Sunday, 26 February 2017

Something is rotten in the brown bin!

THE £40 BROWN BIN CHARGE 
 A LOOK BACK AT THE DECISION TO BRING IN A CHARGE FOR GARDEN WASTE IN DERBY UK.
 FIRST WRITTEN AT THE TIME THE PROPOSAL WAS PUT IN PLACE BUT NOW INCLUDES UPDATES.
         Derby told DEFRA they had in use 89,215 brown bins in 2012/13.
It isn’t clear if that includes homes who had a 2nd brown bin.
Council accountants confirmed to me that in 2012/13 19975.11 tonnes of waste was handled via the brown bin at a cost of £49.13 per tonne – As confirmed by Russell Sexton at Derby City Council.
This is a cost of £981,451.63 plus a collection cost of a claimed £880,000 as confirmed by Malcolm Price at Derby City Council via email giving a total of £1,861,451.63
If these figures are correct that produces a cost per household in the last financial year to the council of £20.86 for a full year including food waste which clearly isn’t £40 without food waste for a part year.
If we presume there are 100,000 bins as is often considered to be the case that becomes £18.61
That waste in general has to be collected whatever bin lorry collects it – once in the RRS / SHANKS residual waste contract that waste would cost at least £100 per tonne to handle – ie circa £1,997,500 WITHOUT THE COLLECTION COST.
 2015/16 costs were at least £107.40 per tonne and at a recent Full Council meeting it was quoted as £120.00 in 2016/17.
 An FOI request was made for all documents relating to the brown bin £40 charge proposal.
Documents show the council expected a 10% fall in recycling – based on the 2012/13 recycling rate of 45% will mean a plunge from 48% in 2010/11 to 35% in the future.
The 2015/16 recycling rate for the city was actually 32.3%

The image below shows the fall in garden waste composting via the brown bin - prior to the service termination this material included a percentage of food waste composted via the brown bin service.


 
The documents sourced via FOI show a planned charge of £20 per bin with £10 for the 2nd bin, this does not reflect the now applied £40 and £20 for the 2nd bin charge.
The final options appraisal further noted a charge of £20 and £10 noting this is relatively low compared to other councils.
It notes that the city will FAIL to reach the 2020 government target of recycling 50% of waste.
The council had planned to move recycling to the black bin and residual waste to the small blue bin.
The council was aiming for a 20 - 30% uptake in the chargeable garden waste collection.
A number of options were put forward for waste management – it is suggested in the documents that option 6 be selected
 
Option 6 To adopt a citywide garden waste charging policy based on 20% participation and implement a single bin comingled recycling collection service using the black bin. We would also rollout a weekly residual waste collection service using the smaller 140L blue bin
The blue bin supplied to residents has a capacity of 140 LTR which is relatively small and does not have the capacity to contain all of the recycling material currently presented at the kerbside. It is therefore proposed that the blue bin is swapped over with the black bin. The black 240 LTR bin will be used as the recycling bin and the blue bin will be used for the residual waste. A weekly residual waste collection service will be rolled out citywide.
A charging policy for the collection of garden waste is proposed which may prove unpopular with customers; however 30% of Local Authorities already charge with others coming on stream.
 This option will produce savings of £1.14m and will streamline our service delivery with the implementation of a single pass collection system for dry recyclables. This will prove very popular with our customers as they will no longer have to use red, orange and blue sacks. A weekly residual waste collection service will also prove very popular.
Recommendation
"Taking the four major factors into consideration it is recommended that Option 6 is introduced.”
The reality is NO considered option matches what has finally taken place as
 option 6 is not what actually happened.

The reality was that while the brown bin itself stayed the same, new larger blue bins were issued and small blue bins were removed. Dry recycling stayed in the blue bin and residual waste in the black bin.
FOI data showing a cost break down suddenly shows a £40 plus £20 charge for bin number 2 or more.
 No FOI papers show why this figure changed from the planned £20 and £10 charge.
The council in the FOI data consider that 20,000 residents would sign up for the £40 charge with 1 in 4 of those agreeing to pay a further £20 for a 2nd bin.
IN 2015 CUSTOMERS FOR THE BROWN BIN SCHEME STOOD AT 12,083 AND NOT THE 20,000 CUSTOMERS THE COUNCIL EXPECTED.
CONCLUSION
It is quite clear that garden and food waste was being processed far cheaper than the charge proposed and later applied and the vastly higher rate if it moves as it has done to the black bin residual route. The charge is shown in council papers to be lower than that now applied. Large volumes of waste will now be diverted from recycling and composting driving down the cities recycling rate and diverting waste to landfill and incineration and will likely be fly tipped.
They have managed to select a waste option that was not even in the options considered.
THERE IS SOMETHING ROTTEN AND IT IS NOT JUST WHAT IS PUT IN THE BROWN BIN!
 
©SIMON BACON 2017


Sunday, 29 January 2017

Consultation - an exchange of views they dont really want!

CONSULTATION - AN EXCHANGE OF VIEWS IN AN ATTEMPT TO REACH A DECISION !
 
So that is what a consultation is considered to be - an exchange of views relating to a decision.
But what about a decision where those making the ruling consider that they do not NEED to consult or do so in such a way that those being consulted do not even know they are subject of a consultation!
 
My previous blog post broke the news to many that they were being consulted on a proposal to burn almost 18,000 tonnes more waste in Sinfin, Derby at a controversial waste incineration plant that has yet to even start operations! It was early December 2016 when the UK Without Incineration Network first advised me that they had spotted a consultation on the subject on an obscure Environment Agency website that 99.9% of people would never look at.
My previous blog post gave the background to this situation and was supplied to local media, Derby News, Derby Telegraph and East Midlands Today etc for further promotion to the public.

To catch up on that post take a look here
 
As I considered this situation unacceptable I contacted the Environment Agency to make a complaint about the consultation as I felt that it was not in the spirit of public engagement as they were failing to gain the views of the community around the facility they were ruling on. The Environment Agency was fully aware of the controversial nature of the project and so should have expected local opposition and so should have been open to engagement.
The response from the Environment Agency appears to set out that we should consider ourselves lucky to even have online consultation access noting that in the last three months they have improved the web based consultation as previously people would have had to go to the local Environment Agency office (which sounds like last century consultation methods). They also say they have a policy of increased consultation where they consider there is likely to be a high degree of local interest and that this could include wider advertising for example in local newspapers -
 WHICH WAS NOT THE CASE WITH THIS APPLICATION!

 
We also learn that this has been the practice since 2010! the Environment Agency are so welcoming of public comment, views and opinions that they have been hiding the consultations for over 6 years squirrelling them away on some faceless government websites and in local Environment Agency office's for all those years.
 
 
After I replied to the Environment Agency further they upgraded my complaint to the Regime Team Leader no less who continued to trot out the excuses for the poor public liaison stating that "We do not publicise all applications" so god help local residents across the UK.
 The team leader went onto suggest that the Sinfin, Derby application was a "normal" variation application which we do not usually publicise. Hold on a minute this is an application to burn thousands of tonnes more waste at a controversial plant which has not even started operations yet! and the Environment Agency are saying they would not usually publicise.


Some are now likening the stance of the Environment Agency to something out of Hitchhiker's Guide to the Galaxy - which included the following -

“But the plans were on display…”
“On display? I eventually had to go down to the cellar to find them.”
“That’s the display department.”...

“With a flashlight.”
“Ah, well, the lights had probably gone.”
“So had the stairs.”
“But look, you found the notice, didn’t you?”


 “Yes,” said Arthur, “yes I did. It was on display in the bottom of a locked filing cabinet stuck in a disused lavatory with a sign on the door saying ‘Beware of the Leopard.”


― Douglas Adams, The Hitchhiker's Guide to the Galaxy


As an update to this blog post I wrote to my MP - Margaret Beckett who was previously a government minister for DEFRA etc who then wrote to the Environment Agency Chief Executive James Bevan. He then passed it onto Mark Haslam the Area Environment Manager for the East Midlands who just sent her the same kind of waffle that they had already sent me. It appears that Margaret Beckett doesn't recognise the issue that if the public are not consulted then there is something very wrong!

SOME SAY THAT ALL I NEED IS THE AIR THAT I BREATHE !

IF IT IS LEFT TO THE UK ENVIRONMENT AGENCY IT IS NOT CLEAR IF YOU CAN EVEN HAVE THAT!

 

©SIMON BACON 2017

Sunday, 1 January 2017

Are we permitted to comment ?

You may not have picked up on the fact that the Sinfin incineration plant - due to open in September 2017 after a delay due to the technology developer going into administration (fills you with confidence) has applied to the Environment Agency (EA) to burn nearly 18,000 tonnes more rubbish than it was granted to burn.
If your a local person - who may have objected in the past you would have expected the Governments Environment Agency to go out of their way to flag this proposal up to you because you have previously engaged with them on the sites permit.
Obviously there are grave concerns regarding this application to burn more waste - the site next to the air quality management area (AQMA) will have an even greater impact than is already proposed. Derby is now being targeted by DEFRA due to poor air quality and so surely greater scrutiny needs to take place with such applications.
 
Resource Recovery Solutions (RRS) / Shanks Waste claim it will not have a greater impact than was passed by the EA but all that consisted of was models of emissions - nobody will be carrying out real tests at ground level - the Environment Agency will not do so, Derby City Council - responsible for air quality in the city will not do so and the developer RRS / Shanks will not do so even after I requested they take on the example of UBB in Gloucestershire who are building an incineration plant and have agreed to fund air quality monitoring around their site before and after construction. When asked RRS/ Shanks refused.  
The important story here - other than something so controversial burning even more than planned and nobody will monitor the impact at ground level is that
 RESIDENTS HAVE NOT BEEN TOLD THAT THERE IS A CONSULTATION TAKING PLACE ON THIS WHICH RUNS TILL JANUARY 20TH 2017.
When the permit was first applied for a number of years ago - and later granted residents were able to have their say. The EA held local consultations and residents could write in with their views - so the EA should have their addresses which you would hope they would use to write to the residents to advise of this latest proposal. It was also advertised in the local press in the Public Notices etc. PEOPLE WERE AWARE !
Move onto late 2016 and out of the blue I heard from the UK Without Incineration Network (UKWIN) that they had seen an application on a government website.
I looked into this and sure enough found the following


 What became very clear very quickly was that nobody was aware of this application - finalised in early December 2016 BUT ACTUALLY IT TURNS OUT submitted in JUNE as was later admitted by Will Spurr from Shanks Waste via the Community Liaison Group (CLG)
 they didn't even tell the CLG even though the CLG had met between June and December.

When challenged in recent weeks the EA have admitted that the only place the consultation is promoted is on their government website! HOW DOES THAT ENGAGE WITH THE PUBLIC ? hiding important consultations away on a government website that 99.99% of the population would never look at !

It shows that the councils, Shanks Waste / RRS and the Environment Agency have a total disregard for public views and opinions 
 WHY?
 
The councils knew because their contractor is Shanks Waste / RRS - but didn't tell the public!
 
Shanks Waste / RRS  knew because THEY were the applicant - but didn't tell the public!
 
The Environment Agency who knew have done the very least they could to tell the public!

CONSULTATION ANYONE !
 
©SIMON BACON 2017

Wednesday, 30 November 2016

Dont lie to school children!

It has always been rather questionable for the councils of Derby and Derbyshire to have school children educated about rubbish by the same company they are paying to burn the same rubbish from mid 2017.
So what is the story?
Via the waste contract the councils get waste education provided to schools from a waste education officer supplied by Resource Recovery Solutions - owned by Shanks Waste.
At a Community Liaison Group meeting in early 2016 a representative of RRS / SHANKS admitted they told school children the plant was a recovery plant (the representative is named in the meetings official minutes) - now its true to say it will recover some materials and some energy - BUT NOT ENOUGH FOR IT TO BE A RECOVERY PLANT AS DEFINED IN LAW.
Now unless the plant is proven to be efficient enough then by default the plant is considered a disposal plant WHICH IS BAD - and so to educate that it is anything else would be wrong - some would say it is a lie and obviously its a big no no to lie to school children when at school.
 
Now burning waste is a funny old game because doing so can be considered to be one of two things when it comes to considering the process in the waste hierarchy it is considered a disposal process unless it can prove otherwise in which case it is a recovery process.
 
In a twist to things a plant that meets the R1 test of efficiency target is STILL a disposal plant until it is granted recovery status.
 
DOES THE CONTRACTOR KNOW WHAT THEIR PLANT IS?
YES AS THEY CONFIRMED IT AT THE 2ND PUBLIC INQUIRY INTO THE PROJECT
 
SHOULD EDUCATIONAL STAFF EMPLOYED BY THE CONTRACTOR KNOW WHAT THE PROJECT IS?
YES THEY MUST DO AS

 IT IS THEIR JOB.

For more information on this issue please check out my previous blog post which can be found here
http://derby-waste-a-rubbish-blog.blogspot.co.uk/2016/11/dont-put-it-in-recovery-position.html


©SIMON BACON 2016

Sunday, 13 November 2016

Dont put it in the recovery position !

It was a simple innocent question that I put to Resource Recovery Solutions at a meeting of the Sinfin waste incineration plants Community Liaison Group (CLG) meeting back in early 2016.
 
We were part way though a presentation by a representative of RRS / SHANKS in relation to what they teach school children they visit at schools across Derby and Derbyshire or tours the construction site with and I was feeling somewhat uneasy that the councils were paying a company that was being employed to burn vast volumes of waste to then also educate school children what we should do with waste.
So at that point I thought hey ho lets just pop a question across to the the RRS / SHANKS  just to satisfy myself that they were in fact educating school children correctly and that I was being unfair to judge them. It was at this point that a representative of RRS / SHANKS (named in the meetings official minutes) told the meeting that they told children it was a recovery plant.
WOW THERE ! WOW THERE ! now hold on just a minute ! did they say it was a RECOVERY PLANT ? really ! a RECOVERY PLANT ?
 
Now burning waste is a funny old game because doing so can be considered to be one of two things when it comes to considering the process in the waste hierarchy it is considered a disposal process unless it can prove otherwise in which case it is a recovery process.

 The waste hierarchy just for clarity is a set of processes when dealing with the whole issue of waste that must be considered as it takes in best practices to deal with waste in the most sustainable way.
It starts with REDUCTION / PREVENTION where the aim is to reduce what waste we produce so managing materials in the best way - by not using them to start with ! Then we have RE-USE which is where whenever possible we take items that are now scrap and attempt to use them again in an innovative way to keep them out of landfill and incineration. Then comes RECYCLE which is when materials at the end of their life if not reused are reprocessed into new items by making use of the products raw material make up. As we head down the hierarchy we get closer to less sustainable methods of waste management such as incineration and landfill - neither of which are good methods of waste disposal. This brings us to RECOVERY which is when those handling waste start to use wastes for energy generation such as in incineration plants which meet an efficiency target called R1. These are plants which can show that their efficiency of energy generation meets a strict target and often requires such plants to export large volumes of heat or steam to customers to meet that efficiency rating. Finally we come to DISPOSAL which includes inefficient energy generation in incineration plants and also landfill.
In a twist to things a plant that meets R1 efficiency targets is STILL a disposal plant until it is granted recovery status.
Now rather conveniently for the UK government they use a waste hierarchy image as shown below which I consider to be incorrect as it blurs the lines between recovery and disposal in the waste hierarchy by using questionable wording.
The image shown below is the image in question and is used by DEFRA in their document
Energy from Waste a Guide to the Debate dated Feb 2014
 
 
Now reviewing the image it would be very easy to be misled into thinking that any incineration plant - including gasification is recovery in the waste hierarchy if it generates energy. The image appears to imply this is the case and as this image is commonly reproduced a gross misunderstanding takes place!
It is only when you take the chance to read other areas of the document that the issue of R1 and its application are considered and at that point you realise the difference between recovery and disposal. Obviously there are some who favour this blurring as it allows them to paint a picture of a project that makes it conveniently sound better than it is.
To aid you readers below is produced a series of statements from DEFRA from the document in relation to R1 and what is known as D10 disposal.
 
Recovery or disposal – the meaning of R1

47. As described above the Waste Framework Directive (WFD) sets out the waste hierarchy and enshrines it in law. It requires that a waste management route defined as recovery should be used ahead of an alternative that is classified as disposal. Exceptions can be made (see below) but this general principle makes it important to know whether a process is considered recovery or disposal. 

48. Historically the Waste Framework Directives have included annexes which set out lists of what are considered to be recovery or disposal operations. Each is given a number and a letter: R for recovery, D for disposal. In the current directive the classifications of particular relevance to energy from waste are: • R1 – Use principally as a fuel or other means to generate energy • D10 – Incineration on land 

49. What this means is that where waste is burnt as a fuel to generate energy it can potentially be considered a recovery operation (R1) but where the purpose of incineration is to get rid of waste, it is considered D10 and hence disposal.  All municipal waste incinerators were and are deemed as disposal activities (D10) unless and until they are shown to meet the requirements of R1. This is why the term R1 often crops up in the debate about how good an energy from waste plant might be and how it compares to other options. 

50. For municipal solid waste, which includes all the waste collected from households, the EU has gone further by defining what it considers to be sufficient for recovery status under R1. The WFD includes a formula relating to the efficiency of the combustion plant. A municipal waste combustion plant can only be considered to be a recovery operation under R1 if it generates energy and the plant meets the efficiency thresholds calculated using the R1 formula

SO THAT IS THE OFFICIAL BLURB FROM DEFRA ON RECOVERY OR DISPOSAL PLANTS AS GOVERNED BY EU DIRECTIVES - WHICH STILL GOVERN THE UK SINCE BREXIT.

So returning to what the RRS / SHANKS representative said they teach students the plant is. they stated they teach students that the plant is a RECOVERY plant - which raises the issue of R1 as noted above.
When we consider R1 and the claims of the RRS / SHANKS representative we know what they are teaching children is false because at the 2nd planning inquiry the developer had to admit that their plant fails the R1 test in its standard mode.
If you tell children something that is false then in general it is usually considered a lie.
It is a lie in this case because staff employed in waste disposal and waste management will know the requirements of the waste hierarchy

 IT IS THEIR JOB.


©SIMON BACON 2016

Thursday, 4 August 2016

Reaching a tipping point !

The Raynesway tip in Derby has reached a tipping point in relation to usage.

The operation of tips - often know these days as Household Waste Recycling Centre sites or HWRC sites for short in Derby and Derbyshire was handed to Resource Recovery Solutions (Derbyshire) Ltd often referred to as RRS a number of years ago now. The operation of the sites which span the county of Derbyshire forms part of the joint waste contract which is linked to the controversial Sinfin waste incineration plant in Derby UK.
 
The councils pay RRS to run the sites and RRS dispose of the waste via whatever route they see fit. They hand that job to HW Martins who appear to run the sites for RRS. The councils pocket some money for waste electricals which are recycled but it appears any other income from recycling is not pocketed by the councils - and so we give money away.
 
The Raynesway HWRC site in Derby is the only recycling site the residents of Derby can take their waste for disposal to. As the city expands one thing that doesn't expand is the Raynesway tip but one thing that DOES expand are the queues that build outside the site of residents waiting to empty their cars. The reason behind these queues is open to debate but one thing is for sure, the controversial £40 brown garden bin charge applied to Derby residents has led to an increase in people looking to dispose of garden rubbish at the tip. This was predicted a number of years ago by myself at a Full Council meeting. The risks were ignored and now along with other issues such as an expanding city and residents from outside of the city using the tip, the HWRC site and the surrounding road structure can no longer cope.
The Derby Telegraph has given the subject of the traffic chaos at the tip pages of coverage over time highlighting the impacts it is having on local businesses with even the suggestion it is causing rubbish to be dumped in areas around the site. plans were published for a change on the site so that more cars would be able to queue on the site although this was recently dropped - mystery surrounds this but the council claim they are working on an alternative.
An out of the box suggestion was suggested by myself to help deal with the situation in the form of a webcam viewing the road to the tip - as is used in Birmingham so that residents can view the queue allowing them to decide if its an ideal time to attend the tip to beat the queues. While published in the Derby Telegraph the council does not appear to have run with this suggestion.

There are 10 HWRC sites in Derbyshire - 1 of those is in Derby and the other 9 are in the county - one of which is run by waste management company SITA - the rest being run by RRS.
Derby as a city continues to expand and areas surrounding the city which are technically in the county become parts of the city by default as residents consider themselves to be from Derby - even if technically they are not. As time passes this puts an ever greater strain on the cities single tip leading to ever greater queues at the tip. Residents in the county living lose to Derby may consider that it is better for them to visit the city tip instead of their own which may be many miles away. Only recently I met a South Derbyshire resident who uses the Raynesway site in Derby because technically her tip was many miles away in Bretby. She said "why would I drive that far when Raynesway is so close?"

Derbyshire County Council publish on their website population estimates for the county and city. They predicted that in 2014 the population would be

DERBYSHIRE 779,800 (with 9 tips)

DERBY 252,500 (with 1 tip)

This is shown here
http://www.derbyshire.gov.uk/community/about_your_county/population/population_estimates/

So while Derby is struggling to get by with one tip for over a QUARTER OF A MILLION residents the county on the other hand is lording it up with one tip per 86,644 residents - based on County Council population claims.

BUT NOW IT GETS WORSE

The Derby Telegraph are now reporting in their latest reports that Derbyshire County Council are looking to ban Derby residents from county tips but the city does not propose a similar ban. To read more on that subject check out this Derby Telegraph story
http://www.derbytelegraph.co.uk/no-plans-to-ban-people-from-outside-derby-using-raynesway-tip/story-29571778-detail/story.html

BUT HOLD ON!

THIS IS THE SAME COUNTY COUNCIL THAT WANTS TO SHIP LARGE VOLUMES OF ITS WASTE TO BE BURNT IN THE CITY OF DERBY FOR THE NEXT 25 YEARS.
FUNNY HOW THE COUNTY DOESNT THINK TWICE ABOUT SENDING ITS WASTE TO THE CITY WHILE BANNING THE CITIES RESIDENTS FROM COUNTY TIPS.


©SIMON BACON 2016


 

Monday, 25 July 2016

To be a fly on the wall

It was only when posing some questions to the Environment Agency - the government body responsible for ensuring waste sites conform to permit conditions that it became clear what a total car crash the situation was at the Shows Waste Management site on Slack Lane, Mackworth, Derby.

 It would be hard to have missed the media coverage of what has happened this year at the Slack Lane site which became a hub for a fly infestation that impacted on a whole area of the city which was only acted on strongly when local residents exposed to the media the situation they found themselves in.
 
Purchased in 2015 for £850,000 by Sam and Wayne Turton - who had run a waste management company in Nottinghamshire for a number of years called Go 4 Greener you would expect from their experience they would understand the requirements of the waste permit which carried the name of their other company - Shows Waste Management. If they failed to meet the requirements of their permit they could face action by the Environment Agency.
 
The permit and some of its many requirements were set out in my previous blog post which can be found here http://derby-waste-a-rubbish-blog.blogspot.co.uk/2016/07/permit-to-fly.html 
What became clear from the Environment Agency response to my questions - which related to the tonnages of material able to be stored on site was the sites operation was riddled with serious issues spanning acceptable practices on site through to serious site management issues. In response to my request for clarification on aspects of the permit - namely the tonnages on site and if they were inert or non inert the Environment Agency sent me a copy of their site visit report from 2nd March 2016 when two members of staff from the Environment Agency visited the site for almost two hours.

Note the 2nd March was BEFORE Shows Waste Management claim to have taken on other companies to operate the site and who they appear to be looking to blame for the situation that developed.
The document itself notes SIX breaches of the waste permit at the time of the site visit - remember the sites owners have run waste companies before - but managed to breach the site permit SIX times on one Environment Agency visit.
What follows is my extraction of information from the site visit report. Text in RED are my observations.

The document start by stating that on arrival it was noted there was a large amount of waste being stored in white bales all around the site. The sites managers name is redacted ( BLACKED OUT) but the manager stated they were refuse derived fuel RDF bales and that they would usually be sent to Andusia Recovered Fuel in Holland
In 2014 Go 4 Greener went to AEG AMSTERDAM to agree disposal contracts for 2015 - it isn't clear if those contracts ran their course but it shows the sites owners have previously engaged with waste to energy plants in Europe.
 but due to transportation issues they were having to find somewhere else to take them, possibly Poland. Someone (redacted but presume it was the site manager) was unable to tell the Environment Agency how many bales were on site but the Environment Agency staff felt there were 300 bales on site.
It was noted that there was a BREACH of permit condition 4.6.1 which requires combustible waste to be stored in bays on impermeable pavement with sealed drainage with access to fire fighting equipment. The bales were not stored in bays and were not on sealed drainage. Someone (name redacted but presume as above) could not locate the site fire plan and their description of the fire fighting equipment did not sound adequate for the amount of combustible waste on the site.
Clearly a site fire plan and suitable fire fighting equipment should have been at hand noting the volumes of waste involved. 
It was noted that the RDF bales needed to be removed from site and this would be formalised in a notice.
Someone (name redacted but presume as above) was not fully conversant with the waste conditions of the permit relevant to his duties. The was noted as BREACH of permit condition 1.3.3. He was also not aware of the site having an environmental management system.
You would hope all staff would be aware and conversant with the above
Someone (name redacted but presume as above) took the Environment Agency staff on a tour of the site and explained that the incoming general mixed waste had already been processed elsewhere metal, paper and card had already been taken out and shredded for transport reasons. Shows Waste Management then shred the waste further and pass it through a trommel to remove fine material. This process results in RDF and fines. The fines are stored within the building before removal off site. The RDF is baled and currently stored all around the site mostly free standing in the open.
This waste operation involving the shredding and screening of waste to produce RDF is not authorised by this permit and is therefore a BREACH of permit condition 1.1.1. This operation should stop immediately.
So they were doing something they were not permitted to do
The incoming mixed general waste has already been mechanically treated elsewhere prior to arrival on site. This means it should be coded as a 19 waste code. The acceptance of this waste type is a BREACH of permit condition 1.2.1. The permit does not allow the acceptance of any waste from waste management facilities. The acceptance of this waste type should stop immediately.
The permit limits the quantity of non inert waste on site to 350 tonnes. The weighbridge operator (name redacted) provided us with a spreadsheet with the incoming and outgoing wastes for February 2016. This showed that the total amount of non inert waste stored under the permit was at least 783 tonnes. This is a BREACH of permit condition 4.6.1 which limits non inert waste to 350 tonnes.
So they knowingly accepted levels of waste above the permit limit
In addition to the bales there was a large amount of unprocessed waste stored in the main building. Some of this waste was visibly steaming indicating that it is decomposing and was likely the cause of the odour reports. Permit condition 4.6.1 table 4.6 b addresses odorous waste including wastes which are likely to be odour producing during storage. It states that odorous waste should not be stored for longer than 48 hours unless agreed to by the Environment Agency. It was clear from the weighbridge spreadsheet that a large amount of potentially odorous waste had been stored on site longer than 48 hours. This is a BREACH of permit condition 4.6.1.
So they were storing stinking waste for longer than they should have
In order to monitor and control odorous emissions permit condition 5.2.1 requires the site operator undertakes monitoring activities at least twice per day and records these in the site diary. This monitoring was not being carried out or recorded in the site diary. This is therefore a BREACH of permit condition 6.3.1. The site now needs to implement monitoring as per their permit condition.
So they were not monitoring the situation successfully
Condition 6.3.1 requires that a site diary should be kept detailing specific events that should be recorded. Someone (name redacted) stated that the site did not have a site diary. This is a BREACH of permit condition 6.3.1. The site should implement a site diary with immediate effect.
Appears they had no site diary to log things in
Permit condition 1.3.4 is being BREACHED as it requires that the technically competent manager records their arrival and departure in the site diary. In addition Warren Steele does not have the required WAMITAB qualification for this permit. Provide details to this office of an appropriately qualified technically competent manager for the site by 23rd March 2016.
The storage of RDF on site without the correct infrastructure or authorisation in place is a serious matter and needs to be dealt with as quickly as possible. Shows Waste Management Limited now need to produce an action plan detailing how they will bring the site back into compliance with timescales. While the RDF is still on site the site should produce a risk assessment detailing what measures and procedures they will put in place in order to deal with any such risks such as fires and odour. The action plan should be submitted to this office by 23rd March 2016.
The fire service have been alerted to concerns we have regarding the site.
We will now be considering what enforcement action we will be taking with regards to these permit breaches.

ALL THIS WAS HAPPENING IN EARLY MARCH BEFORE ANY OTHER COMPANIES THE TURTON'S ARE TRYING TO BLAME WERE INVOLVED ON THE SITE.
IT APPEARS WHAT COULD GO WRONG DID GO WRONG AND THE SITES OWNERS COMPLETELY FAILED TO OPERATE A WASTE DISPOSAL SITE IN THE MANNER EXPECTED OF THOSE NAMED ON THE PERMIT.


©SIMON BACON 2016