Response 937609157

Back to Response listing

Seeking your views

4. Please provide your comments on the environmental permit application received from Neil Wainwright Farming Ltd

Please provide your comments on the environmental permit application received from Neil Wainwright Farming Ltd (Required)
Dear Sir / Madam, I am writing in relation to the Permit Application Ref: EPR/FB3002KD/A001, Two Hoots Digestate Dryer. I am Redacted text for Assured Energy LLP, Permit Ref: EPR/BB3201MD/A001, Two Hoots Farm AD Plant. I have read through the details of the new application as published on your portal and would have some concerns as the application is heavily linked with our AD Plant operation. Within the application and the proposed EMS, the only point source emissions considered are those relating to air. From operating this equipment there may be significant volumes of condensate that shall run to ground during normal operation and also during the weekly wash water clean down. From the communications between the applicant and Environment Agency it would appear that no pre-operational monitoring or H1 risk assessment will be deemed necessary and this shall be accommodated with an ‘improvement condition’ after operations have commenced. If this approach is acceptable then surely the H1 risk assessment should also cover emissions to groundwater, the potential for permitted discharge, and this should have been included within the application and the EMS as presented? Within the proposed EMS there are several statements which directly impact the AD Plant operation that we would ask the Agency to consider to include; • Spent water is fed through the AD Plant for treatment (page 12) • Spent water from the dust catcher is collected in an IBC and emptied every 1-2 weeks into the dirty water system from the AD Plant (page 15) • Contingency Plan – In the event of a breakdown whole digestate is stored within the digestate storage lagoon of the adjacent AD Plant (page 21). Assured Energy LLP have not been approached or consulted on any of these matters so we would be grateful if you could respond to verify the following direct queries; • Should this permit be granted what will be the procedure or mechanism for feeding the dryer ‘dirty water’ back into the Assured Energy AD plant? • What EWC code will be assigned to this waste dirty water? • As part of your consideration will the Agency verify that the Assured Energy Permit has the correct EWC codes to accept this dirty water material? There are various other elements of the application that have not been considered within the application to include the omission of a stack emissions point for the emissions of vapour etc, but our main concerns at this time are focused on the potential impact this development may have on our existing operation.