RE: sae30 Nov 2020 20:21
Part 4: Second question from NRW proposing that there is an option to ask NRW to consider a change to the operating conditions - 2. If, having regard for your answer to question 1 above, you want Natural Resources Wales to consider a change to any of the operating conditions specified in IED Article 50, as may be allowed by IED Article 51, then confirm this request in writing and provide the following written information. If IED Article 51 is not relevant to your application, you may ignore this question:
a. Propose clear alternative conditions, in terms of time and temperature, and other parameters as necessary, which your proposed process will be capable of achieving, and which will ensure that the requirement of IED Article 51 is met. Do this for all instances where Article 50 requirements are not expected to be met or otherwise require alteration as a result of your proposals.
We note your response dated 14/09/20 to our Schedule 5 Notice dated 29/07/20 (Question 2) and in particular the final sentence, “As such we believe that consideration of IED Article 51 authorisation of different conditions from those specified in Article 50 is warranted in this case should this prove necessary under any and all operating conditions of the plant”. However, we cannot consider a case for an IED Article 51 authorisation unless it is clear whether or not you propose to meet Article 50, and unless alternative operating conditions are established which will ensure that the requirements of IED Article 51 are met.
We expect that alternative conditions shall be proposed by the applicant, and specified in the same manner as IED Article 50, i.e. in terms of a minimum time and minimum temperature to which gas resulting from the incineration of waste is raised in a controlled and homogeneous fashion and even under the most unfavourable conditions.