Fertiliser & Regulation - Bryan Lewens (Andigestion Ltd)

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This presentation formed part of the Farming Futures "Farm Biogas Developer: Expert workshop" …

This presentation formed part of the Farming Futures "Farm Biogas Developer: Expert workshop"

30th June 2009

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  • Originally mainly farm manures but some wastes to ABP Capacity 140,000 tonnes Now food wastes only
  • Fertiliser Prices as at June 2009 % Price/tonne 1 Price/kg   Ammonium Nitrate 34.5 £200 £0.58   Phosphate 46 £460 £1.00   Muriate of Potash 60 £500 £0.83  

Transcript

  • 1. Farming Futures Farm Biogas Developer 30 th June 2009 Fertiliser and Regulation Bryan Lewens
  • 2.  
  • 3. Holsworthy Plant
        • Jan 2001 Construction of plant
          • Planned to process mainly animal manures
            • 23 dairy farms and 1 layer unit
          • Pasteurisation 70 o C for 1 hour to kill animal pathogens.
          • Planning Permission to take 20% food wastes
          • Anticipated benign regulation
      • But
        • Feb 2001 – Foot and Mouth Disease.
        • Plant subject to Integrated Pollution, Prevention, Control (IPPC regulations Environment Agency )
        • May 2003 Animal By-Products Regulations- DEFRA Animal Health
        • October 2005 Digestate spreading to land as bio-fertiliser . EA Notifiable Exemptions subject to fees.
        • 2007 Environment Agency fees reach £80,000+/annum
        • May 2008 Food “Waste” only plant- throughput reduced.
  • 4. Digestate- Analysis (courtesy Owen Yeatman )
    • Dry Matter* 4.5%
    • pH* 7.9
    • Total N 3.5 kgs/M 3 31 units/1000 gallons NH 4 N** 2.5 kgs/M 3 23 units/1000 gallons
    • P 2 O 5 1.0 kgs/M 3 9 units/1000 gallons
    • K 2 O 2.3 kgs/M 3 20 units/1000 gallons
    • MgO* 0.8 kgs/M 3 7 units/1000 gallons
    • SO 3 * 0.4 kgs/M 3 4 units/1000 gallons
    • *Estimates BL
    • ** Potentially Crop Available N 70%Total N (Source OY)
    • NB. Typically cow slurry 50% Total N Potentially Crop available.
  • 5. 1st Cut Silage Spreading Rate (m 3 /ha) = 35 Digestate applied on 15th March - Shallow Injection Nitrogen (N) Phosphate (P 2 O 5 ) Potash (K 2 O) Value Estimated total nutrients in digestate (kg/m 3 ) 3.5 1 2.3 £4.95 Estimated available nutrients in digestate (kg/m 3 ) 1 2.8 1 2.3 £4.54 Requirement for 1st cut silage (kg/m 3 ) 2 120 40 80 £176.23 Calculate digestate supply of potentially plant-available nutrients (kg/ha) 98 35 81 £158.89 Calculate supply of plant-available N after NH 3 and NO 3 losses (MANNER) (kg/ha) 79 35 81 £147.88 Calculate inorganic fertiliser need (kg/ha) 41 5 -1 £28.35 Total N/hectate applied (kg/ha) 123
  • 6. Digestate Spreading June 2 nd 2008
  • 7. Grass cover June 30 th
  • 8. Regulation Situation
    • Key regulation is still under consideration
        • DEFRA consultation on Waste Exemptions delayed
          • which in turn has delayed
        • Implementation EA Standard permits covering AD plants, digestate storage and spreading of wastes. Now out for consultation (ends August 28 th 2008) but subject to DEFRA decision on Exemptions.
        • DEFRA is keen for AD to develop- seen as benefit in NVZs and in treating organic waste.
  • 9. What is “Waste”- legally
    • “ Any substance or object the holder discards, intends to discard or is required to discard" is WASTE under the Waste Framework Directive
    • Material continues to be a waste until “fully recovered” e.g Holsworthy digestate spread on land as a fertiliser.
    • If non waste materials are mixed with “waste” materials, the mix is waste
    • Economic value is not relevant to waste status
    • Legal Definition of “waste” can change
  • 10. Animal Manures
    • In April 2008 the EA published a guidance note:
      • Manures and slurries spread to land are not “wastes”
      • But if designated for AD they are “wastes”
      • The resultant digestate is therefore “waste”
    • Following concerns raised during the Exemptions Consultation lobbying by NFU/CLA/REA
    • In December 2008 this was revised
      • Manures and slurries designated for AD are still “wastes”
      • As a result of AD the process improves the fertiliser qualities and if spread to land in the same way as manures and slurries the digestate is not “waste”. Recovery achieved in the digestion process.
  • 11. Implications
    • Digestate from AD plants processing animal manures and slurries and energy crops (non wastes) are not subject to Waste regulations.
      • EA Notifiable Exemptions for spreading wastes are expensive to apply for and require time and expertise (FACTS) to administer- not required
      • No major regulatory issues over storage- (as for slurry)
      • Less likelihood of public concerns over using “waste” on agricultural land
    • Very small farm (non waste) AD plants are likely to be able to operate under a Simple Exemption.
      • Little or no cost registration with EA?
      • Question over economic viability. Thermal input <1.5MW?
  • 12. Implications (cont)
    • Larger plants will require Standard Rules Permit
      • Standard rules if plant specifications fit. (Current EA Consultation)
      • Subject to application fee, maintenance fee, surrender fee.
    • Slurry being temporarily stored prior to digestion should be exempt .
    • But:-
    • If any controlled “wastes” are added to the intake material all the resultant digestate becomes waste and is subject to waste regulation.
    • Farm regulations.
  • 13. Farm Regulation- Cross-Compliance
      • Good Agricultural and Environmental conditions (GAEC 3) Waterlogged soil- e.g making a mess when spreading.
      • Nitrate Vulnerable Zones (70% England)
        • Lot of records to be kept starting April 2009 in existing NVZs
        • Organic Nitrogen limits
          • Farm 170kgsN/ha/year- animal origin
          • Field 250kgsN/ha/12months- all organic material spread
        • Storage Required-
          • 6 months for pig and poultry manure
          • 5 months for cattle and others
        • Closed spreading periods (>30% N availability)
        • Grass Tillage
        • Sandy/Shallow soil Others Sandy/Shallow soil Others
        • 1 st Sept- 31 st Dec 15 th Oct-15 th Jan 1 st Aug-31 st Dec 1 st Oct-15 th Jan
  • 14. NVZs (cont) Digestate Implications
      • Owen Yeatman
      • 8000 tonnes cow slurry
      • 1500 tonnes maize silage
      • 1500 tonnes grass silage.
    • Closed period enforced >30% available N
    • Storage 5 months using cow slurry (6 months if include pig slurry as substrate)- for all digestate.
  • 15. NVZs – Digestate (cont)
    • 3. N Farm Limit.
      • Own farm only- standard calculation (DEFRA leaflet 5)
      • Jointly operated digester- considered an import and supplier should notify you of total N content. Otherwise analyse (leaflet 3)
      • If 100% animal manure then use total N content
      • If mixed with other materials then supplier should advise you of animal proportion so you can calculate imported animal N.
  • 16. NVZs – Digestate (cont)
        • Can estimate on proportion of input
          • For Owen Yeatman 73% of 3.5kgsN =2.56kgs N
        • Can make more detailed calculation if relevant data available
          • Crops low in N could be that 85% of N is from animal source
        • Where no data available or for simplicity take 100% of sample result.
      • 4. Organic N field limit.
        • If digester serves your farm only use standard figures (leaflet 8)
        • Imported N advised by supplier or sample and analyse.
      • 5. Nmax
        • Calculate animal N as for farm limit.
        • Crop available portion use highest percentage applying to livestock manures in feedstock. Eg. Cattle 25% until 2012.
        • Ignore non-livestock N
  • 17. NVZs – Digestate (cont)
    • 6. Nitrogen Planning
        • Must take into account all of the nitrogen in the digestate that will be available to the crop.
        • Starting point potentially available N- 70%(+) of total N
        • Owen Yeatman 2.5kgsN potentially available.
        • Then estimate losses during storage and spreading.
  • 18. Other Issues
    • Pre-storage of slurry coming on to a farm for AD processing to be covered by Standard Permit.
    • DEFRA still to decide in case of Simple Exemptions.
    • Farmer can take his slurry/manure to another farm for AD processing.
    • If done by another farmer must register with EA as a waste carrier-
      • Currently free if farm waste.
    • Mesothilic AD will kill many pathogens and weed seeds but risk of transfer to other farms not regulated.
  • 19. Farm Regulation
    • For a relatively simple life – Manures and energy crops.
    • One estimate of the regulation covering biological treatment of controlled wastes. -7kgs documentation.
    • Detailed understanding of the regulation covering any planned operation is essential.
        • If in doubt take advice
    • Regulation is constantly changing- Anticipating change at the planning stage may save costs later.
    • This applies to England and Wales- Scotland differs.
  • 20. Controlled Waste Regulation
    • “ Waste” plants subject to Environmental Permitting.
      • Smaller plants subject to Standard Rules Permits.
        • Restrictions on Intake materials (Animal By-Products)
      • Larger plants subject to Bespoke Permits (e.g.Holsworthy)
        • Adopt Best Available Technique (BAT).
        • Emissions Controls.
        • Expensive compliance costs and relevant expertise required
  • 21. “ Duty of Care”
    • Code of Practice that places a Legal Requirement on all those holding controlled wastes to ensure that:
      • Wastes are safely cared for.
      • Written information is provided to ensure that anyone dealing with the waste can comply with their duties
      • Waste is only transferred to people authorised to receive it
      • Prevent waste causing pollution or harm whilst under your control or under subsequent control until recovered.
      • Those that supply you with waste want to be sure that you are acting compliantly.
  • 22. “ Wastes” of Animal Origin
    • Subject to Animal By-Products Regulation
    • AD plants can accept:
      • Low risk Category 3 material
      • Milk product
      • Animal Manures.
  • 23. “ Wastes” of Animal Origin (cont)
    • Plant must be ABP compliant.
      • All material pasteurised 70 o C for 1 hour
      • Chopped- particle size <12mm
      • Plant will need to meet design requirements
      • Subject to Hygiene Procedures. (cross-contamination)
      • Routine inspection by Animal Health Vets
      • Subject to audit trail from entry to plant to land spreading.
      • 21 day grazing ban following spreading.
      • Farmer records subject to Animal Health inspections.
  • 24. “ Waste” Digestate Storage- off site
    • Subject to Environmental Permitting
      • Planning may be an issue
      • EP Application + Fee
      • Annual EP maintenance fee
      • Working plan- to ensure facility correctly managed
    • Standard Rules Permit for Digestate Storage .
      • EA Consultation period ends August 28 th 2009
      • Expected to come into forceApril 2010
  • 25. “ Waste” Digestate Spreading
      • EA Controls over spreading waste to land
      • Para 7 Notifiable Exemptions.
          • Must demonstrate agricultural or environmental benefit.
            • For digestate generally to provide nutrients to meet crop demand.
          • Code of Good Agricultural Practice (COGAP)-Nitrogen limits
          • NVZ regulations
          • Submit considerable amount of information with application.
          • Each exemption is for up to 50ha and has to be renewed annually.
          • Fee must be paid- currently £575 for new application
          • Spreading records must be kept for 2 years.
      • To be replaced by Standard Rules for mobile plant for land spreadingPermit
        • Digestate likely to be covered from Oct 2011.
          • Anticipate it to be more onerous than Exemption.
  • 26. Certificate of Agricultural Benefit
    • Signed by FACTS qualified person.
    • Waste Analysis- nutrients and heavy metals
    • Standard Soil Analysis (every 4 years)
    • Crop nutrient demand (RB209)
      • Sets limits on nutrient amounts and timing.
        • Cereals no available nitrogen requirement in seed bed
      • Phosphate soil index 4+
        • No phosphate requirement for most crops
  • 27. Quality Protocol
    • Quality Assurance for digestate, approved by food chain
    • Procedures and Standard (PAS 110) whereby digestate would cease to be a “waste when it leaves the plant”.
    • Still awaiting final go ahead from Europe.
    • Some remaining issues over tests required.
    • Not an easy option.
      • Defaults to waste if not correctly used.
      • Standards and procedures subject to independent audit
      • Supervision of on farm records?
  • 28. Useful Links
    • NVZ guidance
    • http://www.defra.gov.uk/environment/water/quality/nitrate/help-for-farmers.htm
    • Standard Permits
    • http://www.environment-agency.gov.uk/research/library/consultations/36989.aspx
    • Duty of care
    • http://www.defra.gov.uk/environment/waste/legislation/duty.htm#code
  • 29. Useful Links (cont)
    • EA Para 7 Exemptions
    • http://www.environment-agency.gov.uk/business/topics/permitting/34782.aspx
    • Environmental Permitting
    • http://www.environment-agency.gov.uk/business/topics/permitting/32320.aspx
    • COGAP
    • http://www.defra.gov.uk/farm/environment/cogap/
    • Animal By-Products Regulation
    • http://www.defra.gov.uk/animalh/by-prods/wastefood/compindx.htm
    • QP/ PAS 110 .
    • http://www.biofertiliser.org.uk/certification/england-wales/quality-protocol
  • 30. Thank You