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 potentially 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 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.
Following a variation application by Kronospan Ltd, NRW is currently in the process of consolidating the two regulators’ permits and conducting a full review of the conditions to ensure compliance with EPR, the Industrial Emissions Directive (IED) and BAT.
The consolidation 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 variation application also 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 of the current consolidation.
The regulatory regimes highlighted in this statement are not the only considerations taken into account in NRW’s permit determination process. Other legal considerations by NRW will be appropriately addressed in the decision document accompanying the consolidated and updated permit.
The current permits
The current 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.
The NRW permit is available for download on request from email@example.com
The full application made by Kronospan Ltd is available for download on request from firstname.lastname@example.org
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 Spring 2022.
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 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.
Whilst most elements of our determination and assessment have now been concluded, there are still several steps that need to occur in the permitting process, which we will address over the forthcoming months. We recently requested the operator submit a fully consolidated air dispersion modelling report so that we can audit predicted releases from the whole site, including from plant and process investments at the site since October 2014. Our audit of this consolidated modelling information is complete and has concluded that it is robust. This is a milestone in the permitting process and means we have a baseline for all emissions to air from the whole site (currently regulated by WCBC and NRW). This now allows us to continue with a full human health and ecological assessment of releases to air from the site.
We have a duty to ensure that we undertake a complete and thorough assessment of all current 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. We also continue to have a good working relationship with WCBC during this regulatory handover period.
Last updated: 19 November