SR2023 No1: Capture, Treat and Store Biogas from Lagoons and Tanks

At the end of 2023, the Environment Agency consulted on a new standard rule set for operators involved in capturing, treating, and storing biogas from lagoons or tanks and upgrading it to biomethane. The proposed changes would allow operators to collect, store, and upgrade biogas to biomethane, fuel vehicles at the site, and inject biomethane into the grid under a new standard rule (SR2023). You can read the original consultation here and a summary of consultation responses here. 

While we are still waiting for the Government to publish their response to the consultation, on the 2nd of October 2024 the EA published SR2023 No1 — a new standard rules permit to capture, treat and store biogas from lagoons and tanks. The publication includes standard rules and an associated risk assessment. 

The permit allows operators to capture, treat and store biogas from lagoons and tanks providing they can meet the associated rules. SR2023 No1 includes various requirements for management, operations, location, waste acceptance, operating techniques, emissions and monitoring, and record keeping. We’ve summarised the main requirements below, but if you are interested in applying for this permit, please read the guidance in detail. 

At the time of writing, you cannot apply for this permit online. We will update this briefing as more information is released. If you have questions about the permit or application process, please contact us.

Management: Operators must develop a written management system that minimises pollution risks and maintain records to demonstrate compliance. All personnel must be appropriately trained and have access to the permit requirements. 

Operations: Operators must follow manufacturer recommendations for all plant and equipment use and only engage in activities listed on the permit, such as: 

• collecting biogas from lagoons or tanks storing manure, slurry, or digestate;
• storing up to 10 tonnes of combined biogas and biomethane;
• treating and upgrading biogas to biomethane;
• injecting biomethane into the national grid or using it as vehicle fuel on-site;
• and flaring excess biogas or biomethane in an emergency, or to protect life and equipment, or during maintenance.

The permit does not allow the combustion of biogas or biomethane in spark engines for heat and power generation, and there are no permitted discharges to surface water.

Location: Activities must be confined to the permitted site and cannot occur near sensitive areas like nature reserves, groundwater zones, or watercourses.

Waste Acceptance Criteria: The site can accept a maximum of 50,000 tonnes of waste per year and no more than 8,000 cubic metres at any time. Operators can only accept biodegradable waste, like manure, plant waste, or dairy byproducts. See Table 2.3 for allowed waste codes.

Operating Techniques: Before starting any activities, operators must submit a critical infrastructure validation report, a detailed plan for commissioning, a Hazard and Operability Study (HAZOP) or similar risk analysis, and a maintenance plan based on HAZOP findings. The rules also outline 16 techniques for waste management and storage, infrastructure, maintenance, containment, safety, contingency plans, and monitoring and leak prevention. Operators must incorporate all of the relevant techniques to comply with the permit.

Emissions and Monitoring: Operators must implement emissions monitoring and management plans to prevent pollution and ensure no harmful emissions to air, water, or land. This includes implementing a leak detection and repair (LDAR) program, continuous monitoring of meteorological conditions, gas volume, quality, and pressure (recorded in a SCADA system), lagoon and tank integrity, and maintaining comprehensive monitoring records. Any odour, noise, or pest issues must be addressed promptly in line with approved management plans. Additionally, operators must have a fire prevention strategy to minimise risks.

Record Keeping: Operators must maintain clear, legible records of all required information, including emissions, fuel usage, and non-compliance events, for at least six years. Records should be easily accessible in both electronic and hard copy formats. Quarterly reports on on-site activities and waste management must be submitted to the EA, along with annual reports on abatement system efficiency and monitoring results. Operators must immediately notify the EA of incidents that significantly affect the environment or breach the permit conditions and follow up with written confirmation within 24 hours. Additionally, operators must inform the EA about any changes in the operation, including new equipment or changes in company structure.

Charges: The new standard rules permit application fee is £3,926. There is a £1,178 fee for minor variations to the permit, £2,529 for transfer, and £2,356 for surrender. There is also a £2,875 annual subsistence charge.