This is the Schedule 5 document sent by Natural Resources Wales (NRW) to Biomass UK. The document identifies many shortcomings in Biomass’s application for a permit to operate their incinerator. Biomass must comply with the Schedule 5 in order that their application can be considered.
At a recent meeting with NRW, the Docks Incinerator Action Group (DIAG) were able to voice a number of concerns on behalf of the residents of Barry, which have been considered by NRW. Several of these concerns were added to the Schedule 5 document to Biomass.
DIAG spokesman Alexis Liosatos said “We thank NRW for agreeing to meet us and for listening to our concerns. The consultation period is still open so people with questions or complaints about the incinerator should write in to NRW. Your input can make a difference. Please visit www.beautifulbarry.co.uk for details of how to write to NRW. DIAG would also like to thank Jane Hutt for facilitating and chairing this constructive and informative meeting with NRW.”
Noise modelling and impact assessment
The noise impact assessment is described in the following reports:
- Barry Biomass Energy Plant Barry. Noise Assessment (received by NRW on 25th October 2016); and
- Barry Biomass Energy Plant Barry. Noise Assessment (received by NRW on 8th March 2017).
In NRW’s opinion these assessments do not:
- Confirm the exact nature, location and specification of all noise sources included in the impact assessment;
- Include valid justification for exclusion of any potential noise sources from the impact assessment (including those listed in the noise impact assessment reports but having no associated power level spectra data);
- Make clear – where internal noise sources have been used in building reverberant sound level calculations used in the impact assessment modelling – which sources have been included. Where any potential contributing sources have been excluded, the reports do not provide justification for this; and
- Include details of all building material specifications as they relate to sound absorption/noise reduction.
The assessments also do not:
- Provide details of the methodology used to complete the survey of background noise levels. Only the results obtained from the survey are included; and
- Include a complete BS4142:2014 ‘Methods for rating and assessing industrial and commercial sound’ assessment of the impact of the proposed installation on local receptors.
Please therefore submit a full and complete noise impact assessment which considers suitable receptor locations likely to be impacted by the proposed installation. This assessment should address all the points raised in the following paragraphs.
Final confirmation of the sound reduction properties of all cladding materials used in the construction should be provided and, if different from those stated in previously submitted noise impact assessment reports referenced above, confirm that the reverberant noise calculations of the building elements included in the modelling and hence noise emissions to the surrounding environment are based on these final material specifications. In addition, confirmation of all final plant specifications as they relate to noise should be provided including confirmation of what plant has been used in reverberant noise calculations and the justification for any omissions, whether contributing to reverberant noise or as discrete external noise sources:
- Details of the methodology used to complete the survey of background noise levels which enabled the calculation of the results given in Table 3.1 of the Noise Assessment report received by NRW on 8th March 2017. And justification as to why the background survey data is still valid if it was not completed recently;
- Location of louvres and roller shutter doors on both the Boiler House and Steam Turbine building, as these are not indicated on any of the plans submitted;
- Details of the sound reduction index spectra for the louvres and roller shutter doors on the Boiler House and Steam Turbine building. Clarification of how or if these elements have been considered in the calculation of the combined sound power levels for the building facades;
- Drawing ‘Barry_01_DWG_01_20100’ appears to show internal conveyors at the North West end of the reception building (the conveyors are unlabelled), however, there is no indication of any noise source associated with this area within the submitted modelling QSI format file or Noise Assessment reports. Please confirm the specifications of any noise producing plant or activities within the reception building and, if present, provide justification as to why these noise sources have been excluded from consideration in the Noise Assessment reports;
- While indicated as a noise source, the fuel chip conveyor between the Reception Hall and main process building does not appear to have been included in the supplied modelling and no spectrum is included in the Noise Assessment reports. Please provide justification as to why this noise source has been excluded from consideration in the Noise Assessment reports;
- It is not clear from the Drawing ‘Barry_01_DWG_01_20100’ whether fuel material is delivered from the Reception Hall to the fuel chip conveyor via an external covered conveyor along the South West façade of the building or directly via the South East façade of the building. Transfer of wood chip from the Reception Hall to the fuel chip conveyor has not been included as a noise source in the Noise Assessment. Please clarify the method for transferring wood chip to fuel chip conveyor and provide justification for excluding this as a possible external noise source;
- Sound power spectra for Turbine bypass and de-superheater and Firewater pumps are not included in the steam turbine sources listed in Appendix B of the Noise Assessment reports. Please provide justification as to why these have been excluded from consideration in the Noise Assessment reports;
- Items labelled 08 and 10 on Drawing ‘Barry_01_DWG_01_20100’ indicate the presence of air blast coolers with an associated diesel generator immediately adjacent to the North East wall of the main process building. However, these items have not be included as exterior noise sources in the submitted modelling QSI format file or Noise Assessment reports. Please provide justification as to why these have been excluded from consideration in the submitted Noise Assessment reports;
- No details regarding the estimated frequency of fuel material delivery have been provided in the noise impact assessment report, within the daily operating hours. Please ensure that the correct delivery frequency and range of daily operating hours are included as parameters in the noise model. Please provide justification as to why noise sources associated with fuel deliveries by HGV traffic on site and any mechanical shovel loading operations within the Reception Building have been excluded from consideration in the submitted Noise Assessment reports; and
- A complete assessment of the impact of the proposed installation on local sensitive receptors that takes into account the above points and follows the methodology set out in BS4142:2014 ‘Methods for rating and assessing industrial and commercial sound.’
Planning permission granted by Vale of Glamorgan Council (ref. 2015/00031/OUT)
Condition 22 of the associated planning permission for the proposed installation states that the ‘total tonnage of wood waste treated at the plant hereby approved shall not exceed 72,000 dry tonnes per annum.’ However, the report entitled ‘EPR Permit Application. Biomass UK No2. Ltd. Barry Energy Production Facility’ states that ‘The installation has been designed to process approximately 86,400 tonnes of pre-processed non-hazardous mixed waste wood per annum.’ Please provide justification for the discrepancy in these figures.
Condition 24 of the associated planning permission for the proposed installation states that ‘Deliveries to the site … shall be restricted to the following hours: – Monday to Saturday: 07:00 – 19:00; and Sunday /Bank/Public holidays 08:00 – 16:00.’ However, the report entitled ‘EPR Permit Application. Biomass UK No2. Ltd. Barry Energy Production Facility’ states, in Section 3.5, that waste deliveries will take place Monday to Friday between the hours 8.00am to 5.30pm, and in section 3.17 states that ‘deliveries, loading and unloading operations generally (but not restricted to) being carried out … Monday to Friday (between the hours of) 7.00 to 19.00.’ Please provide accurate details of the hours during which deliveries of waste wood will be accepted.
Emissions to air modelling and impact assessment
As the proposed installation is located close to the coast, the potential coastal effects on plume dispersion inland under some meteorological conditions and its potential impact on relevant sensitive receptors should be considered in the modelling risk assessment. Due to the unique topography around the proposed installation (especially at Dock View Road and surrounding areas), more information (i.e. a higher confidence level) on the possible impact of terrain on dispersion of airborne emissions at relevant sensitive receptors is also required: this can be achieved initially through comparison with predictions from a different appropriate model. Please carry out additional assessment of the impact of airborne emissions from the proposed installation that takes into account these effects on local sensitive receptors. The revised impact assessment should follow the rule of thumb on modelling grid resolution; namely 1.5 times the height of the stack to capture elevated concentration in terms of the predicted maximum ground-level concentration in the modelling domain.
In relation to the corrected surface roughness factors referred to in the revised air impact assessment report (entitled Air Quality Assessment, received by NRW on 8th March 2017), please provide the AERMET modelling files relating to this.
In relation to the revised air impact assessment report. The NOx and SO2 emission concentrations when the proposed installation is operating in abnormal conditions (specifically, during periods of failure of the urea injection and lime dosing abatement systems, respectively) is stated to be lower than the short-term emission limit values (ELV) for NO2 and SO2 given in Annex VI of the Industrial Emissions Directive (IED). The justification given in the revised air impact report indicates that this is because the IED ELVs are conservative for this process and have been used as a worst-case scenario, and the short-term NOx and SO2 emissions during abnormal operation are expected to be below the respective IED ELVs. As the IED short-term NO2 and SO2 ELVs have been used in the risk assessment for normal operation, please explain why the NOx and SO2 emission concentration will be lower during abnormal operation when the urea injection and lime dosing abatement systems are in failure. Please provide evidence or valid justification for the NOx and SO2 emission concentrations used in Table C2 on page 46 of the revised air impact assessment report.
The air impact assessment must take into account all emission sources within the installation boundary. Table 3.4 of the report entitled ‘EPR Permit Application. Biomass UK No2. Ltd. Barry Energy Production Facility’ states that diesel will be used to power start-up generators and the mechanical loading shovel. Items labelled 08 and 10 on Drawing ‘Barry_01_DWG_01_20100’ indicate the presence of air blast coolers with an associated diesel generator immediately adjacent to the North East wall of the main process building. The ‘EPR Permit Application. Biomass UK No2. Ltd. Barry Energy Production Facility’ report also indicates that there will be a number of on-site vehicle movements each day. Please consider these emission sources (and any others which will occur within the installation boundary and which have not already been considered) and carry out additional risk assessment for these sources, if required. If the impact from these sources is considered to be insignificance, please provide justification for this assumption.
Please submit a revised Air Impact Assessment report that incorporates all of the above requests for clarification and additional information.
Role of the operator
Please clarify the role of ‘Power Consulting Midlands’ in the operation of the plant.
Please demonstrate that Biomass UK No. 2 Ltd. will have control of the installation using the guidance given in the Environment Agency document ‘RGN 1: Understanding the Meaning of Operator.’
Energy Efficiency Directive
The net rated thermal input of the plant is greater than 20MWth and therefore the installation falls within the scope of Article 14 of the Energy Efficiency Directive (EED). EED requires that a cost benefit analysis (CBA) is carried out for such plant to demonstrate whether or not the installation should be operated as a highefficiency cogeneration installation. If there are no existing or potential heat loads within 15km that it is technically feasible to supply a CBA is not required.
Section 6.4 of the report entitled ‘EPR Permit Application Support Document’ states that:
“The plant has been configured to maximise power generation only and has not been configured for CHP mode operation at this time. The turbine has the capacity to be modified to operate in a CHP mode and steam could be diverted to heat exchangers if required (CHP-ready), however the likely operating mode will be power only.
At present there are no immediate high value heat neighbours which provide an economically viable heat export opportunity. Therefore, a CHP-R assessment is not considered necessary.”
Please provide more detail on the assessment that has been carried out to justify these statements. Please demonstrate that you have considered whether there are any existing or potential heat loads within 15km of the proposed installation, and, if there are, please demonstrate whether or not it is technically feasible to supply heat to these facilities.
Efficient use of energy within the proposed installation
Section 6.3 of the report entitled ‘Biomass UK No. 2 Ltd. Barry Energy Production Facility’ states that:
- “the Installation uses high efficiency electrical generation technology (i.e. steam turbine). The proposed process will achieve 1.075 MWe per tonne of material processed; and
- The overall energy efficiency of the plant, even when in open cycle when taking account of ancillary uses, has been designed to achieve 27.1% efficiency, which compares well with the 25% efficiency target for incinerators.”
Please provide details of the methodology and calculation used to obtain the figures quoted above.
Please also provide the electrical demand of the plant per tonne of waste (based on the lower / net calorific value of the waste) in terms of comparison to the descriptions of BAT for energy recovery given in the Waste Incineration Best Available Techniques Reference (BRef) document and EPR 5.01 ‘The Incineration of Waste’ (i.e. the BRef says that where a plant generates electricity only, it is BAT to recover 0.4 – 0.65 MWh/ tonne of waste (based on LCV of 10.4 MJ/kg). EPR S5.01 states that where electricity only is generated, 5-9 MW of electricity should be recoverable per 100,000 tonnes/annum of waste (which equates to 0.4 – 0.72 MWh/tonne of waste)).
Waste pre-acceptance (ref. BUK-E01)
Section 1.4 of the ‘waste pre-acceptance’ document appears to have a missing sentence. Please amend and re-submit this page.
Off-site waste transfers
Table 1 of the document entitled ‘Off site waste transfers (ref. BUK-E04)’ contains additional waste types to those listed in a similar table (Table 4.10) in the ‘Biomass UK No. 2 Ltd. Barry Energy Production Facility’ report. Please revise and re-submit the ‘Biomass UK No. 2 Ltd. Barry Energy Production Facility’ report to include these additional waste types.
Waste types to be accepted
Table 3.3 of the report entitled ‘Biomass UK No. 2 Ltd. Barry Energy Production Facility’ lists the wastes that will be accepted at the proposed installation. This list includes the following waste code:
’17 02 01. Paper and cardboard; would be typically used for any general nonhazardous wood emanating from building/construction sites.’
Technical Guidance WM3 ‘Guidance on the classification and assessment of waste (1st edition 2015)’ (WM3) describes this waste code as:
17 CONSTRUCTION AND DEMOLITION WASTES (INCLUDING EXCAVATED SOIL FROM CONTAMINATED SITES)
17 02 Wood, glass and plastic 17 02
Please clarify what is meant by the submitted description of this waste code in the context of the description given in WM3, as this description suggests that it is the intention to accept wastes other than waste wood (i.e. paper and cardboard).
References to the physical state of the waste wood that will be accepted at the site vary though out the application documents. For example, the report entitled ‘Biomass UK No. 2 Ltd. Barry Energy Production Facility’ states in the Non Technical Summary that waste wood will arrive at the facility in a ‘shredded’ state, but the Fire Prevention Plan describes the waste wood as being ‘shredded, baled and bagged’. Please clarify the physical condition of all waste streams that will be accepted at the proposed installation.
Fire Prevention Plan
In relation to the report entitled ‘Fire Prevention Plan (ref. BUK-E10)’ (FPP), please clarify the following:
- If the intention is to accept paper and / or cardboard wastes, please address the risks associated with these waste stream(s) and describe the prevention and mitigation measures that will be adopted in this regard;
- If the intention is to accept waste wood and paper and / or cardboard in baled, bagged form, please address the risks associated with accepting these wastes in this physical state and describe the prevention and mitigation measures that will be adopted in this regard;
- Please describe the prevention and mitigation measures that will be applied to the ‘waste storage building’;
- Please describe the prevention and mitigation measures that will be put in place in the event of a prolonged period of shut-down of the gasifier;
- Section 3.1 states that one of the basic fire prevention measures that will be employed is to ‘spread out any waste loads awaiting processing or in reception to ensure that there are no undetected hot items or other materials which could start a fire’. If waste is to be accepted at site in bales or bags, please explain how this process will occur for waste packaged as such and how the waste streams (i.e. waste wood and cardboard and / or paper) will be segregated;
- Section 3.1 states that a dedicated external emergency or quarantine area will be designated on site; however this is not shown on the plans enclosed with the FPP. Please provide a revised plan showing the location of this area;
- Please confirm the quantities of water that will be held at any one time within the onsite storage system and what methods of monitoring will be in place to ensure that appropriate levels can be maintained during warmer periods of weather. Please confirm that the water supply provisions will be adequate to supply water at a rate sufficient to tackle a ‘worst-case’ scenario fire (i.e. all waste wood piles alight simultaneously);
- With reference to NRW’s guidance document ‘Fire prevention and mitigation plan guidance –Waste’ (FPP guidance), please describe how safe access to the site for fire and rescue services and other emergency responders will be achieved;
- With reference to Annex A3: ‘Sensitive Receptors’, our records show that there are significantly more sensitive receptors within 1km of the installation than are shown on the plan. Please confirm that all high-impact receptors have been considered in this assessment and amend, revise and re-submit the plan accordingly, if required;
- With reference to Section 3.6 of the report, which states that ‘Due to the waste being stored internally within the waste storage building, the waste storage is not required to meet the pile size and separation distance standards.’ NRW’s FPP guidance on pile size and separation distance applies to all waste piles whether they are stored internally or externally. Please confirm that the size and separation distance of waste piles stored internally will comply with NRW’s FPP guidance. If it is the intention to receive waste wood and cardboard and / or paper, please explain how these waste streams will be appropriately segregated;
- With reference to Section 3.8 of the report, which states that ‘Due to the nature of the waste streams, stockpile temperature monitoring is not required.’ Please provide further explanation as to why stockpile temperature monitoring is not required;
- Section 3.10 of the FPP states that ‘The seasonal variation of wastes (i.e. during national holidays) may require the site to hold more wastes than under normal operating conditions.’ Please specify the quantity of additional waste that may be stored on site under this scenario and confirm that the total waste storage capacity of the site will not exceed 2,000m3 at any time; and
- The FPP refers to the Environment Agency’s Technical Guidance Note ‘TGN 7.01: reducing fire risk at sites storing combustible waste’. Please review the instances where this guidance note has been used and consider these points instead against NRW’s FPP guidance. Appropriate standards to all construction relating to the containment or storage of potentially hazardous or flammable substances, (which could in this case include any firewater) must be applied. Some of the application supporting documentation references CIRIA C164. However, this is now obsolete and has been replaced by CIRIA C736 guidance. On this basis, please consider all references to CIRIA C164 against CIRIA C736 as the most current version and apply it where appropriate across the development / installation, including in relation to your FPP.
- It is our understanding that construction of the proposed installation has commenced and as such the detailed design stages of the project (as referenced in the FPP) must be at an advanced stage. In view of this, please provide a detailed fire risk assessment for the proposed installation as referenced in Annex C of the Biomass UK No. 2 Ltd FPP.
Please submit a revised Fire Prevention Plan that incorporates all of the above requests for clarification and further information.
Site Condition Report
In relation to the report entitled ‘Site Condition Report. Energy Recovery Facility. EPR Permit Application’ (received by NRW on 23rd February 2017), please provide the following information:
- Please explain and justify suite of analysis used for sampling. In relation to Article 22(2) of the Industrial Emissions Directive, please identify all relevant hazardous substances that may have arisen due to historical activities on site and relevant hazardous substances that may be used as part of permitting activities in your justification;
- Please identify sources and pathways by which any current contamination resulting from historical activities and / or future contamination by the permitted activities may be able to reach land or groundwater. Please show how this information informed the location of intrusive sampling carried out as part of the site investigation;
- Please provide interpretation of groundwater levels and flows at the site;
- Please indicate whether up and downgradient groundwater monitoring has been provided for baseline;
- Where contamination and / or IED relevant hazardous substances have been found to be present as a result of historical activities, please demonstrate that the permitted activities cannot result in release of these substances; and
- Please clarify how the data obtained from the intrusive investigation has been used to set a baseline reference.
Please provide a revised Site Condition Report that that incorporates all of the above requests for clarification and further information.
Demonstration of compliance with Article 50(2) of the Industrial Emissions Directive
As noted in the previous Schedule 5 Notice for Further Information (dated 24th January 2017), Page 31 of the report ‘Biomass UK No. 2 Ltd. Barry Energy Production Facility’ states that:
“Detailed Computational-Fluid-Dynamic modelling (CFD) of the gasification/combustion process has been carried out to ensure complete combustion of the fuels under varying conditions, and also ensures the 2 seconds minimum dwell time above 850°C. This information is commercial in confidence and has not been included within the application.”
The response to this notice (provided in the letter dated 22nd February 2017) did not provide enough information to demonstrate that the CFD modelling carried out complies with the description of Best Available Techniques (BAT) as given in Section 2.5 ‘Validation of combustion conditions’ of EPR 5.01 ‘The Incineration of Waste’.
Please provide a report which describes the CFD modelling in detail and demonstrates that the design combustion conditions comply with the residence time and temperature requirements as defined in Article 50(2) of the Industrial Emissions Directive (IED). The report shall include the heat balance calculations that have been carried out in order to determine the minimum surface temperatures throughout the relevant parts of the flue gas pathway.
Abnormal emissions and failure of duty continuous emissions monitoring system (CEMS)
Page 83 of the report entitled ‘Biomass UK No. 2 Ltd. Barry Energy Production Facility’ states that:
“The plant will be operated with a single CEMS which will be linked into the controls system. In the unlikely event of CEMS failure on one of the streams, a full replacement CEMS will be available on sit with 24 hours.”
Please provide more information describing the preventive maintenance procedure that will be employed for the duty CEMS and the procedure that will be followed in the event of failure of the duty CEMS.
Assessment of Best Available Techniques
Choice of combustion and gasification technologies
In relation to Tables 6.1 and 6.2 of the report entitled ‘Biomass UK No. 2 Ltd. Barry Energy Production Facility’, please provide further explanation indicating why the choice of fluidised bed gasification represents BAT for the proposed installation. Please include the following BAT considerations in this explanation:
- The nature/physical state of the waste and its variability;
- The proposed plant throughput and its affect the number of incineration lines;
- The preference and experience of the chosen technology including plant availability;
- The nature and quantity/quality of residues produced;
- Impact on emissions to air and in particular the effect on the amount of unabated NOx produced;
- The rate of energy consumption whole plant, waste preparation and the effect on Global Warming Potential; and
- The need, if any, for further processing of residues to comply with the IED Total Organic Carbon (TOC) requirements; and
Design of the boiler
In relation to Table 6.5 of the report entitled ‘Biomass UK No. 2 Ltd. Barry Energy Production Facility’, please provide further explanation of why the design of the boiler represents BAT for minimisation of the formation of dioxins and furans.
Primary and secondary flue-gas treatment
In relation to Sections 6.1 and 6.5 of the report entitled ‘Biomass UK No. 2 Ltd. Barry Energy Production Facility’, please provide further explanation indicating why the selection of selective non-catalytic reduction, selective catalytic reduction, dry scrubber with associated anhydrous lime and activated carbon injection, bag filtration system and flue gas recirculation flue gas treatment abatement technologies represent BAT for the proposed installation. Please include the following BAT considerations in this explanation:
- type of waste, its composition and variation
- type of combustion process, and its size
- flue-gas flow and temperature
- flue-gas content, size and rate of fluctuations in composition
- target emission limit values
- restrictions on discharge of aqueous effluents
- plume visibility requirements
- land and space availability
- availability and cost of outlets for residues accumulated/recovered
- compatibility with any existing process components (existing plants)
- availability and cost of water and other reagents
- energy supply possibilities (e.g. supply of heat from condensing scrubbers) reduction of emissions by primary methods
- release of noise.
Efficient use of water, energy and raw materials
The report entitled ‘Biomass UK No. 2 Ltd.’ does not describe in detail the measures that will be adopted to comply with BAT for the proposed installation type in relation to the efficient use of water, energy and raw materials. Please provide further information describing how the applicant will ensure that the installation achieves BAT in these areas.
Handling and storage of air pollution control residues (APCr) and bottom ash
The report entitled ‘Biomass UK No. 2 Ltd.’ does not describe in detail the measures that will be adopted to comply with BAT for the proposed installation type in relation to the handling and storage of APCr and bottom ash, including the procedure for 4-yearly change of the fluidised bed. Please provide further information describing how the applicant will ensure that the installation achieves BAT in this area.
The report entitled ‘Biomass UK No. 2 Ltd.’ does not describe in detail the circumstances under which the auxiliary burners will be required to operate. Please provide further information describing how and when the auxiliary burners will be operated to ensure the installation achieves BAT in this area.
End of Schedule.