As requested by residents at Veolia’s meeting on 3 October, Veolia have provided a written response to the 23 specific questions we posed to them. Veolia’s written responses are below. Veolia state “these are not a verbatim record of the meeting but a position from Veolia on each of the concerns raised to us”.
Source of the waste:
Q1. Over what geographical distance does Veolia intend to transport incoming residual waste for processing at the Lincoln plant? Will this include locations outside of Lincolnshire and if so what towns/cities may be included? We have heard that waste from Peterborough in Cambridgeshire may be processed. Is this correct?
A. As outlined previously in our planning application, waste will be collected from across Lincolnshire, particularly from those areas around centres of waste arisings including Lincoln, Gainsborough, Horncastle, Sleaford and Bourne. Whilst our collection routes do cross county boundaries, the vast majority will be Lincolnshire’s own waste.
Type of vehicles accessing the site:
Q2. Please identify the specific vehicles that Veolia will use to bring to site mixed municipal waste/residual waste for processing into RDF. Will this always be in Refuse Collection Vehicles or will it be transported in other vehicles as well (Front-End Lift Vehicles/Roll on Roll off or Skip Lorry)?
A. We have a small fleet of existing vehicles that are currently used to haul waste for our Lincoln operation. Many of those will be used to bring waste and recycling into the waste transfer station once it is collected from local businesses. These include Refuse Collection Vehicles (RCV); Front-end Lift Vehicles (FEL); Roll-on Roll-off Vehicles (RoRo); and Skip Lorries. In addition, 44 tonnes articulated vehicles, will be used to transport the ‘bulked’ material away from site.
Type of waste:
Q5. In the planning application Veolia sometimes refer to Commercial waste and sometimes Commercial and Industrial waste. Please confirm what the difference is if any in terms of waste codes processed between the Commercial and Industrial descriptions.
Q6. Please supply details of the waste codes and estimated tonnages that the plant will process.
Q7. Please explain the difference, in terms of different waste codes processed, between the residual waste that Veolia will collect from commercial sites and the waste codes used to classify household waste?
Q11. Is it intended that the site will process residual waste from Burger King (Kout Food Group Restaurants UK) such as the Burger King outlets in Lincoln?
A. The proposed facility is to handle commercial waste from local businesses. The term commercial waste simply describes waste from trade premises. The relevant waste codes will be presented in a permit application to the Environment Agency in due course.
To clarify, the proposed facility would accept up to a maximum of 46,500 tonnes of trade waste materials per annum. This waste typically contains a significant proportion of packaging waste, glass and card, along with separated dry mixed recyclables (plastics, cans, paper and card). We have a separate food waste collection service, which will most likely deal with outlets such as fast food restaurants. It is commercially beneficial for us and our customers to separate all possible recyclable materials at source rather than to include it in the residual waste. This includes food waste. No household or hazardous wastes will be accepted at the site.
Accessing the site:
Q3: The access proposed by Veolia from Long Leys Road onto the estate, with 8.4m width and a 10m tangential radius on either side, involves land owned by other parties including AW Curtis. How will Veolia deliver their proposed access to Long Leys Road without securing the permission of AW Curtis?
Q4. Please advise what the anticipated noise levels will be for residents of Oakleigh Terrace as the 12-metre length articulated lorries loaded with RDF turn onto Long Leys Road.
A. Our application includes proposed improvements to the access road. These will be carried out on land which the Local Highways Authority have confirmed is within their control i.e. public highway. Where the road is owned by AW Curtis, Veolia has a right of access.
With regard to anticipated noise levels for adjacent properties when an articulated lorry turns onto or off Long Leys Road, whilst the frequency of vehicle movements will increase, there is no reason to believe the noise levels for each arrival or departure will be any different than those currently experienced when similar vehicles access the area.
Operation of the facility:
Q15. Please provide details on the maximum holding time for shredded waste/RDF in the open sided loading bay that will be included in the Environmental permit (including Christmas and Easter holidays).
Q16. Please explain how the RDF will not create smell when it is tipped loose in an open sided building awaiting collection. Please explain how flies and vermin will be prevented from accessing the loose RDF waste in the open side building when awaiting collection.
Q12. Please provide details on the specification and closure time for the roller door used by vehicles to access the shredding area of the building.
Q13. Will the air pressure of the shredding area of the building be maintained below atmospheric pressure to avoid fugitive emissions? How many air changes per hour are proposed for this building?
Q14. Please provide details of any air filtration proposed for the shredding area.
Q17. Please provide performance and COSHH data for the odour suppression sprays to be used at the site along with estimated annual volume of usage.
A. The proposed facility will essentially be a local ‘drop off’ point for waste materials that Veolia collects from commercial businesses, allowing waste materials to be stored, for a short period of time, before they are sent on for further recycling and recovery. Recyclable waste separated at source by our customers (glass, card, paper, plastics) will be tipped into bays within the building, where it will wait until sufficient quantities allow bulk haulage by articulated lorry to other facilities for processing by third parties.
Residual waste will be tipped in the building, then lifted by shovel (a digger-type vehicle with scoop) into a shredder. The RDF output from the shredder will be moved by conveyor to an open bay to await same-day removal. Since this waste will be cleared by the end of each working day, it will not be on site long enough to deteriorate or encourage flies or vermin.
The site will be enclosed for all shredding operations to keep noise and dust to a minimum however, it is not a dusty operation. With the door only opening for the entry and exit of vehicles. Glass will be compacted in the vehicles and only deposited and loaded within the confines of the building for further noise reduction onsite.
The working day will end in line with the operating hours outlined in our planning application. The waste transfer station will operate Monday to Friday from 7am until 6pm and on Saturdays from 7am until 5pm, by which time the last load will have been removed from site and the waste transfer station will cease operating for the day. There will be no operations on Sundays or bank holidays.
In addition, we will install fast-acting doors on the building that use detectors to recognise a vehicle arriving, then open to allow access. The doors will be closed during the shredding operation and only open when vehicles enter and exit the building. The doors remain closed at all other times during the operations. In our experience odour emissions will be controlled by the building design and these fast-acting doors, as well as having the waste cleared from the site each day and therefore an air filtration system is not required.. Industry standard, water-based odour suppression sprays can be used if necessary, and there are a range of scented and unscented options available to us.
With regard to the materials arriving, glass will be compacted whilst on the vehicle so noise impacts will be lessened. Paper and card within the residual waste will be mixed with other materials, which reduces the scope for dust to be created during shredding.
Refuse Derived Fuel (RDF):
Q10. Please supply the address of the energy from waste facility that will burn the Refuse Derived Fuel (RDF) produced by the plant. Please also supply the end-user’s technical specifications relating as a minimum to the calorific value, the moisture content, the form and quantity of the RDF.
A. There are a number of Energy from Waste plants in the area that could potentially accept this type of RDF material. We will produce material to a specification that meets the requirements of specific commercial arrangements we enter into.
The Planning Application:
Q18. Please identify the qualifications and professional competence to undertake odour assessments of the author of the Odour Assessment report submitted as part of Veolia’s planning application.
A. The odour assessment was prepared following the advice and from a number of technical specialists. The report satisfactorily addressed specific questions raised by the planning authority during determination.
Q22. Please advise whether Veolia are willing to rule out, for a minimum of 10 years at the Long Leys site and its neighbouring properties: (a) construction of an incinerator to burn RDF or generate electricity (b) purchase or lease by Veolia of any additional land to allow further expansion of their operations (c) expansion beyond 46,500 tons of processed waste annually.
A. Our plans for the site and its future operation were set out in the planning application. We have been asked if we have other plans for Long Leys Road but we do not. The 46,500 tonnes applied for is the maximum capacity the site could accommodate and allows us some headroom to expand the business beyond the volume of waste currently handled, which is around 23,000 tonnes per annum.
The Operating Permit:
Q8. Is it Veolia’s intention to apply for a bespoke or a standard rules Environmental Permit? If a standard rules permit, which one will Veolia apply for?
Q9. Residents request that Veolia progress the Environmental Permit for this site with the Environment Agency and present to residents by 1st November to allow greater scrutiny before the public hearing. Will Veolia commit to this?
A. The permit application is an entirely separate process and will be undertaken once we have clarity on the planning position. A decision on the type of permit application we submit will be subject to further discussions with the Environment Agency, but we anticipate a bespoke application. An operating permit from the Environment Agency offers an extra control layer for how we manage operation of the waste transfer station.
Q19. Please provide details on the likely causes of the fire in August 2017 at a Veolia Waste Transfer Station at London Road, Alvaston, Derby and the waste codes and tonnages of waste stored on this site. Please explain what went wrong in Veolia’s operational and fire prevention controls at this site which allowed a fire to destroy the building. Please advise what remedial actions Veolia will be taking on other sites they operate to address the causes of this fire.
A. On August 24, 2017 there was a fire at Veolia’s Waste Transfer Station on London Road, Derby. This was the result of an unknown ignition source in the general waste pile located in the centre of the Transfer Station.
Working with the local fire brigade the Site Manager instructed that two parts of the wall be taken down to allow a better access point for the fire services. Plus the waste had to be removed from the transfer station to be fully dampened down – stopping the risk of re-ignition. However, due to this removal process the source was also moved so has been closed as an ‘unknown’ source.
As an older facility Derby had fire detection systems but not fire suppression. For Lincoln we have proposed both fire detection and fire suppression systems within our design so this will be a modern facility equipped with a sprinkler system, adequate fire water tank and pump house. There is no more of a risk of fire here than at any local business.
Health and safety is our highest priority and we can confirm contingency plans were executed successfully with the site evacuated immediately. No one was injured. We worked with the emergency services and environment agency through the incident. We have emergency plans in for all of our sites and hold regular emergency drills to ensure we can deal with any incidents quickly and effectively.
Veolia is a recognised leader in environmental and social responsibility and has been awarded the UK’s most prestigious business accolade, the Queen’s Award for Enterprise and more recently the Responsible Business of the Year Award which is the Business in the Community’s flagship award.
Q20. Please provide details on the likely causes of the odour and fly problems reported in July 2017 to the Environment Agency at Veolia’s Kirkby in Ashfield site under permit LP3839DK together with a list of the remedial actions Veolia has had to take as a result to satisfy regulators.
A. At Kirkby in Ashfield, we experienced initial teething problems with the biofilter causing odour issues some months back, however these were short-term and the remedial measures put in place to address it were successful. It is worth noting that that particular facility processes organic-rich household waste, which is quite different from the expected commercial waste planned for Lincoln as it includes high proportions of food and green waste. The two facilities are not comparable.
Q21. We are concerned that recycled material may end up at a lower level on the Waste Hierarchy. Please comment on the accuracy of GMB union claims of 17 July 2017 that they have emails suggesting Veolia, under their Sheffield waste management contract, diverted material destined for recycling to their incinerator at Sheffield to be burnt.
A. Claims by the GMB union regarding our Sheffield operation were completely untrue. We are a commercial business, recyclable material has a value which we want to realise, so of course we will separate it out for reprocessing.
Q23. Please advise why Teal Park is not being considered as a viable option for the RDF production plant? The incinerator is owned by the State (county council) and has a need for RDF and Veolia is a provider of RDF, the carbon footprint of operations would be significantly reduced if the Waste was processed and burnt at the same vast (only partially occupied) non-residential site which is specially designed for high volume heavy goods traffic.
A. This question of why we do not consider moving to another site and establishing a waste transfer station elsewhere has come up time and again. As we’ve said previously we are not looking at other site options as we have a long lease remaining on the Long Leys Road site with associated financial and contractual obligations. So extending our activities here at Long Leys Road is our preference. Sites put forward by Lincoln City Council have been just that, a suggestion of a site not a proposal that considers how to limit or remove our obligations for the existing site or the investment that we have made in infrastructure on that site. Should the opportunity to consider an alternative site without penalty come our way, we’ll consider it. We remain open to consider any offer the City Council wish to make to satisfactorily relocate our business, on a cost neutral basis. Until this is received and in the interests of securing employment for our existing workforce we will continue to pursue our plans to develop the site in Long Leys Road. This will increase our service offering to Lincolnshire’s business community from a site we have successfully operated for more than a quarter of a century.