NORFOLK LOCAL AUTHORITY POLLUTION
PREVENTION & CONTROL NEWSLETTER
Introduction March 2014 issue
Welcome to the sixth edition of the Norfolk LAPPC Newsletter produced on
behalf of and in collaboration with all 7 local authorities across Norfolk. The aim
is to give consistent advice across the county aiding with permit compliance
and providing advice to small and medium enterprises. If you have any issues
you want covering or indeed wish to contribute to the newsletter then please
don’t hesitate to contact your local regulator. Contact details are listed on the
back page.
Contents
• Timber Treatment
• Fees & Charges
• Transfer & Surrender
• Tales from an Operator – Bespak
• SMART
• Keep up to date
• Coffee Break Crossword
• Contact details
• Chimneys
• Changes to Management of Waste
Timber Treatment PGN 6/03 now SG 11.
Due to changes introduced by the Industrial Emission Directive Timber
Treatment is being upgraded from a part B activity to an A2 activity.
At this point in time all timber treatment installations require a part B permit if
they process more than 1000m3 in any 12 month period and / or if they use
a treatment which is covered by the Solvent Emissions the solvent threshold
being 25te per any 12 month period.
The criterion is changing for this activity; now being based on capacity of
the installation. If the installation is capable of processing 75m3 of timber a
day it will require an A2 permit this is not dependent on the amount of timber
processed or the treatment methods in place whether solvent based; water
based or indeed solvent free; it is based purely on the capacity criterion.
Capacity is defined as the theoretical capacity of the installation and not the
actual capacity of any installation operating at the present time thus if you
have a reaction vessel capable of treating 3.2m3 or more timber and have no
planning restrictions as to operation times of the installation then you WILL
require an A2 permit.
Your regulator will be contacting you in the next 3 months in order to establish
whether or not your installation falls within these parameters.
If so; an application will be expected by September in order that a permit maybe
in place by the regulation’s deadline of the 7th July 2015.
Transfer & Surrender
If a LAPPC (Part B) or LA-IPPC (Part A2) installation changes hands (i.e. the operator’s legal identity
changes) Regulation 21 of the Environmental Permitting (England & Wales) Regulations 2010 allows for the
Permit to be transferred for the whole installation or for one or more parts of it through a partial transfer.
When an operator wants to transfer all or part of a permit to someone else, he/she and the proposed
transferee must make a joint application. The required application form is obtained from your Local Authority
(LA) and must be signed by both parties. Any changes to the permitted operation which results from the
transfer must be highlighted and the changes detailed. For a partial transfer, a new permit will be issued to
the transferee and hence the application must make clear who has control and hence responsibility over the
given areas of the permitted operation.
The transfer application must be accompanied by the current permit document and must include the
appropriate transfer fee as specified in the list of charges issued by DEFRA. http://www.defra.gov.uk/
industrial-emissions/files/List-of-Charges-April-2013.pdf
The LA has 2 months to determine the transfer application, and can either endorse the old permit with the
transferee’s details or issue a new permit adding or amending any conditions as appropriate.
Surrender
Regulation 24 of the Environmental Permitting (England & Wales) Regulations 2010 allows an operator of
a Part B, or Part A2 incineration installation, to surrender their permit. Regulation 25 enables an operator to
surrender a Part A2 permit in whole or in part.
Where the operator of an Part B installation or mobile plant wishes to surrender their permit either in whole
or in part, they must notify their Local Authority. The operator must use the Surrender form provided by the
authority, which shall require:
•
operator contact details
•
details of the permit to be surrendered and, if partial surrender is applicable, which parts are to be
surrendered (or, in the case of mobile plant, which plant are covered by the surrender)
•
if a partial surrender, details of any conditions the operator considers may need varying as a result
•
details of any information of commercial confidentiality
•
the date on which the surrender is to take effect
•
the operators signature
The outcome of the surrender application will be that the permit ceases to have effect on the date notified
by the operator. If it is a partial surrender and the authority does not consider it necessary to vary any
conditions as a result of the notification, the relevant part of the permit ceases to have effect on the date
notified by the operator. Otherwise if it is a partial surrender but the authority considers it necessary to
vary any conditions, the authority must serve a Variation Notice stating that such variations are considered
necessary, what those variations are and the date when the variation(s) take effect.
For a Part A2 site, the authority has to be satisfied that necessary measures have been taken before the
surrender can be accepted: This is to ensure;
2 any pollution risk resulting from the operation of the installation is avoided, and
3 the site is returned to a satisfactory state, having regard to the state of the site prior to the initial
installation of the operation.
Additional information and reports will be required to demonstrate that this criteria is met to the satisfaction
of the Local Authority before the Surrender will be accepted.
For further information on transferring and surrendering permits; please contact your Local Authority.
SMART – Small to Medium Accident Repair Techniques
As a regulator, inspecting paint body shops under PG6/34 was fairly straight forward. But times are changing and
as body shops now find themselves in a very competitive and challenging market; and it appears the market has
risen to meet that challenge. SMART appears to come in various different guises but the common feature is that
the process reduces vehicle turn around time, therefore allows a greater throughput of vehicles, and reduces
energy costs. For both business and customer this appears to be a win-win situation as, by making repairs more
affordable, it taps into a market formally lost because of high insurance excesses.
When costs are cut, this can often mean that environmental concerns get overlooked but this is not the case with
SMART. All re-sprayers must continue to meet standard permit conditions, with no exception. The inspection
process is the same as for conventional methods of vehicle re-spraying, maintenance regimes are the same,
as are preventative maintenance and plant servicing requirements. Environmental logs must still be kept and
fugitive emissions minimised .Staff training is equally, if not more, important and pollution control procedures
must still be maintained and regularly reviewed. All spaying is maintained under negative pressure and air
circulated through a particulate filter system before discharging to atmosphere. Cleaning of all spray guns and
general housekeeping must not be compromised and must be undertaken with minimal solvent emission to
atmosphere.
There are however further environmental advantages with SMART. The emphasis is put on repairing rather than
replacing body panels thus reducing waste. Energy consumed in curing the paint is significantly reduced and
waterborne base coats now dry quickly at room temperature or by heating with localised infra-red heaters or
UV curing. By concentrating on only repairing the damage and not the whole panel, the amount of paint used
is reduced and hence solvents going to atmosphere. Vehicles are not moved around the workshop; instead the
repair procedure revolves around the car.
Perhaps the only anomaly in the SMART process is the independent mobile units which do not form part of a
body shop. The mobile units do not have the solvent usage to qualify for an LAPPC permit and hence are not
regulated, relying on the operator and the industry itself to ensure emissions to air are minimised. The Norfolk
Environmental Group has taken this matter up with Defra but it appears there is no legislation at the present time
to capture these operations into a more formalised regime.
In summary SMART appears to do what it says on the tin while at the same time meeting environmental
concerns.
Coffee Break Crossword
Across
1.
Allow (6)
4.
You choke if it’s bad! (3,7)
5.
Squander (5)
7.
Capitulate (9)
9.
Help (8)
10. Discharges (9)
Down
2.
Depart (4)
3.
Convey (3)
6.
System (7)
7.
___ James (Actor) (3)
8.
Lubricates (4)
1
2
3
4
5
6
7
8
9
10
Chimneys – what’s hot what’s not.
Most of our operators’ permit will include a generic condition on chimneys and stacks along the lines of:“The final opening of chimneys and process vents shall not be fitted with any restriction.”
So in practical terms what do we mean by this condition - below are some examples of:
What’s Hot
What’s Not
Where we observe chimneys with final opening obstructions as per the not so hot photos we will request that the final
openings are modified to meet the requirements of the permit conditions ie the restrictions removed.
Why is the condition there in the first place – to aid dispersal of any pollutants emitted from the chimney or process
vent and thus preventing nuisance or adverse health effects from the activity.
Changes to the Management of Waste
If you haven’t heard from your suppliers or waste contractors already - changes in waste management may
have an impact on your business. Document WM2 produced by the Environment Agency (enter WM2 into
Google or the search panel on the Environment Agency page) sets out the changes to waste classification and
hazardous waste. You could be affected if you return containers that have previously been considered empty but
have held hazardous substances. The empty packaging, unless cleaned to the appropriate industry standard, is
now classified as hazardous waste and must be treated as such. The Environment Agency website guides you
through this and how to register as a hazardous waste producer if you qualify for this requirement.
New LAPPC Fees & Charges for 2014/15 Part B
Application Fees
Price
Annual Subsistence Charges
Price
Standard process
£1,579
Standard process Low Risk
£739 (+99*)
Additional fee operating without Permit
£1,137
Standard process Medium Risk
£1,111 (£149*)
Reduced fee activities (apart from VR)
£148
Standard process High Risk
£1,672 (+198)
PVR I & II combined
£246
For Combined Permit & Waste add * in brackets
Vehicles Refinishers (VRs)
£346
Reduced fee activities - (Low/Med/High)
£76 / £151 / £227
PVR I & II Combined
£108 / £216 / £326
Vehicle Refinishers - (Low/Med/High)
£218 / £349 / £524
Reduced Fee: additional fee operating
without permit
£68
Mobile screening plant
Mobile screening plant (Low/Med/High)
£618 /£989 / £1485
1st & 2nd plant
£1,579
3rd to 7th plant
£368 / £590 / £884
3rd to 7th plant
£943
8th and subsequent (Low/Med/High)
£189 /£302 / £453
8th and subsequent
£477
Where Permit is subject to E-PRTR add £99
Combined Permit & Waste add
£297
Add £36 for annual subsistence charges paid quarterly
Charge for late payment of fees
Transfer
£50
Transfer
£162
Substantial Change
Partial transfer
£476
Standard process
£1005
New operator at a reduced fee activity
£75
Reduced fee activities transfer
£0
Standard process where substantial change results in a new
activity
£1579
Reduced fee activity partial transfer
£45
Reduced fee activities
£98
Temporary transfer for Mobiles
Surrender
First transfer
£51
Surrender ALL part B activities
Following enforcement or warning
£51
NB from 1st October all mineral activities transferring into the reduced fee sector
will pay the same as Vehicle Refinishers.
£0
Tales from an Operator – Bespak King’s Lynn
Anybody who has had to apply, and then manage,
an Environmental Permit may say the road to being
granted one is not always smooth but at Bespak, once
in place, the impact of having an Environmental Permit
has been nothing but positive.
We started our journey back in 2007 when it became
very clear that manufacturing requirements would
be shooting, our then current capacity, much higher
- a great position to be in! Although we formally
had a Part B permit, establishing an A2 permit was
‘challenging’ to say the least. Firstly, those involved
in the process of applying for the permit had to
understand the implications and requirements of the
regulations and, for anyone involved in deciphering
environmental legislation, it is not always ‘black &
white’.
Nevertheless, a few ‘experts’ soon got to grips, along
with some very helpful advice (ongoing I hasten to
add) from our Environmental Regulator, and before
long our application was in and successful. Of course
this success was and continues to be dependent on a
number of ongoing requirements, including a timetable
of regular data submissions. However, what initially
appeared daunting was soon just part of the day to day
operational activity of managing the complex process
of ethanol extraction. Once new equipment had
been installed to help with data collection, templates
established to gather and interpret that data; the
monitoring process is now just a walk in the park.
Ok, maybe not quite that simple as it still requires
an independent team to manage its continuing
compliance to keep Bespak operating within
Environmental standards, but the key to this is having
good foundations and to not become complacent.
Aside from the tight control that this permit has brought
to one part of Bespak’s manufacturing capabilities,
the impact of establishing the permit can be felt over
the entire business as we have now established
an environmental management system which was
certified to ISO 14001 in March 2010.
The benefit of having this management system in
place has been raising overall awareness of the
potential environmental impacts that our processes
have, not just locally but globally. We are now far
more in tune with the materials we use, the energy
consumed to manufacture our products and the waste
generated as a result of our processes. This has
enabled us to prioritise and focus on initiatives that
have a positive impact on the environmental aspects of
our business.
It’s a continual process but now we are on the
Environmental Train we’ll never get off. With legislation
forever changing and given the environmentally
focussed world we find ourselves operating in, we are
in for the long haul.
And do you know what ... it has a certain feel good
factor about it. Who doesn’t want to care for the
environment we live in!
Jo Ward
EHS & Quality Systems Manager
Bespak Europe Ltd.
Keep up to Date!!
In December Defra issued 13 revised Process Guidance Notes as
listed below ie:
1/13 Storage, unloading
6/21 Hide and skin processes
and loading petrol at
6/24 Pet Food Manufacturing
terminals
6/26 Animal Feed Compound;
1/14 Unloading petrol into
6/30 Mushroom substrate
storage & motor vehicle
manufacture
refuelling, at service
6/31 Powder coating including
stations
sherardizing and vitreous
4/02 Fibre reinforced plastics.
enamelling drying
6/05 Maggot Breeding
6/36 Tobacco processes
6/12 Sausage casings
6/42 Bitumen and tar
6/19 Fish meal processing
processes
There are 6 new sectors now covered by simplified permits – look
out for these permits to be reissued over the next 12 months.
Further Information:
• DEFRA website www.defra.gov.uk/environment/quality/industrial/
las-regulations/guidance
• Business Link website www.businesslink.gov.uk
• Environmental Agency website www.environment-agency.gov.uk/
business
• Free copy of legislation www.opsi.gov.uk/acts/acts1999a.htm
• Net Regs www.netregs.gov.uk
• Carbon Trust www.CarbonTrust.co.uk
• Rev Active. www.revactive.co.uk
Contact Details for your Regulators
Breckland
Environmental Protection
Broadland
Environmental Protection Team
Great Yarmouth
Richard Agar
Kings Lynn & West Norfolk
Environmental Quality Team
North Norfolk
Environmental Protection Team
Norwich City Council
Environmental Protection Team
South Norfolk
Environmental Services
e-mail
Telephone
envprotect@breckland.gov.uk
01362 656350
e-mail
Telephone
envon.protect@broadland.gov.uk
01603 430488
e-mail
Telephone
raa@great-yarmouth.gov.uk
01493 846622
e-mail
Telephone
environmentalquality@west-norfolk.gov.uk
01553 616200
e-mail
Telephone
ep@north-norfolk.gov.uk
01263 516 085
e-mail
Telephone
ehealth@norwich.gov.uk
0344 980 3333
e-mail
Telephone
envserv@s-norfolk.gov.uk
01508 533653 / 08081684444