viridor fichtner viridor beddington erf supporting information

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VIRIDOR
FICHTNER
VIRIDOR
BEDDINGTON ERF
SUPPORTING INFORMATION
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Beddington ERF - Supporting Information
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VIRIDOR
FICHTNER
VIRIDOR
BEDDINGTON ERF
SUPPORTING INFORMATION
Document Production & Approval Record
ISSUE NO. 3
NAME
SIGNATURE
POSITION
DATE
Prepared by:
James Sturman
Consultant
23rd July 2012
Checked by:
Stephen Othen
Technical Director
23rd July 2012
Document Revision Record
ISSUE NO.
DATE
DETAILS OF REVISIONS
th
1
28 May 2012
Draft for client review
2
29th June 2012
Final draft for client approval
3
rd
23 July 2012
Final for issue
4
5
6
7
© 2012 Fichtner Consulting Engineers. All rights reserved.
This report and its accompanying documents contain information which is confidential and is
intended only for the use of Viridor. If you are not one of the intended recipients any disclosure,
copying, distribution or action taken in reliance on the contents of the information is strictly
prohibited.
Unless expressly agreed, any reproduction of material from this report must be requested and
authorised in writing from Fichtner Consulting Engineers. Authorised reproduction of material
must include all copyright and proprietary notices in the same form and manner as the original,
and must not be modified in any way. Acknowledgement of the source of the material must also
be included in all references.
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TABLE OF CONTENTS
TABLE OF CONTENTS ................................................................................................................ III
1
Introduction .............................................................................................................. 1
1.1
The Applicant ......................................................................................................... 1
1.2
The Site ................................................................................................................ 2
1.3
Listed Activities ...................................................................................................... 2
1.4
Waste Operations ................................................................................................... 2
1.5
The Stationary Technical Unit ................................................................................... 3
1.5.1 Raw Materials ......................................................................................................... 4
1.5.2 Combustion Process ................................................................................................ 4
1.5.3 Energy Recovery..................................................................................................... 5
1.5.4 Gas Cleaning .......................................................................................................... 5
1.5.5 Ancillary Operations ................................................................................................ 6
1.5.6 Bottom Ash Processing ............................................................................................ 6
1.5.7 Liquid Effluent and Site Drainage .............................................................................. 6
1.5.8 Emissions Monitoring ............................................................................................... 7
2
Other Information for Application Form ........................................................................ 8
2.1
Raw materials ........................................................................................................ 8
2.1.1 Types and amounts of raw materials ......................................................................... 8
2.1.2 Reagent Storage ....................................................................................................10
2.1.3 Raw Materials Selection ..........................................................................................10
2.1.3.1 Reagent selection.......................................................................................10
2.1.3.2 Auxiliary Fuel.............................................................................................12
2.1.4 Incoming Waste Management .................................................................................12
2.1.4.1 Waste to be Burned....................................................................................12
2.1.4.2 Waste Handling .........................................................................................17
2.1.5 Waste Minimisation Audit (Minimising the Use of Raw Materials) ..................................18
2.1.5.1 Feedstock Homogeneity ..............................................................................18
2.1.5.2 Furnace Conditions.....................................................................................18
2.1.5.3 Flue Gas Treatment Control.........................................................................18
2.1.5.4 Waste Management ...................................................................................19
2.1.6 Water Use .............................................................................................................19
2.1.6.1 Overview ..................................................................................................19
2.1.6.2 Potable and Amenity Water .........................................................................21
2.1.6.3 ERF Process Water .....................................................................................21
2.2
Emissions ............................................................................................................ 21
2.2.1 Point Source Emissions to Air ..................................................................................21
2.2.2 Odour ...................................................................................................................22
2.2.3 Emissions to Water & Sewer ....................................................................................23
2.2.4 Contaminated Water ..............................................................................................25
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2.3
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Monitoring Methods............................................................................................... 26
2.3.1 Emissions Monitoring ..............................................................................................26
2.3.1.1 Monitoring Emissions to Air .........................................................................26
2.3.1.2 Monitoring Emissions to Land ......................................................................28
2.3.2 Monitoring of Process Variables................................................................................28
2.4
Technology Selection............................................................................................. 28
2.4.1 Combustion Technology ..........................................................................................28
2.4.2 NOx Reduction System............................................................................................30
2.4.2.1 Flue Gas Recirculation (FGR) .......................................................................30
2.4.2.2 Conclusion ................................................................................................31
2.4.3 Acid Gas Abatement System ...................................................................................32
2.4.4 Particulate Matter...................................................................................................33
2.5
Cooling System Selection ....................................................................................... 34
2.6
Specific Information required by the Waste Incineration Directive ................................ 34
2.6.1 Furnace Requirements ............................................................................................34
2.6.1.1 Validation of Combustion Conditions.............................................................35
2.6.1.2 Measuring Oxygen Levels............................................................................36
2.6.1.3 Combustion System ...................................................................................36
2.6.1.4 Waste Charging .........................................................................................37
2.6.1.5 Bag Filter Operation ...................................................................................37
2.6.2 Unavoidable Stoppages ..........................................................................................37
2.7
Energy Efficiency .................................................................................................. 39
2.7.1 General ................................................................................................................39
2.7.2 Basic Energy Requirements .....................................................................................39
2.7.2.1 Operating and Maintenance Procedures ........................................................40
2.7.2.2 Energy Efficiency Measures .........................................................................41
2.7.3 Further Energy Efficiency Requirements ....................................................................41
2.8
Waste Recovery and Disposal ................................................................................. 41
2.8.1 Introduction ..........................................................................................................41
2.8.2 Bottom Ash ...........................................................................................................42
2.8.3 Air Pollution Control Residues ..................................................................................42
2.9
Management ........................................................................................................ 44
2.9.1 Introduction ..........................................................................................................44
2.9.2 Business Management System ................................................................................44
2.9.3 Integrated Management Systems ............................................................................44
2.9.4 Developing, Implementing and Improving the BMS ....................................................46
2.9.4.1 Developing ................................................................................................46
2.9.4.2 Implementing ............................................................................................46
2.9.4.3 Improving .................................................................................................46
2.9.5 Reporting Structures and Communication .................................................................47
2.9.5.1 Communication .........................................................................................47
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2.10 Commissioning ..................................................................................................... 48
2.11 Closure ............................................................................................................... 48
2.11.1 Introduction ..........................................................................................................48
2.11.2 General ................................................................................................................48
2.11.3 Site Closure Plan....................................................................................................48
2.11.3.1General Requirements ................................................................................48
2.11.3.2Specific Details ..........................................................................................49
2.11.3.3Disposal Routes .........................................................................................49
2.12 Pre-operational Conditions and Improvement Programme .......................................... 49
2.12.1 Pre-operational Conditions ......................................................................................50
2.12.2 Commissioning ......................................................................................................50
2.12.3 Develop Site Closure Plan .......................................................................................50
3
Waste Incineration Questions ..................................................................................... 51
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1
FICHTNER
INTRODUCTION
The Beddington Energy Recovery Facility (ERF) will generate 26.1 MW of electricity using
residual Municipal Solid Waste from South London, plus some commercial and industrial
(C&I) waste, as the fuel. With an annual availability of 7,800 hours, the plant will process
275,000 tonnes of waste per annum.
In addition, there is a Waste Transfer Station and dry recyclates transfer facility which will
be developed within the site. The environmental permit application for the Waste Transfer
Station and dry recyclates transfer facility is being submitted separately.
This document and its annexes contain the supporting information for the application for the
Environmental Permit (EP). They should be read in conjunction with the formal application
form. In this section 1, we have provided an overview of the proposed installation. In
section 2, we have provided further information in response to specific questions in the
application form. In section 3, we have responded to the specific questions designed to
demonstrate that the proposed installation would comply with the requirements of the
Waste Incineration Directive. The requirements of Sector Guidance Notes (SGNs) EPR 5.01,
S5.06 and the sector BREF – Waste Incineration Industries - have been addressed
throughout this document.
1.1 The Applicant
Viridor Waste Management Limited is one of the UK’s leading recycling, renewable energy
and waste management companies. The company works with more than 90 local authorities
and thousands of private customers across the country.
Viridor’s aim is to protect human health and the environment by safely, responsibly and
efficiently managing waste and maximising recycling and resource generation opportunities.
Viridor offer a wide range of services to its customers from recycling and waste collections,
skips and bins through to fully integrated contracts.
To do this and keep up with the huge number of developments in the waste industry,
Viridor invest heavily in treatment and processing equipment to ensure that the
technology used is state-of-the-art. Viridor is refocusing its business away from simply
disposing of society’s wastes towards far higher levels of resource efficiency via the
recovery of energy and materials.
As a market leader in recycling and reuse of waste, Viridor partners local councils,
helping them to meet waste prevention, recycling and landfill diversion targets. Viridor
also provide the private sector with integrated recycling, waste management and
specialist solutions.
Viridor currently operate a range of sites including 3 Energy from Waste plants, 25
Materials Recycling Facilities and 21 Landfills, as well as offering services from waste
collection, composting and logistics to skip and bin hire.
Viridor provides the full range of recycling and waste services including advanced materials
recycling, glass and plastics reprocessing, composting, mechanical & biological treatment,
waste to energy, transport, collection, and safe and efficient landfill disposal. Each year the
company recycles c. 2 million tonnes of materials, has the capacity to generate over 127.5
megawatts of renewable energy and handled over 8 million tonnes of waste material.
Viridor is owned by Pennon Group, a FTSE 250 British based plc focused on the water and
waste management industries.
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1.2 The Site
The site is located at Beddington Farmlands, which is located south of Mitcham Common
and north of Beddington Park, within the London Borough of Sutton. The site lies 500m
metres to the south of the London Borough of Merton and 600m to the west of the
boundary of the London Borough of Croydon.
The area identified for the Beddington ERF is fairly flat, and is currently in use as a dry
recyclate and waste transfer facility, a skip waste recycling compound, part of an in-vessel
composting facility and associated vehicle circulation areas and hardstanding.
The application site has historically been used for treatment and processing of waste and
waste water and minerals extraction. Prior to this the area was in agricultural use.
The site is bounded to the east by sludge beds (part of Thames Water’s waste water
treatment works) and Beddington Lane beyond, to the west by the railway, to the north by
sludge beds and to the south by Beddington Park.
Access to the site will be gained from a new access road linking into the Coomber Way
roundabout on Beddington Lane. This is presented in Annex 1 (Phase 8: Restoration Plan).
1.3
Listed Activities
The principal activity will consist of a combination of Schedule 1 installation activities (as
defined in the Environmental Permitting Regulations) and directly associated activities:
Table 1.1: Environmental Permit Activities
Type of Activity
Incineration Line 1
Schedule
Activity
5.1 Part A (1) c)
Description of Activity
Incineration Line 1 and 2 – the incineration of
residual wastes with a combined nominal
operating capacity of 35.22 tonnes per hour
Directly Associated Activities
Directly Associated
Activities
Acceptance of waste to the installation.
Directly Associated
Activities
Dewatering of gulley waste
Directly Associated
Activities
The abatement of emissions to air from the
installation.
Directly Associated
Activities
The export of heat and electricity from the
installation.
A drawing which identifies the installation boundary is presented in Annex 1 (Ref: 1190015: Site Plan).
1.4 Waste Operations
To the south of the main ERF building there will be a facility for recyclable wastes and waste
unsuitable for combustion. There is not technical connection between the two facilities. The
application will be applied for separately to this submission.
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1.5
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The Stationary Technical Unit
The Stationary Technical Unit (installation) covers the ERF includes the two waste
incineration lines, waste reception, waste storage, water, fuel gas and air supply systems,
boilers, facilities for the treatment of exhaust gases, on-site facilities for treatment or
storage of residues and waste water, flues, stack, devices and systems for controlling
incineration operations, recording and monitoring conditions.
The plant will be configured as a Combined Heat and Power (CHP) Plant and will have
capacity to export heat to local users and power to the National Grid. The turbine has been
designed to deliver up to 20 MW of thermal energy to the CHP plant, which could deliver
approximately 150,000 MWh of thermal energy per year.
The nominal operating capacity of each incineration line will be approximately 17.61 tonnes
per hour of waste, with an estimated calorific value of 9.8 MJ/kg. The plant will have an
estimated availability of around 7,800 hours. Therefore the ERF will have a nominal design
capacity of approximately 275,000 tpa.
The maximum waste throughput which can be processed continually at 100% MCR (with a
lower CV – 8.7 MJ/kg) will be 19.83 tonnes per hour. Therefore the installation has the
potential to be able to incinerate up to approximately 302,500 tonnes per annum assuming
an annual availability of 7,800 hours. A firing diagram demonstrating the range of capacities
for the installation is presented in Annex 7. This demonstrates that the facility will maintain
the power output during fluctuations in fuel mix and with wastes that have lower calorific
values.
The other factor which will affect total fuel input capacity will be the hours of operation. In
some years, the plant may not need to be shut down for as long a period, consequently the
fuel input capacity will increase.
The process is illustrated in the diagram below. A larger copy is also included in Annex 1.
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1.5.1
FICHTNER
Raw Materials
Waste will be delivered to the plant in road vehicles. Waste deliveries will typically be
during weekdays between 07:00 and 18:00 hours, and on Saturdays between 07:00 and
18:00 hours, although daily waste deliveries will be completed by 1700 hours. Road
deliveries will be weighed at the entrance of the site, before being directed to the tipping
hall.
The tipping hall will be a fully enclosed building, maintained under slight negative
pressure to ensure that no odours, dust or litter can escape the building. The vehicles
will tip into a waste storage pit from where a grab transfers waste to the feed hoppers on
the combustion lines. The grab will also be used to homogenise the waste and to identify
and remove any unsuitable or non-combustible items. Bulky items will be passed through
a shredder so that they are suitable for incineration.
Hydrated lime is used to react with the acid gases in the flue gas cleaning process. Lime
will be stored in silos. The lime will be delivered by tanker and offloaded pneumatically
by means of the on board truck compressor into the silo. The displaced air will be vented
to atmosphere through a fabric filter located on the top of the silo.
Powdered activated carbon (PAC) used for the absorption of volatile heavy metals and
organic components is added with the lime. PAC will be stored in silos. PAC is
pneumatically transferred from the delivery truck by means of an on board compressor.
As with the lime, the exhaust air is de-dusted using a fabric filter located on the top of
the silo.
Urea is used for the NOx reduction using SNCR. Urea will be delivered to the site in dry
form, and stored in a designated area in a silo.
Demineralised water is supplied from an onsite demineralisation plant. It is used to
supply the steam cycle.
Various maintenance materials (oils, greases, insulants, antifreezes, welding and fire
fighting gases etc.) will be stored in an appropriate manner.
1.5.2
Combustion Process
The combustion chamber uses a reverse acting grate which agitates the fuel bed to
promote a good burnout of the material and a uniform heat release. The residence time
of the fuel on the grate is expected to be approximately 60 – 70 minutes. Primary
combustion air is drawn from the tipping hall to minimise odour issues from stored waste
in the bunker and fed into the combustion chamber beneath the grate.
Secondary combustion air injected into the flame body above the grate to facilitate the
oxidation of unburned gasified material released from the fuel. Further up the flue, above
the combustion zone, dry urea is injected through sprays. The urea reacts with the
oxides of nitrogen formed in the combustion process forming water, carbon dioxide and
nitrogen. By controlling the flow rate of urea introduced into the gas stream the
concentration of NOx is reduced to meet required limits.
The combustion chamber is provided with auxiliary burners that use fuel oil. Their
purpose is to ignite the refuse at start-up and to raise the combustion chamber
temperature to the required 850°C. There will be interlocks preventing the charging of
waste until the temperature within the combustion chamber has reached 850°C. During
normal operation, if the temperature falls below 850°C the burners are again initiated to
maintain the temperature above this minimum. Air flow for combustion is controlled by
measuring excess oxygen content in the flue gas. This is set to maximise the efficiency of
the heat recovery process while maintaining the combustion efficiency.
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Bottom ash falls from the grate into the discharger which comprises a water bath
followed by a chute inclined upwards that forms a water seal preventing uncontrolled air
ingress to the combustion chamber from the boiler house. The water serves as a quench
and makes it possible to remove the bottom ash without dust or odour issues. The ash is
pushed upwards and out of the water bath by hydraulically driven rams. The ash will
pass over a vibrating bar screen. After this, the ash is conveyed to a storage area. There
will be regular collections of IBA from the storage area for transfer off-site to a suitably
licensed waste facility.
Ferrous scrap from the vibrating bar screen is stored in a dedicated part of the ash
bunker. The material will be stored on site until a sufficient quantity has been
accumulated, at which point it will be transported to a suitably licensed waste facility.
1.5.3
Energy Recovery
Heat is recovered from the flue gases by means of a water tube boiler integral with the
furnace. Heat is transferred through a series of heat exchangers. The hot gases from the
furnace first pass through evaporators that raise the steam. The hot flue gases then pass
into the boiler. The boiler consists of 4 passes containing evaporators, superheaters and
economisers. At the boiler outlet the flue gases pass through an external economiser
which controls the flue gas temperature to 140°C. The boiler economisers are used to
pre-heat the evaporator feedwater supply. The cooling medium in the external
economiser is condensate from the air cooled condenser. The flue gas temperature is
reduced quickly through the critical range where dioxin reformation can occur.
Superheated steam at 60 bar-g and 400°C is supplied to a high efficiency turbine which
through a connecting shaft turns a generator to produce electricity. The turbine has a
series of extractions at different pressure that are used for preheating air and water in
the steam cycle. The remainder of the steam passes out of the final low pressure
condensing stage. To generate the pressure drop to drive the turbine the steam must be
condensed back to water. A fraction will condense at the exhaust of the turbine in the
form of wet steam. The majority is condensed in the air cooled condenser (ACC)
following the turbine at a pressure well below atmospheric.
A flange will be provided on the medium pressure bleed of the steam turbine in order to
allow a future connection to provide additional steam extraction as required. As potential
heat users become available, the provision of a heat supply will be possible without
modification to the installed system.
1.5.4
Gas Cleaning
The abatement of oxides of nitrogen (NOx) will be achieved by selective non-catalytic
reduction (SNCR). NOx is formed in the boiler at high temperature from nitrogen in the
fuel and in the combustion air. Urea will be injected at the combustion chamber through
a bank of nozzles installed at different places to provide flexibility of dosing, directly into
the hot flue gases above the flame. NOx is chemically reduced to nitrogen, carbon dioxide
and water by the urea.
After the heat recovery stages the flue gas passes to the flue gas treatment (FGT) plant.
The method chosen is known as dry FGT and uses hydrated lime to reduce the
concentrations of acid gases, such as SOx and HCl, in the flue gas stream. This
abatement technology has the benefit that it does not produce a liquid effluent. Energy
recovery is more efficient as additional heat in the boiler flue gas is not required to
evaporate water as in a semi-dry or conditioned FGT process.
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Powdered activated carbon (PAC) is used as an adsorbent to remove volatile metals,
dioxins and furans. Both PAC and lime are held in dedicated storage silos and
transported pneumatically and mixed in line and introduced to the flue gas stream
through a common injection point. The flue gases containing the reagents pass through a
reaction loop and into a bag filter arrangement where reaction products and un-reacted
solids are removed from the stream. The residues cake the outside of the filter bags with
the units periodically cleaned by a reverse jet of air displacing the filtered solids into
chutes beneath.
Residues collected by the bag filters are held in a silo from where it is recycled back into
the flue gas stream at the top of the reaction loop. The lime flow rate is controlled by the
upstream acid gas pollutant concentration measurements and proportioned to the
volumetric flow rate of the flue gases. As fresh reagents are added an equivalent amount
of residues collected from the bag filters are removed.
There will be online monitoring of pressure drop within bag filter compartments to
identify when there has been bag filter failure. If a pressure drop is identified, bag filter
compartments will be isolated to prevent uncontrolled emissions and repaired before
being brought back on-line.
The cleaned gas is monitored for pollutants and discharged to atmosphere through two
85m stacks.
1.5.5
Ancillary Operations
The plant includes a demineralised water plant to treat towns water or collected and
cleaned harvested rainwater so that it is suitable for use as top up for the process
requirements. The treated water will be used to initially fill up the boilers and the water
network and replace blowdown losses. Steam losses from the steam/water cycle would
cause a build-up of solids in the system as concentrations of impurities in the water
gradually increase. Water addition and blowdown prevent this from occurring.
The demineralised water system has a buffer tank to ensure demineralised water is
always available.
Blowdown and waste process water is directed to a settlement pit that will remove
suspended solids. Through a buffer tank the water is supplied to the bottom ash quench
system. Excess wastewater in the settlement pit will be discharged to sewer following pH
correction. During normal operation, the plant is expected to be zero discharge to water.
Water for fire fighting will be supplied by the potable water supplier, and will be stored in
a dedicated firewater tank.
1.5.6
Bottom Ash Processing
The ERF facility is expected to produce approximately 69,000 tonnes per annum of
bottom ash which will be transferred off-site to a suitably licensed waste facility.
Small volumes of boiler ash will be combined with the bottom ash as part of the process.
Bottom ash from the grate will have oversized components removed by a vibrating bar
screen and then be conveyed to the ash bunker. Grate riddling and boiler cleaning
residues will be collected with the bottom ash through the ash dischargers.
1.5.7
Liquid Effluent and Site Drainage
During normal operation the ERF is designed to have zero discharges to water.
Surface run-off from the main access road will be diverted to swales running alongside it,
which will be designed to have the water flow an attenuation pond. Rainwater will be
collected from buildings and used for grey water harvesting for domestic uses.
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The Beddington Lane site has direct connections available to the adjacent Thames Water
sewage works. Discharges from sanitary and kitchen sources within the facility, including
from the administration building, control room, workshop area, tipping hall, and the
weighbridge office, will be discharged to sewer.
All process water within the ERF will be reused within the waste water collection system.
correction if necessary. This is only expected to be required during periods of abnormal
operation.
1.5.8
Emissions Monitoring
Reporting on emissions monitoring is integrated into the continuous emissions
monitoring system (CEMS). There will be one CEMS per line. The following
measurements will be continuously monitored and recorded:

Particulates (PM10);

HCl (Hydrogen chloride);

CO (Carbon monoxide);

SO2 (Sulphur dioxide);

NOx (Nitrogen oxides, NO & NO2 expressed as NO2);

NH3 (Ammonia);

VOC (Volatile Organic Compounds);

oxygen (O2);

water vapour (H2O);

pressure;

temperature; and

volume flow.
As allowed by WID Article 11(4), continuous HF emission monitoring will be replaced by
relying on continuous HCl monitoring. This is because the lime system used for the
abatement of hydrogen chloride is effective for the abatement of hydrogen fluoride and is
operated with an excess of lime. As hydrogen fluoride is more reactive than hydrogen
chloride, by controlling hydrogen chloride below the Emissions Limit Value (ELV), the
hydrogen fluoride level is maintained below the relevant ELV. Periodic monitoring will be
used to verify this is the case.
A spare CEMS unit is available and will be set-up as a stand-by. It will be signalled to be
switched on in case of a failure of either one of the main units.
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2 OTHER INFORMATION FOR APPLICATION FORM
2.1 Raw materials
2.1.1
Types and amounts of raw materials
Question 3c in application form B3 requires information on the types and amounts of raw
materials which will be used. The information requested is shown in Table 2.1 below. In
addition, information on the potential environmental impact of these raw materials, as
required by Getting the Basics Right, is included in Table 2.2.
Table 2.1: Types and Amounts of Raw Materials and consumption rate at
design load
Schedule 1
Activity
ERF
Material
S1190-0900-0002SP
Annual
Throughput
(tonnes per
annum)
Fuel oil
90
2000
Urea
80
700
160
3,500
Activated
carbon
30
100
Boiler
treatment
chemicals
<5
< 50
Hydrated lime
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Maximum
Amount (m3)
Description
including any
hazard code
Low sulphur fuel oil
Prills
Dry, hydrated
Powdered
Corrosion
inhibitor,
scale inhibitor, biocide,
ion exchange resins
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Table 2.2 – Raw materials and their affect on the environment
Environmental Medium
Chemical
Composition
Typical
Quantity
Units
Air
Land
Water
Fuel oil
Mixture of aliphatic
and
aromatic
hydrocarbons. Low
sulphur (<0.1%)
2000
tonnes / year
100
0
Lime
Ca(OH)2 >95%
3,500
tonnes / year
0
Activated Carbon
C
100
tonnes / year
Urea
CO(NH2)2
700
Water
H2O
33,000
Product
Water
Treatment
Chemicals
Corrosion inhibitor,
scale
inhibitor,
biocide,
ion
exchange resins
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< 50
Impact
Potential
Comments
0
Low
impact
Fuel for start-up and shutdown of the ERF, and
site vehicles.
100
0
Low
impact
Injected lime is removed with the APC residues at
the bag filter and disposed of as hazardous waste
at a suitable licensed facility.
0
100
0
Low
impact
Injected carbon is removed with the APC residues
at the bag filter and disposed of as hazardous
waste at a suitable licensed facility.
tonnes / year
100
0
0
Low
impact
Reacts with nitrogen oxides to form nitrogen,
carbon dioxide and water vapour. Any unreacted
ammonia (a chemical intermediate) is released to
atmosphere at low concentrations.
m3 / year
50
0
50
Low
impact
Water is used for various uses, including:
tonnes / year
0
0
100

Demineralised water make-up;

Cleaning water;

Ash quench.
Corrosion inhibitor, scale inhibitor, biocide, ion
exchange resins will be used for the treatment of
boiler feedwater.
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Various other materials will be required for the operation and maintenance of the plant,
including:
a)
Hydraulic oils and silicone based oils;
b)
Electrical switchgear;
c)
Gas supply equipment;
d)
Refrigerant gases for the air conditioning plant;
e)
Oxyacetylene, TIG, MIG welding gases;
f)
CO2 / fire fighting foam agents;
g)
Test and calibration gases.
These will be supplied to standard specifications offered by main suppliers. All chemicals
will be handled in accordance with COSHH Regulations as part of the quality assurance
procedures and full product data sheets will be available on site.
Periodic reviews of all materials used will be made in the light of new products and
developments. Any significant change of material, where it may have an impact on the
environment, will not be made without firstly assessing the impact and seeking approval
from the Environment Agency.
The Operator will maintain a detailed inventory of raw materials used on site and have
procedures for the regular review of new developments in raw materials.
2.1.2
Reagent Storage
In order to minimise contamination risk of process or surface water, all liquid chemicals
will be stored on site in accordance with the Environment Agency Pollution Prevention
Guidelines. In the event of a spillage and/or a leak they will be retained in these areas
and treated locally.
High-level sensors, relief valves, and discharge air filters will be installed on all silos to
prevent over-pressurisation and release of consumables to atmosphere.
Hydrated lime,, activated carbon and urea prills will be delivered to the plant for storage
in silos. Both the lime and the activated carbon will be transported pneumatically from
the delivery vehicle to the correct storage silo. Control is achieved through high level
control and alarm. The top of all silos will be equipped with a vent fitted with a fabric
filter. Cleaning of the filter is done automatically with compressed air after the filling
operation. The filter will be inspected regularly for leaks.
2.1.3
Raw Materials Selection
2.1.3.1
Reagent selection
Acid Gas Abatement
There are several reagents available for acid gas abatement. Sodium Hydroxide
(NaOH) or hydrated lime (Ca(OH)2) can be used in a wet FGT system. Quicklime
(CaO) can be used in a semidry FGT system. Sodium bicarbonate (NaHCO3) or
hydrated lime can be used in a dry FGT process.
The reagents for wet scrubbing and semi-dry abatement are not considered, since
these abatement techniques have been eliminated by the BAT assessment in Annex 4
section 1. The two alternative reagents for a dry system – lime and sodium
bicarbonate have therefore been assessed further.
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The level of abatement that can be achieved by both reagents is similar. However, the
level of reagent use and therefore residue generation and disposal is different and
requires a full assessment following the methodology in Horizontal Guidance Note H1.
The assessment is detailed in Annex 4 section 3 and is summarised in the table below.
Table 2.3 – Acid Gas Abatement BAT Data
Item
Unit
NaHCO3
Ca(OH)2
Mass of reagent required
kg/h
775
525
Mass of residue generated
kg/h
352
389
Cost of reagent
£/tonne
£155
£115
Cost of residue disposal
£/tonne
£150
£125
Overall Cost
£/op.hr/kmol
1,200,000
900,000
1.329
1.000
Ratio of costs
Note: Data based on abatement of one kmol of Hydrogen Chloride
In summary, there is a small environmental benefit for using sodium bicarbonate, in
that the mass of residues produced is smaller. However, there are a number of
significant disadvantages:

The sodium bicarbonate residue has a higher leaching ability than lime-based
residue, and therefore may require additional treatment prior to disposal,
making it more expensive to dispose of;

The reaction temperature for sodium bicarbonate doesn’t match as well with the
optimum adsorption temperature for activated carbon, which will be dosed at
the same time as the acid gas reagent; and

The costs of sodium hydroxide are approximately 30% higher than using a lime
system.
Thus, the use of lime is considered to represent BAT for this installation.
NOx Abatement
A detailed BAT Assessment for the assessment of technologies for the abatement of
NOx has been presented in section 2.4.2.
The SNCR system can be operated with dry urea, urea solution or aqueous ammonia
solution. There are advantages and disadvantages with all of these options:

Urea is easier to handle than ammonia; the handling and storage of ammonia
can introduce an additional risk.

Dry urea needs big-bags handling whereas urea solution can be stored in silos
and delivered in tankers.

Ammonia tends to give rise to lower nitrous oxide formation than urea. Nitrous
oxide is a potent greenhouse gas.

Ammonia emissions (or ‘slip’) can occur with both reagents, but good control will
limit this.
The Sector Guidance on Waste Incineration considers all options as suitable for NOx
abatement. It is proposed to use urea for the SNCR system. The climate change
impacts of urea are considered to be significantly less significant than the handling
and storage issues associated with ammonia solution.
The use of urea in the SNCR system is therefore regarded as representing BAT.
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Auxiliary Fuel
The auxiliary fuel for the ERF will be fuel oil. This will be brought in by tanker,
loaded/unloaded via a sealed pipe system, and stored in an above ground bunded
storage tank.
As stated in Article 6 (1) of the Waste Incineration Directive:
During start-up and shutdown or when the temperature of the combustion gas falls
below 850oC, the auxiliary burner should not be fed with fuels which can cause higher
emissions than those resulting from the burning of gasoil as defined in Article 1 (1) of
Council Directive 75/716/EEC, liquefied gas or natural gas.
Therefore as identified by the requirements of WID the only available fuels that can be
used for auxiliary firing are:
(1)
Natural gas;
(2)
Liquefied gas (LPG); or
(3)
Gasoil.
Auxiliary burner firing on a well managed waste combustion plant is only required
intermittently, i.e. during start-up, shutdown and when the temperature in the
combustion chamber falls to 850oC.
Natural gas can be used for auxiliary firing and is safer to handle than LPG. As stated
previously, auxiliary firing will only be required intermittently. When firing this
requires large volumes of gas, which would be need to be supplied from a highpressure gas main. The installation of a high-pressure gas main to supply gas for
auxiliary firing to the Beddington ERF would be very expensive.
LPG is a flammable mixture of hydrocarbon gases. It is a readily available product,
and can be used for auxiliary firing. As LPG turns gaseous under ambient temperature
and pressure, it is required to be stored in purpose built pressure vessels. If there was
a fire within the site, there would be a significant explosion risk from the combustion
of flammable gases stored under pressure.
A fuel oil tank can be easily installed at the Beddington ERF. Whilst it is acknowledged
that fuel oil is classed as flammable, it does not pose the same type of safety risks as
those associated with the storage of LPG. The combustion of fuel oil will lead to
emissions of sulphur dioxide, but these emissions will be minimised as far as
reasonably practicable through the use of low sulphur fuel oil.
Therefore, low sulphur light fuel oil will be used for auxiliary firing.
2.1.4
Incoming Waste Management
2.1.4.1
Waste to be Burned
The proposed plant will be used to recover energy from MSW and Commercial and
Industrial waste, with European Waste Catalogue Codes as shown in the table below.
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Table 2.4 – EWC Code List for Installation
EWC Code
Description of Waste
WASTES FROM AGRICULTURE, HORTICULTURE, AQUACULTURE, FORESTRY, HUNTING AND
FISHING, FOOD PREPARATION AND PROCESSING
wastes from agriculture, horticulture, aquaculture, forestry, hunting and fishing
02 01 02
animal-tissue waste
02 01 03
plant-tissue waste
02 01 04
waste plastics (except packaging)
02 01 07
wastes from forestry
02 01 09
agrochemical waste other than those mentioned in 02 01 08
wastes from fruit, vegetables, cereals, edible oils, cocoa, coffee, tea and tobacco preparation and
processing; conserve production; yeast and yeast extract production, molasses preparation and
fermentation
02 03 04
materials unsuitable for consumption or processing
wastes from the dairy products industry
02 05 01
wastes from the baking and confectionery industry
02 06 01
02 06 02
wastes from preserving agents
WASTES FROM WOOD PROCESSING AND THE PRODUCTION OF PANELS AND FURNITURE, PULP,
PAPER AND CARDBOARD
wastes from wood processing and the production of panels and furniture
03 01 01
waste bark and wood
03 01 05
sawdust, shavings, cuttings, wood, particle board and veneer other than those
mentioned in 03 01 04
WASTES FROM ORGANIC CHEMICAL PROCESSES
wastes from the MFSU of plastics, synthetic rubber and man-made fibres
07 02 13
waste plastic
WASTE FROM WOOD PROCESSING AND THE PRODUCTION OF PANELS AND FURNITURE, PULP,
PAPER AND CARDBOARD
Wastes from pulp, paper and cardboard production and processing
03 03 01
Waste bark and wood
03 03 07
Mechanically separated rejects and pulping of waste paper and cardboard
03 03 08
Waste from sorting of paper and cardboard destined for recycling
WASTES FROM THE LEATHER, FUR AND TEXTILES INDUSTRIES
Wastes from the textiles industry
04 02 09
Wastes from composite materials, (impregnated textile, elastomer, plastomer)
04 02 10
Organic matter from natural products (for example grease, wax)
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EWC Code
04 02 21
Wastes from unprocessed fibres
04 02 22
Wastes from processed fibres
WASTES FROM ORGANIC CHEMICAL PROCESSES
wastes from the MFSU of plastics, synthetic rubber and man-made fibres
07 02 13
waste plastic
WASTES FROM THE PHOTOGRAPHIC INDUSTRY
wastes from the photographic industry
09 01 07
photographic film and paper containing silver or silver compounds
09 01 08
photographic film and paper free of silver or silver compounds
09 01 10
single-use cameras without batteries
WASTES FROM SHAPING AND PHYSICAL AND MECHANICAL SURFACE TREATMENT OF METALS
AND PLASTICS
wastes from shaping and physical and mechanical surface treatment of metals and plastics
12 01 05
plastics shavings and turnings
WASTE PACKAGING; ABSORBENTS, WIPING CLOTHS, FILTER MATERIALS AND PROTECTIVE
CLOTHING NOT OTHERWISE SPECIFIED
Packaging (excluding separately collected municipal packaging waste)
15 01 01
Paper and cardboard packaging
15 01 02
Plastic packaging (which is contaminated)
15 01 03
Wooden packaging
15 01 05
Composite packaging
15 01 06
Mixed packaging
15 01 09
Textile packaging
Absorbents, filter materials, wiping cloths and protective clothing
15 02 03
Absorbents, filter materials, wiping cloths and protective clothing other than
those mentioned in 15 02 02
WASTES NOT OTHERWISE SPECIFIED IN THE LIST
End-of-life vehicles from different means of transport (including off-road machinery) and wastes
from dismantling of end-of-life vehicles and vehicle maintenance (except 13, 14, 16 06 and 16
08)
16 01 19
plastic
CONSTRUCTION AND
CONTAMINATED SITES)
DEMOLITION
WASTES
(INCLUDING
EXCAVATED
SOIL
FROM
Wood, glass and plastic
17 02 01
Wood
17 02 03
Plastic
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EWC Code
17 09 04
Mixed construction and demolition wastes other than those mentioned in 17 09
01, 17 09 02 and 17 09 03
WASTES FROM HUMAN OR ANIMAL HEALTH CARE AND/OR RELATED RESEARCH (except kitchen
and restaurant wastes not arising from immediate health care)
wastes from natal care, diagnosis, treatment or prevention of disease in humans
18 01 04
wastes whose collection and disposal is not subject to special requirements in
order to prevent infection(for example dressings, plaster casts, linen,
disposable clothing, diapers)
18 01 07
chemicals other than those mentioned in 18 01 06
18 01 09
medicines other than those mentioned in 18 01 08
wastes from research, diagnosis, treatment or prevention of disease involving animals
18 02 03
wastes whose collection and disposal is not subject to special requirements in
order to prevent infection
18 02 06
chemicals other than those mentioned in 18 02 05
18 02 08
medicines other than those mentioned in 18 02 07
WASTES FROM WASTE MANAGEMENT FACILITIES, OFF-SITE WASTE WATER TREATMENT
PLANTS AND THE PREPARATION OF WATER INTENDED FOR HUMAN CONSUMPTION AND WATER
FOR INDUSTRIAL USE
wastes from physico/chemical treatments of waste (including dechromatation, decyanidation,
neutralisation)
19 02 03
Premixed wastes composed only of non-hazardous waste
19 02 10
Combustible wastes other than those mentioned in 19 02 08 and 19 02 09
stabilised/solidified wastes
19 03 05
stabilised wastes other than those mentioned in 19 03 04
19 03 07
solidified wastes other than those mentioned in 19 03 06
Wastes from aerobic treatment of solid waste
19 05 01
Non-composted fraction of municipal and similar wastes
19 05 02
Non-composted fraction of animal and vegetable waste
19 05 03
Off specification compost
wastes from anaerobic treatment of waste
19 06 04
digestate from anaerobic treatment of municipal waste
19 06 06
digestate from anaerobic treatment of animal and vegetable waste
wastes from waste water treatment plants not otherwise specified
19 08 01
screenings
wastes from shredding of metal-containing wastes
19 10 04
fluff-light fraction and dust other than those mentioned in 19 10 03
Wastes from waste water treatment plants not otherwise specified
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EWC Code
19 08 14
Sludges from other treatment of industrial waste water other than those
mentioned in 19 08 13
Wastes from the mechanical treatment of waste (for example sorting, crushing, compacting,
pelletising) not otherwise specified
19 12 01
Paper and cardboard (which is contaminated)
19 12 04
Plastic and rubber (which is contaminated)
19 12 07
Wood other than that mentioned in 19 12 06
19 12 08
Textiles
19 12 10
Combustible waste (refuse derived fuel)
19 12 12
Other wastes (including mixtures of materials from mechanical treatment of
wastes other than those mentioned in 19 12 11)
MSWS (HOUSEHOLD WASTE AND SIMILAR COMMERCIAL, INDUSTRIAL AND INSTITUTIONAL
WASTES) INCLUDING SEPARATELY COLLECTED FRACTIONS
Separately collected factions (except 15 01)
20 01 01
Paper and cardboard (which is contaminated)
20 01 08
Biodegradable kitchen and canteen waste
20 01 10
Clothes
20 01 11
Textiles
20 01 25
Edible oil and fat
20 01 28
Paints, inks, adhesives and resins other than those mentioned in 20 01 27
20 01 30
Detergents other than those mentioned in 20 01 29
20 01 32
Medicines other than those mentioned in 20 01 31
20 01 36
Discarded electrical and electronic equipment other than those mentioned in 20
01 21, 20 01 23 and 20 01 35
20 01 38
Wood other than that mentioned in 20 01 37
20 01 39
Plastics
Garden and park wastes (including cemetery waste)
20 02 01
Biodegradable waste
20 02 03
other non-biodegradable wastes
Other MSWs
20 03 01
Mixed MSW
20 03 02
Waste from markets
20 03 03
Street cleaning residues
20 03 06
waste from sewage cleaning
20 03 07
Bulky waste
20 03 99
MSWs not otherwise specified
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The nominal operating capacity of each incineration line will be approximately 17.61
tonnes per hour of waste, with an estimated net calorific value of 9.8 MJ/kg. The plant
will have an estimated availability of around 7,800 hours. Therefore the ERF will have
a nominal design capacity of approximately 275,000 tpa.
The maximum waste throughput which can be processed continually at 100% MCR
(with a lower NCV of 8.7 MJ/kg) will be 19.83 tonnes per hour. Therefore the
installation has the potential to be able to incinerate up to approximately 302,500
tonnes per annum assuming an annual availability of 7,800 hours. This would
maintain the power output during fluctuations in fuel mix and with wastes that have
lower calorific values.
The other factor which will affect total fuel input capacity will be the hours of
operation. In some years, the plant may not need to be shutdown for as long a
period, so that the fuel input capacity will increase.
Checks will be made on the paperwork accompanying each delivery to ensure that
only waste for which the plant has been designed will be accepted. Where possible,
the weighbridge operator will undertake a visual inspection of waste to confirm it
complies with the specifications of the waste transfer note (WTN).
For waste delivered in Refuse Collection Vehicles (RCVs), it will not be practical to
inspect this waste before it is tipped into the bunker, since it is compressed in the
vehicles/storage vessels. The waste will be observed by the tipping hall operator as it
is tipped and by the crane driver and control room operator as it is mixed.
Unacceptable waste will be removed from the bunker for further inspection and
quarantine, prior to transfer off-site to a suitable disposal/recovery facility.
The bunker design will incorporate a back-loading facility to enable the contents to be
emptied into vehicles for removal from site in the event of unplanned periods of
prolonged shut-down. This will comprise a feed chute, to be loaded by one of the
waste feed cranes, and discharging into an articulated vehicle. This facility can also be
used for the removal of oversized items or non-combustible items identified within the
bunker.
Any unacceptable waste will be rejected and stored in a designated area in the tipping
hall. The Environmental Management System (EMS) will include procedures to control
the inspection, storage and onward disposal of unacceptable waste. Certain wastes
will require specific action for safe storage and handling. The EMS will also contain
procedures for controlling the blending of waste types to avoid mixing of incompatible
wastes.
Unsuitable wastes could include items which are considered to be non-combustible,
large/bulky items or items of hazardous waste. Large/bulky items will be shredded
prior to transfer to the waste bunker. All other ‘unsuitable wastes’ will be loaded into a
bulker or other appropriate vehicle for transfer off-site either to the producer of the
waste or to a suitably licensed waste management facility.
Gulley waste will be delivered to the Gulley Waste facility for processing. The SRF
produced from from the Gulley Waste facility will be transferred to the waste bunker.
2.1.4.2
Waste Handling
At the start of operation, the installation will have documented procedures which will
comply with the BAT requirements in the Sector Guidance Note, including:

A high standard of housekeeping will be maintained in all areas and suitable
equipment to clean up spilled materials will be provided and maintained.

Vehicles will be loaded and unloaded in designated areas provided with
impermeable hard standing. These areas will have appropriate falls to the
process water drainage system.
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
Fire fighting measures will be designed by consultation with the Local Fire
Officers, with particular attention paid to the waste bunker.

Delivery and reception of waste will be controlled by a management system that
will identify all risks associated with the reception of waste and shall comply with
all legislative requirements, including statutory documentation.

Incoming Municipal and Commercial and Industrial waste will be:
2.1.5

in covered vehicles or containers; and

unloaded into the enclosed reception bunker.

Gulley wastes will be delivered to site in enclosed vehicles and unloaded into the
Gulley Waste facility for processing.

Design of equipment, buildings and handling procedures will ensure there is no
dispersal of litter.

Waste crane operating procedures will ensure the waste is well mixed in the
bunker to maximise the homogeneity of waste fed to the ERF Facility.

Inspection procedures will be employed to ensure that any wastes which would
prevent the ERF Facility from operating in compliance with its permit are
segregated and placed in a designated storage area pending removal.

Further inspection will take place by the crane operator during vehicle tipping
and waste mixing.
Waste Minimisation Audit (Minimising the Use of Raw Materials)
A number of specific techniques are employed to minimise the production of residues. All
of these techniques meet the Indicative BAT requirements from the Sector Guidance
Note on Waste Incineration.
2.1.5.1
Feedstock Homogeneity
Improving feedstock homogeneity can improve the operational stability of the plant,
leading to reduced reagent use and reduced residue production. The process of tipping
waste into the storage bunker and subsequent mixing by the grab will serve to
improve the homogeneity of waste from different deliveries.
2.1.5.2
Furnace Conditions
Furnace conditions will be optimised in order to minimise the quantity of residues
arising for further disposal. Burnout in the furnace will reduce the TOC content of the
bottom ash to less than 3% by optimising waste feed rate and combustion air flows.
2.1.5.3
Flue Gas Treatment Control
Close control of the flue gas treatment system will minimise the use of reagents and
hence minimise the residues produced. SNCR reagent dosing is optimised to prevent
ammonia slip. In particular, Computational Fluid Dynamic modelling will be used to
optimise the injection locations of the urea SNCR system to achieve good dispersion.
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Lime usage will be minimized by trimming reagent dosing to accurately match the
acid load using fast response upstream HCl monitoring. Variable speed screw feeders
will ensure the lime dosing rate can be rapidly and precisely varied to match the acid
load. The plant preventative maintenance regime will include regular checks and
calibration of the lime dosing system to ensure optimum operation. Back-up feed
systems will be provided to ensure no interruption in lime dosing.
The bag filter is designed to build up a filter cake of unreacted lime, which acts as a
buffer during any minor interruptions in dosing.
There will be separate controls for the dosing rate for lime and activated carbon.
2.1.5.4
Waste Management
Details of waste management procedures can be found in Section 2.7. In particular,
bottom ash and residues from the flue gas treatment system will be stored and
removed from site separately.
2.1.6
Water Use
2.1.6.1
Overview
The following key points should be noted:

The water system has been designed with the key objective of minimal
consumption of potable water.

Surface water run-off from the roofs of the main ERF process buildings will be
collected and used within the ERF to supplement the use of potable water.

Most of the steam produced will be recycled as condensate. The remainder will
be lost as blowdown to prevent build-up of sludge and chemicals, through
sootblowing and through continuously flowing sample points.

Lost condensate will be replaced with demineralised water.

During normal operation waste water from the process will be re-used in the
bottom ash quench system.
A Process Water Mass Balance drawing is presented on the next page. A larger version
is included within Annex 1.
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2.1.6.2
FICHTNER
Potable and Amenity Water
Water for supplies for the offices facilities will come from a potable water supply. The
quantity of this water is expected to be small compared to the other water uses on
site. Waste water from showers, toilets and other mess facilities will be discharged to
sewer.
2.1.6.3
ERF Process Water
It is anticipated that the facility will use approximately 100 m3/hr of water. This water
will consist of harvested rainwater, potable mains water and demineralised water.
Demineralised water will be supplied to the Beddington ERF from an onsite water
treatment plant.
Process waste water will be collected and treated in the settlement pit and then used
in the bottom ash quenching system. Under normal operating conditions, waste water
is generated from the following:

Process effluent collected in the site drainage system (e.g. boiler blowdown);

Effluent generated through washing and maintenance procedures;

Leachate from the waste reception areas.
The settlement pit allows reuse of the water in the ash quench. Sludge tankers will
periodically remove the settled material and boiler blowdown sludge from the pit for
offsite disposal. During normal operation there will be no water discharge from the
waste water pit or process water system; all water from the ERF plant will be reused
within the building.
In the event of overflow from tanks and equipment within the process, the water will
be directed via the process water drains to the waste water pit for reuse in the ash
quench system.
The settlement pit will be provided to maximise the reuse of process water.
2.2 Emissions
2.2.1
Point Source Emissions to Air
The full list of proposed emission limits for atmospheric emissions is shown in Table 2.4.
Emissions to air from the ERF will be discharged to atmosphere via a 85m high stack.
The stack will contain two flues. The emission points from the ERF facility stack will be A1
and A2. Details regarding the location of the stack are presented in Annex 5 - Air Quality
Assessment.
In addition, there will be emission points from the back-up generators. Due to the
capacity (3MW) of these units, and they are only used infrequently it is not considered
suitable to propose emission limits for these emission points.
There will be two point source emission points for emissions to air from the installation.
These are presented in the table below:
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Table 2.5 – Proposed Emission Points
Emission Point Reference
Source
A1
Incineration Line 1
A2
Incineration Line 2
The full list of proposed emission limits for atmospheric emissions is shown in the table
below. This includes the information requested in Table 2 of Application Form Part B3.
The limits are based on the emission limits required by the Waste Incineration Directive
with the following exception:

The Waste Incineration Directive allows the omission of continuous monitoring of
HF if treatment stages for HCl are used which ensure that the emission limit for HF
is not being exceeded.
Table 2.6 – Proposed Emission Limits Values (ELV’s)
Parameter
Units
Half Hour
Average
Daily
Average
Periodic
Limit
Emission Points A1 and A2
mg/Nm3
30
10
-
VOCs as expressed as Total Organic
Carbon (TOC)
3
mg/Nm
20
10
-
Hydrogen chloride
mg/Nm3
60
10
-
Carbon monoxide
3
mg/Nm
100
50
-
Sulphur dioxide
mg/Nm3
200
50
-
3
400
200
-
Particulate matter
Oxides of nitrogen (NO and NO₂
expressed as NO₂)
mg/Nm
Hydrogen fluoride
mg/Nm3
2
mg/Nm3
-
-
0.05
Mercury and its compounds
mg/Nm3
-
-
0.05
Sb, As, Pb, Cr, Co, Cu, Mn, Ni and V
and their compounds (total)
mg/Nm3
-
-
0.5
Dioxins & furans ITEQ
ng/Nm3
-
-
0.1
Cadmium & thallium
compounds (total)
and
their
All expressed at 11% oxygen in dry flue gas at 0°C and 1 bar-a.
2.2.2
Odour
The storage and handling of waste is considered to have potential to give rise to odour.
The facility will be designed in accordance with the requirements of Environment Agency
Guidance Note H4: Odour. The facility will include a number of controls which are
deemed to represent appropriate measures to minimise odour from the installation
during normal and abnormal operation.
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Tipping Hall and Waste Bunker
The tipping hall will be within a fully enclosed building, to contain odours, dust or litter
within the building.
The ERF will be a two stream facility, and will include a waste bunker which will be
maintained under a slight negative pressure. During normal operation this will ensure
that no odours are able to escape the building. The negative pressure will be created by
drawing combustion air from within the ERF building.
During periods of planned maintenance for the incineration plant, there will only be one
stream shutdown at a time. This will ensure that the building is maintained at negative
pressure during maintenance periods.
During periods of short term unplanned outage when the ERF is not available, misting
sprays may be used to reduce odour from the waste storage areas.
Management Controls
The installation will include the following appropriate management controls for odour:
2.2.3

Olfactory monitoring for odour will be undertaken at the site boundary.

Waste will be stored within contained structures maintained at negative pressure to
prevent odour release.

During shutdown, doors will limit odour spread while still allowing vehicle access.
Misting sprays may be used to reduce odour from the waste storage area.

The main doors used for the waste delivery vehicles will be kept closed, except
during waste delivery periods..

Waste storage management procedures and good mixing
development of anaerobic conditions within the waste bunker.

The plant will employ bunker management procedures (mixing and periodic
emptying and cleaning) to avoid the development of anaerobic conditions.

Wastes will be removed from the bunker on a first in, first out basis.

Procedures will be in place to divert waste away from the site during lengthy shut
downs.

Self-closing doors will be provided for any potentially odorous indoor areas.
will
avoid
the
Emissions to Water & Sewer
A schematic identifying the ‘Drainage Systems Principle’ from the installation is
presented below:
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A full Retention Class 1 separator will provide containment of any spillages or leaks of oil
into the drainage system, and prevent potential contamination of local watercourses.
Therefore the only discharges to water from the installation will be of uncontaminated
rainwater.
During normal operation the ERF is designed to have zero discharges to water. Surface
run-off from the main access road will be diverted to swales running alongside it, which
will be designed to have the water flow an attenuation pond. Rainwater will be collected
from buildings and used for grey water harvesting for domestic uses.
The Beddington Lane site has direct connections available to the adjacent Thames Water
sewage works. Discharges from welfare facilities, including from the administration
building, control room, workshop area, tipping hall, and the weighbridge office, will be
discharged to sewer.
All process water within the ERF will be reused within the waste water collection system.
correction where required. This is only expected to be required during periods of
abnormal operation.
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2.2.4
FICHTNER
Contaminated Water
All chemicals will be stored in an appropriate manner incorporating the use of bunding
and other measures (such as acid and alkali resistant coatings) to ensure appropriate
containment. The potential for accidents, and associated environmental impacts, is
therefore limited.
Concrete structures used for the storage of waste will be designed in accordance with
with BS EN 1992-3:2006 ‘Design of Concrete Structures – Part 3: Liquid retaining and
containment structures’ standard. Preventative maintenance systems will include
inspection and maintenance of containment systems.
Adequate quantities of spillage absorbent materials will be made available onsite, at an
easily accessible location(s), where liquids are stored. A site drainage plan, including the
locations of foul and surface water drains and interceptors will be made available onsite,
where practicable. This will be available following detailed design of drainage systems.
Vehicles operating within the ERF will refuel at the on-site refuelling station located in a
lay-by on the eastern side of the ERF building. This will comprise a 90,000 litre fuel oil
tank and associated pumps. This tank will also be used to supply fuel to the ERF auxiliary
burners. A Full Retention Class 1 Separator is included within the carriageway drainage
system. No additional provision is required for the containment of fuel oil from
spills/leaks.
Any spillage, no matter how minor, will be reported to the Plant Manager and recorded
on the Inspection Checklist in accordance with site inspection, audit and reporting
procedures. Relevant authorities (EA/ Health and Safety Executive) will be informed if
spillages are over a certain volume threshold, as specified in the procedures.
The effectiveness of the Emergency Response Procedures for spillages is subject to
Management Review and may be reviewed following any major spillages and revised as
appropriate.
In the event of a spillage, the following steps are proposed, and these will be developed
into specific procedures for the facility:
(1)
Minor spills:
a)
(2)
Cover the absorbent granules and leave to work for effect as per instructions
on the container.
Major spills, leakage, or run-off:
a)
Contained within bunds, oil absorbent granules, sand, or booms to prevent
spill reaching drains and watercourses;
b)
If spillage has the potential to reach drains, drain outlets to be bunged;
c)
If there is a risk of fire, the Fire Brigade is to be contacted;
d)
Inform supervisor/area manager, who will notify the Environment Agency;
and
e)
Arrange for a specialist contractor to clear up.
In the event of a fire, potentially contaminated water resulting from fire-fighting
operations will be contained on site by two means.
(1)
Any fire water collected within the building will be collected in the internal drainage,
which will drain to the waste bunker. The capacity of the waste bunker is 5,500m3.
(2)
Fire in external areas will be contained in the external drainage network. This will
include an automatic control valve to shut-off the surface water drainage system.
This water will be transferred off-site to a suitably licensed facility.
All firewater would be sampled and tested prior to discharge/transfer off-site.
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2.3 Monitoring Methods
2.3.1
Emissions Monitoring
Sampling and analysis of all pollutants including dioxins and furans will be carried out to
CEN or equivalent standards (e.g. ISO, national, or international standards). This ensures
the provision of data of an equivalent scientific quality.
The plant will be equipped with modern monitoring and data logging devices to enable
checks to be made of process efficiency.
The purpose of monitoring has three main objectives.
(1)
To provide the information necessary for efficient and safe plant operation;
(2)
To warn the operator if any emissions deviate from predefined ranges;
(3)
To provide records of emissions and events for the purposes of demonstrating
regulatory compliance.
2.3.1.1
Monitoring Emissions to Air
The following parameters at the stack will be monitored and recorded continuously
using a Continuous Emissions Monitoring System (CEMS):

Oxygen;

Carbon Monoxide;

Hydrogen Chloride;

Sulphur dioxide;

Nitrogen oxides;

Ammonia;

VOCs; and

Particulates;
In addition, the water vapour content, temperature and pressure of the flue gases will
be monitored so that the emission concentrations can be reported at the reference
conditions required by the Waste Incineration Directive.
The continuously monitored emissions concentrations will also be checked by an
independent testing company at frequencies agreed with the Environment Agency.
The following parameters will also be monitored by means of spot sampling at
frequencies agreed with the Environment Agency:

Hydrogen Fluoride

Heavy Metals;

Organic Compounds;

Dioxins and furans.
The methods and standards used for emissions monitoring will be in compliance with
guidance note S5.01 and the Waste Incineration Directive. In particular, the CEMS
equipment will be certified to the MCERTS standard and will have certified ranges
which are no greater than 1.5 times the relevant daily average emission limit.
The CEMS incorporates an ‘approach to limit’ alarm in order to provide warning of any
potential problem. Should the alarm be triggered, the system will inhibit the feeding of
waste until the reason for the alarm has been fully investigated and the cause
determined and rectified.
It is anticipated that:
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
HCl, CO, SO2, NOx (NO+NO2)and NH3 will be measured by an FTIR type multigas analyser;

VOC will be measured by a FID type analyser;

Particulate matter will be measured by an opacimeter; and

O2 will be monitored by a zirconium probe
The frequency of periodic measurements will comply with the Waste Incineration
Directive as a minimum. The flue gas sampling techniques and the sampling platform
will comply with Environment Agency Technical Guidance Notes M1 and M2.
Reliability
WID article 11 allows a valid daily average to be obtained only if no more than 5 halfhourly averages during the day are discarded due to malfunction or maintenance of
the continuous measurement system. The WID also requires that no more than 10
daily averages are discarded per year.
These reliability requirements will be met primarily by selecting MCERTS certified
equipment.
Calibration will be carried out at regular intervals as recommended by the
manufacturer and by the requirements of BS EN14181. Regular servicing and
maintenance will be carried out under a service contract with the equipment supplier.
The CEMS will be supplied with remote access to allow service engineers to provide
remote diagnostics.
There will be one duty CEMS per line and a stand-by CEMS. The standby CEMS will be
permanently installed and ready to be switched on, if there is a failure of the duty
CEMS. This will ensure that there is continuous monitoring data available even if there
is a problem with the duty CEMS system. If this is not possible, then the plant must
be shut down within 4 hours.
Start-up and Shut-down
The emission limit values under the Waste Incineration Directive do not apply during
start-up and shut-down when the plant is incinerating waste. Therefore, a signal
would be sent from the main plant control system to the CEMS package to indicate
when the plant is operational and burning waste. The averages would only be
calculated when this signal was sent, but raw monitoring data would be retained for
inspection.
Start-up ends when all the following conditions are met:

The feed chute damper is open and the feeder ram, grate, ash extractors and
flue gas treatment systems are all running;

The temperature within the combustion chamber is greater than 850oC;

Exhaust gas oxygen is less than 15% (wet measurement); and

The combustion grate is fully covered with waste.
Shutdown begins when all the following conditions are met

The feed chute damper is closed;

The waste on the grate is burn out;

The flue gas treatment systems are running;

The shutdown burner is in service; and
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2.3.1.2
FICHTNER
Monitoring Emissions to Land
Disposal of residues to land will comply with all relevant legislation. In particular the
bottom ash will comply with the WID criterion of Total Organic Carbon less than 3% or
Loss on Ignition less than 5%. Compliance with the TOC criterion will be demonstrated
during commissioning and checked at periodic intervals agreed with the Environment
Agency throughout the life of the plant. Testing for TOC will be conducted by an
independent laboratory.
2.3.2
Monitoring of Process Variables
The following process variables have particular potential to influence emissions.

Waste throughput will be recorded to enable comparison with the design
throughput. As a minimum, daily and annual throughput will be recorded.

Combustion temperature will be monitored at a suitable position to demonstrate
compliance with the requirement for a residence time of 2 seconds at a
temperature of at least 850°C.

The oxygen concentration will be measured at the outlet from the boiler.

The differential pressure across the bag filters will be measured, in order to
optimise the performance of the cleaning system.

The concentration of HCl in the flue gases upstream of the flue gas treatment
system will be measured in order to optimise the performance of the emissions
abatement equipment.
Additionally, water use will be monitored and recorded regularly at various points
throughout the process to help highlight any abnormal usage. This will be achieved by
monitoring the water consumption within the installation.
2.4 Technology Selection
2.4.1
Combustion Technology
It is proposed that the combustion technology for the plant will be a moving grate
furnace.
This is the leading technology in the UK and Europe for the combustion of untreated
MSW. The moving grate comprises of inclined fixed and moving bars (or rollers) that will
move the waste from the feed inlet to the residue discharge. The grate movement turns
and mixes the waste along the surface of the grate to ensure that all waste is exposed to
the combustion process.
The Incinerator Sector Guidance Note discusses a number of alternative technologies for
the combustion of waste.
(1)
Moving Grate Furnaces
As stated in the Sector Guidance Note, these are designed to handle large volumes
of waste.
(2)
Fixed Hearth
These are not considered suitable for large volumes of waste. They are best suited
to low volumes of consistent waste.
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(3)
FICHTNER
Pulsed Hearth
Pulsed hearth technology has been used for municipal waste in the past, as well as
other solid wastes. However, there have been difficulties in achieving reliable and
effective burnout of waste and it is considered that the burnout criteria required by
WID would be difficult to achieve.
(4)
Rotary Kiln
Rotary Kilns have achieved good results with clinical waste, but they have not been
used in the UK for municipal waste. The energy conversion efficiency of a rotary
kiln is lower than that of a moving grate due to the large areas of refractory lined
combustion chamber.
An oscillating kiln is used for municipal waste at one site in England and some sites
in France. The energy conversion efficiency is lower than that of a moving grate for
the same reasons as for a rotary kiln.
(5)
Pyrolysis/Gasification
Various suppliers are developing pyrolysis and gasification systems for the disposal
of municipal waste. However, it is not considered that any of these technologies
can be considered to be proven. While pyrolysis and gasification systems which
generate a syngas can theoretically take advantage of gas engines or gas turbines,
which are more efficient that a standard steam turbine cycle, the losses associated
with making the syngas and the additional electricity consumption of the site mean
that the overall efficiency is no higher than for a combustion plant and is generally
lower. This means that a combustion plant will have a more beneficial effect on
climate change.
These systems are modular and are only available for small-scale facilities. The
Beddington ERF plant would need at least three modules in order to achieve the
required capacity. This significantly increases the capital cost of the plant, meaning
that it is not viable in this configuration. Pyrolysis and gasification are therefore not
considered to be suitable technologies for the proposed volume of waste.
(6)
Fluidised Bed
Fluidised beds are designed for the combustion of relatively homogeneous waste.
For residual MSW and commercial and industrial (C&I) waste, the waste would
need to be pre-treated before feeding to the fluidised bed, which would lead to
additional energy consumption and a larger building. The pre-treatment can lead to
higher quantities of rejected material. Where MSW is treated at a material recycling
facility, the residues from the MRF may already be suitable for feeding to the
fluidised bed. This does not apply to residues from kerbside collection schemes,
such as that proposed for the Beddington ERF, which would need some pretreatment, including shredding and metals removal as a minimum, before feeding
to the fluidised bed.
While fluidised bed combustion can lead to slightly lower NOx generation, the
injection of ammonia or urea is still required to achieve the emission limits
specified in WID.
Fixed hearth, pulsed hearth and pyrolysis/gasification are not considered suitable, but
moving grate, rotary / oscillating kiln and fluidised bed technologies are considered in
more detail in Annex 4 section 4 following the Horizontal Guidance Note EPR-H1. The
conclusions are summarised below.
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Table 2.7 – Comparison, Combustion Options
Reduction in GWP
t CO2 p.a.
Urea
t/a
Residues
Operating Cost

£ p.a.
Grate
Fluidised Bed
Kiln
104,100
94,900
85,000
700
390
580
78,100
Less bottom ash,
more fly ash
78,100
£2,580,000
£7,460,000
£4,440,000
Grate vs Fluidised Bed
The benefit of reduced urea consumption for a fluidised bed is outweighed by the
higher parasitic load and the higher operating costs. In addition the fluidised bed
technology processing residual MSW has a record of poor reliability. Experience in
the UK of fluidised bed combustion of MSW has been limited. Two plants are
operational, but both have had significant operational problems. Viridor do not
consider that they can be considered a reliable technology for MSW at this stage.

Grate vs Kiln
The kiln system has a lower combustion efficiency resulting in a greater fraction of
uncombusted material in the ash stream. This has a significant impact on the
global warming potential and the operating costs. In addition, the capital cost is
likely to be higher for a kiln since more streams are required.
Therefore, the moving grate is considered to be BAT for this installation.
2.4.2
NOx Reduction System
Burners used for auxiliary firing will be of low NOx design.
NOx levels will primarily be controlled by monitoring the combustion air. Selective noncatalytic NOx reduction (SNCR) methods will also be installed, using urea as the reagent.
The use of Selective Catalytic Reduction (SCR) has also been considered. In this
technique, the urea is injected into the flue gases immediately upstream of a reactor
vessel containing layers of catalyst. The reaction is most efficient in the temperature
range 200 to 350°C. The catalyst is expensive and to achieve a reasonable working life,
it is necessary to install the SCR downstream of the flue gas treatment plant. This is
because the flue gas treatment plant removes dust and SO3 which would otherwise cause
deterioration of the catalyst.
Since the other flue gas cleaning reactions take place at an optimum temperature of
around 140°C, the flue gases have to be reheated before entering the SCR. This requires
some thermal energy which would otherwise be converted to electrical power output,
reducing the overall energy recovery efficiency of the facility. The catalytic reactor also
creates additional pressure losses to be compensated by a bigger exhaust fan, reducing
further the overall energy efficiency.
2.4.2.1
Flue Gas Recirculation (FGR)
The proposed installation will not employ flue gas recirculation.
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It is important to understand that FGR is not a bolt-on abatement technique. The
recirculation of a proportion of the flue gases into the combustion chamber to replace
some of the secondary air changes the operation of the plant in various ways, by
changing the temperature balance and increasing turbulence. This requires the boiler
to be redesigned to ensure that the air distribution remains even.
Some suppliers of grates have designed their combustion systems to operate with
FGR and these suppliers can gain benefits of reduced NOx generation from the use of
FGR. Other suppliers of grates have focussed on reducing NOx generation through the
control of primary and secondary air and the grate design, and these suppliers gain
little if any benefit from the use of FGR.
It is also important to emphasise that, even where FGR does improve the
performance of a combustion system, it does not reduce NOx emissions to the levels
required by WID and so it would not alleviate the need for further abatement.
The proposed technology has been demonstrated on other sites to meet the required
emission limits for NOx by using SNCR.
A BAT assessment of both SNCR and SCR has been carried out in Annex 6 section 2
with an additional assessment of FGR plus SNCR. The conclusions are summarised
below.
2.4.2.2
Conclusion
Table 2.8 – Comparison Table, NOx Abatement Options
Capital Cost
NOx abated
t p.a.
Photochemical
Ozone
Creation Potential (POCP)
Global Warming Potential
t CO2 p.a.
Urea
t p.a.
Annualised Cost

SNCR
SCR
FGR+SNCR
£740,000
£5,910,000
£2,120,000
260
430
150
-10,700
-4,200
-10,700
1,400
4,800
1,900
700
370
410
£295,000
£1,160,000
£462,000
SNCR vs. FGR+SNCR
Some suppliers of grates have designed their combustion systems to operate
with FGR, and these suppliers can gain benefits of reduced NOx generation from
the use of FGR. Other suppliers of grates have focussed on reducing NOx
generation through the control of primary and secondary air and the grate
design. Both grate designs operate at the same NOx emission level. Therefore,
suppliers which have designed their systems to reduce NOx through controlling
air supplies gain no benefit from the use of FGR.
Introducing FGR increases the annualised costs by 55%, or approximately
£167,000, whilst reducing the consumption of urea by 390 tonnes per annum
and abating an additional 110 tonnes per annum of NOx. FGR has no effect on
the direct environmental impact of the plant, but it increases that impact on
climate change by 500 tonnes per annum of CO2. Therefore the effective cost of
FGR is approximately £1,500 per additional tonne of NOx abated.
However, this is based on the assumption that FGR reduces the furnace’s NOx
generation. As discussed in section 2.4.2.1 above, this is not necessarily the
case for all furnace manufacturers. Some designs can achieve lower levels of
NOx without FGR.
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
SNCR vs. SCR
Using SCR increases the annualised costs by £865,000 and the global warming
potential by 3,400 tonnes of CO2, while reducing urea consumption by 330
tonnes and abating an additional 100 tonnes of NOx. This gives an effective cost
of approximately £5,400 per additional tonne of NOx abated. When taken with
the additional contribution to climate change, this is not considered to represent
BAT.
It is possible to achieve lower levels of NOx than 70 mg/m3 with SCR, although
this increases the urea consumption. However, this would not change the
conclusion of this assessment. The cost per tonne of NOx abated would remain
high, and the impact on climate change combined with the extra cost is
considered to outweigh the reduction in NOx emissions.
SNCR is considered to represent BAT for the Beddington ERF. FGR is considered to be
BAT if it improves the performance of the furnace, but this will be dependent on the
selected furnace manufacturer/supplier, as discussed in section 2.4.2.1 above.
2.4.3
Acid Gas Abatement System
There are currently three technologies widely available for acid gas treatment on
municipal waste incineration plants in the UK:
(1)
Wet scrubbing, involving the mixing of the flue gases with an alkaline solution of
sodium hydroxide or hydrated lime. This has a good abatement performance, but it
consumes large quantities of water, produces large quantities of liquid effluent
which require treatment and has high capital and operating costs. It is mainly used
in the UK for hazardous waste incineration plants where high and varying levels of
acid gases in the flue gases require the buffering capacity and additional abatement
performance of a wet scrubbing system.
(2)
Semi-dry, involving the injection of lime as a slurry into the flue gases in the form
of a spray of fine droplets. The acid gases are absorbed into the aqueous phase on
the surface of the droplets and react with the lime. The fine droplets evaporate as
the flue gases pass through the system, cooling the gas. This means that less
energy can be extracted from the flue gases in the boiler, making the steam cycle
less efficient. The lime and reaction products are collected on a bag filter, where
further reaction can take place.
(3)
Dry, involving the injection of solid lime into the flue gases as a powder. The lime is
collected on a bag filter to form a cake and most of the reaction between the acid
gases and the lime takes place as the flue gases pass through the filter cake. In its
basic form, the dry system consumes more lime than the semi-dry system.
However, this can be improved by recirculating the flue gas treatment residues,
which contain some unreacted lime and reinjecting this into the flue gases.
Wet scrubbing is not considered to be suitable, due to the production of a large volume
of hazardous liquid effluent and a reduction in the power generating efficiency of the
plant.
The dry and semi-dry systems can easily achieve the emission limits required by the
Waste Incineration Directive and both systems are in operation on plants throughout
Europe. Both can be considered to represent BAT by Sector Guidance Note S5.01. The
advantages and disadvantages of each technique are varied which makes assessment
complex, therefore the assessment methodology described in Horizontal Guidance Note
H1 has been used and is detailed in Annex 6 section 1.
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The table below compares the options for acid gas treatment.
Table 2.9 – Comparison Table, Acid Abatement Options
SO2 abated
t p.a.
POCP
tonnes
ethylene
eq
Global Warming Potential
t CO2 p.a.
Raw Materials
APC Residues
t p.a.
Waste water
Annualised Cost
£ p.a.
Dry
Semi-Dry
80
80
380
380
5,000
8,100
More lime, less water
Less lime, more water
9,100
9,100
No
No
£4,540,000
£4,720,000
The performance of the options is very similar. The semi-dry system has a greater global
warming potential and greater annualised operating costs that the dry system.
The dry system will use less water than the semi-dry system. In addition, reagent
consumption can be reduced by recycling within the flue gas treatment plant. The two
systems produce the same quantity of residues, however, in a semi-dry system it will not
be possible to recycle reagent within the flue gas treatment plant.
Due to the lower global warming potential and opportunities for recycling reagent within
the flue gas systems, the dry acid gas control system is considered to represent BAT for
the Beddington ERF.
The dry system will include recirculation of APCr residues back into the flue gas
treatment plant.
2.4.4
Particulate Matter
The proposed plant will use a multi-compartment fabric filter for the control of
particulates. There are a number of alternative technologies available, but none offer the
performance of the fabric filter. Fabric filters represent BAT for this type of MSW
combusting installation for the following reasons:
(1)
Fabric filters are a proven technology and used in a wide range of applications. The
use of fabric filters with multiple compartments, allows individual bag filters to be
isolated in case of individual bag filter failure.
(2)
Wet scrubbers are not capable of meeting the same emission limits as fabric filters.
(3)
Electrostatic precipitators are also not capable of abating particulates to the same
level as fabric filters. They could be used to reduce the particulate loading on the
fabric filters and so increase the acid gas reaction efficiency and reduce lime
residue production, but the benefit is marginal and would not justify the additional
expenditure, the consequent increase in power consumption and significant
increase in the foot-print of the facility.
(4)
Ceramic Filters have not been proven for this type of MSW combustion plant, and
are regarded as being more suited to high temperature filtration.
Fabric filters are considered to represent BAT for the removal of particulates for this
installation.
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2.5 Cooling System Selection
There are three potential BAT solutions considered in Sector Guidance Note EPR 5.01 as
representing indicative BAT for the installation, which are:

Air Cooled Condenser (ACC);

Once though Cooling; and,

Evaporative Condenser.
The plant will operate an ACC to condense the steam output from the turbine to allow
return of the condensate to the boiler. The advantages of using ACC are that it does not
require large volumes of water and does not generate a discharge. There is no visual impact
of the ACC, as required for evaporative cooling.
The ACC will be designed and guaranteed by the technology supplier with enough additional
capacity to maintain turbine efficiency during the summer.
Once through cooling systems require significant quantities of water. As there is no readily
available supply of water once through cooling systems are not regarded as appropriate for
this installation.
Evaporative condenser systems also require large volumes of water. There is no local
abstraction point so this would lead to significant potable water use. Chemical additives are
also needed which means there would be a significant effluent flow to water or sewer.
Additionally, evaporative condensers have a significant potential for release of water vapour
plumes.
Air cooled condensing is considered to represent BAT for this installation.
2.6 Specific Information required by the Waste Incineration Directive
This section contains information on how the plant will be designed, equipped and run to
make sure it meets the requirements of Council Directive 2000/76/EC.
2.6.1
Furnace Requirements
Legislative Obligations – Waste Incineration Directive (2000/76/EC)
(1)
The design of the combustors will ensure that all gases resulting from the
combustion of waste are maintained at or above 850ºC for at least 2 seconds;
(2)
Sufficient oxygen levels will be maintained to ensure good combustion.
(3)
Auxiliary burners, fired with gas oil are used to automatically maintain furnace
conditions, again controlled by the combustion control system;
(4)
Measures will be included to minimise the amount and harmfulness of residues
formed from the combustion process. The bottom ash from the combustion process
will not exceed Total Organic Carbon 3% or Loss on Ignition 5%.
(5)
Urea powder will be injected into the combustion chamber to reduce NOx
emissions.
Moving Grate Operation and Combustion Air
The waste will be transferred onto the moving grate from the feeding chutes by hydraulic
power feeding units. Waste charging requirements are detailed in section 2.6.1.4. Fixed
and moving sections on the inclined grate will move the waste from the feed inlet to the
residue discharge. The grate movements mix the waste along the surface of the grate to
ensure that all waste is exposed to the combustion process.
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Primary air for combustion will be fed to the underside of the grates by fans. Secondary
air will also be admitted above the grates to create turbulence and ensure complete
combustion with minimum levels of oxides of nitrogen (NOx). Multiple air injection points
will be provided in groups in both primary and secondary air systems and the proportion
of combustion air sent to each group will be adjustable by the operator. The volume of
both primary and secondary air will be regulated by a combustion control system.
The combustion chamber and associated outlet gas ducts will be designed to be as airtight as possible and will be maintained under a slight negative pressure to prevent
releases into the atmosphere.
During operation the temperature in the combustion chamber will be continuously
monitored and recorded to demonstrate the compliance with the Waste Incineration
Directive. Temperature sensors installed within the boiler will identify if the temperature
within the first pass falls below 860°C. The combustion control system will automatically
start the auxiliary burners when the temperature drops to this level.
The combustion control system will be an automated fully adjustable system, including
the monitoring of combustion and temperature conditions of the grate, modification of
the waste feed rate and the control of primary and secondary air. The control system will
automatically control combustion to avoid excessive temperatures or uneven
temperature profiles that would lead to increased NOx formation.
Boiler Design
The boiler will include the following design features to minimise the potential for
reformation of dioxins within the de-novo synthesis range:

The steam/metal heat transfer surface temperature will be a minimum where the
flue gas in the de novo synthesis temperature range.

CFD will be used to confirm that there are no pockets of stagnant or low velocity
gas.

Boiler passes will be progressively decreased in volume so that the gas velocity
increases through the boiler, and

Boiler surfaces have been designed to minimise boundary layers of slow moving
gas.
In addition, the boiler will include control for preventing the build up of deposits in the
boiler.
Supplementary Burners and Fuels
Supplementary burners will be provided for start-up and shut-down and to maintain the
combustion chamber temperatures above the legislative requirements of 850ºC during
operation. They will be automatically initiated by the combustion control systems.
2.6.1.1
Validation of Combustion Conditions
The plant will be designed to provide a residence time, after the last injection of
combustion air, of more than two seconds at a temperature of at least 850°C. This
criterion will be demonstrated using Computational Fluid Dynamic (CFD) modelling
during the design stage and will be approved by the EA by way of a Pre-operational
Condition.
It will also be demonstrated during commissioning that the Plant can achieve
complete combustion by measuring concentrations of carbon monoxide, volatile
organic compounds and dioxins in the flue gases and TOC of the bottom ash.
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During the operational phase, the temperature at the 2 seconds residence time point
will be monitored to ensure that it remains above 850oC. The location of the
temperature probes will be selected using the results of the CFD model. If it is not
possible to locate the temperature probes at precisely the 2 seconds residence time
point then a correction factor will be applied to the measured temperature.
Urea will be injected into the combustion gases at a temperature of between 850 and
1000°C. This narrow temperature range is needed to reduce NOx successfully and
avoid unwanted secondary reactions, meaning that at least two levels of injection
points are needed in the radiation zone of the furnace.
Sufficient nozzles will be provided at each level to distribute the urea correctly across
the entire cross section of the radiation zone. Advanced CFD modelling will be used to
define the appropriate location and number of injection levels as well as number of
nozzles to make sure the SNCR system achieves the required reduction efficiency for
the whole range of operating conditions while maintaining the ammonia (NH3) slip
below the required emission level.
The CFD modelling will also be used to optimise the location of the secondary air
inputs to the combustion chamber.
2.6.1.2
Measuring Oxygen Levels
The oxygen concentration at the boiler exit will be monitored and controlled to ensure
that there will always be adequate oxygen for complete combustion of combustible
gases. Oxygen concentration will be controlled by regulating combustion airflows and
waste feed rate.
2.6.1.3
Combustion System
The ERF will be controlled from the Central Control Room. A modern control system,
incorporating the latest advances in control and instrumentation technology, will be
used to control operations, optimising the process relative to efficient heat release,
good burn-out and minimum particle carry-over. The combustion control system will
include an infra-red camera to identify cold spots on the grate, and redistribute waste
accordingly to maximise energy release. The system will control and/or monitor the
main features of the plant operation including, but not limited to the following:

primary air;

secondary air;

waste feed rate;

SNCR system;

flue gas oxygen concentration at the boiler exit;

flue gas composition at the stack;

combustion process;

boiler feed pumps and feedwater control;

steam flow at the boiler outlet;

steam outlet temperature;

boiler drum level control;

flue gas control;

power generation;
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
steam turbine exhaust pressure.
The response times for instrumentation and control devices will be designed to be fast
enough to ensure efficient control.
2.6.1.4
Waste Charging
The ERF will meet the indicative BAT requirements outlined in the Incinerator Sector
Guidance Note for waste charging and the specific requirements of WID:

The combustion control and feeding system will be fully in line with the
requirements of WID. The conditions within the furnace will be continually
monitored to ensure that optimal conditions are maintained and that the
mandatory WID emission limits are not exceeded. Temperature sensors installed
within the boiler will identify if the temperature falls below 860°C. The
combustion control system will automatically start the auxiliary burners when
the temperature drops to this level.

The waste charging and feeding systems will be interlocked to prevent waste
charging when the furnace temperature is below 850ºC, both during start-up
and if the temperature falls below 850°C during operation;

The waste charging and feeding systems will also be interlocked to prevent
waste charging if the emissions to atmosphere are in excess of an emission limit
value;

Following loading into the feeding chutes by the grab, the waste will be
transferred onto the grates by hydraulic powered feeding units;

The backward flow of combustion gases and the premature ignition of wastes
will be prevented by keeping the chute full of waste and by keeping the furnace
under negative pressure;

A level detector will monitor the amount of waste in the feed chute and an alarm
will be sounded if the waste falls below the safe minimum level. Secondary air
will be injected from nozzles in the wall of the furnace to control flame height
and the direction of air and flame flow.
The feed rate to the furnace will be controlled by the combustion control system.
2.6.1.5
Bag Filter Operation
The bag filter will not require a flue gas bypass station.
2.6.2
Unavoidable Stoppages
The table below lists unavoidable stoppages, disturbances and failures of the abatement
plant or continuous emission monitoring system during which plant operation will
continue. The table also shows the maximum anticipated frequency of these events. It is
highly unlikely that all of these events would occur at their maximum anticipated
frequencies.
Table 2.10 – Unavoidable Stoppages
Event
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Mitigation
Action
Required
Incident
Duration
Anticipated
Maximum
Frequency
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Table 2.10 – Unavoidable Stoppages
Event
Mitigation
Action
Required
Incident
Duration
Anticipated
Maximum
Frequency
Combustion air
fan(s) failure
Maintenance
Emergency
shutdown
initiated
10 min until
combustion
stopped
Once every 3
years
Filter bag leak (not
exceeding
particulate ELV’s)
Maintenance
Isolation of
filter
compartment
Bag
replacement
30 min until
filter
compartment
isolated
Once a year
Failure of lime
hydrate dosing
system
Stand-by reagent
blower;
filter cake on bag
filter acting as
buffer
Start stand by
blower
-
Twice a year
Failure of SNCR
reagent dosing
system
Stand-by dosing
pump
Start stand by
pump
-
Twice a year
Failure of
activated carbon
dosing system
Stand-by reagent
blower / detection
by flow indicator
Start stand by
blower
-
Twice a year
Loss of electricity
generation
Emergency supply
from back-up diesel
generators
If emergency
supply fails,
emergency
shutdown
initiated
Failure of emission
monitoring
equipment
Redundant
equipment is
installed;
maintenance
Start stand by
CEMS
Burner not starting
as needed when 2
second
temperature drops
below 850C
Maintenance of
burner
Emergency
shutdown
initiated
10 min until
combustion
stopped
Once every
10 years
Failure of ID Fan
Maintenance ;
bearings vibration
monitoring
Emergency
shutdown
initiated
10 min until
combustion
stopped
once every 5
years
Weekly test of
burner
10 min until
combustion
stopped
-
Once every
10 years
Twice a year
Should the grid connection fail, the turbine generator will switch automatically to island
mode to allow for continued operation, although without electrical export to the grid.
Should the grid connection fail while the plant is running in import mode, then a standby
diesel generator will start automatically to restore power to those high-priority circuits
required to permit safe plant shut-down. The standby generator will not be used as a
source of power for normal operations.
In addition, an uninterruptible power supply (UPS) will be installed to provide power to
sensitive items of electrical equipment that could be damaged by the loss of power, or
cause operational difficulties due to the loss or corruption of data. The UPS will be
capable of at least 30 minutes of continuous operation to provide time for the standby
diesel generator to run and synchronise so as to re-supply the equipment.
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2.7 Energy Efficiency
2.7.1
General
The ERF will utilise a waste fired steam boiler. The generated steam will supply a steam
turbine generator to generate electricity.
The facility will supply electricity to the local electricity grid via a power transformer
which increases the voltage to the appropriate level. The plant will be configured as a
Combined Heat and Power (CHP) Plant and will have capacity to export heat to local
users
In case of failure of the electricity supply, an emergency supply from diesel back-up
generators will be provided to safely shut down the plant.
In considering the energy efficiency of the facility, due account has been taken of the
requirements of the Environment Agency’s Horizontal Guidance Note H2 on Energy
Efficiency.
2.7.2
Basic Energy Requirements
The ERF will be capable of generating 26.1 MWe with no steam export. About 3.9 MWe of
this electricity will be used within the facility as a parasitic load with the remaining
22.2 MWe available for export to the National Grid.
An indicative Sankey Diagram for the proposed design, assuming no heat export, is
presented below:
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The plant will be configured as a Combined Heat and Power (CHP) Plant and will have
capacity to export heat to local users and power to the National Grid. The turbine has
been designed to deliver up to 20MW of thermal energy to the CHP plant, which could
deliver approximately 150,000 MWh of thermal energy per year. A report titled ‘CHP
Report’ has been developed in support of the planning application and can be found in
Annex 9. When potential heat users become available, the provision of a heat supply will
be possible without modification to the installed system.
The precise electrical parasitic load will be determined when the EPC Contractor is
appointed and a breakdown will be supplied to the Environment Agency at that time.
However, the most significant electrical consumers are anticipated to be the following:

Combustion air fans;

Induced draft fans;

Boiler feed water pumps;

ACC fans;

Waste loading systems, reagents injection, ash and residue conveying systems;

Bottom ash conveying system; and

Offices and ancillary rooms.
The facility will be designed with careful attention being paid to all normal energy
efficiency design features, such as high efficiency motors, high standards of cladding and
insulation etc.
The plant will be designed to achieve a high thermal efficiency. In particular:

The boilers will be equipped with economisers and super-heaters to optimise
thermal cycle efficiency without prejudicing boiler tube life, having regard for the
nature of the waste that is being burnt;

Unnecessary releases of steam and hot water will be avoided, to avoid the loss of
boiler water treatment chemicals and the heat contained within the steam and
water;

Low grade heat will be extracted from the turbine and used to preheat combustion
air in order to improve the efficiency of the thermal cycle;

Steady operation will be maintained where necessary by using auxiliary fuel firing;

Boiler heat exchange surfaces will be cleaned on a regular basis to ensure efficient
heat recovery; and

A secondary economiser will recover heat downstream of the main boiler to cool
down the flue gas to the right temperature for lime injection.
Due consideration will be given to the recommendations given in the Sector Guidance
Note.
2.7.2.1
Operating and Maintenance Procedures
The O&M procedures will include the following aspects:

good maintenance and housekeeping techniques and regimes across the whole
plant;

Plant Condition Monitoring carried out on a regular basis, to ensure, amongst
other things, that motors are operating efficiently, insulation and cladding are
not damaged and that there are no significant leaks; and

operators trained in energy awareness and encouraged to identify opportunities
for energy efficiency improvements.
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Energy Efficiency Measures
An energy efficiency plan will be built into the operation and maintenance procedures
of the plant ensuring maximum, practical, sustainable, safe and controllable electricity
generation. This plan will be reviewed regularly as part of the ISO:14001 process.
During normal operation, procedures will be reviewed and amended, where
necessary, to include improvements in efficiency as and when proven new equipment
and operating techniques become available. These are assessed on the
implementation cost compared with the anticipated benefits.
2.7.3
Further Energy Efficiency Requirements
The plant will not be subject to a Climate Change Levy agreement, although the energy
generated will be partially exempt from the levy.
Under the Waste Incineration Directive, heat should be recovered as far as practicable.
In order to demonstrate this, the following points should be noted:
(1)
The boiler will operate with superheated steam at a pressure of around 60 bar-g
and a temperature of 400°C. Higher steam temperatures would potentially lead to
more corrosion of the superheater tubes.
(2)
As discussed earlier, the flue gas treatment system will be based on the dry
injection of lime, rather than the injection of a wet slurry. The disadvantage of
injecting a slurry is that the water in the slurry evaporates, absorbing energy. This
means that the flue gas temperature entering the flue gas treatment system has to
be higher, so that the temperature of the flue gases reacting with the lime is
maintained at around 140°C. With a dry system, the flue gases can be cooled to
140°C by extracting the energy into the condensate water, improving the efficiency
of the heat recovery.
The plant is designed to generate approximately 26.1 MWe from the nominal design
capacity of 275,000 tonnes of waste per annum with a calorific value of 9.8 MJ/kg. This
equates to an electrical generation rate of 9.5 MW per 100,000 tonnes of waste per
annum. The efficiency of the proposed plant therefore exceeds the benchmark efficiency
figures, stated within EA Guidance Note EPR5.01, demonstrating the efficiency of the
plant.
The benchmark specific energy consumption for EfW is stated in the Waste Incineration
BREF as 150 kWh/te. The EfW plant will have a specific energy consumption of
103.1 kWh/te. Therefore the EfW plant will compare favourably with the benchmark
stated in the BREF.
2.8 Waste Recovery and Disposal
2.8.1
Introduction
The main residue streams arising from the facility are:
(1)
Bottom ash from the combustion process (Residue Type RT1);
(2)
APC residue and fine ash particles (Residue Type RT2).
As described below, the waste recovery and disposal techniques will be in accordance
with the indicative BAT requirements. The wastes generated are summarised in Table
2.11.
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2.8.2
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Bottom Ash
Bottom ash has been used for at least 20 years in Europe as a substitute for valuable
primary aggregate materials in the construction of roads and embankments. As detailed
earlier in this document, the bottom ash will be transferred to a suitably licenced waste
facility for reprocessing into a secondary aggregate.
2.8.3
Air Pollution Control Residues
APC residues are predominantly composed of calcium as hydroxide, carbonate, sulphate
and chloride/hydroxide complexes. Typical major element concentration ranges for the
UK residues are as follows:

30-36% w/w Calcium

12-15% w/w Chlorine

8-10% w/w Carbonate (as C)

3-4% w/w Sulphate (as S).
Silicon, Aluminium, Iron, Magnesium and Fluorine are also present in addition to traces
of dioxins and the following heavy metals: Zinc, Lead, Manganese, Copper, Chromium,
Cadmium, Mercury, and Arsenic.
APC residues will be sent to a secure hazardous waste landfill site for disposal as a
hazardous waste. Alternatively it may be possible to send the residue to an effluent
treatment contractor, to be used to neutralise acids and similar materials.
APC Residues will be removed from site in enclosed bulk powder tankers by specially
qualified drivers, thereby minimising the chance of spillage and dust emissions. During
the tanker filling operation, displaced air will vent back to the silo and any releases to
atmosphere would pass through a fabric filter.
The process controls for the minimisation of APC residues are identified in Section
2.1.5.3.
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Table 2.11 – Key Waste Streams
Source/
Material
Bottom Ash
Properties of
Waste
Storage location/
volume stored
Grate ash, grate Bottom ash storage area
riddlings,
boiler
ash. This ash is
relatively
inert,
classified as nonhazardous.
Fly Ash / APCR Fly
ash
and APCR silo.
residue from dry
flue
gas
treatment,
may
contain
some
unreacted lime
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Future annual
quantity of
waste produced
(estimate)
Recover/Disposal Route
and Transport Method
Frequency
69,000 tonnes
A small fraction of the bottom Daily/Weekly
ash will be unsuitable for use
as an aggregate and will be
landfilled. Transport occurs by
road vehicles.
9,100 tonnes
Recycled or disposed of in a Weekly
licensed site for hazardous
waste. Transport occurs by
road vehicles.
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2.9 Management
The Plant will be designed and constructed following the latest international and national
regulations, standards and guidance. This will incorporate risk management techniques such
as HazOp studies prior to construction and thorough commissioning and testing before plant
takeover.
Continued Safety, Health and Environmental excellence will be ensured by employing the
latest management best practice as outlined below.
2.9.1
Introduction
Viridor operate a Business Management System (BMS). Viridor’s aim is to protect human
health and the environment by safely, responsibly and efficiently managing waste, and
by maximising recycling and resource generation.
2.9.2
Business Management System
Viridor was the first UK waste company to achieve ISO 14001, the highest international
environmental standard, across all of its major operational sites, providing assurance to
both our customers and communities near our operations. Viridor’s Business
Management System (BMS) incorporates formal environmental, quality, and health and
safety management processes, and applies to all operational facilities.
Compliance with system requirements and policies is mandatory and subject to periodic
audit. Viridor’s BMS is accredited to the following standards:

ISO 14001 Environmental Management Systems;

BS OHSAS 18001 Occupational Health and Safety Management Systems; and

ISO 9001 Quality Management System.
In addition to an already established management system, Viridor is also incorporating a
Competence Management System (CMS), which will demonstrate that Viridor is
technically competent to carry out a wide range of permitted waste operations in
accordance with all appropriate regulatory requirements. The commitment to
implementing CMS complements the ongoing policy to build an environmentally sound
business with a safe working environment.
2.9.3
Integrated Management Systems
An integrated management system (IMS) is a management system which integrates all
components of a business into one coherent system to enable the achievement of its
purpose and mission.
Viridor’s BMS is an IMS based on the systematic Plan – Do – Check – Act principle, and
shares common elements across ISO 9001, ISO 14001, OHSAS 18001, and CMS. Also
integrated are standards for Carbon Management and Biodiversity, which naturally fall
into the existing management system structure.
The common elements include:
(1)
Policy;
(2)
Planning;
(3)
Implementation and operation;
(4)
Performance assessment;
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(5)
Improvement; and
(6)
Management review.
This approach allows common elements of compliance, corrective and preventative
actions and continual improvement to be delivered more efficiently using a single
management system.
Benefits of integration include:

An improved business focus;

Promotion of communication between disciplines;

Encouragement of involvement and ownership;

Provision of a framework for establishing and reviewing objectives;

Reduction of duplication; and

Provision of a simplified approach.
A summary of the key elements of Viridor’s Business Management System is given in the
table below.
Table 2.12 – Key elements of Viridor’s Business Management System
General
Requirements
Policy
Establish policies, set objectives and targets with the aim of
compliance, continual improvement with sustained customer
satisfaction. Top down visible leadership and commitment, critical to
the success of the system, but with the involvement of everyone.
Define the strategic intent and values of the business.
Strengthens corporate commitment.
Includes Corporate Social Responsibility statement and Health,
Safety & Welfare Policy Document.
Planning and Risk
Management
Risk identification and management & control to determine which
issues are significant and depending on the resultant risk, operational
control measures or improvements are implemented.
Identifying and responding to any unplanned event, potential
emergency or disaster. Control of non-conforming products/services.
Implementation
and Operation
The implementation of plans to achieve objectives and targets. The
organisation of people, resources and systems needed to operate all
facilities and services to the highest environmental, health and
safety, and professional standards.
The induction and training procedures ensure that all personnel are
competent to carry out their roles and responsibilities.
The development and maintenance of documented procedures.
Performance
Monitoring, measurement and analysis of performance and customer
satisfaction. Implementation of the audit programme and evaluation
of legal compliance. Corrective, preventative and improvement action
is implemented as required.
Customer perception of the service Viridor provides and/or product
provided. This data is collected, analysed, and used to improve
performance.
Includes Monitoring and Measurement of performance, Evaluation of
Compliance, Internal Audit, and Handling of nonconformities.
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Table 2.12 – Key elements of Viridor’s Business Management System
2.9.4
Improvement
Commitment to continuously improving the effectiveness of the
Business Management System and providing a quality service.
Management
Review
The performance of the system is reviewed and reported regularly to
the Executive. Changes to ensure continued suitably, adequacy and
effectiveness are discussed and implemented.
Developing, Implementing and Improving the BMS
The general scheme of the BMS follows the four-step management method used in
business for the continuous improvement of processes:
(1)
PLAN – establish objectives and processes;
(2)
DO – implement processes;
(3)
CHECK – monitor and measure processes; and
(4)
ACT – take actions to improve process performance.
Development, implementation and improvement of the BMS are considered individually
below.
2.9.4.1
Developing
Viridor uses a business process approach to identify those areas that need to be
managed and controlled in order to deliver essential waste and recycling services to
public and private sector customers across the UK whilst taking due account of health
& safety, environmental obligations, and regulatory and social responsibilities.
Viridor believe that by adopting this approach they can provide its customers,
regulators, employees and interested parties with confidence that significant issues
are being properly managed and that the company can comply with legal and
customer requirements and deliver quality waste management and recycling services.
2.9.4.2
Implementing
The Business System allows a common approach to be adopted across all units. As
the company expands with the addition of new facilities, the BMS is implemented.
Sites will then achieve external accreditation within the shortest practical timescale.
2.9.4.3
Improving
Corporate Targets are agreed annually by the Executive Committee and delivered
through improvement programmes and site action plan meetings (SAP). They are
designed to achieve continual improvement. Sites are also encouraged to set local
targets relevant to their specific activities based upon the results of risk assessments.
Progress against objectives is reviewed at least three times per year by the Executive
Committee. An external Corporate Responsibility report is produced annually. The
report undergoes a rigorous external verification process and is available on Viridor’s
website. It is distributed to interested parties as necessary.
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2.9.5
FICHTNER
Reporting Structures and Communication
Control and co-ordination of HS&E matters is provided through a framework of meetings
at company, business and site level. The overall structure is described below, and
provides a robust structure to monitor and direct improvements in the HS&E
performance of the business.
(1)
Senior Executive Committee
Chaired by the Managing Director, the Senior Executive Committee comprises
directors from departments within the company. The role of the committee is to
clearly demonstrate leadership and commitment by providing concise direction to
Regional Directors through to Area Managers and operational level (working
groups) through settling policy, strategy, vision, and objectives. It meets on a
quarterly basis.
(2)
Director of Environmental Compliance
Oversees the environmental compliance function, which includes the Business
Management System. Responsible for ensuring that policies, procedures, and
arrangements are in place, kept up to date with new information and legal
requirements, and kept in line with company strategy.
(3)
Corporate Social Responsibility and Regulatory Director
Oversees Environmental Compliance, Health and Safety, Human Resources, and
Training. Responsible for ensuring corporate and social policies, procedures and
arrangements are in place, kept up to date with new information and in line with
company strategy. Ensures that the necessary resources are planned into forward
budgetary programmes.
(4)
Working Groups
Working groups are in place to ensure standardised core procedures are in place
for processes within the company. Collectively, the working groups:
2.9.5.1

Develop and facilitate the implementation of the Business System to achieve
the Company’s objectives;

Develop and implement policies, procedures, and standards;

Provide selected training, support, and advice; and

Contribute to the Management Review process.
Communication
Communication is critical to the success of our BMS and therefore takes many forms
within the organisation. Primarily, information is cascaded from the Senior Executive
Committee down to individual managers and then to operational staff. Communication
takes many forms, examples including dialogue, e-mails, internal memos, specific
instructions, regular management meetings, and notice boards. A company
newsletter, Viridor Voice, is circulated every quarter, and additional news articles
concerning Viridor within external press, local papers and events, are circulated every
month.
The company actively promotes good communications with customers, the public, and
stakeholders through regular press briefings and public liaison meetings. It is the
policy of the company to have an active site liaison group at all appropriate site open
days ensuring direct dialogue with customers.
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The company publishes information on its performance and significant environmental
information within an annual corporate responsibility report, which is externally
verified.
2.10 Commissioning
A commissioning plan, including timelines for completion will be developed for the ERF. This
will be submitted to the EA for approval prior to commencement of operations.
The commissioning plan will include the expected emissions to the environment during the
different stages of commissioning, the expected durations of commissioning activities and
the actions to be taken to protect the environment. In addition, it will include requirements
for reporting to the Environment Agency in the event that emissions exceed expected
emissions.
Commissioning of the ERF shall be carried out in accordance with the
commissioning plan as approved.
An example of a commissioning plan for a facility similar to that proposed is presented in
Annex 8.
2.11 Closure
2.11.1 Introduction
The facility is designed for an operational life of 25 years but its actual operational
lifetime may be greater dependent on a number of factors including:

The continued supply of waste fuels; and

The development of alternative methods competing for the same waste fuels.
When the facility has reached the end of its operational life, it may be adapted for an
alternative use or demolished as part of a redevelopment scheme and the site cleared
and left in a fit-for-use condition.
2.11.2 General
At the end of the economic life of the plant, the development site and buildings may be
converted to other uses or form part of an appropriate landscape restoration plan. The
responsibility for this may well rest with other parties if the facility is sold. However, the
Applicant recognises the need to ensure that the design, the operation and the
maintenance procedures facilitate decommissioning in a safe manner without risk of
pollution, contamination or excessive disturbance to noise, dust, odour, ground and
water courses.
To achieve this aim a site closure plan will be prepared. It is anticipated that the closure
plan will include the information listed below.
2.11.3 Site Closure Plan
The Site Closure Plan will be a standalone document, which will be developed and
updated throughout the life of the plant. The following is a summary of the measures to
be considered within the site closure plan to ensure the objective of safe and clean
decommissioning.
2.11.3.1 General Requirements

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Underground tanks and pipework to be avoided except for supply and discharge
utilities such as towns water and sewerage lines;
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VIRIDOR
FICHTNER

Safe removal of all chemical and hazardous materials;

Adequate provision for drainage, vessel cleaning and dismantling of pipework;

Disassembly and containment procedures for insulation, materials handling
equipment, material extraction equipment, fabric filters and other filtration
equipment without significant leakage, spillage, dust or hazard;

The use of recyclable materials where possible;

Methodology for the removal/decommissioning of components and structures to
minimise the exposure of noise, disturbance, dust and odours and for the
protection of surface and groundwater;

Soil sampling and testing of sensitive areas to ensure the minimum disturbance
(sensitive areas to be selected with reference to the initial site report).
2.11.3.2 Specific Details

A list of recyclable materials/components and current potential outlet sources;

A list of materials/components not suitable for recycle and potential outlet
sources;

A list of materials to go to landfill with current recognised analysis, where
appropriate;

A list of all chemicals and hazardous materials, location and current containment
methods;

A Bill of Materials detailing total known quantities of items throughout the site
such as:

steelwork;

plastics;

cables;

concrete and Civils Materials;

oils;

chemicals;

consumables;

contained water and effluents;

Bottom Ash and APC Residues.
2.11.3.3 Disposal Routes
Each of the items listed within the Bill of Materials will have a recognised or special
route for disposal identified; e.g. Landfill by a licensed contractor, disposal by high
sided, fully sheeted road vehicle or for sale to a scrap metal dealer, disposal by
skip/fully enclosed container, dealer to collect and disposal by container.
2.12 Pre-operational Conditions and Improvement Programme
Viridor is committed to continual environmental improvement and are therefore suggesting
the following improvement conditions be incorporated into the Environmental Permit.
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2.12.1 Pre-operational Conditions
Prior to operation of the installation Viridor will:

submit to the Environment Agency for approval a protocol for the sampling and
testing of incinerator bottom ash for the purposes of assessing its hazard status.
Sampling and testing shall be carried out in accordance with the protocol as
approved.

provide a written commissioning plan, including timelines for completion, for
approval by the Environment Agency. The commissioning plan shall include the
expected emissions to the environment during the different stages of
commissioning, the expected durations of commissioning activities and the actions
to be taken to protect the environment and report to the Environment Agency in
the event that actual emissions exceed expected emissions. Commissioning shall
be carried out in accordance with the commissioning plan as approved.
2.12.2 Commissioning
Prior to commissioning of the installation Viridor will:

submit a written report to the Environment Agency, on the details of the
computational fluid dynamic (CFD) modelling used in the design of the boiler.
The report will demonstrate whether the indicative BAT design stage
requirements, given in the Incineration of Waste Sector Guidance note EPR 5.01,
have been completed. In particular the report will demonstrate that the
residence time and temperature requirements will be met.

submit a written report to the Environment Agency on the commissioning of the
installation. The report will summarise the environmental performance of the plant
as installed against the design parameters set out in the Application.

submit a written report to the Environment Agency describing the performance and
optimisation of the Selective Non Catalytic Reduction (SNCR) system and
combustion settings to minimise oxides of nitrogen (NOx) emissions within the
emission limit values described in the permit with the minimisation of nitrous oxide
emissions. The report will include an assessment of the level of NOx and N2O
emissions that can be achieved under optimum operating conditions.

submit a written summary report to the Agency to confirm by the results of
calibration and verification testing that the performance of Continuous Emission
Monitors complies with the requirements of BS EN 14181, specifically the
requirements of QAL1, QAL2 and QAL3.
2.12.3 Develop Site Closure Plan
Viridor recognise that they will be required to develop a Site Closure Plan to demonstrate
that the indicative BAT requirements for closure will be applied. Viridor would propose
that a Site Closure Plan for the installation is developed, and confirmation is submitted to
the Agency, one year after commissioning of the installation.
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3 WASTE INCINERATION QUESTIONS
The guidance notes on Part B of the Application form states that, in order to respond to
questions 4 to 6 in Appendix 7, the application should include all of the details specified in
Agency Sector Guidance Note EPR5.01, ‘Key Issues’, sub-heading ‘Information you must
include in your application for a permit’. In the table below, we have listed all of the
questions asked in the relevant section and explained where the answer can be found.
Question
Additional Information Required
Location of
additional
information in
application
1
Does the installation contain more than one incineration
line? Identify with a brief reference (e.g. L1, L2 etc) and
provide a brief description (e.g. fixed hearth, chain grate) of
each line.
Refer to Application
From
B3
and
Supporting
Information 1.5.
2
State the maximum design capacity (in tonnes/hour) for
waste incineration for each line, and the maximum total
incineration capacity (in tonnes/hour) of the plant.
Form
B3
and
Supporting
Information 1.5.
3
Are any of the wastes you treat hazardous waste for WID
purposes?
No
4
For each line, provide the following information:
a
Is the operating temperature of the plant, after the last
injection of combustion air, 1100°C for hazardous waste
with greater than 1% halogenated hydrocarbons expressed
as chlorine, or 850°C for all other wastes?
Refer to Supporting
Information – 2.6.1.
b
If the operating temperature is below 1100°C for
incineration of hazardous waste with greater than 1%
halogenated hydrocarbons expressed as chlorine, or below
850°C for all other wastes, you must request a derogation
under WID Article 6(4) with a justification that the operation
will not lead to the production of more residues or residues
with a higher content of organic pollutants than could be
expected if operation was according to the WID conditions.
N/A
c
State the residence time of gas at the operating
temperature given above. Is it less than 2 seconds?
N/A
d
Where the residence time is less than 2 seconds, you must
request a derogation under WID Article 6(4) with a
justification that the operation will not lead to the
production of more residues or residues with a higher
content of organic pollutants than could be expected if
operation was according to the WID conditions.
N/A
e
Describe the technique that will be used to verify the gas
residence time and the minimum operating temperature
given, both under normal operation and under the most
unfavourable
operating
conditions
anticipated,
in
accordance with the WID Article 6 (4).
Refer to Supporting
Information 2.6.1.1
f
Describe where the temperature in the combustion chamber
will be measured with a demonstration that it is
representative in accordance with WID Article 6(1).
Refer to Supporting
Information 2.6.1.1
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VIRIDOR
Question
FICHTNER
Location of
additional
information in
application
5
For each line, describe the automatic system to prevent
waste feed under the following circumstances:
a
during start-up;
Refer to Supporting
Information 2.6.1.4.
b
when continuous emission monitors show that an emission
limit value (ELV) is exceeded due to disturbances or failures
of the abatement equipment;
Refer to Supporting
c
whenever the combustion chamber temperature has fallen
below a set value.
Refer to Supporting
6
State the temperature set point at which waste feed is
prevented. It must be at least the temperature specified in
the WID (1100°C for hazardous waste with greater than 1%
halogenated hydrocarbons expressed as chlorine, or 850°C
for all other wastes) or an alternative temperature as
allowed by WID Article 6(4) in which case the applicant
should demonstrate how WID Article 6(4)’s requirements
are met.
850oC
7
Does the plant use oxygen enrichment in the incineration
combustion gas? If it does, specify the oxygen
concentration in the primary air and secondary air (%
oxygen). This is required to enable us to specify standards
for measurement as required in Article 11 (8).
No.
8
Does each line of the plant have at least one auxiliary
burner controlled to switch on automatically whenever the
furnace temperature drops below a set value in accordance
with the requirements of WID Article 6 (1)? If the set value
is not at least the temperature specified in the WID (1100°C
for hazardous waste with greater than 1% halogenated
hydrocarbons expressed as chlorine, or 850°C for all other
wastes), justify how operating at this lower temperature will
not lead to the production or more residues or residues with
a higher organic pollutant content as required by WID
Article 6 (4)?
Refer to Supporting
Information 2.6.1.
9
Which fuel type is used during start-up/shut-down? If it is
not natural gas, LPG or light fuel oil/gasoil, provide evidence
that it will not give rise to higher emissions than burning
one of those fuels, as specified by the WID Article 6 (1).
Fuel oil will be used
at start-up. Refer to
Supporting
10
Are pre-treatment methods required to ensure that the
quality standard for Total Organic Carbon (TOC) content or
Loss on Ignition (LOI) of the bottom ash or slag is
achieved? If they are, describe them. (WID Article 6 (1)).
No.
11
If any line of the plant uses fluidised bed technology, do you
wish to request a derogation of the CO WID ELV to a
maximum of 100 mg/m3 as an hourly average, as provided
for in WID Annex V (e)? If you do, you must provide a
justification.
N/A
12
For each type of waste to be burned, provide the following
information:
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Refer to Supporting
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Question
Location of
additional
information in
application
a
Waste reference (e.g. WT1, WT2 etc)
Form B3 and
Supporting
Information Section
2.1.4.
b
Waste description (e.g. chemical/physical description, trade
name and firing locations)
Form B3 and
Supporting
Information Section
2.1.4.
c
EWC classification number
Form B3 and
Supporting
Information Section
2.1.4.
d
Maximum and minimum annual disposal in tonnes
Form B3 and
Supporting
Information Section
2.1.4.
e
State whether it is hazardous waste for the purposes of the
WID and if it is, provide the following information:
No hazardous waste
will be incinerated
within the
installation.
i
the hazardous waste category (H1 – 14);
N/A
ii
the names and maximum concentrations in grams/tonne of
the specified substances that cause it to be hazardous. This
should include at least PCB, PCP, chlorine, fluorine, sulphur
and heavy metals if these are present;
N/A
iii
whether it is waste oil, as defined in Article 1 of Council
Directive 75/439/EEC (WID Article 3 (2));
N/A
iv
The waste composition
N/A
v
Is the balance of the waste composition more than 10%? If
it is, give details of the waste components and quantities
likely to be present in the balance.
N/A
vi
Provide calorific value (CV) and feed rate details for the
waste (WID Article 4).
N/A
Hazardous Waste Incineration
N/A
13 to 19
Emissions to Surface Water and Sewer
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Question
Location of
additional
information in
application
20
If the technique by which you clean the exhaust gas from
the incinerator generates waste water, you must give
details of the waste water treatment process and
demonstrate that you comply with the requirements of the
WID Annex IV and Articles 8(4) and 8(5). In particular, if
you mix waste waters from your exhaust gas treatment
with other waste waters prior to treatment, monitoring or
discharge, you must demonstrate how you apply the mass
balance requirements referred to in Articles 8(4) and 8(5)
to ensure that you derive a valid measurement of the
emission in the waste water.
N/A
21
Describe your storage arrangements for contaminated
rainwater run-off, water contaminated through spillages and
water arising from fire-fighting operations. Demonstrate
that the storage capacity is adequate to ensure that such
waters can be tested and, if necessary, treated before
discharge. (WID Article 8 (7)).
Refer to Supporting
Information 2.2.4.
22
For each emission point, give benchmark data for the main
chemical constituents of the emissions under both normal
operating conditions and the effect of possible emergency
conditions. In this section we require further information on
how you monitor the pollutants in these emissions. You
must provide information for flow rate, pH, and
temperature. Article 8 of the WID requires that wastewater
from the cleaning of exhaust gases from incineration plant
shall meet the ELVs for the metals and dioxins and furans
referred to in Annex IV of WID. Where the waste water
from the cleaning of exhaust gases in mixed with other
waters either on or offsite the ELVs in Annex IV must be
applied to the waste water from the cleaning of exhaust
gases proportion of the total flow by carrying out a mass
balance. Monitoring for other pollutants is dependant on the
process and the pollutants you have identified in response
to the question.
There are no
aqueous discharges
from the cleaning of
exhaust gases.
23
For each parameter you must define:
There are no
aqueous discharges
from the cleaning of
exhaust gases.
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
the emission point

the monitoring frequency

the monitoring method

whether the equipment/sampling/lab is MCERTS
certified

the measurement uncertainty of the proposed
methods and the resultant overall uncertainty

procedures in place to monitor drift correction

calibration intervals and methods

accreditation held by samplers or details of the
people used and their training/competencies
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VIRIDOR
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Question
Location of
additional
information in
application
24
Describe any different monitoring that you will carry out
during commissioning of new plant.
None
25
Describe any different arrangements during start-up and
shut-down.
None
26
Provide any additional information on monitoring and
reporting of emissions to water or sewer.
None
Waste recovery/Disposal
27
How do you deal with the residue from the incineration
plant? Explain how you minimise, recover, recycle and
dispose of it.
Refer to Supporting
Information 1.3.7
and 2.8.
CEMS Performance
28
How do you intend to manage the continuous measurement
system to satisfy WID Article 11 (11)? WID Article 11 allows
a valid daily average to be obtained only if no more than

5 half-hourly averages, and

10 daily averages per calendar year
Refer to Supporting
during the day are discarded due to malfunction or
maintenance of the continuous measurement system.
Give details of how calibration, maintenance and failure of
the continuous measurement system will be managed in
order to satisfy these limitations. If necessary distinguish
between different incineration lines.
29
Give details of how you define when start-up ends and
shut-down begins. Describe any different arrangements for
monitoring during start up or shut down. Note that the
emission limit values specified for compliance with the WID
do not apply during start-up or shut-down when no waste is
being burned. Explain how you will integrate these periods
into the emissions monitoring system in such a way that the
reportable averages are calculated between these times,
but the raw monitoring data remains available for
inspection. (WID Article 11(11)). If necessary distinguish
between different incineration lines.
Refer to Supporting
Information 2.3.1.1
30
Describe each type of unavoidable stoppage, disturbance or
failure of the abatement plant or continuous emission
monitoring system during which plant operation will
continue. State the maximum time anticipated before shutdown is initiated for each of these types of unavoidable
stoppage.
Refer to Annex 2 –
Air Quality
Assessment –
Abnormal
Operations
31
Will the values of the 95% confidence intervals of a single
measured value of the daily emission limit value, exceed
the percentages of the emission limit values required by
WID Article 11(11) and Annex III. point 3, as tabulated
below? (We will accept that MCERTS certified instruments
satisfy these quality requirements).
CEMs will be
MCERTS certified
and will therefore
satisfy the WID
requirements.
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Question
32
Location of
additional
information in
application
Describe the monitoring of process variables, using the
format tabulated below. For emissions to air, include at
least the arrangements for monitoring oxygen content,
temperature, pressure and water vapour content at the
points where emissions to air will be monitored (WID Article
11 (7)). For emissions of waste water from the cleaning of
exhaust gases include at least the arrangements for
monitoring pH, temperature and flow rate (WID Article 8
(6)).
Refer to Supporting
Information 2.3.1.1
and 2.3.2.
Heat Recovery
33
You must assess the potential for heat recovery from each
line, using the guidance in this Technical Guidance Note.
You must justify any failure to recover the maximum
amount of heat.
Refer to Supporting
Information 1.3.4
and 2.7.3
Residues
34
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For each significant waste that you dispose of, provide the
following information:

Incineration line identifier

Residue type reference (e.g. RT1, RT2 etc)

Source of the residue

Description of the residue

Details of transport and intermediate storage of dry
residues in the form of dust (e.g. boiler ash or dry
residues from the treatment of combustion gases
from the incineration of waste). Article 9 of the WID
requires operators of incineration plant to prevent
the dispersal in the environment in the form of dust.

Details of the total soluble fraction, and soluble
heavy metal fraction of the residues. Article 9 of the
WID requires operators of incineration plant to
establish the physical and chemical characteristics
and polluting potential of incineration residues.

the route by which the residue will leave the
installation – e.g. recycling, recovery, disposal to
landfill, other.
Refer to Supporting
Information 2.8.
Page 56
VIRIDOR
Question
35
FICHTNER
Article 6(1) of the WID requires incinerators to be operated
in order to achieve a level of incineration such that the slag
and bottom ashes have a total organic carbon (TOC)
content of less than 3%, or their loss on ignition (LOI) is
less than 5% of the dry weight of the material.
Location of
additional
information in
application
LOI or TOC
Where the incinerator includes a pyrolysis stage or other
stage in which part of the organic content is converted to
elemental carbon, the portion of TOC which is elemental
carbon may be subtracted from the measured TOC value
before comparison with the 3% maximum, as specified in
the Defra Guidance on the Waste Incineration Directive.
Note that the WID Article 6(1) requirements are complied
with if either TOC or the LOI measurement referred to
below is achieved.
TOC: for waste incinerators, 3% as maximum as specified
by WID Article 6(1).
LOI: for waste incinerators, 5% maximum as specified by
WID Article 6(1).
Specify whether you intend to use total organic carbon
(TOC) or loss on ignition (LOI) monitoring of your bottom
ash or slag.
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Annex 1
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Location Plan, Site Plans and Process Diagram
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Annex 2
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Air Quality Assessment
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FICHTNER
Annex 3
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Environmental Risk Assessment
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Annex 4
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BAT Assessment
Page 61
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FICHTNER
Annex 5
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Site Condition Report
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Annex 6
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Noise Assessment
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Annex 7
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Firing Diagram
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Annex 8
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Example Commissioning Plan
Page 65
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FICHTNER
Annex 9
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Heat Plan
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Page 67

viridor fichtner viridor beddington erf supporting information

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