Table 4.7.2(II) BREF Document on Best Available Techniques on Emissions from Storage, July 2006

Transcription

1 Table 4.7.2(II) BREF Document on Best Available Techniques on Emissions from Storage, July 2006 With respect to the Conclusions on BAT for this horizontal BREF, the details of applicability and status as regards the existing facility (BioCork 1) and the proposed expansion (BioCork 2) are outlined in the following examples: EPA BAT Tanks General principles to prevent and reduce emissions BAT for a proper design is to take into account at least the following: the physico-chemical properties of the substance being stored how the storage is operated, what level of instrumentation is needed, how many operators are required, and what their workload will be how the operators are informed of deviations from normal process conditions (alarms) how the storage is protected against deviations from normal process conditions (safety instructions, interlock systems, pressure relief devices, leak detection and containment, etc.) what equipment has to be installed, largely taking account of past experiences of the product (construction materials, valve quality, etc.) which maintenance and inspection plan needs to be implemented and how to ease the maintenance and inspection work (access, layout, etc.) how to deal with emergency situations (distances to other tanks, facilities and to the boundary, fire protection, access for emergency services such as the fire brigade, etc.). All storage facilities for the existing site are specified to be compatible with the material stored within. All process vessels are fitted with the required level alarms and switches in order to prevent overfills and unnecessary emissions. All process parameters are controlled by the PAS (Process Automation System). Staff are trained and follow SOPs. The process has undergone HAZOPs to ensure that the necessary controls are in place in the case of deviations from the operating norms. The facility has been designed in order to allow for ease of and safe access for maintenance. An Emergency Response Team Plan (DS-SOP-5424) is in place for the existing facility. Similarly for BioCork 2, the same proper design principles outlined above are followed. HAZOPs, risk assessments and 3D Model reviews are ongoing to ensure the necessary storage design safeguards will be in place. Process parameters in the expansion will similarly be controlled by the PAS. Any new staff will be trained in the necessary SOPs. The Emergency Response Team Plan (DS-SOP-5424) will similarly apply to the expansion. Will be- BioCork2 (commenced during detailed design in 2017 and will be in place for commencement of production activity in Q4, 2021) 1

2 BAT is to apply a tool to determine proactive maintenance plans and to develop risk-based inspection plans such as the risk and reliability based maintenance approach BAT is to locate a tank operating at, or close to, atmospheric pressure aboveground. However, for storing flammable liquids on a site with restricted space, underground tanks can also be considered. A maintenance schedule is maintained on site for all process and service equipment. The automation system allows for monitoring of parameters to ensure that all equipment is working as planned. The process has undergone Process Hazard Analysis, e.g. HAZOP, to ensure that the necessary controls are in place in the case of deviations from the operating norms. The facility has been designed in order to allow for ease of and safe access for maintenance. Maintenance and inspection plans will be developed for storage facilities in the new facility. Techniques such as HAZOP and 3D model reviews will inform the development of such plans The majority of existing storage tanks are located over ground. Tanks include firewater and non-potable water tanks, brine tank, waste water treatment tanks and the diesel fuel tank. The only storage vessel underground is the biowaste collection vessel due to gravity drainage requirements. This collection vessel is however contained within a sump which has a high level switch alarm. Given these projective measures for the biowaste collection sump it is regarded that the intent of the BAT statement is met. For the BioCork 2 expansion all process vessels, WWTP expansion vessels will be located above ground. The biowaste and process waste collection vessels are the only storage vessels underground due again to gravity drainage requirements. These vessels will be located within a sump containing a high level switch alarm. 2

3 Preventing incidents and (major) accidents BAT is to implement and follow adequate organisational measures and to enable training and instruction of employees for safe and responsible operation of the installation BAT is to prevent corrosion by: selecting construction material that is resistant to the product stored applying proper construction methods preventing rainwater or groundwater entering the tank and if necessary, removing water that has accumulated in the tank applying rainwater management to bund drainage applying preventive maintenance, and where applicable, adding corrosion inhibitors, or applying cathodic protection on the inside of the tank. The existing site is governed by Johnson & Johnson Worldwide Environmental, Health, Safety & Sustainability Standards. This standard establishes minimum management and operating standards to ensure the projection of employees, community and the environment. All staff are qualified and appropriately trained. Training records are maintained onsite on all relevant SOPs e.g. Emergency Response Team Plan (DS-SOP-5424), Spill Response & Management Procedure (DS-SOP- 4054). The BioCork 2 expansion will follow the same standards and SOPs. Any new staff employed will also receive any necessary training and instruction in SOPs, as appropriate. Materials of construction are compatible with the materials that are used in the process (refer also to BAT 1). Under Condition 6.9 of the site s IE Licence bunds and containment structures are integrity tested every 3 years. Rainwater management within bunds is employed. The above provisions will similarly apply to the BioCork 2 expansion. 3

4 BAT is to implement and maintain operational procedures e.g. by means of a management system as described in , to ensure that: high level or high pressure instrumentation with alarm settings and/or auto closing of valves is installed proper operating instructions are applied to prevent overfill during a tank filling operation, and sufficient ullage is available to receive a batch filling BAT for aboveground tanks containing flammable liquids or liquids that pose a risk for significant soil pollution or a significant pollution of adjacent watercourses is to provide secondary containment, such as: tank bunds around single wall tanks; see double wall tanks; see cup-tanks; see double wall tanks with monitored bottom discharge; see The facility and the process are governed by SOPs, the PAS which control all process parameters. As per condition 3.9 of the site s existing IE Licence, sumps and tanks from which spillage of environmentally significant materials might occur in such quantities as to breach containment are fitted with high liquid level alarms (or oil detectors as appropriate). The above operational procedures will similarly apply to BioCork 2 expansion Tanks containing flammable material are designed in accordance with the requirements of the EPA Guidance Note on Storage and Transfer of Materials for Scheduled activities. This ensures that tank design provides adequate environmental protection. The largest flammable liquid storage tank onsite is the diesel tank supplying the emergency diesel generators located in the Utility Yard. It contains the following safeguards: A high level indicator is present The vessel is double skinned vessel Drip trays are present for the flanges of external pipework Storm water drains from the tanker loading area are directed to a petrol interceptor before going onwards to the site s retention pond. The inlet to the retention pond is monitored for high TOC and will close the outlet from the pond in the event of the high TOC alarm being activated. For BioCork 2, all storage vessels will comply with the requirements of the EPA Guidance Note on Storage and Transfer of Materials for Scheduled activities. Process hazard analysis assessments e.g. HAZOPs, and/or environmental risk assessment where appropriate, will identify the necessary safeguards to mitigate against significant soil or water pollution. 4

5 For toxic, carcinogenic or other hazardous substances, BAT is to apply full containment. All hazardous material on site is stored in dedicated hazardous material store areas. As per Condition of the site s IE Licence bunding capacities comply with the requirement for a minimum of 110% of the volume of the largest container to be stored or a minimum of 25% of the total volume of liquids stored. Because the current manufacturing process at the Janssen Sciences site is primarily a water-based activity, the inventory of chemical material potentially stored on site is (and remains) relatively small and does not exceed any of the recognised guideline thresholds for firewater retention. Furthermore, storage of all potentially polluting materials on the site is within bunded or other double contained systems. Notwithstanding this conclusion, a 3,600m 3 capacity Firewater Retention Pond was installed on the site as a safeguard measure, and to mitigate even the lowest risk of potentially polluted run-off being released to the environment. And as with current site policy and practice, all future materials associated with the BioCork 2 expansion with potentially polluting properties will be stored in bunded or double contained systems. In addition, the new surface water run-off drainage system serving the areas of the new expansion where materials are to be stored, will be linked into the existing network that drains to the existing Storm Water/ Fire Water Retention Pond. As such, all parts of the site, both existing and proposed, with potential for contaminated run-off to arise in an emergency situation such as a fire, will be afforded the protection of the existing 3,600m 3 capacity Firewater Retention Pond. 5

6 Storage of packaged dangerous substances BAT is to appoint a person or persons who is or are responsible for the operation of the store BAT is to provide the responsible person(s) with specific training and retraining in emergency procedures as described in and to inform other staff on the site of the risks of storing packaged dangerous substances and the precautions necessary to safely store substances that have different hazards BAT is to apply a storage building and/or an outdoor storage area covered with a roof Training with regard to handling and storage of hazardous material is provided to all relevant personnel on site. Appropriate staff is employed to run the warehouse at the facility. If additional warehouse staff is required for BioCork 2, they will also receive any necessary training and instruction in SOPs, as appropriate. The SOP Emergency Response Team Plan (DS- SOP-5424) outlines the steps that are to be taken in the event of an emergency onsite and also lists potential emergency situations which may arise. Relevant site personnel are trained in this SOP and other related SOPs such as the Chemical Awareness and Management Procedure (DS-SOP-6056). Existing site SOPs will similarly apply to the BioCork2 expansion and will require updating to account for new areas such as the Warehouse extension and associated Hazardous Material Store room. See also BAT 39. Raw materials and products are primarily stored in the warehouse onsite. Use is also made of dedicated chemical storage units in the WWTP area and the yard area of the Warehouse. As part of BioCork 2, the existing warehouse is being expanding to cater for the increased raw material inventory. 6

7 BAT is to apply a suitable protection level of fire prevention and fire-fighting measures as described in The appropriate protection level has to be decided on a case- by case basis in agreement with the local fire brigade BAT is to prevent ignition at source as described in The existing facility has fire protection measures in accordance with FM Global, the site s insurer. Similarly the BioCork 2 fire protection measures will be designed to be in guidance with FM Global requirements. All existing and proposed buildings except the administration building are and will be protected by wet automatic sprinkler systems. A Fire Safety Certificate application has been made to the local fire authority to certify that the BioCork 2 works will be constructed in accordance with the plans and specifications submitted including all firefighting facilities are in compliance with the requirements of Part B [Fire] of the Second Schedule to the Building Regulations The nearest local authority fire brigade is in Carrigaline, approximately 5 minutes from the site. The site is not a COMAH site; there are no major hazards with regard to fire and explosion. The site s Explosion Protection Document outlines the measures in place to prevent, control and minimise the occurrence of an explosion, e.g. permit to work system which lists the precautions to take in an ATEX hazardous area. As part of the BioCork 2 project, ATEX reviews have been completed, which identified areas where the prevention of ignition sources is a requirement under the ATEX Directive. The measures outlined in the site s EPD will similarly apply to the expansion. 7

8 Considerations on transfer and handling techniques BAT for valves include: correct selection of the packing material and construction for the process application with monitoring, focus on those valves most at risk (such as rising stem control valves in continual operation) applying rotating control valves or variable speed pumps instead of rising stem control valves where toxic, carcinogenic or other hazardous substances are involved, fit diaphragm, bellows, or double walled valves route relief valves back into the transfer or storage system or to a vapour treatment system The design, installation and operation of the pump or compressor heavily influence the life potential and reliability of the sealing system. The following are some of the main factors which constitute BAT: proper fixing of the pump or compressor unit to its baseplate or frame having connecting pipe forces within producers recommendations proper design of suction pipework to minimise hydraulic imbalance alignment of shaft and casing within producers recommendations alignment of driver/pump or compressor coupling within producers recommendations when fitted correct level of balance of rotating parts effective priming of pumps and compressors prior to startup operation of the pump and compressor within producers recommended performance range (The optimum performance is achieved at its best Piping specifications have been developed for the site that outlines the appropriate valve to use for each particular application. These piping specifications will similarly apply to the new pipework installations associated with BioCork 2. All valves for the expansion will be installed by qualified contractors and the associated systems into which they will be installed will be tested and commissioned before being put into operation. All pumps are fit for purpose and have been considered in the relevant process HAZOP. All pumps have installed by a qualified contractor and have been commissioned and tested. All pumps are on a preventive maintenance schedule and have feedback to the DCS in order to detect any problems in the process. Similarly for BioCork 2, pumps will be fit for purpose and their operation and criticality assessed in Process Hazards Analysis techniques. All pumps will be installed by a qualified contractor and will also be commissioned and tested before being put into operation. All pumps will be on a preventive maintenance schedule and will have feedback to the automation system. 8

9 efficiency point.) the level of net positive suction head available should always be in excess of the pump or compressor regular monitoring and maintenance of both rotating equipment and seal systems, combined with a repair or replacement programme BAT is to use the correct selection of pump and seal types for the process application, preferably pumps that are technologically designed to be tight such as canned motor pumps, magnetically coupled pumps, pumps with multiple mechanical seals and a quench or buffer system, pumps with multiple mechanical seals and seals dry to the atmosphere, diaphragm pumps or bellow pumps Storage of solids Open Storage BAT is to apply enclosed storage by using, for example, silos, bunkers, hoppers and containers, to eliminate the influence of wind and to prevent the formation of dust by wind as far as possible by primary measures. See Table 4.12 for these primary measures with cross-references to the relevant sections. Pumps for the existing facility have been selected to meet process requirements. They are on a preventative maintenance schedule which reduces the loss of leak tightness. The same approach will apply to pumps in the BioCork 2 expansion. All storage at the facility is enclosed, e.g. containers, tanks etc. Similarly, storage associated with BioCork 2 will be enclosed General approaches to minimise dust from transfer and handling BAT is to adjust the speed of vehicles on-site to avoid or minimise dust being swirled up The current vehicle speed limit onsite of 20km/hr minimises the creation of excess dust. This speed limit will similarly apply to new areas and roads associated with BioCork 2. 9

10 BAT for roads that are used by trucks and cars only, is applying hard surfaces to the roads of, for example, concrete or asphalt, because these can be cleaned easily to avoid dust being swirled up by vehicles Road access for cars and delivery trucks is via hard standing surfaces. The approach also applies to BioCork 2. 10