From: Amy Ogden To: Mike Hankin

Contact Officer: Team Leader Your Ref: F/3696

Contact: 01909 533533 Date: 25/7/17

Revised 31/7/17

Second revision 10/10/17

Re: Application for the Continued Use of the Existing Industrial Site and Buildings for the Production of a Range of Wood Fuel Products and for the Importation and Processing of Wastes to Produce a Range of Recovered Fuel Products.

LOCATION: Land at Headon Camp Industrial Estate, Lady Well Lane, Headon, , DN22 0PA

Reference: F/3696

Background

Bassetlaw District Council have been in receipt of complaints from members of the public Revised 10/10/2017 about Retford Wood Fuels Ltd since May 2017. There is another company on the same site NCC Received 10/10/2017 called Retford Waste to Energy Ltd. The Council are investigating complaints of smoke, dust and noise from both operations. Officers from Environmental Health visited the site on Monday 26th June and met their consultant. It was established that the two companies are operating around 100 wood fueled boilers which are located in two existing buildings on the site. The furnaces are being used to generate heat which is ducted into shipping containers where crates of pre-cut timber logs are air dried. The company also make a pellet fuel from compressed wood fibers.

Initial Concerns 25th July 2017) A number of chimneys were smoking throughout the duration of my initial visit on the 26th June (60 minutes). It didn’t appear that the staff on site knew how to prevent the chimneys from smoking. I had visited the site a week earlier and parked near the entrance for 20 minutes. Throughout this visit a number of the chimneys were smoking continually and after leaving the site my hair, clothes and inside of my car smelt of smoke. My first impression was that the chimneys appear to be very low in relation to the buildings. Officers have witnessed the smoke plumes being released from the chimneys at very low velocity, grounding close by and creating a smoky haze at ground level around the whole site. On one occasion smoke could be seen rolling down the roof of the building after being released from one of the chimneys. This suggests that the chimneys are too low and not achieving adequate dispersion. There was also an occasion where smoke was seen escaping through the eaves of the building and through the open roller shutter door. Fugitive emissions such as these add to the permanently smoky smell and reduced visibility in the air around the site.

The number of chimneys installed at one location gives very serious cause for concern. The cumulative impact of a significant number of wood fueled appliances operating simultaneously at one location in the immediate vicinity of residential properties has not been considered.

Current Position (10th October 2017) Observations carried out during June/July 2017 confirmed that the smoke emissions from the site were causing a statutory nuisance. These observations were backed up by weeks of records provided by the residents along with photos and videos. An abatement notice was served on the company/s on Monday 10th July 2017 requiring immediate abatement of the smoke.

Since then the company have made considerable improvements to the site and addressed many of the issues which Council believed were contributing to the problems. The main issues were the working practices at the site which were causing the boilers to be loaded, stoked and operated incorrectly. The Council also had concerns about the fuel and how this was handled in the time it was stored on site. This was causing increased levels of smoke beyond what is reasonable and/or expected from this type of appliance. The chimneys on the low side of the building were also below the optimum height and these have since been increased in height by 1 metre. With these and other improvements the site has seen a considerable reduction in smoke, however, some smoke still remains especially during start up and shut down. This remains a concern to the residents and is still impacting on their lives.

Because the company have co-operated with the council requests and made all reasonable steps to abate the nuisance, the notices served on the 10th July 2017 have been withdrawn.

Revised 10/10/2017

NCC Received 10/10/2017 Noise Bassetlaw District Council are in receipt of complaints about noise nuisance from this site. These complaints have not been substantiated by officers of the council, but evidence provided by complainants suggest that there may be issues with noise effecting nearby residential properties. When this development started operating there was no consultation by the developers with Environmental Health on the likely impacts on residents and consequently no pre-commencement conditions could be applied to ensure noise was not a factor to be considered.

As such I would strongly recommend that a comprehensive noise survey be carried out on the site prior to planning permission being granted to identify any probable impacts on local residents. The report should follow the principles of BS 4142 (2014),"Methods for Rating and Assessing Industrial and Commercial Sound" (replacing the earlier 1997 standard). This standard approach complements and supports both UK planning guidance and Environment Agency guidance; it describes methods for rating and assessing sound of an industrial or commercial nature enabling the effects on people nearby to be assessed and the associated risks to be minimised.

For sites regulated under the EU's Waste Framework Directive there is a requirement to ensure that processes are regulated to ensure that they do not cause noise nuisance; relevant conditions are included in waste management permits. As this site is a waste site then consideration must also be given to Horizontal Guidance (H3 Noise Assessment and Control) produced by the regulatory agencies outlines the main considerations relating to the permitting and regulation of noise and vibration from industrial installations.

Industrial Regulation Industrial processes of this type may be subject to regulation under the provisions of the Pollution Prevention and Control Act 1999 (and associated regulations). There may also be a requirement for the applicant to produce an Environmental Impact Assessment under the provisions of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011. This is primary legislation which controls the emissions from such activities through the issue and enforcement of an Environmental Permit.

The permit covers any aspects of the sites operations which can cause emissions, including those to air, land and water. The permit must also consider the need to reduce noise and improve energy efficiency.

The process operator must apply to the relevant regulatory authority for an Environmental Permit prior to commencement of operations. The application for a permit can either be done in parallel with any planning application, or applied for once planning permission is granted and before operations commence. The precise nature of the operation and the likely emissions associated with the site dictates whether the permit is regulated by the Local Authority or the Environment Agency. In the case of applications for energy generation plants or minerals extraction plant, the Environment Agency is the appropriate agency.

Odour Of particular concern with this application is the treatment of waste with heat and the likely odour releases associated with this operation. Consideration should be given by the applicant to the types of odours which may be released and any abatement measures which may be appropriate. An odour assessment and odour management plan should be completed prior to planning permission being granted. Guidance on odour assessment and control (with Revised 10/10/2017 particular relevance to IPPC applications) was issued in 2002, with a revised version publishedNCC Received 10/10/2017 in 2011 by the Environment Agency; H4 Odour Management provides advice on regulatory requirements and advice on the management of odour and what the odour management plan should include. Defra has also produced an Odour Guidance for local authorities (March 2010); this explains the basic properties of odour and identifies common sources; it explains the legal and regulatory framework of preventing and controlling odour; and explains the administrative and practical control measures available to local authorities. An odour assessment carried out by the applicant should have specific reference to the odour guidance (H4) and the local authority odour guidance.

Yours sincerely,

Amy Ogden BSc. (Hons) MCIEH MEHRB Environmental Health Team Leader

Bassetlaw District Council Queens Building Potter Street S80 2AH

Tel: 01909 533533

Revised 10/10/2017 NCC Received 10/10/2017