We have prepared frequently asked questions for the most common questions asked during a public consultation for an environmental permit application to operate an energy recovery facility.
Urbaser Environmental Limited applied to us for an environmental permit to operate an energy recovery facility at Javelin Park, Haresfield, Gloucestershire. It would have capacity to burn upto 190,000 tonnes of waste per year and generate approximately 17.4 megawatts of electricity. As part of our decision making process we consulted the public on the application. We are now consulting the public on our draft decision on whether to issue a permit. Our consultation will open on Wednesday 20 February 2013 and close on Friday 12 April 2013. As part of the consultation we are hosting a drop in session on Tuesday 12 March at Stonehouse Town Hall where our staff will be available to answer questions and discuss any concerns. We aim to issue our final decision on whether to issue a permit by the end of May 2013.
The Environmental Permitting Application Process
1. What is our role?
We will be the regulator for the proposed Javelin Park Energy Recovery Facility (ERF). This means the operator, Urbaser Environmental Limited, has to apply to us for an environmental permit. They cannot operate the facility without one.
We received their application on 27 February 2012 which was made under the Environmental Permitting Regulations 2010.
2. How is the Environmental Permitting application affected by the planning application?
To operate, the Javelin Park facility needs both planning permission from Gloucestershire County Council and an environmental permit from us. These are separate and distinct processes and planning permission can be granted without the environmental permit and vice versa. If Gloucestershire County Council grants planning permission it does not guarantee that we will issue an environmental permit, as the applications are judged by different criteria.
The planning system addresses the acceptability of a proposed development in terms of the use of the land, location, the need for a facility, the amount of waste generated as well as wider issues, such as the visual and traffic impact. The Environmental Permitting Regulations address the design and operation of the process to prevent pollution and minimise impacts on the environment and human health.
We are consulted on the planning application which is determined by Gloucestershire County Council, and we consult them on the environmental permit application which is determined by us.
3. What is the public consultation period?
The official consultation period runs for 20 working days (excluding Bank holidays) from the date our draft decision on the environmental permit application is advertised on our website. However, for sites of high public interest such as Javelin Park, the consultation period can be extended. The consultation period for the Javelin Park draft decision will, therefore, run from Wednesday 20 February 2013 to Friday 12 April 2013.
The public consultation on our draft decision on the environmental permit application is a completely separate exercise from the public consultation on the planning application.
4. Where can I see a copy of the application and draft decision documents?
The application, draft decision document and draft permit is available to view at our offices in Tewkesbury. Should you wish to make an appointment to view the application at our offices please telephone our public register co-ordinator:
You can also arrange to view the documents at Stroud District Council's offices by contacting the planning technicians:
or e-mail:
5. How can I make comments on the draft decision?
Comments can me made online on our e-consultation page from 20 February 2013:
Alternatively comments can be made via email:
or write to us at:
Permitting Support Centre (EP Team)
Environment Agency
Quadrant 2
99 Parkway Avenue
Parkway Business Park
Sheffield, S9 4WF
6. What issues can we consider comments on?
- General operational management of the proposed facility
- Handling and storing of incoming waste
- Efficient use of raw materials, water and energy
- Control of odour, noise, litter and vermin
- Control of emissions to the environment to permitted limits
- Monitoring of the incineration process to agreed procedures
- Monitoring of emissions to the environment to agreed standards
- Control of handling and storage of residual wastes from the process
- Potential impacts on health and the local environment
- Any local factors that you believe Urbaser has not considered in its permit application
7. What issues are we unable to consider comments on?
We are unable to consider the following issues as they form part of the planning application process, being managed by Gloucestershire County Council:
- whether the proposed incinerator would be best turned into an alternative technique for dealing with waste (eg a sorting and recycling proposal)
- alternative locations and size for this proposed facility
- operational hours
- the opportunities to use surplus heat from the proposed facility
- the transport of waste to and from the site
- how much waste is accepted and where it comes from
- whether a site should have a formal designation under conservation legislation
- flood risk (other than issues related to the Accident Management Plan for the installation)
8. Who else is consulted on the application and draft decision?
As well as inviting comments from members of the public, Gloucester City Council and the Highways Agency, we send the application and draft decision documents to the following statutory consultee organisations for their comments:
- Stroud District Council – Environmental Health
- Gloucestershire County Council - Planning Authority
- Health and Safety Executive (HSE)
- Severn Trent Water Limited - Sewerage Undertaker
- Gloucestershire Health Protection Agency/Primary Care Trust
- Natural England
- Food Standards Agency (FSA)
9. What happens before a decision on the application is made?
We examine whether Urbaser's proposal, as described in their application, meets the requirements of the Regulations. The basic principle of these Regulations is that installations are operated in such a way that:
- All appropriate preventative measures are taken against pollution, in particular through the application of best practice and no significant pollution is caused.
- We review the design of the plant, how it will be operated, the emissions it will generate (to air, water and land), the wastes arising, how emissions will disperse in the local environment and whether they have any effect on people and natural habitats.
- Where anything is unclear or if details are lacking we ask Urbaser for further information and anything we find will be made publicly available.
10. What is this consultation for if we already have a draft decision?
Following consideration of the application we published our draft decision and provided information about this on our website:
Members of the public and other organisations will have the opportunity to comment on the draft decision and their comments will be taken into account in reaching our final decision. We have four months to determine most applications, once we have accepted them. This timetable can be extended by agreement with the applicant and is likely to occur with applications for sites of high public interest, such as this. However, we never issue a draft decision or final decision until we have taken all necessary information into account.
How we regulate
11. What is our position on waste incineration?
We issued a position statement on waste incineration. The main elements of this statement are:
- we believe that we need to create less waste, recycle more and dispose of the remainder in a safe and environmentally friendly way.
- we support the “waste hierarchy” as a general guide to selecting the best option for dealing with waste: reduce; re-use; recycle; recover; dispose.
- we believe that incineration has a role in waste management.
- we also consider that energy generated by incineration should be recovered as far as practicable.
If you require full details of our position statement please visit:
- Javelin Park - follow the links to 'Energy from Waste' at the bottom of the page.
Alternatively you can contact our External Relations team in Shrewsbury on:
or email:
12. How do we regulate incinerators?
In accordance with the Industrial Emissions Directive (IED) we regulate the performance of incinerators by:
- requiring continuous monitoring of the main pollutants for which limits are set and periodic monitoring for the other substances.
- carrying out audits of the operator’s procedures and methods for emissions monitoring.
- carrying out annual check monitoring by our own independent contractors.
- regular announced and unannounced inspections.
- adding or changing conditions in the permit if required.
- requiring operators to inform us if they exceed any of the emission limits in the permit, or if they fail to comply with any operating conditions.
- investigating non-compliance with any condition of the permit.
- taking enforcement action if needed, including issuing notices, prosecuting serious breaches or potentially revoking the permit.
Data which we hold as a result of our regulation of the facility can be requested by calling our Public Register Co-ordinator on 01743 283410.
13. What is the new Industrial Emissions Directive (IED) and how will this effect regulation of the facility?
Permits for facilities such as the Javelin Park ERF used to be written in line with the Waste Incinceration Directive (WID). This will soon be superseded by the IED. This is a piece of European legislation that will soon be implemented in the UK. It brings seven separate Directives into one, including the WID. The aim is to produce a single, consistent Directive that will be implemented across operations and Member States.
The aims and objectives from these Directives will remain mostly unchanged. IED will impose new requirements on some permitted operations; strengthen the current pollution control regime; provide greater consistency in the application of BAT (Best Available Techniques); and extend the scope of the activities we regulate.
As IED brings together existing Directives there is no fundamental overhaul of the existing permitting system. All large industrial activities will be regulated under IED.
14. If we grant a permit, what will it cover?
The permit will have legally binding conditions and requirements that will include:
- limits on emissions to air, water, sewer, land and groundwater and/or conditions to protect them
- minimum operating conditions, for example, for temperature, ash burn out
- total tonnages and types of waste which can be burned
- monitoring techniques, standards, frequencies and reporting requirements
- conditions to prevent fugitive emissions from raw materials and ash handling
- conditions to achieve control of noise emissions, accident prevention and energy efficiency
- management requirements, staff training and operating instructions
- notification of any breaches of emission limits and other incidents.
Emissions
15. What will be burned in the facility?
Urbaser proposes to burn residual municipal solid waste and commercial and industrial waste. None of the wastes proposed to be burned are designated as hazardous waste.
It is proposed that over one year the facility would be capable of burning up to 190,000 tonnes of waste. It would have the capacity to generate approximately 17.4 megawatts of electricity.
16. Will there be emissions from the facility?
The main emissions from burning of waste are carbon dioxide, oxides of nitrogen and water vapour. Ash residues will also be produced.
Standard products of combustion are released, including carbon monoxide, volatile organic compounds (VOCs) and particulate matter (dust), in addition to carbon dioxide and nitrogen oxides. Trace levels of dioxins and furans, polycyclic aromatic hydrocarbons and polychlorinated biphenyls are included in the combustion gases. There will also be products from the incinerated wastes, including acid gases (hydrogen chloride, hydrogen fluoride and sulphur dioxide) and small amounts of heavy metals.
Two types of ash are produced: incinerator bottom ash (IBA) from the incinerator grate and air pollution control (APC) residues comprising filter dust and lime scrubber residue. The bottom ash will be processed on site at the Incinerator Bottom Ash Recovery Facility to produce a secondary aggregate for use in construction; the APC residues will be sent to a landfill or other waste disposal facility unless a suitable reuse option can be identified.
17. How will the emissions be controlled?
Emissions from an incinerator are controlled by a combination of good combustion control (to minimise releases of carbon monoxide, VOC’s, dioxins and furans etc) and effective abatement (to reduce oxides of nitrogen, neutralise the acid gases, filter the particulate matter and absorb heavy metals and dioxins). The combustion conditions in the incinerator and the emissions to air are continuously monitored.
The high level of control of the process and the emissions is achieved by strict conditions and emission limits imposed through an environmental permit. The permit determination includes an assessment of whether the control techniques proposed by the applicant are the best practice.
18. How will the emissions be monitored?
As a minimum, the following emissions monitoring will be required:
- continuous monitoring of oxides of nitrogen, carbon monoxide, volatile organic compounds, sulphur dioxide, hydrogen chloride and particulate matter
- in the first year of operation, one measurement every three months of heavy metals, dioxins and furans, polychlorinated biphenyls and polycyclic aromatic hydrocarbons
- after the first year of operation, twice-yearly measurements of heavy metals, dioxins and furans, polychlorinated biphenyls and polycyclic aromatic hydrocarbons.
However, we can request more frequent monitoring and monitoring for additional substances over and above the minimum requirements.
Urbaser may make emissions monitoring data available on their website since this is already done for other facilities.
19. What will happen if equipment controlling emissions broke down?
A modern incinerator is equipped with a large number of alarms which alert the operator to any problems on the plant, either with combustion control, abatement equipment or high readings on the emission monitors. Prompt action would be taken in response to all alarms, and in some cases an automatic controlled shutdown would be initiated.
An environmental permit requires that abatement equipment (technology to reduce emission) is operational at all times when waste is being burned. The Waste Incineration Directive includes a few allowances to this under very specific circumstances and for strictly limited periods, but in practice these periods of “abnormal operation” are rarely seen. All such operation must be notified to us without delay.
Health
20. Will I be exposed to pollution from the facility?
Using dispersion models, it is possible to predict where the plume from the incinerator will travel and where it will come to ground, taking into account different weather conditions. These models are able to predict the concentration of pollutants from the facility in the atmosphere on an hourly, daily or yearly basis. Urbaser has used computer models to estimate the effect of the emissions on local air quality. The results of the modelling, which are presented in detail in the environmental permit application, indicate that the impact from the facility is small. They also indicate that overall levels of pollutants, when combined with existing air quality, are well within the air quality standards laid down in regulations.
As part of our determination of the application, we will review and validate the dispersion modelling which has been carried out by Urbaser. Modern atmospheric dispersion models have been extensively tested to check whether the predictions given by the models match up with actual measurements. We will only accept well validated models used to predict effects from industrial processes that we regulate.
21. Will the facility affect my health?
The application contains detailed assessments of the impact of the emissions on the health of the local population. The assessments use worst-case assumptions about emissions and exposure routes, and employ the latest methods based on current scientific thinking. The assessments conclude that acute impacts on health by inhalation of gases and fine particles would be very small, and that exposure to metals and dioxins would not pose a significant risk to health.
These conclusions are consistent with the findings of authoritative published studies of the health of communities living near to modern municipal waste incinerators (for example, the DEFRA study Review of Environmental and Health Effects of Waste management: Municipal Solid Waste and Similar Wastes, 2004).
Also in support of the conclusions, the Health Protection Agency has published a position statement on incineration of municipal solid waste that states "Modern, well managed waste incinerators will only make a very small contribution to background levels of air pollution provided they comply with modern regulatory requirements, such as the Waste Incineration Directive, they should contribute little to the concentrations of monitored pollutants in ambient air".
We review the assumptions, methodology and results of the assessments as part of our determination of the application. We will also seek the views of the Health Protection Agency and the local NHS Primary Care Trust on the assessments presented.
The actual effect on health depends on the levels of the pollutants which people are exposed to, the frequency and duration of exposure, and in some cases, the existing state of health of the people concerned.
The substances in the emissions from the facility have the potential to affect human health by:
- inhalation of gases and fine particles affecting respiratory and cardiac health and;
- long term exposure to heavy metals and dioxins and furans, mainly through the food chain, causing a risk of cancer and other effects
22. How will the recent study by the HPA affect your position on incinerators?
The Environment Agency takes advice from the Health Protection Agency (HPA) on the health implications of incinerators. In January 2012 the HPA confirmed that it would be undertaking a new study to ascertain if there is a link between municipal waste incinerators and health outcomes including low birth weight, still births and infant deaths. The HPA's current position that modern, well run municipal waste incinerators are not a significant risk to public health remains valid. The study has been undertaken to extend the evidence base and provide the public with further information.
Impacts on climate change
23. What affect will the facility have on climate change?
The facility will emit carbon dioxide and small quantities of other greenhouse gases. Emissions of carbon dioxide are an inevitable consequence of burning waste (or any other fuel) and are related to the amount of waste and the carbon content of the waste. The choice of incineration technology could have a small effect on the amount of carbon dioxide released. Emissions of other greenhouse gases, such as nitrous oxide (N2O), are influenced by the choice of abatement equipment (technology to reduce emission) option for nitrogen oxides. These factors must be considered in determining whether the facility constitutes the best available techniques for minimising emissions of greenhouse gases.
Another important element is the potential for the facility to make indirect savings of carbon emissions by displacing the use of virgin fossil fuels. For every unit of energy that is recovered from burning waste, virgin fossil fuels won’t be burned elsewhere to generate the same energy. The higher the degree of overall energy recovery, the greater this effect is. At the present time, the proposal is for energy recovery by electricity generation, combined with use of the waste heat for preheating of boiler feed water and combustion air. Full combined heat and power is not proposed at this stage due to the absence of a local customer for the waste heat. We will review this position when we have considered any proposals in more detail.
Further information
All information submitted by Urbaser as part of their environmental permit application, and if granted, the permit itself, is placed on the Public Register and is available to view free of charge. The Public Register is located at our offices in Tewkesbury.
For any queries not answered above please contact the External Relations team in Shrewsbury on:
or via email on:
Press enquiries should be directed to our press team on 0121 711 5829/5855. (24 hours a day, seven days a week).
Further information on the energy recovery facility can be found on our Javelin Park home page:
Please note that 'incinerator' is the legal name for a facility such as the proposed Energy Recovery Facility at Javelin Park. However, operators are entitled to give a facility any name they like. For this reason they are often referred to as 'Energy from waste' or Energy recovery' facilities among other descriptions.
