Objecting to JME's Incinerator-linked Waste Site on Barry Dock

The Natural Resources Wales consultation lasted till 9th February.  
Many members of DIAG sent in objections.  Barry&Vale FoE concentrated on some fundamental points for rejection of the license application.  Winning the point that the process comes under the Industrial Emissions Directive (IED) will be important in stopping the current operations, supposedly restricted to a Standard License.
JME have also started a pre-planning consultation - their present operations have no planning consent, but the VoG Council has failed to enforce against them.

JME want to take in waste wood, sort and chip it to make fuel for the Biomass incinerator, and also receive incinerator ash for onwards transfer.  They would do this in the open air, spreading the harmful dust everywhere with no regard to impacts.  The waste-wood is classed as "non-hazardous" but of course the dust from chipping it can be and is hazardous when breathed in.  NRW officers appear not to understand this!

FoE Objection to License 
for   J M Envirofuels (Barry) Limited, Berth 31 Wimborne Road, Barry Docks

   We point out this application for sorting and shredding wood for use of incinerator fuel comes under the Industrial Emissions Directive, as the processes improve the nature of the fuel and its quality for feeding the incinerator.

We therefore object fundamentally to licensing it outside the Directive's requirements.

We are aware that the NRW has formally agreed to exclude changes to the "physical nature" from its definition of processes that improve the nature of the fuel.

We challenge this as a wrong decision that has no basis in law or industry usage.

# Standard descriptions include physical and thermal methods to improve fuel quality. 

A quick internet search finds the Conference publication describes "commonly used methods to improve biomass fuel quality by physical and thermal transformation" in Research progress of biomass fuel upgrading and distributed utilization technology, by Liu, Shuguang et al.  DOI - 10.1088/1755-1315/227/2/022002  IOP Conference Series: Earth and Environmental Science

# Elsewhere are descriptions of improving biomass fuel quality by densification and moulding, like processes for producing fuel pellets   Thus industry usage shows NRW were wrong to exclude physical treatments from their definition of methods that improve fuel quality.

# The physical processes proposed at Berth 31 in fact improve quality.

JME say they collect materials from skips, such as doors, window frames, roof timbers, kitchen cupboards, used work-tops etc. These are likely to include metal handles and fitments, window glass which they sort out.  Excluding non-combustibles by definition improves the calorific value. Thus sorting undoubtedly improves its nature as fuel.

# The remaining waste wood is unusable as fuel until it is chipped/shredded; large pieces have to be excluded as they pass through the system incompletely combusted. The chipping/shredding undoubtedly improves its nature as fuel for the incinerator.

We therefore object that this application be rejected, and one submitted under the more stringent requirements for a facility covered by the IED.

In the IED submission, we expect proper evidence on the nature of the dust from the process, much of which is not "sawdust" as stated but fragments of paint and non-wood materials.  Data from similar waste wood chippers must be supplied, on the nature and hazard of the dust, on health-experiences from people living close to such facilities, and on environmental effect of the dust including in leaching chemicals into surface waters.

The IED submission must justify each statement in the Risk Assessment, showing the capacity of drainage systems can cope with the heaviest rainstorms and worst-case firewater usage; restriction on recreational use of dock waters from run-off contamination etc.   It must detail all receptors liable to be affected, not use the vague term livestock, but include mussel-farms as well as fish stocks in Barry Dock.

The IED submission must also detail how the 20 000 tonnes of wood waste could be accommodated on this site, when the two 'maltese crosses' of chipped wood can hold at most 2000 tonnes. In what form is the rest to be stored?

Request for an IED licence that covers both the incinerator and Berth 31 that supplies it.  

NRW officers said they thought one licence could not cover two companies, yet the Directive allows this, as long as the specific responsibilities are set out. 

Reasons for a combined licence are that

# the incinerator cannot function without this supplier - and have signed a long-term contract with them.  

# The quarantine area to receive part-burned fuel in case of fire on the incinerator site is at Berth 31.   JME have to set aside that quarantine area.  

# The haulage road between the incinerator and Berth 31 is a private road, not subject to controls on sheeting of lorries or spillages (which can affect nearby receptors, including the Dock's controlled waters). Only by NRW requiring a combined IED licence can the haulage be brought under proper controls for the protection of people and the environment.