Britannia Village Residents' Association

John Knight (ABP)

John Knight Animal Rendering Plant is generally accepted as the source for the unpleasant smells in the Britannia Village area.

Map

The Pollution Control Unit from Newham Council have been extremely helpful in providing information regarding the existing licensing and complaints procedures..

What are the requirements attached to the recently renewed Permit?
The rendering of animal remains and food waste is an inherently odorous process. The government has identified animal rendering as a process that requires special regulation. John Knights as a relatively small animal renderer is regulated by Newham Council. The Environment Agency regulates larger processes. Regulatory control by the Council includes good practice in a number of areas including odour control.
In order to put in context the controls the Council is requiring below is a brief description of the process as far as it relates to odour control.

Animal Rendering
The principle part of the process at John Knights is the rendering of animal wastes to produce high grade tallow for pharmaceuticals and cosmetics together with meat meal for pet food. The requirement for the end product means that the animal waste must be in good condition when they reach the factory. In this respect the site is unique in the UK as it does not accept material that was not fit for human consumption when it was dispatched. Animal remains are brought in by lorry from abattoirs, meat cutting plants and butchers. It is unloaded in the raw materials reception area within the factory building. It is then ‘cooked’ in sealed containers producing tallow and meat meal. Both the tallow and the meat meal are kept in sealed tanks before dispatch. Material arrives at Knights, generally from the afternoon onward. Actual processing of material starts once sufficient material has arrived (generally by late afternoon) and goes on until all that day’s deliveries have been processed.

Odours at Knights are from two principal sources: the cooking odour (technically called the ‘foul air’) and the smell inside the factory. Foul air is passed to the boilers as primary feed air. The high temperatures in the boilers should destroy any odour associated with the foul air. Because of the nature of the product handled, the air inside the factory, whilst not as unpleasant as the ‘foul air’ from the cooking process, does smell. This odour is controlled by having all the air in the factory extracted through a scrubber known as a ‘flakt tower’. This is intended to wash out any odours before discharge to the outside air.

Depackaging
As part of an EU Directive, waste food can no longer go to landfill without further processing. Knights have set up a separate operation where waste food of all kinds from shops, supermarkets and food stores are handled. The material received has the packaging removed. The packaging is disposed of and the waste food is removed by lorry to other rendering sites for processing. See point 3 below.

Conditions in their PPC permit require the following works to be conducted in the near future:
1. The flakt tower will have chemical dosing added to the wash water. This tower has a scrubber that removes odours from the plant. The scrubber uses water to spray the air to remove odours. Dosing the water with chemicals will further improve the efficiency of the flakt tower. This system is currently being installed and is due to be finished and evaluated by the end of September 2006.

Update Nov 06: The system has been installed, evaluation and testing is still being conducted.
Update Jan 07: The system has been installed, evaluation of the system has lead to necessary changes being made and testing is therefor still being conducted..

2. Odour sampling of the flakt tower will be carried out along with sampling of the steam raising boilers by the end of September. This will tell us how effective the system is in removing odours. A report for approval will be submitted.

Update Nov 06: Sampling will not take place until the evaluation and testing process is finished.
Update Jan 07:Sampling has confirmed the efficiency of the boilers. They are effectively burning foul air from the process when in operation. Sampling of the flak tower is underway.

3. The depackaging plant on site is due for refurbishment or removal. A decision on this is due by the end of September. If the plant is to stay, then improvements to the buildings integrity and ventilation systems will need to be submitted and approved.

Update Nov 06: Plant will remain and refurb plans have been submitted.

4. Monitoring equipment for boiler efficiency will be installed. This will ensure that the boilers are working to an optimum condition to save energy and ensure efficient burning of foul air.

Update Nov 06: Equipment Installed

5. A datalogger for logging process conditions is being installed currently and this will help to identify process conditions at the time of any odour complaints that we receive. We hope to interrogate this system when complaints occur and it may help us to identify what processes at the plant are causing releases of odour.

Update Nov 06: System is being tested and brought online currently.

By the end of September 2006, conditions in their permit require the following to be implemented or produced:
1. A documented inspection and maintenance programme of impervious surfaces and containment kerbs. This is to minimise emissions to the sewers from the site.

Update Nov 06: To be inspected
Update Jan 07 : Inspected

2. An effective operational and preventative maintenance system shall be adopted on all aspects of the installation whose failure could impact on the environment.

Update Nov 06: To be inspected
Update Jan 07 : Inspected

3. A training system should be in place for all relevant staff to ensure awareness of the regulatory implications of the permit and requirements under this regulatory regime.

Update Nov 06: In Place

4. Skills and competencies for key posts shall be documented and maintained.

Update Nov 06: In Place

5. A feasibility report for keeping separate roof and surface water from process water shall be submitted.

Update Nov 06: To be discussed
Update Jan 07: Submitted

6. An annual review is due to ensure that best environmental options are being used for dealing with all waste from the site.

Update Nov 06: Complete

7. A noise report and maintenance system is due to be produced to minimise noise from all plant and equipment.

Update Nov 06: Submitted - To be discussed

8. An implemented procedure is required for dealing with adverse results from any monitoring activity on the site.

Update Nov 06: To be discussed
Update Jan 07: Complete

By the end of March 2007 conditions in their permit require the following to be implemented or produced:
1.        An airlock to the raw materials reception area is required. This could possibly involve building a ‘shed’ to cover the existing doors to the area, creating a ‘double doors’ effect to the area where raw materials are brought in
2.        All doors used by vehicles are to be of the rapid opening and closing type and be alarmed. This requirement has already been met.
Other requirements:
1.        By the 01/04/08, high intensity process odours and those containing in-condensable gases shall be treated by incineration within the plant boilers or a dedicated thermal oxidiser for by alternative means which can be demonstrated to the Council to be equally effective.
2.        From the 28/12/05, the operator is not permitted to burn tallow unless the requirements of the Waste Incineration Directive (WID) are met on site

We conduct a number of inspections throughout the year to check on site conditions and progress with meeting these requirements. We regularly liaise with the site management and their environmental managers regarding the provision of information and required documentation. We also conduct site visits in respect to any complaints we receive.

What should I do if there’s an unpleasant smell in the Village ?
Complaints regarding the occurrence of odours from the site can be reported to the Pollution Control Team:

020 8430 3792 office hours
020 8472 9624 Out of Hours Initial Response Team

We will try to respond to odour complaints by witnessing such events, however due to officer availability we cannot guarantee a visit at all times. All complaints received are noted on file and the site management are advised of occurrences. For confidentiality reasons complainant’s personal details are of course withheld.

Government guidance requires a judgement on the 'offensiveness' of odours that are witnessed. A number of officers in our department have had their sense of smell tested by reference to a British Standard test by a laboratory. Officers are advised to report whether the odours are 'offensive' and this determines the action that we can take in response to complaints. Of course the wind direction and strength will effect the location and intensity of odours.

We follow the latest Government guidance for this industry with respect to environmental controls for the site that come under our remit. For the Pollution Prevention and Control Regulations, Sector Guidance Note SG8 gives current recommendations and Best Available Techniques that we require the site to operate. The document can be found here:
http://www.defra.gov.uk/environment/ppc/laippc/sg8.pdf

What happens when I call?
In response to odour complaints, officers are advised to visit the site boundary as well as the vicinity of the complainant’s property to assess the odour. An odour tour of Britannia Village is usually conducted at the time as the odour may drift and as you can imagine it can be hard to catch as the wind changes strength and direction.

Are there any follow Up's?

As to what happens if an ‘offensive’ odour is witnessed, the following condition in their permit must be met.

Condition No. 27. "The operator shall prevent the release of offensive odour beyond the installation boundary, as perceived by the local authority inspector, who will take into account the nature of the odour. It shall not be a breach of the condition in a particular case if the operator can show that he or she took all reasonable steps and exercise all due diligence to prevent the release of offensive odour.

For the operator to show that he or she took all reasonable steps and exercised all due diligence to prevent the release of offensive odour the operator shall investigate the occurrence and present a written submission to the Regulator within 3 days of being notified of the occurrence.

In the event of any offensive odour occurrence beyond the installation boundary, the operator shall immediately take remedial action to prevent any further escape of offensive odour and this shall be effective within at most two hours. Where this is not achieved the operator shall demonstrate to the Regulator why this was not achieved (BAT 31)."

This condition was written with regard to the Government's Sector Guidance Note (SG8, as mentioned before). If this condition is not met then we can serve an Enforcement Notice under regulation 24 of the Pollution Prevention and Control Regulations (2000) that enforces the condition to be met.

For all odour complaints we receive I request a report from the site as to action they took regarding the complaint and process conditions at the time. This is followed up by progress reports or site visits as necessary if there are any outstanding issues.

Recent Particular current activities to note are that;
1.        We served an enforcement notice last week on the company regarding an incident where one of the doors to the raw materials reception area was left open unnecessarily. The notice enforces the condition in the permit and requires immediate steps to be taken to stop this happening again.
2.        The operator has appealed against the condition that requires the WID to be met for burning tallow. The appeal is currently with the Planning Inspectorate who hear the appeals. No action shall be taken on this condition until the appeal is heard.
3.        The operator has appealed against the condition requiring the provision of an air lock to the raw reception area. The appeal is currently with the Planning Inspectorate. No action shall be taken on this condition until the appeal is heard.