Feasibility Report Hub and PoD Driving Innovation in ... Harry Land... · dairy farms within...

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Feasibility Report Hub and PoD – Driving Innovation in Anaerobic Digestion A feasibility report from the „Driving Innovation in AD‟ programme which looks at the Hub and PoD concept. Project code: OIN001-403 Research date: March – June 2012 Date: October 2013

Transcript of Feasibility Report Hub and PoD Driving Innovation in ... Harry Land... · dairy farms within...

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Feasibility Report

Hub and PoD – Driving Innovation in Anaerobic Digestion

A feasibility report from the „Driving Innovation in AD‟ programme which looks at the Hub and PoD concept.

Project code: OIN001-403 Research date: March – June 2012 Date: October 2013

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WRAP‟s vision is a world without waste, where resources are used sustainably. We work with businesses, individuals and communities to help them reap the benefits of reducing waste, developing sustainable products and using resources in an efficient way. Find out more at www.wrap.org.uk This report was commissioned and financed as part of WRAP‟s „Driving Innovation in AD‟ programme. The report remains entirely the responsibility of the author and WRAP accepts no liability for the contents of the report howsoever used. Publication of the report does not imply that WRAP endorses the views, data, opinions or other content contained herein and parties should not seek to rely on it without satisfying themselves of its accuracy. Document reference: [e.g. WRAP, 2006, Report Name (WRAP Project TYR009-19. Report prepared by…..Banbury, WRAP]

Written by: Richard Northridge Cwm Harry Land Trust Project Manager Guy Blanch Alvan Blanch Ltd Principal Technical Writer

Cath Kibbler Community Composting Network Regulatory Advisor Chris Budd Alvan Blanch Commercial Advisor Dr. David Neylan PhD Southampton University Technical Advisor, Hub Jon Halle Sharenergy Cooperative Financial Modelling, ESCo design Angie Bywater Methanogen Ltd Technical advisor, PoD Dr. Andrew Salter PhD Southampton University Technical Advisor Hub & PoD model Dr. Tony Yates PhD SLR Consulting Report Writing & EIA Advisor

Adam Kennerley wm Harry Land Trust Project Director, Editor

Front cover photography: digestate

While we have tried to make sure this report is accurate, we cannot accept responsibility or be held legally responsible for any loss or damage arising out of or in connection

with this information being inaccurate, incomplete or misleading. This material is copyrighted. You can copy it free of charge as long as the material is accurate and not

used in a misleading context. You must identify the source of the material and acknowledge our copyright. You must not use material to endorse or suggest we have

endorsed a commercial product or service. For more details please see our terms and conditions on our website at www.wrap.org.uk

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Hub & PoD – Driving Innovation in AD 1

Executive summary

The original Hub & PoD model is the work of the University of Southampton‟s Bioenergy and Organic Resources Research Group lead by Professor Charles Banks. This original model linked heat coming from Hampshire‟s three EfW plants with the pasteurisation of source separated food waste from households, prior to its delivery to anaerobic digesters located on dairy farms within Hampshire. The study evaluated the feasibility of centralised pre-processing functions relating to food waste followed by its anaerobic digestion (AD) with dairy cattle slurry. Existing data of gross energy yields derived from co-digestion of food waste and cattle slurry were used to model a scenario based on Hampshire for both medium size and large dairy farms. The ratio of cattle slurry to food waste was governed by the nutrient demand of the dairy farm and was modelled using both nitrogen and phosphorous as limiting factors. It was found that the nutrient requirements of the larger farms could be met and it was also found that there were additional benefits – a reduction in GHG (greenhouse gas) emissions through improved slurry management and fertiliser inputs. The study indicated that the approach of Hub & PoD compared well with centralised AD of food waste or energy recovery from thermal treatment in the context of resource conservation and pollution abatement Based on this foundation work this report looks at how the model can help drive innovation in AD development generally in the UK. The study has divided into three parts covering:

1. The technology which could be used to equip a Hub where the centralised feedstock preparation stages take place including maceration, pasteurisation and homogenisation;

2. The dispersed to Points of Digestion or PoDs located on farms; and

3. Other potential sites where the by-products of AD can be used – in particular CO2 and heat in horticulture.

The conclusion reached is that a Hub is best linked to a source of heat, preferably waste heat, which can be made use of as an adjunct to another process. This mirrors the University of Southampton‟s Bioenergy and Organic Resources Research Group‟s pioneering study. “Bolting-on” a Hub in such circumstances has helped govern the design brief – small physical footprint which can all be made off site and dropped into place. This has been translated into a plant which is constructed on a skid and in modular form. The key element is that the technology is not generally, of itself, new but has been introduced into this new application and combination from well-established use in other applications. The work also encompassed the regulatory position. The general approach of the regulators, both the EA and AHVLA, is supportive. They wish to see this model develop into a mainstream approach to food waste treatment, anaerobic digestion on farms, renewable energy generation and nutrient recycling. The task has been made easier by the fact that there have been recent and there are upcoming reviews afoot: the 2011 ABP regulations envisage food waste coming on to farms with livestock; the EA is reviewing exemptions next

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Hub & PoD – Driving Innovation in AD 2

year; AHVLA is now engaged in writing new guidelines for split site processes; PAS110 is due to be reviewed in the next few months. These changes provide an opportunity to place Hub & PoD into the main regulatory architecture rather than finding ways for it to fit into the existing architecture, which this report shows can nevertheless be done. The report has also looked at the business case. This will very much depend on the scale at which the model is used. It will also depend on ensuring that PoDs served by a Hub are in tight geographical clusters as transporting material between a Hub and its PoDs has significant cost. The labour requirement for running a Hub is also dependent on its location and what other activities take place there. For example, a Hub situated at a waste transfer station would take very little additional management input if the same resource was spread across managing a multiple of waste streams and handling procedures. The model offers small scale operators, such as farmers, an opportunity to take market share of an industry which has been almost entirely dominated by very large waste management companies. The Hub & PoD model introduces to AD the “just in time” [“JIT”] logistics and distribution methodologies which dominate manufacturing industry and multi-chain retailing. JIT is a manufacturing process methodology originally developed in the Japanese motor manufacturing industry which ensures that no inventory of resources used in the process is stored for longer than necessary; it optimises the deployment of capital so that components become available to the process only when needed. In taking the industry in this new direction with appropriate technology and business models to underpin it, Hub & PoD has the capacity to optimise AD at any scale.

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Contents

Hub and PoD – Driving Innovation in Anaerobic Digestion .................................... 1 1.0 Introduction ................................................................................................. 8

1.1 Company/consortium ................................................................................. 8 1.2 Introduction to the concept and its technology ............................................. 9

1.2.1 About our Hub ............................................................................... 10 1.2.2 About our PoD ............................................................................... 10

1.3 Background to the proposal ...................................................................... 11 1.4 Application into the UK AD industry now and into the future ........................ 11

1.4.1 Adding alternatives, accessing new market places ............................ 11 1.4.2 Overcoming current technical difficulties .......................................... 11 1.4.3 Maximising renewable energy production ......................................... 12 1.4.4 The potential for utilisation of heat from CHP systems ....................... 12 1.4.5 Anticipating changing trends ........................................................... 12

2.0 Project Objectives ...................................................................................... 12 2.1 Objectives of feasibility study .................................................................... 12 2.2 Meeting the outcomes of DIAD .................................................................. 13

3.0 State of technology .................................................................................... 14 3.1 Development history of the technology ...................................................... 14 3.2 Previous evidence .................................................................................... 15

4.0 Relevant regulations and legislation .......................................................... 15 4.1 From the EA perspective ........................................................................... 15 4.2 From the AHVLA perspective ..................................................................... 17

5.0 Detailed technical appraisal ....................................................................... 18 5.1 Theory/process behind the technology ....................................................... 18

5.1.1 Technical data ............................................................................... 18 5.1.2 5 Inputs and outputs ...................................................................... 21

5.2 Operational parameters ............................................................................ 21 5.3 Comparison with „business as usual‟ .......................................................... 22 5.4 Risk Analysis ............................................................................................ 22

6.0 Economic / Cost Benefit Analysis ............................................................... 22 6.1 Appraisal of the economic model ............................................................... 22 6.2 Comparison of the Hub & PoD financial model compared to the „business as usual‟ financial model ............................................................................................. 23

6.2.1 Phase 1 ......................................................................................... 24 6.2.2 Phase 2 ......................................................................................... 25 6.2.3 Possible Phase 3 ............................................................................ 25

7.0 Overall Environmental Impacts .................................................................. 25 8.0 PART 2 - PHASE 2 DEMONSTRATIONS........................................................ 28

8.1 Objectives for a demonstrator of Hub and Pod............................................ 28 9.0 Methodology for demonstration ................................................................. 28

9.1 Selection of sites / contractors etc. ............................................................ 29 9.1.1 Sites ............................................................................................. 29 9.1.2 Stakeholders .................................................................................. 29 9.1.3 Personnel ...................................................................................... 29 9.1.4 Contractors ................................................................................... 29

10.0 Project timescale - Complete and detailed ................................................. 30 11.0 Commercialisation of technology post demonstration ............................... 31

11.1 Commercialisation plans (including evidence) ............................................. 31 11.1.1 Standards and regulation ................................................................ 31 11.1.2 Anticipated size of the market to be approached ............................... 32

12.0 Evaluation and monitoring (WRAP reporting) ............................................ 32

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13.0 Conclusion .................................................................................................. 32 Appendices ........................................................................................................... 34

Appendix A - List of Wastes treatable under Environmental Permit Standard Rules 15 .. 34 Appendix B - Draft Hazard Analysis and Critical Control Points Plan for Hub & PoD for AHVLA 35 Appendix C – Phase 2 site location assessment ......................................................... 46 Appendix D – Hub process flow diagram and mass balance model ............................. 47 Appendix E – References ........................................................................................ 48 Appendix F – Consortium partner summary CVs ....................................................... 49 Appendix G – additional questions for a Demonstrator to answer ............................... 50 Appendix H – energy calculations – Hub .................................................................. 52 Appendix I – detailed description of Hub components ............................................... 54

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Glossary

ABP Animal By-Products i.e. material of an animal origin ABPR Animal By-Products Regulations - the regulations govern how ABPs can be

disposed of or otherwise treated so as to render them benign. The paramount purpose of the regulations is to preserve animal health and prevent infectious diseases affecting animals

AD Anaerobic Digestion, the biodegradation of organic material in the absence of oxygen

AHVLA Animal Health & Veterinary Laboratories Agency, is an executive agency working on behalf of the Department for the Environment, Food & Rural Affairs (Defra), the Scottish and Welsh Governments

Bespoke Bespoke Permit is a one off EP which is peculiar to the particular circumstance and site

BOD Biological Oxygen Demand – the oxygen demand that bacteria use whilst decomposing biologically available organic matter, where if high BOD organic materials enter a watercourse, they rob the aquatic life of dissolved oxygen during this process

Capex Capital Expenditure CCP Critical Control Point featured in a HACCP plan CH4 Methane CHP Combined Heat and Power Plant – basically an engine which generates

electricity and heat COD Chemical Oxygen Demand – a test commonly used to indirectly measure the

amount of organic compounds in water. Most often applied in the waste water industry in determining the financial charges to be imposed on trade effluent discharges to sewer. COD is expressed in milligrams per litre indicating the mass of oxygen consumed per litre of solution. COD determines the amount of organic pollutants found in solutions as a means of measuring water quality

CO2 Carbon dioxide CoTC Certificate of Technical Competence – a certified graded competency

assessment scheme developed by WAMITAB DM Dry matter EA Environment Agency – a UK Public Body responsible for protecting and

improving the environment and promoting sustainable development EfW Energy from Waste plants commonly called incinerators EP Environmental Permit or Permitting – the mechanism by which controlled

waste activities are permitted to be carried out at specific geographical locations. The EA is vested with the power under the Environmental Permitting Regulations 2008 to grant EPs which replaced the Waste Management Licensing and Pollution Prevention & Control regimes

EWC European Waste Catalogue – an inventory of classified waste materials identified by codes which is now called List of Wastes brought in under the List of Waste Regulations 2005

GHG Green House Gas - gas which absorbs and emits radiation within the thermal infrared range. This process is the fundamental cause of the greenhouse effect causing global warming

HACCP Hazard Analysis & Critical Control Points – a planning tool to identify hazards and corresponding preventative measures in food and pharmaceutical production which has been adapted to ensure safe methods & identify intervention points in the treatment of biodegradable waste streams

Hub & PoD Hub and Point of Digestion, an innovative model whereby organic substrates

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which need complex handling and pasteurisation are treated centrally, with a resultant product being sent to distributed anaerobic digesters, either on farm or community digesters

HRT Hydraulic Retention Time – the time in which a substrate is held in a digester K Potassium, used as a nutrient in fertiliser (potash) KWh Kilowatt hour – the amount of power consumed/generated over a period of

one hour Mogden Mogden Formula – a formula by which water companies impose trade

effluent charges on industrial wastewater sent to sewer, the charge being used to recover the cost of carriage to and treatment in sewage works. The scale of this charge depends on set factors, coupled with the measured "strength" and quantity of the received effluent

MSW Municipal Solid Waste – i.e. those streams of waste resources which include those subject to Landfill Directive targets

MWRP Modernising Waste Regulation Panel – an internal body of the EA which receives applications for temporary permissions to carry out innovative trials of waste management activities. The Panel issues Regulatory Position Statements

N Nitrogen, used as a nutrient in fertiliser Opex Operating expenditure OPRA Operational risk appraisal - an assessment tool used by the EA to profile

individual sites in order to assess the environmental risks that site poses. It takes into account the complexity, emissions, location, competence and ability of the site‟s operator to manage its operations and the compliance rating associated with the permit. A site subject to such an appraisal is given a score on which the EA bases the annual fees payable to it by the operator

OLR Organic Loading Rate (g vs/m3 digester space) - an important parameter affecting microbial ecology

PAS110 Publicly Available Specification 110, an industry specification against which digestate producers can verify that their output material is of consistent quality and fit for purpose

pH Potential hydrogen - a measure of the activity of the solvated hydrogen ion PoD Point of Digestion – the PoD part of Hub & PoD coined by Angie Bywater,

author of „A Review of Anaerobic Digestion Plants on UK Farms‟ published by Royal Agricultural Society of England, 2011

P Phosphorus, used as a nutrient in fertiliser PLC Programmable Logic Controller - used for automation of electromechanical

processes, such as control of machinery on factory assembly lines, amusement rides, or light fixtures. PLCs are used in many industries and machines

RPS Regulatory Position Statement – a measure used by the EA to regulate trials of waste management activities approved by the Modernising Waste Regulation Panel

SOP Standard Operating Procedure – a “how to” step by step approach reduced to written documentation

SR Standard Rules – a class of Environmental Permitting issued by the EA against a set of established and published criteria. If the application for the EP meets the particular rules an applicant can assume an EP will be issued

Substrate An organic feedstock which is fed into an anaerobic digester TS Total Solids T/Yr Tonnes per year Thermophilic Temperatures of AD process operation around 55oC VFA Volatile Fatty Acids – the first degradation product prior to methane

generation – the carbon and hydrogen chains shorten, the shortest being

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acetate VS Volatile Solids – dry solids in feedstocks which convert to gas when heated to

550˚C – it‟s a measure of the gas content in a consignment of feedstock and measured in percentiles of total digester feed

WAMITAB Waste Management Industry Training and Advisory Board, a UK company who train and award technical qualifications in the waste industry

WRAP Waste & Resources Action Programme

Acknowledgements

Cwm Harry Land Trust Ltd

Community Composting Network Ltd

Alvan Blanch Development Co Ltd

Methanogen (UK) Ltd

Southampton University

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1.0 Introduction Hub and PoD is a concept for how AD can be restructured, optimised and made available to a wider market place, allowing more food waste to be digested by a wider range of competitors and at a more localised scale. It has the potential to enable digestion of category 3 catering wastes more widely, drawing in both farmers and communities to the industry and allowing them to benefit. By separating the pasteurisation process from the biogas making process, with the full approval of the regulators, costs can be lowered and more „players‟ encouraged to enter the market. The feedstock preparation (i.e. maceration and pasteurisation) „Hub‟ can be located free from consideration of either grid connection, disposal to land issues and many of the planning constraints often attached to AD. Co-location with the point of material production (be it a local authority transfer station or an industrial producer) or a point of surplus heat (for example EfW) becomes possible. The Hub‟s product is a gas laden „soup‟ which has been de-risked from an ABPR point of view and can be conveyed to PoDs (Points of Digestion) located on farms or community growing sites or in such other places suitable for AD. The effect of this model is to de-centralise and disperse the technology. The aims of our feasibility study are to thoroughly explore and report on the following aspects considered essential for the model to be viable:

the regulatory approval for split site ABPR compliance;

the technical solutions to decentralising both the Hub and the PoD aspects;

a financially viable model for attaining profitability in any individual Hub and PoD; and

a commercialisation model that can deliver its widespread uptake.

1.1 Company/consortium Hub and PoD – as already introduced – is not a one dimensional technical solution, it requires a multidimensional approach including technical, regulatory, fiscal and cooperative ownership factors. It is for this reason that Cwm Harry has brought together a consortium of specialists in aspects of UK AD development.

The consortium is led by Cwm Harry Land Trust [CH] a social enterprise trading in resource management and in the innovation of how commercial operations can meet higher environmental and social objectives by operating at as localised a level as possible. Our skill is in product and service development. Cwm Harry has been represented by Richard Northridge and Adam Kennerley;

Alvan Blanch [AB] are development engineers with a background in designing and manufacturing crop processing equipment for the global market;

Methanogen [M] is an AD technology supplier;

Community Composting Network [CCN] is a UK-wide membership based organisation with over 200 members which supports and promotes community groups, social enterprises and individuals who are involved in recycling nutrient within closed loop and local geographical areas;

Southampton University‟s [SU] Bioenergy and Organic Resources research group is internationally recognised for its work on AD, both as a means of stabilising wastes and for the production of renewable energy from source segregated municipal waste, agricultural residues and energy crops;

Sharenery Cooperative [SC] is a new and innovative way to use community energy to make renewable energy; it‟s been called “local power for local people” and works with community groups to establish renewable energy co-operatives, owned and operated by members of the public.

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The consortium has operated in the following teams:

Technical team – led by AB with input from CH, SU;

Regulatory team – led by CH with input from CCN;

Energy and mass balance assessments – led by AB with input from SLR & SU; and

Fiscal and commercialisation team – led by CH with input from SC & AB.

1.2 Introduction to the concept and its technology The Hub and PoD concept proposes to physically split the feedstock preparation processing stage from the anaerobic digestion processing stage so that, whilst they are regarded as a single process by AHVLA, they take place on physically separate sites. This could be summarised as centralising ABPR compliance at a Hub and dispersing digestion at PoDs. ABPR regulated AD plants have to install all of the compliance equipment and procedures on site. The effects of this are to increase both capex and opex at each plant. The Hub and PoD model should allow each of the stages to be optimised individually enhancing the performance of AD and opening it up to more farm based markets. As the illustration below from Southampton University shows Hub and PoD is not a new concept. A centralised pasteurisation Hub co-located at or near the source of waste is linked to a series of on-farm AD plants best placed to maximise biogas production. The downstream digestate which is best spread to land for soil amendment and improvement will already be located at the farm where it is applied. Moving food waste predominantly harvested in urban environments on to farms in a bio-secure manner and ensuring the post digestion material contributes to the land bank found in farm soils, is a sure foundation for a sustainable low carbon agriculture which meets the challenging demands now being placed upon it.

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Figure 1 (see Appendix E references Banks et al)

1.2.1 About our Hub With the need to co-locate the pasteurisation Hub as close to the source of material and/or the source of surplus heat we investigated the transfer of existing technology in to a unit which is both movable and modular. This gives it maximum flexibility and a fit with the market place. The Hub is purposely designed for the recovery, decontamination, maceration and pasteurisation of biomass (food waste) from the community and surrounding commercial businesses. The plant is designed to fit within the confines of a shipping container and is mounted on a compact skid, subsequently enabling it to be easily accommodated at an existing facility which is producing food waste and / or a surplus of heat. 1.2.2 About our PoD There is far less need to invest in on farm AD solutions that are affordable as several companies are now designing and deploying such technology (Methanogen, Evergreen Gas, Marches Biogas). Our investment has been in the economic model that ensures enough individually viable AD plants are located within vicinity of a Hub, allowing each to perform the role of a PoD. Outside of these two technologies (and the infrastructure to guarantee compliance during transport) we have focused our investment on:

The regulatory fit and contractual relationships of these two technologies when put together in a Hub and PoD configuration;

The environmental performance of this configuration; and

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The financial model that allows this configuration to be commercialised.

1.3 Background to the proposal The original concept for this technology was derived from a paper written by the Bioenergy and Organic Resources Research Group of the School of Civil Engineering and the Environment, University of Southampton: Energetic and environmental benefits of co-digestion of food waste and cattle slurry: a preliminary assessment written by Charles J. Banks, Andrew M. Salter, Sonia Heaven and Keith Riley (see Appendix E– References). The data for this paper was based on a number of dairy farms in the English county of Hampshire and kerbside collected food waste. Currently, this food waste is collected as part of the residual waste stream and is thermally treated at three EfW plants within the county. The study revealed a number of benefits of centralised pre-processing and on-farm co-digestion of food waste. The principal benefit is closing the urban / rural nutrient cycle, by returning food nutrients directly to the farm, thereby contributing to increased sustainability of agricultural production. It is felt it is now the right time to put the theory into practice. CWM Harry are currently researching alternative AD strategies and have engaged with the regulators. The view is that the Hub and PoD concept may well be compliant in terms of the regulations but needs to be demonstrated. The timing is good because this coincides with the coming together of the consortium, each member of which brings specific and necessary expertise to the table. On the other side there is growing market demand for more affordable and more widely applicable AD solutions. 1.4 Application into the UK AD industry now and into the future 1.4.1 Adding alternatives, accessing new market places

Alongside centralised AD plants Hub and PoD adds a flexible and decentralised alternative allowing more wastes to be processed by more entrants into the UK AD industry. 1.4.2 Overcoming current technical difficulties Recent studies commissioned by WRAP and DEFRA on „food waste only‟ digesters, have indicated that there are problems with high ammonia concentrations and recommend co-digesting or blending food wastes with animal slurries. This helps to stabilise the process and to minimise the environmental emissions of ammonia from pure food waste digestate. Hub and PoD overcomes this issue without having to resort to more complex processes like ammonia stripping or costly supplementation of trace elements. The operation of „food waste only‟ digesters need key trace elements like Selenium and Cobalt for long term stability available from slurry.1

1 University of Southampton Valour Gas project: Trace element requirements for stable food waste digestion at elevated ammonia concentrations http://www.valorgas.soton.ac.uk/publications.htm

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1.4.3 Maximising renewable energy production Until now, the UK AD industry has tended to by-pass the traditional big farm scale European AD technology, which is dependent on renewable crops / intensively grown GM maize. Whilst the co-digestion of cattle slurry with maize results in substantially increased farm incomes, as well as contributing to renewable energy targets at the same time mitigating GHG emissions from manure, the number of farms taking up this approach remains small. The inability to raise finance may be one reason for slow uptake and the reluctance to rely on energy crops another. The Hub and PoD concept would potentially get around these barriers – less expensive combined with safe access to high yielding feedstocks (i.e. food waste) which is readily available. 1.4.4 The potential for utilisation of heat from CHP systems AD systems offer an opportunity to help meet renewable energy production targets under the current UK system of feed-in tariffs, but generally, there is negligible interest in the available heat outputs from the CHP system, with the odd exception of some farmers who are investing in biomass drying systems or glasshouses / nurseries. Small scale AD which Hub and PoD may make possible, particularly in the context of community ownership and utilisation, is more likely to exploit all advantages of AD technology including the use of heat for horticulture or other production purposes. 1.4.5 Anticipating changing trends Hub and PoD anticipates the industry downshifting to smaller plants thereby spreading the number of digesters. The German AD industry is also preparing for change, with new legislation expected in 2013, which will encourage the growth of smaller scale, AD systems in the range of 90 to 120 kWe. This change is principally focused on better utilisation of the CHP heat, which is generally neglected on the larger 500 kWe AD plants. So to summarise the position, the Hub & PoD approach has the potential to allow development of small scale AD at a local level capable of generating electricity and heat that can be utilised by local heat users. 2.0 Project Objectives 2.1 Objectives of feasibility study Establish whether a Hub and PoD model can:

Reduce build and operational costs for AD;

Be compliant with ABPR regulations;

Contribute to the improvement of the logistics of collecting and treating food wastes; and

Offer an improvement in the deployment of nutrients.

To report on the technology, chain of custody and compliance of a Hub and PoD model, specifically:

Hub technical design and compliance in a decentralised location; and

The identification of farm / community based AD PoDs capable of accepting material from the Hub.

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Investigate the regulatory fit, specifically: AHVLA and EA positions / Supplementary regulatory issues such as HACCP, SOP‟s / Contractual relationships between the parties etc:

Undertake a life cycle analysis of Hub and PoD providing evidence of:

- Carbon assessment; - Assessment of the environmental sustainability elements (specific reference to GHG emission

reduction potential); and - Optimisation of digester biology.

Identify routes to commercial success, specifically:

Commercial partnerships; and

Economic and business modelling.

2.2 Meeting the outcomes of DIAD ‘The goal of the programme is to make AD work better, quicker or more cheaply resulting in more profitable plants’. Better: a reduction in the complexity of operating centralised AD plants by focussing at a “Hub” not only the functions associated with compliance, namely maceration and pasteurisation, but also blending feedstocks so as to stabilise them prior to delivery to AD “PoDs” thereby improving digester biology and de-risking digester operations. Quicker: material arriving at “PoDs” would be “digester ready” being pumped into the digester direct or more likely a buffer tank. Cheaper: reduction in the capital costs of building smaller scale plants of between 20-40% by the centralisation of bio-security compliance at the “Hub”. Processing Improvement: this proposal also meets the desired project outcome for “Processing” as it will improve “... efficiencies and reactor performance (and) optimisation of digestion biology”. Innovative: the UK falls behind the rest of Europe in terms of new waste technologies and its inherent reliance on land filling. The proposed Hub & PoD project offers an innovative idea at an attractive community scale. As stated by WRAP, this DIAD programme is not intended to fund pure R&D, rather „to facilitate technology transfer from other sectors or processes’. Transfer of technology: the „technology transfer‟ between the proposed Hub technology and an African export project (mobile fruit juice processing) has layers of synergy in several areas, both technically and socially. An example – African countries lose approximately eighty per cent of their fruit crop, because of the transport difficulties and high cost of large fruit processing equipment. Alvan Blanch has proven the initial stages of this process, up to and including the pasteurisation stage with a small scale/community sized solution.

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Figure 2 Illustration to show technology transfer between other sectors

Africa (Uganda) – Mobile fruit juice processing equipment

Transfer of know-how from lab to field – laboratory/bench scale AD research has proven the benefits of co-digestion of biomass – Hub & PoD proposes to capitalise on this research, by enabling PoD operators to access this „gas rich‟ feedstock with a level of knowledge and confidence and convert this de-contaminated biomass into renewable energy. Transfer of economic models, introducing Cooperative ownership models – the UK has the expertise to provide community scale AD technology, but there is an apparent lack of understanding, regarding true economies of scale. This Hub & PoD proposal represents the opportunity to test the theory behind local biomass recovery for energy production in all types of markets – European and other. 3.0 State of technology 3.1 Development history of the technology Decentralised bio-fuel technology is a relatively new concept in terms of energy production for the UK. Increasing demand for renewable energy has encouraged the growth in R & D, particularly in European large farm scale AD technology. This European AD technology has travelled across to the UK and merged with existing UK AD technology to provide technically feasible solutions, but at a high cost. This high cost is one of the main reasons for a slow uptake of AD technology in the UK. Another reason is the difficulty in securing long term feedstock contracts in order to de-risk the large capital investments required. The proposed Hub technology could effectively capture feedstocks such as food waste before it leaves a town, and process it into a safe feedstock that can then be converted into biogas and digestate by the PoD. In terms of decentralised bio-fuel technology, the Hub has the potential to transform food large quantities if waste near to the point of origin into a „useable‟ bio-fuel at a feasible and socially responsible cost. The proposed Hub & Pod approach is a newly developed concept. However, the major components for the Hub have been tried / tested within their own industries, but not as a collective package. The process control components and most importantly „systems‟ have also been tried and tested successfully in the bio-fuel industry for many years.

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3.2 Previous evidence The grinding technology proposed for this project, has a key role to play, with respect to ensuring the system is ABPR compliant. The process for grinding biomass into small particles has been well developed in the large scale AD sector and the European waste water industry. There are a number of grinder manufacturers who offer technically suitable products for this project. The method of pasteurisation proposed for this project – steam injection, has been utilised by the waste water industry. The benefits of steam are detailed further in section 5, but generally this technology is not used on large scale AD systems, because there is an abundance of lower grade heat available from the CHP unit. The technology at the Hub which it is proposed is used is designed and will be built by Alvan Blanch who utilise the benefits of steam injection. AB has long experience of working on many biomass projects in the Middle East and Africa for sterilisation of toxins in animal feed plants. An example is soya which contains a trypsin inhibitor that is removed by heat, prior to digestion in the livestock. 4.0 Relevant regulations and legislation There are two major sets of legislation governing the regulation of Anaerobic Digestion – the Environmental Permits regulated by the EA and the ABPR which fall under the remit of the AHVLA. They do not always correlate as they are intended for different purposes so are considered in turn below. 4.1 From the EA perspective 4 (1) Carrier’s license –the EA does not see any specific issues arising from carrying material between Hub & PoD. 4 (2) Hubs and Environmental Permitting Please note that since this report was submitted guide lines have been published by Defra specifically citing Hub and PoD by name – see http://www.defra.gov.uk/ahvla-en/disease-control/abp/compost-biogas-manure/guidance-hub-pod-anaerobic-digestion/ The purpose of this section of the report is to ascertain whether the materials which the Hub & PoD model seeks to pre-treat and process can be regulated through the first line of regulations and, if not, whether the model will fit into some future achievable Environmental Permitting regulations. As a matter of principle, the EA has a positive view to the centralised pre-treatment of feedstock with subsequent treatment elsewhere by AD as it introduces the “just in time” logistics and distribution methodologies which drive much of manufacturing industry and multi-chain retailing. However, the current regulations do not easily accommodate this approach. This is not to say that the regulations will continue to be an inhibition to the development of the Hub & PoD model, or that the EA will not get behind a move to amend the regulations to enable the model to be compliant, or to prevent, as an interim arrangement, a demonstration trial to be carried out over a time limited period within a specified location. All of these are possible and from the EA‟s perspective have merit and are to be commended.

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AD is governed by either Exemptions, Standard Rules or Bespoke Rules under the SI 2009 No. 3381 Environmental Permitting (England and Wales) (Amendment) (No.2) Regulations, Part 2 which contains the exemptions in detail and SI 2010 No 675 Environmental Permitting (England and Wales) Regulations (as amended). Although currently there is no specific Exemption or Standard Rule for a Hub and PoD style split site with the pre-treatment of feedstock, a standard permit and/or exemption could be created by the EA if a suitable demand arose. Another option is that the site is considered for a Bespoke Permit on a site by site basis which would incur a fee of between £3,000 and £10,000 depending on whether an OPRA score is required and what the outcome of this is. By way of introduction, it is well to remember that all Exemptions and Standard Rules are in part defined by the EWC [European Waste Catalogue] Codes. Existing EP Exemptions (under the T24 which provides for and is entitled “Anaerobic Digestion at premises used for agriculture and burning of resultant biogas” or, the T25 which provides for and is entitled “Anaerobic Digestion at premises not used for agriculture and burning of resultant biogas”) have some elements of the activities covered and some of the materials. However, the EA would not look kindly on an attempt to shoe horn a Hub into the T24/T25 scenarios – there needs to be a separate exemption covering the pre-treatment of waste for AD. The T24 has good capacity in that the total quantity of waste treated or stored at any one time allowed should not exceed 1,250m3; but the feedstock is limited to plant tissue waste (EWC 020103, 2020107, 170506, 200201) and horse and farmyard manure and slurry only (EWC 020106). There would need to be a change here to accommodate the Hub model. There is scope for the EA to do so via a regulatory position statement. This would need endorsement by Defra on the basis that the exemptions are extended to cover EWC codes for the same type of waste but from third parties. However, non-farm wastes would not be accommodated. The T25 exemption allows biodegradable kitchen and canteen waste from municipal sources (EWC 200302) along with materials unsuitable for consumption and biodegradable wastes from markets. The total allowable quantity at any one time must not exceed 50m3. There is a minimum retention time for the waste to be in a digester of 28 days. If the site was split as is envisaged and the digester was elsewhere then this would have to be recognised by the regulators in their approval of the exemption for this condition to be met as it would not be retained for 28 days at the Hub nor digested there. Although not an exemption, the “temporary storage at a collection point” provision (in Part 2 paragraph 3 of SI 2009 3381) which allows up to 50m3 tonnes was explored as it allows storage if the waste isn‟t hazardous WEEE and is destined for treatment elsewhere. However, it will not be considered appropriate by the EA as the way in which this provision is interpreted is prone to dispute and, in any case, if the temporary storage includes shredding/pasteurisation it would not be applicable. The Standard Rules Permit, SR2010 No 15 could work for PoDs (i.e. the digesters). However the EA would not be keen on issuing a permit for AD for an operation where AD will not be carried out. It would rather see a separate SR for Hubs authorising the pre-treatment activities without the AD. There is every possibility of a SR permit being formulated once it is established that there is a demand for the Hub & PoD approach as the EA develop SRs to meet market demand. Depending on relative sizes of Hub and PoDs served by it, there could be a hybrid between a Hub operating under a new SR Permit to be developed and PoDs operating under exemption.

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Conclusion: at present the EA would only be able to accommodate Hubs legislatively by way of a Bespoke Permit, which, whilst it makes for additional opex is the recognised route to getting the model established which will lead to the EA considering a Standard Rules permit in due course. Exemptions are being reviewed in October 2013. In the course of this review the EA may consider a regulatory position statement which could favourably affect the widespread adoption of the Hub & PoD model. If there is a demand for Hub and PoD then the EA could draft a Standard Rule suitable for the split site Hub and PoD model. 4 (3) PoDs and Environmental Permitting As previously discussed the T24 Exemption has very limited scope because of the restrictive nature of the allowable wastes, i.e. no catering waste. The T25 Exemption specifically states that the site must not be used for agriculture – so neither exemption would suffice. Standard Rule SR2010 No16 does not include food waste in the table of allowable wastes so is not an option. However, Standard Rule SR2010 No15 at a cost of £3,500 per year not only allows food waste but a considerable range of other materials and very importantly up to 10 tonnes of farmyard manure throughput per day. This would be sufficient capacity for a small farm dairy which would be the kind of farming operation the proposed trial project seeks – a typical small scale dairy farm such as Bwlchwernen near Lampeter in west Wales, which has been worked by Patrick Holden for nearly 40 years and which has approximately 60 milking cows. Conclusion: PoDs could be permitted under Standard Rule SR2010 No15 but further clarification is required – see Appendix A for a list of wastes treatable under this EP. 4.2 From the AHVLA perspective AHLVA guidelines are set out here: www.defra.gov.uk/ahvla-en/disease-control/abp/compost-biogas-manure/guidance-hub-pod-anaerobic-digestion/. 4 (5) Hub & PoD The key approach of AHVLA is to treat the activities at Hub and PoD as being a single process which happens to be carried out at two non-contiguous sites. If the operation falls outside the Low Risk Matrix (see below) then it will be subject to approval under ABPR in which case the draft HACCP plan (see Appendix B) applies along with any SOPs. The Hub would need management with CoTC status; this would normally range between Levels 2 and 4 depending on the scale of operations. If small (>5000 T/Yr) then a CoTC level 2 supervisory role would be sufficient for day to day on site matters, but with a Level 4 backup on call if required. The key to understanding how the regulator sees Hub and PoD translate into practical reality is to realise this is a single process on split sites. This implies a single legal person will be the accountable body though being accountable for both the Hub and any PoDs that the Hub supplies with prepared feedstock. Critical Control Point 15 [CCP15] refers to a legal agreement between the operators of Hub and PoD. This agreement would cover sources of ABP feedstock being delivered to the PoD stipulating that only material passing through the Hub is permitted to be delivered to the PoD. It follows that the legal

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agreement should incorporate a “right to roam” at each PoD serviced by the accountable Hub, that is to say, a right to inspect so as to ensure compliance and takes appropriate steps to rectify any non-compliance. It is recognised that this may be seen as an impingement on the freedom of operation of PoD operators, but keeping livestock comes with a host of regulations in any event which farmers accept is the burden they carry to prevent outbreaks of pandemic diseases and to reassure consumers that animal welfare standards are adhered toABP compliance is, by its nature, restrictive and the relationship between AHVLA and a PoD would in practice be little different, the difference being the vicarious relationship introduced by the Hub. Since commencement of this feasibility study AHVLA have taken an enhanced interest in the Hub and PoD model. The AHVLA view is that there should be CCPs covering the correct category of material coming in, the processing parameters i.e. time, temperature and particle size and microbiological results. The rest is quality or manufacturing standards which are applicable throughout the system. The draft HACCP reflects these requirements. There is a question about re-infectivity given the time lapse between pasteurisation at Hub and eventual digestion at PoD. It‟s understood that the general consensus view is that if the digester is working properly, E. coli and Salmonella (i.e. the usual marker bacteria) should be destroyed in the process. This represents, of course, the second pathogen reduction barrier that applies to AD within the ABPR regime. AHVLA‟s guidance on how it will treat Hub and PoD systems is published at http://www.defra.gov.uk/ahvla-en/disease-control/abp/compost-biogas-manure/guidance-hub-pod-anaerobic-digestion/ The ABPR regulatory position that we could utilise for the purposes of the pilot is the new Low Risk Matrix position for small scale composting/anaerobic digestion: http://www.defra.gov.uk/ahvla-en/disease-control/abp/compost-biogas-manure/home-small-site-composters-anaerobic-digestion-ad-plants/.This strikes the balance between pragmatism and risk, envisaging home and small scale composting and anaerobic digestion plants as essentially low risk operations which, if fully regulated, would make them too expensive to operate. Using the low risk matrix approach community based and scaled operations could avail themselves of the Hub & PoD model and one possibility of a proposed trial envisages using Hub & PoD to find a community based solution to the collection and treatment of food waste in Nottingham. Conclusion: As at the date of final submission of this report there has yet to be an example of a Hub and PoD system operating in the UK so there is no feedback yet from either regulator or operator as to how the guidance works in practice. 5.0 Detailed technical appraisal 5.1 Theory/process behind the technology 5.1.1 Technical data Hub and PoD brings together three technical components – the Hub, the PoDs and the transport required to transfer the material between the two. Pods Based on our knowledge of the market place we have felt confident to assume that the current emergence of smaller and lower cost AD plants – suitable for farms and communities – will continue. Companies such as Evergreen Gas, Marches Biogas and Methanogen are all developing and now

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deploying AD plants suitable for use as Pods. Our requirement at the demonstrator stage is to ensure that the necessary critical control points are met by whichever technology is chosen. Transport Our analysis – which concludes that smaller tonnages are being transported smaller distances - does not require any specialist equipment. Instead there is sufficient off the shelf components (tanks, IBCs, slurry tankers) to allow any configuration of Hub and Pod to be accommodated at modest cost. The individual configuration required will be dependent upon the Pod AD unit chosen, the on-farm / in-community handling capability, the Hub locations handling technology and the feedstock type inputted. Hub This is where we have spent significant effort on technical design, adapting existing components to be both mobile and modular, focusing on the requirement for flexibility to maximise the Hubs‟ ability to be deployed in decentralised locations. The diagram (Figure 3) below outlines in simplistic terms the stages being brought together at the Hub - for a more detailed process flow diagram see the attached excel model (and specifically the sheet on Hub Process Diagram) shown in Appendix D page 49

Figure 3: The stages being brought together at the Hub

Homogenise and preheat

Blending of feedstocks

Convert solids to liquids

Pasteurise

Dewater and storage

Transport food

waste to the Hub

Transport to Pod

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All components within the Hub are off the shelf components. Their configuration and inclusion on a portable skid is what makes the Hub unique and which enables the Hub and PoD concept to open up new markets. A CAD drawing of the Hub is given below in Figure 4.

Figure 4: CAD drawing of the Hub

Issues to note about design/configuration

Designed to manage up to 1,200 tpa. Additional boilers can double this to 2,400 tpa.

Additional modules can expand this further, as demand requires.

Skid mounting provides maximum flexibility in locating the Hub.

Addition of water in the system allows for maceration and contaminant deposition;

Includes subsequent dewatering to maximise energy recovery and minimise transport costs.

Boiler can be replaced with heat exchanger if surplus process heat is available on site.

Front end input and back end storage not shown.

Performance of Hub used in Model

The economic model assumes 1200 tonnes of food waste inputted or approx. 5m3 per day. This equates to approx. 25 m3 per week. This capacity represents typical waste arisings from a small town with approx. 5000 households and restaurants / commercial industries.

To macerate this feedstock to required particle size and ODM content for pumping/flowing through the Hub‟s network 480 tpa of water is added

Prior to transportation to PoDs this additional 40% is extracted through de-watering, (this liquid fraction of process water is to be reused in the maceration process of following batches.

Prepared food waste feedstock contains proportionately higher density of ODM and thus CH4 because it has been dewatered, therefore the value of the prepared feedstock is calculated in relation to its CH4 potential, not tonnage.

Critical control points of:

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- 12mm particle size - 70OC - Held for 1 hour

- Homogenisation for ease of use at PoD and greater consistency of biogas production

A detailed description of the processes involved at the Hub is given in Appendix I. 5.1.2 5 Inputs and outputs The attached spread sheet –„Hub and Pod – Economic Model & Mass Balance‟ – gives details of: Hub Food waste input 1,200tpa Energy input 108,000kWh (gas) Water used to process feedstock 480tpa Pasteurised food waste (feedstock) output 1,200tpa

Single Pod – Model assumes 8 stand-alone AD Pods serving 1 Hub – total input/output therefore five times the following: Feedstock input 144tpa Farm based inputs Cow slurry – 1600 tpa; Chicken litter – 200tpa; Gas production 60,000m3 CH4 Electricity production 225,000kWh after CHP combustion

5.2 Operational parameters Hub

The front end collection / arrival of food wastes will be determined by the location and / or method of collection. The Hub‟s flexibility and skid mounting is intended to allow it to be located at / close to the point of waste arising.

Hub is constrained by its operational capacities – 1200tpa – although this can be double with an additional boiler and then additional modules added if food waste tonnages rise.

The technology and semi automation allow the Hub to be operated by semi-skilled staff, available in most locations.

It has a design that will enable an un-attended process or a manually operated process. Both designs have advantages / disadvantages regarding operation and cost. Initially, a semi-automated version of the Hub will be chosen for this proposal. It offers the best compromise for the project.

Pods

These will vary. Each will be located on a farm and so will be bespoke to the inputs and output capacities of that farm.

Emergent lower cost technology and the potential additional income from food waste allows deployment of smaller AD plants on a wider range of farms.

Transport

The constraint becomes the distance between Hub and the Pods and the volume of material to be transported.

Pods all lie within 25km of the Hub;

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Dewatering reduces volume (and transport costs) by 40%.

5.3 Comparison with „business as usual‟ Transport costs, currently 70% of all waste management costs, will increase as fuel prices increase; this encourages the development of more localised waste treatment. The proposed Hub technology which is a dispersed system requires source separated food waste which, once macerated, transforms into a liquid paste, ideal for treatment by AD technology and also relatively easy to transport. The more concentrated systems such as EfW and landfill requires larger quantities of material to be transported over long distances. These relative costs should enable PoDs to be competitive with EfW or landfill options. The public perception of thermal waste treatment and the fear of dioxin emissions – has slowed the uptake of EfWs technologies. 5.4 Risk Analysis

Hub The proposed Hub technology would be designed to BS EN ISO 12100-1:2010 ~ General principles for design. The risk assessment encompasses mechanical, electrical, thermal, noise and vibration hazards. In addition the technology is designed with the draft HACCP (see Appendix B) in place setting out 16 CCPs. Sitting behind these CCPs will be a series of SOPs. PoD CCP15 envisages a robust legal agreement between Hub & PoD operators whereby the Hub operator, who is likely to be the accountable person so far as AHVLA is concerned, will have to undertake a risk analysis of both the equipment and plant at the PoD as well as its operations. The agreement envisages a “right to roam” at the PoD vested in the Hub operator to provide both regulator and Hub operator confidence that PoDs will be compliant and with the safeguards provided by verification. 6.0 Economic / Cost Benefit Analysis 6.1 Appraisal of the economic model A full model for the operation and performance of the Hub and Pod can be found in the annex accompanying this report. The model allows:

For Hub and PoD to be assessed both individually and together

Against the following performance criteria:

- Financial performance - Mass balance of materials and nutrients - Energy performance

Based on the inputs outlined above the following points can be made about the economic performance of the Hub and PoD model:

Each PoD – assumed here to be an on farm AD plant conforming to the correct HACCP – is designed to run independently of any food waste input i.e. as a stand-alone AD plant. PoDs can of course be existing operational on-farm AD plants.

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Capable of taking in food wastes from the Hub each PoD sees this as additional profit – over and above their farm based digester activity, providing them with access to a feedstock market they could not access alone;

Food waste feedstock is charged in proportion to the tonnage of organic dry matter it contains with the price being set to out compete with maize and to allow both Hub and PoD enterprises to make profit.

The PoDs are new generation, small scale digesters, of the sort which other projects involved with the DIAD programme are working on, characterised by low capex compared to the “traditional” high upfront costs associated with AD. Their low capex enable these PoDs to generate income from their own farm based materials, but would get significant uplifts in biogas yield and resultant income from importing food waste from nearby urban areas.

6.2 Comparison of the Hub & PoD financial model compared to the „business as usual‟ financial model

The Hub & PoD model crosses both elements of the Driving Innovation in AD (DIAD) programme – it optimises AD at any scale and it particularly assists AD at the small on-farm scale. We can also make the case that it could be the basis upon which community AD plants or social enterprises may be able to enter a market which has, till now, been largely the preserve of big waste management companies. The juxtaposition of small scale farmers with large waste companies does not make for an equitable nor, ultimately, successful business relationship. Hub & PoD has the potential for levelling out the market playing field allowing small operators to acquire market share of large waste management contracts. We see three distinct classes of stakeholders/investors:

Farmers who invest in PoDs for better slurry management & income enhancement through energy generation and sales;

Investors who buy into the business model outlined below. These investors may be members of local communities interested in adding value to their waste or commercial / industrial generators of material keen to turn a liability into an asset. These investors see the whole Hub & PoD scheme as a single concept; and

In the context of DIAD, WRAP is interested in buying (by way of a grant in Phase 2) into Hubs to deal with the UK‟s food waste problem through the expansion of AD.

The DIAD programme clearly envisages expanding AD as a technology by down shifting its size and by moving the economic drivers away from gate fees towards energy production and tackling big issues like sustainable waste management, achieving renewable energy targets and addressing climate change with a much improved system of slurry management. Cooperative Ownership Model We rely upon a co-operative ownership model, which is both established and has a successful track record coupled to small scale AD. What is envisaged is an ESCo, or an Energy Services Supply Company, running the operation of the PoDs, taking responsibility for installation and maintenance. By taking on a responsibility and working in partnership with the farmer many more farms can take on AD.

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Having established a cluster of closely proximate PoDs, the ESCo is in a position to establish a Hub to serve that cluster. With the Hub in place members of the cluster can vicariously bid for food waste contracts which would otherwise be beyond them financially as well as technically. The ESCo agrees a contract which sets out the terms on which the PoD is supplied. This model is quite commonly used in the public sector, where for example a council may contract out supply of energy to a third party. This enables the council to concentrate on its core business and to simply pay for the energy it consumes. The ESCo will operate on the same lines. The co-operative will install a PoD on the farmer‟s premises, which is most likely to be a dairy farm, but could be an arable farm where the demand for back end nutrients is most likely to be higher; paying a nominal lease for use of the space the system takes up. The member agrees to use power and heat from the system over parasitic loading and energy exports to pay for the energy consumed – the co-operative guarantees the member a lower price for power and heat than that which they would pay if using another form of energy. Hardware maintenance and digester biology are the responsibility of the co-operative. Not only does this mean that the member does not have to worry about these aspects of the system, it also means that the co-operative can control the quality of feedstock used and ensure the equipment is well-serviced - as the member is paying for power and heat used rather than other forms of fuel, it is in the co-op‟s interest to maximize the PoD‟s efficiency. Whilst the PoD is taking in substrates from within the curtilage of the farm quality of feedstock and digestate will not be so critical; however, this element of control over feedstock becomes crucial when externally sourced material is brought on to the farm through the Hub as the above mentioned HACCP has already indicated. The contract will specify penalties to be taken off the member‟s bill if the power and heat supplied is not up to an agreed specification. In turn, the member signs up to use power and heat from the system to an agreed annual minimum and for a full 20-year period. This enables the co-operative to plan for the future and carry out its plans to bring more farms into AD. Establishing a continuous supply of food waste feedstock cannot happen overnight. Similarly, the installation of a large number of PoDs takes time. Accordingly the ESCo business plan is set out in phases. A share offer would be launched to raise the necessary capital for a DIAD Phase 2 trial, which will morph into a permanent arrangement once the feedstock supply chain to the Hub has been secured. Members of the co-operative will however remain members through the subsequent phases, and therefore the interest payments they receive will depend on the performance of the whole enterprise. It is envisaged that the financial performance and stability of the co-operative will improve as more PoDs are installed. The planned phases are as follows: 6.2.1 Phase 1 Installation of new PoDs within a geographically defined cluster and the signing of contract(s) for locally based food waste feedstocks. This enables the ESCo to be up and running with the first Hub & PoD in place. In order to supply this Hub a Memorandum of Understanding is required to be signed with a local feedstock supplier. This enables us to ensure that we have feedstock in hand for the Hub while we build additional supply chains.

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6.2.2 Phase 2 Installation of subsequent PoDs and the establishment of additional supply chains. We have identified a number of clusters. They are all at different stages of development which leads us to believe that subsequent share offers will be needed when these PoDs are ready to proceed. With a larger installed cluster or clusters of PoDs it becomes both cost-effective and technically feasible for the ESCo to bid for larger food waste contracts. It will be noticed that in our financial predictions for the Hub we anticipate a falling gate fee as the economic driver switches over to energy sales. We believe this is of significance as the current pressures on the AD industry are all around the speed at which feedstock is pushed through the system, resulting in compressed HRTs and digestion failing to run to completion. This is one cause for the low level of plants achieving PAS110. If biological efficiency is paramount (rather than economic efficiency) which large numbers of small scale PoDs are more likely to achieve, it may be possible for larger numbers of plants to attain the Specification. The issue for Hub & PoD in the context of PAS110 is that, as presently written, digestate from PoDs served by a Hub would be disqualified on the grounds that the feedstock was pasteurised off site. We trust that when PAS110 is reviewed in the next few months‟ consideration will be given to this. 6.2.3 Possible Phase 3 In theory there is no reason why this model cannot be replicated across the UK. And there is also no reason why it cannot grow indefinitely although in terms of food waste feedstocks it is anticipated that changes in retail distribution and consumer buying habits will reduce the overall quantity of food waste being generated. The key to success is the establishment of the new generation of small scale low capex PoDs on farms or in other locations where CHP can be fully utilised. This could be, for instance, at community growing spaces such as allotment sites. 7.0 Overall Environmental Impacts On the next page is the mass and energy balance of an individual Pod. The accompanying spread sheet includes a live version of this reflecting the impact of the dynamics between the Hub and Pod.

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Figure 5: The mass and energy balance of an individual Pod

The philosophy behind the Hub & PoD model is that it will provide a viable solution for food waste management as an alternative to landfill or energy from waste. DEFRA guidance on company reporting of carbon emissions2 provides factors for treatment of food waste by AD, EfW and landfill. These figures include the avoided impacts of energy recovery i.e. displacement of grid average electricity.

Figure 6: Lifecycle conversions factors for waste disposal

Lifecycle conversion factors for waste disposal

Scope 3

Waste fraction

Net kg CO2e emitted per tonne of waste treated / disposed of (including avoided

impacts) by method 1:

Energy Recovery

Composting Landfill Combustion

Anaerobic Digestion

(AD)

Energy Recovery

Organic Waste: Food and Drink Waste

-89 -162 -39 450

Organic Waste: Garden Waste -63 -119 -42 213

Organic Waste: Mixed Food and Garden Waste

-67 -126 -42 254

2 http://www.defra.gov.uk/publications/2012/05/30/pb13773-2012-ghg-conversion/

Mass and energy balance at an individual Pod

feedstock

h2o ts total

cattle slurry 1451 149 1600 air

chicken litter 86 114 200 N2 O2

food waste 87 57 144 total (t) 433.9 129.6 563.5

total (t) 1624 320 1944 % 77 23 100

% 83.5 16.5 100.0

757915 MJ

biogas 6.3% 210532 kWh

CH4 CO2 total electricity 35%

AD m3 60454 40303 100757 net energy (MJ) CHP

plant t 43.35 79.20 122.54 2165470.32 Unit

% 35.4 64.6 100.0 heat 50%

1082735.158 MJ

digestate 93.7% flue gas 300760 kWh

h2o ts total N2 CO2 H2O total

total (t) 1502 320 1821 total (t) 433.9 118.9 54.0 606.8

% 82.4 17.6 100.0 % 72 20 9 100

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The net benefit of AD compared to landfill is in the order 380 kg CO2e/t, and 60 kgCO2e/t compared to combustion for mixed food and garden waste. In addition to these impacts it is also necessary to account for the impacts of transport and of operating the hub (energy consumption). The differences in transport emissions are difficult to predict without a real life example as transport emissions are defined by the proximity of the waste management facility. However, it can be confidently ascertained that the transport distances for a Hub & PoD model will be no greater and probably lower than those associated with landfill or EfW management. It can be seen from the data below that where Hub & PoD displaces transportation to a remote waste treatment facility then the benefit is in the order of 0.64 kg CO2e per tonne kilometre. Furthermore, where food waste is transported to remote treatment facilities (as is happening in certain areas of the UK) then the transport impact could completely wipe out any emissions savings associated with the AD operation. The carbon impact of natural gas combustion is 2.217 kgCO2e per m3; based on a hub consumption rate of 13.7 m3/h (refer energy balance) the carbon impact of pasteurisation will be in the order of 30 kgCO2e per m3 of pasteurised material. Assuming a density for collected food waste of 0.5 t/m3 the carbon impact of pasteurisation is estimated at 60 kgCO2e per tonne substrate. These figures illustrate the importance of locating the Hub & PoD together or at a site with waste heat available. In addition to natural gas there is an electrical requirement of 7.75 kWh/m3. Based on a grid-average carbon factor of 0.59 kgCO2e per kWh the carbon impact for supply of electricity is 4.57 kgCO2e per tonne substrate. Using a range of factors as follows, the carbon impact of different scenarios is presented in Figure 7:

Anaerobic Digestion: -126 kgCO2e per tonne Combustion: - 67 kgCO2e per tonne Landfill: + 254 kgCO2e per tonne Hub Electricity: +4.57 kgCO2e per tonne Hub Heat: + 60 kgCO2e per tonne Transport: + 0.64 kgCO2e per tonne

Figure 7: Carbon Impact of Food Waste Management Scenarios (kg CO2e per tonne)

Scenario Hub management

Waste Management

Net Transport Total

1. Hub & PoD 64.6 -126 0 -61.4

2. Hub & PoD co located 4.6 -126 0 -121.4

3. Landfill 0 +254 0 +254.0

4. Combustion 0 -67 0 -67.0

5. Remote AD plant (*1) 0 -126 128 +2.0

*1. Based on 100km distance to remote AD plant i.e. 200km round trip

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As can be seen the Hub & PoD model develops a carbon footprint that is comparable with, and significantly better than, other food waste management scenarios. However, in multi-PoD deliveries from a Hub the geographical proximity of a cluster of PoDs is essential if costs in money and carbon arising from transportation of material are to remain low.

8.0 PART 2 - PHASE 2 DEMONSTRATIONS 8.1 Objectives for a demonstrator of Hub and Pod

1. Plan, construct and operate a real world Hub and PoD demonstrator in order to „prove‟ compliance with EA and AHVLA;

2. Configuration of Hub technologies, specifically: Testing the costs / benefits of dewatering (adds technical costs but significantly reduces transport and enhances value of material) versus dilution (eases processing but increases transport costs whilst also diluting value of feedstock)

3. Putting in place and proving the acceptability of the legal relationship between a Hub and an existing privately owned farm AD plant;

4. Testing the cost model for financing and building a cooperatively owned Pod; 5. As a result of the above three to have resolved the options and best way of transporting

material in a compliant manner between Hub and Pod; 6. Test the legal arrangements of a Cooperative ESCo for efficacy and robustness; 7. Force the recruitment of finance against the model.

9.0 Methodology for demonstration It is proposed that Phase 2 will be delivered by Cwm Harry Land Trust based on its 6 years practical experience of collecting and handling food waste from a variety of sources within MSW streams. For all of that time Cwm Harry has delivered a part of its collections to anaerobic digestion plants, particularly the food waste digester at Ludlow owned by Biocycle (South Shropshire) Ltd and operated now by BiogenGreenfinch. We propose to build a demonstration of Hub and PoD, building and operating: A Hub:

Built by Alvan Blanch;

Owned and operated by the ESCo (under Cwm Harry); and

Located at point source of material.

One Pod based on an existing AD facility:

Privately owned; and

Testing the legal / regulatory / compliance fit to a Hub.

One new PoD – farm or community - based on the installation of a smaller AD unit:

Built under ownership of the ESCo; and

Legal and compliance relationships with farmer / community established.

Site selection remains an outstanding issue (see below) although the likelihood is that it will be located with/near Cwm Harry in Newtown.

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Feedstock is considered less of an issue as material for a nine month demonstration is available.

9.1 Selection of sites / contractors etc. 9.1.1 Sites Our original plan had been to utilise Cwm Harry‟s site in Newtown, Mid Wales as the location for the Hub. Since undertaking this feasibility study the contract for the processing of all Mid Wales‟ food waste has been awarded to an Oxfordshire company. However the Cwm Harry site remains a possibility, but we have also been exploring a range of other locations (see appendix C):

1. Vastre, Newtown – Cwm Harry base carrying all relevant permission, making use of Powys feedstock diverted from Oxfordshire.

2. Bryn Posteg Landfill site, Mid Wales – making use of Powys feedstock diverted from Oxfordshire; 3. Welshpool Waste Transfer Station – making use of Powys feedstock which will be bulked up

here ahead of transport to Oxfordshire; 4. Biocycle AD plant, Ludlow – whilst initial enquiries reveal some technical concerns this may

remain a possibility, building on its reputation as a demonstration AD plant.

However it is worth recording that site location isn‟t critical at this stage as the Hub itself is movable by design (built on a skid) and so investment in a permanent site is less relevant. Also and the principles of the interactions between the Hub and the Pods can be tested without securing their proximity i.e. we could place the Hub and PoDs farther apart that would be demanded by a commercial application of Hub and PoD. 9.1.2 Stakeholders The principle stakeholders, to be brought on board ahead of a demonstration, include:

Feedstock client – does the Hub and PoD offer a viable alternative to their current disposal/ processing route.

Site location – ideally the feedstock client – carrying and capable of carrying the necessary licensing (Cwm Harry already carry).

Regulators – both EA and AHVLA – both of whom have been active parties in this the Hub and PoD feasibility work.

9.1.3 Personnel With the demonstrator located in Mid Wales Cwm Harry would make use of its existing staff complement, specifically:

Richard Northridge as project manager.

Rob Brymer-Griffiths as CoTC and Hub supervisor.

9.1.4 Contractors

Hub. Construction of the Hub will be contracted to Alvan Blanch.

PoD. Construction of the first Coop owned AD PoD will be put out for tender amongst the emerging range of suppliers.

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10.0 Project timescale - Complete and detailed The proposal is a demonstration over 9 months of full operation, beginning with 3 months of build and commissioning. So far as the Hub is concerned, there are two potential routes for its environmental permitting which is dependent on whether the trial morphs into a longer term scheme, either establishing a trial - a trial limited in time and specific to place would require an application to be made to the Modernising Waste Regulation Panel. If the panel grants the application and approves the trial, the EA will issue a position statement to cover the waste management activity: http://www.environment-agency.gov.uk/business/regulation/99685.aspx. If stakeholders are looking for a longer term solution - the Hub will need to apply for a Bespoke Permit as things stand at present. So far as PoDs are concerned, there are also two potential routes for the environmental permitting status, either a standard rules permit under Rule SR2010 No15 or, as stated above (see section 4), for the purposes of the pilot, the new Low Risk Matrix position for small scale composting/anaerobic digestion could apply: http://animalhealth.defra.gov.uk/managing-disease/animalbyproducts/compost-biogas-manure/home-small-site-composters-ad-plants.htm The construction period of the skid package is 15 weeks. This includes design, procurement, manufacturing and assembly. This figure includes the pre-commissioning & installation period. The construction of the skid package consists of a steel fabricated framework, which provides a base to mount all the necessary equipment and pipe work. This framework also enables the package to be transported as a complete package, without lengthy build times on site. This is followed by a commissioning / training period estimated to last 2 weeks, after which time operations will commence. The plan is that the Hub will be operated by Cwm Harry, whilst the farm based PoD will be operated by the farmer on whose land it is located and, in the case of the co-operatively owned PoD, this will be operated under contract to the Co-operative. As this is a trial the entire project will be monitored and evaluated in order to establish beyond doubt the financial, socio-economic, biological and technical dynamics of the Hub and PoD model. In the event of the trial not evolving into a permanent scheme at the end of the operational period decommissioning will take place which involves, so far as the Hub goes, de-piping, de-wiring the skid package and removing from site for strip down and evaluation. Two days have been allocated for this stage. It‟s not envisaged that an existing farm PoD will require decommissioning and so far as the co-operatively owned PoD is concerned, it is the intention to locate this so that it operates independently of the Hub.

With regard to external contracts with third parties, specifically relating to feedstock supplies, a number of approaches have been made and some of these are under development. These discussions continue. The current model for project financing is based on 100% of the costs of build being financed from a share issue. This is broadly similar to the costs of financing from a bank loan and is included to illustrate the full costs of financing a demonstrator of one Hub and one PoD. In all likelihood at the stage when it is commercialised Hub and PoD will be financed by a combination of share issue equity and bank debt (approx 50:50). However for the demonstrator - which includes the additional costs of building prototypes and of the regulatory work - requires an input of grant money to de-risk the project. We are therefore proposing that the additional costs and what would have been loan finance are replaced by grant funding from WRAP and the remaining investment comes from either WRAP convened investors or from a share issue.

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Such a share issue would either:

Be undertaken by Cwm Harry following the Sharenergy Model; or

Be developed through crowd funding such as BuzzBnk.

The finance will therefore be made up of grant: shareholder equity of 50:50. 11.0 Commercialisation of technology post demonstration 11.1 Commercialisation plans (including evidence)

We plan to approach the market using the experience gained through the Phase 2 trial so the intention is to build a strong business case from the information gathered during the trial. This makes the trial‟s evaluation (see below) of considerable importance as it will both inform as well as underpin how we bring Hub & PoD to market. Underlying the approach to marketing is a recognition that people will want to do the “right thing” which will include source separating their waste materials (including food waste) and presenting those materials for collection and subsequent treatment. Whilst there are well known barriers to behaviour change there is substantial evidence to show that if the right approach is made and people and businesses are provided with the right messages and kit, appropriate behaviour and sympathetic response to the call for change will follow. There is an issue between managing demand and supplying capacity for AD treatment of food waste which Hub & PoD has the potential to address. For example London alone has a capacity gap of 1 million tpa (see Appendix E Eunomia‟s AD market outlook report July 2011). Export markets such as Africa, a market in which Alvan Blanch has considerable experience, require smaller scale systems. They have considerable quantities of biomass waste such as plant stems that are to be disposed of and they also are severely challenged by neither sufficient funds nor infrastructure to deal properly with sanitation. It is therefore considered to be perfectly feasible to contemplate an export led approach so far as the technology is concerned. There are Five sectors currently being investigated:-

1. Export 2. Micro Anaerobic Digestion 3. Farmers Co-operatives 4. Community based schemes 5. Education sector – universities and the like.

11.1.1 Standards and regulation The feedstock attracted to UK hubs will need to be governed by various standards and regulations. This includes “Animal By-Products Regulations” and the requirement for it to be source segregated. The use of AD for treatment of waste favours a source segregation that isolates food waste as opposed to a commingled collection of food and garden waste. Food waste, when transported by road from hub to PoD is governed by strict regulation. It must be pasteurised before transfer to the vehicle that will carry it. There are areas of the UK where Nitrates must only be spread on the land at certain times of the year (NVZs). This is aimed at avoiding such nutrients entering water courses in large quantities and must be

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observed by careful storage of waste until it can be safely applied to the land during dry periods. Such storage can cause great expense. 11.1.2 Anticipated size of the market to be approached Studies by Eunomia show that in the UK the current estimate of the total potential size of source separated food waste collection that could be captured for use in AD plants is 2.2 million Tonnes per annum which contracts with DEFRA‟s figure for 2011 of 8.3 million tonnes. These figures have grown from virtually zero, at a fairly linear rate over a six year period. It is predictably higher in the denser populated areas, whereas AD plants tend to be mostly sited in rural areas; hence the value of urban hubs serving rural PoDs. 12.0 Evaluation and monitoring (WRAP reporting) The trial is a demonstrator so reporting the outcome of the work is critical. It will make good on the current lack of practical experience. The regulatory guidance cited above is new and untried in practise; a trial will allow the regulators and practitioners to iron out any issues and make appropriate amendments. HACCP plans are always being tweaked as new situations arise once they are implemented in day to day operations. The demonstrator has to demonstrate to the market the capabilities of the model across the board – showing the economic, social and technical aspects to best advantage. WRAP would receive operational data on digester biology management linked to JIT feeding regimes in order to optimise PoD efficiency. It would also receive detailed financial information on the entire operations of the model. The trial would be the best marketing tool likely to be at hand to promote the model more widely. so careful and comprehensive evaluation is essential. The financial model (see above) which is being proposed to fund the trial also behoves the participants to report candidly and comprehensively. 13.0 Conclusion A major consideration for farmers is a consistent and guaranteed supply of digester feedstock, at least for the period of any loan agreement and preferably extending past this to guarantee future income. Across Europe the trend is for a fall in the number of waste management companies and an increase in their size (Hall, 2010); in the UK there is also a tendency for the contract period between waste management contractors and local authorities to reduce, with 10-year contracts now more typical than the 25-year agreement reached in 1996 for Hampshire's Project Integra (Lisney, 2001). One consequence of this is that medium size and even large-scale dairy farms are too small to deal with large waste management companies and vice versa, and groups of farmers may need to form cooperatives for the purposes of securing the supply of waste. Co-operative and British farmers have a mixed history both of success as well as failure. Across the EU co-operatives comprising farmer members are a well-known and common feature whilst in the UK successful farmer based co-ops tend to be the exception. However, any farmer anywhere is likely to be attracted by economically successful models which allow him to continue to operate as a farmer in a way which fits his skills set and practical working experience. It is submitted that the Hub & PoD model offers UK farmers precisely those outcomes. What this study shows is that there is existing technology used in food processing which can be adapted for use in feedstock preparation of food waste material streams. This technology can be

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scaled so as to fit into a semi-mobile container or skid thereby being bolted on to existing facilities or plant. There is no need for site specificity which will have a positive impact on capital costs. What it also demonstrates is that the regulatory framework covering the position in England and Wales can accommodate split site processing so that a mechanical intervention, which prepares feedstock, can take place in one location and a downstream biological process, which transforms that material, occurs at another site. Lastly, the study has explored the finances of cooperation as the basis of making the model suit current economic conditions and has concluded that this is a model which can be made to work economically for investors.

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Appendices

Appendix A - List of Wastes treatable under Environmental Permit Standard Rules 15

Waste Code Description

02 01 wastes from agriculture, horticulture, aquaculture, forestry, hunting and fishing

02 01 01 sludges from washing and cleaning − food processing waste, food

washing waste

02 01 02 animal tissue waste − Category 3 animal by-products (ABP) including blood, animal flesh,

fish processing waste, fish carcasses, poultry waste − Category 2 ABP consisting only of paunch contents

02 01 03 plant tissue waste - husks, cereal dust, waste animal feeds, off-cuts from vegetable and fruit and other vegetation waste

02 01 06 animal faeces, urine, manure including spoiled straw

02 01 07 wastes from forestry

02 01 99 residues from commercial mushroom cultivation

02 02 wastes from the preparation and processing of meat, fish and other foods of animal origin

02 02 01 sludges from washing and cleaning − process water, − food washing waste

02 02 02 animal tissue waste − Category 3 ABP including blood, animal flesh, fish processing waste,

fish carcasses, poultry waste

02 02 03 materials unsuitable for consumption or processing − coffee, food processing waste, jam, kitchen waste, fruit, vegetable oil, tobacco, tea, vegetable waste − waste fat from processing of meat or fish

02 02 04 sludges from on-site effluent treatment

02 02 99 non specified* − sludges from gelatine production − animal gut contents

02 03 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 01 sludges from washing, cleaning peeling, centrifuging and separation − coffee, mushroom compost, food processing waste, food washing waste, tobacco

02 03 04 biodegradable materials unsuitable for consumption or processing (other than those containing dangerous substances)

02 03 05 effluent from the processes referred to in sources of waste

02 03 99 non specified* − sludge from production of edible fats and oils − seasoning residues, molasses residues − residues from production of potato, corn or rice starch

02 04 wastes from sugar processing

02 04 03 sludges from on-site effluent treatment − biological sludge

02 04 99 other biodegradable wastes

02 05 wastes from the dairy products industry

02 05 01 biodegradable materials unsuitable for consumption or processing (other than those containing dangerous substances) − solid and liquid dairy products, milk, food processing wastes, yoghurt, whey

02 05 02 sludges from on-site effluent treatment

02 06 wastes from the baking and confectionery industry

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Appendix B - Draft Hazard Analysis and Critical Control Points Plan for Hub & PoD for AHVLA Note: This is a draft based on a proposed hub to be located at Cwm Harry Land Trust, Unit H, Vastre Industrial Estate, Newtown,

Powys, SY16 1DZ

There are additional CCPs for internal auditing / quality assurance purposes only in green Abbreviations / legend CM = control measure CCP=critical control point CA=corrective action AH = required by AHVLA under HACCP/SOP QS = Quality Standard required by Hub operator to meet internal quality control and assurance requirements IBC= intermediate bulk container URN= unique reference number

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Process Step Hazards Control measures Critical

Limits

Monitoring Corrective Action Record Verification

Collections off site:

Collection of domestic & trade

catering waste by

company staff

AH QS

Feedstock

contaminated with other

materials not

suitable for anaerobic

digestion [AD] such as metal,

plastic and

glass which could

contaminate final product

[1] Instructions given to

householders / business owners about what wastes are acceptable

in the bins

[2] Collection crews to inspect

catering waste bins prior to loading

[3] Low levels of contamination will be removed by the crew

during collection or during on site processing

[4] Bins seen to contain a high

level of contamination will be

rejected at the kerbside / customer‟s business premises

[5] Staff training on what is

suitable for the AD process

[6] Written / visual guideline on

acceptable levels of contamination and staff training

delivered verbally

CCP 1

Level of contaminatio

n to be within

an acceptable level

specified in site operating

procedures

for domestic kerbside or

trade catering

waste

Constant

monitoring by collection

crew of bins

as they collect

[1] Sticker placed on

bin indicating reasons for no collection

[2] Visit to householder /

business owner (if required) to inform

them of what can be

placed in the bin

Refused bins

recorded by collection

staff if

possible to identify

house / business

premises

Analysis of end

product for contaminants

by approved

laboratory

Analysis results reviewed by

site manager

Visual

inspection of delivered

product by processing staff

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Process Step Hazards Control measures Critical

Limits

Monitoring Corrective Action Record Verification

Reception:

Delivery of catering waste to facility

AH

QS – Hub will seek

to deliver contaminant free

materials to PoDs

Waste material

may be exposed to

scavenging

birds and animals

[7] Catering wastes are delivered

in purpose designed vehicles by collection staff

[8] Customers delivering waste direct to site to be instructed on

the requirements for containing the waste

[9] Reception of catering waste takes place inside building with

the doors closed

[10] Pest control measures in place within facility – bait boxes

around the site and inside the

building

[11] Driver to complete a check sheet / defect report weekly

before leaving site with collection

vehicle so as to ensure that the vehicle is suitable for purpose

CCP 2

Catering waste

deliveries will

only be accepted if

transported in a suitable

vehicle

All delivery

vehicles will be monitored

by site staff

and any non compliance

recorded in the site diary

[3] Customers will be

informed of all site procedures before

trading with the

company starts

[4] Site is not open to random deliveries,

only approved

customers may drop off

[5] If there is a

problem with suitability of delivery

vehicle customers will

be contacted and reminded of their

responsibilities

[6] Site will not

accept further deliveries from

offending company if they do not correct

problems

Details of all

non-compliance

recorded in

site diary along with

record of actions taken

All deliveries

will be monitored by

site staff daily

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Process Step Hazards Control measures Critical

Limits

Monitoring Corrective Action Record Verification

Reception:

Deliveries from customers

contaminated with

other materials not suitable for AD

AH

QS – Hub will seek to deliver

contaminant free materials to PoDs

Damage to

processing equipment

Failure to achieve PAS110

[12] Site staff to visually check

load before acceptance

[13] Low levels of contamination

to be removed by site operatives

[14] A load, which is heavily contaminated, will be rejected

from site

[15] Guidelines issued to staff for

acceptable levels of contamination and training given

to site operatives

[16] Guidelines issued to

customers who supply catering waste

[17] Site operatives to visually

inspect waste prior to processing.

CCP 3

Level of contaminatio

n to be within

an acceptable level

specified in site operating

procedures

for customer deliveries

Daily

monitoring of catering

waste by site

staff and records kept

in the site diary

[7] Loads which are

heavily contaminated will not be put

through the process

[8] Non compliance

report raised

[9] Waste will be

rejected from site

Details of all

loads rejected will

be recorded

on site

Details of all non

compliance

recorded in site diary

along with records of

actions taken

Analysis of end

product for contaminants

by approved

laboratory

Analysis results reviewed by

site manager

Visual

inspection of end product on

site - reviewed daily by

processing staff

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Process Step Hazards Control measures Critical

Limits

Monitoring Corrective Action Record Verification

Reception:

Storage of catering waste

AH

Exposure to

animals and birds

[9] Reception of catering waste

takes place inside building with the doors closed

[18] All catering waste will be processed within 24 hours of

delivery

[10] Pest control measures in

place within facility – bait boxes around the site and inside the

building

[19] Housekeeping and hygiene procedures

[20] Preventative maintenance system to reduce processing

equipment failure

[21] Repair and maintenance

back up for processing equipment breakdown

[22] Removal of stored catering

waste to a suitably licensed facility in the event of equipment

failure for a period > 48 hours

[23] Process logs kept detailing

deliveries and when material is processed

[24] Staff induction and training on procedures

CCP 4

Catering wastes will

be processed

within 24 hours of

delivery

CCP 5

All catering waste to be

stored inside the building

CCP 6

Pest control

system in place at all

times

CCP 7

All steps in cleaning and

hygiene plan to be carried

out as stipulated

CCP 8 Preventative

maintenance schedule in

place and

emergency repair and

maintenance support

available

Daily

monitoring of process logs

for waste

delivery and processing

dates

Timetabled

preventative maintenance

schedule inspections

and checks

Pest control

inspections carried out

by a contractor on

a monthly

basis

Daily site inspection

carried out by site

supervisor

and findings recorded in

site diary

[10] Non compliance

notification raised in the event of failure of

a critical control point

[11] Catering Waste

will be sent off site if it cannot be

processed within 24

hours

[12] Pest control measures increased if

monitoring reveals a problem

[13] Retraining of site staff in procedure

[14] Disciplinary

procedures for site

staff in the event of repeat breaches

Details of all

non-compliance

recorded in

site diary

Details of all non

compliance

recorded in site diary

along with records of

actions taken

Daily review of

inspection reports by site

supervisor

Weekly review

of inspection reports by site

manager

Contractual

relationship with third party

to satisfy CM 21 and to back

up

implementation of

CCP 7 – emergency

repair and

maintenance

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Process Step Hazards Control measures Critical

Limits

Monitoring Corrective Action Record Verification

Reception &

Processing

The regulator

Odour [25] All catering wastes are stored

on site within a building and within a closed vessel

[18] All catering waste will be processed within 24 hours of

delivery

[19] Housekeeping and hygiene

procedures

[20] Preventative maintenance system to reduce processing

equipment failure

[21] Repair and maintenance back

up for processing equipment breakdown

[22] Removal of stored catering

waste to a suitably licensed facility

in the event of equipment failure for a period > 48 hours

[25] Building vented, through bio-

filter - negative air pressure maintained during operating times

[26] Door opening times kept to a minimum to allow for deliveries and

vehicle exits only

CCP 4

Catering wastes will

be processed

within 24 hours of

delivery

CCP 5

All catering waste to be

stored inside the building

CCP 8

Preventative

maintenance schedule in

place and emergency

repair and

maintenance support

available

Daily

monitoring of process logs

for waste

delivery and processing

dates

Daily

preventative maintenance

schedule inspections

and checks

Daily site

inspection carried out

by site supervisor

and findings

recorded in site diary

[10] Non compliance

notification raised in the event of failure of

a critical control point

[11] Catering Waste

will be sent off site if it cannot be

processed within 48

hours

[13] Retraining of site staff in procedure

[14] Disciplinary

procedures for site

staff in the event of repeat breaches

Details of all

non compliance

recorded in

site diary along with

records of actions taken

Daily review of

inspection reports by site

supervisor

Weekly review

of inspection reports by site

manager

Agreements in

place with third party approved

sites to take catering waste

at short notice

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Process Step Hazards Control measures Critical

Limits

Monitoring Corrective Action Record Verification

Maceration

AH

QS – dilution rate to ensure % DM

normally 10-12% however can be

varied depending

on PoD requirements

Failure to

meet particle size

[27] All catering wastes treated by

two stage maceration – course treatment by augur shredder

followed by fine milling to <12mm

in any one plane

[20] Preventative maintenance system to reduce processing

equipment failure

[21] Repair and maintenance back

up for processing equipment breakdown

CCP 9

All catering waste to pass

through

<12mm screen

Daily

monitoring of process logs

Timetabled preventative

maintenance schedule of

inspections

and checks

Daily site inspection

carried out by site

supervisor

and findings recorded in

site diary

[10] Non compliance

notification raised in the event of failure of

a critical control point

[15] Material will be

re-screened or machine repaired to

guarantee particle

size is achieved

[16] Removal of stored catering waste

to a suitably licensed facility in the event of

equipment failure for

a period >48 hours

Details of all

non compliance

recorded in

site diary along with

records of actions taken

Daily review of

inspection reports by site

supervisor

Weekly review

of inspection reports by site

manager

Contractual relationship

with third party to satisfy CM

21 Agreements in

place with third

party approved sites to take

catering waste at short notice

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Hub & PoD – Driving Innovation in AD 42

Process Step Hazards Control measures Critical

Limits

Monitoring Corrective Action Record Verification

Pasteurisation

AH QS

Failure of

pathogen destruction

[28] All material to pass through

the pasteurisation stage

[20] Preventative maintenance

system to reduce processing equipment failure

[21] Repair and maintenance back

up for processing equipment

breakdown

[22] Removal of stored catering waste to a suitably licensed facility

in the event of equipment failure for a period >48 hours

[29] Calibration of temperature probes

[30] All material to be processed in

batches which achieve time and

temperature requirements

[31] All material to be tested for indicator pathogen presence

[32] All material post pasteurisation

to be contained within IBCs

CCP 10

All material to be

pasteurised

at 70°C for 1 hour

CCP 11

Temperature probes to be

calibrated every 3

months

CCP 12 All material

to be processed in

batches

CCP 13

All material post

pasteurisation to be

contained

within IBCs

Daily

monitoring of process logs

Timetabled preventative

maintenance schedule of

inspections

and checks

Daily site inspection

carried out by site

supervisor

and findings recorded in

site diary

Calibration

records to be stored on site

All batches to

have URN

[10] Non compliance

notification raised in the event of failure of

a critical control point

[17] Material will be

re-pasteurised

Details of all

non compliance

recorded in

site diary along with

records of actions taken

Daily review of

inspection reports by site

supervisor

Weekly review

of inspection reports by site

manager

Contractual

relationship with third party

to satisfy CM 21

Agreements in place with third

party approved sites to take

catering waste

at short notice

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Hub & PoD – Driving Innovation in AD 43

Process Step Hazards Control measures Critical

Limits

Monitoring Corrective Action Record Verification

Dispatching

material from Hub to PoD

AH

QS

Cross

contamination at Hub

[33] URN clearly marked on IBCs

[19] Housekeeping and hygiene

procedures

CCP 14

All material post

pasteurisatio

n to be contained

within IBCs

CCP 7

All steps in cleaning and

hygiene plan to be carried

out as stipulated

Daily site

inspection carried out

by site

supervisor and findings

recorded in site diary

[10] Non compliance

notification raised in the event of failure of

a critical control point

[16] Material will be

re-pasteurised

Details of all

non compliance

recorded in

site diary along with

records of actions taken

Daily review of

inspection reports by site

supervisor

Weekly review

of inspection reports by site

manager

Transportation

from Hub to PoD AH

QS

Re-infectivity

post pasteurisatio

n

[34] time / temperature controls - awaiting input from AHVLA

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Hub & PoD – Driving Innovation in AD 44

Process Step Hazards Control measures Critical

Limits

Monitoring Corrective Action Record Verification

Cleaning and

hygiene at Hub

Cross

contamination with

material

caused by movement of

solids or liquids that

have not

been cleaned up, by staff

or vehicles

[35] All material post course

maceration will be contained within pipes, pumps and vessels

[19] Housekeeping and hygiene procedures

[36] All delivery vehicles to have

wheels and any contaminated body

work washed before leaving building

[37] Any spillages in outside yard to

be cleared immediately

CCP 7

All steps in cleaning and

hygiene plan

to be carried out as

stipulated

Daily site

inspections recorded in

site diary

[17] Any areas which

have not been cleaned or area

causing a problem

will be cleaned immediately or by the

end of the working shift

[13] Retraining of site staff in procedure

[14] Disciplinary

procedures for site staff in the event of

repeat breaches

Details of all

non compliance

recorded in

site diary along with

records of actions taken

Daily review of

inspection reports by site

supervisor

Weekly review

of inspection reports by site

manager

Discharge of material at PoD

Livestock having access

to catering

waste

[32] All material post pasteurisation to be contained within IBCs

[38] IBCs discharged directly into buffer / holding tank at PoD

[39] Legal agreement cited in CCP

15 to incorporate “right to roam” by COTC holder

[40] Induction and training given to PoD operator

CCP 13 All material

post

pasteurisation to be

contained within IBCs

CCP 15

Legal

agreement between Hub

& PoD ensuring PoD

compliance

PoD operator to keep

records

based on actions taken

[18] Retraining in procedure of PoD

operator

[19] With holding

further deliveries in the case of repeat

breaches

Details of all non

compliance

recorded by PoD operator

along with records of

actions taken

Weekly review of records by

COTC holder

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Hub & PoD – Driving Innovation in AD 45

Process Step Hazards Control measures Critical

Limits

Monitoring Corrective Action Record Verification

Review of HACCP

plan

Failure of any

CCPs

[41] During first and periodic

subsequent run throughs, the system will be monitored

continually to assess performance

CCP 16

HACCP plan review to

ensure fit for

purpose

Daily site

inspections and findings

recorded in

site and PoD diaries

[20] Immediate

action taken following review

[16] Material will be re-pasteurised (if

required)

Details of any

failures to be recorded in

site and PoD

diaries along with records

of actions taken

Initially

ongoing review of HACCP by all

site staff

HACCP plan

amended in consultation

with AH

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Hub & PoD – Driving Innovation in AD 46

Appendix C – Phase 2 site location assessment

Location for Hub Present availability of heat

Present availability of feedstock

Presence of existing PoDs

Availability of potential PoDs

Political support from LA

Key contacts Do time lines fit with Wrap’s?

Newtown None Running out 10/12 Depends on expansion of trade with Cae Post

Bank Farm Lodge Farm Wykey Farm

None CH Clive Pugh Simon Gittins Russell Mulliner

Good if all else in place

Nottingham x 2 [1] Council / Severn Trent [2] LEAP / University

Plenty – plug into heat main

None [1] Stoke Bardolph potentially interested

LEAP project micro-digesters at University campus

High [1] Antony Greener Peter Saunders Clive Williams [2] Paolo Matelloni

Bad as LA can‟t do anything re MSW feedstock till 4/13 earliest

Wrexham Unknown Not sure Lodge Farm +

potentially another organic farm

Angie Bywater Richard Tomlinson Denise Nichols

Not sure

Stroud

CHP

Divert from Cotswold District Council MSW collection

Kemble farms Hatherop Quenington Malaby?

Unknown

Guy Blanch

Not sure

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Hub & PoD – Driving Innovation in AD 47

Camden LEAP project

None

Potentially yes

Being planned

Rokiah Yaman

Potentially fits with Wrap

Appendix D – Hub process flow diagram and mass balance model

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Hub & PoD – Driving Innovation in AD 48

Appendix E – References

Page 10 Banks, C. J., Salter, A. M., Heaven, S. & Riley, K. (2011) Energetic and environmental benefits and economic feasibility of co-digestion of food waste and cattle slurry: a preliminary assessment. Resources Conservation and Recycling, 56, 71-79. Page 15 Wrap Downloads/ Operators Briefing Note – Anaerobic Digestion Operators Guidance Note – Effective Digestion of Food Waste Page 31 http://www.eunomia.co.uk/shopimages/Eunomia%20-%20Anaerobic%20Digestion%20Market%20Outlook%20Report.pdf PAS 110:2010 Specification for whole digestate, separated liquor and separated fibre derived from the anaerobic digestion of source-segregated biodegradable materials ISBN 978 0 580 61730 0

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Hub & PoD – Driving Innovation in AD 49

Appendix F – Consortium partner summary CVs Alvan Blanch Development Co. Ltd has expertise in designing and developing technology which has agricultural applications, particularly in connection with processing crops. Hubs would need to use existing technology with adaptations. Much of AB‟s customer base is abroad with demands for simple and robust machinery and equipment which is affordable and which has been designed with low energy demands. We see AB as best positioned in the market place to design, build and commission the Hub installation. Community Composting Network (CCN) is a UK-wide membership based organization with over 200 members which supports and promotes community groups, social enterprises and individuals who are involved in recycling nutrient within closed loop and local geographical areas. Most of the members produce compost from green/food waste and use it in their local communities, often linked to food growing projects. Cwm Harry Land Trust Ltd has been interested in the interface between biodegradable waste resources generated in urban areas and their “re-investment” in the soils from which those resources once came. This City to Soil relationship connects the urban based consumers of food to the rural based growers of food. Like other parts of the UK‟s rural areas, the Mid Wales counties comprise a large number of small farms surrounding market towns. Cwm Harry has in more recent times established a track record in pioneering new and innovative ways of handling all streams of waste resources, as evidenced in the way that it has managed the Zero Waste Presteigne Project funded by Welsh Government and in the way in which it adapted the principles of IVC technology to a local market town, within a tight budget and using available local skill sets. Methanogen (UK) Ltd is an anaerobic digester technology supplier with particular experience of small farm and small community digesters. The principals have more than 40 years experience in the field and can claim to have designed and built the largest number of on-farm digesters. University of Southampton‟s Bioenergy and Organic Resources Research Group is internationally recognized for its work on anaerobic digestion, both as a means of stabilizing wastes and for production of renewable energy from source segregated municipal waste, agricultural residues and energy crops. The group's work on food waste digestion has been pivotal to its successful implementation in the UK, where it is now part of the Government's waste management and renewable energy strategy. Members of the group were involved in the earliest trials using source segregated material as digester feedstock, and carried out the research monitoring on the first full-scale digester. Recent research has provided the rapidly growing industrial sector now involved in implementation of AD with operational protocols to improve biogas production and process stability.

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Hub & PoD – Driving Innovation in AD 50

Appendix G – additional questions for a Demonstrator to answer Other questions that arose during the study are more technical: 1. The levels of re-infectivity, i.e. what is the potential for pasteurised material picking up micro-organisms during storage / transport. i.e., a cross contamination issue, which is theoretically covered by the HACCP regime. However, there appears to be little research on other airborne, opportunist micro-organisms that may re-infect the post pasteurised feedstock. This is an area that can be monitored during the trial. 2. Characteristics of the incoming co-substrates and the need to understand the biological composition and the chemical impact of these potential feedstocks? Blending the carbon / nitrogen ratio and ensuring that PoDs are not receiving „un-balanced‟ samples. Much work has been covered here by the University of Southampton – see project WR 0212 report. However, this research information will have to be simplified into a set of target parameters for ease of use at Hub operator level. 3. The requirement for affordable / simple biological sample analysis of incoming co-substrates. The AD industry (PoD operators) already has access to a number of monitoring tools, such as pH monitoring, Biogas volume, methane volume, ammonia content, alkalinity and VFA. For a successful Hub operation - is it possible to minimize the amount of testing of the co-substrates to that of a simple test, as per titration test for sampling vegetable oil, prior to biodiesel production? 4. Does the targeting of COD loading provide us with the best way of developing quality assurance of the Hub‟s product? I.e. is there a Hub & PoD equivalent of the Mogden Formula which could be used to calculate prices for specific consignments delivered to PoDs depending upon their biogas yields? 5. By controlling the TS% content of material flowing through the Hub pipe work to a maximum of 10 – 12% (to suit pump manufacturers & digester operation) are we automatically restricting the maximum output COD/VS content? 6. PAS 110 makes no reference to C / N ratios, although excessive N is important (PAS 110 clause 7.2.4). There are exemptions on farm material from pasteurisation if co-digested with pasteurised off farm material provided the material is spread on the PoD land. But Annex A, Note 4, states that even if the digested material is used on PoD land it has to achieve ABP minimum treatment criteria. PAS 110 requirements for digestate labelling [14.1.5] list 10 parameters. It would seem logical to match these as the PoD operator is looking to meet PAS 110 and would want to work out the effect of the addition of the feed from the Hub on his PoD. 7. The calculations for heat and electrical loading are theoretical and subject to change. It is recommended that these loadings would be monitored and logged during the trial to evaluate true data. 8. The operator skill level has been estimated at CoTC level 2 and CoTC level 4. Is this the correct skill level for Hub operation, with respect to monitoring the incoming food waste streams and blending operations? This may have an impact on social enterprise involvement in the model. 9. Labour costs can be affected by the level of automation: what are the social and economic benefits of manual, semi-automatic & fully automatic?

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Hub & PoD – Driving Innovation in AD 51

10. Other projects working on the DIAD programme have a synergy with Hub & PoD e.g. Marches Biogas‟ work on converting slurry stores (towers) to digesters, Evergreen Biogas‟ upgrade of biogas as a vehicle fuel – there is a need to explore these synergies.

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Hub & PoD – Driving Innovation in AD 52

Appendix H – energy calculations – Hub

See the economic model which also provides a mass balance for Hub and PoD Calculations to show heat energy requirements for pasteurisation Using Q = m.Cp.ΔT and assuming that:- Q ~ Quantity of Energy (kJ) m ~ Mass of substance = 1000 kg per cubic metre of liquidized food waste Cp ~ Specific heat capacity = 4.18 kJ / kg °C ΔT ~ Temperature rise (Average ambient @ 10°C raised to 75°C) = 65°C

In calculating heat requirements it was assumed that the specific heat capacity of food waste is similar to that of water: this is a conservative assumption and use of real values may further improve the energy balance as the specific heat capacity of most food materials and slurries is lower than 4.18 kJ kg-1 K-1 (approx. 3.5) The heat energy: - Q = 1000 x 4.18 x 65 = 271,700 kJ Using a steam table with specific enthalpy of 2134.8 (kJ/kg) @ 3 bar, we can conclude that approximately 127.3 kg/h of steam will effectively raise the liquidised food waste up to pasteurisation temperature, based on a throughput of 1000 kg/h. An approximation of 25% more steam (allowing for thermal loss, etc.) will be required per m3 batch to maintain the temperature @ 75°C. (ABPR compliance requires 70°C for 1 hour minimum) A boiler with a 200 kg/h steam output has been chosen initially to enable a minimal pasteurising capacity of one cubic metre per hour (with spare capacity to enable the warm-up of a second batch). At the level of 100% capacity, this boiler will consume 12.3 kg/h light oil or 13.7 m3/h natural gas. Heat inputs and costs (pasteurisation) Using British Gas figures of 1m3 of Natural Gas equates to 11 kWh and a natural gas tariff of approximately 4.5 pence per kWh, we can estimate a gas costing of 11 x 4.5 = 0.495 or £0.50 per m3

Therefore, the steam boiler will cost approx. £6.85 per hour at a consumption rate of 13.7 m3/h natural gas. The heat energy loading to operate the boiler is approx. 11 kWh/m3 x 13.7 m3/h = 150 kW.

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Hub & PoD – Driving Innovation in AD 53

Electrical inputs & costs Using an approximate electrical tariff value of 14.5 pence per kWh, we can deduce that the approximate cost of processing (e.g. milling, grinding, material handling) the delivered food waste is 7.75 kWh/m3 x 14.5p/kWh = approx. £1.12 per m3 (excluding labour) Table 5b to show total electrical loadings of Hub equipment with relation to processing m3 batch requirements

Combined electrical & heat inputs & costs The combined costs for processing = £1.12 + £6.85 = £7.97 - approximately £8 per cubic metre of processed and pasteurised food waste.

Description of Component Total electrical power consumption (kW)

Power consumption (kWh per m3 batch)

Intake hopper screw 0.33 0.2

Vacuum pump 1.5 0.75

Breaker mill & screw 5.5 3

Grinder 4 2.5

Transfer pump - Black 1.5 0.9

Compressor 0.55 0.1

Transfer pump - White 1.5 0.2

Ancillaries 0.33 0.1

Total 15.2 7.75

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Hub & PoD – Driving Innovation in AD 54

Appendix I – detailed description of Hub components Size reduction

Size reduction has the following benefits in food waste processing:-

There is an increase in surface-area-to-volume ratio of the food particles, which increases the rate of heat transfer, with reference to the later pasteurizing process.

A similar range of particle sizes allow more complete mixing / homogenization for each batch produced.

In some food wastes, size reduction can promote degradation by the release of naturally occurring enzymes from damaged tissues, or by microbial activity and oxidation of the increased area of exposed surface.

There are three types of force used to reduce the size of food waste:

1. Compression

2. Impact

3. Shearing

The first stage of the proposed Hub technology comprises breaker mill technology, which utilises a combination of impact and compression force for the initial size reduction. This is followed by a grinding process, which provides the shearing force and final reduction stage to achieve ABPR compliance (through a suitably sized screen – approx. 10mm aperture)

Moisture content significantly affects both the degree of size reduction and mechanism of breakdown in some food wastes. Some food wastes may need to be thoroughly „soaked‟ in order to obtain complete disintegration. This feature in the breaker mill will also provide cleaning in place (CIP) to assist the post operation clean down.

Blending

A key aspect for the proposed Hub technology is to provide PoDs with a bio-secure „homogenous‟ liquefied blend of food waste. After the size reduction process, the blending tank serves several roles to the process:-

Homogenization in liquid state with suitable C / N ration

Pre-heating prior to pasteurisation (thermal jacket)

Viscosity control / back mixing on discharge. Controlling the solids content (dry matter) of the liquidised food waste between 2 and 12%. This ensures functionality of standard pumps and proper mixing within the PoD‟s bioreactor.

De-gritting

Pasteurisation

Pasteurisation is a relatively mild heat treatment process, usually performed below 100°C. It de-activates enzymes and destroys heat sensitive micro-organisms and pathogens. The proposed Hub technology utilises a batch pasteurising process and the method chosen for heat transfer is steam injection. This will be performed under negative pressure to maximize the heat transfer effect and minimize / control odours.

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Hub & PoD – Driving Innovation in AD 55

Utilisation of Steam

It is envisaged that the proposed Hub technology will be situated in a number of different locations, which suggest a requirement for a versatile heat source. The utilisation of steam for process heating is having resurgence among many new industries, for several reasons:-

It gives up its heat at a constant temperature. This property is exceedingly important. It gives complete control of heating operations, and enables a heating operation to be exactly repeated at any time. (Essential for AHVLA to approve pasteurising process)

Steam has very high heat content. This means a comparatively small pipe can carry a great amount of heat. Water could be, and often is used for pasteurising, but suffers a temperature drop and to keep the temperature drop relatively small, very large quantities of water must be circulated. In a CHP application, any surplus / recovered hot water can be utilised by the steam boiler to pre-heat the feed water (thus reducing operating costs)

It is generated from water which is relatively cheap and plentiful, if using recovered rainwater

Steam offers a cell rupturing effect on the liquefied food waste – thus aiding future digestion

Steam boilers can be supplied to suit a variety of fuels: Oil, Gas or Electricity and the boilers are generally available „off the shelf‟

The proposed Hub technology could be utilised next to a commercial food processing plant and utilise existing low grade steam for processing on-site „Category 3‟ food wastes

Steam can be utilised in the „cleaning / wash-down‟ process at the end of a shift for sterilising pipe work and vessels etc. This wash down water can subsequently be utilised for blending the next batch of feedstock

Low cost/simple/robust technology

The proposed Hub technology is to be kept as simple as possible; the initial system will be controlled by a semi-automated control panel – using timers and relays. PLC control would not be appropriate at this stage of the project development, because of the high cost incurred with programming time.

As mentioned earlier in this proposal, the skill level (CoTC) required for running the system is in question, therefore the design must be kept simple. This factor is equally relevant for the potential export market – simplicity and robustness are key elements.

Modular capabilities With reference to the steam boiler calculations, it quickly became apparent that the overall capacity of the Hub is limited by the thermal capacity, rather than processing capacity. This would suggest that the boiler is kept independent to the Hub skid package and if need be, can be swapped over for a larger unit without detriment to the operation. This upgrade also suggests that the basic skid package which features a pair of pasteurising tanks can be extended, by retrospectively adding another pair of pasteurizing tanks as a „bolt-on‟ to the skid. This can increase the daily capacity from 8 to 10m3 per day. This equates to approximately 40 – 60m3 per week. This would provide a cost effective solution and double the processing capacity of the Hub. If further capacity is required, an additional skid package could be added; otherwise the processing capacity (milling, grinding, etc.) will be compromised.

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www.wrap.org.uk/diad