CODE OF CONSTRUCTION PRACTICE - Planning Inspectorate... · 1.1.2 This Code of Construction...

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CODE OF CONSTRUCTION PRACTICE

Code of Construction Practice | August 2012 1



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2 Code of Construction Practice | August 2012



CONTENTS 1. INTRODUCTION.............................................................................................................5

1.2 Environmental Management System...............................................................................5

1.3 Construction Environmental Management Plans (CEMPs) .............................................6

1.4 Contractual Requirements...............................................................................................7

1.5 Other Environmental Controls .........................................................................................9

1.6 Transport .........................................................................................................................9

1.7 Waste Management ........................................................................................................9

1.8 Local Community Liaison ................................................................................................9

1.9 Considerate Constructors Scheme................................................................................10

1.10 Overall Approach...........................................................................................................10

1.11 Structure of the CoCP ...................................................................................................10

2. AIR QUALITY (INCLUDING DUST MANAGEMENT) ....................................................11

2.1 Design Control Measures ..............................................................................................11

2.2 Control Measures ..........................................................................................................11

2.3 Dust Inspections ............................................................................................................14

2.4 Relevant Requirements .................................................................................................15

3. LAND CONTAMINATION..............................................................................................17

3.1 Control Measures ..........................................................................................................17

3.2 Relevant DCO Requirements ........................................................................................19

4. WATER QUALITY..........................................................................................................21

4.1 Control Measures for the HPC Development Site..........................................................21

4.2 Control Measures (Construction)...................................................................................25

4.3 Control Measures (Operation and Post-Operation) ........................................................34


4.5 Auditing and Reporting ..................................................................................................35

5. NOISE AND VIBRATION................................................................................................37

5.1 Design Control Measures, Operational and Physical Constraints ..................................37

5.2 Noise Control Measures ................................................................................................39

5.3 Construction Noise Threshold and Trigger Level Exceedances .....................................41

5.4 Public Notification ..........................................................................................................42

5.5 Vibration Thresholds: HPC Development Site ...............................................................43

5.6 Vibration Monitoring.......................................................................................................43


6. EXCAVATED MATERIALS ............................................................................................45

6.1 Introduction....................................................................................................................45

6.2 Principle 1: Protection of Human Health and Environment.............................................45

6.3 Principle 2: Suitability for Use ........................................................................................46

6.4 Principle 3: Certainty of Use ..........................................................................................46

6.5 Principle 4: Quantity for Use ..........................................................................................47

6.6 Materials Reuse Arrangements ......................................................................................47

6.7 Soils...............................................................................................................................47




6.8 Made Ground.................................................................................................................47

6.9 Overburden ...................................................................................................................48

6.10 Weathered Rock ............................................................................................................48

6.11 Fresh Rock ....................................................................................................................48

6.12 Excavation and Stockpiling at HPC................................................................................48

6.13 Materials Acceptance Criteria (MAC) for Reuse.............................................................49

6.14 Site-Derived Materials – Validation Testing ...................................................................50

6.15 Material Treatment/Validation and Waste Classification ................................................50


7. ENVIRONMENTAL INCIDENT CONTROLS .................................................................53

7.1 Control Measures to Reduce the Likelihood of Environmental Incidents.......................53

7.2 Environmental Incident Response .................................................................................56

7.3 Environmental Incident Reporting and Investigation ......................................................57

7.4 Environmental Incident Response Training....................................................................58

7.5 Environmental Incident Drills and Auditing ....................................................................58

TABLES Table 5.1: HPC Development Site: Construction Noise Thresholds.............................................37

Table 5.2: Offsite Associated Development Sites: Construction Noise Thresholds.......................38

Table 5.3: Construction Vibration Thresholds ............................................................................43

APPENDICES Appendix 1A : construction environmental management plan template

Appendix 1B : Current Environmental and Sustainability Policies for EDF Energy

Appendix 1C : Environmental Legislation and Policy

APPENDIX 7A: ENVIRONMENTAL INCIDENT controlS

APPENDIX 7B: ENVIRONMENTAL INCIDENT reporting to the environment agency




1. INTRODUCTION

1.1.1 NNB Generation Company Limited (Company Number 06937084), part of EDF Energy, is the company that will lead the new nuclear programme in the United Kingdom. For the purpose of this document, NNB Generation Company Limited is referred to as EDF Energy.

1.1.2 This Code of Construction Practice (CoCP) supports the application for Development Consent. It sets out the management measures which EDF Energy will require its contractors to adopt and implement in the construction of the Authorised Project, to maintain satisfactory levels of environmental protection and limit disturbance from construction activities as far as reasonably practicable. It includes all of the measures detailed in the Subject Specific Management Plans (SSMPs) submitted with the DCO (Annex 3 and 4 of the Environmental Statement) (see Sections 2-7 of this document).

1.1.3 Requirement PW24 in Schedule 11 to the DCO requires the construction of the Authorised Project (i.e. the development described in Part 1 of Schedule 1 to the DCO, the temporary jetty works, and any other development authorised by the DCO) to be carried out in accordance with this CoCP, unless otherwise approved by the relevant local planning authority.

1.1.4 As part of the Environmental Management System (EMS) (see Section 1.2) the SSMPs are ‘live’ documents which guide contractors to the relevant management measures that are required during construction; the SSMPs carry through and implement the control measures contained within the CoCP.

1.1.5 The measures set out in this CoCP, the additional construction phase controls in the DCO requirements, the Section 106 Obligations and other environmental controls, provide a comprehensive set of measures to ensure that the effects during the construction of Hinkley Point C (HPC) remain consistent with those assessed in the HPC Project Environmental Statement.

1.2 Environmental Management System

1.2.1 Best practice guidance encourages the establishment of an EMS. EDF Energy has developed an Integrated Management System which incorporates Environmental Management.

1.2.2 The Environmental Management and Monitoring Plans (EMMPs) submitted with the application, provided in Annex 3 and 4 of the Environmental Statement are an integral part of the environmental arrangements within the EDF Energy Integrated Management System and provide the framework for ensuring environmental control on the HPC development site and the offsite associated development sites.




1.2.3 The EMMPs, together with the SSMPs, establish the environmental controls on construction works, including:

compliance with relevant environmental legislation (see Appendix 1B and 1C);

delivering environmental mitigation measures as identified within the DCO Environmental Statement (and other environmental management measures as appropriate) for the HPC Project; and

monitoring, recording and reporting environmental performance so as to demonstrate compliance with the relevant requirements.

1.2.4 SSMPs have been provided for both the HPC development site and the offsite associated development sites and relate to the following topics:

Air Quality;

Land Contamination;

Water;

Noise and Vibration;

Soil;

Materials; and

Environmental Incidents.

1.2.5 The EMMPs and SSMPs are live documents and are intended to guide contractors as to the relevant management measures that are required during construction. All contractors will be required to prepare Construction Environmental Management Plans (CEMPs). EDF Energy will require all contractors to respond to the site specific details contained in the SSMPs, including the list of sensitive receptors and pathways identified in the Environmental Incident Control Plan (EICP) for both the HPC development site and associated development sites. The relationship of these documents as part of the EMS is illustrated in Figure 1.1.

1.3 Construction Environmental Management Plans (CEMPs)

1.3.1 The Construction Environmental Management Plans (CEMPs) prepared by the contractors will set out details of the practical execution of the construction works and the implementation of the associated environmental management measures. A standard CEMP template, as provided in Appendix 1A of this CoCP, will be provided to all construction contractors to ensure consistency in monitoring and recording of environmental information across the Authorised Development sites and appointed contractors. Contractors will be required to provide the CEMP to EDF Energy for review and approval to ensure that all relevant requirements had been adequately addressed, including appropriate control and mitigation of any potential environmental impact.

1.3.2 Once these CEMPs are prepared, they will be issued in draft to relevant statutory bodies, such as the Environment Agency, Environmental Health Officers and the Local Planning Authority for consultation, if requested. The final CEMPs shall then be made available to the relevant statutory bodies before commencement of construction works. Observations made by statutory bodies will be taken into






account to ensure compliance with the controls put in place to manage and limit construction-related impacts.

1.3.3 The contractor will be required to review the CEMP and method statements throughout the work activities and update them as necessary during construction.

1.4 Contractual Requirements

1.4.1 Contractual requirements will be placed on EDF Energy contractors to comply with all applicable environmental and planning legislation, as well as the requirements of the EDF Energy Integrated Management System, including the EMMPs, SSMPs and EDF Energy Policy and Commitments.

1.4.2 It will be a contract requirement that the contractor will establish, implement and maintain a project specific EMS based on BS EN ISO 14001:2004. This EMS will be based on the measures and practice methods that have been set out in the SSMPs, which support the EMMPs. EDF Energy will require its contractors to demonstrate their EMS includes, as a minimum:

monitoring and review arrangements, including revisions to measures and procedures as appropriate;

implementing the environmental obligations of the project during construction works including legal and other requirements;

identifying environmental risks and opportunities particular to the site by:

reviewing relevant documentation;

consulting regulatory agencies; and

liaising with clients and designers to establish how they can assist to identify and overcome potential environmental risks and realise environmental opportunities.

identifying and managing environmental risks and opportunities and compliance with legal and other requirements during construction works;

defining the environmental responsibilities of relevant personnel within the site management structure, raising awareness of key environmental issues through training (e.g. ‘Tool Box’ talks); as well as defining lines of communication between staff and third parties; and

establishing the processes for monitoring, auditing and management review with the aim to ensure compliance with this CoCP and continually improve performance of the EMS.


Figure 1.1 Environmental Management System Documentation




1.5 Other Environmental Controls

1.5.1 EDF Energy will require all contractors to comply with all relevant legislative controls, construction health, safety and environmental standards and other relevant best practice methodologies. There are many codes, standards, acts of Parliament and subsidiary legislation, as well as statutory guidance, which cover environmental and related matters. Appendix 1B and 1C set out all the relevant environmental legislation and guidance that will be provided to contractors.

1.5.2 Notwithstanding these references, compliance with this CoCP will not absolve EDF Energy or its contractors from compliance with legislative requirements applicable at the time of construction activities. Wherever this Code makes reference to legislation, standards or codes it will be the contractor’s responsibility to ensure that the current versions are used at all times.

1.6 Transport

1.6.1 Controls and limits that are relevant to the construction traffic associated with the HPC construction works are dealt with through the Construction Traffic Management Plan (CTMP) and specific DCO Requirements and S106 Obligations.

1.7 Waste Management

1.7.1 The Waste Management Implementation Strategy sets out the overall framework within which waste and arisings will be dealt with during both construction and operation of the Authorised Project. EDF Energy has committed to preparing a template for the Site Waste Management Plans (SWMPs) that would form the basis for site specific SWMPs to be prepared by the contractors (Requirement PW20 ‘Waste Management Implementation Strategy’).

1.7.2 As required by the SWMP Regulations 2008, the SWMPs would need to be made available to the Discharging Authority, as such, the information could be readily provided to Somerset County Council (SCC) to enable monitoring of commercial and domestic waste arisings. The SWMPs would be developed to a level commensurate with the volume and type of waste to be handled on the site over the construction phase for the specific site.

1.8 Local Community Liaison

1.8.1 At least one week prior to the commencement of main construction activities in an area, i.e. earthworks, civil engineering or building activities, local residents who may be affected by the work will be notified of the nature of the proposed works and provided with a contact name, telephone number and address to which any enquiries should be directed.

1.8.2 EDF Energy will set up and co-ordinate a series of regular communication meetings with major stakeholders and local communities. EDF Energy will ensure that all stakeholders will be kept informed of progress throughout the lifecycle of the development. All matters related to construction activities will follow a similar communications protocol and a designated project manager will be appointed to liaise with the local communities during the construction phases of the development and to take effective action to deal with any complaints.




1.8.3 Requirement PW29 ‘Information Dissemination and Complaints Handling (G36)’ will ensure that appropriate action is taken in response to any non-compliance with approved plans or construction arrangements or in the event of physical damage.

1.9 Considerate Constructors Scheme

1.9.1 In addition to the arrangements under this CoCP the contractor will be required to register with the Considerate Constructors Scheme, which is a voluntary code of practice that seeks to:

minimise any disturbance or negative impact (in terms of noise, dirt and inconvenience) sometimes caused by construction sites to the immediate neighbourhood;

eradicate offensive behaviour and language from construction sites; and

recognise and reward the constructor’s commitment to raise standards of site management, safety and environmental awareness beyond statutory duties.

1.10 Overall Approach

1.10.1 The approach set out above will ensure that a comprehensive EMS will be in place to ensure the works are undertaken in accordance with the environmental performance commitments made in the EMMPs, and associated SSMPs, for the construction of the HPC project. The principal constraints and controls, however, are those set out in the CoCP or otherwise directly specified in DCO requirements or obligations.

1.11 Structure of the CoCP

1.11.1 This document is set out in sections relating to the topics assessed and in the Environmental Statement (ES) accompanying the application. Unless stated otherwise, the principles set out in this document apply to both the HPC development site and the off-site associated development sites.

1.11.2 The structure of the CoCP is as follows:

Air quality (including dust management);

Land contamination;

Water quality;

Noise and vibration;

Excavated materials;

Environmental incident control;

Appendix 1A: Construction Environmental Management Plan Template

Appendix 1B: Current Environmental and Sustainability Policies For NNB GENCO;

Appendix 1C: Environmental Legislation and Policy;

Appendix 7A: Environmental Incident Controls; and

Appendix 7B: Environmental Incident Reporting to the Environment Agency.




2. AIR QUALITY (INCLUDING DUST MANAGEMENT)

2.1 Design Control Measures

a) Materials Storage

2.1.1 Areas designated for stockpiling of friable materials or materials susceptible to generating wind borne dust will be positioned away from sensitive receptors, where possible. As far as is reasonably practicable, stockpiles intended for long-term storage will be placed directly in their planned position rather than via temporary storage so as to avoid the need for double handling that could give rise to emissions. Stockpiles of materials that are consumed as part of a construction process will be assessed to determine the necessity for dust suppression techniques to minimise dust generation. In each case, stockpiles will be shaped to avoid steep sides and sharp edges so as to reduce entrainment of dust by exposure to wind.

b) Site Area

2.1.2 All construction work activities will be undertaken within the designated construction site boundaries; including areas designed to accommodate stockpiles and haul routes.

c) Erection of Physical Barriers

2.1.3 Where appropriate, physical barriers will be erected around particularly dust generating activities.

d) Training

2.1.4 All site personnel will receive training appropriate to the nature of their roles and responsibility; the training will include specific information in relation to air quality management. All staff will receive induction training that will incorporate environmental awareness training and specific training in relation to air quality if their work activities are assessed as potentially producing fugitive emissions. On-site ‘Tool Box’ training will enable site workers to understand how their actions will interact with the environment and potentially impact upon a work area’s sensitive receptors.

2.2 Control Measures

a) Emissions from Plant Equipment and On-site Vehicles

2.2.1 The following mitigation measures will be implemented to limit emissions from construction plant and equipment used on each construction site:

engines of vehicles and equipment shall not be left running unnecessarily;




vehicles and equipment shall be maintained by a programme of routine servicing in accordance with the manufacturers’ recommendations, with records kept of the work undertaken;

haul routes shall be located and equipment operated away from sensitive receptors, where possible, including, but not limited to, houses and commercial properties;

avoid the use of diesel or petrol powered generators and use mains electricity or battery powered equipment where practicable; and

only use road vehicles that meet a minimum of Euro 4 standards during the works as set out in the EC Directive 98/69/EC.

2.2.2 All non-road mobile machinery shall use fuels with a sulphur content equivalent to ultra-low sulphur diesel fuel meeting the specification within EN590:2004. Measures will be implemented to ensure that all diesel fuel used on-site shall be ultra-low sulphur diesel (ULSD) (<10mgS/kg). The measures to ensure only ULSD fuel is procured for use on-site shall include the issue of written instructions to all contractors and audits/inspections of fuel delivery dockets.

2.2.3 Diesel fuelled construction vehicles travelling off site shall also use ULSD.

b) Dust and Particulate Control Measures

2.2.4 The following control measures will be implemented to minimise dust and particulate generation and dispersion:

the burning of material and or waste on-site shall be strictly prohibited;

ensure an adequate supply of water and means of deployment is available at all work areas for dust suppression measures;

dispose of runoff water from dust suppression activities in accordance with the appropriate legal requirements such as discharge consents and/or surface water discharge consents as appropriate;

maintain all dust control equipment in good condition and record maintenance and servicing activities;

keep site fencing, barriers and scaffolding clean using wet methods; not blowing with compressed air lines etc;

provide easily cleaned hard standing for vehicles as appropriate;

ensure regular cleaning of hard standings using wet sweeping methods;

avoid dry sweeping of large areas;

provide and ensure the use of wheel wash facilities near the site exit wherever there is a potential for carrying dust or mud out of the work areas onto the public highways;

ensure wheel wash facilities are fitted with rumble grids to dislodge accumulated dust and mud prior to leaving the work sites wherever there is a potential for carrying dust or mud out of the work areas;




where site space and layout plans permit, ensure there is an adequate area of hard surfaced road between wheel wash facilities and the working area egress points;

inspect haul routes for integrity and instigate necessary repairs to the surfaces as soon as is reasonably practicable;

as dictated by site conditions, regularly damp down unsurfaced haul routes and working areas in dry conditions;

implement a programme of wet sweeping for site access and egress points and include area of public road potentially affected by dust accumulation from our working areas;

position the exhausts of vehicles working on-site to minimise the risk of re- suspension of ground dust (exhausts point upwards);

ensure all vehicles transporting loose or potentially dust generating materials to and from working areas on the public highways are fully sheeted;

ensure bulk cement and other fine powder materials are delivered in enclosed tankers and stored in silos with suitable emission control systems to prevent escape of materials and overfilling during delivery;

enclose or shield areas designated for mixing large quantities of cement, bentonite, grouts and other similar materials. The location of designated areas for mixing these materials should be remote from the site boundary and potential receptors where feasible;

store materials with the potential to produce dust away from working area boundaries wherever practicable;

ensure sand and other aggregates are stored in bunded areas and are not allowed to dry out;

minimise, as far as is reasonably practicable the amount of excavated material stockpiled in the work areas and sheet, seal or damp down unavoidable stockpiles of excavated material held in the working areas. Where appropriate consider sealing or seeding materials and soil stockpiles if they are not to be used for a long period of time;

avoid double handling of friable/dust yielding material wherever practicable;

use water suppression during demolition operations;

hold a copy on-site of the permit required for any crushing or grinding equipment used on-site, which falls within the definition in Section 3.5 Chapter 3 of the Pollution Prevention and Control (England and Wales Regulations 2000 SI1973);

use enclosed rubble chutes and conveyors on crushing or grinding equipment or use water to effectively suppress dust emissions;

sheet or otherwise enclose loaded bins and skips;

minimise drop heights from conveyors, loading shovels, hoppers and other loading or handling equipment and use fine water sprays on such equipment;

seal or re-vegetate completed earthworks as soon as practicable following completion;




design and prefabricate where feasible to reduce the need for grinding, sawing and cutting on site;

use cutting, grinding or sawing equipment fitted or in conjunction with suitable dust suppression techniques such as water sprays or local extraction;

ensure slopes of stockpiles are no steeper that the natural angle of repose of the material and maintain a smooth profile;

ensure that appropriate spill kits, clean up and containment materials are available and that they are used immediately in the event of a spillage; and

identify work activities that have a high potential for dust emissions, enclose fully and maintain the enclosure for the duration that the specific work activity is in operation.

c) Odour

2.2.5 It is not anticipated that odour generation will be significant during the construction of the Authorised Project. However EDF Energy will adopt measures as appropriate to avoid the generation of odours. These measures will include, but not necessarily be limited to:

covering containers holding waste and regularly removing waste containers from site;

careful programming to minimise the duration of work with potential to generate odour nuisance, including but not limited to that on sewers;

removing odour generating materials sources in a timely fashion to limit the formation of odours;

where odour forming materials are encountered and cannot be removed or avoided, the spraying with an approved oxidising agent will be undertaken to minimise the potential for release of odour; and

use of an odour guard or masking agents will also be considered in situations where the risk of odour release cannot be eliminated or controlled.

2.3 Dust Inspections

2.3.1 The dust inspections outlined below will be applied by EDF Energy and undertaken by the EDF Energy Site Environmental Engineer or nominated competent person. Records of inspections will be maintained within the relevant site office. The dust inspections will include the following elements:

record all inspections of haul routes and any subsequent action in the dust log pro-forma at least once per day;

conduct inspections to monitor compliance with dust control procedures in accordance with the measures outlined within this CoCP. Record the results of the inspections, including nil returns, in the dust log pro-forma at least once per day;

increase the frequency of site inspections when activities with a high potential to produce dust are being carried out and during prolonged dry or windy conditions; and




record any exceptional occurrences causing dust episodes on or off the site and the action taken to resolve the situation.

2.4 Relevant Requirements

2.4.1 Details of air quality monitoring for the HPC development site (Work No. 1A) shall be developed prior to the commencement of construction works, pursuant to Requirement MS1B ‘Air Quality Monitoring Scheme’, as follows:

(1) No development shall commence until an air quality monitoring scheme has been submitted to and approved by West Somerset Council. The submitted details shall include:

(a) The air quality monitoring methodology comprising continuous ambient particle (PM10, PM2.5 and Total Suspended Particles) and wind speed and direction, temperature, relative humidity and rainfall monitoring at locations at or near to Doggetts, Knighton Farm, Head Weir House (west of Wick Village) and Yellow Door Cottage (Shurton) which monitoring shall begin not less than one month prior to the date proposed for commencement of development and continue until completion of construction works.

(b) Provision for the submission of proposals for continuous periods of monitoring and the provision of the results to West Somerset Council, together with proposals for the review of monitoring periods following the first anniversary of commencement of development.

(c) The monitoring details shall include real time logging of averaging periods of not less than 15 minutes and include remote interrogation and downloading and details of automatic notification to West Somerset Council and other persons (such as the site manager) in circumstances where monitored concentrations exceed the trigger levels.

(d) The steps to be taken in the event that maximum hourly mean concentrations for PM10 of 200μg/m3 are exceeded.

(e) The identity of persons to carry out visual inspections in order to review the potential for dust nuisance and, in the event of dust nuisance complaints being made, to help quantify the actual or potential dust nuisance.

2.4.2 Project wide Requirement P30 ‘No Burning of Materials (G10)’ requires that there shall be no burning of materials or refuse on the site at any time during the construction of the Authorised Project.




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3. LAND CONTAMINATION

3.1 Control Measures

a) Contractors Compound and Plant

3.1.1 All contractors’ compounds will be secure from third party access. When compounds are not in active use (out of core hours), materials stores and plant will be locked to prevent unauthorised use which could cause a pollution incident. Mobile plant parked overnight within the site will also be locked to prevent unauthorised use.

b) Generators/Static Diesel Powered Plant

3.1.2 All generators and static diesel powered plant used on-site will either be fully bunded to contain spills from operation and refuelling, or placed on drip trays to prevent contamination of the ground. This requirement will apply to all generator sets, pumps and static mobile plant used across the site.

c) Imported Fill Materials

3.1.3 Where it is necessary to import any fill or engineering fill materials to site for either permanent or temporary works from recycled or reused sources, these shall have been produced to the WRAP Quality Protocol standard. The acceptance criteria for the recycler who provides the material shall state that it may only accept clean uncontaminated rock, subsoil, brick rubble, crushed concrete and ceramic or other materials deemed acceptable. Prior to accepting delivery of the first consignment of Quality Protocol approved materials, EDF Energy will undertake an audit of the recycler’s facility to check compliance with its quality management arrangements. Following a successful audit, visual inspections and/or physical sampling and chemical analysis (as necessary) of fill materials imported to site will be undertaken by the contractor’s site foreman to ensure compliance with specification, including an assessment of any non-compliant constituents. Materials failing to meet the agreed specification on either engineering or contamination grounds will be quarantined on-site and returned to the supplier, subject to any health and safety or waste management requirements.

d) Site Area

3.1.4 All construction work activities will be undertaken within the designated site boundaries, including the areas designed to accommodate stockpiles and haul routes.

e) Erection of Physical Barriers

3.1.5 Where risk assessment determines that this is appropriate, physical barriers will be erected to prevent migration of contaminants.

f) Covering of stockpiles/lorry loads

3.1.6 This will be undertaken as necessary to prevent the mobilisation of contaminants.




g) Waste Disposal/Burning

3.1.7 No bonfires will be permitted on-site.

h) Concrete Wash Out

3.1.8 Wash out of concrete wagons or concrete handling equipment will be restricted to dedicated facilities within site compounds where systems such as Siltbuster will be installed and operated. This also applies to grouting and bentonite contaminated equipment.

i) Biological Contamination

3.1.9 All mobile plant brought onto the site for use in soil excavation and or transportation, including excavators, dump trucks, tractors and water bowsers, will be inspected for accumulation of soil within the chassis, wheels or tracks. Any such contamination will be jet washed on a concrete hardstanding area so as to ensure that no invasive plant seeds or rhizomes are accidentally imported.

j) Fuelling Handling

3.1.10 No refuelling shall occur within 10m of a watercourse or indicative floodplain without protective refuelling measures set out in the Environment Agency’s Pollution Prevention Guidelines PPG5. Contractors will be required to submit details of permanent refuelling locations, systems and protective measures for approval by EDF Energy prior to use. Contractors will not be restricted in the number and location of their fuelling locations, but will be required to comply with these guidelines when designing their refuelling infrastructure wherever they are located within the site boundary. Equivalent requirements will be implemented for the storage of materials, chemicals and substances which have the potential to pollute the environment.

k) Oil Interceptors

3.1.11 Oil interceptors will be installed to catch and process all surface water drainage from impermeable parking areas, lorry parks and hardstanding for vehicles before the water is discharged to any watercourse, surface water sewer or soak away system. Details of the oil interceptors will be submitted to and approved in writing by the relevant authority. The oil interceptors will be constructed prior to first use of the relevant area and shall be retained and maintained thereafter through all phases of the development.

l) Storage of Oils, Fuels, Concrete and Chemicals

3.1.12 Any facility for storing oils, fuels, concrete, or chemicals will be sited on an impervious base and either graded to drain to a sump/collector or surrounded by impervious walls. The volume of the bunded compound must be at least equal to the capacity of the storage tank plus 10%. All filling points, vents, gauges and sight glasses must be located within the bund. The drainage system of the bund shall be sealed with no discharge to any watercourse, land or underground strata. Associated pipe work must be located above ground and protected from accidental damage. All filling point and tank overflow outlets must discharge into the bund.




m) Training

3.1.13 All site personnel will receive training appropriate to their role and responsibility. Training will include specific information on land contamination. On-site ‘Tool Box’ training will enable site workers to understand how their actions interact with the environment and potentially impact on sensitive receptors for their work areas.

3.2 Relevant DCO Requirements

3.2.1 Project wide Requirement PW31 ‘Previously Unidentified Contamination’ sets out the measures that would be undertaken should contamination not previously identified be found to be present at the site.

3.2.2 Additional controls relating to potential land contamination are set out within specific controls for each relevant site. For the HPC development site the relevant requirements include:

P14A: Geology and Contaminated Land: Contamination Risk Assessment and Implementation (SP11).

P14B: Storage of Oils, Fuels, Concrete and Chemicals (G20).

P15: Geology and contaminated land: radiological monitoring (SP10).

3.2.3 For the off-site associated development sites, only Bridgwater A and C require specific controls relating to contamination risk, they are:

Bridgwater A:

BRIA18: Contamination; BRIA19: Contamination; BRIA20: Contamination; and BRIA21: Contamination.

Bridgwater C:

BRIC14: Contamination; and BRIC15: Piling or any other foundation designs using penetrative methods.

Junction 23:

J23-13: Contamination.




4. WATER QUALITY

4.1 Control Measures for the HPC Development Site

4.1.1 Appropriate design features have been incorporated into the construction stage of development at the HPC development site to minimise potential water quality impacts arising from the construction works. These design features provide the first level of control that assist in affording protection to local water quality conditions and Environmental Permit requirements are met. Central to these design features are the surface water drainage systems.

a) Drainage Systems

i. Initial Drainage Design

4.1.2 The initial drainage system will include temporary ditches, soakaways and lagoons to manage surface water drainage.

4.1.3 To support the site construction works there will be a need for the provision of site services and facilities, which will include site establishment works (compounds, welfare facilities, haul roads, site access, vehicle parking, utility services) and provision and operation of construction plant and machinery (concrete batching, refuelling, aggregate crushing, wheel and plant washing).

4.1.4 Contractors must ensure that all drainage elements and management plans are in accordance with the design elements contained within the Environment Agency’s Pollution Prevention Guidance notes. In general terms, these include:

minimising the stockpiling of materials and locating essential stockpiles as far away as possible from drainage networks and indicative floodplain, where practicable;

any temporary drainage networks that might be developed to cover interim periods during the construction of the permanent drainage system;

silt traps used to capture suspended solids;

oil storage and refuelling facilities;

oil/water separators; and

drainage rate control to ensure runoff does not exceed the agreed discharge rates.

4.1.5 All drainage systems under the site construction works shall be designed for exceedances up to the 3.33% Annual Exceedance Probability (AEP).

4.1.6 Specific details of measures to protect the water environment will be agreed with the Somerset Drainage Boards Consortium (SDBC), Local Planning Authority (LPA) and the Environment Agency as and when appropriate before the commencement of construction works, and must be detailed in method statements to be prepared by the contractor prior to works taking place.




4.1.7 Slopes or embankments that are intercepted by the main working areas of the site will have drainage facilities at the respective points of inflection. To prevent sediment from entering the drain, filtration measures will be employed. Contractors will assess the most suitable method of sediment filtration on a case by case basis, these are likely to include:

silt fencing; or

sediment mats or tube, i.e. ‘Sedimats’ and/or straw bales.

ii. Site Construction Drainage Design

4.1.8 Details of the surface drainage system that will be installed and available during the HPC development site works are contained in the HPC Site Drainage Strategy (see Appendix 2A of Volume 2 of the ES).

4.1.9 In terms of the drainage strategy, the site will be divided into the northern Build Development Areas (BDA) and the Southern Construction Phase Area (SCPA) to the south. During the early phases of site activity, surface drainage in the BDA will be collected through temporary drainage ditches and existing agricultural drainage ditches for ultimate discharge to the Hinkley Point foreshore via the existing HPC Drainage Ditch. The earthworks during site construction works will result in infilling of the existing agricultural drainage ditch system which will subsequently be replaced with three deep spine drains. The spine drains will collect surface drainage from the northern part of the site for discharge to the foreshore through a single upper foreshore discharge point in the approximate location of HPC Drainage Ditch. This is indicated at Figure A.1.6 of the HPC Drainage Strategy.

4.1.10 Part of the initial site drainage works includes the culverting of the reach of Holford Stream along its course across the SCPA. The primary purpose of the culvert is to increase the area available for stockpile and materials storage in the SCPA. The culvert will also provide an additional function in that it will, once constructed, offer an additional degree of protection to the water quality status of Holford Stream. Drainage from this area will be discharged via outfalls to the culverted Holford Stream. Discharges to Holford Stream will be made at greenfield rates, as defined in the HPC Drainage Strategy.

4.1.11 In the later stages of the construction programme, the side of the Bum Brook is proposed to be reprofiled. This will require the temporary removal of topsoil and placing of material to create the required slopes. This work will result in an increase in the rate of surface water runoff. To mitigate this increase, a Water Management Zone (WMZ) will be created and will be required to hold runoff from a 3.33% AEP (1 in 30 year) flooding event whilst being permitted to discharge to the Bum Brook stream at greenfield runoff rates.

4.1.12 The drainage system in both the BDA and SCPA will be supported by WMZs to ensure compliance with environmental permit conditions in terms of discharge quality and flow rates.




iii. Oil Interceptors and Separators

4.1.13 The principal approach for preventing discharge of hydrocarbon contaminated surface water into drainage features will be via oil separators within the system. Oil interceptors will, as a minimum, serve surface drainage from impermeable surfaces such as vehicle parking areas etc. Roof water will not be passed through oil interceptors.

4.1.14 The design guidance provided in PPG 3 on the ‘Use and Design of Oil Separators in Surface Drainage Systems’ should be followed for both temporary construction and permanent surface drainage system.

4.1.15 Oil separator units will be subject to routine inspection, maintenance and emptying as part of a planned preventative maintenance schedule to ensure performance.

iv. Water Management Zones (WMZs)

4.1.16 The WMZs will form terminal infrastructure of the construction phase drainage systems prior to discharge. The WMZs will provide the necessary facilities to ensure that discharges comply with the permit consent limits in term of volume, rate and chemical quality. These facilities will include lagoons for the attenuation and settlement of solids, together with oil interceptors for the removal of hydrocarbons. The configuration of the WMZs may change during the course of the construction phase to ensure that surface drainage volumes and water quality conditions continue to be effectively managed to meet required discharge permit conditions.

v. Discharge Locations

4.1.17 For the purposes of the water management during construction works there are four discharge locations for the disposal of water from the HPC development site that are likely to be subject to environmental permits.

4.1.18 It is anticipated that the following discharges permits would be sought:

temporary discharges (via six proposed outfalls) to the Holford stream prior to installation of the culvert (this to receive shallow groundwater and rainfall pumped from excavations during the culvert construction and associated earthworks);

discharges to the HPC Drainage Ditch in advance of installation of the spine drain system;

discharges to the Hinkley foreshore from the northern spine drain system;

discharge from the WMZ at the eastern end of the culverted Holford stream in the SCPA; and

discharge from the WMZ at the western end of the culverted Holford stream in the SCPA.




b) Holford Stream Culvert

4.1.19 The culvert is likely to be a pre-cast reinforced rectangular concrete structure manufactured offsite and laid on a suitable foundation on a course parallel to the existing stream. The offline construction of the culvert will minimise the need for in-channel works on Holford Stream that could potentially impact upon downstream water quality and aquatic habitats. The culvert has been designed to minimise flood risk in this area.

c) Materials Stockpiling

4.1.20 The SCPA has been designated as an area for segregated stockpiling of excavated soil and rock. Drainage from stockpiling areas may be high in suspended solids and surface drainage systems around each of these storage areas will direct this drainage towards the WMZ. The potential is recognised for excavated stockpiled rock to generate drainage with low pH; storage of rock materials separately provides an opportunity for pre-treatment of any drainage with low pH prior to its entry into the WMZs where it will combine with drainage from other sources.

d) Internal Haul Roads

4.1.21 Haul roads will be available to ensure construction traffic follows designated routes around the site. This will reduce generation of sediment-laden water from soil erosion and offers opportunity for road drainage to be collected as required and managed through direction to one of the WMZs.

e) Sanitary Waste Water Disposal

4.1.22 During site preparation, package treatment plants will be installed and commissioned in readiness for site construction works. Discharges from the operational plants in the northern part of the site will be discharged to the foreshore through connection into the spine drain system.

4.1.23 Sanitary waste water disposal from the on-site accommodation campus will be routed northwards through the surface and foul water drainage system and treated before discharge through the construction outfall into Bridgwater Bay. This waste water stream will be subject to an Environmental Permit.

f) Dewatering System Design

4.1.24 It is currently proposed that, to cater for the deep dewatering from the nuclear island deep excavations, a deep well dewatering system will be installed. Further pumping trialling, design work and modelling is anticipated to accurately predict the zone of influence of the dewatering system. Once working, the dewatering system will draw down groundwater and any accumulation of surface water ponding in the base of the excavation. The deep wells will be lined to prevent the ingress of sediment. A granular filled porous land drain system will be installed around the perimeter of the deep excavation to intercept and remove any surface runoff so as to minimise water accumulation in the excavation base. The controls for the dewatering system will be electronically operated to enable warnings to be generated in the event that the system fails.




4.1.25 Groundwater and uncontaminated water extracted will be pumped to the surface and discharged into the main collector drain and subsequently to the intertidal outfall under the auspices of the appropriate environmental permit.

4.2 Control Measures (Construction)

4.2.1 To augment the measures incorporated into the design of the site construction works, a range of mitigation measures will also be implemented to further reduce the impact of construction work activities.

4.2.2 Effective environmental management of surface water (with regard to pollution potential) is supported through a ‘toolbox’ of management measures. Describing a toolbox of techniques is considered more appropriate for the plan than a prescriptive approach. The contractor will draw upon this range of mitigation techniques as required in a proactive manner to meet the variable conditions that will be presented by an evolving site landscape. The use of the Environment Agency’s Pollution Prevention Guidance notes should form a key part of surface water management, as recommended within the Environment Agency’s discharge conditionality report and HPC Drainage Strategy document. Another key document that may be used as a reference guide for site contractors is the ‘Control of water pollution from construction sites. Guidance for consultants and contractors, CIRIA C532’.

a) Sediment Control Measures

4.2.3 The management of suspended sediment in any application can be broadly broken down into the following three components:

mitigation at source;

mitigation during the drainage transportation phase; and

mitigation subsequent to the transportation phase and prior to site discharge.

4.2.4 Mitigation at source is the most desirable form of mitigation although it is not always practicable. Therefore, the measures outlined below should be implemented in conjunction with other procedures that seek to trap suspended sediment during the transportation phase. The following section provides a toolbox of techniques that can be incorporated to meet the demands of the prevailing site conditions.

i. Protecting Exposed Soils

4.2.5 Where soil slopes or embankments are likely to be exposed for a prolonged period of time during site construction works, it will be desirable to reduce the potential for erosion in these areas by converting the surface cover of these areas from bare earth. This can be achieved by a number of means including sensible sequencing of the works to avoid prolonged stockpiling where possible, use of compacted stone or loose but coarse stone (i.e. greater than 10mm), covering with terram cloth or other suitable material.

4.2.6 Another solution is to grow and maintain a grassed coverage on slopes and embankments. This measure can include growing grass from seed or by installing biodegradable mats impregnated with grass seed in order to provide immediate protection once the mats have been laid. This method provides protection against erosion and also filtering out sediments.




ii. Sediment Fencing and Sediment Tubes

4.2.7 Where erosion cannot be prevented at source, it will be necessary to remove as much of the suspended load as possible prior to entry into the temporary drainage system. Silt fences or sediment tubes can be employed at the base of, or in series along, any slopes upon which sediment is generated by surface runoff (i.e. sheet, rill or gully erosion). When installing silt fences or sediment tubes the base should be sunk into the ground to ensure that no flows are directed underneath the barrier. The silt fences or sediment tubes should be firmly staked to ensure that the pressure exerted by significant surface water flows is not sufficient to breach the barrier. However, when it is known that surface water flows could compromise the structural integrity of silt fences other measures should be selected as silt fences are not designed to act as filter dams.

4.2.8 The condition of silt fences and sediment tubes should be periodically checked to ensure that any build up of sediment does not exert too much pressure, particularly after a significant surface runoff event. When possible, sediment deposited upslope of silt fences should be removed and disposed of in an area where it will not be at risk of being remobilised. The base of silt fences and sediment tubes should be frequently checked to ensure that no preferential pathways develop during a surface runoff event such that surface water and its suspended load will be routed directly under the fence. The firmness of the supporting stakes should also be periodically checked in an effort to avoid the fencing collapsing during surface water runoff events.

iii. Sediment Mats

4.2.9 Sedimats are fabricated from hessian, the base being continuous hessian while the face consists of a hessian net exterior which holds hay or coir matting within. Sedimats are laid face-up on channel/ditch/flume beds and trap suspended particles. They work best in shallow flows and require continuous mixing of the waters (generally the case in most flowing waters) in order to afford maximum exposure of the sediment load to the Sedimats. Sedimats can be an effective measure in fast or turbulent flows. Therefore they should be placed in areas of the drainage system where the conditions are suited to maximum performance. Also, sediment mats require replacement subsequent to significant sediment transport events.

iv. Straw Bales

4.2.10 Straw bales are commonly installed in drainage ditches (width or length ways) and in standalone situations as an alternative to silt fences where the discharge width is not that great. Whilst effective against, more coarse components of the suspended load (sand and silt) will be less effective when the load is comprised of clay particles. If the clay particles are towards the finest end of the scale, straw bales will be largely ineffective.

4.2.11 Great care will be taken when installing straw bale filters in ditch systems as the resultant impediment to flow will direct water towards the ditch margins which will then be subject to erosion if not protected. Similarly, where the contact between the base of the straw bale and the ditch bed is not that tight, flows will preferably be routed between the bale and ditch bed interface. Not only will this result in the suspended load being unexposed to filtration, but will also promote scouring of the ditch bed, thus exacerbating the problem.




4.2.12 In order to negate the potential problems highlighted in the previous paragraph, it is suggested that, when possible, ditches should be lined with terram cloth which will be held firmly in place by appropriate means (i.e. sandbags, stone). Although the use of terram cloth will mitigate the potential of the ditch banks being eroded, it is imperative that the fit between the straw bale and the channel margins, to include the bed, is impermeable. When it is not possible or desirable to use terram cloth to line drainage ditches, it is recommended that the ditch is lined with stone. The stone should not be so small as to be susceptible to entrainment. This will clearly depend on the ditch capacity.

v. Lagoons

4.2.13 Lagoons can be designed to handle the excess capacity of flows that might be generated during a significant surface runoff event, serving to attenuate the flow to allow sufficient time for sediment to settle prior to discharge into the watercourse. Lagoons will form an integral part of the WMZs. Holding lagoons can be designed in a number of ways in order to promote the deposition of suspended sediment prior to site discharge. Examples of three such designs are presented below.

4.2.14 Lagoon Type 1: Water can be retained in open lagoons while the suspended sediments are allowed to uniformly settle over the entire surface area of the lagoon. Once clear, water can be released into the watercourse via pumping or gravity drainage, ensuring that sediment deposits are not disturbed during this process. If the design specifications of the lagoon and the inflow rates are such that water is sufficiently clear at the downstream end of the lagoon, release of clean waters into the watercourse should occur concurrently with inflow of turbid waters at the upstream end of the lagoon.

4.2.15 Lagoon Type 2: Partitioned lagoons might consist of several compartments separated by either permeable filtration walls or impermeable walls that serve as weirs. Partitions will be orientated perpendicularly to the general direction of flow in the lagoon. Successive partitions will thus decrease in height slightly towards the lagoon outlet to avoid backflows (this should also be implemented for permeable partitions in the event of them becoming blocked).

4.2.16 Lagoon Type 3: A series of impermeable alternating open-ended partitioning baffles can be constructed in order for water to be encouraged to flow in a series of S-shapes, which increase the retention time for settlement. If the likely range of inflows is known, together with settling velocities of site soils and lagoon specifications, the number of walls can be designed a-priori such that waters arriving at the lagoon discharge point will always be clear enough to discharge directly from the site. When the information is available, this type of lagoon is recommended as partitions will consume valuable lagoon capacity. This design is the preferable choice for settlement when using flocculants.

vi. Weirs

4.2.17 Systems of weirs will be constructed in drainage ditches such that the reduced flow velocities upstream of weirs will promote the deposition of sediment. This situation will, to a degree, occur in ditches containing straw bales during times of increased flows when the rate of infiltration through the bales is less than the ditch discharge, thus causing backwater levels to increase up to a point when they may over top the weirs. As with straw bale filtration ditches, systems of weirs will require routine




monitoring, especially immediately after a significant rainfall event and, where necessary, sediment deposits will have to be removed to maintain the maximum capacity of the ditch.

vii. Siltbusters™

4.2.18 Where there is a need to rapidly filter the suspended sediment load from the water body, Siltbusters™ (see http://www.siltbuster.co.uk/) are an effective means of handling the sand and silt component of the load down to a particle size of 0.015mm (fine to medium silt). However, when the suspended load contains finer particles, additional chemical treatments may be necessary (flocculants for example; see following section) in conjunction with Siltbusters to effectively treat the load. When the suspended load contains colloidal clay pre-treatment with chemicals is advised prior to using Siltbusters. When the suspended material is suitably coarse, Siltbusters can effectively treat 50-100m3 of water per hour. Additionally the units take up a relatively small area and thus provide a practical solution where it is not possible to install settlement tanks or to construct a lagoon.

viii. Flocculant Induced Sediment Deposition

4.2.19 When medium and colloidal clay content within site soils is sufficiently high, the aforementioned mitigation measures may not be effective at filtering out this component of the suspended load. As such, flocculants can be used in order to induce the aggregation of fine particles into more coarse particles that will readily settle out of suspension. Flocculants are chemical compounds that adjust the electric charge of individual clay particles such that they are attracted to each other, as opposed to being repelled. Examples of flocculants include aluminium sulphate (alum) and organic polymers.

4.2.20 Flocculants can be applied in one of three ways.

Firstly, they can be dosed as a solution into a body of turbid water prior to entering either a settlement tank or a lagoon. When flow is into a lagoon, flow will typically be encouraged to take an S shaped path in order to try and maximise the residence time and thus the degree of deposition. Residence times are typically in the range of 30-60 minutes for correctly dosed flows.

Secondly, flocculants can be applied via soluble 1kg blocks that sit in a cage that will be subjected to flows discharging into the chosen settlement vessel. Both the solution and soluble forms of flocculant require knowledge of flow rates. Whilst solution doses are controlled by a pump and can thus be regulated, flows have to be controlled in order to regulate soluble dosing.

Thirdly, when it is necessary to flocculate suspended sediment in still water (such as in a lagoon subsequent to a significant event), solute flocculants must be well mixed, typically by air diffusers, in order to ensure uniform deposition across the holding vessel. Soluble blocks cannot be applied in this way as they require running water to dissolve them.

ix. Additional Filtration Prior to Discharge

4.2.21 Other methods of filtration can be employed throughout the site in an attempt to reduce suspended solid concentrations. Such methods include the construction



http://www.siltbuster.co.uk/)


of enclosures using straw bales or another robust construction material and lining with a suitable filtration material. Water is then pumped or drained into these enclosures and allowed to freely drain. The use of these enclosures is more practical as a final source of filtration prior to discharge into the watercourse. Filtration materials require routine monitoring and cleaning to ensure optimum rates o f flow from the enclosures. Similarly, filtration socks or sediment bags can be placed over outflow pipes although flow rates must be carefully controlled to allow correct performance.

x. Flow Attenuation to Reduce Sediment Disturbance

4.2.22 Many construction activities can result in compaction of previously permeable surfaces (soils and grassland) or the direct installation of impermeable surfaces. A common consequence of construction site activities is an increase in surface water runoff rates, particularly associated with storm events.

4.2.23 If flow rates are allowed to increase within receiving watercourses, there exists the potential for in-channel sediments to be disturbed and mobilised into the water column (at an increased rate relative to a pre-construction state). There is also increased risk of erosion of the bed and banks.

4.2.24 Flow attenuation, afforded in particular by drainage system design, will mitigate against sediment disturbance within watercourses. Flow attenuation measures are also used to mitigate flood risk via peak flow attenuation. Flow attenuation is most commonly achieved through runoff ponds, managed so that they store surface waters and discharge these in a controlled manner.

xi. Riparian Erosion Protection

4.2.25 Riparian zones are areas vulnerable to erosion if left unprotected on construction sites. The most effective method of protection is separation from construction activities and machinery access through t h e establishment of buffer zones alongside watercourses.

4.2.26 A further precaution may be afforded by demarking buffer zones using sediment fencing, thus providing an impermeable barrier for sediment contaminated runoff.

4.2.27 Holford Stream has been identified as a particularly sensitive water quality receptor because of the downstream water dependent Site of Special Scientific Interest (SSSI). A buffer zone should be established along the length of Holford Stream, until such time as the culvert is commissioned. Construction of the Holford Stream culvert will take place offline in order to minimise sediment disturbance and generation from in-channel works.

b) Use and Management of Hydrocarbons

4.2.28 There is potential for hydrocarbon contamination of surface drainage water to occur during the site construction works. The source of hydrocarbons results from the use of vehicles, parking and maintenance areas and around refuelling facilities. Hydrocarbons contamination entering the surface drainage system may arise from wash-off or leakage from plant or spillages at designated refuelling areas.




4.2.29 There is legislation and pollution prevention guidance on the storage and use of fuels which is described in the Pollution Prevention Guidelines (PPG) such as PPG2 ‘Above Ground Oil Storage Tanks’ and PPG5 ‘Works and Maintenance in or near Water’. The guidelines detail the approaches and procedures that should be adopted to prevent the majority of hydrocarbon contamination. Such measures will include:

the secure bunded storage of fuels and oils at a location at distance from watercourses or drainage systems and outside the indicative floodplain;

designated parking, maintenance and refuelling areas with appropriate drainage system incorporating oil interceptors;

provision of spill kits and drip trays; and

use of biodegradable hydraulic oils and lubricants in plant where possible.

4.2.30 The procedures for dealing with more significant spillages of fuels and oils are covered within Section 7 of this document, Environmental Incident Controls

4.2.31 There may be some residual hydrocarbons present in the surface drainage from plant activity that will require removal prior to disposal to the freshwater marine environment or to any approved soak-away area. Removal will be undertaken through use of oil interceptors incorporated in to the drainage system.

4.2.32 To be effective an oil separator should be subject to routine inspection and maintenance to ensure that it is functioning correctly and not allowing hydrocarbon contamination to pass in to any discharge.

c) Storage of Fuels and Oils

4.2.33 Fuels, oils and lubricants should be stored in a secured area at a site located at distance from surface watercourses. These hydrocarbons should be stored on areas of hardstanding with a drainage system that includes oil separators and emergency shut-off valves.

4.2.34 Above ground fuel storage tanks should be located on hardstanding areas and provided with a suitably sized bund to allow containment of fuels in the event of tank collapse. All valves should be secured with locks and any associated pipework and hoses regularly inspected for leakage.

4.2.35 Spillage and containment kits should be available in the fuel storage area for rapid deployment in the event of spillages or an incident.

d) Vehicle Parking, Maintenance and Refuelling Areas

4.2.36 Dedicated areas should be identified for the parking, maintenance and refuelling of vehicles and plant. Where necessary, these areas should be hard standing with a dedicated drainage system that incorporates both oil interceptors and emergency isolation values. All of these facilities, particularly designated refuelling areas should be sited at distance from any surface water features. Spillage and containment kits should be available for these areas for rapid deployment in the event of spillages or an incident (see Environmental Incident Control Plan (EICP)).

4.2.37 There may be a requirement for mobile refuelling of generators or other plant to be undertaken outside the main designated refuelling areas. Any mobile refuelling




should not be undertaken adjacent to surface watercourses or the Hinkley Foreshore area. Mobile refuelling s h ou l d be provided with drip trays and spill/containment kits as necessary.

e) Oil Interceptors and Separators

4.2.38 The principal approach for preventing discharge of hydrocarbon contaminated surface drainage into surface water features is through the incorporation of oil separators within the site drainage system. Oil interceptors will, as a minimum, serve surface drainage from impermeable surfaces such as vehicle parking areas etc. Roof water does not need to be passed through oil interceptors.

4.2.39 The design guidance provided in PPG 3 on the ‘Use and Design of Oil Separators in Surface Drainage Systems’ should be followed for both temporary construction and permanent surface drainage systems.

4.2.40 To ensure the good performance of oil separator units it is important that they are subject to routine inspection, maintenance and emptying as part of a planned preventative maintenance schedule.

f) Use of Biodegradable Oils and Lubricants

4.2.41 Biodegradable oils and lubricants will be used, where practicable and available, in construction plant and mechanical equipment. This is of particular importance for plant working in close proximity to watercourses or for any works activities on the Hinkley Point foreshore area.

g) Groundwater in Excavations

4.2.42 Contractors must ensure that the appropriate permissions are in place with the Environment Agency for dewatering the site and any discharges of water to ground or surface waters.

4.2.43 Contractors must know the site history and extent of any potential ground contamination (see Land Contamination Management Plan (LCMP)).

4.2.44 Where, on the basis of suitable investigations and evidence, the ground and/or groundwater is considered contaminated, the contractor must arrange for appropriate samples to be taken to understand the degree of contamination. If necessary, the contractor should consult the Water Quality Specialist in relation to the suite of water analysis required. The contractor must use the results of this analysis to determine how best to dispose of the water. Water will be stored until analytical data is made available. If the water is not contaminated, it may be discharged over land or to the nearest surface water drain. If the water is contaminated, it should be either:

discharged to the foul sewer with the permission of the Water Service Company (Wessex Water) or where a connection is not possible;

pumped to a secure and appropriately sealed tank for removal and off-site disposal as Hazardous Waste (see Waste Management Implementation Strategy (WMIS) and contractor’s Site Waste Management Plan).

4.2.45 Where there is a risk of potential harm to human health from potential contamination contained within soil and/or groundwater, the contractors must ensure that these




risks are evaluated as appropriate under Health and Safety legislation and that suitable and sufficient controls are in place to prevent harm being caused to workers. This would include appropriate working procedures and Personal Protective Equipment (PPE).

4.2.46 For uncontaminated discharges, contractors must take precautions so as to prevent siltation of the waters.

4.2.47 Contractors must ensure that persons involved in earthworks and dewatering must be trained in pollution prevention and dewatering techniques such as:

construction and use of a sump at the base of excavations (with suitable grade of clean stone to filter the sediments);

using the pump appropriately (i.e. to switch off the pump before silty residues are sucked up and released);

preventing water from entering excavations, by using cut off ditches;

discharging via hard surfaces (concrete slabs/gravel) into surface waters;

use of appropriate pump rates (to avoid disturbance of bed or bank the maximum rate should be set after consideration of the flow of the river, the location of the discharge and the risk of erosion);

protection of the pump inlet to avoid drawing in aquatic life and other debris; and

minimising disturbance of standing water.

4.2.48 All suspended solids must be allowed to settle out in a runoff lagoon or equivalent vessel prior to any discharge of uncontaminated water to land or surface waters.

4.2.49 Contractors must ensure that settlement lagoons and/or other settlement vessels are designed and maintained in accordance with guidance provided in Planning Policy Guidance 5 (PPG5) so as to ensure effective functioning. Specifically, contractors should ensure that the lagoons:

maintain a constant pumped inlet rate;

minimise the inlet flow as much as possible by using energy dissipaters or rip rap;

have inlet pipe positioned vertically to dissipate energy;

provide lined inlet chamber to reduce velocity of flow;

have inlet chambers and outlet weirs that are lined with materials like geotextiles, brickwork, polythene or timber;

have a long outlet weir to minimise disturbance;

provide two or three lagoons/basins in series to increase silt retention where necessary;

are cleared of sediment regularly (and silt disposed of in an appropriate manner); and

allow for the monitoring of discharge quality where appropriate.




h) Use of Cement and Concrete

4.2.50 Concrete (and cement) are highly alkaline and can cause potentially adverse water quality conditions through rapid changes in pH, if allowed to enter water features.

4.2.51 Storage of cement should be appropriately located with due regard to potential site runoff characteristics. The mixing of concrete will also be carried out in designated locations and all washout water will be controlled and contained by the use of impermeable containment materials. Mixing of concrete will not take place in close proximity to watercourses.

4.2.52 All concrete pouring and filling operations shall be supervised and monitored. The amount of concrete used will be carefully monitored through poring operations in order to ensure there is no escape into drains etc. Where possible, the use of pre-cast concrete will be promoted. Where it is not possible to use pre-cast units, stable shutters appropriate to the specific location in order to minimise failures, will be used. Excavations will be suitably dewatered prior to the placement of concrete and also during the setting of concrete. Also, the use of quick setting formula is recommended where practical to reduce leachate generation during curing.

i) Other Organic and Inorganic Contaminants

i. Phosphorus

4.2.53 Depending upon monitoring results, there may be a requirement to treat surface waters to remove or reduce the concentration of phosphorus.

4.2.54 Phosphorus is a key limiting nutrient in freshwater systems, which in elevated concentrations can be responsible for nutrient enrichment (eutrophication). Construction site drainage may contribute to elevated phosphorus concentrations, particularly through sediment laden runoff. Measures to reduce sediment concentrations will help to minimise associated phosphorus concentrations.

ii. Acid Rock Drainage

4.2.55 The generation of Acid Rock Drainage (ARD) from stockpiles of excavated mudstones in the Southern Construction Phase Area (SCPA), should it occur, will reduce the pH of surface runoff.

4.2.56 ARD will be monitored through sampling and treated at source i.e. prior to WMZ.

4.2.57 The following hierarchical approach will be adopted:

testing;

prevention and minimising through stockpiling techniques (if necessary); and

treatment (if necessary).

4.2.58 Where mudstones are encountered during excavations, small scale leachate/runoff field trials will be carried out on representative samples prior to large scale stockpiling. The exact scope and nature (e.g. t h e analysis suite for example) will be defined by the EDF Energy Site Environmental Engineer, in response to rock




characteristics, but in summary will involve the controlled testing and analysis of the characteristics (particularly sulphides and pH value) of waters that have come into contact with rock stockpiles.

4.2.59 Where the potential for ARD is identified, careful stockpiling techniques will be employed to control the rate of sulphide mineral oxidation so that ARD formation is prevented or reduced to minimal or acceptable levels (relative to Environmental Quality Standards (EQS) and permit concentrations). To do this, water infiltration and leaching will be minimised (water acts as both a reactant and a transport mechanism for oxidation products).

4.2.60 Initially, and wherever possible, water infiltration and leaching will be prevented by ensuring a ‘dry cover’ over the reactive rock. A dry cover may be achieved via a soil cover, an alkaline cover, an organic cover or a synthetic cover for example.

4.2.61 If treatment is deemed necessary, passive treatment techniques will be employed where possible for the treatment of construction site ARD. Anoxic limestone trenches are an appropriate method of treatment. Runoff may be collected from individual stockpiles of concern and routed through an anoxic limestone trench in order to treat waters. It is appropriate to treat waters at source in this instance, rather than subsequently at the Water Management Zone. Careful design of any anoxic limestone trench will be critical to ensure effective treatment capability.

4.2.62 Where passive treatment is not possible other methods should be explored in discussion with EDF Energy, including chemical alkali addition, chemical precipitation treatments, membrane reactor treatments, ion exchange and biological based treatments.

4.3 Control Measures (Operation and Post-Operation)

4.3.1 During the operation and post-operational phases of the temporary facilities (e.g. accommodation facilities or the aggregates storage area), it is envisaged that there will be a need to maintain and operate the water drainage facilities in accordance with planned preventative maintenance schedules and any other appropriate methods of operation in a manner that is consistent with the requirements set out in any applicable drainage consents or discharge permits.


4.4.1 Details of water quality monitoring for the HPC development site (Work No. 1A) shall be developed prior to the commencement of construction works, pursuant to the following DCO requirements:

HPC Development Site:

P11: Drainage Oil Interceptors (G35); P11A: Surface Water Drainage (FP4 and SP1); P12: Drainage: Culvert of Holford Stream (SP2); MS1C: Drainage: Surface Water Monitoring;MS1D: Ground Water: Monitoring; MS19: Surface Water Drainage; and OS8: Surface and Foul Water.




Bridgwater A:

BRIA12: Surface and Foul Water (Operational); BRIA13: Scheme to Treat Suspended Solids, Hydrocarbons, Concrete Leachate

and Other Contaminants; BRIA19: Infiltration surface water drainage.

Bridgwater C:

BRIC11: Surface and Foul Water (Operational); and BRIC12: Scheme to Treat Suspended Solids, Hydrocarbons, Concrete Leachate

and Other Contaminants.

Cannington Bypass:

CB10: Surface and Foul Water (Operational); and CB11: Scheme to Treat Suspended Solids, Hydrocarbons, Concrete Leachate


Cannington Park and Ride:

CP3A: No Storage of Materials in Areas at Risk of Flooding; and CP11: Surface and Foul Water (Operational).

Combwich:

C11: Surface and Foul Water (Operational); and C12: Scheme to Treat Suspended Solids, Hydrocarbons, Concrete Leachate and

Other Contaminants.

Junction 23:

J23-10: Surface and Foul Water (Operational).

Junction 24:

J24 -10: Surface and Foul Water (Operational).

Williton:

WP11: Surface and Foul Water (Operational); and WP12: Scheme to Treat Suspended Solids, Hydrocarbons, Concrete Leachate


4.5 Auditing and Reporting

4.5.1 During construction, the expected daily and weekly monitoring checklists will have the following outline scope:

Daily and/or weekly checklists: Focused on water quality monitoring requirements, visual inspections of drainage systems and appropriate good practice ‘ways of working’, etc. Identification and reporting of any non-compliance, with proposed actions to remedy the non-compliance and prevent recurrence.

Weekly/monthly reporting: Issues for water quality performance reported to EDF Energy’s HPC project management team.

Ad hoc reporting of water quality monitoring and analytical data: Reporting of any failures to meet thresholds or limits set by the relevant environmental permit and EQS, together with proposed rectification actions.

Periodic Audit: The EDF Energy Site Environmental Engineer will periodically audit compliance with the requirements of the WMP and relevant legal obligations.




5. NOISE AND VIBRATION

5.1 Design Control Measures, Operational and Physical Constraints

a) HPC Development Site: Construction Noise Thresholds

5.1.1 The proposed Construction Noise Thresholds for construction activities undertaken within the HPC development site are presented in Table 5.1. This table includes proposed Construction Noise Thresholds outside of typical daytime working periods, including preparatory and maintenance works to be undertaken during the reduced night-shift.

Table 5.1: HPC Development Site: Construction Noise Thresholds

Period Construction Noise Threshold (free-field)*

Day of Week Time of Day dB LAeq,1hour

Monday – Friday 07.00 – 19.00

19.00 – 23.00

23.00 – 07:00

65

60

45

Saturday 07.00 – 19.00

19.00 – 23.00

23.00 – 07:00

65

60

45

Sunday and Bank Holidays 07.00 – 19.00

19.00 – 23.00

23.00 – 07:00

60

55

45

Notes: dB re: 20μPa

* Measured at a noise sensitive receptor location (free-field)

Where LAeq = the equivalent continuous A-weighted sound pressure level, being the single number that represents the total sound energy measured over that period

5.1.2 It should be noted that the noise levels presented within the table above are Construction Noise Thresholds rather than target values. Noise levels may be permitted up to 75dB LAeq,1hour for specific works of short duration where Best Practicable Means (BPM) have been demonstrated to the Local Planning Authority and noise sensitive receptors / premises have been informed at least 48 hours in advance.

5.1.3 Where measured noise levels exceed the Construction Noise Thresholds outlined above, EDF Energy will investigate the cause of the exceedance and take appropriate measures to prevent further exceedances.

5.1.4 In addition to the Construction Noise Threshold EDF Energy will also implement a Construction Noise Trigger Level which is proposed to be 3dB lower than the Construction Noise Threshold for the corresponding working period.




5.1.5 Noise monitoring equipment will be deployed at locations adjacent to the development site boundary and will be programmed to issue an automatic notification to a group of recipients (as defined by EDF Energy in agreement with the local authority) of a Construction Noise Trigger Level exceedance. The trigger level exceedance represents a proactive means of informing the project that noise emissions measured at sensitive receptors are approaching the Construction Noise Threshold and that contractors should review their methods of operation to ensure that noise exceedances are not caused by on-site construction work activities.

b) Off-Site Associated Development Sites: Construction Noise Thresholds

5.1.6 The proposed noise emission thresholds for construction/deconstruction activities undertaken within the off-site associated development sites are presented in Table 5.2 below. There will be no construction/deconstruction works undertaken during the evenings, night-time periods, on Saturday afternoons, Sundays or on public holidays. In exceptional circumstances, should works be required to continue beyond the agreed construction/deconstruction working hours, this would be agreed in advance with relevant local authority environmental health department.

Table 5.2: Offsite Associated Development Sites: Construction Noise Thresholds

Period Construction Noise Threshold (free-field)*

Day of Week Time of Day dB LAeq T

Monday – Friday 07.00 – 19.00

(Cannington Bypass; Combwich Laydown Facility; Bridgwater A, Bridgwater C; Junction 23, Junction 24 and Williton)

08.00 – 19.00

(Cannington Park and Ride and Combwich Wharf)

65

Saturday 08.00 – 13.00

(Cannington Bypass; Cannington; Park and Ride; Combwich Wharf)

07.00 – 13.00

(Bridgwater A and Bridgwater C; Combwich Laydown Facility; Junction 23; Junction 24 and Williton)

65

5.1.7 There may be specific construction activities (for example piling) where noise levels may exceed this limit for short periods. These specific activities would be agreed with the relevant local authority and noise sensitive receptors/premises would be informed at least 48 hours in advance. It is proposed that a 75dB LAeq, 1hour noise limit would apply to such activities.

5.1.8 Where measured noise levels exceed the Construction Noise Thresholds outlined above, EDF Energy will investigate the cause of the exceedance and take appropriate measures in accordance with BS 4142 to prevent further exceedances.




5.1.9 Noise monitoring equipment will be deployed at the off-site associated development sites at the nearest residential receptor location, or a representative location, to be agreed through Requirement PW33 ‘Noise Monitoring Scheme (Offsite Associated Development Sites)’. The monitoring will be programmed to issue an automatic notification to a group of recipients (as defined by EDF Energy in agreement with the local authority) of a Construction Noise Trigger Level exceedance. The trigger level exceedance represents a proactive means of informing the project that noise emissions measured at sensitive receptors are approaching the Construction Noise Threshold and that contractors should review their methods of operation to ensure that noise exceedances are not caused by on-site construction work activities.

5.2 Noise Control Measures

a) No External Positioned Amplified Sound

5.2.1 No amplified sound shall be generated at any time within the site or at any time in the course of carrying out any phase of works for the development. This constraint shall not apply in the event of emergencies or emergency drills to the extent necessary to deal with an emergency or drill, or other health and safety requirements. This constraint will also not apply to the amplified noise generated by construction plant as a reversing alarm.

b) Reversing Alarms

5.2.2 All mobile construction plant will be fitted with low noise or “white spectrum” reversing alarms to minimise the annoyance to local residents due to noise generated from construction plant. The requirement for low noise reversing alarms will be placed on all contractors undertaking work activities on the site.

c) Mitigation measures

5.2.3 All construction contractors will be required to follow standard good construction practice as outlined in BS 5228-1:2009 (Ref. 1) and BS 5228- 2:2009 (Ref. 2). This will include the following measures:

electrical items of plant will be used instead of diesel plant where possible particularly in sensitive locations;

plant will be started up sequentially rather than all together;

internal haul roads will be well maintained and avoid steep gradients where possible;

loading/unloading activities will be located away from residential properties and shielded from those properties where practicable;

drop heights of materials will be minimised;

continuous noisy plant will be housed in acoustic enclosures, where practicable;

effective exhaust silencing and plant muffling equipment will be fitted and maintained in good working order;

static plant known to generate significant levels of vibration will be fitted with vibration dampening features;




each item of plant used will be carefully selected so as to comply with the noise thresholds quoted in the relevant European Commission Directive 2000/14/EC/United Kingdom Statutory Instrument (SI) 2001/1701;

consideration will be given to the recommendations set out in Annex B of Part 1 of BS 5228 (Ref. 1) noise sources, remedies and their effectiveness;

equipment will be well maintained and where possible will be used in the mode of operation that minimises noise;

plant and equipment will be shut down when not in use;

semi-static equipment will be sited and orientated as far as is reasonably practicable away from occupied buildings and, where feasible, will be fitted with suitable enclosures;

mobile construction plant will be located, as far as is reasonably practicable, away from adjacent occupied buildings or as close as possible to noise barriers or site hoardings to provide additional screening from sensitive noise receptors;

materials will be handled in a manner that minimises noise;

vehicles will not wait or queue on the public highway with engines idling;

reversing alarms will incorporate one of the following features where practicable: directional sounders, broadband signals, self-adjusting sounders or flashing warning lights. Alternative comparable systems may be used to minimise noise and nuisance from reversing alarms;

all appropriate EDF Energy staff and their contractor’s personnel will be instructed on BPM measures to reduce noise and vibration as part of their induction training, and followed up by ‘Tool Box’ talks;

noisy activities will be staggered in time and space where feasible;

site layout (on-site construction traffic routes) shall be designed to minimise the need for reversing; and

only designated haul routes (on-site) will be used.

d) Site Area

5.2.4 All construction/post-operation work activities will be undertaken within the designated operational site boundaries; including areas designed to accommodate stockpiles and haul routes.

e) Erection of Physical Barriers

5.2.5 Where deemed appropriate (through risk assessment), physical barriers will be erected around activities that are expected to generate particularly high noise levels to provide screening attenuation.

f) Training

5.2.6 All site personnel will receive training appropriate to the nature of their roles and responsibility; the training will include specific information in relation to noise and vibration management. All staff will receive induction training that will incorporate environmental awareness training, plus specific training in relation to noise and vibration if their work activities are assessed as being particularly noise/vibration




emission prone. On-site ‘Tool Box’ training will enable site workers to understand how their actions will interact with the environment and potentially impact upon sensitive receptors near to their work areas.

5.2.7 In the event that blasting is required to extract un-weathered rock, the following measures will be implemented:

local residents will be given advanced notification of blasting activities commencing;

blast events will not exceed three per day; and

blasting will only occur between 08:00 and 18:00hrs.

5.3 Construction Noise Threshold and Trigger Level Exceedances

5.3.1 In the event of a Construction Noise Threshold exceedance (including during deconstruction activities), the noise monitoring equipment would be programmed to send an automatic notification (SMS or an email) to the EDF Energy Site Environmental Engineer, project specific Construction Manager and nominated staff of the Local Planning Authority. It would be the responsibility of the EDF Energy Site Environmental Engineer to notify other levels within the EDF Energy project management team.

5.3.2 Upon receipt of notification of an exceedance, EDF Energy would implement the following measures:

Immediately undertake an investigation of construction/deconstruction activities on-site by the EDF Energy nominated person (Site Environmental Engineer for example), to ascertain if any work activities are being implemented contrary to specified noise control measures. If the exceedance is directly attributable to EDF Energy’s work activities then the site foreman would stop the specific work activity suspected of causing noise emissions as soon as it is safe to do so and determine why the appropriate measures of this plan were not being implemented. The remedial measures to ensure no repeat of the Construction/Deconstruction Noise Threshold Level exceedance will be determined by the EDF Energy Site Environmental Engineer and relevant parties from the contractor and local authority as appropriate. Work activities that were identified to have caused the exceedance would not be allowed to continue/ resume until the agreed remedial measures have been implemented to the satisfaction of the EDF Energy Site Environmental Engineer and the EDF Energy appointed Noise and Vibration Advisor.

Notify the HPC Site Construction Director within 24 hours of the Construction Noise Threshold being breached.

Rectify any identified causes, record actions in Site File and notify the HPC Site Construction Director of the actions implemented.

If the cause of the Construction Noise Threshold being breached is not related to site operations, record the outcome of the investigation in the Site File and report the findings to the HPC Site Construction Director once the investigation is completed.




5.3.3 In the event of a series of repeated exceedances of the Construction Noise Threshold within a short period of time, for example, should two or more exceedances occur at the same monitoring location within consecutive monitoring periods, the following course of action would be carried out:

Automatic e-mail or text message notification of exceedances issued to t h e EDF Energy Site Environmental Engineer, project specific Construction Manager and local authority’s Environmental Health Officer.

EDF Energy Site Environmental Engineer will call the site foreman and Construction Manager within 30 minutes of receipt of the exceedance notifications to determine whether the exceedances are directly attributable to it works or off-site activities.

Site foreman to inspect all works currently being undertaken across the site to determine if the noise control measures as outlined within this document are being implemented appropriately.

The site foreman to report back to the EDF Energy Site Environmental Engineer within one hour of multiple exceedance notifications that a site inspection has been completed and with confirmation of the root cause of the exceedance. If the exceedance was identified to have been caused by off-site activities, details and location of these activities would be recorded in the Site File and communicated through to the EDF Energy Site Environmental Engineer. If the exceedance is directly attributable to EDF Energy work activities then the site foreman would stop the specific work activity suspected of causing the exceedance as soon as is safe to do so and determine why the appropriate measures of this plan were not being implemented. The remedial measures to ensure no repeat of the Construction Noise Threshold Level exceedance would be determined by the EDF Energy Site Environmental Engineer, and relevant parties from the contractor. Work activities that were determined to have caused the Construction Noise Threshold exceedance would not be allowed to continue/resume until the agreed remedial measures have been implemented to the satisfaction of the EDF Energy Site Environmental Engineer and the EDF Energy appointed Noise and Vibration Advisor.

Within 48 hours of the exceedance or sequential exceedances the EDF Energy Site Environment Engineer would undertake an investigation to determine which activities and/or decisions resulted in the exceedances occurring. A report would be compiled detailing the findings of the investigation, which would be issued to relevant elements of the EDF Energy project management team, to relevant contractors and the local authority as appropriate.

5.4 Public Notification

5.4.1 Amongst other duties, the EDF Energy “Community Liaison Officer” would be responsible for managing the interface between the project and the communities in which the works are being undertaken. In respect of the Noise and Vibration Management Plan (NVMP) the following procedures will be implemented:

Local residents will be informed of the commencement and likely duration of the construction work activities via a letter drop. The letter will include a contact




telephone number which will be manned during all times that construction activities are being undertaken on-site.

For construction activities with the potential to generate noise levels in excess of the Construction Noise Thresholds, written agreement will be obtained from the relevant local authority and local residents will be informed of the works at least 48 hours prior to works commencing.

EDF Energy will respond appropriately to any complaints received from local residents and will investigate the source of the noise.

Furthermore EDF Energy will co-operate with all reasonable requests made from the local authority in relation to noise and vibration matters.

5.5 Vibration Thresholds: HPC Development Site

5.5.1 The Construction Vibration Thresholds provided (Table 5.3) are based on typical site construction activities (excluding blasting) and for typical blasting operations. The threshold levels are based upon guidance provided in BS5228:2009-2 and BS 6472:2008-2.

Table 5.3: Construction Vibration Thresholds

Construction Activity Vibration Level (mm/s PPV) Effect

All activities excluding blasting 0.3 Vibration might just be perceptible in residential environments.

Blasting Operations 10.0 Vibration might be just perceptible in the most sensitive situations for most vibration frequencies associated with earthworks. At lower frequencies people are less sensitive to vibration.

5.5.2 In the event that a complaint of excessive vibration levels is received, vibration monitoring will be undertaken at impacted sensitive receptors. If the levels of vibration recorded are above those stated in the table above, EDF Energy will investigate the cause and cease the responsible activity until appropriate mitigation measures have been applied to prevent further exceedances.

5.6 Vibration Monitoring

5.6.1 An assessment of the potential vibration generated by construction activities has been undertaken and presented in the Environmental Statement. This assessment concluded that, given the separation distances involved, no perceptible vibration is likely within residential properties. Therefore, continuous monitoring of vibration levels is not proposed.

5.6.2 In the event that complaints regarding vibration are received, measurements will be undertaken either at the complainant’s property or at a suitable known reference distance from the works so that any additional attenuation factors can be determined in accordance with the procedures in BS5228:2009-2 (Ref. 2). Measurements, if required, will also be undertaken in accordance with this standard.





a) HPC Development Site

5.7.1 Noise controls during construction at the HPC development site include the following requirements:

MS3: Construction Noise;

MS3A: Prohibited Activities between 2300 and 0700; and

MS3B: Foghorn.

5.7.2 EDF Energy recognises the potential noise and vibration impacts associated with its work activities across the HPC development site. In light of the level of assessed risk and a commitment to demonstrate compliance to the agreed thresholds, EDF Energy will prepare a scheme that sets out the proposed details of the noise monitoring arrangements. The relevant Requirement MS3C ‘Noise monitoring Scheme’ is set out below:

(1) Works No. 1A (d) to (p), 1B and 1C shall not commence until a noise monitoring scheme for the site has been submitted to and approved by West Somerset Council. The noise monitoring scheme shall set out details of:

(a) noise monitoring to establish the effectiveness of the noise management measures;

(b) frequency and format of reporting monitoring information to West Somerset Council;

(c) contingency measures that would be implemented where monitoring identifies the exceedance of the noise emission levels set at MS3.

(2) The noise monitoring scheme referred to in paragraph (1) shall be implemented for the duration of construction of Work No. 1A.

b) Off-Site Associated Development Sites

5.7.3 Noise controls during construction at the off-site associated development sites include the following requirements:

PW23: Associated Development Construction Working Hours (BRIA, BRIC, Junction 23, Junction 24, Williton and the Highway Improvement works);

PW33: Noise Monitoring Scheme (Offsite Associated Development Sites);

CB4: Cannington Bypass Construction Working Hours (0700 to 1900 Monday to Friday, 0800 to 1300 Saturday);

CP4: Cannington Park and Ride Construction Working Hours (0800 to 1900 Monday to Friday, 0800 to 1300 Saturday); and

C3A: Combwich Construction Working Hours.




6. EXCAVATED MATERIALS

6.1 Introduction

6.1.1 In determining the suitability of site derived materials for reuse, a number of parameters will be assessed to enable the project to make informed and considered decisions as to the reuse of these materials. This section of the CoCP sets out the means of assessing the potential to reuse site-derived material in terms of its risks to human health and the environment. The testing and analysis of site-derived materials needs to provide sufficient information to enable relevant risk assessments to be undertaken on the potential impacts of its reuse.

6.2 Principle 1: Protection of Human Health and Environment

6.2.1 Assessment of the material’s chemical properties should be relevant to the likely contaminants present, typically determined by the site’s current and historical uses. For sites where no previous industrial activities have been undertaken, this may involve a more simplistic desk-based review of the potential for contaminants to exist, followed by a minimal number of samples obtained to qualify the absence of potential contaminants. For the purposes of human health risk assessment, the Environment Agency’s Soil Guideline Values (SGVs) and any available and derived Soil Screening Values (SSVs) will apply. Where SGVs and SSVs are not available, site specific derived criteria would be used where practicable.

a) Soil Ecotoxicity

6.2.2 Criteria for assessing the risk from contaminated soils to ecological systems are currently less well developed in the UK. In October 2008, the Environment Agency published an Ecological Risk Assessment (ERA) framework for contaminated soils in collaboration with Defra, Natural England, the Welsh Assembly Government, the Countryside Council for Wales, local authorities and industry. This document contains guidance on the use of ecological/eco-toxicological SSVs that would be used.

b) Controlled Waters

6.2.3 Impacts on controlled waters (i.e. on-site groundwater/secondary aquifers and surface waters – drainage ditches and Holford Stream) could occur through physical mobilisation (such as soil erosion, runoff and sediment deposition) and disturbance of existing contaminated soils during earthworks or increased infiltration and leaching once the topsoil is removed and areas of open excavations are exposed. Impacts on controlled waters could potentially be direct and adverse. Assessment of risks to controlled waters would utilise relevant Environmental Quality Standards (EQSs) stipulated in the Water Framework Directive (WFD), transposed into the UK law by the River Basin Districts Typology, Standards and Groundwater threshold values (Water Framework Directive) (England And Wales) Directions 2010, and drinking water standards, where appropriate.




c) Buildings

6.2.4 Contamination may pose risks to the built environment (e.g. buried water pipes and concrete) and would need to be evaluated as appropriate as part of any geotechnical ‘suitable for use’ assessment.

6.3 Principle 2: Suitability for Use

6.3.1 Suitability for use means that a material must be suitable for its intended purpose in all respects. In particular, both its chemical and geotechnical properties have to be demonstrated to be suitable, and the relevant specification for its use must be met.

6.3.2 Certain excavated materials would be suitable for their intended use at HPC without any treatment at all. If used in this way, these materials are unlikely to be waste. For example some materials may be assessed as being suitable for direct use, e.g. engineered backfill beneath cover layers, capping layers, buildings and hard standing or for site re-grading. Use for the purposes of reclamation, restoration or landscaping may also fall within this category.

6.3.3 Other materials may not have the required characteristics for use without first being treated. Materials that could be considered waste could be treated so as to be suitable for use and would, therefore, no longer be classed as waste. Where any treatment of waste is necessary (i.e. whether biological, chemical, physical or any combination of these), it would be carried out under an appropriate authorisation/licence or exemption if required.

6.3.4 Some materials, although they do not require treatment to make them suitable for use, may nonetheless be re-graded or compacted before or during their use as part of the development of a site. This re-grading or compacting does not prevent the material being regarded as a non-waste.

6.4 Principle 3: Certainty of Use

6.4.1 The contractor, together with the EDF Energy Site Environmental Engineer and an EDF Energy Soil and Materials Specialist, must demonstrate that the material would actually be used and that the use is not just a probability, but a certainty. For example, if materials are stockpiled with no pre-defined destination and use, they could be waste.

6.4.2 In the process of site development, surplus material may be generated that cannot be used either directly or after treatment. For example, the material may not conform to the required specification following treatment and in such a case the material could remain a waste. Similarly, there may be unexpected arisings on a site that were not identified within the site investigation works. Any out of specification materials which are not suitable for use could be waste and would need to be disposed off appropriately and in accordance with the contractor’s Site Waste Management Plan (SWMP).




6.5 Principle 4: Quantity for Use

6.5.1 Contractors should ensure that materials are only used in the quantities necessary for the intended use, and no more. The use of an excessive amount of material will indicate that it is being disposed of and is therefore waste, thus requiring controlled disposal in accordance with the SWMP.

6.6 Materials Reuse Arrangements

6.6.1 The management of materials from construction activities would be carried out in accordance with the requirements set out in the CL:AIRE Code of Practice (The Definition of Waste: Development Industry Code of Practice (2008)). The precise details of the materials to be reused at the HPC development site would be determined during advanced stages of the post-planning design process and in conjunction with contractors. This section, therefore, provides details of the arrangements that would be adopted to control the reuse of materials, once the precise details (type, volumes etc) of the materials to be reused are confirmed.

6.7 Soils

6.7.1 Soils on-site are heavy, slowly permeable clay soils which show at least some degree of gleying. The soil resources present on-site are topsoil and sub-soils which are under various agricultural uses. Additional small areas of the site are under woodland and calcareous grassland. Soils within the Holford Stream valley are wet groundwater gleys.

6.7.2 Topsoil stripping would follow removal of trees and hedgerows as required and will be undertaken across all areas that will be subject to excavation and stockpiling during the Site Preparation Works. The topsoil would be managed in accordance with the Soil Management Plan (SMP) for HPC construction.

6.8 Made Ground

6.8.1 Following the removal of top and sub-soils, the Made Ground (predominantly restricted in spatial and volumetric terms to the Built Development Area East (BDAE)) will be excavated to the approximate depth of weathered bedrock using conventional earthmoving plant. Excavations of these materials would be focused on those areas of the site where subsequent deep excavation into weathered rock is required.

6.8.2 During these excavations any relict structures, such as concrete slabs and walls present within the Made Ground, would be grubbed out. The overburden would include a very small proportion of demolition and construction materials within the BDAE. Large lumps of concrete and masonry will be crushed and graded for use as fill on-site. Where practicable to do so, as part of a large bulk excavation exercise, materials such as wood would be removed and dealt with in accordance with the SWMP.

6.8.3 The Made Ground containing some demolition and construction materials, together with topsoils will be stored in areas in the Southern Construction Phase Area (SCPA) and used to develop the platforms around the Holford Stream culvert.




6.9 Overburden

6.9.1 Overburden at the site is typically clay; the suitability of available overburden for reuse on-site will be assessed as the project advances, however, it is currently anticipated that this material would be used as fill in the Holford Stream valley

6.10 Weathered Rock

6.10.1 Once the soil and overburden has been removed, excavations would continue where deeper excavations are required into weathered rock, which comprises interbedded mudstone and limestone. This material would be used predominantly for the formation of the construction and development platforms.

6.11 Fresh Rock

6.11.1 Fresh rock (comprising mudstone with interbedded limestone) would be excavated in the deep excavation areas for Units 1 and 2. Conventional earthmoving plant would again be used, augmented by ripping where necessary. The excavated fresh rock would first be transferred to a sorting area where it would be processed to the required grade for reuse. The majority of this material would be used in the development of the construction platforms around the main development site. The remaining material would be stored within the SCPA for reuse as engineering backfill around the permanent buildings. The remaining balance of excavated material would be used as the underlying material in the final landscape restoration following the completion of construction.

6.12 Excavation and Stockpiling at HPC

6.12.1 Site-derived materials would be segregated and stockpiled according to differences in material type and/or intended reuse.

6.12.2 Samples would be analysed for the suite of constituents listed in and screened against the Materials Acceptance Criteria (MAC). These MAC would be developed based upon the quantitative risk assessments carried out by EDF Energy and its contractors.

6.12.3 During and following excavation, site-derived material would be appropriately segregated and given a preliminary unique identification code according to the following criteria:

type and location of origin;

the perceived requirement for treatment (if necessary);

material source; and

date of deposition.

6.12.4 Preliminary material stockpile classification system is as follows:

Category A: Potential Reuse without Treatment: Site-derived topsoil material stockpiles to be given prefix A and numbered sequentially (i.e. A1, A2, A3, etc.). These are considered primarily associated with site-derived topsoil soils.




Category B: Potential Reuse without Treatment: Site-derived sub-soil material stockpiles to be given prefix B and numbered sequentially (i.e. B1, B2, B3, etc.). These are considered primarily associated with site-derived sub-soils.

Category C: Potential Reuse without Treatment: Site-derived overburden material stockpiles to be given prefix C and numbered sequentially (i.e. C1, C2, C3, etc.). These are considered primarily associated with site-derived overburden.

Category D: Potential Reuse without Treatment: Site-derived rock material stockpiles to be given prefix D and numbered sequentially (i.e. D1, D2, D3, etc.). These are considered primarily associated with site-derived rock and weathered rock.

Category E: Potential Reuse with Treatment: Site-derived topsoil material stockpiles to be given prefix E and numbered sequentially (i.e. E1, E2, E3, etc.). These are considered primarily associated with site-derived soils that are to be treated prior to reuse.

Category F: Potential Reuse with Treatment: Site-derived sub-soil material stockpiles to be given prefix F and numbered sequentially (i.e. F1, F2, F3, etc.). These are considered primarily associated with site-derived sub-soils that are to be treated prior to reuse.

Category G: Potential Reuse with Treatment: Site-derived overburden material stockpiles to be given prefix G and numbered sequentially (i.e. G1, G2, G3, etc.). These are considered primarily associated with site-derived overburden.

Category H: Potential Reuse with Treatment: Site-derived rock material stockpiles to be given prefix H and numbered sequentially (i.e. H1, H2, H3, etc.). These are considered primarily associated with site-derived rock and weathered rock.

Category I: Potential Off-site Disposal: Site-derived material stockpiles to be given prefix I and numbered sequentially (i.e. I1, I2, I3, etc.). These are considered primarily associated with site-derived material excavated from identified contaminant hotspots and which do not meet the MAC.

Category SM: Surplus Site-derived Materials: Site-derived material stockpiles associated with the excavation of surplus site-derived materials to be given prefix SM.

6.12.5 All material stockpiles classification codes would include the date of deposition and formatted as follows DD.MM.YYYY.

EXAMPLE:

Code: G5/21.08.11

Fifth stockpile requiring potential off-site disposal comprising site-derived material from hotspot no. 4 and deposited on the 21st August 2011.

Code: F1/24.08.11

First stockpile for potential reuse following treatment (crushing and grading) comprising site-derived hard rock material and deposited on 24th August 2011.

6.13 Materials Acceptance Criteria (MAC) for Reuse

6.13.1 In advance of the commencement of the site works, appropriate MAC would be determined with respect to both chemical quality (including soil contaminants) and




geotechnical properties. These criteria would be applied to facilitate the appropriate selection of materials for specific uses.

6.13.2 The identification, segregation and management of materials on-site would be the responsibility of the appointed contractors under the supervision of EDF Energy.

6.13.3 EDF Energy would require contractors to demonstrate compliance with the acceptance criteria through appropriate materials retained documentation relating to sampling, testing, inspections and audits for example.

6.14 Site-Derived Materials – Validation Testing

6.14.1 Following the segregation of site-derived materials, and prior to reuse, composite samples would be taken from the defined material stockpiles detailed above, to confirm the preliminary classifications.

6.14.2 Samples would be collected at an agreed frequency for site-derived materials anticipated to be suitable for reuse without prior treatment and for site-derived materials anticipated to require pre-treatment and/or off-site disposal.

6.14.3 Soil samples would be taken in accordance with the following guidance:

British Standard (BS) 5930: 1999 – Code of Practice for Site Investigation; and

BS 10175:2001 – Investigation of Potentially Contaminated Sites. Code of Practice.

6.14.4 All site-derived material stockpiles would be analysed for a suite of constituents and statistical assessment techniques would be used to generate representative concentrations for comparison with the MAC.

6.14.5 In addition, geotechnical analysis of site-derived materials would be undertaken in accordance with the earthworks method statements and compared to the defined geotechnical reuse criteria, also included in the earthworks method statements.

6.14.6 The testing criteria outlined above would ensure that site-derived materials are both suitable for reuse geotechnically and through comparison with the appropriate site Soil Target Action Values (STAVs) as applicable and appropriate for each material stream. These would be developed to ensure that the site-derived material reused would not present a risk to on or off-site human and/or environmental receptors.

6.15 Material Treatment/Validation and Waste Classification

6.15.1 Site-derived materials which do not meet the reuse criteria would be taken forward for further treatment prior to disposal or subsequent reuse by third parties as appropriate.

6.15.2 Soil and rock would be treated by segregation and soil screening, including crushing where required, under a suitable mobile treatment licence which would be applied for on a case by case basis.




6.15.3 Following treatment, validation testing would be undertaken at an agreed frequency to assess whether the site-derived material is suitable for reuse and if not, to identify further processing/treatment options or to inform the waste classification with validation samples to enable disposal (this being the least preferred option). Based on this assessment, material would be assigned the suffix ‘pass’, ‘passed for further treatment’ or ‘fail’ and segregated into material stockpiles designated for reuse, retreatment or off-site disposal.


6.16.1 Additional controls relating materials management on the HPC Development Site include:

MS1E: Soil Management Measures; MS1F: Stockpiling details; and MS1G: Infill Material.




7. ENVIRONMENTAL INCIDENT CONTROLS

7.1 Control Measures to Reduce the Likelihood of Environmental Incidents

7.1.1 The principal pollution risks at the construction sites for the HPC and each of the off-site associated developments are set out in Appendix 7A.

7.1.2 In order to minimise the potential for environmental incidents from construction activities at the HPC development site and the associated development sites, a series of preventive (i.e. risk reduction) measures will be adopted.

7.1.3 All contractors and site personnel must be familiar with the potential environmental impacts and risks posed by the construction work. Although many of these are set out in this document, contractors should ensure that they have a clear understanding of those risks that are relevant to their contract before they commence work. Contractors will therefore need to carry out their own risk assessment and devise method statements and incident response plans to ensure that suitable and sufficient controls are in place to avoid pollution and harm to human health or environmental receptors at all times either on or off-site.

7.1.4 All drainage elements and contractor method statements must be in accordance with the design elements in the Environment Agency’s Pollution Prevention Guidance notes and other good construction practice, including that published by CIRIA. These measures are referenced in the management plans and include:

as far as possible, minimising the storage of potentially polluting materials and substances, and locating storage areas:

as far away as possible from high risk locations;

as far away as possible from where there is a risk of damage by collision (e.g. from site traffic);

not within 50m of a spring, well or borehole;

not within 10m of a watercourse, ditch, drainage channel or flood plain;

not where polluting materials or substances could enter an open drain or soak into unmade ground where it could pollute groundwater;

not where a spill could run over hard ground to enter a watercourse or soak into unmade ground where it could pollute groundwater;

not on roofs (materials can enter guttering, itself a pathway to the surface or groundwater environment);

the creation of temporary drainage networks (e.g. temporary connection into combined sewer infrastructure) during interim periods during the construction of the permanent drainage system;

use of silt traps used to capture suspended solids;




use of appropriately designed, built and maintained oil storage and refuelling facilities;

use of oil/water separators; and

control of drainage rate to ensure runoff does not exceed the agreed discharge rates.

a) Storage of Oil, Fuel, and Chemicals

7.1.5 All oil and fuel is to be stored in bunded facilities, and all tanks must be clearly marked as to their contents. The bunding must provide an impermeable base and walls and adequate storage capacity in the event of a leak and comply with Environment Agency’s Pollution Prevention Guide 2 and the Control of Pollution (Oil Storage) Regulations 2001.

b) Storage, Handling and Disposal of Waste

7.1.6 Management of waste will be undertaken in accordance with the Waste Management Implementation Strategy, Materials Management Plan and associated Site Waste Management Plans (SWMPs). Waste is to be segregated and stored in appropriate, covered containers which will be clearly marked as to their contents in accordance with the SWMP. The containers are to be located away from drains and water courses.

c) Drainage Plan

7.1.7 Contractors will develop, submit for approval and update as appropriate a drainage plan (in a graphical format) that identifies drainage facilities of either a permanent or temporary nature on-site that could exacerbate a pollution incident. The drainage plan will be made available at all spill kit locations to enable operatives on-site to respond rapidly in sealing drainage and hence containing a spill in a manner that reduces the impact of the spill on sensitive surface water receptors.

d) Siting of Oil Containing Plant and Equipment

7.1.8 Oil-containing plant and equipment will be located on hard-standing for parking and maintenance with sealed drainage and oil interceptors and away from water courses wherever possible.

e) Uncontrolled Emission to Ground and/or Atmosphere

7.1.9 Plant and equipment will be of good working order and used only during core working hours.

f) Spill Kits

7.1.10 Spill kits will be provided on-site and smaller kits will also accompany mobile plant, equipment and oil containers when taken to remote areas of the site.

7.1.11 Contractors must ensure that responsible personnel are suitably trained in the use of spillage response equipment and materials. If any equipment requires special training to use it, ensure the contact details of staff members who are trained in its use are identified on the equipment and registered with the EDF Energy Site Environmental Engineer.




7.1.12 Maintaining a watching brief for potential additional ‘chance finds’ of contamination: Contractors will ensure that a watching brief for further contamination is maintained by trained personnel during the construction works. In the event that ‘chance finds’ of additional contamination are discovered, the measures outlined in the Land Contamination Management Plan will be implemented.

7.1.13 Maintain a watching brief for the presence of ecological receptors and habitat.

7.1.14 Maintain a watching brief for the presence of archaeological features.

7.1.15 Site security: Access to the site is controlled by EDF Energy to avoid trespass and vandalism which may result in pollution. All valves on storage tanks should be locked when not in use to avoid tampering by vandals. Wherever possible storage of materials should be out of sight and in locked containers so as to deter thieves and vandals.

7.1.16 Contractors shall maintain an up-to-date record of all substances stored on-site, together with an indication of the maximum quantity likely to be stored. Any relevant Material Safety Data Sheets (MSDSs) and COSHH assessments shall also be held for any substances posing a risk to people and/or the environment (including waste materials).

7.1.17 Contractors shall produce an Environmental Incident Response Plan (EIRP) that is specific to their work showing all stores, bulk storage vessels, drums or containers intended for storing oils, chemicals or other potentially polluting materials. This shall be a clear plan of the site showing layout and access details, along with a schematic representation of the site drainage arrangements. Essential features that the plan should contain, include:

the layout of buildings and portakabins;

access routes and meeting points for emergency services;

the location of any on-site treatment facilities for trade effluent or domestic sewage;

details of the potential environmental incidents, impacts and risks that the construction works pose and the control measures to mitigate those and risks;

areas or facilities used to store raw materials, products and wastes (include details of tank sizes and products stored);

bunded areas, with details of products stored and estimated retention capacity;

location of hydrants, ‘fireboxes’ and pollution prevention equipment and materials;

any watercourse, spring, borehole or well located within or near the site;

areas of porous or unmade ground;

site drainage – foul, surface and trade effluent drainage systems including features such as:

inspection points to detect pollution; oil separators/interceptors; firewater/spillage containment systems;




balancing tanks; pollution control devices (shut-off valves/penstocks fitted in drains); sacrificial containment areas such as car parks; and other areas suitable for portable storage tanks, for blocking drains and temporary

storage of firewater.

a brief description of how all the contractor’s facilities operate and how the storage vessels will be labelled for easy identification.

7.1.18 Contractors must keep a record of the equipment and materials on-site to deal with pollution incidents, including:

absorbents;

drain mats/covers;

pipe blockers;

booms;

pumps; and

over drums.

7.1.19 Contractors must ensure that all those involved in emergency response are familiar with, and have access to:

the site plan;

information on materials, their health, safety and pollution risks;

appropriate spill response equipment; and

training in incident response procedures.

7.2 Environmental Incident Response

7.2.1 In the event of an environmental incident, leak or spillage being discovered; contractors must:

ASSESS risks to personnel.

STOP the pollution at its source wherever possible. Spillages will not be washed into the ground or drains.

Use spill kits to CONTAIN the spillage and prevent it from entering surface or groundwater.

NOTIFY relevant parties. When notifying the relevant person, contractors must state clearly:

name; company; site; description of the incident and its location; date and time; any injuries or harm to human health as a result of the incident; and any immediate actions taken to mitigate the causes of the incident.




CLASSIFY the significance of the incident in accordance with EDF Energy’s categorisation procedures.

CLEAN-UP/REMEDIATE the incident using appropriate spill kit and other equipment and personal protective clothing as necessary. If necessary, this can include the use of a specialist spillage response contractor. Remedial actions to control and mitigate the incident shall be put in place (see Section 2). These will include actions to reduce the impact, damage, harm and risk.

DISPOSE of contaminated absorbents and/or contaminated soils/waters as hazardous waste in accordance with waste management procedures and the SWMP.

INVESTIGATE AND REPORT the nature, scale and extent of the incident, together with emergency response actions taken and recommended corrective actions to prevent recurrence. Any consequent learning’s following the incident will be managed in accordance with EDF Energy continuous improvement procedures.

7.3 Environmental Incident Reporting and Investigation

7.3.1 In the event of an incident of an environmental nature, contractors must immediately notify EDF Energy in accordance with defined EDF Energy procedures for managing non-conformances.

7.3.2 For environmental incidents, the contractor should complete an Environmental Incident Investigation Report (EIIR) and provide this to the EDF Energy Site Environmental Engineer within 24 hours of the incident taking place.

7.3.3 In the event that a substance has entered a drain, soaked into the ground, or been released to the atmosphere or ground in breach of permit conditions; or an unexpected discovery made of protected species, habitats or a site of archaeological importance, work in that location will cease as soon as it is safe to do so. The incident will be reported immediately to the EDF Energy Site Environmental Engineer. EDF Energy will consult with the relevant stakeholders on the appropriate course of action, including advice on further remediation and the need and responsibility for notifying the following regulatory bodies:

The Environment Agency: in the event of a pollution incident impacting upon water, land or air.

Natural England: in the event of the identification and disturbance to a suspected protected species of animal, plant or habitat.

English Heritage: in the event of the discovery of unexpected archaeological remains.

The Local Authority (West Somerset District Council): in the event of a significant uncontrolled release of pollution to air, ground and/or water and which have impacted upon third party receptors.

7.3.4 Reporting requirements of environmental incidents to the Environment Agency are set out in Appendix 7B.




7.3.5 Emergency services will also be notified as appropriate to the nature and scale of the environmental incident.

7.4 Environmental Incident Response Training

7.4.1 All site personnel must be provided with appropriate induction and ongoing training on the environmental impact of the work they are carrying out, including the necessary procedures for preventing and responding to, a potential environmental incident as detailed in this CoCP.

7.4.2 Where appropriate to the contract, staff should be trained in environmental incident planning and response, including:

briefings on the procedures and incident plans that are in place at the site;

participation in emergency drills;

participation in post-incident investigations;

training in the use of pollution incident response equipment; and

‘Tool Box’ talks.

7.4.3 Evidence of such training should be available for inspection in the form of completed drill test plans, training records of staff and completed post-incident investigation reports.

7.5 Environmental Incident Drills and Auditing

a) Environmental Incident Response Drills

7.5.1 Within three months of the contractor submitting and EDF Energy approving the contractors’ Environmental Incident Response Plan (EIRP), a live trial of the plan will be undertaken. The purpose of the trial is to ensure that the plan is appropriate for the works being undertaken and that the site staff are prepared to deal with an environmental incident.

7.5.2 To ensure adequate and on-going preparedness and response to potential environmental incidents on-site, contractors should ensure that they carry out regular tests of their EIRP.

7.5.3 Incident response drills should be carried out at least every 4-8 weeks so as to ensure that all those responsible for works that have the potential to cause environmental incidents are fully familiar with the incident response procedures.

7.5.4 Emergency incident test drills should be recorded as if they were incidents in their own right and should be accompanied by a post environmental incident investigation report, citing any relevant lessons learned and corrective actions from the exercise.

b) Auditing and Reporting

7.5.5 Compliance with the requirements of this CoCP and statutory legislation will be monitored through routine inspections and audits.




Periodic checks: The environmental incident prevention arrangements will be inspected periodically to identify and address deterioration or inadequacies in the arrangements;

Monthly reporting: Performance in implementing drills and the occurrence of real incidents will be reported monthly to the EDF Energy HPC project management team, together with the lessons learned for incident prevention and control; and

Periodic audit: On a periodic basis, EDF Energy will undertake an internal audit to monitor compliance with the requirements of the CoCP.




APPENDIX 1A: CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN TEMPLATE



NNB GENERATION COMPANY LTD

[CONTRACT NAME AND NUMBER]

CONSTRUCTION ENVIRONMENTAL

MANAGEMENT PLAN (CEMP) (INDICATIVE)

Version

Date of Issue

Document No.

Next Review Date

Owner & Approver

Author

Position

© 2011 Published in the United Kingdom by NNB Generation Company Limited (NNB GenCo), 90 Whitfield Street - London, W1T 4EZ. All rights reserved. No part of this publication may be reproduced or transmitted in any form or by any means, including photocopying and recording, without the written permission of the copyright holder NNB GenCo, application for which should be addressed to the publisher. Such written permission must also be obtained before any part of this publication is stored in a retrieval system of any nature. Requests for copies of this document should be referred to Head of Management Arrangements, NNB Generation Company Limited (NNB GenCo), 90 Whitfield Street - London, W1T 4EZ. The electronic copy is the current issue and printing renders this document uncontrolled. Controlled copy-holders will continue to receive updates as usual.

NNB GenCo – Company Document

Construction Environmental Management Plan (CEMP) (INDICATIVE)

APPROVAL SIGN-OFF: CONSTRUCTION ENVIRONMENTAL MANAGEMENT

PLAN (CEMP)

………………………………………………..

Originated by:

Name

Title

Date:

………………………………………………..

Reviewed by:

Name

Title

Date:

………………………………………………..

Approved by:

Name

Title

Date:

DOCUMENT CONTROL

Version Purpose Amendment By Date


Construction Environmental Management Plan (CEMP)

Page 3 of 18

TABLE OF CONTENTS

1 INTRODUCTION ...................................................................................................................5

1.1 Purpose.............................................................................................................................5

1.2 Scope ................................................................................................................................5

1.3 References and Definitions .............................................................................................5

1.4 Records.............................................................................................................................7

2 PROJECT DESCRIPTION.....................................................................................................8

3 ENVIRONMENTAL REQUIREMENTS AND CONTROLS.....................................................9

3.1 Policy and Planning .........................................................................................................9 3.1.1 Environmental Policy Statement .....................................................................................9 3.1.2 Environmental Responsibilities and Contact Numbers ....................................................9 3.1.3 Environmental Legislation, Approvals, Licenses and Permits..........................................9

3.2 Environmental Impacts, Risks and Mitigations............................................................10 3.2.1 Environmental Impact and Risk Assessment ................................................................10 3.2.2 Design Requirements ...................................................................................................10 3.2.3 Environmental Protection Requirements.......................................................................10 3.2.3.1 Waste ...........................................................................................................................10 3.2.3.2 Excavation Materials Management ...............................................................................11 3.2.3.3 Water Management ......................................................................................................11 3.2.3.4 Ecology.........................................................................................................................11 3.2.3.5 Air Quality and Dust......................................................................................................11 3.2.3.6 Noise and Vibration.......................................................................................................11 3.2.3.7 Traffic and Transport.....................................................................................................12 3.2.3.8 Landscape ....................................................................................................................12 3.2.3.9 Archaeology and Monuments .......................................................................................12 3.2.3.10 Pollution Prevention and Control of Hazardous Substances .........................................12 3.2.3.11 Lighting.........................................................................................................................13 3.2.3.12 Sustainability and Resource Usage ..............................................................................13

3.3 Supporting Arrangements .............................................................................................14 3.3.1 Incident Response and Event Reporting.......................................................................14 3.3.2 Non-Conformance and Corrective Actions ....................................................................14 3.3.3 Training.........................................................................................................................14 3.3.4 Sub-Contractor Management........................................................................................15

3.4 Environmental Monitoring and Reporting ....................................................................16

APPENDIX A IMPACTS AND ASPECTS MATRIX................................................................17

A.1 [Insert sub-header if appropriate] .................................................................................17 A.1.1 [Insert sub-header if appropriate] ..................................................................................17

APPENDIX B ENVIRONMENTAL RISK ASSESSMENT.......................................................18

B.1 [Insert sub-header if appropriate] .................................................................................18 B.1.1 [Insert sub-header if appropriate] ..................................................................................18



Page 4 of 18

TABLE OF FIGURES

Figure 1 : Geographical Area Covered ......................................................................................... 8

TABLE OF TABLES

Table 1 : Record and Sample Retention....................................................................................... 7



Page 5 of 18

1 INTRODUCTION

1.1 Purpose

NNB Generation Company Ltd is part of EDF Energy and is the company that will lead the new nuclear programme in the United Kingdom. For the purpose of this document, NNB Generation Company Ltd is referred to as NNB GenCo.

This Construction Environmental Management Plan (CEMP) has been produced as a deliverable for [Contract Name and Number] and is maintained as a live document throughout the period of contracted works with NNB GenCo.

This CEMP provides specific details of the environmental controls and processes established to meet the environment and sustainability (E&S) requirements of the Contract, including the E&S Appendix, the relevant Environmental Management and Monitoring Plan (EMMP) and Subject-Specific Management Plans (SSMP).

This CEMP will be prepared, reviewed and issued using the contractor’s own Quality Assurance and documentation management system (including the use of a front-sheet for sign-off, as required) before handover to the NNB GenCo project management team.

1.2 Scope

The scope of this CEMP covers the environmental aspects and mitigations of the works, plant, materials and services described in Sections 2 and 3 of this Plan.

The geographical scope of this CEMP covers the entire area within the boundary described in Sections 2 and 3, but will also include all the environmental characteristics that could be positively or adversely affected for a particular environmental aspect which may be affected by the works. For example, water quality issues will extend as far as relevant watercourses may be impacted, whereas noise and vibration assessments may extend as far as nearby homes or businesses that may be affected.

1.3 References and Definitions

Ref Title Location Document No.

1 NNB GenCo Document and Records Management Procedure

EDRMS NNB-OSL-PRO-000009

2 Environmental Optimisation Statement and Principles

EDRMS NNB-OSL-STA-000006

3 Environmental Management and Monitoring Plan (submitted within the Development Consent Order application, Oct 2011)

EDRMS HPC-NNBPEA-U0-000-REP-000077

4 Waste Implementation Strategy (submitted within the Development Consent Order application, Oct 2011)


5 Site Waste Management Plan Template EDRMS NNB-OSL-TEM-000101

6 Materials Management Plan (submitted within the Development Consent Order application, Oct 2011)


7 Soil Management Plan (submitted within the Development Consent Order application, Oct 2011)




Page 6 of 18

Ref Title Location Document No.

8 Land Contamination Management Plan (submitted within the Development Consent Order application, Oct 2011)


9 Water Management Plan (submitted within the Development Consent Order application, Oct 2011)


10 Ecology Management Plan (submitted within the Development Consent Order application, Oct 2011)


11 Air Quality and Dust Management Plan (submitted within the Development Consent Order application, Oct 2011)


12 Noise and Vibration Management Plan (submitted within the Development Consent Order application, Oct 2011)


13 Construction Traffic Management Plan EDRMS TBC

14 Travel Plan EDRMS TBC

15 Landscape Management Plan (submitted within the Development Consent Order application, Oct 2011)

EDRMS TBC

16 Monument Management Plan EDRMS TBC

17 Environmental Incident Control Plan (submitted within the Development Consent Order application, Oct 2011)


18 Manage Hazardous Substances EDRMS NNB-PCP-PRO-000030

19 Lighting Strategy EDRMS TBC

20 Sustainability Statement (submitted within the Development Consent Order application, Oct 2011)

EDRMS HPC-NNBPEA-XX-000-REP-000021

21 Enable Organisational Learning EDRMS NNB-OSL-PRO-000014

22 Manage Non-Conformance EDRMS NNB-OSL-PRO-000028

23 Environmental Monitoring Procedure EDRMS NNB-PCP-PRO-000012

[Further References including EMMP this CEMP is addressing]

Term / Abbreviation Definition

CEMP Construction Environmental Management Plan - a live document that provides details of how the E&S requirements of the Contract, including the EMMP and SSMP’s are met.

Competence The combination of qualifications, training and experience that enables a person to effectively complete their duties.

EDRMS Electronic Document and Records Management System - the electronic system used by NNB GenCo to store documents and records.

EMMP Environmental Management and Monitoring Plan - the compilation of legal requirements and other commitments that must be met during a project phase or sub-phase.



Page 7 of 18

Term / Abbreviation Definition

SSMP Subject Specific Management Plan - a plan prepared to meet specific best practice or legal requirements for the management of environmental issues (for example, a Site Waste Management Plan).

[Further Terms]

1.4 Records

All records (including documents and physical samples) shall be stored and retained in accordance with the NNB GenCo records management procedure (Ref 1).

Requirements for storage and handover of specific environmental records and samples can be found in the SSMPs.

[Insert here the way in which environmental records, including physical samples, will be stored and handled, with a summary in Table 1 as appropriate]

Table 1 : Record and Sample Retention

Document / Sample

Duration Location Ref. No. Reason For Document / Sample



Page 8 of 18

2 PROJECT DESCRIPTION

The key contractual activities covered by this CEMP are:

[Insert the description of the activities covered by the contract, including reference to the Location (Hinkley / Sizewell / Associated Development), project phase or sub-phase]

The geographical area covered by this CEMP is shown in Figure 1, below.

Figure 1 : Geographical Area Covered

[Insert graphic or site plan]

The activities described above are scheduled to commence on [Insert start date of works] and are scheduled to be completed by [Insert start date of works].



Page 9 of 18

3 ENVIRONMENTAL REQUIREMENTS AND CONTROLS

3.1 Policy and Planning

3.1.1 Environmental Policy Statement

[Insert contract organisation's Environmental Policy Statement]

3.1.2 Environmental Responsibilities and Contact Numbers

The roles and responsibilities under this CEMP are as follows:

[Insert Post Titles, Personnel Names and Responsibilities]

Contact information for personnel with environmental responsibilities is as follows:

[Insert Contact Information, including telephone numbers, email addresses and emergency contact information]

3.1.3 Environmental Legislation, Approvals, Licenses and Permits

The following environmental legislation is applicable to the Contract:

[Insert relevant legislation, by title and summary, in appropriate form, or attach in an annexed document]

Note: NNB GenCo will be responsible for the application of permits and authorisations, unless specifically stated otherwise. However, NNB GenCo will require additional information in relation to Contracted activities to complete the relevant application.

The following approvals, licenses, permits or authorisations are applicable to the Contract:

[Insert approvals, licenses, permits or authorisation references and associated conditions - use an Appendix if appropriate]



Page 10 of 18

3.2 Environmental Impacts, Risks and Mitigations

3.2.1 Environmental Impact and Risk Assessment

An Impacts and Aspects Matrix has been produced to clearly identify all environmental aspects, impacts and risks relating to the work activities for [Insert contract name and number]. This Matrix is included in this CEMP as Appendix A [Insert completed matrix as Appendix A].

Using the information obtained from the Impacts and Aspects Matrix, an Environmental Impacts and Risk Assessment has been undertaken. The Environmental Risk Assessment is included in this CEMP as Appendix B [Insert completed risk assessment as Appendix B]. The assessment determines those impacts and risks which are significant and therefore require mitigation and control to minimise the impacts and risks.

3.2.2 Design Requirements

The following section shall be completed to contain details on the ways in which environmental design impacts and risks will be mitigated through design. These mitigation measures will consider the reduction in whole life environmental impacts, where practicable, during the design phase and take into account all applicable guidance and standards, in accordance with the NNB GenCo Environmental Optimisation Statement and Principles (Ref 2). and all other NNB GenCo Environmental, Sustainability and Planning and requirements set out in the relevant EMMP and SSMP’s.

Environmental impacts and risks and associated mitigation considered during design are [not applicable to this contract OR are detailed below].

3.2.3 Environmental Protection Requirements

Environmental protection measures are required to mitigate significant impacts and risks, identified in the Environmental Risk Assessment, and for the specific requirements set out in the EMMP (3) and SSMP’s.

The following sections contain details on the ways in which the impacts and risks and/or requirements will be controlled to meet the requirements. Control measures cover normal works as well as any potential abnormal or emergency scenarios - for example, the provision of chemical or oil spill response kits.

3.2.3.1 Waste

Controls to manage:

- significant impacts and risks associated with waste;

- requirements set out in the Contract including the EMMP/SSMP’s; and

- requirements set out within the Waste Implementation Strategy (Ref 4)



Page 11 of 18

These requirements are [not applicable to this contract OR detailed in the completed Site Waste Management Plan template (Ref. 5)].

3.2.3.2 Excavation Materials Management

Controls to manage:

- significant risks associated with the excavation, movement, storage and reuse of materials;

- requirements set out in the Contract including the EMMP, Materials Management Plan (Ref 6) and/or Soil Management Plan (Ref. 7);

- requirements set out in the Land Contamination Management Plan (Ref 8), any relevant Site Investigation reports and/or Remediation Strategy

These requirements are [not applicable to this contract OR detailed below/appended to this CEMP].

3.2.3.3 Water Management

Controls to manage the significant risks and the EMMP and/or NNB Water Management Plan (Ref 9) requirements associated with the management of water, liquid effluents and sediment is [not applicable to this contract OR detailed below/appended to this CEMP].

3.2.3.4 Ecology

Controls to manage:

- significant risks associated with ecology;

- requirements set out in the Contract including the EMMP and/or the Ecology Management Plan (Ref 10)


3.2.3.5 Air Quality and Dust

Controls to manage:

- significant risks associated with air quality and dust;

- requirements set out in the Contract including the EMMP and/or the Air Quality and Dust Management Plan (Ref 11)


3.2.3.6 Noise and Vibration

Controls to manage:



Page 12 of 18

- significant risks associated with noise and vibration;

- requirements set out in the Contract including the EMMP and/or the Noise and Vibration Management Plan (Ref 12)


3.2.3.7 Traffic and Transport

Controls to manage:

- significant risks associated with traffic and transport;

- requirements set out in the Contract including the EMMP and/or the Construction Traffic Management Plan (Ref 13) and the Travel Plan (Ref 14)


3.2.3.8 Landscape

Controls to manage:

- significant risks associated with changes to the landscape;

- requirements set out in the Contract including the EMMP and/or the Landscape Strategy (Ref 15)


3.2.3.9 Archaeology and Monuments

Controls to manage:

- significant risks associated with archaeology and monuments;

- requirements set out in the Contract including the EMMP and/or the Monument Management Plan (Ref 16)


3.2.3.10 Pollution Prevention and Control of Hazardous Substances

Controls to manage:

- significant risks associated with hazardous substances;

- requirements set out in the Contract including the EMMP and the Environmental Incident Control Management Plan (Ref 17)

These requirements are [not applicable to this contract OR detailed below/appended to this CEMP.



Page 13 of 18

Management of Hazardous Substances shall be in accordance with the NNB GenCo hazardous substances procedure (Ref. 18). A list of the name and quantity of hazardous substances (including explosives) proposed to be brought onto a site shall be provided to NNB GenCo. The quantity of hazardous substances brought onto a site shall be minimised so far as is reasonably practicable.

3.2.3.11 Lighting

Controls to manage:

- significant risks associated with lighting;

- requirements set out in the Contract including the EMMP and the Lighting Strategy (Ref 19)


3.2.3.12 Sustainability and Resource Usage

Controls to manage

- significant risks/issues associated with sustainability and resource use;

- requirements set out in the Contract including the EMMP and the Sustainability Statement (Ref 20)

the delivery of sustainability commitments and the EMMP requirements for the control of resource usage are [not applicable to this contract OR detailed below/appended to this CEMP].



Page 14 of 18

3.3 Supporting Arrangements

3.3.1 Incident Response and Event Reporting

This section shall be completed in accordance with

- NNB GenCo procedures for Event Response and Reporting (Enable Organisational Learning (Ref. 21) and Manage Non-Conformance (Ref. 22))

- Requirements set out in the Contract including the EMMP and SSMP’s

- Requirements set out in the Environmental Incident Control Plan (Ref 17)

This section shall describe the potential environmental incidents that could reasonably occur during the works, and the contingency plans that which will be put in place to respond to these potential incidents.

[Insert specific detail on internal communication, reporting lines, contingency arrangements, and emergency response procedures]

Reporting of environmental near-misses or incidents which occur during the works shall be in accordance with the NNB GenCo Enable Organisational Learning Procedure, including raising an Event/Learning Report and assessment of the event against pre-determined reporting criteria.

Significant environmental events which have resulted in actual environmental pollution or a breach of a permit or consent condition shall be immediately reported to the Site Environmental Engineer for onward reporting to the appropriate stakeholders (including the Environment Agency) as per the above procedure.

3.3.2 Non-Conformance and Corrective Actions

Investigation of non-conformances shall be undertaken by NNB in accordance with the NNB GenCo Enable Organisational Learning procedure and Manage Non-Conformance procedure.

[Add specific detail on internal performance monitoring, non-conformance management and corrective action management - for sub-contractors as well if applicable which would be done alongside the NNB GenCo Investigation]

3.3.3 Training

Provision of sufficient competent persons to meet the requirements of the Contract including the EMMP and SSMPs, including demonstration of training and competency arrangements, shall be provided below:

[Add description of how training and competency is ensured throughout the project]

Personnel, including sub-contractors, involved in the works and in the management of activities described in this CEMP are detailed below:

[Add names of personnel involved in the management of the environmental requirements covered in this CEMP, including sub-contractors, and a summary of their training and competences]



Page 15 of 18

Training requirements will be assessed throughout the work activities. Training will be provided by the contractor to all stall and sub-contractors in line with the requirements to maintain contractor competency.

3.3.4 Sub-Contractor Management

The process for managing and controlling the activities of sub-contractors during the works is provided below:

[Add details of the processes used to control sub-contractors throughout the works]



Page 16 of 18

3.4 Environmental Monitoring and Reporting

Monitoring of environmental parameters (such as noise, water quality, air quality) shall be in accordance with the requirements of the Contract including the EMMP, SSMPs and the NNB GenCo Environmental Monitoring Procedure (Ref 23).

The majority of environmental monitoring will be undertaken by NNB GenCo. However, on the occasions where contractors are responsible for undertaking their own monitoring and where out of tolerance results are discovered, they shall be reported to the Site Environmental Engineer as described in the NNB GenCo Environmental Monitoring Procedure. A Learning Report shall be raised as described in the NNB GenCo Enable Organisational Learning Procedure. A summary of the monitoring and reporting is provided below:

[Add a summary of any environmental monitoring required by the Contract including the EMMP and SSMPs and the reporting methods]



Page 17 of 18

APPENDIX A IMPACTS AND ASPECTS MATRIX

[Insert Impacts and Aspects Matrix]

A.1 [Insert sub-header if appropriate]

A.1.1 [Insert sub-header if appropriate]



Page 18 of 18

APPENDIX B ENVIRONMENTAL RISK ASSESSMENT

[Insert Environmental Risk Assessment]

B.1 [Insert sub-header if appropriate]

B.1.1 [Insert sub-header if appropriate]


APPENDIX 1B: CURRENT ENVIRONMENTAL AND SUSTAINABILITY POLICIES FOR EDF ENERGY




APPENDIX 1C: ENVIRONMENTAL LEGISLATION AND POLICY




Chapter and Subject

Legislation and Guidance

Coastal Hydrodynamics and Geomorphology

The Conservation of Habitats and Species Legislation 2010

Water Resources Act 1991

UK Marine and Coastal Access Act 2009

Food and Environment Protection Act 1985

Coast Protection Act 1949

Marine Flora and Fauna

The Water Environment (Water Framework Directive) (England and Wales) Regulations 2003

The Conservation of Habitats and Species Regulations 2010

The Wildlife and Countryside Act 1981 (as amended)

The Marine and Coastal Access Act 2009

Salmon and Freshwater Fisheries Act 1975

UK Biodiversity Action Plan 1994

Terrestrial Ecology


The Conservation of Habitats and Species Regulations 2010

The Protection of Badgers Act 1992

UK Biodiversity Action Plan 1994

Planning Policy Statement 9: Biodiversity and Geological Conservation (PPS9)

Water Quality

Environment Act 1995

Environmental Permitting Regulations, 2010

Control of Pollution (Oil Storage) (England) Regulations 2001


Environmental Protection Act 1990

Pollution Prevention and Control Act 1999 (Statutory Instrument 1973/2000)

Surface Waters (Dangerous Substances) Regulations 1989

Water Environment (Water Framework Directive)(England and Wales) Regulations 2003 (the Water Framework Regulations)

UK Marine and Coastal Access Act 2009

Environmental Permitting Regulations 2010 – water discharge activities and groundwater activities

PPS23 – Planning and Pollution Control 2004

PPG 1 – General guide to the prevention of pollution

PPG2 – Above ground oil storage tanks

PPG3 – Use of oil separators in surface water drainage systems

PPG5 – Works or maintenance in or near water

PPG6 – Working at construction or demolition sites






Chapter and Subject


PPG7- Refuelling facilities

PPG8 – Safe storage and disposal of used oils

PPG21- Pollution incidence response planning

PPG22 – Dealing with spillages on highways

Hydrology and Drainage

UK - Water Resources Act 1991 (Chapter 57) - information on the maintenance of flood defences and construction with catchments of various designations

Land Drainage Act 1991 (Chapter 59) - information on obstructing flow in watercourses (e.g. Holford culvert)

Water Act 2003 (Chapter 37) - information on pollution in watercourses, and makes provision in connection with land drainage and flood defence

Water Industry Act 1991 – connections to sewers and trade effluent consents

Flood and Water Management Act 2010 – approval of SuDS systems

Environmental Permitting Regulations 2010 – water discharge activities

Environmental Damage (Prevention and Remediation) Regulations 2009 – governs ‘environmental damage’ which includes damage to surface waters

Planning Policy Statement 25: Development and Flood Risk

CIRIA, 2007. The Sustainable Drainage Systems (SuDS) Manual, C697

CIRIA, 2006. Designing for Exceedance in Urban Drainage – Good Practice, C635

CIRIA, 2010. Culvert Design and Operation Guide (C689)

British Standards Institute, 2008. Drain and sewer systems outside buildings (BS EN 752:2008)

Groundwater

Environmental Permitting (England and Wales) Regulations 2010 (SI 2010/675)


Environmental Damage (Prevention and Remediation) Regulations 2009 – governs ‘environmental damage’ which includes damage to groundwater

Environment Agency Groundwater Protection: Policy and Practice (GP3) 2008

Soils and Land Use

The Environmental Stewardship (England) and Countryside Stewardship (Amendment) Regulations 2006


The Environmental Protection Act 1990 - Part 2A

Environmental Damage (Prevention and Remediation) Regulations 2009 – governs ‘environmental damage’ to water resources

Defra. Code of Practice on Sustainable Soils on Construction Sites (2009)

MAFF. Good Practice Guide for Handling Soils by Machine (2000)

Geology and Contaminated Land

Wildlife and Countryside Act 1981

Water Resources Act 1991 (SI57) (as partly amended by the Water Act 2003) and associated Anti-pollution Works Regulations 1999 (SI 1006)

Control of Pollution (Oil Storage) (England) Regulations 2001




Chapter and Subject


The Water Environment (Water Framework Directive) (England and Wales) Regulations 2003 (SI 3242)

Environmental Permitting (England and Wales) Regulations 2010 (SI 657)

Radioactive Substances Act 1993

Nuclear Installation Act 1965

Environmental Protection Act 1990 Part 2A and associated Contaminated Land Regulations (England) 2006 (SI 1380)

Ionising Radiation Regulations 1999

The Radioactive Substances (Substances of Low Activity) Exemption Order, Statutory Instrument 1986, No. 1002 and amended 1992, No. 647

The Radioactive Substances (Phosphatic Substances, Rare Earths etc.) Exemption Order, Statutory Instrument 1962, No 2648

Policy and Guidance

BS10175:2001 Investigation of Potentially Contaminated Sites – Code of Practice 2001

BS5930:1999 Code of practice for site investigations 1999

EN ISO 14688-2002 Geotechnical investigation and testing – Identification and classification of soil – Part 1: Identification and description 2002

BS EN ISO 10381-2:2002 Soil Quality. Sampling. Guidance on sampling techniques 2002

British Standards Institution. (2007). BS3882:2007 Specification for topsoil and requirements for use 2007

Department of the Environment Prioritisation and Categorisation Procedure for Sites that may be contaminated. Contaminated Land Report 6 1995

Environment Agency Contaminated Land Report 11 – Model Procedures for the Management of Land Contamination, CLR 11 2004

Environment Agency Human Health Toxicological Assessment of Contaminants in Soil. (Science Report SC050021/SR2) 2009

Environment Agency An ecological risk assessment (ERA) framework for contaminated soils 2008

Environment Agency Guidance on the Characterisation of Radioactively Contaminated Land 2002

CIRIA 665 Assessing risks posed by hazardous ground gases to buildings 2007

Planning Policy Statement 9: Biodiversity and Geological Conservation 2005

Planning Policy Statement 23: Planning and Pollution Control – Annex 2: Development of Land Impacted by Contamination 2004

Recreation and Amenity

The Marine and Coastal Access Act 2009

Highways Act 1980 and Town and Country Planning Act 1990

Disability Discrimination Act 2005

Planning and Policy Guidance Note 20: Coastal Planning (PPG 20)

Planning Policy Guidance Note 17: Planning for Open Space, Sport and Recreation (PPG 17) (Ref 17.1)

The Draft Regional Spatial Strategy for the South West 2006-2026

Somerset and Exmoor National Park Joint Structure Plan 1991-2011




Chapter and Subject


Somerset Local Transport Plan 2006-2011

Somerset County Council Rights of Way Improvement Plan 2006

West Somerset District Local Plan

West Somerset Local Development Framework

Air Quality

World Health Organization (WHO) Air Quality Guidelines (AQGs) Global Update 2005

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

Air Quality (England) Regulations 2000

Air Quality (England) (Amendment) Regulations 2002

Air Quality Standards Regulations 2010

Environment Act 1995

Local Air Quality Management Technical Guidance LAQM.TG(09)


Environmental Protection UK (EPUK). Development Control: Planning for Air Quality (2010 Update)

Greater London Authority and London Councils. The control of dust and emissions from construction and demolition - Best Practice Guidance

Minerals Policy Statement 2: Controlling and Mitigating the Effects of Mineral Extraction in England – Annex 1: Dust

Building Research Establishment (BRE). Control of dust from Construction and Demolition Activities

Quality of Urban Air Review Group (QUARG). Airborne Particulate Matter in the United Kingdom – Third Report of the Quality of Urban Air Review Group Prepared for the Department of the Environment

Secretary of State’s Guidance for Mobile Crushing and Screening - Process Guidance Note 3/16(04)

Noise and Vibration

Control of Pollution Act 1974


British Standard BS 5228: 2009 ‘Code of practice for noise and vibration control on construction and open sites’. Part 1. ‘Noise’

British Standard BS 5228: 2009 ‘Code of practice for noise and vibration control on construction and open sites. Part 2: Vibration’

Landscape and Visual Amenity

The European Landscape Convention (ELC)

Countryside Rights of Way Act 2000

National Parks and Access to the Countryside Act 1949 as amended by the Environment Act 1995

Hedgerow Regulations 1997




Chapter and Subject


Policy and Guidance

Planning Policy Statement 7 (PPS7): Sustainable Development in Rural Areas

Strategy for Severn Estuary

Quantock Hills Area of Outstanding Natural Beauty Management Plan 2009-2014

Somerset and Exmoor National Park Joint Structure Plan

West Somerset Local Plan Deposit Draft Plan

LI and IEMA (2002) Guidelines for Landscape and Visual Impact Assessment Second Edition 2002

Countryside Agency and Scottish Natural Heritage (2002) Landscape Character Assessment. Guidance for England and Scotland

BS5837:2005 ‘Trees in relation to construction – recommendations’

Lighting in the Countryside: Towards Good Practice’ (1997)

Archaeology and Cultural Heritage

Ancient Monuments and Archaeological Areas Act 1979

Disused Burial Grounds Act 1884

Planning (Listed Buildings and Conservation Areas) Act 1990

Hedgerows Regulations 1997

Design Manual for Roads and Bridges (DMRB), Volume 11: Environmental Assessment, Section 3, Part 2, Cultural Heritage (Highways Agency 2007)

‘Transport Assessment Guidance Unit 3.3.9 The Heritage of Historic Resources, Table 2’. WebTag (2003)

Institute for Archaeologists’ (IfA) Standards and Guidance for Archaeological Desk-Based Assessment (2008)

Institute for Archaeologists (IfA) ‘Standards and Guidance for Archaeological Field Evaluation’ (2008)

Institute for Archaeologists (IfA) ‘Standards and Guidance for Archaeological Excavation’ (2008)

Institute for Archaeologists (IfA) ‘Standards and guidance for the archaeological investigation and recording of standing buildings or structures’ (2008)


APPENDIX 7A: ENVIRONMENTAL INCIDENT CONTROLS

7.5.1 The principal pollution risks at the construction sites for HPC and each of the off-site associated developments are set out in the following tables:

Table 7A.1: HPC development site: Potential Environmental Incidents

Source Pathway Target (known ‘sensitive areas’ are shown in bold)

Accidental release or spillage from fuel/oil storage area or fuel/oil containing plant and equipment.

Accidental and/or uncontrolled release of chemicals used in construction,

Accidental release and/or spillage of cement, concrete or grout contaminated waters.

Accidental release of suspended solids to watercourses

Uncontrolled released of leachates from contaminated soils/stockpiles.

Accidental release, leakage and/or spillage of potentially contaminated water contained in storage tanks.

Potential accidental release of contaminated firewater.

Accidental release of sediments from drainage failure or WMZ failure.

Discharge of untreated sewage e.g. as result of treatment plant failure.

Direct uncontrolled release of pollutant/ contaminated surface water land drainage from construction works in the area could flow into the Hinkley Point C drainage ditch.

On-site:

Hinkley Point C Drainage Ditch


Accidental and uncontrolled release of chemicals used in construction,

Accidental release or spillage of cement, concrete or grout contaminated waters.





Direct uncontrolled release of pollutant/ contaminated surface water land drainage from construction works in the area could flow into the Hinkley Point C foreshore.

On-site:

Hinkley Point Foreshore









Emergency discharges e.g. from tunnelling operations or water attenuation systems during periods of high rainfall.










Emergency discharges e.g. from tunnelling operation or water attenuation systems during periods of high rainfall.

Direct uncontrolled release of pollutant/ contaminated surface water land drainage from construction works in the area could flow into the Holford Stream with potentially detrimental downstream impacts on Wick Moor and Bridgwater Bay SSSI.

Off-site:

Holford Stream - Important water supply to freshwater wetland habitats of Wick Moor and Bridgwater Bay SSSI







Potential accidental release of

Direct uncontrolled release of pollutant/ contaminated surface water land drainage from construction works in the area could flow into the Bum Brooke with potentially detrimental downstream impacts on Wick Moor and Bridgwater Bay SSSI.

Off-site:

Bum Brook - Important water supply to freshwater wetland habitats of Wick Moor and Bridgwater Bay SSSI





contaminated firewater.



Emergency discharges e.g. from tunnelling operation or water attenuation systems during periods of high rainfall.

Potential harm/damage to sensitive habitats.


Accidental and uncontrolled release of chemicals used in construction,



Accidental release, leakage or spillage of potentially contaminated water contained in storage tanks.


Accidental release of sediments from drainage or WMZ failure.

Potential release of contaminated firewater.

Accidental release of sediments from drainage or WMZ failure.

Removal of habitat or contact with protected species during construction.

Direct and/or indirect pollutant release to protected species and their habitats.

On-site:

Hinkley County Wildlife Site (CWS) (partly on-site)

Lowland calcareous grassland within and outside the proposed development site

Woodland & Hedgerows

Breeding birds (on and up to 250m from the site)

Wintering and passage birds (terrestrial habitats)

Reptiles (harm to individuals)

Breeding Birds (destruction/disturbance of active nests)

Bats and bat assemblage (Destruction of roost and harm to individual bats)

Badger (impact upon setts)

Otter (disruption of commuting route)

Off-site:

Off-site ditches and grazing marsh (part of Bridgwater Bay SSSI)






Accidental release, leakage and/or spillage of potentially contaminated

Leaching of contaminants through soil and rock to groundwater.

On- and Off-site:

Groundwater quality.





water contained in storage tanks.




Emergency discharges e.g. from tunnelling operation or water attenuation systems.

‘Chance finds’ of further previously unidentified / unknown contaminated soil / materials (e.g. asbestos contaminated materials).

Direct contact, ingestion , inhalation

On-site:

Humans

Disturbance of previously unidentified / unknown contaminated soil / materials (e.g. asbestos contaminated materials) leading to potential on and /or Off-site release / escape of contamination.

Direct contact, ingestion, and inhalation. Airborne transport, surface run-off.

On-site / Off-site:

Humans, ecology, controlled waters, soils.

Exposure to elevated concentrations of ground gases in excavations and / or confined spaces

Explosion, fire, asphyxiation.

On-site :

Humans

Marine pollution incident e.g. due to release of materials from, collision of or sinking of barges /boats delivering aggregates to temporary jetty.

Direct, uncontrolled release of aggregates, suspended solids, fuels etc.

Off-site:

Marine water quality, marine ecology, humans.

Road Traffic Accident involving vehicles transporting goods and materials and wastes to and from site.

Release of fuel oils, chemicals, soils and wastes (including potentially contaminated soils and wastes)

Off-site


Flooding e.g. due to emergency discharges during high rainfall events, blockage of culverts, failure of drainage system / pumping equipment.

Inundation On-site / Off-site

Humans, ecology, surface waters, soils, built environment/infrastructure

Mismanagement of wastes e.g. failure to prevent escape of waste, incorrect / inadequate consignment.

On-site / Off-site

Humans, ecology, soils, controlled waters





Potential harm / damage to Archaeology.

Physical disturbance.

On-site

Archaeology.

Release of dust, noise, odour or other nuisance from the site.

Airborne dust, noise, odour and other nuisances.

Off-site:

People and property located near to the site in Shurton, Knighton and Doggett’s Farm.

Table 7A.2: Bridgwater A: Pollution Risks

Source Pathway Target (known 'sensitive areas' are shown in bold)


Accidental and/or uncontrolled release of chemicals used in construction.





Accidental release of sediments from drainage failure.

No direct pathway, but could be impacted indirectly by excessive surface water flows. Under normal flow conditions, the drainage from site does not exhibit any connectivity with the un-named rhyne and impact is unlikely via any direct surface flow.

Off-site

The un-named rhyne to the 200m north-east of the site connects with the King Sedgemoor Rhyne and the River Parrett.


Accidental and uncontrolled release of chemicals used in construction.






Pathway to sensitive receptors would be facilitated by flow to the western drainage ditch (‘railway drain’) on site which is in continuity with other controlled watercourses.

Off-site

The western drainage ditch running north parallel to the railway (‘railway drain’) has existing connections to the Horsey Rhyne (1.3km north of the site) and a culvert under the railway (220m from northern site boundary), both of which form pathways to the River Parrett.












Cellophane Pits to the north-east of the site could be impacted by uncontrolled surface water flows from the site. Under normal flow conditions, the rhyne network does not exhibit any connectivity with the Cellophane Pits. Surface flows would have to be excessive in order to reach the Cellophane Pits.

Off-site

Cellophane Pits.







Removal of habitat or contact with protected species during construction. Direct pollutant release to protected species and their habitats.

On-site

Reptiles (harm to individuals).

Breeding Birds (destruction/disturbance of active nests).

Bats and bat assemblage (Destruction of roost and harm to individual bats).













On and Off-site


‘Chance finds’ of further previously unidentified/unknown contaminated soil/materials (e.g. asbestos contaminated materials).

Direct contact, ingestion, inhalation.

On Site

Humans.

Disturbance of previously unidentified/unknown contaminated soil/materials (e.g. asbestos contaminated materials) leading to potential on and /or off site release/escape of contamination.

Direct contact, ingestion, and inhalation. Airborne transport, surface run off.

On/Off Site


Flooding e.g. due to emergency discharges during high rainfall events, blockage of culverts, failure of drainage system/ pumping equipment.

Inundation. On Site/Off Site

Humans, ecology, surface waters, soils, built environment/ infrastructure.

Mismanagement of wastes e.g. failure to prevent escape of waste, incorrect/inadequate consignment.

On/Off Site

Humans, ecology, soils, controlled waters.

Potential harm/damage to archaeology.

Physical disturbance. On Site

Archaeology.



Off-site

People and property located near to the site in Bridgwater.


Table 7A.3: Bridgwater C: Pollution Risks









No direct pathway as these drains are off-site and are not in continuity with the planned drainage network. Surface flow from site would have to be excessive for these to be impacted.

Off-site

Small ditches/drains located approximately 20m north-east, 70m north and 140m to the north-west of the site.








No direct pathway as these drains are off-site and are not in continuity with the planned drainage network.

Surface flow from site would have to be excessive for these to be impacted.

Off-site

Small ditches located approximately 150m to the west and 160m to the south west that form part of the Wessex Water surface water system.














No direct pathway during construction as these drains are off-site and are not in continuity with the planned drainage network. Surface flow from site would have to be excessive for these to be impacted.

Direct connection is planned, however, as part of the operational drainage network at the site.

Off-site

Wessex Water combined sewers near the site (approximately 25m to the south-east) and any surface water and foul water discharged to this system would ultimately be treated at the Chiltern Trinity Sewage Treatment Works (STW), which lies on the western banks of the River Parrett. The STW consent to discharge contains provision for protection of the water quality status of the receiving environment (River Parrett).









On and Off-site















On-site

Breeding Birds (destruction/disturbance of active nests).

‘Chance finds’ of further previously unidentified/unknown contaminated soil/materials (e.g. asbestos contaminated materials).

Direct contact, ingestion, inhalation.

On Site

Humans.

Disturbance of previously unidentified/unknown contaminated soil/materials (e.g. asbestos contaminated materials) leading to potential on and /or off site release/escape of contamination.

Direct contact, ingestion, and inhalation. Airborne transport, surface run off.

On/Off Site






On/Off Site




Archaeology.



Off-site

People and property located near to the site in Bridgwater.


Table 7A.4: Cannington Bypass: Pollution Risks









Direct uncontrolled surface water land drainage from construction works in the area could flow into the Mill Stream.

On-site

Mill Stream (’Ordinary Watercourse’) flows across the development site in the southern part (NGR ST 2141 3874).

High sensitivity because Mill Stream ultimately discharges into Cannington Brook, which although currently rated as Poor ecological status under the WFD, has historically had good chemistry (GQA scheme).








Direct uncontrolled surface water land drainage from construction works in the area could flow into the drainage ditch and then potentially impacting (through flow continuity) other receptors such as Cannington Brook and River Parrett with which it merges at approximate NGR ST 2777 4088.

On-site

The open drainage ditch adjacent to the Rodway.

Upgraded water quality sensitivity because ultimately discharges into Cannington Brook, which although currently rated as Poor ecological status under the WFD, has historically had good chemistry (GQA scheme).














Uncontrolled surface water land drainage from construction works in the area could flow into the drainage ditch and then potentially impacting (through flow continuity) other receptors such as the Cannington Flood Relief Channel, Cannington Brook and River Parrett with which it merges at approximate NGR ST 2777 4088.

On-site

The open drainage ditch that discharges to Cannington Flood Relief Channel. The FRC will receive water from southern catchment.

High sensitivity because Cannington FRC ultimately discharges into Cannington Brook which, although currently rated as Poor ecological status under the WFD, has historically had good chemistry (GQA scheme).










Direct pollutant release to protected species and their habitats.

On-site

Hedgerows (habitat change).

Watercourses and water bodies (habitat change).

Habitat networks (habitat change).

Reptiles and invertebrates (Great Crested Newts, Slow Worm, etc – harm to habitats and individuals).

Breeding Birds (destruction/disturbance of active nests and habitat).

Bats (including Barbastelle) and bat assemblage (destruction of habitat, roost and harm to individual bats).

Badger (impact upon setts).

Otter (disruption of commuting route).













On and Off-site






On/Off Site




Archaeology.



Off-site

People and property located near to the Cannington Bypass site.


Table 7A.5: Cannington Park and Ride: Pollution Risks









Direct uncontrolled surface water land drainage from construction into the Cannington Flood Relief Channel (in downstream continuity with Cannington Brook).

On-site (eastern and western edges)

Cannington Flood Relief Channel. High level of sensitivity given to this receptor as it is in downstream continuity with Cannington Brook, a WFD water channel.








Direct uncontrolled surface water land drainage from construction works in the area could flow into the drainage ditch and then potentially impact (through flow continuity) other receptors such as Cannington Brook.

Off-site

The open drainage ditch adjacent to the A39.
















Direct pollutant release to protected species and their habitats.

On-site





Breeding Birds (destruction/disturbance of active nests and habitat).

Bats (including Barbastelle) and bat assemblage (destruction of habitat, roost and harm to individual bats).


Otter (disruption of commuting route).

Water Vole (habitat damage).









On and Off-site










On/Off Site




Archaeology.



Off-site

People and property located near to the Cannington Park and Ride site.

Table 7A.6: Combwich Wharf: Pollution Risks









Direct pathway from site drainage to on-site rhynes. This network of drainage channels feeds into the Blindman’s Rhyne which flows into the River Parrett.

On-site

On site rhynes including Blindman’s Rhyne water body. Important water dependent species present. The surface water rhynes are understood to provide habitat and migration routes for water vole and otter and good water quality and adequate flows are important factors in ensuring the habitat and character of these surface water features is maintained for such species.

Blindman’s Rhyne is in continuity with The River Parrett (adjacent to the site) which forms part of the Bridgwater Bay SSSI, Severn Estuary Special Area of Conservation (SAC) and Severn Estuary Special Protection Area (SPA).












The Moxhill Rhyne forms part of the WFD Fiddington Brook water body. Excessive surface flow from the site could potentially reach these waters, but this would have to be excessive and uncontrolled.

Off-site

Moxhill Rhyne water quality. WFD current and predicted status (Fiddington Brook water body) of poor quality.








The Combwich Ponds are located adjacent to the development site (albeit separated by the raised embankment), with regards to water quality. Excessive surface flow from the site could potentially reach these waters, but this would have to be excessive and uncontrolled.

Off-site

Combwich Ponds water quality. Coarse fishery reliant upon water quality status. Site designated as a CWS. Due to the recreational amenity provided by the lake as a fishery and its designation as a CWS, the Combwich Ponds are potentially vulnerable to changes in water quality. Adopting a precautionary approach, the value and sensitivity score of the Combwich Ponds is considered to be high.












Leaching of contaminants through soil and/or rock to groundwater.

On and Off-site











On-site





Breeding Birds/Winter and Passage Birds in terrestrial/marine areas (destruction/disturbance of active nests and foraging habitat).

Bats and bat assemblage (destruction of habitat, roost and harm to individual bats).














On and Off-site






On/Off Site




Archaeology.



Off-site

People and property located near to the Combwich Wharf site.


Table 7A.7: Junction 23 Park and Ride: Pollution Risks









Direct surface flow from construction sites could enter waters of the Sedgemoor Drain and River Parrett, a highly sensitive receptor.

On-site

On-site surface water drainage ditches. No designations under WFD and not monitored by EA. Ultimately discharge into the River Parrett, an estuarine WFD water body with moderate status. Form part of a series of interconnected drains and currently feed into the King’s Sedgemoor Drain and the River Parrett.








Excessive surface flow from the site could potentially reach these waters, but this would have to be excessive and uncontrolled.

Off-site

Small pond adjacent to the A38 roundabout approximately 500m south of the Dunball Drove Track.














Excessive surface flow from the site could potentially reach these waters, but this would have to be very excessive and uncontrolled.

More likely risks are those via the on-site drainage ditches.

Off-site

River Parrett The River Parrett is a defined WFD water body.










On-site




Reptiles and invertebrates (Great Crested Newts, Slow Worm, Grass Snakes etc – harm to habitats and individuals).

Breeding Birds (destruction/disturbance of active nests and foraging habitat).

Bats and bat assemblage (destruction of habitat, roost and harm to individual bats).

Wigeon(disturbance and displacement).

Water Vole (habitat damage).













On and Off-site






On/Off Site




Archaeology.



Off-site

People and property located near to the site. The site is located in a largely rural setting with only one property located near the site. However value/sensitivity of property/people is high.


Table 7A.8: Williton Park and Ride: Pollution Risks









Surface water flow from construction sites could enter waters of these drainage ditches and subsequently the Doniford Stream, a sensitive environmental receptor.

Off-site

Small un-named drainage ditches located immediately south of the proposed development site.








Direct surface flow from construction sites could enter waters of the Sedgemoor Drain and River Parrett, a highly sensitive receptor.

On-site

Network of rhynes which drain the land to the east of the site, towards the Doniford Stream.














Surface flow directly from the site is unlikely to the Doniford Stream; this would have to be excessive and uncontrolled. More likely are the indirect pathways to the Doniford Stream via the on-site drainage ditches.

Off-site

Doniford Stream.










On-site

Breeding Birds (destruction/disturbance of active nests and foraging habitat).













On and Off-site






On/Off Site




Archaeology.



Off-site



Table 7A.9: Junction 24 Park and Ride: Pollution Risks









Potentially contaminated surface water flow or polluting matter from construction site could enter water course.

Off-site

Huntworth Business Park watercourse.

Carries surface water from the Business Park and also provides drainage for the surrounding land. Hydrology/drainage value and sensitivity is considered high due to its Main River status.


Inundation On Site/Off Site



On/Off Site




Archaeology.



Off-site





APPENDIX 7B: ENVIRONMENTAL INCIDENT REPORTING TO THE ENVIRONMENT AGENCY






Environmental Events Categories (ENV) and reporting requirements

ENV 01 (ONR EQUIVALENT RS01, RS02, RS03, RS04)

A pollution incident has been caused by the site which has an actual environmental impact

Incident Notification Incident Classification

Internal External

Class Example Incident Type Responsible

Person Who

Informed How

Informed When

Informed Responsible

Person Who

Informed How

Informed When

Informed

Site Environment

Lead1

Duty Site Manager

Telephone Without

delay

VSI

A pollution incident where life or the physical environment is significantly affected e.g. fish kill, plant death, impact on controlled water quality, restrictions on food or water to prevent harm to human health, restrictions on access by the public or livestock

A radiological pollution incident (e.g. loss of containment of radioactive material) will also require reporting as an REC incident

Environmental Permit breach, Environment Agency Category 1 or 2 notification

Oil spill > 200 litres to land or > 500 litres contained Oil or hazardous chemical spill to off-site watercourses Spill > 1 tonne of hazardous chemical or >5 tonnes of

non-hazardous chemical Disposal of hazardous waste e.g asbestos where there is

a significant risk to the public or environment

Site Environment

Lead

NNB Environment

Team

Learning Report

Within 3hrs

Emergency Co-

ordinator2

EA Incident Hotline

Incident Hotline3

Within 3hrs

1 NNB GenCo person with environmental expertise or the line supervisor of a site environmental expert. 2 The Duty Site Manager is the NNB GenCo person in charge of a site (including construction sites and the Associated Developments of a construction site). 3 The Environment Agency Incident Hotline telephone number is 0800 731 1300.




ENV 02 (ONR EQUIVALENT RS13,RS14)

Environmental permit limit exceeded or discharge made without a permit4


Internal External


Person Who

Informed How

Informed When


Person Who

Informed How

Informed When

Informed

Site Environment

Lead

Duty Site Manager

Telephone Without

delay

SI

Breach of water discharge consent or permit limits (e.g. suspended solids, pH) regardless of whether environmental harm has occurred (pollution incident with environmental harm is an ENV01)

Discharge of sewage effluent, process effluent or process run-off to the environment without an environmental consent or permit being in place (either the route discharged, or the substance discharged, has not been consented by the regulator) e.g. antifreeze discharge via unprotected surface drainage system

Breach of airborne emission limits for combustion plant Disposal of radioactive waste without a Radioactive

Substances Regulation (RSR) permit being in force (also review REC categories)


Site Environment

Lead

NNB Environment

Team

Learning Report

Within 8hrs

Duty Site Manager

EA Pollution Hotline

Within 3hrs

4 Authorisations, consents and permits may need to be read in conjunction with regulatory guidance on compliance with numerical limits.


ENV 03A

Breach of environmental legislation where there is no permitting system that results in an environmental impact


Internal External


Person Who

Informed How

Informed When


Person Who

Informed How

Informed When

Informed

SI

Hazardous waste disposed off site with non-hazardous waste (non-compliance with Hazardous Waste Regulations)

Fly tipping by NNB or contractor under NNB control (non-compliance with Duty of Care under EPA90)

Loss of >3 kg of Ozone Depleting Substances (ODS) or fluorinated gases to the environment where there has been a failure to take all precautionary measures practicable to minimise leakage

Significant complaints about environmental impacts from a site (such as noise or odour) that a magistrate could reasonably decide would be regarded as a statutory nuisance (non-compliance with EPA90)

Activities carried out without a required permit, where an environmental impact has occurred

Site Environment

Lead

Duty Site Manager

NNB Environment

Team

Learning Report

Within 8hrs

Duty Site Manager

EA Area Team

EA Site Regulator

Telephone followed by email

Within 24hrs






Dredging, construction or maintenance work causes impact to marine habitat or species that would not have been authorised by regulator or authorising body

Damage to Special Site of Scientific Interest (SSSI) or local biodiversity (such as loss of species or habitat) not caused by pollution incident

Construction or maintenance work causes impact to terrestrial species (e.g. bats, badgers) that has not been authorised or licensed by the regulator or authorising body


Oil or hazardous chemical spill > 10 litres to land

Site Environment

Lead

Duty Site Manager

NNB Environment

Team

Learning Report

Within 8hrs

Duty Site Manager

EA Area Team

EA Site Regulator

Auth. Body5


Within 24hrs

ENV 03B

Breach of environmental legislation where there has been no environmental impact


Internal External


Person Who

Informed How

Informed When


Person Who

Informed How

Informed When

Informed

I

Paperwork or records required by waste management or environmental legislation are incomplete or inaccurate

Failure in Duty of Care for waste management e.g. using an unregistered waste carrier; failing to complete Waste Transfer Notes

Non-compliance with Control of Pollution (Oil Storage) (England and Wales) Regulations 2001 for the storage of oil outside with suitable spill containment or for inadequate bunding of stored oil

Site Environment

Lead

Duty Site Manager

NNB Environment

Team

Learning Report

Within 24hrs

Duty Site Manager

EA Area Team

EA Site Regulator


Within 72hrs

5 ‘Authorising Body’ will depend upon the activity and any specific licence, consent or planning condition e.g. Natural England (impact on biodiversity or species, including for species where a licence is in force); Crown Estates (dredging and marine works).




Leak checks or maintenance required by environmental legislation not performed

Radioactive material stored on a site without a valid RSR permit or Exemption Order in force (also review REC incident categories)

Failure to obtain approval from Natural England for work on a designated wildlife or conservation site

Marine works undertaken without clearance from the appropriate Authorising Body (e.g. Crown Estates) Site

Environment Lead

Duty Site Manager

NNB Environment

Team

Learning Report

Within 24hrs

Duty Site Manager

EA Area Team

EA Site Regulator

Auth. Body6


Within 72hrs

ENV 04

Failure to meet a condition of an environmental permit7


Internal External


Person Who

Informed How

Informed When


Person Who

Informed How

Informed When

Informed

6 ‘Authorising Body’ will depend upon the activity and any specific licence, consent or planning condition: Natural England (impact on biodiversity or species, including for species where a licence is in force); Crown Estates (dredging and marine works). 7 Exceeding a numerical limit of a permit is covered by ENV 02. Includes supplementary conditions (such as a condition in an Environment Agency Requirement, EAR).




I

Failure to apply Best Available Techniques Failure to operate and maintain plant as required by permit Failure to supply information as described by permit (in the

right form or by the required time) Failure to make improvements or to meet Pre Operational

Conditions of a permit Major challenge to any system designed to protect the

environment, even if pollution event is avoided (e.g. significant quantity of oil lost from a permitted plant, but contained within separators or bunding)

Failure to notify the regulator of a change in permitted plant or a permitted site which could affect environmental impacts

For a radiological permit, review REC incident categories

Site Environment

Lead

Duty Site Manager

NNB Environment

Team

Learning Report

Within 24hrs

Duty Site Manager

EA Area Team

EA Site Regulator


Within 72hrs

ENV 05

An unusual monitoring result or triggering a notification level or reporting condition


Internal External


Person Who

Informed How

Informed When


Person Who

Informed How

Informed When

Informed

O

An unusual discharge or environmental monitoring result considered worth reporting

Unexpected discharges close to permit values Potential spill to controlled waters, but indications are that it

is contained with no environmental impact Unusual environmental monitoring result (e.g. elevated aerial

Site Environment

Lead

Duty Site Manager

NNB Environment

Learning Report

Within 24hrs

Duty Site Manager

EA Area Team

EA Site Regulator


Within 72hrs8

8 Check permit conditions for exact external reporting requirements, including potential incidents that should be reported within 24 hours. Some environmental permits have reporting conditions of 1 week for ENV 05 incidents.




particulate reading, presence of hydrocarbons in borehole sample with no evidence of pollution incident cause by NNB)

Elevated Biochemical Oxygen Demand, suspended solids or nitrogen results from treated sewage samples, within permitted values, but indicating operational problems

For unusual radiological results, review REC incident categories

Triggering a notification level or reporting condition in a permit or legislation

Observation of unusual wildlife capture on site or by site systems (e.g. protected species)

Team

ENV 06

Significant near miss that could have led to a higher category environmental incident


Internal External


Person Who

Informed How

Informed When


Person Who

Informed How

Informed When

Informed

O

Any event or near miss where there is the potential for significant pollution

Failure of a prime containment barrier and reliance on final barrier, such as an intercepted spill (for significant spills, ENV 04 is more appropriate)

Minor non-compliance with waste acceptance criteria Failure to apply environmental advice within processes or

environmental risk assessments, which could have led to non-compliance or an environmental impact

Site Environment

Lead

Duty Site Manager

NNB Environment

Team

Learning Report

Within 24hrs

Duty Site Manager

EA Area Team

EA Site Regulator

Routine meeting or telephone followed by email

Within 7 days9

9 EPR10 permits contain a ‘without delay’ condition “following the detection of any malfunction, breakdown or failure of equipment or techniques, accident, or fugitive emission which… may cause significant pollution), which necessitates reporting within 3 hours of this type of incident.




ENV 99

Other environmental occurrences


Internal External


Person Who

Informed How

Informed When


Person Who

Informed How

Informed When

Informed

O

Something of environmental interest that merits recording but cannot be fitted into previous categories

All

Duty Site Manager

NNB Environment

Team

Learning Report

Within 24hrs

N/A N/A N/A N/A

CODE OF CONSTRUCTION PRACTICE - Planning Inspectorate... · 1.1.2 This Code of Construction...

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