Subject: Re: EPR/FP3599LH/V014 We Need More Information About Your Application CRM:0240108
From: Stuart McNish <[email-masked]>
To: Jake Walker <[email-masked]>, "SM-Defra-RESP-notifications (DEFRA)" <[email-masked]>
Cc: daveg <[email-masked]>
Date: Thu, 23 Jul 2026 14:39:46 +0000

You don't often get email from [email-masked]. Learn why this is important<https://aka.ms/LearnAboutSenderIdentification>
Hi Jake,

Hope you are well

I think attached covers all your points

Have attached remittance advice again for the balance outstanding.

I'm on annual leave for 2 weeks from 3rd August returning on 17th so if you need anything when I am away Dave my colleague in copy can assist (ignore the business name as Dave is a director in the same group of companies (GRG) and has reviewed the documents.

I have updated the site plan labelling so attached also if you can use these please (nothing significant just clarifying area use)

  1.  With reference to the site plan, confirm where wastes would be stored before blending/mixing, and where would they be stored after the treatment (e.g. areas A10, A2). Please also confirm if these storage areas are either;

  *   new storage areas to the permit, or

  *   a proposed increase in capacity to existing storage areas; or

  *   existing storage areas with no proposed increase in capacity.

Wastes will be stored in bunded storage bays segregated by hazard prior to blending / mixing in accordance with HSG 71 as they are currently for transfer activities.

Residues from treatment I.e. Blended waste will be stored in storage bays based on it's primary hazard in accordance with HSG 71 and the storage bay layout. I.e. Bays A2-A8.

It's the existing storage bays we currently use onsite currently and there is no increase in storage capacity within this area of the site for any of the bays associated with this activity. The overall storage increase is in the lower yard repurposing storage areas that were associated with the activities we are removing from the permit as part of this variation.

  1.  Please confirm that all bulking and mixing will occur within the LEV cabinet. If any bulking and mixing occurs outside of the LEV cabinet, please describe this.

Updated within SOP-Waste Mixing and Blending V3 and associated Appendices. Have added some more detail in here on controls during operations that we have on the LEV operation currently

  1.  Provide a Risk Assessment that covers all considerations of risk for all new proposed activities (e.g. noise, dust, odour from the proposed new mixing and blending activity and any associated storage). Some of this information can be found across the application, but we require a standalone Risk Assessment covering all aspects.

Risk assessments for your environmental permit - GOV.UK<https://www.gov.uk/guidance/risk-assessments-for-your-environmental-permit>

     *   As part of the risk assessment, detail how the uncontaminated drainage water will be separated from the waste storage areas - This is included within the document you couldn't open - ''BKP-SO-Surface Water Management'' - Now attached - The file name path was too long

     *   As part of the risk assessment, detail any proposed changes to noise, e.g. new plant such as pumps, times of operation changing, etc - There is a reduction in noise from the facility across this variation - Removing some activities (Centrifugation & road sweeper recycling) which both have much larger pumps and motors. We will use the same pumps currently used in the cabinet for IBC washing for mixing / blending for example so only a noise reduction.

BKP-RA-PV-01- Permit Variation V14 Risk Assessment - That covers the changes

  1.  The document ‘[BKP-SO - Surface Water Management]’ was not able to be opened. Please resubmit this document.

Attached as word version - Sorry about that

  1.  The document ‘[BKP- BAT Assessment - Indirect Discharge to Land Activity vs BAT Conclusions]’ was blank when received. Please resubmit this document.

Sorry - The file name was too long again which is why it wouldn't open. I have had to rename as ''BKP-BAT Assessment - Soakway'' - Attached to this email

  1.  With regards to BAT conclusion 3, please provide information about the characteristics of the waste gas streams, from the abatement systems associated to the LEV container and the proposed new blending/mixing activity.

Attached - BKP-RA-SOP 18 - Mixing and Blending Emissions

  1.  Please confirm whether emissions to air from the abatement systems are expected to increase as a result of the proposed new activity.

     *   If emissions will not increase, please justify this, given the new activity; or

     *   If emissions will increase, please provide a risk assessment that covers the emissions to air. You can complete screening manually or by using the automated H1 screening tool.

Attached - BKP-RA-SOP 18 - Mixing and Blending Emissions. I have attached existing SOPs for the LEV cabinet also BKP-PCK-09-Pre-Treatment in Extracted Cabinet

  1.  Provide a Risk Assessment for the proposed emission to sewer. You can complete screening manually or by using the automated H1 screening tool.

Attached BKP-RA-Uncontaminated Surface Water to Foul Sewer

If you can confirm you have received ok please?

Kind regards
________________________________
From: Stuart McNish <[email-masked]>
Sent: 14 July 2026 14:03
To: Jake Walker <[email-masked]>
Subject: Re: EPR/FP3599LH/V014 We Need More Information About Your Application CRM:0240108

Hi Jake,

That's remittance advice for the payment. Apologies they've not put the reference on it but the confirmation is there.

We don't need a separate document for BAT 3. It's just trying to understand if there has been any characterisation or monitoring results for the emission point. Are other pollutants expected beyond VOCs?

We do monitoring on this emissions point 6 monthly inline with the current permit conditions. No pollutants expected other than VOCs and we have the BAT-AEL emissions limits for this which we comply with. No other pollutants expected but the carbon we use in the filter housing is 2 stage so there is some carbon impregnated with Calcium Hydroxide in 1 stage of the main filter housing as a precautionary measure and all emissions testing we have done has been within the limits defined currently in the permit.

Within the cabinet itself they use a carbon 205L drum for absorbing any displaced air from filling the IBCs with any waste. All receiving containers are dip filled. This is in addition to the carbon filtration unit on the extraction system to ensure compliance.

Drums / containers will be pumped out to minimise the release of pollutants.

Carbon is replaced periodically in-line with manufacturers recommendations on the main extraction system.

Hopefully that clarifies that point and is sufficient?

Will sort the yellows this week. Having a few issues remotely accessing our server at the moment but hopefully being fixed tomorrow

Kind regards

________________________________
From: Jake Walker <[email-masked]>
Sent: 13 July 2026 09:24
To: Stuart McNish <[email-masked]>
Subject: Re: EPR/FP3599LH/V014 We Need More Information About Your Application CRM:0240108

Hi Stuart,

Thanks for the prompt response.

On this point....

These will be the same as the empty containers we currently launder within the LEV booth and any high VOC materials we currently handle in here. Do you want a separate document covering BAT 3 for this activity? Let me know. We should be covered with the same emissions limits as current operation which we MCERTS test 6 monthly as part of the current permit.

We don't need a separate document for BAT 3. It's just trying to understand if there has been any characterisation or monitoring results for the emission point. Are other pollutants expected beyond VOCs?

Kind regards

Jake

________________________________
From: Stuart McNish <[email-masked]>
Sent: Friday, July 10, 2026 8:43 AM
To: SM-Defra-RESP-notifications (DEFRA) <[email-masked]>; Jake Walker <[email-masked]>
Subject: Re: EPR/FP3599LH/V014 We Need More Information About Your Application CRM:0240108

You don't often get email from [email-masked]. Learn why this is important<https://aka.ms/LearnAboutSenderIdentification>
Hi Jake,

  1.  Please confirm that all bulking and mixing will occur within the LEV cabinet. If any bulking and mixing occurs outside of the LEV cabinet, please describe this.

Yes mixing/blending within LEV Cabinet

Didn't answer this fully - I'll expand on this with a document Jake as easier as not all bulking happens within cabinet as per current set up I.e. Non-Hazardous, Non Odorous, non-flammable, Oil and water or antifreeze etc then it's clear in a document.

Will send across early next week with the other yellow pieces. Let me know if you are happy on my response to point 8 on the risk assessment too please when you get a minute

Kind regards

________________________________
From: Stuart McNish <[email-masked]>
Sent: 09 July 2026 16:06
To: SM-Defra-RESP-notifications (DEFRA) <[email-masked]>; [email-masked] <[email-masked]>
Subject: Re: EPR/FP3599LH/V014 We Need More Information About Your Application CRM:0240108

Hi Jake,

Thanks for your email. Sorry on those documents it's to do with file path being > 250 characters which I didn't appreciate when sending as I could open them.

  1.  With reference to the site plan, confirm where wastes would be stored before blending/mixing, and where would they be stored after the treatment (e.g. areas A10, A2). Please also confirm if these storage areas are either;

  *   new storage areas to the permit, or

  *   a proposed increase in capacity to existing storage areas; or

  *   existing storage areas with no proposed increase in capacity.

Wastes will be stored in bunded storage bays segregated by hazard prior to blending / mixing in accordance with HSG 71 as they are currently for transfer activities.

Residues from treatment I.e. Blended waste will be stored in storage bays based on it's primary hazard in accordance with HSG 71 and the storage bay layout. I.e. Bays A2-A8.

It's the existing storage bays we currently use onsite currently and there is no increase in storage capacity within this area of the site for any of the bays associated with this activity. The overall storage increase is in the lower yard repurposing storage areas that were associated with the activities we are removing from the permit as part of this variation.

  1.  Please confirm that all bulking and mixing will occur within the LEV cabinet. If any bulking and mixing occurs outside of the LEV cabinet, please describe this.

Yes mixing/blending within LEV Cabinet.

  1.  Provide a Risk Assessment that covers all considerations of risk for all new proposed activities (e.g. noise, dust, odour from the proposed new mixing and blending activity and any associated storage). Some of this information can be found across the application, but we require a standalone Risk Assessment covering all aspects.

Risk assessments for your environmental permit - GOV.UK<https://www.gov.uk/guidance/risk-assessments-for-your-environmental-permit>

     *   As part of the risk assessment, detail how the uncontaminated drainage water will be separated from the waste storage areas - This is included within the document you couldn't open - ''BKP-SO-Surface Water Management'' - Now attached - The file name path was too long

     *   As part of the risk assessment, detail any proposed changes to noise, e.g. new plant such as pumps, times of operation changing, etc - There is a reduction in noise from the facility across this variation - Removing some activities (Centrifugation & road sweeper recycling) which both have much larger pumps and motors. We will use the same pumps currently used in the cabinet for IBC washing for mixing / blending for example so only a noise reduction.

I will pull it together into one document and resubmit to you with the mixing / blending and soakaway as subheadings

  1.  The document ‘[BKP-SO - Surface Water Management]’ was not able to be opened. Please resubmit this document.

Attached as word and pdf version - Sorry about that

  1.  The document ‘[BKP- BAT Assessment - Indirect Discharge to Land Activity vs BAT Conclusions]’ was blank when received. Please resubmit this document.

Sorry - The file name was too long again which is why it wouldn't open. I have had to rename as ''BKP-BAT Assessment - Soakway'' - Attached to this email

  1.  With regards to BAT conclusion 3, please provide information about the characteristics of the waste gas streams, from the abatement systems associated to the LEV container and the proposed new blending/mixing activity.

These will be the same as the empty containers we currently launder within the LEV booth and any high VOC materials we currently handle in here. Do you want a separate document covering BAT 3 for this activity? Let me know. We should be covered with the same emissions limits as current operation which we MCERTS test 6 monthly as part of the current permit.

  1.  Please confirm whether emissions to air from the abatement systems are expected to increase as a result of the proposed new activity.

     *   If emissions will not increase, please justify this, given the new activity; or

     *   If emissions will increase, please provide a risk assessment that covers the emissions to air. You can complete screening manually or by using the automated H1 screening tool.

It's point a) above but I will put into the risk assessment document

  1.  Provide a Risk Assessment for the proposed emission to sewer. You can complete screening manually or by using the automated H1 screening tool.

Surface water pollution risk assessment for your environmental permit - GOV.UK<https://www.gov.uk/guidance/surface-water-pollution-risk-assessment-for-your-environmental-permit>

I don't have any pollutants to screen as it's uncontaminated surface water so the H1 screening doesn't work in my experience. I will just do a seperate risk assessment in the same format as the discharge to ground if you are happy that it's segregated uncontaminated surface water only and that is sufficient?

Kind regards

________________________________
From: SM-Defra-RESP-notifications (DEFRA) <[email-masked]>
Sent: 09 July 2026 14:12
To: Stuart McNish <[email-masked]>
Subject: EPR/FP3599LH/V014 We Need More Information About Your Application CRM:0240108

Dear Stuart McNish

Environmental Permitting (England and Wales) Regulations 2016

Application reference: EPR/FP3599LH/V014

Operator: BKP WASTE & RECYCLING LTD

Facility: BKP Hazardous Waste Transfer and Treatment Station EPR/FP3599LH, Bunny Lane, Timsbury, SO51 0PG

Thank you for your application received on 20/05/2026.

Payment

Unfortunately the application payment you sent is incorrect. The correct application charge is £40,223.54. This leaves a balance of £1,472.54 to pay. This is due to a 3.8% increase in our fees which came into place on April 1st 2026.

Pay online at this link www.gov.uk/payments/permitting-applications-installations/permitting-application-payment-installations<http://www.gov.uk/payments/permitting-applications-installations/permitting-application-payment-installations>

You need to create your own reference number. Your reference number must follow this format: PSCAPPINSTXXXXXYYY. It should include the first five letters of the company name (replacing the X’s in the above reference number) and a unique numerical identifier (replacing the Y’s in the above reference number). Email us the reference number and the payment date so we can track your payment.

Information Required

We need to ask you for some missing information before we can do any more work on your application. Please provide us with more information to the following questions:

  1.  With reference to the site plan, confirm where wastes would be stored before blending/mixing, and where would they be stored after the treatment (e.g. areas A10, A2). Please also confirm if these storage areas are either;

  *   new storage areas to the permit, or

  *   a proposed increase in capacity to existing storage areas; or

  *   existing storage areas with no proposed increase in capacity.

  1.  Please confirm that all bulking and mixing will occur within the LEV cabinet. If any bulking and mixing occurs outside of the LEV cabinet, please describe this.

  2.  Provide a Risk Assessment that covers all considerations of risk for all new proposed activities (e.g. noise, dust, odour from the proposed new mixing and blending activity and any associated storage). Some of this information can be found across the application, but we require a standalone Risk Assessment covering all aspects.

Risk assessments for your environmental permit - GOV.UK<https://www.gov.uk/guidance/risk-assessments-for-your-environmental-permit>

     *   As part of the risk assessment, detail how the uncontaminated drainage water will be separated from the waste storage areas.

     *   As part of the risk assessment, detail any proposed changes to noise, e.g. new plant such as pumps, times of operation changing, etc.

  3.  The document ‘[BKP-SO - Surface Water Management]’ was not able to be opened. Please resubmit this document.

  4.  The document ‘[BKP- BAT Assessment - Indirect Discharge to Land Activity vs BAT Conclusions]’ was blank when received. Please resubmit this document.

  5.  With regards to BAT conclusion 3, please provide information about the characteristics of the waste gas streams, from the abatement systems associated to the LEV container and the proposed new blending/mixing activity.

  6.  Please confirm whether emissions to air from the abatement systems are expected to increase as a result of the proposed new activity.

     *   If emissions will not increase, please justify this, given the new activity; or

     *   If emissions will increase, please provide a risk assessment that covers the emissions to air. You can complete screening manually or by using the automated H1 screening tool.

  7.  Provide a Risk Assessment for the proposed emission to sewer. You can complete screening manually or by using the automated H1 screening tool.

Surface water pollution risk assessment for your environmental permit - GOV.UK<https://www.gov.uk/guidance/surface-water-pollution-risk-assessment-for-your-environmental-permit>

H1 Risk Assessment Tool

The H1 risk assessment tool<https://admlc.com/h1-tool/> and the guidance on how to use it is hosted on the Atmospheric Dispersion Modelling Liaison Committee (ADMLC) website on behalf of the UK environmental regulators.

If you do not want to use this tool you can:

  *   follow the steps in the risk assessment guides

  *   use other resources such as emission modelling software – you may be charged for this

Please reply directly to this email with your information and copy in [email-masked]<mailto:[email-masked]>.

You must send us the information and or payment by 24/07/2026.

If we do not receive this by this deadline we will return your application.

If we receive what is missing by the deadline, we will continue to check your application. We’ll check to see if there’s enough information for the application to be ‘duly made’. Duly made means that we have all the information we need to begin determination. Determination is where we assess your application and decide if we can allow what you’ve asked for.

We’ll let you know by email whether your application can be duly made. If it can’t be duly made, we’ll return your application to you.

If we do have to return your application we’ll send you a partial refund of your application payment. We’ll retain 20% of the correct application charge to cover our costs in reviewing your application. This maximum amount we’ll retain is capped at £1,673.78. Further information on charging can be found at: https://www.gov.uk/government/publications/environmental-permits-and-abstraction-licences-tables-of-charges

Note: Our email system has a file size limit of 25MB, if your returns exceed this limit you will have to arrange an online file transfer. Please ensure the file transfer link does not have a time limit on it.
If you have any questions please phone me on 02084 748197 or email [email-masked].

Yours sincerely,
Jake Walker

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