appendix 8b: odour management plan - planning … · 8b.1.20 this document forms appendix 8b of the...

Ferrybridge Multifuel 2 (FM2)

Document Ref: 6.4.11

Environmental Statement – Volume III (Appendices)

July 2014 Appendix 1A

APPENDIX 8B: ODOUR MANAGEMENT PLAN


Document Ref No: 6.4.11

PINS Ref: EN010061

The Proposed Ferrybridge Multifuel 2 (FM2) Order

Ferrybridge Power Station Site, Knottingley, West Yorkshire

Appendix 8B - Odour Management Plan

The Planning Act 2008

The Infrastructure Planning (Applications: Prescribed Forms and Procedure)

Regulations 2009

Regulation 5(2)(a)

The Infrastructure Planning (Environmental Impact Assessment) Regulations

2009

Applicant: Multifuel Energy Limited

Date: July 2014

Document History

July 2014 (i)

Document Number 6.4.11

Revision

Author Sarah Taylor(URS)

Signed Date 25.06.14

Approved By Richard Lowe (URS)

Signed Date 25.06.14

Document Owner URS

Revision History

Revision No. Date Reason for Revision Authorised By

Submission version July 2014 K Cobb



Appendix 8B - Odour Management Plan:

July 2014 (ii)

Glossary

MEL Multifuel Energy Limited

DCO Development Consent Order

PINS Planning Inspectorate

PA 2008 Planning Act 2008

MWe megawatts

FM2 Ferrybridge Multifuel 2 Power Station

SoS Secretary of State

FM1 Ferrybridge Multifuel 1

SSE SSE Generation Ltd

WTI Wheelabrator Technologies Inc.

EfW Energy from Waste

WMDC Wakefield Metropolitan District Council

ha hectares

APFP Applications: Prescribed Forms and Procedures

CEMP Construction Environmental Management Plan

EIA Environmental Impact Assessment

MSW Municipal Solid Waste

C&I Commercial & Industrial (Waste)

ES Environmental Statement

WDF Waste Derived Fuel

BAT Best Available Techniques




July 2014 (iii)

Contents

8B.1 Introduction ............................................................................................................................... 1

The Background to the Proposed Development ......................................................................... 1

The Applicant .............................................................................................................................. 1

The Application Site .................................................................................................................... 2

The Proposed Development ....................................................................................................... 2

The Purpose and Structure of this Document ............................................................................. 2

8B.2 Proposed Development Overview ........................................................................................... 3

Fuel Deliveries............................................................................................................................. 3

8B.3 Potential Sources of Odour ...................................................................................................... 4

8B.4 Potential Receptors .................................................................................................................. 5

8B.5 Legislative Controls .................................................................................................................. 6

8B.6 Physical Controls ...................................................................................................................... 7

Routine Operations ..................................................................................................................... 7

Abnormal Operations (Commissioning/ Maintenance/ Outage) ................................................. 7

Fuel Acceptance Procedures ...................................................................................................... 8

Monitoring .................................................................................................................................... 8

Management of OMP .................................................................................................................. 9

8B.7 References ...............................................................................................................................10




July 2014 Page 1 of Appendix 8B

8B. APPENDIX 8B - ODOUR MANAGEMENT PLAN

8B.1 Introduction

8B.1.1 This framework Odour Management Plan has been prepared in support of Multifuel

Energy Limited’s (the Applicant’s) application (the Application) for a Development

Consent Order (DCO) that has been made to the Planning Inspectorate (PINS) under

Section 37 of the Planning Act 2008 (the PA 2008).

8B.1.2 The Application seeks a DCO for the construction and operation of a new build ‘multifuel’

power station of up to 90 megawatts (MW) gross output and associated development (the

Proposed Development). The Proposed Development is known as Ferrybridge Multifuel

Power Station (hereafter referred to as FM2) and will be located within the existing

Ferrybridge Power Station site in Knottingley, West Yorkshire.

8B.1.3 The DCO, if granted, would be known as the ‘Ferrybridge Multifuel 2 (FM2) Power Station

Order’.

The Background to the Proposed Development

8B.1.4 FM2 will be capable of producing low carbon electricity through the use of waste derived

fuels from various sources of processed municipal solid waste, commercial and industrial

waste and waste wood. It will therefore make a positive contribution toward the UK

Government’s climate change commitments, in addition to increasing the diversity and

security of national electricity supply, while also reducing the amount of waste sent to

landfill.

8B.1.5 A similar multifuel power station is already being constructed on land within the

Ferrybridge Power Station site. This project is known as Ferrybridge Multifuel 1 (FM1)

Power Station and was consented under Section 36 of the Electricity Act 1989 in October

2011. It is anticipated that FM1 will be fully operational from Q3 2015.

8B.1.6 The level of interest received from potential fuel suppliers in relation to FM1 has

demonstrated that there is sufficient demand and fuel availability for a second multifuel

power station at Ferrybridge. This is one of the reasons that have led to the Applicant’s

decision to progress FM2.

The Applicant

8B.1.7 The Applicant, Multifuel Energy Limited (MEL) is a 50:50 joint venture that has been

formed by SSE Generation Ltd (SSE) and WTI/EfW Holdings Ltd, a subsidiary of

Wheelabrator Technologies Inc. (WTI) to develop low carbon electricity generating plant.

8B.1.8 SSE is one of the UK’s leading energy companies and the largest non-nuclear electricity

generator, operating a diverse portfolio across the UK and Ireland. A subsidiary of SSE

owns and operates the Ferrybridge Power Station site, which includes the operational

Ferrybridge ‘C’ coal-fired Power Station.

8B.1.9 WTI is a leading developer, owner and operator of energy from waste (EfW) facilities and

has been established for over 37 years. WTI currently owns and/or operates 21 energy

facilities in the USA, 17 of which are EfW facilities. It has also recently acquired part of a

business in China that has three operational plants and a further six under development.

8B.1.10 The Applicant has an option agreement in place to enter into a lease for the land within

the Application Site (the proposed DCO (‘the Order’) Limits’) that is within the control of

SSE, while the draft DCO seeks the necessary powers and authorisations in respect of

the land that lies outside SSE’s control.

8B.1.11 Further information on the Applicant can be found by going to the FM2 project website:

www.multifuelenergy.com/fm2 .

http://www.multifuelenergy.com/fm2





The Application Site

8B.1.12 The Application Site (the Order Limits) comprises almost entirely land inside the

boundary of the Ferrybridge Power Station site and is entirely within the administrative

area of Wakefield Metropolitan District Council (WMDC). The Ferrybridge Power Station

site is situated between the River Aire to the north and east and the A1(M) immediately to

the west.

8B.1.13 The Application Site itself extends to approximately 32 hectares (ha) and consists

primarily of land that originally formed part of the Power Station’s former golf course,

including land that is currently being used in connection with the construction of FM1, in

addition to other land (some of which is outside the Power Station site) that may be

required for electricity grid and utilities connections.

8B.1.14 A detailed description of the Application Site and its location and surroundings is provided

in the ‘Application Site Description Document’ (Application Document Ref. No. 5.2), which

forms part of the Application.

The Proposed Development

8B.1.15 The Proposed Development comprises the multifuel power station (the ‘onshore

generating station’) and all the elements that are integral to it, including the fuel reception

and storage facilities, combustion system, steam turbine and emissions stack, amongst

others, as well as associated and supporting buildings, structures, plant and areas.

8B.1.16 In addition, it includes ‘Associated Development’ within the meaning of Section 115(2) of

the PA 2008 that will support the operational of the multifuel power station. This

comprises a connection to the electricity grid network, improvements to an existing

access road and a new foul water connection.

8B.1.17 The Proposed Development will also involve temporary works connected with the

construction phase, such as contractors’ compounds and laydown areas.

8B.1.18 A detailed description of all the elements of the Proposed Development is provided in the

‘Proposed Development Description Document’ (Application Document Ref. No. 5.3).

8B.1.19 It is currently anticipated that (subject to a DCO being granted and a final investment

decision being made) work will commence on the Proposed Development in Q4 of 2015,

with construction expected to be completed by Q2/Q3 of 2018. Subject to construction

being completed within this timescale, the multifuel power station would enter commercial

operation in Q4 2018.

The Purpose and Structure of this Document

8B.1.20 This document forms Appendix 8B of the Environmental Statement that accompanies the

DCO application. It provides a framework for the management of odour should it arise

from the operation of the Proposed Development. It has been prepared with reference to

Institute of Air Quality Management Guidance (Ref 8B-1)

8B.1.21 At this stage in the development process, the detailed design of the Proposed

Development has not been undertaken as a construction contractor has not yet been

appointed, and therefore any specific odour control measures cannot yet be designed or

sized. However, it is recognised that odour nuisance is a potential concern of the

community and therefore this framework has been developed to which the appointed

contractor must adhere. Odour control will also be managed in accordance with the

principles of Best Available Techniques (BAT) and regulated by the Environment Agency

through the Environmental Permit required for the operation of the multifuel power

station.





8B.2 Proposed Development Overview

8B.2.1 The Proposed Development is a Multifuel Power Station with an electrical generation

capacity of up to 90 MW from the combustion of Waste Derived Fuel (WDF) from various

sources of processed Municipal Solid Waste (MSW), ‘commercial and industrial’ waste

and waste wood. Generated electricity will be exported to the electricity network.

8B.2.2 In outline the process will be as follows:

Fuel will be delivered to the Proposed Development by road, with the additional option

of rail deliveries. The fuel will be unloaded in the tipping hall and stored in a fuel

bunker;

there will be a single shared bunker serving two combustion lines;

for each line, fuel will be moved from the bunker to the furnace where it will be

combusted, generating gases and bottom ash residues;

bottom ash will be ejected to a water bath to cool the ash and provide a gas seal;

the gases will be passed through a boiler to raise steam. The steam from both boilers

will then be passed to a shared steam turbine to generate electricity for use within the

facility and for export;

the resulting flue gas will be cleaned in a Flue Gas Treatment (FGT) plant. This is

anticipated to include the injection of activated carbon (primarily to control dioxin and

furan and heavy metal emissions); the injection of lime or suitable equivalent to control

acid gas emissions; and the use of fabric filters to remove dust. Selective Non

Catalytic Reduction (SNCR) will be installed, which would be used to abate nitrogen

oxide emissions if required;

the cleaned exhaust gases will be released to atmosphere via a stack circa 120 m

high (with the top of the stack fixed at 136 mAOD): and

the facility will be Combined Heat and Power (CHP) Ready as defined within

Environment Agency guidance (Ref 8B-2). If a local heating demand becomes

available, the provision of a heat off-take to supply a potential network would be

possible with minimal modifications to the installed system.

8B.2.3 An Environmental Statement (ES) has been prepared as part of the Environmental

Impact Assessment (EIA) Process. Chapter 8 Air Quality of the ES (Application

Document Ref. No. 6.2) presents an air quality impact assessment which addresses the

potential effects on local air quality predicted to arise as a consequence of emissions to

air from the Proposed Development during construction, operation and eventual

decommissioning. Part of the air quality impact assessment discusses the potential for

odour to impact local receptors and the controls in place to manage this impact.

Fuel Deliveries

8B.2.4 Fuel will be delivered to the Proposed Development by road, with the additional option of

rail deliveries. The preferred and most sustainable transport route for different fuel

contracts will be determined on a case by case basis through discussions with the fuel

supplier, based on proximity to the Site, volume of fuel, economics and transport facilities

at the fuel provider locations.

8B.2.5 The fuel will be delivered to the Site in enclosed containers. Only once the vehicle is

inside the tipping hall will it be opened and tipped into the fuel bunker. Cranes will then lift

the fuel from the fuel bunker into hoppers to subsequently be discharged onto the grate

where it is burnt. This process ensures that all routine fuel handling is done inside the

tipping hall building where the systems described in this Management Plan (see Section

8B.6 below) can control the odour.





8B.3 Potential Sources of Odour

8B.3.1 Odour could potentially be generated from the WDF used at the Proposed Development.

8B.3.2 The odour associated with the fuel could be due to the type of fuel itself or from the

decomposition/ degradation of the fuel during storage.

8B.3.3 No significant odours are envisaged from the handling and storage of combustion by-

products or Flue Gas Treatment (FGT) reagents; the latter (e.g. aqueous ammonia) will

be stored in sealed tanks and filled from tankers fitted with back-venting systems to

minimise fugitive emissions in accordance with indicative ‘Best Available Techniques’

(BAT).

8B.3.4 At this design stage it is anticipated that there will not be any significant odour releases

and therefore there are no likely significant effects anticipated (without mitigation) for

odour. However, the Applicant has given consideration to potential receptors located

near to the Site and outlined the legislative and physical controls to be put in place.





8B.4 Potential Receptors

8B.4.1 The Ferrybridge Power Station site extends to an area of approximately 300 ha, of which

the Proposed Development is being constructed on land that was formerly used as a golf

course, in the north-western part of the Power Station site. The land uses immediately

surrounding the Ferrybridge Power Station site are summarised as:

North: River Aire and Fryston Wood, beyond which are arable fields, small villages

and farms;

South: Stranglands Lane, beyond which are the residential areas of Pollards Fields

and Knottingley;

East: River Aire, Kirkhaw Lane and railway lines, industrial and commercial premises

and a water treatment works, beyond which are arable fields, small villages (including

Brotherton) and farms; and

West: A1(M) and its embankment, wood land and agricultural land (including Fryston

Park and Holmfield Farm) beyond which is Castleford.

8B.4.2 Key receptors have been identified as part of the EIA process and summarised below.

Further details are included in the relevant ES chapters. Where distances are quoted

below, the distance is defined (unless otherwise stated) as the shortest distance between

two described locations, for example from closest point of the Proposed Development

Site boundary to the closest point of a designated site boundary.

8B.4.3 The potentially sensitive receptors to the Proposed Development include:

Local farms and including Holmfield Farm (200 m west), Top Farm (340 m west),

Manor Farm (40 m south-east) and Fryston Hall Farm (900 m north);

Local residents at Oakland Hill off Fryston Lane immediately west of the A1(M),

approximately 200m west of the Site;

Local residents immediately to the south of the Ferrybridge Power Station site off

Stranglands Lane and Kirkhaw Lane;

Local residents of the surrounding urban areas including Castleford, Brotherton,

Ferrybridge and Knottingley; and

Users of local recreational facilities including:

Fryston Park Local Wildlife Site;

Fairburn and Newton Ings Site of Special Scientific Interest (SSSI) and Local Nature

Reserve;

Madbanks and Ledsham Banks SSSI and Local Nature Reserve;

Ledstone Hall and Park; and

Friarwood Valley Gardens.





8B.5 Legislative Controls

8B.5.1 A number of legislative controls are in place to control emissions to air in the UK,

including the Air Quality Standards Regulations 2010, The Environment Act 1995, The

Environmental Permitting (England and Wales) Regulations 2010 (as amended) (EPR)

and the Industrial Emissions Directive (IED) (Ref. 8B-1).

8B.5.2 Of these, the key regulations which direct how odours are mitigated and managed at

regulated facilities are the EPR. These regulations require operators of specified

activities to apply to the Environment Agency for an Environmental Permit prior to

commencing works.

8B.5.3 The Environmental Permit for the operation of the Proposed Development will require the

control of emissions to avoid odour at a level which could cause annoyance outside the

Site, together with the implementation of appropriate control measures to minimise any

odour.

8B.5.4 Once duly made, the Environment Agency will regulate the facility to ensure its

compliance with the conditions stated within the permit (including those relating to odour

control).

8B.5.5 In accordance with the IED, the Environmental Permit will stipulate that control measures

at the facility use ‘Best Available Techniques’ (BAT). An odour assessment and high

level BAT justification has been prepared for the Environmental Permit application that is

being submitted at the same time as this DCO application, recognising that until a

contractor has been appointed for construction, definitive design information and BAT

justifications cannot be provided.

8B.5.6 The control of odour must be in accordance with the use of BAT as outlined in

Environment Agency and European sector guidance and the Environment Agency

Horizontal Guidance Note for Odour H4 (Ref. 8B-3).





8B.6 Physical Controls

8B.6.1 There are two scenarios that need to be considered for odour control: when the power

station is in operation and when the power station is shut down, during periods of

maintenance for example. These two scenarios are considered below.

Routine Operations

8B.6.2 A competent person will be assigned as responsible for each of the routine control

procedures outlined below, which will be managed through the Environmental Permit for

the operational Proposed Development.

8B.6.3 Odours from delivery vehicles will be minimised by the use of enclosed vehicle

containers, in accordance with indicative BAT. The drivers will also be required to close

the containers after unloading, so that the empty trucks are also not open to the

atmosphere. The fuel will be kept enclosed until it is tipped from the vehicle within the

tipping hall, thereby complying with the BAT requirement to enclose waste derived fuel

until it is received in the furnace.

8B.6.4 When the power station is in operation, odour control will be achieved by drawing air from

the fuel bunker and tipping hall through into the combustion system, which will need air to

ensure effective combustion of the fuel. This is in accordance with the BAT requirement

for air from potentially odorous areas to be fed into the combustion system as far as

possible.

8B.6.5 The system will be designed to provide a slight negative pressure within the tipping hall,

minimising the risk of any odours being released as fugitive emissions from the tipping

hall and fuel bunker.

8B.6.6 During normal operation, air would be drawn into the combustion system via two potential

routes:

If the doors to the tipping hall are shut, air would be drawn through vents or louvers;

and

If the doors to the tipping hall are open (during lorry movements), air would be drawn

through the open doors.

8B.6.7 The fuel bunker will be accessed from the tipping hall via tipping bays. Each bay will have

its own cover that would be closed except when deliveries are taking place. When the

covers are in place, vents would allow a flow of air into the fuel bunker. Air would be

drawn from the fuel bunker by the primary air fan of each combustion line.

8B.6.8 The Proposed Development will be designed to maintain an appropriate negative

pressure within the fuel bunker and tipping hall; throughout operation the operational

practice will be to keep the main doors closed where possible so as to restrict

opportunities for fugitive emissions to be carried out of the building.

8B.6.9 Each of the two combustion lines is being designed to operate for around 90% of the time

and planned maintenance periods will be staggered with the intention of keeping at least

one combustion line in operation for 51 weeks of the year. Therefore, through the

installation and operation of two combustion lines, it is expected that at least one line will

be in operation up to 98% of the time throughout the year.

Abnormal Operations (Commissioning/ Maintenance/ Outage)

8B.6.10 A competent person will be assigned as responsible for each of the procedures outlined

below to manage abnormal operations such as commissioning, maintenance and outage.

8B.6.11 When the power station is shut down there will typically be some fuel stored in the fuel

bunker and there may also be deliveries of fuel during the period. However, for planned





off-line periods, both the volume of stored fuel and the deliveries would be reduced where

possible, subject to contractual obligations, in accordance with indicative BAT.

8B.6.12 It is recognised that there is a risk of increased odour from fuel that is stored in situ for

extended periods. Fuel stocks will be managed by the trained operators who will first of

all screen incoming loads that arrive from new sources for example, so they can be

handled appropriately or, if necessary, returned to the supplier. Fuel within the bunker

will then be rotated where possible such that older fuel is prioritised for combustion over

newly received fuel. Good mixing of the fuel will be undertaken to minimise the potential

for development of anaerobic conditions thereby minimising the potential for generation of

odours.

8B.6.13 It is recognised that indicative BAT as specified in the EU BAT Reference document (Ref.

8B-4) is to make provision for the control of odour when the power station is not

operating, by avoiding fuel storage overload and/ or the use of an alternative odour

control system.

8B.6.14 At this stage, the management of fuel stocks is proposed for odour management as the

use of primary means to control a potential emission is higher up the BAT hierarchy than

the use of secondary abatement techniques. However, the Proposed Development will

be designed such that, should the need arise, additional odour control techniques could

be retrofitted to further control odour releases, using for example carbon filters. If

installed, any such control system would be cleaned and maintained under the Site

preventative maintenance regime to minimise the risk of failure. Should the abatement

technologies suffer a temporary break down, or loss of efficiency, the maintenance team

will investigate the cause and fix the issue as soon as practicable.

8B.6.15 Should fuel materials be spilled during handling, they will be collected and returned into

the fuel bunker or process as soon as practicable.

8B.6.16 As a back-up system to the proposed measures, it is intended that a deodorising spray

system will be fitted in the tipping hall for occasional short term use (e.g. depending on

the weather conditions or during periods of shut-down). While such de-odorising sprays

do not abate any odour, they are recognised within the industry as a useful tool to reduce

the intensity or offensiveness of an odour over short periods. This system is being

installed as a back-up control measure on the FM1 power station for example.

Fuel Acceptance Procedures

8B.6.17 Formal, documented fuel management procedures will be put in place to describe the

criteria for fuel acceptance, storage, management and its movement around the facility,

to minimise odour.

8B.6.18 The procedures will specify the types of fuel which can be accepted at the Site (in

accordance with the Environmental Permit). They will also stipulate fuel storage

methods, capacities and inspection processes to be put in place to manage potential

odours.

Monitoring

8B.6.19 Meteorological conditions for the Site have been considered and reported in the

Environmental Statement (see Application Document Ref. No. 6.4.10). The prevailing

wind direction for the Site is from the south-west/ west.

8B.6.20 Odour levels will be monitored by site management regularly around the Site perimeter to

assess the effectiveness of the odour control measures being applied.

8B.6.21 During the construction and operational phases of the Proposed Development,

monitoring of any odour complaints received will be undertaken regularly and appropriate





responses will be initiated. The process for this will be set out in the Construction

Environmental Management Plan (CEMP) and the operator’s Environmental

Management System.

8B.6.22 If the Applicant receives a complaint regarding odour generated at the Site, it will be

managed in accordance with a documented Complaints Procedure, which will include an

investigation into the source of the odour and whether any additional mitigation measures

are required (such as use of the deodorising spray). If necessary, operational procedures

will be amended as appropriate following the outcome of the investigation.

Management of OMP

8B.6.23 A competent person will be designated to implement and maintain this OMP during the

operation of the power station. The site management team will respond to odour-related

incidents and elevated odour levels identified during routine inspections or on receipt of

odour complaints; including carrying out investigations and taking appropriate remedial

action to prevent recurrence.

8B.6.24 The designated person will be responsible for undertaking at least an annual review of

the effectiveness of the odour controls in place, taking account of complaints, monitoring

results, inspections, surveys and other information and feedback received.

8B.6.25 The site maintenance team will undertake planned preventative maintenance including

containment of any odour sources and any control equipment.

8B.6.26 Ongoing liaison with the community and stakeholders will be undertaken via the

Community Liaison Group meetings.

8B.6.27 Records will be maintained of all activities and actions relating to odour and this OMP.





8B.7 References

Ref 8B-1 Institute of Air Quality Management (2014) Guidance on the assessment of

odour for planning

Ref 8B-2 European Commission (2010) European Directive on Industrial Emissions

2010/75/EU

Ref. 8B-3 Environment Agency (2011) Environmental Permitting: H4 Odour

Management

Ref. 8B-4 European Commission (2006) Integrated Pollution Prevention and Control

Reference Document on the Best Available Techniques for Waste

Incineration

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