect of climate change on the intensity of storm events.

3 https://wiki.ceh.ac.uk/display/rpemain/ERICA [Accessed 10 December 2010]

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Amenity

6.15 Odour can arise from waste management operations accepting biodegradable waste or wastes with inherent chemical odours. Hazardous waste and LLW contain minimal quantities of biodegradable waste. The environmental impacts associated with the proposed extension in time with respect to the potential for odour emissions as a result of the chemical nature of some wastes will be assessed taking into account the odour management controls which are incorporated in the design and management of the landfill and treatment facility.

6.16 Hazardous waste and LLW which contain minimal quantities of putrescible material are unlikely to attract vermin such as foxes, rats, flies and birds. It is unlikely that vermin will infest sites operated in accordance with good landfill practice as habitats suitable for the breeding of vermin are minimised. The current and proposed methods of operational control including the method of containing the waste and covering of waste will reduce the attractiveness of the site to vermin. An assessment will be carried out of the potential environmental impacts associated with vermin as a result of the proposals for a time extension.

6.17 Dust emissions if not managed can have an environmental impact and affect nearby agriculture and the quality of life of local communities. Dust emissions may be generated by soil and overburden handling, clay extraction, cell construction, waste handling, particulate emissions, vehicle movements, capping of cells and the placement of restoration materials. A qualitative assessment of the impact of dust was undertaken as part of the planning permission and Environmental Permit applications for the consented activities. A dust management and monitoring plan is currently in use at the site in accordance with the current planning permission and Environmental Permit. A quantitative radiological assessment was carried out of the potential for the migration and impact of particulates as a result of the acceptance and disposal of LLW at the site. Any changes to the results of the assessments as a result of the proposal to extend the operational life of the site will be assessed.

6.18 An assessment of the likely generation of and effects of litter as a result of the proposed extension in the life of the site will be carried out. The nature of the waste

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imported and the methods of containment mean it is unlikely that significant quantities of litter will be generated.

Landscape and visibility

6.19 The currently consented restoration landform will not change. Potential impacts associated with the restoration landform have been assessed previously and approved as acceptable. An assessment of the ‘do nothing’ scenario will be carried out which will assess the landscape and visual impacts associated with the anticipated landform profile at August 2013 based on current waste input rates compared with the consented landform profile.

Traffic

6.20 The currently permitted waste importation rate to the site and the currently permitted total amount of waste materials imported to the soil treatment facility will not change as a result of the variation applications. Traffic impact assessments have been carried out in 2005 and 2007 for previous environmental impact assessments for the site. The baseline information for these traffic assessments will be reviewed and compared with current traffic baseline information. The conclusions of the previous impact assessments will be checked to determine whether they remain valid for the proposed extension in the operational period.

Noise

6.21 Noise impact assessments were carried out in 2005 and 2007 for previous environmental impact assessments for the site. The site is the subject of a noise monitoring scheme and monitoring is carried out at six monthly intervals. The baseline information for these noise assessments will be reviewed and compared with current noise baseline information. The conclusions of the previous impact assessments will be checked to determine whether they remain valid for the proposed extension in the operational period.

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7. The structure of the planning applications and Environmental Statement

7.1 The applications for planning permission and the Environmental Statement will comprise several volumes. The proposed structure of the applications and Environmental Statement is presented at Appendix B.

7.2 Volume 1 will comprise the Section 73 applications which will consist of the planning application forms, the description of the proposed development, a review and analysis of the relevant planning polices an assessment of need for the extension in time. Volume 2 will comprise the Environmental Statement which will be sub-divided into three parts. Part 1 will include a Non Technical Summary, a description of the site, the approach to the EIA and a description of the population and public rights of way at and surrounding the site. The Non Technical Summary will also be made available as a separate document. Part 2 will comprise a description of the proposed variations to the planning conditions and the alternatives considered. Sufficient detail will be provided for development control and to facilitate the assessment of impacts. Part 3 will comprise the assessment of environmental impacts associated with the extension in time. The text will be supported by figures. Detailed technical reports will be appended to the Environmental Statement. Supporting documents will be submitted as necessary.

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FIGURES

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0m 500 1000 1500 2000 2500m

Key / Notes

Boundary of the East Northants Resource Management Facility Final KR MM LH 15/02/11 Draft KR MM LH 11/02/11

Rev Status Drn App Chk Date

Site EAST NORTHANTS RESOURCE MANAGEMENT FACILITY

Client

AugeanPLC specialists in waste management Title The location of the East Northants Resource Management Facility Scale Figure 1 1:50,000@A4 Drawing Ref AU/KCE/02-11/15959 Baddesley Colliery Offices, Reproduced scale mapping by permission of Ordnance Main Road, Baxterley, Atherstone, Warwickshire, CV9 2LE. Survey R on behalf of The Controller of Her Majesty's Telephone : 01827 717891 Stationery Office. C Crown copyright 2006. All rights reserved. Technical advisers on environmental issues Fax : 01827 718507 Licence number 100017818.

WS010001/ENRMF/CONSAPPCRF 239 Key / Notes

Boundary of the East Northants 300400 Resource Management Facility (planning permission reference Collyweston Great Wood EN/05/1264C)

Track Track Approximate location of the N currently consented landfill cell boundaries

300300 Track Boundary of the soil treatment

Track Pond facility (planning permission Ward Bdy Drain Und references 07/00048/WAS and 76.2m Ward Bdy SD 07/01838/NCC)

Surface water Boundary of the area the subject management lagoon of the planning application for the disposal of LLW

300200 Current haul roads

Woodland

Soil treatment area 79.6m concrete pad Water areas

Landfill Phases 1, 2 and 3 300100 Existing gas flare compound

Westhay Cottages

BM 83.97m

2 3

84.4m

300000 Cell 4A

Reservoir Cell 5A (covered)

Site entrance

83.8m

Cell 5B Weighbridge 299900 Cell 4B Final KR MM LH 15/02/11

Offices Draft KR MM LH 11/02/11 Generator Site offices Canteen Rev Status Drn App Chk Date Welfare Site EAST NORTHANTS RESOURCE MANAGEMENT Quarantine FACILITY area Client

299800 AugeanPLC specialists in waste management Pond Title Wheelwash Steel The current site layout Haul road containers Laboratory and storage shed Scale Figure 2 1:3,000@A3 Drawing Ref AU/KCE/02-11/15960 Reproduced scale mapping by permission of Ordnance 299700 Survey R on behalf of The Controller of Her Majesty's 0m 30 60 90 120 150m Stationery Office. C Crown copyright 2006. All rights reserved. Licence number 100017818.

500500

500600

500700

500800

500900

501000

501100

501200 501300 Baddesley Colliery Offices, Main Road, Baxterley, Atherstone, Warwickshire, CV9 2LE. Telephone : 01827 717891 Technical advisers on environmental issues Fax : 01827 718507

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APPENDICES

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APPENDIX A

LIST OF CONSULTEES

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LIST OF CONSULTEES

List 1: Statutory consultees – Organisations

The Health and Safety Executive The Environment Agency The relevant Strategic Health Authority The Commission for Architecture and the Northamptonshire Teaching Primary Built Environment Care Trust Natural England The Equality and Human Rights Commission The Historic Buildings and Monuments The Commission for Sustainable Commission for England Development The relevant fire and rescue authority The Commission for Rural Communities Northamptonshire Fire and Rescue Service The relevant police authority The Highways Agency Northamptonshire Police Authority The relevant parish council, or, where the The relevant Highways Authority application relates to land Wales or Scotland the relevant community council King’s Cliffe Parish Council The relevant local resilience forum The relevant waste regulation authority Northamptonshire Local Resilience Northamptonshire County Council Forum The Forestry Commission The Health Protection Agency

List 2: Statutory consultees – County, Unitary and District Councils

List 3: Other relevant stakeholders

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APPENDIX B

PROPOSED STRUCTURE OF THE SECTION 73 APPLICATIONS AND ENVIRONMENTAL STATEMENT

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APPENDIX B

Provisional contents list for the Section 73 application and Environmental Statement

VOLUME 1 SECTION 73 APPLICATION

Application forms

Description of the proposed variations to planning conditions

Planning history and planning context

Need for the development

VOLUME 2 ENVIRONMENTAL STATEMENT

Non-Technical Summary

Part 1

1. Introduction

2. Approach to the Environmental Impact Assessment

3. Site location and description

4. Properties and population including public rights of way

5. Geology, hydrogeology and hydrology

Part 2

6. Principles of the proposed variations to planning conditions

7. Current operations at the site

8. Site infrastructure

9. Restoration

10. Alternatives

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Part 3 – ASSESSMENT OF EFFECTS

11. Introduction of the assessment of environmental effects

12. Population

13. Ecology

14. Water resources

15. Amenity

16. Landscape and visibility

17. Traffic

18. Noise

19. Cumulative effects

20. Conclusions

Figures and Appendices

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APPENDIX C

SCOPING OPINION, CONSULTEE RESPONSES AND TABLE OF RESPONSES TO SCOPING CONSULTATION

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Northamptonshire County Council

Leslie Heasman Please ask for: Phil Watson Tel: (01604) 236638 M J Carter Associates Limited Our ref: 11/00001/SCO Baddesley Colliery Offices 11/00002/SCO Your ref: AU/KCE/MM/1561/01 Main Road Date: 29th March 2011 Baxterley Atherstone Warwickshire CV9 2LE

Dear Ms Heasman,

TOWN AND COUNTRY PLANNING (ENVIRONMENTAL IMPACT ASSESSMENT) (ENGLAND AND WALES) REGULATIONS 1999: REGULATION 10 SCOPING OPINION FOR PROPOSED DEVELOPMENT AT EAST NORTHANTS RESOURCE MANAGEMENT FACILITY, STAMFORD ROAD, KING’S CLIFFE, NORTHAMPTONSHIRE

11/00001/SCO – Proposals for scope and content of an application for planning permission and EIA for an extension in time and area for the landfill of disposal of hazardous waste and low level radioactive waste, an extension in time for the operation of the soil treatment facility and other associated development

11/00002/SCO – Proposals for scope and content of three Section 73 applications to vary planning permission conditions and an EIA assessment for an extension in time for the landfill disposal of hazardous waste and potentially low level radioactive waste, an extension in time for the operation of the soil treatment facility and other associated development

I refer to your letter dated 16th February 2010 and the two accompanying scoping reports. The scoping reports have been the subject of consultation in accordance with the Environmental Impact Assessment (EIA) Regulations and copies of the responses received have been forwarded to you. The majority of the responses jointly address both proposals.

A large number of responses, particularly from the Parish Councils, raise objections to the principles of the development but do not address the proposed content and scope of the applications. A number of other consultees have provided comment on what they consider should be included in applications rather than necessarily addressing what is proposed in the submitted reports. To avoid unnecessary repetition, broad guidance provided by consultees has not been duplicated in this letter.

Development Control, Planning PO Box 163, County Hall Guildhall Road Northampton, NN1 1AX w. www.northamptonshire.gov.uk t. 01604 236638 f. 01604 236065 e. [email protected]

WS010001/ENRMF/CONSAPPCRF 249 Overall I can confirm that the approach that you are advocating in the scoping reports is considered to be acceptable and appropriate and this is reflected in the nature of the consultation responses. You will note the specific points which have been made by the consultation bodies and you are required to have regard to these. In particular I would draw your attention to the following:

Baseline Data The response from Corby Borough Council (CBC) notes that the proposed baseline for the Environmental Statement associated with the new application for the extension in area of the site (11/00001/SCO) is inappropriate. Rather than being made on the currently permitted activities on site, CBC suggests that to allow a full assessment of the impact of the proposed development the baseline assessment should be based on all current activities on site having ceased.

Cumulative Impacts It is considered important that the assessment of cumulative impacts should include both temporal and in-combination effects.

Several sites in the surrounding area have been flagged as having the potential to contribute to cumulative impacts. In particular minerals and waste development at Cook’s Hole Quarry in Peterborough and future development in Corby have been mentioned. Please refer to the CBC and Peterborough City Council (PCC) responses for further detail.

Air Quality The extension of operations for a further three years has the potential to impact on air quality. On this basis Environmental Statements for both proposals would be expected to include up-to-date air quality assessments.

Ecology and Landscape Detailed comments regarding ecology and landscape have been made by the Senior Environmental Planner at Northamptonshire County Council, the Wildlife Trust and Natural England. These responses do not raise any major issues with the proposed scope of the applications but do provide useful comment and advice. Please refer to these comments directly.

The response from PCC points out that the landscape impact and assessment should be based on distance from the site boundary and not a radius from the centre of the site.

Water Resources The Environment Agency (EA) response refers to the location of the sites (Flood Zone 1) and the size of the sites (greater than 1.0 hectare) and the subsequent requirement for the Environmental Statements to consider all sources of flooding and provide a summary based on a referenced Flood Risk Assessment, including the management of surface

WS010001/ENRMF/CONSAPPCRF 250 water. Please see the EA response for further comment on flood risk, environmental permitting and other related regulation.

Traffic / Traffic and Transport It has been suggested that these sections could be more suitably titled ‘Traffic and Access’.

Given the proposals to operate until 2026, CBC considers that the Environmental Statements should consider the cumulative effects of traffic usage on the A43 in light of the North East Sustainable Urban Extension to Corby and possible future development at Deene Thorpe Airfield.

Rather than focussing on Stamford Road, it has been raised by PCC that the Transport Assessments should extend as far from the site as the additional traffic generation materially impacts on highway safety/free flow of traffic.

Other Matters The Environmental Statements should include an assessment of potential land use conflict.

Table 1 (The Development Plan) in both documents should be expanded to include the adopted Locations for Waste Development DPD and Locations for Waste Development DPD (March 2011) and the Development and Implementation Principles SPD. The Submitted Control and Management of Development DPD is also a material consideration and should be listed.

East Northants District Council (ENDC) considers that further detail should be provided in terms of how the local environmental impacts of the LLW disposal are to be monitored. ENDC is concerned about the future management of the site and how the associated risks are to be properly managed for future generations.

Numerous references are made in the reports to assessments that formed part of previous applications. Any such material referred to in forthcoming Environmental Statements will need to be updated where necessary and enclosed with subsequent applications.

Consultation Rutland County Council wishes to ensure they are consulted and that impact on land and receptors in Rutland is given due consideration.

I will ask Claire Spokes to forward you an updated list of consultees for future correspondence.

WS010001/ENRMF/CONSAPPCRF 251

Please let me know if I can be of any further assistance.

Yours sincerely

For Chief Planning Officer

WS010001/ENRMF/CONSAPPCRF 252 WS010001/ENRMF/CONSAPPCRF 253

From: [email protected] [mailto:[email protected]] Sent: 02 March 2011 08:42 To: Claire Spokes Cc: [email protected]; [email protected] Subject: Re: Fw: Scoping Consultation - Augean 11/00001/SCO & 11/00002/SCO

Hi Claire

Colleagues have made us aware of the Augean scoping consultation and whereas we have no comments to make at this stage we would like to be kept in the loop when the application is submitted as it has strategic implications for us for the continued disposal of hazardous waste and potentially low level radioactive waste.

We note that Warwickshire County Council is listed as a consultee and would be grateful if you could ensure that any documentation is forwarded to [email protected] due course.

Kind regards

Derek Greedy Principal Waste Management Advisor Economy and Development Environment and Economy Directorate Warwickshire County Council Tel: 01926 412455 Mobile 07584490280 Minicom: 01926 412277 Email: [email protected] Web: www.warwickshire.gov.uk

WS010001/ENRMF/CONSAPPCRF 254 WS010001/ENRMF/CONSAPPCRF 255 WS010001/ENRMF/CONSAPPCRF 256

Our ref: L01399 The Cube Your ref: 11/00001/SCO 199 Wharfside Street Birmingham B1 1RN Northamptonshire County Council Development Control Planning PO Box 163, County Hall Direct Line: 0121 687 2583 Guildhall Road Northampton 7 March 2011 NN1 1AX

For the attention of Mr P Watson

Dear Mr Watson

A43 TRUNK ROAD: 11/0001/SCO EAST NORTHANTS RESOURCE MANAGEMENT FACILTY, STAMFORD ROAD, KING’S CLIFFE, NORTHAMPTONSHIRE

The Highways Agency (“the Agency”) is a statutory consultee on planning applications under the Town and Country Planning (Development Management Procedure) (England) Order 2010. The Agency therefore welcomes the opportunity to provide advice on the scope of any Environmental Statement pursuant to the procedures set out in the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999, which also identify the Agency as a statutory party.

In your letter of 25 February 2011 you have invited the Agency to provide comments on the scope of an Environmental Statement in respect of a proposed Landfill Disposal of Hazardous Waste and Low Level Radioactive Waste at the above location.

I have set out below the general areas of concerns that the Agency would wish to see considered as part of an Environmental Statement. The comments relate specifically to matters arising from the Agency’s responsibilities to manage and maintain the Strategic Road Network (SRN) in England.

Comments relating to the local road network should be sought from the appropriate local highway authority.

General aspects to be addressed in all cases:

 An assessment of transport related impacts of the proposal should be carried out and reported as described in the current Department for Transport ‘Guidance on Transport Assessment’.  Environmental impact arising from any disruption during construction, traffic volume, composition or routing change and transport infrastructure modification should be fully assessed and reported.

Scoping Response NCC Stamford Road King's Cliffe 20110307.doc

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 Adverse change to noise and to air quality should be particularly considered, including in relation to compliance with the European air quality limit values and/or in local authority designated Air Quality Management Areas (AQMAs).  No new connections are permitted to the Highways Agency drainage network. In the case of an existing ‘permitted’ connection, this can only be retained if there is no land use change.  Development must not lead to any surface water flooding on the Strategic Road Network (SRN) carriageway.

These comments are only advisory, as the responsibility for determining the final scope of the Environmental Statement rests with the Local Planning Authority.

The Agency comments imply no pre-determined view as to the acceptability of the proposed development in traffic, environmental or highway terms. Should the applicant wish to discuss the merits of the proposal in terms of the likely impact on the SRN please advise them to contact me directly.

Yours sincerely

Adrian Johnson Network Delivery & Development East Midlands Email: [email protected]

Scoping Response NCC Stamford Road King's Cliffe 20110307.doc

WS010001/ENRMF/CONSAPPCRF 258 WS010001/ENRMF/CONSAPPCRF 259 WS010001/ENRMF/CONSAPPCRF 260 WS010001/ENRMF/CONSAPPCRF 261 WS010001/ENRMF/CONSAPPCRF 262 From: John R Wright [mailto:[email protected]] Sent: 08 March 2011 14:00 To: Claire Spokes Subject: Scoping Consultation - Augean 11/00001/SCO & 11/00002/SCO

Dear Ms Spokes, Thank you for consulting Leicestershire County Council before you adopt Scoping Opinions on the above developments proposed at the East Northamptonsire RMF at Kings Cliffe. I have no comments to make at this stage on the Scoping Reports which seem to cover the main matters I would expect. Best Wishes John Wright

Team Leader Policy and Mineral Planning Planning Historic and Natural Environment Leicestershire County Council County Hall Glenfield Leicester LE3 8RA Tel. 01163057041 Fax.01163057353

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WS010001/ENRMF/CONSAPPCRF 263

From: Ken Bolland [mailto:[email protected]] Sent: 08 March 2011 09:32 To: Phil Watson Cc: Jo Wilkins Subject: East Northants Resource Management Facility, Stamford Road, King's Cliffe, Northamptonshire

Dear Sir/Madam,

Re:Proposals for Scope and Content of an Application for Planning Permission and an EIA for an extension of time and area for the landfill disposal of hazardous waste and low level radioactive waste at above site.

With regard to impacts on Lincolnshire, this will not be an issue owing to the location of this landfill site. Lincolnshire County Council considers the ENRMF as having strategic importance with regard to hazardous waste as it is the only waste facility dealing with this type of waste in the East Midlands. Therefore if the Assessment of effects is completed to the satisfaction of Northamptonshire County Council and no unacceptable impacts are found, Lincolnshire County Council would have no objections to this proposal.

Regards

Ken Bolland ------This e-mail and any files transmitted with it are intended solely for the use of the individual or organisation to whom they are addressed. If you have received this e-mail in error, please notify the sender either by return of e-mail or by ringing the County Council's main switchboard on (0)1604 236236. The information contained in this e-mail and in your reply may be subject to disclosure under the Freedom of Information Act 2000 or other legislation and its confidentiality cannot be guaranteed. This e-mail has been checked for the presence of computer viruses. Northamptonshire County Council. http://www.northamptonshire.gov.uk ------

WS010001/ENRMF/CONSAPPCRF 264

Rutland County Council

Community Services Catmose, Oakham, Rutland, LE15 6HP Telephone: 01572 722577 Facsimile: 01572 758373 DX 28340 Oakham

Development Control, Planning PO Box 163, County Hall Guildhall Road Northampton, NN1 1AX

Attn Phil Watson

8 March 2011

Your Ref: 11/00001/SCO

Dear Sirs,

Re: TOWN AND COUNTRY PLANNING (ENVIRONMENTAL IMPACT ASSESSMENT) (ENGLAND AND WALES) REGULATIONS 1999: Scoping Request Consultation - Regulation 10

PROPOSED DEVELOPMENT: Proposals for Scope and Content of an Application for Planning Permission and an Environmental Impact Assessment for an Extension in Time and Area for the Landfill Disposal of Hazardous Waste and Low Level Radioactive Waste, an Extension in Time for the Operation of the Soil Treatment Facility and Other Associated Development.

SITE: East Northants Resource Management Facility, Stamford Road, King’s Cliffe, Northamptonshire.

I refer to your letter, dated 25 February 2011, regarding a scoping request for the aforementioned proposed development.

In respect of both Environmental Impact Assessments, I would request that the impact on land and receptors in Rutland is given due consideration. Whilst I would assume that this will be the case, some references in the Scoping Report do not make it clear that baseline data and views from agencies covering Rutland as well as Northamptonshire will be sought.

For example noise monitoring points proposed are all in Nothamptonshire. I would expect that consultations would be held with both Rutland and Northamptonshire Environmental Health Officers to confirm that these monitoring points meet their requirements. Similarly the Rutland Highway Authority should also be consulted as part of the preparation of the EIAs. Multum•in•Parvo

Rutland County Council District Council

WS010001/ENRMF/CONSAPPCRF 265

Thank you for consulting Rutland on this matter.

Yours faithfully

Carolyn Cartwright Development Control Manager

01572 758264

Multum•in•Parvo

Rutland County Council District Council

WS010001/ENRMF/CONSAPPCRF 266 Cambridgshire CC scoping response From: Phil Watson [[email protected]] Sent: 08 March 2011 11:11 To: Leslie Heasman Cc: Mike Mordue; Claire Spokes Subject: FW: East Northants Resource Management Facility scoping request Leslie, See below for information.

Regards Phil Watson Development Control Manager Planning Development Control Northamptonshire County Council PO Box 163 County Hall Northampton NN1 1AX Tel: 01604 236638 Fax 01604 236065 E-mail: [email protected]

-----Original Message----- From: Wass Helen [mailto:[email protected]] Sent: 01 March 2011 09:28 To: Phil Watson Subject: East Northants Resource Management Facility scoping request Dear Phil Your ref 11/00001/SCO Thank you for inviting Cambridgeshire County Council to comment on Augean PLC's request for a scoping opinion. We do not believe that there are any Cambridgeshire-specific issues that we need to bring to your attention so have no comments to make as a neighbouring waste planning authority at this stage. We are sure that you and the specialist statutory consultees will identify the relevant environmental issues that need to be addressed. We would like the opportunity to comment on the planning application in due course. Yours sincerely Helen Wass I should be grateful if you would use 12 point font in e-mails that you wish me to read. I suffer from chronic eye strain which is exacerbated by reading small type on screen.

Helen Wass Principal Planning Officer (Development Control) Cambridgeshire County Council Box CC1213 Cambridge CB3 0AP tel: 01223 715522 fax: 01223 475994 Page 1

WS010001/ENRMF/CONSAPPCRF 267 Cambridgshire CC scoping response The information in this email is confidential and may be legally privileged. It is intended solely for the addressee. If you receive this email by mistake please notify the sender and delete it immediately. Opinions expressed are those of the individual and do not necessarily represent the opinion of Cambridgeshire County Council. All sent and received email from Cambridgeshire County Council is automatically scanned for the presence of computer viruses and security issues. Visit www.cambridgeshire.gov.uk

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Page 2

WS010001/ENRMF/CONSAPPCRF 268 WS010001/ENRMF/CONSAPPCRF 269

Northamptonshire County Council

Development Control, Planning Please ask for: Rob Sim-Jones Tel: 01604 364338 PO Box 163, County Hall Our ref: PL 15298/4 Your ref: 11/00001/SCO Guildhall Road th Northampton Date: 11 March 2011 NN1 1 AX

Attention of Phil Watson

Dear Phil

Town and Country Planning Act (Environmental Impact Assessment – England and Wales) Regulations 1999

Proposed Development: Proposals for Scope and Content of an Application for Planning Permission and an Environmental Impact Assessment for an extension in time and area for the Landfill Disposal of Hazardous Waste and low level radioactive waste, and an extension in time for the operation of the soil treatment facility and other associated development

Site: East Northants Resource management facility, Stamford Road, King’s Cliffe, Northamptonshire.

I have the following observations to make on your consultation regarding the above scoping opinion.

The scoping report enclosed with the request for scoping opinion includes details of the work to be undertaken regarding transport and highway issues associated with the development proposals. This includes engaging with the Local Highway Authority (LHA) to fully scope out the LHA’s requirements to be included in a full Transport Assessments to accompany any future planning application.

This approach is acceptable to the LHA, and therefore we have no further observations at this stage.

Yours sincerely

Rob Sim-Jones Principal Development Control Engineer

Transport and Highways Riverside House Riverside Way Northampton NN1 5NX w. www.northamptonshire.gov.uk t. 01604 654338 f. 01604 654455 e. [email protected] WS010001/ENRMF/CONSAPPCRF 270 c/o Wastewatchers 4, Bridge Street King’s Cliffe Peterborough PE8 6XH 13 March 2011

Re: AU/KCE/MM/1561/01scoping and AU/KCE/MM/1583/01S73scoping

Dear Sir,

Wastewatchers acknowledge receipt of the scoping documents regarding an extension to the King’s Cliffe site.

Wastewatchers are surprised to note that there is reference to the potential disposal of LLW in these plans. We find it hard to believe that Augean is unaware of local opposition to the disposal of this material. The petition of more than 3000 signatures opposing the original plans for the disposal of LLW, the objections of several local parish councils and East Northamptonshire District Council, and the refusal of Northamptonshire County Council, should have made it abundantly clear that such disposals would be publicly unacceptable.

This strength of feeling was reiterated at the Public Inquiry in November 2010, not just by Wastewatchers but also by a number of local people. It has been further evidenced by the decision of a dozen local villages to hold referendums on the issue. We are aware that the final decision on this process is in the hands of the Secretary of State, but whatever his ruling we regard this new proposal as both insensitive to the needs and fears of local people, and opportunistic.

Wastewatchers hope, at least, that these concerns will be considered in the submission when assessing the impact on local people, and would take the opportunity of reminding Augean that ‘public acceptability’ is the first principle in the 2010 Strategy document.

Wastewatchers, therefore, remain resolutely opposed to the inclusion of LLW in this proposal.

Wastewatchers oppose the disposal of LLW in this location on the following grounds, inter alia:

- The lack of experience of Augean in dealing with LLW - A poor safety culture within Augean, as evidenced by the Cannock explosion, and fines for incorrect handling of hazardous materials - A lack of transparency towards local people as evidenced by claims that there would be no extension, and by the unannounced disposal of radioactive waste at nearby Thornhaugh - The siting of this facility over a major aquifer, and the evident instability of the underlying rock - The distance from sources of radioactive waste, and the consequent flouting of the Proximity Principle - The inappropriateness of siting such waste near breeding grounds of the Red Kite, especially given the lack of knowledge of the effects of radioactivity on wildlife - the public unacceptability, as previously mentioned.

All these reasons have been set out in Wastewatchers’ responses to the previous application, and will be explained more fully if Augean persist in including LLW in its current application.

Yours faithfully,

Chris Leuchars (on behalf of Wastewatchers)

WS010001/ENRMF/CONSAPPCRF 271 KING’S CLIFFE PARISH COUNCIL

Mrs. Hilary Blunt Clerk to the Council Freestone Lodge 50 Bridge Street King’s Cliffe Peterborough PE8 6XH Tel.: 01780470799 e-mail [email protected] www.kingscliffeparishcouncil.co.uk 15th March 2011

G. P. Watson Development Control, Planning PO Box 163 County Hall Guildhall Road Northampton NN1 1AX

Dear Mr. Watson

PROPOSED DEVELOPMENT :Proposals for Scope and Content of an Application for Planning Permission and an Environmental Impact Assessment for an Extension in Time and Area for the Landfill Disposal of Hazardous Waste and Low Level Radioactive Waste, an Extension in Time for the Operation of the Soil Treatment Facility and Other Associated Development

SITE : East Northants Resource Management Facility, Stamford Road, King's Cliffe, Northamptonshire

With reference to the above application, at a meeting of Kings Cliffe Parish Council on 10th March 2011 the decision was taken to strongly oppose any application to extend the time and area for proposals on the above Landfill Site and surrounding area.

Yours sincerely for King’s Cliffe Parish Council

Hilary Blunt

WS010001/ENRMF/CONSAPPCRF 272

Chairman: Mr. David Webb

Clerk Liz Holland, 26, Orchard Lane, Woodnewton, PE8 5EE

Phone: 01780 470676 email: [email protected]

Phil Watson, Development Control, Planning, NCC, PO Box 163, County Hall, Guildhall Road, Northampton, NN1 1AX

March 15th 2011

Dear Mr. Watson,

East Northants Resource Management Facility, King’s Cliffe Scoping Consultation

Please take account of the following comments from Woodnewton Parish Council. Page numbers refer to the report supplied by MJCA dated February 2011.

Assessment of Effects (page 10)

The EIA should include a clear statement of the environmental footprint of continued and extended operations of the site. This should include consideration of the energy and greenhouse gas emissions required to process and landfill wastes together with the energy and emissions required to transport wastes to the site.

People (page 11)

Impact on Local Communities: The proposed extension both in time and space of the activities on the site are likely to cause further stress to those living in surrounding communities. Attempts should be made to measure these against the "do nothing option" along with any proposed measures for mitigating stress to local communities.

WS010001/ENRMF/CONSAPPCRF 273 Water Resources (page 13)

The existing site and proposed extension overlays a Principle Aquifer; the Lincolnshire Limestone. Much of the formation the would normally separate this aquifer from the hazardous operations of the site has been removed by past quarrying activities. The EIA should include consideration of how the location, extension and continuation of the processing and landfilling of the specified wastes at the site pose risks to groundwater quality. These should be particularly examined in the context of the EC Groundwater Directive, the EC Landfill Directive and the Environment Agency's Groundwater Protection Policies.

Traffic (page 15)

The EIA should include consideration of the increased risks of accidents on surrounding roads posed by heavy vehicles containing wastes converging on the site.

Yours sincerely,

Liz Holland

WS010001/ENRMF/CONSAPPCRF 274 To the Chief Planning Officer

I am writing to you on behalf of Transition Kings Cliffe to STRONGLY AND FUNDAMENTALLY OBJECT to the plans by Augean plc to extend their activities in both area and duration.

We were originally told that the site would be filled and handed back to agricultural use by 2013. Now we are being shown plans to extend this to 2026. What will we be told as 2026 approaches?

The extension of the site to the West is also of concern. What will we be told when these cells are full?

It seems to members of TKC that the goalposts will continue to change indefinitely. If these plans were to go ahead, it will make a mockery of our planning system.

Transition Kings Cliffe is part of the wider, global, Transition movement. The Transition movement is all about making the necessary changes at a community level to make our communities resilient to the twin challenges of Climate Change and Peak Oil. These challenges offer us the opportunity to rethink and redesign our current oil dependent lifestyles. To this end, TKC has already set up several local schemes including a local bicycle repair service, a freecycle scheme and a tool sharing scheme. We are working with local schools to establish new orchards and we are always actively encouraging local food production and sharing.

Through our bike group, we are actively encouraging both adults and children to use their bikes more. This will potentially take them along the bridleways that pass close to the landfill site. The danger of airborne radioactivity along with increased numbers of people using these routes will obviously lead to an increase in health risks. The same is also true for runners, walkers and horse riders.

We oppose the plans because we believe that this waste has the potential to cause actual harm to people, the environment and local produce. It will also create the fear of such harm and damage the reputation of our village. The plans will also harm our our efforts to create a network of local producers and businesses that we believe are crucial to the sustainability of our community.We believe that people, even local people, may be unwilling to buy the produce grown in the area for fear of it’s radioactive content.

Yours Sincerely M.Kirk On behalf of Transition Kings Cliffe.

WS010001/ENRMF/CONSAPPCRF 275 Chief Planning Officer East Midlands Region Development Control, Planning Edwinstowe PO Box 163 Mansfield County Hall Notts Guildhall Road NG21 9JL Northampton NN1 1AX [email protected] Tel: 01623 821474 Fax: 01623 820912 ______Regional Director Andy Hall

Dear Mr. Watson 15 March 2011

TOWN AND COUNTRY PLANNING (ENVIRONMENTAL IMPACT ASSESSMENT) (ENGLAND AND WALES) REGULATIONS 1999: Scoping Request Consultation - Regulation 10

SITE: East Northants Resource Management Facility, Stamford Road, King’s Cliffe, Northamptonshire.

Thank you for seeking our advice about the impacts that this application may have on Ancient Woodland. We are pleased to provide you with the attached information that may be helpful when you consider the application:

• Details of the Government's National Forestry Policy • Advice on protecting ancient woodland through development control.

From this, you will see it is Government policy to discourage development that will result in the loss of Ancient Woodland, unless the development offers overriding public benefits. Ancient woodlands are widely regarded as irreplaceable. They have great value because they have a long history of woodland cover, with many features remaining undisturbed.

This consultation response is in line with our usual procedures, providing no opinion supporting or objecting to the proposals. This response provides factual information on related policy which the planning authority may take account of when making its decision. We hope these comments are helpful to you. If you have any further queries please do not hesitate to contact me.

Yours sincerely

Neil Riddle Grants & Regulations Manager

WS010001/ENRMF/CONSAPPCRF 276 Appendix 1 - Policy protecting ancient woodland

Policies for the protection and enhancement of ancient woodland are contained in a number of statutory instruments and national policy documents which are detailed below. This section is of particular relevance to the protection of ancient woodlands outside of statutory sites.

• Planning Policy Statement 9

PPS9, issued in 2005, is a key government policy document for ancient woodland planning cases. The importance of ancient woodlands is reflected by their specific inclusion in PPS9, which states (paragraph 10): 15

Ancient woodland is a valuable biodiversity resource both for its diversity of species and for its longevity as woodland. Once lost it cannot be recreated. Local planning authorities... should not grant planning permission for any development that would result in its loss or deterioration unless the need for, and benefits of, the development in that location outweigh the loss of the woodland habitat.‘

• Keepers of Time

Keeper‘s of Time, issued in 2005, is a statement of policy for England‘s ancient and native woodland which re-emphasises their value, evaluates threats and opportunities and sets out a range of actions to improve their protection and quality. The document provides a strong framework for ancient woodland protection and enhancement, and includes the statement that:

England‘s ancient woodlands and trees represent a living cultural heritage, a natural equivalent to our great churches and castles. They are also our richest wildlife habitat and are highly valued by people as places of tranquillity and inspiration.‘

• UK Biodiversity Action Plan

In 1992 the UK and 159 other governments signed the Convention on Biological Diversity (CBD) at the Earth Summit in Rio de Janeiro. The CBD called for signatories to develop national strategies and action plans to conserve biodiversity, and the UK responded with the UK Biodiversity Action Plan (UK BAP). This was first published in 1994 and included specific plans for species and habitats afforded priority conservation action. These plans set out the threats faced by species and habitats as well as the actions being taken or to be taken to help tackle the threats. The UK BAP list was updated in 2007 and now contains 1,149 species and 65 habitats.

1. Natural Environment and Rural Communities Act

Section 40 of the Natural Environment and Rural Communities Act 2006 (NERC Act) places a duty on Local Authorities to consider biodiversity in the full range of their activities. The duty affects all public authorities in England and Wales, which include public bodies, government and statutory undertakers. It is a legal requirement that:

Every public body must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity.‘

WS010001/ENRMF/CONSAPPCRF 277 Appendix 2 - Advice on protecting ancient woodland through development control

Planning applications should seek to identify and protect ancient woodland from adverse effects to comply with PPS9. Natural England (the government’s adviser on the natural environment) advises that the Natural England decision-making flowchart is used which shows the decision making process for local authorities when dealing with applications affecting ancient woodland. www.naturalengland.org.uk/Images/aw_flowchart_tcm6-25321.pdf

The flowchart should be used in conjunction with the assessment checklist. www.naturalengland.org.uk/Images/aw_checklist_tcm6-25317.pdf

The checklist aims to guide planners in making a comprehensive assessment of the potential effects of a development on ancient woodland and in identifying which aspects may require mitigation.

Further guidance:

Under the Forestry Act (1967) a Felling Licence is required for felling more than 5 cubic metres per calendar quarter. Failure to obtain a licence may lead to prosecution and the issue of a restocking notice. www.forestry.gov.uk/forestry/infd-6dfk86

Under the Environmental Impact Assessment (Forestry) (England and Wales) Regulations 1999 deforestation which is likely to have a significant impact on the environment may also require formal consent from the Forestry Commission. www.forestry.gov.uk/forestry/infd-6dfkbc

WS010001/ENRMF/CONSAPPCRF 278 COLLYWESTON PARISH COUNCIL ______

19 Westonville, Collyweston, Stamford, Lincolnshire. PE9 3PT Tel: 01780 444311 or Email: [email protected] Website: www.collywestononline.co.uk

Wednesday, 16 March 2011

Our Ref: 11/Planning/011

G. P Watson Development Control, Planning Northamptonshire County Council PO Box 163 County Hall Guildhall Road Northampton NN1 1AX

Dear Mr Watson

Re: Proposals for Scope and Content of an Application for Planning Permission and an Environmental Impact Assessment for an Extension in Time and Area for the Landfill Disposal of Hazardous Waste and Low Level Radioactive Waste, an Extension for the Operation of Soil Treatment facility and other associated development at East Northants Resource Management Facility, Stamford Road, King’s Cliffe

Collyweston Parish Council OBJECTS to the scope and content of the above application, on the grounds that the applicant’s case is premature, self-contradictory and does not make the case for a need for this extension at this site. The reasons are as follows:

On page 2 Augean states that the landfill is “extremely unlikely to be completed by 2013”.

1. On page 3 Augean states the wish for an area extension to “provide approximately 10 years of life” with “hazardous waste and potentially low- level radioactive waste”. 2. Contradiction: without existing permission for LLW, which Augean does not have, they have already acknowledged that they cannot fill the area they already have before their permission runs out in August 2013.

The Parish Council has also asked me to convey the following comments:

1. Whilst other applications are running concurrently (including the Appeal on the LLW decision), to allow this proposal to go ahead now might influence perceptions of the other applications, one way or the other. The Parish Council is keen to maintain clarity for the sake of all the local authorities involved – and for the sake of the public understanding.

WS010001/ENRMF/CONSAPPCRF 279 COLLYWESTON PARISH COUNCIL ______

19 Westonville, Collyweston, Stamford, Lincolnshire. PE9 3PT Tel: 01780 444311 or Email: [email protected] Website: www.collywestononline.co.uk

2. The potential for confusion about the LLW application, the area and time extension application, the 3-year time extension application (designed to try to avoid another Appeal on the area and time extension due to nondetermination) is huge. 3. Some people feel that this sense of confusion may not be accidental, and point to the likelihood that further time and area extension applications should be expected in the future, ad infinitum. 4. Given the lack of communication from the Environment Agency recently, regarding the delivery of LLW to Augean’s site at Thornhaugh, the members no longer feel confident to trust that they are being told neither everything relevant, nor that rules and permits are necessarily being abided by as fully as we used to believe.

Yours sincerely Clerk to the Parish Council

Mrs J. Hemingway

WS010001/ENRMF/CONSAPPCRF 280 WS010001/ENRMF/CONSAPPCRF 281 WS010001/ENRMF/CONSAPPCRF 282 WS010001/ENRMF/CONSAPPCRF 283

Northamptonshire County Council Our ref: AN/2011/111535/01-L01 PO Box 163 Your ref: 11/00001/SCO County Hall Guildhall Road Date: 18 March 2011 Northampton NN1 1AX

Mr Phil Watson

Dear Mr Watson

Proposals for Scope and Content of an Application for Planning Permission and an Environmental Impact Assessment for an Extension in Time and Area for the Landfill Disposal of Hazardous Waste and Low Level Radioactive Waste, an Extension in Time for the Operation of the Soil Treatment Facility and Other Associated Development East Northants Resource Management Facility, Stamford Road, Kings Cliffe

Thank you for your Scoping Request consultation letter of 01 March 2011.

We have reviewed the scoping report submitted and our technical comments detailing the information we consider should be provided in the Environmental Statement (ES) are provided below.

Technical comments and advice

Flood Risk Assessment

From the information submitted it appears that the location for the proposed development is located within Flood Zone 1 (low probability of river and sea flooding as defined in Annex D Planning Policy Statement 25 ‘Development and Flood Risk (PPS25)).

The ES needs to consider all sources of flooding and provide a summary based on a referenced Flood Risk Assessment (FRA).

As the site area exceeds 1.0 hectares, a Flood Risk Assessment (FRA) should be submitted with the planning application and ES which primarily focuses on the management of surface water. The FRA must demonstrate that surface water run-off

Environment Agency Customer services line: 08708 506 506 Nene House (Pytchley Lodge Industrial Estate), Weekday daytime calls to 0870 numbers cost 8p plus up to Pytchley Lodge Road, Kettering, Northants, NN15 6JQ 6p per minute from BT Weekend Unlimited. Email: [email protected] Mobile and other providers’ charges may vary. www.environment-agency.gov.uk

Cont/d..

WS010001/ENRMF/CONSAPPCRF 284 can be managed and the proposed surface water drainage system can cope with a 1% event with climate change without increasing flood risk to the site, surrounding area and third parties. The FRA must also demonstrate that post development run-off does not exceed pre-development rates and volumes.

For further advice and guidance on surface water requirements please refer to the Environment Agency and Defra document W5-074 “preliminary rainfall management for developments” version D (PRRMD v. D).

The following documents will assist in the preparation of a PPS 25 FRA: - Planning Policy Statement 25: Development and Flood Risk (PPS25). - Planning Policy Statement 25: Development and Flood Risk Practice Guide.

The amount of detail required in the FRA will in most cases be dependent upon the scale and nature of the proposed development, and the type of application applied for (i.e. outline, full). Should you wish to discuss the required content of the FRA in any detail, please contact our Development & Flood Risk Team on 01536 385228 (please ask for Rebecca Bristow or Christine Hardwick).

Environmental permitting and other regulation

1. Under the terms of the Land Drainage Act 1991 the prior written consent of the Environment Agency is required for any works which may impede the flow of water within a non main watercourse by way of a Flood Defence Consent. Please note that Environment Agency formal consent is required irrespective of any Town and Country Planning Act approvals/permissions. Consent is not implied by these comments and it is therefore imperative that early contact is made with the above team for advice regarding the Environment Agency's requirements. 2. Any development that costs over £300,000 requires a Site Waste Management Plan required under Site Waste Management Plans Regulations 2008 (No. 314) which provides a structure for waste delivery and disposal at all stages during a construction project. This should identify the volume and type of construction and demolition waste, and demonstrate how off-site disposal of wastes will be minimised and managed. 3. The Environment Agency is responsible for regulation under the Radioactive Substances Act 1993 (RSA93). This Act is concerned with the control of radioactivity. Business (referred to in the Act as "undertakings") accumulating and/or disposing of radioactive waste must have a permit known as an Authorisation. This Authorisation is separate to planning permission, therefore, we do not recommend duplication of controls through the planning process.

Any Authorisation issued for this activity will be regulated in conjunction with the existing hazardous waste landfill Environmental Permit. Any activities at this site authorised under the RSA93 must also meet the conditions of the existing Environmental Permit. Radioactive waste is not controlled waste, therefore no changes are required to any existing Environmental Permit.

We ask that our Pollution Prevention Guidelines, are considered. These guidance notes are available to download from: http://www.environment-agency.gov.uk/business/topics/pollution/39083.aspx

The comments we set out above are without prejudice to future decisions we make

Cont/d.. 2

WS010001/ENRMF/CONSAPPCRF 285 regarding any applications subsequently made to us for our permits or consents for operations at the site.

Should you require any additional information, or to discuss matters further, please do not hesitate to contact me on the number below.

Yours sincerely

Kerrie Ginns Planning Liaison Officer Direct dial 01536 385159 Direct e-mail [email protected]

End 3

WS010001/ENRMF/CONSAPPCRF 286

Date: 18 March 2011

Our ref: B 5.11.70

Your ref: 11/00001/SCO

Laura Jones c/o Dean Skrabania Minerals and Waste Planner Spur B West Block 7 Planning Policy County Hall Government Buildings Chalfont Drive Northampton Nottingham NN1 1AX NG8 3SN

Tel: 0300 060 2744 e-mail: EMPlanning@natural By email only, no hard copy to follow england.org.uk

Dear Ms Jones

TOWN AND COUNTRY PLANNING (ENVIRONMENTAL IMPACT ASSESSMENT) (ENGLAND AND WALES) REGULATIONS 1999: Scoping Request Consultation - Regulation 10

Proposal: Proposals for Scope and Content of an Application for Planning Permission and an Environmental Impact Assessment for an Extension in Time and Area for the Landfill Disposal of Hazardous Waste and Low Level Radioactive Waste, an Extension in Time for the Operation of the Soil Treatment Facility and Other Associated Development.

Location: East Northants Resource Management Facility, Stamford Road, King’s Cliffe, Northamptonshire.

Thank you for your email of 25 February 2011 regarding the above. I have read through the scoping report produced by M J Carter Associates and can confirm that this report covers most of the environmental impacts which Natural England would want to be assessed as part of the Environmental Impact Assessment (EIA). The scoping report sets out in sufficient detail the issues to be covered, most of which we fully support and will address our requirements. However, for the avoidance of doubt I include below the range of issues, which from Natural England’s perpective, the Environmental Impact Assessment should give full consideration to:

1. Sites of Special Scientific Interest (SSSIs) and sites of European or international importance (Special Areas of Conservation, Special Protection Areas and Ramsar sites). The Environmental Statement should include an assessment of any direct and indirect effects of the development on the features of special interest for all SSSIs

WS010001/ENRMF/CONSAPPCRF 287 within 5km of the application site boundary. In particular, we would want to see impacts from any gaseous and particulate emissions and impacts on hydrology fully assessed for the biological features within Collyweston Great Wood and Easton Hornstocks SSSI, Bonemills Hollow SSSI and Bedford Purlieus SSSI. Where negative impacts are identified the assessment should include proposals for avoidance, mitigation and compensation.

2. Landscape and visual impacts Natural England would wish to see details regarding local landscape character areas mapped at a scale appropriate to the development site as well as any relevant management plans or strategies pertaining to the area. The EIA should include assessments of visual effects on the surrounding area and landscape together with any physical effects of the development, such as changes in topography.

The EIA should include an assessment of the potential impacts of the development on local landscape character using landscape assessment methodologies. We strongly advocate the use of Landscape Character Assessment (LCA), based on the good practice guidelines produced jointly by the Landscape Institute and Institute of Environmental Assessment in 2002. LCA provides a sound basis for guiding, informing and understanding the ability of any location to accommodate change and to make positive proposals for conserving, enhancing or regenerating character, as detailed proposals are developed. Guidance on LCA, published by the Countryside Agency and Scottish Natural Heritage, is available at:

http://www.snh.org.uk/wwo/sharinggoodpractice/cci/cci/guidance/Downloads/ LCAfull.pdf

Natural England supports the publication Guidelines for Landscape and Visual Impact Assessment, produced by the Landscape Institute and the Institute of Environmental Assessment and Management in 2002 (2nd edition). The methodology set out in this book (which was sponsored by the Countryside Agency, amongst others) is almost universally used in the procedures of landscape and visual impact assessment.

A regional landscape character assessment has also recently been undertaken by Natural England and is available to view via our website at:

http://www.naturalengland.org.uk/regions/east_midlands/ourwork/characteras sessment.aspx

3. Local Wildlife Sites The Environmental Statement should include an assessment of the likely impacts on Local Wildlife Sites. The assessment should include proposals for mitigation of any impacts and if appropriate, compensation measures.

4. Species protected by the Wildlife and Countryside Act 1981 (as amended) and by the Conservation of Habitats and Species Regulations 2010 We recommend that relevant and appropriate surveys for protected species (including, for example, great crested newts, reptiles, birds, water voles, badgers and bats) should be carried out within the area affected by the development.

If any protected species are found or known to occupy the site the Environmental Statement should include details of:  The species concerned;  The population level at the site affected by the proposal;  The direct and indirect effects of the development upon that species;  Full details of any mitigation or compensation that might be required;

WS010001/ENRMF/CONSAPPCRF 288  Whether the impact is acceptable and/or licensable.

In order to provide this information there may be a requirement for a survey at a particular time of year. Surveys should always be carried out in optimal survey time periods and to current guidance by a suitably qualified and where necessary, licensed, consultants.

The great crested newt and all species of bats are European Protected Species (EPS) such that it is illegal to intentionally kill, injure or otherwise disturb them. If any of these species are found to be present you should also consult Natural England’s Wildlife Management and Licensing Unit in Bristol (Tel. 0845 6014523) about licensing implications before any work can proceed. It is noted that EPS licences have been issued to cover the application area. Details of all licences and their requirements should be provided in the assessment together with details of the measures undertaken to comply with the licence. This is important because the current applications may require a re-evaluation of the current licensing requirements if the new development affects the requirements of and compliance with these licences.

5. Other features of nature conservation interest, e.g. habitats and species identified within the UK and County Biodiversity Action Plans. Natural England advises that a habitat survey (equivalent to Phase 2) is carried out on the site, in order to identify any important habitats present. In addition, ornithological, botanical and invertebrate surveys should be carried out at appropriate times in the year, to establish whether any scarce or priority species are present. The Environmental Statement should include details of:

 Any historical data for the site affected by the proposal (e.g. from previous surveys);  Additional surveys carried out as part of this proposal;  The habitats and species present;  The status of these habitats and species (e.g. whether BAP priority habitat);  The direct and indirect effects of the development upon those habitats and species;  Full details of any mitigation or compensation that might be required.

The development should avoid adversely impacting the most important wildlife areas within the site, and should if possible provide opportunities for overall wildlife gain.

6. Cumulative and in-combination effects. The EIA should include an impact assessment to identify, describe and evaluate the effects that are likely to result from the project in combination with other projects and activities that are being, have been or will be carried out. To carry out the assessment of cumulative and in-combination effects, the following types of projects should be included. (Subject to the availability of information):

 Existing completed projects  Approved but uncompleted projects  Ongoing activities  Plans or projects for which an application has been made and which are under consideration by the consenting authorities  Plans and projects which are reasonably foreseeable, i.e. projects for which an application has not yet been submitted, but which are likely to progress before completion of the development and for which sufficient information is available to assess the likelihood of cumulative and in- combination effects.

WS010001/ENRMF/CONSAPPCRF 289

I trust these comments are helpful.

Yours sincerely

IAN EVANS Adviser Email: [email protected] Direct dial: 0300 060 2744

WS010001/ENRMF/CONSAPPCRF 290

Centre for Radiation, Chemical and Environmental Hazards

Health Protection Agency Centre for Radiation, Chemical and Ms Laura Jones Environmental Hazards Minerals and Waste Planner Health Protection Agency Northamptonshire County Council Institute of Population Health Nottingham City Hospital Planning Policy Hucknall Road County Hall Nottingham Northampton NG5 1PB NN1 1AX Tel +44 (0)8442 254524 Fax+44 (0)115 9692667 www.hpa.org.uk

18th March 2011

Dear Ms. Jones,

EIA Scoping Opinion Request for Augean East Northants Resource Management Facility, Stamford Road, Northamptonshire. Application number: 11/00001/SCO

The Health Protection Agency (HPA) received the above Environmental Scoping Report on 28th February 2011. This scoping report relates to the proposal by Augean PLC to submit a planning application to extend the life of the existing East Northants Resource Management Facility and extend the landfill area to the west of the current landfill.

The HPA’s enclosed response focuses on health protection issues relating to chemicals and radiation. The scope of the HPA’s response does not extend to wider health matters; these fall under the remit of other stakeholders. The following document outlines the information that the HPA considers should be provided in the environmental statement. The advice offered by the HPA is impartial and independent.

The applicant states that whilst the proposal for the disposal of low level radioactive waste is included in the scoping exercise, no final decision on whether to include it as part of the proposed development will be made until the outcome of the scoping exercise and completion of other preliminary assessment work.

General approach The EIA should give consideration to best practice guidance such as the Government’s Good Practice Guide for EIA1. It is important that the EIA identifies and assesses the potential public health impacts of the activities at, and emissions from, the installation. Assessment should consider the development, operational, and decommissioning phases.

The EIA Directive2 requires that ESs include a description of the aspects of the environment likely to be significantly affected by the development, including “population”. The EIA should provide sufficient information for the HPA to fully assess the potential impact of the development on public health. The HPA will only consider information contained or referenced in a separate section of the ES summarising the impact of the proposed development on public health:

1 Environmental Impact Assessment: A guide to good practice and procedures - A consultation paper; 2006; Department for Communities and Local Government. Available from: http://www.communities.gov.uk/archived/publications/planningandbuilding/environmentalimpactassessment 2 Directive 85/337/EEC (as amended) on the assessment of the effects of certain public and private projects on the environment. Available from: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:1985L0337:20090625:EN:PDF Health Protection Agency/CRCE/EP06

WS010001/ENRMF/CONSAPPCRF 291 summarising risk assessments, proposed mitigation measures, and residual impacts. This section should summarise key information and conclusions relating to human health impacts contained in other sections of the application (e.g. in the separate sections dealing with: air quality, emissions to water, waste, contaminated land etc) without undue duplication. Compliance with relevant guidance and standards should be highlighted.

It is not the HPA’s role to undertake these assessments as this would pose significant resource implications and would conflict with the HPA’s role as an impartial and independent body.

Consideration of alternatives (including alternative sites, choice of process, and the phasing of construction) is widely regarded as good practice. Ideally, EIA should start at the stage of site and process selection, so that the environmental merits of practicable alternatives can be properly considered. Where this is undertaken, the main alternatives considered should be outlined in the ES3.

The following text covers a range of issues that the HPA would expect to be addressed by the developer. However this list is not exhaustive and the onus is on the developer to ensure that the relevant public health issues are identified and addressed. The HPA’s advice and recommendations carry no statutory weight and constitute non-binding guidance.

Receptors The ES should clearly identify the development’s location and the direction and distance of off-site receptors that may be affected by emissions from, or activities at, the development. Human receptors may include residential, commercial, and industrial premises, together with transport infrastructure (such as roads and railways), recreational areas, and publicly-accessible land where people may be present temporarily. Consideration should also be given to environmental receptors such as the surrounding land, watercourses, surface and groundwater, and drinking water supplies such as wells, boreholes and water abstraction points.

Impacts arising from construction and decommissioning Any assessment of impacts arising from emissions due to construction and decommissioning should consider potential impacts on all receptors and describe monitoring and mitigation during these phases. Construction and decommissioning will be associated with vehicle movements and cumulative impacts should be accounted for.

We would expect the developer to follow best practice guidance during all phases from construction to decommissioning to ensure appropriate measures are in place to mitigate any potential impact on health from emissions (point source, fugitive and traffic-related). An effective Construction Environmental Management Plan (CEMP) (and Decommissioning Environmental Management Plan (DEMP)) will help provide reassurance that activities are well managed. The promoter should ensure that there are robust mechanisms in place to respond to any complaints of traffic-related pollution, during construction, operation, and decommissioning of the facility.

Emissions to air and water Significant impacts are unlikely to arise from installations which employ Best Available Techniques (BAT) and which meet regulatory requirements concerning emission limits and design parameters. However, the HPA has a number of comments regarding emissions in order that the EIA provides a comprehensive assessment of potential impacts.

When considering a baseline (of existing environmental quality) and in the assessment and future monitoring of impacts these:  should include appropriate screening assessments and detailed dispersion modelling where this is screened as necessary  should encompass all pollutants which may be emitted by the installation in combination with all pollutants arising from associated development and transport, ideally these should be considered in a single holistic assessment

3 DCLG guidance, 1999 http://www.communities.gov.uk/documents/planningandbuilding/pdf/155958.pdf

WS010001/ENRMF/CONSAPPCRF 292  should consider the construction, operational, and decommissioning phases  should consider the typical operational emissions and emissions from start-up, shut-down, abnormal operation and accidents when assessing potential impacts and include an assessment of worst-case impacts  should fully account for fugitive emissions  should include appropriate estimates of background levels  should identify cumulative and incremental impacts (i.e. assess cumulative impacts from multiple sources), including those arising from associated development, other existing and proposed development in the local area, and new vehicle movements associated with the proposed development; associated transport emissions should include consideration of non-road impacts (i.e. rail, sea, and air)  should include consideration of local authority, Environment Agency, Defra national network, and any other local site-specific sources of monitoring data  should compare predicted environmental concentrations to the applicable standard or guideline value for the affected medium (such as UK Air Quality Standards and Objectives and Environmental Assessment Levels)  If no standard or guideline value exists, the predicted exposure to humans should be estimated and compared to an appropriate health-based value (a Tolerable Daily Intake or equivalent). Further guidance is provided in Annex 1  This should consider all applicable routes of exposure e.g. include consideration of aspects such as the deposition of chemicals emitted to air and their uptake via ingestion  should identify and consider impacts on residential areas and sensitive receptors (such as schools, nursing homes and healthcare facilities) in the area(s) which may be affected by emissions, this should include consideration of any new receptors arising from future development

Whilst screening of impacts using qualitative methodologies is common practice (e.g. for impacts arising from fugitive emissions such as dust), where it is possible to undertake a quantitative assessment of impacts then this should be undertaken.

The HPA’s view is that the EIA should appraise and describe the measures that will be used to control both point source and fugitive emissions and demonstrate that standards, guideline values or health-based values will not be exceeded due to emissions from the installation, as described above. This should include consideration of any emitted pollutants for which there are no set emission limits. When assessing the potential impact of a proposed installation on environmental quality, predicted environmental concentrations should be compared to the permitted concentrations in the affected media; this should include both standards for short and long-term exposure.

Additional points specific to emissions to air When considering a baseline (of existing air quality) and in the assessment and future monitoring of impacts these:  should include consideration of impacts on existing areas of poor air quality e.g. existing or proposed local authority Air Quality Management Areas (AQMAs)  should include modelling using appropriate meteorological data (i.e. come from the nearest suitable meteorological station and include a range of years and worst case conditions)  should include modelling taking into account local topography

Additional points specific to emissions to water When considering a baseline (of existing water quality) and in the assessment and future monitoring of impacts these:  should include assessment of potential impacts on human health and not focus solely on ecological impacts  should identify and consider all routes by which emissions may lead to population exposure (e.g. surface watercourses; recreational waters; sewers; geological routes etc.)  should assess the potential off-site effects of emissions to groundwater (e.g. on aquifers used for drinking water) and surface water (used for drinking water abstraction) in terms of the potential for population exposure  should include consideration of potential impacts on recreational users (e.g. from fishing, canoeing etc) alongside assessment of potential exposure via drinking water

WS010001/ENRMF/CONSAPPCRF 293 Land quality Relevant areas outlined in the Government’s Good Practice Guide for EIA include:  effects associated with ground contamination that may already exist  effects associated with the potential for polluting substances that are used (during construction / operation) to cause new ground contamination issues on a site, for example introducing / changing the source of contamination  impacts associated with re-use of soils and waste soils, for example, re-use of site-sourced materials on-site or offsite, disposal of site-sourced materials offsite, importation of materials to the site, etc.

Nuisance Potential noise, odour, vermin and dust nuisance should be included within the EIA. The methodology for this should be agreed with the local authority environmental health department.

Waste The EIA should demonstrate compliance with the waste hierarchy (e.g. with respect to re-use, recycling or recovery and disposal).

For wastes delivered to the installation:  the EIA should consider issues associated with waste delivery and acceptance procedures (including delivery of prohibited wastes) and should assess potential off-site impacts and describe their mitigation

For wastes arising from the installation the EIA should consider:  the implications and wider environmental and public health impacts of different waste disposal options  disposal route(s) and transport method(s) and how potential impacts on public health will be mitigated

Other aspects Within the EIA the HPA would expect to see information about how the developer would respond to accidents with potential off-site emissions e.g. flooding or fires, spills, leaks or releases off-site. Assessment of accidents should: identify all potential hazards in relation to construction, operation and decommissioning; include an assessment of the risks posed; and identify risk management measures and contingency actions that will be employed in the event of an accident in order to mitigate off-site effects.

The EIA should include consideration of the COMAH Regulations (Control of Major Accident Hazards) and the Major Accident Off-Site Emergency Plan (Management of Waste from Extractive Industries) (England and Wales) Regulations 2009: both in terms of their applicability to the installation itself, and the installation’s potential to impact on, or be impacted by, any nearby installations themselves subject to the these Regulations.

There is evidence that, in some cases, perception of risk may have a greater impact on health than the hazard itself. A 2009 report4, jointly published by Liverpool John Moores University and the HPA, examined health risk perception and environmental problems using a number of case studies. As a point to consider, the report suggested: “Estimation of community anxiety and stress should be included as part of every risk or impact assessment of proposed plans that involve a potential environmental hazard. This is true even when the physical health risks may be negligible.” The HPA supports the inclusion of this information within EIAs as good practice.

Ionising radiation Particular considerations apply when an application involves the possibility of exposure to ionising radiation. In such cases it is important that the basic principles of radiation protection recommended by the International Commission on Radiological Protection5 (ICRP) are followed. HPA provides advice on the application of these recommendations in the UK. The ICRP recommendations are

4 Available from: http://www.cph.org.uk/showPublication.aspx?pubid=538 5 These recommendations are given in publications of the ICRP notably publications 90 and 103 see the website at http://www.icrp.org/

WS010001/ENRMF/CONSAPPCRF 294 implemented in the Euratom Basic Safety Standards6 (BSS) and these form the basis for UK legislation, including the Ionising Radiation Regulations 1999, the Radioactive Substances Act 1993, and the Environmental Permitting Regulations 2010.

The HPA expects promoters to carry out the necessary radiological impact assessments to demonstrate compliance with UK legislation and the principles of radiation protection. This should be set out clearly in a separate section or report and should not require any further analysis by the HPA. In particular, the important principles of justification, optimisation and radiation dose limitation should be addressed. In addition compliance with the Euratom BSS and UK legislation should be clear.

The radiological impact of the disposal of radioactive waste in the site should be addressed in an assessment to ensure that this complies with UK practice and legislation; information should be provided on the category of waste involved (e.g. low level waste, LLW) and the activity concentrations and radionuclide composition. Of relevance here is the HPA advice on radiological criteria and assessments for land-based solid waste disposal facilities7. The HPA advises that assessments of radiological impact during the operational phase should be performed in the same way as for any site authorised to discharge radioactive waste: including doses to workers and doses to members of the public from any discharges. The HPA also advises that assessments of radiological impact during the post operational phase of the facility should consider long timescales (possibly in excess of 10,000 years) that are appropriate to the long-lived nature of the radionuclides in the waste, some of which may have half-lives of millions of years. The radiological assessment should consider exposure of members of hypothetical representative groups (people expected to receive the highest exposures) for a number of scenarios including the expected migration of radionuclides from the facility, and inadvertent intrusion into the facility once institutional control has ceased. For scenarios where the probability of occurrence can be estimated, both doses and health risks should be presented, where the health risk is the product of the probability that the scenario occurs, the dose if the scenario occurs and the health risk corresponding to unit dose. For the migration scenario, the peak dose to the hypothetical representative group and the time of the peak should be presented, together with the associated health risks. For inadvertent intrusion, the peak dose if the intrusion occurs should be presented; normally this will occur at the earliest date after institutional control has ceased. It is recommended that the post-closure phase be considered as a series of timescales, with the approach changing from more quantitative to more qualitative as times further in the future are considered. The level of detail and sophistication in the modelling should also reflect the level of hazard presented by the waste. The uncertainty due to the long timescales means that the concept of collective dose has very limited use, although estimates of collective dose from the ‘expected’ migration scenario can be used to compare the relatively early impacts from some disposal options if required. The results should be compared with the relevant criteria specified by the environment agencies. In particular, application of the optimisation principle should be demonstrated.

Assessments of the radiological impact of routine discharges of radionuclides to the environment (relevant to the operational and institutional control phases) should consider the dose to the representative person (those members of the public who are likely to receive the highest exposures). Different age groups should be considered as appropriate and should normally include adults, 1 year old and 10 year old children. In particular situations doses to the fetus should also be calculated8. The estimated doses to the representative person should be compared to the appropriate radiation dose criteria (dose constraints and dose limits), taking account of other releases of radionuclides from nearby locations as appropriate. Collective doses should also be considered for the UK, European and world populations where appropriate. The methods for assessing individual and collective radiation doses should follow the guidance given in ‘Authorisation of discharges of radioactive waste to the environment Principles for the assessment of prospective public doses.

6 Council Directive 96/29/EURATOM laying down basic safety standards for the protection of the health of workers and the general public against the dangers arising from ionising radiation. 7 HPA RCE-8, Radiological Protection Objectives for the Land-based Disposal of Solid Radioactive Wastes, February 2009 8 HPA (2008) Guidance on the application of dose coefficients for the embryo, fetus and breastfed infant in dose assessments for members of the public. Doc HPA, RCE-5, 1-78, available at www.hpa.org.uk

WS010001/ENRMF/CONSAPPCRF 295 Interim Guidance, December 2002’9. Additional guidance is published by the National Dose Assessment Working Group on its website (www.ndawg.org). The radiological impact of transporting the radioactive waste to the site should also be considered.

It is important that the methods used in any radiological dose assessment are clear and that key parameter values and assumptions are given (for example, the location of the representative persons, habit data and models used in the assessment).

Liaison with other stakeholders, comments should be sought from:  the local authority regarding any site investigation and subsequent construction (and remediation) proposals to ensure that the site could not be determined as ‘contaminated land’ under Part 2A of the Environmental Protection Act 1990  the local authority should be consulted regarding any impacts on existing or proposed Air Quality Management Areas  the Food Standards Agency for matters relating to the impact on human health of pollutants deposited on land used for growing food/ crops  the Environment Agency for matters relating to flood risk and releases with the potential to impact on surface and groundwaters  the Environment Agency for matters relating to waste characterisation and acceptance

Environmental Permitting Amongst other permits and consents, the development will require an environmental permit from the Environment Agency to operate (under the Environmental Permitting (England and Wales) Regulations 2010). Therefore the installation will need to comply with the requirements of best available techniques (BAT). The HPA is a consultee for bespoke environmental permit applications and will respond separately to any such consultation.

Yours sincerely

Andy McParland Environmental Public Health Scientist Tel: 0115 962 7040 E-mail: [email protected]

Cc: Dr Stephen Horsley, Mrs Cathy Mallaghan

9 The Environment Agency (EA), Scottish Environment Protection Agency (SEPA), Department of Environment, Northern Ireland (DoE, NI), the National Radiological Protection Board (NRPB, now part of the Health Protection Agency and the Food Standards Agency (FSA). Authorisation of discharges of radioactive waste to the environment Principles for the assessment of prospective public doses. Interim Guidance, December 2002. http://publications.environment- agency.gov.uk/epages/eapublications.storefront/47a83bdc0165566e273fc0a8029606a4/Search/Run

WS010001/ENRMF/CONSAPPCRF 296 From: ANTHONY BIANCHI [mailto:[email protected]] Sent: 18 March 2011 09:06 To: Phil Watson Cc: Simon Mclean Subject: objections

On behalf of Harringworth Parish Council I wish to register our objection to the following applications These cover the Kingscliffe site and refer to the scope and content of the applications for the site.

the application numbers are 11/00002/SCO and 11/00001/SCO

Please register our objections

A.R.Bianchi clerk to the Council

------This e-mail and any files transmitted with it are intended solely for the use of the individual or organisation to whom they are addressed. If you have received this e-mail in error, please notify the sender either by return of e-mail or by ringing the County Council's main switchboard on (0)1604 236236. The information contained in this e-mail and in your reply may be subject to disclosure under the Freedom of Information Act 2000 or other legislation and its confidentiality cannot be guaranteed. This e-mail has been checked for the presence of computer viruses. Northamptonshire County Council. http://www.northamptonshire.gov.uk ------

WS010001/ENRMF/CONSAPPCRF 297 WS010001/ENRMF/CONSAPPCRF 298 WS010001/ENRMF/CONSAPPCRF 299 WS010001/ENRMF/CONSAPPCRF 300

The Wildlife Trust Lings House Billing Lings Northampton NN3 8BE Mr Phil Watson, Case Officer Tel: 01604 405285 Development Control, Planning Fax: 01604 784835 Northamptonshire County Council P.O. Box 163, County Hall Sent via Email. Guildhall Road Northampton NN1 1AX 18th March 2011

Dear Mr Watson

RE: Planning Application No. 11/00001/SCO; Proposals for Scope and Content of an Application for Planning Permission and an Environmental Impact Assessment for an Extension in Time and Area for the Landfill Disposal of Hazardous Waste and Low Level Radioactive Waste, an Extension in Time for the Operation of the Soil Treatment Facility and Other Associated Development;

And

Planning Application No. 11/00002/SCO; Proposals for Scope and Content of Three Section 73 Applications to Vary Planning Permission Conditions and an Environmental Impact Assessment for an Extension in Time for the Landfill Disposal of Hazardous Waste and Potentially Low Level Radioactive Waste, an Extension in Time for the Operation of the Soil Treatment Facility and Other Associated Development;

Both at the East Northants Resource Management Facility, Stamford Road, King’s Cliffe.

COMMENT.

Thank you very much indeed for consulting The Wildlife Trust, in respect of the above two, linked and related, Scoping Opinion Requests for proposed variations to Conditions, extensions to time limits, and other aspects of alteration / revision, associated with the existing landfill operations at the site off Stamford Road near to the village of King’s Cliffe.

We refer now to your revised Consultation Covering Letter, dated 1st March 2011, and to its attached letter, of 16th February 2011, as addressed to you from Mr Leslie Heasman of M.J. Carter Associates Limited, seeking Scoping Opinions from your Authority.

We propose, by the means of this single letter of reply, to address our comments to both of these joint Scoping Opinions, for the same general area of land, as a combined response to this particular consultation exercise.

WS010001/ENRMF/CONSAPPCRF 301

With reference to the two separate Scoping Report ( February 2011 ) documents, as prepared by the consultancy MJCA Ltd., we do indeed agree that, for a scheme of this scale and nature, an Environmental Impact Assessment would require to be carried out on it. You may also wish to consider, given its size, location and scope, whether the plans for these projects should also be the subject of a Strategic Environmental Assessment and a Sustainability Appraisal as well.

New developments, as stated in National, Regional and Local planning policy, should both protect and enhance local biodiversity as an integral part of any proposal. Alongside an assessment of the existing ecological value of the site, we would like to see the identification of opportunities for such enhancement.

Surveys and information.

Adequate baseline surveys should indeed be completed to assess the value of the site and surrounding area. The Wildlife Trust recommends that at least an Extended Phase 1 Habitat Survey be carried out, and that all Statutory and Non-Statutory sites, protected species and other relevant species and habitats be fully investigated and evaluated. Information on wildlife records for the area should be obtained as part of this from the Northamptonshire Biodiversity Records Centre ( NBRC ); contact details below. A list of additional local contacts for Northamptonshire is also enclosed below.

For information, the proposed footprint for this particular Application Site has the following features :

 The site lies adjacent to the “Collyweston Great Wood & Easton Hornstocks” National Nature Reserve designated area. Parts of this adjacent land to the Application Site are, in addition, designated as SSSI, and furthermore, it also contains areas of important and valuable Ancient Woodland habitats within it too.

 Within a selected Zone of Interest of 2 kilometres radius out from the assumed centre of this proposed Application Site, there are several non-statutory designated sites – including Local Wildlife Sites, Potential Wildlife Sites and even also a Local Geological Site too. In fact, there is a PWS contained within the red- line footprint boundary of this Application Site itself. There are also other areas of Ancient Woodland habitats within this same ZoI too. These issues are Material Considerations within the context of the Planning System, and thus, the potential for both detrimental impacts upon these wildlife site areas ( both existing and potential ) and for the possibility to deliver biodiversity enhancements to them, as well as to the Application Site itself, must all be comprehensively investigated and addressed before the eventual determination decision-making process can be properly carried-out in respect of these two related development proposals.

 The Wildlife Trust is aware of several historical records of sightings of ‘protected species matters’ within a distance of 2 kilometres away from the assumed centre of this proposed Application Site.

In addition, consideration may well need to be given to the issue of whether or not there is going to be any significant degree of increased artificial lighting levels occurring as a result of the delivery of this proposed development scheme, and if so, the ways in which it might have an impact upon the local biodiversity – such as bat species, for example.

WS010001/ENRMF/CONSAPPCRF 302

Enhancement of biodiversity and Green Infrastructure.

Opportunities for the enhancement of biodiversity include linking and buffering existing wildlife sites and habitats through habitat creation and incorporation of Green Infrastructure ( GI ). Reinforcement of this is found in the East Midlands Regional Plan, PPS 9, NERC Act ( 2006 ) and Local Development Plans. The EIA should include proposals for ecological mitigation linked to the during- and post-construction impacts and should suggest the content of Planning Conditions and ecological sections of S106 Agreements if applicable.

Northamptonshire’s Local Biodiversity Action Plan gives details and targets on locally important species and habitats ( www.northamptonshirebiodiveristy.org ).

We strongly recommend that a GI approach be followed. This process should be incorporated as an integral part of the EIA analysis. The key ecological aspect of GI that we would expect to see is the linking of existing and / or potential wildlife habitat within the site and connections out of the site to create more sustainable ecosystems.

This Application Site lies close to a major, strategic Sub-Regional GI Corridor route.

Landscaping and ecological mitigation are only of worth to wildlife if properly managed. Therefore, the EIA should consider the long-term management of all green spaces.

In our opinion, it is important to not introduce any non-native or invasive species into either terrestrial or aquatic environments. Therefore, any soft landscaping elements that it is intended to include within this development proposal should be provided for by the use of native species ( of plants, shrubs and trees ) only. Ideally, these species should be chosen as ones that are typical of that part of the county and they should all only be sourced from a local and a known provenance. These areas should be managed for the benefit of wildlife.

Analysis of cumulative effects.

The Wildlife Trust recommends that, in addition to addressing any potential direct / indirect impacts as a sole result of their own development scheme, the Applicant also be required to include, in this section of the supporting documentation, a comprehensive review of just what the likely effects of the provision of their facilities is going to be upon the existing biodiversity at this location in combination with all of the other relevant encroaching development pressures in this area of the District.

Feedback in respect of Applicant’s Scoping Report document.

With reference to the two Scoping documents dated February 2011, from MJCA Ltd., please note our specific point of observation, as follows :

 We note that, within Paragraph 6.8, under the sub-heading of “Ecology” in both reports, reference is made to the fact that it is already established that the protected species Great Crested Newt is already present on this site. Therefore, we strongly recommend that you seek consultation with Natural England concerning both the conservation issues relating to this species and also the required Licensing arrangements.

WS010001/ENRMF/CONSAPPCRF 303

The Wildlife Trust would welcome an early opportunity to review the ecological appraisal work as the relevant survey and report information is produced by the Applicant’s consultants.

We hope that the above comments are useful to you. We look forward to reviewing the relevant sections of any Environmental Statement that might be submitted. Please do not hesitate to contact The Wildlife Trust again if you have any questions about the above points.

Yours sincerely,

Alan J.G. Smith Planning & Biodiversity Officer – Northamptonshire. Email : [email protected]

The Northamptonshire Biodiversity Records Centre (NBRC);  Lings House, Billing Lings, Northampton, NN3 8BE; Tel: 01604 400448; Email: [email protected].

Other potential local consultees  The Northamptonshire bat group (Phil Richardson, [email protected])  The North Northamptonshire Badger group (Wellingborough, Kettering, Corby, East Northants) (Peter Edwards, [email protected])  The West Northamptonshire Badger Group (Northampton, Daventry, South Northants) (Steven Jackson, [email protected])  The Northamptonshire Barn Owl Group (Paddy Jackson, [email protected])  The Hawk and Owl Trust (http://www.hawkandowl.org/)  The British Trust for Ornithology (BTO, http://www.bto.org/index.htm)  The RSPB (Colin Wilkinson, [email protected])  Northamptonshire Moth Recorder (John Ward, [email protected])

WS010001/ENRMF/CONSAPPCRF 304 From: Tina Cuss Sent: 23 March 2011 11:38 To: Phil Watson Subject: 11/00001/SCO & 11/00002/SCO

East Northants Resource Management Facility, Stamford Road, King’s Cliffe, Northamptonshire. Environmental Impact Assessment Scoping Request Consultation - Regulation 10

11/00001/SCO - Proposals for Scope and Content of an Application for Planning Permission and an Environmental Impact Assessment for an Extension in Time and Area for the Landfill Disposal of Hazardous Waste and Low Level Radioactive Waste, an Extension in Time for the Operation of the Soil Treatment Facility and Other Associated Development

11/00002/SCO – Proposals for Scope and Content of Three Section 73 Applications to Vary Planning Permission Conditions and an Environmental Impact Assessment for an Extension in Time for the Landfill Disposal of Hazardous Waste and Potentially Low Level Radioactive Waste, an Extension in Time for the Operation of the Soil Treatment Facility and Other Associated Development

The Environmental Statement must include the information included in Part II of Schedule 4 to the Town and Country Planning (Environmental Impact Assessment) Regulations 1999. Information in Part I required to assess the environmental effects of the development should include indirect and any indirect, secondary, cumulative, short, medium and long-term, permanent and temporary and positive and negative effects of the development resulting from the existence of the development. The ES should include a comprehensive description of the measures proposed to prevent, reduce and offset adverse effects on the environment. The ES should include a description of likely significant effects outlined in point 3 of Part I of Schedule 4.

I would support and concur with all the points made by Natural England in their response of 18 March 2011. In addition the following should be considered:

Culture In accordance with the guidance provide in DETR Circular 02/99 the socio economic effects described in the scoping report are not environmental impacts and if required should not be included in the ES but in the planning statements or supporting statement. In my opinion the cumulative effect of the extended timescale of the waste disposal activities on social cohesion and economic potential should not be included in the ES. I note there are no current proposals to consider the impacts on Green Infrastructure. Guidance on the information that should be included is available in the Development Implementation Principles SPD.

Air Quality Impacts of potential effects on air quality should not be limited to effects on the human population but consider effects on ecology and the interaction between effects.

Landscape & Visual Assessment In order to assess the significance of impact of the whole project, the assessment of cumulative impacts on landscape and visual amenity should not be limited to an evaluation of the additional impacts over and above currently permitted activities at the site. An assessment of the long term, medium and short term, permanent, temporary, direct and indirect, positive and negative effects on landscape should all be provided in accordance

WS010001/ENRMF/CONSAPPCRF 305 with EIA and landscape and visual assessment guidance (see Natural England comment and my informal pre-application response).

Ecology Phase 1 habitat survey should be carried out in-line with JNCC guidance and up-to-date best practice, rather than US Institute of Environmental Assessment Guidance. We would prefer the ecological impact assessment be carried out using the IEEM guidance, or to an equivalent standard if necessary. Particular consideration should be given to the Conservation of Habitats and Species Regulations 2010 rather than the 1994 Conservation (Natural Habitats, &c.) Regulation. Consideration should also be given to local BAP and Habitats and species of principal importance. Up-to-date survey records should be sought from relevant County Recorders and the Northamptonshire Biological Records Centre.

I note that the previous Great Crested Newt receptor site is designated as a County Wildlife Site. Not included in the current scope, the impacts on locally designated sites should also be included in the ecological impact assessment. The ecological impact assessment should include assessment and mitigation for potential impacts on other protected species directly and indirectly impacted by the proposals both on site and on habitats impacted by the development such as bats and ground nesting birds.

We would welcome early discussions on the proposed mitigation for Great Crested Newts and would like to request copies of all the ongoing monitoring undertaken as part of previous planning permissions and the extant Natural England Great Crested Newt Licence. I would be happy to comment on the detailed scope of proposed survey work to be undertaken in 2011 and new proposed receptor site and mitigation under consideration. I would also welcome the up-to-date monitoring reports on previous reptile and badger mitigation.

Tina Cuss Senior Environmental Planner Planning Services Northamptonshire County Council 01604 236705

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Appendix C

Table of responses to the Scoping Consultation

Consultee Date of Summary of the issues/comments. Comment regarding how the scoping comments will Response be addressed Health and Safety 25 February HSE do not comment on scoping of the Environmental Statement Executive 2011

Warwickshire County 02 March 2011 Colleagues have made us aware of the Augean scoping consultation and whereas we have no comments to make at this stage Council we would like to be kept in the loop when the proposal is submitted ad it has strategic implications for us for the continued disposal of hazardous waste and potentially low level radioactive waste. We note that Warwickshire County Council is listed as a consultee and would be grateful if you would ensure that any documentation is forwarded to [email protected] in due course.

Peterborough City Council 04 March 2011 The extent of the landscape survey should be taken from the site boundary and not as a radius from the centre of the site. Consideration is being given to the inclusion of these issues in the Environmental Impact Assessment. The focus of the Transport Assessment should extend as far from the site as the additional traffic generation materially impacts on highway safety/free flow of traffic. If there is no further impact beyond the junction with the A47 then this should be stated and quantified with the TA.

The cumulative impact of the application at Cooks Hole Quarry should be considered.

Highways Agency 07 March 2011 An assessment of transport related impacts of the proposal should be carried out and reported as described in the current These issues are addressed in the section of the PEI on Department for Transport ‘Guidance on Transport Assessment’. transport impacts and will be included in the Environmental Impact Assessment. Flooding is dealt with Environmental impact arising from any disruption during construction, traffic volume, composition or routing change and transport in the Flood Risk Assessment section of the PEI. infrastructure modification should be fully assessed and reported.

Adverse change to noise and to air quality should be particularly considered including in relation to compliance with European air quality limit values and/or in local authority designated Air Quality Management Areas.

No new connections are permitted to the Highways Agency drainage network. In the case of an existing 'permitted' connection this can only be retained if there is no land use change.

Development must not lead to any surface water flooding on the Strategic Road Network carriageway. Yarwell Parish Council 07 March 2011 Thank you for the documents you sent, my council have no comments to make on them. They have however, instructed me to reiterate that the council is opposed to Disposal of Low Level Radioactive Waste at this site. Huntingdonshire District 07 March 2011 No comments to make. Council Oxfordshire County 07 March 2011 No comments to make. Council Kettering Borough Council 08 March 2011 Thank you for consulting this Authority about the above proposal. This council raises no objection to the above proposal.

Leicestershire County 08 March 2011 Thank you for consulting Leicestershire County Council before you adopt Scoping Opinions on the above developments Council proposed at the East Northamptonshire RMF at King's Cliffe. I have no comments to make at this stage on the Scoping Reports which seem to cover the main matters I would expect.

Linconshire County 08 March 2011 With regard to impacts on Lincolnshire, this will not be an issue owing to the location of this landfill site. Council Rutland County Council 08 March 2011 In respect of both Environmental Impact Assessments, I would request that the impact on land and receptors in Rutland is given These issues are addressed in the section of the PEI on

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Consultee Date of Summary of the issues/comments. Comment regarding how the scoping comments will Response be addressed due consideration. Whilst I would assume that this will be the case, some references in the Scoping Report do not make it clear noise and traffic impacts and will be included in the that baseline data and views from agencies covering Rutland as well as Northamptonshire will be sought. For example noise Environmental Impact Assessment. monitoring points proposed are all in Northamptonshire. I would expect that consultations would be held with both Rutland and Northamptonshire Environmental Health Officers to confirm that these monitoring points meet their requirements. Similarly the Rutland Highway Authority should also be consulted as part of the preparation of the EIAs.

Cambridgeshire County 08 March 2011 We do not believe that there are any Cambridgeshire-specific issues that we need to bring to your attention so have no Council comments to make as a neighbouring waste planning authority at this stage. We would like the opportunity to comment on the planning application in due course Commission for 09 March 2011 The Commission for Architecture and the Built Environment (CABE) do not comment on the Environmental Impact Assessment Architecture and the Built scoping. However, they would like to be consulted in due course on any significant designs that may come forward for buildings Environment (CABE) and other infrastructure, and any public space works that might be proposed as part of this scheme.

Northamptonshire 11 March 2011 This approach is acceptable to the LHA, and therefore we have no further observations at this stage County Council Transport and Highways department Wastewatchers 13 March 2011 Wastewatchers oppose the disposal of LLW in this location on the following grounds, inter alia: The comments relate to reasons for objection rather than The lack of experience of Augean in dealing with LLW comments on the scoping of the EIA. Impacts on health A poor safety culture within Augean, as evidenced by the Cannock explosion, and fines for incorrect handling of hazardous and the environment are addressed principally in the materials sections of the PEI on population, water resources and A lack of transparency towards local people as evidenced by claims that there would be no extension, and by the unannounced ecology and will be included in the Environmental Impact disposal of radioactive waste at nearby Thornhaugh Assessment. The siting of this facility over a major aquifer, and the evident instability of the underlying rock The distance from sources of radioactive waste, and the consequent flouting of the Proximity Principle The inappropriateness of siting such waste near breeding grounds of the Red Kite, especially given the lack of knowledge of the effects of radioactivity on wildlife the public unacceptability

King's Cliffe Parish 15 March 2011 Strongly oppose any application to extend the time and area for proposals on the above Landfill Site and surrounding area. The comments relate to reasons for objection rather than Council comments on the scoping of the EIA. Woodnewton Parish 15 March 2011 The EIA should include a clear statement of the environmental footprint of continued and extended operations of the site. This The impacts on communities is considered predominantly Council should include consideration of the energy and greenhouse gas emissions required to process and landfill wastes together with in the population section of the PEI. The impacts on water the energy and emissions required to transport wastes to the site. resources including the legislative context is considered in the water resources section of the PEI. The risks of traffic Impact on Local Communities: The proposed extension both in time and space of the activities on the site are likely to cause accidents are considered in the traffic assessment section further stress to those living in surrounding communities. Attempts should be made to measure these against the "do nothing of the PEI. All of these issues will be considered in the option" along with any proposed measures for mitigating stress to local communities. Environmental Impact Assessment. Consideration is being given to how the issues with respect to the The existing site and proposed extension overlays a Principle Aquifer; the Lincolnshire Limestone. Much of the formation the environmental footprint of the proposals are best would normally separate this aquifer from the hazardous operations of the site has been removed by past quarrying activities. addressed. The EIA should include consideration of how the location, extension and continuation of the processing and landfilling of the specified wastes at the site pose risks to groundwater quality. These should be particularly examined in the context of the EC Groundwater Directive, the EC Landfill Directive and the Environment Agency's Groundwater Protection Policies.

The EIA should include consideration of the increased risks of accidents on surrounding roads posed by heavy vehicles containing wastes converging on the site.

Transition Kings Cliffe 15 March 2011 Strongly and fundamentally object The comments are an objection rather than comments on the scoping of the EIA. Forestry Commission 15 March 2011 This response provides factual information on related policy which the planning authority may take account of when making its Relevant policy on woodlands is taken into account in the decision. section in the PEI on ecology and will be included in the Environmental Impact Assessment.

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Consultee Date of Summary of the issues/comments. Comment regarding how the scoping comments will Response be addressed Collyweston Parish Council 16 March 2011 Contradiction: without existing permission for LLW, which Augean does not have, they have already acknowledged that they The comments relate to reasons for objection rather than cannot fill the area they already have before their permission runs out in August 2013. comments on the scoping of the EIA. The status of outstanding and the current planning applications together Whilst other applications are running concurrently (including the Appeal on the LLW decision), to allow this proposal to go ahead with the reasons for the submission of two separate now might influence perceptions of the other applications, one way or the other. The Parish Council is keen to maintain clarity for applications are explained in sections 1 to 3 of the PEI. the sake of all the local authorities involved – and for the sake of the public understanding.

The potential for confusion about the LLW application, the area and time extension application, the 3-year time extension application (designed to try to avoid another Appeal on the area and time extension due to nondetermination) is huge.

Some people feel that this sense of confusion may not be accidental, and point to the likelihood that further time and area extension applications should be expected in the future, ad infinitum

Given the lack of communication from the Environment Agency recently, regarding the delivery of LLW to Augean’s site at Thornhaugh, the members no longer feel confident to trust that they are being told neither everything relevant, nor that rules and permits are necessarily being abided by as fully as we used to believe.

Wansford Parish Council 16 March 2011 Wansford Parish Council would like to draw your attention to the volume of traffic and transportation of waste being carried at the These issues are taken into account in the traffic impact moment and how this will increase. There are a number of other developments being planned in the A47 corridor and we are assessment of the PEI and will be included in the concerned that the cumulative effect will be to increase the number of accidents in this road. Environmental Impact Assessment.

Stamford Town Council 17 March 2011 No comments offered. Stamford Town Council sympathises with the neighbouring villages who are objecting to the application.

Easton on the Hill Parish 17 March 2011 Parish Council considers the scoping report has been very thorough and covers all aspects of the consequences of the Council proposals and as such is a valid Scoping Report

Environment Agency 18 March 2011 The ES needs to consider all sources of flooding and provide a summary based on a referenced Flood Risk Assessment (FRA). A Flood Risk Assessment is included in the PEI and will The FRA must demonstrate that surface water run-off can be managed and the proposed surface water drainage system can be included in the Environmental Impact Assessment. An cope with a 1% event with climate change without increasing flood risk to the site, surrounding area and third parties. The FRA appropriate Environmental Permit will be obtained for must also demonstrate that post development run-off does not exceed pre-development rates and volumes. waste management operations if planning consent is granted. We ask that our Pollution Prevention Guidelines, are considered. Under the terms of the Land Drainage Act 1991 the prior written consent of the Environment Agency is required for any works which may impede the flow of water within a non main watercourse by way of a Flood Defence Consent.

Any development that costs over £300,000 requires a Site Waste Management Plan required under Site Waste Management Plans Regulations 2008

Business accumulating and/or disposing of radioactive waste must have a permit known as an Authorisation.

Natural England 18 March 2011 The Environmental Statement should include an assessment of any direct and indirect effects of the development on the features These issues are addressed in the ecology section of the of special interest for all SSSIs within 5km of the application site boundary. In particular, we would want to see impacts from any PEI and will be included in the Environmental Impact gaseous and particulate emissions and impacts on hydrology fully assessed for the biological features within Collyweston Great Assessment. Wood and Easton Hornstocks SSSI, Bonemills Hollow SSSI and Bedford Purlieus SSSI. Where negative impacts are identified the assessment should include proposals for avoidance, mitigation and compensation.

Natural England would wish to see details regarding local landscape character areas mapped at a scale appropriate to the development site as well as any relevant management plans or strategies pertaining to the area. The EIA should include assessments of visual effects on the surrounding area and landscape together with any physical effects of the development, such as changes in topography.

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Consultee Date of Summary of the issues/comments. Comment regarding how the scoping comments will Response be addressed The EIA should include an assessment of the potential impacts of the development on local landscape character using landscape assessment methodologies.

The Environmental Statement should include an assessment of the likely impacts on Local Wildlife Sites. The assessment should include proposals for mitigation of any impacts and if appropriate, compensation measures.

We recommend that relevant and appropriate surveys for protected species (including, for example, great crested newts, reptiles, birds, water voles, badgers and bats) should be carried out within the area affected by the development. Natural England advises that a habitat survey (equivalent to Phase 2) is carried out on the site, in order to identify any important habitats present. In addition, ornithological, botanical and invertebrate surveys should be carried out at appropriate times in the year, to establish whether any scarce or priority species are present. The Environmental Statement should include details of: Any historical data for the site affected by the proposal (e.g. from previous surveys); Additional surveys carried out as part of this proposal; The habitats and species present; The status of these habitats and species (e.g. whether BAP priority habitat);

The EIA should include an impact assessment to identify, describe and evaluate the effects that are likely to result from the project in combination with other projects and activities that are being, have been or will be carried out. The direct and indirect effects of the development upon those habitats and species; Full details of any mitigation or compensation that might be required Health Protection Agency 18 March 2011 The EIA should give consideration to best practice guidance such as the Government’s Good Practice Guide for EIA. It is The issues are addressed in the PEI. Discussions will be important that the EIA identifies and assesses the potential public health impacts of the activities at, and emissions from, the held with the HPA to agree the level of detail that will be installation. Assessment should consider the development, operational, and decommissioning phases. presented in the Environmental Impact Assessment. The EIA should provide sufficient information for the HPA to fully assess the potential impact of the development on public health. The main alternatives considered should be outlined in the ES. The ES should clearly identify the development’s location and the direction and distance of off-site receptors that may be affected by emissions from, or activities at, the development. Any assessment of impacts arising from emissions due to construction and decommissioning should consider potential impacts on all receptors and describe monitoring and mitigation during these phases. Construction and decommissioning will be associated with vehicle movements and cumulative impacts should be accounted for. When considering a baseline (of existing environmental quality) and in the assessment and future monitoring of impacts these: • should include appropriate screening assessments and detailed dispersion modelling where this is screened as necessary • should encompass all pollutants which may be emitted by the installation in combination with all pollutants arising from associated development and transport, ideally these should be considered in a single holistic assessment • should consider the construction, operational, and decommissioning phases • should consider the typical operational emissions and emissions from start-up, shut-down, abnormal operation and accidents when assessing potential impacts and include an assessment of worst-case impacts • should fully account for fugitive emissions • should include appropriate estimates of background levels• should identify cumulative and incremental impacts (i.e. assess cumulative impacts from multiple sources), including those arising from associated development, other existing and proposed development in the local area, and new vehicle movements associated with the proposed development; associated transport emissions should include consideration of non-road impacts (i.e. rail, sea, and air) • should include consideration of local authority, Environment Agency, Defra national network, and any other local site-specific sources of monitoring data • should compare predicted environmental concentrations to the applicable standard or guideline value for the affected medium (such as UK Air Quality Standards and Objectives and Environmental Assessment Levels) If no standard or guideline value exists, the predicted exposure to humans should be estimated and compared to an appropriate health-based value (a Tolerable Daily Intake or equivalent). Further guidance is provided in Annex 1 This should consider all applicable routes of exposure e.g. include consideration of aspects such as the deposition of chemicals emitted to air and their uptake via ingestion• should identify and consider impacts on residential areas and sensitive receptors (such as schools, nursing homes and healthcare facilities) in the area(s) which may be affected by emissions, this should include consideration of any new receptors arising from future development When considering a baseline (of existing air quality) and in the assessment and future monitoring of impacts these

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Consultee Date of Summary of the issues/comments. Comment regarding how the scoping comments will Response be addressed :• should include consideration of impacts on existing areas of poor air quality e.g. existing or proposed local authority Air Quality Management Areas (AQMAs) • should include modelling using appropriate meteorological data (i.e. come from the nearest suitable meteorological station and include a range of years and worst case conditions) • should include modelling taking into account local topographyWhen considering a baseline (of existing water quality) and in the assessment and future monitoring of impacts these: • should include assessment of potential impacts on human health and not focus solely on ecological impacts • should identify and consider all routes by which emissions may lead to population exposure (e.g. surface watercourses; recreational waters; sewers; geological routes etc.) • should assess the potential off-site effects of emissions to groundwater (e.g. on aquifers used for drinking water) and surface water (used for drinking water abstraction) in terms of the potential for population exposure • should include consideration of potential impacts on recreational users (e.g. from fishing, canoeing etc) alongside assessment of potential exposure via drinking waterRelevant areas outlined in the Government’s Good Practice Guide for EIA include: • effects associated with ground contamination that may already exist • effects associated with the potential for polluting substances that are used (during construction / operation) to cause new ground contamination issues on a site, for example introducing / changing the source of contamination • impacts associated with re-use of soils and waste soils, for example, re-use of site-sourced materials on-site or offsite, disposal of site-sourced materials offsite, importation of materials to the site, etc.Potential noise, odour, vermin and dust nuisance should be included within the EIA. The methodology for this should be agreed with the local authority environmental health department.The EIA should demonstrate compliance with the waste hierarchy (e.g. with respect to re-use, recycling or recovery and disposal).For wastes delivered to the installation: • the EIA should consider issues associated with waste delivery and acceptance procedures (including delivery of prohibited wastes) and should assess potential off-site impacts and describe their mitigationFor wastes arising from the installation the EIA should consider: • the implications and wider environmental and public health impacts of different waste disposal options • disposal route(s) and transport method(s) and how potential impacts on public health will be mitigatedWithin the EIA the HPA would expect to see information about how the developer would respond to accidents with potential off-site emissions e.g. flooding or fires, spills, leaks or releases off-site. Assessment of accidents should: identify all potential hazards in relation to construction, operation and decommissioning; include an assessment of the risks posed; and identify risk management measures and contingency actions that will be employed in the event of an accident in order to mitigate off-site effects.The EIA should include consideration of the COMAH Regulations (Control of Major Accident Hazards) and the Major Accident Off-Site Emergency Plan (Management of Waste from Extractive Industries) (England and Wales) Regulations 2009: both in terms of their applicability to the installation itself, and the installation’s potential to impact on, or be impacted by, any nearby installations themselves subject to the these Regulations.The HPA supports the inclusion of health risk perception and environmental problems information within EIAs as good practice.The HPA expects promoters to carry out the necessary radiological impact assessments to demonstrate compliance with UK legislation and the principles of radiation protection. This should be set out clearly in a separate section or report and should not require any further analysis by the HPA. In particular, the important principles of justification, optimisation and radiation dose limitation should be addressed. In addition compliance with the Euratom BSS and UK legislation should be clear.The radiological impact of the disposal of radioactive waste in the site should be addressed in an assessment to ensure that this complies with UK practice and legislation; information should be provided on the category of waste involved (e.g. low level waste, LLW) and the activity concentrations and radionuclide composition.The HPA advises that assessments of radiological impact during the operational phase should be performed in the same way as for any site authorised to discharge radioactive waste: including doses to workers and doses to members of the public from any discharges.The HPA also advises that assessments of radiological impact during the post operational phase of the facility should consider long timescales (possibly in excess of 10,000 years) that are appropriate to the long-lived nature of the radionuclides in the waste.The radiological assessment should consider exposure of members of hypothetical representative groups (people expected to receive the highest exposures) for a number of scenarios including the expected migration of radionuclides from the facility, and inadvertent intrusion into the facility once institutional control has ceased.The results should be compared with the relevant criteria specified by the environment agencies. In particular, application of the optimisation principle should be demonstrated.Assessments of the radiological impact of routine discharges of radionuclides to the environment (relevant to the operational and institutional control phases) should consider the dose to the representative person (those members of the public who are likely to receive the highest exposures). Different age groups should be considered as appropriate and should normally include adults, 1 year old and 10 year old children. In particular situations doses to the fetus should also be calculated. The estimated doses to the representative person should be compared to the appropriate radiation dose criteria (dose constraints

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Consultee Date of Summary of the issues/comments. Comment regarding how the scoping comments will Response be addressed and dose limits), taking account of other releases of radionuclides from nearby locations as appropriate. Collective doses should also be considered for the UK, European and world populations where appropriate.The methods for assessing individual and collective radiation doses should follow the guidance given in ‘Authorisation of discharges of radioactive waste to the environment Principles for the assessment of prospective public doses. Interim Guidance, December 2002’ It is important that the methods used in any radiological dose assessment are clear and that key parameter values and assumptions are given (for example, the location of the representative persons, habit data and models used in the assessment). Liaison with other stakeholders, comments should be sought from: • the local authority regarding any site investigation and subsequent construction (and remediation) proposals to ensure that the site could not be determined as ‘contaminated land’ under Part 2A of the Environmental Protection Act 1990 • the local authority should be consulted regarding any impacts on existing or proposed Air Quality Management Areas • the Food Standards Agency for matters relating to the impact on human health of pollutants deposited on land used for growing food/ crops • the Environment Agency for matters relating to flood risk and releases with the potential to impact on surface and groundwaters • the Environment Agency for matters relating to waste characterisation and acceptance.

Harringworth Parish 18 March 2011 On behalf of Harringworth Parish Council I wish to register our objection to the following applications These cover the Kingscliffe The comments comprise a statement of objection rather Council site and refer to the scope and content of the applications for the site. than comments on the scoping of the EIA.

English Heritage 18 March 2011 We recommend that there should be a close integration of the cultural heritage assessment with the landscape and visibility These issues are included in the landscape impact assessment assessment so that appropriate cultural receptors are identified and representative viewpoints are selected. section of the PEI and will be included in the Environmental Impact Assessment. The scope of the cultural heritage assessment should be determined in accordance with national and local policy guidance and on the basis of your specialist conservation advice.

The Wildlife Trusts 18 March 2011 The Wildlife Trust recommends that at least an Extended Phase 1 Habitat Survey be carried out, and that all Statutory and Non- The issues are addressed in the PEI and will be included Statutory sites, protected species and other relevant species and habitats be fully investigated and evaluated in the Environmental Impact Assessment.

Within a selected Zone of Interest of 2 kilometres radius out from the assumed centre of this proposed Application Site, there are several non-statutory designated sites – including Local Wildlife Sites, Potential Wildlife Sites and even also a Local Geological Site too. In fact, there is a PWS contained within the red-line footprint boundary of this Application Site itself. There are also other areas of Ancient Woodland habitats within this same ZoI too. These issues are Material Considerations within the context of the Planning System, and thus, the potential for both detrimental impacts upon these wildlife site areas ( both existing and potential ) and for the possibility to deliver biodiversity enhancements to them, as well as to the Application Site itself, must all be comprehensively investigated and addressed before the eventual determination decision-making process can be properly carried-out in respect of these two related development proposals.

Consideration may well need to be given to the issue of whether or not there is going to be any significant degree of increased artificial lighting levels occurring as a result of the delivery of this proposed development scheme, and if so, the ways in which it might have an impact upon the local biodiversity – such as bat species, for example.

The EIA should include proposals for ecological mitigation linked to the during- and post-construction impacts and should suggest the content of Planning Conditions and ecological sections of S106 Agreements if applicable.

The EIA should consider the long-term management of all green spaces.

Any soft landscaping elements that it is intended to include within this development proposal should be provided for by the use of native species ( of plants, shrubs and trees ) only. Ideally, these species should be chosen as ones that are typical of that part of the county and they should all only be sourced from a local and a known provenance. These areas should be managed for the benefit of wildlife.

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Consultee Date of Summary of the issues/comments. Comment regarding how the scoping comments will Response be addressed The Wildlife Trust recommends that, in addition to addressing any potential direct / indirect impacts as a sole result of their own development scheme, the Applicant also be required to include, in this section of the supporting documentation, a comprehensive review of just what the likely effects of the provision of their facilities is going to be upon the existing biodiversity at this location in combination with all of the other relevant encroaching development pressures in this area of the District.

We strongly recommend that you seek consultation with Natural England concerning both the conservation issues relating to this species (Great Crested Newts) and also the required Licensing arrangements.

You may also wish to consider, given its size, location and scope, whether the plans for these projects should also be the subject of a Strategic Environmental Assessment and a Sustainability Appraisal as well.

Northamptonshire County 23 March 2011 The Environmental Statement must include the information included in Part II of Schedule 4 to the Town and Country Planning The issues are taken into account in the PEI and will be included Council Planning Services (Environmental Impact Assessment) Regulations 1999. Information in Part I required to assess the environmental effects of the in the Environmental Impact Assessment. development should include indirect and any indirect, secondary, cumulative, short, medium and long-term, permanent and temporary and positive and negative effects of the development resulting from the existence of the development. The ES should include a comprehensive description of the measures proposed to prevent, reduce and offset adverse effects on the environment. The ES should include a description of likely significant effects outlined in point 3 of Part I of Schedule 4.

In my opinion the cumulative effect of the extended timescale of the waste disposal activities on social cohesion and economic potential should not be included in the ES. I note there are no current proposals to consider the impacts on Green Infrastructure. Guidance on the information that should be included is available in the Development Implementation Principles SPD.

Impacts of potential effects on air quality should not be limited to effects on the human population but consider effects on ecology and the interaction between effects.

An assessment of the long term, medium and short term, permanent, temporary, direct and indirect, positive and negative effects on landscape should all be provided in accordance with EIA and landscape and visual assessment guidance.

Phase 1 habitat survey should be carried out in-line with JNCC guidance and up-to-date best practice, rather than US Institute of Environmental Assessment Guidance. We would prefer the ecological impact assessment be carried out using the IEEM guidance, or to an equivalent standard if necessary. Particular consideration should be given to the Conservation of Habitats and Species Regulations 2010 rather than the 1994 Conservation (Natural Habitats, &c.) Regulation. Consideration should also be given to local BAP and Habitats and species of principal importance. Up-to-date survey records should be sought from relevant County Recorders and the Northamptonshire Biological Records Centre.

Corby Borough Council 23 March 2011 The proposed baseline for the ES (not the Section 73 application) being the currently permitted activities on site is not Consideration is being given to the inclusion of these issues in appropriate and the baseline of ceased activities should be used in order to fully assess the full environmental impact of the the Environmental Impact Assessment. proposed development.

The proposed time frame for operational development of the site until 2026 means there is likely to be significant alterations to traffic usage on the A43 as a result of the North East Sustainable Urban Extension to Corby (Priors Hall, Weldon Park) and

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Consultee Date of Summary of the issues/comments. Comment regarding how the scoping comments will Response be addressed possible future development at Deene Thorpe Airfield. The ES should consider the cumulative effect of these developments particularly in regards to the A43 and transport section.

East Northamptonshire 24 March 2011 At this stage, this Authority would make the following comments on the proposed considerations within the EIA: The issues are taken into account in the PEI and will be included Council in the Environmental Impact Assessment. Ecology As acknowledged within the Scoping Report (SR), the site is adjacent to an SSSI and a NNR. Consideration should be given to the need for updated species and habitats surveys in order to understand the current baseline position and consequently the potential impacts on flora and fauna. It is acknowledged that Natural England, as the relevant experts in this field, will provide detailed advice; however, consideration should be given to the need to assess the impact on ecological receptors from air quality and dust, surface waters and geology, and hydrogeology and soils.

Water Resources As the relevant Statutory Authority, the Environment Agency will no doubt advise further.

Amenity The identified assessments are considered appropriate. Air quality, dust and odour should be controlled and monitored in accordance with the environmental PPC permit.

Noise The Council's Environmental Protection section has agreed the monitoring locations. The proposed methodology is the correct set of guidance in this instance.

Traffic and Transport As the relevant Statutory Authority, early liaison with Northamptonshire County Council is supported. This approach is identified in the SR.Effects on people The SR states that an assessment of the risk to public health will be assessed. Details of the SNIFFER methodology are outlined and this is considered to be an appropriate approach on this site.

Other Matters In addition to the above, it is considered that further detail should be provided in terms of how the local environmental impacts of the LLW disposal are to be monitored. This Authority is particularly concerned about the future management of the site and how it will be ensured that the associated risks are properly managed for future generations.

The comments have been made on the basis of the information available at this time; please be aware that the view may change or this Authority may wish to make further comments in light of further information or advice from experts for the various relevant considerations.

Milton Keynes Council 8 April 2011 I refer to your consultation, received on 16th February 2011. The Council has no objection to the works detailed in your consultation.

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