Marine Harvest Ltd. Kyleakin Salmon Feed Manufacturing Facility Permit Application Application Number PPC/A/1163789

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 PPD Page no: 1 of 48

CONTENTS CONTENTS ...... 1 1 NON TECHNICAL SUMMARY OF DETERMINATION...... 2 2 EXTERNAL CONSULTATION AND SEPA’S RESPONSE ...... 5 3 ADMINISTRATIVE DETERMINATIONS...... 8 4 INTRODUCTION AND BACKGROUND ...... 8 4.1 Historical Background to the activity and application ...... 8 4.2 Description of activity...... 9 4.3 Guidance/directions issued to SEPA by the Scottish Ministers under Reg.60 or 61...... 10 4.4 Identification of important and sensitive receptors...... 10 5 KEY ENVIRONMENTAL ISSUES...... 11 5.1 Summary of significant environmental impacts ...... 11 5.2 Point Sources to Air...... 11 5.3 Point Source Emissions to Surface Water and Sewer...... 14 5.4 Point Source Emissions to Groundwater...... 17 5.5 Fugitive Emissions to Air ...... 17 5.6 Fugitive Emissions to Water ...... 18 5.7 Odour...... 19 5.8 Management...... 23 5.9 Raw Materials...... 23 5.10 Raw Materials Selection ...... 24 5.11 Waste Minimisation Requirements ...... 24 5.12 Water Use ...... 24 5.13 Waste Handling...... 25 5.14 Waste Recovery or Disposal ...... 25 5.15 Energy...... 26 5.16 Accidents and their Consequences...... 26 5.17 Noise...... 26 5.18 Monitoring ...... 28 5.19 Closure ...... 29 5.20 Site Condition Report (and where relevant the baseline report) ...... 30 5.21 Consideration of BAT ...... 30 6 OTHER LEGISLATION CONSIDERED...... 31 7 ENVIRONMENTAL IMPACT ASSESSMENT AND COMAH ...... 32 8 DETAILS OF PERMIT ...... 33 9 EMISSION LIMIT VALUES OR EQUIVALENT TECHNICAL PARAMETERS/ MEASURES...... 35 10 PEER REVIEW ...... Error! Bookmark not defined. 11 FINAL DETERMINATION...... 39 12 REFERENCES AND GUIDANCE ...... 39 APPENDIX 1. SECTION 5.17 – Noise. SEPA observations recorded under determination. APPENDIX 2. SECTION 5.21 – Consideration of BAT APPENDIX 3. SECTION 5.20 - Site Condition. IED-TG-02 Checklist; IED-TG-42 Proforma 1. Permit (Application) Number: PPC_A_1163789 Applicant: Marine Harvest (Scotland) Ltd

1 NON TECHNICAL SUMMARY OF DETERMINATION

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

Will the draft determination be subject to public consultation? Yes

The Marine Harvest (Scotland) Ltd manufacturing facility at the site of the former Allt-An-Avaig Quarry at Kyleakin, Isle of Skye is designed to receive and process wet and dry bulk raw materials to produce salmon feed in dried pellet form. The facility includes a new pier and slipway which will enable most of the raw materials and final product pellet to be transported to and from the site by sea. The site’s coastal location in the north west of Scotland will enable access and transport links by ship, offsetting a proportion of road use, to existing Marine Harvest salmon farms and to overseas customers.

Proposed Installation Activities

The Activities carried out at the Stationary Technical Unit are the treating and processing of animal and vegetable matter being an activity falling within paragraph d(iii) of Part A of Section 6.8 of Schedule 1 of the regulations. The manufacturing process involves the production of dried pelleted salmon feed at a plant with production capacity of up to 170,000 tonnes per year.

The manufacturing process is depicted on the simple schematic diagram below, and involves two separate process lines and includes a number of clearly identifiable steps such as: receipt and transfer of raw materials to storage; dosing / weighing / mixing; fine grinding and control sifting; mixing; extrusion; drying; pre-cooling and coating; and final storage and bagging. A complete process description can be found in Section 3.0 of the Supporting Document to the application.

Figure 1: Simple Process Schematic Permit (Application) Number: PPC_A_1163789 Applicant: Marine Harvest (Scotland) Ltd

The facility also requires a number of Directly Associated Activities to be carried out on the same site including combustion (drying of material and production of steam) generation, effluent treatment and storage of raw materials etc. The steam boiler supplies thermal energy for the extrusion and drying processes and is rated at 7.9 MW net rated thermal input. Dryers serving both Lines 1 and 2, have a combined total of 9.75 MW net rated thermal input. The facility includes a bulk fuel storage facility which will provide liquefied natural gas (LNG) to fuel the steam boiler and dryers.

The solid raw materials consist of vegetable meal, wheat and grain, and fishmeal. These deliveries are received by vessel at the pier and extracted under vacuum via enclosed conveyors to the relevant bulk silos. The liquid materials are vegetable and fish oils. These are pumped from the vessel to an appropriate liquid storage silo which are located in an impermeable bunded area.

Water is used in the milling and blending process with a measured quantity of the different raw materials to produce the desired blended meal that is subsequently extruded to form the feed pellets that are then dried in a hot air stream. The spent air undergoes treatment through abatement systems, being routed through either bag filters or high efficiency cyclones before undergoing odour treatment in a biological treatment unit (‘biofilter’), with the treatment configuration dependant on the source zone of the spent air. Wastewaters from the milling and blending processes are treated at an on-site treatment plant before discharge to the sea via a long sea outfall. Surface water from roofs and hard standing is collected by a separate piped system that is conveyed to two SUDs treatment areas (east and west ponds) prior to discharge to the sea. Outdoor work areas, including the piers, where there is a risk of oil spillage are drained via suitable oil-water separators.

The process is capable of operating on a 24-hour, 7 days a week basis, with maintenance and cleaning operations taking place during periods of planned shut-down.

Application Determination

An application from Marine Harvest (Scotland) Ltd was received by the Scottish Environment Protection Agency (SEPA) on 27/11/2017, for a permit under the Pollution Prevention and Control (Scotland) Regulations 2012 (the Regulations) to operate a Part A Installation for:

“the treating and processing of animal and vegetable matter at the Marine Harvest Kyleakin Salmon Feed Plant, located at Kyleakin, Isle of Skye, IV41 8PQ being an activity falling within paragraph d(iii) of Part A of Section 6.8 of Schedule 1 of the regulations.”

The application was received in the statutory manner on the 27/11/2017. The application was duly made on 12/12/2017. Clarification was sought from the operator on several areas to allow fuller understanding of the activities carried out on site and so ensure that there was no significant impact on the local environment and on human health, that Best Available Techniques were to be employed and that appropriate control could be included within any Permit granted. Sufficient information was supplied to enable SEPA to fully determine the application and assess the impact of the installation on the environment.

Prior to the submission of the PPC application, SEPA had been formally consulted on an environmental impact assessment (EIA) conducted as part of an application to the local planning authority for planning permission for “The erection of a salmon feed manufacturing plant including an extension to the existing pier - Final ES”. This included a detailed review of this Environmental Statement (ES) and extensive discussions with applicant, with a detailed response compiled.

The response included key aspects significant to the determination of a future PPC permit required for the manufacturing plant. At key points during the pre-application dialogue, SEPA advised the applicant of the additional information requirements towards the intended PPC permit application, to ensure the application would be sufficiently supported with necessary assessment reports and information.

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Also within the pre-application period, SEPA had been formally consulted on the Marine Licence application for site construction and capital dredging developments at the coastal foreshore location.

Environmental Setting and Potential Impact

The proposed Kyleakin salmon feed manufacturing plant is located on the coastal foreshore at the former Allt-Anavaig Quarry, on the outskirts of Kyleakin on the Isle of Skye. The site is centred on National Grid Reference (NGR): 173747, 826423. The development area is bounded by the Inner Sound waterbody to the north. The A87 road runs to the south of the development area, and provides the only road access to the Scottish mainland via the Skye Bridge. Land use surrounding the development area is predominantly open agricultural land with no significant commercial / industrial activity. Kyleakin is the largest settlement to the east with a ferry terminal. The town of Kyle of Lochalsh is on the mainland over the Skye Bridge to the east-north-east. Location plans are given in Appendix 1 of the application supporting document.

The potential significant impacts from the proposed installation were identified by the applicant to include the following aspects: emissions to air, odour, emissions to water and noise.

Noise and odour are the aspects of the manufacturing process considered most likely to have potential impacts on people, and assessments were undertaken to include nearby occupied buildings. Sensitive environments and habitats on land were assessed for potential impacts of emissions to air from the installation. Several potentially sensitive ecological receptors have been identified within the specified screening distances from the activity: European designated sites (i.e. Special Areas of Conservation SACs and Special Protection Areas SPAs) within 10km; Sites of Special Scientific Interest (SSSIs) (designated at a national level) within 10km; Local nature sites (National Nature Reserves (NNRs), Local Nature Reserves (LNRs), Ancient Woodlands, Local Wildlife Sites) within 2km. See section 5.2 below for further details.

All process water effluent will be treated in an effluent treatment plant before being discharged from a long sea outfall. The discharge of treated process water into coastal waters was assessed for its potential impact and to enable the derivation of emission limit values to be protective of the marine environment. Surface water runoff will be kept separate on site, and is to be treated using a purpose built sustainable urban drainage system (SUDS). New concrete floors, hardstanding and bunds will be used to contain any spillage and prevent contaminating the ground/ground water.

The PPC Regulations require that the process operator adopt the Best Available Technique (BAT) in order to prevent, and where that is not practicable to reduce emissions and the impact on the environment as a whole. The application and environmental statement (ES) were compiled with regard to the European Commission’s BAT (Best Available Techniques) Reference Document (BREF 0806 Food Drink and Milk (FDM) Industries) August 2006 and the current (first) draft of the revised FDM BREF issued in January 2017. Relevant provisions in the BREF relate to the selection of plant, control of emissions to atmosphere, the marine environment, process monitoring, resource use, staff training and planned preventative maintenance.

A commitment has been stated that the process will utilise up-to-date equipment and be adequately supervised and operated by competent personnel. The operator intends to implement their existing certified environmental management system (under ISO 14001) to include all process operations at the installation. This will include a documented programme of planned preventative maintenance.

Overall, and on consideration of each of the identified aspects, no potential for significant pollution has been identified and the measures proposed by the applicant have been determined to represent BAT. Controls contained within the Permit are designed to monitor the activities undertaken and ensure that this assessment remains the case

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Final Determination

The permit produced by SEPA has been developed utilising relevant guidance documents. Due regard has been given to issues raised from the SEPA assessment team, representations where received from the consultation process and representations received from the Operator. All deviations or additions from the standard Part A Template have been highlighted and justified in Section 8 below.

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.  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.

Glossary of terms

BAT - Best Available Techniques BATC - BAT Conclusions CO - Coordinating Officer DAF - Dissolved Air Flotation EIA - Environmental Impact Assessment ELV - Emission Limit Value EQS - Environmental Quality Standard ES - Environmental Statement (under EIA) ETP - Effluent Treatment Plant FDM BREF - Food Drink and Milk Industries BAT (Best Available Techniques) Reference Document FOG - Fats Oils and Grease LNG - Liquefied Natural Gas MCPD - Medium Combustion Plant Directive NNRs - National Nature Reserves LNRs - Local Nature Reserves OMP - Odour Management Plan PEC - Predicted Environmental Concentration SAC - Special Areas of Conservation SEPA - Scottish Environment Protection Agency SPA - Special Protection Areas SSSI - Sites of Special Scientific Interest SUDS - Sustainable Urban Drainage System

2 EXTERNAL CONSULTATION AND SEPA’S RESPONSE

Is Public Consultation Required - Yes

Advertisements Check: Date Compliance with advertising requirements

Edinburgh Gazette 24/01/2018 Compliant

West Highland Free Press 25/01/2018 Compliant

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Officer checking advert: SEPA

No. of responses received: Three.

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

See details under the headers below for the three respondents: Food Standards Agency; NHS Highland Health Board; Scottish Natural Heritage.

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: Response letter received from FSS dated 18/01/18. No actions required, as FFS consider that there are no unacceptable effects on the human food chain from this installation, provided the applicant complies with permit, relevant guidance etc.

NHS Highland Health Board: Response letter received from NHS Highland, Director of Public Health & Health Policy, dated 18/01/18. The response stated that “from the documentation submitted and within the time constraints for review, it would appear that the proposed activities at the site are unlikely to pose a significant health impact for neighbouring communities as long as all the requisite mitigating and control measures are implemented as described. It would appear that the most likely potential impacts are that of odour and noise although the planned control measures to reduce any possible impact are noted”. SEPA concurs on this and no additional permit conditions to those included are deemed necessary.

The respondent also drew attention to the procedures to be implemented for responding to complaints from external parties in relation to odour and noise impacts, and advised that they expected further investigation and mitigation if adverse impacts were to be identified. SEPA can clarify that in response to any incident (noise and odour included) the permit requires notification to SEPA without delay by telephone and in writing by the next working day, with a follow-up investigation report to be provided within 14 days of a reportable incident. SEPA will also carry out its own investigation into complaints or notified incidents as required.

Lastly, the respondent drew attention to accident potential as well occupational health risks to workers. The latter concern is outside of SEPAs legislative remit however SEPA does have oversight with respect to accident potential; under PPC in order to prevent and mitigate accidents to the environment and under the COMAH Regulations (prevention of major accidents).

NHS Highland comments have been fully considered by SEPA as part of the permit determination.

The Highland Council Local Auth: No response received.

Scottish Water: NA

Health and Safety Executive: No response received.

Scottish Natural Heritage (PPC Regs consultation): Response letter received from SNH dated 08/02/2018, and enclosure, which was requested to be treated as a ‘third party representation’.

The advice summary is as follows: “The marine discharge from the plant is capable of affecting the flame shell bed feature of Lochs Duich, Long and Alsh Marine Protected Area [MPA]. However providing the effluent is treated

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sufficiently to achieve Environmental Quality Standards at the edge of the flame shell bed then any effects are likely to be insignificant.”

SNH commented on the Inner Hebrides and the Minches candidate Special Area of Conservation (cSAC), selected for its harbour porpoise. A Habitats Regulations Appraisal (HRA) had been undertaken under the Marine Licence application. The HRA concluded that: ‘In view of the relatively low and highly localised discharge volumes in question and given the applicant’s commitment to ensure compliance with Scottish EQS for transitional waterbodies, the overall likelihood of adverse effects on marine mammals, or the ability of the habitat to support marine (prey) species from changes to marine water quality is considered to be very low’. This issue was further addressed in the SEPA ecology specialist’s review, indicating that for harbour porpoise, neither the porpoise itself nor its habitat are sensitive to nitrogen deposition, therefore no critical load applies.

SNH commented on Lochs Duich, Long and Alsh Special Area of Conservation (SAC), the boundary of which is approximately 750m from the boundary of the development site. SNH advised that: “While pollutants from construction or operation of the development could affect the SAC reefs, this is less likely than effects on the MPA, due to the greater distance and dilution. Mitigation designed to protect the flame shell feature of the MPA would also protect the reefs within the SAC.”

The specialist assessments carried out under the Environmental Impact Assessment (planning regulation) and under the Marine Licence determination, have provided the technical assessments needed to be able to show that EQS can be achieved. SEPA specialists’ review of the dilution assessment and the chemistry assessments underpinned the derivation of the ELVs set for the key pollutants in order that marine EQSs would not be breached. See Section 5.3 for full details.

Therefore SNH’s comments and recommendation for managing water effluent under the PPC permit requirements have been taken account of by SEPA during the permit determination.

Finally, SNH commented on the likely effects of the air emissions on SACs and SSSIs within10km of the development. SNH considered that the relevant designated sites had been identified, at the appropriate distances, and that the assessment had shown there will be no likely significant effects for any of the protected areas or features. See Section 5.2 for details.

Therefore SNH’s comments for air emissions under the PPC permit requirements have been taken account of by SEPA during the permit determination.

Kyle Harbour Authority: No response received.

Discretionary Consultation - No

Enhanced SEPA public consultation - No

‘Off-site’ Consultation - No

Transboundary 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

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 FINAL Page no: 7 of 48 Permit (Application) Number: PPC_A_1163789 Applicant: Marine Harvest (Scotland) Ltd consultation took place, the number of representations received and SEPA’s response to these are outlined below.

Date SEPA notified applicant of draft determination 23 May 2018

Date draft determination placed on SEPA’s Website 30 May 2018

Details of any other ‘appropriate means’ used to advertise N/A the draft

Date public consultation on draft permit opened 30 May 2018

Date public consultation on draft permit consultation 27 June 2018 closed

Number of representations received to the consultation 0

Date final determination placed on the SEPA’s Website 13 July 2018

Summary of responses and how they were taken into account during the determination: N/A

3 ADMINISTRATIVE DETERMINATIONS

Determination of the Schedule 1 activity

As detailed in the application

Determination of the stationary technical unit to be permitted:

As detailed in the application

Determination of directly associated activities:

As detailed in the application

Determination of ‘site boundary’

As detailed in the application

4 INTRODUCTION AND BACKGROUND

4.1 Historical Background to the activity and application

The Marine Harvest (Scotland) Ltd manufacturing facility is a new-build plant, designed to receive and process wet and dry bulk raw materials to produce salmon feed in dried pellet form. It is located at the site of the former Allt-An-Avaig Quarry at Kyleakin, Isle of Skye.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 FINAL Page no: 8 of 48 Permit (Application) Number: PPC_A_1163789 Applicant: Marine Harvest (Scotland) Ltd

The application was received in the statutory manner on the 27/11/2017 and was duly made on 12/12/2017. Clarification was sought from the operator on specific points on the activities carried out on site. Sufficient information was then supplied to enable SEPA to fully determine the application and assess the impact of the installation on the environment.

In the period prior to the submission of the PPC application, SEPA had been formally consulted on an Environmental Impact Assessment (EIA) conducted as part of an application to the local planning authority for planning permission for “The erection of a salmon feed manufacturing plant including an extension to the existing pier - Final ES”. This included a review of the EIA’s Environmental Statement (ES) and included extensive discussions with the applicant, resulting in the compilation of a detailed response. The response included key aspects significant to the determination of a future PPC permit required for the intended manufacturing plant. Throughout, SEPA noted the additional information requirements the applicant would need to supply towards the PPC permit application and its initial duly made check process.

The preparation of the planning response included a site visit to the former quarry at Allt-An- Avaig, Kyleakin, followed by detailed review of the sections of the ES and supporting assessments dealing with air quality, odour abatement, surface water drainage systems including oily water interceptors, process effluent water treatment and marine discharge, and noise. The review included input from a number of subject specialists within SEPA. Key aspects significant to the determination of a future PPC permit required for the activity were tracked. A key outcome from this stage concerned the water discharge, such that the treated process effluent would be required to discharge to marine receiving waters rather than to a freshwater burn as originally intended. The planning response reflected this outcome, and modifications were made to accommodate a long sea outfall from the effluent treatment plant, with details further developed during the PPC pre-application period.

Also within the pre-application period, SEPA had been formally consulted on the Marine Licence application for site construction and capital dredging development at the coastal foreshore location. Specialist support was obtained internally to assess the ocean modelling and chemistry (marine) aspects of the licence application documents. Specialists in both these aspects were satisfied that appropriate methods and guidance had been followed. SEPA confirmed that the applicant’s submitted methodology on establishing the extent of the long sea outfall was acceptable, but expressed the view that under PPC, details of the two-stage water effluent treatment process needed to be supplied to determine the ability of the chosen process to a) meet BAT and b) achieve water quality standards set in order to protect the marine environment. This was subsequently determined under the PPC application process.

The proposed development is subject to the COMAH regulations and has been designated as an Upper Tier Establishment. As such a pre-construction Safety Report was submitted and which is under assessment by the COMAH Competent Authority (HSE and SEPA), at the time of this PPC determination.

4.2 Description of activity

An overall process description is provided in Section 3.0 of the Supporting Document to the permit application (“the Supporting Document”). This description points to site plans and diagrams that show the process details, and to appendices describing functions and operations of specific items of equipment. A simple schematic diagram is given in Section 2.3.2, (copied in Figure 1. above). The description of the Stationary Technical Unit and Directly Associated Activities given in the opening section (Schedule 1) of the PPC permit was produced from this material.

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A contents list of site plans and drawings is given in Section 2.0 of the Supporting Document. The site plans and drawings are contained within Appendix 1. It is noted that certain plans are still to be finalised in their “as built” layout, as construction is still underway at time of writing. Within the permit, site plans showing the location and the installation “red line” boundary are essential components of the process description, and have been delineated based on the applicant’s submissions to enable identification of emission points subject to permit conditions. Other aspects that were deemed significant to the determination process have been clarified with the operator, these further details were included as addendums to the application and decisions surrounding the appropriateness of technique and level of control required within the Permit based on this confirmed understanding.

The Activities carried out at the Stationary Technical Unit are the treating and processing of animal and vegetable matter being an activity falling within paragraph d(iii) of Part A of Section 6.8 of Schedule 1 of the regulations. The manufacturing process is the production of dried pelleted salmon feed at a plant with production capacity of up to 170,000 tonnes per year.

The manufacturing process involves a number of steps: dosing / weighing / mixing; fine grinding and control sifting; mixing; extrusion; drying; pre-cooling and coating; and final storage and bagging. There are a number of Directly Associated Activities including a steam boiler, effluent treatment plant and storage areas for raw materials. The facility requires combustion plant in the form of a steam boiler, rated at 7.9 MW (net rated thermal input), and drying capacity, rated at 9.75 MW (net rated thermal input) The facility includes a bulk fuel storage facility which will provide liquefied natural gas (LNG) to fuel the steam boiler.

Water is used in the milling and blending process with a measured quantity of the different raw materials to produce the desired blended meal that is subsequently extruded to form the feed pellets that are then dried in a hot air stream. Wastewaters from these processes are treated at an on-site treatment plant before discharge to the sea via a long sea outfall. Surface water from roofs and hard standing is collected by a separate piped system that is conveyed to two SUDs treatment areas (east and west ponds) prior to discharge to the sea. Outdoor work areas, including the piers, where there is a risk of oil spillage are drained via suitable oil-water separators.

The process is capable of operating on a 24-hour, 7 days a week basis, with maintenance and cleaning operations taking place during periods of planned shut-down.

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

4.4 Identification of important and sensitive receptors

The salmon feed manufacturing plant is located on the coastal foreshore on the outskirts of Kyleakin on the Isle of Skye. The site is centred on NGR: 173747, 826423. The development area is bounded by the Inner Sound waterbody to the north and the A87 trunk road to the south. Land use surrounding the development area is predominantly open agricultural land with no significant commercial or industrial activity. Kyleakin is the largest settlement to the east. The town of Kyle of Lochalsh is on the mainland over the Skye Bridge to the east-north-east. Location plans are given in Appendix 1 of the application supporting document.

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The potential significant impacts from the proposed installation were identified by the applicant to include the following aspects: emissions to air, odour, emissions to water and noise.

Noise and odour are the aspects of the manufacturing process considered to have potential impacts on people. Assessments of odour were undertaken, accounting for twenty potentially sensitive locations in the vicinity of the manufacturing plant, comprising residential properties or buildings occupied for business or leisure uses. See section 5.2 below for further details. Assessments of noise were undertaken at several potentially sensitive locations including representative proxy locations where access to property could not be gained. See section 5.17 below for further details

Sensitive environments and land habitats were assessed for potential impacts of emissions to air. Several potentially sensitive ecological receptors have been identified within the specified screening distances from the activity: European designated sites within 10km; Sites of Special Scientific Interest (SSSIs) (designated at a national level) within 10km; Local nature sites (National Nature Reserves (NNRs), Local Nature Reserves (LNRs), Ancient Woodlands, Local Wildlife Sites) within 2km. See section 5.2 below for further details.

The waterbodies of the Inner Sound and Loch Alsh are an important water resource and support a number of European and nationally designated conservation areas such as SACs, SPAs and SSSIs. The proposed SAC for harbour porpoise encompasses the Inner Sound waterbody. The waterbodies surrounding the development and adjacent to it, have an overall status of ‘Good’ and form part of the migratory corridor for diadromous fish species including Atlantic salmon, sea trout and European eel.

The discharge of treated process water into coastal waters was assessed for its potential impact and to enable the derivation of emission limit values to be protective of the marine environment. See section 5.3 below for further details.

5 KEY ENVIRONMENTAL ISSUES

5.1 Summary of significant environmental impacts

Potential significant impacts are considered to be:

- Emissions to Air - Odour - Emissions to Water - Noise

Issues are described in greater detail in the relevant Sections below.

5.2 Point Sources to Air

The manufacturing plant will introduce two new point source emissions to air. The first comprises combustion gas emissions from a natural gas fired boiler utilised to generate steam, and the second comprises spent process air that has been dried before being passed through either a dust filter or cyclone, and then finally an odour abatement bio filter system. Both are discharged through separate process stacks on site. While the second emission point is briefly discussed here, much greater detail is provided when discussing Odour and is dealt with at section 5.7.

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The location of the steam boiler stack point source emission is identified as point A2 in Figure 5 in Appendix 1 of the Supporting Document, and on the Site Plan in the permit.

Information relevant to the point source emissions to air from the boiler stack is provided in Section 6.0 of the Supporting Document to the permit application. This is supported by technical material embedded in Appendix 2, within EIA Chapter 2 Project Description and Chapter 6 Air Quality Technical Appendix (including Stack Height Assessment) 01 Dec 2016.

The air quality technical assessments assumed a boiler stack height of 19 metres, and modelled the dispersion of combustion gases from the burning of LNG fuel using generic boiler combustion details. The selection of the specific boiler to be installed at the Kyleakin facility was stated only later in the application process, and was confirmed as the COCHRAN ST37 package steam boiler. Specification details were provided by the applicant in response to informal Information Requests by SEPA during the application determination process. It should be noted that details had also been requested in other communications during the pre-application stage, for operational information for the correct assessment of impacts to air.

The applicant has re-confirmed their intention to install a 19 metre air stack to the boiler exhaust for dispersion of air emissions as modelled in the application supporting documents. This is an enhanced stack height to a stack of 8 metres height that is supplied as standard with this grade of boiler.

The ST37 boiler at the manufacturing plant is stated to run at a net rated thermal input of 7900KW (7.9 MW), burning a Natural Gas (LNG) fuel of a calorific value of 34,898kj/m3. Under the MCPD schedules, the selection of LNG fuel at the plant excludes the requirement for air emissions monitoring of particulate matter and sulphur dioxides. The applicant has underlined their selection of LNG as a “clean” fuel for combustion to avoid taint in the final product impinged by the hot air flow at the dryers. The applicant has stated in Section 6.8 that the boiler and dryers are fitted with low-NOx burners designed to meet the 3 nitrogen oxide (NOx) emissions limit of 100 mg/m at reference conditions. The MCPD requirement for the stated boiler would be three-yearly monitoring for NOx, and a permit ELV has been set for this interval and the 100 mg/m3 limit. The applicant has stated they will monitor annually for this parameter to ensure optimal combustion performance.

With respect to the dryers employed at the installation it should be noted that MCPD is deemed not to apply as they are considered ‘combustion plants in which the gaseous products of combustion are used for the direct heating, drying or any other treatment of objects or materials,’ The process emission is discussed further with respect to potential odour release under Section 5.7.

The air quality impact assessment in Chapter 6 considered the potential impacts associated with the emission and dispersion of combustion gases and odour. On the boiler emissions, the potential impacts were determined for the following aspects:

 the potential impact on human health due to emissions of NOx in the form of NO2; and CO;  the potential impact on vegetation and ecosystems due to emissions of NOx;

Twenty potentially sensitive locations were identified in the vicinity of the manufacturing plant, as detailed in Table 2.5 of Chapter 6 and shown on the plan at Figure 6.1. Pollutant concentrations were predicted by the model for these specific locations. These are mainly residential receptors however also include places of business or recreation.

The assessment was carried out using an atmospheric dispersion modelling package. A standard atmospheric dispersion model ADMS version 5.1 was used to model releases of the identified substances.

The model concluded that the impacts of the key pollutants, e.g. nitrogen oxides, for both short and long term releases, on human health as well as on ecological receptors were low.

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SEPA reviewed the air quality impact assessment provided which included dialogue with the applicant in order to confirm the validity of the modelling process undertaken including the justification of any assumptions made as well conclusions reached. This further involved ensuring adequate sensitivity testing had taken place.

The conclusion was that risks to human health (people) were low, on the basis that the modelled maximum concentration at receptors represented less than 1% of the annual mean NO2 UK air quality standard (long term) and represented less than 10% of the maximum hourly mean UK air quality standard (short term).

The ecological review found that the emissions were low enough to screen out any further assessment requirements, on the basis of the following findings of the modelling work: Ecological Receptors: CRITICAL LEVELS maximum concentration compared to annual mean expressed as % EALs : <1% at European designated habitat sites, SAC = 4.77%, (total Predicted Environmental Concentration PEC (which includes background) is only 10.9% of the EAL), “The maximum contribution from the boiler plant to the daily mean Oxides of Nitrogen EAL at the identified local nature sites is 40.0%. As this is less than 100% of the EAL the contribution is considered to be not significant.”

CRITICAL LOADS contribution to acid deposition at all of the existing European designated habitat sites is less than 1%. The only site where the predicted concentration was greater than 1% AND PEC > 100% was the pSAC (Inner Hebrides and Minches) which is designated for harbour

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porpoise – neither the porpoise itself nor its habitat are sensitive to nitrogen deposition, therefore no critical load applies.

SEPA concluded that the assessment of the impacts undertaken by the applicant and the conclusions reached are robust. It is deemed that the applicant has employed BAT in the selection of a boiler type, including fuel type, appropriate for the environmental setting and is capable of meeting the legislative requirements described in MCPD.

5.3 Point Source Emissions to Surface Water and Sewer

The proposed development will introduce several new point source emissions to the water environment, the most significant of which is the discharge from the process water effluent treatment plant (ETP). This is identified as point W1 on the site plan in the permit. Water emissions points W2(E) and W2(W) identify the two SUDS ponds. There are five oily water interceptors on site marked as W3(a) to (e) inclusive. Assessment of impacts from each of these categories of water discharge is set out below.

5.3.1 - W1 process water effluent treatment plant (ETP)

Details of the process water effluent treatment plant (ETP) are given in Section 3.22 and 6.14 – 6.26 of the Supporting Document to the permit application. This is supported by the manufacturer’s technical specification in Appendix 7. Other information is embedded in Appendix 2, within EIA Chapter 2 Project Description and EIA Chapter 17 Water Quality FINAL March 2017, which in turn, appends the modelling work “App 17.1 Initial Dilution Report”.

The Supporting Document states that all process wastewaters will be received and treated within an effluent treatment plant (ETP) before discharge to the sea. The discharge point from the long sea outfall will be positioned 8 metres below the surface. The treatment plant has been designed to maintain Environmental Quality Standards (EQS) and to be protect the identified sensitive marine receptors (which are described in Chapter 17, and include flame shell mussel beds on the sea bed at ~9.5 metres depth), using modelling of the predicted current flows in the local area (Inner Sound) to ensure the necessary dilution of the discharge will be achieved.

Further information on the environmental monitoring to validate the predicted effects on the flame shell mussel beds is given within the Kyleakin Marine Monitoring Plan (Final, August 2017) produced by Jacobs for the applicant, in response to recommendations of Scottish Natural Heritage (SNH) under the Marine Licence consultation.

The PPC permit describes the ETP as a directly associated activity in Paragraph 1.1.5.9:

SEPA reviewed the CORMIX ocean modelling work “App 17.1 Initial Dilution Report” and Chapters 2 and 17 under the formal consultation on a Marine Licence application for site construction and capital dredging development at the coastal foreshore location. The assessment included consideration of ocean modelling and marine chemistry aspects and were satisfied that appropriate methods and guidance had been followed. SEPA are content with the dilution factors derived by the modelling work for onward use in deriving emission limit values for specified substances in the ETP discharge and on establishing the extent of the long sea outfall to achieve ammonia (unionised) EQS at the appropriate point (edge of mixing zone 40 m from end of pipe). Statistical analyses of all simulations runs were undertaken at downstream distances of 40m and 100m. These distances corresponded to the closest proximity to the flame shell bed from the discharge point and the extent of the 100m maximum mixing zone limit allowed by SEPA.

The marine EQS is shown here, referenced from SEPA supporting guidance note WAT-SG-53:

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The long sea outfall design, informed by the modelling work, comprises intertidal pipework of 80m in length, connecting to subtidal pipework 300m in length, from Mean Low Water Springs mark out to the point of discharge at ~ 8m below chart datum. Specification of the design and extent, and the specification available for the two-stage water effluent treatment process, as presented in Appendix 7 of the Supporting Document, enabled assessment of the chosen process to be deemed to meet BAT and to achieve water quality standards protective of the marine environment.

The performance criteria for the ETP, submitted by the applicant align with criteria detailed within the first draft revision of the FDM BREF Jan 2017. In its Section 17.1.7.1, Table 17.3 gives BAT-AELs for direct emissions to a receiving water body, for the parameter “Total Nitrogen (TN)” of 2 – 20 mg/l (with a footnote indicating further potential - and caveated - allowances). Recognising the risk of employing a draft BAT-AEL as a design parameter, SEPA considers that the BAT-AEL of 2 – 20 mg/l captures the proposed design as stated in the third column of Table 3.2 in the Supporting Document. This is considered appropriate since the existing published FDM BREF Note, 2006, states in its summary, on page vii, that “the emission levels in the following table are indicative of the emission levels that would be achieved …… do not necessarily represent levels currently achieved within the industry….” . The indicative BAT value for the parameter for Total Nitrogen in the 2006 BREF is set at <10 mg/l.

ELVs for all other parameters identified in both the Jan 2017 revised BREF, and the current published 2006 BREF, are able to be achieved by the ETP. See also Section 8 ELV of this document.

The applicant is required by specific Conditions within the Permit, as well as providing a commitment to investigate further, at commissioning, test indicators for performance on water parameters and ensure the treatment system achieves the required targets. The applicant is aware that this may require modification / enhancement of the level of treatment to ensure they are met, provision for which has been included within the design of the ETP.

Section 5.11 of the Supporting Document lists parameters to be tested at the monthly Process Water Treatment maintenance checks. It states that SEPA will be notified of ELV exceedance and investiga- tions will be commenced. Permit conditions are in place for notification of incidents of breach of ELV.

In conclusion, SEPA acknowledges that conservatism has been built into the calculation by assuming that the whole of the Total Nitrogen within the process effluent is ammonia (i.e. worst case) and that calculated dilution ratios were presented as ranges within which there was availability to account for some variation. Further, it is stated that buoyancy of the warmer discharge will allow dispersion at the surface and subsequently downwards in a gradient prior to reaching the receptors deemed most sensitive (flame shell mussel beds on the sea bed). SEPA concluded that the applicant’s submitted methodology on establishing the extent of the long sea outfall was acceptable and that there remain options available for additional treatment by chemical dosing at the ETP, which is described in section 2.7 of the ETP specification in Appendix 7.

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The implementation of the two-stage treatment of the ETP discharge, and supporting measures, is considered to be BAT in line with FDM BREF 2006 and BATC 12 in the first draft revision of the FDM BREF Jan 2017.

In order to reduce emissions to water, BAT is to use an appropriate combination of the techniques given below. Includes: c Physical separation, e.g. screens, sieves, grit separators, oil/fat separators or primary settlement tanks Biological treatment (secondary treatment) d Activated sludge process

5.3.2 - W2 Surface Water run-off: Rainfall

An outline of the surface water management arrangement is given in Section 3.24 and detail is supplied in Section 6.30 of the Supporting Document. It facilitates segregation of stormwater from process water.

Surface water runoff of stormwater (rainfall) from roofs and hard standing will be collected by a separately piped system that is conveyed to one of two SUDs treatment ponds prior to discharge to the sea. Runoff from roofs is directed towards the SUDS ponds on site, as well as drainage from concrete bunded areas. The biggest surface area is at the silos for the liquid raw materials which are situated on a fully bunded plinth to contain spillage. The bunds contain drains so that rainwater can be drained using a method to be confirmed as BAT as part of the commissioning process, with the determination of diversion to the SUDS ponds or to the ETP, or to be collected for off-site disposal, dependant on the water quality and condition subject to inspection and assessment.

The site plan in the permit identifies W2(E) and W2(W) as the two SUDS ponds, to the east and west.

Visual inspection of the discharges at the outlets of both SUDS pond is included within the weekly monitoring scheduled (Table 4.6 in permit).

The implementation of water segregation is considered to be BAT in line with FDM BREF 2006 and BATC 7 in the first draft revision of the FDM BREF Jan 2017.

“In order to reduce water consumption and the volume of waste water discharged, BAT is to use BAT 7a and a combination of the techniques given below: Includes: “segregation”

Note that due to construction underway, the “as built” details are awaited to confirm the functionality and physical arrangements for the SUDS system, and the interfaces between the types of drainage on site, and logging the exact locations these will discharge to the water environment, if different to that logged on the site plan in the permit. Originally, it had been stated by the applicant that the SUDs basins will be sized with appropriate free board to accommodate firewater loading (a COMAH issue). The second SUDs basin was added to the west of the site. The applicant has confirmed the SUDS ponds capacities for future COMAH reference if fire-fighting water is considered a necessary measure in the Safety Report

5.3.3 - W3 oily water interceptors

There are five oily water interceptors on site marked on the permit site plan as W3(a) to (e) inclusive. Figures 7.1 – 7.9 in Appendix 1 of the Supporting Document show the drainage plans for the pier area.

An outline of the interceptors is given in Section 3.25 and detail is supplied in Section 6.30 of the Supporting Document. This states that all areas where there is a risk of oil spillage are drained via suitable Class 1 oil-water separators. All water potentially contaminated by oil is passed through an oil/ water separator fitted with oil detectors and automatic isolation valves. Storm water from the tank yard, oil room and the defined loading area for trucks next to the tank yard is passed through an oil / grease trap before discharge to the sea.

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Visual inspection of the discharges at the outlets of all interceptors is included within the weekly monitoring scheduled (Table 4.6 in permit). The discharge from the oil/water separator shall contain no visible oil or grease.

The implementation of oily water separators is considered to be BAT in line with FDM BREF 2006 and BATC 7 in the first draft revision of the FDM BREF Jan 2017.

“In order to reduce emissions to water, BAT is to use an appropriate combination of the techniques given below. Includes: Preliminary and primary treatment c Physical separation, e.g. screens, sieves, grit separators, oil/fat separators or primary settlement tanks”

5.4 Point Source Emissions to Groundwater

An outline of the Foul / Sanitary Water arrangements is given in Section 3.23 of the Supporting Document with detailed drawings showing the location and design of the septic tank presented in Appendix 15.

Section 2.3 on Sewage Treatment states that the foul / sanitary water is collected by a separate drainage system and is treated in a septic tank with soakaway.

The soakaway is registered in the permit. SEPA guidance WAT-RM-04 states that sewage discharges to the water environment from a population equivalent of less than or equal to 15 are assumed to be relatively low risk. Registered discharges do not have to specify a responsible person and will not be routinely monitored.

During the pre-application stage, the consultants dealing with the design of the foul effluent system stated: “We are now proposing to have a soakaway downstream of the Septic Tank. The infiltration results from the Site Investigation make this a viable alternative option. Therefore there will be no connection to the surface water sewers from the Septic Tank.” The infiltration findings have been supplied by the applicant confirming the soakaway dimensions appropriate to the ground conditions following the SEPA guidance.

Consideration of other potential emissions to Ground and Groundwater is given in Section 6.38. of the Supporting Document, stating that the facility does not have any discharges that lead directly to ground and groundwater other than surface water run off which is treated by the SUDS arrangements described in 5.3 above.

Standard Conditions have been applied for no discharge to ground or groundwater. No further fixed control required, checked on inspection.

5.5 Fugitive Emissions to Air

An outline of the potential for fugitive emissions to air, and the control measures to be implemented, is given in 6.12 of the Supporting Document, indicating that the only potential fugitive release to air of significance is odour. Odour control, including the minimising of fugitive releases, is considered in 5.7.

Section 6.13 indicates the applicant considers emissions of dust are considered to be negligible. The transfer of solid raw materials and product is by fully enclosed conveyors.

At the pre-application stage, SEPA found references to dust filtration in the mixing area (Section 3.8 of Supporting Document), and in row BREF 4.4.3.10.1 in the table in Appendix 3, “….an emergency gas vent to the air…… the exhaust gases are discharged directly to the air thereby bypassing the bio-filter.

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The use of such a system will mean that the waste gases are emitted untreated, so the conditions leading to such a bypass need to be prevented.” SEPA had also noted the potential for release of unabated odour if the ETP Odour Control Unit (OCU) suffers a failure. SEPA raised these points of concern for potential air emissions, and the concern was answered by the applicant as follows:

“The reference to emergency venting if the temperature of input to the biofilter is too high is not relevant in this case. The temperature of the input is measured and alerts will be set off if the temperature is too high. If immediate attempts to reduce it are not successful then the plant will be shut down while more intensive remedies are applied. The shut down of the plant will result in the termination of flow in this area, so emergency venting will not be required.

It is considered that the venting required for the bulk liquid storage tanks will not require to be identified as air emission points, as this raw material oil is not expected to be odorous, however the potential for receipt of odorous fish oil is identified in the odour management plan. This item may therefore need to be kept under review, as recognised in the final column.” and “No OCU is currently proposed for the ETP. A contingency plan is in place to retro-fit an OCU in the event that some odour treatment is required.”

Standard Conditions have been applied for no offensive odours outside the permitted installation boundary, and provision of an Odour Management Plan. See 5.7 for main detail on the issue of odour. Fugitive releases of dust would indicate a potential containment/extraction system/abatement failure and will be dealt with under application of BAT.

5.6 Fugitive Emissions to Water

See 5.3 for measures to prevent the fugitive release of oil to water, including bunded areas and oil interceptors.

An outline of the potential for fugitive emissions to water, and the control measures to be implemented, is given in 6.27 of the Supporting Document, indicating that the operator will manage operations in such a manner that there are no fugitive releases to water resources. Control mechanisms in place to prevent this are as follows: Hard standing across the site in all areas where contaminants are likely to be present; Process and non-process areas are served by process drains and surface drains respectively – process water cannot enter surface drains under normal operation; Secondary containment is provided for all above ground tanks, IBC and drum stores; and All deliveries / collections are supervised by personnel trained in the use of spill kits.

Section 6.28 states that the facility has installed the hardstanding across the production and material storage areas, with further details on the concrete hardstanding areas given in Appendix 14 to the Supporting Document.

Section 6.36 identifies an inspection programme to be undertaken on a routine basis, in line with BAT requirements, as part of the preventative maintenance in respect of fugitive emissions to water:  Tanks and bunds (monthly);  Pipelines (monthly);  Effluent treatment plant (monthly);  Yard surfaces (monthly); and  Drainage (obvious blockages) (weekly).

Standard Conditions have been included; no discharge to the water environment from the installation other than those specified in the permit. No further fixed control required, with application of BAT checked on inspection.

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5.7 Odour

5.7.1 Odour assessment and predictive modelling

Assessment of the application for potential odour impacts has been identified by SEPA as a key consideration in the determination of the application, given the nature of the process handling bulk fish oils and dry materials of fish origin. The applicant has stated that all potentially odorous raw materials (such as fish oil) are neutralised before they are delivered to the site, and that no ‘wet fish’ is handled at the site.

The applicant has recognised within the application that odour assessment and control are a key aspect to consider. Section 6.1 of the Supporting Document states that the main adverse impact from the installation to potentially affect local residents is odour. A separate Chapter 7.0 of the Supporting Document is given to an overarching description of Odour Management at the installation, with the odour control measures outlined in the stand-alone Odour Management Plan (OMP) for the installation. The OMP is included within Appendix 6 of the Supporting Document; see section 5.7.3 for SEPA’s review. The application states that the main source of odour arises from the drying process and air lifts.

The applicant has stated that the process buildings will be held under negative pressure and that the buildings will be constructed to a high standard to ensure containment. Point source extraction is applied to specific areas of plant that have been identified as having the potential to produce more odorous emissions. All extracted air flows are passed through dust abatement plant with less odorous air passed straight to the stack and the more odorous air passed to a biofilter for treatment prior to emission to air via a stack

SEPA’s approach was to check that the built systems (fixed) comprise the best available technique to control odours, under both normal and abnormal events arising including process upset, off-spec materials, staff factors, and weather conditions (temperature, wind direction).

The Supporting Document states in section 7.1 that the assessment of the odour potential for an installation and the determination of BAT for odour management within an installation are described in SEPA’s Odour Guidance (2010). This guidance has been cited in the application odour assessment.

Section 7.2 states that a detailed odour impact assessment was conducted for the installation as part of the Environmental Impact Assessment (EIA). A dispersion modelling assessment was used to predict the impact of odour releases from the [proposed] salmon feed manufacturing plant development. The aim of the assessment was to identify the potential odour impact at surrounding sensitive receptors given the proposed reduction in odour concentration achieved from the intended biofilter abatement system and that no significant pollution is caused. This also allows for the determination of both the minimum stack height required to ensure compliance with odour benchmarks as well as that deemed to represent BAT.

In effect two assessment reports were provided as part of the application. The original version of this technical report was first supplied to SEPA as part of the Environmental Statement and then again as part of the applicaion, with a second revised version embedded in Appendix 2, within Chapter 6 Air Quality Technical Appendix (including Stack Height Assessment) 01 Dec 2016 and referenced in EIA Chapter 2 Project Description. Both assessments adopted a precautionary approach and both concluded no significant impact. The updated assessment concluded that odour from the installation 3 would comply with SEPA’s odour criterion of 1.5 ouE/ m 1 hour 98%ile at the nearest sensitive receptor, based on pessimistic assumptions about the abatement performance of the bio-filter.

Section 7.3 provides information relating to sensitive receptors involved within the assessment. The site is in a relatively isolated location and there are few nearby sensitive receptors. Twenty potentially sensitive locations were identified in the vicinity of the manufacturing plant, as detailed in Table 2.5 of Chapter 6 and shown on the plan at Figure 6.1 located at the back of that chapter. Pollutant

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Section 7.4 reflects the precautionary approach adopted by the applicant with regard to potential for generation as well as treatment, indicating that the approach taken at the site is to prevent odour release as far as practicable and to minimise unavoidable odours. The odour management strategy at the site is described in detail in Section 7.5. It states that the main controls are to contain potentially offensive odours within the process buildings and to treat these in a biofilter prior to release from a 60m stack. The main source of odour arises from the drying process and air lifts. Further details on the bio-filter are presented in Appendix 10 of the Supporting Document.

The location of the stack at the biofilter odour treatment system, being a point source emission, is identified as point A1 in Figure 5 in Appendix 1 of the Supporting Document, and on the Site Plan in the permit. In assessing minimum stack height the benchmark level for the most offensive odours (i.e. 1.5 3 ouE/ m for the 98th percentile of hourly mean) was employed. The stack height requirement was calculated to be 60 metres. SEPA examined the submissions in detail with input from air modelling specialists to ensure that the assumptions and justifications in the odour dispersion modelling and stack height calculation work were robust. A number of questions were raised, and responses to address these were received, set out at section 1.2 of Chapter 6 Air Quality Technical Appendix (including Stack Height Assessment) 01 Dec 2016. SEPA was content that sufficient information had been supplied to determine the planning consent applied for.

SEPA’s planning response to the EIA had stated:

We can confirm that the submitted information demonstrates that BAT can be accommodated on site for emissions to air (including dust, noise and odour) and there is unlikely to be a significant adverse impact from these emissions upon sensitive receptors.

For the avoidance of doubt, the applicant currently proposes a stack height of 60m. We understand that due to impacts upon landscape, some consideration may be being given to lowering the stack height. Based on the submitted information, we would be unable to support any lowering of the stack height as we consider this could result in unacceptable impacts upon air quality and odour. A stack height below 60m would be unlikely to be consentable under PPC 2012.

SEPA was further consulted prior to the PPC application stage, under a further specific planning consultation, in respect of a location alteration for the biofilter stack A1, needing to be moved by 25 metres across the yard for layout reasons. SEPA had earlier advised the applicant that such a position change to the stack would require for the air emissions to be re-modelled. A revised air and odour dispersion modelling assessment was supplied (ESG v2 June 2017), and planning consent was sought again, with SEPA being consulted for issues in respect of air quality and odour. The second version of “Assessment of stack height requirements for odour dispersion” report (June 2017) is the version appended within Chapter 6 (01 Dec 2016), submitted for the PPC application.

SEPA examined the revised report in detail with input from air modelling specialists to ensure that the assumptions and justifications in the odour dispersion modelling work were robust. SEPA acknowledged that conservatism had been built into the modelling and stack height calculation, (see Section 5 of the report) but needed to assess if the stated flexibility on the stack height, were adequately supported with information on the efficiencies at which the bio-bed operates, assuming all other variable factors were equal.

After detailed discussion with the applicant’s specialists, and onwards confirmation of the applicant’s intended approach, SEPA was content that the revised report had adequately assessed the impacts of odour dispersion on nearby occupied buildings. Although it concludes that a 63 metres air emissions stack would be the most suitable height, SEPA was satisfied that the report, particularly due to the

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During the PPC permit determination period, a deeper examination of the technical information underpinning the operation of the odour abatement systems was undertaken. Additional information was supplied in response to informal information requests. SEPA’s review and assessment under the following sections 5.7.2 to 5.7.4 has been informed by this additional information.

Fugitive odours - further to Section 5.5.

The application has referenced fugitive odours within the Odour Management Strategy in section 7.5 of the Supporting Document. The main odour controls will be to contain potentially offensive odours within the process buildings. On the process building construction details, the applicant has stated that the buildings will be constructed to a high standard to ensure containment (Ref: Executive Summary to the Supporting Document and section 2 of Appendix 6), with details set out in Section 7.7 – 7.12. All equipment and processing areas are to be maintained under negative pressure. While this had been observed for the majority of equipment on the figures submitted to date, it was less clear with respect to Room Air. However the ‘Air Treatment’ Figure (Drw No. 3493401109 Rev.F) provided on the 01/05/18 highlights room air being passed to the Dryer units, that is, room air will be heated and used to dry the product with exhaust gases will then pass to the biofilter.

Other sources of fugitive odour to be considered include displaced air during unloading of raw materials. SEPA therefore questioned the arrangements indicated in the application for unloading raw materials, whether there was any intended back-venting of displaced air into the delivery road-vehicle / sea-vessel to capture any potential odours. The applicant stated in additional information that “the loading / unloading systems are not connected to local abatement systems or to the main air treatment system passing to the biofilter, based on a low potential for odorous emissions from this source (potential odour levels in the exhaust air from the ships intake source are low), as is the actual flow from the limited operating hours. However, there is abatement targeted by the installation of a fully enclosed dust filtration system ensuring that clean air is exhausted to atmosphere”. SEPA notes that the original air quality and odour assessors had eliminated the intake points as sources of odour due to the unloading taking place only periodically and for limited duration, and in the case of the ship unloading, both intakes are located on the pier away from sensitive receptors. On consideration of the potential intensity, frequency and duration of activity SEPA considers this as reasonable, but amendment of the Odour Management Plan is necessary to make this arrangement clear and to better reflect potential sources, significance and rationale for control. SEPA will further confirm the assumptions made on inspection.

5.7.2 Outline description of biofilter:

A key constituent of the odour management regime at the manufacturing plant is the treatment of odorous spent process air through a bio filter. The application Appendix 10 provides the design details from the biofilter manufacturer, described as follows: The spent process air is blown and drawn upwards through the filter media. The filter media consists of a mixture of organic and inorganic materials. The organic element is a specific type of pasteurised decomposed compost. The inorganic element consists of different types of burnt clays with different characteristics such as high water capacity and high porosity. The filter media is inoculated with naturally occurring microorganisms, which treat the odorous process air and convert it primarily into carbon dioxide and water. The odorous air has a residence time of approx. 27 sec inside the biomedia and in order to attain optimum treatment efficiency, it is essential that required water content, pH-level and temperature are under control and can be adjusted as required. The bio filter is covered with a soft cover. The treated air from the biofilter passes to a 60 metre air stack.

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During the permit determination period, SEPA questioned the applicant on details of the biofilter design and function during normal and abnormal operation as well as on commissioning (both lines running, one only etc) so as to ensure understanding of flows of odorous air to the functioning of the biofilter and so that all component parts can be maintained under variable loading. The application appendices, and diagrams obtained under the further information requests, show that temperature, humidity and flow pressure are all critical factors in maintaining optimal performance of the biofilter whilst also maintaining buoyancy of the exhaust gases for correct air dispersion from the stack. Installation management systems will govern the operation of the biofilter under the principles of BAT such that no specific conditions would need to be placed in the permit for its operation, but while the applicant has confidence in the design, this still has to be demonstrated. Key to the demonstration that the biofilter has been correctly designed, built, installed, operated and maintained will be the provision and adherence to site working plans in normal operation (see 5.7.3), and commissioning monitoring (see 5.7.4), which will be checked through inspection.

5.7.3 Odour Management Plan (OMP)

Appendix 6 contains the draft site Odour Management Plan (OMP Rev 02). Operator commitment is made to the control of odour through good site management systems and scheduled inspection and maintenance of plant and equipment. A series of tables identifies: circumstances which may affect the process and the generation of odour (OMP2); circumstances which may affect the ability to abate/reduce odour (OMP3); circumstances which may affect the ability to contain odour (OMP4); and circumstances which may affect dispersion (OMP5). Remedial actions and assignation of responsibility for these tasks is stated.

Appendix 1 of the OMP also sets out a complaints investigation procedure, in a step-wise approach including notification to SEPA. The sheet “Information to be recorded for an odour-related complaint” is useful. On the description of odour characteristics, SEPA advice was followed to strengthen this section with reference to the “FIDOL” approach given in the SEPA odour guidance 2010 – (Frequency, Intensity, Duration, Odour unpleasantness, Location), along with specifying the location from which the observation of any offensive odour is being made. The procedure is to record the contemporaneous onsite activities and operating conditions on the same sheet, and particular locations to check, or equipment readings to note, are intended to be tabulated there so they are not missed.

It is noted that Appendices 2 and 3 of the OMP are awaited. These cover the Critical Odour Control Plant Maintenance Schedules and Visual Monitoring of Odour Control Plant respectively. Updating and amendment of the Odour Management Plan is necessary to include these awaited schedules, which will be checked through inspection.

Provision of an OMP meets the BATC 15 (in the first draft revised FDM BREF Jan 2017) requirement to set up, implement and regularly review an odour management plan. To be reviewed on inspection following the completion of commissioning.

5.7.4 Odour monitoring

The application Supporting Document states in Section 5.5 that a “2U service” will be undertaken once every two weeks at the biofilter by a technician trained in the procedures as described by the biofilter supplier. The tasks to be performed are listed, and include gas measurement of intake and outlet air. The measurements are taken first in the exhaust air. If NH3, R-SH or H2S are registered, then measurements of intake air will be carried out.

The application Supporting Document states in Section 13.2 that the general principles of monitoring air emissions will be to use MCERTS accredited devices and to follow the M1, M2 and M20 guidance documents (cited in References section below), indicating an intention for the extractive testing of air emissions. The M series guidance refers to extractive sampling and offers guidance on the position of sampling ports installed within the stack to enable appropriate samples to be obtained. SEPA considers that whilst no specific condition has been set with respect to an emission limit exiting the biofilter

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 FINAL Page no: 22 of 48 Permit (Application) Number: PPC_A_1163789 Applicant: Marine Harvest (Scotland) Ltd requiring monitoring to be carried out, stack sampling forms a key tool in the assessment of performance of the manufacturing plant’s biofilter. Provision of a sampling port allows the operator to demonstrate that assumptions made with respect to its design and input compared with the expected modelling results remain valid. Extractive monitoring of air emissions will be particularly important at commissioning as a relevant marker for odour to ensure correct design, installation and functioning of the bio filter. There is also the potential for future periodic routine monitoring becoming needed due to performance issues or changes in FDM BREF requirements. A Commissioning Plan is required to be submitted 14 days, or such period as otherwise agreed in writing with SEPA, prior to carrying out any Commissioning Activities and SEPA would expect this to include a demonstration that the biofilter has been design, installed and commissioned in such a way as to deliver as intended.

The Supporting Document also refers to subjective Odour monitoring in the Monitoring section 13.0. Section 13.5 indicates that odour surveys will be undertaken once per shift, at least three on - site and three off-site locations. The location of the assessments will take account of wind direction to ensure that at least one on - site and one off-site assessment are in the downwind direction. Each point will be assessed over a period of at least 5 minutes and the results graded on a 1-5 scale. Dialogue with the applicant is underway in confirming a plan giving a series of locations to be assessed on a routine basis (walkround survey) focussing on the downwind locations on a given day, having checked first the wind speed and direction using a reliable source of meteorological data (as with the odour complaints proforma). The OMP proforma in Appendix 4 “Sniff test Record Sheet” should be developed for the site walkover survey.

Standard Conditions have been applied for no offensive odours outside the permitted installation boundary, and provision of an Odour Management Plan. Updating and amendment of the Odour Management Plan is necessary to include these awaited plans and proformas, which will be checked through inspection following completion of commissioning.

5.8 Management

Details of the Monitoring and Inspection is given in sections 8.1 to 8.41 of the Supporting Document, indicating that the applicant is committed to developing the company’s existing certified environmental management system ( ISO 14001) to include all process operations at the Kyleakin installation. This process will start within one month of the site opening and within six months the site will be assessed and included within the group scope. Key elements of the environmental management system (EMS) on site are discussed in the sections 8.2 to 8.41.

This aligns with BAT 1 of the draft FDM BREF (Jan 2017 1st draft), which indicates that to improve overall environmental performance, BAT is to implement and adhere to an environmental management system (EMS). Implementation to be confirmed on inspection.

5.9 Raw Materials

A description of the applicant’s arrangements for the main raw and auxiliary materials is given in sections 9.1 to 9.24 of the Supporting Document, indicating the process followed to report on the following;

 the chemical composition of the materials where relevant;  the quantities used;  the fate of the material (i.e. approximate percentages to each media and to the product);  the environmental impact where known (for example degradability, bioaccumulation potential, toxicity to relevant species);  any reasonably practicable alternative raw materials that may have a lower environmental impact including, but not limited to any alternatives described in the BAT requirements below (the substitution principle); and

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 to justify ( for example, on the basis of adverse impact on product quality) the continued use of any substance for which there is a less hazardous alternative to show that the proposed raw materials are therefore BAT.

Those materials determined to pose a potential threat to land contamination have been considered further within the Application Site Report (FAIRHURST OCTOBER 2017) in Appendix 13 which forms part of the PPC application.

The applicant will need to consider alignment of approach to the standard permit conditions, including templates available from SEPA, for recording raw material usage annually. The permit requires a 4 yearly review of resource utilisation to identify methods of reducing raw material consumption. Table 4.8 of the permit identifies raw materials storage. The appropriate use and storage of raw materials (stored at the location, following the method and in the quantities specified by the applicant as constituting BAT) will be checked through inspection.

5.10 Raw Materials Selection A description of the Raw Materials Selection and Specification arrangement is given in sections 9.16 and 9.17 of the Supporting Document, indicating that the applicant is limited in the selection of the main raw materials, controlled by the strict quality requirements for the product manufacture. A change in the source of the raw materials will not alter the process significantly and therefore the environmental impact from the facility will remain unchanged.

In terms of ancillary Raw Materials Selection and Specification, section 9.17 indicates that before any new raw material can be used within the installation boundary, a comprehensive assessment (incorporating the statutory COSHH assessment) shall be conducted. The assessment shall include a number of steps including health and safety requirements and that the environmental aspects of the material shall be assessed to ensure that they do not pose unacceptable risks and that other suitable materials, with lesser potential impact, are not available.

5.11 Waste Minimisation Requirements A description of the Waste Minimisation – Raw Materials arrangements is given in sections 9.19 to 9.24 of the Supporting Document, indicating that waste minimisation principles (in particular the waste minimisation hierarchy) have been considered as part of the design process and that baseline monitoring of material uses set out in Table 9.7 shall be analysed to allow the calculation of key performance indicators.

The applicant will need to consider, when developing key performance indicators, that they align in their approach to the standard permit conditions and templates available from SEPA for recording waste material generation annually, to maintain a record of storage locations and to require a 4 yearly review of waste generation to identify methods of minimising waste generation. Storage arrangements and minimisation efforts will be checked through inspection.

5.12 Water Use

A description of the Water Use arrangements is given in sections 9.25 to 9.28 of the Supporting Document, indicating that Mains water used in offices and ‘domestic’ uses is supported by Pond Water abstracted from the reservoir used in steam raising boilers, as an additive to the product; cleaning, washdown and cooling waters.

Section 9.26 indicates that water consumption shall be metered and records shall be checked as part of an audit of water consumption. This will allow for the identification of possible BAT opportunities for the installation to target improved efficiency.

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BAT 7 of the draft FDM BREF (Jan 2017 1st draft) refers to reducing water consumption. It can be seen from 5.3 above that the applicant will be segregating rainwater from roofs and hardstanding, from the more contaminated process effluent to be transferred for treatment. Section 9.27 identifies further measures employed on site. SEPA had queried with the applicant the potential and extent to which the segregated surface water destined for the SUDS pond had potential re-use value elsewhere on site as a source of “grey water”. The applicant responded that water recovery systems are in use within the process. Further, the water supply is a private supply sourced on the site, which is supplied by a large and robust catchment which is not widely used so water scarcity is not a key issue in the site location.

The applicant will need to consider aligning their approach to the standard permit conditions and templates available from SEPA for recording water use annually, to maintain a record s and to require a 4 yearly review of water use to identify methods of minimising usage. Minimisation efforts will be checked through inspection

5.13 Waste Handling

An outline of Waste Handling Recovery and Disposal is given in sections 10.1 to 10.12 of the Supporting Document, with the waste arisings predicted for the installation and details the storage on site, disposal and volumes anticipated where known included in Table 10.1. On commencement of operations, the specific waste streams may alter depending on the materials brought onto site. The applicant has stated their intention to update Table 10.1 with actual quantities within 6 months of starting commercial operations.

Details of waste types are detailed in section 10.6, with Table 10.1 indicating their storage arrangements or methods of removal from the process and site as well as final disposal.

Standard permit conditions are in place to record waste handling and storage. Management aspects of waste will be checked through inspection.

5.14 Waste Recovery or Disposal

A significant arising of waste material is noted to be the dewatered sludge arising from the dewatering press at the Effluent Treatment Plant (ETP). The applicant has stated that the sludge will be stored in a sealed slurry storage tank, and the permit requirement will be for this tank and the slurry disposal tanker loading point to be located in a bunded impermeable surfaced area. At the pre-planning stage, the applicant was requested to provide data from another plant they operate to demonstrate and confirm the effectiveness of the water treatment plant, and that this should also identify waste disposal needs if this was required. The response was that the other plant disposed of treatment process sludge off site on a weekly basis.

For the Kyleakin plant, no quantities were provided at that stage, but two options were being considered for sludge disposal, and identified one named effluent treatment site some 70 miles distant, and the option of transport to an Anaerobic Digester plant, but did not identify the specific details for this second option. These options would appear to be reasonable as identified disposal routes, though the named facilities have not yet been specified. This will be confirmed once commissioning commences and checked through inspection.

Standard permit conditions are in place to record waste handling and storage, and Table 4.9 identifies waste materials storage. Management aspects of waste will be checked through inspection.

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5.15 Energy

An outline of energy consumption and efficiency measures is given in sections 11.1 to 11.24 of the Supporting Document, with the commitment made by the applicant that once the plant has been commissioned and baseline energy usages have been established, an Energy Efficiency Plan will be drafted. The applicant has stated their intention to implement the plan after suitable cost/ benefit analysis.

Section 10.2 states that electricity from the public supply powers all machinery and lighting on site. The boiler and driers are fuelled by LNG. Diesel is used in the standby water pump which is required in the vent of mains failure for fire-fighting. Energy consumption details are listed. Environmental emissions from this usage are listed.

Standard permit conditions are in place to record energy usage annually and to require a 4 yearly review of resource utilisation to identify methods of reducing energy consumption /increasing energy efficiency. Management aspects of energy efficiency will be checked through inspection.

5.16 Accidents and their Consequences An outline of accidents and their consequences is given in sections 12.1 to 12.12 of the Supporting Document, highlighting that the scope of accidents in this section relates only to accidents with potential environmental consequences. Accidents potentially affecting solely people working on the site are excluded as they fall out with the regulatory remit of SEPA.

Section 12.2 describes that the installation shall be controlled by a continuous SCADA process. Section 12.3 indicates that in the event of any plant failure, with potentially significant impacts e.g. failure of the bio-filter or the ETP, that the process will be immediately shut-down. This will allow a systematic analysis of the factors contributing to the failure. The plant will not be re-started until the issues are resolved and appropriate corrective actions implemented. A similar approach will be adopted for the receipt of raw materials and the dispatch of finished product. Any factors leading to spillage of raw materials or finished product will result in the immediate suspension of operations until appropriate corrective actions have been implemented.

The site is an Upper Tier COMAH establishment with the Pre-operational Safety Report recently being submitted and assessment in progress at time of writing. PPC includes a specific duty to prevent and mitigate accidents to the environment which is complementary to the main COMAH duty (prevention of major accidents). In order to avoid potential conflicts between the requirements of COMAH and PPC the competent authority work closely together below the umbrella of the COMAH memorandum of understanding.

Standard conditions are in place with regard to the reporting and recording of incidents. Actual risk assessments, procedures and maintenance carried out on site are to be monitored and controlled through inspection and application of BAT.

5.17 Noise

An outline of environmental noise impact is given in sections 6.49 to 6.53 of the Supporting Document, highlighting that the environmental noise impact from the installation has been assessed. The proposed mitigation measures to be adopted include the containment of noisy plant within the process building and the selection of quiet motors and fans. The applicant has committed to undertaking noise verification surveys and measurements as part of the commissioning period.

Noise assessment was undertaken as part of the Environmental Impact Assessment (EIA) under the planning consent stage. The noise assessment is included within Appendix 2, within the embedded EIA Chapter 7 Noise – Final - September 2016, with reference made to Chapter 2 Project Description.

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The introduction to Chapter 7 states that: “Baseline noise levels at locations near the development had been measured in 2009 by Vibrock for an ES for a different development. A noise survey has also been undertaken in August 2016 for the purposes of the noise assessment of the Kyleakin Fish Feed Plant. The locations of the measurements undertaken in both 2009 and 2016 are shown in Figure 7.1, as are the dwellings at Kyle House that are represented by measurement location B5”.

Assessments of noise were undertaken (2016, Jacobs) at five potentially sensitive locations which include representative proxy locations where suitable access could not be gained.

Review of the noise assessment was undertaken by SEPA and SEPA’s planning response stated:

We are satisfied that the data acquisition and use of the BS4142 assessment has adequately assessed the impacts of noise on the surrounding area and sensitive receptors. In this case, the World Health Organisation guideline level of 45 dB (at night) is also a good indicator of overall impact and is appropriate in situations where there are very low background contributions where the BS4142 assessment is likely to show some degree of adverse effect. The noise assessment has shown that the predicted noise levels are well within the World Health Organisation guideline level and we are satisfied that the proposed plant will not have a significant adverse impact upon receptors in terms of audible noise.

Subsequent to the review of the noise assessment completed under planning, within the PPC permit application, Section 6.50 of the Supporting Document states that the noise impact assessment in Chapter 7 was based on a conceptual design and adopted pessimistic assumptions, particularly relating to noise from external plant. The external fans for the bio -filter are > 10 dB quieter than assumed in the assessment, this reduces the overall noise impact from the installation. The design of the fans has been specified to ensure there is no mechanical energy transmitted through the ducts connected to the stack, to prevent or minimise noise from the top of the stack.

Air-borne noise arising from structural noise and vibration of the 60 metre tall biofilter stack, of steel construction, had been raised as a concern with the applicant’s specialists, based on SEPA case experience. The applicants supplied a further statement of assurance that the stack would be designed to minimise noise and vibration, as follows: “Specifying the air stack noise design criteria in terms of octave band levels will aid design of the air stack such that tonal noise is not emitted due to vibration of the stack. Accordingly, should the aforementioned design criteria be incorporated into the design of the air stack/biobed, and where necessary incorporating noise mitigation measures to achieve these design criteria, the noise modelling indicates that significant adverse noise impacts will not arise at Noise Sensitive Receptors.”

Other aspects of noise control by design are listed in Section 6.50. Noise breakout from entry and exit points to the building are addressed by Section 6.51. Also of concern to SEPA had been the potential for noise generating activities on the pier, including boat engines and conveyors. This is described in section 6.52, with the assessment in Chapter 7 modelling predicted noise from these activities and concluding that they are likely to be of low significance, in fact stating they would be “insignificant at the nearest noise sensitive receptors”.

The Supporting Document indicates in section 6.5.3 that the impacts from environmental noise are controlled through the Noise Management Plan, held in Appendix 8. The Noise Management Plan for the permitted activity was reviewed at the pre-application stage by SEPA’s Noise Specialist on the sufficiency for PPC permitting purposes, making reference to Chapter 7 and related appendices.

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SEPA’s review of the noise assessment has established the following summary points:  The topography (high barrier walls) of the former quarry site are expected to provide sound attenuation and the prediction is for low ambient sound levels at the nearby residential properties.  The noise management plan is comprehensive.  The commitment to verification surveys and measurements as part of the commissioning period is good practice.

SEPA’s observations have been recorded as part of the determination process and the applicant’s attention was drawn to these points at the pre-application stage. These have been copied into Appendix 1 to this document for reference for the commissioning stage.

The applicant had stated at the pre-application stage that noise and vibration control measures are standard engineering objectives at the construction stage and noise sources are typically already understood from experience at a separate site operated by the applicant. Enclosure of conveyors comes as standard, and isolation of noisy plant and equipment (eg. hammer mills) for staff health and safety objectives. Site topography was considered likely to aid attenuation of on-site vehicle noise, and timing of use of forklifts (reversing alarms) will be governed by procedure. It was recognised that existing company commitment for further noise survey work after construction / commissioning would be crucial to identifying problems for resolution and development of a Noise Management Plan to meet PPC permit objectives, and that subsequently, the 4-yearly BAT assessment for noise would identify where continuous improvement would be required.

Standard permit conditions are in place to require a 4 yearly review providing a systematic assessment of noise and vibration emissions in order to identify methods of reducing noise and vibration emissions, and for the provision and adherence to a Noise Management plan. Assessment for noise at the commissioning stage has been committed to by the applicant, and reports for commissioning testing and assessment are required under permit. Management aspects of noise will be checked through inspection and SEPA will ensure input into the required assessment.

5.18 Monitoring

An outline of the Monitoring and Inspection is given in section 6.36 of the Supporting Document, indicating that the following inspection programme will be performed by works engineers on a regular basis, in line with BAT requirements:  Tanks and bunds (monthly);  Pipelines (monthly);  Effluent treatment plant (monthly);  Yard surfaces (monthly); and  Drainage (obvious blockages) (weekly).

Sections 13.1 to 13.6 give detail of the monitoring of different media, specifically water and air, as follows:

Water emissions monitoring Section 13.1 indicates that process effluent will be discharged to a long sea outfall after being treated in the ETP. An MCERTS approved flow meter, installed to meet M18 principles, will provide flow measurement of the discharge. Samples of the effluent will be taken using an MCERTS approved flow- proportional sampler and will be analysed on a regular basis for suspended solids and other parameters to be agreed. On a 6-monthly basis samples of the effluent will be sent by the site to a UKAS accredited laboratory for verification of these parameters.

Air and odour monitoring Details are provided in Sections 13.2 for Monitoring Emissions to Air, with the general principles to use

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MCERTS accredited devices and to follow the M1, M2 and M20 guidance documents (cited in References section below); indicating an intention for the extractive testing of air emissions.

Medium Combustion Plant Directive requirements apply to the steam boiler as its capacity of 7.9 megawatts (MW) net rated thermal input lies between the criterion of 1 and 20 MW, with air emissions 3 requirements set under the relevant ELV table, which for the air parameter NOx is 100 mg/m . The monitoring requirements for the boiler air stack, at emission point A2, have been specified in permit Condition 4.1.2 and associated tables.

SEPA considers that whilst no specific condition has been set with respect to an emission limit exiting the biofilter requiring monitoring to be carried out, stack sampling forms a key tool in the assessment of performance of the manufacturing plant’s biofilter. See section 5.7.4 of this document for further details.

Subjective odour monitoring at agreed assessment points will follow a protocol outlined in the Odour Management Plan. The Supporting Document indicates in Section 13.5 that odour surveys will be undertaken once per shift, at least three on - site and three off-site locations. Dialogue with the applicant is underway in confirming a plan giving a series of locations to be assessed on a routine basis (walkround survey) focussing on the downwind locations on a given day, having checked first the wind speed and direction using a reliable source of meteorological data (as with the odour complaints proforma). See section 5.7.4 of this document for further details.

Details are provided in Sections 13.4 for the monitoring of key Biofilter parameters including:  Total extraction flow rate;  Resistance to flow ( measured as differential pressure across the bed);  Humidity of flow into the bed;  Temperature of flow into the bed;

On a daily basis the bio-filter will be assessed for moisture content. The aim will be for the biofilter medium to be damp to touch across the whole bed as assessed at a depth of 5cm. On a weekly basis the physical condition of the biofilter will be visually assessed to ensure that consolidation or cracking do not compromise flow. Also on a weekly basis, sample tube measurements will be taken and recorded, comprising ammonia and amines; sulphides and mercaptans.

Periodic monitoring of the functioning and balance of the extraction system, and inspection and maintenance tasks, are identified in section 13.6.

Standard Permit conditions are in place to ensure the required monitoring is undertaken to the required standard, and that a sampling plan will be developed and implemented. Checks on monitoring practice and management will be completed through inspection.

5.19 Closure An outline of the Closure Plan is given in sections 14.1 to 14.9 of the Supporting Document, indicating that the closure plan on complete cessation of activities will involve:  Removal of all raw materials and products and disposal via a suitable facility;  Disposal of ancillary materials via suitably licensed disposal facilities;  Dismantling of process equipment, including re-use and recycling wherever practical, and disposal of scrap;  Confirmatory analysis of ground condition to verify no pollution during the operation of the permitted process;  Surrender of PPC permit;  The re-use or demolition of buildings and site; and  Removal and disposal of raw materials and products.

The operations and management procedures that will be implemented to ensure there will not be any deterioration of the site as outlined in the Site Condition Report (SCR) as well as the design features

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 FINAL Page no: 29 of 48 Permit (Application) Number: PPC_A_1163789 Applicant: Marine Harvest (Scotland) Ltd which will be employed to minimise risks from decommissioning of the plant. The proposals for site closure have been adequately outlined in the application and adequately addressed through the inclusions of standard conditions within the Permit. Issues may be addressed during inspection.

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

Information relevant to the Site Condition Report and Baseline reports is provided in Appendix 13 to the Supporting Document “Site Report Phase 1 and Phase 2”.

The site condition report, which included soil and groundwater sampling data from the site, was reviewed following the SEPA guidance note IED-TG-02 and a review filenote was completed for: FAIRHURST OCTOBER 2017. Marine Harvest (Scotland) Ltd. Fish feed plant, Kyleakin, Isle of Skye. Application for a permit to operate a Part A Installation under the PPC(S) Initial Site Condition Report. The site report has been accepted by SEPA, based on review of the submission and completion of the IED-TG-02 filenote included at Appendix 3 to this document.

REGULATION (EC) No 1272/2008 on Classification, Labelling and Packaging of substances and mixtures (CLP) was screened to check for relevant hazardous substances within Table 11 Potentially Polluting Substances in the Site Report, specifically focussing on risk to soil and groundwater, and on material stored in quantities more than “negligible”. The large volumes of fish oils and vegetable oils stored on site are deemed “low risk”, and searching for these items in CLP did not produce any entries. Review of Table 11 for other substances of medium and high pollution risk, showed that cleaning agents, disinfectant fluids and diesel were stored at 1 tonne each and 10 tonnes respectively. The cleaning agents and disinfectant storage amounts to one IBC each to be stored in bunded areas. The diesel storage quantity was later modified down to 100 litres during the PPC permit determination period, further to an information request, with the alteration being due to an incorrect original submission of the capacity of the diesel tank being 10 tonnes. This is actually the firewater tank capacity. The substantially smaller diesel tank has a capacity of 100 litres, and is for standby use for one firewater pump in an above ground tank in a concrete floored kiosk.

The inherent hazard and persistence of diesel, at 100 litres storage and low top-up rate as the fuel is retained for emergency use only, was progressed to a relevant hazardous substance assessment following SEPA guidance IED-TG-42, in order to set appropriate soil and groundwater monitoring requirements. The Proforma 1 (Likelihood of Release) under IED-TG-42 was completed and is shown in Appendix 3 to this document. Completion of Proforma 2 (Consequence Assessment) was not required due to all Proforma 1 findings falling under the lowest risk Category 1 (green column) bar one item: secondary containment of relevant drain which could not be established. The Proforma 1 findings determined that it was appropriate to set the longest extent available (5 yearly for groundwater monitoring, 10 yearly for soils) for the parameter Total Petroleum Hydrocarbons, given that diesel is the primary relevant hazardous substance stored on site that could have a potential to enter ground and groundwater, though the risks have been shown to be low due to quantity stored and location and manner of storage in the firepump kiosk. The diesel storage has been listed in Table 4.8 of the permit along with all other raw materials.

Additionally to this monitoring requirement, the permit includes standard conditions to prevent future land contamination, including no discharge to ground or groundwater, prevention of spillages and the retention of monitoring wells and retention of monitoring records. No further fixed control required. The issue will be covered on checked on inspection and controlled through application of residual BAT where required if the controls applied require revisiting.

5.21 Consideration of BAT The proposed plant will be covered by the scope of the EU Industrial Emissions Directive (IED) and subject to any BAT conclusions required in the sector specific BAT Reference (BREF) documents applicable. The current BREF for the food and drink sector is under review with the first draft issued. As

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 FINAL Page no: 30 of 48 Permit (Application) Number: PPC_A_1163789 Applicant: Marine Harvest (Scotland) Ltd such consideration has been given to the potential BAT Conclusions in order to future proof the Permit as far as is practicable however until such time that they are finalised and published the associated performance criteria required by BAT conclusions have not been set.

The application has included a tabulated BAT assessment in Appendix 3 to the Supporting Document, which has been compiled referring to the existing published food and drink (FDM) sector BREF Note, dated 2006. SEPA notes that cognisance has been given in footnotes to the more recently circulated first draft of the revised FDM sector BREF note: “Best Available Techniques (BAT) Reference Document in the Food, Drink and Milk Industries” Industrial Emissions Directive 2010/75/EU. First Draft (January 2017). Link here: http://eippcb.jrc.ec.europa.eu/reference/BREF/FDM/FDM_31-01-2017-D1_BW.pdf

SEPA considers that the applicant has followed a precautionary rationale by referring to the 2006 published BAT, in the first instance, though the draft 2017 BAT-AELs for discharges to the water environment were cited in the risk assessment work for the marine discharge, given that the 2006 published BAT was indicative BAT only (narrative).

SEPA has included comparison of the application fulfilment against BAT Conclusions in the preceding section headings within Section 5 of this document.

SEPA has included in Appendix 2 to this document an extract of BAT Conclusions from the first draft of the revised FDM sector BREF note (January 2017).

SEPA considers that the applicant has demonstrated that the proposed activities represent BAT (as it currently stands) and will confirm this understanding on inspection.

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? No

Justification: An assessment was submitted in the application supporting document, Appendix 2 - Chapter 6 Air Quality Technical Appendix (including Stack Height Assessment) 01 Dec 2016.

SEPA conducted a review internal ecology support which concluded that the activity passed the screening test. No further assessment was actioned.

It was noted that the only site where the PC >1% AND PEC > 100% was the pSAC which is designated for harbour porpoise – neither the porpoise itself nor its habitat are sensitive to nitrogen deposition, therefore no critical load applies. The applicant appears to have used the minimum critical load of 5 to be precautionary, this is not necessary or correct where it is known that the habitat and species are not sensitive.

Other legislation?

MCPD The Pollution Prevention and Control (Scotland) Amendment Regulations 2017 came into force on 19th December 2017. These bring into force the requirements of the Medium Combustion Plant Directive. The regulations will apply to any new plant coming into operation after 20 December 2018

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 FINAL Page no: 31 of 48 Permit (Application) Number: PPC_A_1163789 Applicant: Marine Harvest (Scotland) Ltd and to existing plant in 2024/2029 depending on size. The applicant has committed to installing an appropriate MCPD-compliant boiler even if the new plant is operational before the date of 20 Dec 2018. The implication of this is that the boiler stack is required to undergo periodic air emissions monitoring. The permit includes these requirements in Condition 4.1.1 and associated tables. See also Section 9 below.

The dryers employed on site are deemed to be out with the scope of MCPD as they are considered to be ‘combustion plants in which the gaseous products of combustion are used for the direct heating, drying or any other treatment of objects or materials’.

Marine Licence consultation, June 2017 Within the pre-application period, SEPA had been formally consulted on the Marine Licence application for site construction and capital dredging development at the coastal foreshore location. Specialist support was obtained internally to assess the ocean modelling and chemistry (marine) aspects of the licence application documents. Specialists in both these aspects were satisfied that appropriate methods and guidance had been followed. SEPA confirmed that the applicant’s submitted methodology on establishing the extent of the long sea outfall was acceptable, but expressed the view that under PPC, details of the two-stage water effluent treatment process were required to determine ability of the chosen process to a) meet BAT and b) achieve water quality standards in order to protect the marine environment. This was subsequently determined under the PPC application process that followed.

SEPA understands that Marine Scotland as regulator has a role for future ecological assessments after construction and capital dredging.

F-gas plant and equipment - Fluorinated Greenhouse Gases (F Gas) and Ozone Depleting Substances (ODS) SEPA has established from the applicant that the manufacturing plant “Cooling plant / cool room” refrigerants and system for cooling would use glycol as the refrigerant, which has ruled out the presence of any F gases / Ozone Depleting Substances. This legislation does not therefore apply.

SEPA notes that the refrigerant glycol is used for cooling of product, held in in a sealed system indoors over concrete flooring. Not included in site inventory in Site Report or raw materials tables. Glycol is not a consumable in the process, but usage (top ups) to be recorded for Resource Efficiency.

[1st draft revised FDM BREF: BAT 9. “In order prevent or reduce emissions of harmful substances in cooling and freezing, BAT is to use refrigerants without ozone depletion potential and with low global warming potential.”]

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?

In the period prior to the submission of the PPC application, SEPA had been formally consulted on an Environmental Impact Assessment (EIA) conducted as part of an application to the local planning authority for planning permission for “The erection of a salmon feed manufacturing plant including an extension to the existing pier - Final ES”. Over the duration of the consultation period, SEPA undertook review of the EIA’s Environmental Statement (ES), and a detailed response was compiled to the planning consultation. The response included key aspects significant to the determination of a future PPC permit required for

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 FINAL Page no: 32 of 48 Permit (Application) Number: PPC_A_1163789 Applicant: Marine Harvest (Scotland) Ltd the intended manufacturing plant. Throughout, SEPA noted the additional information requirements the applicant would need to supply towards the PPC permit application and its initial duly made check process.

The preparation of the planning response had included a site visit to the former quarry at Allt-An-Avaig, Kyleakin, followed by detailed review of the sections of the ES and supporting assessments dealing with air quality, odour abatement, surface water drainage systems including oily water interceptors, process effluent water treatment and marine discharge, and noise. The review included input from a number of subject specialists within SEPA. Key aspects significant to the determination of a future PPC permit required for the activity were tracked. A key outcome from this stage concerned the water discharge, such that the treated process effluent would be required to discharge to marine receiving waters rather than to a freshwater burn as originally intended. The planning response reflected this outcome, and modifications were made to accommodate a long sea outfall from the effluent treatment plant, with details further developed during the PPC pre-application period.

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? Yes – pending.

A COMAH notification has been received by the COMAH Competent Authority. The proposed development is subject to the COMAH regulations and is designated as an Upper Tier Establishment. As such the operator has submitted a pre-construction Safety Report, and assessment is pending at the time of PPC permit determination. Issues identified on assessment of the COMAH Pre Co SR have been considered, where relevant, on determination of this application determination.

8 DETAILS OF PERMIT

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

Condition numbers: 3.4.1 to 3.4.10 inclusive for “Commissioning”.

3.4 Commissioning

3.4.1 The Operator shall not carry out any Permitted Activities except as part of Commissioning Activities notified to SEPA in compliance with Condition 3.4.3, until Conditions 3.4.2 to 3.4.8 inclusive have been complied with, and the Operator has received confirmation from SEPA in writing that those conditions have been complied with.

3.4.1.1 Prior to carrying out the Commissioning Activities the design features necessary to ensure compliance with any condition of this Permit shall be checked and functional test completed, to ensure they have been installed as per design. The scope and outcome of said checks and tests shall be reported to SEPA.

3.4.2 At least 14 days, or such period as otherwise agreed in writing with SEPA, prior to carrying out any further Commissioning Activities after the date of this Permit, the Operator shall notify SEPA in writing of a Commissioning plan which shall include the following:

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(a) details of all Commissioning work that has been carried out or which has commenced, prior to the date of this Permit, including any test undertaken and the dates on which said work was started and completed; (b) details of the work to be carried out including each test required by Condition 3.4.4; (c) an assessment of any environmental impact which the said work may have; (d) the proposed dates on which the said work will be started and completed; and (e) the criteria for determining when the Commissioning Activities have ceased.

3.4.3 When carrying out the Commissioning Activities the Operator shall carry out tests to demonstrate that the Permitted Installation can be operated after the Commissioning Activities are complete so as to comply with any condition of this Permit;

3.4.4 For the period of the Commissioning Activities the Operator shall submit a monthly report containing a summary of: (a) any Commissioning Activities undertaken during the preceding month; (b) details of all tests carried out under Condition 3.4.4 during the preceding month; (c) the results of any such tests received during the preceding month; (d) justification for any delays from the dates notified under Condition 3.4.3 d); and (e) where appropriate, confirmation that the criteria detailed in the notification required by Condition 3.4.3 e) have been met.

3.4.5 The first monthly report required by Condition 3.4.5 shall include a summary of any Commissioning work undertaken prior to the date of this Permit and detail the information required by Condition 3.4.5 for said activities.

3.4.6 Notwithstanding any other condition in this Permit, should any test required by Condition 3.4.4 fail to demonstrate that the Conditions of the Permit can be complied with, the Operator shall cease carrying on the part of the Commissioning Activities which is the subject of the test, until a report has been prepared and submitted to SEPA stating the measures proposed by the Operator to comply with the Conditions of this Permit and SEPA has agreed those proposals in writing.

3.4.7 Within one month of Cessation of Commissioning, the Operator shall prepare and submit to SEPA a written report which demonstrates that all of the conditions of the Permit can be and are being complied with in full.

3.4.8 Unless SEPA agrees in writing otherwise, prior to the commencement of commissioning of the permitted activities, the Operator shall prepare and thereafter maintain a commissioning plan which sets out how it intends to commission in a manner so as to comply with any Condition of this Permit.

3.4.9 All testing undertaken in accordance with condition 3.4.2 shall be recorded.

3.4.10 The Operator shall prepare a report in respect of the commissioning of any change in operation for which a commissioning plan was required under Condition 3.4.1. The said report shall be completed no later than 3 months from the end of the commissioning and reported to SEPA.

Justification:

These conditions have been utilised previously in permits for new installations and are contained within the SEPA “Bank of Conditions”. SEPA considers that the operator will be supported by the addition of commissioning conditions in place, as well as demonstrating compliance, in that it allows for potential non-compliance while the plant is being optimised while at the same time ensuring that

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the environment is protected. Communication routes will be expected to be defined and individuals with responsibilities named. On the sampling and monitoring requirements, SEPA would expect that the effort could be scaled back as performance settles, through trends identified with the incoming data. Test methods are specified in the permit already, and this is taken directly from relevant BAT Conclusions, so deviation is precluded.

Do you propose making changes to existing text, tables or diagrams within the permit? No

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? Yes

Emission limit values Air

Substance: Oxides of Nitrogen (NOx)

Relevant emission benchmarks: 100 mg/Nm3

ELV: 100 mg/Nm3

Emission point: A2

Rationale: Compliance with the Pollution Prevention and Control (Scotland) Amendment Regulations 2017, which came into force on 19th December 2017 bringing into force the requirements of the Medium Combustion Plant Directive. The steam boiler will be fuelled by liquid natural gas (LNG) with the steam generation plant comprising a capacity of 7.9 megawatts (MW) net rated thermal input, with combustion gases released to atmosphere via the boiler air stack (emission point A2). The steam boiler is specified as LNG-fuelled and new plant with a rating of between 1 and 20 MW net rated thermal input, and therefore must comply with the requirements set under the relevant ELV table, which for NOx is 100 mg/m3. The monitoring requirements have been specified in Condition 4.1.2 and associated tables.

Details of any equivalent technical parameters adopted to supplement or replace ELVs: None

Substance: Dust

Relevant emission benchmarks: Industry standard for visual monitoring of stacks

ELV: No visible dust during operation

Emission point: A1

Rationale: A visual assessment for dust has been applied, with the monitoring requirements specified in Condition 4.1.2 and associated tables.

A quantitative monitoring parameter was considered for inclusion at the biofilter stack for compliance with indicative BAT of 5 - 20 mg/Nm3 (dry dust), cited within European Commission’s BAT (Best Available Techniques) Reference Document (BREF 0806 Food Drink and Milk Industries) August

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2006; also, BAT-AEL of 2 – 5 mg/m3 cited within the current first draft revised FDM BREF Jan 2017, BAT Conclusion 5 (pointing to BATC 17 and18). Link here: http://eippcb.jrc.ec.europa.eu/reference/BREF/FDM/FDM_31-01-2017-D1_BW.pdf

BATC 17: “to reduce dust emissions to air from processing of grain based feed” BATC 18: “for dust emissions to air from the extrusion process in compound feed manufacture”

After consideration of the application supporting information, SEPA has concluded that a quantitative dust monitoring requirement is inapplicable, because the air flows from the relevant processes at the manufacturing plant, under the heading “animal feed” - “the processing of grain feed” and “extrusion (manufacture of compound feed)” pass first through either one of a bag filtration process or a high efficiency cyclone prior to the biofilter for odour abatement (treatment). There is no direct release to air from the mill or extruders. No BATC or BAT-AEL was found for dust monitoring of air emissions from biofilters.

At commissioning, the operator will be expected to demonstrate through commissioning tests that concentrations of dust emitted are within the performance criteria specified for the biofilter.

Details of any derogations from the ELVs set out in the BAT conclusions; None

Has an Annex been inserted to the permit containing reasons, assessment and justifications for setting the value: No

Details of any temporary derogation for the use of emerging techniques. NB Such temporary derogations do not require PPD consultation or the insertion of reasons etc. into the permit No

Emission limit values Water

Substance: Biochemical oxygen demand BOD5 (mg/l)

Relevant emission benchmarks: BOD5 indicative BAT # : < 25 mg/l Total organic carbon BAT-AEL* : 10 – 33 mg/l

ELV: 6 mg/l

Emission point: W1

Rationale: Operator-specified parameter based on ETP performance specification. No marine EQS found. See also dilution factor discussion at Section 5.3.1 of this document.

* Table 17.3 BAT-associated emission levels (BAT-AELs) for direct emissions to a receiving water body. European Commission. Best Available Techniques (BAT) Reference Document in the Food, Drink and Milk Industries, revised. First Draft (January 2017)

# European Commission. BAT (Best Available Techniques) Reference Document (BREF 0806 Food Drink and Milk Industries) August 2006

Substance: Chemical oxygen demand COD (mg/l)

Relevant emission benchmarks: COD BAT-AEL * : 30-100 mg/l COD indicative BAT # : < 125 mg/l

ELV: 105 mg/l

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Emission point: W1

Rationale: Operator-specified parameter based on ETP performance specification. No marine EQS found. See also dilution factor discussion at Section 5.3.1 of this document.

Substance: Total suspended solids TSS (mg/l)

Relevant emission benchmarks: TSS BAT-AEL * 4-65 mg/l TSS indicative BAT # < 50 mg/l

ELV: 14 mg/l

Emission point: W1

Rationale: Operator-specified parameter based on ETP performance specification. No marine EQS found. See also dilution factor discussion at Section 5.3.1 of this document.

Substance: pH (-)

Relevant emission benchmarks: pH indicative BAT # 6 - 9

ELV: 6 – 9 mg/l

Emission point: W1

Rationale: Operator-specified parameter based on ETP performance specification. No marine EQS found. See also dilution factor discussion at Section 5.3.1 of this document.

Substance: Oil and grease (mg/l)

Relevant emission benchmarks: Oil and grease indicative BAT # < 10 mg/l

ELV: 10 mg/l

Emission point: W1

Rationale: Operator-specified parameter based on ETP performance specification.

Substance: Total Nitrogen (mg/l)

Relevant emission benchmarks: Total Nitrogen BAT-AEL * 2-20 mg/l Total Nitrogen indicative BAT # < 10 mg/l

ELV: 17 mg/l

Emission point: W1

Rationale: Operator-specified parameter based on ETP performance specification. Design of long sea outfall directly informed by ensuring the achievement of the marine EQS for ammonia. See Section 5.3.1 of this document.

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Substance: Total Phosphorus (mg/l)

Relevant emission benchmarks: Total phosphorus (TP) BAT-AEL * 0.2 - 6 mg/l Total phosphorus (TP) indicative BAT # 0.4 - 5 mg/l

ELV: 4 mg/l

Emission point: W1

Rationale: Operator-specified parameter based on ETP performance specification. No marine EQS found - soluble orthophosphate standard is applicable to rivers only and Total P is only used to classify Lochs and is therefore not applicable in this instance.

Substance: Visual characteristics

Relevant emission benchmarks: General surface water inspection parameter (s53 PPC manual)

ELV: No visible discolouration, iridescence, foaming or sewage fungus

Emission point: W1

Rationale: Operator expectation and observation parameter based on ETP’s performance specification and SUDS function.

Substance: Visible oil

Relevant emission benchmarks: Oil and grease indicative BAT # < 10 mg/l

ELV: No visible oil or sheen

Emission point: W1

Rationale: Operator expectation and observation parameter based on oily water interceptors’ + ETP’s performance specification.

Has an Annex been inserted to the permit containing reasons, assessment and justifications for setting the value NO

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

Emission limit values Land - NONE

Emission limit values Noise and Vibration - NONE

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10 FINAL DETERMINATION

Issue of a Permit - Based on the information available at the time

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/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.

11 REFERENCES AND GUIDANCE

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

European Commission. BAT (Best Available Techniques) Reference Document (BREF 0806 Food Drink and Milk Industries) August 2006

European Commission. Best Available Techniques (BAT) Reference Document in the Food, Drink and Milk Industries, revised. First Draft (January 2017)

Environment Agency October 2005. M1 Technical guidance Note (Monitoring), Sampling requirements for stack-emission monitoring, Version 3.

Environment Agency June 2005 M2 Technical guidance Note (Monitoring), Monitoring of stack emissions to air, Version 3.1.

Environment Agency September 2005. M20 Technical guidance Note (Monitoring), Quality assurance of continuous emission monitoring systems – application of BS EN 14181 and BS EN 13284-2, Version 1.

Environment Agency April 2006. Use and design of oil separators in surface water drainage systems: PPG 3

SEPA Odour Guidance (2010). SEPA WAT-RM-04: Regulation of Indirect Sewage Discharges to Groundwater SEPA WAT-SG-05: Point Source Discharge Constituents SEPA WAT-SG-11: Modelling Coastal and Transitional Discharges SEPA WAT-SG-53: Environmental Quality Standards and Standards for Discharges to Surface Waters SEPA WAT-SG-79: Priority Hazardous Substances Licence Reviews - Guidance SEPA intranet Section 5.3 PPC manual - General – Surface Water SEPA. IED-TG-02 (2013) PPC Technical Guidance Note: CONTENT AND SCOPE OF SITE REPORTS SEPA. IED-TG-42 (2016) Soil and Groundwater Monitoring Technical Guidance for Part A Installations

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APPENDIX 1

SECTION 5.17 – Noise SEPA observations recorded under determination. • The topography (high barrier walls) of former quarry site are expected to provide excellent sound attenuation and the prediction is for low ambient sound levels at the nearby residential properties. • The noise management plan is comprehensive. • The commitment to verification surveys and measurements as part of the commissioning program is good practice. SEPA offers the following observations: 1. taking the manufacturers weighted sound reduction (RW) values of 27-30dB for individual cladding panels and assuming the building envelope will perform to that standard once constructed is likely to overestimate the sound attenuation of the finished building (it does not consider the standard of construction, gaps and penetrations, joints, holes, ventilation openings, doors, etc which can reduce performance by ~10dB); and 2. roller-shutter doors would need to be of a very high spec and installed with great care to get anywhere near an in use RW values of 30dB (again, as built values have been noted at 17-20dB attenuation when closed, less when open); 3. the question previously asked about the potential for stack noise has been answered but not adequately in SEPA’s opinion (an elevated sound source will not benefit from the shielding provided by quarry walls to the same extent as low lying sources, previous assessment of stack noise were taken near the stack base and so potentially in the acoustic shadow of the actual emission point); 4. there is no great detail on potential noise emissions from the pier end activities (materials transfer, and ship idling) although the commitment to electric hook ups is welcomed; and finally 5. the main noise sources are identified as the biofilter system and noise breakout from the main processing building. The BAT demonstration for these aspects is not particularly detailed – it could be argued that this is a proportionate approach as the overall impact is predicted to be low. However, see above comments on building envelope and stack noise. Any further low noise design or post-commissioning sound attenuation works should focus on these areas. The sound emissions may therefore be greater than predicted. However, it is not certain that the overall off-site impact would be an issue. It is suggest that the above comments are recorded as part of the determination process and make the Applicant aware of the risk (i.e. it is for them to investigate and potentially retrofit / modify kit if the plant noise emissions are not as predicted by the sound model).

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APPENDIX 2 SECTION 5.21 – Consideration of BAT

Best Available Techniques (BAT) Reference Document in the Food, Drink and Milk Industries Industrial Emissions Directive 2010/75/EU (Integrated Pollution Prevention and Control)

JOINT RESEARCH CENTRE Directorate B – Growth and Innovation Circular Economy and Industrial Leadership Unit European IPPC Bureau First Draft (January 2017)

BAT 1. In order to improve the overall environmental performance, BAT is to implement and adhere to an environmental management system (EMS) that incorporates all of the following features: (listed I to XII) BAT 2. In order to facilitate the reduction of emissions to water and air and the reduction of water usage, BAT is to establish and to maintain an inventory of waste water and waste gas streams, as part of the environmental management system (see BAT 1), that incorporates all of the following features: BAT 3. For relevant emissions to water as identified by the inventory of waste water streams (see BAT 2), BAT is to monitor key process parameters (including continuous monitoring of waste water flow, pH and temperature) at key locations (e.g. influent to pretreatment and influent to final treatment) BAT 4. BAT is to monitor emissions to water with at least the frequency given below and in accordance with EN standards. If EN standards are not available, BAT is to use ISO, national or other international standards that ensure the provision of data of an equivalent scientific quality BAT 5. BAT is to monitor emissions to air with at least the frequency given below and in accordance with EN standards. If EN standards are not available, BAT is to use ISO, national or other international standards that ensure the provision of data of an equivalent scientific quality. BAT 6. In order to increase energy efficiency, BAT is to use one or a combination of the techniques given below. Heat recovery; Use of biogas by AD BAT 7. In order to reduce water consumption and the volume of waste water discharged, BAT is to use BAT 7a and a combination of the techniques given below. Water recycling; control devices; optimisation of nozzles; segregation; cleaning operations list BAT 8. In order prevent or reduce the use of harmful chemicals in cleaning and disinfection, BAT is to use a combination of techniques given below. BAT 9. In order prevent or reduce emissions of harmful substances in cooling and freezing, BAT is to use refrigerants without ozone depletion potential and with low global warming potential. BAT 10. In order to reduce the quantity of waste sent for disposal, BAT is to use one or a combination of the techniques given below. AD; residues as feed; separate residues; recover &reuse BAT 11. In order to prevent uncontrolled emissions to water, BAT is to provide an appropriate buffer storage capacity for waste water generated during other than normal operating conditions based on a risk assessment (taking into account the nature of the pollutant, the effects on further treatment, the receiving environment, etc.), and to take appropriate further measures (e.g. control, treat, reuse). BAT 12. In order to reduce emissions to water, BAT is to use an appropriate combination of the techniques given below. Preliminary and primary treatment a Equalisation b Neutralisation c Physical separation, e.g. screens, sieves, grit separators, oil/fat

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separators or primary settlement tanks Biological treatment (secondary treatment) d Activated sludge process e Aerobic lagoon f Upflow anaeorobic sludge blanket (UASB) Nitrogen removal h Biological nitrification and denitrification Phosphorus recovery and/or removal Final solids removal l Coagulation and flocculation m Sedimentation n Filtration (e.g. sand filtration, microfiltration, ultrafiltration o Flotation

17.1.7.1 BAT-associated emission levels for emissions to water

The BAT-AELs apply at the point where the emission leaves the installation.

BAT 13. In order to prevent or, where that is not practicable, to reduce noise and vibration emissions, BAT is to set up, implement and regularly review a noise and vibration management plan, as part of the environmental management system (see BAT 1), that includes all of the following elements: I to IV BAT 14. In order to prevent or, where that is not practicable, to reduce noise and vibration emissions, BAT is to use one or a combination of the techniques given below. a Appropriate location of equipment and buildings b Operational measures c Low-noise equipment d Noise and vibration control equipment e Noise abatement

BAT 15. In order to prevent or, where that is not practicable, to reduce odour emissions, BAT is to set up, implement and regularly review an odour management plan, as part of the environmental management system (see BAT 1), that includes all of the following elements: (list)

17.2 BAT conclusions for animal feed

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BAT 16. In order to increase energy efficiency in green fodder processing, BAT is to use one or a combination of the techniques given below. BAT 17. In order to reduce dust emissions to air from processing of grain-based feed, BAT is to use a bag filter.

BAT 18. In order to reduce dust emissions to air from the extrusion process in compound feed manufacture, BAT is to use one or both of the techniques given below. a Bag filter b Bioscrubber c Cyclone BAT 19. In order to reduce odour emissions from compound feed and/or pet food production, BAT is to use one of the techniques given below. a Biofilter b Bioscrubber c Non-thermal plasma treatment

17.14.1 Waste water treatment

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17.14.2 Treatment of emissions to air

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APPENDIX 3 5.20 Site Condition Report

Checklist for Initial Site Report. FAIRHURST OCTOBER 2017. Marine Harvest (Scotland) Ltd . Fish feed plant, Kyleakin, Isle of Skye. Application for a permit to operate a Part A Installation under the PPC(S) Initial Site Condition Report.

Item y Comment n 12 Stage 1: Identification of Substances Used at the Installation 1 Has a list of substances at the installation Y Table 15 under Section 11.0 Potentially Polluting been produced? (raw materials, products, Substances by-products, intermediaries, wastes, auxiliaries) 2 Are there any substances which have N None known obviously been omitted? Note that Liquefied Natural Gas (LNG) is not listed. This is the boiler fuel to be used and stored on site, however, its properties makes it a fire/explosion risk and it is deemed not to be presenting a specific risk to the water environment in the usage intended at Kyleakin NB. The refrigerant glycol is used for cooling of product, held in in a sealed system indoors over concrete flooring. Not included in site inventory in Site Report or raw materials tables. Glycol is not a consumable in the process, but usage (top ups) to be recorded for Resource Efficiency. 13 Stage 2: Identification of Relevant Hazardous Substances and which have a theoretical pollution potential 3 Have Relevant Hazardous Substances been Y Diesel is the only substance identified with “High” pollution identified? risk, with a maximum quantity of approx. 100 litres to be stored on site. Has the theoretical pollution potential of all other sub-stances been determined based on chemical and physical data? e.g. mobility, persistence, state etc 14 Stage 3: Assessment of site specific pollution potential 4 Has the site specific pollution potential been Y A brief indication has been provided in Section 12.2 which determined based on an assessment of the assesses that “will therefore not present a significant risk of quantity used, adequacy and integrity of pollution to the environment due to the primary secondary containment mechanisms for delivery, and tertiary infrastructure control measures that are to be handing, storage, use and disposal of implemented at the site”. substances etc? 5 Have the substances of concern been Y Table 15 identified and their selection justified? 6 Have the likely areas/points of emission Y Section 12.2 been identified? 15 Stage 4: Site History 7 Has the potential for these substances to be Y Good assessment has been provided through the BAM present as a result of activities prior to Ritchie ground investigation undertaken Nov 2015 to Feb operation under PPC been considered 2016, referred to in detail in Section 8.0 Historical Ground through review of site history? Investigation and assessment. This was supported by a site reconnaissance and walkover (Section 5.7), an Envirocheck Report for Marine Harvest, dated Sept 2015. Fairhurst also carried out a historical map review (Section 7.1) and consulted widely to gather additional records or

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Item y Comment n information on pollution incidents from relevant regulatory authorities listed in Table 4 under Section 3.4. 8 Do areas of historic contamination overlap N Section 8.0 shows that the investigation has considered the with potential future emission points? contaminants of concern based on past uses of site, with respect to the hazardous substance (diesel) that will be used on site under the PPC permitted installation. However it should be noted that diesel storage is not indicated to be in the same location (TBC after site construction is complete). 16 Stage 5: Site Environmental Setting 9 Has the environmental setting of the site Y Fairhurst Section 8.0 been considered to determine which strata and groundwater bodies could be affected by emissions and the extent and depth to which the site should be characterised? e.g. by consideration of topography, geology, hydrogeology and hydrology. 10 Have potential flow paths through the sub Y Fairhurst Section 8.0 surface been considered? e.g. drains, services, faults, mines. 17 Stage 6: Conceptual Site Models 11 Has a cross section or conceptual site model N No diagrammatic CSM has been developed. However, this been developed identifying emission points is proportionate given the text of Section 8.0, and the and the extent to which these may impact on remedial action undertaken regards the localised hotspot of the surface, sub-surface and groundwaters? TPH at RBH10, which was removed and disposed of off- site. 18 Stage 7: Site Investigation (Required for Baseline Report) 12 Can the site be adequately characterised N Fairhurst Section 8.0 details the site investigation without a site investigation? (if yes go to item undertaken. 18 – Note: Measured soil and groundwater data is required for relevant hazardous substances) 13 Has a site investigation been undertaken? Y BAM Ritchie ground investigation undertaken Nov 2015 to (either specifically for PPC or has old data Feb 2016, referred to in detail in Fairhurst report Section been used) 8.0 Historical Ground Investigation and assessment. 14 Were samples obtained at appropriate Y Fairhurst report Section 8.0 . depths in strata and groundwaters likely to See Table 8 “Ground Investigation rationale for be impacted by potential emissions / historic environmental purposes” and Table 9 “Ground contamination? Investigation environmental sampling and testing regime”. 15 Has analysis been undertaken for Y Focusses on diesel and Total Petroleum Hydrcarbons appropriate substances? (TPH) and polyaromatic hydrocarbons (PAH) results from the soil and groundwater monitoring, but this is appropriate and proportionate. 16 Where screening or marker substances have Y As above been used are these considered appropriate? 17 Were the samples taken and analysed using Y Appropriate monitoring and chain of custody procedures appropriate quality assured methods, referred to in report. acceptable limits of detection, accuracy and precision? 19 Stage 8: Statement of Site Condition

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Item y Comment n 18 Is a clear statement on site condition Y Fairhurst report Section 8.5 “Summary of existing site presented? condition” 19 Does it cover all substances which have a Y Focusses on diesel and Total Petroleum Hydrocarbons pollution potential? (TPH) and polyaromatic hydrocarbons (PAH) results from the soil and groundwater monitoring, but this is appropriate and proportionate. 20 Has groundwater quality been used as an - Both soil and groundwater sampling was undertaken indicator of ground / soil quality and is it an appropriate indicator? 21 Have soil and groundwater measurements Y The primary relevant hazardous substance in liquid form been provided for relevant hazardous namely diesel (100 litres), was represented by TPH /PAH substances? results from the soil and groundwater monitoring. 22 Has the statement on site condition been Y Statement is supported by appropriate and robust process fully justified? of desk study, data collection and interpretation. Fairhurst refer in section 1.1 to fulfilment of requirements of SEPA guidance IED-TG-02. 23 Is it considered to be representative of the Y Yes, for reasons as above. actual site condition?

Contd.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 FINAL Page no: 47 of 48 Permit (Application) Number: PPC_A_1163789 Applicant: Marine Harvest (Scotland) Ltd

APPENDIX 3 cont. SEPA guidance IED-TG-42 - Proforma 1 (Likelihood of Release) - completed following Aide Memoire 1, based on application details, to determine appropriate soil and groundwater monitoring requirements - “as built” conditions to be confirmed at commissioning and during PPC inspection

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 FINAL Page no: 48 of 48