ADAMS 7 St Peter Street Winchester T 01962 877414 W www.adamshendry.co.uk HENDRY Hampshire S023 SSW F 01962 877415/844968 E info@adamshendry.co.uk

YourRef: none _ Our Ref: NCCIBBF/1 0021 7MD

Phil Watson Development Control Manager Planning Development Control Northamptonshire County Council PO Box 163 CountyHall Northampton NN1 1AX

1i h February 2010',

( )­

Dear Phil

, ODOUR MANAGEMENT- BLACKBRIDGE FARM

NORTHAMPTONSHIRE ­COUNTY COUNCIL

22 FEB 2010 ­, pLJ

GROWTH MANAGEMENT

I refer to your e-mail dated 9th February 2010 and our meeting on 12th February 2010. This .letter deals solely with the issue of alleged odour arising as a result of operations at the above site, run oy rny Client, Think Environmental.

Your e-mail refers-to complaints from Cranford Parish Council. You quite rightly state in your e-mail that in the event of complaints being received regarding odour, noise and/or dust (including bio-aerosols) are received by the Waste Planning Authority from any sensitive receptor. In response to receipt of the complaint I am aware that we are required to carry out an immediate assessment of the complaint and prepare a report on the findings with proposals for removing, reducing or mitigating identified adverse effects resulting from the operation and a programme for the implementation

( ) of remedial mea$ures. ­

I am also aware that the Environment Agency Officer, Jane Mossman, has been in discussion with you regarding a number of issues. As part of this formal response I would like to place on record our understanding of the odour issues being explored by the EA.

I can confirm that the complaint referred to in your e-mail has been investigated thoroLighly and the outcome of investigations is set out below.

Nature of the Odour Complaint (5)

This is the only formal complaint we have received from the Waste Planning Authority to date. You will recall that we discussed odour issues raised by the EA when we met. I believe you indicated that the EA had received around 11 complaints, I can confirm that 'odour has been raised with my Clients but at no stage

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to date has the EA indicated the odour emanating from the operations is serous enough to warrant taking further action.

Six Compliance Assessment Reports have been received from the EA, raising odour; since operations began on the site over Bmonths ago. The Reports are attached for your information.

These reports are dated:

• 14/09/09 Odour detected off site from time to time • 11/01/10 Odour not raised but confirms waste storage • 25/01/10 Odour detected on approach to the facility on Cranford Road • 04/02/10 Stagnant waste odour present off site at Cranford Road ­

numerous complelnts throughout the day [note: EA agreed was from slurry tank]

• 05/02/10 Waste odour detected off site • 11/02/10 Odour complaint from south of site, odour detected from

-( Cranford Road

The latest report was received as a result of a visit by the aforementioned EA Officer on 11 th February 201O.

A further complaint was received from a resident of Windmill Cottages on 14th

February 2010.

I can also confirm that the same Officer called the site at about 5pm on 15th February 2010 to report an informal complaint from a resident of Windmill Cottages. This had been received on Sunday 14th February and the company were advised that no further action was required.

In addition to the above, in advance of receipt of your e-mail, the residents of Windmill Cottages had been invited to attend a site visit on 6th February 2010. Five residents attended site and of those five, two stated. that they were experiencing odour from the site.

Odour lnvestlqetion

As a result of the issues raised by the local residents, Think took immediate action on 8th February 2010 and ordered temporary, mobile odour neutralising units to be installed on site. These were placed on site on Wednesday 10th February 2010. I attach the specification of the units (which are 2 in number) and photographs showing their location on site.

I can also confirm that, in advance of receipt of your e-mail.Think ordered a permanent, site perimeter odour management system which will be installed during the week beginning 1st March 2010. I attach the specification for your information.

These actions were deemed expedient but it should be noted that Think have chosen to install these measures as a precaution rather than as a result of an acceptance that there is a 'siqnificant' odour issue.

ADAMS HENDRY

I can also confirm that the matters raised in the EA Site Assessment Reports were also fully inyestigated. Out of the 5 reports, one incident of odour was a result of spreading'on local fields. A further, more significant odour issue was experienced on 4th February ,201 O. This was also experienced by Think employees and I can confirm " that the oqQ.\:lr was a result of th€JJ?rmers splitting and EELrnoving an old slurrysjore on site. We believe this would 'have given rise to odour being experienced by residents at Windmill Cottages and on Cranford Road. The EAaccepted that neither of these fnciCfehtswere as a"resTiltof fhewaste mana§emenfo-peratioris on site~=-:--'

In addition to the above investigations, I attended a site meeting on 11 th February 2010 with an Odour Management Consultant. The Consultant advised on the appropriateness of the temporary and, proposed measures. In respect' or the perimeter measures, he advised that there would be no need to use neutraliser and that water would have the same mitigation effect. The proposed solution is also governed by wind directions, with the necessary sections of the hosing operating at appropriate 'times. ' . , " '

Further to this we discussed establishing a baseline position and undertaking odour modelling and assessment work as a basis for assessing any future issues. Weare currently exploring this and believe it may be beneficial. '

I can also confirm that investigations of local weather conditions were undertaken after the complaints Or) 5th and 11 th February 2010. On both of these occasions the wind was blowlnq in the opposite direction.

I also visited the site at around 1pm today and can confirm that I detected no odour off site. I can confirm that waste was being baled and covered. Vapour could be seen from Windmill Cottages and the nature of this vapour will be discussed with local residents tomorrow. Local residents viewing vapourcan sometimes perceive it to be odorous.

Current Operational Practices '

\ You should be aware that Think carry out, as a matter' of routine, various daily operational checks to minimise the risk of odour occurring as a result of the operations on site. These are set out in the Site Management Plan which has been submitted to the EA. I believe the EA are happy with its contents. I attach a copy for your information.' I also attach a number of forms' which are used on site for monitoring on a daily basis. You will note the checks include monitoring the weather, down loading forecasts and amending working practices accordingly.

You will also be aware that Condition 8 of the planning permission requires the submission of a management plan requiring the measures proposed to control odour.

, The management plan was submitted to you last year. The EA and the Kettering EHO were consulted on the contents of the plan. No fundamental issues were raised but further to our discussions we agreed that it would be appropriate to update the plan to reflect the contents of the SMP referred to above.

I will submit this 'under separate cover. In the meantime I attach the Plan submitted to the EA.

, ,

ADAMS HEf\/DRY

Thtnk also operate aii informal 'open door' policy for local residents to advise of any issues they are experienCing. As set out above, I can confirm that an odour

- - complaint was received on Sunday 14th February 2010. Think investigated the weather conditions on thatdate and on the.t t th F.§bruary 2010. On bOJD_ occasions the Wind was not biowing :"in the direction of Wihdmill Cottages and investigations

__ could not corroboratethe QQ.9l,Jr being experie.Dceg~ _Think are satisfied thatthe odour - v.,;asriol Els·aresult of operatforis·afBlackbdags-Farm: -- ----- -~-.~- - -=c. -- ­

I can also advise that Gerard Reynolds and Dave Heighton went to site on Sunday 14th February, when incidentally the odour units were turned off, and having spent 1.5 hours with the complainant outslde Windmill Cotta-ges, concluded that there was no odour other than a slight earthy smell over a couple of minutes during that period.

Think will be holding a further, informal meeting with local residents on Thursday 18th

February 2010. This will 'not be a formal Local Liaison Meeting but will seek to ( address the issues and set out a programme for ongoing communication.

I will keep you and the EA informed of the outcomes.

Monitoring and future work

We propose that the odour modelling work is progressed and that our initial findings are with you before 12th March 2010. In advance of that the temporary units will be used before the permanent solution is put in place.

We will hold a further meeting with residents after the permanent solution is in place and will report our findlnqswlth the odour modelling work. .

.ln the meantime, Think are fully committed to working with you and the residents to ensure that activities at the site do not cause undue problems for local residents.

I trust that this is sufficient to show that while odour may emanate from the waste on site, it is controlled in such a way that it is not causing an ongoing amenity issue for. local residents.

Please do not hesitate to contact me if you require further information.

Yours sincerely

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ADAMS HENDRY

Attachments:

1. EA Compliance Assessment Reports x 6 2. Temporary Odour units - specificatiCm ­3. Photographs of temporary odour units _

:'4.- Specificatiorrof proposed petmahi!iflt,'petiniefer odO{Jfmanagemeht system -­5. Site Management Plan (living document) 6. Site Odour Plan

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NQtf;hamptonshire CountY Council

Mr$ M(jarrl? Please ask for; PhllWiiltspl1 . Tel; (01604) 2~66~8g~Q]~H~nry Consulting Ltd. ._ . _ plJr ref: 09100014IWAS

7 Sf PeterStreet Yourref: . I?llte: 1~ April~ij1 0Winchester

Hampshire S0238SW

Dear Mrs Darrie

Bio-drying ~r'ld pyrolysis waste management facility atBlackbridgeFarmJ Cr~nford . Road, Kettering, NN155jJ· - , ; .

Unauthorised Use of Land for Waste storag& after Bio-drying, and Odour Manag~ment

I refer to my e-m~il dated the 9th February 2010 wpichraised lssues relating to the unautnorised storage of waste, and complaints regarding odour emanating from thesite. This had resulted in a complalnt from the Cranford Parish Council on behalf of its

. parishioners in Cranford Road, The operator was required to cease the Waste storage, which 1$ occurring in significant quantities after bio,"drying, and to remove these materials from the site. These matters were further discussed at the meeting held at the County Council offices on the 1th February 2010. . .

Your subsequent letter dated th~17th February 201Oq~alt with yqur approach and '.: intentions towards ,od(jUf. rna!1?gementbut .did notpropose the cessatlori ofunauthorlsed

storage of waste. The additional odour' mah~gement measures Which you did propose and . those which have been put in place at the site have not resolved the odour issue. There is still no final Odourl Noise/Dust management Plan which has been agreed by the Waste Planning Authority (or by the Environment Agency). Planning condition 9 required this to

·1:>e agreed prior to the commencement of the development. Therefore the requirements of this condition have not been satisfactorily discharged.

Conjplclintsreilating to odour being detected at resldential properties near to the sitehave contmued to p~ tec~ived and verified by the Environment Agency. and spqt checks by niys~rf snq Roy Boulton whilst out in that part of the County nave also verified that odour can bedetected off the site.

Planning OeVeiopment Conitol. pb6oJ( 163, CountY Hall. Guildhall Ro~d Northampton. NN11AX· . W. \W(,y,northamplonshlre.gov uk t. 01604 236638 f. 01604 236065 e, gpwatson@northamptonshiie.gov,uk .

The submitted planning application did not identify or describe that waste would be stored after bio-drying Jn significant quantities covering large areas of land within the operational site, I refer you in particular to your drawing reference 07 entitled 'Proposed Site Plan'. This does not -identify any areas for storage of waste after bio-drying. The significant quantities,of waste being stored on the site are contributing to the odour emanating from tpe site. The resultant amenity disturbance to local residents is not acceptable. [therefore t~~terateth~_ r~gl:l.irernef!t that these JII~!erl~I~. which a[~ 9~lDg stored folloWingt!!Q-dryjOg, without-the benefit of planning permission, shall be removed from the site forthwith. The operator is therefore required to put forward their intended proposals by the 19th April 2010 for achieving this in a forthwith manner. I have already instructed the County Solicitor to advise on formal enforcement proceedings relating to the unauthorised operations at the site.

Yours sin-earery

On behalf of the Chief Planning Officer

Copy to: Gerard Reynolds, Thjnk~rlvil"onmefltat Ltd. .