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Breedon Southern Ltd Dowlow Quarry
Environment Permit Variation Application Report
(Ref: ASOCT171)
Permit No – P21B-3/08
October 2017
Dowlow Quarry Sterndale Moor
Buxton Derbyshire SK17 9QF
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1.0 Introduction An Environmental Permit reference number P21B-3/08 was issued to undertake quarrying operations at Dowlow
Quarry, near Buxton, Derbyshire. The original permit is dated 28 April 2003, with the latest Transfer Variation dated
05 March 2015. Breedon Southern Ltd acquired Hope Construction Materials on 1st August 2016, and there has
since been a formal change to the legal entity. The Registered Company address is Pinnacle House, Breedon
Quarry, Main Street, Breedon on the Hill, Derby. DE73 8AP and the Company Registration Number is 00156531.
This has been communicated to the Regulator (High Peak Borough Council) in separate communications.
Permit reference P21B-3/08 is to operate a scheduled activity – “crushing, grinding or other size reduction (other than
the cutting of stone) or the grading, screening or heating of any designated mineral or mineral product except where
the operation of the process is unlikely to result in the release into the air of particulate matter” – Chapter 3, Section
3.5, Part B (a) of the Schedule 1, Environmental Permitting Regulations. This document is to support an application
for a substantial variation to the current Permit to allow additional activities to be undertaken, specifically the “Coating
of Roadstone with tar or bitumen” – Chapter 3, Section 3.5, Part B (e) of the Environmental Permitting Regulations.
2.0 Site Location & Description
The site is located near to the villages of Sterndale Moor & Earl Sterndale, and 5 miles southeast of Buxton,
Derbyshire. Mineral won at the site is used to produce a range of limestone products for industrial uses and as
aggregates. The quarry site covers approximately 90 hectares (ha) and is bound to the north west by Hindlow
Quarry, to the north-east by a mineral railway line and to the south and east by enclosed pastureland. The boundary
of the Peak District National Park is located close to the site to the north. The Crome and Parkhouse Hills and the
Fox Hole Cave Sites of Special Scientific Interest (SSSIs) are located approximately 2.3 km from the site.
The quarry site currently produces a range of aggregate materials in various sizes for use in readymix concrete
production, sale of dry aggregates and for use in animal feed production by Omya UK. Products are dispatched from
Dowlow via road to local markets, and rail for wider dispatch throughout England & Wales. The environmental
setting of the operations is shown in the images below.
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Figure 1 General Location of installation (Taken from Google Earth)
Dowlow Quarry – boundary marked in black, accessed from A515 Buxton (to the North West) – Ashbourne (to the
South East).
Dust Monitoring Gauge locations – marked by Yellow pin – in Sterndale Village and on the perimeter on the
Southeast Boundary
3.0 Dowlow Quarry Operations
Permission from Derbyshire County Council, under the General Permitted Development Order 2015 has been
granted for the erection of an asphalt plant – reference PD17/1/64, dated 31 August 2017. This application is to vary
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the existing Environmental Permit, issued by High Peak Borough Council, to include the operation of this plant as part
of the Dowlow operations.
3.1 Existing Activity
The existing activity at Dowlow is described as follows:
• The removal and stockpiling on site of overburden. This material is generally used in restoration of
worked areas.
• The excavation and transportation of blasted rock to crusher feed points. Dowlow Limestone is drilled
and blasted, by an in-house blasting team, using a combination of packaged explosives and ANFO
mixed on site. Blasted material is loaded into dump trucks, by excavator and transported to the primary
crusher.
• The dump trucks tip the blasted rock into the Primary Crusher dump hopper, which in turn feeds onto an
MMD Pan Feeder. The material then moves across a Roll Grizzly, which separates out <125mm
Scalpings, onto a dedicated stockpile, and allows >125mm material to pass forward into the Primary
Crusher. Product from the Primary Crusher is either stockpiled, then screened to produce 80mm-40mm
material, or >40mm material is carried forward to Secondary crushing. Further crushing will produce
<40mm, <20mm and single sizes (0-2mm, 4mm, 6mm, 10mm, 14mm & 20mm materials) which will be
stocked for sale & dispatch or use in the new Asphalt plant
• The washing of crushed rock is carried out in a dedicated plant to remove excessive fines and silt
materials. The plant, which incorporates a crusher and a screen, is fully enclosed. Water is abstracted
under license, stored on site, used in the process and for dust suppression and housekeeping activities.
There is no discharge from Dowlow Quarry.
• The crushing, screening and stockpiling of these materials. There are 3 stages of crushing available on
site, as described above. Material is moved via conveyors or dump trucks to stockpiles; 3-sided sleeper
bays are used for material loading onto trains and a dust shed is dedicated to certain products requiring
dry storage and protection from wind-ship. This shed will be located such that the rear of the shed faces
the prevailing wind direction, to minimize potential for wind-whipping.
• The loading and transportation from the site by road and rail vehicles of crushed and screened materials.
Road vehicles are loaded by conveyor and chute or directly by loading shovel. Road vehicles pass
through a wheel wash and over the site weighbridge prior to leaving site. Rail vehicles are loaded from
3-sided sleeper bays located in the rail loadout area. These bays are fed from the aggregate plant bins
by rubber wheeled dumpers, dust suppression is provided by dedicated mobile truck.
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• The use of additional authorised mobile crushing and screening plant as and when required.
• The discharge of waste material from the processes to tipping areas within the site boundary.
These activities have been carried out in compliance with an Environmental Permit, first issued in 2003 – reference
number PG21B-3/08.
3.2 Proposed Additional Activity
The proposal is to operate an asphalt plant, located within the processing area at Dowlow Quarry. The plant, a
Gibault-OHL urban asphalt plant, will be located in the north-western corner of the site. The plant will be housed
within a series of connected buildings, and will comprise conveyor feeds, a dryer, mixing tower, storage silos and
tanks (for filler, fuel and bitumen), cold recycling unit and a bag filtration arrestment plant. There will also be
aggregate bays and loading areas, and the facility to store and use Recycled Asphalt Pavement (RAP) will be
incorporated. The asphalt plant will be fully enclosed within a building, with a maximum roofline height of 22.5
metres, and a stack with a maximum height of 26.5 metres. The plant will potentially operate 24 hours a day,
Monday – Saturday, at a maximum of 120 tonnes / hour, using a 2 tonne mixer and the plant’s 20Mw burner will be
fueled by Processed Fuel Oil.
The asphalt plant will use dry single sized aggregates, including limestone filler, produced by Dowlow Quarry.
Materials will be fed into the Asphalt plant cold feed bins using loading shovel. Limestone filler will be produced on
site and stored in appropriate silos. It will either be fed direct into the asphalt plant as required, or loaded directly into
tankers for internal sale and dispatch to other Breedon Southern operations. From the cold feed bins and silos,
material will be conveyed, dried, mixed with bitumen and then stored in hot storage bins prior to loading into road
vehicles.
4.0 Environmental Impacts
The environmental impact of the asphalt plant is discussed in this section, in the context of the new activity being
established alongside and existing quarrying operation. The environmental impact of this quarrying & mineral
processing operation is managed and controlled on an ongoing basis and these controls, procedures and practices
will continue and will support the responsible operation and management of the asphalt plant.
4.1 Potential Emissions & Controls
There is potential for additional visible emissions from the operation of the asphalt plant, including fugitive dust from
the aggregate stockpiles or from the handling and transportation of aggregates and filler materials, smoke from the
combustion process. There is also potential for odour emissions arising from asphalt production and bitumen storage
and use. The combustion process has potential for environmental impacts generally and emissions to atmosphere
can be affected during start-up and shut-down of the process and during abnormal operating conditions, such as
break down or malfunction.
The following table details the substance under consideration, the potential source of emission and the control
techniques which will be implemented on site. These control techniques are derived from the best available
techniques as determined in Process Guidance Note PG3/15, dated September 2012 and published by DEFRA.
Table 1 – Summary of Environmental Impacts & Control Techniques
Substance Emission Source Potential Control Techniques
Particulate Matter
Loading & Unloading processes
Conveyor transfer points
Medium Fully enclosed building
3-sided sleeper bays for aggregate storage
Reduced drop heights
Dust suppression – spray bars or site bowser as appropriate
Asphalt production Medium Fully enclosed building
Bag filter – fitted with 480 bags
Continuous quantitative monitoring (manufacturer to be confirmed) in batch cabin
Procedures, covering combustion process, mixing, monitoring & inspection, maintenance
Training & competence
Deliveries: to silo from road tanker; from silo to road tanker
Medium Process controls & procedures
Automatic silo protection systems – high level monitor / alarms (audible & visible)
Tanker delivery controls & procedures
Silo filling & operation
Low Process controls & procedures
Automatic silo protection systems – high level monitor / alarms (audible & visible)
Aggregate storage Medium Storage arrangements: silos for fine powder materials,
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Table 1 – Summary of Environmental Impacts & Control Techniques
Substance Emission Source Potential Control Techniques
3-sided bays for aggregates
Storage shed for small sized aggregates
Conveyors, conveyor transfer points
Low Containment – fully enclosed building
Roadways Medium Existing site controls – dust suppression, site design, including hard surfacing to allow road sweeping / cleaning
Mobile Plant & Site Vehicles
Medium Wheel wash, cleaning facilities on site
Hard surfacing of roads where practicable to allow sweeping & cleaning
Lorries (on site & on the highway)
Medium Wheel wash
Lorry sheeting
General plant operation
Low Fully enclosed building
Located away from site boundary
Odour or bitumen fume
Bitumen loading Medium Process & Temperature controls
Fully enclosed building
Ground based pumps
Location of plant away from site boundary
Bitumen storage
Handling hot bitumen or coated roadstone
Heating recycled asphalt (RAP)
Low Cold or foam mix techniques
Tar fume Heating reclaimed asphalt (RAP) containing coal tar
Low Cold or foam mix techniques
Other hydrocarbon emissions
Incomplete combustion
Medium Good combustion – process controls, procedures & training
Release agents (cleaning activities)
Low Avoid hot surfaces
Greenhouse Gas emissions (CO, SOx / NOx )
Combustion process – fuel, oil etc
Medium Good combustion – process controls, procedures & training
Visual Impact
Asphalt Plant Low Located away from site boundary, screened from external viewpoints by existing plant infrastructure
Building cladding in Merlin Grey – provides dark recessive finish
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The control techniques detailed in the above table will be established as part of the plant design and build, and as
part of the development of the management and operation procedure.
5.0 Monitoring, reporting & limits
5.1 Monitoring & Inspections
The operation will be monitored both continuously and periodically to ensure emissions are prevented, or where that
is not practicable, they are reduced.
5.1.1 Combustion process – will be free from visible smoke (in normal operation) and monitored continuously by way
of a continuous emissions monitor (CEM) and visually. The CEM will provide output of the stack emissions from the
combustion process. The display will be located in the batch cabin and visible to the plant operator at all times. The
expected emission concentration of the asphalt plant is expected to be in the region of 20-25 mg/m3 or less.
Visual checks will be made at least once per shift by the operator. The time, location and result of the checks, along
with weather conditions will be recorded on the site log book. A weather station will be installed on site to provide
accurate data. The monitoring frequency that will be implemented is shown in Table 1 below.
Any failure of the dust abatement equipment or the CEM will be fully investigated, corrective actions identified and
implemented to prevent further odour emissions.
5.1.2 Calibration & Compliance monitoring - will be carried periodically by appropriate specialist contractors. The
monitoring frequency will be as follows: 1) Upon Commissioning; 2) After 6 months operation; 3) After 12 months
operation; 4) Annual thereafter. The CEM will be calibrated and serviced annually. Adequate facilities will be
provided on the asphalt plant, to enable representative sampling of the main stack to be achieved, in compliance with
the appropriate sampling standard.
5.1.3 Fugitive Dust – monitoring of fugitive dust emissions is carried out by site personnel and also by specialist
contractors. Visual inspections are completed and recorded on Daily Logs by site personnel. Specialist contractors
undertake monitoring at 2 locations using dust deposition gauges (frisbees), with the results being provided to site
management monthly. The current monitoring locations at in the nearby village of Sterndale Moor (Grid Reference
SK 10354 68733) and on the South-East perimeter of the site boundary (Grid Reference SK10972 66984). These
locations are indicated on Figure 1. Dust monitoring results will be submitted to the Local Authority 6-monthly and
internally reviewed to identify increases in dust emission and potential sources of dust. Where issues arising from
Dowlow Quarry & Asphalt operations are confirmed, corrective actions will be identified and implemented to prevent
further issues occurring.
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5.1.4 Emissions from silos – will be controlled through the implementation of silo protection systems. Silos will be
fitted with dust filtration systems fitted with reverse jets, pressure relief valves, audible and visual high level / overfill
alarms. The silo system will also be fitted with auto shut-off systems to prevent overfilling.
Inspections will include visual inspections on the filtration plant at least monthly, weekly inspections of the pressure
relief valves, visual checks will be made at least once per shift by the operator. The time, location and result of the
checks, along with weather conditions will be recorded on the site log book. The monitoring frequency that will be
implemented is shown in Table 1 below.
Any failure of the silo management or protection system (for example, high level alarms, filter, PRV) will be fully
investigated, corrective actions identified and implemented to prevent further odour emissions.
5.1.5 Odour – the plant is located well away from the site boundary and sensitive receptors. The nearest residents
are located in Dowlow cottages (which will be around 500m from the plant) and Dowlow Farm (which is around 1km
from the plant). Consequently, it is expected that the escape of offensive odour is unlikely to cause harm or nuisance.
However, in the initial stages of plant operation, this will be monitored by Dowlow Quarry staff.
If problems arise, or odour complaints are received, extra monitoring at the boundary will be carried out and recorded,
and corrective actions identified and implemented to prevent further odour emissions.
5.2 Reporting
The regulator (High Peak Borough Council) will be kept informed of monitoring to be carried out and the results
achieved. The results will be in the form of a report, issued by the extractive sampling test body, and will include
process conditions at the time of the monitoring.
The regulator will be informed at least 7 days before any periodic monitoring exercise, details to include the
provisional time and date, pollutant to be tested and methods to be used. The results will be forwarded to the
regulator within 8 weeks of the monitoring.
Adverse results from any monitoring activity will be fully investigated, identifying the cause and appropriate corrective
actions. A re-test may be necessary to confirm compliance. The regulator will be kept informed of the re-test, actions
taken and re-test results.
5.3 Emission Limits & Monitoring
The following table, taken from the DEFRA Process Guidance Note, details the emission limits and monitoring
arrangements to be implemented:
Table 2 – Emission Limits, monitoring and other provisions
Substance Source Emission limits / provisions Type of Monitoring Monitoring Frequency Whole site and all authorised emission points 1 Visible
emissions Site No visible emissions to cross site boundary Operator observations Once a day
2 Visible emissions
All authorised emission points No abnormal emission Operator observations
3 Droplets, persistent mist, fume, smoke
All emissions to air (except steam & condensed water vapour)
No droplets, no persistent mist or fume No visible smoke except during startup of coating plant, and then no darker than Ringelmann 1
Visual observations On startup & on at least 2 more occasions during the working day
Roadstone Coating Plant 4 Particulate
Matter Roadstone coating plant – new plant and roadstone coating plant with new or replacement arrestment equipment
50 mg/m3 Continuous, quantitative – CEM Periodic, quantitative – annual monitoring
5 Sulphur dioxide All activities using heavy fuel oil or other residual type / comparable Quality Protocol Process Fuel Oil
1% wt/wt Sulphur in fuel Sulphur content of fuel is regulated under the Sulphur Content of Liquid Fuels Regulations
6 Sulphur dioxide All activities using gas oil / comparable Quality Protocol Process Fuel Oil
0.1% wt/wt Sulphur in fuel Sulphur content of fuel is regulated under the Sulphur Content of Liquid Fuels Regulations
Silos 7 Particulate
matter Silo inlets & outlets Designed to emit less than 10 mg/m3
No visible emission Operator / driver observations Record start & finish times
Every delivery
Notes *All periodic monitoring results shall be checked by the operator on receipt and sent to the Council within 8 weeks of the monitoring being undertaken. * (a) Where the plant is discharging to the external atmosphere (b) The refence conditions for limits in Table xx are: 273.1K, 101.3kPa, without correction for water vapour content © All periodic monitoring shall be representative and shall use standard methods (d) Emission limits do not apply during start-up and shut-down. All emissions shall be kept to a minimum during these periods.
5.4 Management
Dowlow Quarry is certified to ISO 9001 (Quality), ISO 14001 (Environment) and OHSAS 18001 (Health & Safety).
The written & documented management systems, to which this certification applies, will be extended to incorporate
the additional activities where appropriate, and the existing procedures and controls will continue to be implemented
to ensure that a high standard of environmental performance is maintained.
The management system implemented on-site includes written procedures covering operation, checks, and
inspections; these procedures will be audited as part of the internal and external audit processes. All staff
associated with the asphalt plant operation will be trained and competent in the execution of their duties, and records
of any such training will be held on site and available for review.
6.0 Conclusion
This application requests approval from the high Peak Borough Council for the operation of an asphalt plant, within
Dowlow Quarry. It is requested that the current environmental permit be varied to this extent. The Breedon Group is
committed to maintain the highest standards of environmental performance and are certified to ISO 14001 to support
this.
Following consideration of this variation application, it is requested that the Regulator accept this report as detailed
description of the proposal and its management, and allow the variation of Permit P21B-3/08.
End.