NOISE, AIR AND ODOUR IMPACT ASSESSMENT FOR IMPRESS LTD. PROPOSAL FOR OPERATION OF A REGENERATIVE THERMAL OXIDIZER SALHOUSE ROAD, NORWICH AUGUST 2008

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1 NOISE, AIR AND ODOUR IMPACT ASSESSMENT FOR IMPRESS LTD. PROPOSAL FOR OPERATION OF A REGENERATIVE THERMAL OXIDIZER SALHOUSE ROAD, NORWICH AUGUST 2008

2 1 INTRODUCTION Site Description and Environmental Setting Project Description RTO Technology Scoping Process Overview of Methodology NOISE Introduction Planning Policy Guidelines Overview General Methodology for Noise Measurement and Impact Assessment Background Noise Survey Survey Design Noise Monitoring Procedures Background Noise Survey Results Noise Modelling Modelling Methods Modelling Results Noise Impact Assessment Planning Policy Guidance PPG 24: Planning and Noise (1994) BS Noise Mitigation Measures Noise Impact Assessment Summary and Conclusions AIR QUALITY AND ODOUR Project Scope Identification of Pollutants to be Assessed Legislative and Policy Context Planning Policy and Guidelines Air Quality Standards and Guidelines Local Air Quality Background Data for Air Quality Assessment Air Dispersion Modelling Model Selection Model Input Parameters and Key Assumptions Dispersion Modelling Results Assessment of Air Quality Impacts Assessment of Odour Nuisance Air Quality and Odour Assessment Conclusions Appendix A Drawings Appendix B Scoping Meeting Power Point Presentation Appendix C Baseline Noise Survey Appendix D Noise Mitigation Measures Appendix E Air Quality Modeling Report Appendix F RTO Technical Manual 2

3 EXECUTIVE SUMMARY This report presents the results of noise, air quality, and odour impact assessment carried out by Harrison Group Environmental Limited for the operation of a proposed regenerative thermal oxidiser (RTO) by Impress Ltd. at their Salhouse Road plant in Norwich. The objective of the survey was to evaluate potential impacts of the proposed RTO on identified residential sensitive receptors in the area of the site. The specific objectives of the assessment were as follows: Noise: assess the possible noise impacts associated with operation of the RTO on local sensitive receptors. Further, specific measures to mitigate potential noise impacts, as needed, are presented and discussed. Air Quality: assess the potential changes to local air quality and the potential for nuisance odours that may occur as a result of the operation of the RTO. To address these objectives the following tasks were undertaken: Noise Background Noise Survey: The background survey measures the noise levels in the absence of the RTO contribution, and is a necessary requirement for the noise impact assessment. It involved collection of noise data at three identified receptor locations during representative daytime and night time periods. Noise Modelling: Noise emissions and transmission as a result of operation of the RTO was modelled using CadnaA (Computer Aided Noise Abatement) software designed specifically for the calculation, assessment and predication of noise exposure. Specifically, the modelled specific noise from the RTO at the identified receptor points was added to the measured baseline levels in order to evaluate if the operation of the RTO would significantly change the noise environment. Noise Impact Assessment: The recorded noise data and modelled levels were interpreted relative to the Noise Exposure Categories presented in PPG24 and the methodology presented BS4142 in order to assess the significance of the recorded noise levels. Based on the data collected and results of the analysis, the following conclusions were made: Background noise levels at night recorded at the residential locations near the facility are relatively high. In the context of PPG24, these locations would be classified as NEC C. The primary background noise sources are road traffic noise. Added to measured background levels, the modelled specific noise from the future operation of the RTO would increase the receptor point background noise levels by < 1 db, and therefore would not result in a perceptible increase of noise levels compared with background. However, in the event that tonal characteristics are associated with the noise source, according to BS4142, the receptor point noise levels should be adjusted by 5 db to assess the potential for nuisance. Without mitigation, the night-time tonally adjusted specific noise from the RTO is 47 db, which exceeds the WHO outdoor residential threshold of 45 db. In this case, it would be prudent to include a noise barrier around the RTO to reduce the risk of annoyance. Modelling results suggest that a noise barrier height of 3 metres would reduce the RTO specific noise at the closest receptor, including tonal adjustments, to 44.1 db, which is less than the 45 db threshold. 3

4 Air Quality and Odour Air quality dispersion modelling was carried out using the computer model ADMS 4, developed and supplied by Cambridge Environmental Research Consultants (CERC). Modules within the model take account of the projected emission rates, stack dimensions, local meteorology, effect of complex terrain and nearby buildings. ADMS 4 has been used on many occasions for the modelling of emissions for planning and PPC (Pollution Prevention and Control) purposes and air quality assessments using ADMS have generally been accepted by the Environment Agency. Potential odour impacts were assessed by comparing the modelled air concentrations of solvent compounds with published odour thresholds. Based on the data collected and results of the analysis, the following conclusions were made: The receptor point concentrations are less than 0.5% of the health based Air Quality Standards (AQS) or Environmental Assessment Levels (EAL). Further, the long-term modelled concentrations are less than 1% of published EALs for the protection of ecological systems. Based on these considerations, it is concluded that the contribution to air quality from stack emissions will not result in significant adverse impacts to human health or ecological receptors. The process contribution plus the background levels are less than the AQS or EAL levels, and the process contribution contributes < 2% of background in all cases. Therefore, it is concluded that the contribution to background levels from stack emissions is highly unlikely to result in AQS or EAL s being exceeded. The stack considered in this assessment was 15 metres, which is the measured height of the RTO stack. Since the modeled levels based on a 15 metre stack height were well within AQS or EALs, a taller stack is not warranted at the site. The modelled levels of the individual Volatile Organic Compounds (VOCs) are less than the reviewed odour thresholds. This suggests that it highly unlikely that stack emissions from the RTO would result in odour complaints. It is recognized that there can be uncertainties in the assessment of odour data. This is related to variability in values of odour thresholds, differences in individual sensitivity to odour perception, possible synergistic or additive effects of compound mixtures (this could increase or decrease the perceived odour), and desensitization to odour perception over time. Historically, there have been few odour complaints related to emissions from the plant after the recuperative oxidiser was installed, as discussed in the IPPC application. Since the RTO will improve the air quality abatement capabilities, this should result in lower levels of VOC emissions as compared with the recuperative system. As such, this increases the confidence in the conclusion that odour complaints are unlikely based on operation of the RTO. 4

5 1 INTRODUCTION This report presents the results of a noise, air quality, and odour impact assessment carried out by Harrison Group Environmental Limited for a proposed regenerative thermal oxidiser (RTO) to be operated by Impress Ltd. at their Salhouse Road facility in Norwich (herein referred to as the site ). The work detailed in this report was undertaken on behalf of Impress Limited, in accordance with written instructions from Andrew Rope, of Impress Ltd., and Harrison Environmental Consulting proposal (Ref. EN12885 dated 31/03/08). This report is intended to support Impress Ltd. s planning application to install and operate a regenerative thermal oxidizer (RTO) as an air pollution control technology, to replace the existing recuperative thermal oxidizer at the site. Further, the report also supports the data requirements for a variation on the existing Local Authority PPC (LAPPC) permit (permit number A ) to install and operate the RTO at the site. The report is presented in the following Sections. Section 1.1 presents a description of the site setting and Section 1.2 presents a brief overview of the proposed project and development layout plans. The scoping process applied in framing the key environmental issues and developing the approach and methodology for the assessments is given in Section 1.3. Section 1.4 provides an overview of the assessment methods applied. Sections 2 and 3 present the details of the noise and air quality and odour impact assessments respectively, including regulatory drivers, guidance and methodology, results, data analysis and interpretation, and recommendations for mitigation. The overall conclusions and recommendations of the report are detailed in Section Site Description and Environmental Setting The site is located on Salhouse Road, Norwich, adjacent to Sprowston Retail Park. A site location plan is given as Drawing DR/EN12882/001/JS (refer to Appendix A). Land use in the vicinity of the site is shown on Drawing DR/EN12882/001/JS. As shown, adjacent land-use to the north, east, and west of the site are industrial, with residential areas located to the south, across Salhouse Road. Other, less proximate, residential areas are located to the north and west, approximately 500m from the site. Two Schools are in close proximity to the site, one on the adjacent side of Salhouse Road, Southwest of the site, in addition another school is present northwest of the site both approximately 200m from the site boundary. There are no hospitals or nursing homes in close proximity to the site. Relative to possible ecological receptors, Mousehold Heath and Lion Wood Local Nature Reserves are situated within 2km of the site. St Jame s Pit is situated within 2k of the site and is listed as a SSSI (Drawing DR/EN12882/005/JS). 1.2 Project Description The specific proposal is to install and operate a regenerative thermal oxidiser to replace the existing recuperative thermal oxidiser at the site. Thermal oxidizers destroy air toxics and Volatile Organic Compounds (VOCs) that are discharged in industrial process exhausts through the process of high temperature thermal oxidation. VOCs are converted to carbon dioxide and water vapour and released energy is recycled in the process. This reduces gas consumption, thereby reducing greenhouse gas emissions and operating costs. 5

6 The two most common methods of recycling energy in thermal oxidisers are regeneration and recuperation. Regeneration refers to regenerating the heat of a large thermal mass, specifically stoneware beds. Thermal oxidizers employing this method are called Regenerative Thermal Oxidizers (RTO). Recuperation refers to transferring heat directly from the outgoing air stream to the incoming air stream via heat exchangers. Thermal oxidizers employing this method are called Recuperative Thermal Oxidizers. Currently, Impress Ltd. operate a recuperative thermal oxidisers at the site, and are proposing to replace this with an RTO. RTO presents a significant improvement to the existing recuperative oxidiser relative to environmental performance, since it will result in significantly greater destruction efficiency for volatile organic compounds, thereby reducing the VOC emission levels, and a reduction in the combustion of natural gas, reducing greenhouse gas emissions. A brief overview of the RTO technology is presented in Section A comparison of the performance and operating parameters of typical RTO compared with recuperative oxidisers is presented on Table 1-1. Detailed technical specifications of the RTO to be installed and operated at the site are contained within the Operators Manual for the equipment, presented in Appendix F. The key technical information relative to the assessment of environmental impacts has been reviewed and utilized in this assessment. Type of Thermal Oxidiser Feature Recuperative Regenerative Destruction efficiency of VOCs + HAPs (%) Maximum heat recovery (%) Design temperature of system (ºC) Insulation of combustion chamber yes yes Retention time of oxidation process (s) Oxidation Temperature (ºC) Table 1-1 Comparison of Typical RTO vs Recuperative Oxidiser System RTO Technology A schematic of the RTO technology is presented as Figure 1-1 below. A simplified flowchart of the RTO process is given as Figure 1-2. Figure 1-1 Schematic of RTO Technology 6

7 Briefly, process gas with VOC contaminants enters the Twin Bed RTO through an inlet manifold. A flow control valve directs this gas into an energy recovery chamber that preheats the process stream. The process gas and contaminants are progressively heated in the first stoneware bed as they move toward the combustion chamber. The VOCs are then oxidized in the combustion chamber using heat from a natural gas boiler. Further energy is released in the combustion chamber since the oxidation process is an exothermic reaction. From the combustion chamber, the heated gas passes over the second stoneware bed. The stoneware bed is heated and the gas is cooled so that the outlet gas temperature is only slightly higher than the inlet temperature. The incoming gas is then switched via a flow control valve to the (now heated) second stoneware bed, preheating the VOC laden gas before it moves to the combustion chamber. Since the gas has been preheated, the additional energy requirements in the combustion chamber are reduced relative to the first pass. The flow control valve switches and alternates the stoneware beds so each is in inlet and outlet mode. If the process gas contains enough VOCs, the energy released from their combustion, and appropriate switching of the flow control valve, results in a significantly reduced overall consumption of natural gas, and could, at optimal efficiency achieve self-sustained operation (no additional natural gas required). The greater destruction efficiency of VOCs will improve compliance with the relevant emissions targets for VOCs stipulated in the EU Solvent Emissions Directive. Further, consumption of natural gas with the RTO is projected to be 80 85% less than the recuperative system. Therefore, this reduces the level of greenhouse gas emissions and consumption of energy resources. Based on these considerations, the RTO system would be consistent with Best Available Techniques (BAT). 7

8 Process exhaust gases (VOC) Ceramic Heat Transfer Bed RTO inlet Flow Control Valve Combustion chamber (VOC + HAP destruction) Thoroughly mixed 815ºC 982 ºC 0.3s 1.0s Ceramic Heat Transfer Bed Outlet control Exhaust stack Atmosphere CO 2 +H 2 O Figure 1-2 Summary Flow Chart of RTO Process 1.3 Scoping Process The following tasks have been conducted as part of the scoping process: A meeting was held between Impress Ltd. and David Humphrey of Broadland Council on March 18 th Based on that meeting, Mr Humphrey requested the following specific tasks to be addressed 1 : Odour: Analysis would need to be provided that demonstrates that the RTP emissions will not result in offensive odours or loss of amenity for the surrounding area and will meet Best Available Techniques (BAT). The assessment should take full account of EA Technical Guidance Note IPPC H4 Horizontal Guidance for Odour, and include odour dispersion modelling. Air Emissions: Emission rates for the replacement oxidiser would need to be provided, in reference to Sector Guidance Note IPPC SG8 Secretary of States Guidance for A2 Surface Treatment Using Organic Solvents Sector. Appropriate 1 Via from David Humphrey to Andrew Rope, dated March 19 th

9 calculation and modelling would be needed to demonstrate that emissions will be adequately dispersed and not breach air quality standards. Noise: A full noise assessment taking account of Planning Policy Guidance PPG 24 Planning and Noise and the current BS 4142, would be required. Based on the above Councils request, Harrison Group Environmental prepared a proposed scope of work to complete specific technical tasks and analysis. This was presented to Broadland Council and Norwich City Council at a meeting on May 6 th The full presentation from that meeting is appended to this report (refer to Appendix B). 1.4 Overview of Methodology The assessment of impact relative to noise and air quality was conducted by assessing the change in noise and air quality that could occur if the project was implemented, compared to the noise and air quality that would occur in the same setting if the project was not implemented (baseline conditions). Potential impact is then assessed by comparing the projected change in conditions with published environmental standards and benchmarks. The significance of potential impact is assessed based on the degree to which the projected environmental conditions comply with the standards and benchmarks. If potentially significant impacts are identified, then mitigation measures are considered. A general discussion of each of these elements is presented below. Identification of Baseline Conditions: The first step of the process was to define the baseline conditions based on a review of the site setting, project development plans, maps, data, records, information and reports obtained from statutory and non-statutory organisations, field surveys and modelling simulations. The key elements for the definition of baseline are as follows: For noise, a field survey was conducted to reflect current conditions at and in the vicinity of the site. This data was used to assess the noise environment relative to planning policies and guidelines. For air quality, background air quality data were compiled from the National Environment Technology Centre (NETCEN) database for the monitoring location closest to the receptor point being evaluated. The NETCEN data provides estimated levels of specified air pollutants at reference locations for the year 2004, as well as projected future levels, taking into consideration likely changes in concentrations resulting from changes in emissions. Assessment of Impact: There is no accepted definition of what constitutes a significant impact. The question of significance varies according to the environmental factor under consideration and the context in which the assessment is made. Assessment of the significance of an impact is made in the context of legislative or policy standards or guidelines, and, where available, published or site specific derived acceptable thresholds. Further, the following factors may also be considered: Whether it is a positive or negative impact; The scale of the change, e.g. the size of land area or number of people affected; The degree of change from the baseline situation; Whether the effect is temporary or permanent. 9

10 2 NOISE 2.1 Introduction This chapter addresses the noise implications of the proposed development as described in Section 1. Planning Policy Guidelines dictate that noise is a material consideration in assessing if developments should be granted planning permission. Given that the proposed RTO will be located outside the building, whereas the recuperative unit was indoors, it is appropriate to assess possible noise impacts relative to planning considerations. 2.2 Planning Policy Guidelines Overview This section presents a description of the legislative and policy context within which the assessment is considered. The key-planning instrument addressing noise is Planning Policy Guidance PPG24: Planning and Noise (1994). PPG24 introduces the concept of Noise Exposure Categories (NECs), ranging from A-D. Category A represents the circumstances in which noise is unlikely to be a determining factor, while Category D relates to a situation in which development should normally be refused. Categories B and C deal with situations where noise mitigation measures may make development acceptable. PPG24 is intended to allow consideration of planning applications relative to new dwellings rather than existing dwellings near noise sources. To that end, the NECs within PPG24 are not strictly applicable in the current context. However, the information may be helpful for an overall characterization of the general noise environment. In the current context, a more relevant standard for noise assessment is Planning Guidance and Standards BS 4142: 1997 Method for rating industrial noise affecting mixed residential and industrial area: This document provides guidance on the design, implementation and interpretation of noise surveys relevant to mixed industrial and residential settings. Specifically it is used to determine: a) noise levels from factories, industrial premises or fixed installations and sources of an industrial nature in commercial premises; and b) background noise levels This standard also describes a method for assessing whether the noise referred to in (a) is likely to give rise to complaints from people residing in proximate residential buildings. Table 2.1, below, summarizes the key information and thresholds associated with PPG24, BS4142, and other critical Guidelines and Standards Guideline Planning Policy Guidance PPG24: Planning and Noise (1994) Planning Guidance and Standards BS 4142: 1997 Method for rating industrial noise affecting mixed residential and industrial areas: Assessment Criteria For an A' Noise Exposure Category (NEC), PPG24 recommends a noise exposure level during the daytime (i.e hours to 2300 hours) of less than 55dB LAeq. For an NEC having a category A' status: "Noise need not be considered as a determining factor in granting planning permission, although the noise level at the high end of the category should not be regarded as a desirable level." For night time noise, an NEC A' category exposure level is given as less than 45dB LAeq. This document provides guidance on the design, implementation and interpretation of noise surveys relevant to mixed industrial and residential settings. A system of rating noise emissions is described that is based on the measurement of background noise using LA90 noise measurements compared to source noise levels measured in LAeq measurements. The differential between the two measurements, determines the likelihood of complaints. If a differential of +5dB (A) or less is resultant, then the noise is said to 10

11 Guideline Assessment Criteria be of marginal significance; if the differential is +10dB (A) or greater then complaints are likely. World Health For bedrooms, the critical effect is sleep disturbance. Indoor Organisation (WHO) guideline values for bedrooms are 30dB LAeq for continuous noise Guidelines for and 45dB LAmax for single sound events occurring more than Community Noise: times per night. Sound pressure levels at the outside facades of the April 1999 living spaces should not exceed 45dB LAeq, so that people may sleep with bedroom windows open. Table 2-1; Summary of Planning Policies and Guidelines related to Noise 2.3 General Methodology for Noise Measurement and Impact Assessment A general overview of the methodology applied for the noise impact assessment is presented below. Specifically, the following tasks were completed: Background Noise Survey The background survey measures the noise levels in the absence of the RTO contribution, and is a necessary requirement for the noise impact assessment. It involved collection of noise data at three identified receptor locations during representative daytime and night time periods. Noise Modelling Noise emissions and transmission as a result of operation of the RTO was modelled using CadnaA (Computer Aided Noise Abatement) software designed specifically for the calculation, assessment and predication of noise exposure. Specifically, the modelled specific noise from the RTO at the identified receptor points was added to the measured background levels in order to evaluate if the operation of the RTO would significantly change the noise environment. Noise Impact Assessment The recorded noise data and modelled levels were interpreted relative to the Noise Exposure Categories presented in PPG24 and the methodology presented BS4142 in order to assess the significance of the recorded noise levels. Further discussion of the background noise survey, noise modelling, and noise impact assessment is given in Section 2.4, 2.5, and 2.6 respectively. 2.4 Background Noise Survey The background noise survey (for full report refer to Appendix C) was based on the following key guidance document: Planning Guidance and Standards BS 4142: 1997 Method for rating industrial noise affecting mixed residential and industrial area: This document provides guidance on the design, implementation and interpretation of noise surveys relevant to mixed industrial and residential settings. Specifically it is used to determine: Noise levels from factories, industrial premises or fixed installations and sources of an industrial nature in commercial premises; and Background noise levels The background noise level refers to the A-weighted sound pressure level of the residual noise exceeded for 90% of a given time interval. Background noise levels may be obtained by taking measurements when specific noise sources are turned off, but all other conditions are equivalent to the time of operation. In this case, measurements were taken prior to the 11

12 installation and operation of the RTO and therefore themselves represent the background data Survey Design The survey design detail with respect to monitoring locations, timing, duration and frequency is summarised in Table 2-2: Location Location Reference 1 On corner of Salhouse and Daloney Roads 2 Outside 20 Falcon Road East, approximately 135m from Salhouse Road 3 Outside 41 Lone Barn Road This location is diagonally opposite the Impress Ltd factory on the corner of Salhouse and Daloney Roads. It stands on the edge of a residential estate, on flat ground. The dominant noise source is traffic along Salhouse Road with intermittent beeps from a nearby pelican crossing. During the day, reversing beeps from a forklift working on the industrial estate were noted. Outside 20 Falcon Road East, approximately 135m from Salhouse Road in a flat, residential area. The dominant noise sources were traffic and general residential noise specifically lawnmowers and strimmers. Outside 41 Lone Barn Road to the north northwest of the site. There was infrequent traffic and some bird song. Table 2-2: Survey Design Detail The locations of the survey points are shown as positions 1, 2 and 3 respectively on DR/EN1282/006/JS (refer to Appendix A). The following basic strategy was applied to complete the noise survey: Recordings were taken for a period of one hour during the day; for five minutes at night on May 2 nd Additional 15 minute night-time readings were collected from positions 1 and 2 on July 21 st Noise levels were measured at a height of 1.5 metres above ground level Night time recordings were taken between 2200 and 0700 hours The wind speed at each of the locations was measured using a handheld anemometer to make sure that the wind speed was not more than 5m/s. The temperature and wind direction was also noted at each of the three locations. Measurements were only collected in dry, clear conditions Noise Monitoring Procedures All readings were taken with a Norsonic Nor-131 Sound Level Meter. Serial No: The sound level meter was fully (i.e. factory) calibrated on 16/04/08 by Campbell Associates Ltd, certificate number The Sound Level Meter was calibrated with its own calibrator before and after each recording. Calibration levels can be found under instrument sensitivity in the measurement reports in Appendix C. The calibration certificate can be found at the end of the report in the appendix. The following parameters were measured: LAeq,T - the equivalent, continuous, A-weighted sound pressure level. This represents the constant level of noise with the same energy content as the varying 12

13 acoustic noise signal measured over the measurement period T, and is the normal parameter used for ambient and specific noise levels. LAF90,T - the level of A-weighted noise exceeded for 90% of the measurement period T, measured with a fast time weighting. This is the parameter used to describe background noise. LAFmax - the maximum A-weighted noise level measured with a fast time weighting. Wind speed and general weather conditions were noted during noise readings and these records are appended in Appendix C. Further, subjective observations regarding the characteristics of the noise (e.g. intermittent, tonal, impulsive, etc) were noted Background Noise Survey Results The complete background noise survey report, including detailed data tables and field notes from the noise monitoring events are presented in Appendix C, and summarized on Table 2-3 below. Daytime Noise Levels (db) Position 1 Position 2 Position 3 LAeq LA LAFmax Night time LAeq LA LAFmax Table 2-3 Summary of Background Noise Survey Monitoring Position 1 The dominant noise source is traffic along Salhouse Road with intermittent beeps from a nearby pelican crossing. During the day, reversing beeps from a forklift working on the industrial estate were noted. At night, noise levels were dominated by occasional cars and lorries passing on Salhouse Road. Due to the close proximity of the road, and the high volume of traffic, relatively high background noise levels were recorded at this location in the day and night, with Laeq levels of 71.2 and 62.5 db respectively. Monitoring Position 2 In the daytime, the dominant noise sources were traffic and general residential noise specifically lawnmowers and strimmers. At night, noise levels were dominated by occasional passing cars. The volume of traffic was lower than Salhouse Road resulting in lower noise levels in the day and night, with Laeq levels of 64.3 and 57.2 db respectively. Monitoring Position 3 Position 3 was the quietest of the monitoring locations. During the daytime, there was infrequent traffic and some bird song. At night, no specific noise events or traffic was recorded. Recorded Laeq in the day and night time were 51.5 and 36.5 db respectively. 2.5 Noise Modelling Noise emissions and transmission as a result of operation of the RTO was modelled using CadnaA (Computer Aided Noise Abatement) software designed specifically for the calculation, assessment and predication of noise exposure. 13

14 2.5.1 Modelling Methods Technical information and plans supplied by the client were used to model the RTO at a location equivalent to 4.3 metres from the Impress factory building façade and at a height of 1.5 metres. The main noise source at the RTO would be from the motor driving the supply fan from the process exhaust inlet. Free field noise measurements were collected by the equipment supplier, at a distance of 3 metres from the operating RTO. A value of 80 db sound pressure level at 3 metres was reported. As stated by the supplier the measurements were conducted when the supply fan was not connected to the RTO unit. In fact, the noise emissions if the fan is connected to the RTO would be expected to be lower than the reported levels. Therefore, as a conservative measure, the estimate of 80 db at a distance of 3 metres from the source was used to derive a Power Source Rating (PWL) at the source, within the Cadna software. Specifically, PWL was iteratively adjusted such that a 3 metres sound pressure level of 80 db was achieved. Based on this, the PWL was defined as 101.0dB. The point source was then inserted over an imported GoogleEarth Image to allow the adjacent buildings to be accurately mapped. All buildings are assumed to be 7.5m high to top of wall height with no noise attenuation due to reflection Modelling Results Based on the model specifications and assumptions presented above, specific noise levels (Laeq) from the RTO at the identified receptor locations were derived. The predicted specific noise levels from the RTO modelled using the CadnaA software are shown on Drawing DR/EN12882/008/JS in Appendix A and summarized on Table 2-4 below. Location 1 Location 2 Location 3 RTO (Laeq) 42.1dB 24.6dB 17.4dB Background (Laeq) Background (L90) Table 2-4 Modelled Specific Noise Levels from RTO Compared with Background As shown on Table 2-4, the specific noise from the RTO is considerably less than the recorded background noise levels at the respective locations. The potential impacts of the RTO specific noise is assessed further in Section 2.6 below. 2.6 Noise Impact Assessment In this section, the measured and modelled noise levels are interpreted relative to Planning Policies and Guidance and possible to cause annoyance to sensitive receptors. As previously discussed, the data are interpreted relative to guideline values in PPG24 and BS4142 respectively Planning Policy Guidance PPG 24: Planning and Noise (1994) As previously discussed, the key planning instrument addressing noise is Planning Policy Guidance PPG24: Planning and Noise (1994). PPG24 introduces the concept of Noise Exposure Categories (NECs), ranging from A-D, to assist in the consideration of applications for residential development. A summary of the Noise Exposure Categories within PPG24, and the associated noise ranges is summarized on Tables 2-5 and 2-6 respectively. 2 Refer to Table

15 Table 2-5; Noise Exposure Categories Table 2-6; Noise Exposure Categories (NEC) in relation to planning PPG24 is intended to allow consideration of planning applications relative to new dwellings rather than existing dwellings near noise sources. To that end, the NECs within PPG24 are not strictly applicable in the current context. However, the information may be helpful for an overall characterization of the general noise environment. As indicated on Table 2-4, the background noise levels recorded from the three receptor sites place locations 1 and 2 within NEC C (due to the night time noise levels), and location 3 within NEC A. These results indicate that locations 1 and 2 are relatively high background noise environments. In order to assess if the contribution from the RTO would significantly influence the background noise, the CadnaA software was run for the RTO noise source, and including receptor specific background levels equal to the L90 values recorded for that receptor location. The resulting modelled noise levels were compared with the measured background L90 values. The modelled values are summarized on Table 2-7 below 3. Location 1 Location 2 Location 3 RTO (Laeq) Background (L90) RTO (Laeq)+ Background (L90) Table 2-7 Effect of RTO Specific Noise on Background Levels 3 Drawing DR/EN12882/008a/JS in Appendix A shows this modelled value including the RTO specific noise, alongside the recorded background levels without the RTO for each of the three receptor locations. 15

16 As shown, the modelled noise levels with the RTO are less than 1 db greater than the background noise levels. Incremental noise levels less than 1 db are not discernible to the human ear. Therefore, the modelled data suggests that operation of the RTO would not result in a perceptible increase in noise levels at the receptor locations BS4142 This standard describes a method for assessing whether a specific noise source is likely to give rise to complaints from residents in the vicinity of the source. For the assessment procedure, the likelihood of a specific noise source causing complaints depends on its magnitude relative to background noise levels, and whether the noise source has certain audible characteristics (e.g. tonal frequency, discrete or continuous, or other distinguishable features). The background noise level refers to the A-weighted sound pressure level of the residual noise exceeded for 90% of a given time interval (LA90). Under BS 4142, the rating level for community noise is defined as the rating level for ambient noise including specific noise minus the background noise without the specific noise source. A difference of 10dB or greater indicates, complaints are likely, whereas a difference of 5dB or less is defined to be of marginal significance. A difference of 1 db or less is considered to be indistinguishable from background by the human ear. As discussed in Section 2.6.1, the noise contribution from the RTO is not expected to significantly increase recorded background values. However, BS4142 also requires that, in the event that the noise source is associated with tonal characteristics, then the specific noise contribution at the receptor point should be adjusted by a factor of 5 db. Based on currently available information, based on optimum operation and maintenance, a significant tonal component from the RTO noise is not anticipated. However, it is possible that tonal characteristics (squeaks, hums) could occur at some stage during the RTO operation. As such, as a conservative measure, the modelled RTO specific noise was adjusted by 5 db to complete the BS4142 analysis. Based on this adjustment, the specific noise at Location 1 would be 47.1 db Laeq this exceeds the WHO guidelines of 45 db at night external to residential facades. Based on this, incorporation of noise mitigation measures should be considered for the scheme, as discussed in Section 2.7 below. 2.7 Noise Mitigation Measures An open-roofed barrier measuring 2 and 3 metres in height was inserted to illustrate attenuation of the specific noise from the RTO. This was inserted 7 metres in length and 3 metres in width away from the RTO consistent with the RTO concrete pad footprint as illustrated in DR/EN12882/013/JS in Appendix A. The predicted noise values for the closest residential receptors (Location 1), along Salhouse Road based on the modelled scenarios are summarized on Table 2-8. Scenario Modelled Specific Noise (Laeq) db RTO, without barrier 42.1 RTO, with 2m barrier 41.9 RTO, with 3m barrier 39.1 Table 2-8 Assessment of Noise Barriers Without mitigation, the night-time tonally adjusted specific noise from the RTO is 47 db, which exceeds the WHO outdoor residential threshold of 45 db. The modelling results in Table 2-8 suggest that a noise barrier height of 3 metres would reduce the RTO specific noise at the closest receptor, including tonal adjustments, to 44.1 db, which is less than the 45 db threshold. As previously discussed, the main noise source at the RTO would be from the motor driving the supply fan from the process exhaust inlet. Free field noise measurements were collected by the equipment supplier when the supply fan was not connected to the RTO unit. In fact, 16

17 the noise emissions if the fan is connected to the RTO would be expected to be lower than the reported levels. Therefore, the actual mitigation requirements for the operational RTO may be less than the 3 metres indicated above. It is recommended that site-specific noise measurements be conducted during equipment commissioning, and the actual barrier design and height re-assessed based on that data. 2.8 Noise Impact Assessment Summary and Conclusions The following conclusions are made based on the noise impact assessment completed at the Impress Ltd. Salhouse Road facility: Background noise levels at night recorded at the residential locations near the facility are relatively high. In the context of PPG24, these locations would be classified as NEC C. The primary background noise sources are road traffic noise. Added to measured background levels, the modelled specific noise from the future operation of the RTO would increase the receptor point background noise levels by < 1 db, and therefore would not result in a perceptible increase of noise levels compared with background. However, in the event that tonal characteristics are associated with the noise source, according to BS4142, the receptor point noise levels should be adjusted by 5 db to assess the potential for nuisance. Without mitigation, the night-time tonally adjusted specific noise from the RTO is 47 db, which exceeds the WHO outdoor residential threshold of 45 db. In this case, it would be prudent to include a noise barrier around the RTO to reduce the risk of annoyance. Modelling results suggest that a noise barrier height of 3 metres would reduce the RTO specific noise at the closest receptor, including tonal adjustments, to 44.1 db, which is less than the 45 db threshold. 17

18 3 AIR QUALITY AND ODOUR This chapter addresses the air quality and odour implications of the proposed development. There is the potential for air quality impacts to arise from emissions from the RTO. Furthermore, Planning Policy Guidelines dictate that air quality is a material consideration in assessing if developments should be granted planning permission. This chapter provides an overview of the legislative and policy context for the assessment, methodology, baseline conditions, and modelled impacts of the proposed development on air quality. The complete Air Quality Modelling report is provided as Appendix E. 3.1 Project Scope The specific scope of the assessment is as follows: Assess potential impacts to ambient air quality and odour nuisance as a result of the operation of the RTO. This assessment specifically evaluates potential impacts associated with stack emissions from the RTO, and does not consider possible emissions from the facility in the event that the RTO is shut-down or not functioning. In that event, Impress Ltd. have a series of management measures and procedures to be implemented in accordance with the existing IPPC permit. It is assumed that these procedures will be effectively implemented, should the need to do so occur. 3.2 Identification of Pollutants to be Assessed As discussed above, the scope of this assessment is to assess impacts from stack emissions from the RTO. Specifically, emissions from the stack relate to the VOC levels associated with solvents being used at the facility, as well as emissions related to combustion of natural gas in the thermal oxidation chamber. Further discussion of the specific pollutants that could be emitted is presented below. Volatile Organic Compounds (VOCs): Various solvent based inks, lacquers, varnishes, and base coats are used in the process (reviewed in Section 2.4 of the IPPC application). These contain VOCs that are emitted from the process lines to the RTO. The solvent VOCs will be degraded by approximately 98% in the RTO, with the remaining concentrations being emitted from the RTO stack. Based on the information presented in the IPPC application, the following are the principal VOC compounds that could be emitted from the RTO stack: 2 butoxyethanol Butanol 1,2,4-trimethylbenzene 1,3,5-trimethylbenzene (mesitylene) Xylene Formaldehyde 4 Propylbenzene Methanol Heavy aromatic solvent naphtha (modelled as naphthalene) 5 4 Consistent with current requirements, low formaldehyde lacquers are used (<1%) therefore formaldehyde is not considered further in the assessment. 5 Heavy aromatic naphtha (HAN), a mixture consisting mainly of aromatic hydrocarbons having from seven to nine carbons per molecule, including naphthalene. Of the HAN compounds, naphthalene would have the highest vapour pressure, and therefore be a dominant component of HAN in the solvent emission stream. 18

19 Nitrogen Oxides: Nitrogen oxides are produced in combustion processes by direct combination of atmospheric oxygen and nitrogen in the combustion chamber. Nitrogen oxides are oxidised by ozone in the air to give nitrogen dioxide, which is a regulated air quality pollutant. Carbon monoxide: Carbon monoxide is produced as a result of incomplete combustion of natural gas in the combustion chamber. 3.3 Legislative and Policy Context This section presents a description of the legislative and policy context within which the assessment is considered. Specifically, an overview of the Planning Policies and Guidelines, National Air Quality Standards and Objectives, and the local Air Quality Review and Assessment is presented below Planning Policy and Guidelines National, regional, and local policies and guidelines state that potential impacts on human health arising from adverse air quality is a material planning consideration as it pertains to land use. The relevant policies and guidelines are summarized on Table 3-1 below. Policy Relevant Requirements National Guidance- PPS 23: Planning and Pollution Control Any consideration of the quality of land, air or water and potential impacts arising from development, possibly leading to an impact on health, is capable of being a material planning consideration, in so far as it arises or may arise from any land use. East Anglia Regional Planning Guidance 6 Policies Policy Local planning authorities should seek to ensure that the land-use planning 51 system makes an appropriate contribution to the achievement of national air quality objectives. They should also ensure that air quality is properly considered alongside other material considerations in the planning process, particularly where any air quality management areas have been designated. Norfolk County Council Structure Plan Policies NO POLICIES Norwich City Council (The City Council has agreed with the Government Office for the East of England that around 70% of the policies in this Local Plan can be used beyond 30 November These are called 'saved policies'. The following are included within these) EP5 Development which may give rise to air-borne emissions of harmful substances, including smoke, grit and dust, will be required to assess the level of risk of demonstrable harm to human health or to the environment and to identify appropriate mitigation measures. Particular account will be taken of any sensitive uses, which would adjoin or otherwise be affected by such emissions EP6 Where an Air Quality Management Area has been declared (under the Environment Act, 1995), development which may have an impact on air quality will be required to take account of the action plan for that area in respect of its location and density. Table 3-1; Summary of Planning Policies and Guidelines related to Air Quality 19

20 3.3.2 Air Quality Standards and Guidelines The UK Government published the latest Air Quality Strategy for England, Scotland, Wales and Northern Ireland in July 2007 (Cmd paper No 7169, 17 July 2007) (AQS). Specifically, the AQS sets out a way forward for work and planning on air quality issues and establishes the Air Quality Standards (AQS) and Air Quality Objectives (AQO) to be achieved. Where available, AQS and AQO are used to assess potential air quality impacts In addition, for pollutants for which no AQS or AQO are available, other sources, including the Environment Agency s Environmental Assessment Levels (EALs) may be used. Air Quality Standards: The Air Quality Strategy utilizes national Air Quality Standards to enable air quality to be measured and assessed. These are the concentrations of pollutants in the atmosphere, which can broadly be taken to achieve a certain level of environmental quality. The standards are based on assessment of the effects of each pollutant on human health including the effects on sensitive subgroups or on ecosystems. This is the approach adopted by the World Health Organisation (WHO) in the formulation of their air quality guidelines published in 1987 and their subsequent revision in 1994/95 (published in 2000 and 2005), and by Expert Panel on Air Quality Standards (EPAQS) in the UK who last reported on pollutants of national importance in 2002 (Referenced in UK AQS, 2007). Air Quality Objectives: The Air Quality Objectives are based on the standards, but take into account feasibility, practicality, and the costs and benefits of fully complying with the standards. Environmental Assessment Levels: To fulfil its regulatory role the EA has developed environmental criteria, known as Environmental Assessment Levels (EALs) from a variety of published UK and international sources. Although EALs do not carry any statutory basis, they are a benchmark against which any exceedance may be viewed as unacceptable. The relevant standards and guidelines are summarized on Table 3-2 below. Pollutant NO2 Carbon monoxide 2 butoxyethanol Butanol 1,2,4-Trimethylbenzene (all isomers) Propylbenzene Methanol Xylene Naphthalene Assessment Value Source Level (ug/m3) Long Term 40 AQS Annual mean Short Term 200 AQS 1 hr. mean 6 Long Term 350 EAL Short Term 10,000 AQO (8 hrs running mean) Long Term 1,230 EAL Short Term NA Long Term 3,080 EAL Short Term 15,400 EAL Long Term 1,250 EAL Short Term 37,500 EAL Long Term NA Short Term NA Long Term 2,660 EAL Short Term 33,300 EAL Long Term 4,410 EAL Short Term 66,200 EAL Long Term 530 EAL Short Term 8000 EAL Table 3-2; Air Quality Standards and Guidelines 6 Max exceedences 18 times/year by

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