FCC Waste Services (UK) Limited (Formerly WRG Waste Services Limited)

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 1 of 15

FCC Waste Services (UK) Limited (formerly WRG Waste Services Limited)

Greengairs Landfill Site

Permit Variation

PPC/W/0020041

CONTENTS

1 NON TECHNICAL SUMMARY OF DETERMINATION...... 2 2 EXTERNAL CONSULTATION AND SEPA’S RESPONSE ...... 3 3 ADMINISTRATIVE DETERMINATIONS...... 5 4 INTRODUCTION AND BACKGROUND ...... 5 4.1 Historical Background to the activity and application/variation...... 5 4.2 Description of activity...... ERROR! BOOKMARK NOT DEFINED. 4.3 Outline details of the Variation applied for/proposed (delete if not dealing with a variation)6 4.4 Guidance/directions issued to SEPA by the Scottish Ministers under Reg.60 or 61...... 7 4.5 Identification of important and sensitive receptors...... 7 5 KEY ENVIRONMENTAL ISSUES...... 7 5.1 Summary of significant environmental impacts ...... 7 5.2 Implications of the Variation on - Point Sources to Air...... 7 5.3 Implications of the Variation on - Point Source Emissions to Surface Water and Sewer...... 7 5.4 Implications of the Variation on - Point Source Emissions to Groundwater ...... 8 5.5 Implications of the Variation on - Fugitive Emissions to Air...... 8 5.6 Implications of the Variation on - Fugitive Emissions to Water...... 8 5.7 Implications of the Variation on - Odour ...... 8 5.8 Implications of the Variation on - Management ...... 8 5.9 Implications of the Variation on - Raw Materials ...... 8 5.10 Implications of the Variation on - Raw Materials Selection...... 8 5.11 Implications of the Variation on - Waste Minimisation Requirements ...... 9 5.12 Implications of the Variation on - Water Use...... 9 5.13 Implications of the Variation on - Waste Handling ...... 9 5.14 Implications of the Variation on - Waste Recovery or Disposal ...... 9 5.15 Implications of the Variation on - Energy...... 9 5.16 Implications of the Variation for - Accidents and their Consequences...... 9 5.17 Implications of the Variation for - Noise...... 9 5.18 Implications of the Variation for - Monitoring ...... 10 5.19 Implications of the Variation for - Closure ...... 10 5.20 Implications of the Variation for - Site Condition Report ...... 10 5.21 Implications of the Variation for - Consideration of BAT ...... 10 6 OTHER LEGISLATION CONSIDERED...... 11 7 ENVIRONMENTAL IMPACT ASSESSMENT AND COMAH ...... 12 8 DETAILS OF NON STANDARD PERMIT CONDITIONS...... 12 9 EMISSION LIMIT VALUES OR EQUIVALENT TECHNICAL PARAMETERS/ MEASURES...... 15 10 PEER REVIEW ...... Error! Bookmark not defined. 11 FINAL DETERMINATION...... 15 12 REFERENCES AND GUIDANCE ...... Error! Bookmark not defined. Permit (Application) Number: PPC/W/002041 Applicant: FCC Waste Services (UK) Limited

1 NON TECHNICAL SUMMARY OF DETERMINATION

Greengairs Landfill Site is operated by FCC Waste Services (UK) Limited under an existing PPC permit (PPC/W/0020041). The Permit was granted on 22 May 2006, and has been varied on four previous occasions.

Currently FCC Waste Services (UK) Limited is permitted to receive, handle and store inert and non- hazardous waste from waste management facilities, which includes non-hazardous Incinerator Bottom Ash (IBA). This application is to vary its current PPC Permit to include the treatment of IBA within the boundary of the Permitted Installation.

IBA is the fraction that is left over after waste is burnt in an incinerator. Municipal energy from waste plants that use incineration burn a wide range of municipal wastes and therefore the term ‘ash’ is slightly misleading because it is not all powdery but contains glass, brick, rubble, sand, grit, metal, stone, concrete, ceramics and fused clinker as well as combusted products such as ash and slag. IBA equates to between 20% and 30% of the input to the incinerator.

When IBA is removed from the EfW furnace larger objects such as stones, bricks and metals are typically screened out for recycling or reuse if possible.

The source of the IBA is Millerhill Energy from Waste (EfW) site which commenced commissioning operations in the early 2019. The permit holder of Millerhill Energy from Waste installation is also FCC Waste Services (UK) Limited.

A designated lined storage containment pad has been constructed at Greengairs Landfill, on which they intend to store and treat IBA. The construction is similar in design and characteristics to a landfill cell and so is designed to contain waste and rainwater runoff for collection and treatment.

IBA will be sampled at the source site then transported to Greengairs for storage pending analytical results.

If the IBA is confirmed as non-hazardous waste the IBA will undergo maturation for some 10 weeks in the open air (atmospheric carbon dioxide and rainwater being required). The maturation process should result in a reduction of pH and stabilise any heavy metal leachability of the IBA.

The IBA will be treated using mobile plant to remove metals, be crushed, and screened to create an incinerator bottom ash aggregate (IBAA).

The IBAA may be deposited in the landfill or utilised as surrogate aggregate for the specified engineering projects within the Permitted installation as agreed with SEPA and in line with SEPA’s Position Statement “Use of Incinerator Bottom Ash Aggregate”. In the longer term, the producer and contractor intend to develop re-use markets, cycling this material back into the construction sector to reduce reliance on virgin quarried material.

The quantity of IBA accepted at the Permitted Installation will be 38,750 tonnes per annum. The variation does not propose to increase the total or annual quantity of waste that is to be accepted or deposited at the Permitted Installation.

After considering the application SEPA is satisfied that the activity can be adequately controlled through the addition of a small number of permit conditions, predominantly aimed at controlling the primary risks identified – namely dust and noise during periodic use of mobile plant. However, use of such equipment is common place in Britain and Europe, is well understood technology and is not deem to pose an unacceptable environmental or nuisance risk. Glossary of terms

BAT - Best Available Techniques CO - Coordinating Officer ELV - Emission Limit Value IBA - Incinerator Bottom Ash EfW - Energy from Waste

2 EXTERNAL CONSULTATION AND SEPA’S RESPONSE

Is Public Consultation Required - Yes

Advertisements Check: Date Compliance with advertising requirements

Edinburgh Gazette 24/9/18 yes

Airdrie and Coatbridge 26/9/18 yes

No. of responses received: Zero

Summary of responses and how they were taken into account during the determination: Not applicable.

Summary of responses withheld from the public register on request and how they were taken into account during the determination:

N/A

Is PPC Statutory Consultation Required – Yes

Food Standards Agency: Yes.

Response- “Based on the application and provided the applicant complies with the relevant SEPA guidance and all other relevant PPC guidance notes and regulations, Food Standard Scotland considers it unlikely that there will be any unacceptable effects on the human food chain from the emissions from this installation.

No action taken.

NHS Lanarkshire Health Board: yes

“I have reviewed the above PPC application to vary conditions of a permit to “store (temporarily) and treat Incinerator Bottom Ash (IBA) at Greengairs and subject to chemical characterisation will be used on site to assist in the completion of infill and restoration works.”

I would agree that the main potential pollution risk to humans is from dust. There are proposed mitigations to reduce the dust and these should be effective and monitored.

I therefore do not have objections to this variation to the permit from a human health point of view.”

North Lanarkshire Council Yes. “No objections”.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 3 of 15 Scottish Water: N/A – no impact on sewer or public water supply.

Health and Safety Executive: N/A. Application does not relate to installations holding nuclear site licences or COMAH sites.

Scottish Natural Heritage: SSSI within 5km. SNH response 7/9/18 We do not intend to offer advice or comment on this proposal. We are satisfied that SEPA will, at this stage, identify any impacts upon the natural heritage and address them without further reference to SNH. If, through the SCAIL modelling, it is determined that ammonia deposition levels will increase to a level that affects the designated sites, then we will expect to be consulted further.

(SCAIL COMBUSTION is a screening tool that uses the atmospheric dispersion model AERMOD to model SO2 and NOX emissions from small to medium sized combustion sources. The model estimates the impacts of nitrogen oxides (NOx: NO and NO2) and sulphur dioxide (SO2) emissions on sensitive habitat sites. User can enter details of their habitat, source and stack parameters to calculate an estimate of NOx and SO2, acid and nitrogen deposition at the habitat. The model uses wind data from the nearest meteorological station data, of which there are around 30 meteorological stations in the system.)

As there is no combustion to be carried out at the Permitted Installation (other than landfill gas) or intensive agriculture activity, no action taken.

Harbour Authority: N/A. The operation will not involve the release of a substance into a harbour managed by a harbour authority.

Discretionary Consultation - No

Public Participation Consultation - Yes

STATEMENT ON THE PUBLIC PARTICIPATION PROCESS The Pollution Prevention and Control (Scotland) Regulations 2012 (schedule 4, para 22) requires that SEPA’s draft determination of this application be placed on SEPA’s website and public register and be subject to 28 days’ public consultation. The dates between which this consultation took place, the number of representations received and SEPA’s response to these are outlined below.

Date SEPA notified applicant of draft determination 26 April 2019

Date draft determination placed on SEPA’s Website 26 April 2019

Details of any other ‘appropriate means’ used to advertise the draft.

Date public consultation on draft permit opened

Date public consultation on draft permit consultation closed

Number of representations received to the consultation

Date final determination placed on the SEPA’s Website

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 4 of 15 Summary of responses and how they were taken into account during the determination:

3 ADMINISTRATIVE DETERMINATIONS

Determination of the Schedule 1 activity

The recovery or a mix of recovery and disposal of non-hazardous waste at an installation with a capacity exceeding 75 tonnes per day, by treatment of ashes, being an activity falling within paragraph (b)(iii) of Part A of Schedule 5.4 of Schedule 1 of the Regulations;

Determination of the stationary technical unit to be permitted:

No change

Determination of directly associated activities:

To include the treatment of waste at the Permitted Installation condition 1.1.4

Determination of ‘site boundary’

No Change.

4 INTRODUCTION AND BACKGROUND

Historical Background to the activity and variation

Description of activity

Greengairs Landfill Site is operated by FCC Waste Services Limited under an existing PPC permit (PPC/W/0020041), which is currently in place for landfilling activities. The Permit was granted on 22 May 2006, and has been varied on four previous occasions.

FCC Waste Services (UK) Limited is permitted to accept a total of 35,000,000 tonnes of waste and 1,300,000 per annum at Greengairs Landfill Site.

Greengairs Landfill Site is located approximately 700m south of the village of Greengairs and approximately 1km south east of the village of Wattston at National Grid Reference NS 78900 69800.

On 11 May 2012 WRG Waste Services Limited changed its name to FCC Waste Services (UK) Limited. The company registration number 988844 remains unchanged.

The permit allows no more than 35,000,000 tonnes of waste be deposited and 1,300,000 tonnes annually at Greengairs Landfill Site.

The permit currently contains numerous conditions relating to the keeping and disposal of specified waste types. The permit holder is responsible for securing compliance with the conditions, which relate to site engineering, control, monitoring, closure and aftercare. Landfill sites in particular require complex engineering structures. Designs are required to be detailed, and construction quality assurance is required as regards capping of the top and lining of the base. The extent of the site will normally be described by reference to a plan attached to the Permit. SEPA is required to carry out regular

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 5 of 15 inspections of every licensed site to assess compliance with licence conditions. Issues of non- compliance are recorded in SEPA’s Compliance Assessment scheme, from which reports are issued to the operator. Non-compliance of requirements of the Permit impact the operator’s performance ratings for operaton the activity and ultimately dictate the number of inspections going forward.

FCC Waste Services (UK) Limited is assessed as being a chronic non-compliant operator at Greengairs Landfill Site and its compliance performance was poor in 2018.

Outline details of the Variation proposed

The variation application has been received from FCC Waste Services (UK) Limited to allow the treatment of incinerator bottom ash (IBA) at Greengairs LFS.

The treatment of IBA is described in the PPC Regulations under:

“The recovery or a mix of recovery and disposal of non-hazardous waste at an installation with a capacity exceeding 75 tonnes per day, by treatment of ashes, being an activity falling within paragraph (b)(iii) of Part A of Schedule 5.4 of Schedule 1 of the Regulations;”

Currently FCC Waste Services (UK) Limited is permitted to receive, handle and store inert and non- hazardous waste from waste management facilities that includes non-hazardous IBA. Condition 4.1.4 of the Permit states

“4.1.4 No hazardous waste shall be accepted at the Permitted Installation.”

When IBA is removed from the EfW furnace larger objects such as stones, bricks and metals are typically screened out for recycling or reuse if possible.

The source of the IBA is Millerhill Energy from Waste (EfW) site which has commenced commissioning. The permit holder of Millerhill Energy from Waste installation is also FCC Waste Services (UK) Limited.

A designated lined storage containment pad has been constructed at Greengairs Landfill to store IBA.

FCC Waste Services (UK) Limited has been carrying out chemical testing on IBA produced during the EfW commissioning process to establish the waste classification (i.e. non-hazardous or hazardous).

Samples of the IBA for chemical testing will be collected at the point of production at Millerhill EFW site. It is proposed the IBA will then be transported to Greengairs Landfill site and stored in windrows on the constructed containment pad.

The chemical testing may take up to six weeks to get results issued.

If following testing the IBA is classified as hazardous waste, using the agreed classification protocols, the IBA will be consigned as special waste and removed from Greengairs LFS to an appropriately authorised site.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 6 of 15 The IBA will be treated using mobile plant to remove metals, be crushed and screened. Several fractions will result from the treatment including ferrous and non ferrous metals, IBA (0-2mm), and an incinerator bottom ash aggregate (IBAA) at 6-12mm, 12- 22mm and 22-40mm.

FCC Waste Services (UK) Limited will have control over the storage, treatment and use of IBA at Greengairs Landfill Site and the Operator will ensure that the additional treatment operations undertaken by sub-contractors will be operated so as to comply with the conditions inserted into the permit. FCC has stated a Management Plan will be submitted that has to be assessed and approved by SEPA.

Guidance/directions issued to SEPA by the Scottish Ministers under Reg.60 or 61. None

Identification of important and sensitive receptors

1. People.

The Installation is surrounded by villages (Wattston, Greengairs, Upperton, Longriggend, Plains). Greengairs is located approximately 700m north of the village of Greengairs, by Airdrie (NS 789 698).

2. Environment

The landfill is located within 1km of Longriggend Moss Site of Special Scientific Interest (SSSI); 2.5km from West Fannyside Moss SSSI and Special Area of Conservation (SAC) and within 1.9km of the Slamannan Plateau SSSI and Special Protection Area (SPA). SNH was consulted.

5 KEY ENVIRONMENTAL ISSUES

Summary of significant environmental impacts

Potential for release of contaminants to air (in dust), ground water and surface water.

There are existing permit conditions and management practices on site should adequately control environmental impacts from the activities. If the proposed process is managed in compliance with the proposed conditions, then there should be no significant environmental impacts from the activities.

Implications of the Variation on - Point Sources to Air There are no point source emissions to air.

Implications of the Variation on - Point Source Emissions to Surface Water and Sewer

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 7 of 15 There should be no point source or fugitive emissions to surface water from the IBA pad as the pad is effectively a bunded cell with bund walls made of 500m clay. Any site surface water should be managed to ensure appropriate treatment prior to discharge under the existing permit conditions.

Implications of the Variation on - Point Source Emissions to Groundwater

The containment pad itself is to be constructed of 500mm of compacted clay with a permeability of 5 x 10-10 m/s – the same as required at the adjacent landfill for the mineral layer part of the lining system. There is no sealing layer proposed. However, calculations have previously been submitted that show that as long as the containment pad does not allow standing water the clay liner should be sufficient to withhold contaminants from the environment for 30 years which is in excess of the design life of the pad. It is proposed to protect the clay liner by utilising a geotextile and then installing a running surface which would also be made from aggregate of approximately 500mm thick.

Implications of the Variation on - Fugitive Emissions to Air The storage and treatment of IBA may give rise to dust but there is a condition controlling dust in the Permit already. This condition will be amended, and additional conditions inserted to provide adequate regulatory control if necessary. In practice the techniques proposed are widely used, and in some regulatory regimes regulated under less stringent forms of authorisation, therefore the additional risk is deemed low.

Implications of the Variation on - Fugitive Emissions to Water There should be no implications for fugitive emissions to water.

Implications of the Variation on - Odour The operator has advised there should be no odour from the IBA.

There is a condition in the Permit requiring the waste management activities carried out do not give rise to offensive odours beyond the site boundary.

“2.12.1 Waste operations shall be carried out so that offensive odours from the Permitted Installation, in the opinion of an authorised SEPA officer, do not become detectable beyond the boundaries of the Permitted Installation.”

Implications of the Variation on - Management

FCC Waste Services (UK) Limited will be required to submit a Management Plan or amend an existing Management Plan detailing the storage and treatment of IBA by the existing permit condition

3.1.2 Any proposed change(s) by the Operator to the Management Plan shall be submitted in writing by Recorded Delivery letter to SEPA. The Management Plan shall only be amended in accordance with the proposed change(s) if, and to the extent that, either (a) SEPA gives written consent to the proposed change(s) or (b) SEPA has not indicated to the Operator in writing within 14 days of receiving the proposed change(s) that the proposed change(s) are rejected

Implications of the Variation on - Raw Materials There will be negligible implications on raw material as a result of the variation. The pad will be constructed with site sourced clay that will have a geotextile protection layer laid over before a working surface of IBA 500mm deep used as a working running surface.

Implications of the Variation on - Raw Materials Selection Site won clay used for base and bund walls (to have a permeability of 5 x 10-10 m/s) to be covered with geotextile.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 8 of 15 Implications of the Variation on - Waste Minimisation Requirements Ferrous and non ferrous metals to be removed from IBA. The IBA to be treated to an acceptable standard to produce a surrogate to virgin aggregate. The long term aim is to develop virgin material replacements, therefore removing the need for fresh quarried materials.

Implications of the Variation on - Water Use

There will be no implications on water use as a result of the variation.

Implications of the Variation on - Waste Handling

IBA will be deposited onto the constructed containment pad and stored in open windrows for a maturation period of up to 10 weeks to allow pH stabilisation and stabilise any heavy metal leachability If the IBA is classified as non hazardous after testing the waste will be deposited in landfill.

If following testing the IBA is classified as hazardous waste the IBA will be removed from Greengairs LFS to an appropriately authorised site. Given the containment provided by the lined area, the temporary storage of hazardous waste is not deemed to pose an unacceptable environmental risk.

Implications of the Variation on - Waste Recovery or Disposal As part of the Variation application FCC propose to recover metals from the IBA using mobile plant. The metal will be bulked up and then removed to an authorised site for recycling.

The treated IBA will either be disposed of in the landfill or if treated sufficiently to an acceptable incinerator bottom ash standard may be used for engineering purposes e.g. internal site roads construction and resurfacing. In the longer term, markets will be developed for the IBAA as a surrogate virgin aggregate material, pushing that material back into the circular economy.

If the IBA is classified as special waste it will be removed to a suitably licensed facility.

Implications of the Variation on – Energy

Additional fuel will be used constructing the storage pad. Additional plant/machinery will be used to treat the waste and to move to working cell for final disposal.

Implications of the Variation for - Accidents and their Consequences

The site operates under an Accident Prevention and Incident Plan which considers potential hazards on site. The variation is not considered to alter the arrangements of this existing Plan.

Implications of the Variation for – Noise

The facility has been operational for a number of years although this variation will allow the treatment of waste (other than imported leachate). It is unlikely that there will be any additional impacts relating to noise affecting any nearby properties. There is a condition in the permit concerning Noise and vibration control is “2.8 Noise and Vibration 2.8.1 The provisions contained in the Management Plan to minimise the nuisance and hazards arising from the Permitted Installation in respect of noise and vibration shall be complied with, and shall be reviewed every 4 years.”

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 9 of 15 This condition will be removed and replaced with additional conditions which will require a verification assessment to be undertaken during the first round of waste crushing and screening to ensure that impacts were adequately quantified in the application.

Implications of the Variation for – Monitoring

The IBA will need to be tested to confirm its classification i.e. either non hazardous or special waste.

FCC proposes to test the IBA with the ESA protocol. This is not a SEPA approved document but in the absence of any SEPA equivalent it is deemed adequate. However, in the future, SEPA would reserve the right to require alterations to the sampling methodology to bring the site(s) in line with any SEPA produced guidance.

A summary of the proposal would be that it utilises a 24 sample rolling assessment period during which no more than 5 out of any 24 samples can exceed the non-hazardous limits or 1 sample test as more than 4 times the limit. Provided these standards are met the material is deemed non-hazardous.

FCC propose to carry out testing on IBA leachate/washwaters from the lined lagoon prior to the leachate being pumped to the leachate treatment plant or tankered off to a licensed site.

Monitoring of the effluent run-off at the sump/storage lagoon will be monitored on a monthly basis for both chloride and sulphate. Additional determinands should be monitored on a quarterly basis, see Table below. The effluent will either be sent to the onsite LTP for treatment with the landfill leachate or tankered off-site for disposal accordingly. An initial characterisation period will involve sampling every 2 weeks for a period of 3 months before reverting to schedule contained in Table 2.

Location Parameter Units Limits Frequency pH, EC mg/l none Monthly Cl, SO4, NH4-N TOC mg/l none Quarterly Leachate Ca, Mg, Na, K Lagoon Alkalinity, TON Cd, As, Pb Cr, Cu, Ni, Zn Fe, Mn, Hg Hg mg/l none Annually

Implications of the Variation for – Closure There is no implication for closure.

Implications of the Variation for - Site Condition Report (and where relevant the baseline report) There is no implication on the site condition Report.

Implications of the Variation for - Consideration of BAT BAT is not applicable to landfilling activities, but does apply to ancillary waste treatment activity.

In accordance with the requirements of the Waste Incineration Directive (WID) Article 9, Best Available Techniques (BAT) and the BREF Note on Incineration 2, the intermediate storage and transport of dry residues in the form of dust i.e. the boiler dust and dry residues from the treatment of combustion gases will take place in such a way so as to prevent as far as practicable emission to the environment.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 10 of 15 6 OTHER LEGISLATION CONSIDERED

Nature Conservation (Scotland) Act 2004 & Conservation (Natural Habitats &c.) Regulations 1994

Is there any possibility that the proposal will have any impact on site designated under the above legislation? Yes

Screening distance(s) used – 5km

Are there any SSSIs within the area screened? Yes

Has SNH been consulted under section 15(5) of the 2004 Act? Yes

Date consultation letter sent – 15 August 2018

Summary of response received including date –

SNH response 7/9/18 We do not intend to offer advice or comment on this proposal. We are satisfied that SEPA will, at this stage, identify any impacts upon the natural heritage and address them without further reference to SNH. If, through the SCAIL modelling, it is determined that ammonia deposition levels will increase to a level that affects the designated sites, then we will expect to be consulted further.

Actions taken including justification – To proceed with determination.

Has SEPA reached agreement with SNH on protection of the SSSI? - Yes

Are there any SPA or SAC designated areas within the area screened? Yes

Special Protection Area Site Code 9184 Slamannan Plateau Forth Special Protection Area Taiga bean goose (Anser fabalis fabalis), non-breeding

Special Area of Conservation Site Code 8603 West Fannyside Moss Strathclyde & Ayrshire (Blanket bog Upland habitat Favourable Maintained)

Have you carried out an appropriate assessment? No. SEPA’s Terrestrial Ecology considered the proposal and concluded the activity will not result in likely significant effect to any designated conservation site. No further assessment is required under nature conservation legislation or SEPA Nature Conservation Procedure for Environmental Licensing.

Date appropriate assessment consultation letter sent – 3 October 2018

Summary of responses received from SNH including date – No response.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 11 of 15 Other legislation?

None.

7 ENVIRONMENTAL IMPACT ASSESSMENT AND COMAH

How has any relevant information obtained or conclusion arrived at pursuant to Articles 5, 6 and 7 of Council Directive 85/337/EEC on the assessment of the effects certain public and private projects on the environment been taken into account? N/A. No EIA required by planning as they considered the proposal was not a material change to the planning consent.

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 into account? Not applicable.

8 DETAILS OF PERMIT

Do you propose placing any non standard conditions in the Permit Yes

1. Condition 1.1.3 shall be amended to include the following additional Permitted Activity:

• The recovery, or a mix of recovery and disposal, of non-hazardous waste at an installation with a capacity exceeding 75 tonnes per day, by treatment of ashes, being an activity falling within paragraph (b)(iii) of Part A of Schedule 5.4 of Schedule 1 of the Regulations;

2. Condition 1.1.4 shall be amended by inserting the word ‘treatment’ after the word ‘handling’ . The third bullet point shall now read:

3. Condition 2.8 shall be deleted and replaced with the following:

2.8 Noise and Vibration

2.8.1 Within 10 weeks of the commencement of IBA treatment using mobile plant, the Operator shall submit an environmental noise report to SEPA, conforming to a recognised British Standard, quantifying the impact of the specific noise at noise sensitive receptors during operational treatment periods. The report should detail any intermittency, tonal, or other factors that may make the specific noise subjectively more annoying.

2.8.2 Within 2 months of submitting the environmental noise report, as required by Condition 2.8.1, the Operator shall update the Noise Management Plan, describing any further measures to be taken to prevent, or where that is not practicable minimise, the impact of noise emissions on noise sensitive receptors. The updated plan shall be submitted to SEPA.

2.8.3 At least every 4 years, the Operator shall carry out a systematic assessment of noise and vibration emissions associated with the Permitted Activities, the purpose of which shall be to identify sources of noise and vibration on the site and methods of reducing noise and vibration from these sources. Each assessment shall be recorded and reported to SEPA.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 12 of 15 5. Condition 4.10 shall be inserted as follows:

4.10 Storage and treatment of incinerator bottom ash wastes

4.10.1 Storage and treatment of incinerator bottom ash wastes within the Permitted Installation shall only be carried out in the containment pad identified on the site plan shown in Appendix 8.

4.10.2 The base and sides of the containment pad shall consist of an artificially established engineered compacted mineral layer having as a minimum the following standards:

(a) Permeability of less than or equal to 5 x 10-10 metres/second; and (b) Thickness of greater than or equal to 0.5 metre.

4.10.3 The engineered compacted mineral layer specified in condition 4.10.2 shall be protected from damage by a minimum of a geotextile barrier and 500mm depth of suitable fill material.

4.10.4 Stockpiles of incinerator bottom ash shall not be placed within 2m of the containment pad bund walls. 4.10.5 The containment pad shall be provided with a HDPE lined lagoon to collect and contain wash waters and leachate from the incinerator bottom ash.

Do you propose making changes to existing text, tables or diagrams within the permit? Yes

Outline of change

1. The following reporting requirements shall be added to Table 2.4.9:

Summary of Information Condition Date/Within Date First to be Reported period/ Frequency Report Due to be Reported Environmental noise report 2.8.1 One off report Within 10 weeks of the commencement of IBA treatment using mobile plant Environmental Noise 2.8.2 One off report Within 2 months Management Plan of the submission of the report required by condition 2.8.2 Systematic assessment of 2.8.3 At least every 4 30 June 2023 noise emissions years after initial report received

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 13 of 15 Outline of change A site plan is insert into the Permit showing the location of the IBA pad in relation to the rest of the landfill site that gives some visual control of where the IBA is allowed to be stored when assessing compliance.

2. Appendix 8 -SITE PLAN IBA STORAGE PAD LOCATION

IBA STORAGE PAD

Details including justification: as above.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 14 of 15 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 a review of existing ELVs or equivalent technical parameters? No.

Justification: there is no review of existing ELVs or equivalent technical parameters as part of the determination of the variation application.

10 FINAL DETERMINATION

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/mobile plant is operated so as to comply with the conditions of the Permit,  The applicant is a fit and proper person (specified waste management activities only),  Planning permission for the activity is in force (specified waste management activities only),  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.

Consequently, we have determined to deem the application granted subject to the inclusion of specific permit conditions.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 15 of 15