Permit with Introductory Note
The Pollution Prevention and Control Act 1999
Environmental Permitting (England and Wales) Regulations 2010 (as amended)
OPERATOR
Burt Boulton and Haywood Ltd,
Alexandra Docks,
Newport
NP20 2WA
INSTALLATION
Burt Boulton and Haywood Ltd,
Alexandra Docks,
Newport
NP20 2WA
Permit issued by:
Newport City Council
Law & Regulation
Civic Centre
NEWPORT
South Wales
NP20 4UR
Telephone:
01633 656656
Fax:
01633 233138
Website:
www.newport.gov.uk
Email:
environmental.health@newport.gov.uk
LOCAL AUTHORITY POLLUTION
PREVENTION AND CONTROL (LAPPC)
Permit Reference Number: LAPPC/041/07/v2
Pollution Prevention and Control Act 1999
Environmental Permitting (England and Wales) Regulations 2010 (as
amended)
NEWPORT CITY COUNCIL, (the “Regulator”) in exercise of its powers under Regulation 13 of the
Environmental Permitting (England and Wales) Regulations 2010 (as amended), hereby Permit:
Burt Boulton and Haywood Ltd, (“the Operator”)
Alexandra Docks,
Newport
Gwent
NP20 2WA
to operate an installation at:
Alexandra Docks,
Newport
Gwent
NP20 2WA
in which an activity is being carried out as listed in Schedule 1 to the above-mentioned Regulations
and as detailed in Table 1 – Process description.
The Permit is to the extent authorised by and subject to the Conditions contained in this Permit.
Signed on behalf of NEWPORT CITY COUNCIL
Jonathan Keen
Environmental Health Manager
Dated this
day of
Permit issued by:
Newport City Council
Law & Regulation
Civic Centre
NEWPORT
South Wales
NP20 4UR
Telephone:
01633 656656
Fax:
01633 233138
Website:
www.newport.gov.uk
Email:
environmental.health@newport.gov.uk
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LAPPC/041/07/v2 FINAL DRAFT
The Pollution Prevention and Control Act 1999
Permit Reference: LAPPC/041/07/v2
STATUS LOG
Detail
Date
Comments
Date of Application
03.02.15
Full application
Date Duly Made
15.03.15
Permit Issued
FINAL DRAFT
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The Pollution Prevention and Control Act 1999
Permit Reference: LAPPC
Operating Conditions
The Permitted Activity involves processes for the purpose of the preserving of wood with chemicals
(other than sapstain) with a production capacity >75m3 per day. In this permit the "permitted activity"
comprises the whole operation including the treating, handling and storage of any materials used and
products and wastes produced by the activities within the Installation Boundary.
The following process description divides the Installation into its elements and activities both those
activities scheduled under the above regulations and those non-scheduled elements required to be
regulated because of their polluting potential and that have a direct association and a technical
connection to the scheduled activities:
The installation comprises the following activities and elements:






Raw material storage element
Timber pressure treatment activity (Bethel Process)
Timber coating activity (Reuping Process)
Timber drying element
Creosote Recycling element
Waste storage element
All process steps encompassed within the timber treatment activity are supported by specific
equipment specifications, process controls, planned maintenance, quality assurance and product
verification procedures.
Process Description and General Information
Raw material storage element
All deliveries to site are be booked in through the Purchasing Office to ensure there is no congestion
on the yard area, booking slots are allocated to minimise noise, site traffic, avoiding spillages, leaks
and emissions.
The storage area for all chemicals is under cover; chemicals must only be located in designated
areas. Creosote is stored only in the tanks identified for its storage. All areas storing chemicals in
bulk are hard surfaced and fully bunded.
Bulk Deliveries are by tanker, and are supervised by designated Operators. Bulk deliveries are all
carried out within areas that are protected by hardstanding, connected to blind sumps, or connected
to drainage systems that discharge directly into the waste water treatment processes. Filling of tanks
is carried out within protected areas to ensure any potential spillages are contained.
Raw material storage is technically connected and directly associated with the activities falling within
Schedule 1 of the Environmental Permitting (England and Wales) Regulations 2010 (as amended).
Creosote Treatment of Timber
There are two process used in the creosote treatment process treatment:

FULL- CELL (BETHEL) PROCESS
EMPTY- CELL (REUPING) PROCESS
The treatment process can be summarised as follows:



Loading of timber onto the trolleys appropriately secured (strapped) to prevent flotation
Alignment of timber on the trolleys to allow entry into the autoclave
Careful movement of the trolleys into the autoclave to the rear stop position
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



Closure and sealing of the door, ensuring the seal is clean and free from debris to avoid leaks
Locking the door, ensuring safety devices are in position
Selection of the appropriate treatment cycle for the timber product, dependent on end use of the
timber, and ensuring that there is sufficient treatment chemical in the work tank to fully flood the
autoclave
Start the treatment process:
Full-cell (Hethel) process
INITIAL VACUUM: Air is evacuated out of the autoclave and the timber, creating a negative pressure
of approximately -0.8 bar. Typically the vacuum pump will stop when the target intensity of vacuum
has been achieved. Vacuum will be held in the autoclave for a set time period depending on the
treatment cycle selected. This has the effect of drawing air out of the wood, so making room for the
preservative fluid that will replace it.
VACUUM FILL: Once the pre-set initial vacuum stage is completed, the autoclave will fill with
preservative under vacuum and the vacuum pump(s) will switch back on. The ‘vessel full’ sensor
positioned in the vacuum line detects that the autoclave is full.
PRESSURE: Hydraulic pressure is raised within the vessel by the start of the pressure pump.
Monitoring of the preservative uptake starts automatically when slight positive pressure is seen in the
autoclave. Pressure relief valves are integral to the system, one at working pressure (9.5 bar) and
safety back higher (14bar). During this phase preservative fluid is impregnated deep into the wood
structure, to replace the air removed during the initial vacuum stage.
PRESSURE RELEASE: This occurs when the pressure phase has reached the required amount of
preservative has been injected into the timber. Pressure (and any excess preservative fluid) is then
released back into the storage tank
INITIAL DRAIN: Preservative is returned to the work tank once pressure has been released back to
atmospheric level. The autoclave is emptied by a combination of gravity and an additional fluid
transfer pump. The ‘vessel empty’ sensor is positioned in the main flood line and so detects when the
autoclave is empty.
FINAL VACUUM: A negative pressure of -0.8 bar is created once more and maintained for a minimum
of 4hours. During this phase excess fluid is drawn from the timber.
VENT / FINAL DRAIN: After final vacuum, the negative pressure generated in the autoclave is
released and some remaining excess fluid on the surface of the wood is sucked into the wood
structure, helping to further dry the treated product before unloading. The vessel is then vented before
any residual preservative remaining inside the autoclave is recovered back to the work tank and the
vessel door finally re-opened.
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END OF CYCLE: When the autoclave is empty the cycle will stop and a charge report is generated.
The timber can be removed and the process restarted if required.
Empty cell (reuping) process
Preliminary air pressure: Hydraulic pressure is raised within the vessel by the start of the pressure
pump to 3bar This has the effect of filling the wood cells with air so that the cells within the wood can
be coated with creosote and not filled as like the full-cell (Bethel process).
Filling the cylinder: Once 3 bar of pressure is held for 30-35miniutes stage is completed, the autoclave
will fill with creosote. The ‘vessel full’ sensor positioned on the top of the treatment cylinder detects
that the autoclave is full.
PRESSURE: Hydraulic pressure is raised within the vessel by the start of the pressure pump.
Monitoring of the preservative uptake starts automatically when slight positive pressure is seen in the
autoclave. Pressure relief valves are integral to the system, one at working pressure (9.5 bar) and
safety higher (14bar). During this phase preservative fluid is impregnated deep into the wood
structure coating the cells.
PRESSURE RELEASE: This occurs when the pressure phase has reached the required amount of
preservative and has been injected into the timber. Pressure is usually released back into the
scrubber unit. Ans discharged to atmosphere.
INITIAL DRAIN: Creosote is returned to the work tank once pressure has been released back to
atmospheric level. The autoclave is emptied by a combination of gravity and an additional fluid
transfer pump. The ‘vessel empty’ sensor is positioned in the main flood line and so detects when the
autoclave is empty.
FINAL VACUUM: A negative pressure of -0.8 bar is created once more and maintained for a minimum
of 4hours. During this phase excess fluid is drawn from the timber and autoclave back to the storage
tank.
VENT / FINAL DRAIN: After final vacuum, the negative pressure generated in the autoclave is
released and some remaining excess fluid on the surface of the wood is sucked into the wood
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The Pollution Prevention and Control Act 1999
Permit Reference: LAPPC
structure, helping to further dry the treated product before unloading. The vessel is then vented before
any residual preservative remaining inside the autoclave is recovered back to the work tank and the
vessel door finally re-opened.
END OF CYCLE: When the autoclave is empty the cycle will stop and a charge report is generated.
The timber can be removed and the process restarted.
The collection and treatment of creosote is subject to a Natural Resources Wales Permit (ref:
EPR/GB3593/HE dated 02.03.15).
Pressure treatment of wood with chemicals is a scheduled Activity within section 6.6 of the
Environmental Permitting (England and Wales) Regulations 2010 (as amended). The activity also
comprises a Solvent Emission (SE) activity as defined under Schedule 14.
Post Treatment Drying Area
Treated product is only removed from the autoclave when the product is no longer dripping creosote,
and is essentially dry. All treated poles are held on the charge bogey within the rail tracks, which
form the outer limit of the installation boundary. All pole charges are inspected prior to their removal
from the immediate drying area. The immediate drying area consists of impermeable concrete. There
is no forced drying (curing) carried out.
Waste storage element
Waste generated within the installation, including straps, timber sludge and distillate residues from
Creosote recovery, etc. are stored in locations and in such a manner as to ensure proper control of
the wastes. i.e. creosote contaminated waste is secured in sealed containers prior to dispatch for
recovery. Wastes stored onsite are located as noted in the Plan ref: MB006.
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Permit Reference: LAPPC
Waste storage elements of the installation is technically connected and directly associated with the
activities falling within Schedule 1 of the Environmental Permitting (England and Wales) Regulations
2010 (as amended).
Plant & Equipment
The Operator is permitted to carry out the activities and/or the associated activities specified in Table
1.
Table 1
Activity under
Schedule 1 of the
Regulations
Chapter 6
Schedule 1 Activity
Reference
Description of Specified Activity
Section 6.6
Timber activities
Part A(2)
(a) Preservation of wood and wood
products with chemicals with a
production capacity exceeding
75m3 per day other than
exclusively treating against
sapstain
The permitted installation shall consist only of that plant and equipment listed in Table 2 below. No
other relevant plant or equipment capable of emitting pollutants to air, land or water shall be used
without the prior written consent of the regulator.
The key process plant is listed in Table 2 below:
Table 2
Process
Plant/Equipment
Delivery Tank 1
Delivery tank 2
Storage tank 1
Storage tank 2
Storage tank 3
Emissions to environment
Monitoring, sampling and control
VOC, heat
VOC, heat
VOC, heat
VOC, heat
VOC, heat
fugitive
fugitive
fugitive
fugitive
fugitive
Creosote Processing
Plant 1
Creosote Processing
plant 2
VOC, heat
fugitive
VOC, heat
fugitive
Vacuum plant and tank
VOC, heat
fugitive
Autoclave 1
Autoclave 2
VOC, heat
VOC, heat
fugitive
fugitive
Scrubber unit tank
VOC, heat
fugitive
Boiler
Smoke, NOx, PM10, heat
Good combustion, maintenance, no dark
smoke
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LAPPC/041/07/v2 FINAL DRAFT
The Pollution Prevention and Control Act 1999
Permit Reference: LAPPC
Conditions
1.
Any system or procedures used to demonstrate compliance with a condition of this permit shall
be recorded.
2.
All records kept in compliance with conditions of this permit shall be kept in a systematic
manner.
3.
Unless otherwise specified in a condition of this permit, every record made in compliance with a
condition of this permit shall be preserved for not less than 2 years from the date of its being
made. Every such record shall be kept at the permitted installation for not less than 1 year from
the date of its being made and thereafter preserved at a location, previously notified to The
Regulator in writing, if that location is not the permitted installation.
4.
All records shall be legible, and any amendments made to any record in compliance with a
condition of this permit shall be made in such a way as to leave the original entry clear and
legible. The reason for each amendment shall be explained in the said record.
5.
Without prejudice to condition 3, all records relevant to the operation or maintenance of the
permitted installation shall be kept at the permitted installation for not less than 1 year from the
end of the period to which they apply.
6.
The permitted installation shall consist only of that plant and equipment listed in Table 2
(above). No other relevant plant or equipment capable of emitting pollutants to air, land or water
shall be used without the prior written consent of the regulator.
Emission Limits and Controls
Air
7.
The use of dilution of air to achieve emission concentrations limits shall not be permitted.
Dilution air may be added where justified for waste gas cooling or improved dispersion. In such
cases, monitoring should be carried out upstream of the dilution air input or procedures
designed to correct for the ratio of input air to the satisfaction of the regulator.
8.
All releases to air, other than condensed water vapour, shall be free from persistent visible
emissions.
9.
The Operator shall ensure that all operations which generate emissions to air are contained and
adequately meet specified emissions limits and discharge requirements.
10.
The Operator shall ensure that emissions from combustion processes in normal operation are
free from visible smoke and in any case do not exceed the equivalent of Ringelmann Shade 1
as described in British Standard BS 2742:2009.
11.
The Operator has elected to implement the Total Emission Limit method of compliance such
that the Total Emission of solvent is not to exceed 11kgm3 of timber.
NOTE: Compliance with the total emission value per m3 of timber treated is achieved if the total
input of the solvent (C, in kgs), divided by the volume input of wood treated (in m3) is less than
or equal to the emission limit value above.
12.
The Operator shall implement a system whereby the consumption of organic solvents and
materials is monitored against the quantity of product treated using a Solvent Management Plan
approach.
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13.
A Solvent Management Plan (SMP) shall be prepared by the operator and submitted to the
regulator on receipt of a written request. Where required the SMP shall include a determination
of the actual annual emissions from the timber treatment plant.
14.
There shall be no offensive odour outside the site boundary as perceived by the regulator.
It shall not be a breach of the condition in a particular case if the Operator can show that all
reasonable steps have been taken and all due diligence has been exercised to prevent the
release of offensive odour.
“due diligence”, shall mean that the Operator can demonstrate BAT has been applied.
Land
15. There shall be no emission of any pollutants to groundwater or soil from the permitted
Installation.
16.
Plans for the installation shall be maintained that identify the configuration and specification of
all drains, sewers and subsurface pipe-work and the position and purpose of all sub-surface
sumps and storage vessels that are used or have been used within the permitted installation
from the date of this permit until the permit is surrendered.
17.
The Operator shall:

Ensure that waste storage areas are clearly marked and signed, and that containers
are clearly labelled.

Ensure that appropriate storage facilities are provided for substances that are
flammable, sensitive to heat or light etc, and that incompatible waste types are kept
separate.

Ensure that containers are stored with lids, caps and valves secured and in place. (This
also applies to emptied containers.)

Ensure that procedures are in place to deal with damaged or leaking containers.
18.
A record shall be maintained of any incident that has, or might have, impacted on the condition
of any soil or groundwater under the permitted installation, either as a result of that incident or
as a result of an accumulation of incidents, together with a record of any further investigation or
remediation work carried out.
19.
All containers used to store any potentially environmentally hazardous material, shall be located
in a bund. The minimum capacity of any bund shall be either 110% of the capacity of the largest
container within the bund, or 25% of the total capacity of all the containers within the bund,
which-ever is the greater. In the event of any containers being connected to one another, they
shall be treated as one container.
20.
All the bunded area(s) and containers on site shall conform to the following standards:

the walls and base of the bund shall be impermeable and the base of the bunded area
shall drain to a sump

when not in use all taps, valves, pipes and every part of each container shall be
located within the area served by the bund

vent pipes shall be directed downwards into the bund

no part of the bund shall be within 10 metres of a watercourse

all containers with a design capacity above 1250 litres shall be fitted with a device for
continuously monitoring the level of the contents.
21.
At least every 4 years, a systematic assessment shall be carried out of all measures used to
prevent emissions from the permitted installation to soil and groundwater. A written report of
each assessment shall be recorded and reported to the Regulator. The report shall include
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Permit Reference: LAPPC
details of and timescales for any additional measures that are required to prevent emissions to
soil and groundwater.
22.
The storage of treated wood within the immediate post treatment drying area, shall only be
stored on hard standings that has its own containment drainage system.
23.
No other conditions have been requested by Natural Resources Wales or Welsh Water in
respect of this installation.
Monitoring, Sampling and Measurement of Emissions
Air
24.
Visual assessments of emissions shall be made frequently and at least once a day during
operations and recorded on shift report. The results of any such assessments shall be recorded
and retained for at least two years.
25.
Odour assessments to determine whether emissions result in offensive odours at or beyond the
site boundary shall be carried out on a daily basis. The results of any such assessments shall
be recorded and retained for at least 12 months.
26.
An Odour Management Plan (OMP) shall be submitted to the regulator by 31st December 2015.
The OMP shall be implemented should offensive odours beyond the site boundary be noted and
shall include:
(i)
(ii)
(iii)
(iv)
An assessment of the potential odour emissions from the installation
An indication of the potential odour strength of identified emissions
An assessment of any potential mitigation measures to deal with identified sources
A complaint management system
The OMP shall be updated as necessary to reflect changes in the process or upon receipt of a
written request from the regulator.
27.
The Operator shall keep record of inspections, audits, test, monitoring and visual and olfactory
assessments. These records shall be kept in accordance with conditions with this permit.
28.
Emission monitoring of the wet scrubber unit shall be undertaken at the request of the
Regulator.
29.
The Operator shall notify the Regulator at least 7 days before any periodic monitoring exercise
to determine compliance with emission limit values. The Operator shall state a provisional time
and date of the monitoring, pollutants to be tested and the methods used.
30.
The results of any non-continuous emission testing shall be forwarded to the Regulator within 8
weeks of the completion of the sampling.
31.
All results submitted to the Regulator shall include details of the process conditions at the time
of the monitoring, monitoring uncertainty as well as deviations from the procedural requirements
of standard reference methods and the error invoked from such deviations.
32.
Results that exceed the emission limit value from any monitoring activity shall be investigated
by the Operator immediately:
 Identify the cause and take corrective action
 Record as much detail as possible regarding the cause and extent of the problem, and
the action taken by the Operator to rectify the situation
 Inform the Regulator without delay.
 Retest to demonstrate compliance.
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33.
Results from any malfunction or breakdown leading to abnormal emissions shall be investigated
by the Operator immediately:
 Identify the cause and take corrective action
 Record as much detail as possible regarding the cause and extent of the problem, and
the action taken by the Operator to rectify the situation
 Inform the Regulator without delay.
Water
Note: Storm water from the installation consists of roof water only and is discharged to Alexandra
dock.
Note: Site storm water from the treated timber storage area is outside the treatment installation
boundary and is monitored and controlled by Natural Resources Wales under permit ref:
EPR/GB3593/HE dated 02.03.15.
34.
Neither Natural Resources Wales or Welsh Water plc requested conditions for sampling of
water.
Land
35.
Natural Resources Wales have not requested conditions for sampling soil from the installation.
Incidents
36.
There operator shall prepare written procedures for investigating foreseeable accidents, or near
misses which may affect the environment, including identifying suitable corrective action and
follow up.
37.
The Operator shall maintain an accident management plan for the installation covering the three
main components:
 Identification of the hazard
 Assessment of risk
 Measures to reduce the risk
The plan shall be updated as required to reflect changes in the hazards or risk as necessary.
38.
The accident plan shall be available for inspection by the Regulator upon request.
39.
The Operator shall maintain procedures for the control of spills and of firewater to ensure
containment and disposal of liquids in order to prevent or minimise pollution.
40.
The Operators shall ensure that materials are charged into the correct tanks to minimise the
potential for causing waste, spillage or uncontrolled chemical reaction.
41.
In the event of an incident all necessary measures shall immediately be taken:
 To prevent, or where that is not practicable to reduce, emissions from the permitted
installation;
 To limit environmental consequences;
 To prevent further possible incidents.
42.
Without prejudice to the requirements of condition 41 above, in the event of an incident involving
the breach of any condition of the permit, all measures necessary to ensure the compliance is
restored in the shortest possible time shall immediately be taken.
43.
Where a breach of any condition of the permit poses an immediate danger to human health, or
threatens to cause an immediate significant adverse effect on the environment, operation of the
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installation or relevant part shall be immediately suspended until such time it can operate in
compliance with the conditions of the permit.
44.
In an event of an incident, the regulator shall notify the Regulator without delay.
45.
Any incident notified to the regulator shall be confirmed in writing by the next working day after
the identification of the incident. This confirmation shall include:
 The time and duration of the incident;
 The receiving environmental medium or media where there has been any emission as a
result of the incident;
 An initial estimate of the quantity and composition of any emission; and
 A preliminary assessment of the cause of the incident.
46.
Any incident notified to the Regulator shall be investigated, and a written report of the
investigation produced and submitted. The report shall detail, as a minimum:
 The circumstances of the incident,
 An assessment of any harm to the environment; and
 The steps taken by the Operator to bring the incident to an end
 The report shall also set out proposals for remediation where necessary, and for
preventing a reoccurrence of the incident.
47.
Any report detailed in condition 46 shall be submitted to The Regulator no later than 14 days
after the incident.
Management
Environmental Management system
48.
The Operator shall use an effective Environmental Management System with policies and
procedures for environmental compliance and improvement. Audits shall be carried out against
these procedures at regular intervals.
Operations and maintenance
49.
The receipt, handling and storage of organic solvents and any solvent containing liquids shall be
carried out in a manner to prevent emissions. Where this is not practical due to activity
characteristics then emissions must be minimised and rendered harmless.
50.
All connections to static bulk tanks containing organic solvents shall be sited within a bunded
area.
51.
The two autoclaves containing organic solvents with a composite vapour pressure exceeding
0.4kPa at 20̊ C shall be fitted with pressure vacuum relief valves. Pressure vacuum relief valves
should be examined at a minimum of at least once every six months for signs of corrosion,
contamination, incorrect seating and be cleaned and/or corrected as required.
52.
All appropriate precautions shall be taken to minimise emissions during start-up and shutdown
of the treatment plant. The number of start-ups and shutdowns of the treatment plant shall be
kept to a minimum.
53.
The timber treatment vessel shall continue to be fitted with a fully functional interlock that
prevents the chamber door being opened until the vessel is completely drained and ambient
pressure reached.
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54.
All containers that are contaminated with organic solvents shall be kept closed to minimise
emissions from residue to atmosphere. They shall be labelled appropriately so all are aware of
their contents and hazardous properties.
55.
An effective operational and maintenance system shall be employed on all aspects of the
installation whose failure could impact the environment. As a minimum this shall cover bulk
liquids baths, tanks and transfers, and hot dipping. Such systems shall be reviewed and
updated annually.
56.
Environmentally critical process equipment whose failure could impact on the environment shall
be identified and listed. The regulator shall be provided with a list of such equipment within
Table 2.
57.
For equipment listed in condition 56 above:
 Alarms or other warning systems shall be provided, which shall indicate equipment
malfunction or breakdown
 Such warning systems shall be maintained and checked to ensure continued correct
operation, in accordance with the manufacturer’s recommendations.
 Essential spares and consumables for such equipment shall be held on site or shall be
available at short notice from suppliers.
58.
Records of breakdowns shall be kept and analysed by the Operator in order to eliminate
common failure modes.
Competence and training
59.
A competent person shall be appointed to liaise with the regulator and the public with regard to
complaints. The regulator shall be informed of the designated individual(s) and shall be provided
with appropriate contract details and formally notified of any changes.
60.
A formal structure shall be provided to clarify the extent of each level of employee’s
responsibility with regard to the control of the process and its environmental impacts. This
structure shall be prominently displayed within the process building at all times or there shall be
a prominent notice referring to all relevant employees to where the information can be obtained.
61.
Personnel at all levels shall be given training and instruction sufficient to fulfil their designated
duties under the structure required in condition 60. Details of training shall be entered into the
employee’s records and be made available for inspection at the request of a duly authorised
officer of The Regulator.
62.
The potential environmental risks posed by the work of contractors shall be assed and
instructions provided to contractors about protecting the environment while working on site.
Raw Materials and Waste
63. All necessary measures shall be taken to ensure that:
 the waste hierarchy referred to in Article 4 of Directive 2008/98/EC on waste1 (the “Waste
Framework Directive”) is applied to the generation of waste by the permitted activities; and
 Any waste generated by the permitted activities is treated in accordance with the waste
hierarchy referred to in Article 4 of the Waste Framework Directive; and
 Where further treatment or disposal is necessary, this is undertaken in a manner which
minimises its impact on the environment.
1
OJ L312, 22.11.2008, p.3
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64.
Within 18 months of the issue of this permit, and every 4 years thereafter, the Operator shall
carry out a raw materials (including water) and waste review audit. The audit shall identify the
types and quantities of raw materials used per annum and wastes produced per annum. The
methodology used and an action plan for optimising the use of raw materials and production of
wastes shall be submitted to the regulator within 2 months of completion of the audit. The
waste review audit shall identify benchmarks for raw material use and waste production.
65.
Specific improvements resulting from the recommendations of audits above shall be carried out
within a timescale approved by the regulator.
66.
The following shall be monitored and recorded:
 Quantity nature and origin of the waste
 The physical description of the waste
 A description of the composition of the waste
 Any relevant hazardous properties (hazard and risk phrases)
 European waste catalogue code
 Handling precautions and substances with which it cannot be mixed
 Disposal routes for each waste category
67.
All raw materials and waste materials shall be delivered only into the storage and waste storage
areas marked and designated on the plan in Appendix 2 and nowhere else within the
installation.
Raw material or waste noted to be outside the designated areas shall be considered a spillage
and shall be dealt with in accordance with condition 68.
68.
The Operator shall:

Ensure that waste storage areas are clearly marked and signed, and that containers are
clearly labelled.

Ensure that appropriate storage facilities are provided for substances that are flammable,
sensitive to heat or light etc, and that incompatible waste types are kept separate.

Ensure that containers are stored with lids, caps and valves secured and in place. (This
also applies to emptied containers.)

Ensure that procedures are in place to deal with damaged or leaking containers.
Solvent Emissions
69.
The Operator shall construct an inventory of solvent use within the installation. The inventory
shall be carried out by recording:
(i)
The mass of solvent contained in treatment chemicals, cleaners or other materials
used in the installation in the initial stock (IS) at the start of the accounting period,
plus,
(ii)
The mass of solvent contained in treatment chemicals, cleaners or other materials
used in the installation in the purchased stock (PS) during the accounting period,
(iii)
Minus the mass of solvent contained in treatment chemicals, cleaners or other
materials used in the installation in the final stock (FS) at the end of the accounting
period.
Then Total Solvent Input (I1) = IS + PS – FS
Further, having calculated total solvent Input (I1), the Operator shall then calculate solvent
consumption by subtracting from the Input figures any solvent that is sent out for recovery.
Hence: C (consumption) = I1 – O8
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The Pollution Prevention and Control Act 1999
Permit Reference: LAPPC
The inventory and consumption data shall be submitted to the regulating authority on 1st April
and 1st October for the preceding 6 months solvent use, every year. (see Appendix 1).
70.
The total emissions of VOCs, which are not vented through the abatement equipment listed in
Table 2, shall not exceed 20% of the solvent inputs. The methodology to be used shall be that
described in condition 71 below.
71.
To demonstrate compliance with fugitive emission values in required in condition 70 above, the
Operator shall determine the fugitive emissions (F) from the activity using the following:
F = I1-O1-O5-O6-O7-O8
Or
F=O2+O3+O4+O9
Definitions of the outputs (“Os”) are shown in Appendix 1. Each can be determined by direct
measurement of the quantities or, an equivalent calculation can be made by other means, for
instance by using the capture efficiency of the process.
The Fugitive Emission value as a percentage of the Solvent Input (I) is determined by
Fugitive Emission Value = 100 x F/I
Where the Solvent Input (I)= I1+ I2
Fugitive emission values must be determined for the activity, and must be repeated when any
equipment or process modification is carried out. (see Appendix 1).
72.
Based on the data compiled for condition 69 and the descriptions in Appendix 1, the Operator
shall calculate the actual solvent emissions applicable to the installation.
To demonstrate compliance with target emission limit (condition 11) the Operator shall
determine the actual emission (A) using the following:
A = I1-O8-O7-O6 (-O5 if abatement has been used)
Noise and Vibration
73.
Within 18 months of issue of this permit, the Operator shall carry out an acoustic audit to identify
key plant and equipment (or operations) with the potential to give rise to significant noise and
take such measures as are necessary by way of mitigation and maintenance of existing plant
and equipment in order to minimise noise having regard to Table 5.3 of SG11(13).
The Operator shall reassess the audit where there changes to plant or equipment or at the
written request of the regulator. The audit shall be carried out using a methodology agreed with
the Regulator.
Energy
74.
The Operator shall produce an annual report on the energy consumption of the installation
75.
The Operator shall monitor energy flows and identify areas for energy reduction which shall be
updated annually.
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The Pollution Prevention and Control Act 1999
Permit Reference: LAPPC
76.
The Operator shall ensure that all the plant is operated and maintained to optimise the use and
minimise the loss of energy.
77.
The Operator shall notify the Regulator of any:
 failure to achieve a two year milestone target; or
 cancellation of the climate change levy agreement.
78.
The Operator shall calculate the energy efficiency performance expressed as a ratio stated
below.
 Electricity and gas consumed v good tonnes produced
Notification
79.
The Operator shall notify the Regulator without delay of:
(i)
the detection of any malfunction, breakdown or failure of plant or techniques which
has caused, is causing or has the potential to cause significant pollution; and
(ii) any incident, which has caused, is causing or has the potential to cause significant
pollution.
80.
The Operator shall give written notification as soon as possible or at least within 14 days of any
of the following:
(i) Permanent cessation of the operation or part or all of the permitted installation.
(ii) Cessation of operation or part of all of the permitted installation for a period likely to
exceed one year; and
(iii) Resumption of the operation or part or all of the permitted installation after a cessation
has been notified.
81.
The Operator shall notify the following matters to the Regulator in writing within 14 days of either
occurrence:
(i)
Any change to the operation with the capacity to alter the nature of the final products
or intermediate products arising from the operation;
(ii) Any change in the Operators trading name, registered name or registered office
address;
(iii) Any change to particulars of the Operator’s ultimate holding company (including
details of an ultimate holding company where an Operator has become a subsidiary).
(iv) Any steps taken with a view to the Operator going into administration, entering into a
company voluntary arrangement, or being wound up.
European Pollutant Release and Transfer Register
82.
The Operator shall respond to any information notice served for the purpose of complying with
the obligation to report emissions and off site waste transfers pursuant to the directly applicable
EU duty in accordance with Article 5 of EC Regulation No. 166/2006 concerning the
establishment of a European Pollutant Release and Transfer Register. The failure to respond to
annual E-PRTR information Notice will hereby constitute a breach of this permit.
Site Closure Plan
83.
A site decommissioning plan shall be submitted to the regulator within 18 months of issue of this
permit. The plan shall be prepared and updated as may be necessary due to changes in plant,
equipment or materials used within the installation. In any event the plan shall be reviewed and
resubmitted every 3 years from the date of the first submission. The plan shall include:

A complete methodology to be adopted in the decommissioning of the installation, to
include:
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The Pollution Prevention and Control Act 1999
Permit Reference: LAPPC



Removal of key plant or machinery likely to be contaminated.

Removal of contamination associated with the plant and machinery.

Minimising any contamination from the installation buildings during demolition.

Removal of contaminated subsurface infrastructure as may be necessary.
An assessment of the impact of decommissioning on the nearest sensitive receptors.
The Preparation of a ground contamination report to include the testing of soil within the
decommissioned installation to demonstrate contamination levels are no greater than
those submitted in Operators application site reports.
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The Pollution Prevention and Control Act 1999
Permit Reference: LAPPC
Appendix 1 – Site Plan
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The Pollution Prevention and Control Act 1999
Permit Reference: LAPPC
Appendix 2 – Overall Site General Arrangement (including Waste and raw
material storage)
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The Pollution Prevention and Control Act 1999
Permit Reference: LAPPC
Appendix 3 Solvent Management Plan Calculation diagram
Inputs of organic solvent in the time frame over which the
mass balance is being calculated (I)
I1
I2
The quantity of organic solvents or their quantity
in mixtures purchased which are used as input
into the process/activity (including organic
solvents used in the cleaning of equipment, but
not those used for the cleaning of the products).
The quantity of organic solvents or their quantity
in mixtures recovered and reused as solvent input
into the process/activity. (The recycled solvent is
counted every time it is used to carry out the
activity.)
Outputs of organic solvents in the time frame over which the mass balance is
being calculated (O)
O1
Emissions in waste gases.
O2
Organic solvents lost in water, if appropriate taking into account
waste water treatment when calculating O5.
O3
The quantity of organic solvents which remains as contamination or
residue in products output from the process/activity.
O4
Uncaptured emissions of organic solvents to air. This includes the
general ventilation of rooms, where air is released to the outside
environment via windows, doors, vents and similar openings.
O5
Organic solvents and/or organic compounds lost due to chemical or
physical reactions (including for example those which are destroyed,
e.g. by thermal oxidation or other waste gas or waste water
treatments, or captured, e.g. by adsorption, as long as they are not
counted under O6, O7 or O8).
O6
Organic solvents contained in collected waste.
O7
Organic solvents, or organic solvents contained in mixtures, which
are sold or are intended to be sold as a commercially valuable
product.
O8
Organic solvents contained in mixtures recovered for reuse but not as
input into the process/activity, as long as not counted under O7.
O9
Organic solvents released in other ways.
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The Pollution Prevention and Control Act 1999
Permit Reference: LAPPC/041/07/v1
EXPLANATORY NOTES
These notes do not form part of the Permit
For the purposes of this document, the Regulator is Newport City Council.
This Permit is issued on the basis that the information provided by the applicant in support of the
application for Permitting was neither false nor misleading. Any change affecting the accuracy of such
information shall be promptly notified, in writing, to the Newport City Council at the contact address
detailed in Section 4 below.
This Permit must not be taken to replace any responsibilities the Operator has under workplace health
and safety legislation. Neither does it detract from any statutory requirement such as the need to
obtain Planning Permission, Building Regulations approval, hazardous substances consent, or a
discharge consent from the water resources regulator.
The Permit includes conditions that must be complied with. It should be noted that aspects of the
operation of the installation which are not regulated by those conditions are subject to the best
available techniques, BAT, which shall be used to prevent or where that is not practical, reduce the
emissions from the installation.
Please refer to “BAT Definitions” below.
Information
Your attention is drawn to the following publications that are relevant to your process:
i. Environmental Permitting (England and Wales) Regulations 2010 SI No 675 as amended
ii. The Pollution Prevention and Control Act 1999
iii. Council Directive 2010/75/EU of the European Parliament and of the Council on the 24
November 2010 on industrial emissions (integrated pollution prevention and control)
iv. Council Directive 67/548/EEC of 27th June 1967 on the approximation of laws, regulations
and administrative provisions relating to the classification, packaging and labelling of
Dangerous Substances also known as the Dangerous Substances Directive.
v. Draft Sector Guidance Note IPPC SG11 ‘
vi. General Guidance Manual on Policy and Procedures for A2 and B Installations’
1. BAT – Definitions
BAT is defined in Article 3(10) of the Industrial Emissions Directive 2010/75/EC. As follows:
"Best available techniques" means the most effective and advanced stage in the development of
activities and their methods of operation which indicates the practical suitability of particular
techniques for providing the basis for emission limit values and other permit conditions designed to
prevent and, where that is not practicable, to reduce emissions and the impact on the environment as
a whole.
"available techniques" means those developed on a scale which allows implementation in the relevant
industrial sector, under economically and technically viable conditions, taking into consideration the
cost and advantages, whether or not the techniques are used or produced inside the United Kingdom,
as long as they are reasonably accessible to the Operator.
"best" means most effective in achieving a high general level of protection of the environment as a
whole.
"techniques" includes both the technology used and the way in which the installation is designed,
built, maintained, operated and decommissioned.
In the context of this permit, 'activity' comprises the whole activity including the treating, handling and
storage of any materials used and products and waste produced by the activity.
Carmarthenshire County Council is statutorily obliged to include conditions in any permit they issue
which are designed to ensure the activity is operated using the 'Best Available Techniques’. EP
regulations principles are that ‘Installations should be operated in such a way that:
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Permit Reference: LAPPC/041/07/v1
(a) all appropriate preventative measures are taken against pollution, in particular through the
application of best available techniques (BAT);
(b) no significant pollution is caused’.
(c) The best available techniques shall be used to prevent or where that is not practical, reduce
the emissions from the installation in relation to that aspect of the operations of the installation
which is not regulated by any other condition of this permit.
It should be noted that Section 6 (1) and (2) of Schedule 7A to the Environmental Permitting (England
and Wales) (Amendment) Regulations 2013 specifies that the Regulator must ensure that it is
informed of developments in best available techniques and the publication of any new or updated
BAT conclusions. This requirement is as defined in Articles 3(10), 3(11), 3(12) and 3(14) of the
Industrial Emissions Directive 2010/75/EU.
In considering BAT, The Regulator would expect the Operator to have regard to all relevant EPR
sectoral or other technical guidance, including BAT Conclusions and BAT Reference Documents
published by the European Commission and technical guidance published by Natural Resources
Wales, the Environment Agency and other relevant regulatory authorities.
2. APPEALS
If you are aggrieved by any of the Conditions of the Permit, you should initially contact the local
Carmarthenshire County Council Office at the address or telephone number detailed in Section 4
below. Further information on your right of appeal and the appeals procedure is contained in
Regulation 31 and Schedule 6 of the Regulations.
To appeal you must supply in writing:
(a) A statement of the grounds of appeal;
(b) A copy of any relevant application;
(c) A copy of any relevant environmental permit;
(d) A copy of any relevant correspondence between the appellant and the regulator;
(e) A copy of decision or notice which is the subject matter of the appeal; and
(f) A statement including whether the appellant wishes the appeal to be in the form of a hearing
or to be dealt with by way or written representation.
(g) The appeal must be made within 6 months of the decision or deemed decision.
Appeals must be sent to:
The Planning Inspectorate
Crown Buildings
Cathay’s Park
Cardiff
CF10 3NQ
A copy of the notice and documents must also be sent to the The Regulator at the address detailed in
Section 4 below.
3. SUBSISTENCE CHARGES
An annual subsistence charge will be payable in respect of the Permit in terms of any relevant
charging scheme made under Section 65 of the Regulations and issued by Welsh Government,
copies of which are available from Carmarthenshire County Council.
4. ADDRESS AND TELEPHONE NUMBERS
The contact address and telephone number for all information to be reported in terms of the permit, is
as follows:
Newport City Council
Legal and Regulation
Civic Centre
Godfrey Road
NEWPORT
NP20 4UR
Telephone:
Fax:
Website:
Email:
01633 656656
01633 266575
www.newport.gov.uk
environmental.health@newport.gov.uk
The Pollution Prevention and Control Act 1999
Permit Reference: LAPPC/041/07/v1
5. REVIEW OF CONDITIONS
Under Environmental Permitting Regulations 2010 (SI 675) the legislation requires permits to be
‘reviewed’ periodically but does not specify a frequency. It is considered that a frequency of once
every eight years shall be adequate with reference to Regulation 34(1) Environmental Permitting
(England & Wales) Regulations 2010 (SI 675). Where significant pollution is encountered or where
there are changes in BAT or where the operational safety of the activity requires other techniques to
be used an immediate review shall be undertaken.
6. PROPOSED CHANGE IN OPERATION OF INSTALLATION
Notification of Changes under Regulation 20
If an Operator proposes to make a change in operation of the installation, they must, at least 14 days
before making a change, notify the regulator in writing. The notification must contain a description of
the proposed change in operation. It is not necessary to make such a notification if an application to
vary this permit has been made and the application contains a description of the proposed change.
“Change in operation” means a change in the nature or functioning or an extension of the installation
which may have consequences for the environment.
An example form is included in Part C of the ‘General Guidance Manual on Policy and Procedures for
A2 and B Installations’ and can be downloaded as a word document from:
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/69498/env-permittinggeneral-guidance-cd.pdf
These notifications are appropriate for changes that are not likely to require the variation of permit
conditions.
7. ENFORCEMENT & OFFENCES
Offences under Regulation 38 of the Environmental Permitting Regulations are to:
1) It is an offence for a person to
(a) Contravene regulation 12(1): or
(b) knowingly cause or knowingly permit the contravention of regulation 12(1)(a)
2) It is an offence for a person to fail to comply with or to contravene an environmental permit
condition.
3) It is an offence for a person to fail to comply with the requirements of an enforcement notice or of a
prohibition notice, suspension notice or landfill closure notice or mining waste facility closure notice.
4) It is an offence for a person(a) To fail to comply with a notice under regulation 60(1) requiring the provision of information,
without reasonable excuse;
(b) To make a statement which the person knows to be false or misleading in a material
particular, or recklessly to make a statement which is false or misleading in material particular,
where the statement is madei. In purported compliance with a requirement to provide information imposed by or under a
provision of these Regulations.
ii. For the purpose of obtaining the grant of an environmental permit to any person, or the
variation, transfer in whole or in part, or surrender in whole or in part of an environmental
permit, or
iii. For the purpose of obtaining, renewing or amending the registration of an exempt facility;
(c) Intentionally to make a false entry in a record required to be kept under an environmental
permit;
(d) With intent to deceivei. To forge or use a document issued or authorised to be issued or required for any purpose
under an environmental permit condition, or
ii. To make or to have in the person’s possession a document so closely resembling such a
document as to be likely to deceive.
5) It is an offence for an establishment or undertaking to(a) fail to comply with paragraph 14(3) or (4) of Schedule 2; or
(b) intentionally make a false entry in a record required to be kept under that paragraph.
6) If an offence is committed by a person under this regulation is due to the act or default of some
other person, that other person is also guilty of the offence and liable to be proceeded against and
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Permit Reference: LAPPC/041/07/v1
punished accordingly, whether or not the proceedings for the offence are taken against the firstmentioned person.
8. PENALTIES
Penalties under Regulation 39 of the Environmental Permitting Regulations are:
1. A person guilty of an offence under regulation 38(1), (2) or (3) is liable(a) On summary conviction to a fine not exceeding £50,000 or imprisonment for a term not
exceeding 12 months, or to both; or
(b) On conviction on indictment to a fine or imprisonment for a term not exceeding 5 years, or
both.
2. In relation to an offence committed before the commencement of section 154(1) of the Criminal
Justice Act 2003(a), paragraph (1)(a) has effect as if for “12 months” there were substituted “6
months”.
3. A person guilty of an offence under regulation 38(4) is liable(a) On summary conviction to a fine not exceeding the statutory maximum; or
(b) On conviction on indictment to a fine or imprisonment for a term not exceeding 2 years, or to
both.
4. An establishment or undertaking guilty of an offence under regulation 38(5) is liable on summary
conviction to a fine not exceeding level 2 on the standard scale.
9. TRANSFER OF PERMIT
The permitted Operator who wishes to transfer the whole or part of the permit to a person who
proposes to carry out the activity in the holder’s place may do so in accordance with Regulation 21.
Both the Operator and the proposed transferee shall jointly make an application to the regulator to
effect the transfer. An application shall include the permit and any fee prescribed in respect of the
transfer under Regulation 65 and shall contain the Operator’s and the proposed transferee’s contact
details.
10. RECORDED SYSTEMS, PROCEDURES OR INFORMATION RECORDING/ RETURN
REQUIREMENTS
Where a Condition requires any system, procedure or information record/return, the Operator may
demonstrate compliance by making use of any relevant existing written system used for any other
purpose and which meets the requirements of the relevant Condition.
11. SYSTEMATIC ASSESSMENT (AND REVIEW)
Where a condition of the permit requires a “systematic assessment (and review)” the assessment
should be undertaken in a methodical and arranged manner. If you require guidance on the scope or
extent of any assessment (and review) required to be undertaken, you should contact your local
Carmarthenshire County Council office at the address or telephone number given above in Section 4.
12. SURRENDER OF PERMIT
The Operator may apply to surrender their permit under Regulation 25. The application must be
accepted if Schedule 5 Part 1 Regulation 14 of the Environmental Permitting (England and Wales)
Regulations 2010 as amended and Article 22 of the Industrial Emissions Directive 2010/75/EU have
been met. The Operator will be required to supply evidence that necessary measures have been
taken to (a) avoid a pollution risk resulting from the operation of the regulated facility and (b) to return
the site of the regulated facility to a satisfactory state, having regard to the state of the site before the
facility was put into Operator.
13. INSPECTIONS
Under Environmental Permitting Regulations 2010 (SI 675) the legislation requires the regulator
undertake appropriate periodic inspections of regulated facilities. Inspections should be undertaken in
accordance with a risk assessment and following on from any complaints or applications.
END NOTE