Barratt London

NIMR, Mill Hill

Construction and Demolition

Air Quality and Dust Management Plan

for Pre-commencement Conditions 11
and 37

December 2017

Executive Park, Avalon Way, Anstey, Leicester, LE7 7GR

Tel: +44 (0)116 234 8000
Nigel.mann@wyg.com

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Document Control

Project: NIMR, Mill Hill

Client: Barratt London

Job Number: A106459

File Origin: O:\Acoustics Air Quality and Noise\Fee Earning Projects

Document Checking:

Hannah Pearson
Prepared by: Initialled: HP
Environmental Consultant

Daniel Clampin
Checked by: Initialled: DC
Senior Environmental Scientist

Nigel Mann
Verified by: Initialled: NM
Director

Issue Date Status

1 27th September 2017 First Issue

2 5th October 2017 Second Issue: Minor Amendments

3 3rd November 2017 Third Issue: Updated Phase Schedule

4 20th December 2017 Fourth Issue: Minor Amendments and Updates

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Contents Page
1. Introduction ............................................................................................................................. 2
1.1 Site Location and Context ................................................................................................. 2
2. Policy and Legislative Context .................................................................................................... 4
2.1 Documents Consulted ....................................................................................................... 4
3. Risk Assessment of Potential Dust Effects ................................................................................... 5
3.1 Pollutant Sources ............................................................................................................. 5
3.2 Particulate Matter (PM10) .................................................................................................. 5
3.3 Dust ................................................................................................................................ 5
3.4 Ecological Receptors ......................................................................................................... 6
3.5 Background Concentrations .............................................................................................. 6
3.6 Assessment Results .......................................................................................................... 6
4. Construction Activities ............................................................................................................... 8
5. Dust Management Measures ...................................................................................................... 9
5.1 Dust Management Plan ..................................................................................................... 9
5.2 Potential Magnitude of Dust Effects ................................................................................... 9
5.3 Sources, Releases and Impacts ......................................................................................... 9
5.4 Construction Phase Dust Management Plan ..................................................................... 10
5.5 Non-Road Mobile Machinery............................................................................................ 12
5.6 Measures to Reduce Emissions of NOx and Particulates from On-Site Transport during the
Construction ..................................................................................................................................... 12
6. Dust Monitoring ...................................................................................................................... 13
6.1 Monitoring ..................................................................................................................... 13
6.2 Pollution Response Plan .................................................................................................. 16
7. Conclusions ........................................................................................................................... 18

Figures

Figure 1 Phase 1 AQMESH Monitor Locations

Figure 2 Phase 2 & 3 AQMESH Monitor Locations
Figure 3 Phase 3 & 4 AQMESH Monitor Locations
Figure 4 Phase 4 & 5 AQMESH Monitor Locations
Figure 5 Sensitive Receptor Locations

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Executive Summary

WYG have undertaken an assessment to discharge Pre-commencement Conditions 11 and 37, for the
proposed construction of 460 residential units over five phases of construction, at the former NIMR site, Mill
Hill, Barnet.

During the demolition and construction works, it is anticipated that dust sensitive receptors will potentially
experience increased levels of dust and particulate matter before using any mitigation and control measures.
However, these are predicted to be short term and temporary impacts. Throughout this period, the potential
impacts from construction on air quality will be managed through site specific mitigation measures detailed
within this dust management plan. With these mitigation measures in place, the effects from the demolition
and construction work are not predicted to be significant.

AQMESH continuous monitoring on-site will be conducted throughout all five phases of construction. Any
exceedances of the relative criteria for PM10 and PM2.5 will be reported to the client, so that site operations
may be reviewed and altered where necessary.

A Pollution Response Plan is also included should trigger levels be exceeded during monitoring.

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1. Introduction

Barratt London commissioned WYG Environment Planning Transport (WYG) to prepare an assessment of
dust to discharge Pre-commencement Conditions 11 and 37, for the proposed construction of 460 residential
units over five periods of construction, at the former NIMR site, Mill Hill, Barnet.

Condition 11 states: “An Air Quality & Dust Management Plan shall be submitted to, and approved by the
local Planning Authority, before the development commences those propose shall be to control and minimise
emissions attributable to the demolition and/or construction of the development. Reference shall be made to
the Mayor of London’s SPG, “The Control of Dust and Emissions during construction and demolition.” The
plan shall confirm

 Which air quality emission and dust control measures are to be implemented
 Which monitoring methods are to be implemented; and
 What construction machinery will meet NRMM standards

Reason: to comply with the London Plan’s SPG on Sustainable Design and Construction and Policy 7.14 of
the London Plan in relation to air quality.”

Condition 37 states: “Relates to the CEMP which must be submitted before commencement of construction
on site. With regards to dust and air quality control, the condition states the following must be complied
with:

 Measures to minimise dust levels

 Measures to control pollution during construction (including a pollution response plan).”

1.1 Site Location and Context

The approximate United Kingdom National Grid Reference (NGR) is approximately 523342, 192616. The site
is bounded to the north by open fields, to the east and south by residential properties and St Vincent’s RC
Primary School, and to the west by a racing stables and further residential properties. Reference should be
made to Figure 1 for a map of the proposed development site and surrounding area.

The following assessment stages have been undertaken as part of this assessment:

 Baseline evaluation;

 Assessment of potential air quality impacts during the works;

 Dust Management Plan

 Air Quality Monitoring and Pollution Response Plan

The results of the assessment are detailed in the following sections of this report.

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The assessment considers the potential effects of dust and particulate emissions from site activities and
materials movement based on a qualitative risk assessment method based on the Mayor’s SPG ‘The Control
of Dust and Emissions during Construction and Demolition’, July 2014.

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2. Policy and Legislative Context

2.1 Documents Consulted

The following documents were consulted during the undertaking of this assessment:

Legislation and Best Practice Guidance

 National Planning Policy Framework, Department for Communities and Local Government, March
2012;

 Planning Practice Guidance: Air Quality, March 2014;

 The Air Quality Standards Regulations, 2010;

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

 The Environment Act, 1995;

 Local Air Quality Management Technical Guidance LAQM.TG(16), DEFRA, 2016;

 Design Manual for Roads and Bridges, Volume 11, Section 3, Part 1, HA 207/07 - Air Quality,
Highways Agency, 2007;

 Guidance on the Assessment of Dust from Demolition and Construction, IAQM, 2014.Local Air
Quality Management Note on Projecting NO2 concentrations, DEFRA, April 2012.

 Air Quality Neutral Planning Support Guidance, Greater London Authority, 2014.

 The Control of Dust and Emissions during Construction and Demolition, Greater London Authority,
July 2014.

 The London Plan, (Consolidated with Amendments since 2011) March 2015.

 Google maps (maps.google.co.uk);

 The UK National Air Quality Archive (www.airquality.co.uk);

 Department for Transport Matrix (www.dft.go.uk/matrix);

 emapsite.com;

 Multi-Agency Geographic Information for the Countryside (http://magic.defra.gov.uk/);

 Planning Practice Guidance (http://planningguidance.planningportal.gov.uk/); and

 London Borough of Barnet (https://www.barnet.gov.uk/)

 London Borough of Barnet Local Plan Core Strategy, Adopted September 2012.

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3. Risk Assessment of Potential Dust Effects

3.1 Pollutant Sources

Other than negligible emissions from vehicles and equipment, the main emissions during the works are likely
to be dust and particulate matter generated during earth moving (particularly during dry months) or from on
site materials. The main potential effects of dust and particulate matter are:

 Visual - dust plume, reduced visibility, coating and soiling of surfaces leading to annoyance, loss of
amenity, the need to clean surfaces;
 Physical and/or chemical contamination and corrosion of artefacts;
 Coating of vegetation and soil contamination; and,
 Health effects due to inhalation e.g. asthma or irritation of the eyes.

A number of other factors such as the amount of precipitation and other meteorological conditions will also
greatly influence the amount of particulate matter generated.

Site activities can give rise to short-term elevated dust/PM10 concentrations in neighbouring areas. This may
arise from vehicle movements, soiling of the public highway, demolition or windblown stockpiles.

3.2 Particulate Matter (PM10)

The UK Air Quality Standards seek to control the health implications of respirable PM10. However, the
majority of particles released from the works will be greater than this in size.

Works on site have the potential to elevate localised PM10 concentrations in the area. On this basis,
mitigation measures should still be taken to minimise these emissions as part of good site practice.

3.3 Dust

Particles greater than 10µm are likely to settle out relatively quickly and may cause annoyance due to their
soiling capability. There are no formal standards or criteria for nuisance caused by deposited particles,
however, a deposition rate of 200mg/m2/day is often presented as a threshold for serious nuisance though
this is usually only applied to long term exposure as people are generally more tolerant of dust for a short or
defined period. Significant nuisance is likely when the dust coverage of surfaces is visible in contrast with
adjacent clean areas, especially when it happens regularly. Severe dust nuisance occurs when the dust is
perceptible without a clean reference surface.

On site activities have the potential to suspend dust, which could result in annoyance of residents
surrounding the site. Measures will be taken to minimise the emissions of dust as part of good site practice.
Recommended mitigation measures proportionate to the risk associated with the development and based on
best practice guidance are discussed in the following sections.
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Three construction processes are considered; these are earthworks, construction and trackout. For each of
these phases, the significance of the potential dust impacts is derived following the determination of a dust
emission magnitude and the distance of activities to the nearest sensitive receptor, therefore assessing
worst case impacts.

3.4 Ecological Receptors

Air quality impacts associated with the proposed re-development have the potential to impact on receptors
of ecological sensitivity within the vicinity of the site. The Conservation of Habitats and Species Regulations
(2010) require competent authorities to review planning applications and consents that have the potential to
impact on European designated sites (e.g. Special Protection Areas).

A study was undertaken to identify any statutory designated sites of ecological or nature conservation
importance within the extents of the dispersion modelling assessment. This was completed using the Multi-
Agency Geographic Information for the Countryside (MAGIC) web-based interactive mapping service, which
draws together information on key environmental schemes and designations. Following a search within a
1km radius of the site boundary no ecological receptors have been identified.

3.5 Background Concentrations

The use of background concentrations within the modelling process ensures that pollutant sources other
than traffic are represented appropriately. Background sources of pollutants include industrial, domestic and
rail emissions within the vicinity of the study site.

Background concentrations as used within the prediction calculations were referenced from the UK National
Air Quality Information Archive database based on the National Grid Co-ordinates of 1 x 1 km grid squares
nearest to the development site. In June 2014, DEFRA issued revised 2013 based background maps for
nitrogen oxide (NOX), NO2, PM10 and PM2.5 which incorporate updates to the input data used for modelling.
2017 background maps have been utilised throughout the assessment to provide a conservative assessment.
The updated mapped background concentrations used in the assessment are summarised in Table 3.1.

Table 3.1 Published Background Air Quality Levels (µg/m3)

UK NGR(m) 2017
X Y PM10 PM2.5
522500 192500 16.2 11.7
523500 192500 16.2 11.7
522500 193500 15.9 11.5
523500 193500 15.8 11.3

3.6 Assessment Results

Based on the methodology detailed in the supporting Air Quality Technical Report, the summary risk of of
construction impacts prior to mitigation have been defined as outlined in Table 4.2.

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Table 3.2 Impact Significance of Construction Activities without Mitigation

Summary Risk of Impacts Prior to Mitigation
Source
Dust Soiling Health Effects of PM10 Ecological
Demolition High Medium N/A
Earthworks High Low N/A
Construction Medium Low N/A
Trackout Low Low N/A

Appropriate mitigation measures are detailed and presented in Section 5. Following the adoption of these
measures, the subsequent impact significance of the construction phase is not predicted to be significant.

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4. Construction Activities

The works at Mill Hill are currently proposed to start on site in January 2018, with an estimated completion
of December 2021. The construction works have been split up into five construction phases as outlined
below and shown on the Phasing Plan in Figure 4.1:

 Phase 1 – 04/05/2018 – 28/06/2019 (133 Units);

 Phase 2 – 31/07/2018 – 06/03/2020 (60 Units);
 Phase 3 – 13/05/2019 – 08/10/2020 (59 Units);
 Phase 4 – 27/11/2019 – 02/07/2021 (85 Units); and
 Phase 5 – 02/03/2020 – 21/12/2021 (123 Units).

Figure 4.1 Phasing Plan

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5. Dust Management Measures

5.1 Dust Management Plan

The definition and the main purpose of the dust management plan are summarised below:

 A management plan is a live working document that formalises and describes how dust issues will
be managed on site. The plan forms part of the operational management system (indeed it may
form part of a site’s wider Environmental Management System or Integrated Management System);

 The plan should show how dust and odours will be managed and controlled so as to prevent or
minimise impacts. As well as covering normal operations, it should anticipate and plan for abnormal
events and foreseeable accidents and incidents;

 It is not an impact assessment; it is a mitigation/control measure; and

 It should not be complex; simple plans are needed, that can be easily actioned by the site
operatives.

5.2 Potential Magnitude of Dust Effects

As outlined in section 3 of this report, the potential impact significance of dust emissions associated with the
construction phase of the development have been assessed as ‘medium’ risk at the worst effected receptors
without mitigation. Therefore measures to be employed as part of the dust management plans are tailored
to manage this risk.

The risk of dust emissions during the operational phase, from site activities has been considered based on:

 The activities being undertaken;

 The duration of each activity;
 The size of the site;
 The meteorological conditions; and,
 The sensitivity and proximity of receptors.

5.3 Sources, Releases and Impacts

Dust may be released during the following activities:

 Unloading of materials at the site;

 Storage of waste on site;

 Storage of materials on site;

 Loading materials;

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 Vehicle movements.

Once released into the atmosphere, dust can be transported through the air to nearby receptors. Sensitive
receptors include humans living within close proximity of the proposed site.

5.4 Construction Phase Dust Management Plan

The dust risk categories for the proposed site construction activities have been determined in Section 3. The
assessment has determined that the potential impact significance of dust emissions associated with the
construction phase of the proposed development is ‘medium’ risk at the worst affected receptors.

Appropriate site specific mitigation measures associated with the determined level of risk can be found in
Section 8.2 of the IAQM Guidance on the Assessment of Dust from Demolition and Construction. These
mitigation methods for medium risk sites are listed below where applicable to the proposed site works, and
these measures will be adhered to during the construction phase of the development.

Dust Management

General Measures

 Plan the site layout so that machinery and dust causing activities are located as far away as is
possible from receptors.
 Erect solid screens or barriers around dusty activities or the site boundary that are at least as high
as any stockpiles on the site.
 Fully enclose operations where there is a high potential for dust production and where the site is
active for an extensive period.
 Avoid site runoff of water and mud.
 Keep site fencing, barriers and scaffolding clean sing wet methods.
 Remove materials that have a potential to produce dust from site as soon as possible. If they are
being re-used on site, cover as described below.
 Cover, seed or fence stockpiles to prevent wind whipping.
 Ensure equipment is readily available on site to clean any dry spillages, and clean up spillages as
soon as reasonably practicable.
 Use covered skips.

Communications

 Display the name and contact details of the person(s) accountable for air quality and dust issues on
the site boundary.
 Display the head office contact information.

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 Good relations with people living and working in the vicinity of site operations are of paramount
importance.
 Notification of nearby residents and businesses may include letters, door knocking residents and/or
advertisements (e.g. print).
 In the case of work required in response to an emergency, the local authority and local
residents will be advised as soon as reasonably practicable that emergency work is taking
place. Potentially affected residents will also be notified of contact details for a relevant member of
the project team in the incidence of undue disturbance.
 Good relations can be developed by keeping people informed of progress and by treating complaints
fairly and expeditiously. All complaints will be recorded, identifying cause(s) and appropriate
measures to reduce emissions in a timely manner, and record measures taken. The complaints log
will be made available to the local authority when requested.
 Records of any exceptional incidents that cause high dust emissions, either on – or off site will be
kept in the log book along with the action taken to resolve the situation.

Monitoring

 Undertake daily on-site and off-site inspection, where receptors (including roads) are nearby, to
monitor dust, record inspection results, and make the log available to the local authority when
asked. This should include regular dust soiling checks of surfaces such as street furniture and cars
within 100m of site boundary, with cleaning to be provided if necessary.
 Increase the frequency of site inspections by the site manager when activities with a high potential
to produce dust are being carried out and during prolonged dry or windy conditions.
 Increase the frequency of site inspections during prolonged dry or windy conditions.
 Further monitoring to be conducted on site can be found in Section 6 of this report.

Vehicles and Plant

 Ensure all vehicles switch off engines when stationary – no idling vehicles.
 Avoid the use of diesel or petrol powered generators and use mains electricity or battery powered
equipment where practicable.
 Only use cutting, grinding or sawing equipment fitted or in conjunction with suitable dust
suppression techniques such as water sprays or local extraction.
 Ensure an adequate water supply on the site for effective dust suppression, using non-potable water
where possible and appropriate.
 Minimise drop heights from conveyors, loading shovels, hoppers and other loading or handling
equipment and use fine water sprays on such equipment wherever appropriate.
 Impose and signpost a maximum – speed-limit of 10mph on surfaced and un-surfaced haul roads
and work areas.

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 Provision of signage to remind drivers of the on-site speed limit;

 Dampening loads leaving the site when necessary;
 Availability of a road sweeping vehicle for use on internal and external roads, if required;
 All loads transported to and from site should be sheeted and contained to minimise any dust.

5.5 Non-Road Mobile Machinery

An inventory of all Non Road Mobile Machinery (NRMM) will be kept on-site and registered on
‘http://nrmm.London/’ showing the emission limits for all equipment and will be made available to local
authority offices if required. All NRMM will be of net power 37kW and up to and including 560kW used
during the course of demolition, site preparation and construction phases. This will be required to meet
Stage IIIA of EU Directive 97/68/EC. NRMM should be run on low sulphur diesel.

5.6 Measures to Reduce Emissions of NOx and Particulates from On-Site

Transport during the Construction

Arrangements should be made with the on-site vehicle drivers to ensure drivers do not leave vehicle engines
idling unnecessarily during the construction period.

Following the implementation of the mitigation measures detailed in the tables above, the impact
significance of the construction phase is not considered to be significant.

With the adoption of all the simple measures listed above in the construction phases of the proposed
development, it is predicted that there will be no significant effects arising from dust on local sensitive
receptors.

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6. Dust Monitoring

6.1 Monitoring

PM10 monitoring is proposed at two locations at any one time, around the proposed development site in
order to quantify existing deposited dust flux and any demolition and construction phase dust emissions
from the site.

WYG will install an AQMESH particulate monitor at two locations. These will be moved during each phase of
the demolition and construction works to ensure dust levels at sensitive receptors closest to each phase’s
works are accounted for. The proposed locations of the AQMESH monitors for the demolition phase and
each construction phase are outlined in Table 6.1, and displayed in Figures 1 to 4.

Table 6.1 AQMESH Monitoring Locations

AQMESH Location 1 AQMESH Location 2

Phase
X Y X Y
Demolition & 1 523261 192446 523182 192490
2&3 523261 192446 523180 192671
3&4 523261 192446 523538 192520
4&5 523333 192438 523538 192520

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Figure 1 Demolition and Phase 1 AQMESH Monitor Locations

Figure 2 Phase 2 & 3 AQMESH Monitor Locations

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Figure 3 Phase 3 & 4 AQMESH Monitor Locations

Figure 4 Phase 4 & 5 AQMESH Monitor Locations

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The meter will take continuous readings of total suspended particulate (TSP), particulate with aerodynamic
diameter less than 10 microns (PM10), particulate with aerodynamic diameter less than 2.5 microns (PM 2.5)
and particulate with aerodynamic diameter less than 1 micron (PM 1). The monitor will capture and log 15
minute average readings of the particulate levels over the monitoring period. The results will be presented
with reference to both environmental and occupational (EH40) standards. Remote data downloads will be
undertaken on a weekly basis (or with greater frequency if required, and in the event of defined trigger
levels being exceeded) and reported monthly as requested. It will be possible for the LPA to remotely view
results on a password protected internet site at any time. The AQMESH monitors will be powered by battery
which has a 30 day life and will be topped up by solar power, thus removing the need to use local
generators.

6.2 Pollution Response Plan

An assessment using the traffic light approach based on the IAQM document ‘Guidance on Air Quality
Monitoring in the Vicinity of Demolition and Construction Sites’ (2014) is considered appropriate and is
proposed in Tables 6.3 and 6.4 below. Given the proximity of nearby receptors and the possibility for
exposure to PM10 the following criteria is proposed.

Table 6.3 Traffic Light Criteria for PM10 Monitoring

Maximum Permissible 15 minute
Alert level Time Period
average (µg/m3)
Red (at this level all works to cease
immediately, investigate cause of
15 minute average >250
exceedance and use alternative methods
where appropriate)
Amber (continual monitoring and
investigation of alternative methods Two consecutive 15 minute averages >80
where appropriate)
Green (early warning/no action required) 15 minute average >80

The below criteria have been adopted for PM2.5 levels at the boundary of the site.

Table 6.4 PM2.5 Level Criteria – Levels at Boundary

PM2.5 exceedance limits at

Monitoring Levels Time Period
monitoring locations
Red (at this level all works to cease
immediately, investigate cause of
15 minute average >48µg/m3
exceedance and use alternative
methods)
Amber (continual monitoring and
investigation of alternative methods Two consecutive 15 minute averages Between 48 µg/m3 and 40 µg/m3
where appropriate)
Green (no action required) 15 minute average <38 µg/m3

WYG will download the monitoring data from the AQMESH monitors daily, and report monthly. If there are

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any exceedances of the Red or Amber criteria for PM 10 and PM2.5, WYG will make the client aware of these
exceedances so that the client can review any onsite works which may be the cause of these exceedances
and mitigation options will be implemented. To ensure that any exceedances are solely from site operations,
the monitored data will also be compared with the closest London Air roadside, and urban background
monitoring stations, and weather conditions.

The council will be notified of any exceedances of the ‘red’ criteria.

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7. Conclusions

WYG have undertaken an assessment to discharge Pre-commencement Conditions 11 and 37, for the
proposed construction of 460 residential units over five periods of construction, at the former NIMR site, Mill
Hill, Barnet.

Prior to the implementation of appropriate mitigation measures, the potential impact significance of dust
emissions associated with the demolition and construction works of the proposed development has potential
as ‘high’ at some worst affected receptors without mitigation. However, appropriate site specific mitigation
measures have been recommended based on Appendix 7 of the City of London document ‘The Control Of
Dust And Emissions During Construction And Demolition’ SPG and are detailed in the above Dust
Management Plan. It is anticipated that with these appropriate mitigation measures in place, the risk of
adverse effects due to emissions from the demolition and construction works will not be significant.

Following the adoption of the recommended mitigation measures and PM10 monitoring conducted during the
demolition and construction phases, the development is not considered to be contrary to any of the national,
regional or local planning policies and therefore Pre-commencement Conditions 11 and 37 can be
discharged.

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