«OFFICE OF LICENSING & GUIDANCE INSPECTORS REPORT ON A LICENCE APPLICATION Directors To: Kevin Motherway From: - LICENSING UNIT 05/09/2007 Date: ...»
The model for combustion gases also modelled a worst-case scenario of the two boilers running as well as the thermal oxidiser on bypass (running on natural gas to maintain bed temperature). The maximum predicted levels of NOx, SOx and CO were all well below the relevant Air Quality Standards, with the highest predicted level expressed as percentage of a standard being 25%, for the predicted 1-hour maximum ground level concentration for NO2. The continued application of the air emission limit values will ensure compliance with all the relevant air standards.
Emissions to Sewer The licensee has, with the agreement of the Water Services Authority (WSA), decided to connect to a different sewer, as the integrity of the WSA sewer in use, up to July 2007, was in question. Emission point SE1 has therefore been Page 6 of 13 relocated on the site to connect to a newer WSA sewer. This sewer connects to the WSA WWTP at Carrigrennan before discharging to Cork Harbour. Apart from a separate connection for sanitary water arising on-site all emissions to sewer emanate from the on-site WWTP. The WWTP can handle 1,500 kg/day (as carbon) of solvent waste and remove 150 kg/day of Nitrogen from liquid wastes containing ammonia and amines. It is licensed to handle 250 m3/day, but generally handles only 110-120 m3/day.
The water treated at the WWTP is mostly from production area floor washing, reactor vessel washings, regeneration water from the de-ionised water plant and laboratory wastewater. Strong caustic, acidic and cyanide based liquid is treated in neutralisation tanks in PB1 and PB2 before being sent to the WWTP balancing tank. The neutralisation process is a manual operation with samples being confirmed as neutral by the on-site laboratory before the liquid is pumped from the neutralisation tank to the WWTP.
If the waste is unsuitable for the WWTP it is occasionally consigned off-site for incineration.
In terms of loading the emission limits specified by the WSA are unchanged from those specified in P0134-02 apart from the addition of a limit of 10 mg/l for VOCs and a limit of 1 mg/l for total heavy metals and the specification of respirometry in lieu of toxicity testing.
Emissions to Waters All process water is sent to WSA Sewer via the WWTP.
Surface Water All storm water arising on the site is sent to a WSA storm drain. Water from production areas and overflow from bunded storage areas is sent to a Process Area Storm Drain (PASD). The system consists of two 57 m3 tanks (one each from PB1 and PB2) with these overflowing to an 87 m3 holding tank and then to a 2,500 m3 firewater retention pond. Any rainwater falling within the PASD area is stored in the tanks and inspected daily and emptied as necessary to ensure sufficient storage capacity. Water stored in the PASD is visually inspected and tested for COD (which on-site studies have related to TOC on a 3:1 ratio). If the water is of acceptable standard it is released to the WSA storm water sewer. If the water is not of acceptable quality it can be either sent to the WWTP or tankered off-site if required. Two redundant 100 m3 oil tanks have been converted to provide additional overflow capacity at the WWTP, providing more back-up storage capacity. A firewater retention report submitted as part of the application demonstrates ample capacity in the system to cope with the storm water and fire flow demands of the installation.
Storm water from non-production areas such as car parks and roof water (with the exception of roof water from PB1 which goes to the PASD) is sent to the storm water sewer via a continuous TOC meter, with water being diverted in the event of TOC being above 33 mg/l or in the event of a fire on-site. Cooling water from 3 dryers onsite is also sent direct to the storm drain via the TOC meter. This cooling water comes from three dryers, which use water alone as coolant and so is low risk, unlike older water/glycol units which were used on-site in the past. The RD Page 7 of 13 requires the volume of this cooling water to be measured on a daily basis to allow it proportion of the storm water emissions to be determined. In the event of a fire, all surface water is automatically diverted to the PASDS storage. The receiving water for the WSA storm water sewer is Lough Mahon.
Emissions to ground Apart from a soakaway for stormwater emanating from a construction road in the region of the Firewater Retention pond, there are no emissions to ground. An onsite septic tank has been decommissioned, with foul water now sent to the WSA sewer. There is historical groundwater contamination (predominantly THF and MTBE) issue on-site, with the cause identified being up gradient sources located off-site. OEE is dealing with the issue and is satisfied with the cooperation of the licensee.
• Hazardous waste generated on-site is handled by an appropriate contractor with OEE kept fully informed of arrangements for same.
• Any liquid wastes on-site not suitable for treatment in the WWTP are sent offsite for disposal by an appropriately licensed contractor.
• No Class 11.1 activities are carried out on site.
Noise The site is located in an industrially zoned area, with several industrial noise sources (some of which are IPPC licensed), as well as traffic noises, with previous studies showing noise at the site boundaries to be elevated. The previous licensing inspector’s report highlighted that the installation had exceeded noise limits due to two noise sources and that a work programme was in place to improve matters. This work programme has been carried out and noise emissions from the installation are compliant and no complaints regarding noise have been received. Noise levels in the area of the installation appear to be dominated by noise sources outside the installation boundary.
Use of Resources
In 2005 the consumption of resources are reported as:
Fuel 7,846,632 kWH (Natural Gas) Electricity 5,086,679 kWH Water 46,844 m3 The installation uses a variety of solvents with the principal ones being: Ethyl Acetate, Isopropanol, Tetrahydrofuran, Toluene and Acetone.
Compliance with EU Directives IPPC Directive (91/61/EC) This installation falls within the scope of category 4.5 (Installations using a chemical or biological process for the production of basic pharmaceutical process) of Annex Ι of Council Directive 96/61/EC concerning integrated pollution prevention and control.
Page 8 of 13 The Proposed Determination (PD) as drafted takes account of the requirements of the Directive. BAT is taken to be represented by the guidance given in the EIPPCB reference documents, and BAT and BATNEEC Guidance notes for the Pharmaceutical and Chemical Sectors.
Large Combustion Plant Directive (2001/80/EC) The Large Combustion plant directive does not apply.
Solvents Directive (1999/13/EC) The licensee states that the installation does not fall within the remit of the Solvents Directive.
European Communities (Control of Major Accident Hazards involving Dangerous Substances) Regulations, 2006 (S.I. 74 of 2006) The licensee states that the installation does not fall within the remit of the Seveso Directive, as the installation is no longer using or storing Sodium Cyanide. The National Authority for Occupational Safety and Health (NAOSH) is the competent authority responsible for administration and enforcement of these regulations.
Air Quality Directive (1999/30/EC) The installation complies with the Air quality Directive (1999/30/EC).
Habitats Directive (92/43/EC) & Birds Directive (79/409/EEC) The site is located on Little Island in an area zoned as an industrial estate. The operation of the activity in accordance with the RD will not impact on any designated area, the closest being Lough Mahon (Special Area of Conservation (SAC) – Great Island Channel – Site Code 001058 and Special Protection Area (SPA) - Cork Harbour SPA -Site Code: 004030) Best Available Techniques (BAT) A comprehensive BAT assessment carried out the licensee show the installation to have a high level of compliance with BAT. However several aspects of PB1
when compared to PB2 would not be considered BAT. These include:
• A less efficient heating/cooling system
• The reactor design
• The reactor solids charging system
• The process control system
• The subsurface effluent drainage system for weak effluent However due to the age and restrictive design of PB1, the application of the above techniques are not practically or economically feasible i.e. “Available”. I am satisfied that none of the above is causing significant environmental impact. The licensee has indicated that the inefficiencies of running PB1 means that the medium to long-term plan is to replace the manufacturing capacity with a more modern installation which would be fully compliant with BAT.
The installation’s method of local bunding is undersized and the licensee has submitted a firewater retention report, which outlines the ample storage capacity for any firewater, contaminated water or spillage by use of the PASD. This “remote bunding” system complies with the usual licence condition, which specifies, “All tank and drum storage areas shall, as a minimum, be bunded, either locally or remotely”. The OEE inspector has also indicated that they are satisfied the system is sufficient.
The licensee has achieved and is regularly audited for ISO14001 and has implemented several programmes of improvements across the installation to continuously improve their environmental performance.
I have examined and assessed the application documentation and I am satisfied that the site, technologies and techniques specified in the application and as confirmed, modified or specified in the attached Recommended Decision comply with the requirements and principles of BAT. I consider the technologies and techniques as described in the application, in this report, and in the RD, to be the most effective in achieving a high general level of protection of the environment
Environmental Impact Statement The application was not accompanied by an EIS.
Fit & Proper Person Assessment The licensee has a long history of compliant operation, with no prosecution by the Agency recorded or pending. Although they have undergone a recent change of ownership, they have provided financial information regarding their level of assets and environmental liability and they would qualify as a fit and proper person to continue to operate an IPPC licensed installation. It is my view, and having regard to the provisions of Section 84(5) of the EPA Acts and the Conditions of the RD, that the licensee can be deemed a Fit & Proper Person for the purpose of this review.
The OEE inspector for the installation has indicated that the site has a high level of compliance, with the licensee being open and communicative about any issues on-site and being proactive in solving problems.
Complaints There are six complaints on file relating to five dates between July and November in 2006 regarding odours from the WWTP. The WWTP aeration basin was drained and washed out and no other complaints regarding the WWTP have been received since. Apart from these there are no other complaints on record for the installation.
Submissions Apart from a response to a Section 99(E) notice from the Water Services Authority, no submissions were received.
Recommended Determination (RD) The RD permits the licensee permission to continue to operate the installation in accordance with the conditions set out.
Recommendation I recommend that a Proposed Determination be issued subject to the conditions/refused and for the reasons as drafted in the RD.
Signed Kevin Motherway Procedural Note In the event that no objections are received to the Proposed Determination of the application, a licence will be granted in accordance with Section 87(4) of the Environmental Protection Agency Acts 1992 and 2003 as soon as may be after the expiration of the appropriate period.