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CPA | Civil & Structural Consulting Engineers
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CPA | New Blow Moulding Facility, Oakthorpe
SECTOR | INDUSTRIAL, MANUFACTURING & LOGISTICS
New Blow Moulding Facility, Oakthorpe
Client: Arla
This project included the civil and structural design for the construction of a new purpose built steel framed extension to the existing Dairy facility to provide additional manufacturing space and was constructed within a fully operational facility adjacent Pymmes Brook watercourse.
Enabling works for the scheme included the extension and alteration of the service and delivery yards and required careful and detailed drainage coordination and dialogue with Enfield Council and the LLFA to secure Planning Approval.
Due to the prevailing ground conditions including river deposits below made ground, the scheme included a piled foundation solution with piles installed tight against the existing operational facility.
Design of the steel frame considered not only the existing building frame to which it adjoined but also the erection and phasing required to ensure it could be safely constructed adjacent existing live infrastructure including silos and delivery vehicles etc.
Related Projects
Arla Foods Ingredients / Volac Whey Nutrition merger inquiry
The CMA is investigating the anticipated acquisition by Arla Foods Ingredients Group P/S of Volac Whey Nutrition Holdings Limited.
Statutory timetable
| Phase 1 | Action |
| 13 November 2024 | Deadline for phase 1 decision (*) |
| 18 September 2024 | Launch of merger inquiry |
| 18 September 2024 to 2 October 2024 | Invitation to comment |
(*) This date is the current statutory deadline by when the decision will be announced. If any change occurs, the information is refreshed as soon as practicable. However, the Competition and Markets Authority (CMA) cannot guarantee that the decision will be announced on or before this current deadline, as the deadline of a given case may change during the merger assessment process due to different reasons.
Phase 1
Launch of merger inquiry
18 September 2024: The CMA announced the launch of its merger inquiry by notice to the parties.
- (18.9.24)
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However, if you would like to share the information in this article, you may use the headline, summary and link below:
Climate activists cause damage at Arla and Müller sites but milk supply is 'largely unaffected'
https://www.dairyreporter.com/Article/2022/09/08/Climate-activists-cause-damage-at-Arla-and-Mueller-sites-but-milk-supply-is-largely-unaffectedRelated news
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- Animal rights activists sentenced after damage to dairy site
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CPA is the trading name of Crabtree Potts Associates Limited. Company number 12933591. Registered address is Number One, Great Exhibition Way, Kirkstall Forge, Leeds LS5 3BF.
Environment Agency permitting decisions
Variation
We have decided to issue the variation for Oakthorpe Dairy operated by Arla
Foods Limited.
The variation number is EPR/BN0465IG/V003
We consider in reaching that decision we have taken into account all relevant
considerations and legal requirements and that the permit will ensure that the
appropriate level of environmental protection is provided.
Description of the changes introduced by the Variation
This is a Substantial Variation as detailed in RGN8 (version 3.0 March 2011)
paragraph 3.5.
This variation permits the installation and operation of a physico-chemical
effluent treatment plant using dissolved aeration and flotation (DAF)
technology under Section 5.4 A(1)(a)(ii) of the EPR regulations. The sites
general effluent currently discharges into the public sewer for treatment by
Thames Water at the local sewage treatment works (Deephams STW). The
operator has had significant difficulty in meeting the restrictions of the
discharge consent issued for the site by Thames Water for Chemical Oxygen
Demand (COD) and Fats, Oil and Grease (FOG) and this plant represents a
significant upgrade to the operational process allowing discharge consent
limits to be met utilising partial and full chemical treatment methods. The plant
will treat circa 1,100m3/day.
This variation additionally incorporates the changes required by the Industrial
Emissions Directive. This includes the amendment of the wording of several
permit conditions relating to notifications, and also includes the addition of a
condition relating to a requirement for monitoring of groundwater and soil.
EPR/BN0465IG/V003
Page 1 of 11Purpose of this document
This decision document:
explains how the application has been determined
provides a record of the decision-making process
shows how all relevant factors have been taken into account
Unless the decision document specifies otherwise we have accepted the
applicant’s proposals.
Structure of this document
Key issues
Annex 1 the decision checklist
Key issues of the decision
Noise
The application contained a noise impact assessment which identified local
noise-sensitive receptors, potential sources of noise from the proposed DAF
plant together with noise attenuation measures. Measurements were taken of
the prevailing ambient noise levels whilst the current site activities were being
undertaken to produce a baseline noise survey and an assessment carried
out in accordance with BS4142:2014 to compare the predicted plant rating
noise levels with background levels. The applicant concluded that the plant
proposed as part of the permit variation will be sufficiently below the
background noise level that it will give “comfortable compliance”.
The applicants background data indicates that there is a significant variation
(Daytime: 37dB to 66dB, Night time: 36dB to 61dB) between minimum and
maximum values. The Local Environment Agency Officer has confirmed that
there has been a history of noise complaints due to intermittent noise
emissions from current sources on the site. It is noted that should there be a
reduction in the current operational sources, this would likely reduce
background noise levels (LA90). Considering this in context, for our
sensitivity checks we have used the minimum background noise levels
monitored by the applicant’s consultant which will likely exclude noise
emissions from the existing operations (including the intermittent noise
source) that is causing the compliance issue, we consider this to represent a
conservative approach.
EPR/BN0465IG/V003
Page 2 of 11The consultant did not include any corrections or penalties in the
BS4142:2014 assessment for tonality (hisses, screeches, bangs thumps etc),
however items such as the compressor, pumps, and piping if incorrectly
installed could result in acoustic features such as totality and impulsivity
features, which should such features appear further attenuation measures
would be required as the plant would not meet BAT requirements. Conditions
2.3.3 and 2.8 fulfil the needs to protect the surrounding soundscape. We
have reviewed the partial levels of each source at sensitivity receptors as part
of our sensitivity checks to consider if these sources are likely to be
perceivable at receptor locations. Our review of the partial levels indicates
that the proposed noise sources should not be audible above the minimum
background noise levels (LA90).
The applicant states in section 4.2 of the application paperwork that the
Environment Agency has asked for the plant to meet noise levels of 5dB
above background noise based on previous assessments. The operator was
requested to clarify this statement as this is not consistent with the
Environment Agency’s approach to noise. Confirmation was received from the
operator, dated 24th June 2015, via e-mail in which they confirmed that no
target or limits had been set or agreed by the Environment Agency for the
new DAF plant to meet, and that the response further clarified that the that the
5dB above background specification had related to another project and had
been merely used as a benchmark figure in the absence of any other criteria
provided by the Environment Agency.”
While we do not agree with the consultants absolute numerical predictions,
we agree with the consultant’s conclusions that the noise levels from the
proposed plant are likely to have a low impact.
The operator has provided a revised noise and vibration management plan in
response to a schedule 5 request for further information dated 08/09/15.
EPR/BN0465IG/V003
Page 3 of 11Annex 1: decision checklist
This document should be read in conjunction with the application, supporting
information and permit/notice.
Aspect
considered
Justification / Detail
Receipt of submission
Confidential
A claim for commercial or industrial confidentiality has not
information
been made.
Identifying
confidential
information
Consultation
Scope of
consultation
Criteria
met
Yes
We have not identified information provided as part of the
application that we consider to be confidential. The
decision was taken in accordance with our guidance on
commercial confidentiality.
The consultation requirements were identified and
implemented. The decision was taken in accordance with
RGN 6 High Profile Sites, our Public Participation
Statement and our Working Together Agreements.
Local Authority Environmental Protection Department
Sewerage Undertaker
European Directives
Applicable
All applicable European directives have been considered
directives
in the determination of the application.
The site
Extent of the
site of the
facility
The operator has provided a plan which we consider is
satisfactory, showing the extent of the site of the facility
including discharge points.
A plan is included in the permit and the operator is
required to carry on the permitted activities within the site
boundary.
Site condition
report
EPR/BN0465IG/V003
The operator has provided a description of the condition
of the site.
Page 4 of 11Aspect
considered
Justification / Detail
Criteria
met
Yes
We consider this description is satisfactory. The decision
was taken in accordance with our guidance on site
condition reports and baseline reporting under IED–
guidance and templates (H5).
Biodiversity,
Heritage,
Landscape
and Nature
Conservation
The application is within the relevant distance criteria of a
site of nature conservation, and/or protected species or
habitat.
Local Wildlife Sites
Site Name: Thorold Road Allotments
Site Name: Chitts Hill Allotments
Site Name: New River Sports Centre, White Hart Lane
Recreation
Ground & Woodside Park
Site Name: Stockton Road Allotments
Site Name: Gosspatrick Road Allotments
Site Name: Tower Gardens
Site Name: Tottenham Cemetery, All Hallows Churchyard
and Bruce
Castle Park
Site Name: Crews Hill to Winchmore Hill Railsides
Site Name: New River
Site Name: Devonshire Hill Allotments
Site Name: Courtman Road Allotments
Site Name: Tatem Park
Site Name: Coles Park Allotments
Site Name: The Paulin Ground Woods
Site Name: Grovelands Park & Priory Hospital
Site Name: Pymmes Park
Site Name: Broomfield Park
Special Area of Conservation (SAC)
Site Name: Epping Forest Site
Ramsar and Special Protection Area (SPA)
Name: Lee Valley
EPR/BN0465IG/V003
Page 5 of 11Aspect
considered
Justification / Detail
Criteria
met
Yes
An assessment of the application and its potential to
affect the sites habitat has been carried out as part of the
permitting process. We consider that the application will
not affect the features of the habitat.
Emissions to air include the existing boiler emission
points as well as a new abated odour exhaust emission
point A27..
There are no direct discharges to controlled waters (or
land) except existing clean uncontaminated surface
waters via appropriate interceptors (Emission Point S1
and S2, Enclosure A:4).
All process water discharges will be made to sewer under
a relevant discharge consent (Reference TDEE0735)
issued by Thames Water (Emission Point E2 on plan
drawing 000-084 dated 01/05/201). Emissions contain
mostly sanitary determinands which are readily treated at
the STW. Changes represent an overall environmental
improvement and relate to discharges of aqueous effluent
to sewer only.
We have not formally consulted on the application. The
decision was taken in accordance with our guidance.
Environmental Risk Assessment and operating techniques
Environmental We have reviewed the operator's assessment of the
risk
environmental risk from the facility.
The operator’s risk assessment is satisfactory.
Based upon the information in the application the
assessment shows that, applying the conservative criteria
in our guidance on Environmental Risk Assessment,
emissions may be categorised as environmentally
insignificant.
For pollutants that are readily treated/removed by the
sewage treatment works, where we are satisfied that BAT
has been applied at the facility, and the operator has a
Trade effluent agreement in place we can accept that
these emissions will be acceptable as the final discharge
will be controlled by a water quality environmental permit
EPR/BN0465IG/V003
Page 6 of 11Aspect
considered
Justification / Detail
Criteria
met
Yes
(discharge consent). There will be no increase in effluent
volumes as a result of this variation.
The new DAF effluent treatment plant is considered to be
an overall environmental improvement in respect of
discharges to the aquatic environment (Sewer) with
significant reductions in discharge levels of FOG and
COD to meet consented limits.
We conclude that the potential for any adverse impact
from the operators discharge is negligible, and agree
with the sewerage undertaker that the trade effluent
consent issued by them provides adequate protection,
however we feel that the discharge of process waters
should be part of an appropriate IPPC BAT review to
further identify high product loss areas in order to reduce
product losses to sewer from the site in compliance with
Dairy and Milk Processing Sector Guidance S6.13 as well
as Food and Drink industries BREF document. Please
see improvement condition section.
The operator has confirmed that the DAF plant conforms
to CIRIA C736 containment standards for the prevention
of pollution, however concern has been raised by the
local Environment Agency Officer regarding tertiary
containment for the protection of controlled waters in the
event of a catastrophic failure of secondary containment.
An improvement condition has been included in the
permit to address this issue, please see improvement
condition section.
No limits have been applied for these releases by the
Environment Agency within the EPR Permit.
Noise
Please see Key Issues section.
Odour
The operation of the DAF plant has the potential to
generate odour pollution. Two individual (in series)
activated carbon filters are to be used to abate odours
from the sealed effluent treatment plant which are then
exhausted to a single emission point (Point A27 Odour
EPR/BN0465IG/V003
Page 7 of 11Aspect
considered
Justification / Detail
Criteria
met
Yes
Abatement Exhaust). Monitoring will be undertaken in-
between these filters and after the second filter prior to
discharge to air to ensure breakthrough of any odour is
identified and to ensure efficient use of raw materials. In
addition a small single (Air displacement) carbon filter
has been included into the side of the bin enclosure,
which is directly fed from the effluent screen. The
operator has provided a risk assessment in relation to
potential odour generation from the plant, and these
emission points to air are included within Table 2.2.1 of
the environmental permit.
The DAF plant is a sealed system being PLC and SCADA
controlled, however in order to ensure that appropriate
measures are in place and in case the proposed plant
fails to work as described i.e. generates. we have
updated the permit to include our standard odour
condition being part of our latest EPR permit wording.
This will ensure appropriate environmental control is in
place requiring the submission of a full odour
management plan at the request of the Environment
Agency should a problem occur.
Based upon the information in the application we are
satisfied that the appropriate measures will be in place to
prevent or where that is not practicable to minimise odour
and to prevent pollution from odour.
Operating
techniques
We have reviewed the techniques used by the operator
and compared these with the relevant guidance notes.
The operator has indicated the use of techniques and
standards in line with technical guidance notes IPPC
S6.13, S6.10 and EPR 1.00 “How to comply with your
Environmental Permit.
The Key issues for determining BAT for the effluent
treatment plant are described in TGN EPR 6.13 ‘Dairy
and Milk Processing Sector’, Sections 1.1 to 1.4, 2.1, 2.2,
2.5, 2.6, 2.8, 2.9, 2.10 and 3.1 to 3.2, In addition Key
issues for determining BAT are also described in the
‘Food and Drink TGN EPR 6.10 Sections 1.1 to 1.4, 2.1,
2.2, 2.4 to 2.5, 2.7 and 3.1 to 3.3. The operator has
provided site specific BAT conclusion documents
confirming use of the standards as set out in the TGN’s
and relevant BREF documents
EPR/BN0465IG/V003
Page 8 of 11Aspect
considered
Justification / Detail
Criteria
met
Yes
The operator has provided a revised pollution risk
assessment and accident management plan (including
preventative techniques and actions) in response to a
Schedule 5 request for further information dated
08/09/15.
The proposed techniques for control are in line with the
benchmark levels contained in the TGN and we consider
them to represent appropriate techniques for the facility.
The permit conditions ensure compliance with relevant
BREFs and BAT Conclusions.
The permit conditions
Use of
Based on the information in the application, we consider
conditions
that we do not need to impose conditions other than
other than
those in our permit template, which was developed in
those from the consultation with industry having regard to the relevant
template
legislation.
Improvement
conditions
Based on the information on the application, we consider
that we need to impose improvement conditions.
We have imposed improvement conditions to ensure that
appropriate measures are in place to ensure that
accidents that may cause pollution are minimised and
appropriate measures are in place to ensure the efficient
use of raw materials and water. . We consider these
conditions to be proportionate to the risk posed by the
operation of the facility, as it is not classed as a ‘low risk’
installation.
Reduction of product losses and raw material usage (IC5)
Although we consider the DAF plant to represent an
overall environmental improvement, we consider that a
BAT review of operating techniques and to identify area
of high product loss should be undertaken, together with
proposals for reducing product loss where identified. We
have imposed this improvement condition to ensure that
appropriate measures are in place to minimise pollution
by reducing effluent loading and chemicals used for
treatment in order to ensure prudent use and
EPR/BN0465IG/V003
Page 9 of 11Aspect
considered
Justification / Detail
Criteria
met
Yes
management of natural resources as required by
paragraph 2 of IED.
Spill prevention. Containment and Indecent response
(IC6)
IC6 requires the operator to undertake a review of current
spill prevention, containment and incident response
procedures for the protection of controlled waters in
accordance with Environment Agency Guidance PPG21
and PPG22. The Environment Agency have imposed this
condition to ensure that appropriate incident repose
measures are in place to ensure accidents that may
cause pollution are minimised.
Site secondary and tertiary containment (IC7)
IC7 requires the operator to commission a qualified
engineer to undertake a full review of the sites secondary
and tertiary containment to ensure that appropriate
standards are met for the protection of land and
controlled waters (Pymmes Brook) in the event of
containment failure. The operator will be expected to
undertake a topographical survey of the site and review
the movement of liquids together with the identification of
high risk areas such as un-surfaced ground, proximity of
controlled waters etc. Design, suitability and integrity of
the sites secondary and tertiary containment including
holding capacities together with calculations must be
provided in the paln. The plan must contain dates for the
implementation of individual measures identified in order
to ensure compliance with indicative BAT as set out in
CIRIA C736 – Containment systems for the prevention
pollution guidance.
We have imposed this improvement condition to ensure
that appropriate measures are in place to minimise
pollution
Incorporating
the application
EPR/BN0465IG/V003
We have specified that the applicant must operate the
permit in accordance with descriptions in the application,
including all additional information received as part of the
determination process.
Page 10 of 11Aspect
considered
Justification / Detail
Criteria
met
Yes
These descriptions are specified in the Operating
Techniques table 2.1.1 in the permit.
Monitoring
We have decided that monitoring should be carried out
for the parameters listed in the permit, using the methods
detailed and to the frequencies specified.
Condition 2.10.2 requiring periodic monitoring of
groundwater and soil and is included as part of the
changes required by the Industrial Emissions Directive.
The operator has a suitable monitoring plan in place for
emissions to sewer. This monitoring has been additionally
included in table 2.10.1 (Other monitoring requirements).
Waste waters from raw milk dairy processing plants may
be higher in ‘phosphorus’ if phosphoric acid is being used
for FOG emulsion cracking, in addition milk and cream
products may also be high phosphorus content. We have
additionally specified monitoring for phosphates as ‘Total
Phosphorous’ this is included in table 2.10.2.
Based on the information in the application we are
satisfied that the operator’s techniques, personnel and
equipment have either MCERTS certification or MCERTS
accreditation as appropriate.
Operator Competence
Environment
There is no known reason to consider that the operator
management
will not have the management systems to enable it to
system
comply with the permit conditions. The decision was
taken in accordance with RGN 5 on Operator
Competence.
Relevant
convictions
The National Enforcement Database has been checked
to ensure that all relevant convictions have been
declared.
No relevant convictions were found. The operator
satisfies the criteria in RGN 5 on Operator Competence.
EPR/BN0465IG/V003
Page 11 of 11
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