Tradebe Healthcare National Ltd Bellshill Healthcare Waste ... · Empty clean containers and waste...

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 1 of 34

Tradebe Healthcare National Ltd

Bellshill Healthcare Waste Treatment andTransfer Site

Permit Application

PPC/A/1180708(Casefile ID - 19/31431)

CONTENTS

TRADEBE HEALTHCARE NATIONAL LTD............................................................................................1BELLSHILL HEALTHCARE WASTE TREATMENT AND TRANSFER SITE ..........................................1CONTENTS .............................................................................................................................................11 NON TECHNICAL SUMMARY OF DETERMINATION.................................................................32 EXTERNAL CONSULTATION AND SEPA’S RESPONSE ..........................................................53 ADMINISTRATIVE DETERMINATIONS.......................................................................................74 INTRODUCTION AND BACKGROUND .......................................................................................74.1 Historical Background to the activity and application .............................................................74.2 Description of activity.................................................................................................................74.3 Guidance/directions issued to SEPA by the Scottish Ministers under Reg.60 or 61. ............84.4 Identification of important and sensitive receptors..................................................................95 KEY ENVIRONMENTAL ISSUES...............................................................................................105.1 Summary of significant environmental impacts .....................................................................105.2 Point Sources to Air..................................................................................................................115.3 Point Source Emissions to Surface Water and Sewer............................................................145.4 Point Source Emissions to Groundwater ................................................................................155.5 Fugitive Emissions to Air .........................................................................................................165.6 Fugitive Emissions to Water ....................................................................................................165.7 Odour.........................................................................................................................................17

Permit (Application) Number: PPC/A/1180708

Applicant: Tradebe Healthcare National Ltd


5.8 Management ..............................................................................................................................205.9 Fit and Proper Person...............................................................................................................215.10 Raw Materials ............................................................................................................................225.11 Raw Materials Selection ...........................................................................................................225.12 Waste Minimisation Requirements ..........................................................................................225.13 Water Use ..................................................................................................................................225.14 Waste Handling .........................................................................................................................235.15 Waste Recovery or Disposal ....................................................................................................235.16 Energy........................................................................................................................................235.17 Accidents and their Consequences.........................................................................................245.18 Noise..........................................................................................................................................245.19 Monitoring .................................................................................................................................245.20 Closure ......................................................................................................................................285.21 Site Condition Report (and where relevant the baseline report) ...........................................285.22 Consideration of BAT ...............................................................................................................286 OTHER LEGISLATION CONSIDERED......................................................................................297 ENVIRONMENTAL IMPACT ASSESSMENT AND COMAH ......................................................308 DETAILS OF PERMIT ................................................................................................................31DO YOU PROPOSE PLACING ANY NON STANDARD CONDITIONS IN THE PERMIT? YES...........318.2 Waste Pre-Acceptance ...................................................................................................................319 EMISSION LIMIT VALUES OR EQUIVALENT TECHNICAL PARAMETERS/ MEASURES......3311 FINAL DETERMINATION...........................................................................................................34

Permit (Application) Number:

Applicant:

1 NON TECHNICAL SUMMARY OF DETERMINATION

PPC requires that where the draft determination of an application or a SEPA initiated variation is to besubject to public consultation (this is usually referred to as PPD consultation) the decision documentwill contain a non technical summary of the determination. There is no need to have a non technicalsummary if the application is not subject to PPD

Will the draft determination/proposed SEPA initiated variation be subject to public consultation? Yes

An application has been made by Tradebe Healthcare National Limited (THNL) for a clinical wastestorage, transfer and treatment installation at Building 2, 100 Inchinnan Road, Bellshill, Glasgow.THNL have recently been awarded a contract with NHS Scotland to collect, transport, treat and disposeof healthcare waste from 18 NHS Health Boards in Scotland.In order to satisfy the requirements of this contract THNL require a waste treatment facility in Scotlandto handle the waste.

The Bellshill site will manage clinical waste disposal in Scotland primarily for waste produced by NHSScotland (NHSS) trusts, but could also include waste arising from private hospitals, pharmacies, carehomes, beauticians and veterinary practices.The waste will be brought back to the site where, depending on waste type, it will be either bulked upand sent off site for incineration or disposal at landfill or treated on site via a shredder, steam augerand drier, before compaction.The objective of the waste treatment process proposed for Bellshill is to disinfect clinical waste withheat to render it safe and unrecognisable, and to produce a waste floc that meets a specificationsuitable for use in an Energy from Waste Plant.

It is proposed that the installation will handle 24, 900 tonnes of waste per annum. The applicant hasapplied for a new PPC permit to carry out the following activities at the site:

Hazardous waste transfer; Treatment of clinical waste using thermal screw auger(s);

The waste treatment process will be supported by natural gas powered boilers to provide heat togenerate steam, natural gas burners to provide warm air for the drier (indirect heating), enclosedautomatic bin washers and a vehicle washdown area.The vast majority of waste received is typically classified as solid as although there is the potential for asmall amount of liquid within the waste, the amount of absorbent and other dry waste in the waste streamresults in the waste being solid.Any liquid wastes received at the site will be stored in containers within a bunded area. Different liquidwastes will be kept segregated to ensure there is no cross contamination with other wastes accepted atthe site.All waste accepted at site will be inspected, weighed and documentation checked to ensure it ispermitted for acceptance. Waste for treatment will be tipped into a shredder hopper fitted with anextraction hood and will be maintained under negative pressure to ensure all airborne pathogens arecontained and filtered. Once shredded the waste will then pass through a screen into the thermal screwauger. The thermal screw system is a continuous feed process consisting of a rotating screw system totreat and transmit the shredded waste. Steam is produced by the boilers and is injected into the steamjacket on the thermal screw auger and via “live” steam injection to disinfect the waste. Steam will beprovided at a temperature of 122oC. The thermal screw auger has an air extraction system whichmaintains a negative pressure and minimizes the potential for diffuse emissions to air from the thermalscrew auger system. The residence time in the thermal screw auger system is approx. 80 minutes




which has been determined to be adequate to disinfect the waste to make it microbiologically inactive(rendered “safe”).Steam will be injected both direct into the waste at the bottom of the steam auger and into the augershaft at the top to ensure maximum exposure to heat as the waste travels through the auger system.The steam auger length is 19m long to ensure sufficient residence time.From the thermal screw system, the waste is then routed via a sealed screw auger directly into the driersystem where hot air at approximately 80oC (provided by an indirect gas-fired burner system) isintroduced. The drier will treat waste at a rate of around 2,000kg/hour. The residence time in the driersystem will be approx. 80 minutes.From the drier the waste is transported directly by conveyor/screw outside the main building into sealedwaste compactors.THNL propose to use deep push compactors and the surface on which the compactors are located willbe impermeable and will have a sealed drainage system.When full the compacted waste skips will be replaced and removed either temporarily into the main yardarea to await transport offsite or moved directly offsite.Empty waste bins will be cleaned in a purpose built enclosed automatic bin washer which incorporatesa water recycling system. Bins will then be temporarily stored before being sent offsite for re-use.Some of the waste received at site will not be processed on-site but will be transferred offsite to anotherlocation (waste transfer operations). This waste will be stored within the building where possible. If thisis not feasible it will be stored either in trailers or on impermeable surfaces and sealed drainage.Empty clean containers and waste bins will be stored in the main yard area to await use/re-use. Anydirty bins will be identified and washed in the provided facilities. Dirty containers and waste bins will bestored indoors if they cannot be washed immediately.

Each activity has been considered in turn and proposed measures considered BAT. The applicant hasprovided sufficient detail in the application to justify the storage and transfer of clinical wastes, and thetreatment of clinical waste using thermal screw auger(s).

The applicant is considered technically competent for these activities due to its operation of similarpermitted sites in England, the provision of relevant certification and the passing of relevant convictionand financial checks. The permit for these activities has been created in consultation with the applicantand includes conditions based on the guidance for this sector.

It is therefore proposed to issue a draft permit to THNL for the storage, transfer and treatment ofclinical waste.

Glossary of terms

BAT - best available techniquesCO - Co-ordinating OfficerEA – Environment AgencyELV - emission limit valueEWC – European Waste CatalogueIED - Industrial Emissions DirectiveSNH - Scottish Natural HeritageEPR 5.07 - How to comply with your environmental permit. Additional guidance for clinical wasteEAL - environmental assessment limitMCPD – Medium Combustion Plan DirectiveNHSS – National Health Service ScotlandNRW - Natural Resources WalesPPC - The Pollution Prevention and Control (Scotland) Regulations 2012RHS – Relevant Hazardous SubstanceSSSI - site of special scientific interestSAC - special areas of conservation




THNL - Tradebe Healthcare National Limited

2 EXTERNAL CONSULTATION AND SEPA’S RESPONSE

Is Public Consultation Required - Yes

Advertisements Check: Date Compliance with advertising requirements

Edinburgh Gazette 26/4/19 yes

Motherwell Times 1/5/19 yes

Officer checking advert: Hilary Holding

No. of responses received: 0

Summary of responses and how they were taken into account during the determination:n/a

Summary of responses withheld from the public register on request and how they were takeninto account during the determination:n/a

Is PPC Statutory Consultation Required – Yes

Food Standards Agency: Yes – statutory for all Part A applications.Letter sent out 17/4/19. Response received 23/4/19 – Food Standards Scotland consider it unlikelythat there will be any unacceptable effects on the human food chain from the emissions from theinstallation.

NHS Lanarkshire: Yes - statutory for all Part A applications.Letter sent out 17/4/19. No response received

North Lanarkshire Council: Yes - statutory for all Part A applications.Letter sent out 17/4/19. Response received 09/05/19 – no comments except to confirm they areprocessing a change of use application to allow healthcare treatment at this site referenced19/00280/FUL.

Scottish Water: Yes – there will be substances released to the public sewerage system.Letter sent out 17/4/19. No response received

Health and Safety Executive: No – the application does not relate to an installation holding nuclearsite licenses or COMAH

Scottish Natural Heritage (PPC Regs consultation): No – there are no designated sites within therequired screening distance. Checked on GIS at 2km radius.

Harbour Authority: No – there are no substances proposed to be emitted into a harbour




Discretionary Consultation - Yes

Consultee: NHS Scotland, Meridian Court, 5 Cadogan Street, Glasgow, G2 6QE

Justification: The application relates to healthcare waste treatment for the NHS Scotland contracttherefore it is appropriate that they are consulted on the application.

Summary of response and actions taken:Letter sent out 17/4/19. Response received 23/5/19.Response raised the following concerns about the application–

Application lacks detail on how waste will be accepted and recorded on site. Pre acceptance requirement - not specified in their tender response and has not been included

as a contract requirement. Incorrect description of ‘18 01’ EWC coded waste wastes originating from animals rather than

human healthcare. Documents relating to waste acceptance, non-conforming waste and rejection do not fully

reflect Scottish practices and NHS Scotland would have liked to see examples of Scottishfocused documents.

Proposed waste storage – not adequate for expected quantity of waste NHSS will be sendingto the site.

Proposed use of domestic refrigeration units will not be adequate. Vehicle movements – numbers of, inaccurate. Waste quantities for transfer has been under estimated. NHSS data likely to be 10% plus. Insufficient information provided on waste treatment testing protocols.

Actions to address the above comments: held a meeting with NHSS 28 May 2019 to discuss.

Many of the queries relate to a lack of detail in the permit application however this will be dealt withthrough permit conditions. For example there are many systems and procedures which the applicantwill be required to prepare and implement plans for prior to operating the site. Key documents will beassessed by SEPA to ensure all of the appropriate systems and procedures are in place to ensurethere will be minimal risk to the environment and human health.

The document titled ‘Clinical Waste EPR 5.07’ is an EA and NRW document and details keyrequirements and industry best practice for the treatment of healthcare related wastes. This documenthas been referred to in the proposed permit in relation to the key stages of the waste treatmentprocesses. The permit has therefore been drafted to take on board its principles, including wastetreatment, waste treatment efficacy, pre-acceptance procedures, waste acceptance and electronic on-site tracking.

SEPA therefore consider that all of the questions posed from NHSS will be adequately addressed andcontrolled through permit conditions as drafted.

Enhanced SEPA public consultation - No

‘Off-site’ Consultation - No

Transboundary Consultation - No

Public Participation Consultation - Yes




3 ADMINISTRATIVE DETERMINATIONS

Determination of the Schedule 1 activity

As detailed in the application.

Determination of the stationary technical unit to be permitted:


Determination of directly associated activities:


Determination of ‘site boundary’

As detailed in the application – all STU and DAA activities are contained within the proposed permittedinstallation boundary

Officer: David Smith

GUIDANCE NOTES TECHNICAL DETERMINATION

4 INTRODUCTION AND BACKGROUND

4.1 Historical Background to the activity and application

Tradebe have been awarded a contract with NHS Scotland to collect, transport, treat and dispose ofhealthcare waste from 18 NHS Health Boards in Scotland.

Tradebe Healthcare National Limited, who will be the operators at the Bellshill site, are a subsidiary ofTradebe Environmental Services Ltd, whose ultimate parent company is Grupo Tradebe Medio AmbienteS.L.

Tradebe Environmental Services manages 85 fixed plants in Europe (Spain, UK and France), the UnitedStates and Oman.

Tradebe Healthcare provides the collection, transport, treatment and disposal of clinical waste. TradebeHealthcare currently operate four other UK sites that are regulated under the Environmental PermittingRegulations (England and Wales). These sites are located in Rochester, Avonmouth, Redditch andWrexham.

The Bellshill site will manage clinical waste disposal in Scotland for a range of waste producers. This willprimarily involve waste produced by NHS Scotland (NHSS) trusts, but could also include waste arisingfrom private hospitals, pharmacies, care homes, beauticians and veterinary practices. The service willinclude collecting, transporting, treating and disposing of the clinical wastes.

To enable Tradebe to begin their contractual arrangements with NHS Scotland they have made anapplication for a PPC Part A permit to undertake the required storage and treatment activities at Bellshill.

4.2 Description of activity




The objective of the waste treatment process proposed for Bellshill is to disinfect clinical waste with heatto render it safe, and to produce a waste floc (processing residues) that meets a specification suitable foruse in an Energy from Waste Plant.

It is proposed that the installation will handle 24,900 tonnes of waste per annum.The principal processes applied for are:

Clinical waste shredding Treatment of clinical waste via thermal screw auger Continuous flow drier system Compaction of autoclaved waste. Bin wash system Waste storage areas for the purpose of waste transfer.

Waste accepted at site for treatment will be tipped into a shredder hopper. The waste will be fully enclosedby the shredder unit. The shredded waste will then be routed via a screen into the thermal screw augersystem. An air extraction system maintains a negative pressure in the shredder system with the exhaustair being treated to remove dust and odour prior to discharge at elevation outside the process building.

The thermal screw auger system consists of a rotating screw system to move the shredded waste throughon a continuous basis. Steam is supplied via the boiler plant in a steam jacket on the thermal screw augerand via “live” steam injection to disinfect the waste. Steam is provided at a temperature of 122oC for 80minutes to disinfect the waste and ‘render safe’ Steam will be injected both direct into the waste at thebottom of the steam auger and into the auger shaft at the top to ensure exposure to heat as the wastetravels. The steam auger length is 19m long to ensure sufficient residence time. Again, air extraction fansmaintain a negative pressure in the system to prevent fugitive emissions. The exhaust air is treated toremove moisture, dust and odour prior to being discharged at elevation outside the building.

From the thermal screw system, the waste is then routed to the drier system where hot air provided by anindirect gas-fired burner system at approximately 80oC, is introduced. The drier will treat waste at a rateof approx. 2,000kg/hour. The residence time in the drier system will be approx. 80 minutes. The drier ismaintained under negative pressure with the exhaust air being discharged at elevation outside the processbuilding.

From the drier the waste is transported by conveyor/screw outside the main building into deep push wastecompactors located on impermeable surface and sealed drainage system.

Empty waste bins will be cleaned in a purpose built enclosed automatic bin washer which incorporates awater recycling system. Bins will then be temporarily stored before being sent offsite for re-use. The binwash will be connected directly to the foul sewer.

Waste accepted on site for storage and transfer without treatment will be stored within the building onimpermeable surface with sealed drainage. This waste will be bulked up and sent for final disposalelsewhere.

4.3 Guidance/directions issued to SEPA by the Scottish Ministers under Reg.60 or 61.

Directions may be made to SEPA by the Scottish ministers under Regulation 60 of the PPC 2012Regulations and the Scottish ministers may also issue guidance to SEPA under Regulation 61 of the PPC2012 Regulations.

The Scottish ministers have issued two directions to SEPA of a specific character with respect to thecarrying out of its functions under the 2012 PPC Regulations. The direction on small PVR terminals onislands is not applicable to this application. However, the Pollution Prevention and Control (Access toInformation) (Scotland) Directions 2013 are relevant. These directions are issued under Regulation 60 ofthe 2012 PPC Regulations and specify that:




“(1) Subject to paragraph (2), when a decision on granting, reconsideration or updating of apermit has been taken, SEPA shall publish on its website:

(a) the content of the decision, including a copy of the permit and any subsequentupdates;(b) the reasons on which the decision is based;(c) in relation to an application for surrender of all or part of a permit for a Part Ainstallation, any information provided in accordance with regulation 48(3)(d) and(4)(a);(d) in relation to the revocation of a permit for a Part A installation under regulation50(3)(a) or (b), the revocation notice.

(2) Paragraph (1) does not apply where such information is excluded from or is removed fromthe register maintained under regulation 64 by virtue of regulations 65 or 66 or paragraphs2 or 3 of Schedule 9.”

In this case, only paragraph 1(a) is applicable. The application is not subject to the withholding ofcommercially confidential or information affecting national security. The requirements of paragraph 1(a)are already addressed by standard SEPA determination procedures which are described in more detail insection 2 above on Public Participation Directive (PPD) issues.

The Scottish ministers have not issued any guidance under Regulation 61 which is applicable to thisapplication.

4.4 Identification of important and sensitive receptors

Human Health:The nearest dwelling housing is located approximately 420m from the eastern boundary of the site and475m south of the site.

St Gerard’s Primary and Nursery School is approx. 890m to the north east of the site.

Neighbouring warehouses and industrial units within a 500m radius of the site.

Designated sites:Screening distance is 2km (from SEPA Procedure NCP-P-01).

No SSSIs, SACs or SPAs within screening distance

Table 1 below shows a map provided with the application showing the location of the site in relation toreceptors which were used to inform the input data for predictive modelling. It shows that the immediateneighbours to the proposed site are all commercial industrial units and that it is 420m to the nearestresidential receptor (point 13 on the map).




Figure 1 - receptors

5 KEY ENVIRONMENTAL ISSUES

5.1 Summary of significant environmental impacts

Figure 2 below summarises the main emission points which have the potential to contribute to theenvironmental impacts from the proposed activities. The key issues are air emissions from the wastetreatment systems as well as the boilers, liquid effluent from the thermal screw auger and bin washingsystems and bio aerosol containment within the shredders.




Figure 2

5.2 Point Sources to Air

There are proposed to be 6 point source emissions to air from the permitted installation as follows:

Emission Point 1 (EP1) – BoilerEP4 – BoilerEP2 - gas burner associated with the waste drier unit serving one of the two waste processing linesEP3 – Combined exhaust stack for one shredder and its associated thermal screw auger plus one wastedrier.EP6 – Combined exhaust stack for the second shredder and its associated thermal screw auger.EP7 - Back up diesel generator

Taking each emission point in turn:

EP1 & EP4 (2 x main boilers) - The main boilers are each 1.3 MWth rated thermal input. They exceedthe minimum size in the Medium Combustion Plant Directive (MCPD) and are therefore considered a PPCactivity in their own right and part of the stationary technical unit. They are described in Schedule 1 of thedraft permit as:




The burning of Fuel in a Medium Combustion Plant with a Rated Thermal Input of 1 – 20MW,falling within Schedule 1, Part 1, Chapter 1, Section 1.1, Part B (d) of the Regulations, theprincipal purpose of which is to produce steam to heat the screw augers used in the HeatTreatment process.

This activity was recently inserted into the PPC Regulations by the Pollution Prevention and Control(Scotland) Amendment Regulations 2017 which transposed the requirements of the Medium CombustionPlant Directive (2015). The directive contains emission limits values (ELV’s) for different types of plant aswell as requirements for periodic monitoring.

The relevant ELV’s for boilers between 1 and 5 MWth thermal input and firing on natural gas is 100 mg/Nm3

for oxides of Nitrogen. There is also a requirement to monitor for Carbon Monoxide however there is noassociated ELV for this.

These requirements are placed in the proposed permit in condition 11.2 with the first round of monitoringto be undertaken within 4 months of the start of the activity and thereafter every 3 years. This meets therequirements of MCPD.

The applicant has provided all of the relevant information to support this aspect of the permit application.The emission stacks will be 3 m above roof ridge height (15.3 m above ground level).

The applicant’s proposals meet with the requirements to use best available techniques and compliancewith the permit conditions as drafted will ensure that the risk to the environment or human health isminimised.

EP2 (1 x gas burner) – this emission is associated with the waste drier unit serving one of the two wasteprocessing lines. The system comprises an indirect gas-fired burner system to pre-heat the air inlet to thedrier system. The applicant originally proposed to have two of these however this was amended duringthe determination processes. See section 5.7 below for an explanation as to why the change was made.

Two drier units will be present however one will be incapable of operating as a drier and will be used as aconveyor unit only. The operator will be asked to demonstrate to SEPA’s satisfaction that the second driercannot be operated as a drier. This unit has been installed so that Tradebe have the option to vary theirpermit in future to operate two driers. It would be very difficult to retro-fit once everything else is installed.

This gas burner will use natural gas and the rated thermal input is 0.812 MWth. This is not big enough tobe caught by the PPC regulations as an activity in its own right and therefore does not need to comply withthe requirements of the medium combustion plant directive.

Operation of this gas burner will be listed as a directly associated activity to the main activities in schedule1 of the permit. The applicant’s proposals meet with the requirements to use best available techniquesand compliance with the permit conditions as drafted will ensure that risk to the environment and humanhealth is minimised as far as possible.Emissions from this burner unit will discharge from a 3m stack ensuring sufficient dispersion is achieved.

There is no requirement to place specific emission limits in the permit to control emissions from this source.

EP3 & EP6 (2 x emission stacks each serving one of the two waste treatment lines)

Each stack is proposed to be 3m above roof apex height and each serves one of two separate wastetreatment lines. The exhausts from each waste treatment line and associated risks and mitigationmeasures are discussed below:




For both EP3 & EP6 (treatment lines 1 & 2)

Waste shredder hood extraction – an extraction hood is to be located above each of the waste shreddersin order to remove particulates and other emissions generated in the shredding process. When operational,all waste within the shredders will be fully enclosed, and under negative pressure. The wastes to beshredded will comprise of potentially infectious healthcare wastes. The exhaust air from this extractionsystem therefore requires treatment prior to discharge to atmosphere.

The fans serving the hood extraction will discharge air via a H13 HEPA filter and carbon filter so as toremove particulates and also odorous compounds such as VOC’s present in the emissions. On both EP3& EP6 the extracted air will then be discharged to atmosphere after being combined with the air from thethermal screw auger extraction and on EP3 only, the drier exhaust.

Full enclosure of the waste being shredded with all air being collected plus the use of HEPA filters to treatthe collected air represent BAT for the sector and this type of system is used successfully at similar plantsin the UK. The addition of carbon filters to deal with odorous compounds is a necessary addition. Theapplicant has provided details of the design of the carbon filters demonstrating that they will be sufficient.However, very little information is provided detailing how the odour abatement systems will be monitoredand what indicators will be used to determine when the carbon media requires replacing. See section 5.7below for further information as to how this will be addressed in the proposed permit.

Thermal Screw Auger Extraction Exhausts – A fan will be used to maintain negative pressure in thethermal screw auger and to ensure there are no fugitive emissions from the auger. The extracted air willbe damp due to the steam disinfection process within the augers. The air will therefore be routed througha condenser where the air will be cooled and then a coalescing filter. Water removed in both the condenserand coalescing filter will be routed to the drainage system and then the public sewer. The air will then passthrough a carbon filter and on both EP3 & EP6 discharged to atmosphere after being combined with theair from the shredders and on EP3 only, the drier exhaust.

The use of condensers and coalescing filters on the thermal screw auger lines to remove water andparticulates represent BAT for the sector and are used successfully at other similar plants. The addition ofcarbon filters to deal with odorous compounds is a necessary addition. The applicant has provided detailsof the design of the carbon filters demonstrating that they will be sufficient. However, very little informationis provided detailing how the odour abatement systems will be monitored and what indicators will be usedto determine when the carbon media requires replacing. See section 5.7 below for further information asto how this will be addressed in the proposed permit.

For EP3 only:

Drier Exhaust – A fan will be used draw air from outside through the indirect gas burner heating system.The heated air will then be routed through to the drier system where it will make contact with the wastecoming from one of the two thermal screw augers. The warm air after contact with the waste is extractedand discharged to atmosphere after being combined with the air from the thermal screw auger and thewaste shredder hood (on EP3 only).

No abatement is proposed for the exhaust from the drier unit. The waste is disinfected at this point thereforerendered safe. The applicant has stated in their application that they consider it unlikely that this processwill give rise to significant particulate matter or VOC’s at the outlet. Nonetheless, SEPA have required thatTradebe carry out monitoring for dust and VOC’s at EP3 & EP6 within 2 months of commencing wastetreatment operations so that predicted low levels of dust and VOC’s may be supported by data.

Odour is considered to be the main risk from this process. See Section 5.7 below for details of how thisaspect has been considered and addressed in the proposed permit.




In addition to the initial monitoring for dust and VOC’s there is also a requirement placed in the draft permitto monitor for these parameters annually to confirm the predicted low risk from emissions.

BAT Conclusion ELV’s (from waste treatment BREF) – Treatment of healthcare waste is discussedbriefly as ‘treatment of other waste’ in section 5.8.5 of the waste treatment BREF. There are nocorresponding ELV’s for point source discharges to air provided in the BAT conclusions for either‘treatment of other wastes’ or ‘treatment of healthcare waste’.

Nonetheless SEPA have placed requirements in the permit to monitor the following from EP3 & EP6although there are no corresponding limits. If monitoring data does not support the applicants’ assurancesthat these parameters present minimal risk to the environment and human health then SEPA will imposeappropriate limits with associated plant upgrade requirements.

Dust monitoring – details above.

Odour – BAT10 in the Waste treatment BREF states that BAT is to periodically monitor odour emissions(using dynamic olfactometry) where there is a risk of odour nuisance at receptors. Odour is consideredone of the main risks of nuisance from this operation therefore the permit has a requirement to monitor forthis. Quarterly monitoring for the first year then annual monitoring is considered appropriate. SEPA havenot set an emission limit for this because the applicant have provided detailed modelling which predictsthere should be no odour nuisance at any receptors. Once SEPA receives sufficient data on actual odouremissions from the waste treatment process we may consider inserting a condition limiting odour units atthe emission points.

TVOC – details above.

5.2.1 Hazardous waste transferNo point sources to air identified.

5.3 Point Source Emissions to Surface Water and Sewer

All emissions to water from the site will be routed via the site drainage system into the adjacent publicsewer network systems as shown on Figure 3 . There are no emissions to water from the site directly tocontrolled waters (the water environment).

Condensed water from the condenser installed on the air extraction system from the thermal screw auger willbe routed directly to the trade effluent drainage system on-site from the condenser system located within theprocess building. Water from the coalescing filter system installed on the air extraction system from the thermalscrew auger will also be routed directly to the trade effluent drainage system.

The boiler blowdown discharge which will contain some traces of boiler treatment chemicals and othercomponents from the waste in the thermal screw auger system will be directed to the trade effluent drainagesystem on-site in the boiler house.

Periodically there will be a discharge from the bin washers direct to the trade effluent drainage system on-sitewithin the process building.

A condition is placed in the permit requiring that all waste effluent produced at the site is routed to the publicsewer as this is considered to represent BAT in an area served by a sewer.

Hazardous waste transferWater emissions from this activity would be limited to the wash down of interior surfaces and the clean-up ofspillages. All waste transfer areas within the process building and on the pad, site cleaning will be directed tothe trade effluent drainage system on-site.

In other external yard areas, water will be directed to the surface water drainage system which dischargesoffsite via interceptors.




Vehicle washing will be done on the pad to the southern end of the site with drainage routed directly to thetrade effluent drainage system on-site.

Tradebe are currently in the process of negotiating a trade effluent discharge consent with Scottish Water.

Requirements of the regulations to prevent unlicensed emissions to surface water will be specified throughstandard permit conditions.

Figure 3

5.4 Point Source Emissions to Groundwater

Hazardous waste transferNone identified. It is proposed that all liquid storage will be bunded to appropriate current standards, (i.e.110% of the tank contents), and surfaces will be sealed to prevent fugitive emissions to groundwater.

Requirements of the regulations to prevent unlicensed emissions to groundwater will be specified throughstandard permit conditions.

Clinical waste treatment via thermal screw augerNone identified. It is proposed that all liquids storage will be bunded to appropriate current standards, (i.e.110% of the tank contents), and surfaces will be sealed to prevent fugitive emissions to groundwater.




Requirements of the regulations to prevent unlicensed emissions to groundwater will be specified throughstandard permit conditions and are considered sufficient to control this aspect.

5.5 Fugitive Emissions to Air

There should be no significant fugitive releases to air for the permitted installation. All of the wastetreatment operations have air extraction which is routed to controlled releases through external emissionspoints at elevation.

Much of the activity at the installation will be carried out inside buildings. Fugitive emissions to air arepossible due to dust generation from external roadways. The site will be subject to periodic cleaning,should dust or other materials be present.

Emissions of volatile organic compounds from handling volatile liquids, other than diesel, are not envisagedas these materials are not held in significant quantity at the installation. Emissions from diesel storage mayoccur during displacement of vapours in the headspace above the liquid during filling and from breathinglosses at other times. Diesel tanks will be situated in bunded areas.

Hazardous waste transferProposed dust controls include enclosed vehicles, sealed containers and bags for waste, visualinspections, waste handling within buildings and site speed limits. In addition, a spillage procedure will bein place.

The proposed permit includes conditions to reduce the possibility of fugitive air emissions.

Clinical waste treatment via thermal screw augerThe applicant has proposed the same controls as for hazardous waste transfer with negative pressure atshredders via a HEPA filter. Differential pressure would be used as an indicator that the filter needs to bereplaced.

The shredders should be fully enclosed (e.g. doors with no gaps) as well as the negative pressure drawof air.

Displaced air from the discharge of condensate must not be emitted directly to air (even via a HEPA filter)due to known odour issues. The applicant has proposed a carbon filter to prevent odours from thisemission.

The proposed permit includes conditions that specify the standard that must be met by the HEPA filter.

Bioaerosols – there is potential for fugitive microbial emissions from activities such as shredding healthcarewaste and also washing the bins the waste arrives in. This is mitigated at the shredder units by ensuringthe waste being shredded is fully enclosed and all air is extracted via HEPA filters. Best practice must alsobe followed when undertaking bin washing activities.

Conditions are placed in the permit to ensure these measures are taken as well as requiring good routinemaintenance of equipment is undertaken and recorded. There is also a requirement to undertake microbialemissions monitoring at key areas on and off site as part of commissioning and periodically thereafter.

5.6 Fugitive Emissions to Water

Hazardous waste transferNone identified in the application. Much of the activity at the installation will be carried out inside buildings.Minimisation of fugitive emissions to water are addressed through the design and operation of the




installation, which specifies: use of bunds for liquid storage; impervious paving resistant to the materialsstored for areas where wastes or process materials are received; stored or handled and a maintenancesystem requiring routine planned inspection of civil engineering assets such as bunds, drains, floors etc.

The requirements of the regulations to prevent and monitor for emissions of hazardous substances to soiland groundwater will be specified through the standard template conditions.

Clinical waste treatment via thermal screw augerAs above

5.7 Odour

SEPA have been very clear since our first pre-application meeting with Tradebe in November 2018 thatthe potential for odour nuisance would be a significant consideration in our determination of a permitapplication for healthcare waste treatment.

The permit application details two point source emissions from the process where there is a risk or odouremissions. These are as follows:

EP3 & EP6 - 2 x emission stacks serving the healthcare waste treatment process. Each stack will serveone of the two distinct processing lines.

One stack will discharge the combined exhausts from a shredder, thermal screw auger and drier unit whilethe other one will only discharge combined exhausts from a shredder and thermal screw auger. It wasoriginally proposed to have an operational drier unit on both processing lines however this had to bechanged during the application determination process for the reasons described below.

Each stack is proposed to discharge three meters above roof apex height.

Odour emissions from the shredder hoods and thermal screw augers have been considered by theapplicant and carbon filters are proposed. The applicant has provided details of the design of the carbonfilters which demonstrate that they should be sufficient. However, very little information is provided detailinghow the odour abatement systems will be monitored and what indicators will be used to determine whenthe carbon media requires replacing.

The waste treatment BREF (BAT conclusions) specify that where odour nuisance is considered a risk thenthe operator of the plant must develop an odour management plan (OMP). SEPA have therefore inserteda condition into the proposed permit requiring an OMP is prepared, implemented and maintained whichincludes all of the elements required in the BAT conclusions.

In addition we have also inserted a condition specifically requiring the OMP to include details of how theperformance of the odour abatement systems will be monitored and what indicators will be used todetermine when the carbon media requires replacing. In this way we can ensure the operator will monitorabatement performance and will replace the carbon media before performance drops due to saturation.

The OMP must be submitted to SEPA at least 14 days prior to operating the waste treatment systems toensure management of the systems are compliant with BAT. They will be unable to commence operationsof the shredders, drier and thermal screw augers (collectively termed as Waste Treatment Operations inthe permit) unless an OMP is first submitted which complies with the above permit requirements.

No odour abatement is proposed for the exhaust from the waste drier unit. Two drier units were originallyproposed by the applicant; one on each of the two distinct waste processing lines however this was




reduced to one during the course of determining the application for the reasons outlined below. Thereasons for the applicant not installing abatement for this aspect of the process is also discussed below.

Tradebe operate a pilot drier plant at their Avonmouth plant without abatement and they point out therehave been no odour issues. During pre-application discussions SEPA suggested they should take samplesfrom the pilot plant to gauge the level of odour and use this data to work out if it would be of concern ornot. They subsequently collected 6 odour samples from the discharge point at this drier; Odourconcentrations in all six samples collected were low in the context of waste treatment with untreated airfrom the dryer having odour concentrations in the range 358 to 960 ouE/m3, levels which are not dissimilarto industrial emissions often achieved post-treatment from an odour abatement system.

In their application Tradebe considered several options for discharge from the driers to demonstrate theuse of BAT. This included different abatement technologies as well as dispersion from a stack with noabatement. Of the abatement technologies considered only 3 of 5 abatement suppliers provided a quotefor a solution. All three opted for the installation of a chemical wet scrubber priced at around £100,000,000(average over the 3 suppliers).

Given this cost of abating a relatively low inlet odour concentration Tradebe concluded that combining thedrier exhausts with the exhausts from the shredder hoods and thermal screw augers and discharging via3m stacks was sufficient to control odour emissions and prevent nuisance at receptors.

After our assessment of this information SEPA were concerned that this conclusion lacked sufficientjustification and there may indeed be a risk of nuisance odour at receptors. We therefore required theapplicant to provide further demonstration that the risk of odour nuisance was minimised as much aspossible.

An odour assessment including a modelling exercise was subsequently submitted by the applicant on 25June 2019. During the exercise the modelling had shown that odour concentrations at the closest receptors(industrial units) were predicted to be high enough to indicate that complaints are likely. Stack heights forthe emission points would therefore require to be increased to reduce the predicted odour concentrationat receptors to a level where nuisance would be unlikely.

Along with looking at stack height increases Tradebe also looked at the process itself to see if they couldreduce odour generation at source. While conducting a process optimisation assessment they realisedthey could operate sufficiently with one drier only rather than the two originally proposed. This wouldsignificantly reduce the overall volume of air discharged and also the potential odour load.

Tradebe repeated the modelling exercise using predicted input data from using one drier instead of twoand at a discharge point 3 m above roof apex height. The model predicted no exceedance of an odourconcentration likely to cause nuisance at any discrete receptor outwith the permitted boundary as appliedfor. The receptors considered in the modelling exercise are detailed on the map below.




There was a mistake made in the model inputs in that only one stack was modelled with a combinedexhaust from the 2 shredders, 2 steam augers and one drier. In reality there was proposed to be twostacks 16 m apart (EP3 and EP6), one with combined air from a shredder, auger and drier and the otherwith air from a shredder and auger only (no drier). The report was reviewed by SEPA’s Air Modellingexperts and we concluded that the model should be run again.

We therefore served a Notice requiring further information be submitted in demonstration that the proposedwaste treatment operations at Bellshill Healthcare Waste Treatment and Transfer site will not result inoffensive odour being detectable out-with the site. This required to include a new air modelling report whichconsiders both stacks serving the waste treatment process. We also required a detailed method statementfor the air modelling to be agreed in writing with SEPA prior to modelling being undertaken.

During subsequent discussions Tradebe made the decision to move emission points 3 & 6 so that theywill be situated next to each other (1.3 m apart). The reasons for this was to aid dispersion and ensureboth stacks were at least 3m above the roof apex however it also meant that these two emission pointscould effectively be considered as one emission point due to plume entrainment effects. There was nowno need to carry out further modelling however in consultation with our air modelling expert we requiredTradebe to carry out some sensitivity analysis comparing the one stack scenario to the two stack scenario.The software predicts very little difference. We have reviewed this information and have accepted theapplicants’ demonstration that it is unlikely there will be impacts at receptors from nuisance odour.

Two drier units will still be installed however one will be incapable of operating as a drier and will be usedas a conveyor unit only. The operator will be asked to demonstrate to SEPA’s satisfaction that the seconddrier cannot be operated as a drier. This unit has been installed so that Tradebe have the option to varytheir permit in future to operate two driers. It would be very difficult to retro-fit once everything else isinstalled.




Given that the odour concentration data for the model came from a surrogate plant in Avonmouth andmodelling for odour concentration at receptors can be quite uncertain, SEPA will require the operator tocarry out odour monitoring at key locations within 3 months of commencing waste treatment operations.This will provide site specific data to then undertake a repeat of the above modelling exercise using thisdata to validate the odour modelling assessment submitted. This must be carried out within 2 months ofobtaining the odour concentration data. Tradebe must report the results of the modelling to SEPA no laterthan 6 months after commencing waste treatment operations.

The above is considered sufficient demonstration that there will be minimal likelihood of amenity impact atreceptors due to odour. The standard odour condition precluding offensive odour being detectable beyondthe site boundary has also been included in the permit to ensure SEPA can take any necessaryenforcement action should offensive odour become detectable off site.

Since much of the above work and discussions occurred after initial permit application SEPA requestedthe applicant summarise all of the relevant stages of work and conclusions in one document to supportthe original application; particularly because they were now proposing one drier instead of two. This canbe found in the document entitled ‘Odour Mitigation Summary Report for tradebe Healthcare Bellshill’received by SEPA on 2 August 2019 which is appended to the original application.

The above deals with point source emissions of odour. The application also discusses the risk of fugitiveemissions of odour and proposed mitigation measures in section 7.2 of the supporting documentssubmitted with the application. They have sufficiently addressed all areas of risk and proposed appropriatemitigation. Conditions elsewhere in the proposed permit covering waste pre-acceptance and acceptance,waste storage and handling procedures as well as cleaning and maintenance will ensure the potential forfugitive odour releases are sufficiently managed.

5.8 Management

The management system Tradebe propose to use achieves certification from SGS (UKAS AccreditedCertification Body) for:

• ISO 9001:2015 Quality Management;

• ISO 14001:2015 Environmental Management;

• OHSAS 18001: 2007 Occupational Health and Safety.

ISO14001 is an international standard which define a set of criteria which make up an effectiveenvironmental management system and is a voluntary undertaking.

A documented system of procedures will be developed according to the ISO14001 criteria and in line withexisting accredited schemes prior to first operation of the installation and this should ensure that allnecessary procedures and controls are developed and are in place.This will include operating procedures for plant and equipment which encompass both normal andabnormal operation.

Training needs matrices for management and operative training and competency should be developed tomatch individual job specifications and training will be delivered through company and specialist equipmenttraining. Training needs will be reviewed.

Standard conditions require that all staff involved in the operation of the permitted activities are adequatelytrained to carry out their work, that the training is documented and that SEPA is informed of the names ofthese personnel and their qualifications. These conditions also require that the installation is managed andsupervised by a competent person. The majority of personnel recruitment has not taken place for thisinstallation and standard permit conditions require the activity is operated by a fit and proper technicallycompetent person.




Maintenance systems will be required to identify items of plant and equipment which, should they fail, mayhave an impact on the environment and develop a preventative maintenance scheme to ensure theseitems are effectively monitored and maintained.

Regular auditing of systems incorporated into the business management system will be carried out toensure the systems are functioning as intended and delivering the necessary control. Standard permitconditions relate to records and recording of information, and are considered sufficient to ensure robustrecords are maintained.

BAT1 in the BAT conclusions for waste treatment requires an operator to have an environmentalmanagement system. Having the above accreditation means Tradebe satisfy most of the requirements setout in BAT1. Other management requirements elsewhere in the permit such as developing and maintainan odour management plan ensures Tradebe will comply with all of BAT1.

5.9 Fit and Proper Person

For an application for a permit for a ‘specified waste management activity’ SEPA requires to make checksto ensure the installation will be operated by a ‘fit and proper person’.

‘Specified waste management activity’ is defined in the PPC 2012 Regs as meaning an activity comprising– “ … (b) the disposal of waste falling within Sections 5.3, 5.4 or 5.6 of the Part of that Schedule [Schedule1] or (c) the disposal or recovery of waste in a waste incineration installation,”. This installation includesSection 5.3 Part A, (b) (ii), Section 5.6 Part A, (a) and is therefore a specified waste management activityfor which the ‘fit and proper person’ test applies.

The PPC2012 regulations specify certain measures which have to be satisfied in Regulation 18 in relationto fit and proper persons:

The applicant is proposing to carry out 2 specified waste management activities: hazardous waste transferand clinical waste treatment via thermal screw auger. In order to assess the technical competence of anapplicant SEPA applies three fit and proper person tests comprising:

1. A check against relevant convictions.2. An assessment of technical competence.3. A financial check.

In addition to fit and proper person checks for specified waste management activities, in terms of regulation13 (2) of the PPC Regulations 2012, SEPA also generally requires to consider whether or not the applicantwill ensure that the installation is operated so as to comply with the conditions which would be included inthe permit.

Hazardous waste transfer1. No relevant convictions identified.2. Demonstration provided of technical competency for waste transfer activities in accordance

with SEPA WST-G-002: Guidance - provision and assessment of technical competentmanagement at licensed waste management facilities.

3. Applicant passed credit check.

Clinical waste treatment via thermal screw auger1. No relevant convictions identified.2. Demonstration provided of technical competency for clinical waste autoclaving activities in

accordance with SEPA WST-G-002: Guidance - provision and assessment of technicalcompetent management at licensed waste management facilities.

3. Applicant passed credit check.




5.10 Raw Materials

Hazardous waste transferThe waste types to be handled and maximum quantities to be stored on site have been specified in theapplication. Only certain waste types will be permitted on the basis of the application. The maximumpermitted quantities will be an annual total of 24, 900 tonnes, with daily maximum permitted quantities of190 tonnes.

Standard permit conditions will specify the time limits and maximum tonnages for the storage of the wastetypes which could be received on site.


5.11 Raw Materials Selection

Raw materials proposed for the installation are described in the application and they represent the rangeof raw materials appropriate for the activities proposed at this installation. Routine review of raw materialsselected for use and periodic waste efficiency audits are a requirement of standard permit conditions.

Hazardous waste transferAs above


5.12 Waste Minimisation Requirements

Hazardous waste transferRequirements of the regulations to regularly review options for waste minimisation will be specified throughthe standard permit conditions.


5.13 Water Use

Hazardous waste transferThe Bellshill site will source water from the Mains supply. Overall rate of use is currently unknown but willbe closely monitored and recorded.

One steam auger is estimated to use around 800kg of water per hour to treat 48 tonnes of clinical wasteper day.The enclosed automated bin washers are designed to reuse water and detergents as much as possible.Power washers used on site will be turned off and all hoses will be routinely checked for leaks.Tradebe propose to implement a program whereby the use of water on site will be periodically reviewedand any steps to minimise water are reported and if feasible implemented.Water is metered to site and as such the quantity of water used by the site will be monitored.Opportunities that will be investigated for the re-use of water on site include:

Rainwater harvesting Vehicle washdown areas Use of water in staff welfare areas Cleaning waters from process areas

Clinical waste treatment via thermal screw augerAs above.




5.14 Waste Handling

Hazardous waste transferThe waste code list applied for is included in Table 5 of the permit. The applicant has provided informationon storage, containment, odour and management measures to be put in place in respect of the wastesproposed to be accepted.In order to comply with the technical guidance, operators are required to have systems in place that willtrack the waste on the site as it is stored or processed until it is removed from the site. This includes anability to check the capacity of the site to accept incoming wastes at the gate. The applicant has anelectronic tracking system in place on its other sites which it proposes to use to this site. Additionalinformation was provided on this electronic system which clarifies its capabilities. The permit conditionsspecify the requirements of the technical guidance and are considered sufficient to ensure waste is fullytracked throughout the plant and its processes, including dispatch from the site. The electronic wastetracking system proposed by the applicant is considered BAT.

Clinical waste treatment via thermal screw augerThe waste types that are suitable for treatment via thermal screw auger are included in the permit as perthe standard permit conditions.Waste tracking will be dealt with as above for thermal screw auger activities.

Waste acceptance procedures are required to ensure that only permitted wastes are allowed to bereceived at the installation. Standard permit conditions are in place to require that waste is only acceptedif it conforms to a waste type and quantity permitted to be received at the installation and that it is inspectedto assure conformance. Where subsequent waste checks identify non-conforming waste this will be heldin a quarantine area set aside for non-conforming wastes to be isolated pending removal from theinstallation to another appropriate waste management installation.

Restrictions are placed via standard conditions on the quantity of waste which may be stored at theinstallation.

Periodically and in rotation, parts of the site will be emptied and cleaned to ensure hygienic conditions aremaintained and waste is processed in a timely manner to minimise potential odour generation andemissions during storage. This is controlled via standard permit conditions. A first in first out approach willbe used to minimise the time waste is in storage at the installation with priority placed on potentiallyodorous wastes or wastes likely to cause nuisance.

5.15 Waste Recovery or Disposal

Hazardous waste transferRequirements of the regulations will be specified through the standard permit conditions.

Clinical waste treatment via thermal screw augerRequirements of the regulations will be specified through the standard permit conditions.

5.16 Energy

Hazardous waste transferRequirements of the regulations will be specified through the standard permit conditions.

Clinical waste treatment via thermal screw auger




Requirements of the regulations will be specified through the standard permit conditions.

5.17 Accidents and their Consequences

Hazardous waste transferThe application deals with the potential for accidents to occur and how they would be dealt with. The mostsignificant event environmentally would be a fire on site. Adequate isolated firewater containment isprovided should this happen. Permit conditions concerning fire detection specific to the drying system havebeen included in the permit involving continuous monitoring of temperature, the provision of alarms andfire suppression equipment.

Permit conditions are included to ensure that the potential for accidents and a plan for dealing with themwill be in place.


5.18 Noise

A SEPA noise specialist reviewed the noise submission. The submission was made some weeks after theinitial application was made because discussions were ongoing between Tradebe and SEPA regardingthe required level of information. It was determined that a noise modelling exercise was required to supportthe application.

The submission, including the noise modelling report, contained the expected level of detail. The applicantsufficiently demonstrated through modelling and proposed mitigation measures that noise nuisance is notexpected and the likelihood of noise complaints is minimal.

SEPA are therefore satisfied that the proposed healthcare waste treatment operation at Bellshilldemonstrates the use of BAT with regard to noise emissions. The following standard condition is insertedto the draft permit and is considered sufficient to control noise emissions:

‘At least every 2 years, the operator shall carry out a systematic assessment of noise emissions associatedwith the permitted activities, the purpose of which shall be to identify methods of reducing noise andvibration emissions. Each assessment shall be recorded and reported to SEPA’.

The requirement to have a specific noise management plan as detailed in BAT 12 of the waste treatmentBREF is not considered to be applicable. The noise report has demonstrated that noise nuisance atreceptors is not expected.

A two year systematic assessment period is used in the condition because noise data from another sitewas used in the modelling work. SEPA would therefore wish to see site specific noise measurementscarried out to verify the model inputs after the site has been operational for a short while. Our expectationwould therefore be that measurements are taken to support the first systematic assessment required bythis permit condition. After this we may relax the condition and only require a desk based assessmentevery 4 years.

5.19 Monitoring

5.19.1 Monitoring of emissions to air

Hazardous waste transferNo monitoring required.




Clinical waste treatment via thermal screw augerA requirement to undertake in situ monitoring of the HEPA filters has been included to ensure they aremeeting the stated standard (99.95% removal of particles >0.3um). The method referenced is based onthat used for clean rooms however is the most suitable available. In situ testing will corroborate thepressure differential monitoring.

The operator will also be required to undertake quarterly odour monitoring during the first year of operationand annually thereafter in order to confirm the effectiveness of the abatement.

Annual microbial emissions monitoring of the shredders, surfaces and effluents will be undertaken inaccordance with (EPR 5.07). This testing is required to provide assurance that the containment measuresare working effectively.

Annual testing of the boilers are also required. Tradebe has experience of the required monitoringmethods.

2 X boilers serving the thermal screw augers - There will be no interaction between the combustion

products of natural gas and the waste streams and so these emissions will consist only of NOx, CO and

CO2. Two of the emissions are related to MCPD plant (>1MW thermal input) and as such must comply

with the monitoring requirements designated for MCPD in the Pollution Prevention and Control (Scotland)

Amendment Regulations 2017. The limits are set out in Section 5.2 above.

The other boiler emission is related to non-MCPD plant serving the waste drier unit (< 1MW thermal input)

and as such no specific monitoring requirements are applicable. Regular servicing and maintenance of

this system should ensure that combustion efficiency is maintained and emissions from the sources are

minimised.

The combustion of diesel in the back-up diesel generator will similarly result in emissions of combustion

products. However the diesel generator will only be used infrequently (<500 hours per annum) and

predominantly for testing purposes only to ensure the availability and functionality of the system if and

when required no routine monitoring of the emissions is proposed.

The combined discharges from the air extraction systems serving the waste processing equipment

(shredder hood, steam auger air extraction and drier extraction) will be discharged to air via two stacks at

elevation. As the air discharged has been in direct contact with the waste being processed the potential

exists for the air to contain some residual components of the waste being processed.

Extracted air from the shredder hood will be treated via a High Efficiency Particulate Air (HEPA) filter (H13

type) and then a carbon filter before discharge to air. Specifications for the HEPA filter to be used have

been included at Appendix 9 of the application supporting document. The H13 HEPA filter is certified to

EN 1822:2009 and will be of the H13 (≥99.95%) class in terms of efficiency. The H13 HEPA filter will

remove particles that have a size greater than or equal to 0.3µm. As the H13 HEPA filter is not designed

to deal with odours or gases (VOCs), it will be followed by a carbon filter. Carbon filters use activated

carbon to remove contaminants and impurities by chemical adsorption. Conditions are placed in the permit

requiring the operator monitor the carbon filters to ensure they are changed prior to performance efficiency

dropping due to saturation. Notwithstanding this, there are monitoring requirements and limits placed in

the permit for carbon filter inlet air humidity and temperature. These limits are based on widely accepted

best practice guidance for carbon filter operation.

Displaced air and steam from the thermal screw will be discharged via a condenser, a coalescing filter and

a carbon filter. The condenser will condense steam back to a liquid. The liquid condensate will be




discharged to the site trade effluent drainage system. Any remaining steam and air will be passed through

a coalescing filter which will further separate liquid from the air to be discharged to the site trade effluent

drainage system. Any remaining air will be passed through a carbon filter to remove any remaining

contaminants and impurities. The above requirements for carbon filter monitoring also applies here.

Extracted air from the drier will be discharged without abatement. The main risk associated with this

emission source is odour therefore the reasons for this being acceptable are explained in section 5.7

above.

The combinations of H13 HEPA filter/Carbon filter, Condenser/Coalescing filter/Carbon filter followed by

discharge at elevation aims to ensure that there are no nuisance issues associated with these discharges.

Odour, dust and VOC’s are all required to be monitored for (periodically) from the combined emissions

points, EP3 and EP6 in the permit, so that the predicted low values and minimal risk of impact can be

confirmed.

5.19.2 Monitoring of emissions to water

All emissions to water from the permitted installation will route via the public sewage treatment system.The waste treatment BAT conclusions do require monitoring of emissions to the public sewer for someactivities however there is no requirement to apply these to healthcare waste treatment activities. ScottishWater are responsible for regulating the effluent quality to their sewer therefore SEPA have not consideredapplying any monitoring requirements or associated ELV’s to this emission point.

5.19.3 Monitoring of emissions to soil and groundwater

There should be no emissions to soil or groundwater from the permitted installation. Permit conditions areincluded requiring appropriate technical measures, such as site surfacing and suitable waste storage, toensure liquids do not escape the site by any means other than via the public sewer. That said potentialleakages of hazardous substances are possible therefore consideration must be given to periodicallymonitor for these substances. This is dealt with in PPC as follows:

Where PPC installations use produce or release hazardous substances there will be standard conditionsimposed requiring regular analysis of soil and groundwater as required by Regulation 23(2) (b) of the PPCRegulations. The frequency of monitoring depends on the risk and severity of contamination and has beenset taking into account the nature of the relevant hazardous substances used and the nature of the existinginfrastructure and environmental setting.

Based on information received from the PPC application SEPA have considered the requirement to setsoil and groundwater monitoring conditions. Our assessment is summarised in the table below includingjustification for monitoring frequency.

Score / rating / summary Outcome

PROFORMA 1 -LIKELIHOOD OFRELEASE

Total of 17 possible (no pipe window)

Cat 1 Green – 3 / 17Cat 2 Amber – 12 / 17Cat 3 Red – 2 / 17

Cat 2. See Proforma 2,consequence assessment.

PROFORMA 2 -CONSEQUENCEASSESSMENT

Liquids.Hazard statements “acute to chronic toaquatics”

The site will undergo repairs and newequipment will be in place as stated

All relevant information presented




under the site condition report; alsoprimary, secondary and tertiarycontainment will be as per legislativerequirements; in addition to the factthat it has been stated that inspection,testing and maintenance of all themeasures in place to prevent pollutionwill be undertaken through the life ofthe permit.Some of the hazardous substances asper CLP will only be present in smallamount, therefore focus is on RelevantHazardous Substances (RHS) whichare present in high volumes.The drainage CCTV survey outcomehighlighted some repairs needed andblockages that needed clearing, reasonwhy a CCTV survey will be arequirement under the permit every twoyears in addition to the fact thatintegrity of the drainage will provideproof of containment for those RHSwhich will be conveyed by it.

Presence of low permeability soils:Glacial Till described as stiff and firm tostiff to very stiff reddish brown/grey-brown/grey sandy silty clayencountered to a maximum depth of10m below ground level.

Rate and direction of groundwater flow- unknown.

Special features The site was previously operated byfood distributors. The environmentalsetting and associated risks of pollutiondue to geology, hydrology andhydrogeology have been presented.

CCTV drainage survey will be requiredon this site every two years to ensurethat no leaks or spillages associated tofaulty drainage take place and couldcause pollution of soil and/orgroundwater at the site.

Baseline reporting has beenprovided with regards to thediesel and transformer areas.Baseline waivers will be providedfor the relevant hazardoussubstances (RHS) associated toBin Wash Lemon andQuantaclene Plus. Based on thenature of the permitted activityand the environmental setting itwas agreed that no boreholesfitted with monitoring wells tocollect groundwater samples atthe site will be required on thisinstance. In addition to the factthat there are no commerciallyavailable laboratory analysis toquantify the relevant hazardoussubstances associated with BinWash Lemon and Quantaclene.As a result, it is considerednecessary that a drainage CCTVsurvey will be required on this siteevery two years to ensure that nopollution of soil and groundwatertakes place, in addition to




requesting on the permit,chemical testing of the tradeeffluent at the point of entry tosewer discharge.

Groundwatermonitoringrecommendedinterval

In light of testing restrictionsdetailed above, initiallyconsidered monitoring processeffluent, however this does notprove protection of groundwater,only content of effluent. DrainageCCTV every 2 years withrequirement to maintain integrityconsidered sufficient todemonstrate protection of soil andgroundwater.

Soil monitoringrecommendedinterval

Ten yearly.Soil monitoring within 12 months ofdate of permit.

At or near the original locationsused for setting baselineconditions near the diesel andtransformer areas.

Substances tomonitor in soil

TPH CWG speciated aliphatic andaromatic fractionsBTEX (Benzene, Toluene,Ethylbenzene and Xylenes)Polycyclic Aromatic Hydrocarbons(speciated PAH-16)

Based on relevant hazardoussubstances identified in use at thesite (and able to be tested for atcommercial labs).

Regarding the locations to be monitored, the permit requires that prior to the monitoring being undertaken,the operator must submit a monitoring plan to SEPA detailing locations to be sampled. It should be notedthat soil and groundwater monitoring is not restricted by the installation boundary.

5.20 Closure

Hazardous waste transferThe requirement for a decommissioning plan is included in the permit.


5.21 Site Condition Report (and where relevant the baseline report)

Hazardous waste transferSite investigation data provided for the site identifying fuels and oils and bin wash fluids as hazardoussubstances. Baseline conditions have been provided and soil and groundwater monitoring conditions willbe included in the permit where appropriate.


5.22 Consideration of BAT

Hazardous waste transferA BAT assessment has been carried out on the waste types that will be accepted on site, and adequatemeasures are in place. See section 5.14The applicant has provided information on storage, containment, odour and management measures to beput in place in respect of all the wastes proposed to be accepted. Where the wastes applied for requirespecial measures to be put in place, due to their potentially odorous nature or due to requirements forspecial handling, sufficient information as to how those wastes will be stored, contained and managed hasbeen provided and considered in line with BAT 4. .




SEPA is able to conclude that the applicant will ensure that the waste transfer activity in respect of thewastes will be operated so as to comply with the conditions which would require to be included in thepermit in respect of that activity.

Where SEPA has concluded that sufficient information has been provided on the sufficiency of measuresto be put in place, those wastes applied for are proposed to be included in the permit.

In order to comply with the technical guidance, operators are required to have systems in place that willtrack the waste on the site as it is stored or processed. This should include an ability to check the capacityof the site to accept incoming wastes at the gate. The applicant has an electronic system in place on itscurrent sites, which it proposes to transfer to the new site. Additional information was requested on thisissue, which provided clarifications. Non-standard permit conditions with respect to waste tracking weredeveloped by the east region Permit Review Team in order to specify the requirements of the technicalguidance and require greater clarity.

Clinical waste treatment via thermal screw augerThe waste types that are suitable for heat treatment are included in the permit as per the standardconditions. See section 5.19

Waste tracking will be dealt with as above for treatment via steam auger.

The treatment of clinical wastes via thermal screw auger for a new installation requires that the installationmeets relevant technical guidance, which is based on IPPC S5.06 Guidance for the recovery and disposalof hazardous and non-hazardous wastes, and the associated Environment Agency’s EPR5.07 guidancemust also be met, regarding site commissioning, efficacy and emissions monitoring as the minimumstandard. The specific guidance that relates to clinical wastes defines what can be treated and how itshould be treated. It also clarifies very specific requirements with respect to the management, assessmentand tracking, and the handling of such wastes for the protection of the environment and human health.Consideration of the application against the technical guidance for clinical waste treatment indicates thatthe proposed technologies and processes for shredding and treating the waste via thermal screw augerare acceptable and representative of BAT if operated correctly.Conditions elsewhere in the proposed permit covering waste pre-acceptance and acceptance wastestorage and handling procedures as well as cleaning and maintenance will ensure the potential for fugitiveodour releases are sufficiently managed. With the submission of an updated noise assessment documentSEPA are therefore satisfied that the proposed healthcare waste treatment operation at eh sitedemonstrates the use of BAT with regard to noise emissions – see Section 5.18

6 OTHER LEGISLATION CONSIDERED

Nature Conservation (Scotland) Act 2004 & Conservation (Natural Habitats &c.) Regulations1994

Is there any possibility that the proposal will have any impact on site designated under theabove legislation? No

Officer: Hilary Holding




7 ENVIRONMENTAL IMPACT ASSESSMENT AND COMAH

Guidance Notes – The PPC Regulations require that under certain circumstances SEPA take into considerationthe information in any statutory Environmental Impact Assessment carried out as part of the planning process or aSafety Report produced under the Control of Major Accident Hazards Regulations.

How has any relevant information obtained or conclusion arrived at pursuant to Articles 5, 6 and7 of Council Directive 85/337/EEC on the assessment of the effects certain public and privateprojects on the environment been taken into account? n/a

How has any information contained within a safety report within the meaning of Regulation 7(safety report) of the Control of Major Accident Hazards Regulations 1999 been taken intoaccount? n/a

Officer: Hilary Holding


Applicant:

8 DETAILS OF PERMIT

DO YOU PROPOSE PLACING ANY NON STANDARD CONDITIONS IN THE PERMIT? YES

No Condition Justification4.4 Odour Mixture

Requirement for an odour management plan in linewith BAT prior to operating, and requirement forodour monitoring within two months of commencingoperation.

Air monitoring conditions require quarterlymonitoring during the first year of operation.

This site has the potential to cause an odour impacton nearby sensitive receptors therefore it is criticalthat the operator closely monitors odour emissionsat the beginning to ensure any issues are quicklypicked up and addressed.

4.2.1 4.2.1 Prior to carrying out any PermittedActivities, the Operator must submit areport to SEPA demonstrating that alldrainage systems within the PermittedInstallation are capable of ensuringcompliance with condition 4.2.2.

Drainage survey highlighted broken orobstructed drains. Construction workunderway. Upgrade condition necessary toprotect soil and groundwater prior to activitiescommencing

Schedule 8 8.2 Waste Pre-Acceptance Considered BAT. The site must quality controlincoming waste acceptance in order to avoidbottlenecks of non-conforming wastes on site,storage issues and inappropriate or incompletetreatment.

Schedule 9 9.1 Electronic Tracking System Electronic tracking considered BAT Requiringclear and accurate traceability of waste throughthe site. Supports maximum storage limitcondition




Schedule10

10.5 Drying system Taken from PPC/A/1138879 to cover. Incidentand fire mitigation considered BAT

10.2.2 10.2.2 When operational, allwaste within the shredders must be fullyenclosed, and under negative pressure asdefined in Condition 10.2.4.

Changed from standard condition requiringshredders to be enclosed, to clarify the wastewithin the shredder must be fully enclosed, notthe shredder unit itself.


Applicant:

9 EMISSION LIMIT VALUES OR EQUIVALENT TECHNICAL PARAMETERS/ MEASURES

Are you are dealing with either a permit application, or a permit variation which would involve areview of existing ELVs or equivalent technical parameters? No

Emission limit values Air

Substance: Oxides of Nitrogen

ELV: 100 mg/m3

Emission point: EP1 & EP4

Rationale: ELV taken from Table 1 Part 2 of the Medium Combustion Plant Directive for newplants running on natural gas. The ELV’s in this table vary depending on fuel type thereforeSchedule 1 of the Permits stipulates that the plant must run on natural gas only.

Details of any derogations from the ELVs set out in the BAT conclusions;N/A

Has an Annex been inserted to the permit containing reasons, assessment and justificationsfor setting the value: N/A

Details of any temporary derogation for the use of emerging techniques. NB Such temporaryderogations do not require PPD consultation or the insertion of reasons etc. into the permit

Emission limit values Water

Not required

Emission limit values Land

Not required

Emission limit values Noise and Vibration - None

10 PEER REVIEW

Has the determination and draft permit been Peer Reviewed? Yes

Name of Peer Reviewer and comments made: David Smith




11 FINAL DETERMINATION

Hazardous waste transferIssue of a draft permit.

Clinical waste treatment via thermal screw augerIssue of a draft permit.

Issue a Permit – Based on the information available at the time of the determination SEPA is satisfied that The applicant will be the person who will have control over the operation of the installation/mobile plant, The applicant will ensure that the installation is operated so as to comply with the conditions of the Permit, The applicant is a fit and proper person Planning permission for the activity is in force That the operator is in a position to use all appropriate preventative measures against pollution, in particular

through the application of best available techniques. That no significant pollution should be caused.

Officer:Hilary Holding

12 REFERENCES AND GUIDANCE

Guidance Notes – Identify key references, guidance (BREF, UK Technical Guidance, etc) used in determination

BAT conclusions and BREF for Waste Treatment

IPPC S5.06 Guidance for the recovery and disposal of hazardous and non-hazardous wastes, andassociated Environment Agency’s EPR5.07 guidance

Tradebe Healthcare National Ltd Bellshill Healthcare Waste ... · Empty clean containers and waste...

Documents

Transcript of Tradebe Healthcare National Ltd Bellshill Healthcare Waste ... · Empty clean containers and waste...