Newbury Works,

Thatcham, Berkshire

Environmental Permit (EP) Application

Environmental Risk Assessment

SLR Ref: 416.05921.00016/ERA

May 2016

Version
Forterra Building Products Limited i SLR ref.: 416.05921.00016/ERA
Newbury Works
Environmental Risk Assessment May 2016

CONTENTS

ENVIRONMENTAL RISK ASSESSMENT

1.0 INTRODUCTION .......................................................................................................... 1
2.0 IDENTIFYING THE RISKS ........................................................................................... 2
3.0 SITE SETTING AND RECEPTORS ............................................................................. 3
3.1 Site Setting ........................................................................................................ 3
3.2 Geology ............................................................................................................. 4
3.3 Hydrology .......................................................................................................... 4
3.4 Hydrogeology.................................................................................................... 4
3.5 Source Protection Zone.................................................................................... 4
3.6 Ecology.............................................................................................................. 4
3.7 Cultural Heritage ............................................................................................... 5
4.0 ENVIRONMENTAL RISK ASSESSMENT ................................................................... 8
5.0 CONCLUSION ........................................................................................................... 21
6.0 CLOSURE.................................................................................................................. 22

REFERENCED DRAWINGS

Drawing 001 Site Location Plan

Drawing 002 Environmental Permit Boundary and Site Layout
Drawing 003 Source Pathways and Receptors
Drawing 004 Cultural and Natural Heritage

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1.0 INTRODUCTION

Forterra Building Products Limited (Forterra) has retained SLR Consulting Limited (SLR) to
prepare an Environmental Risk Assessment in support of an application for a bespoke
Environmental Permit (EP) for the Newbury Works, Thatcham, Berkshire.

This Environmental Risk Assessment is an assessment of the risks to the environment and
human health that may be associated with the operations at the site.

The assessment has been completed in accordance with the Environment Agency (EA)
Technical Guidance ‘Environmental Risk Assessment for your Environment Permit’ dated 1st
February 2016. The aim of the assessment is to identify any significant risks and
demonstrate that the risk of pollution or harm will be acceptable by taking the appropriate
measures to manage these risks.

This environmental risk assessment uses the following approach for identifying and
assessing the risks from the proposed operation:

Step 1 Identify risks and sources of risk from your activity.

Step 2 Where risks are identified from Step 1 then identify the receptors that could
be affected
Step 3 Identify potential pathways between the sources of risk and receptors
Step 4 Assess the risks and check that they are acceptable. Justify appropriate
measures to control your risks, if necessary.
Step 5 Present your assessment.

The Environmental Risk Assessment for an Environmental Permit application requires all
receptors that are near the site and could reasonably be affected by the activities to be
identified and considered as part of the assessment.

For the purposes of this Environmental Risk Assessment, a 2km radius from the site’s
Environmental Permit boundary has been adopted in reviewing potentially sensitive
receptors of ecological importance along with features such as sites of cultural and natural
heritage. A radius of 500m from the site’s Environmental Permit boundary has been adopted
for all other potentially sensitive receptors (for example, residential, commercial, industrial,
agricultural and surface water receptors).

Section 2.0 of this document is a screening step to identify the risks requiring consideration
as part of this assessment. Section 3.0 identifies people or parts of the environment that
could be harmed (at potentially significant risk) by the activity. Section 4.0 of this document
presents the assessment and demonstrates that any risks of pollution or harm will be
mitigated to manage the risk.

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2.0 IDENTIFYING THE RISKS

Step 1 is a screening step to identify the potential risks to the environment from the
proposed development. The following are generally considered to require assessment for
bespoke waste operations:

 Amenity and Accidents

 Surface Water
 Air
 Site Waste
 Global Warming Potential
 Groundwater

There will be no point source emissions to groundwater, surface water or air resulting from
the proposed development and neither will there be any site waste arising or global warming
potential.

Therefore only ‘Amenity and Accidents’, remains applicable for assessment in this instance,
and includes the consideration of odour, noise and vibration, fugitive emissions (including
dust, mud, litter and pests) and accidents.

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Environmental Risk Assessment May 2016

3.0 SITE SETTING AND RECEPTORS

3.1 Site Setting

The Newbury Works site, hereon referred to as ‘the site’, is located on the eastern edge of
Thatcham and approximately 6km to the east of the centre of Newbury. The site location is
illustrated on Drawing 001. The National Grid Reference (NGR) for the site is 453383,
166854.

The site is located within an industrial estate and so is surrounded by industrial units to the
north, south, east and west. Enterprise way, from where the site is accessed, is located to
the north, whilst the closest residential properties are located approximately 130m to the
west off Pipers Way. A railway line is located 300m to the south and the Kennet and Avon
Canal is located 400m to the south. The Environmental Permit boundary and site layout is
illustrated on Drawing 002.

There are a number of European/Internationally designated sites within 2km of the site, the
closest of which is a Site of Special Scientific Interest (SSSI), the River Kennet, which lies
1300m to the south of the site.

Surrounding land-use and receptors are identified on Drawing 003 – Sources Pathways and
Receptors and Drawing 004 - Cultural and Natural Heritage, and are identified in Table 2-1
below.

Table 3-1
Surrounding Land Uses

Boundary Description
Enterprise Way and industrial units beyond which lies the A4 (Bath Road) and
North
agricultural land/open space and a caravan park.
Industrial units beyond which lies agricultural land/open space and West Berkshire
East
Crematorium
South Industrial units, a railway line and the Kennet and Avon Canal.
West Berkshire Drive, residential properties within Thatcham and open land.

The immediate surrounding land use is described in further detail below:

Residential Properties

The nearest residential properties are located in Thatcham, along Pipers Way 130m to the
west and north west.

Industrial Properties

Industrial properties lie adjacent to the site to the north, south, east and west.

Agricultural Land and Open Spaces

Agricultural land and open spaces lie to the north, east and south of the site, with the closest
area located 225m to the north.

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Transport Network

Enterprise Way is located adjacent to the north and Berkshire Drive lies adjacent to the west
of the site.

The Bath Road (A4) lies 210m to the north of the site.

A railway track likes 290m to the south.

Other Receptors

The West Berkshire Crematorium lies 340m to the east.

A caravan site lies 310m to the north.

3.2 Geology

As detailed in the Land Quality Assessment included within Appendix SCR1, the superficial
deposits comprise of the Beenham Grange Gravel Member, mainly consisting of sand and
gravel and Alluvium typically consisting of clay, silt, sand and gravel.

The bedrock geology comprises of the Lambeth Group which is typically made up of clay, silt
and sand.

3.3 Hydrology

As detailed within Appendix SCR1, a small stream flows north to south along part of the
western site boundary and under a section of the product storage yard.

The Kennet & Avon Canal is located 400m to the south of the site. The River Kennet is
approximately located 800m to the south of the site.

The site is not recorded as being located within a flood plain.

3.4 Hydrogeology

As detailed in Appendix SCR1, the site and surrounding area (to the south) is a Secondary A
Aquifer (drift and solid). The Chalk is designated as a Principal aquifer.

3.5 Source Protection Zone

EA data indicates that the site lies within Zone 3 (Total Catchment) of a Source Protection
Zone (SPZ).

3.6 Ecology

European/International Sites

Searches on the Multi-Agency Geographic Information for the Countryside (MAGIC)1

website confirm that the following European/Internationally designated sites lie within 2km of
the permit boundary;

1
Multi-Agency Geographic Information for the Countryside, www.magic.gov.uk, accessed May 2016.

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Environmental Risk Assessment May 2016

 Site of Special Scientific Interest (SSSI); and

 Special Areas of Conservation (SAC)

The Thatcham Reed Beds SSSI is located 1700m to the west. The Kennet and Lambourn
Floodplain SAC also lies within the same designation area as illustrated on Drawing 004.

The River Kennet SSSI lies 1300m to the south of the site and the Bowdown and
Chamberhouse Woods SSSI lies 1950m to the south west.

Ancient Woodland

There are a number of designated areas of Ancient Woodland within 2km of the permit
boundary, the closest of which lies 500m to the north of the site.

Priority Habitats

There are a number of Priority Habitats within 2km of the proposed environmental permit
boundary. These include:

 meadows;
 grassland;
 heathland; and
 floodplain grazing Marsh.

Other Ecological Receptors

The North Wessex Downs Area of Outstanding Natural Beauty (AONB) is located 1400m to
the north of the site.

Searches on the MAGIC2 website confirm there are none of the following ecological
receptors identified within 2km of the application site:

 Local Nature Reserves;

 National Nature Reserves;
 National Parks; and
 National Forest.

3.7 Cultural Heritage

Listed buildings

There are a number of listed buildings located within a 2km radius of the site illustrated on
the MAGIC website. These are illustrated on Drawing 004.

Scheduled Monuments

Searches on the MAGIC website confirm the presence of two scheduled monuments within
2km of the proposed permit boundary;

 Monkey Marsh Lock, associated with the Kennet and Avon Canal, located 900m to the
south west; and
 Moated manorial site 200m north-west of East Field Copse, located 1750m to the south
east of the site.

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Other Cultural Heritage Receptors

Searches on the MAGIC website confirm that there are none of the following within 2km of
the application site:

 National Trust Properties;

 World Heritage Sites; and
 Registered Battlefields.

Receptors Table 2-2 and Drawings 003 and 004 show the locations of receptors that are
considered to be potentially sensitive and could reasonably be affected by the proposed
waste management activities.

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Table 3-2
Identified Receptors
Receptor Name Receptor Type Direction from Approximate
Site Distance from site
boundary (at
nearest point)
Identified receptors within 500m of the Environmental Permit Boundary as shown on
Drawing 003 Sources, Pathways and Receptors
Industrial / Commercial North, east, south
Industrial / Commercial Adjacent
Premises and west
Enterprise Way/Berkshire North and west
Local Road Network Adjacent
Drive respectively
Bath Road Local Road Network North 210m
Residential properties
within Thatcham, off Pipers Residential West 130m
Way
Kennet and Avon Canal Canal South 400m

Railway Line Transport Network South 290m

Agricultural Land / Areas of North, east, south
Agricultural 225m
open space and west
West Berkshire
Crematorium North east 340m
Crematorium
Identified receptors within 2km of the Environmental Permit Boundary as shown on Drawing
004 Cultural and Natural Heritage
Thatcham Reed Beds SSSI West 1700m
Bowdown and
SSSI South west 1950m
Chamberhouse Woods
River Kennet SSSI South 1300m
Kennet and Lambourn
SAC West 1700m
Floodplain
North Wessex Downs AONB North 1400m

Areas of Ancient Woodland Ancient Woodland North (closest) 500m

Monkey Marsh Lock Scheduled Monument South west 900m

Moated manorial site Scheduled Monument South east 1750m

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4.0 ENVIRONMENTAL RISK ASSESSMENT

The following tables present the assessment in terms of hazards posed, receptors and pathways, along with management and residual risks for
the following hazards:
 Odour;
 Noise and Vibrations;
 Fugitive Emissions (including dust, mud, litter and pests); and
 Accidents,

Table 4.1 Odour Risk Assessment and Management Plan

What do you do that can harm and what could be harmed Managing the Risk Assessing the Risk
Hazard Receptor Pathway Risk management Probability of Consequence What is the overall
exposure risk
What has the What is at risk what do I How can What measures will you take to reduce the risk? – Who is How likely is What is the harm What is the risk that
potential to cause wish to protect? the responsible for what? this contact? that can be still remains? The
harm? hazard caused? balance of
get to the probability and
receptor? consequence
Odour associated Potentially sensitive Air The waste types to be accepted are not considered to be Low Odour nuisance Not significant –
with the acceptance receptors as listed in Table odorous at all in nature. due to the type of
and treatment of 2-2, including residential Unprocessed wastes will remain enclosed within silos; only waste accepted on
waste. premises, industrial / finished products will be stored externally. site.
commercial units, All waste processing occurs within the building.
agricultural land, public Strict waste acceptance procedures will be adhered to, to
footpaths and highways, ensure only permitted wastes are accepted on site.
sensitive habitat, cultural The Site Manager will be responsible for implementing risk
and heritage receptors, management measures in accordance with the Best
surface waters and Available Techniques and Operating Techniques (BATOT)
groundwater. document included in this application and Forterra
procedures.
Receptors as shown on
Drawing 003 and 004.

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Table 4.2 Noise Risk Assessment and Management Plan

What do you do that can harm and what could be harmed Managing the Risk Assessing the Risk
Hazard Receptor Pathway Risk management Probability of Consequence What is the
exposure overall risk
What has the potential to What is at risk what do I How can What measures will you take to reduce the risk? – Who is How likely is What is the harm What is the risk
cause harm? wish to protect? the responsible for what? this contact? that can be that still remains?
hazard caused? The balance of
get to the probability and
receptor? consequence
Noise and vibration Potentially sensitive Air The site is located within an industrial setting and is Low Noise disturbance Not significant
from vehicular receptors as listed in accessed via Enterprise Way to the north.
movements and the Table 2-2, including Site operations will be restricted to the hours specified in
operation of site plant residential premises, the planning consent.
industrial / commercial Speed limits will be implemented for vehicles using the
units, agricultural land, site.
public footpaths and Traffic calming measures will be implemented to enforce
highways, sensitive speed limits.
habitat, cultural and The processing of the waste will occur within the main
heritage receptors, building.
surface waters and Site access and haul roads and operational areas will be
groundwater. maintained and repaired to minimise emissions of noise
due to uneven and poor surfacing.
Receptors as shown on Auditory inspections will also be carried out daily and in
Drawing 003 and 004. response to complaints.
A record of the inspection findings will be made in the site
diary.
Plant will be selected and operated to minimise noise. All
site plant and machinery will be operated and maintained
in accordance with manufacturer’s specifications.
The Site Manager will be responsible for implementing risk
management measures in accordance with the Best
Available Techniques and Operating Techniques (BATOT)
document included in this application and Forterra
procedures.

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Table 4.3 Fugitive Emissions Risk Assessment and Management Plan

What do you do that can harm and what could be harmed Managing the Risk Assessing the Risk
Hazard Receptor Pathway Risk management Probability of Consequence What is the
exposure overall risk
What has the potential What is at risk what do I How can What measures will you take to reduce the risk? – Who is How likely is What is the harm What is the risk
to cause harm? wish to protect? the hazard responsible for what? this contact? that can be that still remains?
get to the caused? The balance of
receptor? probability and
consequence
To Air:
Dust Potentially sensitive Air Waste and non-waste will be delivered to site in bulk Medium Dust nuisance Not significant –
receptors as listed in tankers which will benefit from filters and air pressurisation due to
Delivery of cement, Table 2-2, including equipment. The material will be transferred pneumatically management and
lime, waste and residential premises, to the enclosed silos via flexible hosing and standard mitigation
anhydrite to site. industrial / commercial sealed couplings. The pressurised discharge will have a methods
units, agricultural land, maximum blowing pressure of two bar. implemented on
Storage of hazardous public footpaths and The 10 storage silos filled with the waste, cement, lime and site.
waste highways, sensitive anhydrite/sand will be fitted with a dust arrestment plant.
habitat, cultural and Each silo will be individually labelled with the contents.
heritage receptors, The driver and site operative will inspect all equipment
surface waters and before carrying out the transfer to the silos.
groundwater. The silo system will be fitted with automatic cut-off in the
event of over pressurisation of the silo.
Receptors as shown on The silos will be fitted with both visual and audible high
Drawing 003 and 004. level alarms.
All hazardous waste will be stored within a specified silo.
Dust emissions from unloading will be minimised by back
venting to the tanker which will be fitted with an on-board,
truck mounted relief valve and filtration system. Transfer
lines will initially be connected to the delivery inlet point
and then to the tanker discharge point.
The Site Manager will be responsible for implementing risk
management measures in accordance with the Best
Available Techniques and Operating Techniques (BATOT)
document included in this application and Forterra
procedures.

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Forterra Building Products Limited 11 SLR Ref: 416.05921.00016/ERA
Newbury Works
Environmental Risk Assessment May 2016

What do you do that can harm and what could be harmed Managing the Risk Assessing the Risk
Hazard Receptor Pathway Risk management Probability of Consequence What is the
exposure overall risk
What has the potential What is at risk what do I How can What measures will you take to reduce the risk? – Who is How likely is What is the harm What is the risk
to cause harm? wish to protect? the hazard responsible for what? this contact? that can be that still remains?
get to the caused? The balance of
receptor? probability and
consequence
Dust Potentially sensitive Air Waste processing will occur within the building and is Low Dust nuisance Not significant
receptors as listed in inherently an enclosed process.
Waste processing Table 2-2, including Only finished products will be stored externally, after being
operations. residential premises, shrink wrapped.
industrial / commercial Traffic calming measures will be implemented to enforce
Vehicle movements. units, agricultural land, speed limits & reduce emissions of dust.
public footpaths and Site access & haul roads and operational areas will be
highways, sensitive maintained and repaired to minimise emissions of dust due
habitat, cultural and to uneven and poor surfacing.
heritage receptors, All roads and operational areas will be swept where
surface waters and necessary to reduce dust emissions.
groundwater. Daily, visual inspection at all areas of the site and site
boundary will be carried out by site personnel.
Receptors as shown on In the event that significant visual dust is observed at the
Drawing 003 and 004. boundaries of the operational areas, action will be taken to
suppress the dust.
A record of the inspection findings & remedial action taken
will be made in the site diary.
The Site Manager will be responsible for implementing risk
management measures in accordance with the Best
Available Techniques and Operating Techniques (BATOT)
document included in this application and Forterra
procedures.

To Water

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What do you do that can harm and what could be harmed Managing the Risk Assessing the Risk
Hazard Receptor Pathway Risk management Probability of Consequence What is the
exposure overall risk
What has the potential What is at risk what do I How can What measures will you take to reduce the risk? – Who is How likely is What is the harm What is the risk
to cause harm? wish to protect? the hazard responsible for what? this contact? that can be that still remains?
get to the caused? The balance of
receptor? probability and
consequence
Contaminated site Surface water Runoff and All waste (including hazardous waste) and non-waste Low Groundwater and Not significant
run off. percolation materials will be stored within silos prior to treatment. surface water
Groundwater Wastes will be delivered within enclosed tankers and contamination
blown into the designated silo.
Only finished products (blocks) will be stored externally,
which after extensive quality testing will no longer be
deemed to be a waste, but a product under BS EN 771-
4;2011 (as detailed in the Non-Technical Summary
included in Section 1 of this application). No waste material
will be stored externally.
Waste processing will occur within the building and is
inherently an enclosed process.
There will be no point source discharge of process waters
to sewer or groundwater from the site.
The site benefits from impermeable surfacing throughout.
All surface water drains to the south of the site and then
towards the west and discharges via an interceptor.
Strict waste acceptance procedures will ensure that only
permitted waste types are accepted on site.
In the event that non-conforming wastes are delivered to
site, they will be isolated and removed at the earliest
opportunity.
The Site Manager will be responsible for implementing risk
management measures in accordance with the Best
Available Techniques and Operating Techniques (BATOT)
document included in this application and Forterra
procedures.

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Environmental Risk Assessment May 2016

What do you do that can harm and what could be harmed Managing the Risk Assessing the Risk
Hazard Receptor Pathway Risk management Probability of Consequence What is the
exposure overall risk
What has the potential What is at risk what do I How can What measures will you take to reduce the risk? – Who is How likely is What is the harm What is the risk
to cause harm? wish to protect? the hazard responsible for what? this contact? that can be that still remains?
get to the caused? The balance of
receptor? probability and
consequence
Start up and shut Potentially sensitive All plant will undergo planned preventative maintenance
down of plant receptors as listed in and be maintained and checked in accordance with
Table 2-2, including manufacturer’s instructions. This will ensure that all
residential premises, emissions to air are kept at a minimum during start up and
industrial / commercial shut down of the plant.
units, agricultural land, All operatives at the plant will be suitably trained to ensure
public footpaths and the efficient running of the plant.
highways, sensitive The Site Manager will be responsible for implementing risk Low Dust nuisance. Not significant
habitat, cultural and management measures in accordance with the Best
heritage receptors, Available Techniques and Operating Techniques (BATOT)
surface waters and document included in this application and Forterra
groundwater. procedures.

Receptors as shown on
Drawing 003 and 004.
Plant breakdowns Potentially sensitive Air and All equipment will undergo planned preventative
receptors as listed in land maintenance and be maintained and checked in
Table 2-2, including accordance with manufacturer’s instructions.
residential premises, All equipment will be inspected, maintained and repaired or
industrial / commercial replaced, at weekly, monthly and six monthly intervals, in
units, agricultural land, accordance with Forterra’s internal procedures, and Low – due to
public footpaths and records will be maintained of all these issues. mitigation Nuisance and loss
highways, sensitive Full training will be given to all relevant site operatives. measures of amenity Not significant
habitat, cultural and If there is a plant breakdown on site, a suitably trained employed on
heritage receptors, external contractor will be called to site to carry out site.
surface waters and maintenance on the plant.
groundwater. The Site Manager will be responsible for implementing risk
management measures in accordance with the Best
Receptors as shown on Available Techniques and Operating Techniques (BATOT)
Drawing 003 and 004.

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What do you do that can harm and what could be harmed Managing the Risk Assessing the Risk
Hazard Receptor Pathway Risk management Probability of Consequence What is the
exposure overall risk
What has the potential What is at risk what do I How can What measures will you take to reduce the risk? – Who is How likely is What is the harm What is the risk
to cause harm? wish to protect? the hazard responsible for what? this contact? that can be that still remains?
get to the caused? The balance of
receptor? probability and
consequence
document included in this application and Forterra
procedures.

Pests
Birds, vermin and Potentially sensitive Land and The waste types to be accepted at the site are unlikely to Low. Nuisance and Not significant
insects attracted to receptors as listed in Air attract birds, vermin & insects. health issues
site. Table 2-2, including Waste acceptance procedures will ensure that only
residential premises, authorised wastes are accepted.
industrial / commercial In the event that birds, vermin & insects are identified at
units, agricultural land, the site, a specialist pest control contractor will be
public footpaths and employed to undertake remedial measures.
highways, sensitive The Site Manager will be responsible for implementing risk
habitat, cultural and management measures in accordance with the Best
heritage receptors, Available Techniques and Operating Techniques (BATOT)
surface waters and document included in this application and Forterra
groundwater. procedures.

Receptors as shown on
Drawing 003 and 004.

Mud/Litter
Litter from waste Potentially sensitive Windblown The waste types to be accepted at the site are unlikely to Low Dangerous Not significant
receptors as listed in litter generate any quantities of litter. conditions on roads
Table 2-2, including Waste acceptance procedures will ensure that only for local residents.

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Environmental Risk Assessment May 2016

What do you do that can harm and what could be harmed Managing the Risk Assessing the Risk
Hazard Receptor Pathway Risk management Probability of Consequence What is the
exposure overall risk
What has the potential What is at risk what do I How can What measures will you take to reduce the risk? – Who is How likely is What is the harm What is the risk
to cause harm? wish to protect? the hazard responsible for what? this contact? that can be that still remains?
get to the caused? The balance of
receptor? probability and
consequence
residential premises, authorised wastes are accepted. Unprocessed wastes will Nuisance from litter
industrial / commercial be enclosed within silos.
units, agricultural land, The site and its immediate surrounding will be inspected
public footpaths and on a daily basis and action will be taken to maintain the
highways, sensitive area free of significant accumulations of litter and debris.
habitat, cultural and The Site Manager will be responsible for implementing risk
heritage receptors, management measures in accordance with the Best
surface waters and Available Techniques and Operating Techniques (BATOT)
groundwater. document included in this application and Forterra
procedures.
Receptors as shown on
Drawing 003 and 004.
Mud on roads Local road network Transferral The surfacing of all roads will be maintained as required to Nil Mud on road, road Not significant
of mud on maintain the integrity of the surfacing. traffic accidents
vehicle Roads will be swept and cleaned whenever necessary.
wheels In the event that mud, debris or waste arising from the site
is deposited outside the site, the affected area will be
cleaned and traffic will be isolated from sources of mud
and debris within the site.
The Site Manager will be responsible for implementing risk
management measures in accordance with the Best
Available Techniques and Operating Techniques (BATOT)
document included in this application and Forterra
procedures.

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Environmental Risk Assessment May 2016

Table 4.4 Accidents Risk Assessment and Management Plan

What do you do that can harm and what could be harmed Managing the Risk Assessing the Risk
Hazard Receptor Pathway Risk management Probability Consequence What is the overall
of risk
exposure
What has the potential What is at risk what do I How can the What measures will you take to reduce the risk? – How likely What is the harm What is the risk
to cause harm? wish to protect? hazard get to Who is responsible for what? is this that can be that still remains?
the receptor? contact? caused? The balance of
probability and
consequence
Unauthorised waste Potentially sensitive Via air Upon delivery, waste will be subject to strict waste Low Odour nuisance Not significant
receptors as listed in Table (odours) acceptance procedures to identify, reject and/or
2-2, including residential Overland (to segregate potentially non conforming waste. Water
premises, industrial / sewers, Only waste authorised by the permit will be accepted contamination
commercial units, surface and at the site.
agricultural land, public groundwater) All wastes will be subject to inspection and checking
footpaths and highways, against the declaration on the waste transfer note.
sensitive habitat, cultural In the event that unauthorised waste is delivered to
and heritage receptors, the site, the waste will be segregated and stored in a
surface waters and designated quarantine area prior to export from site.
groundwater. The Site Manager will be responsible for
implementing risk management measures in
Receptors as shown on accordance with the Best Available Techniques and
Drawing 003 and 004. Operating Techniques (BATOT) document included
in this application and Forterra procedures.

Leakage of fuel and oils Local land quality, surface Overland and Tanks used for the storage of fuel and maintenance Low Odour nuisance Not significant
from site plant water and groundwater seepage oil, will be constructed so that any leaks/spillages will
through site be contained. Water
surface Tanks will be surrounded by a leakage containment contamination
bund capable of containing at least 110% of the
volume of the largest tank within the bund or 25% of
the total tank volume within the bund, whichever is
the greater.
Storage tanks will be constructed to the appropriate
British Standard.

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Forterra Building Products Limited 17 SLR Ref: 416.05921.00016/ERA
Newbury Works
Environmental Risk Assessment May 2016

What do you do that can harm and what could be harmed Managing the Risk Assessing the Risk
Hazard Receptor Pathway Risk management Probability Consequence What is the overall
of risk
exposure
What has the potential What is at risk what do I How can the What measures will you take to reduce the risk? – How likely What is the harm What is the risk
to cause harm? wish to protect? hazard get to Who is responsible for what? is this that can be that still remains?
the receptor? contact? caused? The balance of
probability and
consequence
Tanks will be inspected visually on a daily basis by
the site staff to ensure the continued integrity of the
tanks and identify the requirement for any remedial
action.
Minor spillages will be cleaned up immediately, using
sand or proprietary absorbent to clean up liquids and
placed in alternative containers.
Materials suitable for absorbing and containing minor
spillages will be maintained on site.
Site operatives will inspect the site on a daily basis
for evidence of spillage and leakage. Alongside
regular visual inspections, the tanks will be fitted with
level indicators to prevent overfilling.
The Site Manager will be responsible for
implementing risk management measures in
accordance with the Best Available Techniques and
Operating Techniques (BATOT) document included
in this application and Forterra procedures.

Cleaning of equipment Potentially sensitive Air and land All material will be transferred pneumatically to the
receptors as listed in Table enclosed silos via flexible hosing and standard
Clearing up of spillages 2-2, including residential sealed couplings. In the unlikely event that spillages Low – due
premises, industrial / occur, they will be cleaned up immediately. to mitigation Contamination of
Spillages during the commercial units, The Site Manager will be responsible for measures groundwater and Not significant
process agricultural land, public implementing risk management measures in employed surface water
footpaths and highways, accordance with the Best Available Techniques and on site.
sensitive habitat, cultural Operating Techniques (BATOT) document included
and heritage receptors, in this application and Forterra procedures.

SLR
Forterra Building Products Limited 18 SLR Ref: 416.05921.00016/ERA
Newbury Works
Environmental Risk Assessment May 2016

What do you do that can harm and what could be harmed Managing the Risk Assessing the Risk
Hazard Receptor Pathway Risk management Probability Consequence What is the overall
of risk
exposure
What has the potential What is at risk what do I How can the What measures will you take to reduce the risk? – How likely What is the harm What is the risk
to cause harm? wish to protect? hazard get to Who is responsible for what? is this that can be that still remains?
the receptor? contact? caused? The balance of
probability and
consequence
surface waters and
groundwater.

Receptors as shown on
Drawing 003 and 004.

Fire from the following Potentially sensitive Air The waste types to be accepted at the site will not Low Nuisance (smoke Not significant
sources; receptors as listed in Table readily burn, are not self-combustible and do not and fumes) and
2-2, including residential require a Fire Prevention Plan as detailed within the harm to human
Waste acceptance; premises, industrial / EA’s Fire Prevention Plan Guidance, March 2015. health
Waste storage; commercial units, The plant inspection schedule will include checks of
Waste processing agricultural land, public electrical equipment within the site to ensure that any Water
Plant footpaths and highways, faults are identified and repaired. contamination
vehicles sensitive habitat, cultural Smoking will not be permitted in the operational (runoff)
and heritage receptors, areas of the site.
surface waters and The operators working practices will ensure
groundwater. assessment of fire hazards and training of employees
in fire prevention, e.g. in the use of fire extinguishers
Receptors as shown on and emergency procedures.
Drawing 003 and 004. No waste shall be burned on the site and any fire at
the site will be treated as an emergency.
Actions to be taken in the unlikely event of a fire:

 Notify the fire brigade immediately and the EA

as soon as practicable;
 Isolate the burning area and attempt to
extinguish the fire utilising the on- site fire
extinguishers, if safe to do so;

SLR
Forterra Building Products Limited 19 SLR Ref: 416.05921.00016/ERA
Newbury Works
Environmental Risk Assessment May 2016

What do you do that can harm and what could be harmed Managing the Risk Assessing the Risk
Hazard Receptor Pathway Risk management Probability Consequence What is the overall
of risk
exposure
What has the potential What is at risk what do I How can the What measures will you take to reduce the risk? – How likely What is the harm What is the risk
to cause harm? wish to protect? hazard get to Who is responsible for what? is this that can be that still remains?
the receptor? contact? caused? The balance of
probability and
consequence
 Prevent, if possible, contaminated site drainage
from entering any unsurfaced ground; and
 Evacuate the site if the fire is not containable.

The Site Manager will be responsible for

implementing risk management measures in
accordance with the Best Available Techniques and
Operating Techniques (BATOT) document included
in this application and Forterra procedures.

Flooding Site Personnel Run off over The site does not lie within a floodplain. Low Contamination of Not significant
land Evacuation procedures will be implemented in the groundwater and
event of flooding. surface water
The Site Manager will be responsible for
implementing risk management measures in
accordance with the Best Available Techniques and
Operating Techniques (BATOT) document included
in this application and Forterra procedures.

Security and Vandalism The integrity of onsite Unauthorised The site is located within an industrial estate. Low Nuisance and harm Not significant
buildings and the loss of access The site will have the benefit of site security guard. to human health
products/machinery. Access to the site is via a lockable gate.
Gates and fencing will be inspected daily by the Contamination of
operations staff to identify deterioration and damage land and surface
and the need for any repairs. Fencing and gates will water
be maintained and repaired to ensure their continued
integrity. In the event that damage is sustained,
repairs will be made by the end of the working day. If

SLR
Forterra Building Products Limited 20 SLR Ref: 416.05921.00016/ERA
Newbury Works
Environmental Risk Assessment May 2016

What do you do that can harm and what could be harmed Managing the Risk Assessing the Risk
Hazard Receptor Pathway Risk management Probability Consequence What is the overall
of risk
exposure
What has the potential What is at risk what do I How can the What measures will you take to reduce the risk? – How likely What is the harm What is the risk
to cause harm? wish to protect? hazard get to Who is responsible for what? is this that can be that still remains?
the receptor? contact? caused? The balance of
probability and
consequence
this is not possible, suitable measures will be taken to
prevent any unauthorised access to the site and
permanent repairs will be affected as soon as
practicable.
All visitors to the site will be required to register in the
visitor’s book and sign out again on exit. This
minimises the risk of unauthorised visitors being
present at the site.
Operational procedures, including regular
inspections, ensure continual monitoring of security
provision at the site.
The Site Manager will be responsible for
implementing risk management measures in
accordance with the Best Available Techniques and
Operating Techniques (BATOT) document included
in this application and Forterra procedures.

SLR
Forterra Building Products Ltd 7 SLR ref.: 416.05921.00016/ERA
Newbury Works
Environmental Risk Assessment May 2016

5.0 CONCLUSION

This environmental risk assessment has been undertaken as described by regulatory

guidance. The assessment is provided as part of the application for an environmental permit
for the proposed Newbury Works.

This qualitative risk assessment has considered odour, noise, fugitive emissions, dust,
releases to water, litter, potential for accidents and incidents and impact on sites of
ecological importance. The assessment concludes that with the implementation of the risk
management and mitigation measures described above, potential hazards from the
proposed site are not likely to be significant and no further assessment is required.

SLR
Forterra Building Products Ltd 7 SLR ref.: 416.05921.00016/ERA
Newbury Works
Environmental Risk Assessment May 2016

6.0 CLOSURE

This report has been prepared by SLR Consulting Limited with all reasonable skill, care and
diligence, and taking account of the manpower and resources devoted to it by agreement
with the client.

This report is for the exclusive use of Forterra Building Products Ltd; no warranties or
guarantees are expressed or should be inferred by any third parties. This report may not be
relied upon by other parties without written consent from SLR.

SLR disclaims any responsibility to the client and others in respect of any matters outside
the agreed scope of the work.

SLR
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