From:
Sent:
To:
Subject:
Price, Nathan
05 September 2016 11:40
David Pocklington
RE: EMR Liverpool Alexandra draft review
Hi David, Ignore that last email, I reviewed the waste tonnages and now estimate the Opra score to be 99 which will mean a fee of £11,187. Kind regards, Nathan Nathan Price | Permitting Officer ‐ Waste | National Permitting Service | Part of National Services E&B | Environment Agency | Trentside Offices, Scarrington Road, West Bridgford, Nottingham, NG2 5BR | Telephone: 020 302 53348 Fax 0115 846 3706 General Enquiries. 03708 506 506 Email. nathan.price@environment‐agency.gov.uk Help us to improve our service and complete our customer survey ‐ click NPS Survey. From: Price, Nathan Sent: 05 September 2016 11:26 To: 'David Pocklington' <david.pocklington@mayer‐enviro.com> Subject: RE: EMR Liverpool Alexandra draft review Hello David, The fee will be based on the ‘to be issued’ permit. Opra score for the new facility S5.3, S5.4, S5.6 (estimated to be 114) x substantial variation multiplier (113) = £12,882 Under this fee you will be able to add the S5.3 activity and increase the storage capacity of the S5.6. The site plan was adequate, thank you. I will be in touch once the variation is issued. Kind regards, Nathan Nathan Price | Permitting Officer ‐ Waste | National Permitting Service | Part of National Services E&B | Environment Agency | Trentside Offices, Scarrington Road, West Bridgford, Nottingham, NG2 5BR | Telephone: 020 302 53348 1
Fax 0115 846 3706 General Enquiries. 03708 506 506 Email. nathan.price@environment‐agency.gov.uk Help us to improve our service and complete our customer survey ‐ click NPS Survey. From: David Pocklington [mailto:david.pocklington@mayer‐enviro.com] Sent: 02 September 2016 15:21 To: Price, Nathan <nathan.price@environment‐agency.gov.uk> Subject: RE: EMR Liverpool Alexandra draft review Hi Nathan, Thanks for addressing the issues in the second draft and for providing answers to our outstanding queries. With regards the second draft of the permit, I would like to make the following comments: 1. I would like to confirm that the D15 code can be removed from the ELV operations (Table S1.1, A8) in order to reduce the subsistence fees. 2. An application to vary the permit will be submitted to the EA to add the shredding of hazardous waste (section 5.3) and to increase the maximum amount of hazardous waste that can be received. With regards this variation, I would be grateful if you could please confirm the application fee and if the application was to be submitted prior to the issue of the new permit, which permit the application fee is based on (i.e. would we be varying the existing permit or the soon to be issued permit?). We have no further comments regarding the draft permit. Please let me know if you need anything else, I trust the new site plan we provided with the emission points was adequate? Regards David From: Price, Nathan [mailto:[email protected]]
Sent: 10 August 2016 10:43
To: David Pocklington
Subject: RE: EMR Liverpool Alexandra draft review
Hello David, Thank you for the map. Subsistence The choice to keep D15 is up to your business needs. If you accept all ELV waste types with the intention to recycle then D15 is not needed. Even if there is incidental disposal after treatment. 2
However if you do intend to accept and store some ELV waste streams solely for disposal then it will be required and the subsistence fee will be the higher figure. The standard rules permits have the extra codes for contingency however for some reason they have been awarded a much lower subsistence fee. Annual Throughput I have had the draft permit reviewed internally and it has been noted you have asked for a significant increase in hazardous waste storage over what you are currently permitted to take (currently 15,000tpa) so I have had to put that limit back in. An increase in hazardous waste storage increases the risk to the environment which is outside of the scope of this project, therefore you can apply to increase this when you apply to add the S5.3 activity. Points for clarification Regarding your points for clarification in your previous letter: 1. We would like to raise a point of clarification around the issue of LDA (large domestic appliances) and these materials being firstly defined as WEEE and secondly metals. Activity A9 of the draft refers to WEEE treatment; in respect of LDA this would also involve shredding and not just sorting, separation and dismantling. In addition, if LDA are eventually designated as Hazardous Waste (something which we understand the EA is considering) how would this impact upon the current Activity Reference drafting? We are therefore requesting that the subsequent operational changes associated with the addition of shredding SMW (small mixed WEEE) included in the permit to account for this activity. To outline the importance of this issue to EMR it was raised with their national EA account manager to ensure the issue was highlighted as soon as possible. As the addition of S5.3 will need a separate variation and non‐haz shredding is covered by the S5.4, A9 does not permit shredding. Not all LDA will be hazardous dependent on the type of item. 2. Condition 2.4.1 Hazardous waste shall not be mixed with a different category of hazardous waste… Point of clarification ‐ SMW is made up of several categories of WEEE, can we confirm that SMW is the category, and therefore mixture of loads is not an issue? Acceptance of mixed loads is not an issue. 3. Condition 2.6.2 ‐ Clarification requested on the term ‘where appropriate’. Does it just refer to the reuse of WEEE and not infeed materials? This depends on end use, if you are storing infeed materials outside which could cause pollution or are due to be refurbished and rain could damage the electronics then this would breach the WEEE Directive. If the infeed material is due to be shredded or disposed of and pollution risk is not a problem then storage outside is not an issue. 4. Condition 3.1.3 Point of clarification – ‘Periodic monitoring shall be carried out at least once every 5 years for groundwater and 10 years for soil…’. Can you confirm whether this monitoring will form the permit SCR and therefore shall occur immediately following permit issue, or whether the first monitoring event is to occur within the first 5 and 10 years respectively, and then within each and every period after that? You will need to establish background conditions for the SCR at commencement of the permitted activities, so monitoring period will follow on from permit issue. 5. Condition 3.6.7 Point of clarification – ‘… inform the Environment Agency of each confirmed detection of radiation in accordance with this condition…’. Can you please define what a ‘confirmed detection’ is? i.e. a 3
response from the detectors indicating a change in radioactivity no matter the source, or the actual detection/ discovery of a radioactive source in a load. A confirmed detection is the actual detection/ discovery of a radioactive source in a load. 6.
Activity Reference A2: Activity listed ‘…pending any of the activities listed in Section 5.1, 5.2 and 5.3.’ Can you indicate to what this is making reference please? This is referencing waste that is going to be transported offsite that will then be subject to these activities. 7.
Activity Reference A9: Point of clarification: Does the term WEEE used in the permit include and cover both SMW and LDA, one of which is potentially hazardous waste and one Non Hazardous waste, either way we requested that both to be treated through the shredder. SMW to be batch processed. As previously mentioned the S5.3 haz waste shredding activity cannot be added at this stage. When you submit a variation to add this the WEEE to be shredded will have to achieve the recovery requirements of the WEEE regulations, the specific types of WEEE are also identified in the Directive WEEE annex II, III and IV. I have attached the latest version of the draft permit which has a few changes. Please can you let me have any comments by 24 August 2016. Kind regards, Nathan Nathan Price | Permitting Officer ‐ Waste | National Permitting Service | Part of National Services E&B | Environment Agency | Trentside Offices, Scarrington Road, West Bridgford, Nottingham, NG2 5BR | Telephone: 020 302 53348 Fax 0115 846 3706 General Enquiries. 03708 506 506 Email. nathan.price@environment‐agency.gov.uk Help us to improve our service and complete our customer survey ‐ click NPS Survey. From: David Pocklington [mailto:david.pocklington@mayer‐enviro.com] Sent: 05 August 2016 16:59 To: Price, Nathan <nathan.price@environment‐agency.gov.uk> Subject: RE: EMR Liverpool Alexandra draft review Hi Nathan, It would be tempting to remove it for the cost saving, but I’ve noticed the standard rules for ELV have D15 listed – is D15 not required for any amount of ELV‐derived wastes that cannot be recycled and have to be disposed of? Regards David 4
From: Price, Nathan [mailto:[email protected]]
Sent: 22 July 2016 12:06
To: David Pocklington
Subject: RE: EMR Liverpool Alexandra draft review
Hello David, Also I’m not sure if Ruth advised you on the likely subsistence charges for Alexendra? The total fee will be Installation subsistence + waste subsistence. As it stands the Installation subsistence will be £11,312. It appears you haven’t been charged the right waste subsistence and when corrected that would be £12,300. However if you remove the D15 code from activity A8 (ELV) then this will drop to £3,430. Please let me know if you are happy to remove D15 from this activity. (Many similar sites do not have this code as the main intent is to recover and not store solely for disposal) Kind regards, Nathan Nathan Price | Permitting Officer ‐ Waste | National Permitting Service | Part of National Services E&B | Environment Agency | Trentside Offices, Scarrington Road, West Bridgford, Nottingham, NG2 5BR | Telephone: 020 302 53348 Fax 0115 846 3706 General Enquiries. 03708 506 506 Email. nathan.price@environment‐agency.gov.uk Help us to improve our service and complete our customer survey ‐ click NPS Survey. From: Price, Nathan Sent: 22 July 2016 09:17 To: 'David Pocklington' Subject: RE: EMR Liverpool Alexandra draft review Hello David, I have taken over the determination of this variation from Ruth. There wasn’t much of a handover so I’m coming in at a strange stage in the determination. I’m working on getting your points of clarification clarified. I will send these over when I can. Regarding the main point in your review of the draft permit, the addition of the S5.3 activity cannot happen at this stage as hazardous waste shredding is not something you are currently permitted to do. You will have to submit a separate variation application to add this activity and it is likely to be a substantial variation. I’ve attached the latest version of draft taking into account the rest of your comments. Please can you send over the new site plan as I don’t think this came in with your letter. 5
Please note I am on annual leave after today until 08 August 2016. I will pick this up upon my return. Kind regards, Nathan Nathan Price | Permitting Officer ‐ Waste | National Permitting Service | Part of National Services E&B | Environment Agency | Trentside Offices, Scarrington Road, West Bridgford, Nottingham, NG2 5BR | Telephone: 020 302 53348 Fax 0115 846 3706 General Enquiries. 03708 506 506 Email. nathan.price@environment‐agency.gov.uk Help us to improve our service and complete our customer survey ‐ click NPS Survey. From: David Pocklington [mailto:david.pocklington@mayer‐enviro.com] Sent: 26 June 2016 12:05 To: Ingle, Rob Cc: O'Donnell, Anke Subject: RE: EMR Liverpool Alexandra draft review Hi Rob, Please find attached our reply to the draft permit for EMR Alexandra Dock provided to us by Ruth Pears. I would be grateful if you could confirm its receipt. Regards David From: Pears, Ruth C [mailto:[email protected]]
Sent: 13 June 2016 12:50
To: David Pocklington
Cc: Ingle, Rob; O'Donnell, Anke
Subject: EMR Liverpool Alexandra draft review
Hi David, As per our telephone conversation, you have an extension until 27th June Midday to respond with comments regarding Liverpool Alexandra draft permit. Could you please respond to Rob and Anke, both are cc’d in this email. If you have had chance to split the waste tables and tonnages before this date could you please email them so we can work out the Opra charges. Many thanks for your time and patience. Ruth 6
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