What they do
H+H Celcon produce aircrete products to the construction industry. The factory in this area opened in 1992. The manufacturing process is based on PFA, pulverised fuel ash. In the KCC Kent Minerals & Waste Local Plan Examinations Library, H+H had in 2015 submitted 3 Reports, advising on their wish to re-allocate the Site 50, to convert the AONB fields on the Western Side for a Silica Sand Quarry. The reason that has been submitted so far for this potential quarry, is that with the closure of coal-fired power stations, there will be less PFA (pulverised fuel ash) to acquire (which at present, is being currently sourced from the East Midlands) and the only altnerative to PFA is Silica Sand to be the main raw material. H+H Celcon have advised that without this conversion to Silica Sand (with also an upgraded factory costing around £10 million), the factory cannot operate beyond 2020 and will have to shut down which will cause the loss of 120 "local" jobs.
H+H Celcon also advised in their submission that Wrotham Quarry if extended (it has been given planning permission for the extension in 2015) will offer Silica Sand up till 2025 (Submission 1; Rep 127, Statement 2); Nepicar Quarry will offer another 10 years of such a resource. Therefore, H+H Celcon state they will need its own steady supply of Silica Sand at an annual requirement of 175,000-200,000 tpa totalling 2.6-3.0 million tonnes.
celcon's track record
contaminating the land
- Contaminated AONB Land to the Northern area of the Western AONB Fields
During H+H Celcon's Planning Application period in 2006, it came to pass from an investigation conducted by Southern Testing Ltd, that under the approved restorative scheme for backfilling the old quarry, no records could be found on the type of materials tipped at the Northern site, under the Site Licence. On further investigations, between the infilling time of 1991-2002, identification of unauthorised noxious fill materials, hydrocarbon stained and odorous sandy clayey substances including large quanitites of metal, pipework, occasional drums, polythene and concrete were found still present in 2006. Material of this nature usually contain elevated concentrations of contaminants. The Environmental Agency in its response considered the potential to cause groundwater contamination to be high.
- Why has there not been any remediation scheme completed to date?
- If non-fulfillment of the restorative licence had been committed, why had nothing been done and why hadn't KCC acted on this evidence?
- Does this instil confidence?
delisting field from register of historic parks and gardens
- H+H Celcon Submission to the Kent Minerals Waste Local Plan in March 2015, Examinsations Library, in preparation to the adoption of July 2016 (Submission 3; Rep 127, Statement 3)
Celcon advised prior to the delisting of one of the AONB fields next to Ightham Court Grade II*, that
"....that H+H, with the support of Ightham Parish Council, have made representations to English Heritage to remove that part of the Historic Park and Garden that extends beyond Ightham Court on the north part of Site 50. English Heritage have conducted a site investigation and are currently preparing a report for determination which we expect to be sympathetic to our request to have the designation lifted..."
- How could H+H know in advance that they expect the report to be sympathetic?
- Another question, is there evidence that H+H got support from Ightham Parish Council?
PFA - present storage and dust emission concerns
- H+H factory - dust complaints have been logged
For those residents who live near the Eastern side of H+H Celcon factory, they have been plagued by dust particles every day. The dust settles on everything; they have to wipe down garden furniture every day, their cars are covered every day and they cannot hang out their washing because of the dust settling on their clean items. Complaints have been logged with Tonbridge & Malling Borough Council (TMBC) for years since H+H Celcon opened the factory in 1992. Kent County Council (KCC) have been made aware of the dust complaints too.
The Borough Council's responsibilities lie essentially with the enforcement of the Environmental Permit issued under the Environmental Permitting (England and Wales) Regulations 10. The Permit in relation to H+H was issued as a direct requirement of Schedule 1 Section 3.1. Part B(b) of the 2010 Regulations which relates to the blending of cement in bulk for the purposes of the manufacture of concrete blocks. The Borough Council's other responsibility lies with the assessment of Statutory Nuisance which can include the assessment of dust nuisance arising from a commercial site. Apparently, TMBC advise that they have only a limited history of complaints from local residents totalling 3 since 2000, all of which are from one residential address. Although dust/grit was noted "no statutory nuisance was substantiated". TMBC also have advised that if further complaints of dust is to be received, then the matter would be investigated.
Notification by 6 local Parishes have informed TMBC that there is an issue of dust nuisance, one of the Councillors has been in contact with TMBC over this issue for years. The entire area of the factory site is coated with grey slurry and dust. Dust blows everywhere, it cannot be easily contained.
Because of heavy vehicle traffic within Borough Green, regular testing of air quality management has been recognised. The testing was triggered by excessive NO2 (Nitrogen Dioxide). However, it is not legal to allow processes that impact on AQMA. What is this present dust experienced by residents?
- Why hasn't anything been done to date to assess the dust nuisance?
- Why aren't any complaints being taken seriously by TMBC?
- What is the components of this dust and if it is released into the air what is the outcome when it combines with the AQMA (Air Quality Management Area)?
H+H Celcon and PFA - Crisis 1
PFA is stored within the factory's site. It is stored out in the open. Complaints have been raised by residents of the open storage as well as the Members of the 6 Parish Alliance Group.
On questioning TMBC over the open storage of PFA and its health risks, it has come to pass the there has been a violation of H+H's PFA handling Permit. The Environmental Permit under the 2010 Regulations states a condition that PFA, when delivered to site, should be suitably stored in the ash pit prior to use in the process. KCC have inspected the site and it was identified that some PFA is also now stored in an external bay in the yard area. (Apparently this is due to the fact that recent supplies have come from locations much further away than previous sources and the external supply has a rapid turnaroud.) TMBC are currently in discussion with H+H concerning this matter and the likely amendment of the relevant Permit condition, is to allow some controlled external storage of PFA on the basis that H+H follow 3 controls, namely,
"1. The control of PFA is ancillary to the actual need for the Permit which relates to the control and blending of cement;
2. The PFA will continue to be received at site in an already dampened down state; and
3. External storage will remain in an appropriate bay to reduce the likelihood of ‘wind whipping’."
TMBC advise that there are no known health risks associated with the external storage of PFA in the UK. A bold statement. (See link to new research on "Ash in the Lungs: How breathing Coal Ash is Hazardous to your Health") Coal-fired stations which produce PFA are normally erected in remote areas where wind-blown dust does not impact on the public. PFA contains a mix of particle sizes, and the smaller particles cause a health hazard even when the parent mineral is inert.
- H+H are in breach of their conditions; why is the Permit being amended to pacify the breach?
- It is illegal to store PFA in the open; why aren't the necessary procedures being followed when a breach has been committed?
- Why is there no consultation process being addressed and a new planning permission initiated?
- Wind will dry out any open storage; open storage needs to be sheeted or kept damp at ALL times; what is meant by "in an already dampened down state (control no.2 above)?
- If new open storage is to be permitted, why hasn't there been any data collated first by Environmental Health and Planning before such permit is even being attempted at being granted, to ensure its safety first and foremost to the Public?
H+H Celcon and PFA - Crisis 2
H+H Celcon are to produce exceptional circumstances why a proposed quarry is essential to their factory future. Their subsmissions so far have "pleaded" the need to convert the heavily depleting supply of PFA into silica sand as an alternative. In a letter dated 29 March 2017 addressed to the Members of the 6 Parish Alliance Group by Crispin Kennard of TMBC, he states,
"Although the PFA is becoming harder to source locally, there is still sufficient supply for Celcon’s needs for the foreseeable future, meaning that the use of the fine ground sand you mention is not required."
- Exceptional circumstances for a proposed silica sand quarry...?
silica sand quality
- H+H Submission to KMWLP Exminations Library (Submission 2; Rep 127, Statement 1)
In relation to geological terms, the area around Maidstone, Wrotham and Ightham are known to be part of the Folkestone Beds. The Folkestone Beds formation is a marine shallow-water deposit of the Cretaceous age.
In the Quarterly journal of Engineering Geology and Hydrogeology, The Lyell Collection
The Folkestone Bed Sands: Microfabric and Strength article states that the consistency is "mostly of poorly lithified sands which classify onto the sand/sandstone borderline, having properties neither akin to the classical concept of an engineering soil nor being strong enough to be labelled a rock. Intact samples were obtained by block sampling at 17 locations. Studies of the microfabric were made from thin sections prepared after epoxy resin impregnation. Although predominantly quartzose, the samples have a very wide range of grain sizes, size distributions, porosity and grain contact relations. The random inter-relationships amongst the microfabric parameters suggest that shelf sands, such as this formation, do not fit the patterns reported for deeply buried, and hence more diagenetically altered, sandstones.
The majority are weakly cemented but samples from two locations possess negligible binding cement and are classed as locked sands. Measurements of the peak shear strength were carried out on air-dry samples of the intact sand using a 60 mm square, direct shear box. The peak shear strengths were strongly influenced by the intensity of interlocking: this factor being more significant than either porosity or total cement content. The samples possess a tensile strength, uniaxial compressive strengths up to 725 kPa and a cohesion intercept at zero normal stress in the shear box. The fabric cohesion reduces with increasing content of coarse sand and is very poorly developed in coarse sands."
On the KCC website, under Safeguarding Individual Land-won Minerals section 3.2.2 it states that "Silica sand is quarried from the same geological formation as the soft sand deposits situated on the Folkestone Beds. All seven quarries on the Kent part of the Folkestone Beds produce a combination of soft sand (building sand) and specialist industrial sand, in varying proportions. There are no sites in Kent which only supply silica (or specialist) sand. However, three quarries produce predominantly silica sand (industrial sand) and these are considered as silica sand quarries in the Kent Minerals and Waste Local Plan Annual Monitoring Reports. The three silica sand quarries in Kent are Addington (Wrotham Sand Pit), Aylesford Sand Pit and Nepicar Farm. Kent does not produce the highest grade of silica sand used in the chemical, glass or ceramic industries, although historically glass sand has been produced in a number of locations in Kent."
In a leaked press release last year to Kent Live News, The Chronicle, it was stated by Martin Cavalier of the Borough Green Gardens Consortium, ( H+H Celcon being one of them) on the issue of a potential Relief Road running alongside this potential quarry next to the existing factory,
"The use of this previously developed poor quality land currently used for landfill and mineral extraction would protect high quality Green Belt elsewhere in the borough and deliver the relief road that the people of Borough Green have been campaigning for"
This statement suggests that the whole area produces poor quality mineral extraction.
- What proof is there that the western side of H+H's proposed quarry will produce the necessary sand quality to replace the PFA in making airecrete blocks?
- If the quality is poor, then other ingredients will be needed in order to refine the quality; this will create further HGV traffic to the site to bring in the necessary ingredients for refining.
...PEACE OF MIND?