VIRIDOR WASTE MANAGEMENT LIMITED Lostock Waste Treatment Plant
CONTENTS 1 Introduction... 1 2 Sources, releases and impacts... 2 3 Airborne Pollutant Control Measures... 3 3.1 General... 3 3.2 Site Management Responsibility... 3 3.3 Physical Control Measures... 3 3.4 Management Control measures... 4 4 Emission Limits and Monitoring... 5 4.1 Bioaerosol Emission Limits... 5 4.2 Bioaerosol Monitoring... 5 4.3 Dust, Fibre and Particulate Monitoring... 6 5 Bioaerosol Contingency Measures... 7 5.1 Introduction... 7 5.2 Elevated levels... 7 5.3 Reporting Measures... 8 6 Dust, Fibres and Particulate Contingency Measures... 9 6.1 Introduction... 9 6.2 Dust, Fibre and Particulate Complaint Investigation... 9 6.3 Elevated levels... 10 6.4 Reporting Measures... 11 7 Emergency Plans...12 7.1 General... 12 7.2 Abnormal Meteorological Conditions... 12 7.3 Breakdown of Process Equipment and Plant... 13 7.4 Staffing Issues... 13 8 Management Responsibilities and Review...14 8.2 Review of bioaerosol, dust, fibre and particulates control measures... 14 TABLES TABLE 1 Bioaerosol Monitoring... 5 APPENDICES Appendix 1 Customer care and complaints procedure
1 Introduction 1.1.1 This outlines the methods by which Viridor will systematically assess, reduce and prevent excess bioaerosol, dust, fibres and particulate emissions from the Lostock Waste Treatment Plant (WTP). The Airborne Pollutant Management Plan is a working document with the specific aim of ensuring that: bioaerosol, dust, fibres and particulate impact is considered as part of routine inspections bioaerosols, dust, fibres and particulates are primarily controlled at source by good operational practices, including physical and management control measures all appropriate measures are taken to prevent or, where that is not reasonably practicable, to reduce bioaerosol, dust, fibre and particulate emissions to air from the Waste Treatment Plant at nearby receptors 1.1.2 This addresses the impact of bioaerosol, dust, fibre and particulate release and the control measures employed to mitigate the risk. These are supported through monitoring procedures to identify both elevated levels and review complaints should they arise. The complaints management procedure including the management responsibilities are also addressed. 1.1.3 Bioaerosols are discussed separately from dust, fibres and particulates as appropriate, for example in the Monitoring Plans (Section 4) and Contingency Measures (Sections 5 and 6). 1
2 Sources, releases and impacts 2.1.1 Bioaerosols are microscopic, airborne particles including bacteria, fungal spores, protozoa and organic constituents of microbial and fungal origin. Bioaerosols are naturally present in air but may also be produced by the turning (disturbance) and shredding of organic material. 2.1.2 Bioaerosols, dust, fibres and particulates may be released during the following activities: unloading of waste in the reception hall mechanical separation, screening and refinement loading and unloading of biodrying tunnels outloading 2.1.3 Once released into the atmosphere, the pathway for bioaerosols, dust, fibres and particulates will be air transport. Receptors will include humans living and working close to the site, in particular existing and consented industrial development adjacent to the site and residential properties to the north of the site. The risk of bioaerosol release has been assessed as part of the risk assessment and identified as a low overall risk. More detail on the risks and pathways of bioaerosol release are provided in report 03 Risk Assessment including the Bioaerosol Risk Assessment which is Appendix 1 to the Risk Assessment. 2.1.4 Further detail on the processes that may release bioaerosols, dust, fibres and particulates is provided in 02 Operating Techniques. 2
3 Airborne Pollutant Control Measures 3.1 General 3.1.1 Whilst the waste types accepted at the site are not inherently dusty, bioaerosols, dust, fibres and particulates may be generated by the WTP process on site, as identified in Chapter 2. This chapter identifies the measures in place to control bioaerosols, dust, fibres and particulates. The control measures are discussed separately as physical, management and contingency measures. 3.2 Site Management Responsibility 3.2.1 The Technically Competent Manager (TCM) (or designated responsible person) will have responsibility for ensuring that nuisances and hazards arising from the facility due to airborne pollutants are minimised. Regular meetings will be instigated to discuss current and planned site operations that have the potential to generate airborne pollutants. 3.3 Physical Control Measures 3.3.1 A comprehensive range of physical control measures will be implemented at the site, including: 3.3.2 Enclosed buildings are provided with high speed roller shutter doors, air curtains on all doors and an active air extraction system (as detailed below) to create a negative pressure within the building; 3.3.3 All waste processing plant, including conveyors, will be closed units with point source air extraction applied at strategic locations; 3.3.4 Air extraction equipment will actively extract air from the waste reception hall and the waste treatment building. The air extraction system will induce a slight negative pressure within the relevant buildings. This negative pressure will promote the inflow of air into, rather than out, of the facility so that when the doors are open there is less potential for bioaerosols to leave the building. 3.3.5 Air Treatment Technology, incorporating dust filters and biofilters, will manage aerial emissions prior to discharge to the atmosphere via a stack. The stack has been designed to be of sufficient height (27m) to aid dispersion to the point where emissions will not impact on any receptors. 3
3.3.6 Dust filters will remove particulates, including bioaerosols from collected air. Biofilters will reduce the air flow down so that residual suspended particulates are filtered out of the air. 3.4 Management Control measures 3.4.1 A comprehensive range of management control measures will be implemented at the site. 3.4.2 All waste unloading, loading, treatment and storage will be undertaken inside the WTP buildings. 3.4.3 Doors will be kept closed at all times when waste access is not required. 3.4.4 Road sweeping will be carried out at all of the sites on access roads and forecourts or areas of hardstanding that vehicles would have access to on a daily basis to prevent the formation of dust clouds resulting from vehicle movements on the sites; 3.4.5 All machines, walls and floors will be subject to a cleaning regime to prevent the accumulation of dust that could potentially migrate off site. The cleaning regime will involve daily inspections and where deemed necessary subsequent cleaning will be undertaken prior to the following inspection. 3.4.6 All control equipment as detailed in the physical control measures will be maintained to the manufacturer s specification to ensure that it operates effectively at all times. 4
4 Emission Limits and Monitoring 4.1 Bioaerosol Emission Limits 4.1.1 It is proposed that background bioaerosol monitoring will be undertaken prior to the operation of the facility. This will be carried out both upwind and downwind of the site. Data obtained will be utilised as a benchmark and from this an appropriate trigger and control level will be agreed with the Agency. 4.2 Bioaerosol Monitoring 4.2.1 Before waste treatment operations commence, sampling will be carried out in the vicinity of the site to establish background levels. An accredited laboratory will be used to assess the levels. 4.2.2 Monitoring of bioaerosols will be in accordance with Table 1 below. Monitoring points 1 upwind 1 down wind at site boundary Parameters Bioaerosols Total bacteria, Total Fungi, Salmonella, Escherichia coli and Aspergillus fumigatus Wind Direction Wind Speed Table 1- Bioaerosol Monitoring Monitoring frequency Annually Monitoring method Suitable method to be agreed with the Environment Agency. Other specification Sampling at 1.5m above ground level Action Level TBA accounting for background monitoring results 4.2.3 Bioaerosol monitoring will be undertaken with regard to the standard protocol methods mentioned in the Environment Agency s Guidance on the evaluation of bioaerosol risk assessments for composting facilities or another suitable method as agreed with the Environment Agency. 4.2.4 Additional monitoring will be undertaken as commissioned by the TCM (or designated responsible person) as a contingency measure to mitigate any elevated levels of bioaerosols. 4.2.5 Monitoring has been selected at this frequency as the Air Quality Assessment indicates that there is a low risk of elevated emissions. 5
4.3 Dust, Fibre and Particulate Monitoring 4.3.1 No specific routine dust, fibre and particulate monitoring is proposed, however the monitoring of elevated dust, fibre and particulate levels will be included as a factor to be considered with the daily odour assessment, as detailed in the Odour Management Plan, and will be considered by the TCM (or designated responsible person) as part of their daily walkover of the site. 6
5 Bioaerosol Contingency Measures 5.1 Introduction 5.1.1 Elevated levels of bioaerosols are unlikely given the process operated at the site and the abatement measures proposed. However, if identified at elevated levels as a result of the monitoring procedures detailed in section 4. Contingency measures will be in place to identify the source of elevated bioaerosol levels and bring brioaerosol levels back under control and minimise their impact. 5.2 Elevated levels 5.2.1 Any elevated levels of bioaerosols identified by the monitoring detailed in section 4 will be mitigated as follows: The TCM (or designated responsible person) will commission further monitoring to be undertaken Monitoring locations for bioaerosol monitoring will be agreed with the Environment Agency and/or the local Planning Authority prior to undertaking monitoring. Should the levels still be elevated then the manager will carry out a range of checks to ensure the plant is being operated to the manufacturer s specification, to the requirements set out in Sections 3.2 and 3.3 of this management plan, and to ensure that any improvements required to meet these standards are made. 5.2.2 Once the improvements identified by the TCM (or designated responsible person) have been completed, the manager will commission a further set of monitoring to ensure that the improvements have met the required standard. 5.2.3 If operational failings are identified, the retraining of employees will take place to ensure that all employees operate to the required standards. If the failings are identified as part of the operating techniques then the problem will be raised as part of the review of control measures detailed in section 7.2. 5.2.4 The TCM (or designated responsible person) will ensure close liaison with the Environment Agency throughout all stages of the process following an identified elevated bioaerosol level. 7
5.3 Reporting Measures 5.3.1 In the event of bioaerosol release exceeding the limits identified in Chapter 4, the event will be reported into an Issue Management System by a member of operational staff. This Issue Management System is accessed via internal company intranet, known as the portal. Upon notification of an Environmental Incident, the TCM (or designated responsible person) will complete an incident reporting form. The completed form is then distributed throughout the company for review at operational, management and health and safety meetings. 5.3.2 All performance failures will be categorised for input into the IMS as follows; Minor event: quick fix possible, locally resolved; Medium event: brief disruption to service, Management intervention required; Major event: significant disruption to service significant disruption to service. 5.3.3 Each non-conformance category has a given deadline for rectification. 5.3.4 The IMS will record any actions taken to rectify the issue any necessary actions or review are recorded onto the Issue Management system and the person reporting the incident is notified. 5.3.5 The TCM (or designated responsible person) will investigate the performance failure event within 2 hours and, if necessary, will report the event to the Environment Agency. Once the issue has been resolved, the corrective action taken will be entered onto the system and the issue will be closed. 8
6 Dust, Fibres and Particulate Contingency Measures 6.1 Introduction 6.1.1 Elevated levels of dust, fibres and particulates may be identified either by: receipt of a dust complaint that is attributable to the Waste Treatment Plant; detection of dust as part of the monitoring procedures detailed in Chapter 4; or malfunction of the dust abatement system. 6.1.2 This section details the contingency measures in place to identify the source of elevated levels of dust, fibres and particulates and bring dust, fibres and particulates levels back under control and minimise their impact. 6.2 Dust, Fibre and Particulate Complaint Investigation 6.2.1 A site diary, plus forms to record complaints, will be completed by the TCM (or designated responsible person) and input into the IMS. 6.2.2 As part of the Business Management System, a customer care and complaints procedure will be implemented. The customer care and complaints procedure applies to all complaints, feedback and requests made by third parties regarding Viridor's operational activities, environmental, health and safety performance or quality of service/product. 6.2.3 All complaints from third parties including external customers, potential customers, statutory authorities, statutory consultees, members of the general public and internal clients will be forwarded to the TCM (or designated responsible person) to action as below and recorded onto an online incident reports database within 72 hours. 6.2.4 The TCM (or designated responsible person) will ensure that: The complaint is investigated to identify the cause, if necessary this may involve direct communication with the complainant. In the event of elevated levels of dust, fibres and particulates being detected, the presence of abnormal on site activity is assessed and if necessary preventative action is taken that will 9
prevent a reoccurrence of the same problem. These actions must be documented. The Complainant will be contacted and given information on the investigations conducted and actions taken as appropriate. Details of other complaints are sent to the other Company personnel as appropriate. If the investigation indicates that the complaint has not been justified this will be clearly recorded on the Incident Report. All complaints will be logged. 6.3 Elevated levels 6.3.1 Any elevated levels of dust, fibres and particulates identified by the monitoring detailed in Chapter 4 and the customer care and complaints procedure identified in section 6.2 will be mitigated as follows: The TCM (or designated responsible person) will investigate the source of the dust, fibres and particulates and carry out a range of checks at the identified source of the elevated levels if it is found to be originating from within the site. The TCM (or designated responsible person) will then ensure the plant, including the air extraction system and dust filters are being operated to the manufacturer s specification, to the requirements set out in Sections 3.2 and 3.3 of this management plan, and ensure that any improvements required to minimise the dust, fibres and particulate levels, for example additional cleaning, are made. 6.3.2 Once the improvements identified by the TCM (or designated responsible person) have been completed, the manager will commission a further set of monitoring to ensure that the improvements have met the required standard. If the dust, fibre and particulate emissions are still not being met then the manager will repeat the request for improvements and subsequent monitoring until the limits are met. 6.3.3 If operational failings are identified, the retraining of employees will take place to ensure that all employees operate to the required standards. If the failings are identified as part of the operating 10
techniques then the problem will be raised as part of the review of control measures detailed in section 6.2. 6.3.4 The TCM (or designated responsible person) will ensure a close liaison with the Environment Agency throughout all stages of the process following an identified elevated dust, fibres or particulates level. 6.3.5 To further mitigate the elevated dust, fibre or particulates levels, an improved more intensive and robust cleaning programme may be implemented. 6.4 Reporting Measures 6.4.1 Reporting measures in the event of dust, fibres or particulate release being identified in Chapter 4, will be the same as the reporting measures in the event of bioaerosol release detailed in section 5.3. 11
7 Emergency Plans 7.1 General 7.1.1 This section considers the potential for accidents (or incidents) which would result in the loss of control of airborne pollutants and could have an unacceptable short term impact on the local community. 7.1.2 The measures in place to mitigate any emergency situations will generally be the same as the contingency measures identified in section 5.3. 7.1.3 If the situation is considered to be an emergency by the TCM (or designated responsible person) then the mitigation measures will be immediately implemented and the manager will consider limiting the hours of operation or immediately suspending the site operations creating the unacceptable levels of airborne pollutants. These measures will be considered on a case by case basis. 7.1.4 In addition to the above mitigation measures, Unit Emergency Plans (UEPs) will be prepared for, but not limited to the following: Fire; Bomb / Explosives; 7.1.5 Should an emergency occur outside of normal operating hours, a nominated representative will be on site within two hours of notification. 7.1.6 Should an emergency occur out of hours, the nominated representative will contact his operatives and managers, as appropriate, via mobile telephone. The nominated representative will identify whether the emergency services are required to attend a site emergency and will contact them directly if necessary. 7.2 Abnormal Meteorological Conditions 7.2.1 Abnormal meteorological conditions may promote elevated levels of bioaerosols, dust, fibres and particulates either on the site or at nearby sensitive receptors. A wind direction towards sensitive receptors may increase bioaerosol, dust, fibre or particulate levels at these locations. Conversely, very low wind strength and temperature inversions may minimise dispersion and potentially create a concentration of bioaerosols. High temperatures may also increase emissions. 12
7.2.2 The mitigation measures to be undertaken in the event of abnormal meteorological conditions are the same as the contingency mitigation measures detailed in section 5.3. 7.3 Breakdown of Process Equipment and Plant 7.3.1 The breakdown of the waste treatment process or abatement equipment may cause elevated levels of bioaerosols, dust, fibres or particulates due to equipment not operating to the manufacturer s specification or the failure of control equipment. 7.3.2 The mitigation measures to be undertaken in the event of process breakdown are the same as the contingency mitigation measures detailed in section 5.3. 7.4 Staffing Issues 7.4.1 Human error and accidents may cause elevated levels of bioaerosols, dust, fibres or particulates either through the unloading and outloading of waste or the failure of control equipment. 7.4.2 The mitigation measures to be undertaken in the event of staffing issues are the same as the contingency mitigation measures detailed in section 5.3. The Unit Emergency Plan for accident/injury will also provide further detail on the procedures to be undertaken in the case of an accident at the site. 13
8 Management Responsibilities and Review 8.1.1 The control of bioaerosols, dust, fibres and particulates will be managed according the Business Management System which includes Environmental Management at the site accredited to ISO 14001. 8.1.2 It will be the responsibility of the TCM (or designated responsible person) to ensure that the Business Management System is adhered to. 8.1.3 The TCM (or designated responsible person) will be supported by the Compliance Manager. The Compliance Manager is responsible for monitoring, auditing and evaluation of site performance, which includes compliance with the ISO 14001 standard. 8.2 Review of bioaerosol, dust, fibre and particulates control measures 8.2.1 Bioaerosol, dust, fibres and particulates control measures will be reviewed through internal audits as part of the monitoring and reporting of the Business Management System. 8.2.2 With reference to bioaerosols, dust, fibres and particulates, the internal audits will include but will not be limited to the following; Monthly spot check inspections of the paper trail of forms and the IMS to ensure that all data is being entered correctly. Checks to ensure that any issues entered into the IMS have been resolved correctly Visual inspections to ensure that there is no non compliant waste getting on to site. External Audits 8.2.3 External Audits of the Business Management System (BMS) will be carried out in order to achieve and maintain ISO14001 accreditation. 14