The Pollution Prevention and Control Act 1999
Permit Reference: LAPPC/041/07/v1
Permit with Introductory Note
The Pollution Prevention and Control Act 1999
Environmental Permitting (England and Wales) Regulations 2010 (as amended)
OPERATOR
Burt Boulton and Haywood Ltd,
Alexandra Docks,
Newport
NP20 2WA
INSTALLATION
Burt Boulton and Haywood Ltd,
Alexandra Docks,
Newport
NP20 2WA
Permit issued by:
Newport City CouncilLaw & Regulation
Civic Centre
NEWPORT
South Wales
NP20 4UR / Telephone:
Fax:
Website:
Email: / 01633 656656
01633 233138
www.newport.gov.uk
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LAPPC/041/07/v2 FINAL DRAFT
The Pollution Prevention and Control Act 1999
Permit Reference: LAPPC/041/07/v2
LOCAL AUTHORITY POLLUTION
PREVENTION AND CONTROL (LAPPC)
Permit Reference Number: LAPPC/041/07/v2
Pollution Prevention and Control Act 1999
Environmental Permitting (England and Wales) Regulations 2010 (as amended)
NEWPORT CITY COUNCIL, (the “Regulator”) in exercise of its powers under Regulation 13 of the Environmental Permitting (England and Wales) Regulations 2010 (as amended), hereby Permit:
Burt Boulton and Haywood Ltd, (“the Operator”)
Alexandra Docks,
Newport
Gwent
NP20 2WA
to operate an installation at:
Alexandra Docks,
Newport
Gwent
NP20 2WA
in which an activity is being carried out as listed in Schedule 1 to the above-mentioned Regulations and as detailed in Table 1 – Process description.
The Permit is to the extent authorised by and subject to the Conditions contained in this Permit.
Signed on behalf of NEWPORT CITY COUNCIL
Jonathan Keen
Environmental Health Manager
Dated this day of
Permit issued by:
Newport City CouncilLaw & Regulation
Civic Centre
NEWPORT
South Wales
NP20 4UR / Telephone:
Fax:
Website:
Email: / 01633 656656
01633 233138
www.newport.gov.uk
STATUS LOG
Detail / Date / CommentsDate of Application / 03.02.15 / Full application
Date Duly Made / 15.03.15
Permit Issued / FINAL DRAFT
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LAPPC/041/07/v2 FINAL DRAFT
The Pollution Prevention and Control Act 1999
Permit Reference: LAPPC
Operating Conditions
The Permitted Activity involves processes for the purpose of the preserving of wood with chemicals (other than sapstain) with a production capacity >75m3 per day. In this permit the "permitted activity" comprises the whole operation including the treating, handling and storage of any materials used and products and wastes produced by the activities within the Installation Boundary.
The following process description divides the Installation into its elements and activities both those activities scheduled under the above regulations and those non-scheduled elements required to be regulated because of their polluting potential and that have a direct association and a technical connection to the scheduled activities:
The installation comprises the following activities and elements:
Ø Raw material storage element
Ø Timber pressure treatment activity (Bethel Process)
Ø Timber coating activity (Reuping Process)
Ø Timber drying element
Ø Creosote Recycling element
Ø Waste storage element
All process steps encompassed within the timber treatment activity are supported by specific equipment specifications, process controls, planned maintenance, quality assurance and product verification procedures.
Process Description and General Information
Raw material storage element
All deliveries to site are be booked in through the Purchasing Office to ensure there is no congestion on the yard area, booking slots are allocated to minimise noise, site traffic, avoiding spillages, leaks and emissions.
The storage area for all chemicals is under cover; chemicals must only be located in designated areas. Creosote is stored only in the tanks identified for its storage. All areas storing chemicals in bulk are hard surfaced and fully bunded.
Bulk Deliveries are by tanker, and are supervised by designated Operators. Bulk deliveries are all carried out within areas that are protected by hardstanding, connected to blind sumps, or connected to drainage systems that discharge directly into the waste water treatment processes. Filling of tanks is carried out within protected areas to ensure any potential spillages are contained.
Raw material storage is technically connected and directly associated with the activities falling within Schedule 1 of the Environmental Permitting (England and Wales) Regulations 2010 (as amended).
Creosote Treatment of Timber
There are two process used in the creosote treatment process treatment:-
· FULL- CELL (BETHEL) PROCESS
· EMPTY- CELL (REUPING) PROCESS
The treatment process can be summarised as follows:
· Loading of timber onto the trolleys appropriately secured (strapped) to prevent flotation
· Alignment of timber on the trolleys to allow entry into the autoclave
· Careful movement of the trolleys into the autoclave to the rear stop position
· Closure and sealing of the door, ensuring the seal is clean and free from debris to avoid leaks
· Locking the door, ensuring safety devices are in position
· Selection of the appropriate treatment cycle for the timber product, dependent on end use of the timber, and ensuring that there is sufficient treatment chemical in the work tank to fully flood the autoclave
· Start the treatment process:
Full-cell (Hethel) process
INITIAL VACUUM: Air is evacuated out of the autoclave and the timber, creating a negative pressure of approximately -0.8 bar. Typically the vacuum pump will stop when the target intensity of vacuum has been achieved. Vacuum will be held in the autoclave for a set time period depending on the treatment cycle selected. This has the effect of drawing air out of the wood, so making room for the preservative fluid that will replace it.
VACUUM FILL: Once the pre-set initial vacuum stage is completed, the autoclave will fill with preservative under vacuum and the vacuum pump(s) will switch back on. The ‘vessel full’ sensor positioned in the vacuum line detects that the autoclave is full.
PRESSURE: Hydraulic pressure is raised within the vessel by the start of the pressure pump. Monitoring of the preservative uptake starts automatically when slight positive pressure is seen in the autoclave. Pressure relief valves are integral to the system, one at working pressure (9.5 bar) and safety back higher (14bar). During this phase preservative fluid is impregnated deep into the wood structure, to replace the air removed during the initial vacuum stage.
PRESSURE RELEASE: This occurs when the pressure phase has reached the required amount of preservative has been injected into the timber. Pressure (and any excess preservative fluid) is then released back into the storage tank
INITIAL DRAIN: Preservative is returned to the work tank once pressure has been released back to atmospheric level. The autoclave is emptied by a combination of gravity and an additional fluid transfer pump. The ‘vessel empty’ sensor is positioned in the main flood line and so detects when the autoclave is empty.
FINAL VACUUM: A negative pressure of -0.8 bar is created once more and maintained for a minimum of 4hours. During this phase excess fluid is drawn from the timber.
VENT / FINAL DRAIN: After final vacuum, the negative pressure generated in the autoclave is released and some remaining excess fluid on the surface of the wood is sucked into the wood structure, helping to further dry the treated product before unloading. The vessel is then vented before any residual preservative remaining inside the autoclave is recovered back to the work tank and the vessel door finally re-opened.
END OF CYCLE: When the autoclave is empty the cycle will stop and a charge report is generated. The timber can be removed and the process restarted if required.
Empty cell (reuping) process
Preliminary air pressure: Hydraulic pressure is raised within the vessel by the start of the pressure pump to 3bar This has the effect of filling the wood cells with air so that the cells within the wood can be coated with creosote and not filled as like the full-cell (Bethel process).
Filling the cylinder: Once 3 bar of pressure is held for 30-35miniutes stage is completed, the autoclave will fill with creosote. The ‘vessel full’ sensor positioned on the top of the treatment cylinder detects that the autoclave is full.
PRESSURE: Hydraulic pressure is raised within the vessel by the start of the pressure pump. Monitoring of the preservative uptake starts automatically when slight positive pressure is seen in the autoclave. Pressure relief valves are integral to the system, one at working pressure (9.5 bar) and safety higher (14bar). During this phase preservative fluid is impregnated deep into the wood structure coating the cells.
PRESSURE RELEASE: This occurs when the pressure phase has reached the required amount of preservative and has been injected into the timber. Pressure is usually released back into the scrubber unit. Ans discharged to atmosphere.
INITIAL DRAIN: Creosote is returned to the work tank once pressure has been released back to atmospheric level. The autoclave is emptied by a combination of gravity and an additional fluid transfer pump. The ‘vessel empty’ sensor is positioned in the main flood line and so detects when the autoclave is empty.
FINAL VACUUM: A negative pressure of -0.8 bar is created once more and maintained for a minimum of 4hours. During this phase excess fluid is drawn from the timber and autoclave back to the storage tank.
VENT / FINAL DRAIN: After final vacuum, the negative pressure generated in the autoclave is released and some remaining excess fluid on the surface of the wood is sucked into the wood structure, helping to further dry the treated product before unloading. The vessel is then vented before any residual preservative remaining inside the autoclave is recovered back to the work tank and the vessel door finally re-opened.
END OF CYCLE: When the autoclave is empty the cycle will stop and a charge report is generated. The timber can be removed and the process restarted.
The collection and treatment of creosote is subject to a Natural Resources Wales Permit (ref: EPR/GB3593/HE dated 02.03.15).
Pressure treatment of wood with chemicals is a scheduled Activity within section 6.6 of the Environmental Permitting (England and Wales) Regulations 2010 (as amended). The activity also comprises a Solvent Emission (SE) activity as defined under Schedule 14.
Post Treatment Drying Area
Treated product is only removed from the autoclave when the product is no longer dripping creosote, and is essentially dry. All treated poles are held on the charge bogey within the rail tracks, which form the outer limit of the installation boundary. All pole charges are inspected prior to their removal from the immediate drying area. The immediate drying area consists of impermeable concrete. There is no forced drying (curing) carried out.
Waste storage element
Waste generated within the installation, including straps, timber sludge and distillate residues from Creosote recovery, etc. are stored in locations and in such a manner as to ensure proper control of the wastes. i.e. creosote contaminated waste is secured in sealed containers prior to dispatch for recovery. Wastes stored onsite are located as noted in the Plan ref: MB006.
Waste storage elements of the installation is technically connected and directly associated with the activities falling within Schedule 1 of the Environmental Permitting (England and Wales) Regulations 2010 (as amended).
Plant & Equipment
The Operator is permitted to carry out the activities and/or the associated activities specified in Table 1.
Table 1
Activity under Schedule 1 of the Regulations / Schedule 1 Activity Reference / Description of Specified ActivityChapter 6 / Section 6.6
Timber activities / Part A(2)
(a) Preservation of wood and wood products with chemicals with a production capacity exceeding 75m3 per day other than exclusively treating against sapstain
The permitted installation shall consist only of that plant and equipment listed in Table 2 below. No other relevant plant or equipment capable of emitting pollutants to air, land or water shall be used without the prior written consent of the regulator.
The key process plant is listed in Table 2 below:
Table 2
Process Plant/Equipment / Emissions to environment / Monitoring, sampling and controlDelivery Tank 1 / VOC, heat / fugitive
Delivery tank 2 / VOC, heat / fugitive
Storage tank 1 / VOC, heat / fugitive
Storage tank 2 / VOC, heat / fugitive
Storage tank 3 / VOC, heat / fugitive
Creosote Processing Plant 1 / VOC, heat / fugitive
Creosote Processing plant 2 / VOC, heat / fugitive
Vacuum plant and tank / VOC, heat / fugitive
Autoclave 1 / VOC, heat / fugitive
Autoclave 2 / VOC, heat / fugitive
Scrubber unit tank / VOC, heat / fugitive
Boiler / Smoke, NOx, PM10, heat / Good combustion, maintenance, no dark smoke
Conditions
1. Any system or procedures used to demonstrate compliance with a condition of this permit shall be recorded.
2. All records kept in compliance with conditions of this permit shall be kept in a systematic manner.
3. Unless otherwise specified in a condition of this permit, every record made in compliance with a condition of this permit shall be preserved for not less than 2 years from the date of its being made. Every such record shall be kept at the permitted installation for not less than 1 year from the date of its being made and thereafter preserved at a location, previously notified to The Regulator in writing, if that location is not the permitted installation.
4. All records shall be legible, and any amendments made to any record in compliance with a condition of this permit shall be made in such a way as to leave the original entry clear and legible. The reason for each amendment shall be explained in the said record.
5. Without prejudice to condition 3, all records relevant to the operation or maintenance of the permitted installation shall be kept at the permitted installation for not less than 1 year from the end of the period to which they apply.
6. The permitted installation shall consist only of that plant and equipment listed in Table 2 (above). No other relevant plant or equipment capable of emitting pollutants to air, land or water shall be used without the prior written consent of the regulator.
Emission Limits and Controls
Air
7. The use of dilution of air to achieve emission concentrations limits shall not be permitted. Dilution air may be added where justified for waste gas cooling or improved dispersion. In such cases, monitoring should be carried out upstream of the dilution air input or procedures designed to correct for the ratio of input air to the satisfaction of the regulator.
8. All releases to air, other than condensed water vapour, shall be free from persistent visible emissions.