Comments/complaints and concerns - 29 January 2024

Bryn Group – Briefing note – 03/06/24

This briefing note provides a general overview of Natural Resources Wales (NRW) regulation of Bryn Group

What activities does Bryn Group carry out at Gelliargwellt farm that NRW regulate?

  • Anaerobic Digestor (AD) Plant (EPR/AB3092ZE): Processes food waste.
  • Waste Transfer Station (EPR/WB3993HE): Processes incoming general and mixed waste.
  • Composting Facility (EPR/WB3993HE): Processing of green waste.
  • Water Abstraction Licence (WA/057/0022/0005): Abstraction of water for the quarry and other activities

Environmental Complaints

Since the last Bryn liaison meeting on 29/01/24 and as of 17/05/24, NRW have received a total of 2 complaints.

  • 2 x Odour complaints

Over this period, we have not been able to confirm that the smell we have been notified is attributable to the permitted facility. We often find that where there is an obvious odour present in the area, it is linked to an agricultural activity both on-site and neighbouring farms, e.g. cleaning out of cattle sheds, or slurry spreading.

What is NRW doing in response to the odour complaints?

Upon an incident being reported to Natural Resources Wales, we ensure that an initial assessment is undertaken by the Incident Communication Centre, who then pass the incident to the regulatory officer. A response is then undertaken, which can be in varying forms, such as;

  • A deskside review of the incident, wherein local knowledge of current site activity is utilised.
  • Forwarding the description of the incident to the Bryn facility for internal investigation.
  • Deployment of resource to the vicinity of the report to substantiate the presence of odour.

Enforcement Action

  • There is no ongoing NRW enforcement action related to Bryn Group permitted activities

Completed Site Inspections since 29/01/24 (last Bryn Group liaison meeting)

Anaerobic Digestor (AD) Plant (EPR/AB3092ZE):

  • 1 inspection(s) undertaken – 21/03/24
  • No breaches identified.
  • ​Waste treatment capacity (i.e. number of treatment vessels) expanding. An environmental permit variation will be required to authorise the changes prior to operation.
  • ​A further site inspection planned during 2024/25 financial year. Date TBC.

Waste Transfer Station (EPR/WB3993HE) & Composting Facility (EPR/WB3993HE):

  • 1 inspections undertaken – 05/03/24
  • Category 3 Breach
  • ​Stockpile height of unprocessed green waste not in compliance with sites Fire Prevention and Mitigation Plan
  • Action completed by operator and unprocessed green waste back in compliance with sites Fire Prevention and Mitigation Plan
  • Site inspection due Quarter 2 of 2024/2025 financial year

Complaint Report

Bryn Compost Odour Complaint

To - Mr Alan Price

From - NRW Incident Communications Centre

Bryn Compost Ltd Gelliargwallt Farm, Gelligaer

Date - Thursday, April 4, 2024

Natural Resources Wales has just received the following complaint about your site:

  • Date / Time Observed - 03-04-2024 21:15
  • WIRS Ref No - 2404516
  • Location - Penywrlod, Gelligaer CF82 8eu
  • Complaint - Bryn Compost
  • At 9.15 on Wednesday night strong smells of sulphur coming from site.
  • All odour events should be recorded and investigated as per the procedure in the Odour Management Plan Section 14. Actions taken and their results should be recorded on the Odour Complaint Report form. These must be kept for future inspections. Thank you

Environmental Health Service Requests since the last meeting held on the 29 January 2024 

Date

Complaint

30/1/24

Dan Y Graig – site working early and late – passed to planning

1/2/24

Not a complaint but a request for Air Quality info – emailed info with an explanation

12/4/24

Ongoing noise complaint – noise/ high pitch/hum – trial turning the animal bedding drying fan speed down manually during evenings/weekends. Difficult to investigate over the winter during the bad weather.
Complainant to comment if any improvement has been noticed as a result of the trial.

14/5/24

Noise and vibration from quarry blast on 13th (recorded levels within
criteria stipulated in the planning conditions.
  • Total 3 complaints.
  • No odours complaints this year to date. Farm did spread in April.

Air Pollution Report

Produced by Ricardo Energy & Environment on behalf of Caerphilly

Caerphilly Gelligaer E-Sampler 01/01/2024 to 16/05/2024

E-sampler attached to this lamppost near 28 Brynheulog Street, Gelligaer CF82 7FZ

Note: These data are provisional

Correction Factor for Gravimetric Equivalence applied

  • V High (No. of Days) - PM10 (µg/m³) - 0
  • High (No. of Days) - PM10 (µg/m³) - 0
  • Mod (No. of Days) - PM10 (µg/m³) - 0
  • Low (No. of Days) - PM10 (µg/m³) - 136
  • Max. Hourly Conc. - PM10 (µg/m³) - 171
  • Max. Daily Conc. - PM10 (µg/m³) - 34
  • Max. Running 8 Hour Mean - PM10 (µg/m³) - 45
  • Max. Running 24 Hour Mean - PM10 (µg/m³) - 39
  • Period Mean Conc. - PM10 (µg/m³) - 6
  • Period Data Capture (%) - PM10 (µg/m³) - 99.6

PM10 

Air Quality Objective

Exceedances

Days

PM10

Daily mean > 50 µg/m³

None

0

PM10

Period mean > annual mean obj 40 µg/m³

No

  

Note: When comparing site measurements against the air quality objectives data capture should meet or exceed 90% across a calendar year.

Comments regarding answers to questions raised at 29th January 2024 meeting

Question

Parking on access drive to Bryn Group site being approved

Response

Bryn Group

Comment

1 resident complaint to CCBC. Verbal discussion with CCBC officers

CCBC EH does not hold any records of such complaints

How can a verbal discussion between Bryn Group and an unnamed CCBC officer allow lorries to park up at the site?

Who is the officer and why is this allowed to happen? CCBC receive numerous complaints of alleged out of hours working at site because of lorries being seen entering and leaving site when the site is supposed to be closed. However it seems that in this case allegedly just 1 person complained. We would like this permission to be rescinded in writing.

CCBC Additional Response

There are conditions attached to certain activities at the site in relation to hours of operation, e.g. the re- cycling area may start from 7am. However, there are no conditions to prevent lorries entering the access lane, so long as the associated regulated/conditioned activities do not start before 7am. This is likened to vehicles entering the carparks of supermarkets on Sunday mornings before the supermarkets are allowed to trade from 10 am.

Additionally, there are no hours of operation associated with the farming activity, thereby farm related vehicles may enter or leave the site at any time.

The decision to allow vehicles to enter the access lane, is a practical and pragmatic solution to prevent them parking or stacking up on the B4254 Gelligaer Road. There are bends and a gradient near the entrance, so parked wagons may be a risk for passing/overtaking vehicles with resultant road traffic accidents and potential fatalities. This explanation has been provided to the liaison group several times, it is disappointing that residents would argue for vehicles remain outside the site. Vehicles parked in the access lane do not pose a nuisance by way of noise or odour to local residents.

Bryn Additional Response

Please could the residents explain why they want to stop the lorries parking on the drive?

Please could they also tell us where they would prefer for the lorries to park?

Do residents know there is 24/7 access to site for utility vehicles? This means that there will be lorries entering and exiting the site all day and sometimes at night.

The farm also has feed lorries, and the milk tanker arrives outside of 7am to 5pm hours. They do not need planning permission for this.

Question

How many years do Bryn Group anticipate they have left of quarrying.

Response

Bryn Group - the amount of rock in the regen is hundreds of years of work.

Comment

The question was how long Bryn Group would quarry on land that they own if they achieve Planning permission.

CCBC Additional Response

Current mineral extraction under the provisions of planning permission Ref. 22/0175/NCC is permitted up to 31st December 2024.

Bryn Additional Response

24 years if we get the new planning.

Question

Level of rubbish falling from skips and lorries.

Response

Bryn is not responsible for the action of others. This litter is presumably thrown out of cars. 

CCBC residents are asked to note reg number, location etc. and report it for investigation.

Comment

Once again, the response from Bryn Group seeks to blame residents for the litter on this stretch of road. I am sure that residents do not throw the amount of rubbish that is seen on the road out of their car windows at precisely this point. Skips and lorries also contain takeaway containers, disposable coffee containers and drinks cans (recyclable).

Again, the residents responsibility. What investigation would be carried out if this was reported?

CCBC Additional Response

Sadly, we witness many roads across the county borough that are prone to littering from vehicles. The Environmental Health Enforcement Team can serve fixed penalty notices on the perpetrators of the offence. Officers have taken such action when they themselves have witnessed such offences. They can also take such action resulting from other people witnessing such offences, so long as accurate details are captured and reported, and the witness is prepared to provide a formal statement to the investigating officer.

Bryn Additional Response

All lorries must legally be sheeted to bring waste into site. We can only advise customers of the law. We have no authority to enforce it on the highway.

Customers are told sheets must be used in the site rules AND when they weigh in at the weighbridge and when they weigh out.

If a lorry leaves site not sheeted, they are put on a week ban and if they persist a life ban.

Question

Why don't Bryn Group use the water jets to clear mud off lorries.

Response

Bryn Group - if there is mud on the road, please report to CCBC Highways

Comment

As a responsible company would it not be prudent to check the state of the road immediately outside your site and not yet again ask residents to report it

CCBC Additional Response

The wheel wash is used on site and the wagons travel along a surfaced lane prior to entering the highway. Thereby, the amount of mud falling from wagons is minimised. Checks are routinely made on the highway and the highway is subject to regular sweeping. If excess mud is noticed, it should be reported to the council.

Bryn Additional Response

We undertake checks on the road up to 4 times a day and when needed we get a road sweeper to clean the road.

If we receive a report of mud or spilt loads on the road, we inspect, shovel up if there is a lot that the road sweeper cannot remove or call in the road sweeper to clean the road.

Question 

How many people work at Bryn Group

Response

Bryn Group - 104

Comment

Could this be broken down into the various operations at site. This is completely outside the Terms of Reference for this Group and is not correspond with Companies house records for Bryn Group's operations.

CCBC Additional Response

This is completely outside the Terms of Reference for this Group and is not related to nuisance impacts to local residents. No further stats will be provided.

Bryn Additional Response

You do not have to record the number of employees in the records for companies’ house. For more information, please see guidance.

https://www.gov.uk/governm ent/collections/companies- house-guidance-for-limited- companies-partnerships- and-other-company-types

Currently we’ve had someone leave on the farm that has not been replaced so we are now 103.

  • Price and co – 15
  • Aggregates – 13
  • Compost – 4
  • Recycling - 71

Question

Why are the lights on 24 hours

Response

Bryn Group - for security and the cows

Comment

Why do the cows need the artificial lights on? Surely security lights don't need to be on constantly.

Bryn Additional Response

Cows are happy when they have 18 hours of day light, strong bright light and 6 hours of dark light, a dim red light. This is the light we provide them.

We agree, it is very sad that we have to have security lights on all night.

Comments taken from protest page

Date

Comment

Response

Bryn Response

NRW Response

15/04/24

Walking dogs over common where muck spreading on weekend. 2 dogs been unwell. Reported to CCBC, NRW and Councillor

The muck spreading takes place on the grazing land, not on public footpaths.

We have not received a report from CCBC, NRW or Councillor.
 
We hope the dogs are well and wan to ensure residents that there would be nothing in the digestate that would make a dog ill.
 
We have monthly salmonella and e-coli test done and quality testing every 3 months. This testing is a
legal requirement for all AD plants.

Total of 2 missed calls, one unknown at 11:37am with a wait time of 6 minutes and the other was another Withyhedge reporter.

13/04/24

Constant hum coming from Bryn Group. First day in garden after all the rain. Complaint made to CCBC, tried ringing NRW but like last week nobody picked up the phone

Need details of complainant to provide a response

We have not received a report from CCBC or NRW.

 

11/04/24

Lorry entering Bryn Group gone midnight

As above relating to vehicle movements.

Utility lorry

 

07/04/24

7.25pm on Sunday large artic on entrance to Bryn Group heading
out.

As above relating to vehicle movements.

The lorry had been delivering feed to the farm.

 

04/04/24

No luck with NRW last night over smell of rotten eggs, tried twice this morning and once tonight still no answer on their hotline.

 

Is this correct as we received notification from NRW of a complaint on this date.
Complaint reference 2404516, date 04.04.24

Total of 2 missed calls on 04/04/24, one of which was a complaint for Withyhedge (South West Wales) and the other rang off after only a 5 second wait time.
 
NRW ICC are currently receiving a large amount of reports for the Withyhedge landfill issue and with lower numbers of ICC Officers on duty, the chances of longer wait times for callers has increased, especially during these busy periods.

03/04/24

Gone out to lock the gates to be hit by a strong smell of rotten eggs.
Unbelievable at 9.15 in the night, tried ringing NRW to register a complaint surprise, surprise no one answered the phone

 

Again, the above complaint states the odour occurred
03.04.24 @ 21.15. Please see attached complaint.
 
Site investigation was undertaken when the complaint was received and no activity that may have produced an odour was being undertaken at the time.

NRW ICC checked call logs, only one call received between 9pm- 10pm on 03/04/24 which was answered. Possibly reporter used old EA 0800 number.
 
Again, NRW ICC are currently receiving a large amount of reports for the Withyhedge landfill issue and with lower numbers of ICC Officers on duty, the chances of longer wait times for callers has increased, especially during these busy periods.

22/03/24

I thought the site was closed on Sundays

The farm is continuously operational, and some operations are permitted on Sundays

We are open on Sundays for Council waste from 7am to 4pm and 24/7 (this includes Sundays) for utility companies. We have
planning permission for this.

 

22/03/24

High pitched noise coming from the Bryn site tonight at 7.30. phoned the Council out of hours line which said press 1 to leave a complaint only for the line to go dead before you can press 1. I tried this several times

IT checked the records log for the caller’s phone number (which was provided) and the person rang the main switchboard at 19.38:03 hours;
the message would have asked him to ring out of hours number on 01443 875500. The call
lasted 33 seconds.
 
No call was made to the out of hours phone line from the complainant’s phone number.

 

 

14/03/23

Gone midnight heavy lorries leaving Bryn Group

As above relating to vehicle movements

Utility lorry

 

20/02/24

12.20 am Driving up from Nelson to Gelligaer looked across to Bryn to see rear lights of lorry obviously
working

As above relating to vehicle movements.

Utility lorry

 

13/02/24

Tipper leaving Bryn at 07.11 which I think had been in weighbridge, loaded or unloaded as they went through wheel/chassis wash all in minutes. As they do not open until
07.00. all done in 11 minutes?

As above relating to vehicle movements.
 
How does the complainant know what happened at the
site?

Does this person have the correct time? The first tipper that day weighed off the weighbridge at 7:20am.

 

12/02/24

Greenhill school covered in mould. Could this be the material they built it with or is the Anaerobic Digester somehow causing it?

There is no link between mould growing on a school building and the Anaerobic Digester.

The Anaerobic Digester is a sealed unit that does not contain mould.
 
Mould is fungi and needs oxygen to live. The Anaerobic digester as the name says is the digestion of nutrients without oxygen.
 
If there is mould growing on the school and it is not just discolouration of the render, it would not have come from
the AD as it is growing in the air, which has oxygen in it.