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 
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.




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