EIA Final Version

Environmental Impact
Assessment Associated
with the Development of a
New Waste Treatment
Facility
BSc (Hons) Environmental Health:
Year 4
ENH6010: Environmental Protection
and Management
st20000106
Word Count: 3,302 words
Appendices included with document

ENH6002 EIA Assessment - Report st20000106
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Introduction for Mott MacDonald
This was an Environmental Impact Assessment I conducted as part of the above
module. It was focused around a proposed Mechanical Biological Treat plant located
within a fictitious local authority that ‘employed’ me as an Environmental Health
Officer. For this piece of work I received a mark of 81% which equates to 40% of the
module.
Summary
The aim of this report is to discuss the proposed Mechanical Biological Treatment
(MBT) plant to be located on a 4 hectare site off the A7876 in Curninshire County
Council. This report has been written by Oliver Davies a Chartered Environmental
Health Practitioner in the Environmental Protection Section of the Environmental
Health Department of Curninshire County Council. For the purposes of this report
Curninshire County Council is a Welsh local authority.
Justification for the need for an Environmental Impact Assessment for the MBT
facility
In 2010 the UK was warned that it would run out of landfill space within 8 years
(Independent, 2010), The UK is in danger of exceeding current EU targets for the
amount of waste that goes into landfill. (National Audit Office, 2006) MBT is one of
the options available to reduce waste that ends up in landfill; it’s at the top of the
waste hierarchy and allows for the creation of greater resource efficiency and the
optimisation of recycling. (CIWEM, 2013) EU Directive 1999/31/EEC is a driver for
the increased adoption of MBT. The main aspect of this directive is a progressive
reduction in the weight of biodegradable municipal waste that is sent to landfill by
2020. (EU, 2014) There is growing public anxiety and a slowly growing body of data
concerning the health impacts of landfilling and incineration. (LJMU, 2009)
MBT plants use a range of physical and biological processes in order to treat
residual waste (also known as ‘black sack’ waste). The biological processes are
aerobic decomposition and anaerobic digestion. The physical processes include size
reduction, shredding of waste, physical separation and heat or steam treatment.
There are other types of physical process available and it’s important to note that not
all MBT plants will use all available physical or biological methods. There can be
several different outputs from the plants these can include metals, glass or liquid
digestate. (Environment Agency, 2005)
There is not one specific definition for what an Environmental Impact Assessment is
(EIA from here on). The United Nations Environment Programme defines EIA as “as
a tool used to identify the environmental, social and economic impacts of a project
prior to decision-making. The Government Planning Portal states “The aim of
Environmental Impact Assessment is to protect the environment by ensuring that a
local planning authority when deciding whether to grant planning permission for a
project, which is likely to have significant effects on the environment, does so in the
full knowledge of the likely significant effects, and takes this into account in the
decision making process.” Use of EIA has both environmental and economic benefits
that can be realised, for example reduced costs and time for project implementation
or the avoidance of treatment and clean-up costs at a future date.

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The need for an EIA derives from European Law, specifically Directive 85/337 the
Assessment of the Effects of Certain Public and Private Projects on the Environment
as amended by EC Directive 97/11/EC. Town and Country Planning (Assessment of
Environmental Effects) Regulations 1999 implements this directive in UK law, they
are generally known as the EIA Regulations. An EIA is required when the project is
either a schedule 1 (of the Town and Country Planning (Assessment of
Environmental Effects) Regulations 1999) installation where an EIA is always
required, or a schedule 2 installation of the same regulations where by the project in
question could give rise to significant environmental impacts. (Department of
Communities and Local Government, 2000) An EIA looks at the possible positive,
negative and neutral effects that a project could have across all phases of the
project’s life, for the purposes of this assignment the EIA will focus on the most
significant effects, therefore neutral effects are not considered. The use of EIA allows
an opportunity for local participation in the decision making process (Planning
Guidance Portal, 2014)
The term “significant impacts” is specifically not defined within the guidance,
schedule 3 of the Town and Country Planning (Assessment of Environmental
Effects) Regulations 1999 states the “selection criteria for screening Schedule 2
developments.” This allows schedule 2 developments to be assessed on a case by
case basis. This development has the potential to cause pollution and nuisances,
with the site proposed to be open 24 hours a day there is potential for noise
nuisance to be caused to nearby residents. The development does not meet any of
the criteria outlined in Schedule 1. This development therefore requires an EIA as
the size of the development plot exceeds the applicable thresholds and criteria
stated in schedule 2 of the Town and Country Planning (Assessment of
Environmental Effects) Regulations 1999 and the MBT plants proposed location is
260 from the nearest residential premises with industrial businesses located in closer
proximity to that according to the map. The proposed location is also in proximity to a
SSSI which is an area of increased environmental sensitivity.
In Summary, this site requires an EIA because:
 The site size exceeds the applicable threshold and criteria stated in Schedule
2 (11) (b) of the Town and Country Planning (Assessment of Environmental
Effects) Regulations 1999
 According to Selection Criteria contained in Schedule 3 of the Town and
Country Planning (Assessment of Environmental Effects) Regulations 1999 1
(e) the proposed site has the characteristics to cause pollution and nuisances
 According to Selection Criteria contained in Schedule 3 of the Town and
Country Planning (Assessment of Environmental Effects) Regulations 1999 2
(c) (i) The location of the development is in the proximity of an
environmentally sensitive area (The Local Wetlands, which are a SSSI)
 The nearest residential properties are 260m away and according to the map,
the nearest businesses are closer than that.

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Scoping exercise on behalf of the Local Planning Authority to identify the significant
environmental effects associated with the proposed development
Please see attached as Appendix 1 the Scoping matrix used by Curninshire County
Council.
Bio Aerosols
The term “bio aerosol” encompasses all particles having a biological source that are
in suspension in the air and includes microorganisms (bacteria, fungi, virus,
protozoa, algae, pollen…) as well as biomolecules (toxins, debris from
membranes…) (Sykes et al, 2011) There are a number of health effects linked to
increased exposure to bio aerosols, these have potential effects on respiratory
health and may cause headaches, nausea and fatigue. International studies have
shown that there is a wide variability in individual susceptibility to bio aerosol
exposure. (Environment Agency, 2011)
The identified significant impacts of bio aerosols will mainly occur during the
operation of the plant, this scored 50/75 in the scoping exercise placing the activity in
the highest percentile of impacts. The decommissioning scored lower and is a
consideration, but the most significant period is construction. Environment Agency
states “one particular aspect of composting that needs to be controlled is the release
of potentially harmful bio aerosols.” In this statement a set of emission limits were
established at 300, 1000,500 cfm3. (Environment Agency, 2010) the developer will
need to have reference to these limits. In undertaking the operation of the site, there
is the potential for Bio Aerosols to be release through a number of processes, the
most significant practices being:
 Collection and Preparation
 Separation
 Bio Drying
The possibility of the release of bio aerosols during the operational phase of this
project is a significant impact; this is due to the lack of scientific evidence as to how
exactly the bio aerosols disperse in the air. It’s also significant due to its long term
nature, the bio aerosols if not controlled correctly have the potential to be emitted
from the site for the entirety of the operational phase as bio aerosols presence is an
inherent part of the processes involved at the MBT plant. The scoping exercise has
identified that there are significant impacts during the operational stage of the plant
for bio aerosols.
Noise
Noise is defined as “a sound that is unpredicted, unexpected or undesired.”
(G.Davis, 2014) Noise can have both auditory and non-auditory effects on a human.
The non-auditory effects include annoyance, sleep disturbance, cardiovascular
effects and disturbance of concentration. Auditory effects are usually manifest from
an industrial setting, and this causes direct hearing damage such as deafness,
tinnitus and temporary threshold shift which can have a knock on effect on mental
wellbeing. (CIEH, 2011) The scoping exercise has identified that noise has the

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potential to cause significant environmental problems through the whole life process
of the MBT plant. The themes for possible noise problems are recurring and can be
categorised into the following themes:
 Vehicle Noise
 Delivery Noise
 Construction Activities
 Operational Activities
Noise has the potential to occur through the whole process of the MBT plants life
and therefore has the potential to affect the neighbouring businesses and residents
over a significant period of time. With regard to the construction stage the Control of
Pollution Act 1974 allows the local authority to set times for construction activities to
take place, and also can apply for Section 61 consent to build outside the permitted
hours. The developer will need to have reference to this legislation to ensure no time
limits are breached. The operational phase is the period of time where noise is most
likely to potentially cause issues. Increased vehicle traffic has the potential to cause
increased noise around the site during operational hours. With regards to vehicle
noise the developer will need to look at additional information in conjunction with the
Highways department of Curninshire Council as this information is not available at
this time. The decommissioning phase was considered, it is not as significant as the
potential negative effects during operation and decommissioning issues should be
negated by using a competent contractor.
The noise impact from the above activities will occur throughout the whole life of the
MBT plant and has the potential to cause a Statutory Nuisance under the
Environmental Protection Act 1990 Part 3. Using competent contractors during the
decommissioning should ensure that noise is correctly controlled. The planning
document TAN11 (Welsh Government, 1997) sets out noise exposure limits for new
residential properties. Whilst the residential properties are outstanding, it would be
relevant for the developer to have reference to these when conducting noise
monitoring and to identify if it’s going to cause a problem.
Odour
Odour is this context is an unwanted smell that has the potential to cause a
nuisance. Odour can be caused for a number of reasons, in this case a potential
cause can the presence of the bacteria in the compost that is breaking it down. The
WHO states that there is a link to mental and physical illness to being exposed to
chronic odour nuisance. (WHO, 2013)
The most significant period for odour to be a problem is during the operational phase
of the MBT plant, by its very nature the MBT plant will store waste and therefore if it’s
not controlled successfully it is likely to cause an odour problem. Incorrect controls
could cause a Statutory Nuisance under Part 3 of the Environmental Protection Act
1990. Consideration can be had to the decommissioning and construction phases
but they will not cause as significant impacts as the operation phase as long as they
are carried out by competent contractors.

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Pollutants (NOx, SOx, PM10 and PM2.5)
The majority of the pollutants identified are linked to an increase in road traffic during
all the stages of the MBT process. (Department for Transport, 2014) These levels
can be dependent on the age, condition and use of the vehicle. The HGV’s used to
deliver the waste are most likely to have diesel engines and therefore SOx could
increase in the area. An increase of 20 HGV vehicle movements a day will increase
SOx levels at the proposed site this could therefore potentially lead to the area
exceeding emission limits. (Health Protection Agency, 2010a). The table below
demonstrates the sources and health effects:
Pollutant Sources Health Effects
Nitrogen Dioxide Predominately burning of fossil fuels
and other human activities, although
there is a degree of household
emissions
Irritant gas leading to: Cough, Chest
Tightness and Difficulty Breathing
(Health Protection Agency, 2010b)
Sulphur Dioxide Burning of fossil fuels (specifically
diesel motors) and other human
activities
Irritant gas leading to: cough, airway
irritation and chest tightness (Institute of
Occupational Medicine, 2004)
PM10 Airborne road dust or soil and
vehicle exhaust fumes
Association between cardiovascular
illness and mortality (DEFRA, 2011)
PM2.5 Airborne road dust or soil and
vehicle exhaust fumes
Airborne particulate matter is defined by
the International Agency for Research
on Cancer as a group 1 carcinogen,
(IARC, 2014) Due to their size they
have the ability to get ‘deeper’ into lungs
and cannot be coughed back up and
therefore cause more severe damage
(Health Protection Agency, 2010c)
The table below states the emission limits for each of the pollutants according to the
Air Quality Strategy, 2007. (DEFRA, 2007):
Pollutant Legal Emission Limit
Nitrogen Dioxide 200μg.m3 not to be exceeded more than 18 times a year
Sulphur Dioxide 350μg.m3 (1 hour mean) not to be exceeded more than 24 times a year.
PM10 50μg.m3 not to be exceeded more than 35 times a year as a 24 hour mean.
PM2.5 25μg.m3 with a target of 20% reduction in concentrations at urban background
levels
More information is be required to ascertain whether the increase has the potential to
cause environmental effects, using any current Air Quality monitoring data would
help establish the base line measurement for the location. It would be strongly
advised that the developer uses MET Weather data and publically available Air
Quality Data to establish a baseline of these pollutants in the area. Using this data
will allow for, if necessary an Air Quality Management Area should be declared by
the authority. The developer must have reference to the fact that the legislation
requires the local authority to monitor air quality in their area. These identified

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pollutants do have the potential to cause legal limits to be breached and in light of
that they are significant.
Dust
Dust is a solid particle that ranges in size from below 1 µm up to around 100 µm and
can have varying physical and chemical characteristics. (WHO, 1999) The health
effects can vary depending on the chemical properties of the dust in question. The
dusts present from MBT can be attributed to some of the processes involved in MBT.
It’s important to differentiate between particulate matter and dusts, the dusts in this
section are more likely to cause dust nuisance rather than significant health impacts.
Incorrect controls could cause in local authority action as a Statutory Nuisance under
Part 3 of the Environmental Protection Act 1990. Even with this in mind, it’s still an
important issue due to the plants proposed proximity to residential and business
properties and the potential to cause a statutory nuisance if not correctly controlled.
Compared to the other issues, dust is the least significant.
Critical discussion of the control measures that affect and should be implemented by
the developer to avoid, reduce and where possible, remedy the significant
environmental effects identified.
A MBT plant is a permitable activity under the Environmental Permitting Regulations
2010, Part A (1) Permit, Schedule 1 Part 2 Section 5.3 (c) (i). There is a standard
permit for this type of installation (SR2008 No 18) but this standard permit only
applies to installations that have a total quantity of waste of less than 75,000 tonnes
per year. This installation has an estimate annual throughput of approximately
90,000 tonnes per year and therefore does not meet the requirements of the
standard permit.
The Environmental Permitting (England and Wales) Regulations 2010 Schedule 1
Chapter 5 Section 5.3 c (i) states that a Part A1 permit is required if “Disposal of non-
hazardous waste in a facility with a capacity of more than 50 tonnes per day by (i)
biological treatment.” In light of this the developer will be required to apply for an A1
permit. The use of the Compost Like Output (CLO) from the site is also subject to the
permitting controls. The resulting use of the CLO on land must meet the Animal By-
Products Regulations. (DEFRA, 2013)
Implementing a bespoke permit rather than the standard permit will take the
developer more time and therefore be more costly but will allow for more site specific
permit conditions to ensure that the significant impacts identified above will be
remedied in line with the legal limits contained in the regulations cited above as well.
Using a standard permit as a base point would cover the initial basic controls and
then the developer can focus upon the more significant issues and implement
controls for those.
The planning process can also be used in order to design out potential impacts; an
example of this could be the site layout, the inclusion of rapid closing doors or
implementing landscaping options. Planning conditions should not be used to control
matters that are subject to specific controls elsewhere in legislation. (Planning

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Guidance, 2014) Using both the permitting regime and planning process can allow
for robust operational controls to be implemented and also creates legal
consequences for breaching conditions. Effective conditions implemented by a
planning department should reduce the possibility of environmental impacts being
realised prior to the operational stage.
Whilst the current available evidence suggests that sensitive receptors further than
250m away are not at risk from bio aerosols (Environment Agency, 2011) the
businesses are closer than 250m and therefore a site specific risk assessment for
bio aerosols is required. It’s impossible for MBT plants to apply the hierarchy of
control to the process, bio aerosols are a component of the process. A key control to
consider in terms of bio aerosols is the use of enclosed areas. These are widely
used in other operational MBT plants and provide a good level of control for the
release of bio aerosols. The use of these areas can minimise the escape of bio
aerosols by creating a barrier in the affected areas.
The presence of a Maggot Farm in the proximity of the proposed location of the MBT
could pose a number of practical issues for any monitoring required under permitting
controls. The Maggot Farm will also produce bio aerosols. In light of this the
monitoring will become more difficult, although you are able to differentiate between
certain bio aerosols using the most cutting edge technology. Bio Aerosols is one of
the most significant impacts for the MBT plant, partially due to the uncertainty of how
bio aerosols disperse.
Noise is another operational significant impact that will require controls that can be
achieved through both the planning and permitting regimes. The roads can be
placed as such through planning to ensure maximum distance from the residential
and business sites. There’s the option to landscape the road area and ensure
adequate natural acoustic barriers. Planning and Permitting can both implement
controls regarding the operational hours, and this would be something that would
need to be considered as currently the developer proposed a 24 hour operation. By
using enclosed areas for some of the key activities which could cause bio aerosol
emissions could also allow for reduction of noise from these activities. A BS:4142
(2014) assessment should also be carried out over a sufficient length of time to
identify any noise issues during the life of the MBT plant. Noise issues will need to
be planned out and practical measures inserted. It would even be recommended to
work with the local community should they complain, or be concerned about noise
problems.
Air Quality is the area which has the highest number of significant impacts ranging
through a number of various pollutants. The pollutants identified in this report have a
strong link with increased road traffic and controlling this could be a consideration,
although working with the developer would be recommended. Possible controls
could include certain times for delivery, although consideration would be needed to
the noise impact that this could then have. Monitoring will be required and regard
needed whether an Air Quality Management Area needs to be declared or whether
any emissions limits under the Air Quality Regulations 2010 will be broken.

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Permitting Regulation allow for management controls to be implemented at an
installation, the ‘H’ guidance note series gives a wide range of guidance on how to
comply with permits. H4 Guidance document titled “Odour Management: how to
comply with your permit” (GOV.uk, 2011) implementing this document will ensure
that the developer meets their legal obligations and does not breach any permit
regulations. The document offers a range of advice regarding odour and I would
recommend that the developer have regard to this guidance. The ‘lower’ significance
areas will be well combatted through correct, competent management.
It’s important to note that these controls represent a small proportion of the possible
controls available to implement at the site to reduce the significant impacts. It’s vital
that the developer works with Natural Resources Wales to ensure that the most
applicable controls are used.

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Appendices
Appendix 1 – Scoping Matrix conducted by Local Authority

EIA Final Version

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