Dust Management Plan - apps.eastsussex.gov.uk

0 © OAKTREE ENVIRONMENTAL LTD – THE UNAUTHORISED COPYING OR REPRODUCTION OF THIS DOCUMENT (OR

Oaktree Environmental Ltd Waste, Planning & Environmental Consultants

Oaktree Environmental Ltd, Lime House, 2 Road Two, Winsford, Cheshire, CW7 3QZ Tel: 01606 558833 | Fax: 01606 861183 | E-Mail: [email protected] | Web: www.oaktree-environmental.co.uk

REGISTERED IN THE UK | COMPANY NO. 4850754

DUST MANAGEMENT PLAN Yard at Knights Business Centre, Squires Farm Ind. Est., Palehouse Common, Fairfield,

Uckfield TN22 5RB

Pyrite Industries Ltd

Version: 1.1 Date: 22 May 2019

Doc. Ref: 4034-1906_DMP Author(s): CP Checked:

Client No: 1906 Job No: 4034

Dust Management Plan Version 1.1 Pyrite Industries Ltd 22 May 2019

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Document History:

Version Issue date Author Checked Description

1.0 22/05/2019 CP -- Internal draft 1.1 22/05/2019 CP -- Corrected typo


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CONTENTS

DOCUMENT HISTORY: ......................................................................................................................................... I CONTENTS ......................................................................................................................................................... II LIST OF TABLES .................................................................................................................................................. IV LIST OF APPENDICES: .......................................................................................................................................... V 1 INTRODUCTION ....................................................................................................................................... 1

1.1 SITE HISTORY / BACKGROUND ...................................................................................................... 1 1.2 SITE LOCATION ......................................................................................................................... 1 1.3 FACILITY OVERVIEW ................................................................................................................... 2 1.4 SITE MANAGEMENT ................................................................................................................... 2 1.5 SENSITIVE RECEPTOR LOCATIONS .................................................................................................. 3

2 SITE OPERATIONS WITH THE POTENTIAL FOR DUST CREATION ................................................................. 5

2.1 GENERAL SITE PROCEDURES ........................................................................................................ 5 2.2 VEHICLES, PLANT AND EQUIPMENT ............................................................................................... 5 2.3 OVERVIEW OF WASTE PROCESSING ACTIVITIES CONTROLS .................................................................. 6 2.4 EMISSIONS CONTROLS ................................................................................................................ 6

3 DUST MANAGEMENT & CONTROL MEASURES ......................................................................................... 7

3.1 RESPONSIBILITY FOR IMPLEMENTATION OF THE DMP ...................................................................... 7 3.2 CONTROL MEASURES (STAFF TRAINING/DAILY INSPECTIONS) ............................................................. 7 3.3 CONTROL MEASURES (BOUNDARY FENCING/CONTAINMENT) ............................................................. 8 3.4 CONTROL MEASURES - SITE SURFACING /DRAINAGE ......................................................................... 8 3.5 CONTROL MEASURES - WATER SUPPLY ........................................................................................... 8 3.6 CONTROL MEASURES – SITE SURFACES AND VEHICLE MOVEMENTS ...................................................... 9 3.7 CONTROL MEASURES – STORAGE OF WASTE ................................................................................... 9 3.8 CONTROL MEASURES - LOADING AND UNLOADING VEHICLES ............................................................ 10

4 DUST MANAGEMENT RISK ASSESSMENT MODEL .................................................................................... 11

4.1 FUNDAMENTAL CONSIDERATIONS ............................................................................................... 11 4.2 PATHWAY ............................................................................................................................. 11 4.3 CONSEQUENCES ..................................................................................................................... 12 4.4 EFFECTS OF CONSEQUENCES ...................................................................................................... 12 4.5 RISK ESTIMATION AND EVALUATION (PROBABILITY/FREQUENCY OF OCCURRENCE OF HAZARD) ................ 13 4.6 RISK ASSESSMENT OUTCOME (COMBINATION OF PROBABILITY & CONSEQUENCE) ................................. 13 4.7 RISK ASSESSMENT TABLE........................................................................................................... 14

5 MONITORING AND RECORDING .............................................................................................................. 15

5.1 VISUAL ASSESSMENT ................................................................................................................ 15 5.2 MONITORING ........................................................................................................................ 15

6 EMERGENCY & CONTINGENCY PROCEDURES .......................................................................................... 17

6.1 STAFF SHORTAGES ................................................................................................................... 17 6.2 WEATHER CONDITIONS ............................................................................................................ 17 6.3 OPERATIONAL FAILURE ............................................................................................................. 18

7 COMPLAINTS AND RESPONSIBILITIES ...................................................................................................... 19

7.1 COMPLAINTS PROCEDURE ......................................................................................................... 19


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7.2 KEY RESPONSIBILITIES .............................................................................................................. 19


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List of Tables

Table 1.1 – Distances to Selected, Representative Sensitive Locations ................................................................... 3 Table 1.2 – Other Dust/Particulate Emitting Operators ........................................................................................... 4 Table 2.1 - Plant & Equipment .................................................................................................................................. 5 Table 4.1 - Consequences ....................................................................................................................................... 12 Table 4.2 -Potential effects ..................................................................................................................................... 12 Table 4.3 -Likelihood ............................................................................................................................................... 13 Table 4.4 - Risk assessment outcome ..................................................................................................................... 13


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List of Appendices:

Appendix I - Drawings

Drawing No. 4034/1906/03 – Proposed Layout Plan

Drawing No. 4034/1906/04 – Sensitive Receptors Plan

Appendix II - Complaints Recording Form


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1 Introduction

1.1 Site history / background

Oaktree Environmental Ltd have been instructed by Pyrite Industries Ltd to prepare a Dust

Management Plan (DMP) for their proposed tyre recycling facility.

1.1.1 The purpose of this DMP will allow Weybridge Skip Hire Ltd to implement an action plan

should site operatives detect a dust presence or receive complaints from third parties.

1.1.2 Guidance has been sought from the Institute of Air Quality Management (IAQM document

“Guidance on the Assessment of Mineral Dust Impacts for Planning” dated May 2016

(v1.1) in preparing this DMP.

1.2 Site location

1.2.1 The application site is located within the larger Squires Farm Industrial Estate, Palehouse

Common. The Industrial Estate is within a rural location although it is situated approximately

3 miles to the south east of central Uckfield. The Estate is accessed via a concrete road

leading from Palehouse Common Road, an unclassified road which adjoins the B2192

approximately 300 metres to the east. The B2192 connects to the A22 some 1.5 miles to the

south.

1.2.2 The nearest residential property is approximately 150-175 metres to the west of the site

and comprises Tewitts Farm. Residential cottages are also situated approximately 300

metres west of the site on Pump Lane, (as well as adjacent to the B2192 approximately 350

metres to the east of the site. A further residential property is some 320 metres to the

south of the site across two open fields and Palehouse Common Road.

1.2.3 The site is not located within a designated Air Quality Management Area (AQMA). The

nearest AQMA is situated over 1,000m from the site and given the small number vehicle

movements associated with the site, it is not anticipated that air quality in terms of NOx or

PM10 will be affected by this development.


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1.3 Facility overview

1.3.1 The site will operate in accordance with a SR2015No6 Environmental Permit (EP) which

will be issued by the Environment Agency (EA).

1.3.2 The main treatment processes which will be carried out on site will include the following:

• Manual sorting/separation by hand

• Shredding (by using appropriate mechanical shredding plant and equipment)

• Baling (by using appropriate mechanical baling plant and equipment)

• Separation (by using appropriate mechanical plant and equipment)

• Magnetic separation of ferrous metals (overband magnet)

1.3.3 The waste types handled on site will consist of dry, inert and non-hazardous household,

commercial and industrial waste arising from activities within the surrounding area. This is

as defined in the Controlled Waste (England and Wales) Regulations 2012 and Section 75

of the Environmental Protection Act 1990 and will consist of end-of-life tyres and rubber.

1.4 Site management

1.4.1 The site will be assigned a Technically Competent Manager (TCM) who will be responsible

for the general management of the site including the acceptance and handling of any

potentially dust-forming wastes.

1.4.2 The company, through the TCM, will ensure that a nominated deputy is sufficiently trained

and be familiar with all site management documentation (which includes this DMP) in

addition to all relevant company procedures who, in the absence of the TCM, will act the

competent person.


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1.5 Sensitive receptor locations

1.5.1 The sensitive receptors in proximity to the site are shown on Drawing No. 4034/1906/04.

Table 1.1 details the receptors which are most likely to be at risk in terms of dust; however,

for a comprehensive list of receptors, reference should be made to the sensitive receptors

plan in Appendix I.

Table 1.1 – Distances to Selected, Representative Sensitive Locations

Boundary Receptor

Approximate distance from site boundary (m)

West Tewitts Farm (residential) 105

South-west Residential properties off Palehouse Common 235

East / North-east Residential properties off the B2192 250 - 400 South-east Residential properties off the B2192 400 - 500

North-west Residential properties off Pump Lane 230 - 450

North-west Others uses of the industrial estate 25 - 250

1.5.2 Other receptors not listed are clearly shown on Drawing No. 4034/1906/04.


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1.5.3 Other dust/particulate emitting operators are tabulated below in Table 1.2.

Table 1.2 – Other Dust/Particulate Emitting Operators

Company Address Type of Business Approximate distance from site boundary (m)

Gb Metals Recycling Sussex Ltd

Unit 1, Squires Farm, Industrial Estate, TN22 5RB

Scrap metal facility 180 / North-east

Holley Ltd Squires Farm, Industrial Estate, TN22 5RB

Wood processing facility

180 / North-east

Allied waste management

Unit 8 Knights Business Centre, Squires Farm Ind Est, Framfield, Uckfield, East Sussex, TN22 5RB

Asbestos waste transfer facility

Adjacent / west

Other industrial estate uses

Squires Farm, Industrial Estate

Various industrial, manufacturing processes

Various


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2 Site operations with the potential for dust creation

2.1 General site procedures

2.1.1 The full procedures with regards to checking & inspection of loads, preliminary procedures,

waste acceptance etc. are discussed in Section 6 of the Planning, Design & Access Statement

(PDAS).

2.1.2 In general; waste will arrive at the site using Pyrite Industries Ltd’s own vehicles/contracts

whose details would be checked prior to the delivery/collection of waste. The waste will be

subject to the rigorous checking and waste acceptance procedures prior to being deposited

and stored in the relevant areas on site.

2.2 Vehicles, plant and equipment

2.2.1 Waste will be handled using the plant listed in Table 2.1 below. Only trained operators will

be permitted to drive/operate the plant listed below. Any changes to the list will be notified

to the Environment Agency prior to implementation. The minimum requirements when the

site is operational are shown in bold italic print.

Table 2.1 - Plant & Equipment

Item Number Function

Tyre shredder [Eldan Super Chopper 1412 (SC1412/160)]

1 Shredding of tyres

Tyre granulator (EldanHR162TRasper) 1 Granulation of tyres Tyre baler (Gradeall Mark 2) 1 Baling of tyres Mobile tyre colouring unit 1 Colouring of tyres for certain

specifications Forklift truck 1 - 2 Manoeuvring/loading of tyres

around or on/off the site 2.2.2 Should additional plant/equipment be required which could pose a further dust nuisance,

the control measures associated with similar plant already onsite (risk assessment within

section 2.0 and the control measures within 4.0) will apply.


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2.3 Overview of waste processing activities controls

2.3.1 Reference should be made to the Proposed Site Layout; Drawing No. 4034/1906/03

situated in Appendix I of this DMP which illustrates how the waste will be treated following

deposit to the site. Based on this, the next section details the likely sources of dust which

could arise from the site.

2.4 Emissions controls

2.4.1 The main sources of dust and particular matter to arise from the site are as follows:

i) Unsheeted vehicles accessing/egressing to/from the site

ii) Unloading of waste deliveries into the waste reception area

iii) Loading of waste into mechanical treatment plant

iv) The shredding process during treatment

v) Mechanical treatment process (discharge points etc.)

vi) The baling process

vii) Transporting / loading of waste around the site

2.4.2 Other sources could be linked to prolonged periods of dry/warm or windy weather

conditions.


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3 Dust Management & Control Measures

3.1 Responsibility for implementation of the DMP

3.1.1 The site manager, site foreman and TCM (site management) will be responsible for the

implementation of the DMP. Deputy site managers, senior plant operatives will also be

identified in order to support the site manager.

3.1.2 Site management will ensure the DMP is reviewed annually or sooner in the event of

complaints/dust issues; whichever is the soonest, with any amendments or alterations put

in place as soon as reasonably possible.

3.1.3 The above staff with the aid of Oaktree Environmental Ltd (if required) will be responsible

in providing training to relevant operational staff to ensure they are deemed competent and

understand the contents of this DMP. Staff will undergo re-fresher every 12 months or in

the event of a dust complaint / issue or the implementation operational changes. If deemed

necessary, a suitable Dust/Air Monitoring Consultant may be contacted to train staff

regarding third party monitoring i.e. Ambient Air Monitoring.

3.1.4 The following control measures listed in Sections 3.2 – 3.8 detail the proposed measures the

site will have to minimise dust emissions and procedures in place during all site operations

i.e. day to day.

3.2 Control Measures (staff training/daily inspections)

3.2.1 Good housekeeping and site practices are vital to ensure that the impacts from fugitive dust

impacts are controlled. The site will undertake dust monitoring inspections throughout the

day for the presence of dust with corrective actions taking place upon discovery.

Operational staff will be suitably trained in procedures to keep the levels of dust to a

minimum including prevention and mitigation. The inspections will be once a day minimum

and more frequent during dry/windy weather conditions or less during damp weather

conditions. The inspections points may vary on site so are not included on the Proposed

Layout Plan.


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3.3 Control measures (boundary fencing/containment)

3.3.1 The site benefits from 2m high wooden fencing to the west and there are a number of

mature trees on other perimeters of the site which act as a further boundary.

3.4 Control measures - site surfacing /drainage

3.4.1 All areas which store and process the waste and product will benefit from a concrete

hardstanding surface and as the site surface will reduce the risk of airborne debris such as

fugitive emissions, mud, stones being tracked around areas of the site from vehicle chassis.

3.4.2 The concrete area is relatively flat and any defects such as cracks, rivets will be repaired as

soon as practically possible to ensure the site can be swept by hiring in a road-sweeper or

similar.

3.5 Control measures - water supply

3.5.1 A permanent water supply will be available on site 24/7 to ensure the dust suppression

systems can function effectively. All external water pipes will be lagged to prevent frost

damage during winter months and the operator will subscribe to the Met Office in the event

of a drought being imminent. This will enable the operator to source water and store in

tanks prior to a potential water ban.

3.5.2 The supply and drainage of the water is provided from the sewerage undertaker who can

be contacted in the event of low water pressure to ensure the issue is rectified so

suppression techniques are not compromised.

3.5.3 If additional suppression is required following increased dust nuisance from daily

inspections or third complaints received, the applicant will contact a suitable Air/Dust

Monitoring Consultant to install a suppression system around the site. Given the waste is

stored and processed externally the site will deploy suppression techniques to the areas

shown on 4034/1906/03 (processing areas) which will consist of a series of water sprays

connecting to the water supply which will be in use during dry, windy weather conditions to

stop any fugitive emissions escaping the site boundary.


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3.6 Control Measures – site surfaces and vehicle movements

3.6.1 The control measures implemented by site management to minimise the risk of dust and

debris emissions from dusty site surfaces and vehicle movements include:

• All site surfaces used for the tracking and running of vehicles and/or plant and all

stockpiles of wastes which have the potential to be dust-forming will be swept manually

be operational staff during the morning and pre-end of shift, six days per week to

minimise fines, dust & debris. If this is not considered suitable, the applicant may look

to hire in a road sweeper during extreme dry weather conditions lasting for over 24

hours.

• Vehicle speed on will be restricted to 5 miles per hour. Signs will be erected at the

relevant areas of the site, including the main access gates, to advise drivers of the speed

limit. This will reduce the re-suspension of dust and particulate matter.

• All vehicles will be checked before they leave the site to ensure no mud/dust can stretch

beyond the site access. All incoming/outgoing vehicle loads will be sheeted.

• Any mud/dust deposited onto the public highway or industrial estate road will be

treated as an emergency and cleaned by operatives or by way of a road sweeper which

would be hired-in as necessary.

3.7 Control Measures – storage of waste

3.7.1 The control measures implemented by site management to minimise the risk of dust and

debris emissions from the continuing storage of wastes and the loading/unloading of these

include:

• Other than the waste reception area which will consist of stacked tyres, all other

waste/product will be stored in tonne bags and contained.

• Prior to loading into the treatment plant, tyres will be washed / sprayed using a hose or

dipped into a container of water to remove any mud/dust from the tyre; this also ensure

the shredding is more effective.


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• If required stockpiles can be sprayed with water during >24 hour periods of dry/windy

weather to prevent excessive drying and dust formation.

• As standard, the removal of material from stockpiles will be carried out from the most

sheltered location adjacent to the containment wall. If necessary, stockpiles will be pre-

wetted and sprayed during loading operations.

• Drop heights from conveyor points will be kept to a minimum to prevent dust emissions

where adjustment permit; these points will also benefit from a water spray system.

3.8 Control measures - Loading and unloading vehicles

3.8.1 All loading and unloading of waste will be done by forklift truck and it is considered that this

will not lead to any dust formation. Furthermore, the waste being loaded will not be ‘dusty’

in nature.


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4 DUST MANAGEMENT RISK ASSESSMENT MODEL

4.1 Fundamental considerations

4.1.1 Source/Hazard: A property or situation that in particular circumstances could lead to harm.

4.1.2 Consequences: The adverse effects or harm as the result of realising a hazard which causes

the quality of human health or the environment to be impaired in the short or long term.

4.1.3 Risk: A combination of the probability of occurrence of a defined hazard and the magnitude

of the consequences of the occurrence.

4.2 Pathway

4.2.1 Important in the assessment of a particular risk(s) and to inform the subsequent

management of the risk(s) is the identification of the pathway(s) through which the risk may

affect the identified receptor(s). The following are examples of pathways:

• Air

• Ground

• Water

• Direct contact / exposure


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4.3 Consequences

4.3.1 The following table highlights the consequences of the hazard(s) identified and the

abbreviations for each as used in the Risk Assessment Table in Section 3:

Table 4.1 - Consequences

Abbreviation Consequences

A MINOR INJURY B MAJOR INJURY C DEATH D AIR POLLUTION E WATER POLLUTION F POLLUTION OF LAND

4.4 Effects of consequences

4.4.1 In order to quantify the level of risk and identify the appropriate management procedures,

the potential effects must be considered, as outlined in the table below:

Table 4.2 -Potential effects

Abbreviation Effect of Consequences Management Required?

S SEVERE In all cases Mo MODERATE In most cases Mi MILD Occasionally N NEGLIGIBLE No

4.4.2 Note: “Management” is the action required to reduce the risk of a hazard causing a problem

on site. Contingency measures are procedures which are in place to reduce the

consequences of a hazard.


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4.5 Risk estimation and evaluation (probability/frequency of occurrence of hazard)

4.5.1 The following table allows the likelihood of an occurrence of an identified risk to be

assessed:

Table 4.3 -Likelihood

Probability Evaluation

1 Very likely Could occur during any working day 2 Likely Could occur regularly 3 Possible Event possible 4 Unlikely Event very unlikely

4.6 Risk assessment outcome (combination of probability & consequence)

4.6.1 The following table shows the resultant risk of an identified hazard or potential situation.

This uses the hierarchy of both probability and consequence to assess the level of risk. The

level of risk determines what level of management would be required in order to reduce

the risk of occurrence and/or scale.

Table 4.4 - Risk assessment outcome

Consequence

S Mo Mi N

Prob

abili

ty 1 High High Medium Low

2 High Medium Low Near-Zero

3 Medium Low Near-Zero N/A

4 Low Near-Zero N/A N/A

4.6.2 Where the risk assessment outcome is high, first-level management of the risk is essential,

i.e. removal of hazard, implementation of major infrastructure/structural design measures

to contain the risk/hazard and company policy changes to incorporate the management of

the risk. All risk management measures must be supplemented with detailed induction

training, spot training and tool-box talks to ensure all site staff and users are made fully

aware of the risk/hazard, all potential consequences and necessary management and

contingency procedures.


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4.6.3 Where the risk assessment outcome is medium, the management of the risk should be

tackled by management or delegates. If removal of the hazard is not possible, management

will normally be met through implementing minor structural design measures or by

imposing procedures for the prevention of occurrences which will be conveyed to all site

staff through the appropriate training, including any contingency measures/procedures.

4.6.4 Where the risk assessment outcome is low, the management of the risk can be done wholly

through appropriate training to site staff including any contingency measures/procedures.

4.6.5 Where the risk assessment outcome is near-zero, site staff should be made aware of the

possibility of an occurrence and contingency measures should be readily available to all staff

should they be required.

4.7 Risk assessment table

4.7.1 The following pages contain the site-specific risk assessment for the site with appropriate

remedial actions, recommendations and comments included for each identified hazard,

potential contaminant or situation.

4.7.2 The table also contains references to the appropriate section(s) of the site’s EMS for

additional management procedures.

4.7.3 As discussed in the section above, all situations which identify a risk from Low –High should

be incorporated into the staff/visitor training schedule, where appropriate and acted on as

required.

4.7.4 The table overleaf details the relevant pathways and receptors for each individual

dust/emission source and relevant measures required to break these linkages. The control

measures outlined in Section 4 will be included within these tables as well as additional

specific measures.


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Hazard / Potential Contaminant or Situation

Source(s)

Pathway Receptor(s) Consequences

Effect Probability Assessment Outcome

Remedial Action/ Recommendations/ Comments

Assessment Outcome following actions / recommendations

Dust / Particulates

Unsheeted vehicles accessing/ egressing to/from the site

Air As detailed on Sensitive Receptors Plan Site personnel / visitors

Air Pollution Inhalation/ Embedment of dust

Moderate 3 Medium Management will ensure that all site vehicles are adequately sheeted before accessing and leaving the site. If third parties deliver waste to , they will be advised prior to delivery that loads must be sheeted. The management will attempt to ensure deliveries will be spread out evenly throughout the day. A maximum speed limit of 5mph will be maintained. Any mud/dust deposited onto the public highway will be treated as an emergency and cleaned by operatives or by way of a road sweeper which would be hired-in should management observe significant dust build up or generation along the access road.

Low

Dust / Particulates

Vehicles tipping waste deliveries into the waste reception area



Moderate 2 Medium All waste will be manually deposited by hand or forklift truck into the reception area and stacked appropriately. There will be a water supply to spray or wash any tyres which contain large amounts of dust forming properties i.e. mud.

Low

Dust / Particulates

Loading of waste into treatment plant



Moderate 2 Low The loading will be done by hand or forklift and waste is not considered to be ‘dusty’ in nature. Waste loaded into the plant will be pre- sprayed/dowsed prior to loading.

Low

Dust / Particulates

Transporting waste/product around the site



Moderate 2 Low The loading will be done by hand or forklift and waste is not considered to be ‘dusty’ in nature. All product will be kept in tonne bags ensuring the material is contained.

Low


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Hazard / Potential Contaminant or Situation

Source(s)

Pathway Receptor(s) Consequences

Effect Probability Assessment Outcome

Remedial Action/ Recommendations/ Comments

Assessment Outcome following actions / recommendations

Dust / Particulates

Mechanical treatment plant



Moderate 2 Medium Prior to treatment process, the tyres will be have been dampened down to remove any dust forming properties i.e. mud. The shredders are enclosed and will benefit from water sprays which connect to the water supply providing a constant suppression aid throughout the day. Conveyors will be enclosed using tarpaulin to reduce the risk of crumb being blown off the treatment plant. The discharged material along the conveyors will directly feed into a bagging area to which will reduce the risk of tyre crumb being tracked throughout the site. The baling process will only be in use if the plant is not operational and all tyres prior to baling will be dampened down. The baler is also enclosed and material after baling will not create and dust

Low

Dust / particulates

Prolonged periods of dry/warm or windy weather conditions

Air As detailed on Sensitive Receptors Plan

Site personnel / visitors


Mo 2 Medium Site management will carry out the wetting down/suppression/ of all onsite storage areas and vehicle surfaces. The processing and tipping/loading/unloading of waste will cease until conditions have been improved if noted that dust is escaping beyond the site boundary. The site manager is responsible for ensuring this. Additional visual assessment / monitoring will be onsite and undertaken around the site perimeter in order to ensure dust is not migrating offsite. Receive regular updates from the Met Office to prepare for any potential dry/windy weather conditions in advance.

Low


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5 Monitoring and Recording

5.1 Visual assessment

5.1.1 Site management which will consist of the technically competent manager site manager or

site foreman will make a visual inspection of dust emissions around the entire site perimeter

at least twice daily. Additional monitoring may be carried out during times of severe

dry/windy weather conditions or should operatives observe significant levels of dust. The

monitoring will be carried at intervals out while the site is operational, should it be observed

that dust is being emitted from the site, notes will made as to; the amount.

5.1.2 The results of monitoring exercises and any remedial action taken will be entered into the

log book which is available for East Sussex County Council to inspect upon request. The

name of the site management will be stated in the site’s diary / inspection form for each

day of operation.

5.1.3 Should the monitoring conclude that a certain activity is giving rise to dust which is migrating

offsite, then the contingencies shown in Section 6 below will take place to reduce the

impact.

5.1.4 The site manager will be suitably trained to carry out these duties. Further information

regarding training and technical competence is provided within the site’s EMS.

5.2 Monitoring

5.2.1 Operational staff will continuously visually monitor dust emissions whilst the site is in

operation and will aim to prevent dust emissions using the procedures listed above, asking

the site management for advice as required. Work procedures will be stopped/adjusted

should it be evident significant dust is being emitted which has the potential to migrate

offsite.

5.2.2 Operational staff will also be required to make a note of any unavoidable events such as bad

weather in the site diary, rather than just actual complaints received. This will ensure that

if complaints are received retrospectively from either East Sussex County Council or directly,


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any circumstances which led to that complaint as a result of elements outside of the

operator’s control would be able to be attributed (or, at least, in part) to the cause of the

complaint.

5.2.3 Due to the location of the site, its surrounds and the likely existing air quality, it is deemed

that PM10 monitoring equipment is not required at the proposed development.


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6 Emergency & Contingency Procedures

6.1 Staff shortages

6.1.1 In the event of unforeseen staff shortages arising from illness, suspension or no shows, the

operator will make a judgement whether to reduce the number of incoming loads, thus

reducing processing frequency and divert material to an alternative site. The operator will

then seek further employment within a timely manner to ensure the site can continue to

operate at its required capacity.

6.2 Weather conditions

6.2.1 The site will regular updates from the Met Office in terms weather alerts for the following

weather conditions which could cause a potential on or off-site dust complaint:

i) High winds >30mph

ii) Droughts or periods of hot weather exceeding 3 major dry days which could lead

to water shortages, hosepipe bans and excessive dust.

6.2.2 The site will install the following preventative measures to avoid serious dust pollution:

HIGH WINDS

• There will be no sorting, processing or treatment of any wastes which are likely to be

blown around during conditions of high winds; high winds would be where it is evident

where dust is escaping beyond the site.

• Vehicles leaving the site will be sheeted to comply with the requirements of the Duty of

Care legislation.

• Storage of loose waste/material will be reduced to a suitable height to prevent the

material escaping beyond the site boundary i.e. below the heights of boundary walls.

• Stockpiles may be covered with tarpaulin in the event the above procedures are not

considered effective.


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• In the event of extreme winds, the site will deploy the above measures and may be

forced to close operations until conditions have improved.

DROUGHTS/WARM, DRY WEATHER

• In extreme cases such as a hosepipe ban or water shortage, the site will ensure there is

additional water available i.e. tanks/containers prior to the ban.

• The site will contact the water company in the event of an emergency to see if the water

pressure can be increased.

• If the above measures are not suitable, the site will look at further measures such as

additional fencing or dust netting in agreement with East Sussex County Council

• Where dust is becoming a major concern then the operator will stop processing the

material and cover the piles using tarpaulin until conditions or dust suppression

techniques are considered effective.

6.3 Operational failure

6.3.1 The manager will be contacted by staff in the event of any operational failure such as the

breakdown of plant, systems or equipment and will decide whether operations are to

continue or be suspended prior to corrective action being taken. Serious operational

failures, which result in the closure of the site, will be recorded in the site diary.


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7 Complaints and Responsibilities

7.1 Complaints procedure

7.1.1 If any dust complaints are received, the complaint will be assigned to an operative familiar

with the sites operation who will complete a 'complaints and events log' and detailed

individually on the complaints form (in Appendix II), both of which will be kept for inspection

on request by the LA and/or EA. Details of information to be completed are dates, nature of

complaint, weather conditions at the time of the complaint, investigation details, action

taken and a signature (as a minimum). Complaints will be investigated and responded to

within 3 working days.

7.1.2 The operator would also be required to make a note of any unavoidable events

plant/equipment malfunctions in the site diary, rather than just actual complaints received.

This will ensure that if complaints are received retrospectively from either the Council/EA

or directly, any circumstances which led to that complaint as a result of elements outside of

the operator’s control would be able to be attributed to the cause of the complaint.

7.1.3 The applicant will regularly liaise with the LPA and other relevant interested parties

(typically by email on a quarterly basis or following a complaint) regarding the dust

mitigation measures implemented and their effectives.

7.2 Key responsibilities

7.2.1 The table below outlines the key responsibilities and the staff member responsible for each

task.

Task Staff position responsible Dust monitoring and ongoing assessment Site manager + assistant

Access road maintenance Specialist contractor Vehicle maintenance Specialist contractor

Overseeing of deliveries Site manager + assistant


Appendix I

Appendix I

Drawings

(c) Copyright Oaktree Environmental Ltd

Reproduced with the permission of the controller of H.M.S.O. Crown copyright licence No. 100015148

Key:

Application boundary

Waste storage areas

Non waste storage areas

Concreted areas

Other buildings (offices, etc.)

Stone / hardcore surface (free draining)

Tree canopies (indicative)

Surface water drainage (clean)

Sealed drain/kerb

Surface drainage fall direction

Foul drainage fall direction

Surface gully

Manholes

Oaktree Environmental LtdPlanning, Waste Management

and Environmental Consultants

Lime House, 2 Road Two

Winsford Industrial Estate

Winsford, Cheshire CW7 3QZ

Tel: 01606 558833

E-mail: [email protected]

NOTES:

1. Drawing is for indication only.2. All measurements must be verified on site.

Tyrereception

area

Primary tyreshredder - 3.5m high

with water sprays

Conveyor; feed = 0.3mabove shredder

Tyre baler (2.0m highworking chamber)

Generator forplant feed

Site access /egress

Storage of PAS 107 /108 tyres in bags

(product - non-waste)

PAS 107 (shred)colouring area

Existing 2.5m closeboard wooden fence

Mature treeboundary

G3 Tree boundary(see arboricultural

report)


Existing 2m steelmesh fencing



Staff/visitor parking(5 no. spaces)

Secondary tyre shredder(granulator) - 3.0m high

with water sprays

Bagging area(ground level)

Tyre storageprior to baling

Proposed portable(modular) cabin foroffice and welfare

(2m high)

Conveyor;outfeed = 0.3m

below granulator

Proposed common ivy(Hedera helix) planting toexisting fence on southern

boundary fence


Staff/visitor parking(3 no. spaces)


report)


report)

English Oak (tobe protected)

10.8m rootprotection area

Proposed 1.0m postand wire fence

Proposed underground110mm diameter

drainage pipe

Connection with Ind.Est surface waterdrainage system

Proposed sealed sump(underground tank)

Title:

Drawing No:

Site:

Date:

Scale:

Printed At:

Job No: Drawn By: Checked:

4034/1906/03

PROPOSED LAYOUT PLAN

22 May 2019 A3

CP4034

Client:

1:200

Revision:C

--Client No:

1906

Yard at Knights Business Centre, Squires FarmInd. Est., Palehouse Common, Fairfield, UckfieldTN22 5RB


Revision Details:Rev: Init: Description: Date:

- CP Initial drawing 01/02/19A CP Client comments 13/02/19B CP LPA comments 27/02/19C CP Amended re. consultation

responses22/05/19

0 m 1 0 m 2 0 m

S c a l e B a r ( 1 : 2 0 0 )

AutoCAD SHX Text

1

AutoCAD SHX Text

3

AutoCAD SHX Text

5

AutoCAD SHX Text

7

AutoCAD SHX Text

8

Oaktree Environmental LtdWaste Management and

Environmental Consultants

Lime House, 2 Road Two

Winsford Industrial Estate

Winsford, Cheshire CW7 3QZ

Tel: 01606 558833

E-mail: [email protected]

Title:

Drawing No:

Site:

Date:

Scale:

Printed At:

Revision:

Job No: Checked:

RECEPTOR PLAN

4034/1906/04

22 May 2019 A3

4034

-

Revision Details:Rev: Description: Date:

Client:

1:10,000

- Initial drawing 22/05/19

Drawn By:CP

Client No:1906

Notes:

(1) Boundaries are shown indicatively.(2) Wind rose data shows the prevailing

wind direction to be SW.

--

0 m 500 m

Scale Bar (1:10,000)

100 200 300 400

Compass Wind Rose for London/Gatwick (EGKK)Period 2010-2019

KEY:

Permit boundary

Watercourse i.e. ditch, stream, river

Watercourse i.e. pond, lake etc.

Workplaces (includes agriculture industry, commerce and retail)

Industrial/commerical properties within 400mof the site

Residential receptors

Class B, C Roads

Railway line

Wooded areas

Public footpath

Possible location ofgreat crested newts

200m

400m

600m

800m

1,000m

Yard at Knights Business Centre,Squires Farm Ind. Est., PalehouseCommon, Fairfield, Uckfield TN22 5RB



Appendix II

Appendix II

Complaints and Events Log


Appendix V

COMPLAINTS PROCEDURE

1. Any complaints received in relation to noise, odour or dust will be recorded on the form

below. This form will normally be completed, signed and dated by the site operator, if they

are not available, the Office Manager will complete the form.

2. The name, address and telephone number of the caller will be requested.

3. Each complaint will be given a reference number.

4. The caller will be asked to give details of:

• the nature of the complaint;

• the time;

• how long it lasted;

• how often it occurs;

• is this the first time the problem has been noticed; and,

• what prompted them to complain.

5. The person completing the form will then, if possible, make a note of :

• the weather conditions at the time of the problem (rain snow fog etc.)

• strength and direction of the wind; and,

• the activity on the installation at the time the noise, dust or odour was detected,

particularly anything unusual.

6. The reason for the complaint will be investigated and a note of the findings added to the

report.

7. The caller will then be contacted with an explanation of the source of the complaint if

identified and the action taken to prevent a recurrence of the problem in future.

8. If the caller is unhappy about the outcome or unwilling to identify themselves the caller will

be referred to the appropriate department of East Sussex County Council.

9. Following any complaint the complaints procedure will be reviewed to see if any changes are

required or if new procedures need to be put in place.


Appendix V

Complaints Report Form

Date Recorded Reference Number Name and address of caller

Telephone number of caller

Time and Date of call

Nature of complaint (noise, odour, dust, other) (date, time, duration)

Weather at the time of complaint (rain, snow, fog, etc.)

Wind (strength, direction from wind sentry and anemometer)

Any other complaints relating to this report

Any other relevant information

Potential reasons for complaint

The operations being carried out on site at the time of the complaint

Follow Up Actions taken

Date of call back to complainant Summary of call back conversation

Recommendations Change in procedures

Changes to Written Management System

Date changes implemented

Form completed by

Signed

Date completed

Dust Management Plan - apps.eastsussex.gov.uk

Documents