TECHNICAL REPORT. For inspection purposes only. FOR. Vitra Tiles (Ireland) Ltd IDA Business Park Ballynattin Arklow

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1 The Tecpro Building, Clonshaugh Business and Technology Park, Dublin 17 Tel: +353 (0) Fax: +353 (0) TECHNICAL REPORT DETERMINATION OF EMISSIONS TO ATMOSPHERE FROM THE VITRA TILES FACILITY, ARKLOW, CO. WICKLOW (UPDATED STUDY FOR FURTHER INFORMATION REQUEST - JULY 2007) FOR Vitra Tiles (Ireland) Ltd IDA Business Park Ballynattin Arklow Report prepared by: Eoin Collins B.Sc. Ph.D. MRSC Our reference: Date: 20 July info@awnconsulting.com Website: Registered in Ireland. No Registered Office: Evergreen House, Congress Road, Cork Directors: Fergal Callaghan, Chris Dilworth, Terry Donnelly, Edward Porter Associate Director: Damian Kelly

2 EXECUTIVE SUMMARY Air dispersion modelling of emissions from the Vitra Tiles (Ireland) facility, Ballynattin, Arklow, Co. Wicklow was carried out using the United States Environmental Protection Agency s regulatory model AERMOD. The purpose of this modelling study was to determine whether the emissions from the site will lead to ambient concentrations which are within the relevant ambient air quality standards for the nitrogen dioxide (NO 2 ), sulphur dioxide (SO 2 ), PM 10 and PM 2.5 a, hydrogen chloride (HCl), hydrogen fluoride (HF) and volatile organic compounds (VOCs). This report describes the outcome of this study. components: The study consists of the following Review of emission data and other relevant information needed for the modelling study; Summary of background NO 2, SO 2, PM 10, PM 2.5, VOC, HCl and HF levels; Dispersion modelling of released substances under typical operating conditions; Presentation of predicted ground level concentrations of released substances; Evaluation of the significance of these predicted concentrations, including consideration of whether these ground level concentrations are likely to exceed the relevant ambient air quality limit values. A comparison of typical stack emissions from Vitra Tiles with the corresponding BAT limit shows that in general emissions from Vitra Tiles are below the BAT limits. However dust emissions from the kiln firing process (A2-1 to A2-4) exceed their BAT limit and HF emissions from A2-1 exceed the BAT limit. An air dispersion modelling study of emissions at the BAT limits (where these represent a reduction relative to typical emissions) has also been carried out. Emission data for the following emission points was not available and therefore was not included in the dispersion modelling study: A2-7 Kiln Entrance Dryer, A3-1 Shrink Wrap Machine and A3-2 Decoration Dryer. Assessment Summary Emissions Under Typical Operation Ambient pollutant levels of NO 2 (including background) resulting from typical operating conditions comply with the relevant limit values, with levels reaching at most 19% of the 1- hour limit value (measured as a 99.8 th %ile) and 38% of the annual limit value at the worstcase receptor. Ambient ground level concentrations of SO 2 (including background) comply with the relevant limit values under typical operating conditions. Predicted SO 2 concentrations reach at most 6% of the 1-hour limit value (measured as a 99.7 th %ile) and 10% of the 24-hour limit value (measured as a 99.2 nd %ile) at the worst-case receptor. With regard to PM 10, ambient ground level concentrations (including background) exceed the 24-hour limit value and are below the annual limit value under typical operating conditions. Emissions from the Vitra Tiles facility lead to an ambient PM 10 concentration (including background) which is 133% of the ambient 24-hour limit value (measured as a 90.4 th %ile) and 78% of the annual limit value at the worst-case receptor. a PM 10 and PM 2.5 refer to particulate matter with a size <10 µm and <2.5 µm respectively. Page 2

3 Emissions from the Vitra Tiles facility lead to an ambient PM 2.5 concentration (including background) which reaches 100% of the proposed annual concentration cap at the worstcase receptor under typical operation. For the purposes of this study, the pessimistic assumption was made that all VOC emissions from the Vitra Tiles facility were camphor (a TA Luft Class I VOC). Under typical operation, ambient VOC ground level concentrations comply with both the long-term and short-term Environmental Assessment Levels (EALs) for camphor, reaching at most 29% of the longterm EAL and 33% of the short-term EAL at the worst-case receptor. With regard to HCl, the results indicate that the ambient ground level concentrations are below the short-term EAL and above the long-term EAL for HCl under typical operating conditions. Emissions from the Vitra Tiles facility lead to an ambient HCl concentration (including background) which is 73% of the short -term EAL and 155% of the long-term EAL value at the worst-case receptor. The results for HF show that ambient ground level concentrations exceed the TA Luft annual limit value for HF under typical operating conditions. Emissions from the Vitra Tiles facility lead to an ambient HF concentration (including background) which is 293% of the limit value at the worst-case receptor. Thus, the modelling results show that mitigation measures are required in order to reduce the air quality impact of the Vitra Tiles facility and to fully comply with the relevant air quality standards. Emissions at BAT Limits With regard to PM 10, results indicate that the predicted ambient ground level concentrations of PM 10 are below both the 24-hour and annual limit values when emissions from A2-1 to A2-4 are reduced to the BAT emission limit. Emissions from the Vitra Tiles facility lead to an ambient PM 10 concentration (including background) which is 63% of the ambient 24-hour limit value (measured as a 90.4 th %ile) and 51% of the annual limit value at the worst-case receptor. With regard to PM 2.5, results indicate that the predicted ambient ground level concentrations are below the annual concentration cap for PM 2.5 when emissions from A2-1 to A2-4 are reduced to the BAT emission limit. Emissions from the Vitra Tiles facility lead to an ambient PM 2.5 concentration (including background) which is 58% of the proposed annual concentration cap at the worst-case receptor. With regard to HF, results indicate that the predicted ambient ground level concentrations exceed the TA Luft annual limit value for HF when emissions from A2-1 are reduced to the BAT emission limit. Emissions from the Vitra Tiles facility lead to an ambient HF concentration (including background) which is 193% of the limit value at the worst-case receptor. Report Prepared By: Report Checked By: DR EOIN COLLINS Senior Environmental Consultant DR EDWARD PORTER Director, Air Quality Page 3

4 CONTENTS Page Executive Summary Introduction Assessment Methodology Air Quality Standards Baseline Air Quality Assessment Baseline Air Quality Monitoring Sampling Methodology Baseline Monitoring Results Background Concentrations - Review of Existing Data Procedure for Addition of Background Concentrations Air Dispersion Modelling Methodology Description of the Air Dispersion Model Meteorological Data Typical Process Emissions BAT Techniques and Emission Limits Results & Discussion Process Contributions Concentration Contours Assessment Summary Mitigation Measures - Stack Height Increase 25 Appendix I Description of the AERMOD Model 37 Appendix II Meteorological Data - AERMET PRO 39 Appendix III Sensitivity Assessment - Selection of Met Year 41 Page 4

5 1.0 INTRODUCTION Air dispersion modelling of emissions from the Vitra Tiles (Ireland) facility, Ballynattin, Arklow, Co. Wicklow was carried out using the United States Environmental Protection Agency s regulatory model AERMOD. The purpose of this modelling study was to determine whether the emissions from the site will lead to ambient concentrations which are within the relevant ambient air quality standards for the nitrogen dioxide (NO 2 ), sulphur dioxide (SO 2 ), PM 10 and PM 2.5 b, hydrogen chloride (HCl), hydrogen fluoride (HF) and volatile organic compounds (VOCs). This report describes the outcome of this study. The study consists of the following components: Review of emission data and other relevant information needed for the modelling study; Summary of background NO 2, SO 2, PM 10, PM 2.5, HCl and HF levels; Dispersion modelling of released substances under typical operating conditions; Dispersion modelling of released substances at BAT emission limits; Presentation of predicted ground level concentrations of released substances; Evaluation of the significance of these predicted concentrations, including consideration of whether these ground level concentrations are likely to exceed the relevant ambient air quality limit values. The assessment methodology and study inputs are presented in Section 2. The dispersion modelling results and assessment summaries are presented in Section 3. The model formulation is detailed in Appendix I, a review of the meteorological data used is detailed in Appendix II. The results of a sensitivity assessment of the MM5 meteorological data is detailed in Appendix III. 2.0 ASSESSMENT METHODOLOGY Emissions from the proposed facility have been modelled using the AERMOD dispersion model which has been recently developed by the U.S. Environmental Protection Agency (USEPA) (1). The model is a steady-state Gaussian plume model used to assess pollutant concentrations associated with industrial sources and is a USEPA regulatory model for modelling emissions from industrial sources in both flat and rolling terrain (2-4). The model has more advanced algorithms and gives better agreement with monitoring data in extensive validation studies (5-9). An overview of the AERMOD dispersion model is outlined in Appendix I. The air dispersion modelling input data consisted of information on the physical environment (including building dimensions and terrain features), design details from all emission points on-site and a full year of appropriate meteorological data. Using this input data the model predicted ambient ground level concentrations beyond the site boundary for each hour of the modelled meteorological year. The model postprocessed the data to identify the location and maximum of the worst-case ground level concentration. This worst-case concentration predicted by the AERMOD dispersion model was added to the background concentration to give the predicted environmental concentration (PEC) for the pollutant. The PEC was then compared with the relevant ambient air quality standard to assess the significance of the releases from the site. b PM 10 and PM 2.5 refer to particulate matter with a size <10 µm and <2.5 µm respectively. Page 5

6 3.0 AMBIENT AIR QUALITY STANDARDS In order to reduce the risk to health from poor air quality, national and European statutory bodies have set limit values in ambient air for a range of air pollutants. These limit values or Air Quality Standards are health- or environmental-based levels for which additional factors may be considered. The ambient air quality standards for NO 2, SO 2 and PM 10 are outlined in S.I. 271 of 2002, which is based on EU Council Directive 1999/30/EC (see Table 1). With regard to PM 2.5, proposed Directive COM(2005) 447 has set a concentration cap of 25 µg/m 3 as an annual average to be attained by 2010 (see Table 1). MSDS sheets provided by Vitra Tiles detail the potentially hazardous chemical compounds which are in use at the facility. The individual VOCs which may be emitted from the facility were determined from the MSDS sheets and compared to those detailed in the German TA Luft guidelines (10). It should be noted that the full set of MSDS sheet is not currently available. Based on the MSDS sheet data currently available, camphor is the only Class I VOC which is used at the facility. In order to carry out a worst-case assessment of VOC emissions from Vitra Tiles, it has thus been assumed that all VOCs emitted from the facility are camphor. No statutory air quality standards for camphor exist in Irish legislation. In the absence of statutory standards, it is common practice to derive an ambient air quality guideline from occupational exposure limits (OEL) for the pollutant. The UK Environment Agency (11) provides a methodology for calculation of both long-term (annual) and short-term (1- hour) Environmental Assessment Levels (EALs) for individual chemical species based on their OELs. The Health and Safety Authority have set 8-hour and 15- minute OELs for camphor in Ireland (12). The calculated EALs for camphor are detailed in Table 2. No statutory air quality standards for hydrogen chloride (HCl) exist in Irish legislation. The UK Environment Agency (11) provides both long-term (annual) and short-term (1- hour) Environmental Assessment Levels (EALs) for HCl. These are detailed in Table 2. The TA Luft guidelines set an annual average limit value for HF of 0.3 µg/m 3(10) (see Table 2). These standards have been used in the current assessment to determine the potential impact of NO 2, SO 2, PM 10, PM 2.5, VOC, HCl and HF emissions from the proposed facility on air quality. Page 6

7 Pollutant Regulation Limit Type Margin of Tolerance Value Nitrogen Oxides Sulphur dioxide Particulate Matter Stage 1 Particulate Matter Stage 2 Note 2 S.I. 271 of 2002 S.I. 271 of 2002 S.I. 271 of 2002 S.I. 271 of 2002 Hourly limit for protection of human health - not to be exceeded more than 18 times/year Annual limit for protection of human health 50% until 2001 reducing linearly to 0% by % until 2001 reducing linearly to 0% by µg/m 3 NO 2 40 µg/m 3 NO 2 Annual limit for protection of None 30 µg/m 3 NO + vegetation NO 2 Hourly limit for protection of human health - not to be exceeded more than 24 times/year Daily limit for protection of human health - not to be exceeded more than 3 times/year Annual & Winter limit for the protection of ecosystems 24-hour limit for protection of human health - not to be exceeded more than 35 times/year Annual limit for protection of human health 24-hour limit for protection of human health - not to be exceeded more than 7 times/year 90 µg/m 3 until 2003, reducing linearly to 0 µg/m 3 by µg/m 3 None 125 µg/m 3 None 20 µg/m 3 30% until 2003 reducing linearly to 0% by % until 2003 reducing linearly to 0% by 2005 Not to be exceeded more than 28 times until 2006, 21 times until 2007, 14 times until 2008, 7 times until 2009 and zero times by % from 2005 reducing linearly to 0% by 2010 None. Limit value applicable in µg/m 3 PM µg/m 3 PM µg/m 3 PM 10 Annual limit for protection of 20 µg/m 3 PM 10 human health PM 2.5 COM (2005) Annual concentration cap 25 µg/m 3 PM designed to limit unduly high risks to the population An annual average limit for NO X (sum of NO and NO 2) is applicable for the protection of vegetation in highly rural areas away from major sources of NO X such as large conurbations, factories and high road vehicle activity such as a dual carriageway or motorway. Annex VI of EU Directive 1999/30/EC identifies that monitoring to demonstrate compliance with the NO X limit for the protection of vegetation should be carried out distances greater than 5 km from the nearest motorway or dual carriageway, 5 km from the nearest major industrial installation or 20 km from a major urban conurbation. As a guideline, a monitoring station should be indicative of approximately 1000 km 2 of surrounding area. This limit value is not applicable in the region of the Vitra Tiles facility due to the close proximity of the N25 dual carriageway and the facility itself. Note 2 EU 1999/30/EC states Indicative limit values to be reviewed in the light of further information on health and environmental effects, technical feasibility and experience in the application of Stage 1 limit values in the Member States. Proposed EU Directive COM (2005) 447 will replace the indicative limit values for PM 10 for the year 2010 by a legally binding cap for the annual average concentrations of PM 2.5 of 25 µg/m 3 to be attained by Table 1 EU Ambient Air Standard - S.I. 271 of 2002 and COM(2005) 447 Page 7

8 Pollutant Regulation Limit Type Value VOC EAL EAL Long-term (annual) environmental assessment level Short-term (1-hour) environmental assessment level HF TA Luft Annual limit value for the protection of health HCl EAL Note 2 EAL Note 2 Long-term (annual) environmental assessment level Short-term (1-hour) environmental assessment level EAL derived from OELs for camphor (TA Luft Class I VOC). Note 2 EAL derived by the UK Environment Agency (11). Table 2 Air Quality Standards for VOCs, HF and HCl 120 µg/m µg/m µg/m 3 20 µg/m µg/m BASELINE AIR QUALITY ASSESSMENT 4.1 Baseline Air Quality Monitoring A detailed baseline air monitoring program was carried out at the site of the Vitra facility over the period November - December 2005 and March 2006 to assess baseline levels of NO 2, SO 2, PM 10 and PM Sampling Methodology NO 2 The spatial variation in NO 2 levels away from sources is particularly important, as a complex relationship exists between NO, NO 2 and O 3 leading to a non-linear variation of NO 2 concentrations with distance. In order to assess the spatial variation in NO 2 levels in the region around Vitra Tiles, NO 2 was monitored using passive diffusion tubes over a one-month period at locations M1 - M4 (see Figure 1). Passive sampling of NO 2 involves the molecular diffusion of NO 2 molecules through a polycarbonate tube and their subsequent adsorption onto a stainless steel disc coated with triethanolamine. Following sampling, the tubes were analysed using UV spectrophotometry, at a UKAS accredited laboratory (Bureau Veritas). The passive diffusion tube results allow an indicative comparison with the annual average limit value. SO 2 In order to assess the spatial variation in SO 2 levels in the area, SO 2 was monitored using passive diffusion tubes over a one month period at locations M1-M4 (see Figure 1). Passive sampling of SO 2 involves the molecular diffusion of SO 2 molecules through a tube fabricated of PTFE and their subsequent adsorption onto a stainless steel gauze coated with sodium carbonate. Following sampling, the adsorbed sulphate was removed from the tubes with deionised water and was then analysed using ion chromatography. This analysis was carried out at a UKAS accredited laboratory. The passive diffusion tube results allow an indicative comparison with the annual average limit value. Page 8

9 PM 10 / PM 2.5 The PM 10 / PM 2.5 monitoring program focused on assessing 24-hour average concentrations over a 12-day period at an on-site location (M5, see Figure 1). Sampling was carried out by means of a Turnkey Instruments Osiris Environmental Dust Monitor. The Osiris instrument is a light scattering device capable of continuous measurement of PM 10 and PM 2.5. The air sample was continuously drawn into the instrument by a pump through a heated inlet at a flow rate of 600 ml/min. The incoming air passed through a laser beam in a photometer. The light scattered by the individual particles of dust was measured by the photometer and this information used to measure the size and concentration of the dust particles. The results allow an indicative comparison with both the 24-hour and annual limit values. 4.3 Baseline Monitoring Results NO 2 The monitoring results are detailed in Table 3. Average concentrations of NO 2 at are significantly below the EU annual limit value of 40 µg/m 3. The monitoring locations were chosen in order to indicate the average NO 2 levels close to the Vitra Tiles facility and also show the spatial distribution of NO 2 in the region. The highest measured NO 2 level of 14 µg/m 3, reaches only 35% of this annual limit value. The spatial variation in NO 2 levels between the four locations is low, indicating only a minor influence from the N11 dual carriageway at the IDA Business Park. Background concentrations range from 8-10 µg/m 3. Location NO 2 Concentration (µg/m 3 ) 06/11/05-06/12/05 Location M1- East Boundary of Site 11 Location M2 - IDA Business Park (South of Site) 14 Location M3 - Ballyrooaun (North of Site) 8 Location M4 - Ballintombay (Northwest of Site) 10 Limit Value 40 EU Council Directive 1999/30/EC (as an annual average). Table 3 Average NO 2 concentrations at or near the site boundary of the Vitra Tiles facility, as measured by passive diffusion tubes. SO 2 The SO 2 diffusion tube monitoring results are detailed in Table 4. The monitoring locations were chosen in order to indicate the average SO 2 levels close to the Vitra Tiles facility and also show the spatial distribution of SO 2 in the region. The results show that SO 2 levels in the area range from µg/m 3. The levels are typical of a rural area, with worst-case levels reaching 14% of the EU annual limit value for the protection of ecosystems of 20 µg/m 3. Page 9

10 Location SO 2 Concentration (µg/m 3 ) 06/11/05-06/12/05 Location M1- East Boundary of Site 1.5 Location M2 - IDA Business Park (South of Site) 0.67 Location M3 - Ballyrooaun (North of Site) 2.0 Location M4 - Ballintombay (Northwest of Site) 2.7 Limit Value 20 EU Council Directive 1999/30/EC (as an annual average - for the protection of ecosystems). Table 4 Average SO 2 concentrations at or near the site boundary of the Vitra Tiles facility, as measured by passive diffusion tubes. PM 10 / PM 2.5 Daily average PM 10 concentrations at location M5 ranged from µg/m 3 (see Table 5). There were no exceedences of the 24-hour National and EU limit value of 50 µg/m 3. The 24-hour limit value is expressed as a 90.4 th %ile, which means 35 exceedences are permitted per year. The average PM 10 concentration over the 12- day monitoring period was 14 µg/m 3. This level is well below the National and EU annual limit value of 40 µg/m 3. Daily average PM 2.5 concentrations at location M5 ranged from µg/m 3 (see Table 5). The average PM 2.5 concentration over the 12-day monitoring period was 5.2 µg/m 3. This is significantly lower than the annual concentration cap of 25 µg/m 3 proposed for Sampling Date PM 10 Conc. (µg/m 3 ) PM 2.5 Conc. (µg/m 3 ) 03/03/ /03/ /03/ /03/ /03/ /03/ /03/ /03/ /03/ /03/ /03/ /03/ Average No. Days >50 µg/m 3 0 Note 2 Note 3 Table 5 Limit Value 50, 40 Note 2 25 Note 3 EU Council Directive 1999/30/EC (24-hour average limit value as a 90.4th%ile). EU Council Directive 1999/30/EC (annual average limit value). Proposed Directive COM(2005) 447 on Ambient Air Quality and Cleaner Air for Europe - annual concentration cap Measured PM 10 & PM 2.5 ambient concentrations measured at the site boundary of the Vitra Tiles facility. Page 10

11 4.4 Background Concentrations - Review of Existing Data Estimates of the appropriate background concentrations in the region of the facility are based on the baseline air quality monitoring carried out in the region of the Vitra Tiles site. The region of Vitra Tiles is categorised as Zone D (Rural) with regard to air quality management and assessment (as defined in S.I. 271 of 2002). Available long-term monitoring data carried out by the EPA (13) at similar locations has also been used to determine background concentrations. Furthermore, the results of a long-term monitoring campaign at Poolbeg in Dublin has been used for some pollutants (see below). Appropriate background values are outlined in Table 6. NO 2 In terms of NO 2, the on-site survey indicated a background level of approximately 8-10 µg/m 3 (see Table 3). Long-term NO 2 monitoring is carried out at the two rural Zone D locations, Glashaboy and Kilkitt (13). The NO 2 annual average in 2005 for both sites was 9 and 2 µg/m 3, respectively. The results of NO 2 monitoring carried out at the urban Zone D locations in Mountrath in 2005 indicated an average NO 2 concentration of 12 µg/m 3(13), with no exceedences of the 1-hour limit value. Furthermore, average NO 2 concentrations measured at Wexford, Carlow and Kilkenny in 2005 (Zone C locations) ranged from 9-18 µg/m 3 respectively (13). Hence long-term average concentrations measured at these locations were significantly lower than the annual average limit value of 40 µg/m 3. Based on the above information, a conservative estimate of the background NO 2 concentration in the region of the Vitra Tiles facility in 2007 is 12 µg/m 3. SO 2 In terms of SO 2, the on-site survey indicated a background level of approximately 1-3 µg/m 3 (see Table 4). EPA monitoring was carried out using a continuous monitor in 2005 at two rural Zone D locations; Kilkitt and Shannon Estuary and also at the urban Zone D location in Mountrath (13). The annual average at these locations ranged from 3-4 µg/m 3. Based on the above information, a conservative estimate of the background SO 2 concentration in the region of the Vitra Tiles facility in 2007 is 5 µg/m 3. PM 10 / PM 2.5 The on-site PM 10 survey gave an average PM 10 concentration of 14 µg/m 3 over a 12- day period (see Table 5). Although this provides useful additional information on PM 10 levels in the region of the site, long-term EPA monitoring data gives a better indication of long-term average background concentrations. PM 10 measurements were carried out by the EPA at Mountrath, Drogheda and Castlebar in 2005, giving average levels of µg/m 3(13). Based on the above information, a conservative estimate of the background PM 10 concentration in the region of the Vitra Tiles facility in 2007 of 15 µg/m 3 has been used. Long-term PM 10 and PM 2.5 monitoring in Cork City Centre in 2005 gave annual average levels of 19 and 11 µg/m 3 respectively. The corresponding PM 10 /PM 2.5 ratio of 0.6 has been used to generate a background PM 2.5 concentration in the region of the Vitra Tiles facility in 2007 of 9 µg/m 3. Page 11

12 HCl With regard to hydrogen chloride (HCl), no monitoring is carried out by the EPA or Local Authorities. However, a long-term monitoring program for HCl was carried out by AWN Consulting for Dublin City Council as part of the Dublin Waste to Energy project. The data, which was published in the EIS for the proposed development, shows an average HCl concentration at Sean Moore Road measured over 16 weeks from August 2003 to August 2005 of 0.18 µg/m 3. Based on the above information, a conservative estimate of the background HCl concentration in the region of the Vitra Tiles facility in 2007 is 0.2 µg/m 3. HF With regard to hydrogen chloride (HCl), no monitoring is carried out by the EPA or Local Authorities. However, data from the Dublin Waste to Energy project shows an average HF concentration at Sean Moore Road measured over 16 weeks from August 2003 to August 2005 of 0.01 µg/m 3. Based on the above information, a conservative estimate of the background HCl concentration in the region of the Vitra Tiles facility in 2007 is 0.02 µg/m 3. VOCs For the purposes of this study and to represent a worst-case assessment, all VOC emissions were assumed to be the TA Luft Class I VOC camphor (see Section 3.0). The EPA carries out monitoring for a individual VOCs which are involved in tropospheric ozone formation, no data is available for camphor. However, background levels of camphor in the region are expected to be negligible. Pollutant Baseline Monitoring (µg/m 3 ) Background Concentration (µg/m 3 ) Nitrogen Dioxide (NO 2) Sulphur Dioxide (SO 2) PM PM Hydrogen Chloride (HCl) 0.2 Hydrogen Fluoride (HF) 0.02 VOC (as camphor) - 12-day average concentration. Table 6 Estimated Annual Background Concentrations in the Vicinity of the Vitra Tiles Facility (µg/m 3 ). 4.5 Procedure for Addition of Background Concentrations In order to obtain the predicted environmental concentration (PEC) of the Vitra Tiles emissions, background concentrations were added to the process immissions (immission is defined as the level of a pollutant beyond the site boundary at ground level). In relation to the annual averages, the ambient background concentration was added directly to the predicted immission concentration. However, in relation to the short-term peak ground level concentrations, concentrations due to emissions from elevated sources cannot be combined in the same way. Guidance from the UK Environment Agency (11) advises that an estimate of the maximum combined pollutant Page 12

13 concentration can be obtained by adding the maximum short-term concentration due to emissions from the source to twice the annual mean background concentration. 5.0 AIR DISPERSION MODELLING METHODOLOGY 5.1 Description of Air Dispersion Model Throughout this study a worst-case approach was taken. This will most likely lead to an over-estimation of the levels that will arise in practice. The worst-case assumptions are outlined below: Maximum predicted concentrations were reported in this study, even if no residential receptors were near the location of this maximum; Worst-case background concentrations were used to assess the baseline levels of substances released from the site; The effects of building downwash, due to on-site and any nearby off-site buildings, has been included in the model. The United States Environmental Protection Agency (USEPA) approved AERMOD dispersion model has been used to predict the ground level concentrations (GLC) of compounds emitted from the principal emission sources on-site. The modelling incorporated the following features: Two receptor grids were created at which concentrations would be modelled. Receptors were mapped with sufficient resolution to ensure all localised hotspots were identified without adding unduly to processing time. The receptor grids were based on Cartesian grids with the site at the centre. An outer grid extended to 5 km from the site with concentrations calculated at 500 m intervals. An inner grid extended to 2 km from the site with concentrations calculated at 100 m intervals. Boundary receptor locations were also placed along the boundary of the site, at 50 m intervals. In addition, the locations of nearby residential receptors were directly input into the model, giving a total of 2137 calculation points for each model case. All on-site buildings and significant process structures were mapped into the computer to create a three dimensional visualisation of the site and its emission points. Buildings and process structures can influence the passage of airflow over the emission stacks and draw plumes down towards the ground (termed building downwash). The stacks themselves can influence airflow in the same way as buildings by causing low pressure regions behind them (termed stack tip downwash). Both building and stack tip downwash were incorporated into the modelling. The year representing the worst-case MM5 mesoscale meteorological data (14) for the five year period from was selected for use in the model (worst-case year 2002). AERMOD incorporates a meteorological pre-processor AERMET PRO (15). The AERMET PRO meteorological preprocessor requires the input of surface characteristics, including surface roughness (z 0 ), Bowen Ratio and albedo by sector and season, as well as hourly observations of wind speed, wind direction, cloud cover, and temperature. The values of albedo, Bowen Ratio and surface roughness depend on land-use type (e.g., urban, cultivated land Page 13

14 etc) and vary with seasons and wind direction. The assessment of appropriate land-use type was carried out to a distance of 3km from the source location in line with USEPA recommendations (16). The source and emission data, including stack dimensions, gas volumes and emission temperatures have been incorporated into the model. Detailed terrain has been mapped into the model. The site is located on rolling terrain with some changes in terrain in the immediate environs of the site. All terrain features have been mapped in detail into the model out to a radius of 10 km with the site at the centre using the terrain pre-processor AERMAP. 5.2 Meteorological Data The weather conditions identified for the Vitra Tiles site were obtained using the MM5 mesoscale meteorological model (14) over the period This hourlysequenced data was converted to AERMOD-ready data by Lakes Environmental and used in the dispersion modelling assessment. The selection of the appropriate meteorological data has followed the guidance issued by the USEPA (2). A primary requirement is that the data used should have a data capture of greater than 90% for all parameters. As the MM5 meteorological data is generated from a meteorological model, the full hourly data set for each year is available, thus meeting the USEPA criteria. The MM5 mesoscale meteorological model (14) provides data on the prevailing wind conditions for the Ballynattin region (see Figure 2 for the wind profile over the period ). The data for 2002 indicates that the prevailing wind direction is from south to westerly in direction with an annual incidence of around 40%. The mean wind speed is approximately 7.7 m/s over the period The incidence of calm conditions is <1% with strong winds (>9 m/s) occurring for about 27% of the time. 5.3 Typical Process Emissions Process emissions data used for the typical emissions scenario in the air dispersion model are shown in Table 7 with further details of the input parameters used in the air dispersion model given in Table 8. Emission data for A2-1 to A2-4 and A2-6 were obtained from the results of emissions monitoring carried out by REC Ltd in January/February Emissions data for A2-5 were obtained from the REC Ltd monitoring results and manufacturer s data supplied by Vitra Tiles. Measured emission data for A2-8 was not available. However, data from Vitra Tiles shows that on average kg of dust is collected daily by Dust Extraction Unit 1, which is a bag filter system. Assuming a typical collection efficiency of a bag filter of 99%, the mass emission from stack A2-8 is kg/day or g/s. Manufacturer data on stack temperature and volume flow supplied by Vitra Tiles allowed the stack emission concentration to be calculated (see Table 8). Dust Extraction Unit 2 is smaller than Extraction Unit 1 and thus emissions are less significant. However, detailed information on emissions from A2-9 is not available. To allow for a worst-case impact assessment, it was thus assumed that emissions from Dust Extraction Unit 2 were equivalent to those from Extraction Unit 1. Page 14

15 Emission data for the following emission points was not available and therefore was not included in the dispersion modelling study: A2-7 Kiln Entrance Dryer, A3-1 Shrink Wrap Machine, and A3-2 Decoration Dryer. Height Above Stack Reference Stack Location Ground Level (m) Exit Diameter (m) A2-1 Kiln 1 Inlet E N A2-2 Kiln1 Exit E N A2-3 Kiln 2 Inlet E N A2-4 Kiln 2 Exit E N A2-5 Tile Dryer E N A2-6 Spray Dryer E N A2-8 Dust Extraction 1 E N A2-9 Dust Extraction 2 E N OS coordinates of stack location to nearest 5 metres. Table 7 Stack Release Points Used In The Air Dispersion Model Page 15

16 Stack Reference Exit Diameter (m) Cross- Sectional Area (m 2 ) Temperature (K) Volume Flow (Nm 3 /hr) Exit Velocity (m/sec actual) Concentration (mg/nm 3 ) Mass Emission (g/s) A2-1 Kiln 1 Inlet A2-2 Kiln 1 Exit PM10 / PM NOx - 39; SO2-10 VOC - 322; HCl HF PM10 / PM NOx - 45; SO2-1 VOC - 53; HCl - 11 HF PM10 / PM NOx ; SO VOC ; HCl HF PM10 / PM NOx ; SO VOC ; HCl HF A2-3 Kiln 2 Inlet A2-4 Kiln 2 Exit PM10 / PM NOx - 18; SO2-1 VOC - 129; HCl - 36 HF PM10 / PM NOx - 25; SO2-1 VOC - 178; HCl - 31 HF PM10 / PM NOx ; SO VOC ; HCl HF PM10 / PM NOx ; SO VOC ; HCl HF A2-5 Tile Dryer Note PM10 / PM2.5-1 PM10 / PM A2-6 Spray Dryer PM10 / PM2.5-7 PM10 / PM A2-8 Dust Extraction 1 Note PM10 / PM2.5-9 Note 4 PM10 / PM A2-9 Dust Extraction 2 Note PM10 / PM2.5-9 Note 4 PM10 / PM Data sources: Vitra Tiles - stack height & diameter; REC Ltd - stack temperature, volume flow, emission concentration. Note 2 Data sources: Vitra Tiles - stack height & diameter; REC Ltd - emission concentration; Manufacturer - Temperature, volume flow. Note 3 Data sources: Vitra Tiles - stack height & diameter, mass emission (derived - see section 5.3); Manufacturer - Temperature, volume flow. Note 4 Emission concentration calculated based on mass emission and volume flow. Note 5 Emissions from Dust Extraction Unit 2 assumed to be equivalent to those from Extraction Unit 1. Table 8 Vitra Tiles Facility, Ballynattin, Co. Wicklow. Stack Emission Details - Typical Operation. Page 16

17 5.4 BAT Techniques and Emissions Limits The European Commission BREF document on the ceramic manufacturing industry (17) details the Best Available Techniques (BAT) for reduction of air emissions from a range of processes involved in the manufacture of wall and floor tiles. In addition it provides limit values for stack emission concentrations resulting from these individual processes. Table 9 details the BAT limit values and techniques relevant to the Vitra Tiles facility and comparison with the current emission concentrations at the facility. Pollutant Manufacturing Process BAT Emission Reduction Technique BAT Limit (mg/nm 3 ) Dust Kiln Firing process Clean dry flue gas with bag filter 5 Channelled dust from dusty Apply bag filter 10 operations Drying processes Chanelled dust from spray drying processes Avoid accumulation of dust residues in dryer. Adopt adequate maintenance protocols. Apply bag filter 1-30 NO x Kiln firing process Reduce input of NOx precursors. 250 SO x VOC Chloride (as HCl) Fluoride (as HF) Kiln firing process Kiln firing process Kiln firing process Kiln firing process Reduce input of SOx precursors. Heating curve optimisation. Apply cascade type bed adsorber or dry flue gas cleaning with filter. Reduce input of VOC precursors. Heating curve optimisation. Apply cascade type bed adsorber or dry flue gas cleaning with filter. Reduce input of HCl precursors. Heating curve optimisation. Apply cascade type bed adsorber or dry flue gas cleaning with filter. Reduce input of HF precursors. Heating curve optimisation. Apply dry flue gas cleaning with bag filter. Operations other than drying, spray drying or firing. Note 2 Applies to sulphur content in raw material of 0.25%. Note 3 The range depends on the content of the pollutant (precursor) in the raw material. Table 9 Best Available Techniques and Emission Limits for Wall and Floor Tile Manufacturing 20 <500 Note Note Note 3 A comparison of typical stack emissions from Vitra Tiles with the corresponding BAT limit is shown in Table 10. The data shows that in general emissions from Vitra Tiles are below the BAT limits. However dust emissions from the kiln firing process (A2-1 to A2-4) exceed their BAT limit and HF emissions from A2-1 exceed the BAT limit. These are highlighted in Table 10. An air dispersion modelling study of emissions at the BAT limits (where these represent a reduction relative to typical emissions) has also been carried out. Thus the BAT emission limits for dust from stacks A2-1 to A2-4 and at the BAT emission limit for HF from A2-1 have been applied. Stack emission details relevant to this study that differ from typical operation (see Table 8) are given in Table 11. Page 17

18 Stack Reference Pollutant Emission Conc. (mg/nm 3 ) BAT Limit Vitra Tiles A2-1 Kiln 1 Inlet A2-2 Kiln1 Exit A2-3 Kiln 2 Inlet A2-4 Kiln 2 Exit Dust NO x SO x < HCl HF Dust 5 13 NO x SO x <500 1 HCl HF Dust 5 78 NO x SO x <500 1 HCl HF Dust 5 75 NO x SO x <500 1 HCl HF A2-5 Tile Dryer Dust 20 1 A2-6 Spray Dryer Dust A2-8 Dust Extraction 1 Dust 10 9 A2-9 Dust Extraction 2 Dust 10 9 Note 2 Vitra Tiles emissions under typical operation (see Tables 7-8). Note 2 Dust Extraction Unit 2 emissions assumed to be equivalent to Extraction Unit 1 (see section 5.3). Table 10 Comparison of BAT Emissions Limits and Typical Vitra Tiles Emissions Page 18

19 Stack Reference Exit Diameter (m) Cross- Sectional Area (m 2 ) Temperature (K) Volume Flow (Nm 3 /hr) Exit Velocity (m/sec actual) Concentration (mg/nm 3 ) Mass Emission (g/s) A2-1 Kiln 1 Inlet PM10 / PM HF PM10 / PM HF A2-2 Kiln 1 Exit PM10 / PM PM10 / PM A2-3 Kiln 2 Inlet PM10 / PM PM10 / PM A2-4 Kiln 2 Exit PM10 / PM PM10 / PM Data sources: Vitra Tiles - stack height & diameter; REC Ltd - stack temperature, volume flow, emission concentration. Table 11 Vitra Tiles Facility, Ballynattin, Co. Wicklow. Stack Emission Details at BAT Emissions Limits. Page 19

20 6.0 RESULTS & DISCUSSION 6.1 Process Contributions Ambient Ground Level Concentrations (GLCs) of NO 2, SO 2, PM 10, PM 2.5, VOCs, HCl and HF have been predicted with the Vitra Tiles facility in operation under typical operating conditions and at the applicable BAT emission limits (as detailed in section 5.4). Emission data for the following emission points was not available and therefore was not included in the dispersion modelling study: A2-7 Kiln Entrance Dryer, A3-1 Shrink Wrap Machine and A3-2 Decoration Dryer. NO X Emissions The NO X modelling results are detailed in Table 12. The results indicate that the ambient ground level concentrations are below the relevant air quality standards for nitrogen dioxide under typical operating conditions. Emissions from the Vitra Tiles facility lead to an ambient NO 2 concentration (including background) which is 19% of the maximum ambient 1-hour limit value (measured as a 99.8 th %ile) and 38% of the annual limit value at the worst-case receptor. Pollutant / Scenario NO 2 / Typical Note 2 Note 3 Background (µg/m 3 ) 12 Averaging Period Vitra Tiles Contribution (µg/m 3 ) Predicted Immission Concentration (µg/nm 3 ) Standard (µg/nm 3 ) Annual Mean Note th %ile of 1-hr means Note S.I. No. 271 of 2002 & Council Directive 1999/30/EC Conversion factor following guidance from USEPA (Tier 2 analysis, annual average) based on the default ratio of 0.75 (worst-case). Conversion factor, following guidance from USEPA (Tier 3 analysis), based on an empirically derived maximum 1-hour value for NO 2 / NO X of Table 12 Dispersion Model Results NO 2 SO 2 Emissions The SO 2 modelling results are detailed in Table 13. The results indicate that the ambient ground level concentrations are below the relevant air quality standards for SO 2 under typical operating conditions. Emissions from the Vitra Tiles facility lead to an ambient SO 2 concentration (including background) which is 6% of the maximum ambient 1-hour limit value (measured as a 99.7 th %ile) and 10% of the 24-hour limit value (measured as a 99.2 nd %ile) at the worst-case receptor. Page 20

21 Pollutant / Scenario SO 2 / Typical Background (µg/m 3 ) 5 Averaging Period 99.7 th %ile of 1-hr means 99.2 nd %ile of 24- hr means S.I. No. 271 of 2002 & Council Directive 1999/30/EC Table 13 Dispersion Model Results SO 2 Vitra Tiles Contribution (µg/m 3 ) Predicted Immission Concentration (µg/nm 3 ) Standard (µg/nm 3 ) Pollutant / Scenario PM 10 / Typical PM 10 Emissions The PM 10 modelling results are detailed in Table 14. The results indicate that the ambient ground level concentrations of PM 10 exceed the 24-hour limit value and are below the annual limit value under typical operating conditions. Emissions from the Vitra Tiles facility lead to an ambient PM 10 concentration (including background) which is 133% of the ambient 24-hour limit value (measured as a 90.4 th %ile) and 78% of the annual limit value at the worst-case receptor. Results for the BAT limits modelling scenario indicate that the predicted ambient ground level concentrations of PM 10 are below both the 24-hour and annual limit values when emissions from A2-1 to A2-4 are reduced to the BAT emission limit. Emissions from the Vitra Tiles facility lead to an ambient PM 10 concentration (including background) which is 63% of the ambient 24-hour limit value (measured as a 90.4 th %ile) and 51% of the annual limit value at the worst-case receptor. Background (µg/m 3 ) 15 Averaging Period 90.4 th %ile of 24-hr means Vitra Tiles Contribution (µg/m 3 ) Predicted Immission Concentration (µg/nm 3 ) Standard (µg/nm 3 ) Annual Mean PM 10 / BAT Limits th %ile of 24-hr means Annual Mean S.I. No. 271 of 2002 & Council Directive 1999/30/EC Table 14 Dispersion Model Results PM 10 PM 2.5 Emissions The PM 2.5 modelling results are detailed in Table 15. The results indicate that the ambient ground level concentrations reach the relevant air quality standard for PM 2.5 under typical operating conditions. Emissions from the Vitra Tiles facility lead to an ambient PM 2.5 concentration (including background) which is 100% of the proposed annual concentration cap at the worst-case receptor. Page 21

22 Results for the BAT limits modelling scenario indicate that the predicted ambient ground level concentrations are below the annual concentration cap for PM 2.5 when emissions from A2-1 to A2-4 are reduced to the BAT emission limit. Emissions from the Vitra Tiles facility lead to an ambient PM 2.5 concentration (including background) which is 58% of the proposed annual concentration cap at the worst-case receptor. Pollutant / Scenario PM 2.5 / Typical PM 2.5 / BAT Limits Background (µg/m 3 ) 9 9 Averaging Period Annual Concentration Cap Annual Concentration Cap S.I. No. 271 of 2002 & Council Directive 1999/30/EC Table 15 Dispersion Model Results PM 2.5 Vitra Tiles Contribution (µg/m 3 ) Predicted Immission Concentration (µg/nm 3 ) Standard (µg/nm 3 ) VOC Emissions The VOC modelling results are detailed in Table 16. For the purposes of this study and to represent a worst-case assessment, all VOC emissions were assumed to be were camphor, which is a TA Luft Class I VOC (see Section 3.0). The results indicate that the ambient ground level concentrations are below the relevant air quality standards for camphor under typical operating conditions. Emissions from the Vitra Tiles facility lead to an ambient VOC concentration which is 29% of the longterm EAL and 33% of the short-term EAL at the worst-case receptor. Pollutant / Scenario VOC / Typical Averaging Period Predicted Immission Concentration (µg/nm 3 ) Standard (µg/nm 3 Notes 1,2 ) Annual Mean Maximum 1-hour For the purposes of this assessment, all VOC emissions were assumed to be the TA Luft Class I VOC Camphor (see Section 3.0). Note 2 EALs derived from 8-hour and 15-min OELs for Camphor Table 16 Dispersion Model Results VOCs (as Camphor) HCl Emissions The HCl modelling results are detailed in Table 17. The results indicate that the ambient ground level concentrations are below the short-term EAL and above the long-term EAL for HCl under typical operating conditions. Emissions from the Vitra Tiles facility lead to an ambient HCl concentration (including background) which is 73% of the short -term EAL and 155% of the long-term EAL value at the worst-case receptor. Page 22

23 Pollutant / Scenario Background (µg/m 3 ) Averaging Period Vitra Tiles Contribution (µg/m 3 ) Predicted Immission Concentration (µg/nm 3 ) Standard (µg/nm 3 ) HCl / Typical 0.2 Annual Mean Maximum 1-hour EALs derived from 8-hour and 15-min OELs for HCl (11). Table 17 Dispersion Model Results HCl Pollutant / Scenario HF / Typical HF / BAT Limits HF Emissions The HF modelling results are detailed in Table 18. The results indicate that the ambient ground level concentrations exceed the TA Luft annual limit value for HF under typical operating conditions. Emissions from the Vitra Tiles facility lead to an ambient HF concentration (including background) which is 293% of the limit value at the worst-case receptor. Results for the BAT limits modelling scenario indicate that the predicted ambient ground level concentrations exceed the TA Luft annual limit value for HF when emissions from A2-1 are reduced to the BAT emission limit. Emissions from the Vitra Tiles facility lead to an ambient HF concentration (including background) which is 193% of the limit value at the worst-case receptor. Background (µg/m 3 ) Averaging Period Vitra Tiles Contribution (µg/m 3 ) Predicted Immission Concentration (µg/nm 3 ) Standard (µg/nm 3 ) 0.02 Annual Mean Annual Mean German Technical Guidelines on Air Quality - TA Luft. Table 18 Dispersion Model Results HF 6.2 Concentration Contours The geographical variation in ground level concentrations for the worst-case scenario for each pollutant is illustrated as concentration contours in Figures 3-9. The contents of each figure are described below. Figure 3 Predicted Annual Average NO 2 Concentrations (µg/m 3 ) (Typical Operation) Figure 4 Predicted 99.2 nd %ile of 24-Hour SO 2 Concentrations (µg/m 3 ) (Typical Operation) Figure 5 Predicted 90.4 th %ile of 24-Hour PM 10 Concentrations (µg/m 3 ) (Typical Operation) Page 23

24 Figure 6 Predicted Annual Average PM 2.5 Concentrations (µg/m 3 ) (Typical Operation) Figure 7 Predicted Maximum 1-Hour VOC Concentrations (µg/m 3 ) (Typical Operation) Figure 8 Predicted Annual Average HCl Concentrations (µg/m 3 ) (Typical Operation) Figure 9 Predicted Annual Average HF Concentrations (µg/m 3 ) (Typical Operation) The concentrations listed in Tables are for the maximum concentrations to be predicted at any location off-site. All other locations are below these values. The concentration contours show where the maximum concentrations are predicted to occur and the reduction in concentration with distance away from the maximum. The maximum concentrations are observed at or near the boundary of the site. The contour plots show a significant fall in concentrations with distance from the site. The south-westerly prevailing winds tend to lead to higher long-term concentrations to the north of the site. 6.3 Assessment Summary Typical Emissions Ambient pollutant levels of NO 2 (including background) resulting from typical operating conditions comply with the relevant limit values, with levels reaching at most 19% of the 1-hour limit value (measured as a 99.8 th %ile) and 38% of the annual limit value at the worst-case receptor. Ambient ground level concentrations of SO 2 (including background) comply with the relevant limit values under typical operating conditions. Predicted SO 2 concentrations reach at most 6% of the 1-hour limit value (measured as a 99.7 th %ile) and 10% of the 24-hour limit value (measured as a 99.2 nd %ile) at the worst-case receptor. With regard to PM 10, ambient ground level concentrations (including background) exceed the 24-hour limit value and are below the annual limit value under typical operating conditions. Emissions from the Vitra Tiles facility lead to an ambient PM 10 concentration (including background) which is 133% of the ambient 24-hour limit value (measured as a 90.4 th %ile) and 78% of the annual limit value at the worst-case receptor. Emissions from the Vitra Tiles facility lead to an ambient PM 2.5 concentration (including background) which reaches 100% of the proposed annual concentration cap at the worst-case receptor under typical operation. For the purposes of this study, the pessimistic assumption was made that all VOC emissions from the Vitra Tiles facility were camphor (a TA Luft Class I VOC). Under typical operation, ambient VOC ground level concentrations comply with both the long-term and short-term Environmental Assessment Levels (EALs) for camphor, reaching at most 29% of the long-term EAL and 33% of the short-term EAL at the worst-case receptor. With regard to HCl, the results indicate that the ambient ground level concentrations are below the short-term EAL and above the long-term EAL for HCl under typical Page 24

25 operating conditions. Emissions from the Vitra Tiles facility lead to an ambient HCl concentration (including background) which is 73% of the short -term EAL and 155% of the long-term EAL value at the worst-case receptor. The results for HF show that ambient ground level concentrations exceed the TA Luft annual limit value for HF under typical operating conditions. Emissions from the Vitra Tiles facility lead to an ambient HF concentration (including background) which is 293% of the limit value at the worst-case receptor. Thus, the modelling results show that mitigation measures are required in order to reduce the air quality impact of the Vitra Tiles facility and to fully comply with the relevant air quality standards. Emissions at BAT Limits With regard to PM 10, results indicate that the predicted ambient ground level concentrations of PM 10 are below both the 24-hour and annual limit values when emissions from A2-1 to A2-4 are reduced to the BAT emission limit. Emissions from the Vitra Tiles facility lead to an ambient PM 10 concentration (including background) which is 63% of the ambient 24-hour limit value (measured as a 90.4 th %ile) and 51% of the annual limit value at the worst-case receptor. With regard to PM 2.5, results indicate that the predicted ambient ground level concentrations are below the annual concentration cap for PM 2.5 when emissions from A2-1 to A2-4 are reduced to the BAT emission limit. Emissions from the Vitra Tiles facility lead to an ambient PM 2.5 concentration (including background) which is 58% of the proposed annual concentration cap at the worst-case receptor. With regard to HF, results indicate that the predicted ambient ground level concentrations exceed the TA Luft annual limit value for HF when emissions from A2-1 are reduced to the BAT emission limit. Emissions from the Vitra Tiles facility lead to an ambient HF concentration (including background) which is 193% of the limit value at the worst-case receptor. 6.4 Mitigation Measures for Typical Operation - Stack Height Increase The major air quality impacts from the Vitra Tiles facility result from emissions from the Kiln 1 Inlet (Emission Point A2-1) and the Dust Extraction Units 1 & 2 (Emission Points A2-8 & A2-9). An increase in the Kiln 1 Inlet stack height from the current height of 9.8m to 18m and of Dust Extraction Units 1 & 2 from the current height of 5m to 8m will lead to full compliance with the air quality standards. The predicted ambient ground level concentrations for NO 2, SO 2, PM 10, PM 2.5, VOCs, HCl and HF following this mitigation measure are detailed in Table 19. Ambient levels of these pollutants are predicted to range from 4-93% of the relevant limit values with the proposed mitigation measure in place. Page 25 EPA Export :22:02:33

26 Pollutant / Scenario Background (µg/m 3 ) Averaging Period Vitra Tiles Contribution (µg/m 3 ) Predicted Immission Concentration (µg/nm 3 ) Standard (µg/nm 3 ) NO 2 / Typical SO 2 / Typical PM 10 / Typical Annual Mean th %ile of 1-hr means 99.7 th %ile of 1-hr means 99.2 nd %ile of 24- hr means 90.4 th %ile of 24-hr means Annual Mean PM 2.5 / Typical VOC / Typical HCl / Typical HF / Typical Annual Concentration Cap Annual Mean Maximum 1-hour Annual Mean Maximum 1-hour Annual Mean Table 19 Dispersion Model Results Following A2-1 Stack Height Increase Page 26 EPA Export :22:02:33

27 References (1) USEPA (2004) AERMOD Description of Model Formulation (2) USEPA (2005) Guidelines on Air Quality Models, Appendix W to Part 51, 40 CFR Ch.1 (3) USEPA (2000) Seventh Conference on Air Quality Modelling (June 2000) Vol I & II (4) USEPA (2003) Human Health Risk Assessment Protocol, Chapter 3: Air Dispersion and Deposition Modelling, Region 6 Centre for Combustion Science and Engineering (5) USEPA (1999) Comparison of Regulatory Design Concentrations: AERMOD vs. ISCST3 vs. CTDM PLUS (6) Schulman et al (1998) Development and evaluation of the PRIME Plume Rise and Building Downwash Model, Air & Waste Management Association (7) Paine, R & Lew, F. (1997) Consequence Analysis for Adoption of PRIME: an Advanced Building Downwash Model Prepared for the EPRI, ENSR Document No (8) Paine, R & Lew, F. (1997) Results of the Independent Evaluation of ISCST3 and ISC-PRIME Prepared for the EPRI, ENSR Document No (9) USEPA (2005) Estimating Exposure to Dioxin-Like Compounds Volume IV, Chapter 3 Evaluating Atmospheric Releases of Dioxin-Like Compounds from Combustion Sources (Draft) (10) German VDI (2002) Technical Instructions on Air Quality Control - TA Luft (11) UK Environment Agency (2003) IPPC Environmental Assessment for BAT, The Stationary Office (12) Health & Safety Authority (2002) 2002 Code Of Practice for the Safety, Health and Welfare at Work (Chemical Agents) Regulations, 2001 (13) Environmental Protection Agency (2006) Air Quality Monitoring Report 2005 (14) NCAR (1995) A Description of the Fifth Generation Penn State/NCAR Mesoscale Model (MM5) (15) USEPA (2004) User s Guide to the AERMOD Meteorological Preprocessor (AERMET) (16) Auer Jr, (1978) Correlation of Land Use and Cover with Meteorological Anomalies, Journal of Applied Meteorology 17(5): (17) European Commission (2006) IPPC Reference Document on the Best Available Techniques in the Ceramic Manufacturing Industry (18) USEPA (1995) User s Guide for the Industrial Source Complex (ISC3) Dispersion Model Vol I & II Page 27 EPA Export :22:02:33

28 awn The consulting M1 M5 M2 M4 M3 Tecpro Building, Clonshaugh Business and Technology Park, Dublin 17. Tel: +353 (0) Fax: +353 (0) Project Vitra Tiles Air Quality Assessment Reference 05/2833AR02 Figure 1 Approximate Location of Air Monitoring Stations EPA Export :22:02:33

29 awn The consulting Tecpro Building, Clonshaugh Business and Technology Park, Dublin 17. Tel: +353 (0) Fax: +353 (0) Project Vitra Tiles Air Quality Assessment Reference 05/2833AR02 Figure 2 Windrose for Ballnattin Region EPA Export :22:02:33

30 awn consulting N The Tecpro Building, Clonshaugh Business and Technology Park, Dublin 17. Tel: +353 (0) Fax: +353 (0) Reproduced from Ordnance Survey Ireland Permit No: EN 7507 Scale 1:43,500 approx Project Vitra Tiles Air Quality Assessment Reference 05/2833AR02 Figure 3 Predicted Annual Average NO 2 Concentrations (µg/m 3 ) (Typical Operation) EPA Export :22:02:33

31 awn consulting N The Tecpro Building, Clonshaugh Business and Technology Park, Dublin 17. Tel: +353 (0) Fax: +353 (0) Reproduced from Ordnance Survey Ireland Permit No: EN 7507 Scale 1:43,500 approx Project Vitra Tiles Air Quality Assessment Reference 05/2833AR02 Figure 4 Predicted 24-Hour SO 2 Concentrations (µg/m 3 ) (Typical Operation) EPA Export :22:02:33

32 awn consulting N The Tecpro Building, Clonshaugh Business and Technology Park, Dublin 17. Tel: +353 (0) Fax: +353 (0) Reproduced from Ordnance Survey Ireland Permit No: EN 7507 Scale 1:43,500 approx Project Vitra Tiles Air Quality Assessment Reference 05/2833AR02 Figure 5 Predicted 24-Hour PM 10 Concentrations (µg/m 3 ) (Typical Operation) EPA Export :22:02:33

33 awn consulting N The Tecpro Building, Clonshaugh Business and Technology Park, Dublin 17. Tel: +353 (0) Fax: +353 (0) Reproduced from Ordnance Survey Ireland Permit No: EN 7507 Scale 1:43,500 approx Project Vitra Tiles Air Quality Assessment Reference 05/2833AR02 Figure 6 Predicted Annual Average PM 2.5 Concentrations (µg/m 3 ) (Typical Operation) EPA Export :22:02:33

34 awn consulting N The Tecpro Building, Clonshaugh Business and Technology Park, Dublin 17. Tel: +353 (0) Fax: +353 (0) Reproduced from Ordnance Survey Ireland Permit No: EN 7507 Scale 1:43,500 approx Project Vitra Tiles Air Quality Assessment Reference 05/2833AR02 Figure 7 Predicted Maximum Hourly VOC Concentrations (µg/m 3 ) (Typical Operation) EPA Export :22:02:33

35 awn consulting N The Tecpro Building, Clonshaugh Business and Technology Park, Dublin 17. Tel: +353 (0) Fax: +353 (0) Reproduced from Ordnance Survey Ireland Permit No: EN 7507 Scale 1:43,500 approx Project Vitra Tiles Air Quality Assessment Reference 05/2833AR02 Figure 8 Predicted Annual Average HCl Concentrations (µg/m 3 ) (Typical Operation) EPA Export :22:02:33

36 awn consulting N The Tecpro Building, Clonshaugh Business and Technology Park, Dublin 17. Tel: +353 (0) Fax: +353 (0) Reproduced from Ordnance Survey Ireland Permit No: EN 7507 Scale 1:43,500 approx Project Vitra Tiles Air Quality Assessment Reference 05/2833AR02 Figure 9 Predicted Annual Average HF Concentrations (µg/m 3 ) (Typical Operation) EPA Export :22:02:33