Mr Derek Luby Technical Director SLR Consulting Ireland 7 Dundi-um Business Park Windy Arbour Dundruni Dublin 14 Headquarters. PO Box 30CO Johnsiobvn Castle Estate Couilty Wexford. Ireland Ceanncheathru. Bosca Poist 3000 Eastdt Chaislean Bhaile Sheain Comae loch Garrnan. Eire T c353 53 9160600 F: +353 53 9160699 E info@epa le W: vw'.epa le LoCall. 1890 33 55 99 1 St'' July 201 3 Reg. No. WO277-01 Re: Registration Form to determine whether existing licence applications come within the scope of the new First Schedule of the EPA Acts 1992 to 2013 Industrial Emissions Directive (2010/75/EU) European Union (Industrial Emissions) Regulations 2013 (S.I. No. 138 of 2013) 0 European Union (Industrial Emissions) (Licensing) Regulations 2013 (S.I. No. 137 of 201 3) Dear Applicant, I am to refer to the above referenced application for a waste licence or review of a waste licence. In order to further consider your application, it is necessary to detennine whether the class or classes of activity that you have applied for fall within the scope of the new First Schedule of the Environmental Protection Agency Acts 1992 to 2013. This notice is given under Article 16( I) of the Waste Management (Licensing) Regulations, to enable the Agency to decide on the application. I One of the main functions o,f the Environmental Protection Agency has been the licensing and control of specified activities that are listed in: 0 the Third and Fourth Schedules to the Waste Management Acts 1996, as amended; and the First Schedule to the Environmental Protection Agency Acts 1992, as amended. Under these acts, the Agency has to date granted waste licences and IPPC licences respectively.
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30CO Johnsiobvn Couilty Wexford. Ireland Eastdt Chaislean ... · CROl nu in bet-: Instructions You should firstly review of tlie classes of activity included in the First Schedule
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Mr Derek Luby Technical Director SLR Consulting Ireland 7 Dundi-um Business Park Windy Arbour Dundruni Dublin 14
Headquarters. PO Box 30CO Johnsiobvn Castle Estate Couilty Wexford. Ireland
Guidance on "Pre-treatment of waste for incineration or co-incineration"
This topic is relevant to activity classes 1 I .4(a)(iii) and 1 1.4(b)(ii).
The term "pre-treatment" is not defined in the Industrial Emissions Directive. The tenn
"treatment" is defined i n the Waste Framework Directive (2008/98/EC) as:
'recovery or disposal operations, including preparation prior to recovery or
disposal'.
The teiiii 'treatment' has the same meaning as 'pre-treatment' . 3
Waste licence applicants will have already selected applicable recovery and disposal
activities in their waste licence applications (section B.7 of the waste licence application
form) that they have sought for authorisation. As a general rule, i t is appropriate that any of
Municipal Solid Waste - Pre-treatment (9i Residuals Management: An EPA Technical Guidance Document,
2009.
IED Registration Fonn for Waste Licence Applicants Page 2
~ _ _
these activities folloived by dispatch of the \\;aste for incineration or co-incineration shoulcl be
regarcled as "pre-treatment of waste for incineration or co-incineration" for the purposes of
the new First Sclieclu le.
When deciding whether an activity comprises "pre-treatment of waste for incineration or co-
incineration" for the purposes of the new First Scheclule, applicants should consider \\;hat
happens w i t l i i ~ the waste fcicilitv thcrt is /o be criitl7orisecl; and not any treatment or pre-
treatment that took place previously at another facility or the presence of ivaste segregation
practices at the point of waste collection.
The following should not generally be regarded as constituting "pre-treatnient of waste for
incineration or co-iiiciiieration":
0 the incidental generation of waste from waste treatment activities and the dispatch of
such incidental waste for incineration.
Solid recovered fuels and refuse derived fuels are often but not always produced to a
technical specification that might also comprise a quality standard and/or a quality assurance
scheme. They are also often produced to be classified by the EWC codes 19 12 10 or 191 21 2.
The absence o f
0 a technical specification,
a quality standard:
a quality assurance scheme: and/or
EWC codes 19 12 I O and 19 12 12
for a solid recovered fuel or refuse derived fuel is not indicative hat an activity does not
comprise "pre-treatment of waste for incineration or co-incineration' .
I
Guidance on "Class 1 1 . 1 " - non-JED activity
Class 1 1 . I is not an IED class of activity. If this class of activity is selected, a reason must be
provided at the end of the form. Class 1 1 .1 will generally only be applicable where there are
non-IED classes of activity being carried on at a facility i n addition to IED classes of activity.
The following are IED classes of activity, subject to relevant capacity thresholds: 1 1.2, I 1.3,
11.4, 11.5, 11.6 and 11.7.
IED Registration Form for Waste Licence Applicants Page 3
\
Registration F o r m
This table lists only class 1 1 activities. There is space at the bottom of the table to list other
applicable classes of activity and you'slioulcl take the time to consider the entire new First
S ched u I e.
Class of
activit!.
1 1
1 1 . 1 ('
Descriptioii of activit!.
Waste management
The recovery or disposal of waste in a facility,
within the meaning of the Act of 1996, which
facility is connected or associated with
another activity specified i n this Schedule in
respect of which a licence or revised licence
under Part 1V is In force or in respect of which
a licence under the said Part is or will be
required.('
Tick ;111 classes of
a c t ivi t y t I i a t a p p I 11
to your waste
I i ce n c e a pp Ii c a t i o n'
(clear cells only)
Transition
date to IE
Licensing
Regulations
(Section 76A
of Waste
Management
Acts)
Please note, this form relates to giJ of the activities included in your licence application. This includes activities
that you are already authorised to cany out if you intend to maintain these activities under a new licence (should
i t be granted).
5 European Union (Industrial Emissions) (Licensing) Regulations 2013, S.1. No. 137 of 201 3.
If this class of activity is selected, an explanation must be provided. Complete the box below the table. 0
IED Registration Fonn for Waste Licence Applicants Page 4
I
Class of
act i vi t!;
11.2
Ikscription of activit!.
Disposal or recovery of hazardous waste with
a capacity exceeding I O tonnes per day
involving one or more of the following
activities;
biological treatment;
physico-chemical treatment;
blending or mixing.prior to submission to any
of the other activities listed in paragraph 11.2
or 11.3:
repackaging prior to submission to any of the
other activities IistecI i l l paragraph 1 I .2 or
11.3;
solvent reclamation or regeneration;
recyc I i ng or i-ecl a mat ion of I noi-gam c
inaterials other than metals or metal
compounds;
regeneration of acids 01- bases,
recovery of components used for pollution
a ba t einent ;
r .. I lCk classe\ of
acti\ it! that appl!
to !'our waste
I i cen ce a p p li ca t i o n'
(clear cells only)
I- 1-21 11 sit io n
date to I E
Lice n s i 11 g
Regulations
(Section 76A
of Waste
hi1 ana gem en t
Acts)
IED Registratioii Form for Waste Licence Applicants Page 5
Class of
it c t ivi t y
11.3
1 1.4(a)
(ii)
Description of acti\,it!;
recovery of components from catalysts;
oil re-refining or other reuses of oil;
surface impoundment.
Disposal or recovery of waste in waste
incineration plants or in waste co-incineration
plants:
for non-hazardous \vaste with a capacity
exceeding 3 tonnes per hour;
for hazardous waste with a capacity exceeding
10 tonnes per day.
Disposal of non-hazardous waste with a
capacity exceeding 50 tomes per clay
involving one or more of the following
act i vi t i es :
biological treatment;
physico-chemical treatment;
Tick &I classes of'
activity that appl!.
Transit ion
clate to 1E
to your waste Licensing
Reg u I a t io n s
(Section 76A
of Waste
I i ce n c e a p p I i ca t i o n'
(clear cells only)
Management
Acts)
I 30/9/2013 I 30/9/2013
IED Registration Fonn for Waste Licence Applicants Page 6
! I
i I
I !
I
i
I j
I
i ! i
I I ' !
I I I i
I
Class ot'
i1 c t i \ . i t >,
(iii)
~
11.4(b)
(ii)
(iii)
Des c ri ption o f R c t ivi t >.
pre-treatment of waste for incineration or co-
incineration;
treatment of slags and ashes;
treatment in shredders of metal waste,
including waste electrical and electronic
equipment and end-of-life iehicles and their
components.
Recovery, or a mix of recovery and disposal,
of non-hazardous waste with a capacity
exceeding 75 tomes per day7 invoIving one or
more of the following activities, (otiier tlian
activities to which the Urban Waste Water
Treatment Regulations 2001 (S.I. No. 254 of
200 1 ) apply):
b i o I og i ca I treat men t ;
pre-treatment of waste for incineration or co-
incineration; ~~
treatment of slags and ashes;
I'ick classes o f
21 c t ivi t >' t hi1 t PPI\.
t o your waste
I ice nc e a p pl i ca t ion'
(clear cells only)
c
T ra II si t ion
date to 1E
Licensing
Regulations ' (Section 76A
of Waste
Mana, oement
Acts)
28/2/20 14
28/2/2014
28/2/20 14
25/2/2014
When the only waste treatment activity carried out is anaerobic digestion, the capacity tlueshold for that 7
actiyity shall be 100 tonnes per day.
E D Registration Form for Waste Licence Applicants Page 7
Class of
activity
(iv)
11.5
11.6
11.7
llescription of activity ,. .. I tck fl classes of
act iv it !. that a p PI!.
to !'our U aste
I i c e nc e a p p I i c a tio n'
(clear cells only)
treatment in shredders of metal waste,
including waste electrical and electronic
equipment and end-of-life vehicles and their
components.
Landfills, within the meaning of section 5
(amended by Regulation 1 l (1) of the Waste
Management (Certification of Historic
Unlicenced Waste Disposal and Recovery
Activity) Regulations 2005 (S.I. No. 524 of
2005)) of the Act of 1996, receiving more
than 10 tonnes of waste per day or with a total
xpacity exce'eding 25,000 tonnes, other than
landfills of inert waste.
.- I empoi-ary storage of hazardous \\Taste (other
:han waste referred to in paragraph 1 1 3)
xnding any of the activities referred to i n
magraph 11.2, 1 I .3; 1 1.5 or 11.7 with a total
xpacity exceeding 50 tonnes, other Fhan
.emporary storage, pending collection, on the
site where the waste is generated.
Jnderground storage of hazardous waste with
i total capacity exceeding SO tonnes.
'Ira n s i t io n
clate to 1E
Licensing
Kegulations ' (Sect ion 76.4
of Waste
M an a gem en t
Acts)
30/9/2013
!5/2/20 14
!5/2/20 1 4
IED Registration Form for Waste Licence Applicants
~
Page 8
Class of
act i \ . i t!,
0.1
012
Des cr-i p tio n o f a c t i \ . i t!'
None of the above classes of activity apply to
the existing or proposed activities that are the
subject of my waste licence application.
Other applicable activities in the iiew Firs[
Schedule of the EPA Acts
(List in the box to the right any other
activities, other than class 1 I , that you carry
out or 'have applied for a waste licence to
carry out).
r .. I ick ~ classes o f
a c t ivi tj, that a p pl !
to !.our \\ aste
licence application'
(clear cells 0111);)
r . I ransition
date to IE
Licensing
Regulations
(Section 76A
of Waste
Maria= menient
Acts)
IED Registration Form for Waste Licence Applicants Page 9
CI ai ificatioii of any considerations of .'capacity" taken into account \vhen completing the Reg I strati on F o rim :
[ED Registration Form for Waste Licence Applicants Page 10
IED Registration Form for Waste Licence Applicants Page 1 1
Please select all applicable Chapters of the Inclustrial Emissions DirectiiTe (201 01751EU):
0
U
111: Special provisions for combustion plants
IV: Special provisions for waste incineration plants ancl waste co-incineration p 1 ants
V: Special provisions for installations and activities using organic solvents
VI: Special provisions for installations producing titanium dioxide
0
0
IED Registration Fonii for Waste Licence Applicants Page 12
____________ ~~
Ackrio~\iledgeriierits and final cleclaratiori
I acknowledge that:
0 The information provided to the EPA i n this form will be made publicly available and will be open to inspection'by a n y person.
This form does not purport to be and should not be consiclered a legal interpretation of the provisions and recluirenients of the Eiiropean Union (Inclustrial Emissions) Regulations 201 3, the European Union (Industrial Emissions) (Licensing) Regulations 20 I 3 or other legislation.
By ticking box 0.1 above, 1 am stating that none of my existing activities or any new activities for which I've made application for authorisation under a waste licence are
0
0
listed in the new First Schedule of the EPA Acts 1992 to 201 3
I declare the following:
0 The EPA may copy this registration foiin response for its own use and mine i t available for inspection and copying by the public, both in the foim of paper files available for inspection at EPA offices and via the EPA's website.
I have read
o this registration forni and accompanying letter, and
o the new First Schedule of the EPA Acts 1992 to 20 13,
i n their entirety.
I make this response on behalf of the organisation namecl i n this registration foml.
I certify that the inforniation given in this registration fonn response is true, accurate and complete.
Signature on behalf of applicant:
Date of signature:
Print name: I Job title:
IED Registration Foim for Waste Licence Applicants Page 13