Environmental Permit Application
Rory J Holbrook Limited Lakenheath Country Club, Hereford Road, Brandon, Suffolk, IP27 9PP.
Environmental Permit Application Report: Version 1, November 2020
Document Control Table
Project Reference 18/014c
Project Title Lakenheath Bund: WR Permit Application
Document Title Environmental Permit Application Report: Version 1, November 2020
Document Issue No. 1
Document Issue Date 19 November 2020
Client Rory J Holbrook Limited
Status Issue
Report Produced by/Date Georgina Watkins 12 November 2020
Report Checked by/ Date Kate Brady 13 November 2020
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Environmental Permit Application Report: Version 1, November 2020
Contents 1. Introduction ...... 1 2. Site location and setting ...... 2 3. Operator details ...... 3 4. Non-technical summary of waste operations ...... 4 Existing Operations ...... 4 Proposed Operations ...... 4 5. Operational processes ...... 5 6. List of waste codes ...... 6 7. Site management ...... 8 Environmental Management System (EMS) ...... 8 Environmental Management System Report ...... 8 Technically Competent Management ...... 10 8. Condition of the Site and risk assessments ...... 11 Site Condition ...... 11 Environmental Risk Assessment ...... 11 Dust Management Plan ...... 11
Tables Table 6.1 Waste types ...... 6
Drawings
Drawing No. 18/014c 001 Permit Boundary Plan
Appendices
Appendix 1 Enhanced Pre-application Advice
Appendix 2 Evidence of Technically Competent Management
Appendix 3 Environmental Setting and Site Design Report
Appendix 4 Dust Management Plan
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Environmental Permit Application Report: Version 1, November 2020
1. Introduction
1.1. This Environmental Permit application seeks to apply for a new bespoke Environmental Permit at Lakenheath Country Club, Hereford Road, Brandon, Suffolk, IP27 9PP (the Site). This application has been completed by Westbury Environmental Limited on behalf of Rory J Holbrook Limited (the Operator).
1.2. Lakenheath Country Club is home to a clay shooting centre. Landscaping at the Country Club is considered required to:
• Dampen noise from the shooting centre. This is necessary, as a three-storey dormitory for USAF personnel is located north of the shooting ground on the RAF Lakenheath Base. • Provide security to the Country Club. • Improve health and safety on Site and for those working on adjacent farmland. • Increase vantage points for spectators of shooting events. • Benefit wildlife in the surrounding protected area.
1.3. Planning permission for a bund at Lakenheath Country Club was initially granted on 7 August 2006 by Forest Heath District Council. On 31 March 2009 further planning permission was granted to allow for bunding to be developed on the eastern boundary of the Country Club.
1.4. A Waste Recovery Plan for the Site was completed by Westbury Environmental Limited, see Appendix 3 Environmental Setting & Site Design (ESSD) Report – App1 Waste Recovery Plan.
1.5. The Waste Recovery Plan was deemed to be a "recovery" activity by the Environment Agency on 13 January 2020. The RvD Pre-Application Advice Letter EPR/JB3001MP/A001 has been provided as Appendix 3 ESSD Report- App2 EA Recovery Opinion. There have been no changes to the proposal since the RvD Pre-Application Advice Letter was received.
1.6. Due to the volume of waste to be deposited (c. 788,120m3) and location of the bund, the Site does not meet the criteria for a Standard Rules 2015 No. 39 Environmental Permit and therefore a bespoke Environmental Permit is being applied for.
1.7. The relevant Environment Agency forms (Part A, Part B2, Part B4 and Part F1) for a bespoke Environmental Permit are included within this Environmental Permit application.
Pre-application Advice
1.8. Enhanced pre-application advice was requested from the Environment Agency. The Pre-application Advice Letter received stated that a Hydrogeological Risk Assessment and Stability Risk Assessment would be required as part of the permit application and detailed what should be considered in those assessments, see Appendix 1, Enhanced Pre-Application Advice.
1.9. It is considered that the Hydrogeological Risk Assessment and Stability Risk Assessment meet the requirements set in the Pre-Application Advice.
1.10. Both the Hydrogeological Risk Assessment and Stability Risk Assessments are provided as appendices in the ESSD Report.
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Environmental Permit Application Report: Version 1, November 2020
2. Site location and setting
2.1. The Site is located 2.4km to the southeast of Lakenheath.
2.2. The Site is surrounded by agricultural land and protected habitat to the south and east and the RAF Lakenheath Base to the north and west.
2.3. The Site extends to approximately 17ha, see Permit Boundary Plan, Drawing No. 18/014c 001. The proposed bund will surround the country club.
2.4. The Site is located within Groundwater Source Protection Zone 1. The Site is located on a Principal designated bedrock aquifer but not on a designated superficial aquifer.
2.5. There are protected areas located on or within the Site boundary including Breckland Farmland Site of Special Scientific Interest (SSSI) , Breckland Special Protection Area (SPA), Lakenheath Warren SSSI and Breckland Special Area of Conservation (SAC). The protected areas are shown on the Sensitive Receptors Plan, Drawing No. 18/014c 002.
2.6. The closest residential dwelling is located approximately 70m to the northwest of the Site at RAF Lakenheath.
2.7. There are no surface water courses located on the Site. The nearest surface water feature is Caudle Head, approximately 700m to the northwest of the Site.
2.8. An Environmental Setting and Site Design (ESSD) Report has been completed for the Site and is included as Appendix 3.
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Environmental Permit Application Report: Version 1, November 2020
3. Operator details
3.1. Company details for Rory J Holbrook Limited are provided below:
Company Name Rory J Holbrook Limited Company Number 04494452 Registered Address Roudham Road, East Harling, Attleborough, Norfolk, England, NR16 2QN Incorporation Date 25/07/2002 Companies House Link https://find-and-update.company-information.service.gov.uk/company/04494452
3.2. Rory J Holbrook Limited has one director. The name and date of birth information for the director are included below.
Name Date of Birth Rory Joseph Holbrook
3.3. Previous relevant offences against Mr Rory Holbrook are included in the table below. The offences relate to once case held at Kings Lynn Magistrates Court on 16 October 2014.
Date Conviction Amount (£) Contravention of Environmental Permitting Regulations 18,000 Deposit of waste without a permit 12,000 16/10/2014 Costs 20,000 Proceeds of Crime Act 247,278.74
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Environmental Permit Application Report: Version 1, November 2020
4. Non-technical summary of waste operations
Existing Operations 4.1. Part of the bund has been constructed to date. Aggregates produced under the WRAP Quality Protocol: Aggregates from inert waste and compressed / baled tyres have been used in the construction of the bund.
Proposed Operations 4.2. Operations to be carried out at the Site will include the importation and deposit of waste for the construction of a bund as described in the Waste Recovery Plan.
4.3. There is a requirement for approximately 788,120m3 of waste to be used in the construction of the bund in order to be in accordance with the plans included in the planning permissions.
4.4. Strict waste acceptance procedures will be applied on the Site to ensure that only the permitted waste types area accepted, see Appendix 3 ESSD Report – App3 Waste Acceptance Procedures. The List of Waste codes to be accepted at the Site are presented in Section 6 of this Environmental Permit Application Report.
4.5. Waste will be brought onto the Site for use in the construction of the bund. The waste may be stored temporarily or placed directly in the bund.
4.6. There will be no tipping of waste into groundwater.
4.7. There are no proposed waste treatment operations to be undertaken under the Environmental Permit.
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Environmental Permit Application Report: Version 1, November 2020
5. Operational processes
5.1. Imported materials will be subject to strict waste acceptance procedures to ensure that only suitable materials are used in the recovery operations at the Site, see Appendix 3 ESSD Report – App3 Waste Acceptance Procedures.
5.2. Acceptable wastes will be imported onto the Site and placed directly in the construction of the bund or placed temporarily in stockpiles for later use.
5.3. There are no proposed treatment operations to take place under the Environmental Permit.
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Environmental Permit Application Report: Version 1, November 2020
6. List of waste codes
6.1. The List of Waste codes proposed the be accepted onto the Site under the Environmental Permit are listed below:
Table 6.1 Waste types
Exclusions
Wastes having any of the following characteristics shall not be accepted: • Consisting solely or mainly of dusts, powders or loose fibres • Wastes that are in a form which is either sludge or liquid
Waste Source Sub-source Description Additional restrictions code 01 Waste resulting from 01 01 wastes 01 01 02 Wastes from mineral Restricted to waste exploration, mining, from mineral non- metalliferous overburden and quarrying and physical excavation excavation interburden only. and chemical treatment of minerals 01 04 wastes 01 04 08 Waste gravel and from physical crushed rocks other and chemical than those mentioned processing of in 01 04 06 non- metalliferous 01 04 09 Waste sand and clays minerals 02 Waste from 02 04 wastes 02 04 01 Soil from cleaning agriculture, horticulture, from sugar and washing beet aquaculture, forestry, processing hunting and fishing, food preparation and processing 17 Construction and 17 01 concrete, 17 01 01 Concrete demolition wastes bricks, tiles and ceramics 17 01 02 Bricks
17 01 03 Tiles and ceramics
17 01 07 Mixtures of concrete, Metal from reinforced bricks, tiles and concrete must have been ceramics other than removed. those mentioned in 17 01 06 17 05 soil 17 05 04 Soil and stones other Restricted to topsoil, stones and than those mentioned peat, subsoil and stones dredging spoil in 17 05 03 only. 19 Wastes from waste 19 12 wastes 19 12 09 Minerals (for example Restricted to wastes from management facilities from the sand, stones) only treatment of waste mechanical aggregates that are treatment of otherwise naturally waste (for occurring minerals. example sorting, crushing, 19 12 12 Other wastes Including crushed bricks, compacting, (including mixtures of tiles, concrete and pelletising) not materials) from ceramics. otherwise mechanical treatment specified of wastes other than Including soils from the those mentioned in mechanical treatment of 19 12 11 construction / demolition waste.
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Environmental Permit Application Report: Version 1, November 2020
Waste Source Sub-source Description Additional restrictions code Metal from reinforced concrete must be removed.
Does not include gypsum from recovered plasterboard. 20 Municipal wastes 20 02 garden 20 02 02 Soils and stones Restricted to topsoil, (household waste and and park wastes peat, subsoil and stones similar commercial, only. industrial and institutional wastes) including separately collected fractions
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Environmental Permit Application Report: Version 1, November 2020
7. Site management
Environmental Management System (EMS) 7.1. Rory J Holbrook Limited will operate the permitted operations under an EMS.
7.2. A hard copy of the EMS will be kept on the Site at all times.
7.3. The EMS will be committed to:
• Prevention of pollution. • Compliance with permitting regulations. • Continual environmental improvement.
7.4. The EMS folder shall include a copy of the Environmental Permit and will contain the following sections:
Environmental Management System Report This report contains a description of the purpose and scope of the EMS, all Site details including the location of the Site, receptors located in close proximity to the Site boundary, waste storage, the plant and equipment that is used on the Site, the different types of waste treatment activities carried out on Site, the Site security measures, information on the competence of the staff working on Site, roles and responsibilities for each member of staff and details for Site closure.
Appendix 1 – Authorisations A copy of the permit and EA Registrations for the site.
Appendix 2 - Technical Competence This section of the EMS includes details of the competence status of the Technical Competent Manager(s) (TCM), the operational hours for the Site, the minimum attendance requirements for the TCM and copies of relevant certificates.
Appendix 3 – Assessment of Environmental Impacts and Controls This assessment provides information on the processes, activities and equipment on site, the potentialemissions and impacts that they may have on air, water, energy usage, waste disposal, land contamination, nuisance and resource consumption and how any identified impact may be controlled.
Appendix 4 - Environmental Accident Management Plan This report contains an assessment of the potential accidents that could occur on Site, details of the likelihood of each accident occurring, the preventative measures taken to reduce the risk of each accident occurring, actions to be taken in the case of an accident on Site and an explanation on how to record any accidents that occur on Site. The types of accident included in this report include:
• Leaks or Spillages • Failure of Plant and Equipment • Fire • Cross-Contamination • Flooding • Failure of Services • Unauthorised Entry
Appendix 4 - Appendix 1 Preventing Accidents / Incidents This document contains an assessment of the potential accidents and/or incidents that could occur on site, what the harm could occur, how to reduce the risk of the accident occurring and details on what to do if the accident and/or incident did occur the on Site.
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Environmental Permit Application Report: Version 1, November 2020
Appendix 5 - Flood Management Plan This report contains a brief description of the site, its size, the key contacts to contact in an emergency, whether there are staff employed with any special needs, the locations of any gas, water and / or electric cut off points of Site and ways to keep all plant and computers / files safe in the event of a flood.
Appendix 6 - Procedures and Forms The EMS contains a number of procedures that cover its implementation, waste acceptance, operations controls and emergencies. Records to be produced in accordance with these procedures are provided in the EMS as forms. These completed forms provide records that evidence the implementation of the EMS. The following list details procedures that are included in the EMS;
Implementation
• Environmental Training, Awareness and Competence • Compliance with Legal requirements • Staff Organogram Operational Control
• Housekeeping, litter, pests and vermin • Noise Control • Waste storage and Handling • Site Security • Reporting and Investigation of Accidents, Incidents and Complaints • Dust, Fibres and Particulates • Maintenance Waste Acceptance and Rejection
• Waste Acceptance • Waste Rejection and Non-compliance • Waste Reporting • Duty of Care Environmental Protection
• Dust Fibres and Particulate • Mud and Debris • Noise Control • Odour • Surface Water Management Emergency Provisions
• Environmental Accidents /Incidents / Complaints and associated forms • Fire • Flood • Spillages • Utility Failure Reporting
• Waste Returns • Notifications to the Environment Agency
(This list is not exhaustive.)
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Environmental Permit Application Report: Version 1, November 2020
Drawings The drawings included in the EMS include:
• Site Boundary Plan showing the Site boundaries. • Site Layout plan detailing all cut off points, areas of operations, stockpiles, spill kits, etc. • Site Sensitive Receptors Plan.
Technically Competent Management 7.5. A copy of the original WAMITAB Certificates and extra WAMITAB VRQ410 unit for “Principle and practices of managing an inert landfill” for Benjamin Williams and Pav Myrcik are provided in Appendix 4 Evidence of Technically Competent Management. Benjamin Williams and Pav Myrcik will be the Technically Competent Managers for the Site.
7.6. Benjamin Williams and Pav Myrcik act as Technically Competent Managers for the following other sites/permits:
Permit number Site Address Postcode EPR/HB3305TR Elveden Farms Recycling Facility, Brandon Road, Nr Eriswell, IP27 9FB Lakenheath, Suffolk EPR/GB3106LK Roudham Recycling Facility, Roudham Road, East Harling, NR16 2QN Attleborough, Norfolk EPR/GB3106KG Brandon Rail Head Recycling Facility, The Station Buildings, IP27 0BA Railway Station, Brandon
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Environmental Permit Application Report: Version 1, November 2020
8. Condition of the Site and risk assessments
Environmental Risk Assessment 8.1. An Environmental Risk Assessment has been completed as part of the ESSD Report, see Appendix 3 ESSD – App 4 Environmental Risk Assessment.
8.2. The Environmental Risk Assessment considers the risks associated with the operations to be carried out on the Site.
8.3. The Environmental Risk Assessment considers the potential impacts of the proposed waste operations with regard to the local population, watercourses and protected sites etc.
Hydrogeological Risk Assessment 8.4. A Hydrogeological Risk Assessment (HRA) has been prepared for the Site due to the Site’s location above a Principal Aquifer and in accordance with pre-application advice. The HRA concludes that the bund does not pose an unacceptable risk to the aquifer and does not require an engineered barrier.
8.5. A copy of the HRA is enclosed with Appendix 3 ESSD, App 5 Hydrogeological Risk Assessment.
Stability Risk Assessment 8.6. A Stability Risk Assessment (SRA) has been prepared due to the above ground nature of the proposed bund. The SRA gives methodology for the bund’s construction and concludes that it will remain stable during and post construction.
8.7. A copy of the SRA is enclosed with Appendix 3 ESSD, App 6 Stability Risk Assessment.
Site Condition 8.8. Part 1 of a Site Condition Report has been produced from the Site as part of the Environmental Setting and Site Design (ESSD) Report required as part of this Environmental Permit application.
8.9. A copy of the Site Condition Report Part 1 is included as an appendix within the ESSD Report, see Appendix 3 ESSD Report- App 7 Site Condition Report.
Dust Management Plan 8.10. Due to the location of sensitive receptors including residential dwellings within 500m of the Site boundary, a Dust Management Plan has been completed for the proposed waste operations at the Site.
8.11. The Dust Management Plan lists a number of mitigation measures that will be implemented on the Site to mitigate dust emissions from the Site boundary.
8.12. The Dust Management Plan is included as Appendix 5 of this Environmental Permit application report.
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Environmental Permit Application Report: Version 1, November 2020
Application Forms
Part A
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk
Form EPA: Application for an environmental permit – Part A about you
Application for an environmental permit Part A – About you
You will need to fill in this part A if you are applying for a new It will take less than one hour to fill in this part of the permit, applying to change an existing permit or surrender application form. your permit, or want to transfer an existing permit to yourself. Where you see the term ‘document reference’ on the form, give Please check that this is the latest version of the form the document references and send the documents with the available from our website. application form when you’ve completed it. You can apply online for Waste standard rules environmental Contents permits, bespoke waste permits and bespoke Medium combustion plant permits 1 About you 2 Applications from an individual Apply online for an environmental permit. 3 Applications from an organisation of individuals or charity Please read through this form and the guidance notes that 4 Applications from public bodies came with it. 5 Applications from companies or corporate bodies 6 Your address The form can be: 7 Contact details 1) saved onto a computer and then filled in. Please note 8 How to contact us that the form follows a logic that means questions will 9 Where to send your application open or stay closed depending on a previous answer. So Appendix 1 – Date of birth information for installation and you may not be able to enter text in some boxes. waste activities (applications for a new permit or transferring a permit) only 2) printed off and filled in by hand. Please write clearly in the answer spaces.
Note: if you believe including information on a public register would not be in the interests of national security you must enclose a letter telling us that you have told the Secretary of State. We will not include the information in the public register unless directed otherwise.
1 About you Are you applying as an individual, an organisation of individuals (for example, a partnership), a company (this includes Limited Liability Partnerships) or a public body?
An individual Now go to section 2 and if you are applying for a new permit or transferring a permit for an installation or waste activity please also fill in Appendix 1
An organisation of individuals (for example, a partnership) Now go to section 3 and if you are applying for a new permit or transferring a permit for an installation or waste activity please also fill in Appendix 1
A public body Now go to section 4
A registered company or other corporate body Now go to section 5 and if you are applying for a new permit or transferring a permit for an installation or waste activity please also fill in Appendix 1
2 Applications from an individual 2a Please give us the following details Name Title (Mr, Mrs, Miss and so on) First name Last name Now go to section 6
EPA Version 14, August 2020 page 1 of 7 Form EPA: Application for an environmental permit – Part A about you
3 Applications from an organisation of individuals or charity 3a Type of organisation For example, a charity, a partnership, a group of individuals or a club 3b Details of the organisation or charity If you are an organisation of individuals, please give the details of the main representative below. If relevant, provide details of other members (please include their title Mr, Mrs and so on) on a separate sheet and tell us the document reference you have given this sheet Contact name Title (Mr, Mrs, Miss and so on) First name Last name Now go to question 3c or section 6 3c Details of charity Full name of charity This should be the full name of the legal entity not any trading name. 3d Company registration number If you are registered with Companies House please tell us your registration number 3e Charity Commission number If you are registered with the Charity Commission please tell us your registration number Now go to section 6 4 Applications from public bodies 4a Type of public body For example, NHS trust, local authority, English county council 4b Name of the public body 4c Please give us the following details of the executive An officer of the public body authorised to sign on your behalf Name Title (Mr, Mrs, Miss and so on) First name Last name Position Now go to section 6
5 Applications from companies or corporate bodies 5a Name of the company 5b Company registration number Date of registration (DD/MM/YYYY) If you are applying as a corporate organisation that is not a limited company, please provide evidence of your status and tell us below the reference you have given the document containing this evidence. Document reference EPA Version 14, August 2020 page 2 of 7 Form EPA: Application for an environmental permit – Part A about you
5 Applications from companies or corporate bodies, continued 5c Please give details of the directors If relevant, provide details of other directors and company secretary, if there is one, on a separate sheet and tell us the reference you have given this sheet. Document reference Details of company secretary (if relevant) and director/s Title (Mr, Mrs, Miss and so on) First name Last name
Title (Mr, Mrs, Miss and so on) First name Last name Now go to section 6
6 Your address 6a Your main (registered office) address For companies this is the address on record at Companies House. Contact name Title (Mr, Mrs, Miss and so on) First name Last name Address
Postcode Contact numbers, including the area code Phone Fax Mobile Email For an organisation of individuals every partner needs to give us their details, including their title Mr, Mrs and so on. So, if necessary, continue on a separate sheet and tell us below the reference you have given the sheet. Document reference 6b Main UK business address (if different from above) Contact name Title (Mr, Mrs, Miss and so on) First name Last name Address
Postcode
EPA Version 14, August 2020 page 3 of 7 Form EPA: Application for an environmental permit – Part A about you
6 Your address, continued Contact numbers, including the area code Phone Fax Mobile Email Now go to section 7
7 Contact details 7a Who can we contact about your application? It will help us if there is someone we can contact if we have any questions about your application. The person you name should have the authority to act on your behalf. Please add a second contact on a separate sheet if this person is not always available. Document reference of this separate sheet This can be someone acting as a consultant or an ‘agent’ for you. Contact name Title (Mr, Mrs, Miss and so on) First name Last name Address
Postcode Contact numbers, including the area code Phone Fax Mobile Email 7b Who can we contact about your operation (if different from question 7a)? Contact name Title (Mr, Mrs, Miss and so on) First name Last name Address
Postcode Contact numbers, including the area code Phone Fax Mobile Email
EPA Version 14, August 2020 page 4 of 7 Form EPA: Application for an environmental permit – Part A about you
7 Contact details, continued 7c Who can we contact about your billing or invoice? Note: Please provide the name and address that all invoices should be sent to for your subsistence fees.
As in question 7a
As in question 7b Please give details below if different from question 7a or 7b. Contact name Title (Mr, Mrs, Miss and so on) First name Last name Address
Postcode Contact numbers, including the area code Phone Fax Mobile Email
8 How to contact us If you need help filling in this form, please contact the person who sent it to you or contact us as shown below. General enquiries: 03708 506 506 (Monday to Friday, 8am to 6pm) Textphone: 03702 422 549 (Monday to Friday, 8am to 6pm) Email: enquiries@environment‐agency.gov.uk Website: www.gov.uk/government/organisations/environment‐agency If you are happy with our service, please tell us. It helps us to identify good practice and encourages our staff. If you’re not happy with our service, please tell us how we can improve it. More information on how to do this is available at: www.gov.uk/government/organisations/environment‐agency/about/complaints‐procedure. Please tell us if you need information in a different language or format (for example, in large print) so we can keep in touch with you more easily.
9 Where to send your application For how many copies to send see the guidance note on part A. For water discharges by email to PSC‐WaterQuality@environment‐agency.gov.uk For waste and installations by email to PSC@environment‐agency.gov.uk For flood risk activity permits send 1 copy only to enquiries@environment‐agency.gov.uk or to the local Environment Agency office for where the work is proposed to be carried out. Or Permitting Support, NPS Sheffield Quadrant 2 99 Parkway Avenue Parkway Business Park Sheffield S9 4WF
EPA Version 14, August 2020 page 5 of 7 Form EPA: Application for an environmental permit – Part A about you
Feedback (You don’t have to answer this part of the form, but it will help us improve our forms if you do.) We want to make our forms easy to fill in and our guidance notes easy to understand. Please use the space below to give us any comments you may have about this form or the guidance notes that came with it.
How long did it take you to fill in this form? We will use your feedback to improve our forms and guidance notes, and to tell the Government how regulations could be made simpler. Would you like a reply to your feedback?
Yes please
No thank you
For Environment Agency use only Date received (DD/MM/YYYY) Payment received? No Our reference number Yes Amount received £
EPA Version 14, August 2020 page 6 of 7 Form EPA: Application for an environmental permit – Part A about you
Appendix 1 – Date of birth information for installation and waste activities (applications for a new permit or transferring a permit) only Date of birth information in this appendix will not be put onto our Public Register Are you applying as an individual, an organisation of individuals (for example, a partnership) or a company (this includes Limited Liability Partnerships)?
An individual Now go to 2
An organisation of individuals (for example, a partnership) Now go to 3
A registered company or other corporate body Now go to 4 2 Applications from an individual Please give us the following details Name Date of birth (DD/MM/YY) 3 Applications from an organisation of individuals or charity Details of the organisation or charity If you are an organisation of individuals, please give the date of birth details of the main representative below. If relevant, provide details of other members on a separate sheet and tell us the document reference you have given this sheet. Name Date of birth (DD/MM/YY) Document reference 4 Applications from companies or corporate bodies Name of the company Please give the date of birth details for all directors and company secretary if there is one. If relevant, provide those details of other directors on a separate sheet and tell us the document reference you have given this sheet. Details of company secretary (if relevant) and director/s Name Date of birth (DD/MM/YY) Name Date of birth (DD/MM/YY) Name Date of birth (DD/MM/YY) Document reference
EPA Version 14, August 2020 page 7 of 7
Environmental Permit Application Report: Version 1, November 2020
Application Forms
Part B2
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk
Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit
Application for an environmental permit Part B2 – General – new bespoke permit
Fill in this part of the form together with parts A and F1 if you 2) printed off and filled in by hand. Please write clearly in the are applying for a new bespoke permit. You also need to fill in answer spaces part B3, B4, B5, B6, or B7 (this depends on what activities It will take less than two hours to fill in this part of the you are applying for). Please check that this is the latest application form. version of the form available from our website. Contents You can apply online for waste bespoke environmental permits. 1 About the permit 2 About the site Apply online for an environmental permit. 3 Your ability as an operator Please read through this form and the guidance notes that 4 Consultation came with it. 5 Supporting information 6 Environmental risk assessment The form can be: 7 How to contact us 1) saved onto a computer and then filled in. Please note Appendix 1 – Low impact installation checklist that the form follows a logic that means questions will Appendix 2 – Date of birth information for Relevant offences open or stay closed depending on a previous answer. So and/or Technical ability questions only you may not be able to enter text in some boxes.
1 About the permit 1a Discussions before your application If you have had discussions with us before your application, give us the permit reference or details on a separate sheet. Tell us below the reference you have given this extra sheet. Permit or document reference 1b Is the permit for a site or for mobile plant?
Site Now go to section 2
Mobile plant Now go to question 1c Note: The term ‘mobile plant’ does not include mobile sheep dipping units. Mobile plant 1c Have we told you during pre‐application discussions that we believe that a mobile permit is suitable for your activity? No Yes 1d Have there been any changes to your proposal since this discussion? No Now go to section 3 Yes You should send us a description of the activity you want to carry out, highlighting the changes you have made since our pre‐application discussions Document reference Now go to section 3
2 About the site But not mobile plant 2a What is the site name, address, postcode and national grid reference? Site name
EPB2 Version 16, August 2020 page 1 of 11 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit
2 About the site, continued Address
Postcode National grid reference for the site (for example, ST 12345 67890) 2b What type of regulated facility are you applying for? Note: if you are applying for more than one regulated facility then go to 2c.
Installation
Waste operation
Mining waste operation
Water discharge activity
Groundwater activity (point source)
Groundwater activity (discharge onto land) What is the national grid reference for the regulated facility (if only one)? (See the guidance notes on part B2.)
As in 2a above
Different from that in 2a Please fill in the national grid reference below National grid reference for the regulated facility Now go to question 2d
EPB2 Version 16, August 2020 page 2 of 11 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit
2 About the site, continued 2c If you are applying for more than one regulated facility on your site, what are their types and their grid references? See the guidance notes on part B2. Regulated facility 1 National grid reference What is the regulated facility type?
Installation
Waste operation
Mining waste operation
Water discharge activity
Groundwater activity (point source)
Groundwater activity (discharge onto land) Regulated facility 2 National grid reference What is the regulated facility type?
Installation
Waste operation
Mining waste operation
Water discharge activity
Groundwater activity (point source)
Groundwater activity (discharge onto land) Use several copies of this page or separate sheets if you have a long list of regulated facilities. Send them to us with your application form. Tell us below the reference you have given these extra sheets. Document reference Now go to question 2d
EPB2 Version 16, August 2020 page 3 of 11 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit
2 About the site, continued 2d Low impact installations (installations only) Are any of the regulated facilities low impact installations? No Yes If yes, tell us how you meet the conditions for a low impact installation (see the guidance notes on part B2 – Appendix 1). Document reference Tick the box to confirm you have filled in the low impact installation checklist in appendix 1 for each regulated facility 2e Treating batteries Are you planning to treat batteries? (See the guidance notes on part B2.) No Yes Tell us how you will do this, send us a copy of your explanation and tell us below the reference you have given this explanation Document reference for the explanation 2f Ship recycling Is your activity covered by the Ship Recycling Regulations 2015? (See the guidance notes on part B2.) No Yes Tell us how you will do this. Please send us a copy of your explanation and your facility recycling plan, and tell us below the reference numbers you have given these documents Document reference for the explanation Document reference for the facility recycling plan 2g Multi‐operator installation If the site is a multi‐operator site (that is there is more than one operator of the installation) then fill in the table below the application reference for each of the other permits. Table 1 – Other permit application references
3 Your ability as an operator If you are only applying for a standalone water discharge or for a groundwater activity, you only have to fill in question 3d. 3a Relevant offences Applies to all except standalone surface water discharges and groundwater discharges (see the guidance notes on part B2). 3a1 Have you, or any other relevant person, been convicted of any relevant offence? No Now go to question 3b Yes Please give details below Name of the relevant person Title (Mr, Mrs, Miss and so on) First name Last name Position held at the time of the offence Name of the court where the case was dealt with Date of the conviction (DD/MM/YYYY)
EPB2 Version 16, August 2020 page 4 of 11 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit
3 Your ability as an operator, continued Offence and penalty set Date any appeal against the conviction will be heard (DD/MM/YYYY) If necessary, use a separate sheet to give us details of other relevant offences and tell us below the reference number you have given the extra sheet. Document reference Now go to question 3b Please also complete the details in Appendix 2. 3b Technical ability Relevant waste operations only (see the guidance notes on part B2). Please indicate which of the two schemes you are using to demonstrate you are technically competent to operate your facility and the evidence you have enclosed to demonstrate this. ESA/EU skills Please select one of the following: I have enclosed a copy of the current Competence Management System certificate or We will have a certified Competence Management System within 12 months and have enclosed evidence of the contract with an accredited certification body CIWM/WAMITAB scheme Please select one of the following: • I have enclosed a copy of:
− the relevant qualification certificate/s or − evidence of deemed competence or − Environment Agency assessment or − evidence of nominated manager status under the transitional provisions for previously exempt activities and, if deemed competent or Agency‐assessed, or nominated manager, or if the original qualification is over two years old: I have enclosed a copy of the relevant current continuing competence certificate/s • I will complete my qualification within four weeks of starting the permitted activities and have enclosed evidence of my registration with WAMITAB or my EPOC booking as appropriate • For medium‐ and high‐risk tier activities other than landfill I will complete the qualification within 12 months and have enclosed evidence of registration with WAMITAB and, where relevant, EPOC booking. I understand I must complete either four specified units of the relevant qualification or an EPOC within four weeks of the permitted activities commencing For each technically competent manager please give the following information. If necessary, use a separate sheet to give us these details and tell us below the document reference you have given the extra sheet. Title (Mr, Mrs, Miss and so on) First name Last name Phone Mobile Email
EPB2 Version 16, August 2020 page 5 of 11 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit
3 Your ability as an operator, continued Please provide the environmental permit number/s and site address for all other waste activities that the proposed technically competent manager provides technical competence for, including permits held by other operators. Continue on a separate sheet as required. Permit number Site address Postcode
Document reference Now go to question 3c Please also complete the details in Appendix 2. 3c Finances Installations, waste operations and mining waste operations only. Please note that if you knowingly or carelessly make a statement that is false or misleading to help you get an environmental permit (for yourself or anyone else), you may be committing an offence under the Environmental Permitting (England and Wales) Regulations 2016. Do you or any relevant person or a company in which you were a relevant person have current or past bankruptcy or insolvency proceedings against you? No Yes Please give details below, including the required set‐up costs (including infrastructure), maintenance and clean up costs for the proposed facility against which a credit check may be assessed
We may want to contact a credit reference agency for a report about your business’s finances. Landfill, Category A mining waste facilities and mining waste facilities for hazardous waste only How do you plan to make financial provision (to operate a landfill or a mining waste facility you need to show us that you are financially capable of meeting the obligations of closure and aftercare)?
Renewable bonds
Cash deposits with the Environment Agency
Other – provide comprehensive details Document reference Provide a cost profile and expenditure plan of your estimated costs throughout the aftercare period of your site. Document plan reference Now go to question 3d 3d Management systems (all) You must have an effective, written management system in place that identifies and reduces the risk of pollution. You may show this by using a certified scheme or your own system. Your permit requires you (as the operator) to ensure that you manage and operate your activities in accordance with a written management system. You need to be able to explain what happens at each site and which parts of the overall management system apply. For example at some sites you may need to show you are carrying out additional measures to prevent pollution because they are nearer to sensitive locations than others. You can find guidance on management systems on our website at www.gov.uk/government/organisations/environment‐agency
EPB2 Version 16, August 2020 page 6 of 11 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit
3 Your ability as an operator, continued Tick this box to confirm that you have read the guidance and that your management system will meet our requirements What management system will you provide for your regulated facility?
ISO 14001
BS 8555 (Phases 1–5)
Green dragon
Own management system
EC Eco‐Management and Audit Scheme (EMAS)
EMAS Easy Please make sure you send us a summary of your management system with your application. Document reference/s
4 Consultation Fill in 4a to 4c for installations and waste operations and 4d for installations only. Could the waste operation or installation involve releasing any substance into any of the following? 4a A sewer managed by a sewerage undertaker? No Yes Please name the sewerage undertaker 4b A harbour managed by a harbour authority? No Yes Please name the harbour authority 4c Directly into relevant territorial waters or coastal waters within the sea fisheries district of a local fisheries committee? No Yes Please name the fisheries committee 4d Is the installation on a site for which: 4d1 a nuclear site licence is needed under section 1 of the Nuclear Installations Act 1965? No Yes 4d2 a policy document for preventing major accidents is needed under regulation 5 of the Control of Major Accident Hazards Regulations 2015, or a safety report is needed under regulation 7 of those Regulations? No Yes
5 Supporting information 5a Provide a plan or plans for the site But not any mobile plant Clearly mark the site boundary or discharge point, or both. Also include site drainage plans, site layout plans, and plant design drawings/process flow diagrams (as required). (See the guidance notes on part B2.) Document reference/s of the plans 5b Provide the relevant sections of a site condition/baseline report if this applies See the guidance notes on part B2 for what needs to be marked on the plan. Document reference of the report If you are applying for an installation, tick the box to confirm that you have sent in a baseline report
EPB2 Version 16, August 2020 page 7 of 11 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit
5 Supporting information, continued 5c Provide a non‐technical summary of your application See the guidance notes on part B2. Document reference of the summary 5d Are you applying for an activity that includes the storage of combustible wastes? This applies to all activities excluding standalone water and groundwater discharges. No Yes Provide a fire prevention plan (see the guidance notes on part B2). You need to highlight any changes you have made since your pre‐application discussions. Document reference of the plan
6 Environmental risk assessment Provide an assessment of the risks each of your proposed regulated facilities poses to the environment. The risk assessment must follow the methodology set out in ‘Risk assessments for your environmental permit’ at www.gov.uk/government/collections/technical‐ guidance‐for‐regulated‐industry‐sectors‐environmental‐permitting or an equivalent method. Document reference for the assessments For Waste and Installation Permits only All bespoke waste and installations permit applications must carry out a climate change risk assessment if the planned duration of the operation is more than 5 years. This will normally be reviewed and discussed with you as part of our compliance activities. However, we may require you to submit your climate change risk assessment as part of your application depending on your risk screening score. We will consider the information contained within your climate change risk assessment when we grant your permit. Conditions may be applied to some permits to manage climate risks. 6b Climate change risk screening See the guidance to Part B2. Mark your score in each category in the table below. Add each individual score to give a total. CATEGORY SCREENING QUESTIONS SCORE YOUR SCORE
1 TIMESCALES How long will a permit be required for this site/activity? 5 years or less of operation. No need to fill in the rest of the 0 screening. You do not need to fill in a risk assessment. Please go straight to question 7. Less than 20 years of operation 1 Until between 2040 and 2060 (between 20 and 40 years from now) 3 Until 2060 or beyond (more than 40 years from now) 5 2 FLOODING What is your site’s risk of flooding from rivers or the sea? Not in a flood‐risk zone 0 Very low or Low 1 Medium 2 High 5 3 WATER USE If you use water for your site operations or fire prevention, what is the source of your water? Water not required 0 Mains water 1 Surface water or groundwater abstraction 5 TOTAL SCREENING SCORE If your total screening score is 5 or more, complete the climate change risk assessment and submit it with your permit application. If you expect to operate for 5 years or less, you do not need to submit a risk assessment with your application, regardless of your screening score. You must enter your score for every category in the table above. If you expect to operate for 5 years or less you may enter ‘Not Applicable’ for categories 2 and 3.
EPB2 Version 16, August 2020 page 8 of 11 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit
6 Environmental risk assessment, continued Document reference of the risk assessment (if submitted with application) If your total screening score is less than 5 we may still request your risk assessment as part of determining this application if we believe you face unmanaged climate risks. If we do not review your risk assessment as part of your application, it will form part of your Environmental Management System and we will discuss it with you as part of our compliance activities.
7 How to contact us If you need help filling in this form, please contact the person who sent it to you or contact us as shown below. General enquiries: 03708 506 506 (Monday to Friday, 8am to 6pm) Textphone: 03702 422 549 (Monday to Friday, 8am to 6pm) Email: enquiries@environment‐agency.gov.uk Website: www.gov.uk/government/organisations/environment‐agency If you are happy with our service, please tell us. It helps us to identify good practice and encourages our staff. If you’re not happy with our service, please tell us how we can improve it. Please tell us if you need information in a different language or format (for example, in large print) so we can keep in touch with you more easily. Feedback (You don’t have to answer this part of the form, but it will help us improve our forms if you do.) We want to make our forms easy to fill in and our guidance notes easy to understand. Please use the space below to give us any comments you may have about this form or the guidance notes that came with it.
How long did it take you to fill in this form? We will use your feedback to improve our forms and guidance notes, and to tell the Government how regulations could be made simpler. Would you like a reply to your feedback?
Yes please
No thank you
For Environment Agency use only Date received (DD/MM/YYYY) Payment received? No Our reference number Yes Amount received £
EPB2 Version 16, August 2020 page 9 of 11 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit
Plain English Campaign’s Crystal Mark does not apply to appendix 1.
Appendix 1 – Low impact installation checklist See the guidance notes on part B2. Installation reference Condition Response Do you meet this?
A – Management techniques Provide references to show how your application meets A Yes References No
B – Aqueous waste Effluent created m3/day Yes No C – Abatement systems Provide references to show how your application meets C Yes References No
D – Groundwater Do you plan to release any hazardous substances or Yes Yes non‐hazardous pollutants into the ground? No No E – Producing waste Hazardous waste Tonnes per year Yes Non‐hazardous waste Tonnes per year No F – Using energy Peak energy consumption MW Yes No G – Preventing accidents Do you have appropriate measures to prevent spills and Yes Yes major releases of liquids? (See ‘How to comply’.) No No Provide references to show how your application meets G References
H – Noise Provide references to show how your application meets H Yes References No
I – Emissions of polluting Provide references to show how your application meets I Yes substances References No
J – Odours Provide references to show how your application meets J Yes References No
K – History of keeping to the Say here whether you have been involved in any Yes regulations enforcement action as described in Compliance History No Appendix 1 explanatory notes
EPB2 Version 16, August 2020 page 10 of 11 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit
Appendix 2 – Date of birth information for Relevant offences and/or Technical ability questions only Date of birth information in this appendix will not be put onto our Public Register Have you filled in the Relevant Offences question? Yes No Have you filled in the Technical ability question? Yes No 2 Relevant Offences ‐ date of birth information Please give us the following details Name Date of birth (DD/MM/YY) 3 Technical ability ‐ date of birth information Name Date of birth (DD/MM/YY)
EPB2 Version 16, August 2020 page 11 of 11
Environmental Permit Application Report: Version 1, November 2020
Application Forms
Part B4
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk
Form EPB: Application for an environmental permit – Part B4 new bespoke waste operation permit
Application for an environmental permit Part B4 – New bespoke waste operation permit
Fill in this part of the form, together with parts A, B2 and F1, if Contents you are applying for a new bespoke permit for a waste 1 What waste operations are you applying for? operation. Please check that this is the latest version of the 2 Point source emissions to air, water and land form available from our website. 3 Operating techniques Please read through this form and the guidance notes that 4 Monitoring came with it. 5 How to contact us Appendix 1 – Specific questions for the recovery to land for You can apply online for waste bespoke environmental agricultural benefit of compost like outputs from the permits. treatment of mixed municipal solid wastes Apply online for an environmental permit. Appendix 2 – Specific questions for inert waste landfill and deposit for recovery operations The form can be: 1) saved onto a computer and then filled in. Please note that the form follows a logic that means questions will open or stay closed depending on a previous answer. So you may not be able to enter text in some boxes. 2) printed off and filled in by hand. Please write clearly in the answer spaces. It will take less than three hours to fill in this part of the application form.
1 What waste operations are you applying for? Fill in Table 1a with details of what you are applying for. Fill in a separate table for each waste operation you are applying for. Use a separate sheet if you have a long list and send it to us with your application form. Tell us below the reference you have given the extra sheet. Document reference Types of waste accepted For each line in Table 1a, fill in a separate document to list those wastes you will accept on the site for that operation, giving the List of Wastes catalogue code (search for ‘Technical guidance on how to assess and classify waste’ at www.gov.uk/government/organisations/environment‐agency). If you need to exclude waste from your activity or facility by restricting the description, quantity, physical nature, hazardous properties, composition or characteristic of the waste, include these in the document. Send it to us with your application form.
EPB4 Version 12, August 2020 page 1 of 9 Form EPB: Application for an environmental permit – Part B4 new bespoke waste operation permit
1 What waste operations are you applying for?, continued Table 1a – Waste operations which do not form part of an installation Name of the waste operation Description of the waste operation Annex I (D codes) and Annex II (R codes) Hazardous waste treatment Non‐hazardous waste and descriptions capacity (if this applies) treatment capacity (if this (See note 1) applies) (See note 1) Add extra rows if you need them. If you Use the description from the guidance. do not have enough room, go to the Include any extra detail that you think line below or send a separate would help to accurately describe what document and give us the document you want to do reference here
For all waste operations Total storage capacity (see note 2) Annual throughput (tonnes each year) Notes 1 By ‘capacity’, we mean: • the total landfill capacity (cubic metres) for landfills • the total treatment capacity (tonnes each day) for waste treatment • the total storage capacity (tonnes) for waste‐storage operations 2 By ‘total storage capacity’, we mean the maximum amount of waste in tonnes you store on the site at any one time. EPB4 Version 12, August 2020 page 2 of 9 Form EPB: Application for an environmental permit – Part B4 new bespoke waste operation permit
1 What waste operations are you applying to vary?, continued Please provide the document reference. You can use Table 1b as a template. If you want to accept any waste with a code ending in 99, you must provide more information and a full description of the waste in the document, (for example, detailing the source, nature and composition of the waste). Where you only want to receive specific wastes within a waste code you can provide further details of the waste you want to receive. Where a waste is dual coded you should use both codes for the waste. Document reference Table 1b – Template example – types of waste accepted and restrictions Waste code Description of the waste Example Example 02 01 08* Agrochemical waste containing hazardous substances 18 01 03* Infectious clinical waste, not contaminated with chemicals or medicines – human healthcare (may contain sharps) for alternative treatment 17 05 03*/17 06 05* Non‐hazardous soil from construction or demolition contaminated with fragments of asbestos cement sheet
1c Deposit for recovery purposes (see Appendix 4 and the guidance notes on part B4) Are you applying for a waste recovery activity involving the permanent deposit on waste on land for construction or land reclamation (including landfill restoration)? No Go to section 2 Yes Are you applying for an inert landfill permit that includes a restoration activity using waste? No Go to section 2 Yes Please send us a copy of your restoration plan in accordance with our guidance at https://www.gov.uk/guidance/landfill‐operators‐environmental‐permits/restore‐your‐landfill‐site Have we advised you during pre‐application discussions that we believe the activity is waste recovery? No Go to section 2 Yes Have there been any changes to your proposal since the discussions? No Yes Please send us a copy of your waste recovery plan that complies with our guidance at https://www.gov.uk/guidance/waste‐recovery‐ plans‐and‐permits. You need to highlight any changes you have made since your pre‐application discussions. Also give us the reference number of the document with your justification. Please note that there is an additional charge for the assessment of a waste recovery plan that must be submitted as part of this application. For the charge see https://www.gov.uk/topic/environmental‐management/environmental‐permits. Document reference
EPB4 Version 12, August 2020 page 3 of 9 Form EPB: Application for an environmental permit – Part B4 new bespoke waste operation permit
2 Point source emissions to air, water and land Fill in Table 2 below with details of the point source emissions that result from the operating techniques at each of your waste operations. Fill in one table for each waste operation. Table 2 – Emissions Name of the waste operation Point source emissions to air Emission point reference and location Source Parameter Quantity Unit
Point source emissions to water (other than sewers) Emission point reference and location Source Parameter Quantity Unit
Point source emissions to sewers, effluent treatment plants or other transfers off site Emission point reference and location Source Parameter Quantity Unit
Point source emissions to land Emission point reference and location Source Parameter Quantity Unit
EPB4 Version 12, August 2020 page 4 of 9 Form EPB: Application for an environmental permit – Part B4 new bespoke waste operation permit
Supporting information
3 Operating techniques 3a Technical standards Fill in Table 3a for each waste operation you refer to in Table 1a above and list the ‘appropriate measures’ you are planning to use. If you are using the standards set out in the relevant technical guidance(s) (TGN) there is no need to justify using them within your documents in Table 3a. You must justify your decisions in a separate document if: • there is no technical standard • the technical guidance provides a choice of standards, or • you plan to use another standard This justification could include a reference to the Environmental Risk Assessment provided in part B2 of the application form. Table 3a should summarise: • the operations undertaken • the measures you will use to control the emissions from your process, as identified in your risk assessment or the relevant technical guidance • how you will meet other standards set out in the relevant technical guidance Table 3a – Technical standards Fill in a separate table for each waste operation. Waste operation Description of the waste operation Appropriate measure (TGN reference) Document reference Add extra rows if you need them (if appropriate)
In all cases, describe the type of facility or operation you are applying for and provide site infrastructure plans, location plans and process flow diagrams or block diagrams to help describe the operations and processes undertaken. Give the document references you use for each plan, diagram and description. Document reference 3b General requirements Fill in a separate table for each waste operation. Table 3b – General requirements Name of the waste operation
If the technical guidance or your risk assessment shows that emissions of substances not Document reference or references controlled by emission limits are an important issue, send us your plan for managing them If the technical guidance or your risk assessment shows that odours are an important Document reference or references issue, send us your odour management plan. If your activity type is listed in the guidance document ‘Control and monitor emissions for your environmental permit’ as needing an odour management plan, or your risk assessment shows that odours are an important issue, you need to send us your odour management plan. If the technical guidance or your risk assessment shows that noise or vibration are Document reference or references important issues, send us your noise or vibration management plan (or both)
EPB4 Version 12, August 2020 page 5 of 9 Form EPB: Application for an environmental permit – Part B4 new bespoke waste operation permit
3 Operating techniques, continued We may need to ask for management plans or risk assessments in other circumstances based on our regulatory experience. If you are unsure as to whether you need to submit a management plan with your application, please discuss this with the Environment Agency prior to submission. Search for ‘Risk assessment for your environmental permit’ at www.gov.uk/government/organisations/environment‐agency. 3c Information for specific sectors For some of the sectors, we need more information to be able to set appropriate conditions in the permit. This is as well as the information you may provide in sections 5, 6 and 7. For those activities listed in Table 3c, you must answer the questions in the related document. Table 3c – Questions for specific sectors Sector Appendix
Recovery to land for agricultural benefit of compost like outputs See the questions in appendix 1 from the treatment of mixed municipal solid wastes Inert landfill and deposit of waste on land for construction, land See the questions in appendix 2 reclamation, restoration or improvement
General information 4 Monitoring 4a Describe the measures you use for monitoring emissions by referring to each emission point in Table 2 above You should also describe any environmental monitoring. Tell us: • how often you use these measures • the methods you use • the procedures you follow to assess the measures Document reference 4b Point source emissions to air only Provide an assessment of the sampling locations used to measure point source emissions to air. The assessment must use M1 (search for ‘M1 sampling requirements for stack emission monitoring’ at www.gov.uk/government/organisations/environment‐agency). Document reference of the assessment
5 How to contact us If you need help filling in this form, please contact the person who sent it to you or contact us as shown below. General enquiries: 03708 506 506 (Monday to Friday, 8am to 6pm) Textphone: 03702 422 549 (Monday to Friday, 8am to 6pm) Email: enquiries@environment‐agency.gov.uk Website: www.gov.uk/government/organisations/environment‐agency If you are happy with our service, please tell us. It helps us to identify good practice and encourages our staff. If you’re not happy with our service, please tell us how we can improve it. Please tell us if you need information in a different language or format (for example, in large print) so we can keep in touch with you more easily.
EPB4 Version 12, August 2020 page 6 of 9 Form EPB: Application for an environmental permit – Part B4 new bespoke waste operation permit Feedback (You don’t have to answer this part of the form, but it will help us improve our forms if you do.) We want to make our forms easy to fill in and our guidance notes easy to understand. Please use the space below to give us any comments you may have about this form or the guidance notes that came with it.
How long did it take you to fill in this form? We will use your feedback to improve our forms and guidance notes, and to tell the Government how regulations could be made simpler. Would you like a reply to your feedback?
Yes please
No thank you
For Environment Agency use only Date received (DD/MM/YYYY) Payment received? No Our reference number Yes Amount received £
EPB4 Version 12, August 2020 page 7 of 9 Form EPB: Application for an environmental permit – Part B4 new bespoke waste operation permit
Plain English Campaign’s Crystal Mark does not apply to appendices 1 to 2.
Appendix 1 – Specific questions for the recovery to land for agricultural benefit of compost like outputs from the treatment of mixed municipal solid wastes 1 Please provide an accurate and reliable characterisation of your compost like outputs (CLO). This should be based on sampling and analysis of the CLO produced by the treatment (MBT) process over a 12‐month period and in accordance with section 2 of TGN 6.15 Document reference 2 Please provide an agricultural benefit assessment for the use of your CLO. This should be based on section 2 of TGN 6.15 and should be signed and dated by an appropriate technical expert Document reference 3 Please provide a site‐specific risk assessment of risks to soil and food chain receptors. This should be based on Schedule 2 of TGN 6.15 and include a map with a green outline showing the boundary of the area being treated and include: • locations where the waste will be stored and spread • any spring, well or borehole used to supply water for domestic or food production purposes that is within 250 metres of the area being treated • any spring, well or borehole not being used for domestic or food production purposes that is within 50 metres of the area being treated • any European designated sites (candidate or Special Area of Conservation, proposed or Special Protections Area in England and Wales or Ramsar Site) or Sites of Special Scientific Interest (SSSI) which are within 500 metres of the place where waste is to be stored or spread • the location of public rights of way • any Groundwater Source Protection Zones • surface watercourses • any buildings or houses within 250 metres of the area being treated • land drains within the boundary Document reference 4 Are the technical standards and measures fully in line with those set out in section 3 of TGN 6.15? No Provide justification for departure from TGN 6.15 and a copy of the proposed technical standards, measures or procedures Document reference
Yes
Appendix 2 – Specific questions for inert waste landfill and deposit for recovery operations 1 Please provide your Environmental Setting and Site Design (ESSD) report Document reference Note: You should use the Environment Agency template to help you develop an environmental setting and site design (ESSD) report. 2 Please provide your Waste Acceptance Procedures (including Waste Acceptance Criteria) Document reference 3 Have you provided a hydrogeological risk assessment (HRA) for the site? No Please refer to the section of your ESSD that explains why this is unnecessary for your site Yes Document reference 4 Have you completed an outline engineering plan for the site? No Please refer to the section of your ESSD that explains why this is unnecessary for your site Yes Document reference 5 Have you provided a stability risk assessment (SRA) for your site? No Please refer to the section of your ESSD that explains why this is unnecessary for your site Yes Document reference
EPB4 Version 12, August 2020 page 8 of 9 Form EPB: Application for an environmental permit – Part B4 new bespoke waste operation permit
Appendix 2 – Specific questions for inert waste landfill and deposit for recovery operations, continued 6 Have you completed a monitoring plan for the site? No Please refer to the section of your ESSD that explains why this is unnecessary for your site Yes Document reference 7 Have you completed a plan for closing the site and procedures for looking after the site once it has closed? No If no for deposit for recovery activities please refer to the section of your ESSD that explains why this is unnecessary for your site Yes For inert waste landfill you must provide a closure plan Document reference
Spreading waste to support plant growth 8a Does the activity involve the deposit of waste to create or treat a growing medium (R10 for land treatment)? No Yes 8b If you answered ‘yes’ to question 8a, does the R10 activity include the spreading of waste to improve the quality of the growing medium (e.g. soil conditioner to improve existing soil profile)? No Yes Go to question 8c 8c If you have answered ‘Yes’ to question 8b, have you completed a benefit statement? No Please explain why Document reference
Yes Note: Refer to our guidance when completing your statement (including EPR 8.01, section 6).
EPB4 Version 12, August 2020 page 9 of 9
Environmental Permit Application Report: Version 1, November 2020
Application Forms
Part F1
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk
Form EPF: Application for an environmental permit – Part F1 Charges and declarations
Application for an environmental permit Part F1 – Charges and declarations
Fill in this part for all applications for installations, waste It will take less than two hours to fill in this part of the operations, mining waste operations, water discharges, point application form. source groundwater discharges and groundwater discharges Contents onto land. Please check that this is the latest version of the form available from our website. 1 Working out charges 2 Payment Please read through this form and the guidance notes that 3 Privacy notice came with it. 4 Confidentiality and national security The form can be: 5 Declaration 6 Application checklist 1) saved onto a computer and then filled in. Please note 7 How to contact us that the form follows a logic that means questions will 8 Where to send your application open or stay closed depending on a previous answer. So you may not be able to enter text in some boxes. 2) printed off and filled in by hand. Please write clearly in the answer spaces.
Each individual who is applying for their name to appear on the permit must complete the declaration in section 5. You will have to print a separate copy of the declaration page for each additional individual to complete.
1 Working out charges You must fill in this section. You have to submit an application fee with your application. You can find out the charge by searching for ‘Environment Agency charging scheme and guidance: environmental permits’ at www.gov.uk/government/organisations/environment‐agency. Please remember that the charges are revised on 1 April each year and that there is an annual subsistence charge to cover the costs we incur in the ongoing regulation of the permit. Table 1 – Type of application (fill number of activity being applied for in each column) Installation Waste Mining waste Medium Combustion Water Groundwater Plant (MCP)/Specified discharge/point spreading onto land Generator (SG) source discharge to groundwater
Table 2 – Charge type (A) Charge activity reference Charge activity description What are you applying to do? Amount E.g. new, minor variation, normal variation, substantial variation, surrender, low risk surrender, transfer e.g. 1.17.3 e.g. Sect 5.2 landfill for hazardous waste e.g. transfer e.g. £5,561
Total A
EPF1 Version 13, August 2020 page 1 of 8 Form EPF: Application for an environmental permit – Part F1 Charges and declarations
1 Working out charges (you must fill in this section), continued Table 3 – Additional assessment charges (B) Part 1.19 Charges for plans and assessments Tick appropriate
Reference Plan or assessment Charge 1.19.1 Waste recovery plan £1,231 1.19.2 Habitats assessment (except where the application activity is a flood risk activity) £779 1.19.3 Fire prevention plan (except where the application activity is a farming £1,241 installation) 1.19.4 Pests management plan (except where the application activity is a farming £1,241 installation) 1.19.5 Emissions management plan (except where the application activity is a farming £1,241 installation) 1.19.6 Odour management plan (except where the application activity is a farming £1,246 installation) 1.19.7 Noise and vibration management plan (except where the application activity is a £1,246 farming installation) 1.19.8 Ammonia emissions risk assessment (intensive farming applications only) £620 1.19.9 Dust and bio‐aerosol management plan (intensive farming applications only) £620 Advertising £500
Total B
Total charges Total A plus total B
2 Payment Tick below to show how you have paid.
Cheque
Postal order
Cash Tick below to confirm you are enclosing cash with the application
Credit or debit card
Electronic transfer (for example, BACS) Remittance number Date paid (DD/MM/YYYY) How to pay Paying by cheque, postal order or cash Cheque details Cheque made payable to Cheque number Amount £
You should make cheques or postal orders payable to ‘Environment Agency’ and make sure they have ‘A/c Payee’ written across them if it is not already printed on. Please write the name of your company and application reference number on the back of your cheque or postal order. We will not accept cheques with a future date on them. We do not recommend sending cash through the post. If you cannot avoid this, please use a recorded delivery postal service and enclose your application reference details. Please tick the box below to confirm you are enclosing cash.
I have enclosed cash with my application
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2 Payment, continued Paying by credit or debit card If you are paying by credit or debit card we can call you. We will destroy your card details once we have processed your payment. We can accept payments by Visa, MasterCard or Maestro card only.
Please call me to arrange payment by debit or debit card Paying by electronic transfer BACS reference If you choose to pay by electronic transfer you will need to use the following information to make your payment. Company name Environment Agency Company address SSCL (Environment Agency), PO Box 797, Newport Gwent, NP10 8FZ Bank RBS/NatWest Address London Corporate Service Centre, CPB Services, 2nd Floor, 280 Bishopsgate, London EC2M 4RB Sort code 60‐70‐80 Account number 10014411 Account name EA RECEIPTS Payment reference number PSCAPPXXXXXYYY You need to create your own reference number. It should begin with PSCAPP (to reflect that the application is for a permitted activity) and it should include the first five letters of the company name (replacing the X’s in the above reference number) and a unique numerical identifier (replacing the Y’s in the above reference number). The reference number that you supply will appear on our bank statements. If you are making your payment from outside the United Kingdom, it must be in sterling. Our IBAN number is GB23NWK60708010014411 and our SWIFTBIC number is NWBKGB2L. If you do not quote your reference number, there may be a delay in processing your payment and application. Provide a unique reference number for the application, i.e. do not only use the company name only State who is paying (full name and whether this is the agent/ applicant/other) Fee paid £ Date payment sent (DD/MM/YYYY) Now read section 3 below You should also email your payment details and reference number to [email protected].
3 Privacy notice The Environment Agency runs the environmental permit application service. We are the data controller for this service. A data controller determines how and why personal information is processed. Our personal information charter explains: • your rights • what we do with your personal information We’re allowed to process your personal information because we have official authority as the environmental regulator. We need this information to carry out a task in the public interest that is set out in law. As the data controller, when you apply for an environmental permit, we have a legal obligation to process your personal data under the Environmental Permitting Regulations. The second lawful basis for processing your personal data is to comply with this legal obligation. We need your personal information to process your environmental permit application. If you do not give us this information we cannot issue a permit to you. After we’ve issued a permit to you, we use your personal information: • to check that you’re complying with your permit • during any potential enforcement action What personal information we collect If you’re the individual applicant, director or company secretary of a company applying or a technically competent manager we need your: • name • date of birth
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3 Privacy notice, continued • address • email address If you’re the agent, consultant, employee responsible for the activity or the employee responsible for billing and invoicing we need your: • name • address • email address If you’re the applicant we need details of any: • convictions • bankruptcy We also collect any questions or feedback you leave, including your email address if you contact us. Your responsibility with other people’s personal information If you’ve included personal information about other people on your application, you must tell them. You must provide them with a copy of this privacy notice so that they know how their personal information will be used. What we do with your personal information We use your personal information to help us decide whether to issue you with a permit. The information (except dates of birth) is available online on our consultation website during the consultation period. This website is available to everyone so your information may be seen outside the European Economic Area. After consultation we put all the information (except dates of birth) you give us in your application on our public register. If you can demonstrate that any information you send us is commercially or industrially confidential, we’ll consider withholding that information from our public register. If you think that the information you’ll send us may be a threat to national security you must contact the Secretary Of State before you apply. You must still send us that information with your application. We will not include this information on our public register unless the Secretary of State decides it can be included. See the environmental permitting guidance for guidance on national security. We may use your email address to contact you for user research to improve our service. You don’t have to take part in the research. Where your personal information is processed and stored We store and process your personal information on servers in the UK. We will not host your personal information outside the European Economic Area. We do not use your personal information to make an automated decision or for automated profiling. How long we keep your personal information We keep your personal information while your permit is in use and for 7 years after you surrender your permit. If the permit is for a landfill site, we keep the data for 10 years after surrender. Removing personal information from the public register We will remove your personal information from the public register if: • you withdraw your application • we refuse your application and the time limit for appealing the decision has expired or an appeal is dismissed • the information is no longer relevant for public participation purposes under the Environmental Permitting Regulations Contact Our Data Protection Team gives independent advice. They monitor how the Environment Agency uses your personal information. If you have questions or concerns about how we process personal information, or to make a complaint or request relating to data protection, please contact: Address: Data Protection Team Environment Agency Horizon House Deanery Road Bristol BS1 5AH
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3 Privacy notice, continued Email: dataprotection@environment‐agency.gov.uk You can also make a complaint to the Information Commissioner’s Office (ICO). The ICO is the supervisory authority for data protection legislation. The ICO website has a full list of your rights under data protection legislation. Now read section 4 below
4 Confidentiality and national security Confidentiality We will normally put all the information in your application on a public register of environmental information. However, we may not include certain information in the public register if this is in the interests of national security, or because the information is confidential. You can ask for information to be made confidential by enclosing a letter with your application giving your reasons. If we agree with your request, we will tell you and not include the information in the public register. If we do not agree with your request, we will let you know how to appeal against our decision, or you can withdraw your application. You can find guidance on confidentiality in ‘Environmental permitting guidance: core guidance’, published by Defra and available via our website at www.gov.uk/government/organisations/ environment‐agency. Only tick the box below if you wish to claim confidentiality for your application
Please treat the information in my application as confidential National security You can tell the Secretary of State that you believe including information on a public register would not be in the interests of national security. You must enclose a letter with your application telling us that you have told the Secretary of State and you must still include the information in your application. We will not include the information in the public register unless the Secretary of State decides that it should be included. You can find guidance on national security in ‘Environmental permitting guidance: core guidance’, published by Defra and available via our website at www.gov.uk/government/organisations/environment‐agency. You cannot apply for national security via this application. Now fill in section 5
5 Declaration If you knowingly or carelessly make a statement that is false or misleading to help you get an environmental permit (for yourself or anyone else), you may be committing an offence under the Environmental Permitting (England and Wales) Regulations 2016. A relevant person should make the declaration (see the guidance notes on part F1). An agent acting on behalf of an applicant is NOT a relevant person. Each individual (or individual trustee) who is applying for their name to appear on the permit must complete this declaration. You will have to print a separate copy of this page for each additional individual to complete. If you are transferring all or part of your permit, both you and the person receiving the permit must make the declaration. You must fill in the declaration directly below; the person receiving the permit must fill in the declaration under the heading ‘For transfers only’. Note: we will issue a letter to both current and new holders to confirm the transfer. If you are changing address we will need to send this letter to your new address; therefore please tell us your new address in a separate letter. If you are unable to trace one or more of the current permit holders please see below under the transfers declaration. I declare that the information in this application is true to the best of my knowledge and belief. I understand that this application may be refused or approval withdrawn if I give false or incomplete information. If you deliberately make a statement that is false or misleading in order to get approval you may be prosecuted. I confirm that my standard facility will fully meet the rules that I have applied for (this only applies if the application includes standard facilities) Tick this box to confirm that you understand and agree with the declaration above, then fill in the details below (you do not have to provide a signature as well) Tick this box if you do not want us to use information from any ecological survey that you have supplied with your application (for further information please see the guidance notes on part F1)
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5 Declaration, continued Name Title (Mr, Mrs, Miss and so on) First name Last name on behalf of (if relevant; for example, a company or organisation and so on) Position (if relevant; for example, in a company or organisation and so on) Today’s date (DD/MM/YYYY) For transfers only – declaration for person receiving the permit A relevant person should make the declaration (see the guidance notes on part F1). An agent acting on behalf of an applicant is NOT a relevant person. I declare that the information in this application to transfer an environmental permit to me is true to the best of my knowledge and belief. I understand that this application may be refused or approval withdrawn if I give false or incomplete information. Note: If you cannot trace a person or persons holding the permit you may be able to transfer the permit without their declaration as above. Please contact us to discuss this and supply evidence in your application to confirm you are unable to trace one or all of the permit holders. If you deliberately make a statement that is false or misleading in order to get approval you may be prosecuted. Tick this box to confirm that you understand and agree with the declaration above, then fill in the details below (you do not have to provide a signature as well) Name Title (Mr, Mrs, Miss and so on) First name Last name on behalf of (if relevant; for example, a company or organisation and so on) Position (if relevant; for example, in a company or organisation and so on) Today’s date (DD/MM/YYYY) Now go to section 6 6 Application checklist You must fill in this section. If your application is not complete we will return it to you. If you aren’t sure about what you need to send, speak to us before you submit your application. You must do the following: Complete legibly all parts of this form that are relevant to you and your activities Identify relevant supporting information in the form and send it with the application List all the documents you are sending in the table below. If necessary, continue on a separate sheet. This separate sheet also needs to have a reference number and you should include it in the table below For new permits or any changes to the site plan, provide a plan that meets the standards given in the guidance note on part F1 Provide a supporting letter for any claim that information is confidential
Get the declaration completed by a relevant person (not an agent)
Send the correct fee
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6 Application checklist, continued Question reference Document title Document reference
7 How to contact us If you need help filling in this form, please contact the person who sent it to you or contact us as shown below. General enquiries: 03708 506 506 (Monday to Friday, 8am to 6pm) Textphone: 03702 422549 (Monday to Friday, 8am to 6pm) Email: enquiries@environment‐agency.gov.uk Website: www.gov.uk/government/organisations/environment‐agency If you are happy with our service, please tell us. It helps us to identify good practice and encourages our staff. If you’re not happy with our service, or you would like us to review a decision we have made, please let us know. More information on how to do this is available at: https://www.gov.uk/government/organisations/environment‐agency/about/complaints‐procedure. Please tell us if you need information in a different language or format (for example, in large print) so we can keep in touch with you more easily.
8 Where to send your application For how many copies to send see the guidance note on part F1. Please send your filled in application form to: For water discharges by email to PSC‐WaterQuality@environment‐agency.gov.uk For waste and installations by email to PSC@environment‐agency.gov.uk Or Permitting Support, NPS Sheffield Quadrant 2 99 Parkway Avenue Parkway Business Park Sheffield S9 4WF Do you want all information to be sent to you by email? Please tick this box if you wish to have all communication about this application sent via email (we will use the details provided in part A)
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Feedback (You don’t have to answer this part of the form, but it will help us improve our forms if you do.) We want to make our forms easy to fill in and our guidance notes easy to understand. Please use the space below to give us any comments you may have about this form or the guidance notes that came with it.
How long did it take you to fill in this form? We will use your feedback to improve our forms and guidance notes, and to tell the Government how regulations could be made simpler. Would you like a reply to your feedback?
Yes please
No thank you
For Environment Agency use only Date received (DD/MM/YYYY) Payment received? No Our reference number Yes Amount received £
EPF1 Version 13, August 2020 page 8 of 8
Environmental Permit Application Report: Version 1, November 2020
Drawings
Drawing No. 18/014c 001 Permit Boundary Plan
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk
Client: Rory J Holbrook Limited
Title: Proposed permit boundary plan
Site: Lakenheath Bund Lakenheath Brandon Rd, Brandon IP27 9FB
Date: 22 October2020
Scale:
Reference: 18/014c 001
Proposed permit boundary Bund boundary (C) OS OpenStreetMaps
Environmental Permit Application Report: Version 1, November 2020
Appendix 1
Pre-application Advice
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk
You have provided a letter that leads on from the agreed waste recovery plan requesting further information on the stability risk assessment required for the proposed above ground screening bund, and the proposed extent of hydrogeological risk assessment.
We have reviewed the waste recovery plan, and the information available on the site setting, and provide the following advice to be considered in any permit application. It should be noted that the waste recovery plan has been approved as a recovery operation rather than disposal but a permit application will require further assessment of the proposed waste types based on the sensitivity of the site location.
Hydrogeological Risk Assessment:
The letter received identifies that the site is located on a Principal aquifer. This is the Holywell nodular chalk formation and new pit chalk formation, and that as such a hydrogeological risk assessment will be required. The letter does not however identify that the site is located within a Source Protection Zone 1 for two groundwater abstractions. The Environment Agency would normally object to deposit for recovery activities within an SPZ1 at the planning stage in line with our approach to groundwater protection. (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/6929 89/Envirnment-Agency-approach-to-groundwater-protection.pdf) As such the application will need to show what, if any, agreement was given at the planning stage to any objection raised. Due to the sensitive nature of the site setting it is agreed that a hydrogeological risk assessment will be required.
Guidance for producing a hydrogeological risk assessment is given at: https://www.gov.uk/guidance/groundwater-risk-assessment-for-your-environmental-permit This provides information on the information required for the conceptual site model, which would often be presented in the Environmental Setting and Site Design report – a template for this is given at: https://www.gov.uk/government/publications/report-template-environmental-setting-and-site-design
The hydrogeological risk assessment needs to include the first tier of risk assessment, risk screening, to demonstrate the risks posed by the source. Guidance on the tiers of risk assessment that are appropriate are given at https://www.gov.uk/guidance/groundwater-risk-assessment-for-your- environmental-permit#generic-quantitative-risk-assessment). We expect you to have screened your waste acceptance criteria against appropriate water quality standards for the receptors identified (for example minimum reporting values, Drinking Water Standards or Environmental Quality Standards from the Water Framework Directive) or background concentrations if these are significantly lower, to identify which substances may pose a risk to the water environment. https://www.gov.uk/guidance/groundwater-risk-assessment-for-your-environmental- permit#qualitative-risk-screening. We would then expect you to provide suitable assessment of those substances that exceed the water quality standards using calculations to show that the criteria proposed will not cause pollution. The risk assessment produced may indicate that either a) an attenuation layer is required or b) the waste acceptance criteria need to be reduced. For b) we would expect you to derive the reduced waste acceptance criteria.
The generic quantitative assessment level proposed will need to show with enough certainty that you are using worst case scenario figures. Given the sensitive location of the site you may require a tier 3 detailed quantitative risk assessment to demonstrate that your activity does not pose a pollution risk to groundwater.
Further guidance where your risk assessment shows you need to do engineering work (provide an attenuation layer for example) to protect the environment from your activity or to monitor the environment is provided on https://www.gov.uk/guidance/waste-recovery-engineering-create-a- construction-quality-plan. Given the location of the site within an SPZ1 we would expect groundwater monitoring to be in place. It does not appear from the letter provided that an attenuation layer is proposed, the risk assessment will need to justify this with regard to the waste acceptance criteria proposed.
A review of the waste codes proposed within the waste recovery plan identified that there are two codes that will require the producer to test the waste: 02 04 01 – soil from cleaning and washing beet, and 19 12 12 other wastes from mechanical treatment of waste, and two codes that are proposing taking peat: 17 05 04, and 20 02 02. These codes will require the operator to have waste acceptance criteria to show that the waste acceptance procedures will prevent the waste causing pollution and to show how the operator will decide which wastes to accept and from which sources. More guidance on waste acceptance criteria are given at: https://www.gov.uk/guidance/waste-acceptance-procedures-for-waste- recovery-on-land
The guidance says that you can develop your own site-specific criteria (which is through a quantitative risk assessment of an appropriate tier of assessment as discussed above) or demonstrate that the Landfill Directive’s inert waste acceptance criteria (Article 2(e)) are appropriate.
For recovered waste you must demonstrate that the material to be used will not cause pollution and is physically and chemically suitable. This should be assessed within your risk assessment, with (where necessary) proposals for limits on the quality of material to ensure that there will be no pollution of surface water or groundwater. The risk assessment should also consider a rogue load risk assessment for accepting waste that does not meet the criteria limits for example, contaminated soil, or non-inert waste concealed within a load of waste that appears to be inert.
In order to demonstrate that the Landfill Directive inert waste acceptance criteria are appropriate for the site setting without the presence of an engineered/natural attenuation layer that was assumed in the original development of the inert waste criteria, the applicant must show that the criteria will not result in the direct discharge of hazardous substances (currently the hazardous substances in the landfill inert waste criteria are mercury, arsenic, lead, BTEX and PAH) to groundwater or cause pollution to groundwater or surface water from non-hazardous pollutants. The UKTAG document Technical report on Groundwater Hazardous Substances (https://www.wfduk.org/sites/default/files/Media/UKTAG_Technical%20report_GW_Haz- Subs_ForWebfinal.pdf) provides limits of quantification (minimum reporting values) for some hazardous substances.
Stability Risk Assessment:
The letter received identifies that the site is an above ground structure and the Environment Agency may wish the stability of the structure to be assessed. It is confirmed that a stability assessment will be required. This will need to demonstrate that the bund and waste material placed is effective, stable and permanent, provide the details of the engineering design and techniques to be employed during construction, and confirm that the waste types will meet the minimum engineering standards proposed. This should assess the stability of any engineering proposed, so this will need to cover any attenuation layer proposed, and an assessment of the waste slopes proposed.
While there is not at present specific guidance available on the risk assessment of stability for deposit for recovery applications, a template is available for landfills where the relevant sections can be used when looking at the attenuation layer and waste stability risks. This is provided at https://www.gov.uk/government/publications/stability-risk-assessment-report-template
Clear design drawings will be required to show which slopes have been assessed, and minimum factors of safety must be justified. The Stability Risk Assessment should use the conceptual site model presented in the Environmental Setting and Site Design report.
Best practice guidance of relevance that should be referred to include: the Specifications for Highways Works Series 600 for Earthworks and the BS 6031:2009 Code of Practice for Earthworks. The guidance document Earthworks in landfill engineering LFE4 https://www.gov.uk/government/publications/earthworks-in-landfill-engineering-lfe4 also contains useful information with regards to the design, construction and quality assurance of earthworks relating to above ground bunds, and to any attenuation layer required as an engineered liner. This is in addition to the information provided at https://www.gov.uk/guidance/waste-recovery-engineering-create-a- construction-quality-plan mentioned in relation to the hydrogeological risk assessment above.
Should the applicant wish to discuss elements of this advice further on a telecom this can be arranged on receipt of a proposed agenda outlining the further questions and agreement to extension of pre- application fees.
Environmental Permit Application Report: Version 1, November 2020
Appendix 2
Evidence of Technically Competent Management
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk
Environmental Permit Application Report: Version 1, November 2020
Appendix 3
Environmental Setting and Site Design Report
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk
Environmental Setting and Site Design Report
Rory J Holbrook Limited Lakenheath Country Club, Hereford Road, Brandon, Suffolk, IP27 9PP
Environmental Setting and Site Design Report
Document Control Table
Project Reference 18/014c
Project Title Recovery Permit Application
Document Title Environmental Setting and Site Design Report
Document Issue No. 1
Document Issue Date 20 November 2020
Client Rory J Holbrook Limited
Status Issue
Report Produced by/Date George Evans / Kate Brady 12 November 2020
Report Checked by/ Date Kate Brady 20 November 2020
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Environmental Setting and Site Design Report
Contents 1. Introduction ...... 1 Site Details ...... 1 2. Source ...... 3 Historical Development ...... 3 Proposed Development ...... 3 3. Pathway and receptors ...... 6 Geology ...... 6 Hydrology ...... 6 Hydrogeology ...... 6 Sensitive Receptors ...... 7 Local Human Population ...... 8 Dust and Particulates ...... 8 Noise ...... 9 Odour ...... 9 Mud and Debris ...... 9 Pests and vermin ...... 9 Habitats and Protected Sites ...... 10 4. Pollution control measures...... 11 Site Engineering ...... 11 Construction ...... 11 Past closure controls (Aftercare) ...... 11 5. Monitoring ...... 12 Local Wind Data ...... 12 Rainfall ...... 12 Gas Monitoring Infrastructure ...... 12 Gas Monitoring ...... 12 6. Site Condition Report ...... 14
Tables Table 2.1: Waste types ...... 4 Table 3.1: Sensitive receptors within 500m of the site boundary ...... 7
Elveden Farms Limited: Lakenheath Country Club, Suffolk iii
Environmental Setting and Site Design Report
Figures Figure 1.1 Location and extent of proposed bund ...... 2 Figure 5.1: Wind rose from RAF Lakenheath Observing Station 11/2009 to 10/2019. The arrow indicates predominant wind direction ...... 12
Drawings
Drawing No. 18/014c 001 Permit Boundary Plan
Drawing No. 18/014c 002 Sensitive Receptors Plan
Appendices
Appendix 1 Approved Waste Recovery Plan
Appendix 2 Recovery vs disposal opinion
Appendix 3 Waste Acceptance Procedures
Appendix 4 Environmental Risk Assessment
Appendix 5 Hydrogeological Risk Assessment
Appendix 6 Stability Risk Assessment
Appendix 7 Site Condition Report
Elveden Farms Limited: Lakenheath Country Club, Suffolk iv
Environmental Setting and Site Design Report
1. Introduction
1.1. This Environmental Setting and Site Design Report (ESSD) supports an Environmental Permit application for deposit of waste for recovery to construct a bund at Lakenheath Country Club, Hereford Road, Brandon, Suffolk, IP27 9PP (the Site).
1.2. This ESSD report has been produced by Westbury Environmental Limited on behalf of Rory J Holbrook Limited (the Operator). Westbury Environmental Limited are an environmental consultancy who assist waste operators with waste regulatory compliance issues.
1.3. Planning permission F/2005/0015/FUL for “Erection of replacement clubhouse, storage building, three clay towers, landscaped bunding and alterations to vehicular access” was granted to on 7 August 2006 by Forest Heath District Council.
1.4. Planning Permission F/2009/0073/VAR for “Variation of Conditions 2, 11 and 15 of planning permission F/2005/0015/FUL to allow for a section of bunding to be constructed on the eastern boundary of the site” was granted on 31 March 2009.
1.5. A Waste Recovery Plan (WRP) for the construction of the bund in accordance with the approved planning permissions was submitted to the Environment Agency in November 2019, see Appendix 1 Waste Recovery Plan Version 2. The WRP concluded that there was a planning obligation to construct the bund in accordance with the planning permissions. The Environment Agency deemed the proposed bund to be a “recovery” activity and approved WRP Version 2 on 13 January 2020, see Appendix 2 Recovery vs Disposal Opinion. Copies of the planning permissions are appended to the Approved WRP.
1.6. Following to the approval of WRP Version 2, a bespoke Environmental Permit for deposit of waste for recovery is being applied for. The Site does not meet the criteria for a Standard Rules 2015 No. 39 Environmental Permit due to the volume of waste required in the works and its location within the Breckland Farmland Site of Special Scientific Interest (SSSI).
1.7. The bund will be constructed in accordance with the approved WRP and as shown on the Bund Cross- Section, Drawing No. SX97600001-62.
1.8. The Environmental Permit application that this ESSD Report supports, seeks to allow 788,120m3 of waste to be deposited in the works at the Site.
Site Details
1.9. The proposed Site Bund Boundary is shown in Figure 1: “Location and extent of Lakenheath Country Club bund”. Fencing and hedging exists along the boundaries of the Site.
1.10. Access to the Site is via Brandon Road which runs north-east along the western boundary of the Site. The access point to the Site from Brandon Road is located at grid reference TL 73488 80164.
1.11. The footprint of the proposed bund will cover an area of approximately 15ha, as shown on Permit Boundary Plan, Drawing No. 18/014c 001.
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Environmental Setting and Site Design Report
Figure 1.1 Location and extent of proposed bund
1.12. The land-use to the east and south of the Site is farmland associated with the Breckland Farmland SSSI. To the north and west lies the Lakenheath RAF ‘village’ which include Lakenheath hospital and some eateries within 300m of the western boundary. Between the Site and the Lakenheath RAF village is the A1065 highway.
1.13. Nearby sensitive receptors include protected habitats, residential dwellings and the Lakenheath Country Club clubhouse. The sensitive receptors proximate to the Site are identified in Section 3 (Pathway & Receptor) of this report.
Elveden Farms Limited: Lakenheath Country Club, Suffolk 2
Environmental Setting and Site Design Report
2. Source
2.1. The Site is currently used as an amenity facility for the Lakenheath Country Club. Waste recovery operations are proposed to be carried out under a Bespoke Environmental Permit in order to construct a bund that will help to reduce noise pollution and increase security.
Historical Development
2.2. Land uses in the surrounding area have not changed significantly in the last 20 years. The RAF Lakenheath Base to the north has developed but not changed in its size or extent. To the south and east surrounding agricultural land has not changed in 30 years. There are no historic landfills within 1km radius of the Site.
2.3. Previous planning permissions for the Site include submissions by the Lakenheath Country Club for a replacement clubhouse, storage building, target towers, landscaped bunding and alterations to vehicle access (Ref. No. F/2005/0015/FUL) this was received 6 January 2005 – see Appendix 1 Waste Recovery Plan for copies of the planning permission.
2.4. Construction of the bund was started in 2005 using aggregates produced under the WRAP Quality Protocol: Aggregates from inert waste and waste exemptions, including those allowing the use of baled tyres in construction which was in circulation at the time of the tyre waste deposit.
2.5. The use of baled tyres in civil engineering projects of this type is no longer appropriate under an exemption. It was agreed with the Environment Agency that the existing bund was lawful at the time of construction and poses little risk to the environment. As such it may remain in place and added to as part of the design.
Proposed Development
2.6. Waste Recovery Plan Version 2 for the construction of a bund at the Site was submitted to the Environment Agency in November 2019. The Environment Agency confirmed it to be a “recovery” operation on 13 January 2020, see Appendix 2 Recovery Opinion.
2.7. It is estimated that it will take 788,120m3 of material to construct the bund in accordance with the approved WRP and planning permissions.
2.8. The waste types included in Table 2.1 are proposed to be used in the construction of the bund under the Environmental Permit.
2.9. The proposed phasing of the bund is shown on the Bund Phasing Plans Drawing Nos. SX97600001 48 – SX97600001 54. Cross sections of the bund are shown on Drawing Nos. TSES-20195-442-EGL-03 and 20195-442-EGL-04. All drawings are appended to the approved WRP, see Appendix 1 Waste Recovery Plan.
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Environmental Setting and Site Design Report
Table 2.1: Waste types
Exclusions Wastes having any of the following characteristics shall not be accepted: • Consisting solely or mainly of dusts, powders or loose fibres • Wastes that are in a form which is either sludge or liquid
Source Sub-source Waste code Description Additional restrictions
01 01 wastes Wastes from mineral Restricted to waste from mineral 01 01 02 non- metalliferous overburden and 01 Waste resulting excavation excavation interburden only. from exploration, 01 04 wastes Waste gravel and mining, quarrying from physical crushed rocks other 01 04 08 and physical and and chemical than those mentioned chemical treatment processing of in 01 04 06 of minerals non- metalliferous 01 04 09 Waste sand and clays minerals 02 Waste from agriculture, horticulture, 02 04 wastes aquaculture, Soil from cleaning and from sugar 02 04 01 forestry, hunting washing beet processing and fishing, food preparation and processing
17 01 01 Concrete
17 01 02 Bricks
17 01 concrete, bricks, tiles and 17 01 03 Tiles and ceramics 17 Construction ceramics and demolition Mixtures of concrete, wastes bricks, tiles and Metal from reinforced 17 01 07 ceramics other than concrete must have those mentioned in 17 been removed. 01 06 17 05 soil Soil and stones other Restricted to topsoil, stones and 17 05 04 than those mentioned peat, subsoil and stones dredging spoil in 17 05 03 only. Restricted to wastes from treatment of waste aggregates that are 19 12 wastes otherwise naturally Minerals (for example occurring minerals. from the 19 12 09 mechanical sand, stones) only Does not include fines treatment of from treatment of any 19 Wastes from waste (for non-hazardous waste or waste management example sorting, gypsum from recovered facilities crushing, plasterboard compacting, Other wastes Including crushed bricks, pelletising) not (including mixtures of tiles, concrete and otherwise materials) from ceramics. specified 19 12 12 mechanical treatment Including soils from the of wastes other than mechanical treatment of those mentioned in 19 construction / demolition 12 11 waste.
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Environmental Setting and Site Design Report
Source Sub-source Waste code Description Additional restrictions
Metal from reinforced concrete must be removed. Does not include gypsum from recovered plasterboard. 20 Municipal wastes (household waste and similar commercial, Restricted to topsoil, 20 02 garden industrial and 20 02 02 Soils and stones peat, subsoil and stones and park wastes institutional only. wastes) including separately collected fractions
2.10. Waste to be used in the works will be accepted and classified in accordance with the Waste Acceptance Procedures, see Appendix 3 Waste Acceptance Procedures.
Elveden Farms Limited: Lakenheath Country Club, Suffolk 5
Environmental Setting and Site Design Report
3. Pathway and receptors
Geology
3.1. Bedrock geology is defined on the British Geological Survey (BGS) website as “a term used for the main mass of rocks forming the Earth and present everywhere, whether exposed at the surface in outcrops or concealed beneath superficial deposits or water”.
3.2. The bedrock geology of the site comprises strata from the Cretaceous White and Grey Chalk Subgroups. The Site is underlain by white chalk of the Holywell Nodular Chalk Formation and New Pit Chalk Formation (undifferentiated).
3.3. BGS borehole logs within 1km of the Site proved the base of the chalk to between 31.7 and 59.0mAOD (or 51 and 78mbgl) (ref Appendix 5, Hydrogeological Risk Assessment).
3.4. The Chalk is overlain by superficial deposits comprising of Cover Sands for the majority of the bund site. Borehole records in the vicinity of the Site indicate the Cover sand to range from between 1 - 5m (ref Appendix 5, Hydrogeological Risk Assessment).
3.5. No site investigations were available at the time of writing this ESSD Report.
Hydrology
3.6. There are no surface water features within or proximate to the Site. The closest surface water features are Caudle Head located approximately 700m northwest of the Site and a cut-off channel located approximately 1.7km west of the Site.
3.7. The closest river is the River Lark located approximately 6.6km south of the Site.
3.8. The Site is located in Flood Zone 1, where the probability of fluvial flooding is 0.1% in any year. The majority of the Site is considered to be at a very low risk of flooding from surface water with isolated areas of the Site that are at a medium / high risk of flooding from surface water in the north west corner travelling diagonally through the centre of the site which the bund encompasses. The same areas are at some risk of flooding from reservoirs.
3.9. The Environmental Risk Assessment for the Site has assessed that there is a “very low” risk to surface water due to the following reasons:
• Permitted waste types will not include sludges or liquids and accepted waste types are non- hazardous. Strict waste acceptance procedures will ensure that no contaminated waste enters the Site. • There will be no point-source emissions to water. • All liquids on the Site will be provided with secondary containment.
3.10. There are no Drinking Water Safeguard Zones for surface water located on or in close proximity to the Site.
3.11. The Site is located in a Drinking Water Protected Area for surface water (Cut Off Channel). The Site has no overland links to this watercourse.
Hydrogeology
3.12. The Cover Sands do not comprise an aquifer as designated by the Environment Agency.
3.13. The Chalk which underlies the Site comprises a Principle Aquifer. The Site is also within the inner catchment Source Protection Zone (SPZ) 1.
3.14. Groundwater level data collected from BGS boreholes (ref Appendix 5, Hydrogeological Risk Assessment), record groundwater elevations are around 7-13mAOD and are considered to decline towards the northwest. Groundwater flow is therefore considered to be in a north westerly and westerly
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direction, following the topographic slope, towards Caudle Head, the Cut-Off Channel, and the local water supply borehole at RAF Lakenheath.
3.15. The Site is located within an Inner Source Protection Zone 1 (nominally the 50 day travel time). Details of the abstraction this protection zone has been defined for have not been provided by the EA, however, it is likely to be related to a private water supply for the RAF base, 120m west of the Site.
3.16. There is understood to be an active borehole abstraction, owned by the landowner and registered as a private potable supply for 9.9m3/day at Eriswell Lodge (reference P/298/PWS/050), within 500m of the Site. There is no record of a borehole at this location from the BGS, however it is considered that the borehole likely abstracts from the chalk aquifer for potable supply.
3.17. A further two licensed groundwater abstractions have been identified between 980m – 1km south of the Site. The licences are held by Elveden Farms Ltd and allow abstraction from the chalk aquifer for spray irrigation purposes. A single deregulated abstraction (source unknown) for domestic supply is located 760 m east of the site; no further details are provided. A further four waterwell locations are identified on the BGS database, three of which are chalk abstractions within Little Eriswell, approximately located 410 m and 430 m northwest (noted as disused or contaminated), and 820 m southwest of the site (status unknown). The fourth is located at Warren Lodge, approximately 1 km northeast, however no geological records or status are provided.
3.18. Further detail on abstractions are given in Appendix 5 Hydrogeological Risk Assessment.
3.19. Strict waste acceptance procedures will be implemented at the Site to ensure that no contaminated waste types are accepted onto the Site.
3.20. The Site is located within the Nitrates Directive (NVZ) - Groundwater Zone 71 for the Anglian Chalk. The Site does not overlie any groundwater safeguard zones and drinking water protection areas.
3.21. A Hydrogeological Risk Assessment (HRA) has been prepared to assess the risk of the proposed bund to controlled waters, see Appendix 5 Hydrogeological Risk Assessment.
3.22. The HRA concludes that under normal operational and post-operational phases Hazardous substances will not be present in groundwater beneath the site in concentrations discernible above background and Non-hazardous pollutants will not be present in concentrations such that pollution of nearby groundwater is caused. It is therefore considered that the Site will be compliant with respect to the Environmental Permitting (England and Wales) Regulations (2016) without the need for an artificial geological barrier.
Sensitive Receptors
3.23. There are number of sensitive receptors within 500m of the Site boundary. The direction and distances of the sensitive receptors from the Site boundary are provided in Table 3.1. The receptors numbered 1 to 15 are labelled on the Sensitive Receptors Plan, Drawing No. 18/014c 002.
Table 3.1: Sensitive receptors within 500m of the site boundary
Approximate Direction from Ref Receptor Description distance from Site Site Boundary Boundary (m) Breckland Designated Protected Within 1 0 Farmland SSSI Habitat boundary Designated Special Within 2 Breckland SPA 0 Protection Area boundary Deciduous Designated Protected Within 3 0 woodland Habitat boundary Lakenheath Site of Special Scientific On northern 4 North Warren SSSI Interest boundary Designated Special Area On northern 5 Breckland SAC North of Conservation boundary
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Approximate Direction from Ref Receptor Description distance from Site Site Boundary Boundary (m) Deciduous Designated Protected On southwestern 6 Southwest Woodland Habitat boundary A1065 7 (Brandon Main Road West 10 Road) Lodging for staff and visitors of RAF 8 Liberty Lodge Northwest 80 Lakenheath with associated open space South, west Lakenheath Country club and shooting and east 9 180 Country Club range (surrounded by bund) Area of restaurants with 10 Restaurants West 150 associated car parks RAF Hospital buildings and 11 Lakenheath associated infrastructure West 270 Hospital on airbase AFB Baseball 12 Playing fields North 275 Fields RAF Area of shops and 13 Commercial Northwest 290 services on airbase Area Dental Clinic Dentist and associated 14 Northwest 390 Lakenheath infrastructure Eriswell Low Site of Special Scientific 15 South 440 Warren SSSI Interest
3.24. The Sensitive Receptors identified in Table 3.1 have been considered within the Environmental Risk Assessment completed for the Site (Appendix 4 Environmental Risk Assessment) and the risks to receptors are summarised in this section of the ESSD Report.
Local Human Population
3.25. The A1065 (Brandon Road) separates the Site and town of RAF Lakenheath. Immediately adjacent to the western boundary of the Site are many local businesses and amenities for RAF Lakenheath residents, however there is no residential housing within 500m of the Site.
3.26. The following sources in the Site’s Environmental Risk Assessment are considered to have the potential to cause harm to the local human population.
Dust and Particulates
3.27. Dust and particulates from waste operations have the potential to cause harm to the local population by harming human health by respiratory irritation and to cause nuisance by leading to dust deposition on cars, homes and clothing etc.
3.28. The only waste types to be used in the construction of the bund are described in Table 2.1, of this ESSD Report. Waste will be accepted onto the Site in strict accordance with the Waste Acceptance Procedures (see Appendix 3), which will form part of the Site’s Environmental Management System (EMS).
3.29. It is considered that there is the potential of dust production from vehicle movements and from the placement of waste into the construction of the bund.
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3.30. A Dust Management Plan (DMP) for Waste Operations has been completed for the Site and refers to mitigation measures that will be implemented at the Site for dust emissions (see Permit application, Appendix 4).
3.31. Due to the size of the dust particles, the majority of dust emissions are likely to be deposited within 50m of the source. Residential dwellings and workplaces are located more than 50m from the Site boundary.
3.32. The Environmental Risk Assessment considers that there is a “low” residual risk to nearby receptors from dust and particulates.
Noise
3.33. Noise has the potential to cause nuisance, loss of amenity and loss of sleep to the local human population.
3.34. All of the plant and equipment kept on the Site will be maintained in accordance with the manufacturer’s recommendations. In addition, the number of items of plant required in the bund construction will be minimal. This ensures a low-likelihood of excessive noise from plant due to malfunction and routine operation.
3.35. It is considered that the Site is not located in an area sensitive to noise from the temporary movement of soils and plant. Existing activities in the vicinity include clay-pigeon shooting and waste recycling.
3.36. It is considered that there is a “low” risk of nuisance to the local human population from the potential noise from the Site’s operations.
3.37. It is considered that there would be other receptors in close proximity to the Site such as RAF Lakenheath Base which would cause a greater noise pollution to the neighbouring residents.
Odour
3.38. Waste types accepted onto the Site have a low potential to give rise to odour. They are not putrescible. Strict waste acceptance procedures are applied to incoming loads to ensure that they do not contain malodourous materials.
3.39. It is considered that there is a “very low” residual risk of the local human population being caused a nuisance by odour from site operations.
Mud and Debris
3.40. Local residents can be sensitive to mud and debris on local roads from heavy goods vehicles entering and exiting the Site. The Site will have procedures and mitigation measures in place to ensure that mud and debris on local roads is minimised.
3.41. The Site will be accessed off the A1065, Brandon Road via the adjacent waste treatment facility. The recycling yard employs the use of a wheelwash. As such mud is unlikely to be tracked onto Brandon Road.
3.42. Waste types to be permitted under the Environmental Permit have a low potential to produce litter.
3.43. A road sweeper will be used when necessary to clear local highways, including Brandon Road, from litter, mud and waste.
3.44. It is considered that there is a “low” residual risk of mud and debris to cause nuisance and loss of amenity to the local population.
Pests and vermin
3.45. Due to the nature of the waste types used in the construction, it is considered that the risk to the local human population is “very low”. Pests and vermin are generally attracted to waste sites that accept putrescible wastes.
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3.46. There is likely to be a naturally occurring vermin population due to the Site’s surrounding land-use of agricultural fields and woodland.
3.47. Housekeeping procedures and strict waste acceptance procedures will ensure that activities and materials that could attract vermin and pests are not undertaken or accepted onto the Site.
Habitats and Protected Sites
3.48. There are three SSSIs (Lakenheath Warren, Eriswell Low Warren and Breckland Farmland), a Special Area of Conservation/Special Protection Area and multiple areas of protected deciduous woodland within 500m of the Site. The closest area SSSI is the Eriswell Low Warren which surrounds the Site entirely.
3.49. It is considered that the main risk to these habitats is likely the emission of dust from the Site causing some vegetation smothering. However, controls are in place to prevent dust emissions from the Site boundary.
3.50. The implementation of the Site’s EMS procedures should minimise the risk to protected sites within 500m of the Site. Waste types accepted at the Site are non-hazardous and are not degradable.
3.51. There is considered to be a “low” residual risk to the habitats located in close proximity to the Site.
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4. Pollution control measures
Site Engineering
4.1. The HRA and SRA conclude that an artificial geological barrier (AGB) is not required for this development for the purposes of environmental protection.
4.2. However, in order to ensure stability, the in-situ ground will be excavated to remove the top 0.5m of material in order to ensure the removal of any organic material or air voids. This material will be replaced with material which is clay-rich and placed in layers of 0.3m and compacted with 6 passes of a roller. This process will result in an effective AGB of 0.5m.
4.3. Further information on the engineering methodology is provided in Appendix 6, Stability Risk Assessment. In addition, waste materials will be placed in the construction following good practice techniques.
Construction
4.4. The construction of the bund has been designed to create a landscape that is congruous with the surrounding area.
4.5. The Environment Agency ESSD Report template refers to pre-settlement and post-settlement contours. Settlement is only likely to be significant for sites filled with putrescible waste or waste placed with significant air voids. Waste types to be imported at the Site will be non-putrescible and will be placed in accordance with an engineering specification, therefore is not anticipated to be subject to significant settlement. Waste materials will be placed in the construction works following good practice techniques.
4.6. Further methodology on the bund construction method is provided in Appendix 6, Stability Risk Assessment.
4.7. The waste types and quantities to be used in the construction are discussed in the approved Waste Recovery Plan (Appendix 3). Once the construction of the Site is complete it is considered that a total of 1,182,180 tonnes of waste will be required in the construction of the bund.
4.8. The waste types to be used in the construction of the Site, from the approved Waste Recovery Plan, are reproduced in Table 2.1 of this report.
4.9. The Site will operate in accordance with strict Waste Acceptance Procedures to ensure that wastes accepted are chemically and physically suitable, see Appendix 3, Waste Acceptance Procedure.
Past closure controls (Aftercare)
4.10. The bund is to be constructed in accordance with the approved Waste Recovery Plan and Planning Permission for the Site.
4.11. The likelihood of differential settlement and structural failure of the Site is considered to be low due to the types of wastes to be used in the construction works. This is confirmed in Appendix 6, Stability Risk Assessment.
4.12. The proposed waste types are not biodegradable and will have very low organic content. This together with the above-ground nature of the bund mean that the production or emission of gas is not considered to be an issue.
4.13. The Environmental Permit will be surrendered when recovery operations are completed at the Site in accordance with the approved WRP.
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5. Monitoring
Local Wind Data
5.1. Wind speed and direction data have been obtained from the RAF Lakenheath observing station for the period from 11/2009 to 10/2019. RAF Lakenheath observing station is located approximately 2km to the north of the Site. This observing station has wind speed and direction data appropriate for characterisation of the wind climate at the Site, see Figure 5.1.
Figure 5.1: Wind rose from RAF Lakenheath Observing Station 11/2009 to 10/2019. The arrow indicates predominant wind direction
Direction Percentage (%) N 4.2 NNE 4.7 NE 4.8 ENE 4.0 E 3.4 ESE 3.1 SE 4.2 SSE 5.4 S 7.1 SSW 9.0 SW 12.0 WSW 11.6 W 8.2 WNW 6.8 NW 6.0 NNW 5.4
Rainfall
5.2. Orographic enhancement is the effect that mountains and high-altitude areas have on clouds and winds. Higher altitude areas force the prevailing winds to rise, which cools the air and consequently enhances the formation of clouds. The landscape surround the Site is largely flat and there are no mountainous regions.
5.3. Monthly average rainfall has been provided by the Environment Agency for their Mildenhall raingauge (reference 186712), located outside Mildenhall (NGR TL 69320 74836), 7km southwest of the Site. The long-term annual average (LTA) rainfall for the Mildenhall raingauge (February 1996–January 2020) is 549.1mm. The maximum total annual rainfall was recorded at 773.2mm (2012) and minimum of 343mm (1996) (from Hydrogeological Risk Assessment, Hafren Water, Nov 2020).
Gas Monitoring Infrastructure
5.4. The waste types to be used in the construction will be soil and stones, will not biodegrade and therefore will not generate gas.
5.5. There is no existing gas monitoring infrastructure at the Site. Due to the above-ground nature of the waste recovery activity and the waste types proposed to be used, it is not proposed to install gas monitoring infrastructure within the Site or around the perimeter.
Gas Monitoring
5.6. Gas monitoring is not proposed to be undertaken at the Site due to the nature of waste types to be deposited and the above-ground nature of the screening bund to be constructed.
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5.7. It will be confirmed that no biodegradable waste will be present in the Site through the implementation of strict waste acceptance procedures. Waste Acceptance Procedures are in place on the Site to ensure that only waste types allowed under the Environmental Permit are accepted for use in the construction of the bund.
5.8. Any contravening waste types will be identified at the following points:
• Pre-acceptance checks on incoming soils by way of a Hazardous Waste Assessment in accordance with WM3 Technical Guidance. • By checking the accompanying Waste Transfer Note. For example, wastes that have been incorrectly coded on the Waste Transfer Note will not be accepted onto the Site. • By carrying out a visual assessment of the load prior to offloading. • By visual checks during offloading. • By visual checks during the placement of material.
5.9. If contravening waste types are discovered during these checks, they will be removed in accordance with the Site’s Waste Rejection Procedure.
5.10. It is considered that implementation of the Waste Acceptance Procedures on the Site will ensure that no biodegradable waste will be used in the construction works. There is a very low potential for the proposed waste types to produce gas, even if placed at depth of more than 2m below ground level. All waste deposited will be above ground level.
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6. Site Condition Report
6.1. Site Condition Report Part 1 for the Site is included as Appendix 7 of this ESSD Report.
6.2. A Site walkover was conducted on 11 November 2020. The Site was observed to be sparsely covered with wild grasses with no visible evidence of prior contamination events. The Site surface was dry due to recent dry conditions.
6.3. On completion of the construction works, Elveden Farms Limited will undertake a topographical survey to ensure the conditions of the planning permission has been complied with. This information will be included as Part 3 of the Site Condition Report in due course.
6.4. A Site Closure Plan has not been provided. The bund will be constructed in accordance with the plans submitted as part of the planning permissions for the Site.
6.5. Upon completion of the bund construction, the Environmental Permit will be formally surrendered.
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Drawings
Drawing No. 18/014c 001 Permit Boundary Plan
Drawing No. 18/014c 002 Sensitive Receptors Plan
Elveden Farms Limited: Lakenheath Country Club, Suffolk
Client: Rory J Holbrook Limited
Title: Proposed permit boundary plan
Site: Lakenheath Bund Lakenheath Brandon Rd, Brandon IP27 9FB
Date: 22 October2020
Scale:
Reference: 18/014c 001
Proposed permit boundary Bund boundary (C) OS OpenStreetMaps Lakenheath Country Club Bund
Client Elveden Farms Limited
Title Sensitive Receptors Plan
Dwg No. 18/014c 002
Site Lakenheath Country Club, 12 Hereford Road, Brandon, Suffolk, £ IP27 9PP 14 9
Scale See Drawing
Date 13/11/2020 8 4 1 2 5 Key 11 1 Breckland Farmland SSSI 7 2 Breckland SPA 3 Deciduous Woodland 4 Lakenheath Warren SSSI 6 £ 5 Breakland SAC 10 6 Deciduous Woodland £ 7 A1065 13 8 Liberty Lodge 9 £ Restaurants 10 £ Lakenheath Country Club 3 11 RAF Lakenheath Hospital 12 AFB Baseball Fields 13 £ Commercial Area 14 Dental Clinic Lakenheath 15 Eriswell Low Warren SSSI
Site Boundary 500 buffer
15
Agriculture House, T: 01952 879705 Southwater Way, M: 07762 580839 0m 200m 400m Telford, E: [email protected] TF3 4NR www.westburyenv.co.uk
Environmental Setting and Site Design Report
Appendix 1
Approved Waste Recovery Plan
Elveden Farms Limited: Lakenheath Country Club, Suffolk
Environmental Setting and Site Design Report
Appendix 2
Recovery vs Disposal Opinion
Elveden Farms Limited: Lakenheath Country Club, Suffolk
Our ref: EPR/JB3001MP/A001 Georgina Watkins Westbury Environmental Date: 13 January 2020
Dear Miss Watkins
Environmental Permitting – Recovery or Disposal Operation Pre-application Reference: EPR/JB3001MP/A001 Proposed Operator: Elveden Farms Limited Site Address : Lakenheath Country Club, Hereford Road, Brandon, Suffolk, IP27 9PP
As part of our pre-application discussions, you have submitted information to us that includes your assessment that the activity you wish to undertake at your site amounts to a recovery operation.
We have now fully considered your submission and we would like to advise you that:
We agree with your assessment that your activity is a recovery operation. This advice is based on the information you have provided in relation to waste types, amounts and nature of proposal including any proposed landform. If you change any of these between now and when you submit an application form, this advice may no longer apply. Please also note that following submission of an application, additional assessment will take place (for example, further assessment of the proposed waste types based on the sensitivity of the site location) and therefore agreement that an operation is a recovery activity does not guarantee that a permit will be granted or a variation issued.
For the sake of clarity, the following documents are considered to form the approved waste recovery plan;
Waste Recovery Plan: Version 2: 6th November 2019 – Project reference 18/014a
If you have any questions please phone me or email elisabeth.platts@environment- agency.gov.uk
Yours sincerely
Elisabeth Platts Permitting Officer
Customer services line: 03708 506 506 Email: [email protected] www.environment-agency.gov.uk
Environmental Setting and Site Design Report
Appendix 3
Waste Acceptance Procedures
Elveden Farms Limited: Lakenheath Country Club, Suffolk
Environmental Site Setting & Design Report: Appendix 5 – Waste Acceptance Procedure
Procedure No. 1.1: Waste Acceptance V.1, November 2020 Purpose: To ensure that all waste accepted for construction purposes is acceptable under the conditions of the Environmental Permit.
RESPONSIBLE RECORD PERSON
Waste Recovery Plan and waste codes
1. The Environmental Permit contains the list of waste types that are permitted to All Table 1 Permitted be accepted at the Site for deposit of waste for recovery. A table containing the Waste Types codes and descriptions of waste types that are permitted on this Site is included at the end of this procedure, see Table 1 Permitted Waste Types.
This list of waste types shall be consulted if you are unsure whether a load can be accepted, alternatively the Site Manager should be consulted.
2. If the waste code on the Waste Transfer Note (WTN) is not listed in the Site Operative Procedure No. 2.3 Environmental Permit / Table 1 in this procedure, the load must be rejected in Waste Rejection accordance with the Waste Rejection Procedure. Table 1 Permitted Waste Types
3. The maximum amount of waste which can be brought onto the Site for recovery Site Manager shall not exceed 788,119.15 m3.
Waste pre-acceptance
4. Following a customer enquiry, the operator will follow the steps in the ‘Pre- Site Manager Acceptance Flowchart’ to determine if the waste is acceptable. In any case, the operator may choose to not accept waste which has the potential to be contaminated.
5. Waste Information is requested from the supplier of the waste. This information Site Manager Waste is recorded on the Waste Information Form and the information reviewed to Information assess if the waste is acceptable or not. Form
6. A judgement should be made as to the necessity to obtain comprehensive Site Manager Waste information at this stage. If the source of the waste is not likely to be Information contaminated, then it may not be necessary to obtain a full site investigation or Form hazardous waste assessment. If the source of the waste is likely to be contaminated, then a full site investigation and/or a hazardous waste assessment should be requested.
7. Review of the information in the Waste Information Form will determine the Site Manager Procedure: need for (further) sampling/testing/Hazardous Waste Assessment. Waste Classification
Form: Waste Information
8. A Hazardous Waste Assessment based on WM3 Guidance shall be completed Site Manager where necessary and a copy of the assessment kept with Duty of Care Documentation associated with that waste. Review of the information in the Waste Information Form will determine the need for a Hazardous Waste Assessment.
9. All associated Waste Information records will be kept along with Waste Transfer Site Manager Waste Notes in a secure location. These records will be maintained for a minimum of Information six years Form
Waste Transfer Note
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Collection of a load
10. A driver arriving at a site to collect waste will: Site Operative • Ensure that the waste type is acceptable as per instructed. • Ensure a Waste Transfer Note is issued with the load and that the description matches the load.
11. If a driver collecting a load suspects that the description on the WTN is not Site Operative accurate then the Site Manager will be contacted. The description on the WTN may be changed as a result of discussions & agreement.
All vehicles
12. All vehicles carrying waste on the pubic highway must be registered as waste Site Operative Waste Carriers carriers and a copy of their certificate should be held on file in the Site office. A Licence regular check should be carried out to ensure that registrations are still in date, and where they are found not to be, a copy of the new registration should be obtained immediately.
Acceptance of waste onto the Site
13. The driver will provide a WTN to the Site operative, who will complete the Site Operative Waste Transfer section relating to transfer of waste, unless a season WTN has been provided. Note The Site operative will then return the WTN to the driver, keeping a copy of the WTN for his own records. A WTN will be generated if one is not provided by the driver.
14. A Waste Transfer Note for every load is obtained from the driver and the Waste Site Operative Waste Transfer Transfer Note is checked to ensure it contains the following: Note • Vehicle registration and driver’s name and signature. • Waste haulier name and valid waste carriers registration number. • Name, address (of source site) and signature of the transferor. • Name, address (of destination site) and signature of the person receiving the waste (transferee). • Permit number or exemption reference of person receiving the waste (if applicable). • Description of waste including; waste type, waste source, waste containment and waste quantity. • List of Waste (LoW) code. • SIC Code of the waste holder using SIC Codes (2007). • Date and time of waste transfer and waste transfer note number. • Confirmation that the Waste Hierarchy has been considered.
15. Loads will be checked to ensure that the load matches the description on the Site Operative WTN that the correct waste type has been used to categorise the load and that the waste to be accepted accords with the site-specific Waste Acceptance Criteria (WAC). Acceptable waste types are detailed in and in Table 1 below. Site-specific WAC is given in Table 2 below.
16. Loads not accompanied by a WTN, that do not match the description on the Site Operative WTN, or do not accord with the site-specific WAC will be rejected in accordance with the Waste Rejection Procedure once the Site Manager has been informed.
17. Every load is visually inspected prior to being off loaded. Site Operative
If there is any doubt about the waste type delivered, then a message is relayed to the Site Manager.
18. After checking the load and the associated paperwork the vehicle is directed to Site Operative the offloading area for inspection and stockpiling. A Site Operative will inspect tipped loads.
19. If there is a discrepancy with the load or its paperwork then the Site Manager Site Operative shall be informed immediately. If the load is not acceptable under the Environmental Permit then, if possible it should be re-loaded onto the vehicle and rejected from Site in accordance with the Waste Rejection Procedure.
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Environmental Site Setting & Design Report: Appendix 5 – Waste Acceptance Procedure
20. If it is impossible to load a rejected load back onto the delivering vehicle the Site Operative load will be put into the quarantine area. Waste will be rejected from the Site in accordance with the Waste Rejection Procedure.
Compliance Testing
21. Compliance testing will be carried out on waste accepted on to the Site. Site Manager Samples taken from waste piles will be tested at a laboratory to determine the characteristics of the waste and to ensure that the waste is as described on the WTN.
22. An ‘Environmental Suite’ should be requested from the laboratory for the Site Manager sample of waste. The Environmental Suite must contain at least the following parameters: • Total Sulphate. • Boron. • Arsenic. • Cadmium. • Metals, including; Chromium III, Chromium VI, Copper, Lead, Mercury, Nickel, Selenium, Zinc. • Acid Soluble Sulphide. • Total Phenols (Monohydric). • Total Cyanide. • pH Value. • PAH (total/speciated). • TPH (total/speciated). • BTEX. • Total Sulphate, Water Soluble Sulphate.
Compliance testing for WAC will be undertaken by completing a leachate testing suite in accordance with (BS EN) 12457.
23. A Hazardous Waste Assessment, in accordance with WM3 Guidance, will be Site Manager completed using the testing results received from the laboratory. This Hazardous Waste Assessment will classify the waste as non-hazardous or hazardous.
24. If a waste sample is found to be hazardous in nature or to be non-compliant Site Operative with the site-specific WAC, then the corresponding waste pile will be quarantined and removed from the Site in accordance with the Waste Rejection Procedure.
Records
25. A record is kept of all vehicles delivering waste to and from the Site, along with the type, quantity and source of waste delivered.
26. Waste Transfer Notes will be appropriately stored for a minimum of two years.
27. Information from the Waste Transfer Notes will be used to provide the necessary data to complete the Waste Return as required by the Environment Agency.
Consequences
28. The consequence of not following this procedure may result in unsuitable waste being accepted on to the Site. This may constitute a breach in the conditions of the Environmental Permit, in addition to causing potential contamination of the Site.
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Pre-Acceptance Flowchart
Customer Enquiry
Is the source site known, or Yes suspected to be potentially No contaminated?
Is Waste Information No Is Waste Information available? No available?
Yes Yes
Does the information provide Is there sufficient information? (Refer Decision No sufficient analysis to determine the No Decision to Waste Characterisation Guidance) waste is uncontaminated?
Yes Yes
Accept Waste Accept Waste
Request Request Information Information (further) Yes Yes (further) Obtained obtained information? information?
No No
Reject Waste Reject Waste
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Environmental Site Setting & Design Report: Appendix 5 – Waste Acceptance Procedure
Form No. 1.1a: Waste Information V.1, November 2020
Waste Producer: Contact Name:
Telephone No.:
Please tick the box if person completing the form: Fax No.:
Waste Carrier: Contact Name:
Telephone No.:
Please tick the box if person completing the form: Fax No.:
Anticipated Volume of waste: m3 Anticipated Date(s) of delivery:
Indicate whether estimate if for: Loose / solid / stockpile GeneralInformation
Full address of source of waste (including Postcode)
Process from which waste arises:
Hazardous Waste Assessment Type of YES NO Non Hazardous Hazardous (based on WM3) carried out? Waste:
Description and/or composition of waste:
43.1 Demolition 41.1 Construction 41.2 Roads Standard Industrial Classification & Site Preparation (SIC) Code:
Please circle most appropriate
LoW 17 01 17 01 17 03 17 09 20 02 17 01 01 17 01 07 17 05 04 Other: Code: 02 03 02 04 02
Details of existing and/or previous use of site (if known)
(identify any know previous potentially polluting uses.
Has a Site Investigation been carried out? YES NO (If YES, attach ALL information e.g. testing for coal tar)
Is waste being generated as a result of site decontamination works? YES NO
Does waste contain any biodegradable material? (e.g. wood, paper, YES NO
vegetation) Information required InformationWaste for Information required
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Environmental Site Setting & Design Report: Appendix 5 – Waste Acceptance Procedure
This section is to be signed by the Waste Producer or Carrier
I/we confirm that the information given above and the chemical analysis provided with this form, are representative of the
material to be delivered.
Name(s): ………………………………………………… Signed: ………………………………………………… Declaration
This section is to be completed by the Waste Assessor i.e. Rory J. Holbrook Ltd.
Hazardous Waste Assessment (WM3) Required? YES NO
Accept the waste? YES NO
Compliance Testing to be carried out? YES NO
Frequency of Compliance Testing?
Comments:
testing and assessment and testing
Signature of Waste Assessor: Date returned: Waste
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Environmental Site Setting & Design Report: Appendix 5 – Waste Acceptance Procedure
Table 1 Permitted waste types
Exclusions Wastes having any of the following characteristics shall not be accepted: • Consisting solely or mainly of dusts, powders or loose fibres • Wastes that are in a form which is either sludge or liquid
Source Sub-source Waste code Description Additional restrictions
Wastes from mineral Restricted to waste 01 01 wastes from 01 01 02 non- metalliferous overburden and mineral excavation 01 Waste resulting excavation interburden only. from exploration, Waste gravel and mining, quarrying 01 04 wastes from crushed rocks other and physical and 01 04 08 physical and than those mentioned chemical treatment chemical processing in 01 04 06 of minerals of non-metalliferous minerals 01 04 09 Waste sand and clays
02 Waste from agriculture, horticulture, aquaculture, 02 04 wastes from Soil from cleaning and 02 04 01 forestry, hunting sugar processing washing beet and fishing, food preparation and processing
17 01 01 Concrete
17 01 02 Bricks
17 01 concrete, bricks, tiles and 17 01 03 Tiles and ceramics 17 Construction ceramics and demolition Mixtures of concrete, wastes bricks, tiles and Metal from reinforced 17 01 07 ceramics other than concrete must have been those mentioned in 17 removed. 01 06 Soil and stones other Restricted to topsoil, 17 05 soil stones and 17 05 04 than those mentioned peat, subsoil and stones dredging spoil in 17 05 03 only. Restricted to wastes from treatment of waste aggregates that are otherwise naturally Minerals (for example occurring minerals. 19 12 09 sand, stones) only Does not include fines 19 12 wastes from from treatment of any the mechanical non-hazardous waste or treatment of waste gypsum from recovered 19 Wastes from (for example sorting, plasterboard waste management crushing, facilities Including crushed bricks, compacting, tiles, concrete and Other wastes pelletising) not ceramics. (including mixtures of otherwise specified Including soils from the materials) from mechanical treatment of 19 12 12 mechanical treatment construction / demolition of wastes other than waste. those mentioned in 19 Metal from reinforced 12 11 concrete must be removed.
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Environmental Site Setting & Design Report: Appendix 5 – Waste Acceptance Procedure
Source Sub-source Waste code Description Additional restrictions
Does not include gypsum from recovered plasterboard. 20 Municipal wastes (household waste and similar commercial, Restricted to topsoil, 20 02 garden and industrial and 20 02 02 Soils and stones peat, subsoil and stones park wastes institutional only. wastes) including separately collected fractions
Table 2a: Site-specific waste acceptance criteria
L/S 10 l/kg Component mg/kg dry substance Arsenic 0.5 Barium 20 Cadmium 2,928 Chromium (total) 0.5 Copper 2 Mercury 0.01 Molybdenum 0.5 Nickel 0.4 Lead 0.5 Antinomy 0.06 Selenium 0.1 Zinc 4 Chloride 2,337 Fluoride 10 Sulphate 1,000 (*) Phenol Index 1 DOC (**) 500 Ammoniacal Nitrogen 12.99 TDS (***) 4,000 (*) If the waste does not meet these values for sulphate, it may still be considered as complying with the acceptance criteria if the leaching does not exceed either of the following values: 1 500 mg/l as C0 at L/S = 0.1 l/kg and 6 000 mg/kg at L/S = 10 l/kg. It will be necessary to use a percolation test to determine the limit value at L/S = 0.1 l/kg under initial equilibrium conditions, whereas the value at L/S = 10 l/kg maybe determined either by a batch leaching test or by a percolation test under conditions approaching local equilibrium. (**) If the waste does not meet these values for DOC at its own pH value, it may alternatively be tested at L/S = 10 l/kg and a pH between 7.5 and 8.0. The waste maybe considered as complying with the acceptance criteria for DOC, if the result of this determination does not exceed 500 mg/kg. (A draft method based on prEN 14429 is available). (***) The values for total dissolved solids (TDS) can be used alternatively to the values for sulphate and chloride (bold) Site-specific / where waste acceptance criteria differs from that of WAC for inert landfill
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Environmental Site Setting & Design Report: Appendix 5 – Waste Acceptance Procedure
Table 2b: Site Specific Waste Acceptance Criteria: Limit values for total content of organic parameters
In addition to the leaching limit values in Table 2a, wastes must meet the following additional limit values. Parameter Value mg/kg TOC (Total Organic Carbon) 30000 (*) Benzene 3746 PCBs 1 Mineral Oil (C10 to C40) 500 PAHs 100 (*) In the case of soils, a higher limit value maybe admitted by the competent authority, provided the DOC value of 500 mg/kg is achieved at L/S = 10 l/kg, either at the soil's own pH or at a pH value between 7.5 and 8.0. (bold) Site-specific / where waste acceptance criteria differs from that of WAC for inert landfill
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Environmental Site Setting & Design Report: Appendix 5 – Waste Acceptance Procedure
Procedure No. 1.2: Waste Classification V.1, November 2020 Purpose: To outline the steps to be taken to classify waste in accordance with WM3 Guidance.
RESPONSIBLE RECORD PERSON
1. This procedure describes how the Operator will test and classify waste in All accordance with the Waste Classification – Guidance on the Classification and Assessment of Waste – Technical Guidance WM3 (WM3 Guidance) produced by the Environment Agency.
2. Waste will be classified as non-hazardous or hazardous following an Site Management assessment in accordance with WM3 Guidance (Hazardous Waste Assessment). Waste classified as hazardous will need to be dealt with appropriately, as follows: • Described with an appropriate List of Waste code. • Accompanied by a Hazardous Waste Consignment Note when leaving the Site. • Sent to a suitably licensed facility.
3. A Hazardous Waste Assessment may be required in the following situations: • Waste pre-acceptance. • Compliance testing. • Removal of waste from the Site.
Further information relating to these situations can be found in the sub-sections in this Procedure.
Testing of Waste
4. Samples should be sent to a laboratory in order to obtain testing results. Site Operative
5. An ‘Environmental Suite’ should be requested from the laboratory for the Site Operative sample of waste. The Environmental Suite must contain at least the following parameters: • Total Sulphate. • Boron. • Arsenic. • Cadmium. • Metals, including; Chromium III, Chromium VI, Copper, Lead, Mercury, Nickel, Selenium, Zinc. • Acid Soluble Sulphide. • Total Phenols (Monohydric). • Total Cyanide. • pH Value. • PAH (total/speciated). • TPH (total/speciated). • BTEX. • Total Sulphate, Water Soluble Sulphate
Waste Classification
6. A Hazardous Waste Assessment will be completed using the waste analysis Site Operative results received from the laboratory. This Hazardous Waste Assessment will classify the waste as non-hazardous or hazardous.
7. A Hazardous Waste Assessment may be carried out by manual assessment or Site Operative by using a software package to determine the relevant hazardous properties of the waste.
8. A copy of the Hazardous Waste Assessment should be kept with the Duty of Site Operative Care information for that waste.
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Environmental Site Setting & Design Report: Appendix 5 – Waste Acceptance Procedure
Pre-Acceptance
9. Waste Information is requested from the supplier of the waste, such information Site Manager Form No. 1.1a could include Site Investigation reports/lab test reports. This information is Waste recorded on the Waste Information Form and the information reviewed to Information assess if the waste is acceptable or not.
10. Review of the information in the Waste Information Form will determine the Site Manager Form No. 1.1a need for a Hazardous Waste Assessment. Waste Information
11. The waste will not be accepted on to the Site if the Hazardous Waste Site Manager Assessment classifies the waste to be hazardous.
Compliance Testing
12. Compliance testing will be carried out on waste accepted on to the Site. The Site Manager purpose of compliance testing is to ensure that the information provided during pre-acceptance is correct. If a Hazardous Waste Assessment was not completed as part of pre-acceptance then compliance testing and a Hazardous Waste Assessment will be carried out.
13. Any waste that is found to be hazardous will be quarantined before being sent Site Operative off Site to a suitably licensed facility.
Removal of Waste
14. All waste that has been classified as hazardous will need to be sent to a suitably Site Operative licensed facility, accompanied by a Hazardous Waste Consignment Note.
15. Any waste that has not been imported on to the Site, and therefore has not Site Manager been classified, will need to be tested and classified. The exception to this would be any waste that is known to be hazardous e.g. waste oils.
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Environmental Site Setting & Design Report: Appendix 5 – Waste Acceptance Procedure
Procedure No. 1.3: Waste Rejection V.1, November 2020 Purpose: To ensure non-compliant waste is rejected and that associated records of rejected loads are created.
RESPONSIBLE RECORD PERSON
Reasons for Rejection
1. A waste may be non-conforming and rejected from the Site for the following Site Manager Waste Transfer reasons: Notes • Delivery vehicle is unsuitable for Site operations / conditions. • The waste is not acceptable at the Site under the Environmental Permit. • There is a prohibited waste within the load. • The load is not accompanied by the correct documentation. • The waste does not match the description on the accompanying documentation. • The waste is unsuitable for treatment. • The waste contains putrescible waste.
The list is not exhaustive, if you are unsure speak to the Site Manager.
2. If a waste is identified as being unacceptable at the Site entrance or at the point Site Manager Form No. 1.3a of offloading the Site Manager is contacted and a Waste Rejection Form is Waste Rejection issued to the driver.
3. The driver of the load is informed of the load’s rejection. The driver will be Site Manager informed of the reasons for this and requested to leave the Site.
4. If the load is being rejected because the description of the waste on the transfer note is incorrect, the driver may be given the opportunity to correct the mistake so long as the waste is acceptable at the Site.
5. In the event of a rejected load the Environment Agency may be contacted by Site Manager telephone and / or email with details of the rejected load. These details should include information relating to the nature and quantity of waste involved, the time and date, the name and address of the waste producer, the registration number of the vehicle delivering the waste and the name and address of the vehicle driver and haulage contractor.
6. If the load is not safe to be sent back onto the road, then the vehicle is kept in the Quarantine Area until appropriate arrangements can be for its removal.
Waste rejected after offloading of the vehicle
7. If appropriate, a rejected load should be reloaded onto the delivery vehicle.
8. If waste cannot be reloaded onto the delivery vehicle, the waste will be stored in the quarantine area. The customer will be contacted, arrangements to remove the quarantined waste will be made and a copy of the rejection form containing reasons for the rejection will be supplied.
9. If arrangements for the customer to remove the waste cannot be made, Rory J. Site Manager Holbrook Limited will make these arrangements themselves. Waste material in the quarantine area will be exported off Site by a licensed waste carrier to an appropriately licensed facility. If necessary, Rory J. Holbrook Limited will contact the EA regarding the rejection of the waste.
10. Waste will be stored for a maximum of seven working days in the quarantine Site Manager area.
11. Details of any unauthorised waste and its subsequent removal from Site is Site Manager Form No. 1.3a recorded and retained on Site. Waste Rejection
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Environmental Setting and Site Design Report
Appendix 4
Environmental Risk Assessment
Elveden Farms Limited: Lakenheath Country Club, Suffolk
Environmental Setting and Site Design Report: Appendix 4, Environmental Risk Assessment Environmental Risk Assessment
Data and Information Judgement Action (By Permitting)
Probability of Magnitude of Justification for Residual Receptor Source Harm Pathway Consequence Risk Management Exposure Risk Magnitude Risk
Local human Releases Harm to Air transport Medium Medium Low Construction materials, A number of mitigation measures Low population, of dust. human health - then that will be used for the are used to reduce the risk of Including respiratory inhalation. development of the bund, dust emissions. industrial units, irritation and will by their nature have neighbouring illness. the potential to be dusty. Strict waste acceptance businesses Residents and procedures are in place to and residential commercial / independent ensure that excessively dusty dwellings. businesses e.g. loads are not accepted on Site. restaurants and manufacturers, are All vehicles on Site will be located proximate to the restricted to a 5mph speed limit Site and may be sensitive to reduce the dispersion of dust to dust emissions. by vehicle movements.
The proposed waste Vehicle movement will be types are non-hazardous restricted as much as possible, and predominantly soil there will be no unnecessary based materials. double handling of materials – materials will be deposited in the Incoming loads will be construction works as required deposited straight on the and arrange by the Site construction works after Manager. acceptance and will take place outdoors. This is Vehicles will be sheeted before where the majority of dust arrival to the Site to reduce dust generation is going to dispersion from the load during occur – through the transport and restrict any handling and transport of debris/material falling form the materials. vehicle.
There will be no treatment Materials deposited on the activities on Site to construction works will be produce waste. Waste dropped from minimal heights to will already be treated on reduce atmospheric dispersion of arrival to Site and will be dust during handling. deposited directly onto the bund.
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk 1 Environmental Setting and Site Design Report: Appendix 4, Environmental Risk Assessment
Probability of Magnitude of Justification for Residual Receptor Source Harm Pathway Consequence Risk Management Exposure Risk Magnitude Risk
Nuisance - Air transport Medium Low Low As above. Businesses in Should excessively windy and/or Low dust on cars, then close proximity to the Site arid climatic conditions influence clothing etc. deposition have associated car the amount of dust generation on parks. Site, both a road sweeper and dust spraying suppression will be used on the Site access roads and also water suppression during the deposit of materials.
If climatic conditions are classified as unmanageable, cessation of works will be temporarily ordered by the Site Manager until condition improve to manage the dust suppression requirements.
Methods of Dust management are included in the Dust Management Plan, which is included in this permit application.
The Dust Management Plan will form part of the Environmental Management System (EMS) for the site and will be implemented using procedures. Surface water Releases Harm to Air transport Very low Low Low Proposed waste types are Waste transfer operations that Low features, of dust surface water then non-hazardous. The have the potential to generate including features deposition permitted waste stored on dust are completed outside. nearby ponds through toxic the Site has the potential contamination. to be dusty. Methods of dust management are included in the Dust Incoming waste is used Management Plan, which is for construction works in included in this permit the bund and stored application. outside. The Dust Management Plan will form part of the EMS for the site and will be implemented using procedures.
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk 2 Environmental Setting and Site Design Report: Appendix 4, Environmental Risk Assessment
Probability of Magnitude of Justification for Residual Receptor Source Harm Pathway Consequence Risk Management Exposure Risk Magnitude Risk
Local human Litter Nuisance, loss Air transport Low Low Low Proposed waste will have Control of litter will be included in Very Low population, of amenity and then already been treated the Housekeeping Procedure Including harm to animal deposition upon arrival and are within the EMS and is included industrial units, health unlikely to contain any on the inspection checklists. neighbouring contravening waste or businesses litter. Incoming waste can be and residential handpicked to remove waste dwellings. There is a low chance of types that may generate litter if litter being generated by deemed necessary during waste Deciduous the acceptance of soils acceptance. Handpicked waste woodland and and aggregate materials. will be stored within containers to SSSI / SPA / prevent the escape of litter. SAC’s Inspection checklists will include litter checks that will be carried out on a regular basis to identify and remove any litter on the site. Waste Nuisance, loss Vehicles Low Low Low Road safety, local As above. Very Low and litter of amenity, entering and residents often sensitive on local road traffic leaving the to waste / litter being Proposed waste will have roads accidents. site spread on roads. already been treated upon arrival and are unlikely to contain any contravening waste or litter and therefore has a low potential to generate waste or litter that could reach local roads.
Inspection checklists will include litter checks that will be carried out on a regular basis to identify and remove any litter on the site. Local human Odour Nuisance, loss Air transport Very Low Low Low Local residents often No putrescible waste types are Very Low population, of amenity then sensitive to odour, accepted on to the Site, as such Including inhalation. however permitted waste it is unlikely that odour will be an industrial units, types are not putrescible issue. Soil and aggregates are neighbouring and have low to zero not considered to be odorous. businesses potential to emit odour. and residential The implementation of strict dwellings. waste acceptance procedures and criteria will ensure that no putrescible waste types are accepted onto the site. Good housekeeping methods will be
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk 3 Environmental Setting and Site Design Report: Appendix 4, Environmental Risk Assessment
Probability of Magnitude of Justification for Residual Receptor Source Harm Pathway Consequence Risk Management Exposure Risk Magnitude Risk
actively maintained to reduce risk of odour from the site. Local human Noise Nuisance, loss Noise Medium Medium Medium Local residents often A number of mitigation measures Low population, of amenity, through the sensitive to noise. will be in place to minimise noise. Including loss of sleep. air and Such mitigation measures industrial units, vibration include no leaving plant idling neighbouring through the and minimising drop heights as businesses ground. far as reasonably practicable. and residential dwellings. Waste activities that generate noise emissions are carried out exclusively within the operational hours of the Site. Local human Scavengi Harm to Air transport Low Medium Low Proposed waste types do The implementation of strict Very Low population, ng human health - and over not contain putrescible waste acceptance procedures Including animals from waste land. waste and are therefore and criteria will ensure that no industrial units, and carried off site unlikely to attract pests, putrescible materials, that are neighbouring scavengi and faeces. scavenging animals and attractive to scavenging species businesses ng birds Nuisance and birds. The Site may or pests, will be accepted on to and residential loss of become breeding / the site. dwellings. amenity. nesting sites for pests, scavenging animals Pests Harm to Air transport Low Medium Low Very Low and/or birds. The site will be inspected (e.g. human health, and over regularly for evidence of flies). nuisance, loss land. infestations and the findings will of amenity. be recorded on Inspection Checklists. If any evidence is found, an appropriate specialist contractor shall be called in to manage / eradicate the problem.
Local human Flooding If waste is Flood Low Medium Medium It is reported that the Site All waste construction is taking Low population, of the washed off waters. is not located in an area place outside. It is therefore Including Site. site, it may with a risk of flooding from considered waste will disperse industrial units, contaminate rivers / seas. It is reported into surface waters when neighbouring buildings / that the site is located in apparent on Site. businesses gardens / an area with a low risk of and residential natural flooding from surface Surface water/ reservoir flooding dwellings. habitats water. It is reported that waters may come into contact downstream. the site is in an area with with the construct works on the Deciduous a low risk of flooding from northern boundary of the Site but woodland and reservoirs. given the absence of surface water receptors nearby, it is
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk 4
Environmental Site Setting & Design Report: Appendix 5 – Waste Acceptance Procedure
Form No. 1.3a: Waste Rejection Form V.1, November 2020
Customer / Producer (if Haulier: different):
Contact: Contact:
Phone: Phone:
Fax: Fax:
Email: Email:
Transfer Note Date: No:
Vehicle Time: Registration:
Carriers Drivers Certificate: Name:
Reason for Rejection:
Actions Taken:
You MUST inform the Site Manager or other member of management before taking any further action.
Site Manager Informed:
Destination for Waste:
Transfer Note No: Date:
Vehicle Registration: Time:
Carriers Certificate: Drivers Name:
Hazardous: Yes / No Consignment Note No:
Signed Date
Name Position
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Environmental Setting and Site Design Report: Appendix 4, Environmental Risk Assessment
Probability of Magnitude of Justification for Residual Receptor Source Harm Pathway Consequence Risk Management Exposure Risk Magnitude Risk
SSSI / SPA / The area to the north east considered that the waste will not SAC’s. of the Site has a low- risk readily leach significant of flooding from concentrations of contaminants reservoirs. into the surface water.
There is a very low – nil The waste is therefore risk of flooding from seas considered to pose a low risk to or rivers as the closest nearby surface water features. significant water source is the River Lark The EMS will include a Flood approximately 6.25km Management Plan for the Site. south of the Site. The The Flood Management Plan land between the Site and includes key contact information the river is agricultural and a description of the actions to and forested land, as be taken in case of a flood on such, flood waters are site. likely to percolate down through the ground. This All staff will be trained on will reduce the likelihood procedures implemented by the of surrounding potential Flood Management Plan and flood waters reaching the with regard to the location of River Lark and other utility cut off points. ponds.
Waste types accepted on to the site are non- hazardous. Waste is unlikely to leach contaminants into the surface water due to the nature of the waste. Staff, local All on- Bodily injury. Direct Medium Medium Medium Proposed incoming waste The EMS will include an Low human site physical types are soils and Environmental Accident population, hazards: contact. aggregates, which does Management Plan for the Site. Including wastes; not pose a significant risk The Environmental Accident neighbouring machiner to health in terms of Management Plan contains businesses y and irritation or injury from accident and incident procedures and residential vehicles. direct physical contact. which outline what is required if dwellings. There is a chance that there is an accident on Site. proposed incoming waste types could pose a risk if The EMS will also contain a Near contravening wastes are Miss Reporting Procedure which present such as sharp will include information on objects. reporting near misses, with the
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk 5 Environmental Setting and Site Design Report: Appendix 4, Environmental Risk Assessment
Probability of Magnitude of Justification for Residual Receptor Source Harm Pathway Consequence Risk Management Exposure Risk Magnitude Risk
aim of avoiding potential There is a risk that sharp accidents / incidents in the future. edges of waste or sharp objects e.g. metal could Staff are required to wear PPE at cause bodily harm during all time on the Site – hard hats, the handpicking process high visibility clothing and gloves. should it be required. Plant and equipment on the Site Machinery equipment on is regularly checked as part of the the Site could cause Site inspection regime. Any bodily injury if misused or faults identified during these if malfunctioning. checks will be rectified by the Site Manager.
The Maintenance Procedure within the EMS contains a list of Plant / Equipment and their servicing requirements. A record is kept when plant / equipment is serviced. Regularly servicing plant / equipment will identify and rectify issues before they potentially cause a malfunction. Elveden Storage Respiratory Respiration. High Medium Medium Waste accepted on to the Waste transfer activities are Low Farms Limited of waste irritation and site is non-hazardous. completed outside. The treeline staff, local and illness. and hedge row on the A1065 will human waste There are no treatment screen nearby sensitive population, moveme activities completed on receptors from dust emissions. Including nt Site, waste is brought The particle size (and weight) of industrial units, onto site and deposited the waste means that particles neighbouring within the construction are likely to dropout of the air businesses works of the bund, which before they reach sensitive and residential can generate dust. Dust receptors. dwellings. can be inhaled if a person is in close proximity to the Staff carrying out waste transfer transfer activities. activities are required to wear PPE i.e. face masks in dry Waste by its nature is conditions, to prevent the friable and as a result has inhalation of dust. small particles, which when unsettled could be inhaled.
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk 6 Environmental Setting and Site Design Report: Appendix 4, Environmental Risk Assessment
Probability of Magnitude of Justification for Residual Receptor Source Harm Pathway Consequence Risk Management Exposure Risk Magnitude Risk
Elveden Farms Arson Respiratory Air transport Very Low Medium Low The site is located The implementation of strict Very Low Limited staff, and / or irritation, of smoke. opposite the RAF base of Waste Acceptance Procedure local human vandalis illness and Spillages Lakenheath with access will ensure that no waste types population, m nuisance to and off the A1065, Brandon other than those outlined in the Including causing local contaminate Road, through a lockable Environmental Permit (soils and industrial units, the population. d firewater by gated entrance. Aggregates) are accepted on to neighbouring release Injury to staff, direct run-off the Site. businesses of fire fighters or from the Site. Construction works is and residential polluting arsonists/vand completed outside and Any incidental combustible waste dwellings. materials als. Pollution of additional gated areas on types within incoming loads will to air water or land. Site will be locked outside be handpicked from the load and Deciduous (smoke of operational hours. stored in container(s). woodland and or SSSI / SPA / fumes), Waste accepted onto site These containers act as a fire SAC’s. water or is not combustible in break and prevent immediate land. nature. Ignition methods access which reduces the used in arson are unlikely likelihood of a fire spreading and to reach and sustain the a fire occurring as a result of required temperature to arson. ignite the waste. The fire would be unlikely to The EMS contains a Fire sustain itself without a Prevention Procedure which significant amount of includes information relating to accelerant. minimising the risk of fire on the Site. There is a chance that handpicked waste could The EMS also contains a Site be combustible. A small Security Procedure which amount of handpicked includes information relating to waste is stored minimising the risk of appropriately on the Site, unauthorised entry on to the Site. in containers. Elveden Farms Accident Respiratory Air transport Very Low Medium Low The implementation of strict Low Limited staff, al fire irritation, of smoke. Fuel will not be stored on Waste Acceptance Procedure local human causing illness and Spillages the site. will ensure that no combustible population, the nuisance to and waste types are accepted on to Including release local contaminate Pollutants may spread to the site. Any incidental industrial units, of population. d firewater by protected areas and combustible waste types within neighbouring polluting Injury to staff direct run-off neighbouring residents incoming loads will be businesses materials or fire fighters. from the Site. and businesses. handpicked from the load and and residential to air Pollution of stored in container(s). These dwellings. (smoke water or land. containers act as a fire break or against ignition sources and a Deciduous fumes), fire spreading, which reduces the woodland and likelihood of accidental fires.
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk 7 Environmental Setting and Site Design Report: Appendix 4, Environmental Risk Assessment
Probability of Magnitude of Justification for Residual Receptor Source Harm Pathway Consequence Risk Management Exposure Risk Magnitude Risk
SSSI / SPA / water or SAC’s. land. The EMS will contain a Fire Prevention Procedure which includes information relating to minimising the risk of fire on the Site. Staff will be trained on how to prevent fires and what to do in the event of accidental fires. All surface Spillage Acute effects: Direct run-off Very Low Medium Medium Proposed waste types do Implementation of strict waste Low waters on, of liquids, oxygen from site not include sludges or acceptance criteria will ensure close to and leachate depletion, fish across liquids. No point source that only permitted waste types downstream of from kill and algal ground emissions to water are are accepted and stored on the the site -The waste, blooms. surface, via proposed. Site, which typically contain a River Lark is contamin run-off. very low concentration of located ated Proposed waste types are contaminants. approximately rainwater non-hazardous and are 6.25km south run-off unlikely to leach Infrastructure associated with the of the Site. from significant concentrations drainage system, including the There is a waste of contaminants into surfacing and drains, will be pond e.g. surface water. Proposed checked as part of the Inspection approximately containin waste types are therefore Checklists. Any defects / 700m north g unlikely to cause blockages in the drainage west of the suspend contamination of surface system will be rectified. Site which ed solids. waters. feeds a Liquids will be not be stored on stream, Fuel will not be stored on Site. connected to the Site. the River Lark. The Spillage and Refuelling It is considered that there Procedures within the EMS is a negligible potential for implement the requirement for contaminated rainwater spill kits to be in place in the run-off from waste stored event of a spillage to clean the on Site reaching The spill up. Staff will be trained on River Lark due to its the Spillage Procedure to ensure distance from the Site and they are aware of the use of spill the very low risk of kits and what to do in the event of surface water flooding a spill. and river/sea flooding on the Site.
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk 8 Environmental Setting and Site Design Report: Appendix 4, Environmental Risk Assessment
Probability of Magnitude of Justification for Residual Receptor Source Harm Pathway Consequence Risk Management Exposure Risk Magnitude Risk
Groundwater – Spillage Chronic Transport Low Low Low Proposed waste types do Surface water is unlikely to come Low The Site is of liquids, effects: through soil / not include sludges or into contact with waste. It is located on a leachate contamination groundwater. liquids. No point source considered that waste will not Groundwater from of emissions to water are readily leach significant Source waste, groundwater, proposed. concentrations of contaminants Protection contamin requiring into the surface water. The site Zone 1 (Inner ated run- treatment of Proposed waste types are is therefore considered to not Protection off from water. non-hazardous, unlikely pose a risk to groundwater or Zone). waste to leach significant nearby surface water features. e.g. concentrations of The Site is containin contaminants into surface Waste acceptance procedures located on a g water. Proposed waste will be implemented on the site to Principal suspend types are therefore ensure that no contaminated designated ed solids. unlikely to cause waste types are accepted under bedrock contamination of surface the Environmental Permit. aquifer. The waters. Site is not Implementation of the located on a requirements of the EMS will designated ensure that polluting substances superficial will not contaminate the aquifer groundwater. deposit. Local human Contamin Harm to Direct Very Low Low Very Low Unlikely to occur but As above. Very Low population - ated human health contact or might restrict recreational Including waters - skin damage ingestion use. residents used for or gastro- using nearby recreatio intestinal There are no waters used surface water nal illness. for swimming / other features e.g. purposes sports located in close ponds / lakes. proximity to the Site. Nearby ponds / lakes are used for fishing, but there is likely to be no direct affect to residents as the fish are caught for sport, rather than food and are too far away to be considered a direct receptor.
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk 9 Environmental Setting and Site Design Report: Appendix 4, Environmental Risk Assessment
Protected sites Any Harm to Any High Medium Medium The River Lark is located The following potential sources Low – SSSI, SPA protected site approximately 6.25 km are cross referenced from the and SAC and through toxic south of the Site. It is justification of magnitude (left) a number of contamination, considered very unlikely and identify the management of areas of nutrient that dust or noise would potential hazards associated with deciduous enrichment, reach the River Lark, due each source: woodland, the smothering, to its location and the closest of disturbance, screening from trees 1. Dust emissions from the Site which is predation etc. located between the Site will be minimised. Dust located direct and River. mitigation measures are included on the Site in in the Dust Management Plan the form of the Waste operations have and will be implemented by Breckland the potential to harm procedures within the EMS which Farmland deciduous woodland and control operations that have the SSSI, wildlife within the potential to generate dust and Breckland woodland, due to its implement the use of dust SPA, close proximity to the mitigation measures and control. Lakenheath Site. Dust mitigation will include use of Warren SSSI water suppression and road and the Harm may arise from the sweeper, handling procedures Breckland following sources: SAC. 2. Waste accepted on Site is not 1. Dust putrescible, as such it is not the type of material that would attract 2. Litter scavenging animals.
3. Contamination from 3. The nearby ponds will be taken surface water run-off. into consideration in the EMS which will include general flood management and surface water management procedures. It is considered that the management of these potential hazards would result in a low residual risk to the protected habitat in the vicinity of the Site. Please see above entries relating to flooding and surface water contamination.
It is considered that the management of potential hazards would results in a low residual risk to the protected sites.
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk 10
Environmental Setting and Site Design Report
Appendix 5
Hydrogeological Risk Assessment
Elveden Farms Limited: Lakenheath Country Club, Suffolk
HYDROGEOLOGICAL RISK ASSESSMENT
LAKENHEATH COUNTRY CLUB WASTE RECOVERY OPERATION
Report Reference: 2990/HRA FINAL VERSION F1 November 2020
Report prepared for:
Elveden Farm Limited Estate Office London Road Elveden THETFORD Norfolk IP24 3TQ
Barkers Chambers Barker Street Shrewsbury United Kingdom S Y 1 1 S B T : 01743 355770 F: 01743 357771 E : [email protected]
Elveden Farm Ltd Lakenheath Country Club HYDROGEOLOGICAL RISK ASSESSMENT
GENERAL NOTES
Title of report: Hydrogeological risk assessment Site: Lakenheath Country Club Waste Recovery Operation Report ref: 2990/HRA Date: November 2020
Version Date Issued to
Draft: D1 30th October 2020 Westbury Environmental Draft: D1.1 3rd November 2020 Westbury Environmental Draft D2 11th November 2020 Westbury Environmental Final version F1 19th November 2020 Westbury Environmental
Author: Rosie Morrant BSc MSc FGS Reviewer: Heather Macleod BSc MSc FGS
This report has been prepared by Hafren Water Ltd for the named Client, with reasonable skill, care and diligence within the agreed scope and terms of contract. Hafren Water Ltd disclaims any responsibility to the client and others in respect of any matters outside the agreed scope of work. This report has been prepared for use by the client and others acting on their behalf. The report may be passed to regulators. This report does not constitute legal advice or opinion.
This report does not represent advice to third parties and no reliance is offered to third parties. No liability is accepted with regard to third parties. Reliance required by any specific Third Party must be agreed in writing with Hafren Water Ltd.
P:\Projects\Lakenheath\2020-Permit\Reports\HRA\2990_HRA_vn F1 (November 2020).docx
Version: F1 November 2020 Page i Elveden Farm Ltd Lakenheath Country Club HYDROGEOLOGICAL RISK ASSESSMENT
CONTENTS
1 INTRODUCTION ...... 1
1.1 Report context ...... 1
2 BASELINE CONDITIONS ...... 2
2.1 Site details ...... 2 2.1.1 Site location and setting ...... 2 2.1.2 Landform...... 2 2.1.3 Cultural heritage ...... 3 2.1.4 Waste activities ...... 3 2.1.5 Environmental and ecological sites of interest ...... 3 2.1.6 Rainfall ...... 4 2.1.7 Watercourses and site catchment ...... 5 2.1.8 Waterbodies ...... 6 2.1.9 Surface water abstractions ...... 6 2.1.10 Water Framework Directive - Surface Water ...... 6 2.1.11 Surface water quality ...... 7 2.2 Geological setting ...... 8 2.3 Hydrogeological setting ...... 10 2.3.1 Aquifer designation ...... 10 2.3.2 Groundwater levels and flow ...... 10 2.3.3 Water Framework Directive - Groundwater ...... 11 2.3.4 Groundwater quality ...... 11 2.3.5 Groundwater abstractions ...... 13 2.4 Historical site development ...... 14 2.5 Conceptual hydrogeological understanding ...... 14
3 PROPOSED DEVELOPMENT ...... 16
3.1 Post-closure controls...... 18 3.1.1 Surface water run-off control ...... 19 3.1.2 Groundwater control ...... 19 3.1.3 Construction engineering ...... 19
4 SOURCE, PATHWAY, RECEPTOR ...... 20
4.1 Source ...... 20 4.2 Pathways ...... 20 4.3 Receptors ...... 20
5 HYDROGEOLOGICAL RISK ASSESSMENT ...... 23
5.1 Nature of the Hydrogeological Risk Assessment ...... 23 5.2 Risk screening ...... 23 5.2.1 Location ...... 23 5.2.2 Waste types ...... 24 5.2.3 Waste Acceptance Procedures ...... 24 5.2.4 Compliance with Environmental Permitting (England and Wales) Regulations (2016) ...... 25 5.2.5 Proposed technical precautions ...... 25 5.2.6 Screening assessment ...... 25 5.3 Proposed assessment scenarios ...... 26
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Elveden Farm Ltd Lakenheath Country Club HYDROGEOLOGICAL RISK ASSESSMENT
5.3.1 Lifecycle phases ...... 26 5.3.2 Failure scenarios and accidents ...... 26 5.4 Generic quantitative risk assessment ...... 27 5.4.1 Environmentally Acceptable levels ...... 27 5.4.2 Justification for modelling approach and software ...... 28 5.4.3 Model parameterisation ...... 29 5.4.4 Results of the risk assessment ...... 32 5.5 Review of technical precautions...... 32 5.6 Emissions to groundwater ...... 33 5.6.1 Hazardous substances ...... 33 5.6.2 Non-hazardous pollutants ...... 33 5.6.3 Surface water management ...... 34 5.7 Emissions to surface water ...... 34
6 REQUISITE SURVEILLANCE ...... 35
6.1 Risk-based monitoring scheme ...... 35 6.2 Groundwater monitoring ...... 35
7 CONCLUSIONS ...... 36
7.1 Compliance with the Environmental Permitting (England and Wales) Regulations (2016) ...... 36
8 REFERENCES ...... 37
TABLES
2990/HRA/T1: Average monthly rainfall (February 1996 – January 2020) ...... 4 2990/HRA/T2: Average monthly rainfall, potential transpiration from MAFF data ...... 5 2990/HRA/T3: Surface water quality data (2015 – 2020) ...... 7 2990/HRA/T4: Regional geological succession ...... 8 2990/HRA/T5: Groundwater quality data ...... 12 2990/HRA/T6: Permitted waste types ...... 16 2990/HRA/T7: Phase areas ...... 18 2990/HRA/T8: Summary of identified receptors and pathways ...... 21 2990/HRA/T9: Derivation of EALS for Hazardous substances ...... 28 2990/HRA/T10: Quality standards and background levels for Non-hazardous pollutants...... 28 2990/HRA/T11: Model input parameters ...... 29 2990/HRA/T12: Results of quantitative risk assessment ...... 32
DRAWINGS
2990/HRA/01 Site layout 2990/HRA/02 Site location and setting 2990/HRA/03 Sites of environmental and ecological interest 2990/HRA/04 Hydrology 2990/HRA/05 Geology & abstractions 2990/HRA/06 Local hydrogeology 2990/HRA/07 Schematic site conceptual model
APPENDICES
2990/HRA/A1 Phasing drawings of progressive operation 2990/HRA/A2 Results from RAM Model
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1 INTRODUCTION
1.1 Report context
Lakenheath Country Club, the “site”, is a clay shooting centre located near Brandon, Suffolk, owned by Elveden Farm Limited. Planning Permission (reference F/2005/0015/FUL) was granted in August 2006, and planning variation (reference F/2009/0073/VAR) was granted in March 2009, by Forest Heath District Council. These permissions permit the site to replace buildings, erect three clay target towers, alter vehicular access and create landscaped bunding. The bund will be constructed in line with the above planning permissions.
A Waste Recovery Plan (Westbury Environmental Ltd, November 2019) has been accepted by the Environment Agency as a deposit of waste for recovery activity. The approved Waste Recovery Plan proposes the construction of the noise screening bund from waste materials. This waste recovery operation requires a permit under the Environmental Permitting (England and Wales) Regulations (EPR) (2016).
This report sets out the Hydrogeological Risk Assessment (HRA) that has been prepared in support of the Environmental Permit Application for a bespoke waste recovery permit. The HRA has been prepared with due regard to the hydrogeological risk assessment guidance (Environment Agency, 2016) and template (Environment Agency, March 2010) provided by the Environment Agency. Additional detail of the baseline conditions of the water environment and receptors have been included within this report to allow the conceptual model to be described.
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2 BASELINE CONDITIONS
Baseline conditions of the water environment and receptors are set out below, which are then used to derive a conceptual model for the proposed waste recovery operation. The land raising operation will be located around the perimeter of the site. The bund area and the Application Area boundary is shown on Drawing 2990/HRA/01.
2.1 Site details
2.1.1 Site location and setting
The site location and setting is shown on Drawing 2990/HRA/02.
The site extends across 35 hectares (ha) of greenfield grassland, with the bund occupying around half of this space (c14.5 ha). The perimeter bund is approximately centred at National Grid Reference (NGR) TL 7393 8014 around the existing country club buildings (Drawing 2990/HRA/02). Access to the site is via the A1065 (Brandon Road) at the southwestern extent of the site, at NGR TL 73490 80150.
The site is bordered to the west by the Brandon Road (A1065), with the village of Little Eriswell and the Lakenheath RAF base beyond and to the north. The village of Lakenheath is located 2.4 km northwest of the site. The closest residential buildings are located within the RAF airbase, located 60 m to the northwest at its closest point. Three school or educational buildings have been identified within the base. The main RAF airfield is located over 1 km to the north.
Land to the northeast, east and south comprises of marsh/heathland, forestry or agricultural land cover. There are no other buildings within 1 km distance from the site to the east or south. The closest buildings to the east and south are a single building marked “Warren Lodge” located 1.05 km to the northeast, Cranhouse Farm located 1.1 km to the southeast and a Lodge located 1.2 km to the southwest.
2.1.2 Landform
The site lies on the eastern side of a main drain known as the Cut-Off Channel. Low-lying fenlands are located to the west of the Cut-Off Channel, at elevations of approximately between 0–5 metres Above Ordnance Datum (mAOD). To the east of the Channel, within the vicinity of the site, the land remains fairly low-lying, but slightly more undulating, between 5–30 mAOD. Ground elevations within the site are approximately between 9–14 mAOD.
There is a slight decline in elevation from the site in a northerly and northwesterly direction, towards a tributary of the Cut-Off Channel. The local high points at around 50 mAOD are
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located approximately 4 km to the northeast within Wangford Warren, and approximately 3 km to the southeast at Rakeheath.
2.1.3 Cultural heritage
A search of the Magic website (Magic.defra.gov.uk) indicates that no scheduled monuments or listed buildings are present within a 1 km radius of the site. The closest listed building is 1.2 km to the west. The closest scheduled monument is 1.3 km to the southeast (Drawing 2990/HRA/02).
2.1.4 Waste activities
There are no authorised or historic landfills within 2 km of the site. The closest landfill is a historic site located 2.3 km to the north.
Elveden Farms Recycling Facility is an active waste management site for recovery of waste, located 220 m west of the site (Drawing 2990/HRA/02). The facility is registered as a Physical Treatment Facility under Permit EA/EPR/HB3305TR/V002. Non-hazardous waste for recovery is manually and mechanically sorted, separated, crushed, screened and blended. The Permit was issued in 2016, however, the site did not become fully operational until 2019.
A single discharge consent is located within 500 m of the site, 30 m to the north of the site boundary, directly adjacent to the RAF Lakenheath Visitor Centre. The consent is held by the Ministry of Defence under Permit AN/NPSWQD000438/001 and the type of discharge is given as “Prisons/MOD Sites/Public Admin+Defence+Comp Social Sec”. No clear information on the nature or outfall location of this discharge has been provided.
Historic waste activities on-site have been authorised under exemptions from waste permitting (licensing) and low risk waste positions. Further information on historical site uses is provided in Section 2.4.
2.1.5 Environmental and ecological sites of interest
The Application Area is within the Breckland Farmland Site of Special Scientific Interest (SSSI) and within the Breckland Special Protection Area (SPA). The Lakenheath Warren and Eriswell Low Warren, and Foxhole Heath SSSI’s, Breckland Special Conservation Area (SAC) are also located within 1 km of the site. These designated areas are shown on Drawing 2990/HRA/03.
The SSSI sites are generally lowland heath areas designated to protect a range of plants as well as a variety of breeding birds. Of specific note is Stone Curlew which is specially protected by being listed on Schedule 1 of the Wildlife and Countryside Act 1981, the
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European Communities Directive 79/409/EEC on the Conservation of Wild Bird and UK Biodiversity Action Plan.
The Elderbush Belt Deciduous Woodland, located at the west and southwest of the site, is an area of Protected Habitat.
These designated areas, within the permit boundary and within the immediate vicinity of the site, are not considered to be water-supported.
2.1.6 Rainfall
Monthly average rainfall has been provided by the Environment Agency for their Mildenhall raingauge (reference 186712), located outside Mildenhall (NGR TL 69320 74836), 7 km southwest of the site. The data are presented in Table 2990/HRA/T1.
2990/HRA/T1: Average monthly rainfall (February 1996 – January 2020)
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Rainfall 43.7 36.1 33.0 33.3 46.7 49.0 50.6 56.9* 43.2 54.6 53.9 48.0 All units = mm * Excluding August 2014 data
Long-term annual average (LTA) rainfall for the Mildenhall raingauge (February 1996–January 2020) is 549.1 mm. The maximum total annual rainfall was recorded at 773.2 mm (in 2012) and minimum of 343 mm (in 1996).
The maximum monthly rainfall for the Mildenhall raingauge during this period was 684.2 mm recorded during August 2014. This value has been excluded from the average values calculated above as it appears erroneously large considering the next highest monthly rainfall is recorded as 137 mm recorded in July 2012. The minimum monthly rainfall of 0.6 mm was recorded in April 2007.
MAFF (Ministry of Agriculture Food and Fisheries) Technical Bulletin B4 for this area (Area 24) gives the long-term annual rainfall as 623 mm with a rainfall range given as 520 to 710 mm. Data for Area 28 is summarised in Table 2990/HRA/T2.
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2990/HRA/T2: Average monthly rainfall, potential transpiration from MAFF data
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Rainfall 55 45 40 40 46 49 55 66 52 54 66 55 Potential 1 10 32 57 85 95 95 78 50 22 5 0 transpiration Effective 54 35 8 0 0 0 0 0 2 32 61 55 rainfall All values in mm
These are a similar order of magnitude to the recent Mildenhall data and are used in the quantitative risk assessment modelling.
2.1.7 Watercourses and site catchment
The locations of the main rivers and other water features are shown on Drawing 2990/HRA/04.
The Cut-Off Channel is the closest major watercourse to the site, located 1.7 km west of the site at its closest point, and classified as a main river by the Environment Agency. The channel is used at times in summer to transfer water from the Ely Ouse catchment down to Essex in order to top-up reservoirs, causing a temporary reversal of flow downstream of the site. It is an unlined man-made drain dug into the superficial clays and chalk bedrock, and is maintained by the EA; a hydraulic connection between groundwater and surface water is considered likely (pers comms Andy Newton, IDB Engineer, October 2020).
The Cut-Off Channel flows northwards, and water is syphoned under the Little River Ouse, 6.5 km to the north of the site. The Little River Ouse is another main river which flows from west to east. A sluice system connection is present between the two watercourses, however this is only used as a flood alleviation scheme (pers comms Andy Newton, IDB Engineer, October 2020).
The low-lying land to the west of Cut-Off Channel is characterised by field drains which are connected to the Cut-Off Channel. A limited network of land drains is also present to the west of Little Eriswell, between Eriswell Road and the Cut-Off Channel. Drainage in these areas is managed by several different Internal Drainage Boards (IDB). The IDB operates a pumping station on a minor drain to the north of Lakenheath, which transfers water from the minor land drains to the Little River Ouse.
The site is located on grassland that slopes gently northwestwards towards Brandon Road and towards the closest minor watercourse to the site, a minor tributary of the Cut-Off
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Channel (Drawing 2990/HRA/04). This watercourse rises from an issue to the west of the airfield, located 1.1 km to the northwest of the site, and also drains to this minor watercourse; it is not understood whether this is a culverted groundwater issue from River Terrace Deposits, or a drainage outfall from within the airfield. However, there are no springs or spring issues mapped within 2 km of the proposed site. Water also drains to the watercourse from a waterbody known as Caudle Head, which is located 630 m to the northwest of the site on exposed chalk bedrock, at the edge of the superficial Cover Sand deposit.
Locally, ground level elevations are highest to the northeast and southeast of the site, and decline to the north and west. Run-off into the site under greenfield conditions, is therefore possible only from the south, east and northeast. Run-off from the site will be towards the north and west. Run-off will not enter the site following completion of the bund around the site perimeter.
The site is located within Flood Zone 1, and is not located within 500 m of a defined flood zone associated with the watercourses discussed above (Drawing 2990/HRA/04).
2.1.8 Waterbodies
A single small waterbody is shown on the OS maps within 500 m of the site (Drawing 2990/HRA/04). The waterbody is located adjacent to some disused workings, approximately 365 m west of the proposed Application Area. This waterbody is adjacent to the active waste management site identified, and it is not known if it is a natural waterbody, or linked to site drainage. It is considered unlikely to receive drainage from the Application Area.
Apart from the aforementioned Caudle Head waterbody and associated drainage, no other water features are identified within 1 km of the site. Caudle Head is down-gradient of the site and may receive drainage from it.
2.1.9 Surface water abstractions
No licensed, deregulated or private surface water abstractions have been identified within 1 km of the site by the Environment Agency or the Local Authority.
2.1.10 Water Framework Directive - Surface Water
The site is located within the catchment of the Cut-Off Channel (waterbody ID GB2050000040), within the Cam and Ely Ouse Management catchment. The waterbody has a “Moderate” Ecological status and the Chemical status is recorded as “Fail”. The main issues for not achieving “Good” status are related to low flows (physical modifications for flood/water level management) and point source sewage discharge, which both lead to problems with dissolved oxygen concentration.
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The catchment is within the following protective zones:
. Nitrates Directive NVZ - Surface Water Zone 390 - Ely Ouse and Cut Off Channel . Drinking Water Protection Area – Cut-Off Channel (Cam and Ely Ouse) . Designated Sensitive Area (Eutrophic) under the Urban Wastewater Treatment Directive (UWWTD)
2.1.11 Surface water quality
Surface water quality monitoring data is available for the Cut-Off Channel at sample point ID AN-56M01, located directly adjacent to the site catchment (c2.4 km southwest) at Eriswell Bridge. Data is available from 2000–2020; the most recent 5 years of data has been summarised in Table 2990/HRA/T3 below:
2990/HRA/T3: Surface water quality data (2015 – 2020)
Determinand Unit Sample count Min Max Average
pH - 20 7.5 8.72 8.00 Temperature of Water °C 20 4.7 21.7 10.43
Alkalinity to pH 4.5 as CaCO3 mg/l 20 193 259 229.90 Conductivity at 25°C µs/cm 20 608 840 761.95 BOD, 5 Day ATU mg/l 11 <1 6.15 1.926 Oxygen, Dissolved, % Saturation % 20 59.6 134.1 95.465
Oxygen, Dissolved as O2 mg/l 20 6.51 15.1 10.756 Ammoniacal Nitrogen as N mg/l 20 <0.03 0.38 0.11 Ammonia un-ionised as N mg/l 20 0.00019 0.00423 0.00151 Nitrogen, Total Oxidised as N mg/l 20 2.9 10 6.346 Nitrate as N mg/l 20 2.83 9.96 6.274 Nitrite as N mg/l 20 0.017 0.17 0.072 Orthophosphate, reactive as P mg/l 20 <0.01 0.109 0.047
No increasing or declining trends have been observed within the previous 5 years of data for any of the above determinands. Concentrations of all determinands fluctuate, with most reaching a peak value in summer 2019 (April to September).
The data for Ammoniacal Nitrogen as N from 2015–2020 was reviewed against the relevant Drinking Water Standards (DWS) and Environmental Quality Standard (EQS). All 20 samples analysed were at or above the Limit of Detection of <0.03 which is in exceedance of the EQS of 0.015 mg/l.
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2.2 Geological setting
Details of the geology of the site and its surrounds have been drawn from British Geological Survey (BGS) mapping shown on geological map sheet 174 for the Thetford area, and on GeoIndex and Web Map Service (WMS) layers. The regional geological succession is set out in Table 2990/HRA/T4 below:
2990/HRA/T4: Regional geological succession
Age Group Formation Lithology SUPERFICIAL Peat Peat Alluvium Silt and clay Cover sand Sand Head Clay, silt, sand and gravel Quaternary River Terrace Deposits Terrace Sand and gravel 1 Croxton Sand and Gravel Sand and gravel Member Ingham Sand and Gravel Sand and gravel Formation BEDROCK Seaford Chalk Formation, Chalk – white smooth with Newhaven Chalk Formation thin beds of marl and And Culver Chalk Formation common flint beds (40– (Undifferentiated) 50 m) Lewes Nodular Chalk Chalk – white gritty, White Chalk Formation with Brandon Flint variably hard and nodular Subgroup Member at base with thin beds of marl and common flint beds (65 m Upper and with basal flint bed forming Lower base 10-15 m) Cretaceous Holywell Nodular Chalk Chalk – white blocky and Formation and New Pit Chalk massive or gritty. Less Formation (Undifferentiated) marl/ flint (55–60 m) Grey Chalk Zig Zag Chalk Formation/ Chalk – pale to dark grey, Subgroup West Melbury Marly Chalk locally pink or red, massive Formation with marl and limestone beds (combined 15–40 m) Selborne Gault Formation Mudstone – grey and silty Group
The geological site setting is shown on Drawing 2990/HRA/05. The bedrock geology of the site and its immediate surrounds comprises strata from the Cretaceous White and Grey Chalk Subgroups. The site is underlain entirely by the white chalk of the Holywell Nodular Chalk Formation and New Pit Chalk Formations (Undifferentiated).
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The chalk is mostly described in BGS borehole logs as creamy or off-white in colour, merging to grey at depth. The weathered surface of the chalk is generally rubbly with some putty chalk and flint gravels, which becomes harder and blocky at depth. The BGS logs for two boreholes located 980 and 985 m directly south of the site (BGS references TL77NW76 and TL77NW56) have proved the base of the chalk at between –31.7 and -59.0 mAOD (51– 78 metres below ground level (mbgl)). Elsewhere, a maximum chalk thickness between 86.5- 90 m (-64 and -64.5 mAOD at BGS boreholes reference TL78SE19 and TL77NW98) was recorded, however the base of the chalk was not proved at either of these boreholes (located 820 m southwest and 2.75 km east of the site).
Bedrock at the site is overlain by Cover Sands across the majority of the Application Area. The chalk bedrock is exposed across approximately half of Phase 6 (see Appendix 2990/HRA/A1) at the southwestern site extent. Immediately surrounding the site, other areas of exposed bedrock are present. To the northeast and south of the site, small areas of head deposits are present, with limited areas of the Ingham and Croxton sand and gravel members also present to the northwest and southwest of the site. Further west of the site, the superficial geology changes, with the Cut-Off Channel signalling a change in topography and superficial geology. Superficial deposits become dominated by Peat Alluvium, and River Terrance deposits.
Borehole records of the Cover Sands are available immediately adjacent to the site from the BGS. Adjacent trial pit and borehole records indicate between 1-5 m (average thickness 2.4 m) of brown, orange and occasionally white, fine to medium, silty or gravelly, sand (occasionally sandy gravel). The gravel is either chalk or flints, and the sand can be very chalky in places. These sands are overlain by topsoils, and occasionally made ground, and underlain by the weathered chalk surface.
The soil cover on-site is mapped by the Cranfield Soil and Agrifood Institute (Soilscape 8) across the same area as superficial cover sand deposits. These soils are classified as “freely draining and slightly acidic sandy soils”.
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2.3 Hydrogeological setting
2.3.1 Aquifer designation
The superficial Cover Sands in the area have not been defined as an aquifer by the EA, however based on the geological description, they are considered capable of transmitting water. The nearby Ingham and Croxton sand and gravel members are designated as Secondary ‘A’ Aquifers.
Cretaceous Chalk bedrock underlies the sands and outcrops at the surface where superficial deposits are absent around the site. The chalk is designated a Principal Aquifer by the Environment Agency. The site is also in the inner catchment (Source Protection Zone (SPZ) 1) of a local water supply borehole which utilises groundwater from the Chalk Aquifer.
The BGS borehole records for chalk abstraction boreholes TL77NE11 and TL77NE12, located c1.5 km southwest of the site, have recorded pumping tests from the 1980’s. These boreholes are considered likely to be historically linked to licences referenced AN/033/0046/002/R02 (Section 2.3.5 below) and 6/33/43/*G/0007, held by Elveden Farms Ltd. Transmissivities between 457–1,687 m2/day were recorded at the pumped boreholes, and between 673– 2,563 m2/day at the observation boreholes. The report included in the BGS records considered a transmissivity of 1,500 m2/day typical of this aquifer. A hydraulic conductivity for the chalk between 1 x 10-4 and 2 x 10-4 m/s has been estimated considering the BGS records for the pumped boreholes.
2.3.2 Groundwater levels and flow
Groundwater level data has been collated from BGS boreholes surrounding the site. Where recorded, water strikes are intercepted mostly in the chalk. The unsaturated sandy superficial deposits are underlain by a ~3.5–4.75 m unsaturated thickness of chalk. Occasionally the rest groundwater elevation is located at the interface between the chalk and the Cover Sands.
To the south and southwest of the site, where the chalk outcrops at the ground surface, groundwater elevations recorded within BGS boreholes are recorded between 7-13 mAOD. Groundwater elevations decline to the northwest, to elevations recorded between 3.5– 6 mAOD at BGS boreholes located within Little Eriswell and the RAF base, where the chalk is overlain by Cover Sands. Immediately adjacent to the northwest and west of the site, rest groundwater elevations have been recorded between 4–6 mAOD. Groundwater flow is therefore considered to be in a northwesterly and westerly direction, following the topographic slope, towards Caudle Head, the Cut-Off Channel, and the local water supply borehole (Section 2.3.5 below).
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A chalk aquifer hydraulic gradient of 0.001 is estimated based on the above data.
2.3.3 Water Framework Directive - Groundwater
The site is situated within the groundwater catchment for the Cam and Ely Ouse Chalk (waterbody ID GB40501G400500). Both the Quantitative and Chemical status for this catchment are recorded as “Poor”. Reasons for not achieving “Good” status are listed as groundwater abstraction for agriculture and industry, poor nutrient management in agriculture, transport drainage and continuous sewage discharge (industrial and domestic).
The site is located within the Nitrates Directive (NVZ) - Groundwater Zone 71 for the Anglian Chalk. The groundwater catchment is also within groundwater safeguard zones and drinking water protection areas, however the site is not located within these designated areas.
2.3.4 Groundwater quality
Groundwater quality data is available for a chalk borehole, located at Avenue Farm, Icklingham, approximately 6.7 km southeast of the site. The borehole is around 37.2 m in depth, with a rest water level of approximately 12.35 mAOD, and is considered as up- gradient of the site. The sampling location has ID AN-TL77034C; the most recent 5 years of data from January 2015 to January 2020 has been summarised in Table 2990/HRA/T5.
Groundwater quality data is also available at two boreholes located at Wangford Farm/Hall (sample point ID AN-TL78024C) and Willow Grove Farm (sample point ID AN-TL78060C), located 2.8 km northeast and 3.9 km northwest respectively. These locations are considered to be representative of down-gradient groundwater quality in the chalk aquifer and a selection of determinands from the most recent data available from 2010 to 2017 have been summarised in Table 2990/HRA/T5. Both boreholes intercept the chalk bedrock; the borehole at Wangford Farm/Hall was completed at around 17.4 m depth, with a rest water level at approximately 5.8 mAOD, and at Willow Grove Farm borehole at approximately 17 m deep, with a rest water level around 2 mAOD.
No increasing or declining trends have been observed within the recent data. Many determinands were recorded at or below the limit of detection. Where recorded, concentrations appear more stable down-gradient, with more frequent fluctuation in concentration observed at the up-gradient borehole. In general, there is no significant
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2990/HRA/T5: Groundwater quality data
Up-gradient – Avenue Farm Down-gradient – Wangford Hall Down-gradient - Willow Grove (Jan 2015 - Jan 2020) (March 2010 - May 2015) Farm (March 2010 - May 2017) Determinand Unit Cnt Min Max Ave Cnt Min Max Ave Cnt Min Max Ave pH: In situ 18 7 7.49 7.255 7 7.17 7.71 7.37 11 7.15 7.75 7.53
Conductivity at 25°C µs/cm 18 581 1289 803.8 7 489 519 503 11 605 651 633.03
Bicarbonate as HCO3 mg/l 18 220 310 254.1 7 238 265 251.14 11 255 266 262 Carbon, Organic, mg/l 18 0.97 3.6 1.8 7 0.95 1.42 1.18 11 0.85 1.27 1.05 Dissolved as C:- {DOC}
Oxygen, Dissolved as O2 mg/l 18 8.43 10.3 9.2 7 0.677 4.07 2.481 11 5.75 9.86 8.62 Ammoniacal Nitrogen as N mg/l 18 <0.03 <0.03 <0.03 7 <0.03 <0.03 <0.03 11 <0.03 <0.03 <0.03 Calcium, Dissolved mg/l 18 97 204 129.5 7 89 96.9 92.79 11 108 122 116.27
Sulphate, Dissolved as SO4 mg/l 18 22.8 69.2 38.6 1 15.1 15.1 15.1 11 24.3 26.5 25.08 Chloride mg/l 18 33.8 110 57.5 7 8.1 10.8 9.54 11 18.2 21.1 20.02 Potassium, Dissolved mg/l 18 1.46 15.8 6.5 7 4.38 8.2 5.50 11 1.1 1.32 1.2 Sodium, Dissolved mg/l 18 13.8 47.5 24.05 7 5.06 5.92 5.5 11 8.8 9.74 9.32 Magnesium, Dissolved mg/l 18 1.8 3.9 2.5 7 1.85 2.06 1.98 11 1.82 1.96 1.90 Arsenic, Dissolved µg/l 4 <1 <1 <1 5 <1 <1 <1 2 <1 <1 <1 Cadmium, Dissolved µg/l 18 <0.01 0.0237 0.01 7 <0.01 <0.1 0.09 9 <0.1 <0.1 <0.1 Benzene µg/l 8 <0.1 <0.1 <0.1 5 <0.1 <0.1 <0.1 10 <0.1 <0.1 <0.1 Ethylbenzene µg/l 8 <0.1 <0.1 <0.1 5 <0.1 <0.1 <0.1 10 <0.1 <0.1 <0.1 Toluene:- {Methylbenzene} µg/l 8 <0.1 0.18 0.11 5 <0.1 <0.1 <0.1 10 <0.1 0.17 0.107
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difference in concentrations observed up and down-gradient within the chalk, with the exception that the peak concentrations observed up-gradient are generally greater.
The recorded concentrations of ammoniacal nitrogen, arsenic, benzene, cadmium and chloride were screened against the relevant Drinking Water Standards (DWS) and Environmental Quality Standard (EQS).
The only exceedance detected was for ammoniacal nitrogen as samples analysed were at or above the Limit of Detection of <0.03, which is in exceedance of the EQS of 0.015 mg/l.
2.3.5 Groundwater abstractions
The Application Area is located within an Inner Source Protection Zone 1 (nominally the 50 day travel time) (Drawing 2990/HRA/05). A review of BGS boreholes and waterwells indicate the protected supply abstracts from the chalk aquifer. The supply is likely located within 120 m immediately west of the site and to the west of Brandon Road. Details of the abstraction this protection zone has been defined for have not been provided by the EA, however, it is likely to be related to a private water supply for the RAF base.
Waterwells identified by the BGS are shown on Drawing 2990/HRA/05; the details listed are for when the waterwell was constructed and do not necessarily signify that a water supply is available/used at these locations.
The only abstraction identified by the EA and Local Authority within 500 m of the site is located on-site, but outside of the Application Area. It is understood to be an active borehole abstraction, owned by the client and registered as a private potable supply for 9.9 m3/day at Eriswell Lodge (reference P/298/PWS/050). There is no record of a borehole at this location from the BGS, however it is considered that the borehole likely abstracts from the chalk aquifer.
A further two licensed groundwater abstractions, reference AN/033/0046/002/R02, have been identified between 980 m–1 km distance south of the site. The licence is held by Elveden Farms Ltd and allows abstraction from the chalk aquifer for spray irrigation purposes. A single deregulated abstraction (source unknown) for domestic supply is located 760 m east of the site; no further details are provided. A further four waterwell locations are identified on the BGS database, three of which are chalk abstractions within Little Eriswell, approximately located 410 m and 430 m northwest (noted as disused or contaminated), and 820 m southwest of the site (status unknown). The fourth is located at Warren Lodge, approximately 1 km northeast, however no geological records or status are provided.
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2.4 Historical site development
A review of historical satellite imagery shows that previous land cover/use within the Application Area comprised greenfield grassland. Soil stripping and movement of materials was observed since 2005. Within the centre of the site, but outside of the Application Area, the Shooting Centre appears to have been in use since the 1990’s with the layout appearing relatively unchanged.
Part of the bund is reported to have been constructed. Aggregates produced under the WRAP Quality Protocol, including aggregate from inert waste and compressed tyres, have been used in the construction works. No other land raising has commenced at the site.
The EA has identified historic waste activities on-site which were authorised under exemptions from waste permitting (licensing) and low risk waste positions. The Lakenheath Country Club held registration references NCC/E/LAK006/0/19 and NCC/025890, which were approved and renewed from 2008 until 2011. This registration permitted “Paragraph 19 Waste for Construction Exemption” which includes storage and use of up to 50,000 tonnes of certain waste types on site, with up to 6 months of storage permitted. Another historic waste activity is registered to the Country Club under Mr Peter Usher of Lakenheath Clay Target Centre and reference LRW035. This permission allowed for low risk waste activities including use of 500 tonnes of tyre bales in above ground construction works in 2009. It is understood the tyre bales were covered over using waste soils imported under the “Paragraph 19” exemptions.
The EA has reported that between 8 August 2016 and 5 April 2017, the site was subjected to importation of controlled waste without appropriate waste controls or permissions in place. The landowner voluntarily committed to the waste deposit sampling requirements to investigate into levels of contamination which were set out by the EA. Three pockets of low- level hydrocarbon contamination were identified and the landowner, through their consultant, was requested to remove the affected material and submit a validation report to confirm the material removal. The EA have confirmed that following submission of a validation report confirming the removal of the materials containing hydrocarbons, they would consider the remaining risk to groundwater from the remaining waste deposits to be acceptable.
2.5 Conceptual hydrogeological understanding
The local hydrogeology is shown on Drawing 2990/HRA/06 and schematic cross-sections through the site are provided on Drawing 2990/HRA/07 representing the hydrogeological conceptual model for the site.
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The site and the immediate down-gradient area is underlain by topsoil and a silty or gravelly, superficial Cover Sand with an average 2.4 m thickness (ranging locally between 1–5 m in thickness). These superficial deposits are underlain by the weathered surface of the white chalk bedrock which is locally described as creamy white, rubbly with some putty chalk and flint gravels, becoming harder and blocky at depth.
An unsaturated zone exists within the Cover Sands and the top of the chalk bedrock across the proposed Permit area. This extends locally between c1–7 mbgl, representing an average unsaturated thickness within the chalk of 4 m. The rest groundwater level in the chalk aquifer is in the order of 4-6 mAOD (based on local BGS borehole logs) at the site and groundwater is considered to flow in a northwesterly and westerly direction at a gradient of 0.001.
The chalk is defined as a Principal Aquifer by the EA, and the Application Area lies within the Inner Source Protection Zone 1 (nominally the 50 day travel time) for a groundwater abstraction likely to be associated with the RAF base to the west and within 120 m of the site.
Surface water run-off into the site is possible from elevated ground to the south, east and northeast, however, this will be intercepted by the bund as it is constructed. Run-off from the site will be to the north and west. It is likely that recharge to the Chalk Aquifer occurs from run-off or incident rainfall through the Cover Sand, or directly to the chalk where it outcrops at the surface nearby.
The site is located within the surface water catchment for the Cut-Off Channel, and baseflow from the chalk aquifer is considered possible. The closest tributary of the Cut-Off Channel to the site rises from a waterbody known as Caudle Head, located 630 m to the northwest of the site. The waterbody is also likely in hydraulic continuity with the chalk and the Cover Sand deposit, and is considered to be down-gradient of the site.
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3 PROPOSED DEVELOPMENT
Planning Permission exists for construction of a bund surrounding the Lakenheath Country Club through land raising using imported waste materials. Topsoils stripped from within the site will be placed over top of the waste materials only.
a) Waste types
The proposed materials to be imported to the Lakenheath Country Club site will include soils, subsoils and minerals as listed in Table 2990/HRA/T6 below. The site will only accept wastes classified as non-hazardous, excluding wastes which are solely or mainly of dusts, powders or loose fibres, and not in a form which is either sludge or liquid.
2990/HRA/T6: Permitted waste types
Source Sub-source Waste Description Additional code restrictions
01: Waste resulting 01 01: Wastes from 01 01 02 Wastes from mineral Restricted to waste from exploration, mineral excavation non-metalliferous overburden and mining, quarrying and excavation interburden only physical and chemical 01 04: Wastes from 01 04 08 Waste gravel and treatment of minerals physical and crushed rocks other chemical processing than those of non-metalliferous mentioned in minerals 01 04 06 01 04 09 Waste sand and clays 02: Waste from 02 04: Wastes from 02 04 01 Soil from cleaning agriculture, horticulture, sugar processing and washing beet aquaculture, forestry, hunting and fishing, food preparation and processing 17: Construction and 17 01: Concrete, 17 01 01 Concrete demolition wastes bricks, tiles and 17 01 02 Bricks ceramics 17 01 03 Tiles and ceramics 17 01 07 Mixtures of Metal from reinforced concrete, bricks, concrete must have tiles and ceramics been removed other than those mentioned in 17 01 06 17 05: Soil, stones 17 05 04 Soil and stones other Restricted to topsoil, and dredging spoil than those peat, subsoil and mentioned in stones only 17 05 03
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2990/HRA/T6: Permitted waste types
Source Sub-source Waste Description Additional code restrictions
19: Wastes from waste 19 12: Wastes from 19 12 09 Minerals (eg sand, Restricted to wastes management facilities the mechanical stones) only from treatment of treatment of waste waste aggregates that (eg sorting, crushing, are otherwise naturally compacting, occurring minerals. pelletising) not Does not include fines otherwise specified from treatment of any non-hazardous waste or gypsum from recovered plasterboard 19 12 12 Other wastes Including crushed (including mixtures bricks, tiles, concrete of materials) from and ceramics. mechanical Including soils from the treatment of waste mechanical treatment other than those of construction/ mentioned in demolition waste. 19 12 11 Metal from reinforced concrete must be removed. Does not include gypsum from recovered plasterboard 20 Municipal wastes 20 02: Garden and 20 02 02 Soils and stones Restricted to topsoil, (household waste and park waste peat, subsoil and similar commercial, stones only industrial and institutional wastes) including separately collected fractions
Incoming waste materials will be chemically and physically suitable for the construction of a bund of the size and height proposed. All waste will be visually inspected on arrival at the site. Any waste identified as ‘not suitable’ will be refused entry or removed from the site in accordance with the Waste Rejection Procedure.
Material with waste codes 02 04 01 (soil from cleaning and washing beet), 19 12 12 (other wastes from mechanical treatment of waste), 17 05 04 and 20 02 02 (both containing peat) will be subject to rigorous Waste Acceptance Criteria and Procedures (WAC) to ensure they are chemically and physically fit for purpose. Details of the Waste Acceptance Procedure (WAP) are provided elsewhere together with the Environmental Management System (EMS). The WAP will ensure that the history of the site from which the waste is derived and the chemical composition of the waste (where appropriate) will be obtained before the waste is accepted.
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b) Phasing
A review of historical satellite imagery shows that soil stripping and movement of materials has been observed since 2005. Part of the bund, located in the west of the site, is reported to have already been constructed. Aggregates produced under the WRAP Quality Protocol including aggregate from inert waste and compressed tyres have been used in the construction works under an exemption from waste management licensing (further information on historical site uses are provided in Section 2.4).
It is proposed that land raising will continue from the northwest in a further five phases (2 to 6), completed in a clockwise direction around the perimeter of the site. An outline of the land raising sequence is provided as Appendix 2990/HRA/A1 and the phase sizes are listed below in Table 2990/HRA/T7:
2990/HRA/T7: Phase areas
Phase Area (ha) 1 2.6 2 3.2 3 2.3 4 3 5 1.7 6 1.7 Total 14.5 c) Waste volumes
In order to complete the land raising exercise and achieve the approved bund profile, approximately 788,120 m3 of suitable waste will be imported to the site. The completed bund will be 145,970 m2 in area, 260 m long in the direction of groundwater flow and 390 m wide, perpendicular to flow (ie across Phases 1 and 2 in the direction of groundwater flow), and up to 16 m in height.
3.1 Post-closure controls
Management measures implemented in order to ensure compliant operation of the proposed waste facility include:
. Visual monitoring and recording of incoming waste streams . Strict adherence to Waste Acceptance Procedures . Groundwater level and quality monitoring and reporting systems
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Groundwater monitoring is not currently in place but will include a minimum of one up- gradient and two down-gradient boreholes in order to identify any changes in groundwater as it passes the site and before it reaches the private water supply for the RAF base. Monitoring will continue throughout the life of the proposed development at Lakenheath Country Club, including the active and post-closure phases and until the site no longer poses a potential risk to the environment or to human health. Monitoring infrastructure that becomes inoperable will be replaced as necessary.
3.1.1 Surface water run-off control
Surface water run-off management will be required during and post bund construction. The design of the bund is such that surface water run-off will increase and ingress of water will reduce within its footprint. Run-off from the bund will be controlled via provision of ditches or berms at its base, where required. The usual concern regarding run-off entering the working area will not occur due to this development being a land raise operation rather than below ground infilling.
Controls will need to be in place to prevent silt laden run-off from the working area leaving the site. These measures will include standard best practice for construction sites.
3.1.2 Groundwater control
No dewatering is required during or post bund construction as the structure is above ground.
3.1.3 Construction engineering
Within phases 1 to 5 the bund will be located over the superficial Cover Sand deposits. Therefore, a natural attenuation barrier exists protecting the Chalk aquifer across much of the site. Phase 6 will be partially located where the Cover Sand is absent.
It is proposed to excavate to 0.5 m below ground level within the footprint of the bund, and replace this material with suitable clay wastes, in layers of 300 mm thickness. These clay layers will be compacted with 6 passes of a roller and have been included in the bund design to provide stability. However, this will also act as a further protective layer to the Chalk aquifer, in addition to the Cover Sand where present.
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4 SOURCE, PATHWAY, RECEPTOR
4.1 Source
Surface water infiltration into, and run-off across, the surface of the bund has the potential to mobilise any contaminants present.
The recovery operation will receive only chemically and physically suitable wastes as listed in the Waste Recovery Plan and Table 2990/HRA/T5. For the specified waste codes (02 04 01, 19 12 12, 17 05 04 and 20 02 02) this will be ensured by the application of strict Waste Acceptance Procedures (WAP), provided elsewhere in the application, by appropriately trained staff.
A total volume of 788,119.15 m³ of waste will be recovered for use in construction of the bund.
The bund construction has been divided into six phases as shown in the phasing plans, provided as Appendix 2990/HRA/A1. The northern bund slopes are graded softly to the northwestern down-gradient site boundary and it is assumed that waste will not be placed within 5 m of this boundary. The centre of the bund in Phase 1 is approximately located 80 m from the site boundary.
4.2 Pathways
Much incident rainfall will become run-off and only estimated conservative, 45% of effective rainfall has been assumed to infiltrate the waste body. This will flow vertically through the waste, and the 0.5 m of compacted suitable clay wastes and into the Cover Sands, which have an average thickness for 1.9 m allowing for up to 0.5 m removal prior to placement of the clay rich layer. Infiltrating water will then pass vertically through the approximate 4 m of unsaturated chalk before entering groundwater within the chalk saturated zone beneath the bund. From here the water will flow with the hydraulic gradient, north/northwestwards away from the site.
No other plausible pathways exist.
4.3 Receptors
The groundwater table underlying the site within the Chalk Principal Aquifer is considered as the primary receptor.
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The Application Area is located within an Inner Source Protection Zone 1 (nominally the 50 day travel time) for a groundwater abstraction from the chalk aquifer, northwest and approximately 120 m down-gradient of the site. This supply is considered as the secondary receptor.
The only other supply identified by the EA and Local Authority within 500 m of the Application Area is an active private borehole potable supply at Eriswell Lodge (reference P/298/PWS/050), located within the centre of the Permit area. No borehole record is available however it is likely that the borehole abstracts from the chalk aquifer. This abstraction is 350 m down-gradient of part of Phase 6 of the bund. In this location the bund is small, approximately 12 m wide and therefore comprises a smaller source term, which combined with the greater travel distance renders the risk to this abstraction commensurately smaller than that to the RAF abstraction. This receptor has therefore not been considered in the quantitative assessment.
Further down-gradient, a minor tributary of the Cut-Off Channel rises from Caudle Head, 630 m to the northwest of the site, and is potentially hydraulically connected to groundwater. Baseflow from groundwater within the chalk to the Cut-Off Chanel main river is also considered possible. These receptors are at a distance where impact from the construction of the bund is unlikely and hence are not considered in the quantitative assessment.
The compliance point for Hazardous substances if the groundwater underlying the site and for Non-hazardous pollutants is groundwater at the down-gradient site boundary. As it is not possible to sample groundwater beneath the site, compliance will be determined at the down-gradient site boundary.
Identified receptors and pathways are summarised in Table 2990/HRA/T8.
2990/HRA/T8: Summary of identified receptors and pathways
Hazard Only the selected chemically and physically suitable wastes listed within the Waste Recovery Plan will be imported for land raising operations at the site. Based on the proposed Waste Codes and Waste Acceptance Procedures, and the fact that the development represents a land raising exercise it is considered that the site poses minimal potential hazard to nearby surface and groundwater. The total volume of waste to be imported is 788,119.15 m³
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2990/HRA/T8: Summary of identified receptors and pathways
Source All waste to be deposited will be visually inspected as it enters the site. All waste accepted will adhere to Waste Acceptance Procedures which shall ensure the waste is correctly characterised and in accordance with Environment Agency guidance, and is physically and chemically suitable. It is therefore considered highly unlikely that infiltration to the waste will incorporate within it measurable concentrations of pollutants as it percolates through the waste. No Hazardous substances are expected to be present and Non-hazardous pollutants, if present, will be of low concentration such that pollution of nearby groundwater will not occur. Potential pathway Migration vertically via compacted suitable clay wastes, unsaturated cover sands and chalk to the groundwater table within the underlying Chalk Principal Aquifer. Potential primary Groundwater in the underlying Chalk Aquifer receptor
Potential secondary Private RAF water supply chalk abstraction borehole, estimated to be receptor 120 m down-gradient of the site.
Compliance point Non-hazardous, groundwater in the Chalk Aquifer at the site boundary and hazardous substances, groundwater in the Chalk Aquifer underlying the site.
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5 HYDROGEOLOGICAL RISK ASSESSMENT
5.1 Nature of the Hydrogeological Risk Assessment
The Environment Agency does not necessarily require a Hydrogeological Risk Assessment (HRA) in support of a bespoke permit for waste recovery to land. These are only required where the site setting is deemed particularly sensitive. This HRA has been prepared as the waste will overlie a Principal Aquifer and is within an inner Source Protection Zone 1, hence the site setting is deemed highly sensitive.
Environment Agency guidance proposes a tiered approach to risk assessment such that the degree of effort and complexity reflects the potential risk posed by a particular site or situation, the sensitivity of the site setting and the degree of uncertainty and likelihood of the risk being realised. To meet the requirement, a robust conceptual model for the site has been set out and basic risk screening undertaken. The conceptual model is set out in Section 2.5 above. A risk screening has been undertaken and is summarised in Section 5.2 below.
Although this application is not for a landfill, but a waste recovery operation, risk screening can be partially reviewed by the assessment of the application of the Environment Agency’s Landfill Location Policy, the identification of source-pathway-receptor linkages (Section 4 above) and the proposed technical precautions to be put in place to reduce any potential impacts. These are assessed in Section 5.4.
5.2 Risk screening
5.2.1 Location
Although an application for a landfill permit is not being made, the location of the site is assessed against the Environment Agency’s policy on the location of landfills, which is detailed in ‘The Environment Agency’s approach to groundwater protection (March 2017), Position Statement E1. Landfill Location’. This states:
“ The Environment Agency will normally object to any proposed landfill site in groundwater SPZ1.
For all other proposed landfill site locations, a risk assessment must be conducted based on the nature and quantity of the wastes and the natural setting and properties of the location.
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Where this risk assessment demonstrates that active long-term site management is essential to prevent long-term groundwater pollution, the Environment Agency will object to sites:
below the watertable in any strata where the groundwater provides an important contribution to river flow, or other sensitive receptors within SPZ2 or 3 on or in a Principal Aquifer”
The site is located overlying a Principal Aquifer and is within a groundwater Source Protection Zone 1 and hence the EA would likely object to the siting of a waste recovery site at this location during planning.
Agreement for construction of the bund was given at the planning stage and no objection or comments from the EA can be found on the Planning Portal. It is considered that the controls placed on the waste to be deposited are such that there will be a negligible risk of deterioration in groundwater or surface water quality. Due to the nature of the waste and its position above the pre-existing ground levels it is considered that long-term management will not be necessary to prevent groundwater pollution.
However, due to the sensitive site setting, a generic quantitative risk assessment of the site has been undertaken.
5.2.2 Waste types
It is proposed that the site will take a restricted range of wastes as detailed in Section 3 above. This is a reduced list from that included within Standard Rules Permits for waste recovery. Only chemically and physically suitable waste materials will be accepted in strict accordance with the Waste Acceptance Procedure. The EA has indicated that the operator will need to demonstrate that waste with codes 02 04 01, 19 12 12, 17 05 04 and 20 02 02 will not cause pollution.
5.2.3 Waste Acceptance Procedures
Waste acceptance criteria and procedures have been prepared and are detailed elsewhere in the permit application. The site will not operate on an “open gate” policy and incoming waste will be from known sources and carefully scrutinised.
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5.2.4 Compliance with Environmental Permitting (England and Wales) Regulations (2016)
Based upon the waste types to be accepted at the site, the site should not produce leachate (defined here as water coming into contact with the waste) that could result in discharge of Hazardous substances or Non-hazardous pollutants. Hence the site falls outside the scope of the Environmental Permitting (England and Wales) Regulations (2016), Schedule 22 Groundwater Activities.
5.2.5 Proposed technical precautions
Leachate collection As the waste to be accepted at the site will be limited to those detailed in the Waste Recovery Plan, in accordance with Environment Agency guidance, it is considered that there is no requirement to collect and manage leachate. Therefore there is no requirement for leachate drainage layers or an artificial sealing liner.
In addition, due to the final shape of the bund, rainwater run-off will increase compared with the current topography rather than infiltrate thereby reducing the volume of water entering the waste.
Geological barrier As the site will receive a restricted range of suitable waste under a Waste Recovery Permit, and strict Waste Acceptance Procedures will be in place, a geological barrier is not required.
However, the placement of clay waste in the lower 0.5 m of the bund, where this is below ground level, will provide an attenuation layer.
Monitoring It is proposed that a groundwater monitoring scheme will be implemented at the site. This will include, as a minimum, one up-gradient and two-down gradient monitoring boreholes within the chalk aquifer.
5.2.6 Screening assessment
Based on the:
. location of the site on a Principal aquifer within SPZ1 of a private water supply . the presence of an unsaturated zone of sand and chalk prior to recharge to the chalk watertable, which will promote retardation and attenuation of any contaminants . the restricted stream of wastes to be accepted at the site
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. the waste acceptance procedures proposed in accordance with the Environment Agency guidance “Waste acceptance procedures for waste recovery on land” available on their website (https://www.gov.uk/guidance/waste-acceptance- procedures-for-waste-recovery-on-land) dated October 2016
The site setting is deemed highly sensitive hence, despite the reduced waste stream and proposed controls on imported waste, a generic quantitative modelling of the risk posed by the site has been undertaken as described below in accordance with the Environment Agency Pre-Application advice.
5.3 Proposed assessment scenarios
5.3.1 Lifecycle phases
Environment Agency guidance states that a Hydrogeological Risk Assessment must be carried out for the whole lifecycle of a landfill, ie from the start of the operational phase until the point at which the landfill is no longer capable of posing an unacceptable environmental risk.
As the bund is not a landfill but a recovery operation and given the outcome of the risk screening, a quantitative Hydrogeological Risk Assessment of the intended operational and post-closure phases is not deemed necessary. However, in response to the Environment Agency’s pre-application advice, a generic quantitative risk assessment of the completed site has been undertaken.
The waste mass as a whole will be considered for assessment which uses the ‘remedial target’ function within RAM to calculate, for a given time slice, the maximum concentration acceptable within the waste which will not cause breach of the proposed Environmental Acceptable Limits for the site.
5.3.2 Failure scenarios and accidents
Failure scenarios
Due to the nature of the proposed infill materials, there are no engineering management structures at the site to prevent the ingress of groundwater or the egress of leachate. Failure of such systems is, therefore, not possible and failure scenarios will not be considered.
Accidents
Accidents are considered to be unintentional incidents that could reasonably occur, which are unforeseeable at their time of occurrence. For inert landfills or waste recovery operations
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the accidental inclusion of non-conforming waste, a ‘rogue load’ is usually modelled as the accident scenario. However, as the proposed method of modelling the site is to back calculate maximum acceptable concentrations for the site, a ‘rogue load’ assessment has not been deemed necessary.
Due to the proposed Waste Acceptance Procedures, and the fact that the development comprises an above ground, land raise exercise, it is considered highly unlikely that ‘rogue loads’ would not be identified and rejected from the site.
5.4 Generic quantitative risk assessment
The Environment Agency has requested that a generic quantitative risk assessment is undertaken and therefore risk assessment modelling using the RAM spreadsheet model has been undertaken to assess the need for a geological barrier to provide attenuation capacity and hence prevent pollution of groundwater or other receptors.
5.4.1 Environmentally Acceptable levels
Groundwater or surface water Environmentally Acceptable Levels (EALs) are used as a measure against which the results of models can be compared. EALs have been determined on the basis of available water quality standards for the parameters below in the absence of background groundwater concentrations from within the site boundary.
Hazardous substances
The Environmental Permitting (England and Wales) Regulations 2016 (EPR, 2016) require there to be no discernible discharge of Hazardous substances to groundwater. Therefore, the appropriate EAL would be the concentration at which they become ‘discernible’. There are no known contaminative land uses nearby other than agriculture, hence high background concentrations of Hazardous substances are not expected.
Arsenic was chosen as a representative hazardous metal and benzene was chosen to represent a hazardous hydrocarbon. Only very limited groundwater quality background data are available for the Chalk Aquifer currently, hence the initial EAL has been set as the most suitable guideline concentration, which, as the site is within a SPZ1, in this case is the UK Drinking Water Standard (DWS).
Relevant quality standards are presented in Table 2990/HRA/T9 together with the derived EAL.
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2990/HRA/T9: Derivation of EALS for Hazardous substances
Substance UK Drinking Fresh Water Minimum Resultant Water Standard EQS1 reporting value EAL Arsenic 10 µg/l 50 µg/l 1 µg/l 10 µg/l Benzene 1 µg/l 10 µg/l (50) 1 µg/l 1 µg/l
1 EQS = Environmental Quality Standard
Non-hazardous pollutants
The EPR (2016) requires there to be no groundwater pollution caused as a result of discharges of non-hazardous pollutants. The appropriate EAL is therefore deemed to be the most stringent relevant quality standard, except where background concentrations exceed those standards. A drinking water receptor is closer than the surface water receptor, hence the most appropriate EAL is the UK Drinking Water Standards. The relevant standards are provided in Table 2990/HRA/T10.
Ammoniacal nitrogen and cadmium are used to represent non-hazardous parameters, and chloride has been chosen as a conservative, non-reactive parameter.
2990/HRA/T10: Quality standards and background levels for Non- hazardous pollutants
Substance UK Drinking Fresh Water Resultant EAL Water Standard EQS1 Chloride 250 mg/l 250 mg/l 250 mg/l Ammoniacal Nitrogen 0.39 mg/l 0.015 mg/l 0.39 mg/l2 Cadmium 5 µg/l 0.25 µg/l 5 µg/l 1 EQS = Environmental Quality Standard (Annual average) 2 A drinking water receptor is closer than the surface water receptor
5.4.2 Justification for modelling approach and software
The assessment has been undertaken using ESI’s (now Stantec) Risk Assessment Model (RAM) in order to determine if an enhanced geological barrier is required to prevent pollution of the water environment occurring due to the proposed land raising at the site under a permit for water recovery. The initial input concentrations for the model are arbitrary and are based around the Inert WAC criteria. However, the model ‘back calculates’ the maximum concentration of each substance for a series of different time slices.
Due to the topography of the bund being created, higher run-off will occur than if a void was being infilled back to original ground levels. Therefore, the recharge to the site has been
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taken as 45% of the effective rainfall as determined from the MAFF bulletin (Technical Bulletin 34; Climate and Drainage (1976)). Where known, site-derived hydraulic properties have been used, and these have been supplemented by literature values.
5.4.3 Model parameterisation
The parameters used in the RAM assessment are described together with justification for their use within the RAM model and in Table 2990/HRA/T11. A printout of the RAM model is provided as Appendix 2990/HRA/A2.
A single pathway has been modelled from the source, assumed to be the completed waste mass, vertically through the unsaturated cover sand and unsaturated chalk, into the underlying saturated Chalk Aquifer, and then with the hydraulic gradient to the down- gradient site boundary. Hazardous substances are modelled at the base of the unsaturated zone and non- hazardous pollutants at the closest down-gradient site boundary.
The model was run for a minimum time period of 1,000 years, (except where peak concentrations occurred sooner). This is significantly longer than the time period that is likely to be required to achieve Permit Surrender and, hence, is considered to be a conservative upper time limit for the simulation.
The RAM model simulates the resultant concentrations in groundwater surrounding the site based on a declining source term. However, it also calculates the maximum concentrations that could be accepted in the waste before failure of the EAL’s at the modelled receptors (similar to the Environment Agency remedial target spreadsheet). This latter calculation has been the focus of this study.
Parameter values were determined from information directly measured on-site or, in the absence of site data, other recognised sources. The results of the assessment are discussed below.
2990/HRA/T11: Model input parameters
Parameter Value/distribution Justification SOURCE TERM Waste volume Based on a value given in the Whole bund mass 788,119.15 m3 Waste Recovery Plan.
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2990/HRA/T11: Model input parameters
Parameter Value/distribution Justification GENERAL CONTAMINANT INFORMATION Free water diffusion coefficient (m2/s): Arsenic 9.05 x 10-10 Arsenic from Allison & Allison, 2005. Benzene 7 x 10-10 Benzene, chloride and ammoniacal Chloride 2.03 x 10-9 nitrogen from Buss et al, 2004, Table Cadmium 7.17 x 10-10 3.1 -9 Ammoniacal Nitrogen 1.96 x 10 HYDROGEOLOGICAL UNITS Thickness (m): Compacted clay wastes 0.5 m Stability Risk Assessment. Fine – medium silty gravelly sand 1.9 m Estimated from BGS borehole and Unsaturated chalk 4.0 m trial pit logs. Saturated chalk 20 m Considered upper 20 m only as representative of greatest flow Hydraulic conductivity (m/s): Compacted clay wastes 1 x 10-9 m/s Assumed value. Fine – medium silty gravelly sand 2 x 10-5 m/s Assumed conservative value. Unsaturated chalk 2 x 10-4 m/s Assumed as per saturated chalk – Saturated chalk 2 x 10-4 m/s derived from pumping test at BGS boreholes TL77NE11 and TL77NE12 located c1.5 km southwest of the site Hydraulic gradient: Unsaturated clay 1 Assumed vertical Unsaturated sand 1 Assumed vertical Unsaturated chalk 1 Assumed vertical Saturated chalk 1 x 10-3 Estimated gradient from rest groundwater levels in BGS boreholes Porosity: Compacted clay wastes 0.33 Lower end of range Fetter (1994) 0.35 Fine – medium silty gravelly sand Conservative values Fetter (1994) & 0.20 Unsaturated chalk Freeze & Cherry (1979) Saturated chalk 0.15 Tortuosity 5 Assumed generic value for all hydrogeological layers Horizontal travel distance to: West-northwest boundary 5 m Approximate distance from edge of Supply borehole 120 m waste deposits ATTENUATION PARAMETERS Dispersivity Up to unit Standard assumption thickness/10 Mixing depth in saturated chalk 5 m Assumed
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2990/HRA/T11: Model input parameters
Parameter Value/distribution Justification
Bulk density (kg/m3): Compact clay wastes 1900 Estimate Fine – medium silty gravelly sand 2000 Estimate Unsaturated chalk 1800 Estimate Saturated chalk 1800 Estimate Fraction of organic carbon Compact clay wastes 0.01 Minimum Fine – medium silty gravelly sand 0.01 Mid-point (both from Thrasher et al, Unsaturated chalk 0.001 2004, Table 7.2) Saturated chalk 0.001 Arsenic Partition coefficient (kd) (L/kg) 1.58 Allison & Allison (2005) Benzene Koc 135 Average from Earl et al, 2003 Partition coefficient (kd) (L/kg) calculated Half life in groundwater (days) 240 Chloride Average from California EPA, 1994, Partition coefficient (kd) (L/kg) 0 p25, also USEPA, 1996. Half life (days) No decay Cadmium Partition coefficient (kd) (L/kg) 501 Allison & Allison (2005) Ammoniacal nitrogen Partition coefficient (kd) (L/kg) 0.1clay Lower end of range, Buss et al 0.4 Cover Sand (2003) 0.01 Chalk Half life (days) 1095 (3 years) Mid point in range, Buss et al (2003) WATER BALANCE Precipitation (mm/yr) 623 MAFF Technical Bulletin 34, Area 24 Effective Precipitation (mm/yr) 247 111.15 45% of Effective rainfall References Allison, JD & Allison, TL, 2005. Partition coefficients for metals in surface water, soil and waste. United States Environmental Protection Agency, Report EPA/600/R-05/074 Buss, SR, Herbert, AW, Morgan, P & Thornton, SF, 2003. Review of ammonium attenuation in soil and groundwater. Environment Agency NGWCLC report No NC/02/49 Buss, SR, Herbert, AW, Green, KM & Atkinson, C. Contaminant fluxes from hydraulic landfills – a review. Environment Agency Science Report SC0310/SR California EPA & Department of Toxic Substances Control, 1994. Intermedia transfer factors for contaminants found at hazardous waste sites Earl, N, Cartwright, CD, Horrocks, SJ, Worboys, M, Swift, S, Kirton, A, Askan, AU, Kellener, H & Nancarrow, DJ, 2003. Review of the fate and transport of selected contaminants in the soil environment. Environment Technical Report P5-079/TR1 Thrasher, J, Morgan, P & Buss, SR, 2004. Attenuation of mecoprop in the subsurface. Environment Agency Science Group report NC/03/12
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5.4.4 Results of the risk assessment
As discussed above, although the site will receive only a restricted range of suitable waste, the Environment Agency has requested a quantitative assessment to justify the use of recovered waste and the absence of a formal geological barrier bearing in mind the sensitivity of the site setting. Whilst an artificial geological barrier has not been proposed for the site, 0.5 m of compacted suitable clay waste is required to ensure long term stability of the bund. This will therefore act as an attenuation layer.
The results of the assessment are provided in Table 2990/HRA/T12.
2990/HRA/T12: Results of quantitative risk assessment
Determinand EAL at the Maximum permitted leachable concentrations* compliance assuming compliance at the appropriate boundary point not for Hazardous substances and Non-hazardous exceeded pollutants (mg/l) Hazardous: Arsenic 0.01 0.46 mg/l at 30 years Benzene 0.001 3746 mg/l at 8 years Non-hazardous: Chloride 250 2337 mg/l at 3 years Ammoniacal nitrogen 0.39 12.99 mg/l at 5 years Cadmium 0.005 2928 mg/l at 5000 years(max not reached) *assuming same concentrations in the whole waste mass
An approximation of conservative soil concentrations can be determined by assuming the density of ‘leachate’ equals that of water, in which case, the above concentrations can be directly translated as mg/kg concentrations. The results indicate that concentrations in excess of the inert waste WAC can be accepted at the site for chloride, cadmium, ammoniacal nitrogen and benzene.
5.5 Review of technical precautions
Due to the nature of the waste it is considered that the proposed essential and technical precautions detailed below are appropriate and sufficient to prevent any unacceptable discharge from the site: i) Strict control of waste types sourced and accepted ii) Strict adherence to Waste Acceptance Criteria and Procedures for specified waste codes
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iii) Construction of a structure that encourages surface water run-off and minimises water ingress iv) Provision of a surface water management plan, as required by the Planning Permission v) Monitoring of groundwater quality at the site boundary
It is considered that leachate monitoring and management is not required due to the nature of the waste and the bund characteristics (engineered/compacted waste placement and geometry designed to shed water).
Details of the Waste Acceptance Criteria and Procedures are considered elsewhere in the application.
5.6 Emissions to groundwater
One of the main purposes of the HRA is to establish whether the predicted discharge from the site complies with the requirements of the Environmental Permitting (England and Wales) Regulations (EPR 2016) Schedule 22 Groundwater activities.
5.6.1 Hazardous substances
As discussed, the HRA must demonstrate that the proposed technical precautions will prevent Hazardous substances from entering groundwater. Consequently it must consider whether there is likely to be a discernible discharge of Hazardous substances to groundwater. The compliance point is, therefore, the watertable prior to any dilution occurring.
Hazardous substances are not expected to be present in concentrations in the imported waste which are likely to cause a breach of the EPR (2016). It is therefore considered that the technical precautions discussed in Section 5.5 above are sufficient to ensure that during normal operation and through to long-term post-closure, there would be no discernible discharge of hazardous substances from the waste into groundwater. Maximum concentrations of certain substances have been demonstrated through quantitative modelling.
5.6.2 Non-hazardous pollutants
The HRA must also demonstrate that technical precautions will limit the introduction of Non- hazardous pollutants into groundwater so as to avoid pollution. Consequently it must consider whether predicted concentrations of non-hazardous pollutants are likely to exceed
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relevant standards and other environmental quality criteria, or cause an unacceptable deterioration in groundwater quality following dilution.
A pathway exists for non-hazardous pollutants to a receptor, namely groundwater at the site boundary. However, given the nature of the waste, it is concluded that under normal operation and through to long-term post-closure concentrations of non-hazardous pollutants would be sufficiently low as to avoid pollution of the groundwater. Maximum concentrations of certain substances have been demonstrated through quantitative modelling.
5.6.3 Surface water management
Berms and ditches will be constructed as necessary to direct surface water run-off away from the active working area during its operational and post-operational phase as per the requirements of the Planning Permission.
5.7 Emissions to surface water
Given the nature of the waste and the other technical precautions in place, it is concluded that during normal operation and through to long-term post-closure, concentrations of Hazardous substances will not be discernible and Non-hazardous pollutants will be sufficiently low as to avoid pollution of surface water.
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6 REQUISITE SURVEILLANCE
6.1 Risk-based monitoring scheme
The risk screening and the quantitative modelling indicate under normal operation and through to post-closure that the proposed waste recovery scheme does not pose a risk to the water environment.
However, the site is considered to be in a sensitive location due to the proximity of the Chalk Principal Aquifer, hence a monitoring scheme is required for the site. The scheme will allow for monitoring up and down-gradient of the site in both the Chalk and Cover Sands.
6.2 Groundwater monitoring
It is proposed that groundwater levels and quality is monitored on a quarterly basis. A minimum of one up-gradient monitoring borehole and two down-gradient monitoring boreholes will be installed prior to commencement of waste importation.
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7 CONCLUSIONS
7.1 Compliance with the Environmental Permitting (England and Wales) Regulations (2016)
The risk assessment has demonstrated that under normal operational and post-operational phases Hazardous substances will not be present in groundwater beneath the site in concentrations discernible above background and Non-hazardous pollutants will not be present in concentrations such that pollution of nearby groundwater is caused. It is therefore considered that, as designed, the site will be compliant with respect to the Environmental Permitting (England and Wales) Regulations (2016).
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8 REFERENCES
Environment Agency, February 2016. Landfill developments: groundwater risk assessment for leachate. https://www.gov.uk/guidance/landfill-developments-groundwater-risk-assessment-for- leachate
Environment Agency, March 2010. Hydrogeological risk assessment template. Version 1. https://www.gov.uk/government/publications/hydrogeological-risk-assessment-report- template
Westbury Environmental Ltd, November 2019. Waste Recovery Plan: Lakenheath Country Club Bund
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DRAWINGS
November 2020 Version: F1 573000 574000 575000 Legend Proposed permit boundary 500 m buffer from permit area 1 km buffer from permit area Bund footprint 0 0 0 0 0 0 1 1 8 8 2 2 0 0 0 0 0 0 0 0
8 8 Scale correct at A4 2 2 Client Elveden Farm Limited Estate Office London Road Elveden, Thetford Norfolk. IP24 3TQ Title Site layout
Project Lakenheath Country Club Drawing 2990/HRA/01 Version 1 Date October 2020 Scale 0 0 0 0 0 0 9 9 7 7 2 2 Barkers Chambers • Barker Street • Shrewsbury • © Crown copyright and database rights 2015 Ordnance Survey 0100031673 Shropshire • SY1 1SB 573000 574000 575000 www.hafrenwater.com • Tel. 01743 355 770 571000 572000 573000 574000 575000 576000 Lakenheath Legend Proposed permit boundary 500 m buffer from permit area Lakenheath
0 Airfield 0 1 km buffer from permit area 0 0 0 0 2 2 8 8 2 2 Listed buildings Scheduled monuments School/university buildings Properties/residential buildings 0 0
0 0 Discharge permits/outlets 0 0 1 1 8 8
2 2 Waste management site Historical landfill sites
Little Eriswell 0 0 0 0 0 0 0 0 8 8 2 2
Scale correct at A4 Client Elveden Farm Limited Estate Office London Road
0 0 Elveden, Thetford 0 0 0 0
9 9 Norfolk. IP24 3TQ 7 7 2 2 Title Site location and setting
Project Lakenheath Country Club Drawing 2990/HRA/02 Version 1
0 0 Date Scale
0 0 October 2020 0 0 8 8 7 7 2 2
© Crown copyright and database rights 2015 Ordnance Survey 0100031673 Contains Environment Agency information © Environment Agency and/or Barkers Chambers • Barker Street • Shrewsbury • database right Shropshire • SY1 1SB 571000 572000 573000 574000 575000 576000 www.hafrenwater.com • Tel. 01743 355 770 572000 573000 574000 575000 576000 Legend Maidscross Hill
0 0 Proposed permit boundary
0 LNR/SSSI 0 0 0
2 2 1 km buffer from permit area 8 8 2 2 Breckland SPA & SSSI SAC/RAF Lakenheath SSSI SAC SPA LNR
Breckland SPA
0 & SAC 0 0 0 0 0 1 1 8 8 2 2
Lakenheath Warren SSSI
Lordswell Field Elderbush Belt SSSI Priority Habitat 0 0 0 0 0 0 0 0 8 8 2 Breckland 2 Farmland SSSI Scale correct at A4 Eriswell Low Client Elveden Farm Limited Warren SSSI Estate Office London Road Elveden, Thetford Norfolk. IP24 3TQ 0 0 0 0
0 0 Title
9 Foxhole Heath 9 Sites of environmental and 7 7 2 SSSI 2 ecological interest Project Lakenheath Country Club Drawing 2990/HRA/03 Version 1 Date October 2020 Scale 0 0 0 0
0 © Crown copyright and database rights 2015 Ordnance Survey 0100031673 0 8 8
7 Contains Environment Agency & natural England information © Environment 7 Barkers Chambers • Barker Street • Shrewsbury • 2 Agency and/or database right 2 Shropshire • SY1 1SB 572000 573000 574000 575000 576000 www.hafrenwater.com • Tel. 01743 355 770 572000 573000 574000 Legend Proposed permit boundary 1 km buffer from permit area
0 0 Waterbodies (Within 1 km) 0 0 0 0 1 1
8 8 Main river
2 Caudle 2
n i Head Flood Zone 2
a r
D Flood Zone 3 f f
O
t
u
C 0 0 0 0 0 0 0 0 8 8 2 2
Scale correct at A4 Client Elveden Farm Limited Estate Office London Road Elveden, Thetford Norfolk. IP24 3TQ Title Hydrology
Project Lakenheath Country Club Drawing 2990/HRA/04 Version 1 0 0
0 0 Date Scale 0 0 October 2020 9 9 7 7 2 2
© Crown copyright and database rights 2015 Ordnance Survey 0100031673 Contains Environment Agency information © Environment Agency and/or Barkers Chambers • Barker Street • Shrewsbury • database right Shropshire • SY1 1SB 572000 573000 574000 www.hafrenwater.com • Tel. 01743 355 770 572000 573000 574000 575000 Legend Proposed permit boundary
Main river
Abstractions Private Supply Wells (OS Map)
BGS waterwells No details
Licenced/de-regulated: Groundwater Surface water 0 0 0 0 0 0
1 1 Superficial Geology 8 8 2 2 Cover Sand
Croxton Member
Head
Peat
River Terrace
Alluvium
Bedrock Geology
0 0 Holywell Nodular Chalk 0 0 0 0 0 0
8 8 Grey Chalk Subgroup 2 2
Scale correct at A4 Client Elveden Farm Limited Estate Office London Road Elveden, Thetford Norfolk. IP24 3TQ Title Geology & Abstractions 0 0
0 0 Project 0 0 Lakenheath Country Club 9 9 7 7 2 2 Drawing 2990/HRA/05 Version 1 Date October 2020 Scale
© Crown copyright and database rights 2015 Ordnance Survey 0100031673 Contains British Geological Survey materials © NERC [year] Barkers Chambers • Barker Street • Shrewsbury • Contains Environment Agency information © Environment Agency and/or database right Shropshire • SY1 1SB 572000 573000 574000 575000 www.hafrenwater.com • Tel. 01743 355 770 572000 573000 574000 575000 Legend Proposed permit boundary
1 km buffer from permit area
Main river
Approximate Inner SPZ area
Groundwater flow direction within Principal Aquifer 0 0 0 0 0 0
1 Caudle 1 Superficial Geology 8 8 2 2 Head Cover Sand - No aquifer designation
Croxton Member - Sec 'A' aquifer
n i
a r
D Bedrock Geology - Principal Aquifer f f
O Holywell Nodular Chalk
t
u
C Grey Chalk Subgroup 0 0 0 0 0 0 0 0 8 8 2 2 Scale correct at A4 Client Elveden Farm Limited Estate Office London Road Elveden, Thetford Norfolk. IP24 3TQ Title Local Hydrogeology 0 0
0 0 Project Lakenheath Country Club 0 0 9 9 7 7 2 2 Drawing 2990/HRA/06 Version 1 Date October 2020 Scale
© Crown copyright and database rights 2015 Ordnance Survey 0100031673 Contains British Geological Survey materials © NERC [2020] Barkers Chambers • Barker Street • Shrewsbury • Contains Environment Agency information © Environment Agency and/or database right Shropshire • SY1 1SB 572000 573000 574000 575000 www.hafrenwater.com • Tel. 01743 355 770 A
B
Rainfall Wider bund around northern and Narrow bund northwestern site around boundary southern site boundary Run off & infiltration
Run off & c Supply infiltration Client Elveden Farm Limited Waste Waste borehole Estate Office Cover Sand 0.5 mbgl Compacted clay London Road Elveden, Thetford, 2.4 mbgl Chalk Norfolk, IP24 3TQ 6.4 mbgl Title Schematic site conceptual model Project Groundwater flow direction Lakenheath Country Club Drawing 2990/HRA/07 Version 1 Date Oct-20 Scale nts A - NORTHWEST B- SOUTHEAST
Barkers Chambers • Barker Street • Shrewsbury • United Kingdom • SY1 1SB E: [email protected] • T: 01743 355 770 Elveden Farm Ltd Lakenheath Country Club HYDROGEOLOGICAL RISK ASSESSMENT
APPENDIX 2990/HRA/A1
Phasing drawings of progressive operation
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APPENDIX 2990/HRA/A2
Results from RAM Model
November 2020 Version: F1
Elvedon Farm Appendix 2990/HRA/A2 Lakenheath Country Club
Source Type
Soil Source Groundwater Source
Level Number
Bund
Compacted Clay
Advanced Cover Sand Base of UnSat Zone Parameter Values UnSat Chalk Deterministic Probabilistic
Sat Chalk Chalk GW Created: 13/11/2020 10:55:32 by: Heather MacLeod Version: 3.00.00 Adv Site: Lakenheath
Numerical value Suggested formula Probabilistic parameters Data specified elsewhere Suggested formula edited Elvedon Farm Appendix 2990/HRA/A2 Lakenheath Country Club SOURCE CONCENTRATIONS: Bund
Source Data Options Source Type
Pore water concentrations Constant source Leaching test Declining source Soil contaminant concentrations
Source Geometry
Bund_Source_length 260 m Bund_Source_width 390 m Bund_Source_area 152191 m2 Bund_Source_thickness m Bund_Source_volume 788119.2 m3
General Source Properties
Bund_Source_field_capacity [-] 0.025
Source Contaminant Information
Source determinand names Chloride Cadmium AmmN Arsenic Benzene
Bund_Leaching_test_concentration mg/L 500 4.9 0.8 1.50E-03 2.50E-03
Bund_Initial_inventory kg 9851.49 96.5446 15.76238 0.029554 0.049257
Bund_Input_concentration mg/L 500 4.9 0.8 0.0015 0.0025 Elvedon Farm Appendix 2990/HRA/A2 Lakenheath Country Club CONTAMINANT INFORMATION
Species1 Species2 Species3 Species4 Species5 Source determinand names 5 Chloride Cadmium AmmN Arsenic Benzene
Receptor Target Concentrations Name Values in mg/L Quality Standard 1 DWS 250 0.005 0.39 0.01 0.001 Quality Standard 2 Quality Standard 3 Quality Standard 4 Not Specified
Generic Contaminant Properties
Contaminants_Organic_Carbon_Water_Partition_Coefficient_Koc L/kg 135
Contaminants_Free_Water_Diffusion_Coefficient m2/s 2.03E-09 7.17E-10 1.96E-09 9.05E-10 7.00E-10 Elvedon Farm Appendix 2990/HRA/A2 Lakenheath Country Club HYDROGEOLOGICAL UNITS
Hydrogeological Units Compacted Clay Cover Sand UnSat Chalk Sat Chalk
Hydrogeology_Unit_Thickness m 0.5 1.9 4 5
Hydrogeology_Log_Hydraulic_Conductivity log(m/s)
Hydrogeology_Hydraulic_Conductivity m/s 1.00E-09 2.00E-05 2.00E-04 2.00E-04
Hydrogeology_Head m
Hydrogeology_Hydraulic_Gradient [-] 1 1 1 1.00E-03
Hydrogeology_Porosity [-] 0.3 0.35 0.2 0.15
Hydrogeology_Velocity m/s 3.33333E-09 5.71429E-05 0.001 1.33333E-06
Hydrogeology_Tortuosity [-] 5 5 5 5 Elvedon Farm Appendix 2990/HRA/A2 Lakenheath Country Club
ATTENUATION PARAMETERS
Hydrogeological Units Compacted CoverClay Sand UnSat ChalkSat Chalk
General properties
Attenuation_Dry_bulk_density kg/m3 1900 2000 1800 1800
Attenuation_Fraction_organic_carbon [-] 0.01 0.01 0.001 0.001
Contaminant specific parameters
Chloride
Attenuation_Partition_Coefficient_Kd_Species_1 L/kg 0 0 0 0
Attenuation_Retardation_Species_1 [-] 1 1 1 1
Attenuation_Half_Life_Species_1 days No Decay No Decay No Decay No Decay
Attenuation_Decay_Coefficient_Species_1 1/s 0 0 0 0
Cadmium
Attenuation_Partition_Coefficient_Kd_Species_2 L/kg 501 501 501 501
Attenuation_Retardation_Species_2 [-] 3174 2863.857 4510 6013
Attenuation_Half_Life_Species_2 days No Decay No Decay No Decay No Decay
Attenuation_Decay_Coefficient_Species_2 1/s 0 0 0 0
AmmN
Attenuation_Partition_Coefficient_Kd_Species_3 L/kg 0.1 0.4 0.01 0.01
Attenuation_Retardation_Species_3 [-] 1.633333 3.285714 1.09 1.12
Attenuation_Half_Life_Species_3 days 1095 1095 1095 1095
Attenuation_Decay_Coefficient_Species_3 1/s 7.33E-09 7.33E-09 7.33E-09 7.33E-09
Arsenic
Attenuation_Partition_Coefficient_Kd_Species_4 L/kg 1.58 1.58 1.58 1.58
Attenuation_Retardation_Species_4 [-] 11.00667 10.02857 15.22 19.96
Attenuation_Half_Life_Species_4 days No Decay No Decay No Decay No Decay
Attenuation_Decay_Coefficient_Species_4 1/s 0 0 0 0
Benzene
Attenuation_Partition_Coefficient_Kd_Species_5 L/kg 1.35 1.35 0.135 0.135
Attenuation_Retardation_Species_5 [-] 9.55 8.714286 2.215 2.62
Attenuation_Half_Life_Species_5 days 240 240 240 240
Attenuation_Decay_Coefficient_Species_5 1/s 3.34E-08 3.34E-08 3.34E-08 3.34E-08 Elvedon Farm Appendix 2990/HRA/A2 Lakenheath Country Club WATER BALANCE
User defined
Enter your own calculations for the water balance Carry fluxes and velocities over onto the Pathway sheet
Infiltration through the soil zone source Source Name: Inert Fill Cells Locked Effective_Rainfall 111.15 mm/year Area 24 of MAFF bulletin Infiltration_Factor 1 [-] run_ram 1 Infiltration_Rate 111.15 mm/year Infiltration_Area 152,191 m2
Q_Infiltration 5.36E-04 m3/s
Jan feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Rainfall (mm) 55 45 40 40 46 49 55 66 52 54 66 55
Potential transpiration (mm) 1 10 32 57 85 95 95 78 50 22 5 0
Effective rainfall (mm) 54 35 8 2 32 61 55 Total ER 247 less factor for runoff from bund due to its shape 111.15 assuming only 45% infiltrates Elvedon Farm Appendix 2990/HRA/A2 Lakenheath Country Club
PATHWAY SUMMARY
Path 1 Section 1 Section 2 Section 3 Section 4 Section 5 Section 6 Path 1 Type Source Unit Unit Unit Unit Receptor Path 1 Name Bund Compacted Clay: Node 1 Cover Sand: Node 1 UnSat Chalk: Node 1 Sat Chalk: Node 4 Chalk GW Path 1 Process Declining source ADRD (1D) + Dilution ADRD (1D) + Dilution ADRD (1D) + Dilution ADRD (1D) + Dilution Monitoring Borehole Path 1 Standards Target Standard DWS Path 1 Parameter1 Q_managed [m3/s] 0.000E+00 Velocity [m/s] 3.333E-09 Velocity [m/s] 5.714E-05 Velocity [m/s] 1.000E-03 Velocity [m/s] 1.333E-06 Path 1 Parameter2 Managed time [years] 0.000E+00 Dispersivity [m] 0.1 Dispersivity [m] 0.2 Dispersivity [m] 0.4 Dispersivity [m] 0.5 Path 1 Parameter3 Q_path [m3/s] 5.360E-04 Travel Distance [m] 0.5 Travel Distance [m] 1.9 Travel Distance [m] 4.0 Travel Distance [m] 5.0 Path 1 Parameter4 Q_decline [m3/s] 5.360E-04 Mixing Depth [m] Mixing Depth [m] Mixing Depth [m] Mixing Depth [m] 5.0 Path 1 Parameter5 Mixing Width [m] Mixing Width [m] Mixing Width [m] Mixing Width [m] 390.0 Path 1 Parameter6 Q_Dilute [m3/s] 0.000E+00 Q_Dilute [m3/s] 0.000E+00 Q_Dilute [m3/s] 0.000E+00 Q_Dilute [m3/s] 3.900E-04 Q_dilute [m3/s] 0.000E+00
Path 2 Section 1 Section 2 Section 3 Section 4 Section 5 Path 2 Type Source Unit Unit Unit Receptor Path 2 Name Bund Compacted Clay: Node 4 Cover Sand: Node 4 UnSat Chalk: Node 4 Base of UnSat Zone Path 2 Process Declining source ADRD (1D) + Dilution ADRD (1D) + Dilution ADRD (1D) + Dilution Monitoring Borehole Path 2 Standards Target Standard DWS Path 2 Parameter1 Q_managed [m3/s] 0.000E+00 Velocity [m/s] 3.333E-09 Velocity [m/s] 5.714E-05 Velocity [m/s] 1.000E-03 Path 2 Parameter2 Managed time [years] 0.000E+00 Dispersivity [m] 0.1 Dispersivity [m] 0.2 Dispersivity [m] 0.4 Path 2 Parameter3 Q_path [m3/s] 5.360E-04 Travel Distance [m] 0.5 Travel Distance [m] 1.9 Travel Distance [m] 4.0 Path 2 Parameter4 Q_decline [m3/s] 5.360E-04 Mixing Depth [m] Mixing Depth [m] Mixing Depth [m] Path 2 Parameter5 Mixing Width [m] Mixing Width [m] Mixing Width [m] Path 2 Parameter6 Q_Dilute [m3/s] 0.000E+00 Q_Dilute [m3/s] 0.000E+00 Q_Dilute [m3/s] 0.000E+00 Q_dilute [m3/s] 0.000E+00 Elvedon Farm Appendix 2990/HRA/A2 Lakenheath Country Club
BREAKTHROUGH RESULTS Site Name: "Lakenheath" Advanced Pollutant Linkage: Bund, Compacted Clay, Cover Sand, UnSat Chalk, Sat Chalk, Chalk GW Concentrations in mg/L in Chalk GW
Compared with DWS target concentration in mg/L 2.500E+02 5.000E-03 3.900E-01 1.000E-02 1.000E-03
Species1 Species2 Species3 Species4 Species5 Time(years) Chloride Time(years)Cadmium Time(years)AmmN Time(years)Arsenic Time(years)Benzene 0.2 2.050E-04 500 1.033E-12 0.1 1.317E-18 1 0.000E+00 1 7.204E-15 0.3 1.127E-01 600 1.614E-10 0.25 5.653E-09 2 5.466E-13 2 7.139E-09 0.4 2.116E+00 700 5.430E-09 0.5 4.737E-04 4 2.888E-07 4 7.190E-07 0.5 1.061E+01 800 7.049E-08 0.75 1.237E-02 6 1.257E-05 6 6.489E-07 0.8 7.804E+01 900 4.875E-07 1 4.812E-02 8 5.266E-05 8 2.078E-07 0.8 7.804E+01 1000 2.177E-06 2.5 1.248E-01 10 8.815E-05 10 4.688E-08 1 1.226E+02 1100 7.092E-06 5 2.041E-02 15 7.094E-05 15 7.356E-10 1.25 1.512E+02 1200 1.826E-05 7.5 2.448E-03 20 2.748E-05 20 1.019E-11 1.5 1.541E+02 1500 1.233E-04 10 2.868E-04 30 2.556E-06 30 1.768E-15 2 1.248E+02 2000 5.653E-04 25 7.868E-10 50 1.773E-08 50 1.024E-15
Pollutant Linkage: Bund, Compacted Clay, Cover Sand, UnSat Chalk, Sat Chalk, Chalk GW Remedial Target Concentrations in mg/L in Bund
Species1 Species2 Species3 Species4 Species5 Time(years) Chloride Time(years)Cadmium Time(years)AmmN Time(years)Arsenic Time(years)Benzene 0.2 6.097E+08 500 2.372E+10 0.1 2.370E+17 1 1.000E+40 1 3.470E+08 0.3 1.109E+06 600 1.518E+08 0.25 5.519E+07 2 2.744E+07 2 3.502E+02 0.4 5.906E+04 700 4.512E+06 0.5 6.586E+02 4 5.194E+01 4 3.477E+00 0.5 1.179E+04 800 3.476E+05 0.75 2.522E+01 6 1.194E+00 6 3.852E+00 0.8 1.602E+03 900 5.026E+04 1 6.484E+00 8 2.848E-01 8 1.203E+01 0.8 1.602E+03 1000 1.125E+04 2.5 2.501E+00 10 1.702E-01 10 5.332E+01 1 1.020E+03 1100 3.455E+03 5 1.529E+01 15 2.114E-01 15 3.399E+03 1.25 8.268E+02 1200 1.342E+03 7.5 1.275E+02 20 5.459E-01 20 2.453E+05 1.5 8.111E+02 1500 1.987E+02 10 1.088E+03 30 5.867E+00 30 1.414E+09 2 1.002E+03 2000 4.334E+01 25 3.965E+08 50 8.459E+02 50 2.442E+09
Compared with source concentrations in mg/L 5.000E+02 4.900E+00 8.000E-01 1.500E-03 2.500E-03
Pollutant Linkage: Bund, Compacted Clay, Cover Sand, UnSat Chalk, Sat Chalk, Chalk GW Dilution Factor
1.728E+00 for all species and timeslices
Pollutant Linkage: Bund, Compacted Clay, Cover Sand, UnSat Chalk, Sat Chalk, Chalk GW Attenuation Factor
Species1 Species2 Species3 Species4 Species5 Time(years) Chloride Time(years)Cadmium Time(years)AmmN Time(years)Arsenic Time(years)Benzene 0.2 1.412E+06 500 5.673E-03 0.1 4.483E+11 1 8.683E-03 1 1.099E+15 0.3 2.569E+03 600 4.727E-03 0.25 2.868E+09 2 3.473E-03 2 2.560E+05 0.4 1.368E+02 700 4.052E-03 0.5 8.529E+07 4 1.737E-03 4 3.055E+00 0.5 2.729E+01 800 3.545E-03 0.75 6.570E+06 6 1.158E-03 6 1.170E-01 0.8 3.709E+00 900 3.152E-03 1 9.499E+05 8 8.683E-04 8 3.007E-02 0.8 3.709E+00 1000 2.836E-03 2.5 2.127E+05 10 3.473E-04 10 1.160E-02 1 2.362E+00 1100 2.579E-03 5 6.530E+04 15 1.737E-04 15 7.090E-02 1.25 1.914E+00 1200 2.364E-03 7.5 2.536E+04 20 1.158E-04 20 5.913E-01 1.5 1.878E+00 1500 1.891E-03 10 3.756E+03 30 8.683E-05 30 5.046E+00 2 2.320E+00 2000 1.418E-03 25 8.192E+02 50 3.473E-05 50 1.839E+06 Elvedon Farm Appendix 2990/HRA/A2 Lakenheath Country Club
Pollutant Linkage: Bund, Compacted Clay, Cover Sand, UnSat Chalk, Base of UnSat Zone Concentrations in mg/L in Base of UnSat Zone
Compared with DWS target concentration in mg/L 2.500E+02 5.000E-03 3.900E-01 1.000E-02 1.000E-03
Species1 Species2 Species3 Species4 Species5 Time(years)Chloride Time(years)Cadmium Time(years)AmmN Time(years)Arsenic Time(years)Benzene 0.2 1.081E-01 500 9.217E-07 0.1 1.447E-15 1 1.833E-13 1 2.759E-12 0.3 3.733E+00 600 7.508E-06 0.25 5.179E-06 2 5.893E-08 2 6.756E-08 0.4 2.050E+01 700 3.153E-05 0.5 5.862E-03 4 2.227E-05 4 1.922E-06 0.5 5.382E+01 800 8.805E-05 0.75 5.037E-02 6 1.062E-04 6 1.355E-06 0.8 1.850E+02 900 1.880E-04 1 1.277E-01 8 1.663E-04 8 4.011E-07 0.8 1.850E+02 1000 3.336E-04 2.5 2.085E-01 10 1.671E-04 10 8.784E-08 1 2.431E+02 1100 5.182E-04 5 3.253E-02 15 8.063E-05 15 1.353E-09 1.25 2.687E+02 1200 7.295E-04 7.5 3.888E-03 20 2.698E-05 20 1.871E-11 1.5 2.592E+02 1500 1.383E-03 10 4.554E-04 30 2.360E-06 30 3.485E-15 2 2.000E+02 2000 2.027E-03 25 1.134E-09 50 1.638E-08 50 2.431E-15
Pollutant Linkage: Bund, Compacted Clay, Cover Sand, UnSat Chalk, Base of UnSat Zone Remedial Target Concentrations in mg/L in Bund
Species1 Species2 Species3 Species4 Species5 Time(years)Chloride Time(years)Cadmium Time(years)AmmN Time(years)Arsenic Time(years)Benzene 0.2 1.156E+06 500 2.658E+04 0.1 2.156E+14 1 8.185E+07 1 9.061E+05 0.3 3.349E+04 600 3.263E+03 0.25 6.024E+04 2 2.545E+02 2 3.700E+01 0.4 6.099E+03 700 7.771E+02 0.5 5.323E+01 4 6.735E-01 4 1.301E+00 0.5 2.323E+03 800 2.783E+02 0.75 6.194E+00 6 1.412E-01 6 1.844E+00 0.8 6.756E+02 900 1.303E+02 1 2.443E+00 8 9.018E-02 8 6.233E+00 0.8 6.756E+02 1000 7.344E+01 2.5 1.496E+00 10 8.979E-02 10 2.846E+01 1 5.142E+02 1100 4.728E+01 5 9.592E+00 15 1.860E-01 15 1.848E+03 1.25 4.651E+02 1200 3.358E+01 7.5 8.025E+01 20 5.559E-01 20 1.336E+05 1.5 4.823E+02 1500 1.771E+01 10 6.850E+02 30 6.355E+00 30 7.174E+08 2 6.251E+02 2000 1.209E+01 25 2.750E+08 50 9.156E+02 50 1.028E+09
Compared with source concentrations in mg/L 5.000E+02 4.900E+00 8.000E-01 1.500E-03 2.500E-03
Pollutant Linkage: Bund, Compacted Clay, Cover Sand, UnSat Chalk, Base of UnSat Zone Dilution Factor
1.000E+00 for all species and timeslices
Pollutant Linkage: Bund, Compacted Clay, Cover Sand, UnSat Chalk, Base of UnSat Zone Attenuation Factor
Species1 Species2 Species3 Species4 Species5 Time(years)Chloride Time(years)Cadmium Time(years)AmmN Time(years)Arsenic Time(years)Benzene 0.2 4.625E+03 500 9.800E-03 0.1 8.680E+05 1 1.500E-02 1 1.728E+12 0.3 1.339E+02 600 8.167E-03 0.25 1.066E+05 2 6.000E-03 2 4.827E+02 0.4 2.440E+01 700 7.000E-03 0.5 2.537E+04 4 3.000E-03 4 4.265E-01 0.5 9.290E+00 800 6.125E-03 0.75 9.086E+03 6 2.000E-03 6 4.964E-02 0.8 2.702E+00 900 5.444E-03 1 4.255E+03 8 1.500E-03 8 1.958E-02 0.8 2.702E+00 1000 4.900E-03 2.5 2.398E+03 10 6.000E-04 10 1.199E-02 1 2.057E+00 1100 4.455E-03 5 1.544E+03 15 3.000E-04 15 7.686E-02 1.25 1.860E+00 1200 4.083E-03 7.5 1.097E+03 20 2.000E-04 20 6.430E-01 1.5 1.929E+00 1500 3.267E-03 10 5.784E+02 30 1.500E-04 30 5.489E+00 2 2.501E+00 2000 2.450E-03 25 3.947E+02 50 6.000E-05 50 2.204E+06 Elvedon Farm Appendix 2990/HRA/A2 Lakenheath Country Club
Maximum concentration in waste without causing breach of EAL's at Site bounday for Non-hazardous Pollutants
Chloride concentration (mg/l) vs time (years) 1.8E+02 1.6E+02 1.4E+02 1.2E+02 1.0E+02 8.0E+01 Chloride 6.0E+01 4.0E+01 2.0E+01 0.0E+00 0.0E+00 0 0.5 1 1.5 2 2.5
Cadmium concentration (mg/l) vs time (years) 6.0E-04
5.0E-04
4.0E-04
3.0E-04 Cadmium 2.0E-04
1.0E-04
0.0E+00 0.0E+00 0 500 1000 1500 2000 2500
Ammoniacal NItrogen concentration (mg/l) vs time (years) 1.4E-01
1.2E-01
1.0E-01
8.0E-02
6.0E-02 AmmN
4.0E-02
2.0E-02
0.0E+00 0 5 10 15 20 25 30 Elvedon Farm Appendix 2990/HRA/A2 Lakenheath Country Club
Maximum concentration in waste without causing breach of EAL's at Base of unsaturated zone for Hazardous substances
Arsenic concentration (mg/l) vs time (years) 1.8E-04 1.6E-04 1.4E-04 1.2E-04 1.0E-04 8.0E-05 Arsenic 6.0E-05 4.0E-05 2.0E-05 0.0E+00 0 10 20 30 40 50 60
Benzene concentration (mg/l) vs time (years) 2.5E-06
2.0E-06
1.5E-06
Benzene 1.0E-06
5.0E-07
0.0E+00 0 10 20 30 40 50 60 Elvedon Farm Appendix 2990/HRA/A2 Lakenheath Country Club
Maximum concentration in waste without causing breach of EAL's at Maximum concentration in waste without causing breach of EAL's at Site bounday for Non-hazardous Pollutants Base of unsaturated zone for Hazardous substances
Chloride concentration (mg/l) vs time (years) Arsenic concentration (mg/l) vs time (years) 1.0E+09 1.0E+08 1.0E+08 1.0E+07 1.0E+07 1.0E+06 1.0E+05 1.0E+06 1.0E+04 1.0E+05 1.0E+03 1.0E+04 Chloride Arsenic 1.0E+02 1.0E+03 1.0E+01 1.0E+02 1.0E+00 1.0E+01 1.0E-01 1.0E+00 1.0E-02 0 0.5 1 1.5 2 2.5 0 10 20 30 40 50 60
Cadmium concentration (mg/l) vs time (years) Benzene concentration (mg/l) vs time (years) 1.0E+11 1.0E+10 1.0E+10 1.0E+09 1.0E+09 1.0E+08 1.0E+08 1.0E+07 1.0E+07 1.0E+06 1.0E+06 1.0E+05 1.0E+05 Cadmium Benzene 1.0E+04 1.0E+04 1.0E+03 1.0E+03 1.0E+02 1.0E+02 1.0E+01 1.0E+01 1.0E+00 1.0E+00 0 500 1000 1500 2000 2500 0 10 20 30 40 50 60
Ammoniacal NItrogen concentration (mg/l) vs time (years) 1.0E+10 1.0E+09 1.0E+08 1.0E+07 1.0E+06 1.0E+05 AmmN 1.0E+04 1.0E+03 1.0E+02 1.0E+01 1.0E+00 0 5 10 15 20 25 30
Environmental Setting and Site Design Report
Appendix 6
Stability Risk Assessment
Elveden Farms Limited: Lakenheath Country Club, Suffolk
Environmental Setting and Site Design Report
Appendix 7
Site Condition Report
Elveden Farms Limited: Lakenheath Country Club, Suffolk
Site Condition Report: Part 1
Site Condition Report, Part 1
1.0 SITE DETAILS
Name of the applicant Rory J Holbrook Limited
Activity address Lakenheath Country Club, Hereford Road, Brandon, Suffolk, IP27 9PP
National grid reference TL 73781 80364
Document reference and dates for Site Condition 11 November 2020 - Site Condition Report Part 1 Report at permit application and surrender
Document references for site plans (including location Permit Boundary Plan, Drawing No. 18/014c 001 and boundaries) Site Layout Plan, Drawing No. 18/014d 001
2.0 Condition of the land at permit application
Environmental setting including: Superficial deposit Geology: “Cover Sand - Sand”. The superficial deposits formed up to 3 million years ago in the • geology Quaternary Period. The local environment was previously • hydrogeology dominated by wind-blown deposits. These sedimentary deposits • surface waters are aeolian in origin. They are detrital, comprising medium- to fine- grained materials, forming lenses, beds (and locally) dunes. This classification has been obtained from the British Geological Survey Geology Map.
Bedrock Geology: “Holywell Nodular Chalk Formation and New Pit Chalk Formation (undifferentiated) – Chalk”. The sedimentary bedrock formed approximately 90 to 101 million years ago in the Cretaceous Period. The local environment was previously dominated by warm chalk seas. These sedimentary rocks are shallow-marine in origin. They are biogenic and detrital, generally comprising carbonate material (coccoliths), forming distinctive beds of chalk This classification has been obtained from the British Geological Survey Geology Map.
The Site is located within Groundwater Source Protection Zone 1. The Site is located on a Principal designated bedrock aquifer. The Site is not located on a designated superficial aquifer.
The closest surface water feature to the Site is Caudle Head, approximately 700m to the NW.
Pollution history including:
• pollution incidents that may have affected land The Environment Agency has reported that between 8 August 2016 and 5 April 2017, the Site was subjected to importation of controlled waste without appropriate waste controls or • historical land-uses and associated permissions in place. The landowner voluntarily committed to the contaminants waste deposit sampling requirements to investigate into levels of contamination which were set out by the Environment Agency. • any visual/olfactory evidence of existing Three pockets of low-level hydrocarbon contamination were contamination identified and the landowner, through their consultant, was requested to remove the affected material and submit a validation • evidence of damage to pollution prevention report to confirm the material removal. The Environment Agency measures is awaiting submission of a validation report indicating that this contamination has been removed from site. The Environment Agency confirmed that following submission of a validation report confirming the removal of the materials containing hydrocarbons
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk 1 Site Condition Report: Part 1
were removed, they would consider the remaining risk to groundwater from the remaining waste deposits to be acceptable.
Historical land-uses include agricultural land and use as part of the Lakenheath Country Club. Part of the bund has already been constructed from tyre bales and aggregates from in. It has been agreed that these must remain in situ and not be touched (the tyres).
No visual or olfactory evidence of any existing contamination was found on the Site during the walkover.
No evidence of damage to pollution prevention measures as none present on the Site.
Evidence of historic contamination, for example, “Draft Sampling report and assessment for Anthill/Holbrook waste historical site investigation, assessment, remediation deposit” – Bream Material Management Limited, dated October and verification reports (where available) 2018 – identifies low-level hydrocarbon contamination at the Site.
Supporting N/A information
Site Reconnaissance Report (11 November 2020)
Deliveries of material will access the Site through Elveden Farms Recycling Facility, located southwest of the Site. There is an access track running from Elveden Farms Recycling Facility to the Site. Elveden Farms Recycling Facility is also operated by Rory J Holbrook Limited. Access arrangements The Site can also be accessed via a track that runs from Hereford Road to the main Lakenheath County Club buildings. It is considered unlikely that the Site will be accessed by vehicles delivering material without these vehicles driving through the Elveden Farms Recycling Facility.
The layout of the Site is shown on the Site Layout Plan, Drawing No. 18/004d 001. The Site layout including presence Site Layout Plan is considered to be an accurate representation of what was observed and condition of above and in November 2020. below ground buildings/structures etc. There are no buildings with the Site boundary. The only structure present is the partially constructed bund.
Evidence of disturbed land, Land disturbance at the Site relate to the deposit of materials in the footprint of the discoloured soil or water, bund. subsidence, above ground deposits etc. No discoloured soil or water observed.
The majority of the Site is sparsely covered with grasses. The existing portion of the Vegetation type and signs of constructed bund has naturally propagated. This vegetation is maintained in order to distress or absence where it control weeds. might be expected There was no evidence of vegetation die back or obvious discolouration.
Significant odours from the land No odours detectable as of November 2020.
Liquid discharges from the site There are no liquid discharges from the site.
Direction and flow of surface No surface water visible at the time of visit due to dry conditions. Site was relatively water run-off and presence of flat so no major flow paths expected. ponding
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk 2 Site Condition Report: Part 1
The land-use surrounding the Site is predominantly agricultural fields to the south and east with RAF Lakenheath located to the north and west. The main buildings of Lakenheath Country Club are surrounded by the proposed bund but are not included within the boundary of the Site.
Brandon Road bounds part of the western boundary of the Site. Land uses in the vicinity of the site Elveden Farms Recycling Facility is located to the southwest of the Site and its operations are key to the proposed works at the Site (e.g. it acts as an access point to the Site).
Other land-uses include deciduous woodland and protected areas (including Sites of Special Scientific Interest (SSSIs), Special Protection Areas (SPA) and Special Areas of Conservation (SAC).
Presence and condition of There are no surface water features within the Site boundary or in close proximity to surface water features the Site.
Evidence of any accidental/uncontrolled No visual or other evidence of accidental/uncontrolled releases on Site. releases at the site (previous or current)
Identity potential access constraints e.g. overhead No access constraints identified on the site. cables, location of machinery, operations at the site.
Evidence of historic contamination, for example, historical site investigation, “Draft Sampling report and assessment for Anthill/Holbrook waste deposit” – Bream assessment, remediation and Material Management Limited, dated October 2018 verification reports (where available)
Baseline groundwater data - See Environmental Setting & Site Design Report (ESSD) Appendix 5 Hydrogeological Risk Assessment Baseline soil and groundwater
reference data Baseline soil data – “Draft Sampling report and assessment for Anthill/Holbrook waste deposit” – Bream Material Management Limited, dated October 2018
3.0 Permitted activities
Permitted activities This Site Condition Report Part 1 forms part of an Environmental Permit application for deposit of waste for recovery operations.
Non-permitted activities undertaken Material deposit has previously been undertaken at the Site.
Document references for: • plan showing activity layout • Site Layout Plan, Drawing No. 18/014d 001 • environmental risk assessment. • See ESSD Report Appendix 6: Environmental Risk Assessment
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk 3
Environmental Permit Application Report: Version 1, November 2020
Appendix 4
Dust Management Plan
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk
Dust Management Plan
Rory J Holbrook Limited
Lakenheath Country Club, Brandon Road, Brandon, Suffolk, IP27 9PP
Dust Management Plan: Version 1, November 2020
Document Control Table
Project Reference 18/014d
Project Title Dust Management Plan
Document Title Dust Management Plan: Version 1, November 2020
Document Issue No. 1
Document Issue Date 16 November 2020
Client Rory J Holbrook Limited
Status Issue
Report Produced by/Date George Evans / Georgina Watkins 13 November 2020
Report Checked by/ Date Kate Brady 13 November 2020
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk ii
Dust Management Plan: Version 1, November 2020
Contents
1. Introduction ...... 1 Content of the Dust Management Plan ...... 1 2. Relevant legislation ...... 3 Air Quality Management Area (AQMA) ...... 3 Low Emission Zone (LEZ)...... 3 3. Site location and sensitive receptors ...... 4 Site Location ...... 4 Meteorology ...... 4 Sensitive Receptors ...... 5 Other Sources of Dust ...... 6 4. Operations at the Site ...... 7 Waste Deliveries ...... 7 Overview of Waste Operations ...... 7 Waste Handling and Movement ...... 7 Waste Storage ...... 8 Vehicle Movements ...... 8 Site Layout ...... 8 Waste Types ...... 8 Plant and Equipment ...... 8 5. Dust management and mitigation ...... 10 Responsibility for Implementation of the Dust Management Plan ...... 10 Overview of Dust Control ...... 10 Sources and Control of Fugitive Dust Emissions ...... 10 Water availability ...... 17 In the event of a drought ...... 17 Out of hours arrangements ...... 17 6. Monitoring ...... 18 Visual Dust Monitoring ...... 18 Monitoring Location ...... 18 Operation of the PM Monitoring Equipment...... 18 Quality Assurance/Quality Control and Record Keeping ...... 18 Equipment and Data Management ...... 18 Reporting of Data ...... 19
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk iii
Dust Management Plan: Version 1, November 2020
Additional Detailed Monthly Reporting ...... 19 7. Actions when alarm is triggered ...... 20 8. Reporting and complaints response ...... 21 Engagement with the Community ...... 21 Reporting of Complaints ...... 21 Management Responsibilities ...... 21
Tables Table 3.1: Sensitive Receptors within 500m of the Site Boundary ...... 5 Table 4.1: Potential of waste types to produce dust ...... 8 Table 5.1: Source-pathway-receptor routes ...... 11 Table 5.2: Mitigation measures ...... 12
Figures Figure 1.1: Location and extent of Lakenheath Country Club bund ...... 1 Figure 3.1: Wind rose from RAF Lakenheath Observing Station from 11/2009 to 09/2020. Arrow indicates predominant wind direction ...... 4
Drawings
Drawing No. 18/014c 001 Permit Boundary Plan
Drawing No. 18/014c 002 Sensitive Receptors Plan
Drawing No. 18/014d 001 Site Layout Plan
Appendices
Appendix 1 Inspection Checklists
Appendix 2 Complaints Form
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk iv
Dust Management Plan: Version 1, November 2020
1. Introduction
1.1. Westbury Environmental Limited has prepared this Dust Management Plan on behalf of Rory J Holbrook Limited (the Operator) to support an Environmental Permit application.
1.2. The Environmental Permit application that this Dust Management Plan supports seeks to allow 788,200m3 of waste to be deposited in the construction of a bund at Lakenheath Country Club, Brandon Road, Brandon, Suffolk, IP27 9PP (the Site).
1.3. The location and extent of the Site is shown in the Permit Boundary Plan, Drawing No. 18/014c 001 and in Figure 1.1 below.
Figure 1.1: Location and extent of Lakenheath Country Club bund
1.4. The bund is to be constructed around the main buildings of Lakenheath Country Club and is proposed to act as a noise bund to shield surrounding receptors from the noise from the shooting range and provide additional safety.
Content of the Dust Management Plan
1.5. This Dust Management Plan will form part of the Environmental Management System (EMS) for the Site. Procedures and Forms referenced within this Dust Management Plan will be included within the EMS. Completed forms (records) will be kept, as required by conditions included in the Environmental Permit.
1.6. This Dust Management Plan is structured as follows:
• Section 2 provides a summary of the relevant legislation and guidelines. • Section 3 provides information relating to the Site setting, including the location of the Site and nearby sensitive receptors. • Section 4 provides a summary of the operations carried out on the Site and the delivery of material to the Site.
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk 1
Dust Management Plan: Version 1, November 2020
• Section 5 provides information on the site management and the mitigation measures employed at the Site. • Section 6 provides information on how dust emissions are monitored at the Site. • Section 7 provides a summary of what happens when an alarm is triggered. • Section 8 provides a description of how complaints can be made and how they are addressed by the site management.
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk 2
Dust Management Plan: Version 1, November 2020
2. Relevant legislation
2.1. The Air Quality Strategy (AQS) for England, Scotland, Wales and Northern Ireland fulfils the requirement under Part IV of the Environment Act 1995 for a national air quality strategy which sets out policies for improving ambient air quality and keeping these under review. The first strategy, the National Air Quality Strategy (NAQS), was published in March 1997. In January 1999, proposals to amend the strategy were put out for consultation and a consultation document was produced. Following consultation, a revised version of the strategy was published in January 2000. This was further revised in 2007 and has not been revised since this date.
2.2. The AQS provides a framework for air quality control through air quality management and air quality standards and objectives for different pollutants (including particulate matter). These air quality standards and objectives were transposed into English Law by the Air Quality (Standards) Regulations 2010.
Air Quality Management Area (AQMA)
2.3. The system of local air quality management (LAQM) was introduced under the Environment Act 1995. LAQM requires local authorities to periodically review and assess the current and future quality of air in their areas. Where it is determined that an air quality objective is not likely to be met within the relevant time period, the authority must designate an AQMA.
2.4. The Site is located within a Local Authority that has an AQMA. However, the closest AQMA boundary is 32km SW of the Site (the A14 Corridor).
Low Emission Zone (LEZ)
2.5. A LEZ is an area that has restrictions on the type and age of vehicles permitted in it, therefore, vehicles emitting high levels of pollution can be prevented from entering and operating within the zone.
2.6. The Site is not located within a LEZ.
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3. Site location and sensitive receptors
Site Location
3.1. The Site is located on the edge of RAF Lakenheath, the base of which is approximately 600m north of the Site. The residential town of Lakenheath is approximately 2.5km north west of Site. Access to the Site is via the A1065 (Brandon Road) which runs along part of the north western boundary of the Site. The access point to the Site from Brandon Road is located at grid reference TL 73293 79857.
3.2. The entire Site extends to approximately 15ha, see Permit Boundary Plan, Drawing No. 18/014c 001.
3.3. The land-use surrounding the Site is predominantly agricultural fields to the south and east with RAF Lakenheath located to the north and west.
3.4. The Site is located in Flood Zone 1, where the probability of fluvial flooding is 0.1% in any year. The Site is considered to be at a very low risk of flooding from seas and rivers with a few northern areas of the Site prone to flooding from surface water. The north eastern boundary of the Site may be prone to flooding from reservoirs.
3.5. The Site is located within a Groundwater Source Protection Zone 1.
3.6. The Site is located on a Principal designated bedrock aquifer. The Site is not located on a designated superficial aquifer.
Meteorology
3.7. Unlike many other atmospheric pollutants, the generation of dust is particularly dependent upon weather conditions.
3.8. The prevailing meteorological conditions at any site will be dependent upon many factors, including its location in relation to macroclimatic conditions as well as more site specific, microclimatic conditions. Clearly the most significant meteorological factor is the predominant wind direction and wind speeds, and consequently data has been collected regarding the predominant wind speeds and directions appropriate to the Site.
Figure 3.1: Wind rose from RAF Lakenheath Observing Station from 11/2009 to 09/2020. Arrow indicates predominant wind direction
3.9. Wind speed and direction data have been obtained from the RAF Lakenheath observing station for the period from 11/2009 to 09/2020. RAF Lakenheath observing station is located approximately 2km to the
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north of the Site. This observing station has wind speed and direction data appropriate for characterisation of the wind climate at the Site, see Figure 2: Wind rose from RAF Lakenheath Observing Station 11/2009 to 09/2020.
3.10. The predominant wind blows towards receptors to the north-east of the Site which includes the eastern boundary of RAF Lakenheath base and agricultural land.
Sensitive Receptors
3.11. This Dust Management Plan identifies all types of receptors within 500m of the Site that may be sensitive to dust emissions.
3.12. Locations with a high sensitivity to dust for this Dust Management Plan include deciduous woodland/protected habitat, agricultural land and residential dwellings.
3.13. The distance from the Site boundary to the sensitive receptor plays an important role in the potential impact experienced from airborne dust. Concentrations of airborne dust reduce significantly further away from the source.
3.14. Due to the nature of the materials being handled on this Site the particle size of the dust emitted is of intermediate to large particles. Therefore, it can be concluded that these particles are highly likely to be deposited within 50m of the source.
3.15. The direction and distances from the boundary of the Site to the boundary of sensitive receptors are provided in Table 3.1 Sensitive Receptors, see Sensitive Receptors Plan Drawing No. 18/014c 002.
Table 3.1: Sensitive Receptors within 500m of the Site Boundary
Direction Distance from Ref Receptor Description from Site Site Boundary Boundary (m) Designated Protected Breckland Farmland Within 1 Habitat – Site of Special 0 SSSI boundary Scientific Interest (SSSI) Designated Protected Within 2 Breckland SPA Habitat - Special Protection 0 boundary Area (SPA) Designated Protected Within 3 Deciduous woodland 0 Habitat boundary Lakenheath Warren Designated Protected On northern 4 North SSSI Habitat - SSSI boundary Designated Protected On northern 5 Breckland SAC Habitat - Special Area of North boundary Conservation (SAC) Designated Protected On southwestern 6 Deciduous woodland Southwest Habitat boundary A1065 (Brandon 7 Main Road West 10 Road) Lodging at RAF Lakenheath 8 Liberty Lodge Northwest 80 with associated open space n/a - Lakenheath Country Country club and shooting 9 surrounded 150 Club range by the Site Area of restaurants with 10 Restaurants West 150 associated car parks Hospital buildings and RAF Lakenheath 11 associated infrastructure on West 270 Hospital airbase
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Direction Distance from Ref Receptor Description from Site Site Boundary Boundary (m)
12 AFB Baseball Fields Playing fields North 275
RAF Commercial Area of shops and services 13 Northwest 290 Area on airbase Dental Clinic Dentist and associated 14 Northwest 390 Lakenheath infrastructure Eriswell Low Warren Designated Protected 15 South 440 SSSI Habitat – SSSI
3.16. Due to the predominant wind direction to the north-east and their proximity to the Site, receptors 1 - 5 in Table 3.1 are considered to be at risk from dust emissions if mitigation measures are not implemented at the Site in very windy or dry weather.
3.17. Due to the distance of the Site from the receptors 6 – 10 (0 – 150m), these receptors could be at risk of impact from dust emissions if mitigation measures are not implemented at the Site in very windy or dry weather.
3.18. Due to the distance from the Site to the sensitive receptors 11 – 15 (270 – 440m), it is considered unlikely that dust from the waste operations at the Site will reach these sensitive receptors. The mitigation measures discussed in Section 5 of this Dust Management Plan should further limit the likelihood of dust emissions reaching sensitive receptors around the Site.
Other Sources of Dust
3.19. There is the potential for dust to be emitted from vehicle movements along Brandon Road which runs broadly north to south on the western boundary of the Site.
3.20. It is considered that agricultural activities have the potential to cause dust emissions. In particular the ‘Fen Blows’ which is the incidence of very strong winds around February, when it is not uncommon for soils from agricultural fields (including crops) to be blown onto adjacent land.
3.21. Elveden Farms Recycling Facility is located approximately xm south of the Site and is operated by Rory J Holbrook Limited. The nature of the operations at that site also have the potential to release dust. The Elveden Farms Recycling Facility operates in accordance with their own Dust Management Plan which contains mitigation and remedial measures for the prevention of dust emissions from the recycling site. As such, dust emissions from this adjacent site are considered unlikely.
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4. Operations at the Site
Waste Deliveries
4.1. All waste deliveries will be accompanied by a Waste Transfer Note (WTN) which will be obtained from the load driver. The WTN will provide information on the driver, waste haulier name, permit number, description of waste etc. Loads that are not accompanied by a WTN or that do not match the description on the WTN will be rejected.
4.2. A record will be kept of all vehicles delivering waste to and from the Site, along with the type, quantity and source of waste delivered. WTN’s will be appropriately stored for a minimum of two years.
4.3. Wastes imported for use in the construction of the bund may either be imported directly from pre-approved sources or may be treated at the Elveden Farm Recycling Facility first, before being sent to the Site.
4.4. All waste coming into the Site will undergo prior approval at the Elveden Farms Recycling Facility weighbridge in accordance with the Waste Acceptance Procedure.
4.5. All incoming loads to the Site will also be checked at the point of deposit. The Operator will monitor the volume of waste coming into the Site by recording the net tonnage of each incoming load. A record will be kept of the total tonnage brought into the Site for the restoration and the agreed conversion factor will be applied to the tonnage to determine the total volume.
4.6. Waste acceptance procedures will be applied to ensure that only suitable waste is accepted. Only those waste codes detailed in the Environmental Permit will be accepted onto the Site.
4.7. Waste will be delivered onto the Site by Heavy Good Vehicles. All vehicles entering / exiting the Site will be sheeted to minimise the likelihood of dust emissions. Loaded vehicles arriving onto the Site that are not sheeted will be rejected in accordance with the Waste Rejection Procedure within the EMS.
4.8. The movement of vehicles visiting the Site has the potential to cause dust emissions, particularly in dry and windy conditions. A 5mph speed limit and the minimisation of vehicle movements will be enforced on the Site to help reduce the amount of dust generated by vehicle wheels.
4.9. Vehicles entering the Site will be visually inspected prior to unloading to ensure that excessively dusty loads are not accepted. Excessively dusty loads will be rejected from the Site in accordance with the Waste Rejection Procedure in the EMS.
4.10. Mud will be prevented from being tracked out of the Site by vehicles by the use of the wheelwash at the Elveden Farms Recycling Facility prior to exiting the facility. This will ensure the prevention of dust by resuspension of vehicles on the adjacent highway. Dust emissions from Site surface will also be prevented by regular dampening using mobile water bowsers (600 gallon capacity).
Overview of Waste Operations
4.11. The operations carried out at the Site will include the importation and deposit of waste to build a screening perimeter bund around the Lakenheath Country Club.
4.12. Operations will be conducted by staff from Rory J Holbrook Limited on a daily basis, this includes the use of plant and equipment owned by Rory J Holbrook at Elveden Farms Recycling Facility located south of the Site.
4.13. Specific operations to be carried out on the Site are listed below with further information regarding the potential for these activities to cause dust emissions:
Waste Handling and Movement
• Wastes such as soils can be considered to be dusty materials if they are dry. Therefore, movement of wastes has the potential to cause dust emissions. • Loading and off-loading of vehicles and equipment has the potential to cause dust emissions.
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Waste Storage
• Imported wastes may be temporarily stored in stockpiles before being deposited in the bund. Should these stockpiles of waste become dry, then they may be a potential source of dust emissions. • Dust emissions from stockpiles may occur in the event of windwhipping.
Vehicle Movements
• The movement of vehicles within the Site has the potential to cause dust emissions, particularly in dry and windy conditions. • Mud could be tracked out of the Site by vehicles potentially causing dust emissions from the road surface.
Site Layout
4.14. The proposed layout of the Site is shown on the Site Layout Plan, Drawing No. 18/014d 001.
4.15. Incoming loads will arrive via the adjacent Elveden Farms Recycling Facility weighbridge and will then be directed to the waste deposit area on Site.
4.16. Delivery HGVs will enter and leave the Site via the wheel wash at the Elveden Recycling Facility which is accessed by internal haul routes, see Site Layout Plan Drawing No. 18/014d 001.
4.17. Waste may be temporarily stored in an offloading area on the Site or will be placed directly into the construction of the bund. Temporary storage will be avoided where possible to reduce double handling of materials on the Site.
Waste Types
4.18. The waste types allowed at the Site have been summarised and assigned a “low”, “medium” or “high” risk level for the potential to emit dust, as shown in Table 4.1 Potential of waste types to produce dust below.
Table 4.1: Potential of waste types to produce dust
Processes waste type Summary of Dust Potential Waste types subjected to on the mitigation measures Site implemented Low Bricks, ceramics, tiles Handling Water used to dampen etc. surfaces (site and stopkpiles) Medium Concrete, minerals Handling (sands and gravels) etc. All waste types subject High Soils (silty, sandy, Handling to visual monitoring by clayey) residual waste Site Operatives. from treatment processes etc.
4.19. Mitigation measures on the Site have been considered and implemented with a “high” risk potential in mind. The Operator will have a conservative approach to all waste types used in the construction of the bund regarding their potential to emit dust. All waste types are handled with mitigation measures in place to minimise the potential to produce dust.
4.20. It is likely that the majority of waste handled and placed at the Site will fall under the ‘high risk’ category. However a majority of the time, this material will have an inherent water content and will not arrive to Site with the potential to emit dust (controlled via Waste Acceptance Procedure). This status will be maintained by the application of the mitigation measures mentioned in Table 4.1 as required.
Plant and Equipment
4.21. The following equipment will be used on the Site for the waste operations:
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• 360o excavator • D6 Blade (dozer) • Loading shovel
4.22. All plant and equipment to be used on the Site will be mobile plant.
4.23. All plant and equipment will be subject to maintenance checks in accordance with procedures in the Site’s EMS.
4.24. All plant will be operated in a manner appropriate to minimising emissions. There will be no unnecessary revving of engines and machinery will be shut off when not in use.
4.25. The Operator will continue their policy of replacing older machinery with new, low emission machinery as it becomes available and as the business allows.
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5. Dust management and mitigation
Responsibility for Implementation of the Dust Management Plan
5.1. The Site Manager is responsible for the implementation of the Dust Management Plan and for ensuring that the mitigation strategies in place are adhered to. Where the Site Manager is unavailable to oversee the implementation of dust suppression measures, a suitably experienced Site Operative is delegated responsibility.
5.2. This Dust Management Plan will be reviewed every four years or when a change in operations is deemed to have a potential effect on increasing dust emissions. The review process will amend any mitigation measures that have been identified as areas for improvement to reduce the potential for dust emissions from the Site.
5.3. All staff members will be given the necessary training to deliver dust suppression measures detailed within this Dust Management Plan. All staff will be given training on the EMS for the Site, which includes a Dust Procedure. All staff on the Site will be trained on the Dust Procedure which includes details regarding mitigation measures and monitoring/recording visual inspections. Site procedures will be communicated between staff via EMS training and weekly toolbox talks. Where new dust suppression measures are to be implemented, refresher training will be provided to ensure staff remain competent. This training will be delivered by the Site Manager.
Overview of Dust Control
5.4. Dust control measures are in place to help mitigate dust emissions at the Site, see Table 5.2: Mitigation measures. These measures are implemented when appropriate, particularly in periods of dry weather or when dust is identified to be escaping the Site boundary. The Site boundary is inspected regularly to identify any dust entrainment/ emissions / dust leaving the Site. If dust entrainment or emissions are observed, then the use of water is instigated to suitably dampan the material/ surface.
5.5. A 600 gallon mobile water bowser will be available at the Site to dampen surfaces and material to prevent particulate matter becoming airborne. The condition and integrity of the bowser will be checked as part of the Inspection Checklists (in the Site’s EMS).
5.6. Site surfacing will be checked by way of the Inspection Checklists, see Appendix 1. Build-up of materials on the Site surface will be minimised by implementing the procedures within the EMS.
5.7. The Site Manager may decide to cease operations should there be excessive dust emissions from the Site. Operations will resume on the Site when the circumstances causing the excessive dust have been resolved. It is the Site Manager who decides when operations will continue.
Sources and Control of Fugitive Dust Emissions
5.8. Table 5.1 details the potential sources of dust on the Site and which mitigation measures are implemented to break the source-pathway-receptor routes for dust emissions.
5.9. Table 5.2 lists the mitigation measures to control dust emissions at the Site.
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Table 5.1: Source-pathway-receptor routes
Source Pathway Receptor Type of Impact Where relationship can be interrupted Mud Transportation of Brandon Road Mud on Brandon Road and other All vehicles entering and exiting the Site must do so dust on wheels and local roads. via the wheelwash (at the Elveden Farms Recycling vehicles, then mud Facility). dropping off Resuspension of mud as airborne wheels/vehicles particulates. The Site and unpaved surfaces/ haul routes are when dry. dampened down by mobile water bowsers when overly dry or dusty conditions present.
Should the above measures fail, a road sweeping vehicle will be hired and deployed when necessary to mitigate any mud on the public highways and prevent the generation of dust as a result of the Site operations. Debris Falling off lorries Brandon Road and Visual soiling, also consequent Vehicles delivering waste are sheeted. other public resuspension as airborne highways particulates Where debris is identified, it will be cleared up immediately, either manually or by a hired road sweeper.
All areas are subject to regular housekeeping. Vehicle / Plant Atmospheric Surrounding Airborne particulates and build-up The Site is subject to regular housekeeping and movements dispersion from sensitive receptors of dust on surfaces of site and water is utilised to dampen surfaces as required. resuspension of dust including local roads. designated protective habitats. Tipping and storage of Atmospheric Surrounding Visual build-up of dust. The potential of dust emissions will be minimised by wastes in the open dispersion sensitive receptors lowering drop heights, where possible.
It is intended for incoming waste to be deposited directly onto the bund or as close to its intended deposit location as is operationally possible.
Operations will be halted when wind speeds are deemed to be excessive.
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Table 5.2: Mitigation measures
Mitigation Description / Effect Use on Site Trigger for How is it implemented? Further mitigation if Measure implementation not effective Site speed Reducing vehicle There is a no-idling policy in 5mph speed limit These measures will be If excessive dust limit, ‘no movements reduces dust place on the site for vehicles. signage. implemented by staff emissions are idling’ policy emissions from the Site. training on the EMS and observed to be and Enforcement of the speed Vehicle movements will be Enforcement of speed limit signs on the leaving the Site minimisation limit and limiting minimised by ensuring that the speed limit by Site Site. boundary, then the of vehicle movements will reduce the double handling of materials is Manager and further mitigation movements chance and amount of re- avoided where possible. constant observation measure(s) will be on Site. suspension of dust by and reminders by triggered. vehicle wheels. A 5mph speed limit is enforced Site operatives. on the entire Site. If there is mud on the access road, then a mobile bowser will be deployed to clean and dampen the surface.
If excessive dust emissions from vehicle movements continue after these measures, then operations shall cease. Minimising Minimising the height at The EMS will require that the This measure will be By plant operators Water will also be drop heights which waste is dropped handling of waste material on Site implemented lowering the grabs/shovels available to dampen for waste. should reduce the distance will be minimised where possible. whenever the Site is on the equipment being surfaces and over which dust could be operational i.e. used to move and deposit stockpiles to reduce blown and dispersed by Staff will be trained about the whenever material is materials. dust generation. winds. importance of reducing drop being moved. heights. If excessive dust emissions continue after these measures, then operations shall cease. Good Having a consistent, The EMS will have a These measures will Good housekeeping is If excessive dust housekeeping regular housekeeping housekeeping procedure. be implemented implemented by following emissions are regime that is supported by whenever the Site is the housekeeping observed to be management, will ensure The waste types to be accepted operational. procedure within the EMS leaving the Site the Site is regularly at the Site will contain very little, if and by carrying out site boundary, then the checked and issues any, litter. inspections. further mitigation
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Mitigation Description / Effect Use on Site Trigger for How is it implemented? Further mitigation if Measure implementation not effective remedied to prevent and measure(s) will be remove dust build up. On-site litter will be collected and triggered e.g. water disposed of daily by a Site suppression. Operative to keep the Site tidy.
Due to the presence of hedging / fencing around the perimeter of the Site there is little risk of litter from the waste operations leaving the Site. Sheeting of Prevents the escape of The EMS will state that all Loading/ unloading of The sheeting equipment If excessive dust vehicles debris, dust and vehicles entering / exiting the Site materials to/from a will be activated and emissions are particulates from vehicles must be sheeted to minimise the vehicle will be checked to ensure proper observed to be as they travel. likelihood of dust emissions. followed by closing of coverage before the leaving the Site the sheet covers on vehicle can leave the site. boundary, then the Excessively dusty loads will not that vehicle. further mitigation be accepted to the Site. Incoming vehicles that are measure(s) will be Visual observation of not sheeted will be triggered. Materials incoming vehicles will rejected from the site or may be dampened. take place to ensure sheeted immediately. vehicles arriving are sheeted.
All vehicles carrying waste to the site will be sheeted at all times unless being loaded or unloaded. Ceasing Mobilisation of dust and During exceptionally dry and/or If excessive dust is The Site Manager makes N/A operations particulates is likely to be windy conditions, if any being generated by the decision to cease during high greater during periods of operations / Site movements the operations, then activities that are causing winds and/or strong winds or cause or are likely to cause the Site Manager will the dust emissions. exceptionally exceptionally dry conditions visible dust emissions beyond the notify staff and dry and hence ceasing Site boundary, or if abnormal dust operations may be conditions. operation at these times emissions are observed within temporarily ceased. may reduce peak pollution the Site, site waste operations events. may be suspended to avoid Operations further dust emissions. commence once the wind has subsided The weather conditions at the and/or the area is Site will be considered and dampened down.
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Mitigation Description / Effect Use on Site Trigger for How is it implemented? Further mitigation if Measure implementation not effective recorded at the start of each working day so that the day’s Prevailing weather work may be planned to take in condition monitoring regard any potential dust (visual observation) emissions. If the wind speed and including wind direction are likely to increase the strength, wind risk of nuisance to neighbouring direction and rainfall. receptors, then operations may This monitoring will be temporarily stopped. There is be recorded on the no specific wind speed limit Inspection and/or no specific criteria for this Checklists. to occur, as dust is dependent on other conditions such as rain.
The Site Manager will decide whether to cease operations because of weather conditions.
This decision is based on a combination of factors, including those mentioned above. The conditions are recorded on the Inspection Checklists. The record includes an overall description of the weather conditions including, but not limited to, wind strength (e.g. windy, not windy), wind direction (e.g. towards northern boundary) and rain. Road Removes the mud from the A road sweeping vehicle is hired/ Visual observation of The road sweeper would N/A sweeper access road and Brandon deployed to control the amount of the state of the be deployed to clean the Road and reduces the mud on local roads and minimise access road and access road and local potential for dust emissions the generation of dust when local roads - findings roads (Brandon Road). from vehicle movements in required. recorded on the Site management instructs the area. Inspection Checklists a trained Site Operative to The road sweeper will be in Appendix 1. carry out the road maintained in accordance with sweeping. the manufacturer’s specifications. This identifies the need for the use of the road sweeper.
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Mitigation Description / Effect Use on Site Trigger for How is it implemented? Further mitigation if Measure implementation not effective Appendix 1 Inspection Checklists Constant observation will be populated with items on by all operatives on the Site that are required to be the Site. maintained on a scheduled basis, such as the road sweeper. The Site Manager will check on the state of The cleanliness of roads in the the road at least once vicinity of the Site entrance are daily and if mud is checked as part of the Inspection visible on the road, Checklists. that has been tracked out from the Site, then the road sweeper will be hired and deployed. Wheel wash The wheel washing facility is The wheel wash will The wheel wash will be N/A used solely to remove mud from be used by all used by all vehicles the wheels of vehicles and is vehicles entering and entering and exiting the inspected on a regular basis to exiting the Site. Site. ensure the facility is in working order.
The wheel wash is located on the adjacent Elveden Farms Recycling Facility. The wheelwash is accessed via internal haul routes managed by the Operator, prior to the vehicles exit to Brandon Road.
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Mitigation Description / Effect Use on Site Trigger for How is it implemented? Further mitigation if Measure implementation not effective Water Using towed mobile water Towed 600 gallon mobile water During periods of dry/ The water levels in the If excessive dust suppression bowser to dampen Site bowser will be in use at the Site windy weather to bowsers are monitored by emissions are surfaces. This measure to dampen surfaces or material, prevent entrainment Site Operatives to ensure continued to be dampens down dry / dusty to prevent dust emissions. The of dust by wind. that there is a sufficient observed leaving the materials. condition and integrity of the supply available. Water for Site boundary, then water bowser will be checked as When excessive dust suppression is sourced the further mitigation part of the Inspection Checklists. emissions are from Elveden Farms measure(s) is observed to be Recycling Facility. triggered. Cease leaving the Site operations causing boundary. Visual the dust emission. observation will be carried out by all employees on the Site.
Findings from the visual observations will be recorded on Inspection Checklists.
Use on the Site to minimise dust emissions unless the Site is not operational or there is wet weather.
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Other Considerations:
Water availability
5.10. Water for dust suppression will be obtained from the mains water supply at Elveden Farms Recycling Facility, also operated by Rory J Holbrook Limited. Additional water may be delivered to the Site in IBCs from external sources if required.
5.11. The water bowser at the Site can be deployed to anywhere within the Site boundary and on the access road. The bowser has a capacity of 600 gallons.
In the event of a drought
5.12. During exceptionally dry and/or windy conditions, if any operations / site movements cause or are likely to cause visible dust emissions beyond the Site boundary, or if abnormally high dust emissions are observed within the Site, operations may be suspended to avoid further dust emissions. This will be decided by the Site Manager.
5.13. Depending on the severity of the drought conditions, restrictions may be in place on the amount of water available for use on Site from the supplier (mains water supply). In this case, operations may be reduced or suspended in order to comply with any water usage restrictions.
Out of hours arrangements
5.14. The Site Manager will make the decision on whether to implement mitigation measures depending on the forecast for the night. For example, should the day have been a particularly dry, windy day then the Site Manager may instruct operatives to dampen down the Site surfaces before closing the Site.
5.15. Should an out-of-hours complaint be received regarding dust emissions, the Site Manager will attend the Site or will instruct a relevant operatives to attend the Site.
5.16. The attending operative will identify the source of the dust emission and instigate mitigation measures.
5.17. The cause of the emissions will be determined and, if necessary, the Dust Management Pan will be updated to reflect any necessary change in routine procedures.
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6. Monitoring
Visual Dust Monitoring
6.1. Dust emissions at the Site will be monitored by visual observation. This monitoring will take place at all times by Site Operatives, within the Site boundary and at the Site perimeter at designated times.
6.2. It is expected that staff members will also check for dust emissions as they approach and leave the Site.
6.3. It will be the responsibility of every member of staff to monitor the dust emissions on the Site as they undertake their daily tasks.
6.4. Reports of dust potential or dust emissions will be made to the Site Manager.
6.5. If excessive dust emissions (dust clouds) are observed, then the Site Manager will establish what is causing the excessive dust emission to be generated and take remedial action. The results of the investigation and what action was taken will be recorded and retained.
6.6. The weather conditions at the Site will be considered and recorded at the start of each working day so that the day’s work may be planned as appropriate regarding potential dust emissions. Information on the Inspection Checklists will contain an overall description of the weather conditions including, but not limited to, wind strength, wind direction (e.g. toward northern boundary) and rain.
6.7. As well as visual monitoring being undertaken by Site Operatives at all times, there are times of the day where visual monitoring is required to be recorded on the Inspection Checklists. The recorded visual monitoring checks will be carried out by a Site Operative, who will have been trained in accordance with the procedures within the EMS. Remedial actions required will be specified and identified on the Inspection Checklists.
6.8. Recorded visual monitoring will be undertaken at least twice a day, for a minimum of five minutes each time. They will take place at the beginning of the working day and when operations with the highest potential to produce dust are taking place. Undertaking visual monitoring recorded checks at the times when the Site is considered to have the highest potential for dust emissions is considered to be the most beneficial method to ensure that mitigations measures in place at the Site are effective.
6.9. Extra and unplanned monitoring will be carried out on the Site when conditions are particularly windy or dry, new activities are being undertaken, new machinery is being used or following the receipt of a complaint or incident related to dust emissions.
Monitoring Location
6.10. There will be no particulate matter monitoring equipment used on Site. Visual monitoring of dust will take place whenever the Site is operational and from anywhere within the Site boundary and the vicinity, particularly the Site boundary.
Operation of the PM Monitoring Equipment
6.11. There will be no particulate matter monitoring equipment located on the Site. Only visual monitoring of dust emissions will take place.
Quality Assurance/Quality Control and Record Keeping
6.12. There will be no particulate matter monitoring equipment located on the Site. Only visual monitoring of dust emissions will take place.
Equipment and Data Management
6.13. There will be no particulate matter monitoring equipment located on the Site. Only visual monitoring of dust emissions will take place.
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Reporting of Data
6.14. There will be no particulate matter monitoring equipment located on the Site. Only visual monitoring of dust emissions will take place. No data from equipment will therefore be reported to the Environment Agency.
Additional Detailed Monthly Reporting
6.15. There will be no particulate matter monitoring equipment located on the Site. Only visual monitoring of dust emissions will take place. No data from equipment will therefore reported to the Environment Agency.
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7. Actions when alarm is triggered
7.1. There will be no specific dust monitoring equipment on the Site with trigger alarms. Monitoring will be carried by visual observation and assessing whether dust emissions are excessive i.e. leaving the Site boundary. If dust emissions are perceived to be excessive then the Site Manager will establish what is causing the excessive dust emission to be generated and take remedial action.
7.2. The remedial measures are stated in Table 5.2: Mitigation measures.
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Dust Management Plan: Version 1, November 2020
8. Reporting and complaints response
8.1. The Site’s EMS will contain a procedure for responding and dealing with complaints. A complaints form will be available on Site and must be filled in and kept on file whenever a complaint is received in accordance with the EMS complaints procedure.
Engagement with the Community
8.2. The Site Notice Board will be placed at the entrance of the Site with the following information:
• The Permit holder’s name (Rory J Holbrook Limited). • The operator’s name (Rory J Holbrook Limited). • An emergency contact name and telephone number. • A statement that the Site is permitted by the Environment Agency • The Environmental Permit Reference. • The Environment Agency national numbers, 03708 506506 and 0800 807060 (incident hotline).
8.3. The provision of the above information will ensure that members of the community can contact the Operator should they be concerned by dust emissions or wish to make a complaint. This also applies to any events that may happen when the Site is unmanned / not operational.
Reporting of Complaints
8.4. Should a complaint regarding dust be received by the Site, the complaint will be recorded on the Complaints Form in the EMS and investigated in accordance with the Complaints Procedure within the EMS. The Complaints Form will record who made the complaint, what the complaint was about and what has been done to resolve the issue and make sure this does not happen again. A copy of the Complaints Form is included as Appendix 2.
8.5. The Site Manager will identify what caused the excessive dust emission to be generated. This generation may have been caused by failure of site machinery or dust procedures. If the excessive dust emission has been caused by a procedure not being carried out properly, then staff will receive further training on the dust procedures and site management. If the excessive dust emission has been caused by plant failure, then the plant will be repaired as soon as possible.
8.6. All complaints will be acknowledged and investigated, with resultant actions reported to the complaint. Any complaints received by the Environment Agency relating to dust emissions from the site are dealt with on the same day.
Management Responsibilities
8.7. Site staff will be responsible for dust management issues and detecting/reporting dust emissions. All members of staff will be given training on the EMS for the Site, which will include a Dust Procedure. All staff on the Site will be trained on the Dust Procedure which will include details regarding mitigation measures and monitoring/recording visual inspections.
8.8. Upon receipt of a complaint, the Site Manager will investigate and establish the cause. The most effective corrective or preventative action must then be determined to prevent future emissions occurring. Where additional time is required to implement the appropriate corrective or preventative action, the complainant will be contacted with details of the actions to be implemented and the estimated timescales for completion. The maximum response time for investigating the cause of the complaint and contacting a complainant will be two working days.
8.9. Should numerous complaints be received at the Site regarding the same issue, the cause of the complaint(s) will be investigated in accordance with the Accidents, Incidents & Complaints Procedure within the EMS. Operations on the Site will cease, should excessive dust emissions be seen leaving the boundary following the implementation of additional mitigation measures or when instruction from the Environment Agency to cease operations has been received.
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk 21
Dust Management Plan: Version 1, November 2020
Drawings
Drawing No. 18/014c 001 Permit Boundary Plan
Drawing No. 18/014c 002 Sensitive Receptors Plan
Drawing No. 18/014d 001 Site Layout Plan
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk
Client: Rory J Holbrook Limited
Title: Proposed permit boundary plan
Site: Lakenheath Bund Lakenheath Brandon Rd, Brandon IP27 9FB
Date: 22 October2020
Scale:
Reference: 18/014c 001
Proposed permit boundary Bund boundary (C) OS OpenStreetMaps Lakenheath Country Club Bund
Client Elveden Farms Limited
Title Sensitive Receptors Plan
Dwg No. 18/014c 002
Site Lakenheath Country Club, 12 Hereford Road, Brandon, Suffolk, £ IP27 9PP 14 9
Scale See Drawing
Date 13/11/2020 8 4 1 2 5 Key 11 1 Breckland Farmland SSSI 7 2 Breckland SPA 3 Deciduous Woodland 4 Lakenheath Warren SSSI 6 £ 5 Breakland SAC 10 6 Deciduous Woodland £ 7 A1065 13 8 Liberty Lodge 9 £ Restaurants 10 £ Lakenheath Country Club 3 11 RAF Lakenheath Hospital 12 AFB Baseball Fields 13 £ Commercial Area 14 Dental Clinic Lakenheath 15 Eriswell Low Warren SSSI
Site Boundary 500 buffer
15
Agriculture House, T: 01952 879705 Southwater Way, M: 07762 580839 0m 200m 400m Telford, E: [email protected] TF3 4NR www.westburyenv.co.uk Client Rory J Holbrook Limited
Title Site Layout Plan
Dwg No. 18/014d 001
Site Lakenheath Country Club, Brandon Road, Brandon, Suffolk, IP27 9PP
Scale See Drawing
Date 13/11/2020
Key
Date Bund permit boundary Bund boundary Elveden Farms Recycling Facility boundary Proposed Storage Area Access track Wheel wash Elveden Farms Recycling Facility entrance/exit Office Weighbridge
Agriculture House, Southwater Way, T: 01952 879705 Telford, M: 07762 580839 TF3 4NR 0m 100m 200m 300m 400m E: [email protected] www.westburyenv.co.uk
Dust Management Plan: Version 1, November 2020
Appendix 1
Appendix 1 Inspection Checklists
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk
Appendix 1: Inspection Checklists
Daily Inspection Checklists V1, November 2020
Weather checks - dust Describe the current conditions on site e.g. dry, sunny, windy, raining
How may the conditions affect site operations? E.g. dry conditions or windy conditions – more dust mitigation required
OK to proceed with operations as normal? YES / NO If no, explain why:
All dust equipment working? YES / NO
Item for Visual Inspection Aspects for Inspection Checked? Remedial Action Required? Action Form Completed Site security Gates near Site entrance working and lockable
Fencing around Site in good condition e.g. no holes
Spills Spill kits in place with office Litter No litter within deposit area
No litter on site boundaries
No litter outside site boundary
Fire Fire extinguishers in place and no obvious damage
Soil / sand available to aid in firefighting
Roads Public highways and entrance road clear of mud and debris
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk Appendix 1: Inspection Checklists
Dust Visual Monitoring Checks
Time/activity Area to check Level of dust observed Remedial action required Action Form (Leave blank if no action required) completed
Beginning of working day Deposit area None Low Medium High
Waste storage area None Low Medium High
Activity undertaken with Deposit area None Low Medium High potential to produce dust
Describe: …………….. Waste storage area None Low Medium High
Activity undertaken with Deposit area None Low Medium High potential to produce dust
Describe: …………….. Waste storage area None Low Medium High
Date: ______Completed by: ______Signature:
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk
Dust Management Plan: Version 1, November 2020
Appendix 2
Appendix 2 Complaints Form
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk
Appendix 2: Complaints Form
Complaints Form V.1 November 2020
Who made the complaint? Name:
Address:
Phone No.:
Date and time they made the complaint:
What happened? What was it about?
Was anyone else aware of this – other neighbours or your staff? If so, who?
Did the complaint relate to your site? If so, what happened? What went wrong?
What have you done to make sure that it does not happen again?
Was there any significant pollution – for example: dust, odour or noise outside the site or spillage of polluting liquids onto the ground, into a drain or a watercourse?
If there was, then you must notify the Environment At what time did you phone? Agency on 0800 807060 and any other relevant regulators.
Have you done so? Yes No
You must also write or send an email to confirm this What date did you contact? to your local Environment Agency office.
Have you done so? Yes No
Please print and sign your name:
Rory J Holbrook Limited: Lakenheath Country Club, Suffolk