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

Tradebe Healthcare National Ltd

Bellshill Healthcare Treatment and Transfer Site

Permit Application

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

CONTENTS

TRADEBE HEALTHCARE NATIONAL LTD...... 1 BELLSHILL HEALTHCARE AND TRANSFER SITE ...... 1 CONTENTS ...... 1 1 NON TECHNICAL SUMMARY OF DETERMINATION...... 3 2 EXTERNAL CONSULTATION AND SEPA’S RESPONSE ...... 5 3 ADMINISTRATIVE DETERMINATIONS...... 7 4 INTRODUCTION AND BACKGROUND ...... 7 4.1 Historical Background to the activity and application ...... 7 4.2 Description of activity...... 7 4.3 Guidance/directions issued to SEPA by the Scottish Ministers under Reg.60 or 61...... 8 4.4 Identification of important and sensitive receptors...... 9 5 KEY ENVIRONMENTAL ISSUES...... 10 5.1 Summary of significant environmental impacts ...... 10 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...... 15 5.5 Fugitive Emissions to Air ...... 16 5.6 Fugitive Emissions to Water ...... 16 5.7 Odour...... 17 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

5.8 Management...... 20 5.9 Fit and Proper Person...... 21 5.10 Raw Materials...... 22 5.11 Raw Materials Selection ...... 22 5.12 Requirements ...... 22 5.13 Water Use ...... 22 5.14 Waste Handling...... 23 5.15 Waste Recovery or Disposal ...... 23 5.16 Energy...... 23 5.17 Accidents and their Consequences...... 24 5.18 Noise...... 24 5.19 Monitoring ...... 24 5.20 Closure ...... 28 5.21 Site Condition Report (and where relevant the baseline report) ...... 28 5.22 Consideration of BAT ...... 28 6 OTHER LEGISLATION CONSIDERED...... 29 7 ENVIRONMENTAL IMPACT ASSESSMENT AND COMAH ...... 30 8 DETAILS OF PERMIT ...... 31 DO YOU PROPOSE PLACING ANY NON STANDARD CONDITIONS IN THE PERMIT? YES...... 31 8.2 Waste Pre-Acceptance...... 31 9 EMISSION LIMIT VALUES OR EQUIVALENT TECHNICAL PARAMETERS/ MEASURES...... 33 11 FINAL DETERMINATION...... 34

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

1 NON TECHNICAL SUMMARY OF DETERMINATION

PPC requires that where the draft determination of an application or a SEPA initiated variation is to 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/proposed SEPA initiated variation be subject to public consultation? Yes

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

The Bellshill site will manage clinical waste disposal in Scotland primarily for waste produced by NHS Scotland (NHSS) trusts, but could also include waste arising from private hospitals, pharmacies, care homes, beauticians and veterinary practices. The waste will be brought back to the site where, depending on waste type, it will be either bulked up and sent off site for or disposal at or treated on site via a shredder, steam auger and drier, before compaction. The objective of the waste treatment process proposed for Bellshill is to disinfect clinical waste with heat to render it safe and unrecognisable, and to produce a waste floc that meets a specification suitable for use in an Energy from Waste Plant. It is proposed that the installation will handle 24, 900 tonnes of waste per annum. The applicant has applied for a new PPC permit to carry out the following activities at the site:  transfer;  Treatment of clinical waste using thermal screw auger(s);

The waste treatment process will be supported by natural gas powered boilers to provide heat to generate steam, natural gas burners to provide warm air for the drier (indirect heating), enclosed automatic bin washers and a vehicle washdown area. The vast majority of waste received is typically classified as solid as although there is the potential for a small amount of liquid within the waste, the amount of absorbent and other dry waste in the waste stream results in the waste being solid. Any liquid received at the site will be stored in containers within a bunded area. Different liquid wastes will be kept segregated to ensure there is no cross contamination with other wastes accepted at the site. All waste accepted at site will be inspected, weighed and documentation checked to ensure it is permitted for acceptance. Waste for treatment will be tipped into a shredder hopper fitted with an extraction hood and will be maintained under negative pressure to ensure all airborne pathogens are contained and filtered. Once shredded the waste will then pass through a screen into the thermal screw auger. The thermal screw system is a continuous feed process consisting of a rotating screw system to treat and transmit the shredded waste. Steam is produced by the boilers and is injected into the steam jacket on the thermal screw auger and via “live” steam injection to disinfect the waste. Steam will be provided at a temperature of 122oC. The thermal screw auger has an air extraction system which maintains a negative pressure and minimizes the potential for diffuse emissions to air from the thermal screw auger system. The residence time in the thermal screw auger system is approx. 80 minutes Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd which has been determined to be adequate to disinfect the waste to make it microbiologically inactive (rendered “safe”). Steam will be injected both direct into the waste at the bottom of the steam auger and into the auger shaft at the top to ensure maximum exposure to heat as the waste travels through the auger system. The steam auger length is 19m long to ensure sufficient residence time. From the thermal screw system, the waste is then routed via a sealed screw auger directly into the drier system where hot air at approximately 80oC (provided by an indirect gas-fired burner system) is introduced. The drier will treat waste at a rate of around 2,000kg/hour. The residence time in the drier system will be approx. 80 minutes. From the drier the waste is transported directly by conveyor/screw outside the main building into sealed waste compactors. THNL propose to use deep push compactors and the surface on which the compactors are located will be impermeable and will have a sealed drainage system. When full the compacted waste skips will be replaced and removed either temporarily into the main yard area to await transport offsite or moved directly offsite. Empty waste bins will be cleaned in a purpose built enclosed automatic bin washer which incorporates a water system. Bins will then be temporarily stored before being sent offsite for re-use. Some of the waste received at site will not be processed on-site but will be transferred offsite to another location (waste transfer operations). This waste will be stored within the building where possible. If this is not feasible it will be stored either in trailers or on impermeable surfaces and sealed drainage. Empty clean containers and waste bins will be stored in the main yard area to await use/re-use. Any dirty bins will be identified and washed in the provided facilities. Dirty containers and waste bins will be stored indoors if they cannot be washed immediately.

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

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

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

Glossary of terms

BAT - best available techniques CO - Co-ordinating Officer EA – Environment Agency ELV - emission limit value EWC – European Waste Catalogue IED - Industrial Emissions Directive SNH - Scottish Natural Heritage EPR 5.07 - How to comply with your environmental permit. Additional guidance for clinical waste EAL - environmental assessment limit MCPD – Medium Combustion Plan Directive NHSS – National Health Service Scotland NRW - Natural Resources Wales PPC - The Pollution Prevention and Control (Scotland) Regulations 2012 RHS – Relevant Hazardous Substance SSSI - site of special scientific interest SAC - special areas of conservation

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 4 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

THNL - Tradebe Healthcare National Limited

2 EXTERNAL CONSULTATION AND SEPA’S RESPONSE

Is Public Consultation Required - Yes

Advertisements Check: Date Compliance with advertising requirements

Edinburgh Gazette 26/4/19 yes

Motherwell Times 1/5/19 yes

Officer checking advert: Hilary Holding

No. of responses received: 0

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

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

Is PPC Statutory Consultation Required – Yes

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

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

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

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

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

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

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

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 5 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

Discretionary Consultation - Yes

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

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

Summary of response and actions taken: Letter sent out 17/4/19. Response received 23/5/19. Response raised the following concerns about the application–  Application lacks detail on how waste will be accepted and recorded on site.  Pre acceptance requirement - not specified in their tender response and has not been included as a contract requirement.  Incorrect description of ‘18 01’ EWC coded waste wastes originating from animals rather than human healthcare.  Documents relating to waste acceptance, non-conforming waste and rejection do not fully reflect Scottish practices and NHS Scotland would have liked to see examples of Scottish focused documents.  Proposed waste storage – not adequate for expected quantity of waste NHSS will be sending to the site.  Proposed use of domestic refrigeration units will not be adequate.  Vehicle movements – numbers of, inaccurate.  Waste quantities for transfer has been under estimated. NHSS data likely to be 10% plus.  Insufficient information provided on waste treatment testing protocols.

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

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

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

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

Enhanced SEPA public consultation - No

‘Off-site’ Consultation - No

Transboundary Consultation - No

Public Participation Consultation - Yes

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 6 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

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 – all STU and DAA activities are contained within the proposed permitted installation boundary

Officer: David Smith

GUIDANCE NOTES TECHNICAL DETERMINATION

4 INTRODUCTION AND BACKGROUND

4.1 Historical Background to the activity and application Tradebe have been awarded a contract with NHS Scotland to collect, transport, treat and dispose of healthcare waste from 18 NHS Health Boards in Scotland. Tradebe Healthcare National Limited, who will be the operators at the Bellshill site, are a subsidiary of Tradebe Environmental Services Ltd, whose ultimate parent company is Grupo Tradebe Medio Ambiente S.L. Tradebe Environmental Services manages 85 fixed plants in Europe (Spain, UK and France), the United States and Oman. Tradebe Healthcare provides the collection, transport, treatment and disposal of clinical waste. Tradebe Healthcare currently operate four other UK sites that are regulated under the Environmental Permitting Regulations (England and Wales). These sites are located in Rochester, Avonmouth, Redditch and Wrexham. The Bellshill site will manage clinical waste disposal in Scotland for a range of waste producers. This will primarily involve waste produced by NHS Scotland (NHSS) trusts, but could also include waste arising from private hospitals, pharmacies, care homes, beauticians and veterinary practices. The service will include collecting, transporting, treating and disposing of the clinical wastes. To enable Tradebe to begin their contractual arrangements with NHS Scotland they have made an application for a PPC Part A permit to undertake the required storage and treatment activities at Bellshill.

4.2 Description of activity

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 7 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

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

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

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

Waste accepted at site for treatment will be tipped into a shredder hopper. The waste will be fully enclosed by the shredder unit. The shredded waste will then be routed via a screen into the thermal screw auger system. An air extraction system maintains a negative pressure in the shredder system with the exhaust air being treated to remove dust and odour prior to discharge at elevation outside the process building. The thermal screw auger system consists of a rotating screw system to move the shredded waste through on a continuous basis. Steam is supplied via the boiler plant in a steam jacket on the thermal screw auger and via “live” steam injection to disinfect the waste. Steam is provided at a temperature of 122oC for 80 minutes to disinfect the waste and ‘render safe’ Steam will be injected both direct into the waste at the bottom of the steam auger and into the auger shaft at the top to ensure exposure to heat as the waste travels. The steam auger length is 19m long to ensure sufficient residence time. Again, air extraction fans maintain a negative pressure in the system to prevent fugitive emissions. The exhaust air is treated to remove moisture, dust and odour prior to being discharged at elevation outside the building. From the thermal screw system, the waste is then routed to the drier system where hot air provided by an indirect gas-fired burner system at approximately 80oC, is introduced. The drier will treat waste at a rate of approx. 2,000kg/hour. The residence time in the drier system will be approx. 80 minutes. The drier is maintained under negative pressure with the exhaust air being discharged at elevation outside the process building. From the drier the waste is transported by conveyor/screw outside the main building into deep push waste compactors located on impermeable surface and sealed drainage system. Empty waste bins will be cleaned in a purpose built enclosed automatic bin washer which incorporates a water recycling system. Bins will then be temporarily stored before being sent offsite for re-use. The bin wash will be connected directly to the foul sewer. Waste accepted on site for storage and transfer without treatment will be stored within the building on impermeable surface with sealed drainage. This waste will be bulked up and sent for final disposal elsewhere.

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

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

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

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 8 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

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

(a) the content of the decision, including a copy of the permit and any subsequent updates;(b) the reasons on which the decision is based; (c) in relation to an application for surrender of all or part of a permit for a Part A installation, any information provided in accordance with regulation 48(3)(d) and (4)(a);(d) in relation to the revocation of a permit for a Part A installation under regulation 50(3)(a) or (b), the revocation notice.

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

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

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

4.4 Identification of important and sensitive receptors

Human Health: The nearest dwelling housing is located approximately 420m from the eastern boundary of the site and 475m south of the site.

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

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

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

No SSSIs, SACs or SPAs within screening distance

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

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 9 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

Figure 1 - receptors

5 KEY ENVIRONMENTAL ISSUES

5.1 Summary of significant environmental impacts

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

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 10 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

Figure 2

5.2 Point Sources to Air

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

Emission Point 1 (EP1) – Boiler EP4 – Boiler EP2 - gas burner associated with the waste drier unit serving one of the two waste processing lines EP3 – Combined exhaust stack for one shredder and its associated thermal screw auger plus one waste drier. EP6 – Combined exhaust stack for the second shredder and its associated thermal screw auger. EP7 - Back up diesel generator

Taking each emission point in turn:

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

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 11 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

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

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

The relevant ELV’s for boilers between 1 and 5 MWth thermal input and firing on natural gas is 100 mg/Nm3 for oxides of Nitrogen. There is also a requirement to monitor for Carbon Monoxide however there is no associated ELV for this.

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

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

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

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

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

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

Operation of this gas burner will be listed as a directly associated activity to the main activities in schedule 1 of the permit. The applicant’s proposals meet with the requirements to use best available techniques and compliance with the permit conditions as drafted will ensure that risk to the environment and human health is minimised as far as possible. Emissions from this burner unit will discharge from a 3m stack ensuring sufficient dispersion is achieved.

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

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

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

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 12 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

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

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

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

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

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

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

For EP3 only:

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

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

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

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 13 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

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

BAT Conclusion ELV’s (from waste treatment BREF) – Treatment of healthcare waste is discussed briefly as ‘treatment of other waste’ in section 5.8.5 of the waste treatment BREF. There are no corresponding ELV’s for point source discharges to air provided in the BAT conclusions for either ‘treatment of other wastes’ or ‘treatment of healthcare waste’.

Nonetheless SEPA have placed requirements in the permit to monitor the following from EP3 & EP6 although there are no corresponding limits. If monitoring data does not support the applicants’ assurances that these parameters present minimal risk to the environment and human health then SEPA will impose appropriate limits with associated plant upgrade requirements.

Dust monitoring – details above.

Odour – BAT10 in the Waste treatment BREF states that BAT is to periodically monitor odour emissions (using dynamic olfactometry) where there is a risk of odour nuisance at receptors. Odour is considered one of the main risks of nuisance from this operation therefore the permit has a requirement to monitor for this. Quarterly monitoring for the first year then annual monitoring is considered appropriate. SEPA have not set an emission limit for this because the applicant have provided detailed modelling which predicts there should be no odour nuisance at any receptors. Once SEPA receives sufficient data on actual odour emissions from the waste treatment process we may consider inserting a condition limiting odour units at the emission points.

TVOC – details above.

5.2.1 Hazardous waste transfer No point sources to air identified.

5.3 Point Source Emissions to Surface Water and Sewer All emissions to water from the site will be routed via the site drainage system into the adjacent public sewer network systems as shown on Figure 3 . There are no emissions to water from the site directly to controlled waters (the water environment).

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

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

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

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

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

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

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 14 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

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

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

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

Figure 3

5.4 Point Source Emissions to Groundwater Hazardous waste transfer None identified. It is proposed that all liquid storage will be bunded to appropriate current standards, (i.e. 110% of the tank contents), and surfaces will be sealed to prevent fugitive emissions to groundwater.

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

Clinical waste treatment via thermal screw auger None identified. It is proposed that all liquids storage will be bunded to appropriate current standards, (i.e. 110% of the tank contents), and surfaces will be sealed to prevent fugitive emissions to groundwater.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 15 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

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

5.5 Fugitive Emissions to Air

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

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

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

Hazardous waste transfer Proposed dust controls include enclosed vehicles, sealed containers and bags for waste, visual inspections, waste handling within buildings and site speed limits. In addition, a spillage procedure will be in place.

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

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

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

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

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

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

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

5.6 Fugitive Emissions to Water Hazardous waste transfer None identified in the application. Much of the activity at the installation will be carried out inside buildings. Minimisation of fugitive emissions to water are addressed through the design and operation of the

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 16 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd installation, which specifies: use of bunds for liquid storage; impervious paving resistant to the materials stored for areas where wastes or process materials are received; stored or handled and a maintenance system requiring routine planned inspection of civil engineering assets such as bunds, drains, floors etc.

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

Clinical waste treatment via thermal screw auger As above

5.7 Odour

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

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

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

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

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

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

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

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

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

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

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 17 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd reduced to one during the course of determining the application for the reasons outlined below. The reasons for the applicant not installing abatement for this aspect of the process is also discussed below.

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

In their application Tradebe considered several options for discharge from the driers to demonstrate the use of BAT. This included different abatement technologies as well as dispersion from a stack with no abatement. Of the abatement technologies considered only 3 of 5 abatement suppliers provided a quote for a solution. All three opted for the installation of a chemical wet scrubber priced at around £100,000,000 (average over the 3 suppliers).

Given this cost of abating a relatively low inlet odour concentration Tradebe concluded that combining the drier exhausts with the exhausts from the shredder hoods and thermal screw augers and discharging via 3m stacks was sufficient to control odour emissions and prevent nuisance at receptors.

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

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

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

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

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

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

During subsequent discussions Tradebe made the decision to move emission points 3 & 6 so that they will be situated next to each other (1.3 m apart). The reasons for this was to aid dispersion and ensure both stacks were at least 3m above the roof apex however it also meant that these two emission points could effectively be considered as one emission point due to plume entrainment effects. There was now no need to carry out further modelling however in consultation with our air modelling expert we required Tradebe to carry out some sensitivity analysis comparing the one stack scenario to the two stack scenario. The software predicts very little difference. We have reviewed this information and have accepted the applicants’ demonstration that it is unlikely there will be impacts at receptors from nuisance odour.

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

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

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

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

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

5.8 Management The management system Tradebe propose to use achieves certification from SGS (UKAS Accredited Certification Body) for: • ISO 9001:2015 Quality Management; • ISO 14001:2015 Environmental Management; • OHSAS 18001: 2007 Occupational Health and Safety. ISO14001 is an international standard which define a set of criteria which make up an effective environmental management system and is a voluntary undertaking.

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

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

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

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

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

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

5.9 Fit and Proper Person For an application for a permit for a ‘specified activity’ SEPA requires to make checks to ensure the installation will be operated by a ‘fit and proper person’.

‘Specified waste management activity’ is defined in the PPC 2012 Regs as meaning an activity comprising – “ … (b) the disposal of waste falling within Sections 5.3, 5.4 or 5.6 of the Part of that Schedule [Schedule 1] or (c) the disposal or recovery of waste in a waste incineration installation,”. This installation includes Section 5.3 Part A, (b) (ii), Section 5.6 Part A, (a) and is therefore a specified waste management activity for which the ‘fit and proper person’ test applies.

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

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

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

In addition to fit and proper person checks for specified waste management activities, in terms of regulation 13 (2) of the PPC Regulations 2012, SEPA also generally requires to consider whether or not the applicant will ensure that the installation is operated so as to comply with the conditions which would be included in the permit.

Hazardous waste transfer 1. No relevant convictions identified. 2. Demonstration provided of technical competency for waste transfer activities in accordance with SEPA WST-G-002: Guidance - provision and assessment of technical competent management at licensed waste management facilities. 3. Applicant passed credit check.

Clinical waste treatment via thermal screw auger 1. No relevant convictions identified. 2. Demonstration provided of technical competency for clinical waste autoclaving activities in accordance with SEPA WST-G-002: Guidance - provision and assessment of technical competent management at licensed waste management facilities. 3. Applicant passed credit check.

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5.10 Raw Materials Hazardous waste transfer The waste types to be handled and maximum quantities to be stored on site have been specified in the application. Only certain waste types will be permitted on the basis of the application. The maximum permitted quantities will be an annual total of 24, 900 tonnes, with daily maximum permitted quantities of 190 tonnes.

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

Clinical waste treatment via thermal screw auger As above

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

Hazardous waste transfer As above

Clinical waste treatment via thermal screw auger As above

5.12 Waste Minimisation Requirements Hazardous waste transfer Requirements of the regulations to regularly review options for waste minimisation will be specified through the standard permit conditions.

Clinical waste treatment via thermal screw auger As above

5.13 Water Use Hazardous waste transfer The Bellshill site will source water from the Mains supply. Overall rate of use is currently unknown but will be closely monitored and recorded.

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

Clinical waste treatment via thermal screw auger As above.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 22 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

5.14 Waste Handling Hazardous waste transfer The waste code list applied for is included in Table 5 of the permit. The applicant has provided information on storage, containment, odour and management measures to be put in place in respect of the wastes proposed to be accepted. In order to comply with the technical guidance, operators are required to have systems in place that will track the waste on the site as it is stored or processed until it is removed from the site. This includes an ability to check the capacity of the site to accept incoming wastes at the gate. The applicant has an electronic tracking system in place on its other sites which it proposes to use to this site. Additional information was provided on this electronic system which clarifies its capabilities. The permit conditions specify the requirements of the technical guidance and are considered sufficient to ensure waste is fully tracked throughout the plant and its processes, including dispatch from the site. The tracking system proposed by the applicant is considered BAT.

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

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

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

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

5.15 Waste Recovery or Disposal

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

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

5.16 Energy

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

Clinical waste treatment via thermal screw auger

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

5.17 Accidents and their Consequences Hazardous waste transfer The application deals with the potential for accidents to occur and how they would be dealt with. The most significant event environmentally would be a fire on site. Adequate isolated firewater containment is provided should this happen. Permit conditions concerning fire detection specific to the drying system have been included in the permit involving continuous monitoring of temperature, the provision of alarms and fire suppression equipment.

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

Clinical waste treatment via thermal screw auger As above

5.18 Noise

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

The submission, including the noise modelling report, contained the expected level of detail. The applicant sufficiently demonstrated through modelling and proposed mitigation measures that noise nuisance is not expected and the likelihood of noise complaints is minimal.

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

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

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

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

5.19 Monitoring

5.19.1 Monitoring of emissions to air

Hazardous waste transfer No monitoring required.

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

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

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

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

2 X boilers serving the thermal screw augers - There will be no interaction between the combustion products of natural gas and the waste streams and so these emissions will consist only of NOx, CO and

CO2. Two of the emissions are related to MCPD plant (>1MW thermal input) and as such must comply with the monitoring requirements designated for MCPD in the Pollution Prevention and Control (Scotland) Amendment Regulations 2017. The limits are set out in Section 5.2 above.

The other boiler emission is related to non-MCPD plant serving the waste drier unit (< 1MW thermal input) and as such no specific monitoring requirements are applicable. Regular servicing and maintenance of this system should ensure that combustion efficiency is maintained and emissions from the sources are minimised.

The combustion of diesel in the back-up diesel generator will similarly result in emissions of combustion products. However the diesel generator will only be used infrequently (<500 hours per annum) and predominantly for testing purposes only to ensure the availability and functionality of the system if and when required no routine monitoring of the emissions is proposed.

The combined discharges from the air extraction systems serving the waste processing equipment (shredder hood, steam auger air extraction and drier extraction) will be discharged to air via two stacks at elevation. As the air discharged has been in direct contact with the waste being processed the potential exists for the air to contain some residual components of the waste being processed.

Extracted air from the shredder hood will be treated via a High Efficiency Particulate Air (HEPA) filter (H13 type) and then a carbon filter before discharge to air. Specifications for the HEPA filter to be used have been included at Appendix 9 of the application supporting document. The H13 HEPA filter is certified to EN 1822:2009 and will be of the H13 (≥99.95%) class in terms of efficiency. The H13 HEPA filter will remove particles that have a size greater than or equal to 0.3µm. As the H13 HEPA filter is not designed to deal with odours or gases (VOCs), it will be followed by a carbon filter. Carbon filters use activated carbon to remove contaminants and impurities by chemical adsorption. Conditions are placed in the permit requiring the operator monitor the carbon filters to ensure they are changed prior to performance efficiency dropping due to saturation. Notwithstanding this, there are monitoring requirements and limits placed in the permit for carbon filter inlet air humidity and temperature. These limits are based on widely accepted best practice guidance for carbon filter operation.

Displaced air and steam from the thermal screw will be discharged via a condenser, a coalescing filter and a carbon filter. The condenser will condense steam back to a liquid. The liquid condensate will be

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 25 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd discharged to the site trade effluent drainage system. Any remaining steam and air will be passed through a coalescing filter which will further separate liquid from the air to be discharged to the site trade effluent drainage system. Any remaining air will be passed through a carbon filter to remove any remaining contaminants and impurities. The above requirements for carbon filter monitoring also applies here. Extracted air from the drier will be discharged without abatement. The main risk associated with this emission source is odour therefore the reasons for this being acceptable are explained in section 5.7 above. The combinations of H13 HEPA filter/Carbon filter, Condenser/Coalescing filter/Carbon filter followed by discharge at elevation aims to ensure that there are no nuisance issues associated with these discharges. Odour, dust and VOC’s are all required to be monitored for (periodically) from the combined emissions points, EP3 and EP6 in the permit, so that the predicted low values and minimal risk of impact can be confirmed.

5.19.2 Monitoring of emissions to water

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

5.19.3 Monitoring of emissions to soil and groundwater

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

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

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

Score / rating / summary Outcome

PROFORMA 1 - Total of 17 possible (no pipe window) Cat 2. See Proforma 2, LIKELIHOOD OF consequence assessment. RELEASE Cat 1 Green – 3 / 17 Cat 2 Amber – 12 / 17 Cat 3 Red – 2 / 17

PROFORMA 2 - Liquids. All relevant information presented CONSEQUENCE Hazard statements “acute to chronic to ASSESSMENT aquatics”

The site will undergo repairs and new equipment will be in place as stated

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under the site condition report; also primary, secondary and tertiary containment will be as per legislative requirements; in addition to the fact that it has been stated that inspection, testing and maintenance of all the measures in place to prevent pollution will be undertaken through the life of the permit. Some of the hazardous substances as per CLP will only be present in small amount, therefore focus is on Relevant Hazardous Substances (RHS) which are present in high volumes. The drainage CCTV survey outcome highlighted some repairs needed and blockages that needed clearing, reason why a CCTV survey will be a requirement under the permit every two years in addition to the fact that integrity of the drainage will provide proof of containment for those RHS which will be conveyed by it.

Presence of low permeability soils: Glacial Till described as stiff and firm to stiff to very stiff reddish brown/grey- brown/grey sandy silty clay encountered to a maximum depth of 10m below ground level.

Rate and direction of groundwater flow - unknown.

Special features The site was previously operated by Baseline reporting has been food distributors. The environmental provided with regards to the setting and associated risks of pollution diesel and transformer areas. due to geology, hydrology and Baseline waivers will be provided hydrogeology have been presented. for the relevant hazardous substances (RHS) associated to CCTV drainage survey will be required Bin Wash Lemon and on this site every two years to ensure Quantaclene Plus. Based on the that no leaks or spillages associated to nature of the permitted activity faulty drainage take place and could and the environmental setting it cause pollution of soil and/or was agreed that no boreholes groundwater at the site. fitted with monitoring wells to collect groundwater samples at the site will be required on this instance. In addition to the fact that there are no commercially available laboratory analysis to quantify the relevant hazardous substances associated with Bin Wash Lemon and Quantaclene. As a result, it is considered necessary that a drainage CCTV survey will be required on this site every two years to ensure that no pollution of soil and groundwater takes place, in addition to

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requesting on the permit, chemical testing of the trade effluent at the point of entry to sewer discharge.

Groundwater In light of testing restrictions monitoring detailed above, initially recommended considered monitoring process interval effluent, however this does not prove protection of groundwater, only content of effluent. Drainage CCTV every 2 years with requirement to maintain integrity considered sufficient to demonstrate protection of soil and groundwater. Soil monitoring Ten yearly. At or near the original locations recommended Soil monitoring within 12 months of used for setting baseline interval date of permit. conditions near the diesel and transformer areas.

Substances to TPH CWG speciated aliphatic and Based on relevant hazardous monitor in soil aromatic fractions substances identified in use at the BTEX (Benzene, Toluene, site (and able to be tested for at Ethylbenzene and Xylenes) commercial labs). Polycyclic Aromatic Hydrocarbons (speciated PAH-16)

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

5.20 Closure Hazardous waste transfer The requirement for a decommissioning plan is included in the permit.

Clinical waste treatment via thermal screw auger As above

5.21 Site Condition Report (and where relevant the baseline report) Hazardous waste transfer Site investigation data provided for the site identifying fuels and oils and bin wash fluids as hazardous substances. Baseline conditions have been provided and soil and groundwater monitoring conditions will be included in the permit where appropriate.

Clinical waste treatment via thermal screw auger As above

5.22 Consideration of BAT Hazardous waste transfer A BAT assessment has been carried out on the waste types that will be accepted on site, and adequate measures are in place. See section 5.14 The applicant has provided information on storage, containment, odour and management measures to be put in place in respect of all the wastes proposed to be accepted. Where the wastes applied for require special measures to be put in place, due to their potentially odorous nature or due to requirements for special handling, sufficient information as to how those wastes will be stored, contained and managed has been provided and considered in line with BAT 4. . Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 28 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

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

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

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

Clinical waste treatment via thermal screw auger The waste types that are suitable for heat treatment are included in the permit as per the standard conditions. See section 5.19

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

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

6 OTHER LEGISLATION CONSIDERED

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

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

Officer: Hilary Holding

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 29 of 34 Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

7 ENVIRONMENTAL IMPACT ASSESSMENT AND COMAH

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

How has any relevant information obtained or conclusion arrived at pursuant to Articles 5, 6 and 7 of Council Directive 85/337/EEC on the assessment of the effects certain public and private projects on the environment been taken into account? n/a

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? n/a

Officer: Hilary Holding

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 30 of 34 Permit (Application) Number: Applicant:

8 DETAILS OF PERMIT

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

No Condition Justification 4.4 Odour Mixture Requirement for an odour management plan in line with BAT prior to operating, and requirement for odour monitoring within two months of commencing operation.

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

This site has the potential to cause an odour impact on nearby sensitive receptors therefore it is critical that the operator closely monitors odour emissions at the beginning to ensure any issues are quickly picked up and addressed.

4.2.1 4.2.1 Prior to carrying out any Permitted Drainage survey highlighted broken or Activities, the Operator must submit a obstructed drains. Construction work report to SEPA demonstrating that all underway. Upgrade condition necessary to drainage systems within the Permitted protect soil and groundwater prior to activities Installation are capable of ensuring commencing compliance with condition 4.2.2. Schedule 8 8.2 Waste Pre-Acceptance Considered BAT. The site must quality control incoming waste acceptance in order to avoid bottlenecks of non-conforming wastes on site, storage issues and inappropriate or incomplete treatment. Schedule 9 9.1 Electronic Tracking System Electronic tracking considered BAT Requiring clear and accurate traceability of waste through the site. Supports maximum storage limit condition Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

Schedule 10.5 Drying system Taken from PPC/A/1138879 to cover. Incident 10 and fire mitigation considered BAT

10.2.2 10.2.2 When operational, all Changed from standard condition requiring waste within the shredders must be fully shredders to be enclosed, to clarify the waste enclosed, and under negative pressure as within the shredder must be fully enclosed, not defined in Condition 10.2.4. the shredder unit itself.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 32 of 34 Permit (Application) Number: Applicant:

9 EMISSION LIMIT VALUES OR EQUIVALENT TECHNICAL PARAMETERS/ MEASURES

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

Emission limit values Air

Substance: Oxides of Nitrogen

ELV: 100 mg/m3

Emission point: EP1 & EP4

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

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

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

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

Emission limit values Water

Not required

Emission limit values Land

Not required

Emission limit values Noise and Vibration - None

10 PEER REVIEW

Has the determination and draft permit been Peer Reviewed? Yes

Name of Peer Reviewer and comments made: David Smith Permit (Application) Number: PPC/A/1180708 Applicant: Tradebe Healthcare National Ltd

11 FINAL DETERMINATION

Hazardous waste transfer Issue of a draft permit.

Clinical waste treatment via thermal screw auger Issue of a draft permit.

Issue a Permit – Based on the information available at the time of the determination SEPA is satisfied that  The applicant will be the person who will have control over the operation of the installation/mobile plant,  The applicant will ensure that the installation is operated so as to comply with the conditions of the Permit,  The applicant is a fit and proper person  Planning permission for the activity is in force  That the operator is in a position to use all appropriate preventative measures against pollution, in particular through the application of best available techniques.  That no significant pollution should be caused.

Officer: Hilary Holding

12 REFERENCES AND GUIDANCE

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

BAT conclusions and BREF for Waste Treatment

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

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