ADBA PERMITTING WORKSHOP27 March 2013Stephen Barnes, Technical Director, Wardell Armstrong
Introduction
• Regulatory Background
• Exemptions
• Standard Rules Environmental Permits
• Bespoke Environmental Permits
• Fees and timescales.
Regulatory Background
• Environmental Permit required to deposit, treat, keep and dispose of waste (unless lawfully exempt)
• Environmental Permitting (England and Wales) Regulations 2010o Schedule 1 includes AD plants that treat >10 tonnes per day of
animal carcasses or animal waste (up to 6 April 2012 gas engines with a net rated thermal input ≥3MW also fell under Schedule1)
o Schedule 3 lists exempt activities, which includes small scale AD plants
o Schedule 9 list waste operations, which includes those AD plants that do not fall under exemption or Schedule 1.
Regulatory Background
• Environmental Permitting (England and Wales) (Amendment) Regulations 2013 implement the Industrial Emissions Directive (IED)
• Sites that fall under the IED also fall under Schedule 1, however there are phase-in dates
• Implementation of IED, from: o 7 January 2013 - at new sites that fall under the Directiveo 7 January 2014 – at existing Schedule 1 sites that fall under the
Directiveo 7 July 2015 – at existing sites (not previously Schedule 1) that fall
under the Directive
Regulatory Background
• The AD of non hazardous waste at a site with a capacity ≥100 tonnes per day falls under the IED and therefore Schedule 1
• Schedule 1 activities subject to additional permitting requirements, Best Available Techniques, Energy Assessment, Raw Materials Assessment
• Existing sites that fall under the IED will require a variation of the Environmental Permit (possibly an Environment Agency administrative variation, otherwise an application by the Operator).
Regulatory Background
Schedule 9Other AD Waste Activities
not falling underSchedules 1 and 3
Schedule 1AD≥100 tonnes per dayAD > 10 tonnes per day of
animal waste≥ 50MW (Part A)≥ 20MW - <50MW (Part B)
Schedule 3T24T25U10U11
Environmental Permit Exemption
Environmental Permitting (England and Wales) Regulations 2010, as amended
Exemptions
• Register exemption, renewal required every 3 years
• Exemptions for on farm AD (T24), off farm AD (T25) and spreading digestate on land (U10 & U11)
• Comparatively small schemes only (gas engines with a net rated thermal input less than 0.4MW)
• Maximum waste storage and treatment at any one time: on farm AD - 1,250m³; off farm AD 50m³
• Spread digestate on land to confer benefit - up to 50 tonnes per hectare in any 12 months period
• Exempt activity must not cause pollution, harm or nuisance.
Exemptions
Cockle Park Farm, photo courtesy of Newcastle University
Exemptions
• Small scale activities, e.g. Cockle Park Farm
o University of Newcastle upon Tyne
o 350kWe
o Gas to a boiler for heat production
o Heat supplied to farm buildings
o Plant installed by Marches Biogas
Environmental Permits
Environmental Permits
Standard Rules
Schedule 1
Bespoke
Schedule 9 Schedule 1(Subject to BAT etc)
Schedule 9
On-farm InstallationOff-farm Installation
On-farm waste OperationOff-farm waste operation
Standard Rules Environmental Permit
• New Standard Rules permits published in January 2013 (SR2012 No 09, SR2012 No 10, SR2012 No 11 and SR2012 No 12)
• Replace previous Standard Rules permits SR2010 No 15 (off-farm AD) and SR2010 No 16 (on-farm AD)
• SR2010 No 15 (off-farm AD) and SR2010 No 16 (on-farm AD) are no longer available for new sites
• Existing sites under Standard Rules permits for AD will be phased-in to the new Standard Rules
• Phase-in details to be finalised by the Environment Agency.
Standard Rules Environmental Permit
• Generic criteria for Standard Rules permits (SR2012 No 09, SR2012 No 10, SR2012 No 11 and SR2012 No 12)
o Not within 10m of any watercourse
o Not within 50m of any well, spring or borehole used to supply water for human consumption
o Not within a Groundwater Protection Zone 1
o Not within a specified Air Quality Management Area
• Gas engine emission limits (NOx = 500mg/m3, CO = 1,400mg/m3,
SO2 = 500mg/m3, total volatile organic compounds = 1,000mg/m3.
• No emission limits for boilers, back up flares, pressure relief valves.
Standard Rules Environmental Permit
• Specific criteria for Standard Rules permit SR2012 No 09, on-farm installation
o Not within 500m of a European Site or SSSI (excluding geological SSSI)
o Minimum stack height of 3m
o Not within 200m of a sensitive receptor unless the stack height is at least 7m or the effective stack height is at least 3m
o AD capacity over 100 tonnes per day
o Up to 100,000 tonnes per annum of farm waste only (or a combination of farm waste & non waste)
o Net rated thermal input of gas engines <5MW
o Permit includes physical pre-treatment of wastes, gas drying cleaning & storage & upgrade to biomethane).
Standard Rules Environmental Permit
• Specific criteria for Standard Rules permit SR2012 No 10, on-farm waste operation
o Not within 200m of a European Site or SSSI (excluding geological SSSI)
o Minimum stack height of 3m
o Not within 200m of a sensitive receptor unless the stack height is at least 7m or the effective stack height is at least 3m
o Farm waste (or a combination of farm waste & non waste) only
o AD capacity less than 100 tonnes per day (therefore < 36,500 tpa)
o Permit includes physical pre-treatment of wastes, gas drying cleaning & storage & upgrade to biomethane).
Standard Rules Environmental Permit
• Specific criteria for Standard Rules permit SR2012 No 11, off-farm installation
o Not within 500m of a European Site or SSSI (excluding geological SSSI)
o Not within 200m of a sensitive receptor
o Minimum stack height of 3m
o AD capacity over 100 tonnes per day
o Up to 100,000 tonnes per annum (includes a much wider range of wastes than on-farm Standard Rules permits)
o Net rated thermal input of gas engines <5MW
o Permit includes physical pre-treatment of wastes, gas drying cleaning & storage & upgrade to biomethane).
Standard Rules Environmental Permit
• Specific criteria for Standard Rules permit SR2012 No 12, off-farm waste operation
o Not within 200m of a European Site or SSSI (excluding geological SSSI)
o Not within 200m of a sensitive receptor
o Minimum stack height of 3m
o AD capacity less than 100 tonnes per day (therefore < 36,500 tpa)
o No more than 10 tonnes per day of animal waste
o Permit includes physical pre-treatment of wastes, gas drying cleaning & storage & upgrade to biomethane).
Bespoke Environmental Permits
Reliance Street, photo courtesy of Viridor Laing
Bespoke Environmental Permits
• Sites that do not fall under exemption or Standard Rules
• Detailed application, including quantification of all emissions (H1)
• Air dispersion modelling may be required in some cases
• Use of Best Available Techniques for certain activities (known as Schedule
1)
• Risk based assessment to determine application fee (EPR OPRA)
Bespoke Environmental Permits
Westry AD Facility, photo courtesy of Local Generation Limited
Timescales and Costs
• Exemptionso Complete form and submit to Environment Agencyo Environment Agency should register exemption within 5 working dayso Registration is free
• Standard Rules Environmental Permit
o AD waste operations - £1,590 application fee (on-farm & off-farm) and annual subsistence fees of £1,540 (on-farm) or £2,420 (off-farm)
o AD installations - £1,900 application fee (on-farm & off-farm) and annual subsistence fees of £1,990 (on-farm) or £3,330 (off-farm)
o Environment Agency has 13 weeks to determine application once Duly Made (should take less) • Bespoke Environmental Permit
o Application fee based on EPR OPRA (experience of AD indicates at least £7,000)o Annual subsistence fees based on either EPR OPRA or fees and charges schemeo Environment Agency has 13 weeks to determine application once Duly Made