AD and EA

[The Son]

Just thought I would post my most recent dealings with the EA.

I run a 400kW on farm digester using standard farm inputs on a standard rules permit, all digestate on own land.

Last October I had my annual visit was told that they are focusing on tank integrity at 5 years they require all tanks on site to be emptied, cleaned, and inspected, any concrete tanks that have cladding will have to have that, and insulation removed so tank can be properly checked.

I didn't really respond at the time as the EA worry me at the best of times, but after they left I started ringing round and getting costs and timescales, this is when it got frightening, it became abundantly clear that to do as they ask would most likely at best put me back financially 5 years, at worst break me, so in true male fashion I stuck my head in the sand at hoped it would go away.

Fast forward to Monday had an email saying they would be onsite Wednesday 1300 hours. Two arrived this time reiterating tank integrity checks and asking what I had done towards it. I explained that to complete the integrity checks would break me, the one officer smirked, the other did take it a bit more seriously and at least said she would look into it as the wording in the standard rules permit is vague and different interpretations can be made.

She has rung this afternoon to say that the tank integrity checks they initially asked for are too onerous and they are making changes, and requested another meeting, when she will bring another EA officer. This time I am having a big hitter sat on my side of the table too.

And to top it all, when I queried the doubling of my subsistence fees she welcomed the additional cash as it now means they are properly funded and can visit me twice a year.

 

[thesilentone]

Just to clarify, which permit do you have , an exemption (T24) or standard ?

 

[ollie989898]

Just thought I would post my most recent dealings with the EA.

I run a 400kW on farm digester using standard farm inputs on a standard rules permit, all digestate on own land.

Last October I had my annual visit was told that they are focusing on tank integrity at 5 years they require all tanks on site to be emptied, cleaned, and inspected, any concrete tanks that have cladding will have to have that, and insulation removed so tank can be properly checked.

I didn't really respond at the time as the EA worry me at the best of times, but after they left I started ringing round and getting costs and timescales, this is when it got frightening, it became abundantly clear that to do as they ask would most likely at best put me back financially 5 years, at worst break me, so in true male fashion I stuck my head in the sand at hoped it would go away.

Fast forward to Monday had an email saying they would be onsite Wednesday 1300 hours. Two arrived this time reiterating tank integrity checks and asking what I had done towards it. I explained that to complete the integrity checks would break me, the one officer smirked, the other did take it a bit more seriously and at least said she would look into it as the wording in the standard rules permit is vague and different interpretations can be made.

She has rung this afternoon to say that the tank integrity checks they initially asked for are too onerous and they are making changes, and requested another meeting, when she will bring another EA officer. This time I am having a big hitter sat on my side of the table too.

And to top it all, when I queried the doubling of my subsistence fees she welcomed the additional cash as it now means they are properly funded and can visit me twice a year.

Absolute bunch of jobsworths. They clearly have no clue what is involved in just cleaning one of these things out, a specialist job if there ever was one given the atmosphere and confined spaces angle.

More people need to call their bluff and tell them they will just shut up shop in the face of carp like this.

 

[The Son]

Just to clarify, which permit do you have , an exemption (T24) or standard ?

Standard rule permit, the visit report has come today, I just had a quick scan but I have a load of work to do and my scores have gone up by 4 points, I am in band B and I have a site warning.

 

[Digester Man]

That’s madness. Surely in England you have SSAFO regulations? If your tank is SSAFO compliant it should have a design life of at least 20 years as certified by the engineer who designed and signed off the build. Why would you need to prove to them every 5 years that the tank still has integrity, if an engineer has certified it to have a design life of at least 20 years? I would also be massively emphasising the risk to life of entering a confined space to clean it out and hopefully that might scare them back down off their high horse. Decommissioning and cleaning out a digester is not something anyone should ever have to do unless there is a genuine need for it.

 

[thesilentone]

There are ways of testing tank integrity without emptying, however, it does beg the question why ?

In addition there is old historical data available as reference.

However, if the tanks are made from concrete, there is an expectation that emptying and re-coating is carried out periodically, however this is usually specified by the tank supplier.

 

[The Son]

My next course of action is to go through all the tank specs and details, which the EA are now asking for, unfortunately, the tank builder Calglas ceased trading a while ago, although I do have a lot of info on the tank construction, which to be honest is beyond me as it involves lots of calculations, so I am unsure whether to pass the info on as it may not be correct.

What really annoys me is that at the planning stage the EA specified bunding so we spent a huge amount of money digging the tanks into the ground so that in the event of a failure everything is held within the bund. We also had to install a leak detection system, at vast expense, and both measures they now seem to ignore.

 

[renewablejohn]

My next course of action is to go through all the tank specs and details, which the EA are now asking for, unfortunately, the tank builder Calglas ceased trading a while ago, although I do have a lot of info on the tank construction, which to be honest is beyond me as it involves lots of calculations, so I am unsure whether to pass the info on as it may not be correct.

What really annoys me is that at the planning stage the EA specified bunding so we spent a huge amount of money digging the tanks into the ground so that in the event of a failure everything is held within the bund. We also had to install a leak detection system, at vast expense, and both measures they now seem to ignore.

Just get a decent barrister to point this out in legal speak and the EA will run to the hills as its totally out of there technical ability.

 

[Pond digger]

The EA just love making up new rules; it’s job creation! Anything they tell you should be judged against actual legislation, you’re doing the right thing in questioning them. If everyone just bent over for them, it would only make matters worse.

 

[The Son]

You are all right and I should stand up, but then I think I have 15 years left to go arguing with these people, can I really stomach that?

I am not against regulation, and like to think I run a tidy unit that is not an environmental disaster zone, but after each visit that is how I am left feeling.

As an aside a few years ago we had 4 VAT inspections in the space of 18 months, not something I worry about as I have an excellent secretary and everything is up to scratch. It was the same lady and in the end I asked her why we were inspected so often, she said that she gets given a number of businesses to goto, and for some reason ours kept coming up, she didn't say anything to her bosses as she enjoyed coming to us as we treated her well, the books were in order and she sat in comfort in our kitchen with a lovely view. Normally she is stuck in the corner of a miserable office on an industrial estate and no one will talk to her.

Perhaps I should not be so accommodating with the EA and they would not come so often?

 

[Wastexprt]

Perhaps I should not be so accommodating with the EA and they would not come so often?

They will visit whether you are accommodating or not, however, I find it better not to antagonise anything.

The EA has recently finished a three year audit in to AD plants where many have been found lacking, including concrete tanks cracking, which is forcing them to reassess their regulation of permitted sites. The additional funding is certainly creating waves in the industry, and plants of all sorts are coming under massive scrutiny from experts in the field. The officer may not be a technical expert, but they have access to staff in the EA that are.

A consultation last year https://www.gov.uk/government/consu...mits-review-to-improve-environmental-outcomes may see the SR permits being restricted further. This means that if you have a plant that is currently an SR plant, it may need to be varied to become a 'bespoke' permit.

There are good officers in the EA, but there are also ones with appalling attitudes.