Regulatory Compliance Requirements for the Operation of Talbotts Biomass Heating Appliances

Transcription

1 Regulatory Compliance Requirements for the Operation of Talbotts Biomass Heating Appliances Background to Talbotts Biomass Energy Systems (Talbotts) Talbotts are the largest manufacturer of biomass air heaters and boilers. The company produces a broad spectrum of biomass appliances to match the diverse range of biomass and waste to energy issues within the renewable energy and woodworking sectors. Talbotts has over 5,000 working installations world-wide, including the UK, France, Ireland, USA, Canada, Japan and Australia. Talbotts biomass appliances operate in the Domestic, Commercial, Industrial and Public sectors, and have been installed extensively in the Woodworking Industry to recover energy from offcuts and other waste biomass arising from on-site process operations 1. The range of biomass appliances includes hand fed units for the combustion of solid wood offcuts with thermal outputs from 25 kw th to 150 kw th, to automatic units for the clean and efficient combustion of extracted dust, chips, shavings and shredded waste wood, with thermal outputs from 50 kw th up to 2 MW th. Talbotts biomass heaters are classified as exempt appliances under the Clean Air Act 1993 regulations 2, and so can be operated in urban areas where Smoke Control Areas have been declared by Local Authorities. Typical biomass fuels utilised in Talbotts appliances include; softwood; woodchip; Oriented Strand Board (OSB); forest residues; hardwood; blackboard; miscanthus; pallets; short rotation coppice; Melamine Faced Chipboard (MFC); cardboard; packaging; hardboard; wood pellets; chipboard; Medium Density Fibreboard (MDF); and energy crops. Regulatory Issues Associated with Biomass Combustion Air Quality Regulations The UK has a comprehensive range of legislation to protect the environment and to control the release of pollution from industrial and other energy-intensive processes, including activities associated with the burning of fuels. The legislation includes statutory air quality standards for priority pollutants including nitrogen dioxide (NO 2 ), sulphur dioxide (SO 2 ) and particles (PM 10 and PM 2.5 ) which are specified for the protection of human health. Responsibility for local air quality management (LAQM) resides with Local Authorities as set out in Part IV of the Environment Act (1995), the Air Quality Strategy for England, Scotland, Wales and Northern Ireland 2007 and relevant Policy and Technical Guidance documents. The LAQM process places an obligation on all Local Authorities to regularly review and assess air quality in their areas, and to determine whether or not the air quality objectives are likely to be achieved. Where exceedences are considered likely, the local authority must then declare an Air Quality Management Area (AQMA) and prepare an Air Quality Action Plan (AQAP) setting out the measures it intends to put in place in pursuit of the objectives. The existence of an AQMA can impose stringent operational conditions on biomass combustion facilities in relation to their contribution to the inventory of the pollutant responsible for the declaration. However, Talbotts can provide add-on technology to further reduce emissions of appliances, at a relatively low cost, to meet the stringent requirements of such areas. Environmental Regulations Applicable to Biomass Combustion As a result of the major air quality problems of the smogs of the 1950s that resulted in the premature deaths of thousands of people due to exposure to high levels of smoke and SO 2 from coal fossil-fuel burning appliances, UK legislation has been developed to restrict pollutant emissions from a wide range of industrial process and energy utilisation activities. Aspects of the environmental regulations that apply to biomass combustion are summarised in the following sections. Clean Air Act 1993 Following the problems encountered during the smog events of the 1950s, a series of Clean Air Acts were introduced into UK statute that restricted the burning of fuels in domestic,

2 commercial and industrial facilities, in order to restrict pollutant emissions from fuel burning in order to protect the health of the local population. Medium sized boilers with thermal inputs of 45 to 20,000 kw th are subject to regulation under the Clean Air Act 1993 (NI: 1981 Clean Air Order) and are regulated by the appropriate Local Authority. This legislation requires that new biomass combustion plant have adequate particulate arrestment equipment, and that where emissions from plant appear excessive, measurements of emissions to the atmosphere can be required. Small biomass combustors with thermal inputs of <45 kw th are also regulated under the Clean Air Act Where the local authority has designated a Smoke Control Area, biomass combustion plant must be approved as an exempt appliance, or burn an approved smokeless fuel. Where an appliance is designed to burn fuel at a rate greater than 45.4 kg per hour, the Local Authority is required to approve the chimney height, and permission must be sought prior to installation (Article 14). The majority of Talbotts biomass combustion plant are classified as exempt appliances under the Clean Air Act 1993, and are suitable for operation within Smoke Control Areas. Environmental Permitting Regulations (England and Wales) 2010 Following on from the Clean Air Act legislation, the UK Government developed a more comprehensive range of environmental regulation that applied to the major polluting sectors of industry, including the burning of fuel and waste for the purpose of energy recovery. These regulations incorporate an integrated approach to pollution control that takes into account not only the impact on air quality, but considers also the impact on the aquatic environment and land. The regulations have evolved over recent years to incorporate European legislation such as the Integrated Pollution Prevention and Control (IPPC) Directive, the Waste Framework Directive and the Waste Incineration Directive (WID). The regulations that apply to the burning of biomass in the UK are currently defined within the Environmental Permitting Regulations (England and Wales) 2010, and the Pollution Prevention and Control Regulations (Scotland and Northern Ireland) which incorporate the requirements of the above European legislation. Depending upon the scale of operation, and whether the fuel is a non-waste, an exempt waste or a waste, biomass combustion will be regulated as either a Combustion activity or a Waste Incineration activity, subject to regulation by either the Local Authority or the Environment Agency. For combustion plant burning clean, non-waste biomass the appropriate regulatory authority is determined solely by the capacity of the appliance. If the net rated thermal input is between 20 MW th and 50 MW th, then the facility will be regulated as a Section 1.1 Part B(a) Combustion activity by the Local Authority. For appliances greater than 50 MW th, the appropriate regulatory authority is the Environment Agency. Appliances with thermal inputs of <20 MW th are not regulated under the Environmental Permitting Regulations, but are still subject to the requirements of the Clean Air Act Guidance on the regulatory classification of combustion plant burning clean biomass and waste biomass is provided by the Environment Agency 3 and DEFRA 4, based upon capacity and the type of fuel to be burned. 3 The Environment Agency, Combustion Activities (EPR 1.01), March Environmental Permitting Guidance, The Directive on the Incineration of Waste, For the Environmental Permitting (England and Wales) Regulations 2007, Updated October 2009, Version 2.0

3 WID DOES APPLY Regulatory Classification of Biomass Fuels Environment Agency Guidance on Combustion Activities The principal criterion for determining the regulatory status of a biomass combustion facility is whether or not the fuel is classified as a waste. Virgin Timber and Clean Biomass The combustion of virgin timber and clean biomass is regarded as solid fuel combustion and is regulated accordingly under the Environmental Permitting Regulations or the Clean Air Act 1993, depending upon the thermal input of the appliance. The Environment Agency gives specific guidance on whether the waste arising from forestry activities is classified as waste 5. In relation to potential fuels for biomass combustion, the guidance specifies that this material is not a waste and is not subject to WID regulation: Forestry operations can also produce large quantities of brash, wood chip and bark. If you use them for a specific purpose, such as energy production, then they are not classified as waste. Non-Virgin Timber and Waste Biomass Whether a material is a waste or not is determined by reference to the European Waste Framework Directive. Article 1(a) of the Directive defines waste as: (a) waste shall mean any substance or object in the categories set out in Annex I which the holder discards or intends or is required to discard; Accordingly, any biomass material that would ordinarily be discarded, or consigned for disposal, is a waste, and combustion of that material would be subject to the WID. However, the WID provides for exemption of certain waste biomass materials, as defined in the following flowsheet in the DEFRA guidance on the use of waste wood as a biomass fuel DEFRA, Waste Wood as a Biomass Fuel, Market Information Report, Waste Infrastructure Delivery Programme, April 2008

4 DEFRA Guidance on the Waste Wood Biomass Reference to Article 2(2) of the WID refers to whether the waste to be burned is an exempt waste. DEFRA guidance provides clarification on the interpretation of Article 2(2). Wood Waste (Article 2(2)(a)(iv)) 3.28 Plants treating only wood waste, with the exception of wood waste which may contain halogenated organic compounds or heavy metals as a result of treatment with woodpreservatives or coating, and which includes in particular such wood waste originating from construction and demolition waste, are excluded from the WID. Wood cannot be taken to include paper and card The Government recognises that some manufacturers producing, for example fibre board, do not use chemicals containing halogens or heavy metals in the manufacturing process. However, if the wood waste used for the manufacture of the fibre board was already contaminated, then the final product may be also contaminated (note: the WID doesn t specify at what point the contamination has to take place), consequently the exclusion might not be applicable. However, this is a question of fact and the onus is on the operator of the incineration / co-incineration plant to demonstrate that the wood waste originally used did not arise from treated wood Some untreated wood products, such as wood pallets, may become unintentionally or accidentally contaminated during their normal use with organic chemicals and / or heavy metals. However, the WID exclusion would still apply because the contamination is not as a result of treatment with wood preservatives or coating. Operators wishing to take advantage of this exclusion will have to demonstrate to the regulator that the contamination is accidental and not as a result of a treatment process The WID envisages that wood wastes arising from construction or demolition are likely to have been treated and hence covered by the WID. Wood waste recovered from Transfer Stations is equally likely to contain demolition or construction wood waste. It will be for the operator to demonstrate that such wastes do not contain treated wood waste. On the basis of the above guidance offcuts and other similar materials from the Woodworking Industry, providing they are not contaminated with halogenated compounds, or incorporate wood that was previously contaminated with these materials, should be classified as WIDexempt waste wood. The combustion of these materials should, therefore, not be subject to WID regulation and the facility should be regulated as a Combustion activity according to its thermal rating, or in the case of multiple appliances, the aggregate thermal rating.

5 The Environment Agency Regulatory Position Statement on the Environmental Regulation of Wood provides the following confirmation of the above. Use as fuel the material can be burnt. Its burning is normally regulated under WID. However, if it can first be shown that it is not contaminated with halogenated organic compounds or heavy metals (resulting from treatment with wood preservatives or coating), WID does not apply. In such circumstances, the material remains waste until it has been burned as a fuel, and its burning may still be subject to PPC or WMLR. It must be stored and burned in accordance either with a PPC permit or (for very small appliances) under the exemption from waste management licensing contained in Paragraph 5 WMLR. The onus is on the Operator to substantiate the claim that a particular wood waste should be classified as an exempt waste. Examination of Materials Safety Data Sheets for wood products such as MDF, MFC, etc, and laminates such as Formica and other melamine-types, demonstrate that the binders used in their manufacture are urea-formaldehyde, or phenol-formaldehyde resins that do not include halogenated materials. Accordingly, the incorporation of these resins into the product formulation does not affect the WID-exempt status of waste materials arising from manufacturing processes using these board materials. In the event that a proportion of the waste biomass burned as a fuel is not WID-exempt, then the combustion plant would be classed as an incinerator and, depending upon capacity, would either be regulated by the Environment Agency as a Section 5.1 Part A1(c) Incineration activity, or by the Local Authority as a Section 1.1 Incineration or Co-Incineration activity. Regulatory Requirements for Talbotts Biomass Combustion Plant Talbotts biomass combustion plant burning virgin timber or clean biomass are exempt from regulation under the Environmental Permitting (England and Wales) Regulations 2010 and do not require a permit to operate. They are however, subject to the requirements of the Clean Air Act (1993) and if they burn fuel at a rate of more than 45.4 kg per hour they will require planning permission for the chimney associated with the appliance. The majority of Talbotts biomass combustion plant are accredited as Clean Air Act exempt appliances and are therefore suitable for use in Smoke Control Areas. On the basis of guidance provided by the Environment Agency and DEFRA, Talbotts biomass combustion plant with a thermal input of 0.4 MW th to 3 MW th, and burning exempt wood waste would be regulated by the Local Authority as a Section 1.1 Part B(c) Combustion activity, but not subject to the WID Regulations. For appliances with a thermal input of between 3 MW th and 50 MW th, the appropriate regulatory authority would be the Environment Agency and the facility would be regulated as a Section 1.1 Part A1(b)(iii) Combustion activity. The Environmental Permitting Regulations (England and Wales) 2010 amended the guidance for appliances burning WID-exempt waste with a thermal input of <0.4 MW th. Where there is more than one combustion plant with an aggregate capacity of 0.4 MW th to 3 MW th, then the facility would be regulated by the Local Authority as a Section 1.1 Part B(d) combustion Activity.

6 Accordingly, a single biomass combustion plant with a thermal input of <0.4 MW th and burning WID-exempt waste wood does not require an Environmental Permit to operate and should only be subject to the requirements of the Clean Air Act However, if there were two or more appliances with a combined thermal input of >0.4 MW th but <3 MW th, then the facility would be regulated as a Section 1.1 Part B(d) Combustion activity by the Local Authority. The regulatory requirements for the range of Talbotts biomass combustion plant burning nonwaste, WID-exempt waste and waste biomass, are summarised in Appendix 1.

7 APPENDIX 1 Regulatory Implications for Biomass Fuels Used in Talbotts Combustion Plant Manually fed units for the combustion of solid wood offcuts Model Wood Waste Format Heat Output* Virgin Timber & Clean Biomass Non-Virgin Timber & WID-Exempt Biomass T75 solid off-cuts 25kW Clean Air Act 1993 Clean Air Act 1993* T150 solid off-cuts 50kW Clean Air Act 1993 Clean Air Act 1993* T300 solid off-cuts 100kW Clean Air Act 1993 Clean Air Act 1993* T500 solid off-cuts 150kW Clean Air Act 1993 Clean Air Act 1993* WID Waste Biomass Automatic units for the safe, clean and efficient combustion of extracted dust, chips, shavings and shredded waste wood Model Wood Waste Format Heat Output* Virgin Timber & Clean Biomass Non-Virgin Timber & WID-Exempt Biomass T1.5a shredded/extracted 50kW Clean Air Act 1993 Clean Air Act 1993* T3a shredded/extracted 100kW Clean Air Act 1993 Clean Air Act 1993* T5a shredded/extracted 150kW Clean Air Act 1993 Clean Air Act 1993* TMA shredded/extracted 300kW Clean Air Act 1993 Clean Air Act 1993* C1 shredded/extracted 50kW Clean Air Act 1993 Clean Air Act 1993* C2 shredded/extracted 100kW Clean Air Act 1993 Clean Air Act 1993* C3 shredded/extracted 150kW Clean Air Act 1993 Clean Air Act 1993* C4 shredded/extracted 300kW Clean Air Act 1993 Clean Air Act 1993* C5 shredded/extracted 600kW Clean Air Act 1993 EPR Section 1.1 Part B(c) C6 shredded/extracted 1000kW Clean Air Act 1993 EPR Section 1.1 Part B(c) C7 shredded/extracted 1000kW Clean Air Act 1993 EPR Section 1.1 Part B(c) C8 shredded/extracted 2000kW Clean Air Act 1993 EPR Section 1.1 Part B(c) C9 shredded/extracted 2500kW Clean Air Act 1993 C10 shredded/extracted 3000kW Clean Air Act 1993 EPR Section 1.1 Part A1(b)(iii) EPR Section 1.1 Part A1(b)(iii) WID Waste Biomass Note: * Assumes only one combustion plant, however, if more than one and aggregate capacity is >0.4 MW th then the facility will be a Section 1.1 Part B(d) Combustion activity. Please note that this document does not cover Talbotts Bio and CMH ranges, please contact us for further information regarding these appliances. For further information relating to this document please contact: Amy Fielding Talbotts Biomass Energy Systems Ltd Tollgate Drive Tollgate Industrial Estate Stafford ST16 3HS Tel: Fax: sales@talbotts.co.uk Talbotts offer a full and comprehensive consultancy service to assist with planning and environmental requirements.