Consolidation and review of environmental permit for Chirk 'Kronospan' Particleboard factory
Kronospan Ltd have been operating a particleboard and medium density fibreboard (MDF) manufacturing plant in Chirk, North Wales for many years. The activities involved in manufacturing the boards have required several environmental permits to control the levels of harmful emissions resulting from the activities and to ensure that the techniques used are in line with technical advances and industry standards. These standards are known as ‘Best Available Techniques’ (BAT).
The activities at the Installation that are regulated by the Environmental Permitting Regulations 2016 (EPR) have been the subject of various Directions from Government. Most notably, the first Direction was in 2003 which split that regulation between Wrexham County Borough Council (WCBC) and the Environment Agency Wales (now subsumed into Natural Resources Wales (NRW)).
In March 2018 Welsh Government issued a further Direction (the ‘2018 Direction’) which requires Natural Resources Wales (NRW) to consolidate the existing permits for the Installation into one and then subsequently conduct all regulatory functions in relation to that permit.
This will essentially ‘normalise’ the regulation of the Installation in that all relevant activities will be regulated by a single environmental regulator, NRW. From that time WCBC will no longer regulate activities at the Installation and the site will no longer be subject to a Ministerial direction.
NRW is currently in the process of consolidating the two regulator’s permits and conducting a full review of the conditions to ensure compliance with EPR, the Industrial Emissions Directive (IED) and BAT.
The variation application also includes an assessment of predicted releases from plant and process changes resulting from investment in the site by Kronospan Ltd since October 2014 when the current version of the WCBC permit was issued.
Kronospan’s application also originally contained a proposal for a new oriented strand board (OSB) production line which will now be considered at a later date and does not form part the current determination.
For the reasons detailed in the “Progress on the Permit Determination” section below, NRW are prioritising and progressing with the consolidation (and BAT review) of the current WCBC and NRW permits separately to the OSB determination, whilst recognising there is some overlap in the considerations.
The regulatory regimes highlighted in this statement are not the only considerations taken into account in NRW’s permit determination process and these will be appropriately addressed in the decision document accompanying the consolidation, updates and changes to the permit.
The current permits
There are two current environmental permits for the activities at the Installation. The main activity permit is a WCBC permit. The second permit is NRW for some additional activities.
Wrexham Permit WCBC/IPPC/03/KR(V3) covers the following activities: Particleboard and medium density fibre board production, two biomass plants, sawmill and laminated flooring line, as well as some heat generating plant. Raw material deliveries and storage and waste handling, processing and storage are directly associated activities in the permit.
The current NRW permit (EPR/BW9999IG) covers the following activities: Manufacture of formaldehyde by catalytic oxidation of methanol, manufacture of urea-formaldehyde and melamine-urea-formaldehyde resin and the operation of natural gas fired combustion plant. The VITS paper impregnation process and operation of surface water lagoons 1, 2, and 3 are directly associated activities in the permit.
Both permits are available for download on request from firstname.lastname@example.org
The full application made by Kronospan Ltd is available for download on request from email@example.com
We have already undertaken public consultation on the received application (September 2018). We are also committed to undertaking a further public consultation when we have reached a draft decision on the consolidated permit.
We are anticipating that a draft decision for the consolidated permit will be ready for public consultation in summer 2021.
Our Public Participation Statement can be viewed on our website.
Progress on the permit determination
Since receiving Kronospan’s application in 2018 and commencing our detailed determination, we have requested a significant amount of further information from Kronospan Ltd. This includes detailed information about their company structure, activities, operating procedures, emissions and emission points to help with our assessments and ensure that they will comply with BAT. More requests for detailed information have arisen as we gain a better understanding of the current and proposed activities at the Installation. Questions raised during our initial public consultation on the application (September 2018) have also been valuable in formulating these requests for further information.
We have a duty to ensure that we undertake a complete and thorough assessment of activities at the plant before completing our determination, to ensure that a legally robust decision is made, prior NRW taking on overall environmental regulation of the site.
Several issues remain unresolved in relation to Kronospan’s application for a new OSB production line, the most significant being the noise assessment. NRW consider that the background data is currently not representative, so we cannot determine the magnitude of the predicted noise impact associated with the proposed OSB development. Kronospan Ltd have been unable to collect representative data during 2020; due to adverse weather conditions in February and early March, following which the Covid-19 restrictions then commenced. Any survey conducted during this time would be considered unrepresentative of normal site conditions.
We are unable to complete our assessment of Kronospan’s OSB application without this information, so we have decided to prioritise and progress with the consolidation of the WCBC and NRW permits separately to the determination for the proposed OSB activities.
The benefits of this revised approach are two-fold. First, it means that NRW will take over regulation of the entire site, conducting all regulatory functions in relation to the permit in a shorter time. Second, it means that we can complete our statutory review of current site activities against the published BAT for Production of Wood-based Panels, ensuring the permit incorporates the latest European best practice and associated emission limits for the Medium Density Fibreboard (MDF) and Particleboard production processes.
We continue to have a good working relationship with WCBC during this regulatory handover period and are engaging with Kronospan Ltd on the unresolved issues. We remain committed to consulting with the public on our draft decision for the consolidated permit and anticipate this will be in summer 2021.
At present, it is not possible to give a definitive date for a draft decision on the OSB application, because although the technical assessment is continuing, it is being impacted by the Covid-19 situation. However, if we decide to grant the OSB application, we will consult with the public on our draft decision once we have reached this stage.