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EA LTD Environmental

Assessment

Air Quality Assessment

associated with the Griffins Farm Extension

at

Southam Quarry Southam Road Long Itchington

CV23 8RA

August 2013

EA LTD, Swallow Barn, Stretton under Fosse, Warwickshire, CV23 0PE

Registered in England and Wales 5230569 www.ea.ltd.uk [email protected] 01788 832296

Southam Quarry – Griffins Farm Extension - Air Quality Assessment August 2013 Tim Pinder 0 of 27

Project Date Author Pages


Assessment

An Assessment of Potential Air Quality Impacts

associated with proposed Griffins Farm Extension at

Southam Quarry Southam Road Long Itchington

CV23 8RA

operated by

CEMEX UK Cement Limited

August 2013

Prepared by Tim Pinder BSc(HONS) MSc FIEMA MIEnvSc CEnv

Executive Summary This report has been based on the assessment requirements outlined in the Technical Guidance to the 2012

National Planning Policy Framework, Mineral Policy Statement 2 Annex 1: Dust, and Secretary of State Process

Guidance Note PG3/8 (12).

An assessment has been made of the potential air quality impacts associated with the Griffins Farm extension to

Southam Quarry. The existing operations at Southam Quarry are subject to a high standard of site management

that incorporates a large number of highly effective dust control measures. The proposed extension at Southam

will utilise the same processes and facilities as currently exists including retaining the well screened processing

area, providing screening bunds and shelter belts, and using a conveyor under the A426 situated away from

potentially dust sensitive receivers. The site is currently independently certified to the internationally recognised

ISO14001:2004 which requires continual improvement and provides additional safeguards and a rigorous

demonstration of compliance with all legal requirements.

The quarrying activities at Southam have an inherently low risk of dust emission which has been recognised in the

environmental permitting regime. Southam Quarry is not required to have an environmental permit as ‘the

handling of clay at quarries is not normally likely to result in the release into air of particulate matter’. CEMEX

have indicated that they are not aware of any dust nuisance complaints arising from existing activities.

An analysis of wind patterns in the area identified prevailing south-westerly winds and the susceptibility of

neighbouring activities to dust dispersal has been calculated. During periods when the site is working in areas

close to sensitive properties the potential for dust related impacts will be carefully managed and CEMEX has

indicated that it will take extra care to monitor meteorological conditions and will apply additional dust control

measures such as water bowsers to prevent any potential dust emissions.

The extension area will be screened from prevailing winds by planted shelter belts, and the proposed site

management techniques will ensure that the risk of dust emissions remains low. The distance to dust sensitive

receivers and their location in relation to prevailing winds will further ensure that the potential for dust nuisance is

low. It is therefore highly unlikely that any of the surrounding neighbouring activities will experience any increase

in dust levels and there will be no deterioration in local air quality from the proposed extension.

Mr Pinder has over 25 year’s technical expertise of dust assessments in the minerals and waste industry as a consultant, researcher and environmental director. He has given expert dust evidence

at public inquiries and has participated in government and industry sponsored research into dust management and control. He is an Environmental Advisor to the UK Mineral Products Association

and the European Ready Mixed Concrete Organisation. He has a BSc (HONS) in Environmental Studies, a Postgraduate Diploma in Advanced Environmental Practices, an MSc in Environmental

Management, is a Fellow of the Institute of Environmental Management and Assessment, a Member of the Institution of Environmental Sciences, and a Chartered Environmental Scientist.

EA LTD, Swallow Barn, Stretton under Fosse, Warwickshire, CV23 0PE Registered in England and Wales 5230569

www.ea.ltd.uk [email protected] 01788 832296




Assessment

Contents

1. Existing Situation ..................................................................................................................2

1.1 Legislative framework ...................................................................................................3

1.2 Local Air Quality .........................................................................................................5

1.3 Local Meteorological Environment .................................................................................9

1.4 Neighbouring Dust Sensitive Receivers ......................................................................... 11

2. Assessment ........................................................................................................................ 17

2.1 Site Design and Sources of Dust .................................................................................. 17

2.2 Dust Management ..................................................................................................... 20

2.3 Soil Stripping and Handling ........................................................................................ 23

2.4 Extraction ................................................................................................................. 23

2.5 Conveyor ................................................................................................................. 23

2.6 Processing Plant ........................................................................................................ 24

2.7 Stockpiles ................................................................................................................. 24

2.8 Loading/Unloading ................................................................................................... 24

2.9 Vehicle Movements .................................................................................................... 24

3. Potential Impacts ................................................................................................................ 25

4. Conclusion ........................................................................................................................ 27

Table 1 UK Air Quality Criteria 3

Table 2 Results of Dust Deposition Monitoring 2006/07 9

Table 3 Meteorological Susceptibility Rating 10

Table 4 Average monthly weather data for Stratford Upon Avon Weather Station 11

Table 5 Dust sensitive activities 12

Table 6 Potential Dust sensitivity 13

Table 7 Meteorological Susceptibility 14

Table 8 Potential Sources of Dust 18

Table 9 Southam Farm Dust Control Plan 21

Table 10 Risk of Potential Emissions 25

Table 11 Potential Risk of Air Quality Impacts from Griffins Farm Extension 26

Figure 1 Site Location 2

Figure 2 UK Background Concentration of PM10

6

Figure 3 PM10

Monitoring Location 7

Figure 4 Frisbee Dust Deposition Gauge Monitoring Locations 8

Figure 5 Wind rose for Church Lawford Weather Station 10

Figure 6 Location of the nearest dust sensitive receivers 13

Figure 7 Existing vegetation screening along A426 16




Assessment

1. Existing Situation

This report assesses the potential dust impacts associated with the Griffins Farm extension of Southam

quarry proposed by CEMEX UK Cement Limited. The assessment is based on acknowledged research,

industry best practice, legislative requirements, and follows guidance contained in the Technical Guidance

to the 2012 National Planning Policy Framework1

, Mineral Policy Statement 2 Annex 1: Dust2

and

Secretary of State Process Guidance Notes PG3/8 (12)3

. The operators, CEMEX, are proposing an

extension to the existing Southam quarry which will release up to 14 million tonnes of clay over a 21.4

year period.

Figure 1

Site Location

1

Department for Communities and Local Government, Technical Guidance to the National Planning Policy Framework March 2012

2

Mineral Planning Statement 2: Controlling and Mitigating the Environmental Effects of Minerals Extraction in England. Annex 1: Dust

3

Secretary of State Process Guidance Note 3/8 (12) Quarry Processes, September 2012

Existing CEMEX

Controlled Land

Proposed Griffins

Farm Extension




Assessment

1.1 Legislative framework

The principal air emissions from quarries are wind-blown fugitive dusts (particulate matter) and nitrogen

dioxide from engines in heavy goods vehicles and mobile plant. European Union (EU) air quality directives

provides the framework for all UK air quality policy and EU air quality limit values have been incorporated

into the UK Air Quality Standards Regulations 2010. The current UK Air Quality limit values are outlined

in Table 1.

The air quality standards for dusts apply only to dust particles smaller than 10 µm (PM10

) or 2.5 µm (PM2.5

)

in diameter. PM10

and PM2.5

usually remain suspended in the atmosphere for very long periods of time

and are of concern with regard to human health as they are capable of being inhaled into the lungs. They

are, however, less likely to cause dust nuisance or disturbance as they rarely deposit out of the

atmosphere. There are no air quality standards for dusts larger than 10 µm in diameter or for nuisance

related dusts that may settle out of the atmosphere and lead to complaints.

Table 1

UK Air Quality Criteria

Pollutant Averaging

Period Limit Value/Objective

Year for

Compliance

Fine particulates

(PM10

)4

Daily mean 50 µg/m

3, not to be exceeded more

than 35 times a year (90th percentile)

31st Dec 2004

Annual mean 40 µg/m3 31

st Dec 2004

Fine particulates

(PM2.5

)4


st Dec 2020

Benzene

Running

annual mean 16.25 µg/m

3 31

st Dec 2003

Running


3 31

st Dec 2010

1,3-Butadiene Running


3 31

st Dec 2003

Carbon monoxide Running 8-

hour mean 10.0 mg/m

3 31

st Dec 2003

Lead

Annual mean 0.5 µg/m3 31

st Dec 2004

Annual mean 0.25 µg/m3 31

st Dec 2008

Nitrogen dioxide

1-hour mean 200 µg/m

3 not to be exceeded more

than 18 times a year 31

st Dec 2005


st Dec 2005

Sulphur dioxide

1-hour mean 350 µg/m

3, not to be exceeded more


st Dec 2004

24-hour

mean

125 µg/m3, not to be exceeded more


st Dec 2004

15-minute

mean

266 µg/m3, not to be exceeded more


st Dec 2005

4

Measurement technique: Gravimetric




Assessment

In addition to detailing air quality standards, the UK National Air Quality Strategy5

also outlines measures

to be taken by local authorities and others through a system of Local Air Quality Management in pursuit

of the achievement of the national objectives.

Local air quality objectives associated with quarrying are enforced and managed by Local Authorities

using a combination of wide ranging planning controls, which can impose dust conditions on quarries,

and environmental permitting. In addition to wide ranging planning conditions to control dust from

quarries most quarry processes are also required to hold an Environmental Permit under the

Environmental Permitting (England and Wales) Regulations 2010 except where the operation of the

activity is unlikely to result in the release into the air of particulate matter. Southam Quarry is not required

to hold an Environmental Permit as the moisture content of the material excavated will ensure the risk of

dust emission is very low. In addition, Process Guidance Note PG3/8 (12)6

states that ‘the handling of

clay at quarries is not normally likely to result in the release into air of particulate matter’. Despite the

absence of a site environmental permit extensive best practice guidance, contained in the Secretary of

State Process Guidance Note 3/8 (12) Quarry Processes has been followed at the site. CEMEX have

indicated that they are not aware of any dust nuisance complaints arising from activities at the Southam

Quarry.

In addition to ambient air quality standards and environmental permitting, local authorities are also under

a duty to regularly inspect their area for statutory nuisance and to investigate any complaints. If a

statutory nuisance exists the local authority is also under a duty to serve an abatement notice requiring the

nuisance to be stopped or reduced. Abatement notices will usually be served on the person responsible

for that nuisance but may also be served on land owners. Failure to comply with the terms of an

abatement notice without reasonable excuse is an offence and may result in a fine. If a notice is not

complied with, a Local Authority can also take steps to abate the nuisance itself and recover the costs.

Conviction in a Magistrates' Court can result in a maximum fine of £20,000, plus a daily fine of £500 for

each day on which the offence continues after conviction. Although enforcement is undertaken by Local

Authority environmental health, actions can be brought by any person who is aggrieved by the existence of

a nuisance by making a complaint directly to the court.

There are no statutory standards or mandatory guidelines relating specifically to thresholds for dust

nuisance and there are recognised problems in identifying thresholds. In the absence of standards and a

5

The Air Quality Strategy for England, Scotland, Wales and Northern Ireland 2007

6

Secretary of State Process Guidance Note 3/8 (12) Quarry Processes, 2012




Assessment

recognised method to measure dust deposition nuisance is assessed by environmental health officers on a

case-by-case basis.

1.2 Local Air Quality

Southam Quarry is located immediately north of the town Southam and is within the local authority

borough of Stratford on Avon. Detailed reviews of local air quality within the Southam area have been

undertaken as part of the national air quality strategy updating and screening assessment programme.

The objective of these assessments is to monitor relevant pollutants and identify any areas where residents

may be exposed to air pollution that exceeds concentrations detailed in the UK Air Quality Objectives.

Where potential exceedances are identified, Local Authorities are required to designate Air Quality

Management Areas (AQMA) and detail action plans for reducing exposure. The last screening assessment

in the Southam area was conducted in 20097

and confirmed that there was only one property identified as

presenting a potential concern with regard to dust concentrations in the district located near a waste

recycling site in Napton-on-the-Hill. No concerns were identified associated with quarrying of the CEMEX

activities at Southam.

Stratford on Avon DC has declared two AQMA’s for the whole of Stratford upon Avon and at a location in

Studley due to exceedances of the NO2 objective. It is extremely unlikely that quarrying activities would

have any effect on local air quality in Stratford upon Avon or Studley as Southam Quarry is located many

miles away from both locations. Although concerns were raised regarding NO2, the last Updating and

Screening Assessment concluded that PM10

objectives are likely to be met at all locations in the district and

that no further detailed assessment would be required.

In undertaking its screening assessment, Stratford on Avon has followed the latest DEFRA technical

guidance, LAQM.TG (09)8

, which outlines the difficulties associated with quantifying dust emissions from

quarrying and quarry sites. The guidance recommends that the following approach is taken:

If there are no relevant locations for public exposure within 1000 metres of the dust emissions

source then there should be no need to undertake further assessment;

If the PM10

background is less than 26 µgm-3

, as they are around Southam,

then there is no need for

further assessment if there are relevant locations for public exposure within 200 to 400 metres;

7

Air Quality Updating and Screening Assessment Report 2009 Stratford on Avon District Council

8

DEFRA Technical Guidance (2009) ‘Local Air Quality Management’ (LAQM) TG(09)




Assessment

Where properties lie closer than 200 metres to the source, local authorities are advised to

investigate whether any dust nuisance complaints have been reported, as this may give a guide to

potential problems. The absence of complaints is not alone a basis for saying that the objectives will

not be exceeded, and authorities are advised to take account of local background levels and their

own professional judgement based on visual inspection of the operations.

Although there are several properties within 200m of the proposed site boundary the DEFRA guidance

does suggest that quarrying activities are unlikely to contribute to background PM10

. Reference to the

national background pollution maps suggests that PM10

concentrations in the area are likely to range from

17 - 20 µgm-3

.

Figure 2

UK Background Concentration of PM10

2010 (µgm-3

)9

In addition to the Stratford on Avon assessment of all local sources of dust there have been numerous

generic assessments of the potential local dust contribution from quarrying operations in the UK10

, all of

which have shown quarries to be insignificant contributors to local PM10

concentrations.

9

Air Pollution in the UK 2010, DEFRA Sept 2011




Assessment

CEMEX has undertaken routine PM10

monitored at three locations around the existing Southam site for

several years. The monitoring has been undertaken using an Osiris airborne particulate monitor (Turnkey

Instruments) which employs a light scattering technique that gives a continuous and simultaneous

indication of the TSP (Total Suspended Particulates), PM10

, PM2.5

, and PM1.0

mass fractions. A Turnkey

Instruments weather station including wind direction, speed and temperature sensors has also been used.

This measurement device provides a good indication of the general particulate matter environment and is

excellent for portable surveys. The monitoring locations are shown in Figure 3.

Figure 3

PM10

Monitoring Locations

An analysis of the PM

10 monitoring data confirms that the monitored PM

10 levels are similar, or lower than

those predicted for the area by the UK Air Quality Archive. During 2012 PM10

levels for the existing quarry

area (monitoring point 1) were approximately 13 µg/m3

, well below the national average background

10

AQEG (2005) Particulate Matter in the UK. Defra, London.




Assessment

levels, despite being downwind of the existing quarrying operations. The monitored levels are significantly

below the UK air quality objective levels.

In addition to PM10

monitoring, CEMEX undertook a limited dust deposition survey in 2006/7. Although

there are no air quality standards for dust deposition in the UK, other countries often refer to a guideline

of 200-250 mg/m2

/day to indicate when nuisance may occur. Although this guideline is poorly defined

and very difficult to monitor accurately11

CEMEX collected samples at six locations (Figure 4) south of the

existing quarry during 2006 and 2007 using Frisbee Gauges12

.

Figure 4

Frisbee Dust Deposition Gauge Monitoring Locations

The results of the Frisbee gauge monitoring show that dust deposition rates are generally low throughout

the monitoring period and well below the nuisance guideline of 200-250 mg/m2

/day.

11

Vallack.H.W (1995) A field evaluation of Frisbee-type dust deposit gauges, Atmospheric Environment, Vol 29, Issue 12

12

Dust from the collecting bowl and foam disc was washed out after a one month period into the collecting vessel using 1 litre of deionised water, before replacement with a clean collection container

containing 200ml of 2methoxyethanol solution and wrapped in black plastic to prevent algal build-up. The volume of the collected liquid was measured to allow the determination of rainfall during each

period. The liquid was filtered to remove the solid and the weight gain determined gravimetrically. An aliquot of the filtrate was evaporated to determine the dissolved solids content by gravimetric

determination.




Assessment

Table 2

Results of Dust Deposition Monitoring 2006/07 (mg/m2/day)

Monitoring

location1

Monitoring

location 2

Monitoring

location 3

Monitoring

location 4

Monitoring

location 5

Monitoring

location 6 Average

Feb 06 18 11.1 25.3 18 17 3.1 15

Mar 06 51 3.3 19 23 85 13 32

Apr 06 22 13.8 12.1 31 - 8.5 17

May 06 56 70 66 29 29 30 47

Jun 06 148 79 31 73 38 172 90

Jul 06 - 74 36 74 27 480 138

Aug 06 21 63 46 54 26 251 77

Sep 06 250 160 95 140 110 300 176

Oct 06 130 62 47 20 120 68 75

Nov 06 45 30 16 12 25 64 32

Dec 06 9 41 27 20 25 170 49

Jan 07 69 19 31 41 25 120 51

Feb 07 30 20 27 29 60 52 36

Mar 07 7 3 8 5 4 - 5

Apr 07 46 32 51 35 27 33 37

May 07 19 33 20 49 32 115 45

Jun 07 89 135 63 110 84 151 105

Jul 07 135 70 15 61 102 413 133

Aug 07 96 43 37 74 92 18 60

Sep 07 51 - 27 52 36 39 41

Oct 07 58 14 44 43 63 33 43

Nov 07 150 140 20 52 11 32 68

Dec 07 150 19 23 11 21 23 41

Average 80 58 34 46 48 95 61

1.3 Local Meteorological Environment

The risk periods for dust generation always directly relates to meteorological conditions. Analysis of

precipitation, potential evapotranspiration, winds and atmospheric stability can give an indication of

periods when dusty materials can dry quickly and dust control measures such as water spraying may be

required. The greatest risk of dust generation is when drying conditions occur although dust generation is

not restricted to these periods and can also occur during dry freezing conditions when dust control by

damping down is not effective.

Wind rose data has been obtained from Church Lawford Weather Station, approximately 13 km north of

the site. The wind rose illustrates that the prevailing winds in the area are south-westerly with

approximately 40% of winds occurring in the southerly, south-south-westerly, and west-south-westerly wind

sectors. Easterly and northerly winds are notably very light with a very low frequency of strong to gale force

winds.




Assessment

Figure 5

Wind rose for Church Lawford - Jan 1999 - Dec 2007

N.G.R 4456E 2736N - Altitude: 107metres AMSL

Southam, situated to the south-west of the site will be unaffected by prevailing winds and has a very low

likelihood that winds will occur from the direction of the quarry. Stockton, to the north-east of the site, will

be down-wind of the prevailing south-westerlies but at a significant distance away from the extension area.

To assist in characterising the susceptibility of dust sensitive receivers in relation to prevailing

meteorological wind conditions Table 3 identifies the potential risk from dust dispersal as high for

receivers who receive over 20% wind frequency and are located less than 100m from the dust source. In

comparison, receptors that are over 250m from the dust source can be considered to have a very low

susceptibility.

Table 3

Meteorological Susceptibility Rating

Wind Frequency

Distance from dust source to sensitive receiver

<100m 101-175m 176-250m >250m

<6% Low Low Low Very Low

6 - 13% Moderate Low Low Very Low

13 - 20% Moderate Moderate Low Very Low

>20% High Moderate Low Very Low




Assessment

Rainfall data for the area has been obtained from the Stratford upon Avon weather station, 25km south

west of the site. Periods of rainfall combined with reduced temperatures and hours of sunshine ensure that

potential evapotranspiration is exceeded and therefore drying conditions are unlikely to occur. During

these periods materials are often handled damp and the generic meteorological risk of potential dust

emissions from the site is therefore very low.

Table 4

Average monthly weather data for Stratford Upon Avon Weather Station

Period of data: 1981 - 2010

Month Max Temp

(deg C)

Min Temp

(deg C)

Days of Air

Frost

(days)

Sunshine

(hours)

Rainfall

(mm)

Days of

Rainfall

>=1mm

(days)

Jan 7.3 1.0 11.2 52.3 53.8 11.3

Feb 7.8 0.6 12.4 68.1 39.0 9.3

Mar 10.8 2.3 8.1 101.9 43.9 10.1

Apr 13.6 3.5 5.1 143.1 49.0 9.7

May 17.0 6.4 1.1 177.1 52.4 9.8

Jun 20.1 9.3 0.1 171.1 52.4 8.5

Jul 22.6 11.3 0.0 189.6 58.3 8.4

Aug 22.1 11.0 0.0 179.2 58.1 8.9

Sep 19.0 9.1 0.2 131.8 53.2 8.9

Oct 14.6 6.5 2.1 101.3 65.0 11.0

Nov 10.2 3.2 6.7 58.6 59.9 10.9

Dec 7.4 1.1 11.7 44.9 57.3 10.7

Year 14.4 5.5 58.7 1418.9 642.3 117.4

The rainfall data illustrates that the area receives an average rainfall when compared to the rest of the UK.

The area typically experiences rainfall on 117 days of the year (30 percent of the time).

1.4 Neighbouring Dust Sensitive Receivers

The extension area covers approximately 55 hectares of agricultural land located between Southam and

Stockton. The site currently comprises a series of fields in arable agricultural production. The fields are

delineated by hedgerows and hedgerow trees. The site also includes belts of advance screen tree planting

in the south. The site slopes gently from west to east.

At its closest point the site is situated approximately 150m to the north-east of Southam, 350m south-west

of Stockton. The extension area adjoins the A426 to its north-western boundary across the road from the

existing Southam Quarry Workings and site and buildings of the former Southam Cement Works. The

northern, eastern and south-eastern boundary of the site adjoins agricultural fields.




Assessment

The site and its surroundings are rural in nature. The nearest residential properties lie along Merestone

Close, Southam. The proposed extension area is screened to the west by a wide tree shelter belt along the

A426 which provides an excellent wind break.

Neighbouring activities around the Griffins Farm extension can be categorised in relation to their dust

sensitivity. Any increases in ambient dust levels will have varying degrees of potential impact dependant on

the type and sensitivity of the receiver. Dust deposition on agricultural land, for example, is likely to have a

much lower impact than similar levels of dust falling on a paint spraying or food processing facility, where

very small amounts of dust can impact activities. Although this principle does not always apply, Table 5

categorises dust sensitive receivers and highlight their risk in relation to potential dust sources.

Table 5

Dust sensitive activities

High sensitivity Moderate sensitivity Low sensitivity

Hospitals

Electronic industry

Painting activities

Food processing

Schools

Residential areas

Shops

Offices

Agricultural land excluding

market gardening

Heavy industry

Parks and open spaces

Figure 6 shows the location of potential dust sensitive receptors and Table 5 the dust sensitivity of these

locations.




Assessment

Figure 6

Location of the nearest dust sensitive receivers

Table 6

Potential Dust Sensitivity of Neighbouring Receivers

Indicative Receptor NGR Description

Indicative

Dust

Sensitivity

1 Merestone Close, Southam SP420625

A cul-de-sac of residential properties adjacent

to the A423 Southam bypass. Well screened by

a mature hedgerow.

Moderate

2 Greenacres SP416629

A residential property to the rear of a petrol

station adjacent to the A423. Screened by trees

and fencing.

Moderate

3 Tollgate House, Stockton SP433640

An isolated residential property adjacent to the

A426 and well screened to the south by mature

trees.

Moderate

4 26 Laurel Drive, Stockton SP433636

A quiet residential cul-de-sac adjacent to

agricultural fields on the south-western part of

Stockton.

Moderate

5 St Michael’s Crescent,

Stockton SP435635

Adjoining playing fields and screened by trees

this residential street has approximately 14

properties.

Moderate

6 Laurels Farm SP432627 An isolated farm and farmhouse surrounded by

extensive agricultural land. Moderate




Assessment

Although a number of surrounding activities are classed as Moderate sensitivity, this does not indicate that

they are likely to be impacted by the proposed development. Extensive research and study at other

quarries has shown that the likelihood of dust impacts occurring at distances over 100m from a site is very

low as the majority of fugitive dusts are likely to be greater than 30µm in size and will deposit easily within

100m of the source13

.

No receptors lie within 100m of the edge of the excavation area and only one location is within 250m as

measured at the nearest point from the edge of the operating area/void. These properties risk of an

increase in background dust when quarrying activities are located closest to the sensitive receiver. This,

however, is a worst case scenario and is only likely to occur for limited periods of time when the site is

excavating close to the properties and when winds are occurring from the site towards the receiver. During

these periods careful management and proactive dust control with water will prevent any contribution to

background dust.

Table 7

Meteorological Susceptibility of Potential Dust Sensitive Receivers

Indicative Receptor NGR

Bearing

from

nearest

Phase

Approx.

closest

distance

from

nearest

phase (m)

Percentage

of time

wind

frequency

Meteorological

Susceptibility

(from 3)

1 Merestone Close, Southam SP420625 SW 150 6% Low

2 Greenacres SP416629 W 500 4% Very Low

3 Tollgate House, Stockton SP433640 NNE 520 15% Very Low

4 26 Laurel Drive, Stockton SP433636 NE 370 15% Very Low

5 St Michael’s Crescent, Stockton SP435635 NE 500 15% Very Low

6 Laurels Farm SP432627 ENE 300 11% Very Low

Table 7 details the location and bearing of potential dust sensitive activities in relation to the site and this

has been compared against local meteorological conditions. Meteorological susceptibility has been

determined based on the relationship of wind direction and distance from the site. Wind frequency is

important as dust can only be dispersed by winds and deposition of dust is a simple function of particle

size, wind speed and distance. The closer the distance, the higher the potential risk of dust impact.

13

Mineral Planning Statement 2: Controlling and Mitigating the Environmental Effects of Minerals Extraction in England. Annex 1: Dust




Assessment

The prevailing winds in the area, in common with most of the UK, are south-westerly, thereby dispersing

any potential dust emission to the north-east of the site. As northerly winds are very infrequent, only

occurring for 6% of the time, the likelihood is that properties to the south of the site will not have any risk

of potentially elevated dust levels for 94% of the time. The risk is then further reduced as in the UK, rain or

damp conditions occur for at least 30% of the time, thereby preventing any potential dust emissions.

The meteorological susceptibility analysis identified that the majority of surrounding areas have low, or

very low susceptibility. At all locations the potential susceptibility will only occur when operations occur at

the closest point of the quarry development. In these circumstances, especially when working in the

southern part of the site, CEMEX has indicated that it will take extra care to monitor meteorological

conditions and will apply additional dust control measures such as water bowsers to prevent any potential

dust emissions. There are no known ecological sensitive areas close to the site.

The micrometeorology of the site is affected to a great extent by the presence of screening provided by

existing vegetation. This screening, especially along the A426, forms a very effective wind barrier which

will suppress dust emissions by reducing wind velocities hence reducing the level of wind erosion. Tree

lines can also act as an efficient dust filter and can be a useful dust control safeguard. The planted tree

screen to the south of the extension area will form an effective screen which will increase in efficiency as

the vegetation continues to mature thereby providing additional protection.

Studies by the United States Environmental Protection Agency14

suggest that a wind break of 50 per cent

porosity, which is five times the length of the source width, of height equal to the emission height and

positioned at a distance twice the height of the source, would reduce dust emissions by up to 60 per cent.

The closest potentially dust sensitive receivers downwind of the prevailing south westerly winds are over

350m at its nearest point. Tree screening and the use of screening bunds will protect the location and the

tree screen along the A426 will further reduce wind speeds and therefore potential wind related dust

emissions.

14

Relative effectiveness of chemical additives and wind screens for fugitive dust control. (2006) Drehmel D

, Daniel B, Carnes D




Assessment

Figure 7

Existing vegetation screen along the A426




Assessment

2. Assessment

2.1 Site Design and Sources of Dust

The extension area covers approximately 55 hectares of agricultural land between Southam and Stockton.

The site comprises a series of fields currently in arable agricultural production. The fields are delineated by

hedgerows and hedgerow trees. The site also includes a small belt of advance screen tree planting. The

site slopes gently from west to east.

The extension area will include a tunnel under the A426 with a 1km conveyor transporting mineral from

the extension area to the existing processing area. An occasional access traffic route will be made from

the A426 into the quarry although all processed mineral will continue to leave the Southam site through

the existing access from the A423.

Site design considerations which will reduce the dust emission potential at Southam include:

a covered conveyor will connect a new crusher at the Griffins farm site with the existing processing

area;

maintaining the existing tree screening, especially in the south of the extension area, to reduce wind

speeds and entrain any fugitive dust;

maintaining the processing plant in the main Southam site, well screened from neighbouring

activities;

placing soil storage bunds around the plant site to provide some protection from wind;

once well established the site will use a field conveyor to transport the mineral from the extraction

area to the Griffins Farm crusher thereby reducing vehicle movements across the site;

Dust is ubiquitous in the environment being dispersed by wind from a wide range of both natural and

anthropogenic sources. The existing dust environment around Southam is therefore likely to contain dusts,

typically from local agricultural activities. Dust is also one of the most complex pollutants to assess

because of the infinite variation of sources, particle shapes, sizes, density and their resultant aerodynamic

qualities. These qualities also determine the likelihood for a particle to be suspended by wind, transported

and potentially deposited. Fugitive dust particles generated from materials handling typically range in

diameter from 30 to 300 µm. The largest particles, because of their weight, generally travel only short

distances and deposit near to the emission source. The smaller particle sizes however can travel further,

especially during dry windy periods. The higher the wind speed the further a particle can be dispersed and

the greater the size of particles that can be kept aloft.




Assessment

As the existing dust environment is influenced by so many natural and anthropogenic sources it is often

very difficult to source-attribute any variations in the monitored background levels. Dust events are often

caused by the deposition of dusts which have been transported over great distances. According to the

Meteorological Office, desert sands from the Sahara are frequently seen in the United Kingdom in the

spring, though they can occur at other times as well. These dusts tend to be washed out of the air by

rainfall and can be seen on cars, window sills and other flat surfaces.

The potential sources of dust at Southam Quarry can most easily be classed by the size of the emission

area. The loading of trucks in the plant site , for example, can be classed as a point source as dust has

the potential to be generated in a defined location. Emissions from vehicles travelling to the excavation

area for infilling , in comparison, can be classed as line sources as emissions can occur along the entire

route.

Table 8

Potential Sources of Dust

Point Sources

Excavation/Loading/

Unloading

Clay has a high moisture content which

will help reduce any potential emissions

during material handling.

Processing plant The existing processing plant has the

potential to generate point source

emissions of dust although this is well

controlled with containment and

suppression.

Line sources

Haul road movements Occasional vehicle movements have the

highest potential for dust emission but

will be infrequent and the haul road will

be conditioned with water where

required.

Conveyors One established a field conveyors will

be used, covered and located close to

the ground and will transport material

with a high moisture content reducing

the potential for wind whipping.

Area sources

Soil handling Soil handling will be managed carefully

to ensure the risk of dust emissions is

minimised.

Stockpiles The existing stockpiling and blending

areas at the main Cement Works site

will be used which re well screened and

protected from wind whipping.

Vehicle movements on haul roads are likely to present the highest risk of dust nuisance as emissions can

increase rapidly in proportion to vehicle speed and traffic volume but despite this risk, research has shown

that the majority of 50 µm particles, typically produced from un-surfaced roads, deposit rapidly within 8m.

For 20 µm particles a similar decline occurred at 30m15

. The movement of soil and the creation of bunds

15

Particle re-suspension from an asphalt road caused by car and truck traffic Atmospheric Environment 7 p291-309




Assessment

are also likely to present a high dust nuisance risk as this activity occurs close to sensitive receivers when

machinery movements can lift dust into the air. Disturbed soils, with no vegetation cover, can also become

exposed to strong winds.

Particles smaller than 10 µm, PM10

and PM2.5

, can usually remain suspended in the atmosphere for very

long periods of time. They are, however, less likely to cause dust nuisance or disturbance. Little evidence

exists to show that quarrying is a significant source of PM10

or PM2.5

emissions as the majority of fugitive

dust from quarries are likely to be greater than 30µm in size and will deposit within 100m of the source16

.

The National Atmospheric Emissions Inventory17

for PM10

emissions shows that the majority of emissions

are from sources other than quarrying.

The various types of dust source at Southam require very different approaches to control. In common with

other management strategies, ‘prevention’ is better than ‘cure’. Generally there are four ways of reducing

dust, although distinction between them is not always clear:

foreseeing problems and avoiding them;

preventing its escape into the atmosphere;

recapturing it once it is in the air;

reducing its spread once it is airborne.

The following factors will influence the rates of emissions from potential activities at Southam Quarry:

the moisture content of any access routes to the extracted area;

the local meteorology and the exposure of the site to wind erosion.

Dust has the potential to have an impact on the environment in relation to both nuisance and health, but

these are quite separate issues, and the methods used to measure them are different. Dust nuisance is

typically associated with the build-up of potentially unsightly deposits of dust/grit, making their

appearance objectionable. Health impacts relate to the potential for adverse effects on the health of

individuals.

The site generally has a high moisture content which will help ensure that the potential for dust emissions

are considerably reduced when compared to dry sites.

16

Mineral Planning Statement 2: Controlling and Mitigating the Environmental Effects of Minerals Extraction in England. Annex 1: Dust 17

http://www.naei.org.uk/




Assessment

2.2 Site Dust Management

Quarrying for limestone and clay at Southam has been undertaken since the early 1800’s. Initially, the

extracted mineral was used in the production of agricultural lime and then from around the 1840’s for use

in the manufacture of cement. Southam Cement works was established around this time. Limestone and

clay extracted from Southam Quarry has been used in the manufacture of cement at both the Southam

Works and Rugby Cement Works. Since the closure of Southam Cement Works in 1999 all limestone and

clay extracted from Southam Quarry has been transported to the Rugby Works for use in the production of

cement.

The extraction of limestone and clay will be undertaken using the same techniques as the current

operation. A mechanical excavator will extract materials which will be transferred by dump truck to a new

mobile crusher located within the quarry void. The crushed material will then be transferred by covered

conveyor to the existing processing area at the former cement works before being transported by conveyor

into a building for blending and storage. From here the material is loaded into articulated road trucks for

onward transportation to the Rugby Cement Works. The trucks would utilise the existing site entrance, and

there would be no change to the recent average rates of output, and no change to the established pattern

of vehicle movements.

CEMEX operate a large number of sites similar to Southam across the UK and employ site environmental

management systems to co-ordinate controls and procedures. Southam is currently certified to the

internationally recognised BS EN ISO14001:2004 Environmental Management System standard, and

these controls require the company to demonstrate its compliance with regulations and measure its own

environmental performance. It also allows a more proactive response to be made to potential site

environmental impacts.

At Southam, as at all CEMEX sites, the site manager will be responsible for ensuring effective dust control

and this relies on good site operational controls such as:

identifying and monitoring the intensity of potential dust generating activities;

monitoring weather conditions during dust sensitive periods;

responding to potential and actual dust problems;

planning contingency measures;

ceasing operations when major impacts cannot be avoided.




Assessment

Good environmental performance requires effective management. CEMEX employs structured

environmental management with employees at all levels having the necessary training and instruction in

their duties relating to control of the process and emissions to air. The Site Manager will have

responsibility for ensuring that the risk of any potential dust nuisance arising from quarrying activities are

minimised. The likelihood of failure of any dust prevention management techniques is likely to be low.

A Dust Management Plan will be incorporated into the site procedures and will be continually revised as

necessary to ensure that it remains appropriate to the activities occurring at the site and that any change

in conditions relating to dust management are dealt with as part of those revisions. In particular, the

monitoring procedures and compliance actions will be updated as required by the procedures specified

within it. A summary of the dust control techniques which will be utilised at Southam Farm are outlined in

Table 8.

Table 9

Southam Griffin Farm Quarry Dust Control Plan

Soil Stripping and Handling

Soil removal will be restrict to low risk meteorological periods.

Vehicle speeds will be restricted.

Only small scale plant will be used.

The duration of the activity will be minimal.

Disturbed surfaces will be re-seeded as soon as is practicable.

Screening bunds will be created to provide protection from winds.

Extraction

The extraction of clay presents an inherently low risk of dust emission.

Field conveyors will minimise the handling of materials.

Occasional Haul road and conveyor movements

Vehicle speeds will be restricted.

Unsurfaced roads will we damped down when required using a water bowser.

Loading and unloading will occur in areas protected from wind.

Drop heights will be minimised.

All vehicle loads will be sheeted and loads inspected to ensure no potential spillages.

A water bowser and sprays will be available to moisten material if required.

Loading/Unloading

Drop heights will be kept to a minimum wherever practicable.

The materials handled will retain a moisture content.

Mobile Crushing/processing

The existing processing plant at the Southam Cement Works will be retained.

The processing of clays will ensure that dust generation is minimised.

The plant and weighbridge are damped down when required.

A mobile bowser will be available to water areas around the plant when required.

Storage/Stockpiles

Stockpiles will be sprayed with water to maintain moisture content if required.

Stockpiles will be located in areas protected from prevailing winds.

The storage areas are located away from sensitive areas.

Vehicle Movements and Housekeeping

Yard area will be kept clean.

Vehicle exhausts will be directed above the horizontal.

A road sweeper will be regularly used.

Training will be received for all employees.

Site procedures and daily records.




Assessment

Whilst there are no environmental permit requirements to undertake dust monitoring, CEMEX has followed

guidance which states that dust monitoring should be risk based and may be quantitative, semi-

quantitative, or subjective (e.g. visual). The objective of the dust monitoring is to determine whether dust

has been transported off-site in such quantity or concentration that a nuisance may occur and further

actions are required to be taken.

Should any problems arise action will be undertaken in accordance with the details in the Dust

Management Plan. In response to the need to undertake any dust monitoring’ the Site Manager (or

appropriate) shall undertake an immediate review of the management practices in order to identify and

rectify potential problems.

The results of all visual dust monitoring observations, along with remedial actions implemented and

details of who carried out the monitoring will be recorded. All personnel employed on-site will be aware of

and will undertake visual monitoring for dust throughout the working day. Daily monitoring in the form of

a visual assessment will be undertaken at the site.

Any problem observed, i.e. raised clouds of dust, will be reported to the Site Manager (or the next level of

management if they are unavailable), who will be responsible for investigating the cause and

implementing any necessary remedial action. All personnel who will undertake particulate observations

will have received appropriate training, guidance and instruction in how to carry out the task.

Effective preventative maintenance will also be undertaken on all plant and equipment concerned with the

control of emissions to the air and spares and consumables will be available at short notice in order to

rectify breakdowns rapidly.

Plant personnel complete a daily site diary. This will be kept on site, and will be available for inspection.

Daily comment is made about weather conditions on site when necessary. Daily checks will be carried out

to ensure that there are no visible emissions across the boundary.

The Company works to high operating standards according to strict written procedures. In compliance

with these procedures and standards the plant will undergo daily, weekly and monthly maintenance

checks. The quarry will also have extensive management and supervision to meet the above standard. For

example, internal environmental, quality and safety audits are complemented by external quality audits

and system reviews. CEMEX also undertakes annual environmental compliance audits of all its operational

sites to assess environmental aspects, raise standards, and promote greater environmental awareness. The




Assessment

audits assess the operations with reference to the compliance with planning conditions, authorisation

conditions, legislation recognised good practice and their environmental implications. This is carried out

in conjunction with the CEMEX Sustainability Department who are responsible for the environmental

monitoring of all company sites.

2.3 Soil Stripping and Handling

At Southam, the movement of soil and overburden, and the creation of bunds are likely to present a dust

nuisance risk as this activity occurs outside the quarry void and machinery movements can lift dust into the

air. Disturbed soils can also become exposed to strong winds, especially when vehicles and machinery are

travelling at speed. Soil and overburden would be removed using a hydraulic excavator with dump trucks

being used to take the material to either create a temporary storage/screen bund to place the soil directly

on to a previously worked area for final restoration. A second hydraulic excavator would be used for

bund formation.

The soil storage mounds will be created to the heights shown on the plans and profiled using the

excavator and will be grass seeded to bind the soil to prevent any wind- blown dust arising and erosion.

2.4 Extraction

A 360º excavator will create a small stockpile of material at the working area from which a loading

shovel will pick up material and load a dump truck which will transport it to the mobile crusher located

near the tunnel under the A426. The hopper discharge height will be approximately 3.5m. For the

majority of time extraction will occur within the quarry void and will be screened from winds.

2.5 Conveyor

In addition to the potential low risk presented by the excavated material, CEMEX propose to employ

industry best practice dust control measures including the use of conveyors. A main covered conveyor will

run from the Griffins farm mobile crusher to the existing processing plant. The conveyor will have no

transfer points which will minimise dust emissions. The long conveyor will transport materials to the existing

area and create and stock pile material from where the existing plant will feed the existing system. In the




Assessment

future, once the existing Spires Farm extension has closed, the long conveyor will be connected directly to

the existing system with a new short conveyor.

During initial phases of the extension the transfer from the extraction area to the mobile crusher will be by

dump truck. Once the site is established and extraction occurs further afield the use of field conveyors will

be carefully considered to ensure quarrying best practices are applied.

2.6 Processing Plant

CEMEX propose to utilise the existing processing plant which is currently in use on the cement works site.

The plant is sited in an area which is sheltered from the prevailing wind. The plant site area and

weighbridge will be damped down as required using a mobile bowser. In addition, a new mobile crusher

will be employed within the Griffins Farm site located within the void. The new mobile crusher would be

fed via a feed hopper.

2.7 Stockpiles

Stockpiles will be generally sheltered from prevailing winds by existing vegetation and soil storage bunds.

Profiling and minimised drop heights will reduce the likelihood of wind whipping. Loading to and from

stockpiles will also be carried out in such a manner as to minimise wind-borne dust e.g. taking place at

sheltered points. Periodic conditioning with water will occur depending upon weather conditions.

2.8 Loading/Unloading

Vehicles transporting mineral from the site will be loaded within the sheltered plant site area and when

arriving or leaving the site with loads that may give rise to dust in transportation will be required to be

sheeted. No loaded lorries shall leave the site unsheeted. The access road from the A424 to the existing

processing plant is hard surfaced and is regularly swept by road sweepers.

2.9 Vehicle Movements

The site is accessed through the existing site entrance on the east side of the A423. On the western side of

the A423 is a residential access road serving approximately 40 properties at the Model Village. The site

entrance has been constructed to accommodate HGV traffic associated with the former cement works and

continues to be used for mineral extraction and other activities.




Assessment

HGV movements between the Southam Quarry site and Rugby Cement works are subject to a formal

vehicle routing agreement (a Section 106 Agreement) between CEMEX and the local planning authority,

Warwickshire County Council. Delivery traffic will be routed along the A423 upon leaving Southam and

when travelling from Rugby. This will take traffic through the villages of Long Itchington, Marton and

Princethorpe which line the road.

It is proposed that the application site would be operated as an extension of the existing Southam Quarry

with production/output continuing at current levels. Therefore, the proposal would not result in an

increase in vehicle movements from the site associated with the transport of limestone and clay to the

Rugby Cement Works. Vehicles would continue to access the site via the existing site access onto the

A423, Southam Road.

3. Potential Impacts

An assessment of the extension area has been undertaken and mitigation and control measures have

been described and compared against industry best practices. It has been concluded that clay extraction

has an inherently low risk of associated dust emissions. The potential risk of emissions from the Griffins

Farm extension are directly related to emission sources, inherent risk and the resultant control measures. A

comparison with the classification of potential emissions in Table 10 highlights that the potential risk from

this development can be classified as ‘low’.

Table 10

Risk of Potential Emissions

Potential Risk Description

High

The proposal has a very high risk of emission. Management and control measures may be

inadequate to control all identified sources of emission. It is very likely that the proposed site will

cause exceedances of Local Air Quality Objectives

Moderate

The management and control measures appear adequate but the proposals have a high inherent

risk. Emissions could occur as a result of a procedural or design failure. There is a known potential

for emissions to cause exceedances of Local Air Quality Objectives but exceedances are not

certain.

Low

The proposal has inherently low risk, is well managed and controlled and /or has extensive

regulatory controls to minimise emissions from all emission sources. There is likely to be no

discernible change in local air quality as a result of the proposal.

By comparing the potential risk of an emission with the sensitivity and susceptibility information detailed in

Table 6 and Table 7 an overall likelihood rating can be derived. The potential likelihood of dust related

impacts on the closest dust sensitive receivers has been assessed and is presented in Table 11.




Assessment

Table 11

Potential Risk of Air Quality Impacts from Southam Quarry

Receptor Sensitivity

(from table 5)

Susceptibility

(from table 7)

Emission

(from table 10) Likelihood

1 Merestone Close Moderate Low Low Low

2 Greenacres Moderate Very Low Low Low

3 Tollgate House Moderate Very Low Low Low

4 26 Laurel Drive, Stockton Moderate Very Low Low Low

5 St Michael’s Crescent Moderate Very Low Low Low

6 Laurels Farm Moderate Very Low Low Low

As the potential risk of emissions from the site is ‘low’, at locations with a ‘low’ or ‘very low’ susceptibility

and ‘low’ sensitivity the overall classification of the likelihood of an impact is also classed as ‘low’.

Risk ratings have been derived from assessment of the following:

the potential risk of dust emissions associated with the proposed activities;

the distance from potential dust emission sources to dust sensitive receivers;

the frequency of winds from potential dust emission sources to dust sensitive receivers.

The assessment has identified one area as having a low susceptibility of potential dust impacts during

limited periods when the site activities are at their closest to the sensitive receiver; Merestone Close, at the

northern edge of Southam. During the periods when the site is working in areas close to sensitive

properties the potential for dust related impacts will be further minimised by careful use of identified dust

control techniques, the application of water and close observation of meteorological conditions.




Assessment

4. Conclusion

Quarrying activities at Southam do not require a Permit under the Environmental Permitting (England and

Wales) Regulations 2010 as the moisture content of the excavated material from clay operations ensures

that dust emissions are classed in legislation as ‘trivial’. CEMEX are not aware of any reported dust related

incidences at Southam.

The proposed extension at Southam will utilise the same processes and facilities as currently exists

including retaining the well screened processing area, providing screening bunds and shelter belts, and

locating new covered conveyors and haul roads away from potentially dust sensitive receivers. The site is

currently independently certified to the internationally recognised ISO14001:2004 which requires

continual improvement and provides additional safeguards and a rigorous demonstration of compliance

with all legal requirements.

There are no highly dust sensitive activities located near the proposed activities and an analysis of

activities and sensitivities surrounding the site has been undertaken. An analysis of wind patterns in the

area has also been undertaken and used to calculate susceptibility to dust dispersal. During these periods

when the site is working in areas close to sensitive properties the potential for dust related impacts will be

carefully managed as CEMEX has indicated that it will take extra care to monitor meteorological

conditions and will apply additional dust control measures such as water bowsers to prevent any potential

dust emissions.

An assessment has been made of all sources of dust from the site and the resultant management controls

which will be in place to ensure that the potential for any emissions is low. The Griffins Farm extension is

well screened by existing vegetation including evergreen shrubs which will ensure year round screening.

The proposed activities at Griffins Farm will have a low potential to cause dust related disturbance as:

the handling of clay at quarries is not normally likely to result in the release into air of particulate

matter;

the site design will ensure there is a negligible risk of potential dust emissions;

the prevailing winds and rainfall in the area ensure a low risk of potential impact on the nearest dust

sensitive receivers;

the distance to dust sensitive receivers far exceeds that identified in assessment guidance criteria;

the industry best practice design includes the use of covered conveyors and extensive dust control

measures.

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