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Although energy from waste facilities produce carbon dioxide as a result of burning waste, landfilling waste produces both methane and carbon dioxide gas.
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There is significant public concern about the possible health risks and environmental impact of emissions from energy from waste facilities. The Scottish Environment Protection Agency (SEPA), as Scotland’s environmental regulator, is responsible for protecting the environment and human health from all process and activities we regulate – including energy from waste facilities.
This document describes the role energy from waste plays in waste management in Scotland, and explains how we ensure that human health and the environment are protected.
What is energy from waste?
Energy from waste is the process of creating energy, in the form of electricity and/or heat, from incinerating waste. Like all other combustion plants burning solid or liquid fuels, the incineration process produces emissions in the form of:
We regulate the environmental impact of these emissions under the Pollution Prevention and Control (Scotland) Regulations 2000, which includes the controls required under the European Waste Incineration Directive.
How can the heat from an energy from waste facility be used?
Energy from waste facilities can be designed to provide power (electricity) and/or heat, and the ratio of heat compared to power can be split to favour either. The distance you can send heat in a district heating scheme depends on how much energy is in the steam or hot water being sent out. The greater the energy content, the further it can be transported before system losses make it unsuitable. One waste company in Denmark transmits heat over 80km using booster stations to reduce energy losses. Further information on district heating in Denmark is available on our website^1.
Good quality district heating schemes use steam drawn off the turbine to heat the district hot water system, typically to around 80oC. By providing electricity, only low quality heat arising from steam condenser cooling operations is left, giving hot water which is – at best – about 40oC. That is sufficient for space heating large areas such as warehouses, sports centres etc, but is of little use domestically as most hot water systems run at 60oC.
An existing energy from waste facility in Lerwick provides heat to properties over 6km away. The Lerwick-based facility treats about 21,000 tonnes of residual waste per year and supplies over 900 domestic and commercial premises with heat, including leisure centres and a hospital.
The price range for a domestic heat exchanger providing heating and hot water is £1,000–1,500, plus installation costs. The price depends on the size of house and thus energy demand. Installation costs also depend on the type of heating system being replaced or upgraded. The size of the domestic heat exchanger is significantly smaller than a conventional boiler. The pipework sizes for distribution pipes are typically up to 200mm diameter and 25mm diameter on the actual house supply (the house supply size may increase for large houses).
(^1) www.sepa.org.uk/waste/information__resources/events/previous_events/sustainable_waste_management.aspx
In Lerwick, when the energy from waste facility^2 is not operating there is a standby boiler system which uses heavy fuel oil as a back up heat source.
Where will the waste for any proposed energy from waste facility come from?
Every household and business in Scotland generates waste, and that waste must be managed. Although recycling has increased, the remaining waste has traditionally been disposed of in landfills. The Zero Waste Plan^3 describes ways to make sure that as much waste as possible is recycled, and to maximise the resource value in remaining waste by recovering its energy.
Is energy from waste a renewable energy source?
No, but the energy produced by energy from waste facilities replaces that generated by other fuels such as coal, oil and natural gas. Scottish Planning Policy 6: Renewable Energy^4 identifies that energy from waste, landfill gas and other technologies will be used to help meet Scotland’s targets for increasing the amount of electricity generated from renewable energy sources, as this is a vital part of our response to sustainable development and climate change.
The Renewables Obligation is the main support scheme for renewable electricity projects in the UK. It places an obligation on UK suppliers of electricity to source an increasing proportion of their electricity from renewable sources. Renewable Obligation Certificates are issued to an accredited generator for eligible renewable electricity generated and supplied in the UK. More information is available from Ofgem^5.
Do energy from waste facilities undermine efforts to improve recycling?
No. Incineration is compatible with high rates of recycling. High recycling levels depend on efficient segregation of the recyclable materials: waste that cannot be technically or economically recycled can be incinerated and the energy recovered. The table below shows that countries which have high rates of incineration (compared to Scotland and the UK as a whole) also have high rates of recycling.
Recycled/composted Incinerated Landfill Denmark 41.2 53.8 5. Netherlands 64.4 32.9 2. Belgium 51.8 35.7 12. Germany 57.2 22.9 19. Luxembourg 35.7 41.6 22. France 28.2 33.7 38. UK 18.0 8.0 74. Source: e-Digest of Environmental Statistics, Defra 2006^6.
Are there safer alternatives to incineration?
All waste management activities pose some risk to human health and the environment. It is because of that risk that we control their operation and emissions through the environmental permit we issue to them. Energy from waste facilities must comply with stringent emissions standards and that means they are unlikely to pose a threat to health.
Once all technically and economically recyclable materials have been removed from the waste stream, landfill is the only alternative to incineration. Even if landfill gas is captured and used for
(^2) www.sheap-ltd.co.uk/site/Home%201.html (^3) www.scotland.gov.uk/Publications/2010/06/08092645/ (^4) www.scotland.gov.uk/Resource/Doc/171491/0047957.pdf (^5) www.ofgem.gov.uk/sustainability/environment/renewablobl/Pages/RenewablObl.aspx (^6) www.defra.gov.uk/evidence/statistics/environment/whatsnew.htm
We provide our views to the planning authority on the environmental impact of energy from waste facilities. We do this by commenting on strategic and local development plans and by responding to consultations on planning applications in our role as a statutory consultee. The advice we give in relation to planning applications for energy from waste facilities is:
How does SEPA determine at the planning stage whether a facility is likely to obtain a permit to operate?
An energy from waste facility requires both planning permission from the local authority and a permit under the Pollution Prevention and Control (Scotland) Regulations 2000 (PPC) from SEPA before it can operate.
Planning Advice Note 51: Planning Environmental Protection and Regulation^9 , states:
“When SEPA comments on a planning application and is also the environmental regulator, it should assess the land use aspects of the planning application to clarify whether, on the information available at the time, the proposed development is potentially capable of being consented under the licensing regime.”
We strongly encourage applicants to apply for planning permission and any environmental licence (such as PPC) at the same time. That’s because we prefer all the technical information required for all permissions and licences to be submitted at the same time as the planning application. However, we recognise that not all of the information required for environmental licences is always available at the planning stage – for example if the detailed design is incomplete.
As a minimum, the planning application must provide the necessary information on key environmental matters. We will not issue a permit if we believe the site will cause significant pollution to the environment or harm human health. We will inform the planning authority and the developer as early as possible in the planning process if we think we will be unable to grant the necessary environmental permit.
The information submitted at the planning stage should also include a detailed examination of energy recovery and use of heat and power generated to demonstrate that the facility will maximise its thermal efficiency. No development should start on site until a heat plan for the potential use of heat recovered has been provided, and the facility must be constructed in accordance with the details submitted.
What is the role and responsibility of local authorities in the planning process?
The local authority is responsible for land use planning and approving or rejecting applications for planning permission for waste management sites such as energy from waste facilities and landfills. As the planning authority, the local authority decides where an energy from waste facility should be built.
What happens if planning permission is not granted?
(^8) www.sepa.org.uk/waste/waste_regulation/idoc.ashx?docid=b61dc32b-f2e8-4f65-b237-
8e67c5194f08&version=- (^9) www.scotland.gov.uk/Publications/2006/10/20095106/
If planning permission is not granted then the facility cannot be built. The applicant can appeal against the decision to the Scottish Government’s Inquiry Reporters Unit or the Court of Session.
What happens if planning permission is granted?
In order to operate an energy from waste facility, the operator must apply to us for a permit under the Pollution Prevention and Control (Scotland) Regulations 2000 (as amended). We will follow the legal requirements set out by the European Union and the Scottish and UK Governments to ensure that the facility complies with relevant legislation.
There is no legal requirement to submit an application for a PPC permit before receiving planning permission.
When determining an application for a permit under the PPC Regulations, SEPA’s main aim is to ensure that the facility is operated in such a way, and under such conditions set in the permit, that human health and the environment remain protected from any harmful emissions.
Before reaching a decision to grant a permit, we must be satisfied that the applicant has demonstrated that the proposed facility meets the requirements of the legislation. The applicant must:
The application will be subject to statutory consultation, which includes the opportunity for public participation. We decide whether or not to grant a PPC permit, and the local authority is a statutory consultee in that process.
We then have to judge whether or not the application meets the requirements of the law. If it does, we will issue a permit defining what the applicant can and cannot do, including minimum performance standards. We are legally obliged to issue a permit if an application meets the legal requirements. We cannot grant a permit if it does not.
How can I get a copy of an application to operate an energy from waste facility?
We will make public as much of any application as possible on our website. Some parts of the application may not be available for practical reasons (such as large diagrams); however, you can view a hard copy in the local SEPA Registry Office. Please contact us^10 for more information.
What conditions will SEPA set in a permit?
Our permit will detail many things, covering every aspect of the facility’s operation, including:
(^10) www.sepa.org.uk/about_us/contacting_sepa.aspx
How will the proposals affect local air quality?
We will require the applicant to use advanced air quality modelling techniques to predict the effect of emissions. Their results will then be assessed by our modelling experts, who ultimately decide if the modelling has been performed correctly. We will assess these results to ensure that any effect on air quality is within acceptable levels.
Will emissions to air be a problem for ‘sensitive receptors’?
The air quality modelling described above predicts the ground level concentrations in the surrounding environment, including at ‘sensitive receptors’ such as hospitals, nurseries and nearby homes. The modelling is based on worst-case scenarios and must be within the limits in the air quality standards^12. The modelling results are used to consider the predicted impact on any sensitive receptor.
What difference does the weather make?
The weather affects how discharges from a chimney are distributed in the local environment. We take the weather into account when assessing any permit application. As part of an application, the operator will carry out pollution dispersion modelling, which aims to predict how the emissions will react in different weather conditions (ie not just the normal weather) at the proposed location. This includes any specific conditions that are prevalent and particular to the local area, such as haar, local topography and any effect they could have on dispersion of emissions.
What is the risk of damage to human health?
In October 2009 SEPA published a report Incineration of waste and reported human health effects^13. Carried out by Health Protection Scotland, the report looked at a range of previous studies on the health effects of incinerators, concluding that due to many uncertainties it is difficult to be definitive about the effects. However, it is clear from the studies that any past health effects on populations living near incinerators is likely to have been small.
Today's incinerators are subject to much stricter legislative controls. They use improved technology and produce less emissions, so any effects would be very small – if detectable at all.
What risk is there from dioxins emission?
Dioxins are formed by burning materials that contain chlorine. As well as industrial emissions, other significant sources include domestic stoves and fires, garden bonfires, fireworks, vehicle exhausts and tobacco smoke.
In 1995, 55% of all UK dioxin mass (total) emissions (in excess of 600g) came from waste incineration. Stricter controls on incinerators and their emissions were introduced in 1996, including a dioxin emission limit set at one nanogram (one thousand millionth of a gram per cubic metre [ng/m^3 ]) of flue gas. Consequently, emissions fell and in 2003–2004 the incineration of household waste produced between 0.04g and 0.21g of dioxins in total (<1%). The emissions limit was further reduced on the implementation of the Waste Incineration Directive in 2003: it now stands at 0.1ng/m^3 of flue gas.
A 2009 Department for Environment, Food and Rural Affairs (Defra) report showed dioxin mass emissions from incineration of municipal solid waste to be 0.02g in 2006. That compares to 2.64g from road transport, 4.41g from residential combustion and 60.59g from accidental fires. Research by the Food Standards Agency has also shown that, since 1992, there has been a 70% reduction
(^12) www.legislation.gov.uk/ssi/2010/204/contents/made (^13) www.documents.hps.scot.nhs.uk/environmental/incineration-and-health/incineration-of-waste-and-
reported-human-health-effects.pdf
in the amount of dioxins and polychlorinated biphenyl (a toxic chemical with high potential for accumulating in the food chain) released into the environment as a result of a combination of improved technology and stricter, more effective regulations. The concentrations of dioxins found in individual foods in a study in 2001 were all below EU safety limits.
While there is no safe level of exposure to dioxins, the research and information above show that emissions from incinerators are much less than other everyday sources, and that the risk of health effects from dioxins from incinerators is so small as to be undetectable.
(Units of weight expressed above refer to I-TEQ units for dioxin measurement.)
What risk is there from particulate material?
‘Particulate material’ refers to fine particles suspended in the atmosphere. It comes from a variety of sources, some of which are natural, and can affect human health. It can be various sizes but controls are in place for PM 10 (particles with a size less than 10 microns – ie 0.01mm) and PM2. (less than 2.5 microns, ie 0.0025mm). The smaller the particle the longer it remains in the air.
We request permit applications and Environmental Impact Assessments include particulate matter when assessing the effect of emissions. The outcome of that assessment will determine the contribution to the annual mean air quality objective, and is one of the factors we use in our impact assessment and decision-making.
The Air Quality Standards (Scotland) Regulations 2007, and the amended Air Quality Limit Values (Scotland) Regulations, define air quality standards for many airborne pollutants relevant to energy from waste processes. Further information on the application of air quality standards to this type of development is available on Page 51 of The Pollution Prevention and Control (Scotland) Regulations 2000 - A Practical Guide^14.
A review of the mass emissions of PM 10 particulates from a variety of sources was undertaken in 2001 by the UK Government’s Air Quality Expert Panel^15. It identified that, in the UK, transport generated the highest levels of PM 10 , with mass annual emissions of 48.4 kilotonnes (kT). Power generation produced 17.7kT, domestic heating generated 31.1kT, and waste disposal operations (including waste incineration operations, landfills etc) produced 1.5kT. Road and kerbside levels of particulates cause the most local air quality limit breaches in the UK. The report also noted that burning natural gas generates the same proportion of PM 10 , PM2.5 and PM0.1 as the incineration of waste.
It is important to also note that, due to regulatory changes, significant reduction in particulate emissions in the UK has been achieved over recent years (ie PM 10 emissions fell by 42% during 1990–2001 and are expected to fall a further 28% by the end of 2010).
The Scottish Government is currently consulting on Draft 2010 Air Quality Standards (Scotland) Regulations, which will introduce a Scottish PM2.5 air quality standard. The consultation and draft regulations are available at: www.scotland.gov.uk/Publications/2010/01/25153504/
Do these facilities create bad smells?
Any facility handling biodegradable wastes can cause a bad smell if adequate controls are not in place or if the wastes are not managed properly. We require facilities to control odours, for example by keeping the waste handling and storage areas under negative pressure and by extracting room air to the combustion plant or a suitable bio-filter.
More information on how we regulate potentially odorous sites can be found in our Odour guidance
(^14) www.scotland.gov.uk/Publications/2001/10/10153/File- (^15) www.defra.gov.uk/environment/quality/air/airquality/panels/aqs/
of £40,000 for each offence. However, the courts can impose unlimited fines in some circumstances.
What should I do if I suspect a site operator is in breach of their permit conditions?
Contact your local SEPA office^18 or call our free 24 hour pollution hotline on 0800 80 70 60.
Scottish Pollutant Release Inventory
The Scottish Pollutant Release Inventory (SPRI)^19 is a database of annual mass releases of specified pollutants to air, water and land from SEPA-regulated industrial sites. Operational energy from waste facilities must complete an annual SPRI report, which we publish after verifying.
(^18) www.sepa.org.uk/about_us/contacting_sepa.aspx (^19) www.sepa.org.uk/air/process_industry_regulation/pollutant_release_inventory.aspx