Legislation Details for Combustion
Introduction
Combustion in this case is intended
by means of using woodchips as fuel. There is a good deal of applicable
legislation.
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Applicable
Legislation
Firstly it must be ascertained whether
the plant is used or going to be used for combined heat and power. Biomass
generation under the Renewables Obligation (RO) is defined by plant
build since the beginning of 1990 which uses less than 2% of fossil
fuels (this is mainly to allow the use of fossil fuels for cleaner ignition).
Plants can also be retrofitted but this is not applicable in the case
of Barony College.
The second stage must be to ascertain
or confirm wood supply. This is a fluid issue at the moment. The SEPA
interpretation of the EU Waste Framework Directive and Waste Incineration
Directive states that wood (and particularly woodchips in this case),
should not be considered waste if they are from virgin wood, not intended
for disposal, and not required to be disposed of. Therefore new wood
‘off-cuts’ are not waste if there is an intention, ability
and final outcome of energy use. This is the case in our project. Such
wood supplies must be accredited by SEPA.
Finally there is the installation
itself, and how it pertains to residues, emissions and to planning permissions.
Such permissions and building warrants are necessary in the normal way:
particular attention must be given to chimney heights, which are dependent
partly on the size of the installation, and to Smoke Control Areas –
so called ‘smoke free zones’ – specified under the
Clean Air Act. Few technologies are available which are appropriate
for installation in these areas; retrospective permissions are hard
to come by. Barony College is not within a smoke control areas however.
The EU Air Quality Framework Directive
and the Air Quality Limit Values (Scotland) ensure that emissions do
not legally exceed prescribed values. Such emissions include SO2,
NOx, fly-ash and associated small particulate matter of less
than 10µm in size, known as PM10. Disposal of collected
fly-ash as a product of small installation combustion is currently being
investigated by SEPA. PM10 should not be an issue except
when boilers are running at part load or are using fuel with excessive
moisture content. This again is currently under investigation by SEPA.
Other residues (ground ash etc.) are covered by the EU Integrated Pollution
Prevention and Control (IPPC) Directive; the intention should be to
use Best Available Technology Not Entailing Excessive Cost (BATNEEC).
SEPA should be contacted for further advice.
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Further Information