Response 423736673

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Seeking your views

4. Please provide your comments on the environmental permit application received from Day Group Limited

Please provide your comments on the environmental permit application received from Day Group Limited (Required)
It appears from the Permit application that the applicant envisages receiving 'raw' untreated and untested IBA from the supplier. With reference to the General Process Description (paragraph 3.12 et seq of the Environmental Management System & Operating Techniques section of the Permit Application: The applicant refers to the arrangements for the storage of IBA and to the ESA IBA Sampling & Testing Protocol and elsewhere (paragraph 2.15 et seq) to the IBA storage arrangements. The current 2016 Protocol sets out the procedure for dealing with IBA following a sampling but the Protocol that the applicant has included is the version dated 2010, and is no longer applicable. Section 3.4 of the current protocol requires that: 'Action: The EfW facility operator should dispatch the sample to the laboratory within 48 hours of sampling. From receipt of a 40 kg sample of IBA sample at the test laboratory all reports for the monthly hazardous property assessment should be sent to the EfW facility within 20 working days, and where possible data should be returned more quickly to allow prompt reporting of data to a third party reprocessor. If there has been a quality assurance failure at the test facility, the sample should be retested. Where a result is anomalous (either high or low) in comparison with historic data a retest on the same sample should be undertaken by the test facility. Where the sample has been lost or compromised by the test facility or courier the reserve sample should be sent for testing. Each EfW facility should provide information on the IBA hazard classification and any exceedances to their nominated ash reprocessor immediately on receipt of sample data and if asked for by the Environment Agency. This is because the IBA cannot be processed until the result has been supplied (see 3.5). As long as the ash was non-hazardous prior to this sample, and the operator is not aware of any other reason why the ash may be hazardous, and has followed this protocol, waste can be transferred to a suitably authorised reprocessor for storage (only) as presumptively nonhazardous whilst the result is awaited'. The applicants proposed arrangements for storage do not, and should, appear to reflect the above requirement. The applicant should be using the current protocol.