Stericycle Tamworth Healthcare Treatment Plant and Transfer Station Environmental Permit Application Report Application Document Number 07

July, 2019 Version 1.0

Table of contents Stericycle Tamworth ...... 1 Healthcare Plant and Transfer Station ...... 1 Environmental Permit Application Report ...... 1 Application Document Number 07 ...... 1 PART A - OVERVIEW ...... 4 1. Non-Technical Summary ...... 4 2. Permitted Activities ...... 6 Activity Flowchart ...... 6 Installation and Waste Operation Activities (Table 1a) ...... 7 Activities – BAT and supplementary Information ...... 9 3. Permitted (Table 1b) ...... 10 4. Emissions ...... 14 Overview ...... 14 Point source emissions to air ...... 14 Point source emissions to foul sewer ...... 15 Other point source emissions ...... 15 Fugitive emissions ...... 15 Waste transfers off-site ...... 16 PART B – OPERATING TECHNIQUES ...... 17 5. Technical standards and general requirements ...... 17 6. Waste pre-acceptance and acceptance ...... 18 7. Waste storage ...... 19 Description ...... 19 Storage area designation ...... 20 Storage timescales ...... 21 Storage area schematic ...... 22 Storage areas – supplementary information ...... 22

8. The treatment process ...... 24 Steam Disinfection Auger Description ...... 24 Cold shredding of offensive waste ...... 24 Treatment Plant Process Schematic ...... 26 Commissioning and validation...... 27 9. Techniques for pollution control ...... 29 Waste pre-acceptance and acceptance ...... 29 Waste storage ...... 29 Air abatement system ...... 29 10. Emissions monitoring ...... 31 Emissions to air ...... 31 Emissions to sewer ...... 31 11. Business Management System ...... 32 12. Raw materials ...... 33 13. Resource efficiency and climate change ...... 34 Energy efficiency ...... 34 Climate change ...... 34 Justification for use of raw materials ...... 34 Avoidance of waste production ...... 35 14. Environmental Risk Assessment and Options appraisal ...... 37 15. Combustible Wastes & Fire Prevention Plan ...... 37 16. Site Condition ...... 38 PART C – Appendices ...... 39 17. Appendix List ...... 39

PART A - OVERVIEW

1. Non-Technical Summary

The proposed development comprises a healthcare waste treatment plant and transfer station. The site will receive packaged healthcare and related wastes that are suitable for either on-site treatment (physio-chemical or mechanical) or transfer off-site to other disposal or recovery facilities.

The on-site treatment plant consists of a single steam auger with integral shredder and a separate cold shred line (for mechanical treatment only) for the following activities:  Installation - the heat disinfection and mechanical re-processing of hazardous healthcare wastes for disposal or recovery  Waste operation - the mechanical re-processing of non-hazardous healthcare wastes for disposal or recovery

The following are directly associated activities to the treatment plant:  Gas fired steam raising plant to supply the steam auger  Bin washing system for re-usable waste containers  Storage of treatment plant residues pending transfer off-site for disposal or recovery

The transfer station consists of the following activities:  Installation - the storage of hazardous wastes pending on-site treatment or transfer off-site for disposal or recovery  Waste operation - the storage of non-hazardous wastes pending on-site treatment or transfer off-site for disposal or recovery  Waste operation – repackaging of offensive waste (light compaction) pending transfer off site for disposal or recovery

The main features of the facility are as follows:

The treatment plant consists of a shredder, a single chamber steam auger and pollution abatement equipment. Waste is shredded under negative pressure before transfer to the auger chamber where a combination of heat, moisture and residence time is sufficient to disinfect the waste. Steam is supplied to the auger from the gas fired steam raising plant. Off-gases from the auger are cooled in a condenser with the resulting water being discharged to foul sewer. Any residual gases are transferred through the abatement system with the off-gases from the shredder system.

The abatement system comprises a high efficiency particulate air (HEPA) filter, a coalescing vessel and a carbon filter bed that in combination are designed to remove any infectious bio-aerosols, excess moisture and any residual organic compounds and odours from the off- gases before their release to atmosphere.

There is a single emission point to air from the treatment process where the final off-gases are released, and a further associated emission point to air from the gas fired steam raising plant. There is also an emission point to foul sewer for effluent arising from the treatment process condensate and for effluent arising from the container washing process. There are no emissions to surface water arising from the activities at the site. The shredded and treated residue is stored on site pending transfer off-site for disposal to or for recovery and use as a refuse derived fuel.

The thermal waste treatment process and mechanical treatment of offensive waste is undertaken wholly within the process building with no treatment activities being undertaken outside the building. Light compaction of offensive waste is the only activity which occurs externally. Waste is stored in designated storage areas both inside and outside the building. All designated storage areas have impermeable surfaces with sealed drainage and all waste is stored in fully enclosed, leak-proof containers.

The site is located on Lichfield Road Industrial Estate, Tamworth. All adjacent property and land is in commercial/industrial use. The nearest residential area to the site is the area off Buckingham Road approximately 130m to the South West. The site is located within flood zone 3 for rivers and sea with the nearest watercourse being the River Tame, 550m to the South West. There is also a surface water culvert that runs adjacent to the entrance of the site on the North East side.

2. Permitted Activities

Activity Flowchart

Installation and Waste Operation Activities (Table 1a)

Installation activities Schedule 1 Description of the Annex IIA or IIB treatment Installation name references activity Activity capacity codes capacity A1 Treatment Plant – 5.3 A (1) a Heat disinfection 48 tonnes per day R03; D09 48 tonnes per day hazardous (ii) steam auger A2 Transfer Station - 5.6 A (1) a Storage of 380 tonnes total R13; D15 n/a hazardous hazardous waste storage capacity (excluding residues from A4) Directly associated activities to the installation Name of the DAA Description of the DAA A3 Combustion Plant - Steam Raising of steam in a gas fired boiler (serves the treatment plant (activity A1) and bin wash (Activity 5) generation A4 Storage of residues from Storage of residue arising from the treatment plant pending transfer off-site (serves the treatment the treatment process plant) A5 Container washing Washing of re-usable healthcare waste containers prior to dispatch to customers (serves both installation activities) For installations that take waste

Total storage capacity 380 tonnes (excluding residues from A4) Annual throughput 17,500 tonnes Waste operation activities operation name Description of the activity Activity capacity Annex IIA or IIB codes A6 Treatment – non - Disposal of non-hazardous healthcare Max 10% of treatment plant capacity R03; D09 hazardous waste (blood products) combined with activity A1 A7 Treatment – non- Mechanical shredding of offensive waste 20 tonnes per day R03; D09 hazardous for disposal or recovery A8 Transfer station – Storage of non-hazardous waste prior to Included in the 380 tonnes total R13; D15 Non-hazardous transfer storage capacity A9 Transfer station – Repackaging of offensive waste – light 20 tonnes per day R12; D14 non-hazardous compaction

Activities – BAT and supplementary Information

All activities will be operated in accordance with Environment Agency guidance note EPR5.07, and as a consequence Stericycle believes that the operational processes and techniques to be used represent best available techniques (BAT). Further details of this are provided in sections 3-9 of this report.

3. Permitted Wastes (Table 1b)

Waste types permitted for treatment – activities A1 and A6 Maximum quantity 48 tonnes per day Hazard properties HP9 Waste Code Description 18 WASTES FROM HUMAN OR ANIMAL HEALTH CARE AND/OR RELATED RESEARCH 18 01 wastes from natal care, diagnosis, treatment or prevention of disease in humans 18 01 03* wastes whose collection and disposal is subject to special requirements in order to prevent infection 18 01 02 body parts and organs including blood bags and blood preserves (except 18 01 03) 18 02 wastes from research, diagnosis, treatment or prevention of disease involving animals 18 02 02* wastes whose collection and disposal is subject to special requirements in order to prevent infection

20 MUNICIPAL WASTES (HOUSEHOLD WASTE AND SIMILAR COMMERCIAL, INDUSTRIAL AND INSTITUTIONAL WASTES) INCLUDING SEPARATELY COLLECTED FRACTIONS

20 01 separately collected fractions (except 15 01)

20 01 99 other fractions not otherwise specified (comprising only of separately collected fractions of municipal clinical waste which is subject to special requirements in order to prevent infection

Waste types permitted for treatment or repackaging – activities A7 and A9 Maximum quantity 20 tonnes per day Hazard properties n/a Waste Code Description 18 WASTES FROM HUMAN OR ANIMAL HEALTH CARE AND/OR RELATED RESEARCH 18 01 wastes from natal care, diagnosis, treatment or prevention of disease in humans

18 01 04 wastes whose collection and disposal is not subject to special requirements in order to prevent infection 18 02 wastes from research, diagnosis, treatment or prevention of disease involving animals 18 02 03 wastes whose collection and disposal is not subject to special requirements in order to prevent infection

20 MUNICIPAL WASTES (HOUSEHOLD WASTE AND SIMILAR COMMERCIAL, INDUSTRIAL AND INSTITUTIONAL WASTES) INCLUDING SEPARATELY COLLECTED FRACTIONS

20 01 separately collected fractions (except 15 01)

20 01 99 other fractions not otherwise specified (comprising only of separately collected fractions of municipal offensive or hygiene waste which is not subject to special requirements in order to prevent infection

Waste types permitted for storage and transfer – activities A2 and A8 Maximum quantity 380 tonnes total storage (including storage in transit) capacity (max 330 tonnes hazardous at any one time or max 50 tonnes non- hazardous at any one time) 48 tonnes per day maximum throughput Hazard properties HP3, HP4, HP5, HP6, HP7, HP8, HP9, HP10, HP11 Waste Code Description 18 WASTES FROM HUMAN OR ANIMAL HEALTH CARE AND/OR RELATED RESEARCH (except kitchen and restaurant wastes not arising from immediate health care) 18 01 wastes from natal care, diagnosis, treatment or prevention of disease in humans 18 01 01 sharps (except 18 01 03) 18 01 02 body parts and organs including blood bags and blood preserves (except 18 01 03) 18 01 03* wastes whose collection and disposal is subject to special requirements in order to prevent infection 18 01 04 wastes whose collection and disposal is not subject to special requirements in order to prevent infection (for example dressings, plaster casts, linen, disposable clothing, diapers) 18 01 06* chemicals consisting of or containing dangerous substances 18 01 07 chemicals other than those mentioned in 18 01 06

18 01 08* cytotoxic and cytostatic medicines 18 01 09 medicines other than those mentioned in 18 01 08 18 01 10* amalgam waste from dental care 18 02 wastes from research, diagnosis, treatment or prevention of disease involving animals 18 02 01 sharps (except 18 02 02) 18 02 02* wastes whose collection and disposal is subject to special requirements in order to prevent infection 18 02 03 wastes whose collection and disposal is not subject to special requirements in order to prevent infection 18 02 05* chemicals consisting of or containing dangerous substances 18 02 06 chemicals other than those mentioned in 18 02 05 18 02 07* cytotoxic and cytostatic medicines 18 02 08 medicines other than those mentioned in 18 02 07 07 WASTES FROM ORGANIC CHEMICAL PROCESSES

07 05 wastes from the MFSU of pharmaceuticals 07 05 13* solid wastes containing dangerous substances 07 05 14 solid wastes other than those mentioned in 07 05 13 09 WASTES FROM THE PHOTOGRAPHIC INDUSTRY

09 01 wastes from the photographic industry 09 01 01* water-based developer and activator solutions 09 01 02* water-based offset plate developer solutions 09 01 03* solvent-based developer solutions 09 01 04* fixer solutions 09 01 05* bleach solutions and bleach fixer solutions 09 01 07 photographic film and paper containing silver or silver compounds 09 01 08 photographic film and paper free of silver or silver compounds 15 WASTE PACKAGING; ABSORBENTS, WIPING CLOTHS, FILTER MATERIALS AND PROTECTIVE CLOTHING NOT OTHERWISE SPECIFIED 15 01 packaging (including separately collected municipal ) 15 01 10* packaging containing residues of or contaminated by dangerous substances (lead foils from dental care) 20 MUNICIPAL WASTES (HOUSEHOLD WASTE AND SIMILAR COMMERCIAL, INDUSTRIAL AND INSTITUTIONAL WASTES) INCLUDING SEPARATELY COLLECTED FRACTIONS 20 01 separately collected fractions (except 15 01) 20 01 31* Cytotoxic and cytostatic medicines 20 01 32 Medicines other than those mentioned in 20 01 31 20 01 99 other fractions not otherwise specified (comprising of separately collected fractions of municipal clinical waste (not arising from

healthcare and/or related research i.e. not including waste from natal care, diagnosis, treatment or prevention of disease) which is subject to special requirements in order to prevent infection).

4. Emissions

Overview The facility will have two emission points arising from the treatment plant activities (installation and operation), and one emission point arising from a directly associated activity to the installation. There are no emission points from the storage and transfer installation or operation.

The only emissions parameters requiring control are those for microbial emissions. Pharmaceutical and chemical emissions monitoring is not required as suitable pre- acceptance and acceptance measures are in effect.

Table 2 - Emissions Emission point reference and location Source Parameter Quantity Unit A1 – treatment Treatment plant Bacillus spores Not more than Cfu per m3 plant exhaust abatement system benchmark of 1000 A2 – boiler Steam raising boiler n/a n/a n/a exhaust S1 – foul sewer Treatment plant effluent Bacillus spores Not more than Cfu per litre discharge point discharge benchmark of 300

Point source emissions to air The pollution control system described in section 8 of this report is designed to reduce and minimise any impact arising from these emissions.

Stericycle operates five other clinical waste treatment facilities with comparable pollution control systems in the UK, all of which have routinely proven to be effective at:  Removal of infectious bio-aerosols from the point source emissions. This will be demonstrated by completion of microbial emissions monitoring (at commissioning and validation then routinely as specified in EPR 5.07). Testing will be undertaken by an independent contractor.  Minimisation of odour.

The pre-acceptance and acceptance measures in place will ensure that the emissions will not contain any chemicals (for example volatile organic compounds) or pharmaceuticals in any significant quantities that would require further assessment. In accordance with the guidance note EPR 5.07 we do not propose to undertake any further investigations into such emissions.

Emissions arising from the steam raising boiler will be below thresholds requiring further assessment. The boiler will be of a modern high efficiency design with self modulating burners designed to optimise combustion. The maximum thermal rating of the boiler is 800 kilowatts.

Point source emissions to foul sewer

Condensate arising from the treatment process is transferred directly to foul sewer. Experience at other Stericycle facilities indicates that clinical waste treatment effluents routinely comply with all terms of the discharge consents for the facilities, and are also within benchmark thresholds for microbial emissions. Limited parameters in trade effluent discharge consents are determined by the sewerage undertakers, however the following table provides information from a comparable steam auger facility operated by Stericycle.

Parameter Limit Average result Chemical oxygen demand 2000 mg/l < 500 mg/l (settled) Suspended solids 500 mg/l < 50 mg/l pH 6 - 10 7.5 – 9.5 Anionic detergents 200 mg/l < 50 mg/l

Effluent arising from the directly associated activity of container washing will also be transferred directly to foul sewer.

The Company will apply to the sewerage undertaker (Severn Trent) for a trade effluent discharge consent to cover discharge of these effluents, and will undertake any monitoring as required by the consent.

Monitoring of microbial emissions to sewer will be undertaken at the same time and to the same schedule and standard as the monitoring of microbial emissions to air.

Other point source emissions There will be no point source emissions to groundwater, surface water or land as a result of the activities at the site.

Fugitive emissions The measures in place for the storage of waste at the facility will ensure that the risk of spillage resulting in fugitive emission of any waste material to any medium is minimised as far as reasonably possible. The fugitive emission of odour is controlled by the measures for waste storage.

The risk of fugitive emissions to air from the treatment process is minimised as the system is fully enclosed and operates under negative pressure, therefore drawing all emissions

through the abatement system. Comparable Stericycle facilities have not required implementation of any fugitive emissions monitoring plans.

Waste transfers off-site Treated waste residue and the shredded offensive waste (known as flock) will be transferred off-site for recovery as a refuse derived fuel. Recovery of the flock using this method is subject to operational viability and regulatory approval at the receiving sites.

It may at periods be necessary to transfer the flock to disposal via landfill if the receiving recovery outlet cannot accept waste e.g. during shutdowns. The pre-acceptance and acceptance measures in place will ensure that the treated flock contains no hazardous components and will not have any adverse impact on land or groundwater.

PART B – OPERATING TECHNIQUES

5. Technical standards and general requirements

The site will operate as a healthcare waste treatment plant and transfer station, and as such operates in accordance with the guidance set out in EPR 5.07 Clinical Waste.

Table 3a Technical standards Relevant technical guidance Activity description note or BAT reference Document reference All installation and operation Clinical Waste sector guidance EPR 5.07 activities (A1-A9) note

The environmental risk assessment for the facility does not indicate that any of the following will be important issues:  Emission of substances not controlled by emissions limits  Fire  Odour  Noise or vibration

Comparable facilities operated by Stericycle within England do not have management plans in place for any of the above issues.

The company’s Business Management System (BMS) includes policies, procedures and work instructions designed to ensure compliance with all permit conditions and that meet the BAT requirements for general management specified in section 1.1 of EPR 5.07.

6. Waste pre-acceptance and acceptance

Waste pre-acceptance data will be obtained prior to acceptance of wastes from all waste producing sites. In practice the waste producers whose waste will be received at the facility will already have provided Stericycle with suitable pre-acceptance data as they are already Stericycle customers whose waste is currently received at other facilities.

The pre-acceptance system operated by Stericycle conforms with the requirements set out in sector guidance note EPR 5.07 (appropriate measures on pages 25-29), is fully documented in the company business management system and is already in operation (and has therefore been subject to regulatory audit and inspection) at 17 other permitted facilities operated by Stericycle in England.

Waste acceptance checks will be undertaken that conform with the requirements set out in sector guidance note EPR 5.07 (appropriate measures on pages 30-34). The fundamental requirement that the full contents of carts containing clinical waste can be inspected is met by the use of an inspection hopper into which the waste is tipped prior to loading into the treatment process. We do not intend to implement the process whereby only one cart in ten can be checked per customer after successful completion of 100% checks for the first six loads (appropriate measures point 6), and as a consequence our process will exceed the BAT requirement by continuing to require that every cart is checked in full.

A waste quarantine and rejection procedure is in effect for the handling and reporting of non-conformant wastes.

This system is already in operation at four other permitted treatment facilities operated by Stericycle in England, (and has therefore been subject to regulatory audit and inspection) and is fully documented in the company business management system.

7. Waste storage

Description Waste will be stored at and dispatched from the facility in accordance with the requirements of EPR 5.07 (appropriate measures page 41-44). Storage standards will be the same for waste destined for on-site treatment and for waste destined for off-site transfer. Storage standards will also be the same for the installation activities and for the waste operation activities.

Waste will be received into the site in 770l carts, on secured pallets or loose either directly from producers, third parties or other Stericycle facilities. All waste is received, unloaded, loaded, handled and stored in secure areas with impermeable surfaces and sealed drainage systems.

All healthcare wastes received on site (i.e. not in transit) will be stored by one of the following means:  In 770ltr wheeled carts that are lockable, fully enclosed and leak-proof.  On pallets in UN approved primary packages are stacked upright and secured  In other approved containers such as re-usable sharps containers with their associated carts/cages  In a designated, bunded storage area inside the building (Dental amalgam, x-ray fixer and developer, lead foils only).  In a fully enclosed, leak-proof static or mobile compactor (non-hazardous offensive waste only).

On receipt into the site or following loading prior to dispatch, waste can be designated as in transit. When in transit waste may be temporarily stored in trailers to facilitate a logistical operation. On acceptance of vehicles containing waste in transit, the vehicles and waste inside the vehicles is visually inspected to ensure the waste is stored appropriately and is integral. Daily checks are made by the site manager to ensure this remains the case until the trailer is sent for onward transfer.

Waste designed as in transit can be loose, in 770l carts, on pallets or other approved containers and will be contained within trailers which are lockable, fully enclosed and leak- proof. Said trailers will be located in one of the designated storage areas externally (B1, B2 or B3) for a maximum of 14 days and will not contain any pharmaceutical waste streams.

Treatment process and waste operation residues will be stored by the following means:  In walking floor containers loaded and held in an enclosed steel framed annex to the main building

Stericycle operates a proprietary waste tracking system that requires all waste carts, pallets or other secondary containers to be labelled with bar-coded tags that hold all relevant information pertaining to the waste in the container. All waste received is weighed on receipt

and again before processing through the treatment plant or transfer off-site. This system enables the following:  Maintenance of waste segregation as required by EPR 5.07  Management of waste stocks to comply with permitted limits  Management of waste stocks to ensure routine and efficient turnover of waste, thus minimising the risk of odour or other problems  Record keeping of tonnage throughputs to comply with permitted limits  Only wastes permitted for treatment can be processed through the treatment plant (barcode labels for transfer only wastes cannot be scanned into the processing system) This system is in operation and has therefore been subject to regulatory audit and inspection at 17 other permitted facilities operated by Stericycle in England.

Storage area designation Corresponding Area activities Capacity Description A A1, A2, A6, A7, A8, 300 tonnes Internal storage area with impermeable surface and A9 total sealed drainage for storage of waste on pallets, in wheeled carts or other approved container Max 260 tonnes hazardous Max 40 tonnes non-hazardous

Storage area A includes a designated, signed quarantine area for the temporary quarantine storage of up to 20 waste carts (approx. 1 tonne) B1 A1, A2, A6, A7, A8, 25 tonnes External storage area with impermeable surface and A9 total sealed drainage for storage of waste in fully enclosed, leak-proof trailers containing waste either loose, palletised or in 770l carts 25 tonnes hazardous (5 containers @ 5 tonnes (trailers)) B2 A1, A2, A6, A7, A8, 35 tonnes External storage area with impermeable surface and A9 total sealed drainage for storage of waste in fully enclosed, leak-proof trailers containing waste either loose, palletised or in 770l carts 35 tonnes hazardous (7 containers @ 5 tonnes (trailers)) B3 A8 10 tonnes External storage area with impermeable surface and total sealed drainage for storage of waste in fully enclosed, leak-proof trailers containing waste either loose, palletised or in 770l carts 10 tonnes hazardous or non-hazardous (2 containers @ 5 tonnes (trailers/mobile compactor or enclosed leak proof skips) C A2 10 tonnes Internal storage area with impermeable surface and total dedicated bunding for storage of containerised dental wastes 10 tonnes hazardous

D A4 48 tonnes Covered and enclosed external storage area with total impermeable surface and sealed drainage for storage of treatment plant residues. 2 x 24 tonne walking floor trailers

The total storage capacity for wastes received at the facility, exclusive of storage area D which is solely for the storage of residues produced by the treatment plant, is set out in the following table.

Capacity Hazardous waste 330 tonnes Non-hazardous waste 50 tonnes Total 380 tonnes

Storage timescales Waste received onto site for treatment or transfer are processed or transferred within the quickest possible timescales. In some abnormal situations i.e. major plant shutdowns waste timescales may extend those outlined below however during these periods Stericycle endeavor to find alternative outlet routes as far as reasonably practicable. All waste received onto site aim to be stored for no longer than the timescales prescribed below:

Waste Type Normal Operational Storage timescales Infectious clinical waste (contaminated which chemicals) Up to 14 days Infectious clinical waste (not contaminated with chemicals) Up to 14 days Offensive waste or non-infectious waste Up to 14 days Anatomical waste 24 hours (no longer than 72 over weekends) Cytotoxic and cytostatic drugs Up to 6 months Other medicines or drugs (non-haz pharecuiticals) Up to 6 months Dental amalgam Up to 6 months Other chemicals or other wastes Up to 6 months

Storage area schematic

Storage areas – supplementary information Anatomical waste is not refrigerated however our procedures ensure that waste is moved to an incinerator within 24 hours (up to a maximum of 72 hours over weekends). This procedure is also followed for high intervention waste such as Genetically Modified Organism (GMO) or Human Tissue Act (HTA) wastes which are prioritised for transfer to an STERICYCLE incinerator before any other waste types.

Justification for waste quantity in area A Area A has a total storage volume of 300 tonnes as listed in section 7.2. The area will consist of a ground level and a mezzanine level. To calculate the proposed permitted tonnage area

calculations are used with upper weight limits for pallets and carts to ensure that during operation areas operate as visual indicators of permit compliance i.e. once an area is full visually the site is at capacity.

Area available (area A) Total area at ground level ground level Approx. 1,500 m2 Total area at mezzanine level Approx. 550 m2 Total Area Approx. 2,050 m2

Area A will be used for the storage of waste in carts or on pallets interchangeably however pallets are significantly heavier than carts, thus to calculate an upper weight maximum a nominal proportion of 35% has been allocated to pallets with the remaining 65% to waste in carts.

Palletised Waste Waste stored in carts Total area available 750 m2 Total area available 1, 300 m2 Area occupied per Area occupied per 1 m2 1.5 m2 (max) pallet carts (1.26*0.76 = 0.96m2) Estimated area Estimated area available to account 750 m2 / 1.75 m2 available to account Deduct 38m*5m = 180 m2 for inspection isles 430 m2 for walkways and 1,120 m2 and FLT movement FLT movement Estimated number of Estimated number of 290 1,120 pallets carts Estimated maximum Estimated maximum 450 kg 150 kg weight per pallet weight per cart Total estimated Total estimated 130 tonnes 170 tonnes weight for pallets weight for bins

NHS Contingency Situation It should be noted that although Stericycle commit to compliance with the storage arrangements outlined in sections 7.1-7.4 above, it will not be possible to comply with specific elements whilst the NHS is in contingency measures due to the capacity situation within the clinical waste market (correct at the time of writing). Once the NHS is out of contingency measures and the market place has returned to normal operating conditions, Stericycle commit fully to all of the operating techniques outlined in sections 7.1-7.4 above. The operating techniques that cannot be complied with during the contingency period are as follows:  Section 7.1 – Waste in transit will be moved through the facility as quickly as practically possible however the 14 day time limit cannot be met for all trailers  Section 7.3 – With the exception of anatomical waste which will be transferred off site within 24 hours (72 hours if over a weekend) and offensive waste, the 14 day limits for infectious waste cannot be complied with in all circumstances.

8. The treatment process

Steam Disinfection Auger Description The treatment plant will be a Steam Auger with a design throughput of 2 tonnes per hour. The treatment process comprises the following stages:

a. Waste is loaded into the inspection hopper directly from the 770ltr wheeled carts used to transport and store the waste. This is a mechanical process to minimise manual handling of the waste. The waste is then visually inspected in the hopper, with any non-conformant waste identified being removed and reported as specified in the relevant management system procedure. b. After inspection the waste is transferred from the inspection hopper and into the treatment process loading hopper above the shredder. This is a mechanical process to minimise manual handling of the waste. c. The waste then passes directly into a four-shaft shredder designed to a 38mm cut. The shredder is designed to cope with all permitted wastes including small metal items commonly found in the non-medicinal stream. The shredder is maintained under negative pressure, with air from the process being transferred via ducting located above the loading hopper to the pollution control system (see section 9.3). d. The shredded waste is then transferred through the treatment chamber, an enclosed elongated tube containing an auger screw which mechanically moves the waste flock (the shredded waste material is known as flock) through the process. Steam is injected into the chamber at several points along the auger to provide the necessary heat and moisture to disinfect the waste. Temperature monitoring points are located along the auger and at the discharge point. e. An integrated SCADA system monitors and controls the plant temperatures, steam injection rates and auger rotation speed to ensure that the plant is maintained within validated parameters during all hours of operation. The system records and archives all data. f. The shredded, inactivated waste flock is then discharged into a walking floor trailer where it is stored prior to transfer off-site to be recovered for use as a solid recovered fuel or for disposal at a permitted landfill site. The residual steam is transferred to the pollution control system (see section 9.3)

Cold shredding of offensive waste The mechanical treatment (shredding) of offensive waste will take place in a stand alone shredder separate to the above treatment process. The process comprises the following stages:

a. Waste is loaded into the inspection hopper directly from the 770ltr wheeled carts used to transport and store the waste. This is a mechanical process to minimise manual handling of the waste. The waste is then inspected in the hopper, with any

non-conformant waste identified being removed and reported as specified in the relevant management system procedure. b. After inspection the waste is transferred from the inspection hopper and into the treatment process loading hopper above the shredder. This is a mechanical process to minimise manual handling of the waste. c. The waste then passes directly into a shredder designed to reduce the size of the waste and facilitate transportation as per point d. The shredder is maintained under negative pressure, with air from the process being transferred via ducting located above the loading hopper to the pollution control system (see section 9.3). d. The shredded waste is then transferred through an enclosed transportation screw and meets the inactivated flock waste from the treatment process (post auger) before being discharged into a walking floor trailer where it is stored prior to transfer off-site to be recovered for use as a solid recovered fuel or for disposal at a permitted landfill site.

Treatment Plant Process Schematic

Walking Floor Trailer

Walking Floor Trailer

Commissioning and validation Commissioning and validation of the treatment plant will be undertaken to demonstrate the following criteria specified in EPR 5.07 (appropriate measures for commissioning, page 37):

 Infectious waste - the treatment must demonstrate the ability to reduce the number of organisms present in the waste to a level that no additional precautions are needed to protect workers or the public against infection by the waste;  for any clinical waste – renders any syringes, needles or any other equipment or item unusable and no longer in their original shape and form (un-recognisable);

The criteria for anatomical and pharmaceutical wastes are not relevant as the treatment plant will not accept these wastes.

The efficacy of the treatment process is controlled by time and temperature. The waste must reach a certain temperature for a certain length of time to ensure that bacteria within the waste are inactivated to the required level. The required treatment level, as defined in sector guidance note EPR 5.07, is a minimum of STAATT Level III inactivation of the waste.

The treatment temperature is controlled by the injection of steam into the process and monitored at the waste entry point into the auger, the mid-point of the auger and the waste exit point from the auger. The residence time is controlled by the speed of rotation of the auger screw. During commissioning of the treatment plant the optimum temperatures, steam injection volumes and screw rotation speeds will be defined, and will then be subject to external validation by an independent contractor.

The validation tests, to be undertaken by a suitably qualified independent contractor, will be carried out in accordance with the requirements of sector guidance note EPR 5.07. The test method to be employed is that for microbial validation for pre-maceration thermal technologies where spore strip integrity can be guaranteed (appropriate measures on page 51 of EPR 5.07)

After completion of the validation test ongoing routine microbial efficacy tests will be undertaken by Stericycle in accordance with the requirements of sector guidance note EPR 5.07. The routine efficacy test method to be employed is that where monitoring using spore strips is appropriate (appropriate measures on page 62 of EPR 5.07)

The technology to be employed is not novel as Stericycle already operates a steam auger at two other facilities in England. These facility consistently exceeds the STAATT Level III inactivation criteria during both validation tests and routine operations, and produces a flock

residue with no recognisable components. As such the process to be employed demonstrates BAT for the relevant treatment criteria.

9. Techniques for pollution control

Waste pre-acceptance and acceptance The procedures for waste pre-acceptance and acceptance ensure that only those wastes that are permitted for storage and treatment at the facility are received, and that wastes permitted for storage for transfer but not on-site treatment are segregated from those wastes permitted for on-site treatment. This minimises the risk of treatment of non- conformant waste types that could potentially result in adverse emissions (for example chemical, pharmaceutical or anatomical wastes).

Waste storage The waste storage measures in place ensure that all wastes are stored and handled only on impermeable surfaces with sealed drainage. This ensures that in the event of a spillage there is no risk of emission to land or surface waters, and that emissions to foul sewer are controlled.

The waste storage measures in place also ensure that all wastes are stored in secure, fully enclosed, leak-proof containers or on bunds for liquid wastes. This minimises the risk of odour, and pest infestation; and also further reduces the risk of spillage or emissions arising from a spillage.

Air abatement system The treatment plant air abatement system is designed to minimise point source emissions to air, specifically the emission of any infectious bio-aerosols, any compounds with the potential to cause odour, and any volatile organic compounds. The system complies with the measures specified in EPR 5.07 (appropriate measures pages 45-46).

Off-gases from the treatment plant are transferred to the abatement system from two different sources as follows:  Steam and air emissions from the auger are transferred under slight negative pressure to a condenser, which removes the excess moisture from the off-gases by condensation, the resulting condensate being transferred to foul sewer as a trade effluent.  Air is drawn off from the shredder systems under negative pressure and transferred through air ducts to the abatement system.

The remaining auger off-gases present after the condenser are transferred under negative pressure to the abatement process which comprises the following:

 A coalescing vessel containing matrix material to remove the remaining moisture from the gas stream, the resulting moisture being transferred to foul sewer as a trade effluent.  A carbon adsorption filter bed to remove odorous organic compounds and any residual volatile organic compounds

The air drawn off from the shredder system is transferred to a HEPA filter designed to remove any infectious bio-aerosols. The H13 HEPA filter has a 99.95% efficacy rate for the removal of particulates. After the HEPA filter the remaining shredder off-gases are transferred to the coalescing vessel and carbon filter beds with the off-gases from the auger.

The final off-gases are then released to atmosphere via a short stack positioned horizontally out of the rear wall of the facility. All elements of the pollution control system are subject to routine planned preventative maintenance as specified in the Company business management system.

Calibration of magnahelic gauges used to monitor pressure gradients across the system for maintenance of negative pressure; replacement of carbon filter media for the carbon adsorption system, and replacement of the HEPA filters are all scheduled maintenance activities.

There is one further point source emission to air arising from a directly associated activity to the installation, an emission point from the steam-raising boiler flue.

10. Emissions monitoring

Emissions to air Monitoring of emissions to air (emission point A1) will be undertaken during commissioning and validation of the treatment plant, then routinely on annual basis thereafter.

The emissions monitoring conducted will be of microbial emissions to air, surfaces and wastewater as specified in EPR 5.07. The method to be employed will be that using tracer spore suspensions with air, surface and effluent monitoring all being undertaken (appropriate measures pages 66-68). The monitoring will be undertaken by an external independent contractor.

We do not propose to undertake any monitoring of chemical or pharmaceutical emissions as waste pre-acceptance and acceptance measures are in place that fully comply with EPR 5.07.

We do not propose to undertake any monitoring of emissions from emission point A2, which is solely for emissions arising from the gas fired steam raising boiler.

Emissions to sewer Monitoring of emissions to sewer (emission point S1) will be undertaken during commissioning and validation of the treatment plant, then routinely on annual basis thereafter.

The emissions monitoring conducted will be of microbial emissions to air, surfaces and wastewater as specified in EPR 5.07. The method to be employed will be that using tracer spore suspensions with air, surface and effluent monitoring all being undertaken (appropriate measures pages 66-68). The monitoring will be undertaken by an external independent contractor.

Any monitoring required by any condition of the trade effluent discharge consent issued by the sewerage undertaker will also be completed as required.

11. Business Management System

Stericycle operates an integrated environmental, quality and health & safety business management system (BMS). The system is externally certified by BSI to ISO14001, ISO9001 and OHSAS18001. The management system is in operation at all UK Stericycle facilities, including sixteen healthcare waste facilities in England that are already subject to permitting and regulation by the Environment Agency.

An overview of the management system structure is provided in the following table

Section No. Section Name Activities covered 1 System Administration Document control; record-keeping; internal audit; management review; planning including development and maintenance of environmental aspects & legal registers; corrective & preventive action; communication 2 Safety, Health and Compliance related training requirements for all personnel; Compliance Training training records; personal development 3 Sales Sales process including pre-acceptance 4 Purchasing & Finance Purchasing including QESH assessment of suppliers and duty of care audits; finance 5 Incident Management Emergency preparedness & response; incident reporting; contingency planning 6 Operations Operational management for all facilities including waste reception, acceptance, storage, rejection and quarantine; plant operating techniques; disposal of by-products; emissions monitoring; efficacy testing & validation; permit compliance and reporting; energy efficiency; raw materials; 7 Engineering & Planned preventative maintenance for all facilities; plant maintenance engineering requirements; process change control 8 Transport All transport service operations 9 Health & Safety All health & safety requirements including risk assessment

12. Raw materials

The site does not use any raw materials in significant quantities with the exception of natural gas used to fire the steam-raising boiler for the treatment plant. Other raw materials that may be stored in quantities in excess of 200 litres are listed in the following table. Raw materials stored in smaller quantities are used on site for a range of general domestic purposes (for example kitchen cleaning products).

Activity Description of raw Maximum Annual How material used material and composition amount on throughput material site A3 for A1, Natural gas n/a Approx. 3000 To fire steam raising A6 MWh boiler for treatment plant A3 & A5 Water n/a Approx. 7000 m3 To supply the boiler (indirect and the container for all washer activities) A1, A6, A7 Activated carbon granules 400 kg 400 kg Carbon adsorption filter unit A3 for A1, Boiler water treatment 100 litres 300 litres Dosed to boiler water A6 chemical to reduce hardness / scaling All Detergents 1,200 litres 4,000 litres Use for container activities washing and cleaning of site surfaces All Hydraulic and silicone 1000 litres 2,500 litres Used for general site activities based oils maintenance

All liquid raw materials will be stored appropriately on bunds, and COSHH and MSDS sheets will be obtained and retained on file for the specific products to be used. The site emergency response plan will also list the quantity and location of chemicals and oils held on site.

13. Resource efficiency and climate change

Energy efficiency As the site is a new facility the first measure for improving energy efficiency will be the inclusion of energy efficient plant equipment at the design stage and its subsequent installation. In order to do this the basic energy requirements for the new facility have been benchmarked against the most energy efficient treatment and transfer facility already in operation by Stericycle. The basic energy requirements for the facility are defined in the following table.

Energy source Energy consumption (primary energy) % of total Gas 210 kWh per tonne waste treated 51.2% Electricity 200 kWh per tonne waste treated 48.8%

After commencement of operations the facility will be subject to Stericycle’s standard process for improving energy efficiency. The facility will be required to review energy efficiency on an annual basis by comparing monthly energy usage data for the preceding twelve months against the same data for the twelve months preceding that. The site will also be included in any improvements identified through ESOS.

The facility must then identify any measures for further improvement and record them on a documented energy efficiency plan. The plan and usage data are then subject to review on a periodic basis.

Other than any incremental improvements brought about by this process we do not anticipate any other changes to the energy used by the activities.

Climate change The site has not entered into a climate change levy agreement, and there are currently no proposals for an agreement to be entered into. The impact that the site activities have on climate change is monitored through the energy efficiency improvement process as described above. To enable analysis of trends data on gas and electricity usage is converted into corresponding figures for carbon and greenhouse gas emissions.

Justification for use of raw materials The proposed treatment plant design has been selected as it is a new version of the most energy efficient treatment plant already operated by Stericycle. Stericycle considers that disinfection treatment by heat has been proven to be the most reliable system for

consistently achieving the required level of bacterial inactivation of infectious wastes suitable for alternative treatment.

As an operator of three different designs of heat disinfection treatment process the company has been able to identify which process is the most energy efficient. This has been confirmed as the steam auger system to be installed at the Tamworth facility.

Gas is considered to be the best material to use to fire the boiler as it achieves more efficient combustion than other fossil fuels with corresponding lower carbon emissions (and emission of other pollutants, specifically NOx and particulate) per unit of energy required. The boiler will be of a modern high efficiency design with self modulating burners designed to optimise combustion. The maximum thermal rating of the boiler is 800 kilowatts.

Water use is minimised as far as possible, however it is not possible to recycle steam from the treatment process and steam injection volumes cannot be reduced below that which is necessary to maintain the required treatment temperatures.

Electricity use is essential to drive the treatment plant shredders, conveyors and compactors, and to provide lighting for the facility. There is no alternative to this however any incremental improvements possible will be made using the energy efficiency process described above.

Carbon used for the carbon adsorption filter system is a bespoke product designed for use in air abatement systems.

All other raw materials used are off the shelf products used for cleaning or maintenance purposes.

Avoidance of waste production The treated waste residue, or flock and the shredded offensive waste, arising from the treatment plant is suitable for recovery as a solid recovered fuel. Stericycle has demonstrated the viability of this process with full recovery of flock material in effect at a number of other company facilities in the UK and .

The intention is to implement comparable processes for the flock produced at the Tamworth facility with immediate effect from the start of operation.

Use of raw materials at the facility will be minimised from the commencement of operations therefore further efforts to avoid the production of waste will be focussed on customer waste production and container usage. The company management system includes objectives and targets relating to this, specifically:

 A target for to landfill (maintaining 95% by end of 2019)  A target for the reduction in the amount of virgin plastic purchased and used

A range of initiatives are underway to achieve these objectives, including the following:

 Diversion of treatment residues (flock) from landfill to recovery as a solid recovered fuel.  Diversion of offensive healthcare waste from landfill by mechanically processing and combining with the flock for use as a solid recovered fuel.  Diversion of healthcare waste metals from or treatment to treatment and options  Promoting the use of re-usable sharps containers, including the installation of a second re-usable sharps container washing system at a Stericycle facility in SE England to provide additional capacity to the existing facility in Leeds.  Promoting the use of cardboard single use containers in place of plastic single use containers.

Progress against objectives and targets is tracked through management system reviews, audits and KPI monitoring.

14. Environmental Risk Assessment and Options appraisal

An environmental risk assessment for the facility is enclosed as an appendix to this report. Also enclosed is an H1 assessment and options appraisal providing background information and a justification for the technology chosen for the treatment plant at the Tamworth facility.

The three alternative treatment options selected for appraisal were:  Steam auger disinfection plant  Hot oil auger disinfection plant  Autoclave disinfection plant

The assessment defined the steam auger technology as being the best available technique for the following reasons:

 Autoclave technology was screened out as it uses more raw materials and energy (water, electricity and gas) than the other two options per unit of waste processed.  Hot oil and steam auger technologies have similar impacts in most areas, the key differences being that hot oil auger processes use less electricity but use more raw materials in the form of treatment process oil.  Operational efficacy was therefore used to make the final decision between the two auger technologies. The steam auger technology has achieved a 100% efficacy test pass rate over a number of years where it is already in operation, whereas the hot oil auger technology, although consistently achieving the required pass rates has not achieved a 100% pass rate at all sites where it is in operation.

15. Combustible Wastes & Fire Prevention Plan

Although the site stores theoretically combustible waste streams, the Environmental Risk assessment deems the fire risk on site to be very low and historically Stericycle have not had any fires occur at treatment plant facilities or transfer stations. Incident response plans and emergency procedures will be in place at the facility in line with Stericycle’s EMS requirements. All of the waste streams are containerized whilst in storage and do not constitute the definition of waste in containers or waste in piles as outlined within the Fire Prevention Plan (FPP) Guidance. The risk of self-combustion is very low and the clinical waste sector does not clearly fall within one of the sectors listed within who FPP’s apply to therefore Stericycle do not intend on creating a RPP.

16. Site Condition

A desktop site condition report is enclosed as an appendix to this report. Stericycle is undertaking further site investigation works at the facility and a further report providing baseline data will be submitted in support of this application after completion of the works.

The report will provide baseline data on the following:

 Analysis of soil samples taken from five boreholes located on a grid pattern covering the entire facility  Analysis includes Asbestos Screening, pH, TOC, Total Sulphate, Sulphide, Monohydric Phenols, Total Cyanide, W/S Boron, As, Cr, Cu, Pb, Se, Zn, Cd, Hg, Ni, Speciated PAH, TPH1 (C10 – C40) & TPH CWG.  Logging will take place in accordance with BS10175:2011 Investigation of Potentially Contaminated Sites and BS5930:1999+A2 2010 Code of Practice for Site Investigations.  Borehole core data on the sub-surface strata, and supporting evidence from visual and olfactory inspection.

The site investigation works are scheduled for completion before the end of August 2019 and as such we would envisage provision of the resulting report to the Environment Agency before the end of September 2019.

PART C – Appendices

17. Appendix List

Document Ref Document 09 Site Condition Report (Phase I Survey) 10 ERA Tamworth July 2019 14 H1 Environmental Assessment