Decision Document Part A
Q57/15 Version 0
Decision Document for ERE Development Ltd
Permit Number P0387/12A
CONDITION(S)
1.1The permitted
activities
1.2.1 The site
1.3 Overarching
Management
1.4 Pre-operation1.4.1
1.4.2
conditions
1.4.3
1.4.4
1.4.5
1.4.6
Page 1 of 11
JUSTIFICATION
The permit relates to the burning of non-hazardous waste in a co-incinerator. The nominal mass of waste that can be burned is
20 tonne/hr which is stated in table 1.1 as required by Article 45(1)(b) of the Industrial Emissions Directive 2010/75/EU
(IED). The permit also covers directly associated activities including the combustion of virgin timber.
The IED Article 3(41), defines co-incineration plant as any plant whose main purpose is the generation of energy or material
products from waste. The proposed installation is designed to achieve an electrical output of 0.8MWe/tonne of waste or
greater. The main purpose of the plant is the generation of electricity. The activity is prescribed under Schedule1, Section 5.1
Incineration and Co-incineration of waste, para (c) - an installation involving the incineration of non-haz waste in a coincinerator with a capacity of 3 tonnes or more per hour.
The site boundary is area highlighted by the black line on the site plan and incorporates all activities associated with the
operation.
This is a standard condition requiring a management system, organisational structure and resources to ensure compliance
with the conditions of the permit.
Condition 1.4.1. – The operator is to provide details of the on site water drainage plans.
Condition 1.4.2. – The Permitted Installation shall not be brought into operation until a commissioning programme has been
agreed by the Chief Inspector. This is required to ensure emissions are managed during the hot commissioning phase of the
installation.
Condition 1.4.3. – requires a monitoring proposal for post commissioning noise levels. This is included to ensure that actual
noise emissions are in line with those predicted in the permit application.
Condition 1.4.4. – is required to ensure the waste quality is managed and does not result in the co-incinerator feed material
having high concentration of halogens or mercury. The exact means of doing this has yet to be agreed, however it is likely
that it will involve the sampling of waste received on site and the setting of upper concentrations for substances that require
control. Further measures such as supplier agreements and third party audits are also likely to be required.
Condition 1.4.5. – is included to ensure that the sampling facilities for emissions to air from the co-incinerator meet the
requirements of BS EN 13284 (Stationary Source Emissions – Determination of low range mass concentration of dust) and
BS EN 15259 (Stationary Source Emissions – “Requirements for the measurement sections and sites and for the
measurement objectives, plan and report”).
Condition 1.4.6 – The environmental impact with a 39 m stack is considered acceptable. However, IPRI’s assessment showed
that for a modest increase in stack height a significant reduction in the environmental impact could be achieved.
Decision Document Part A
Q57/15 Version 0
1.5 Off site conditions
1.6 Minor operational
changes
There are no-off site conditions.
These are standard conditions requiring agreement from the Inspectorate before carrying out certain changes.
2.1 In process controls
Conditions 2.1.1 to 2.1.4 are standard conditions.
Conditions 2.1.5 to 2.1.11 include the requirements of the Chapter 4 of IED as detailed in the table below.
2.2.1 Emissions into air
(other than odour, noise
and vibration)
Page 2 of 11
Permit Condition
Condition 2.1.5
Condition 2.1.6
Condition 2.1.7
Condition 2.1.8
Condition 2.1.9
IED Condition
Article 50 paragraph 2.
Annex VI Part 6 (2.1) (b)
Article 50 paragraph 4
Article 45 paragraph 1(f)
Article 47
Condition 2.1.10
Article 46 paragraph 6
Condition 2.1.11
Condition 2.1.12
Article 45 paragraph 1 (a).
Article 50 paragraph 2.
Comments
850ºC for 2 seconds requirement for co-incineration.
Temperature measurement requirement.
The automatic stopping of waste feed.
Requirement to cease operation if CEMs fail.
Requirement to shut down in case of breakdown of pollution
control equipment.
Requirement to shut down after 4 hours of emission
exceedances and up to a maximum of 60 hours of exceedances
in a year.
Categories of non-hazardous waste which may be accepted.
This condition prevents the combustion of waste which
contains more than 1% halogenated organic compounds as this
requires a different combustion temperature.
The ELVs to air as set out in the permit are those obligated by Annex VI of IED.
The proposed installation will not give rise to significant ground-level pollution (as per Article 46, paragraph 1 of IED) and
no statutory emission limit or objective will be exceeded due to emissions from the installation.
The applicant and NIEA assessed the impact of emissions to air using the maximum daily average values specified in Annex
VI of IED. The modelling was based on the assumption the plant will be emitting at the maximum daily average values for
100% of the time.
A summary of the results from the applicant’s (using AERMOD) and NIEA’s (using ADMS) air dispersion modelling is
tabulated. The background concentrations included contributions from other local sources.
Decision Document Part A
Q57/15 Version 0
Air Quality
Objective
Predicted
max conc
NIEA
Model
(μg/m3)
Predicted
max conc
Applicants
Model
(μg/m3)
Background
conc
(μg/m3)
Air
quality
objective
(μg/m3)
% of air quality
objective impacted
based on NIEA
Model
PEC
% of air quality
objective impacted
based on Applicant
Model
PEC
NO2 annual mean
7.421
0.97
11.85
40
48.18%
th
NO2 99.79 %ile
52.242
24.6
23.7
200
37.97%
of 1hr mean
NOx annual mean
7.42
2.41
16.81
30
80.76%
th
SO2 99.2 %ile of
24.7
5.91
30.4
350
15.7%
max 24 hour conc
SO2 99.7th %ile of
1hr mean
26.07
20.89
30.4
125
45.18%
concentrations
SO2 annual mean
1.862
0.6
15.2
20
85.3%
PM10 annual mean
1.2
0.42
12.9
40
35.3%
th
PM10 90.4 %ile
0.4
0.12
12.9
50
26.6%
of 24hr mean
1
: 100% NO2 as per EA Guidance http://www.environment-agency.gov.uk/business/regulation/38791.aspx
2
: 50% NO2 as per EA Guidance http://www.environment-agency.gov.uk/business/regulation/38791.aspx
32.0%
24.15%
64.07%
10.37%
41.03%
79%
33.3%
26.04%
PEC is the impact from the installation on top of background concentrations.
Representative background air quality concentrations were taken at a location 1.6 km from the site.
The conclusion from the NIEA dispersion modelling is that even using worse case emission concentration the local air quality
objectives will not be threatened.
According to the NIEA modelled data the SO2 annual mean is increased by 9% to 17 μg/m3 , which when combined with the
background gives a total predicted environmental concentration of 85% of the air quality objective. This includes a
contribution of 76% of the air quality objective from the existing background concentration. However, the modelled value is
very conservative for several reasons:
- The model assumed the plant will be emitting at the maximum daily average value prescribed in Annex VI of IED for
Page 3 of 11
Decision Document Part A
Q57/15 Version 0
-
100% of the time.
The sulphur content of wood is typically very low at <0.2%; and
Similar installations are known to operate at 1/10th of the SO2 emission limit value
The Conditions 2.2.1.2 to 2.2.1.7 include the requirements of the Chapter IV of IED as detailed in table below.
Condition 2.2.1.1 lists the point emissions sources from which emission to air are permitted. The source permitted is the coincinerator stack.
Permit Condition
IED Condition
Condition 2.2.1.2 Annex VI Part 6, (2.1) & Annex VI Part
3
Comments
Emissions limit values to air should have been
determined for the co-incineration of waste using the
mixing rule in Annex VI Part 4 of IED. The operator
requested the flexibility to combust any ratio of virgin to
waste wood so the elv’s set out in Annex VI Part 3 of
IED assuming 100% combustion of waste wood were
applied.
Condition 2.2.1.3
Annex VI Part 3, (1)
A 11% oxygen reference condition has been included.
Condition 2.2.1.4
Condition 2.2.1.5
Annex VI Part 6 (1.3) & Annex VI Part
8 (1.2)
Determination of half hour averages, including
confidence intervals.
Condition 2.2.1.6
Annex VI Part 8 (1.1)
Condition 2.2.1.7
Condition 2.2.1.8
Annex VI Part 8 (1.2)
Article 53
Compliance criteria have been included in line with
Annex VI of IED.
Discarding of values due to malfunction or maintenance.
Includes the requirement of for the management of dry
residues such as ash.
Condition 2.2.1.10 is a standard condition requiring for the best available techniques to be used to control fugitive emissions
to air.
2.2.2 Emissions into
water
2.2.3 Emissions in to
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The emission limits in condition 2.2.2.2 are for surface water run off only.
Condition 2.2.2.3 & 2.2.2.4 are standard conditions for BAT and the protection of surface waters.
All process water discharges will be to sewer. The elvs have been set from the NI Water Consent to Discharge Trade Effluent
Decision Document Part A
sewer
2.2.4 Emissions into land
2.2.5 Emissions to
groundwater
2.2.6 Odour
2.3 Management
2.4 Efficient use of raw
materials
2.5 Waste Handling and
Storage
2.6 Waste recovery and
disposal
2.7 Energy Efficiency
2.8 Accident prevention
and control
2.9 Noise and vibration
2.10 Monitoring
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Q57/15 Version 0
issued 14 Nov 2012, and a monitoring requirement for a monthly 24 hour composite sample.
There are no process emissions to land from the proposed facility.
There are no process emissions to groundwater from the proposed facility.
These are standard conditions relating to control of odour on site.
Standard conditions for the training of staff, maintenance of equipment and procedure for incidents
Conditions 2.4.1 to 2.4.3 are standard conditions for the efficient use of raw materials, water and waste minimisation.
Conditions 2.5.1 and 2.5.2 are standard conditions for the storage of waste on site.
Conditions 2.6.1 -2.6.4 are standard conditions for the management and recording of waste sent for recovery/disposal from
and on site.
Condition 2.6.5 is added to include the requirement of the IED Article 53 requiring the harmfulness and amount of residues to
be minimised and that they be recycled on site where appropriate.
Condition 2.7.1 and 2.7.2 are standard conditions for the management of energy on site.
Condition 2.7.3 is included as it is a requirement of IED Article 50(5) requiring that heat from the co-incineration plant is
recovered as far as practicable.
Condition 2.8.1 is a standard condition for a plan to prevent and control accidents on site.
Conditions 2.8.2 and 2.8.3 are included as they are a requirement of Article 46(5) of IED for the control of spills and
firewater. An IMP item has been included to address this.
Conditions 2.9.1 and 2.9.2 are standard conditions for the control of noise. The conclusion of modelling exercise was that
noise limits are predicted to be below those presented in BS4142 and WHO guidance and the site will be operating to BAT.
The operator is required to assess the actual impact of noise emissions once the plant has been commissioned. This is
required under Section 6 of the permit.
Condition 2.9.3 was at the request of the district council and restricted the operation of the wood chipper to 08:00-18:00
Mon-Sat and not at all on Sunday or public holidays.
Conditions 2.10.1, 2.10.2, 2.10.3, 2.10.5& 2.10.8 are standard permit conditions. Conditions 2.10.4, 2.10.6 & 2.10.7 include
the requirement of IED.
Condition 2.10.4 is included as it is a requirement of IED Annex VI Part 6 (1.2) for parallel measurement for calibration and
continuous monitors.
Condition 2.10.6 is included to deliver the requirements of IED Annex VI Part 6 (1.2) and BS EN 14181 clause 5.4.
requirement for accredited quality assurance according to EN ISO/IEC 17025.
Condition 2.10.7 specifies BS EN 15259 in accordance with IED Article 48(3) which requires the competent authority to lay
down requirements for the sampling or measurement points.
Decision Document Part A
Q57/15 Version 0
2.11 Closure and
Decommissioning
2.12 Multi Operator
installations
2.13 Transfer to effluent
treatment plant
3 –Records
4 – Reporting
Conditions 2.11.1 to 2.11.4 are standard conditions requiring a closure plan and notification of closure.
5 - Notification
Condition 5.1 is a standard condition requiring the notification of certain incidents. Notification of continuous emission
monitors (CEMS) failure is also required.
IMPROVEMENT
PROGRAMME
IMP 6.1- The Operator shall give a written notification of when commissioning is complete.
This is required so the Inspectorate knows when commissioning has ceased and operation had begun.
IMP 6.2 – Environmental commissioning report
This is required to verify operation in accordance with Article 50(4) and Annex VI Part 6 (2.2) of IED.
IMP 6.3 – Qual 2 of CEMs
This is required in order to specify a time for the compilation of Qual 2 procedure as per Condition 2.10.4 and for parallel
measurement calibration of continuous monitors.
IMP 6.4 – Noise Monitoring
This is required to validate the conclusion for the monitoring report submitted as part of application.
IMP 6.5 – Marking of drainage
This is required to ensure drainage is suitably identified to prevent unauthorised discharges.
IMP 6.6 – Demonstration of boiler cleaning techniques
This is required to ensure boiler surfaces are cleaned as far as practicable to limit de-novo synthesis of dioxin/furans.
IMP 6.7 – Testing of Ash characteristics
This is required to aid in demonstrating Condition 2.6.5 and thus ensuring appropriate disposal or recovery.
IMP 6.8 – On site storage
This is required to ensure compliance with condition 2.8.3 and requirements of Article 46(5) of IED.
IMP 6.9 – Environmental Monitoring Programme
Page 6 of 11
This is a single operator site
There are no transfers to an effluent treatment plant.
Condition 3.1 is standard condition for the maintenance of records.
Conditions 4.1 to 4.6 are standard conditions.
Condition 4.2 requires the submission of reports as specified in the permit. Additional monitoring and reporting is required on
account of Annex VI Part 6 (2.1) (b) of IED for monitoring of process operating parameters.
Condition 4.6 is added to ensure the reporting of waste recovered on site is included in permit.
Decision Document Part A
Q57/15 Version 0
This is required to confirm that the actual environmental impact is in line with that predicted by the modelling.
CONSULTEE
COMMENTS
Health and Social
Services Board
District Council
Food Standards Agency
NIEA Water
Management Unit
NIEA Conservation
Designations and
Protection
Health and Safety
Executive (NI)
Londonderry Port
Authority
IMPACTS ON THE
ENVIRONMENT
European sites & ASSI
Other environmental
Page 7 of 11
Comments and measures in permit where applicable
The Public Health Agency (PHA) commented that the primary potential health concerns in relation to the facility include
emissions from the process. With the implementation of the mitigation measures identified, the PHA is reassured that the
potential human health effects due to emissions from this biomass fuelled power plant facility, where non-hazardous waste
wood is incinerated, will be minimal.
The main points of Derry City Council’s response to consultation in relation to PPC where;
(i) restriction of wood chipping operations to 08:00-18:00 Monday to Saturday and not at all on Sunday or public holidays
(ii) the stack should be 39 m based on the Air Quality Impact Assessment.
On the basis of the proposal to use non-hazardous waste it seems unlikely that activities planned for the site will have an
adverse impact on the human food chain provided the plant is operated and maintained by appropriately trained staff.
The limits and parameters associated with the discharge to surface water have been determined in consultation with WMU.
The site was not previously regulated and there has been no pollution incidents recorded in relation to the site.
The NIEA Conservation Designations and Protection division of the NIEA have determined the proposal to unlikely have a
significant effect on any site selection features of any designated site. The proposed installation is 400m from River Foyle
and 1.2 km from Faughan River. Both these are designated as ASSI and RAMSAR sites. There are no direct discharges to
these waterways from the site apart from storm water run off. The air dispersion model predicted concentrations of emissions
to be below air quality objectives.
No comments on the proposal.
No comments on the proposal.
The River Foyle and Faughan River are Special Areas of Conservation (SAC). The NIEA Conservation Designations and
Protection division of the NIEA determined the proposal unlikely to have a significant effect on any site selection features of
any designated site. The proposed installation is 400m from River Foyle and 1.2km from the Faughan River. The proposed
installation does not have any direct process discharges from the site to these waterways. Storm water off is to the River
Foyle. There are emission limit values within the permit for the storm water which will prevent an adverse impact on the
River Foyle. The air dispersion modelling predicted concentrations of emissions to have no adverse impact on air quality
objectives. Condition 2.8.3 and IMP6.8 have been included requiring retention of any potentially contaminated fire water.
Decision Document Part A
receptors
People
Q57/15 Version 0
The site is located 6km to the NE of Londonderry on the east bank of the River Foyle. It is bounded on the North and West
by Temple Road and to the east by Maydown Road with the Lisahally Industrial Estate situated to the SE of the proposal. The
nearest sensitive receptors are located 350m to the south. The Strathfoyle housing estate is located approximately 780m SE
and the houses along Culmore Point on the opposite side of the River Foyle are located approximately 550m N.
Impact on air Quality
The dispersion of NOx SO2, and PM10, emitted by the proposed installation were modelled using AERMOD and ADMS
dispersion modelling software. The result of the exercise led to the conclusion that local air quality standards will not be
exceeded by the proposed installation. The assessment took into account the background concentrations which includes
contributions from other local sources. See section 2.2.1.
Total particulate emissions to air from co-incineration will be controlled via the limits specified in IED.
The ground level concentrations of the heavy metals were also modelled and found to be acceptable.
The are 3 Local Air Quality Management Areas within the Derry area. Derry City AQMA encompasses parts of the Creggan
Road, Windsor Terrace on Infirmary Road, Creggan Street and Marlborough Terrace on Lone Moor Road. This AQMA is
located 6.6 km from the proposed location. Dale’s Corner AQMA incorporates all on Ebrington Terrace and Columba
Terrace on Limavady Road and No1-19 Glendermott Road. This AQMA is located 6km from the proposal. The third AQMA
is at the junction of the Buncrana Road/ Racecourse Road and incorporates all of St Patrick’s Terrace, all of Maybrook
Terrace and No. 1-12 Collen Terrace to the South East. This AQMA is located 4.5km from the proposal.
At over 1 km from the installation the predicted long term air quality concentration for NO2 resulting from the installation is
less than 0.5 μg/m3 i.e. less that 1.25% of the Air Quality Objective for NO2. The impact on the AQMA will not be
significant.
Both PCBs and PAHs are for the most part either destroyed or their formation prevented due to the high temperatures
maintained during the incineration process. Any PCBs or PAHs which remain in the exhaust gas would be absorbed by the
injected activated carbon before release to the environment. The operator is required to monitor the emissions of PCBs and
PAHs every three months for the first 12 months of operation and bi-annually thereafter.
The emission limit as laid down in IED, for dioxins and furans from the proposed facility is 0.1ng/m3 TEQ (Toxicity
equivalents).
Page 8 of 11
Decision Document Part A
Q57/15 Version 0
The report “Dioxins and Dioxin-like PCBs on the UK Environment” published by DEFRA in 2002 quotes typical mean
ambient dioxin concentrations in the urban environment as 103fg/m3. Whilst there are no statutory air quality standards for
dioxins, using NIEA modelling data at the point of maximum impact the predicted increase in the long term concentration
would be some 2.53% of the typical background value.
Impact on Food Chain
The primary route of exposure for dioxins is ingestion with inhalation being a minor route of exposure.
The applicant’s initial application stated a daily dry deposition rate of dioxins of 0.08053ng/m2/day. Clarification was sought
and the dioxin assessment calculation was repeated to give 8.64*10-5 ng/m2/day compared to NIEA calculated daily dry
deposition of 4.6*10-4 ng/m2/day. Using the applicant’s modelling data at the point of maximum impact the predicted
increase to the typical soil background value over a 25 year period would be 3.94%. Using NIEA’s modelling data at the
point of maximum impact the predicted increase to the typical soil background value over a 25 year period would be 21.06%.
Assumptions made in the calculations:






Dry deposition velocity of 0.2cm/s used
Environment Agency H1 Annex F – Air Emissions recommend the value of 3 as a nominal factor to convert dry
deposition to total deposition.
UK Soil and Herbage Pollutants Survey 2007 gives mean measured value of dioxins in NI urban soils of 1.57 ng/kg.
Soil core samples taken to depth of 5cm.
Depth of soil used to calculate the total deposition was 5cm in line with the UK Soil and Herbage Pollutant Survey
Average Bulk soil density for Northern Ireland from the within the UK Soil and Herbage Pollutants Survey 2007
ranges between 390 kg/m3 and 1333 kg/m3 (dry basis). The average value of 750kg/m3 was used.
No removal of PCCD/F takes place from the soil over the 25 year period.
Calculations are based on the point at which the maximum ground level concentration occur assuming operation of 8760
hours per year for 25 years.
The addition of IMP6.9 to confirm that the actual environmental impact is in line with that predicted by the modelling.
The Scientific Committee for Food established a tolerable weekly intake of 14pg/kg TEQ/kg of body weight a week for
dioxins. The Committee on the Toxicity of Chemicals in Food, Consumer Products and the Environment recommend a
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Decision Document Part A
Q57/15 Version 0
tolerable daily intake of 2 picograms WHO-TEQ/kg body weight/day. This is based on the most sensitive effect of TCDD in
laboratory animals, namely adverse effects on the developing foetus resulting from exposure in utero. This 2 picogram WHOTEQ/kg body weight/day value has been used in the screening tool put forward by the operator. Using the screening method
derived by SNIFFER the proposed facility will at worst case contribute to 7% of the tolerable daily intake. This 7% of daily
intake is for the hypothetical most exposed individual whose entire diet is presumed to derive from the point of maximum
ground level pollutant concentration.
The SNIFFER method was also applied to emission of heavy metals emitted at emission limit values. The predicted daily
intakes were found to be acceptable on an individual basis with no further assessment required. Annex VI of IED groups
together certain pollutants i.e. Cd & Th; Sb, As, Pb, Cr, Cu, Co, Mn, Ni, V therefore the impact of the %TDI will be greatly
reduced.
Page 10 of 11
Annual
emission
(g/yr)
Ground
level
conc
(ug/m3)
Daily
intake
Pollutant
Effective Annual
stack
Emission
height (m) (tonnes/yr)
(mg/kg/day)
TDI
(mg/kg/day)
Source
of
TDI
Intake
as
% of
TDI
Further
assessment
required?
Antimony
40
0
0.00E+00
0.00E+00
4.00E-04
IRIS
0%
No
Arsenic
40
0.5
500000
1.76E-02
2.30E-04
2.00E-03
WHO
11%
No
Cadmium
40
0.05
50000
1.76E-03
2.93E-04
1.00E-03
WHO
29%
No
Chromium VI
40
0.5
500000
1.76E-02
2.79E-04
3.00E-03
IRIS
9%
No
Lead
40
0.5
500000
1.76E-02
1.79E-04
6.00E-03
WHO
3%
No
Manganese
40
0.5
500000
1.76E-02
2.49E-04
1.40E-01
IRIS
0%
No
Mercury
40
0.05
50000
1.76E-03
6.10E-06
7.00E-04
WHO
1%
No
Nickel
40
0.5
500000
1.76E-02
2.51E-04
1.10E-02
WHO
2%
No
Thallium
40
0.05
50000
1.76E-03
2.41E-05
8.00E-05
IRIS
30%
No
Vanadium
40
0.5
500000
1.76E-02
1.10E-04
9.00E-03
IRIS
1%
No
Dioxin/furan
40
0.1
3.52E-09
1.46E-10
2.00E-09
WHO
7%
No
Decision Document Part A
Q57/15 Version 0
Noise:
The conclusion of modelling exercise was that noise limits are predicted to be below those presented in BS4142 and WHO
guidance and the site will be operating to BAT. The Operator is required to validate the re accesses the actual impact of noise
emissions one the plant has been commissioned. This is required under Section 6 of the permit.
Draft Permit Discussion
with Operator
Draft permit shared with Operator via email on the 15th Jan 2013. Comments received on the 06th March 2013 with no
concerns raised to the content of the permit or improvement programmes.
Public Participation
Directive
Draft determination was posted on website and public registers on the 07 March 2013. No comments were received in
relation to the draft determination.
Completed by …………………………. Keith Bradley
Date: 09/04/2013
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