Summary
• Prevention of pollution at source is the preferred option.
• Companies are rated as high, medium or low risk in the allocation of local air pollution permits.
• Savings of almost £900 per year can be made.
• Further scope for saving exists for companies with authorised wood combustion systems.
Over the past five years there has been a range of changes to the traditional controls on air pollution from timber processing companies. These controls apply to sites in a range of circumstances:
• manufacture of timber and wood based products – where sites process more than 1,000m³ of timber or purely saw more than 10,000m³ in any consecutive 12-month period;
• wood combustion in boilers rated from 0.4-3.0MW net rated thermal input – with multiple boilers on a single site having their ratings added together if their function could not be provided by a single unit;
• wood coating using more than 5 tonnes of organic solvent per year.
The regimes were originally under the umbrella of Local Air Pollution Control but this is now Local Air Pollution Prevention & Control, which recognises that prevention of pollution at source is always the preferred option.
Historically, each permit had a fixed annual renewal fee of around £700-800. The current system rates each company according to the risk profile of the process and the charges vary accordingly. The fees in 2008/9 will be:
• high risk – £1,581
• medium risk– £1,060
• low risk activity– £706
With a small amount of effort, it is possible to shift a “high risk” site to the “low risk” category with a saving of over £880 per year. The risk-based assessment system can be viewed at www.Defra.gov.uk/environment/ppc/localauth/fees-risk/pdf/laippc-risk.pdf
Regulators use a template to assess each permit. They score the site against two categories of criteria – environmental impact appraisal (EIA), which concerns the potential environmental impacts of an activity according to its type, level of upgrading to meet regulatory requirements, and its location; and operator performance appraisal (OPA) which relates to how well the operator manages the potential environmental impact of the activity.
Each of these aspects is evaluated by scoring the activity against a number of different components. The higher the perceived risk, the higher the score. Operators achieving a total score above 80 are rated as “high” risk and will pay accordingly. Ratings of 40-80 are “medium” risk with “low” risk below 40.
Work with a handful of timber processing companies has shown that good scope exists to reduce their scores, especially in the “assessment of management training and responsibility” section relating to operator performance. If not properly managed, this section can contribute 25 points to the company total. If properly managed, the section can subtract five points from the company total.
How to save money
The section headings in the management and responsibility section of the form are listed below, with advice on what needs to be undertaken to demonstrate compliance.
• Documented procedures in place for implementing all aspects of the authorisation?
• Specific responsibilities assigned to individual staff for these procedures?
• Completion of individual responsibilities checked and recorded by the company?
Compliance with these requirements involves working through your permit and drawing out the main requirements for control.
• Documented training records for all staff with air pollution control responsibilities?
• Trained staff on site throughout the periods where potentially air polluting activities take place? A simple 15-30 minute training programme is all that is required, covering: What environmental impact can the process have? What controls does the company have in place? What is the role of the individual in ensuring compliance?
• Is an appropriate environmental management system in place?
This can either be certified (for example, ISO 14001) or uncertified. The aim is to ensure that systems are in place to ensure the systematic management of relevant issues. Companies with no customer pressure for badges of achievement can document a simple in-house management system to show that there is a method to ensure the management of all environmental issues.
For those companies with authorised wood combustion systems, further scope for saving exists with regard to continuous monitoring equipment. This will typically have a capital cost of £20,000-30,000 and will usually be unreliable, especially with regard to carbon monoxide. Consequently, there will be sizeable maintenance and re-calibration costs.
Alternative monitoring
Discussions with local regulators may allow an alternative approach to monitoring for authorised plant. For example, some argue that an oxygen trim system is preferable to standard monitoring kit. The latter typically performs no active role, but simply records performance. However, oxygen trim mechanisms involve the monitoring of temperature and oxygen with a feedback mechanism which can control the fuel feed rate and oxygen levels. If the temperature and oxygen levels are maintained within specific parameters, it is argued that carbon monoxide is effectively destroyed.
Such a theory can be tested using a relatively inexpensive (£1,000) hand-held device. These units are only designed for occasional use – for example, weekly checks on combustion performance. They are self-calibrating and simply require the insertion of the monitoring probe into the stack.
A number of sites have been able to convince their regulators that such units have the potential to take the place of continuous monitoring, either with or without oxygen trim.
