Biofuels and (Waste) Legislation- Presentation to Funding and Legislation Workshop

1
Biofuels and (Waste) Legislation- Presentation
to Funding and Legislation Workshop

• 29th March 2011
• Dave Gorman
• Head of Environmental Strategy
• Scottish Environment Protection Agency

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Brief overview of environmental legislation that
may apply

• Pollution Prevention Control (PPC)
• Waste Management Licensing and exemptions (WML
  and WMX)
• Control of Major Accident Hazards (COMAH)
• Controlled Activities Regulations (CAR)
• Waste Incineration Directive (WID)
• Waste Framework Directive
• Animal By-products Regulations (ABPR)
  (administered by Scottish Government Animal
  Health)

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Requirements

• If under PPC or WML then you need an
  environmental license before you can start
  operating
• If WMX then you need to register an exemption
  with SEPA
• If under CAR then depending on the scale of the
  activity you will need a licence, registration or
  follow a general binding rule
• If COMAH you need to notify HSE SEPA and then
  depending on scale prepare submit a safety
  report for assessment before you can start
• If WID then you need a PPC permit (as above)
• If ABPR you will need permission from Animal
  Health as well as a licence from SEPA

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Biodiesel a case study

• Making biodiesel from waste vegetable oils.
• Uses physical and chemical processing
  (trans-esterfication)
• Prescribed as an activity for control under PPC
  Part A as a chemical process.
• There is no lower throughput threshold level

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Biodiesela case study (2)

• May not be a Chemical PPC activity if not
  commercial or at industrial scale.
• SEPA undertook a review and with Scottish
  Government concluded that if capacity is less
  than 200 tonnes biodiesel production per year
  then would not be considered to be subject to PPC
  Part A
• A new waste management exemption was issued to
  allow lt200 tonnes per year biodiesel production
  without need of a licence (still require to
  comply with certain conditions and other
  legislation)

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Developments gasification

• Kerosene for aircraft fuel using mixed wastes
  such as municipal waste.
• Gasification to produce carbon and hydrogen rich
  syngas followed by Fischer-Tropsch reaction to
  produce hydrocarbons
• Gasification - PPC Part A
• Producing Hydrocarbons PPC Part A

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Developments biological route

• Anaerobic Digestion producing syngas currently
  burned in gas engine/CHP
• Syngas could be used either in Fischer Tropsch
  reaction or
• used as feedstock for bio fermentation
  (ethanol/butanol) or
• Used in a fuel cell
• Traditional AD plants would likely be regulated
  under WML or WMX unless taking animal by-products
  gt10 tes/day which would require PPC
• Syngas conversion would probably be PPC Part A

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Developments fuel cells

• As with previous routes generate syngas to be
  used directly in a fuel cell
• Syngas generation will probably require a licence
  of some kind

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Developments - biomass

• Several large biomass plants already in operation
• Eon Stevenscroft, Lockerbie
• UPM Kynmee, Irvine
• PPC Part A combustion with WID controls (due to
  potential for contaminated biomass)
• 4 proposed by Forth Ports (currently at Section
  36 Electricity Act (planning) stage)
• Not all biomass burning requires licence depends
  on scale and source/type of waste biomass

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Waste Framework Directive

• Recently Revised
• Requirement to hold a licence or exemption to
  undertake waste disposal or recovery operations
  (In UK through either PPC, WML or WMX)
• Key question in this sector will be
• Is biofuel made from waste still a waste?

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Bio fuel Is it still a waste?

• Treating or processing a waste material does not
  mean that the product will automatically be
  considered to be fully recovered and not a waste
• Several tests have to be applied
• Guidance on Is it waste? on SEPAs website
• If product still considered to be a waste then
  burning as a fuel will require PPC Part A permit
  with WID controls
• Example
• Biodiesel made from vegetable oils and tallow by
  Argent Energy not a waste (other outputs might
  be still a waste e.g. residues). Biodiesel
  produced can be blended with fossil diesel at the
  refinery with no further environmental licence
  controls required

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Working with Industry

• SEPA happy to engage with industry sector level
  and others
• Establish positions, protocols, interpretation at
  high level
• Consistency of approach
• Advise Scottish Government of legislative changes
  that may be required (e.g. WMX for biodiesel)
• Example
• FREDS Sub Group on hydrogen economy

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Energy Position Statement

• Sets out our strategic view on energy and
  renewables
• http//www.sepa.org.uk/about_us/news/2011/sepa_set
  s_out_how_it_will_help.aspx
• Launched February 2011
• Supportive of renewable energy including
  bio-energy but with caveats

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Advice

• Complex area
• Speak to local SEPA office
• NETREGS netregs.gov.uk
• SEPA website position statements contacts for
  offices etc.