Carlisle Road Resource Recovery Facility

Management Plan

BAT REVIEW OF THE OPTIONS AVAILABLE FOR EMISSIONS CONTROL

1.0 1.1

INTRODUCTION This report encompasses the BAT assessment of emissions control measures to

be employed at the Carlisle Road Resource Recovery Facility (CRRRF) for abatement of point source emissions to air and abatement of potential releases of the emissions of the following parameters: Point Source Emissions to Air of odour. Consideration is given to the measures to be employed for the control

1.2

Release of Odour

Acid Gases e.g. HCI, HF, SOx, NOx Heavy Metals VOCs, carbon monoxide, dioxins and furans Particulate Matter Carbon dioxide and water

In order to demonstrate that those emissions control systems to be incorporated at the Carlisle Road Resource Recovery Facility are indeed BAT for the Document on the Best Available Techniques for Waste Incineration (BREF August installation, compliance with the BAT standards as set out in IPPC Reference 2006) and IPPC Sector Guidance Note IPPC S5.01 must be demonstrated. appropriate justification and operational data evidence where available.

Deviation from those BAT standards specified must be supported with Indicative BAT is demonstrated in accordance with sector guidance note IPPC S5.01 throughout the main PPC Permit application document. 1.3

The CRRRF will incorporate a Materials Recycling Facility (MRF) and associated

Business waste (similar to Municipal Solid Waste) including Commercial and

Energy Recovery Facility (ERF) that will process the residual waste from the MRF.

Industrial Waste and some residual household waste (non source segregated black bag wastes), including a nominal amount of hazardous wastes, from the South Lanarkshire region will be accepted at the installation. All wastes will primarily be transferred to the Waste Treatment and Fuel Preparation Area for initial screening, removal of bulky items, segregation of hazardous waste and waste streams will be generated by the MRF; dry recyclates, biodegradable wastes and residual wastes. audit checks. Following this waste will be processed through the MRF. Three

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1.4

The dry recyclates and biodegradable wastes will be stored and bulked on site

pending off-site transfer to suitable reprocessers and the residual wastes will be temporary on site storage of biodegradable wastes has been identified as a potential source of odour; in order to abate this odour a biofilter will be installed given in Section 2.0 below.

transferred to the ERF for thermal treatment with the hazardous wastes. The

at the installation. Consideration of the proposed biofilter in terms of BAT is

1.5

Treatment of the residual wastes in the ERF will generate emissions to Limited, proposes to install a Flue Gas Treatment System at the CRRRF in order to abate the emissions generated by the operation of the ERF. Consideration of below.

atmosphere via the 50m stack. The Operator, Scotgen (South Lanarkshire)

the proposed Flue Gas Treatment System in terms of BAT is given in Section 3.0

2.0 2.1 2.1.1

ODOUR ABATEMENT SYSTEM Introduction As discussed above, biodegradable waste storage on site at the Carlisle Road

Resource Recovery Facility has been identified as a potential source of odour and as detailed throughout the PPC Permit application documentation the Operator is principles for the CRRRF. Biodegradable wastes will be stored separate to all proposing to install a biofilter abatement system in conjunction with the design other wastes on site, in a dedicated storage bay with separate drainage as described in the Management Plan and in close proximity to the biofilter extraction system.

2.1.2

The selection of a biofilter odour abatement system is based on sound odour

abatement principals adopted within the Composting and Waste Management Industries where biodegradable wastes are stored at sites either for biological treatment or onwards transportation for biological treatment, as proposed at the

CRRRF. The Composting Associations document An Industry Guide for the Prevention and Control of Odours at Biowaste Processing Facilities identifies biofilters as the number one treatment option for emissions from such facilities. these types work on the same principals of odour abatement. Further detail on biofilter design is considered below. 2.1.3

It notes that there are two types of biofilter; closed and open, but that both of

Sector Guidance Note IPPC S5.01 (and the above Composting Association Report)

also states that where odour can be contained, for example within buildings, the

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Operator should maintain the containment and manage the operations to prevent its release at all times and that odour can be controlled by: 2.1.4 Enclosing odorous areas (applicable to all) Confining waste to designated areas (all) timescale (MWI, CWI, ACI, SSI)

Enclosing odorous waste all the way to the furnace (ACI, CWI) Ensuring that putrescible waste is incinerated within an appropriate Refrigeration of such waste which is to be stored for longer than an appropriate timescale (CWI, ACI) handling areas (all) Regular cleaning and (for putrescible wastes) disinfection of waste Design of areas to facilitate cleaning (all) appropriate (all)

Ensuring that the transport of waste and ash is in covered vehicles, where Ensuring good dispersion at all times from any release points (all) timescales (SSI, MWI)

Preventing anaerobic conditions by aeration, turning of waste and short

Chlorination of waters being returned to STW or in storage (SSI) captured (all), and

Drawing air from odorous areas at a rate which will ensure that odour is Treating such extracted air prior to release to destroy the odours.

management operations will be undertaken within an enclosed building with all waste deliveries via a dedicated one way system controlled by high speed roller building. shutter doors to maintain the air control management system within the

As detailed in the Management Plan to the PPC Permit application all waste

2.1.5

Treatment and Fuel Preparation Area and the Energy Recovery Area. The Energy Recovery Area will only incorporate the Energy Recovery operation and will not be used for the storage of wastes. Air control within the Energy Recovery Area is

The proposed building will be divided into two operational areas, the Waste

undertaken via air changes associated with the combustion process. A series of roof vents will also be permanently maintained in the open position in order to provide ventilation. 2.1.6

HGV movements will only be within the Waste Treatment and Fuel Preparation

Area of the building and will be managed so that vehicles are within the building for the shortest period of time possible via the one way system and dedicated high speed roller shutter doors. Operation of the high speed roller shutter doors

will provide a pulsing venting system for the movement of HGV vehicles within
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the Waste Treatment and Fuel Preparation Area and is therefore considered to negate the need for specific vehicle exhaust emissions. 2.1.7

The Waste Treatment and Fuel Preparation Area will be the main waste storage area and will incorporate specific storage bays for the isolation of both dry recyclates and biodegradable wastes (separately) prior to off-site transportation.

The waste within the biodegradable wastes storage area will be maintained with required. Wastes will only be stored for a maximum of 7 days prior to off-site

a separate drainage system and will have the capacity for complete enclosure if removal. Operational procedures will also be developed by the Operator that will area will be undertaken. 2.1.8

ensure that good housekeeping and regular cleaning / disinfection of the storage

Air control management within the Waste Treatment and Fuel Preparation Area will consist of a negative air pressure system that will extract air from this area and process it through the proposed biofilter treatment process prior to release for the biofilter design is given below. to air in order to destroy the odour that may be present. Consideration of BAT

2.1.9

Sector Guidance Note IPPC S5.01 also states that the Operator should assess the odour generating potential where identified and include an assessment of the results with a level of detail in keeping with the risk of causing odour-related annoyance at sensitive receptors.

2.1.10 The Atmospheric Dispersion Modelling (ADM) Report (Appendix 10 to the PPC Permit Application) contains an assessment of the potential impact of odorous emissions on sensitive receptors around the site and predicted emission limits at regards to the requirements for the odour reduction potential of the biofilter to be installed. These recommendations will be implemented at the facility. 2.2 Biofilter Abatement System Technique Selection 2.2.1 A biofilter abatement system has been selected for CRRRF based on their observed efficiencies and known operational ability with regards to the removal below (Table 4.53 from IPPC Reference Document on BAT for the Waste Treatment Industries) shows Biofilter Efficiencies for MBT waste gas treatment. of odours from biodegradable waste storage and treatment facilities. Table 1 the site boundary. The ADM Report conclusions make recommendations with

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Table 1: Biofilter Efficiency in MBT Waste Gas Treatment (Table 4.53 BREF Waste Treatment) Substance (Group) Aldehydes, alkanes Alcohols AOX, hydrocarbons (benzene) Aromatic hydrocarbons (toluene, xylene) NMVOC PCDD/F Odour NMVOC (Values in total Carbon) 30-70 10-40 80 83 40 95-99 80 aromatic 40 Input Concentration (mg/Nm3) Output Concentration (mg/Nm3) Biofilter Efficiency (%) 75 90

2.2.2

As can be seen biofilters remove between 95 and 99% of odour from waste gas biofilters. Open biofilters are where the medium is exposed to atmosphere,

emissions. As identified above there are two types of biofilter; open and closed sometimes at the sides as well as the top, gaseous emissions from these types of the biofilter medium is housed within a structure. This will typically have an inlet port for the dirty air, and an exhaust port for the treated air.

biofilters will escape freely from exposed surfaces. Closed biofilters are where

2.2.3

An enclosed biofilter system was modelled for the Atmospheric Dispersion rate. As such an enclosed biofilter is proposed at Carlisle Road.

Modelling as this allows greater control over flow rate, volume and extraction

2.2.4

In addition to the removal of odour, biofilters can achieve reductions in VOC

emissions from natural compounds and from the synthesis of inorganic 2006), as demonstrated in Table 1 above. However, they are not considered to HGV emissions.

compounds, aromatic and aliphatic compounds (BREF Waste Treatment, August be effective for the removal of particulates and emissions of NO2 associated with

2.2.5

Particulates will be controlled via a dust suppression system to be installed

within the Waste Treatment Fuel Preparation Area. This will consist of a fine mist necessary.

of water being used to damp down particulate emissions when it is considered

2.2.6

As detailed in paragraph 2.1.6 above, emissions associated with the movement of HGVs into and out of the building will be abated via the pulsing action of the roller shutter doors acting to flush the HGV emissions from the building.

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2.2.7

The detailed design of the proposed biofilter will be based on the quality the Waste Treatment Industries (August 2006).

principals for biofilter media as identified in IPPC Reference Document on BAT for

2.2.8

The IPPC BREF document for Waste Treatment describes a biofilter as consisting of an apparatus filled with decomposable material such as compost, bark or a mixture of turf and heather, etc. Micro-organisms (fungi, bacteria, viruses and algae) are resident on the material. The exhaust airflows through the material

while the micro-organisms decompose the harmful substances. The desired Note). qualities of a biofilter are outlined below in Table 2 (Table 4.52 from the BREF

Table 2: Qualities of Biofilter Media

Characteristic Filter Media Organic matter content >60% Porous and friable with 75-90% void volume Resistant to water logging and compaction Relatively low fines content to reduce gas headloss Relatively free of residual odour above characteristics Moisture Content Nutrients 50-80% by weight Provisions must be made to add water and remove bed drainage Usually not a problem with aerobic digestion gases because of the high NH3 content pH Temperature Gas pre-treatment 7 to 8.5 Near ambient, 15-35 or 40C Humidification could prove to be useful in order to achieve near 100% inlet gas humidity Dust and aerosols may be removed to avoid media plugging, but for most biofilters this is not a problem (unless they have a tissue layer in the bottom) Gas loading rate Gas residence time Media depth Elimination capacity Gas distribution <100m3/h-m3, unless testing supports higher loading 30-60 seconds, unless testing supports shorter residence time >1m, <2m Depends on media and compound (typically in the range 10-160g.m-3.h-1) The manifold must be properly designed to present a uniform gas flow to the media Must be adequate to avoid limitations Specifically designed mixtures of materials may be desirable to achieve the Description Biologically active, but reasonably stable

2.2.9

of the above quality requirements as part of the detailed design. The filter media will be made up of decomposable material most likely bark and turf as this will provide suitable void volume and water absorption capacity.

It is considered that any biofilter to be installed at the CRRRF will incorporate all

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2.2.10 The moisture content will be maintained between 50 and 80% by weight, grey and maintain moisture content within the above range. The pH and temperature of the biofilter will be maintained by the filter media and inlet gas flow, the gas will not be heated, and will therefore enter the biofilter at ambient temperatures.

water collected from the building roof will be used to damp down the biofilter

proposed media will ensure that the pH remains approximately neutral. The inlet

2.2.11 The gas loading rate, residence time and media depth with be determined at the final detailed design stage and will be calculated in relation to the perceived volumes of air changes to be managed via the biofilter and the odour potential of the biodegradable waste being stored.

2.2.12 The selection of a biofilter for the odour abatement system to

within the Waste Treatment and Fuel Preparation Area is considered to be BAT for the abatement of odour at not only Waste Treatment operations but for composting facilities that store biodegradable wastes as well.

be installed

2.2.13 The selection of a closed biofilter with suitable decomposable media and considered to provide BAT for an odour abatement system. FLUE GAS TREATMENT SYSTEM Introduction

characteristics as set out in IPPC BREF document for Waste Treatment is

3.0 3.1 3.1.1

The BREF document lists the factors to be considered when selecting flue-gas treatment systems as: Types of waste, its composition and variation Types of combustion process, and its size Flue-gas flow and temperature Target emission limit values

Flue gas content, size and rate of fluctuations in composition Restrictions on discharge of aqueous effluents Plume visibility requirements Land and space availability recovered plants) Availability and cost of outlets for residues accumulated / Compatibility with any existing process components (existing Availability and cost of water and other reagents

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scrubbers)

Energy supply possibilities (e.g. supply of heat from condensing

Availability of subsidies for exported energy Reduction of emissions by primary methods Release of noise

Tolerable disposal charge for the incoming waste

Arrange different flue-gas cleaning devices if possible with decreasing flue-gas temperatures from boiler to stack

3.1.2

Taking each of the above into consideration, the proposed flue gas treatment system is described below.

3.1.3

During gasification in the Primary Combustion Chamber (PGC), suction within the from the PGC into the SCC where combustion of the fuel gas will take place. Each gasification stream will have a dedicated SCC that will serve four PGCs.

Secondary Combustion Chamber (SCC) pulls the synthesis fuel gas produced

3.1.4

Each SCC will be a refractory lined carbon steel cylindrical vessel, completed with two thermocouples and a pressure transmitter.

two Combustion Air Fans, two SCC Burners, one Flue Gas Recirculation Air Fan,

3.1.5

The flue gas generated by the SCC will be extracted by the downstream variable speed Induced Draught Fan. The speed of the fan will be regulated by an outlet of the SCC. inverter, whose signal will be set to achieve a desired suction pressure at the

3.1.6

The suction in the SCC will extract the gases from the four PGCs, through the Cross Over Ducts and into the inlet end of the SCC. The connections into the SCC gas, flue gas and hot air. The type of gas in each duct will depend on the PGC mode of operation and will change as the PGC batch cycle progresses. will be tangential to promote rapid mixing and burn out of the synthesis fuel

3.1.7

Additional secondary combustion / quench air will be injected into the SCC through an injection ring close to the PGC Cross Over inlets. The injection ring will comprise several nozzles located around the circumference of the SCC and synthesis fuel gas / quenching of the flue gas. The combustion air will be provided by the two duty Combustion Air Fans, each being rated for 75% of the a flue gas temperature to that required in the WID.

these will promote rapid mixing and ensure complete combustion of the

total duty. These fans will be inverter driven and the speed controlled to provide

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3.1.8

normally not be used, but will be necessary during start-up, shutdown and periods of low waste calorific value. The SCC Burners will fire gas oil and will be above the temperature required by WID. automatically fired to ensure that the flue gas exiting the SCC is maintained

Two SCC Burners will also be located in the inlet end of the SCC. These will

3.1.9

The control of nitrogen oxides exiting the SCC will be provided by the following three systems:

Staged Air Combustion (as detailed above) Flue Gas Recirculation Urea Injection

3.1.10 Each stream will be equipped with a Flue Gas Recirculation Fan which will recirculate approximately 15% of the total flue gas flow from the outlet of the boiler to the secondary combustion air inlet of the SCC. This will reduce the for NOx formation.

oxygen content in the flue gas exiting the SCC and hence minimise the potential

3.1.11 Each SCC will also be equipped with a De-NOx system utilising urea. Urea prills

will be mixed with towns water in a proprietary De-NOx preparation package and the resulting urea solution will be pumped to each SCC and injected by air atomised nozzles. The dose rate of urea solution to each SCC will be controlled a

PLC utilising the NOx readings from the CEMS.

3.1.12 A Bypass Protection Vent will be provided on the discharge of each SCC. During normal operations, the Bypass Protection Vent (BPV) will be isolated by a hydraulically operated isolation valve and flue gas flow will be discharged from discharged to atmosphere via the main stack.

the SCC through the boiler and into the flue gas cleaning plant prior to being

3.1.13 The BPV will only be opened during the gasification process when there has been potential that downstream flue gas equipment will be damaged. The failure scenarios that will result in opening of the BPV are: Over pressurisation of the secondary combustion chamber as a result of ID fan failure, Boiler tube burst / leak,

a failure of the downstream flue gas processing equipment or when there is the

Boiler water feed failure,

Power failure (until such time as the plant is back online as a result of the start-up of the back-up generator),

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plant as necessary.

As a consequence of the emergency isolation of specific process

3.1.14 Flue gas exiting the SCC will then be processed through the waste heat boilers before entering the Flue Gas Cleaning System.

3.1.15 Each waste gasification stream will be served by its own independent flue gas comprise a Reaction Tower, a Bag Filter, an Induced Draught Fan, a CEMS and a

cleaning plant, which will utilise dry scrubbing. Each cleaning system will common multi-flue discharge stack. The purpose of the cleaning system will be emissions to atmosphere are in compliance with WID.

to remove ash, acid gas, dioxins and heavy metals from the flue gas, so that

3.1.16 Flue gas will exit the waste heat boilers of each gasification stream at a

temperature of 180C and will enter their respective flue gas cleaning streams. The temperature of the flue gas will be continuously monitored and if this exceeds 220C, the BPV will be opened to prevent damage to the bag filter.

3.1.17 Flue gas will initially flow into the reaction tower, where sodium bicarbonate and be provided by variable speed volumetric feeders and the dose rate will be

powdered activated carbon (PAC) will be dosed. The feed of these chemicals will automatically controlled by a PLC using the CEMS measurements of flue gas flow,

be conveyed by the flue gas through the reaction tower and into the bag filter, where they will be deposited on to the outside of the fabric bags.

SO2 concentration and HCL concentration. The sodium bicarbonate and PAC will

3.1.18 The sodium bicarbonate will rapidly decompose in the hot flue gas and this will

form sodium carbonate with a high surface area to volume ratio. This high with the SO2, HCI and HF contained in the flue gas. The PAC will adsorb dioxins

surface area will increase the reactivity of the sodium carbonate, which will react

and heavy metals.

3.1.19 The bag filter will be a pulsed jet type unit containing a set of heat resistant filter bags. As flue gas enters the bag filter, the fly ash, sodium carbonate and PAC will be collected on the surface of the filter media. The flue gas will be de-dusted

and this will be extracted by the variable speed induced draught fan. The speed

of the fan will be automatically controlled to achieve the desired suction pressure multi-stack. A CEMS unit will record the contaminants being discharged to the

in the SCC. Flue gas will be discharged by the fan to atmosphere through a atmosphere.

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3.1.20 Periodically, the bag filter media will be cleaned by pulsing the filter bags with compressed air. The solid residue dislodged from the filter bags will be collected in the hopper at the base of the bag filter. This residue will comprise fly ash, sodium fluoride.

contaminated PAC, sodium carbonate, sodium sulphate, sodium chloride and

3.1.21 The majority of the bag filter residue will be discharged from the bag filter

hopper by a screw conveyor and recycled back to the inlet of the reaction tower,

where it will be re-injected into the flue gas stream. This recycling will aid in the minimise the generation of solid waste residue from the gas cleaning plant.

minimisation of the consumption of fresh sodium bicarbonate and hence

3.1.22 Consideration of each individual section of the flue-gas cleaning system with specific reference to BAT is given below. NOx Abatement System Technique Selection 3.2.1 Sector guidance note S5.01 indicates that the use of flue gas recirculation and other primary techniques may be considered BAT. This is addressed in Section 2.3 of the PPC Permit application which confirms that the proposals for primary NOx control are considered BAT. 3.2.2

3.2

Secondary NOx control measures require consideration in order to prevent or where this is not possible to minimise emissions. The options considered in this cost benefit analysis are the use of no secondary control, use of selective noncatalytic reduction (SCR). catalytic reduction (SNCR) using ammonia or urea, and the use of selective

3.2.3

The option of no secondary control for NOx is rejected because this does not

compliance with the WID limits for NOx could not be guaranteed. BAT cannot be demonstrated for this option and it is therefore rejected.

attempt in any meaningful way to minimise emissions of NOx, and because

3.2.4

A comparison of SNCR and SCR appears in Table 3 below.

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Table 3: Comparison of SNCR and SCR

BAT consideration (a) the use of low-waste technology (b) the use of less hazardous substances (c) the furthering of recovery and and used in the process and of waste, where appropriate (d) comparable processes, facilities have been tried with success on an industrial scale (e) changes in scientific knowledge and understanding (f) the nature, effects and volume of the emissions concerned (g) the commissioning dates for new or existing installations or mobile plant (h) the length of time needed to introduce technique (i) the consumption and nature of raw materials (including water) used in the process and the energy efficiency of the process Urea consumed. Small by energy dosing reaction 2-3). at For 25% ammonia Ammonia solution consumed, and water used 1.1), consumed. due less to Less reagent more favourable reagent at is 25% consumption to less the best available No difference. No difference. Significant decrease in NOx-in the range of 30-75%. No difference. Likely to be greater decrease in NOx, often >80%. No difference. technological advances and Will continue to be monitored. Will continue to be monitored. or methods of operation which Established technique-particularly for smaller plants (EU BREF). Established capital cost more justifiable for larger plants. technique-greater Can use urea is or ammonia. more Ammonia hazardous. recycling of substances generated Not applicable. Not applicable. considered SNCR No solid waste produced. SCR Waste catalyst produced (0.01 kg waste/tonne waste processed). Uses ammonia which is considered more hazardous.

equipment. More reagent used due favourable (ratio 9 kg waste stoichiometry ammonia, solution/tonne

stoichiometry of reaction (ratio 1excess (3.4 kg waste required solution). ammonia

solution/tonne

solution consumed. Minimal efficiency. (j) the need to prevent or reduce to the emissions on the environment and the risks to it (k) the need to prevent accidents and to minimise the consequences for the environment a minimum the overall impact of effect

on

energy

Reheat of gases required, hence energy efficiency potentially lower. NOx concentrations in flue gas with lower energy efficiency, and production catalyst. of additional waste could be decreased further, but

Environmental impacts reduced at acceptable cost.

Urea is inherently less hazardous raw material.

Ammonia solution is inherently more hazardous raw material.

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(l) the information published by the Commission pursuant to Article 16(2) of the Directive or by international organisations Capital costs Operating costs Maintenance costs Other relevant issues Notes:

Potential BAT, endorsed by EU BREF Note for waste incineration and S5.01. Capital costs lower. Lower (by 25-40%). Lower costs and downtime. Little space required.

Potential BAT, endorsed by EU BREF Note for waste incineration and S5.01. Capital costs significantly higher.

Requires more space for additional process unit.

Cost implications also considered in accordance with BAT principles. Data from EU BREF, Section 4.4.4

3.2.5

Based on the indicative BAT considerations given in the PPC Permit application considered that the BAT for minimising control of emissions of NOx to

document, along with the specific BAT considerations outlined in Table 3, it is atmosphere for the facility is by use of flue gas recirculation and SNCR. SNCR Reagent Selection

3.2.6

There are two possible reagents that can be used with SNCR for the abatement of NOx, these are Urea and Ammonia. A comparison of the use of both of these of a reagent is included below. options is included in Table 4 below. Further technical discussion on the choice

Table 4: Comparison of urea and ammonia solution for use in SNCR

BAT consideration (a) the use of low-waste Urea Can lead to higher nitrous oxide formation than ammonia (2-2.5 times higher) and emissions of ammonia optimised. Lower ammonia slip (~1mg/Nm3). Urea is effective over a wider temperature range (850-1050 C). No solid waste produced. No solid waste produced. (b) the use of less hazardous substances (c) the furthering of recovery and recycling of substances generated and used in the process and of waste, where appropriate Urea less hazardous for storage and handling, and for Health and Safety and odour considerations. Not applicable. Not applicable. Ammonia hazardous. is considered more Higher (~10mg/Nm3). Narrower effective temperature ammonia slip if dosing is not Leads Ammonia solution to lower nitrous oxide

technology

formation if dosing optimised.

range (850-950 C).

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(d) comparable processes, facilities or methods of operation which have been tried with success on an industrial scale (e) technological advances and

Established technique.

Established technique.

Will continue to be monitored.

Will continue to be monitored.

changes in scientific knowledge and understanding (f) the nature, effects and volume of the emissions concerned Higher N2O emissions (25 35 mg/Nm) (g) the commissioning dates for new or existing installations or mobile plant (h) the length of time needed to introduce technique (i) the consumption and nature of raw materials (including water) used in the process and the energy efficiency of the process Minimal efficiency. (j) the need to prevent or reduce to a minimum the overall impact of the emissions on the environment and the risks to it (k) the need to prevent accidents and to minimise the consequences for the environment (l) the information published by the Commission pursuant to Article 16(2) of the Directive or by international organisations Operating costs Maintenance costs Notes: 4.4.4. Lower cost per tonne waste. Similar. Higher cost per tonne waste. Similar. Urea is inherently less hazardous raw material. Urea has minimal potential for odour emissions from storage or leaks. Potential BAT, endorsed by EU BREF Note for waste incineration and S5.01. Ammonia solution is inherently more hazardous raw material. Potential for odour emissions from storage or leaks. Potential BAT, endorsed by EU BREF Note for waste incineration and S5.01. Environmental impacts reduced at acceptable cost. effect on energy Urea consumed. Small by energy dosing Ammonia solution consumed, and water consumed. Small by energy dosing consumption equipment. Minimal efficiency. Environmental impacts reduced at higher cost. effect on energy the best available No difference. No difference. No difference. Significant decrease in NOx. Likely to be greater potential decrease in NOx. Lower N 2O emissions (10 15

mg/Nm). No difference.

consumption equipment.

Cost implications also considered in accordance with BAT principles. Data from EU BREF, Section

3.2.7

Selective Non Catalytic Reduction (SNCR) has been selected as the most appropriate technique for abatement of emissions of oxides of nitrogen from the sequential batch oxidation system (SBOS) gasification process to be installed at the CRRRF.

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3.2.8

The Incineration BREF Note indicates that the use of urea as the reagent for SNCR can, under certain circumstances, lead to elevated concentrations of nitrous oxide (N2O) in the emissions to atmosphere, a situation which, it states, is less

likely to occur with ammonia as the SNCR reagent. 3.2.9

The SNCR control system for the SBOS gasification system will incorporate two the formation of N2O:

levels of control to optimise NOX reduction and minimise ammonia slippage and

A feed pump with an inverter will control the amount of urea solution operating parameters or in the fuel-N N2O content. The CEMS

injected into the flue gases for short-cycle variation either in the continuously monitor the NOX, and ammonia emissions will

concentrations. If an increase in NOX concentration is observed, then the speed of the feed pump will increase accordingly until the NOX concentration falls to a minimum. During this process, if the preset feeding pump will slow down and the PLC control will generate a warning message to the operator; the same principles are applied when the measured NOX concentration falls. ammonia and N2O concentrations are reached, then the speed of the

The speed of the feeding pump can only deal with short-period cycles of

NOX variation. If a steady pattern of NOX emission concentration is the urea solution in the holding tank, the variable-speed worm-feeders will be used to vary the amount of urea added to the water so that the

observed for a time period equal or greater than the residence-time of

urea concentration solution changes. In such a way, the volume of the urea solution will be kept at the optimised level to provide the best atomisation quality from the injection nozzles.

3.2.10 Alternative gasification techniques/processes, such as those discussed in Appendix characteristics due to variations in the operating conditions (temperature and 1 to the Management Plan, have differing NOX

emissions

excess air level) within the various combustion systems. Accordingly, those with compliance with the WID NOX emission standard. Therefore, the addition of SNCR reagents will be lower for these systems with reduced potential for associated emissions of N2O. lower inherent NOX emissions will require less abatement in order to ensure

3.2.11 The situation, however, is not that simple, as the operating temperature has a significant impact on both the formation and dissociation of N2O. According to

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are promoted by:

the Incineration BREF Note, emissions of N2O from waste incineration processes

The use of lower combustion temperatures typically this becomes important below 850 C

The use of SNCR for NOX reduction (particularly where urea is the reagent).

3.2.12 Fluidised Bed (FB) gasification systems generally operate at lower temperatures within the bed which could lead to blockages and uneven combustion air flow

than conventional systems, in order to minimise the potential for ash fusion within the bed. Accordingly, they are generally associated with lower NOX

emissions compared to the more-intensive combustion conditions found in alternative thermal treatment processes.

3.2.13 Measurements carried out on solid fuel-fired combustion systems 1 showed that emissions of N2O from conventional combustion systems such as grate firing and pulverised fuel combustion were associated with emission concentrations of <25 mg m-3. However, results from FB gasification systems were up to an order of

magnitude higher due to their lower operating temperatures. Accordingly,

although the operating conditions found within FB gasification systems produce concentrations that may be as much as ten times higher than from grate firing.

lower NOX emissions, they also promote the formation of N2O with emission Accordingly, above bed secondary combustion temperatures and residence times must be maintained at conditions that will promote the thermal decomposition of N2O.

3.2.14 Accordingly, in addition to the comments made about the non-applicability of FB gasification technology to the gasification of the waste to be processed at the them from consideration as BAT for this particular application. CRRRF, the higher inherent release of N2O from these systems further precludes

3.2.15 Determining whether the proposed SNCR system for a gasification process represents BAT is primarily related to the reagent used. The BREF Note for Waste of N2O for ammonia and urea-based SNCR systems: Incineration processes provides the following information on relative emissions

Nitrous Oxide from Solid Fuel Combustion: Contribution to National Inventories in the UK, France and Germany, Fynes G, Hughes ISC & Sage PW. Non-CO2 Greenhouse Gases: How and Why to Control. Proceedings of an International Symposium, Maastricht, The Netherlands, 13-15 December 1993

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3.2.16 Accordingly, emissions of N2O from urea-based SNCR systems may be twice as high those when ammonia is used. However, this will vary from plant to plant, required. depending upon the level of abatement and associated reagent loadings

3.2.17 In relation to the operation of the SBOS Gasification system, with an operating temperature in the secondary combustion chamber of about 1120C, when to be ~2 ppm or ~4 mg m-3 based on information in the following graph: processing hazardous waste, the expected N2O emission concentration is likely

Ref. Combustion and Flame, Volume 117, Issue 4, June 1999, Pages 821 to 831

3.2.18 Based upon the estimated fluegas volumetric flowrate for the SBOS system and

the N2O emission concentration data in the above table, annual emission values
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have been calculated to compare the GWP values for ammonia and urea-based SNCR systems for the SBOS gasification process associated with the CRRRF.
Table 5: Comparison of GWP Values for Ammonia and Urea Based SNCR System SNCR Reagent FG Volumetric Flowrate (m /hr) Hours Operation per Annum N2O Emission Concentration (mg m ) N2O Emission per Annum (tonne) GWP* (CO2 Equivalent) Note: *
-3 3

Ammonia 93,220 8,000 15 11 3,468

Urea 93,220 8,000 35 26 8,091

Urea 93,220 8,000 4 3 925

GWP for N2O assumed to be 310

3.2.19 Accordingly, assuming a worst case scenario of an N2O emission concentration of 35 mg m-3 for urea-based SNCR, there is likely to be an additional GWP for the SBOS gasification process associated with the CRRRF of ~8,100 tonne CO2-

equivalent per annum. This would increase the overall GWP for the process to factor of ~1.67 tonne CO2-equivalent per MWhr of renewable electricity exported

~133,932 tonne CO2-equivalent per annum, with an associated CO2 emission to the grid. This is at the lower end of the range quoted for MSW in the Incineration BREF Note.

3.2.20 If the expected N2O emission concentration of ~4 mg m-3 is achieved, then the annum, and the overall value would be ~126,757 tonne CO2-equivalent per per MWhr of renewable electricity exported to the grid. annum, with an associated CO2 emission factor of ~1.58 tonne CO2-equivalent additional GWP for the SBOS facility would be ~925 tonne CO2-equivalent per

3.2.21 The corresponding figures for an ammonia-based SNCR system, assuming a N2O facility of ~3,500 tonne CO2-equivalent per annum. This would increase the with an associated CO2 emission factor of ~1.62 tonne CO2-equivalent per MWhr. 3.2.22 The incorporation of urea-based SNCR is likely to result in an ~1% to ~6% emission concentration of 15 mg m-3, would be an additional GWP for the SBOS

overall GWP for the SBOS facility to ~129,332 tonne CO2-equivalent per annum,

increase in CO2-equivalent emissions per annum from the SBOS gasification value in the BREF Note, is approximately twice that if ammonia was used as the
3

process associated with the CRRRF. The higher value, based on the maximum SNCR reagent. However, if the expected N2O emission concentration of ~4 mg m-

that for ammonia injection.

is achieved, then the additional GWP due to urea injection would be less than

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3.2.23 Despite the fact that the BREF Note advises the use of ammonia as the reagent for SNCR, there are mitigating circumstances in favour of the system proposed for use at Carlisle Road Resource Recovery Facility.

3.2.24 The SBOS design incorporates most of the recommendations in the Incineration BREF Note for controlling emissions of N2O from the thermal treatment process.

3.2.25 The one exception to the BREF guidance for avoidance of N2O formation is the financial reasons, some of which have significant Health & Safety implications, and are identified in the BREF guidance document. 1. Handling and storage

selection of urea as the SNCR reagent. This is for a number of technical and

solutions are generally more stringent and, hence, more expensive than for urea, which can be stored as a solid;

requirements for ammonia liquid, gas and

2. Saturated solutions can develop a significant pressure inside a closed storage vessel in warm weather, and pose risk to the safety of the plant operation. The external storage of ammonia could be a major hazard at associated with the operations of the adjoining MRF;

the CRRRF due to the movement of heavy vehicles around the site, 3. Storage of more than 50 tonnes of gaseous ammonia is regulated under

COMAH Directive. This may cause extra costs due to requirements of ammonia is used as a solution. There are still some safety requirements but less stringent than with gaseous or liquefied ammonia. This is an for external storage of ammonia.

local authorities and permit application procedures. In most cases

issue for a small site such as at CRRRF where there is little available space 4. The lower cost of urea is only valid for relatively small plants. For larger

plants the higher storage cost of ammonia may be fully compensated by the lower chemical cost. As stated already, the CRRRF is relatively small and confined, and the on-site movement of vehicles associated with the adjacent MRF operations could present a significant risk to external ammonia storage tanks.

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3.2.26 Ammonia slippage from urea-based SNCR systems is quoted in the IPPC BREF

Note for Waste Incineration to be much lower than from ammonia-based

ammonia. Although there is not a WID ELV specified for ammonia in the

systems, with values of ~1 mg m-3 quoted for urea and ~10 mg m-3 quoted for

emissions to atmosphere, there is likely to be a condition in the PPC Permit to measure it continuously with the expectation that emissions should be as low as possible. Accordingly, the use of a urea-based SNCR system will assist in achieving this objective.

3.2.27 On the basis of the above technical discussion, it is considered that in relation to NOX abatement using urea as the SNCR reagent constitutes BAT with regard to

the wastes to be processed by the SBOS waste gasification plant at the CRRRF,

emissions of N2O from the process. Accordingly, a cost benefit appraisal was not undertaken.

3.3

Acid Gas Abatement System Technique Selection

3.3.1

Sector Guidance Note S5.01 indicates that the use of primary techniques that control inputs of sulphur and chlorine in support fuels and wastes (respectively) to the facility may be considered BAT. This is addressed in Section 2.1 of the PPC are considered BAT.

Permit application which confirms that the proposals for primary acid gas control

3.3.2

or where this is not possible to minimise emissions. The options considered in

Secondary acid gas control measures require consideration in order to prevent

this cost benefit analysis are the use of no secondary control, use of wet systems. 3.3.3

scrubbing systems, use of semi-dry scrubbing systems, and use of dry scrubbing

The option of no secondary control for acid gases is rejected because this does

not attempt in any meaningful way to minimise emissions, and because compliance with the WID limits for acid gases could not be guaranteed. BAT cannot be demonstrated for this option and is therefore rejected.

3.3.4

For wet scrubbing systems significant volumes (typically 250-500 litres per which given the location and lack of a foul sewer connection at the CRRRF would

tonne of waste processed BREF August 2006) of effluent would require disposal prove costly in terms of storage media (as well as space requirements) and

tankering to the nearest Waste Water Treatment Works. Wet scrubbing systems are also relatively complex and expensive, although it is noted that they can lead
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to the lowest residual concentrations of acid gases. However, given the effluent treatment requirements and on-site infrastructure available at the proposed development site the use of wet scrubbing systems in now rejected. 3.3.5

Semi-dry scrubbing systems are considered to be more complex than dry scrubbing systems as well as more expensive to install and maintain. Consequently, the use of semi-dry scrubbing systems is now rejected.

3.3.6

Conversely, dry scrubbing systems are generally considered to be of low

complexity, reduced installation and maintenance costs, satisfactory abatement of acid gases (demonstrated to comply with the requirements of WID) and reduced effluent volumes. Dry systems also have a high effective temperature range (140-3000 C with sodium bicarbonate, 130-180o C with lime) and can cope with high acid gas loadings. The simplicity of dry scrubber systems is noted as being a critical factor in EU BREF. Simplicity of design is a key consideration throughout the Sequencing Batch Oxidation System (see assessment of alternatives document, Appendix 1) and assists in selection of a dry scrubber system as BAT for the facility.

3.3.7

In terms of the global warming potential of the alternative process types for acid gas abatement, there are two principal issues that need to be taken into account: 1. Energy consumption associated with process operation; and, 2. Emissions of CO2 associated with the preparation and utilisation of the acid gas neutralising agent.

3.3.8

Table 5.3 of the Incineration BREF Note indicates that there is little difference

between the energy consumption for dry and semi-dry acid gas abatement to pump demand, and may be even higher when combined with other flue gas treatment processes, such as particulate removal.

systems. However, energy consumption in wet FGT systems may be higher due

3.3.9

The Incineration BREF Note indicates that for wet scrubbing systems the specific

energy consumption may be as high as 19 kWhr/tonne waste, whereas the corresponding figure for semi-dry processes is quoted to be in the range of 6 to 13 kWhr/tonne waste. The principal contributor to the energy consumption figures is the pressure drop across the bag filter and increased fan power

requirements. Similar conclusions are drawn for the bag filtration plant associated with dry systems, however, as they are capable of operating at higher temperatures there is less requirement for flue gas reheat prior to release, with associated benefits for overall energy efficiency.

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3.3.10 The energy efficiency considerations outlined above, support the above conclusion that dry scrubbing represents BAT for acid gas abatement at the CRRRF.

Neutralising Agent Selection 3.3.11 The use of lime or sodium bicarbonate as the neutralising agent for acid gases in the dry scrubber system is considered in Table 5 below.

Table 5: Comparison of Lime and Sodium Bicarbonate in Dry Scrubber Systems

BAT consideration (a) the use of low-waste Lime Reagent stoichiometric ratio for neutralisation of 1.5-2.5 leads to production residues. Waste Waste is less leachable, but more alkaline. (b) the use of less hazardous substances Lime material. is considered being a more corrosive Sodium hazardous to (c) the furthering of recovery and recycling of substances generated and used in the process and of waste, where appropriate (d) comparable processes, facilities or methods of operation which have been tried with success on an industrial scale (e) technological advances and Will continue to be monitored. Especially as overall efficiencies become known. EU BREF indicates acid gas removal can <50 (g) the commissioning dates for new or existing installations or mobile plant (h) the length of time needed to introduce technique (i) the consumption and nature of Lime consumed. Small energy Sodium bicarbonate consumed, the best available No difference. No difference. be for
3

Sodium bicarbonate Reagent stoichiometric ratio for neutralisation 1.25 leads to production of less waste residues. has greater leachable

technology

of

more

waste

component. bicarbonate for is nonand Safety

hazardous,

storage and

handling, and better with respect Health considerations.

Residue recycling systems proven.

Residue recycling systems proven.

Established technique.

Established technique.

Will continue to be monitored. Especially as overall efficiencies become known. EU BREF indicates acid gas removal can be more effective (achieved emission range <5 for HCl and <20 for
3

changes in scientific knowledge and understanding (f) the nature, effects and volume of the emissions concerned

effective SO2, daily

(achieved average

emission range <10 for HCl and mg/Nm ). No difference.

SO2,

daily

average

mg/Nm ). No difference.

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raw

materials

(including

water)

consumption equipment.

by

dosing

smaller

mass

due Small by

to

reaction energy dosing

used in the process and the energy efficiency of the process

chemistry. consumption equipment.

Minimal efficiency.

effect

on

energy

Minimal efficiency.

effect

on

energy

No water consumed. (j) the need to prevent or reduce to a minimum the overall impact of the emissions on the environment and the risks to it (k) the need to prevent accidents and to minimise the consequences for the environment (l) the information published by the Article 16(2) of the Directive Operating costs Commission pursuant to Lime is inherently more hazardous as a raw material and as a waste material. Potential BAT, endorsed by EU BREF Note for waste incineration and S5.01. Environmental impacts reduced at acceptable cost.

No water consumed. Environmental impacts reduced at slightly higher cost.

Sodium

bicarbonate

is

less

hazardous. Potential BAT, endorsed by EU BREF Note for waste incineration and S5.01.

or by international organisations Similar cost per tonne waste (more reagent required but lower cost compared to alternative). Maintenance costs Notes: 4.4.3 Similar-dosing plant similar. Similar cost per tonne waste (less reagent required but higher cost compared to alternative). Similar-dosing plant similar.

Cost implications also considered in accordance with BAT principles. Data from EU BREF, Section

3.3.12 The conclusion is that BAT for acid gas control at the facility is a dry scrubber system using sodium bicarbonate as the neutralisation reagent, the global warming potential of which is considered further in the following technical discussion taken from a GFE Environmental report written for Scotgen (South Lanarkshire) Limited.

3.3.13 With regards to emissions of CO2 associated with the preparation and utilisation of the acid gas neutralising agent, there is little to choose between lime (Ca(OH)2) and sodium bicarbonate (NaHCO3).

3.3.14 It is important to note that lime is manufactured from the calcination of calcium gas abatement systems. The following example relates to emissions of SO2:

carbonate, which is then hydrated to produce slaked lime which is used in acid

CaCO3 Heat CaO + CO2 CaO + H 2 O Hydration Ca(OH) 2 Ca(OH) 2 + SO2 CaSO3 + H 2O

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3.3.15 Accordingly, the production of one mole of slaked lime is associated with the mole of SO2. However, in acid gas abatement systems, the Incineration BREF Note requirement in order to achieve WID ELVs.

release of one mole of carbon dioxide, and one mole of Ca(OH)2 reacts with one states that lime addition can be as high as 2.5 times the stoichiometric

3.3.16 In acid gas abatement systems based upon sodium bicarbonate, the reaction with SO2 occurs via the following mechanism:

2NaHCO 3 + SO 2 +

O2 Na 2 SO 4 + 2CO 2 + H 2O

3.3.17 Therefore two moles of sodium bicarbonate are required to abate one mole of Incineration BREF Note reports that sodium bicarbonate addition is generally at a equivalent to that of slaked lime at the upper end of range of quoted stoichiometries (2.5).

sulphur dioxide, with the associated release of two moles of CO2. The

stoichiometric ratio of about 1.25, therefore the overall CO2 release is roughly

3.3.18 Accordingly, the GWP of dry acid gas abatement systems based upon sodium the achievement of lower stoichiometric ratios, may be balanced out by the bicarbonate with lower requirements for flue gas reheat prior to release.

bicarbonate or lime is likely to be similar. Any potential benefits for lime through

potentially lower specific energy consumption of systems based upon sodium

3.3.19 According to the Gasifier Mass Balance drawing which forms part of the PPC Permit Application (SG1004/5/12), the sodium bicarbonate dosing rate is expected to be ~316 kg/hr, or ~2,251 tpa. Accordingly, assuming that there is complete reaction of all of the sodium bicarbonate added to the flue gas, the annual release of CO2 associated with the use of ~2,251 tpa of acid gas

abatement reagent is likely to be ~1,179 tpa. This represents about 1% of the CO2 that is likely to be produced by the carbon in the 80,000 tpa of waste to be processed by the SBOS gasification plant at the CRRRF. Accordingly the overall annum.

release of CO2 from the CRRRF would increase to 127,936 tonnes CO2 per

3.3.20 This BAT assessment submitted as part of the PPC Permit Application clearly demonstrates that there are strong technical reasons for a dry acid gas abatement Accordingly, a cost benefit appraisal was not undertaken. system with sodium bicarbonate as the neutralising agent.

3.3.21 A detailed BAT assessment of the selection of particulate abatement has not been undertaken. A bag filter is currently proposed for implementation at the

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CRRRF. It is acknowledged that alternatives capable of withstanding greater gas operating / bypass protection system to be installed at the CRRRF will not be

temperatures are available (i.e. Ceramic Filters), however, the proposed abnormal activated as a consequence of high flue gas temperature exiting the SCC (See 3.1.14 above). Elevated flue gas temperature exiting the SCC will be cooled to gas cleaning system. temperatures within the bag filters range within the boiler and subsequent flue

3.3.22 Bag filters are currently in use at an operational facility utilising the SBOS

gasification technology to be installed at the CRRRF and as can be seen from the WID Compliance Assessment (Appendix 30 the PPC Permit Application) the bag bag filter particulate abatement system is currently considered BAT for the SBOS gasification system. filter is currently achieving the required particulate emission levels. As such a

3.4

Bypass Protection Vent - Abnormal Operation Technique Selection

3.4.1

Sector Guidance Note IPPC S5.01 indicates that dump stacks and by-passes are considered BAT but that they should only operate for safety reasons or where a otherwise be damaged. heat removal system has failed, and the downstream gas cleaning plant will

3.4.2

It is also noted that it should be possible for dump stacks to be ducted to the main stack, thus effectively completing a bypass operation and allowing improved dispersion with the additional height and dispersion afforded from the main stack, as well as allowing monitoring equipment to quantify the release.

3.4.3

Further requirements for consideration of dump stacks and by-passes as BAT are detailed below: Systems should be designed so that dump stacks / by-passes do not operate as part of normal, planned operation. acceptable. Operational frequencies greater than once per year are unlikely to be Operation of a dump stack / by-pass may be considered to be a period of abnormal operation and the process should be reduced or closed down. Start-up and shut down should normally be achieved without any releases from the dump stack / by-pass.

/ release point where linkage to the main stack is impractical) may be

An abatement bypass system, linked to the main stack (or auxiliary stack

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operated on start-up where this has been authorised and is necessary to prevent damage to abatement plant. need for bypass on start up. Electric heating is an available option for new bag filters to avoid the Failure of the flue gas cleaning plant should not normally lead to operation of the dump stack. 3.4.4 As detailed above, a Bypass Protection Vent is proposed within the ERF process

for protection of the down-stream flue gas cleaning system. The proposed operation scenarios of the bypass protection vent are detailed within Section 2.3 of the Management Plan to the PPC Permit Application and listed below:

Over pressurisation of the secondary combustion chamber as a result of Boiler tube burst / leak, Power failure (until such time as the plant is back online as a result of the As a consequence of the emergency isolation of specific process plant as necessary. start-up of the back-up generator), Boiler water feed failure, ID fan failure,

3.4.5

In accordance with the requirements specified in IPPC S5.01 the above proposed operation scenarios are therefore considered BAT for the operation of a dump stack / bypass as they are all considered to represent both safety and heat removal system failure scenarios only. Consideration of the design for the Bypass Protection Vent with regards to BAT is given below.

3.4.6

The Bypass Protection Vents (BPV) are not proposed to be routed to the main

stack at Carlisle Road Resource Recovery Facility (CRRRF) but to individual vents on the roof of the main building. These vents will each be 19m in height (from ground level) and 1.5m in diameter.

3.4.7

It is not proposed to duct the bypass protection vent to the main stack because

the flue gas exiting the BPV will be at approximately 1100C, which will require would be costly and would require the entire length of the main stack to be rerated from a temperature of 250C to 1100C i.e. the main stack would require refractory lining and the outside diameter would have to be increased the BPV and roof vent to be refractory lined. Routing this line to the main stack

significantly. In accordance with the principals of BAT, that techniques selected should achieve an appropriate balance between environmental benefits and the costs incurred by Operators, this is not considered to represent BAT.

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3.4.8

It is also considered that, from a safety view point, it is important that when the BPV operates, suction is maintained in the SCC. The BPV relies on natural ventilation and it is therefore important that the BPV length from the SCC is minimised as far as possible to ensure a low pressure loss in the BPV. Should the increase and due to the distance involved it is probable that the SCC would operate at pressure rather than suction. BPV be routed to the main stack then the pressure loss in this system would

3.4.9

No waste will be treated during this pre-operational warm up period and waste

treatment will not be started until the BPV is closed via the hydraulically operated propose operation of the BPV during normal, planned operation and is Although electric heating of the bag filter is now available this system has not specifically not considered to represent BAT.

isolation valve. This operation is considered to represent BAT as it does not considered to provide protection of the downstream flue gas cleaning system. been tested operationally on an SBOS gasification plant in the UK and is therefore

3.4.10 This BAT assessment demonstrates that within the specific constraints of the design of the SBOS gasification system the proposed operation scenarios and design of the Boiler Protection Vent are considered to represent BAT is accordance with the requirements detailed in IPPC S5.01. 4.0 4.1 CONCLUSIONS In accordance with the principles of Best Available Technique and the descriptions set out in the appropriate sections of this document it is considered that the abatement techniques proposed for implementation at the Carlisle Road Resource Recovery Facility are considered to represent BAT for the installation.

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