Is your wood fuel increasing in price? Are you struggling to get hold of virgin woodchip at a decent price? Well moving to waste wood may be on your mind, but this could be a costly mistake if you don’t comply with the regulations.

Waste Wood Compliance

If your biomass boiler is not subject to permitting, either because you are on virgin biomass or you have an existing plant not due until 2024 or 2029, then you may be tempted to switch to a cheaper waste wood fuel. However, this will mean there will be new environmental compliance requirements you must adhere to.

Waste wood fits into two criteria, each of which involve different permits:

• Clean, untreated wood (consistent in colour and without contaminants). This requires regulation by either a Local Authority Part B permit (>50 kg/hr up to 3 t/hr firing capacity) or by an EA Part A1 permit (>3t/hr).

Or

• Demolition waste (paint, metal, plastic contamination expected). This requires a Local Authority Part A2 (SWIP) permit (>50 kg/hr up to 3 t/hr firing capacity) or EA Part A1 permit (>3t/hr).

The true costs of emissions

Each of the above permit’s have varying emission limit compliance. This means a variety of potential secondary abatement could be required for the boiler. For instance, Part A1 and A2 permits typically require Continuous Emission Monitoring systems (CEMs), Nitrogen Reduction units, and multi-cyclone filter systems which could cost you up to £500,000 up front, and £100,000’s more over their lifetime. This system is necessary to ensure the boiler emissions do not exceed the regulatory limitations.

The permit may also have pre-operational conditions that must be met prior to purchasing, storage, and combustion of waste wood. Sites could also see further costs through the installation of impermeable surfaces, contaminated water drainage systems, fire detection and prevention systems, etc. The permit process will also require supply chain contracts and waste acceptance procedures to be set up to ensure that only the waste permitted to be used will be accepted onto site. Failure to do so could result in fines, your combustion activities being shut down by the regulator, or even incarceration.

Should I stay or should I swap?

The upfront investment required to meet waste environmental compliance is not to be underestimated, especially for larger plants. Smaller boilers <5 MWth may be able to afford the change, as additional filter units are relatively inexpensive. However, larger boilers over 5 MWth, and especially over 10 MWth, should consider all potential ramifications before making the switch as a Part A1/A2 compliant system could cost you up to £500,000 up front, and £100,000’s more over their lifetime.

For more information about whether or not you should have a permit or waste procedures for your current combustion activities, please see our blog: Updates on permitting and ongoing compliance.

If you have any queries about whether you should be considering environmental compliance for an existing or planned boiler, please call the NFU Energy team on 024 7669 8899.