HALTON GROUP. Keighley Clean Energy Facility, Airevalley Road, Keighley. Environmental Statement. Non Technical Summary

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1 , Airevalley Road, Keighley Environmental Statement Non Technical Summary

2 Wardell Armstrong Sir Henry Doulton House, Forge Lane, Etruria, Stoke-on-Trent, ST1 5BD, United Kingdom Telephone: +44 (0) Facsimile: +44 (0) DATE ISSUED: JOB NUMBER: SH11087 REPORT NUMBER: 02 HALTON GROUP, Airevalley Road, Keighley Environmental Statement Non-Technical Summary This report has been prepared by Wardell Armstrong LLP with all reasonable skill, care and diligence, within the terms of the Contract with the Client. The report is confidential to the Client and Wardell Armstrong LLP accept no responsibility of whatever nature to third parties to whom this report may be made known. No part of this document may be reproduced without the prior written approval of Wardell Armstrong LLP. Wardell Armstrong is the trading name of Wardell Armstrong LLP, Registered in England No. OC Registered office: Sir Henry Doulton House, Forge Lane, Etruria, Stoke-on-Trent, ST1 5BD, United Kingdom UK Offices: Stoke-on-Trent, Birmingham, Cardiff, Carlisle, Edinburgh, Greater Manchester, London, Newcastle upon Tyne, Penryn, Sheffield, Truro, West Bromwich. International Offices: Almaty, Moscow ENERGY AND CLIMATE CHANGE ENVIRONMENT AND SUSTAINABILITY INFRASTRUCTURE AND UTILITIES LAND AND PROPERTY MINING AND MINERAL PROCESSING MINERAL ESTATES AND QUARRYING WASTE RESOURCE MANAGEMENT

3 CONTENTS 1 Introduction EIA Approach and Scope of Assessment Site Location The Proposed Development Environmental Impact Prediction, Evaluation and Mitigation Summary and Conclusions Page 3

4 1 INTRODUCTION 1.1 Purpose of this Non-Technical Summary This Non-Technical Summary (NTS) presents (in non-technical language) the findings of a detailed Environmental Impact Assessment (EIA) undertaken in connection with the proposed development of a Clean Energy Facility on land south of the A650 (Airevalley Road), Keighley. A planning application has been submitted to the City of Bradford Metropolitan District Council (BMDC) This NTS has been prepared by Wardell Armstrong LLP on behalf of Halton Group (the Applicant ). The full report known as the Environmental Statement (ES) has been submitted with the planning application. The ES has been prepared with full regard to the requirements of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 and other relevant guidance This NTS provides a brief site description, a detailed discussion of the proposed scheme and then presents the assessment findings for each technical section of the ES, in non-technical language. Anyone with interest in exploring specific technical assessment findings can refer to the main ES. 1.2 Introduction The site is vacant brownfield land located approximately 3km from Keighley town centre and 12km from the city centre of Bradford The site covers approximately 3.5 hectares of vacant brownfield land. Remediation of the site was completed in 2005 to allow re-development for a commercial / industrial use, following the site s historical use as a Gasworks The site is located within land allocated in the Bradford Metropolitan District Council (BMDC) replacement Unitary Development Plan (UDP) as employment land. The current proposals will target a zero waste to landfill policy, in line with the BMDC s proposed zero waste approach and associated regeneration of the site The facility will use multiple fuel sources from commercial and industrial waste, which will be sourced and produced locally. The proposal consists of three energy recovery technologies, including, Refuse Derived Fuel (RDF) power plant, tyre crumb melting and waste plastic melting. The energy generated by the facility will be distributed into the electricity network. There is also the potential for the heat to be used offsite. Page 4

5 2 EIA APPROACH AND SCOPE OF ASSESSMENT An Environmental Impact Assessment (EIA) was deemed necessary in accordance with the Town and Country Planning (Environmental Impact Assessment) Regulations The EIA has been produced in accordance with the most up to date Government guidance: Environmental Impact Assessment: A Guide to Good Practice and Procedure A Consultation Paper (LCLG, June 2006); and Circular 02/99 Environmental Impact Assessment The request for a Scoping Opinion which was submitted to BMDC in on 30 May The following organisations and bodies were contacted during the stakeholder consultation period: City of Bradford Metropolitan District Council; The Environment Agency; Natural England; English Heritage; West Yorkshire Archaeology; Yorkshire Water; WY Fire Service; NATS; Childrens Services; Police Architectural Officer; Northern Gas Networks; National Grid; Network Rail. Page 5

6 2.1.4 Following the Scoping Opinion from BMDC dated 16 July 2013, the scope of the EIA was refined. It was decided that the following topic areas would need to be considered in the ES: Archaeology and Cultural Heritage; Landscape and Visual Impact; Geology, Ground Conditions and Potential Contamination; Ecology and Nature Conservation; Hydrology, Drainage and Flood Risk; Noise; Air Quality; Traffic and Transport; Climate Change; and Assessment of Amenity The scope of the EIA gave due consideration of public consultation responses, technical recommendations, and any other considerations that came to light during the process On the basis of the above considerations the Halton Group commissioned Wardell Armstrong LLP to undertake the following tasks: Carry out baseline studies; Identify potential impacts which may arise as a result of the proposed development with regard to the topic areas; Assess the potential impacts (by quantitative means where appropriate and practicable) to give an indication of their magnitude and significance; Advise on appropriate mitigation measures which would either eliminate or reduce any adverse effects to minimum practicable levels; and Identify and assess and residual long-term impacts. 2.2 Significance Criteria The criteria for the assessment of significance has been selected and applied in accordance with published guidance specific to the individual topic areas covered in the technical assessments. Such guidance represents the industry standard method Page 6

7 for assessing potential impacts and is consistent with EIA best practice. The published guidance used in the undertaking of the assessments is referenced in each technical chapter. Where published guidance or criteria is not available the chosen method for assessing impacts and their significance is explained in detail to ensure transparency Where significant impacts have been identified, mitigation measures have been recommended to avoid, reduce or remedy such impacts. These have involved alterations to the basic design or operation of the development or the introduction of specific safeguards to ameliorate potential effects. The assessment methodology has therefore been used to refine the development proposals in an iterative process. 2.3 Local Engagement This EIA has been accompanied by a programme of stakeholder engagement and consultation. The key elements include: Formal pre-application meeting and presentation on 2 July 2013 to discuss the proposed development Public exhibition of proposals held at Keighley Civic Centre on 25 September 2013 Design Review Report Design Review Service for Yorkshire and the Humber, 30 th July The public engagement process provided opportunities for local residents and stakeholders to express their views and contribute towards the EIA and development proposals prior to submission of the planning application. 2.4 Mitigation The development proposals incorporate measures to avoid, reduce and remedy any potential adverse environmental impacts, and to enhance the environmental benefits of the scheme. This has been done by ensuring that potential adverse effects, issues or constraints are designed out of the scheme as far as practicably possible, with impacts that cannot be adequately mitigated through site design addressed through a combination of operational methods and techniques, best working practices, or specific strategies or action plans. Page 7

8 3 SITE LOCATION The site is located on the valley bottom on vacant brownfield land approximately 3km east of Keighley town centre and 12km north west of Bradford City Centre, at National Grid Reference SE The site is bound by the A650 (Airevalley Road) to the north and east, a railway line to the south and industrial works to the west. Green belt land is located to the north and south of the site Site access is located off the A650, on the site s northern boundary. The location of the site on the A650 ensures it is suitably connected to the local strategic highway network The location of the site is shown on the Location Plan provided as Figure 1. SITE Figure 1: Site Location Page 8

9 4 THE PROPOSED DEVELOPMENT Halton Group is seeking planning consent to build and operate a Clean Energy Facility. In summary the proposal will consist of:- Refuse Derived Fuel (RDF) power plant with an expected throughput of approximately 90,000 tonnes per annum (tpa) and a stack of 60 m in height above ground level. Power generation of approximately 10 MW of electricity gross; Tyre crumb melting plant (Pyrolysis) with an approximate throughput of 10,000tpa. Power generation of 2MW of electricity and production of carbon black for use in the Clean Energy facility; Waste plastics melting plant with a throughput of 30,000tpa. Forecast of 28,500 million litres per annum of biofuel for distribution; Grid connection cables, plant and equipment to enable electricity to be supplied to the public supply network; Infrastructure to enable Combined Heat and Power (CHP) including the potential for the provision of a steam off take connection to the Data Hotel site and Dalton Mill site; Four storey office building with capacity for 170 personnel for commercial let; A three storey Visitor Centre to promote education and greater awareness relating to waste issues (waste minimisation, re-use, recycling etc), including the role of Energy from Waste (EfW); Installation of weighbridges, access and internal roads and parking facilities; The provision of Sustainable Urban Drainage Systems (SuDS) and Landscape and biodiversity enhancement areas within the site boundary to attenuate rainfall and enhance the appearance and biodiversity benefits of the site The main structures on site are a series of buildings some of which are interlinked by conveyors. The taller elements (RDF power plant) are located in the eastern part of the site close to the existing gasometers. The landscaped areas to the southern and northern boundaries will provide some screening of views of the lower parts of development from the Airevalley road and railway line. Page 9

10 Material source The source of material for the plants will be source-separated commercial and industrial wastes that have had some of the recyclables removed and have been treated by size reduction and the extraction of recyclates to produce a specific refuse derived fuel (RDF). The multiple fuel sources will be regionally sourced The proposal consists of three energy recovery technologies, including:- Refuse Derived Fuel Power Plant; Tyre crumb melting; Clean energy waste plastic melting. Refuse Derived Fuel (RDF) Power Plant The RDF energy plant is a controlled process where pre-treated waste is burned to convert the material into energy, ash and gases. The energy can be used to generate steam, used to provide electrical energy or heating; ash can be used as a construction material; and the gases are cleaned before discharge to atmosphere. In the UK there is already approximately 8 million tonnes per year of incineration/energy from waste capacity operational or under construction Figure 2 below provides an overview of the processes involved in the RDF Energy Plant. Figure 2: RDF Power Plant Process flow diagram Page 10

11 4.1.7 The steps below describe the process shown in Figure 2. 1) Waste is delivered to the storage bunker where it is loaded into the feed chute by overhead crane. 2) The moving grate is where the waste is combusted under controlled conditions to meet minimum legal requirements for time and temperature so that complete burnout is achieved. 3) Collection of bottom ash and storage in a bunker. Bottom ash can be used as an aggregate replacement in construction. 4) The hot gases pass over a heat exchanger which raises steam. The steam is used to produce electricity and can be used for heating. 5) Treatment and cooling of combustion gases to remove chemical contaminants. 6) Bag filters to remove ash and other solids. 7) Collection and storage of air pollution control residues 8) Emission of cleaned gases to atmosphere. Tyre Crumb Melting Plant Nearly 50 million waste tyres are generated every year in the UK and have been banned from landfill since Tyres will take in excess of 50 years to degrade and can have a significant impact on the environment and ecology. In the UK of the 50 million tyres produced each year 25% are burned for energy, 25% are re-used, 6% are retread, while 44% are recycled in some shape or form Utilising a number of proven technologies from a broad range of highly specialised industries, the pyrolysis of waste tyres provide an environmentally safe option for the treatment of end of life tyres, without the release of additional emissions into the environment The pyrolysis process is shown in Figure 3 below. Page 11

12 Figure 3: Tyre Crumb Melting Plant Process Flow Diagram The pyrolysis process shown above in Figure 3 is explained as follows: 1) Incoming waste tyre is delivered to the facility, having been shredded down to smaller sized particles and is conveyed to the pyrolysis reactor. 2) The prepared feedstock is continuously fed into the pyrolysis reactor which subjects the feedstock to high temperatures in an oxygen free environment, which causes the decomposition of the material. Energy from the process is released as hot gas, any remaining energy left is collected as a solid black, carbon rich residue, biochar, for onward transport and re-sale. 3) The hot combustible gas still contains small particles of biochar, which is separated out in the Cyclone Separator. 4) The separated biochar is collected and stored in the Char Collector for onward transport and re-sale. 5) Exiting the cyclone separator the purified hot gases are introduced into the Quench System where cold water is incorporated to cool the gas down. During this cooling down process the bio-oil held within the gases is released and deposited into the Bio-Oil Storage tank. 6) The remaining gas or Syngas is filtered off and recycled to be used as fuel to provide continued power to the pyrolysis plant. 7) The Bio-oil is stored in the oil tank for onward transport and sale. Page 12

13 The pyrolysis process is very similar to the natural process of decay and decomposition that Planet Earth will do on its own given a hundred million years or so, where organic matter is reduced to coal, oil and gas. The entire process is natural chemistry which only works as long as the feedstock is not burnt Products generated from the process are recycled or re-used as fuel or as an additive in construction and any emissions are cleared of any toxins or contaminants. Plastics Melting Plant Thermal Depolymerisation is a process used to treat waste plastics using heat and pressure to produce a fuel resource in the form of crude oil products. The process is undertaken in an environmentally friendly way generating clean and highly useful crude oil products eliminating toxic contaminants The steps below describe the process shown in Figure 4: Figure 4: Plastics Melting Plant Process Flow Diagram 1) Pre-treated plastics are delivered to the processing facility. 2) The pre-treated plastic waste is directed into a mixer unit. 3) Water is introduced to make a slurry mixture. 4) The mixed slurry is pre-heated prior to entering the reactor. 5) The mixed slurry is introduced into the reactor where the mix is subjected to heat and pressure 6) A catalyst is introduced into the reactor to create a fractional depolymerisation reaction this process separates the water in the form of steam, from the oils or distillate. Page 13

14 7) Bituminous waste is collected and taken off site and can be used a by-product in construction e.g. for road construction. 8) The steam released from the reactor is cooled and re-cycled back into the process as a process additive. 9) The oil residue/distillate is directed into a distillation column which separates the oil products from the gases. 10) The separated gases are cleaned in a scrubber and recycled as fuel back into the reactor. 11) Post process fuel resources are collected in the form of gasoline, diesel and fuel oils. 12) Excess air is vented to atmosphere The UK uses over 5 million tonnes of plastic each year of which an estimated 24% is currently being recovered or recycled, the remainder going to landfill. The optimum recovery route for most plastic items at the end of life is to be recycled, preferably back into a product such as fuel. Site Layout The layout of the development has been designed to present a strong and attractive frontage on to Airevalley Road. The existing entrance from Airevalley Road will be improved to include merge and diverge tapers to and from the main carriageway The proposed site layout is shown in Figure 5. Figure 5: Site Layout Site Access and Infrastructure Vehicles will access the facility via an access road from A650 Airevalley Road. The Page 14

15 same entrance will be used for operational vehicles and staff/visitors. As the weighbridges are located at the end of a long access road, there is space for large number of HGVs to queue to minimise impact on the public highway In addition, the facility will receive vehicles to remove process residues and recyclates and for the delivery of consumables used in the treatment process, such as lubricants, lime and activated carbon The site will be enclosed by a 2.4m high perimeter fence which will ensure the site remains secure. The operational area of the site will not be accessible to the general public. Public access to the site offices and visitor centre, either by vehicle or by foot, will be from Airevalley Road. There will be adequate parking on the site for staff and visitors, as well as parking provision for disabled users. Cycle spaces are also proposed in a secure location Consideration has been given to alternative modes of travel for the facility s employees, addressing more sustainable transport choices and reducing overall car use. The sustainable options of cycling and public transport are considered to be a realistic and attractive alternative to private car use for both employees and visitors. Ancillary Infrastructure In addition to the main building of the development and the technology described above, several ancillary structures will be located around the proposed development, predominantly on the northern side of the development. Bunding will be provided around all tank farms. Hours of Operation The site will be open for receipt of waste and dispatch of reject material from the residual waste 24 hours a day, 7 days a week. However the core hours of delivery will be between: 07:30 18:00 (last vehicle entry 18:00) Monday to Friday, including bank holidays. 07: Saturday The Visitor Centre will typically operate the following hours: 09:00 17:00 Monday to Saturday (excluding Bank Holidays) The three plants (RDF power plant, plastic melting plant and tyre crumb melting plant) will operate on a 24 hours per day, 7 days per week basis. Page 15

16 Material for treatment in the facilities will be fed to the plant based upon the appropriate shift pattern and on a 24 hours per day, 7 days per week basis. Staffing The development will provide both short and long term employment opportunities. Short term opportunities will arise in the form of construction jobs at the site. The direct and indirect operation of the development will create permanent long term skilled positions for operational staff, as well as work placements Halton Group recognises that the required workforce is available locally, and is committed to employing staff from the local area as far as is practicable without the need to bring in staff from other regions. Site Office and Welfare Facilities The proposed development incorporates a main building which will house the site offices and welfare facilities. The layout of the development has been designed to present a strong and attractively designed frontage onto Airevalley Road. The main building to the east of the site entrance will house the offices. A visitor / education centre will be located to the west of the site entrance and adjacent the main office building. The entrance from Airevalley Road will be retained A weighbridge office will be located between the proposed weighbridge located in the south of the site and opposite the Material Reception / Feedstock Building. Community Benefits The will deliver a series of community benefits including: Enhanced recycling and energy to power; 79 operational jobs including the full range of professional, skilled and new entrant jobs including apprenticeships and work placements: Approximately 300 construction jobs (direct and indirect) 170 potential full-time jobs in the offices (commercial let) A broad range of opportunities for local small business and social enterprise Page 16

17 5 ENVIRONMENTAL IMPACT PREDICTION, EVALUATION AND MITIGATION Potential impacts of the proposed development have been considered with regard to a number of distinct topic areas and technical assessments. Potential impacts have been identified and evaluated with reference to magnitude and significance and where required, measures to avoid, reduce, remedy or compensate any adverse effects have been recommended and incorporated into the site design and working methods An overview of each of the environmental assessments provided in the main Environmental Statement is provided below. Archaeology and Cultural Heritage Baseline information was gathered from the Historic Environment Record held by the West Yorkshire Archaeology Service and English Heritage data sets In respect of heritage designations the proposed facility has the potential to impact upon the setting of one Grade I Listed Building, four Grade II Listed Buildings and the Leeds Liverpool Canal Conservation Area. In respect of all but the Grade I Listed Building (East Riddlesden Hall) potential setting impacts would not exceed that of slight adverse significance. In respect of East Riddlesden Hall the significance of any potential impact is likely to be up to moderate adverse. However this is not considered a significant impact in terms of EIA assessment; significant impacts being those that exceed a score of moderate. No impacts are expected to exceed moderate The proposed facility would not physically impact upon any designated cultural heritage designations. Therefore no mitigation measures, for example building recording, would be required It has been established that no designated cultural heritage designations would be physically impacted upon by the proposals. However one Grade I Listed Building four Grade II Listed Buildings and the Leeds Liverpool Canal Conservation Area may experience setting impacts. Landscape and Visual Impact Issues associated with the siting and visual intrusion of waste management facilities often focus on the co-location of such facilities together with buildings of similar appearance and characteristics. The move towards facilities within purpose designed Page 17

18 buildings means that facilities such as the proposed Clean Energy facility are often similar to various process industries The negative public perception associated with energy from waste technologies is often due to the scale of the development in terms of large built structures and associated infrastructure, such as the stack associated with air clean up systems. These effects can in part be mitigated by the co-location of energy facilities as is proposed for the Architect input into the design and physical appearance of the buildings and surrounding structures has been a key principle of the proposed development, in line with the Defra guidance Incineration of Municipal Solid Waste (February 2013). The buildings are of an intrinsically high standard and therefore screening can be limited. The use of good design techniques in the proposed development will contribute to minimise visual intrusion The methodology for the landscape and visual impact assessment (LVIA) follows the recommendations and guidance set out in the following reports: Guidelines for Landscape and Visual Impact Assessment, Third Edition (GLVIA 3); and Landscape Character Assessment Guidance The LVIA involved a combination of desk-based study and site survey work undertaken in August and September Viewpoints representative of views from identified sensitive receptors in the vicinity of the application site were selected and agreed with the landscape officer at Bradford Metropolitan District Council (BMDC). A series of photoviews were produced which formed the basis of the assessment Within the Airedale Landscape Character Area (LCA) the site is specifically located in an area referred to as Airedale: Industrial Corridor. Immediately adjacent to the site is a gasworks, including two gas storage towers, a busy transport corridor (the A650) and a railway line. The landscape sensitivity of the site to the proposed development is therefore considered to be very low, the magnitude of change as medium and the overall effect on the landscape of the site as slight and neutral due to its current classification and former usage All built developments generate landscape and visual effects, but these are addressed as part of the design process, to ensure that the resulting development will fit appropriately into the site and the surroundings. The proposed development Page 18

19 would sit within a landscape currently characterised as a busy transport corridor together with significant industrial and commercial usage. The location and scale of the facility is therefore considered to be appropriate to the site and the surrounding land uses; the landscape effects of the scheme are assessed as at most slight to moderate adverse (not significant) with exception of seasonal affects on East Riddlesden Hall. The visual effects generated by the scheme are assessed as at most moderate to substantial adverse (significant) for a relatively small number of residential properties, and one park and garden particularly during the winter months. Views are generally from upper storey windows and will be softened somewhat by the proposed soft landscape works and good design of the facility itself. Effects are not considered significant from any other landscape areas or any other visual receptors. Ground Conditions The assessment is based upon a review of historical data including past site investigations and a site walkover. A conceptual site model has been developed which provides a summary of the environmental processes in the site and its surrounding area, potential sources of contamination and ground instability and receptors that could be at risk The site has a history of industrial use dating back to the 1850 s and was developed as a gas works towards the end of the 19 th Century. The site was cleared of the gas works in the 1970s and has been largely vacant since. The site currently comprises of vacant land with some building remains in the south west corner and a substation in the north west. A number of previous assessments have been carried out at the site. Site investigations were undertaken by Celtic Technologies Ltd in 2003 and a risk assessment and outline remediation strategy prepared in The remediation strategy proposed has provided betterment to the site and included: Removing structures including tanks and pipework; Removal of NAPL (Non-Aqueous Phase Liquids) from the alluvium; Excavation and processing of the made ground and shallow soils with off-site disposal (for heavily contaminated materials) and/or on-site treatment (for organic contaminated material); Groundwater remediation; and Page 19

20 Monitoring and validation Letters received from the City of Bradford Metropolitan Council (Environmental Services) and the Environment Agency dated 2006 indicate that the site has been remediated to a satisfactory standard The nearest surface water course is the River Aire approximately 200m north and north-east of the site. The site is within Zone 1 and has a low probability of flooding Based on the information reviewed the impacts on the geology from the proposed development are likely to be minor and not significant Impacts on the development from the existing condition of the site are likely to be more significant but these can be mitigated within the design and throrough implementation of measures during construction. Ecology and Nature Conservation Survey and consultation in relation to ecology has been undertaken from the early stages of the development. This work has allowed the compilation of a representative baseline which characterises the ecological conditions within the Site and adjacent areas and informed a robust mitigation strategy Protected species surveys have been undertaken for: Bats Birds Reptiles Invertebrates The ecological assessment has identified and evaluated the elements that make up the local ecosystem and has considered how the impacts of the development may affect each of these in accordance CIEEM Guidelines for Ecological Impact Assessment (2006) It is not anticipated that any statutory designated sites would be negatively affected by the development. Emissions to air from the proposed facility are forecast to have no significant effects at nearby European, national or locally designated habitat sites Habitat loss is confined to areas of ephemeral/short perennial (Open Mosaic habitats) and standing open water habitat. In the longer term compensatory habitat creation would provide ecological enhancement. Best practice methods of protected Page 20

21 species would be secured through a Construction Environment Management Plan (CEMP). With mitigation in place, the significance of impacts on protected species is assessed as being negligible or beneficial. Hydrology, Drainage and Flood Risk The only significant potential impact of this proposed development on the existing environment will be that of surface water run-off and its effect of increasing flood risk downstream. However, as described in the Flood Risk Assessment, this impact will be fully mitigated by the provision of Sustainable Urban Drainage Scheme (SuDS)- based attenuation storage and flow control Other potential impacts concerning fluvial and groundwater flooding, land drainage, pollution and foul sewerage will be mitigated by good design to the point where their residual impacts are acceptable or negligible Overall, therefore, the proposed development will not adversely impact the hydrological or drainage environment. Noise As set out in the Defra guidance (February 2013) the main contributions of noise associated with energy from waste facilities are likely to be: - Vehicle movements/manoeuvring; - Traffic noise on the local road networks; - Mechanical processing such as waste preparation; - Air extraction fans and ventilation systems; - Steam turbine units; and - Air cooled/other condenser units The activities carried out during the earthworks and construction phase of the development will have the potential to generate short term increases in noise levels above the recommended noise limits, set in accordance with current guidance, at existing and proposed sensitive receptors surrounding the site Given the small distances between the construction activities and the nearest sensitive receptors, some sensitive receptors may experience minor adverse noise and vibration impacts in the short term. This would occur temporarily and only for short periods. Page 21

22 To minimise the potential impact of construction works, mitigation measures would be put in place. These will include the restrictions on working hours, the implementation of temporary screening, and best working practice where possible In addition to earthworks and construction it is possible that piling will be required. At this stage detailed information regarding the type of piling has not been confirmed. To minimise the potential for vibration to be generated by piling careful consideration will be given to the type of piling used With the implementation of best working practice and restriction on working hours, the noise and vibration impacts of earthworks and construction phases, are likely to be negligible, with only brief periods of minor adverse impacts likely in the short term at local level During operation of the facility mitigation measures will be incorporated into the site design of the proposed energy facility, to ensure the noise impacts of the facility are reduced to acceptable levels at existing sensitive receptors and proposed offices. It is considered that mitigation measures may include screening, building envelope design, and noise silencers, as appropriate With mitigation measures in place it is considered that the impact of the proposed facility will be negligible in both the long and short term, and meets with the requirements of the Environmental Health Officer during both the daytime and night time. Air Quality Air emissions and health effects is a key issue when designing an energy from waste facility. As detailed in the Defra guidance for incineration (February 2013), in order to comply with the Industrial Emissions Directive (IED) the major emission from a plant with energy recovery is the release of flue gases. The provision of post-combustion gas clean-up measures are key for compliance with the Directive Modelled levels of all released substances when combined with background levels are forecast to comply with standards and guidelines for air quality As detailed in the Air Quality assessment, rigorous gas clean up technologies are proposed for the in order to remove and minimise the formation of potentially harmful substances, such as oxides of nitrogen, mercury, Page 22

23 dioxins and furans and acid gases. The residual emissions will be discharged from the 60 m stack which has been designed to provide sufficient dispersion for the low levels of remaining air pollutants Any dust and odour can also be controlled by good building design, good working practices and the suppression of dust from vehicle movements. As all of the proposed activities will occur in enclosed buildings, any potential odour emissions will be controlled by the building ventilation system The proposed development is forecast to have no significant effects on air quality during abnormal operating conditions or due to road traffic emissions, and no significant cumulative effects are forecast to occur. No odour, bioaerosols or dust issues would be expected to arise outside the site boundary Emissions to air from the proposed facility are forecast to have no significant effects at nearby European, national or locally designated habitat sites. The information set out in the Air Quality assessment indicates that the process contributions would be less than 1% of the long-term critical levels and critical loads, and less than 10% of the short-term critical levels. In view of these results, and in the context of generally declining baseline levels of the relevant substances, there is no likelihood of a significant effect on the designated interest features of the European sites, having regard to the conservation objectives of those sites. Following the Environment Agency guidance, it is concluded that an Appropriate Assessment is not required The study was carried out using a conservative approach to ensure that any air quality effects are more likely to be over-estimated than under-estimated In view of the finding that the proposed Clean Energy Facility will have no significant adverse effects on air quality, it is concluded that no further mitigation is necessary, other than the extensive mitigation and control measures already built into the proposed facility Emissions from the proposed facility will be measured continuously, and as part of a programme of period extractive monitoring. This work programme will be managed under the terms of the Environmental Permit for the proposed facility In view of the low forecast levels of released substances, and conservative assumptions built in to the modelling study, it is most unlikely that an environmental monitoring programme would be effective in identifying a detectable change in air quality which could be linked to emissions from the proposed facility. However, an Page 23

24 ambient air quality monitoring programme could be designed as a cross-check on the conclusions of the study. Again, this would fall under the remit of the Environmental Permit It will be important for the proposed facility not to give rise to excessive dust, odour or bioaerosols during operation. Under normal operating conditions, no odour, bioaerosols or dust issues would be expected to arise outside the site boundary. This is because air will be drawn into the RDF building through the reception area, and used in the combustion of fuel. This is well established practice for RDF combustion facilities of this nature, and will be effective in preventing any significant escape of odour, bioaerosols or dust from the building. Further control on the potential for odours and bioaerosols can be achieved by ensuring good mixing of waste in the bunkers and minimising residence time of waste materials at the facility In the event of boiler down-time, there will be no boiler air demand to draw potentially odorous air from the waste reception hall through the combustion process. The risk of odours will be minimised by avoiding having putrescible waste materials present at the site during planned down-time, and by minimising the duration of unplanned shut-downs. In the unlikely event of extended boiler downtime, waste will be removed from the building. If necessary, odour control can be maintained by keeping the main doors closed, and providing air extraction and treatment using temporary plant. Human Health The Human Health assessment considers the possible effects on the health of humans due to emissions from the proposed Clean Energy Facility. Based on advice from the Environment Agency and experience of working on similar facilities, this was focused on dioxins and furans, for which any effects are likely to be chronic arising from prolonged exposure. Potential secondary exposures, following the deposition of dioxins and furans, through the ingestion of affected soils, home-grown produce, beef, milk, pork, poultry and eggs at receptors within the vicinity of the site were also considered in the assessment In the absence of UK protocols for this type of assessment, the US EPA methodology Human Health Risk Assessment Protocol 2005 was used. The US EPA default exposure parameters and toxicological data were replaced by those recommended by Defra and the Environment Agency where available. The Defra common framework for risk assessment and management was used as the guidelines for the Page 24

25 assessment and appraisal of potential impact on human health from the proposed facility A simplified conceptual model was built for the site identifying all viable sources, receptors and pathways of exposure relevant to each of the receptors. In the absence of specific information in relation to the nature of the local receptors, all default pathways of exposure were assumed to exist, for each receptor scenario, to screen receptors with potentially significant exposure and consequently greater risks Dioxin and furan concentrations in the different receiving media were calculated from the particle phase and vapour phase air concentrations and deposition to the soil. The estimated concentrations were based on a number of conservative assumptions to ensure that worst-case scenarios were assessed To identify the level of potential risk from exposure to each individual chemical in all relevant pathways of exposure, the hazard quotients for each medium were calculated. Potential cancer risk was also estimated and compared with relevant acceptable risk levels and recommended tolerable daily intake The risks to health were found to comply with the relevant benchmarks at all potentially sensitive locations. The greatest intake was predicted to result if an individual could theoretically consume above ground vegetables, at the location of highest concentration. The highest theoretically possible intake of dioxins and furans was predicted to be pg/kg-day. Despite the worst-case approach adopted in the assessment, this incremental intake associated with the proposed facility is a small fraction (1.55%) of the recommended tolerable daily intake for dioxins of 2 pg/kg-day, and would not be detectable in practice. Similarly, the potential exposure of infants via breast milk was assessed, and it was found that the proposed facility would have no significant or detectable influence on exposure in this way It was therefore concluded that emissions to air from the proposed Clean Energy Facility will not pose unacceptable health risks to the residential or farmer locations identified in the vicinity of the proposed facility. Traffic and Transport Vehicular access to the development will be gained from Airevalley Road the classified A650 former trunk road. The development site is roughly triangular in shape bounded by the Airevalley Road to the north, the railway to the south and on its western side by the gasworks with two gasometers. Further west are industrial Page 25

26 and employment units accessed via Airedale Road and Valley Road / Gasworks Road. Keighley railway and bus stations are approximately 1.4km and 1.8km to the west of the site respectively Airevalley Road is a dual carriageway road with a pedestrian footway along the southern flank which is separated from the carriageway by a grass verge. It has street lighting and is subject to the national speed limit. Nearby the Airevalley Road provides direct access to a Yorkshire Water sewage treatment works (Marley). A pedestrian/cycle route is proposed from the site to Airedale Road along the former Marley Road for use of staff and visitors to the proposed development The closest bus stops to the site are located on Wenning Street some 500m to the West of the site, and will be easily accessed by the proposed cycleway/footway connecting the site from Airedale Road An assessment has also been made of the existing sustainable transport facilities and improvements considered appropriate to provide satisfactory links to and from the site have been incorporated into the design Traffic surveys have been undertaken of the highway network to establish base flows of traffic along the Airevalley Road. The peak hours from these counts are considered to be and Traffic flow data has also been obtained from a permanent count station on the A650 (CP80857) between the B6265 and Aireworth Road roundabout junctions. The data identifies the Average Annual Daily Flow on the A650 between 2005 and It shows that traffic flows on the A650 rose gradually from 2005 to a peak in 2010 of some 34,947 vehicles with a similar but slightly lower flow in 2011 before falling significantly in 2012 with a flow of 32,448. The HGV percentage of this was 4.24% slightly higher than in 2010 and The traffic generation potential of the proposed Clean Energy Facility and the previous planning consent on the site are assessed. The proposed development comprises of the Clean Energy facilities, Education and Visitor centre and offices. The nationally recognised TRICS 2013 (b) database has been utilised to estimate the likely traffic generated by the visitor centre and office use elements. With regard to the Clean Energy facilities traffic generation is based on an analysis of the staff and shift patterns and quantity of materials that can be utilised by the various processes on the site. Page 26

27 The likely level of traffic generated by the previous planning consent proposals would have been in the region of 160 two way trips in the AM peak and 150 two way trips in the PM peak with 1305 over the day. In comparison the current proposals are 61 two way trips in the AM peak and 48 vehicles in the PM peak with 394 over the day. This is 2.6 times less in the AM peak, 3.1 times less in the PM peak and 3.3 times less over the day The distribution of development traffic for people working at the site has been assessed on the basis of the working population in surrounding areas to Keighley and the distance that people may travel to work with the aid of census data. This analysis results in a relative proportion of 70% travelling to and from the Bradford area and 30% to and from the three areas of Ribble Valley, Pendle and Craven. Development traffic has then been assigned onto the Airevalley Road and local road network based on turning proportions from the traffic surveys Extensive junction capacity modelling has been undertaken and from this it is concluded that the development traffic flows can be accommodated and the effect would less than would have been experienced had the previous planning consented proposals been implemented A detailed Travel Plan has been prepared to accompany the Transport Assessment which will seek to reduce the level of single person car journeys generated by the development. Measures included in the Travel Plan aim to encourage use of sustainable travel modes Improvements to the adjacent bus stops are proposed in the vicinity of the site access which will further encourage use of public transport, thereby further reducing the number of vehicle borne journeys. It is also proposed to operate a Mini bus for the site In summary it is concluded that a robust analysis of the effect of the development has been undertaken and that the mitigation measures proposed as part of the scheme are sufficient to bring about changes in traffic flows such that the development traffic can be accommodated on the network without severe detriment. Climate Change For this scheme, there is a positive environmental impact through the reduction in Page 27

28 waste haulage miles of material to landfill. Fewer haulage miles results in a reduction in greenhouse gases (GHG) generated. Energy from waste offsets greenhouse gases to combat Climate Change. According to the U.S Environmental Protection Agency (EPA), for every ton of waste processed at an energy from waste facility, the release of approximately one ton of Carbon Dioxide equivalent emissions into the atmosphere is prevented due to avoidance of methane generation at landfills, the offset of greenhouse gases from fossil fuels electrical production and the recovery of metals. The proposed facility will utilise waste as a fuel which would have otherwise been sent to landfill. Landfill gas emission contribute to about 40% of UK methane (CH 4 ) emissions and 3% of all UK Greenhouse Gas Emission (Defra, 2007). Methane is about 23 times more potent than Carbon Dioxide as a greenhouse gas (IPPC, 2001). Amenity Due to the enclosed nature of the proposed development of the Keighley Clean Energy Facility, the impacts upon air quality and odour will be minimal. Similarly, the location of all machinery and plant enclosed within buildings, will serve to minimise the noise impacts of the development. Other potential sources of nuisance, such as pests and vermin, will be avoided by good working practices, good housekeeping and regular inspection and monitoring of the site As far as possible, potential significant adverse environmental impacts have been designed out of the scheme, and measures have been incorporated into the proposals to mitigate any impacts that cannot be adequately addressed through design. There are no adverse individual or cumulative environmental impacts of overriding significance associated with the proposed Clean Energy Facility. Page 28

29 6 SUMMARY AND CONCLUSIONS Halton Group is seeking planning consent for the proposed development of an Clean Energy Facility with a stack of 60 m in height above ground level; associated plant and infrastructure, three and four storey office buildings, weighbridge, parking areas and internal access roads, on land south of the A650 (Airevalley Road), Keighley The site is vacant brownfield land located approximately 3km east of Keighley town centre and 12km north west of Bradford City Centre, at National Grid Reference SE The site entrance is located off the A650 (Airevalley Road). The site was remediated in 2005 and currently comprises scrub land with a scattering of sapling and semi-mature trees The facility will use multiple fuel sources from commercial and industrial waste, which will be sourced and produced in the region. The proposal consists of three energy recovery technologies, including, RDF power plant, tyre crumb melting plant and waste plastic melting plant. The energy generated by the facility will be distributed into the electricity network and have potential for distribution into a proposed heat network In accordance with the Town and Country Planning (Environmental Impact Assessment) Regulations 2011, an Environmental Impact Assessment (EIA) has been carried out to assess the potential environmental impacts of the proposed development on the site and its immediate surroundings. This has included a scoping exercise, in which opinions were sought of the Local Planning Authority, and statutory and non-statutory consultees regarding the information and level of detail required in the EIA The EIA has been accompanied by a comprehensive programme of community consultation to keep the public informed of the proposal and to offer opportunities to express views and put forward recommendations The potential impacts have been considered according to ten distinct topic areas, and associated technical assessments were undertaken. As far as is possible, the potential adverse environmental impacts have been designed out of the scheme. Any potential impacts that could not be adequately designed out have been mitigated to minimise impact. Page 29

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