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Waste Recovery Plan

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Waste Recovery Plan ENVIRONMENTAL PERMIT APPLICATION WASTE RECOVERY PLAN BLOCKADE SERVICES LTD SOUTH GODSTONE QUARRY (PHASE 4) LAMBS BUSINESS PARK SOUTH GODSTONE SURREY RH9 8LJ JULY 2019 envee ...making business green Blockade Services Ltd Permit Application CONTENTS 1.0 INTRODUCTION 2.0 SITE HISTORY 3.0 REQUIREMENT TO IMPROVE 4.0 WASTE PROPOSALS 5.0 PROPOSED WASTE TYPES 6.0 POTENTIAL FOR CONTAMINATION 7.0 AMOUNTS OF WASTE 8.0 LIMITS OF WASTE ACTIVITY 9.0 RECOVERY AND INTENDED USE 10.0 CONCLUSIONS APPENDIX A – HISTORIC LANDFILL DATA 1 EA historic landfill data APPENDIX B – PLANNING DOCUMENTS 1 Letter from Surrey County Council dated 12 February 2016 2 Planning consent TA/99/155 dated 30 August 2002 3 Soil handling Discharge of condition 12 TA/99/155/D1 dated 20 June 2003 4 Pre-settlement contours discharge of condition 15 TA/99/155D 04 July 2003 5 Drainage scheme discharge of condition 18 TA/99/155/D2 dated 15 October 2003 6 Aftercare and Landscape discharge of condition 22 & 25 TA/99/155/D4 dated 28 September 2005 7 Working Method Statement Planning Consent TA/99/155 8 Surrey County Council Planning and Regulatory Committee report dated 21 February 2001 Item 16 and Annex A 9 Extracts from email from SCC dated 17 June 2015 10 Section 106 Agreement dated 08 August 2002 APPENDIX C – CROSS SECTIONS Waste Recovery Plan - July 2019 2 Blockade Services Ltd Permit Application 1.0 INTRODUCTION This waste recovery plan is to support the application for an environmental permit for Blockade Services Ltd at South Godstone Quarry, Lambs Business Park, South Godstone, Surrey, RH9 8LJ. The permit is required to achieve the restoration of the Phase 4 void area of the quarry, shown in Figure 1 below, which is a clay pit that has been formed by the removal of minerals associated with former brickworks operations on site. The quarry is subdivided into Phases for planning purposes, which coincides with previous extraction and ancillary operational activity, and are referred to throughout this document. Fig 1: Phasing plan for the entire site. The Phase 4 void is formed in virgin clay where extraction has taken place in the past. There is also an historical landfill covering part of the proposed permitted area. Also, Environmental Permit EPR/EB3107CQ has areas in the same Phase. This permit is for aggregate production and dewatering of the lagoon. These permits are in place to aid with the restoration of the quarry. The Waste Framework Directive provides that imported inert material required to create the approved restoration landform, and construct the lakes required by the restoration scheme, involves waste replacing other materials which would otherwise have been used and is therefore in accordance with the definition of recovery under Article 3(15) of the Directive. The central NGR for the site is TQ 34759 48458. The proposed environmental permit is a Tier 3 bespoke based on the Standard Rules SR2015No39. This is to take into account the amount of waste material required. Waste Recovery Plan - July 2019 3 Blockade Services Ltd Permit Application Although referred to as Phase 4, this is the second area to be permitted. Phase 2 is permitted under EPR/EB3400MB, a recovery permit issued in November 2016. The activities were deemed to be recovery and now the Phase is almost completed to the approved levels. The activities proposed for Phase 4 are identical as Phase 2, to recover waste to restore the quarry to the approved levels. Much of the previous WRP will be relevant to this one. This plan has been written using the guidance of the Environment Agency’s guidance. The types and amounts of waste are specified in this Waste Recovery Plan. Cross- sections and profiles have been produced to demonstrate both current and the proposed landform levels. Reference has also been made to the Methley case, (R (Tarmac Aggregates Ltd) v Secretary of State for Environment, Food and Rural Affairs [2016] Env. L R 15), as the restoration requirements in that case have parallels with the restoration obligations at Godstone as advised by the EA. The main aspect of the engineering operation is to import inert materials for use in restoration of Phase 4 of the site. This inert material is required for restoration of the former quarry works needed to return the site to the approved productive use for nature conservation. 2.0 SITE HISTORY Lambs Business Park and former brickworks lies within open countryside and arable farmland to the west of South Godstone village. The former brickworks extend to 8.2 hectares and is made up of a disused quarry and associated ancillary land and buildings. There is a railway siding to the north of the site which branches from the mainline. The land has been cleared of the majority of weed and scrub growth vegetation, self- set since the site was last operational, to prepare for the restoration works. Much of the lagoon in Phase 4 has now been dewatered. The quarry and associated workings have been in existence since 1898. Previously waste was used as an infill material in parts of Phase 4 from 31 August 1981 until 31 December 1996. This was conducted under an environmental permit registered to W T Lamb & Sons Ltd, the landowner. Only inert waste materials were imported into Phase 4 and used in the previous infilling works and the restoration of this area far from complete. As alluded to in the WRP for Phase 2, a separate WRP (this document) would be forthcoming for Phase 4. The historic landfill is referred to in Appendix A. Waste Recovery Plan - July 2019 4 Blockade Services Ltd Permit Application Fig 2: Environment Agency data showing historic landfill. The approved final restoration scheme profile for the site, including phases 2, 3 and 4, is a gentle downwards slope from north to south, to marry in with the existing levels in the woodland to the south of the site close to Phase 1, with the creation of meadow areas, planting of broadleaf trees and shrubs as well as coniferous planting and scrub vegetation to support nature conservation and including the creation of water bodies for enhanced biodiversity. The approved restoration scheme was devised with the directional engagement of Surrey County Council and using independent landscape specialists. All of the relevant planning documents are included as Appendix B of this document. The scheme was devised, geared towards woodland and amenity lakes, to minimise the amount of inert material required and reduce it from what would be needed if the site were to be returned to agriculture. The Planning and Regulatory Committee (PRC) report contained in Appendix B(8) summarises the development proposal and consultation responses including specific considerations in Appendix B also included in Appendix B(8). The report notes that the scheme ensures the minimum amount of material is required to achieve the scheme which enhances the conservation value of the site and the County Landscape Architect concludes it would “lead to a substantial enhancement locally of landscape and ecological aspects” (PRC para 31). The nature conservation qualities of this restoration scheme will enhance the surrounding environment to the west and south. This scheme remains relevant and current to date and Surrey County Council has reaffirmed its requirement for the site to be restored strictly in accordance with the approved scheme as indicted in the letter in Appendix B(1) dated 12th February 2016. Planning consent was approved by Surrey County Council for the continuation of winning and working of brick clay from an area of 5.64 hectares, incorporating Phases 1, 2 and 3 as indicated on Figure 3 below, with provision for restoration through Waste Recovery Plan - July 2019 5 Blockade Services Ltd Permit Application importation of inert material only. At the time of determination SCC recognised the “balance which needs to be struck between the beneficial use of inert material for site restoration and their potential use in place of primary aggregates” (PRC para 34) and the planning consent, and Section 106 agreement, does not distinguish between the use of waste and non-waste in achieving the restoration of this site. The expectation is for the site to be restored and that this should not be delayed. SCC’s expectation is unchanged as referred to in section 3 below. A copy of the Decision Notice, TA/99/155 dated 30 August 2002, is included within this document as Appendix B(2). Plans were put into place to restore the quarry works. Consent TA/99/155 required discharge of conditions relating to soil placement, pre settlement contours, drainage scheme, landscaping scheme and aftercare scheme. These schemes encompass all the details of how the restoration will be achieved including planting and layout of the compartment areas of the site. All conditions were discharged and are referred to in more detail in section 3 below and the approved documents are appended to this WRP in B(3), B(4), B(5) and B(6). Restoration of the consented area, Phases 1 to 3, and an additional adjacent operational area, outside of this governed by a separate planning consent, Phase 4, were made subject of a Section 106 legal agreement, included in Appendix B(10). Planning permission allows development to proceed and the section 106 agreement in this case makes that permission a legally binding obligation. This strengthens the County Council’s ability to enforce against non-completion of restoration. This cannot be achieved without the necessary recovery permit. Blockade Services Ltd has been appointed to complete the works. The company will be the sole contractor for the project. The company operates the inert waste recycling and aggregate production facility at South Godstone Quarry and also the recovery permit for Phase 2.
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