Bury Green Party

14 August 2013

The Anaeobic Digester  Planning Application from Peel Evironment Ltd and Marshall Mono Ltd is now with Bury Planning Department. It has not, as yet, been published. Bury and Ramsbottom Greens will make their decision to support or oppose Tamar's application when we had the opportunity to study the full planning application, the Environment Impact Assessment recommendation  from the Environment Agency and the Highways Department report. 

Whilst Bury  planners are preparing their recommendations for members of the Planning Committee to approve or reject the application, we are now keen - as promised - to share the results of our own investigation in this controversial proposed development in Ramsbottom. 

The investigation carried out by our Working Party on the matter has covered three main areas : 

1. Direct questions to Tamar Ltd arising from the Consultation Event of 26th June 2013 in Ramsbottom 

2. Comments from Friends of the Earth  and independent experts 

3. Responses from green councillors 

1. Questions put to Tamar Ltd and their responses  

Q 1 : When the plant will be fully operational, how many lorries per day do you anticipate will deliver the waste products to the plant ?

A: Tamar anticipates that there would be between 27 and 40 trips per day * depending on the average load weight of vehicles to and from the the site. This is the same or less than traffic permitted by the current planning consent * for green waste open window composting and aggregates recycling that exists on the same site and which the proposed plant effectively replaces. 

*  Marshall Mono Ltd informed us that approximately 100 lorries per day go in and out of the quarry on a regular basis 

* This refers to planning application ref. 43048 from Peel Investments (North) Ltd  and Marshall Mono Ltd which was approved in October 2006 ( Thanks Stewart ). Ramsbottom residents should be aware that, pending  approval at the Licence Stage, this permission is valid until 2036.  The proposal was: " Quarry extension: construction, demolition & excavation waste landfill, operation: construction & demolition waste recycling facility; green waste composting facility".

Please note : waste landfill, waste recycling and green waste composting facility.  

Q 2: Have you assessed the air speed and direction of the wind over the Quarry itself ?

A: SLR * have used meteorological data from the nearest approved sources, not immediate to the quarry as there is no locally available long terms data. However, in conjunction with the answer below, the assessement forms a robust approach to air movement and dispersion modeling. 

* SLR Consulting is a registered Environment Impact Assessment and IEMA member. It is a national consultancy with a strong track record in the minerals, renewables and waste industries and with  experience of the proposed development site. 

Q 3: Have you assessed the effect of the eddy perturbation within the Quarry caused by the ground level differentiation between the north east ridge and the lower south west bank which is less than 200m from the closest residential homes? 

A: The air dispersion model exercise * which models deposition or particulate matter, odour, etc. uses a surface model that takes into account the buildings, structures and landform of the plant and the surrounding areas. Therefore this has incorporated the surrounding terrain into the calculations which are used to assess impacts on people, ecology and the surrounding area. This uses a recognised methodology and is a standard process for assessing facilities such as that proposed. 

* Peel Investements(North) and Marshalls Mono 2006 planning application was advised that "the validity of using data measured at Manchester Airport to derive conclusions on the acceptability of the impact of dust, bioeaerosol and odours has not been demonstrated". However, the Environment Agency had raised no objections to or made reference to the need to assess the possible impact of these emissions, and it was therefore assumed that they, as the Licencing Authority would consider that these issues could be satisfactorily addressed at the Licensing stage. 

We will study closely this "model exercise "when the planning application is published. 

Q 4:  What measure will you put in place to eliminate offensive odour from the plant ? 

A: The plant is designed, built and will be operated in such a way that external conditions are actually of little significance, insofar as that the plant is designed to prevent the escape of odour. Odour control begins with the fact that no materials, before, during or after processing are held, stored, or processed outside, is exposed to the air. They are delivered to the site in sealed containers or vehicles, and taken into the reception building, which has fast acting roller shutter doors, remaining closed at all times other than for entry and exit from the building. The building is held under slight negative pressure, meaning that any flow of air is into, rather than out of, the building, containing any odour within it. The air within the building is then put through an odour treatment process. The details of this will be designed in collaboration wih the Environment Agency, but are likely to include a large bio-filter, a container in which substanticial volumes of woodly materials are held, and in which odour molecules naturally break down. The site will be operated so that no materials are left lying for prolonged period on the reception building floor, and the building will be cleaned every day. 

Once inside the process, feedstock materials will be at all times entirely contained within pipes or tanks. In many other AD facilities, the major source of potential odour issues is the venting of pipework or tanks, which is routinely conducted to atmosphere. Tamar Energy is taking the expensive but effective approach of ensuring that all points at which emissions can occur are captured directly into the gas train, which then passes through the gas engines, ensuring that the gas burning process effectively manages the potential for odour release. 

In the tank farm, we have designed in sufficient capacity that when a tank needs maintenance, we can isolate and empty it, moving all materials to a different tank, allowing it to be worked on when empty, meaning that it will not represent a high odour risk,*  unlike the sites of many of our competitors which suffer from under capacity.

*  We will seek further re-assurances on this specific tank maintenance issue (thanks Mark for your comment). 

All offtake of digestate and liquids from the plant will be carried out via sealed piped connections, ensuring that no matgerials are exposed to the atmosphere. Thers ia a failsafe measure, as the digestion process ensures all decomposition ( which generates the odour) has taken place by this stage. 

In terms of regulatory enforcement, the terms of the permit from the Environment Agency will require that the plant should not allow unacceptable emissions to pass the site boundary. 

Q 5: What measures will you put in place to minimise the possible offensive odour in case of a mechanical fault * ? 

A: If the site suffers a serious mechanical fault meaning the plant cannot operate within the terms of its Permit, feedstock would be diverted to another facility until it was fixed. However, on a day to day basis, we have sufficient redundancy designed into the plant to ensure that this is a highly unlilekly outcome. 

* This is what happened at the  Cannock Chase AD Plant plant managed by Biffa in Staffordshire, causing odours of an uncceptable level for over 6 months and serious distress to local residents. The cause of the fault was a power failure on 27th and 28th December 2012. This meant that the valves at the top of the tank released gas through emergency release valves to avoid pressure building up in the tank. The valves were closed manually so soon as power was restored to the plant. ( Environment Agency Neighbours Newsletter Feburary 2013). The Agency's deadline to Biffa to take final appropriate measures to prevent odour pollution was 12th July 2013 (AE Newsletter May 2013 ).

We are awaiting for a reply from the EA to confirm if the new measure has been installed and if local residents are now satisfied that the odour problem has been resolved. We will keep on trying to find a way to obtain  up-to-date comments from local residents right up to the end of the consultation period and, if successful in our endeavour, we will post them on our facebook and twitter accounts. 

 Q 6:  What types of waste will be used in the digesters? 

A: Tamar Energy will target the supply of three types of feedstock to our proposed facility at Fletcher Bank Quarry(FBQ), outlined as follows:

(a) Agricultural By-Products/Purpose Grown Crops 

The proposed facility would have the ability to process by-products from agriculture, such as fruit and vegetables not deemed suitable for sale or supply to retailers etc. This potential feedstock would typically be disposed of to either composting facilities ( where no energy value is captured) or landfill. Our facility at Holbeach Hum in Lincolnshire, for example, will be predominently fuelled by potatoes unsuitable for sale or human consumption. 

(b) Food Processors 

By their very nature, food processors generate some levels of unavoidable waste by-products from their manufacturing businesses. These by-products could constitute a suitable feedstock for the proposed Bury Fletcher Bank Quarry facility. Tamar Energy has a very well developped strategic relationship with the retailer Sainsbury's -which is also an investor in our business. Sainsbury's plays an important role in introducing Tamar Energy to lcoal food processors in their supply chain with whom we deal, so as to facilitate those processers in diverting food waste away from landfill and into Anaerobic Digestion. For more information, please see the review of AD in Sainsbury's Sustainability Plan, which is widely avaiable online. 

(c) Post-Consumer

It is likely that the largest source of feedstock ( in volume terms) for this proposed facility will be post-consumer food waste, typically derived from a combination of local authorities and reputable waste companies with responsibility to collect segregated food waste material from both business and households. The majority of this material is currently disposed of to either landfill or composting; neither of which captures the energy value of the material. 

The vehicles delivering the feedstock will be enclosed and  sealed, typically having payload of around 20 tonnes. However, to provide a robust and precautionary assessment of the potential impact, we have undertaken our assessment on a worst case basis with smaller payloads of six tonnes. The biofertiliser will be exported from the site in 10 or 20 tonnes  tanker vehicles. 

Q 7: Will this waste be separated for the digestion process according to type ? 

A: The feedstock accepted at this proposed facility will all be received in the sealed Receptiopn Building referenced in the planning application, and noted in drawings used at the public exhibition etc. Material will be fed into the same infeed hopper and be homogenised early in the AD process. 

The facility would have the ability to de-pack post-consumer food-waste so as to segregate food-waste material from packaging. The packaging removed would subsequently be sent for recycling. 

Q 8: What will you do if the supply of intended waste goes down ?

Tamar Energy has completed significant research to ensure that there is sufficient suitable waste stream in the area around this proposed facility, to ensure that feedstock supplies can be maintained. You will appreciate that, for a commercial perspective, we need to have a very strong level of confidence in this regard. 

 Q 9: Output is stated as bio-fertiliser material: how will  it be disposed of ? 

A: The bio-fertiliser produced during the AD process is nutrient rich in its content, and therefore has an inherent commercial and renewable benefit as a sustitute for petro-chemical based fertilisers. The bio-fertiliser produced would be taken from the site in sealed containers to be provided (under contract) to local farmers or agricultural landowners to use on their land. 

This biol-fertiliser would have to received a quality certification known as PAS 110 before it could be used on agricultural land. This is a standard that certifies that the materials is no longer to be regarded as a waste, but as a product. 

Q 10: Where will it be stored ? 

A: There will be sufficient storage on-site within the proposed AD development to store the bio-fertiliser produced in sealed vessels/tanks. This will also ensure that sufficient storage exists to manage volumes at times during the year when local farmers etc. cannot spread the material. All such storage is totally enclosed. 

Q 11: Will this product be used for the proposed landscaping of the old part of the quarry ?

A: Potential exists for some of the bio-fertiliser produced to be used to enrich the nutrient value of the restored parts of the quarry. However, we do not as yet know what volumes of this material would be used in this regard, if at all. Spreading of bio-fertiliser on the restored quarry land would only represent a small part * of an overall solution. Any spreading of biofertiliser on this land would be managee under the appropriate permit where applicable. 

* We are seeking further re-assurances on this matter and asked if the fertiliser to be used to improve the landscaping will be odourless ( thanks John for this comment ). 

 

2. Friends of the Earth  and independent experts 

 

Friends of the Earth : Anaerobic Digestion - a technical briefing  for local group campaingners - November 2012 

Paragraph 94 and 95. 

" Today, well run AD plants are virtually odourless on the exterior. There can be a faint odour when you are within a few feet of a plant but what you can smell is actually the biogas. However, some of the early plants, through a combination of inappropriate design and bad operation, have a well- documentated history of odour problems   (Holdworthy Farm and Ludlow being good examples of this )"

"Odour problems in general only arise if waste is stored in buildings for several days and/or the odour treatment in insufficient. Food waste will always smell and it is how this is controlled and treated that is the key - the operation of a plant is key in this regard. Friends of the Earth local groups members who have visited large AD food processing plants say that other than internal in the main food waste reception hall odour was not noticeable. If the AD process itself causes odour then this means that the sealed process is leaking, or that it is not digesting and undigested waste is being taken out of the back end of the plant. " 

Anaerobic Digestion.com   The AD community: an independent wesbite *

" Concerned about odour need not, and really should not, hold back the development of either aerobic or anaerobic composting ( anaerobic digestion) plant facilities. Odour prevention is not "rocket science", but design for odour prevention starts with the initial design, and does not cost money and need investment, from the outset. If necessary, and the site is very close to properties, or the incoming feedstock is inherently very odorous during offloading/transfer, composting can be carried inside buildings, and these buildings are then provided with an odour filter which will render an odour free discharge. The building is then maintained at a negative internal air pressure and doors are kept closed, this no odour need escape "

 * for further information,  please visit Anaerobic Digestion.com

 

3. Green councillors' responses 

 

Cllr Julia Wakeman from Bury St Edmunds - 1st July 2013 

" Suffolk people are quick to defend their local area and I am sure that if there were any problems with the (Lackford AD) plant, as I am reasonably well know as a Greenie, I would have been made aware" .

Cllr Alex Dunn from Bristol - 3rd July 2013 

" I have not heard of anything bad being said about it (GENeco AD food waste recycling facility). It is a long way from housing though. Seems to have won lost of awards. Not aware any any smell when I've been to the nearby recycling plant ".

 

There is no denying that a number of residents up and down the country and abroad have had bad experiences with AD plants other than at Cannock Chase. 

Bearing in mind that not all of these are strictly AD Plants, we suggest you google the following:  Fernbrook Bio, Cannington, HL Foods, Cumbernauld, Hear Veskt in Norway, Farington on Lancashire, Blankenheimer and Osnabruck in Germany. 

 

We hope you have found this contribution to the debate helpful.

 

Do visit us again for our assessement of Peel Environmental Ltd and Marshall Mono Ltd  Planning Application due to be published shortly. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 







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