Fife Council Balbarton Landfill Leachate Treatment Plant. Permit Application

Transcription

1 Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 1 of 12 Fife Council Balbarton Landfill Leachate Treatment Plant Permit Application PPC/A/ CONTENTS FIFE COUNCIL... 1 BALBARTON LANDFILL LEACHATE TREATMENT PLANT... 1 CONTENTS NON TECHNICAL SUMMARY OF DETERMINATION EXTERNAL CONSULTATION AND SEPA S RESPONSE ADMINISTRATIVE DETERMINATIONS INTRODUCTION AND BACKGROUND Historical Background to the activity and application Description of activity KEY ENVIRONMENTAL ISSUES Point Sources to Air Point Source Emissions to Surface Water and Sewer Point Source Emissions to Groundwater Fugitive Emissions to Air Fugitive Emissions to Water Odour Management Raw Materials Waste Handling Waste Recovery or Disposal Energy Accidents and their Consequences Noise Monitoring Closure Consideration of BAT OTHER LEGISLATION CONSIDERED ENVIRONMENTAL IMPACT ASSESSMENT AND COMAH... 11

2 8 DETAILS OF PERMIT FINAL DETERMINATION REFERENCES AND GUIDANCE Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 2 of 12

3 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 Balbarton Landfill is a closed landfill site with an existing leachate plant on site which is currently regulated by a licence under the Water Environment (Controlled Activities) (Scotland) Regulations 2011 (CAR) CAR/L/ The site does not have a WML however it appears that an application was made in 1997 but withdrawn in Nov The site is owned and operated by Fife Council and managed by Fife Resource Solutions (a limited liability partnership entirely owned by Fife Council. The site received both inert and non-inert waste (some domestic and commercial) and stopped receiving waste in Over recent years the characteristics of the leachate form the site has changed and the treatment plant was successfully converted to a nitrification plant and has been operating in compliance with its CAR licence limits. The leachate arising from the closed Balbarton landfill has passed the methanogenic phase and is low in BOD and COD but high in ammonia and the age/type of landfill drainage means that it collects both leachate and surface water. During high rainfall the leachate is diluted and as a result the hydraulic retention times within the treatment plant are increased reducing the efficiency of the plant. During periods of low rainfall there is insufficient quantity of leachate to sustain the biological treatment process. In 2013 Fife Council changed the treatment plant from a 3 lagoon heterotrophic bacteria Sequencing Batch Reactor (SBR) into a 3 lagoon SBR nitrification plant. The leachate now needs a different feedstock to keep the nitrifying bacteria healthy, high in ammonia but low in COD/BOD. After testing it was found that Lochhead landfill leachate had the required characteristics from particular cells (Phase 1, Central and Western chambers only). Fife Council carried out trials in 2015 and 2016 with SEPA approval to test the leachate form Lochhead as a feedstock and have been able to demonstrate continued compliance with the existing CAR authorisation. Therefore this application is for the acceptance of waste leachate from Lochhead landfill to be treated in the existing leachate plant at Balbarton landfill. This has been proposed in order to maintain the nitrification function in the Balbarton treatment plant and still remain within the consent limits of the existing CAR licence which will be transposed into the PPC permit along with new parameters. The Industrial Emissions Directive (IED) has been implemented by The Pollution Prevention and control (Scotland) Regulations 2012 and came into force in This application would fall under PPC rather than Waste Management Licencing due to the quantity of leachate being brought to the site from Lochhead. The leachate will be brought by tanker loads and exceed 50 tonnes per day. This would be authorised under Section 5.4(a) of the PPC regulations: SECTION 5.4: Disposal, recovery or a mix of disposal or recovery of non-hazardous waste PART A (a) Disposal of non-hazardous waste at an installation with a capacity exceeding 50 tonnes per day by one or more of (i) biological treatment, The new permit includes conditions for much tighter control than the CAR licence to include: odour, vermin, litter, dust, noise, fire and groundwater and soil protection. The permit also has conditions for

4 monitoring in agreement with the operator for gas, effluent discharge, watercourse sampling upstream of the discharge and resource utilisation. Glossary of terms BAT - Best Available Techniques CAR - Water Environment (Controlled Activities) (Scotland) Regulations 2011 CO - Coordinating Officer ELV - Emission Limit Value IED - The Industrial Emissions Directive SBR - Sequencing Batch Reactor WML - Waste Management Licencing 2 EXTERNAL CONSULTATION AND SEPA S RESPONSE Is Public Consultation Required - Yes Advertisements Check: Date Compliance with advertising requirements Edinburgh Gazette 20/04/2017 Yes Fife Free Press 20/04/2017 Yes No. of responses received: None Summary of responses and how they were taken into account during the determination: N/A Is PPC Statutory Consultation Required Yes Food Standards Agency: Consultation letter sent 14 July Response received 15 July They said that they consider it unlikely that there will be any unacceptable effects on the human food chain from the emissions from the Balbarton installation. NHS FIfe: Consultation letter sent 14 July No response received. Fife Council: Consultation letter sent 14 July No response received. Scottish Water: N/A Health and Safety Executive: N/A Scottish Natural Heritage (PPC Regs consultation): Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 4 of 12

5 Consultation letter sent 14 July Response received 19 July They advise that it is unlikely that the proposal will have a significant effect on any qualifying interests either directly or indirectly, that an appropriate assessment is therefore not required and that there would be no impact on the SSSI Camilla Loch which is at a higher elevation than the Balbarton installation. Harbour Authority: N/A Discretionary Consultation No Enhanced SEPA public consultation No Public Participation Consultation - Yes STATEMENT ON THE PUBLIC PARTICIPATION PROCESS The Pollution Prevention and Control (Scotland) Regulations 2012 (schedule 4, para 22) requires that SEPA s draft determination of this application be placed on SEPA s website and public register and be subject to 28 days public consultation. The dates between which this consultation took place, the number of representations received and SEPA s response to these are outlined below. Date SEPA notified applicant of draft determination 28/06/2017 Date draft determination placed on SEPA s Website 11/07/2017 Details of any other appropriate means used to advertise the draft N/A Date public consultation on draft permit opened 11/07/217 Date public consultation on draft permit consultation closed 11/08/2017 Number of representations received to the consultation None 3 ADMINISTRATIVE DETERMINATIONS Determination of the Schedule 1 activity Disposal of non-hazardous waste at an installation with a capacity exceeding 50 tonnes per day by one or more of (i) biological treatment Described in Chapter 5 - Section 5.4 Part A of the PPC Regulations Determination of the stationary technical unit to be permitted: As detailed in the application. Determination of directly associated activities: As detailed in the application. Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 5 of 12

6 Determination of site boundary As detailed in the application. 4 INTRODUCTION AND BACKGROUND 4.1 Historical Background to the activity and application Balbarton landfill is a closed landfill with leachate treatment plant. The discharge from this treatment plant is currently regulated by a CAR licence (CAR/L/ ). The site is owned and operated by Fife Council and managed by Fife Resource Solutions (a liability partnership owned by Fife Council). The site received both inert and non-inert waste (some domestic and commercial) and stopped receiving waste in Restoration works were undertaken from 1994 to 2005 which also included the construction of the treatment plant. Over recent years the characteristics of the leachate from the site have changed and the treatment plant was successfully converted to a nitrification plant and has been operating in compliance within its CAR licence limits. The leachate arising from the closed Balbarton landfill has passed the methanogenic phase and is low in BOD and COD but high in ammonia and the age/type of landfill drainage means that it collects both leachate and surface water. During periods of low rainfall there is insufficient quantity of leachate to sustain the biological treatment process. In 2013 Fife Council changed the treatment plant from a 3 lagoon heterotrophic bacteria Sequencing Batch Reactor (SBR) into a 3 lagoon SBR nitrification plant. The leachate now needs a different feedstock to keep the nitrifying bacteria healthy, high in ammonia but low in COD/BOD. After testing it was found that Lochhead landfill leachate had the required characteristics from particular cells (Phase 1, Central and Western chambers only). Fife Council carried out trials in 2015 and 2016 with SEPA approval to test the leachate form Lochhead as a feedstock and have been able to demonstrate continued compliance with the existing CAR authorisation. Therefore this application is for the acceptance of waste leachate from Lochhead landfill to be treated in the existing leachate plant at Balbarton landfill. This has been proposed in order to maintain the nitrification function in the Balbarton treatment plant and still remain within the consent limits of the existing CAR licence which will be transposed into the PPC permit along with new parameters. 4.2 Description of activity The treatment of waste leachate from Lochhead landfill at the existing leachate treatment plant at Balbarton closed landfill. The treatment plant consists of a 3 stage lagoon system. The first lagoon is the collection and settlement lagoon and allows any suspended solids to settle to the base of the lagoon. This acts as a buffer to reduce the temperature fluctuations to protect the downstream process. The second lagoon acts as a secondary biological treatment and comprises a cyclical phase including dosing with phosphoric acid, aeration (24 hours/day) via semi flexible fine bubble diffusers and decanting. This lagoon is also fitted with bio reefs to provide media for the bacteria to adhere to. The last lagoon is used for final polishing of the effluent before being discharge to the Tiel Burn. Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 6 of 12

7 5 KEY ENVIRONMENTAL ISSUES 5.1 Point Sources to Air Point source emissions to air may be considered to be from the lagoons. The leachates from both Balbarton and Lochhead have passed the methanogenic phase and no longer produce offensive odours. Due to the nature of the leachate and biological process, there is no requirement for specific emission controls from these points. Gas monitoring has been added to the permit with the view to review the data after one year to fully assess of there are any potential gas emissions from the site. 5.2 Point Source Emissions to Surface Water and Sewer The main watercourse in the vicinity of the site is the Tiel burn located approximately 20 meters south of the of the final discharge point V notch. This is the same discharge point which is licenced by CAR which will be covered by the PPC permit. The design and containment measures of the treatment plant ensure that there are no other point source emissions to surface water. Treated leachate stored in the treatment plant contains a number of contaminants including ammonia, solids, chloride, metals and ph. These are potentially harmful to the environment however the concentration levels within the treated effluent would not normally be considered to have the potential to cause serious harm. The treatment of the leachate will be closely monitored and sampled. The final effluent will be routinely sampled and if at any time this was considered to have the potential to cause harm to the Tiel Burn the control valves existing on site can be used to prevent any effluent entering the burn. 5.3 Point Source Emissions to Groundwater Due to the design and construction of the leachate treatment plant there are no emissions to groundwater associated with this activity. 5.4 Fugitive Emissions to Air The process is unlikely to give rise to fugitive emissions to air or odour from the existing closed Balbarton landfill as the leachate test from the site indicate that the waste mass has passed the methanogenic phase, as do the summary and feasibility reports carried out in the past. However as there are some monitoring wells along the boundary running parallel from the entrance gate at the main road back to Auchtertool these are available to monitor for landfill gas and testing will be carried out for the first year with a review of results during this time. The treatment lagoons could also be considered to be a source of fugitive emissions to air however as the leachate from both Balbarton and Lochhead have passed the methanogenic phase and no longer produce offensive odours. 5.5 Fugitive Emissions to Water N/A 5.6 Odour As above 5.7 Management Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 7 of 12

8 Effective pollution control relies on effective management to prevent raw waste leachate entering the water environment. This is a relatively straight forward process; the applicant has indicated in the application that they follow an effective Management System and that the site will be controlled by a Fit and Proper Person as well as training for any relevant staff SEPA believes that this comprises BAT and can be adequately controlled by standard permit conditions which require the operator to maintain and implement documented procedures in place on environmental performance objectives and targets and future improvements. 5.8 Raw Materials The table below details the infrastructure for the storage of leachate and raw materials. Location Capacity Contents Storage Duration Type/Description Raw Leachate collection lagoon 4042 m3 min capacity Raw leachate Temporary storage pending treatment. Existing storage lagoon Typically > 24 hours Primary Treatment 2268 m3 min Raw Leachate which Duration of Existing primary lagoon Final Treatment Lagoon capacity 1134 m3 min capacity is then treated Treated effluent treatment process Temporary storage and final treatment prior to discharge treatment lagoon Existing final treatment lagoon Phosphoric Acid 2 x 25 litre drums Phosphoric Acid Stored until required Storage within store room Raw leachate form Balbarton landfill will be pumped to the collection/settlement lagoon. Leachate for Lochhead Phase1, Wester and Central Chambers will be stored in the collection lagoon prior to treatment. Volumes from Lochhead will be dependent on spare capacity and performance of the Balbarton treatment plant and as such will be assessed at the start of each working day. The lagoon is 4m deep but has a leachate compliance level of 2m to control the risk of leachate escaping through increased leachate generation or periods of heavy rainfall. Liquid level reading within the treatment plant will be transmitted back to the Lochhead weighbridge operator and Lochhead charge hand to ensure capacity within the Balbarton leachate treatment plant. 5.9 Waste Handling All waste leachate brought to site will be transported by tanker and piped directly into the first lagoon of the leachate treatment plant. The leachate from Lochhead will undergo characterisation tests prior to delivery. All waste acceptance and sampling procedures will be overseen by the Landfill Site manager who is suitably qualified and experienced to undertake this work. Computerised records are held of all leachate sampling and monitoring data. Manual copies will also be retained in the Landfill Managers Site office Waste Recovery or Disposal The treatment plant and abatement techniques for waste management and disposal comply with the principles of BAT as the treatment process does not generate any waste. There is no sludge generation as the treatment plant does not use heterotrophic bacteria and there is no sludge settlement period within this process. No diesel operated plant is required so there are no emissions from this or waste products from servicing Energy The applicant has indicated that they use relatively low amounts of energy. The power used per annum is 245,280 kwh. To optimise energy efficiency the equipment will be maintained and serviced as required. Any equipment not required will be turned off including lighting and heating as appropriate. Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 8 of 12

9 5.12 Accidents and their Consequences The operational area of the site is designed so that any leak from the treatment plant would drain to capture points and be returned to the process for treatment prior to discharge Noise The main sources of noise are considered to be as follows: Vehicles using the site; Reversing bleepers and Silenced aeration units It is considered that due to the site operations the generation of vibration will not be significant and is, therefore, given no further consideration. The nearest town is 1.5km away and is hidden from the site due to the hill to the north of the site and is considered far enough away to be unaffected by any noise at the site. The placement of any plant and equipment which could create noise will be given due consideration to the proximity of receptors and the prevailing wind direction. If reversing alarms give rise to complaints alternative alarms or technology will be investigated. Noise levels will be monitored from personal exposure within various sections of the site Monitoring The site operator will carry out monitoring with compliance to the permit to include: Sampling of the leachate being brought to site Sampling of the treated discharge effluent Sampling of the river upstream of the plant Noise monitoring Gas emissions Lagoon levels to ensure capacity 5.15 Closure A standard condition is included in the permit for the de-commissioning of the plant. A decommissioning plan is required within 6 months of the start of the permit to set out the steps to be taken by the operator after final cessation of the permitted activities Consideration of BAT The waste acceptance procedures employed at the leachate treatment plant are considered to be BAT for the following reasons: 1. The leachate at Balbarton Landfill is subject to a regular programme of in-situ sampling and analysis 2. There will also be laboratory analysis of the combined leachate, leachate during treatment, treated leachate and final effluent which will be undertaken in accordance to the monitoring schedule in the permit 3. When the sample is taken, the following information is recorded: a. Location of sample b. Operating conditions at the time of sampling c. Number of samples d. Method of sampling 4. Samples are clearly labelled and recorded 5. List 1 substances within the leachate are determined on an annual basis at a UK national Measurement Accreditation Service (NAMAS) accredited laboratory 6. Any wastes derived from offsite sources will be subject to analysis prior to acceptance Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 9 of 12

10 7. Waste acceptance is the responsibility of a suitably qualified and experienced person. It is considered that the operation of the treatment plant conforms to BAT for the following reasons: 1. On-site treatment is a passive treatment system utilising fixed media and dissolved oxygen. No heating is required and no feeding such as activated sludge or molasses is required. Operating plant is limited to two aeration units and 2 pumps that run for a maximum of 2 hours per day, at an energy cost of around 8,000 per annum based on historical energy use readings. Energy saving is also reduced through the reduction in tankers traveling further distances from Lochhead to third party treatment facilities. 2. Treated effluent currently conforms to the CAR licence. The performance of the treatment plant and the quality of the effluent is maintained under review in order to evaluate alternatives and to ensure that the treatment process represents BAT and minimises the environmental impact of the facility. The proposed waste storage procedures implemented on site are considered to be BAT for the following reasons: 1. The treatment plant comprises an engineered storage lagoon which was constructed with CQA. 2. All storage lagoons located within the treatment plant have been designed in accordance with the CQA standards. 3. The treatment plant is surrounded by an extensive drainage system, bund wall and bentonite wall. 4. Storage areas are clearly marked. 5. Procedures are in place for the regular inspection and maintenance of storage areas with any repairs being undertaken as soon as is practicable. 6. Leachate levels within the treatment plant are continuously monitored by separate water level indicators. Any high level alarms are transmitted back to the Lochhead weighbridge operator and Lochhead Charge hand. 7. The open lagoons provided adequate provision for ventilation. 8. The treatment plant is an existing operational plant managed under an existing CAR permit. 9. Provides a more commercially viable proposition to transferring off site and treatment by 3 rd party organisations 10. The design and build of a new treatment plant at Lochhead to treat Lochheads leachate is not an option based on previous studies. 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: The waste leachate brought to site is classified as non-hazardous and will be tested before leaving Lochhead landfill to ensure the composition of the leachate is suitable for the treatment plant at Balbarton. The leachate can be dangerous to the ground and the water environment if released without treatment. There are controls in place to ensure that there will be no emission of potentially polluting substances from this activity and it is anticipated that there is no likely significant negative effect on any designated sites from this activity. The primary issue of significance for the environment is the potential for the release of leachate to soil or groundwater or any direct or indirect discharge to the water environment. The main controls used to prevent any release are the use of appropriate control systems, closed site Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 10 of 12

11 drainage and bunding. The site has been operating and carrying out leachate treatment activities at this location since The treatment process operates as a closed system with one controlled emission point to the Teal Burn. The treatment area is on hardstanding and containment is in place to prevent any spillages escaping the process boundary minimising the risk of an incident having impacting upon the environment. SNH were consulted as statutory consultees and the response is as below: It is unlikely that the proposal will have a significant effect on any qualifying interests either directly or indirectly, that an appropriate assessment is therefore not required and that there would be no impact on the SSSI Camilla Loch which is at a higher elevation than the Balbarton installation. Screening distance(s) used based on Nature Conservation Procedure NCP-P-01: 2Km used Page 6 Annex A of NCP-P-01 states that: All discharges to water from PPC sites should be considered to be equivalent to a simple licence and screened at 1km unless they meet the thresholds for a complex licence, where they should be screened at 3 km application to land of waste sheep dip is 1km and coating activities - section 6.4 activities are 2km. Are there any SSSIs within the area screened? Yes Has SNH been consulted under section 15(5) of the 2004 Act? No If No, Justification: A consultation letter was sent to SNH and they responded saying they had no issues. The nearest SSSI is uphill from the treatment plant and therefore highly unlikely to have a n impact from the plant. Are there any SPA or SAC designated areas within the area screened? No 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 8 DETAILS OF PERMIT Do you propose placing any non standard conditions in the Permit - No Do you propose making changes to existing text, tables or diagrams within the permit? - No Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 11 of 12

12 9 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 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, 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. 10 REFERENCES AND GUIDANCE Guidance Notes Identify key references, guidance (BREF, UK Technical Guidance, etc) used in determination SEPA s Part A Practical Guide NCP-P-01 (SEPA NATURE Conservation Procedure for Environmental Licensing) Horizontal Guidance: Odour & Noise IPPC H2 Horizontal Guidance Note, Energy Efficiency SEPA Odour Guide 2010 SEPA Guidance Control of Noise at PPC Installations. IED-PG SEPA Application and Duly Made Guidance IED-PG SEPA Public Participation Consultation Guidance Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 12 of 12