APPENDIX D ATMOSPHERIC EMISSION LICENCE APPLICATION

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1 APPENDIX D ATMOSPHERIC EMISSION LICENCE APPLICATION

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3 Table of Contents 1 TYPE OF APPLICATION ENTERPRISE INFORMATION SITUATION AND EXTENT OF THE PLANT Location and extent of plant Description of surrounding land use NATURE OF THE PROCESS Process description Listed activities Unit process or processes Hours of operation Graphical process information RAW MATERIALS AND PRODUCTS Raw materials used Production rates Materials used in energy sources Sources of atmospheric emission (including all tiers of greenhouse gas) APPLIANCES AND MEASURES TO PREVENT AIR POLLUTION Appliances and control measures Start-up, maintenance, and shut down conditions Complaint register DISPOSAL OF WASTE AND EFFLUENT ARISING FROM ABATEMENT EQUIPMENT ANNEX A SIMPLIFIED BLOCK DIAGRAM ANNEX B BASIC SITE LAYOUT MAP Page 2 of 24

4 List of Tables Table 1: Enterprise information... 4 Table 2: Contact details of the responsible person... 4 Table 3: Location and extent of plant... 5 Table 4: Listed activities under NEMAQA Table 5: Scheduled processes under APPA Table 6: Unit processes Table 7: Hours of operation Table 8: Raw materials used Table 9: Production rates Table 10: Materials used in energy sources Table 11: Point source parameters Table 12: Point source emissions Table 13: Greenhouse gas emissions Table 14: Point source emissions monitoring requirements Table 15: Point source emission information List of Figures Figure 1: The location of Lead and Solder Sales cc within Belville... 6 Figure 2: Photographs of the 2% and 9% melting pots... 7 Figure 3: Photographs of melting pots 1, 2 and 3 and the wire extruder... 8 Figure 4: Photographs of the automated wheel balancing weight machines... 9 Figure 5: Photographs of the scrap metal separation process... 9 Page 3 of 24

5 1 TYPE OF APPLICATION X New Application Transfer Renewal Variation/Amendment/Review Current APPA Permit / Atmospheric Emission Licence Number: APPA Registration Certificate Number ENTERPRISE INFORMATION Table 1: Enterprise information Enterprise name Lead and Solder Sales cc Trading as Lead and Solder Sales cc Type of enterprise Closed corporation Close corporation registration number 2010/104356/23 VAT registration number Business partner number Not applicable Registered address Unit 6A, Saxon Park, Glucose Rd, Belville Postal Address P.O. Box 457, Kasselsvlei, 7533 Telephone number (general) Fax number (general) Industry type/nature of trade Manufacturing of solder and lead products Land use zoning as per town planning scheme General Industrial 1 Land use rights if outside town planning scheme Not applicable Table 2: Contact details of the responsible person Responsible person name or emission control officer (where appointed) Lenon Guzha Telephone number Cell phone number Fax number address production@lass.co.za After hours contact details Page 4 of 24

6 3 SITUATION AND EXTENT OF THE PLANT 3.1 Location and extent of plant Table 3: Location and extent of plant Physical address of the plant Description of site (Where no street address) Coordinates of approximate centre of operations Unit 6A, Saxon Park, Glucose Rd, Belville Not applicable 33 54'39" S 18 38'36" E Extent (km²) km 2 (3 200 m 2 ) Elevation above mean sea level (m) Province Metropolitan/District municipality Local municipality Designated priority area 73 m Western Cape Province City of Cape Town Not applicable Not applicable 3.2 Description of surrounding land use Lead and Solder Sales cc (LASS) is situated within Saxon Industrial Park in Mimosa, a general industrial area in Belville, in the City of Cape Town (Figure 1). Businesses within the Saxon Industrial Park include Telesnacks, Kerlizons (a plastic product manufacturer), panel beating, and mechanical workshops. Saxon Industrial Park is bordered by Glucose Way to the east and railway line to the north. The Tongaat Hulett Starch, Bellville Mill lies directly across Glucose Way from Saxon Industrial Park. SCP Southern Canned Products and Transpaco Flexables are also situated along Glucose Way, approximately 500 m from Lead and Solder cc. The closest residential suburbs, within 1 km of Lead and Solder cc, are: Belville Lot 6, approximately 200 m to the west. Belville Lot 3, approximately 560 m to the south-west. Belrail, approximately 550 m to the north-west. Belville South Ext. 13, approximately 600 m to the south-east. There are numerous schools, tertiary education and medical facilities within 5 km of Lead and Solder cc. The closest school and hospital are; the Belville-suid Secondary School (1 km to the south-west) and Belville Medical Centre (1.5 km to the north-west). Page 5 of 24

7 Figure 1: The location of Lead and Solder Sales cc within Belville Page 6 of 24

8 4 NATURE OF THE PROCESS 4.1 Process description LASS produces solder, pewter for the jewellery industry, sash weights for windows, and wheel balancing weights as well as lead shot and billets. Raw materials in the form of lead, tin, antimony, and copper ingots, are delivered by truck. Ingots are moved from trucks to the factory store by forklift. The lead, solder, pewter, sash weight, and wheel balancing weight manufacturing processes, are described hereafter Lead billets for wire and shot Lead wire and shot are produced through the melting of lead and antimony ingots in two six (6) tonne capacity melting pots referred to as the 9% and 2% pots (Figure 2a and Figure 2b). The 9% and 2% refers to the amount of antimony in the alloy. Antimony increases the hardness of the lead wire and shot. The melting pots are heated with paraffin burners located at the bottom of each pot. The molten alloy is manually cast into moulds and cooled using a soluble oil and water mixture. Cooled bars from the moulds are then sent to the extruder or tumbler for the manufacturing of lead wire and shot. Final products from this process include spooled lead wire, lead shot packed in boxes, and if requested by a client, sold as lead billets. Each melting pot is covered by an extraction hood (Figure 2c) to evacuate fumes generated by the melting process from the factory. Fumes are released to atmosphere through vents on the factory roof. (a) 2% melting pot (b) 9% melting pot (c) 2% melting pot extraction hood Figure 2: Photographs of the 2% and 9% melting pots Page 7 of 24

9 4.1.2 Solder, sash weights, and pewter bars To produce solder bars and sticks, lead, antimony and tin are melted in paraffin heated pots (Figure 3b) referred to as melting pot 1, melting pot 2, and melting pot 3 (Figure 3a). Whereas melting pot 1 has a capacity of three (3) tonnes, melting pots 2 and 3 each have capacity of 600 kilograms. Molten alloy from these pots are manually cast into trays and the solder bars cooled with a soluble oil and water mixture. Solder bars are either sold as is, or extruded to form solder sticks and wire (Figure 3). To produce pewter, tin and copper is melted in pot 3 and similarly cast and cooled to form pewter bars for the jewellery industry. Lead sash weights are manufactured from lead melted in pot 2, which is cast into moulds and cooled using the soluble oil and water mixture. Each pot is covered by an extraction hood through which melting fumes are extracted into a common duct. Fumes are leased to atmosphere through a vent in the factory roof. (a) Melting pots 1, 2 and 3 (from right to left) (b) Melting pot 1 paraffin burner Figure 3: Photographs of melting pots 1, 2 and 3 and the wire extruder (c) Extruder Wheel balancing weights Lead billets are melted in seven (7) electric melting pots and automated casting machines (Figure 4a). Several different sizes wheel balancing weights are manufactured. A fume extraction hood is positioned above each machine (Figure 4b). Fumes from machine numbers 1 to 4 are extracted to a common duct and vented through the wall of the factory near roof level. Machines 5, 6, and 7 each have a dedicated duct and vent (Figure 4c). Page 8 of 24

10 (a) Wheel balancing weight machine melting pot and automated casting (b) Extraction hood positioned over wheel balancing weight machine Figure 4: Photographs of the automated wheel balancing weight machines (c) Extraction hood ducting and capped vent to atmosphere Metal recovery LASS also operates a scrap metal separation and reclamation process on their premises. Wastes such as old municipal street lamps are disassembled to extract copper and other metals that are bagged and sent to a factory in Gauteng for recycling. Only mechanical separation methods are used. Emissions from this process are limited to dust and exhaust emissions from the three forklifts used to move materials. These emissions are considered negligible. (a) Forklift operational is scrap metal seperation area Figure 5: Photographs of the scrap metal separation process (b) Recovered lead Page 9 of 24

11 4.2 Listed activities Listed Activities, as published in terms of Section 21 of the National Environmental Management Air Quality Act (NEMAQA) (no. 39 of 2004), conducted at the premises are listed in Table 4. Scheduled Processes as per the Second Schedule of the repealed Atmospheric Pollution Prevention Act (APPA) (no. 45 of 1965) are listed in Table 5. Table 4: Listed activities under NEMAQA Listed Activity Number Category of Listed Activity Subcategory of the Listed Activity Name of the Listed Activity Description of the Listed Activity 4 Metallurgical industry 4.2 Combustion installations Combustion installations not used primarily for steam raisin and electricity generation. 4 Metallurgical industry 4.13 Lead smelting The extraction, processing and use of lead in production by the application of heat. The production of leadcontaining electric batteries. 4 Metallurgical industry 4.15 Processing of arsenic, antimony, beryllium, chromium and silicon The metallurgical production and processing of arsenic, antimony, beryllium, chromium, and silicon and their compounds by the application of heat. Table 5: Scheduled processes under APPA APPA Registration Certificate Number Date of Registration Certificate Scheduled Process Number Scheduled Process Description November Lead processes Page 10 of 24

12 4.3 Unit process or processes Unit process associated with listed activities in operation at the premises are listed in Table 6. Table 6: Unit processes Unit Process Unit Process Function Batch or Continuous Process 2% melting pot (6 t) 9% melting pot (6 t) Melting pot 1 (3 t) Melting pot 2 (600 kg) Melting pot 3 (600 kg) 7 x wheel balancing weight melting pot (700 kg) and casting machines Melting of lead and antimony to produce lead bars for billets, wire or shot. Melting of lead and antimony to produce lead bars for billets, wire or shot. Melting of lead, antimony and tin to produce solder bars, sticks or wire. Melting of lead, antimony and tin to produce solder bars, sticks or wire; or Melting lead to produce sash weights. Melting of lead, antimony and tin to produce solder bars, sticks or wire; or Melting of tin and copper to produce pewter bars. Melting of lead to produce wheel balancing weights. Batch Batch Batch Batch Batch Continuous 4.4 Hours of operation LASS s operational hours are listed in Table 7. The factory is closed on Saturdays, Sundays, and public holidays. Table 7: Hours of operation Unit Process 2% melting pot (6 t) 9% melting pot (6 t) Melting pot 1 (3 t) Melting pot 2 (600 kg) Operating hours Mon to Thu 07:30 to 16:00 Fri 07:15 to 13:00 Mon to Thu 07:30 to 16:00 Fri 07:15 to 13:00 Mon to Thu 07:30 to 16:00 Fri 07:15 to 13:00 Mon to Thu 07:30 to 16:00 Fri 07:15 to 13:00 Number of Days Operated per Year (a) Page 11 of 24

13 Unit Process Melting pot 3 (600 kg) 7 x wheel balancing weight melting pot (700 kg) and casting machines Operating hours Mon to Thu 07:30 to 16:00 Fri 07:15 to 13:00 Mon to Thu 07:30 to 16:00 Fri 07:15 to 13:00 Number of Days Operated per Year (a) Notes: (a) LASS operates 250 days per year. Except for the WBWM, melting pots produce products in batches and might not be continually operational for 250 days of the year. 4.5 Graphical process information The following is submitted with the application form: Annex A, a simplified block diagram Annex B, a basic site layout map (a floor plan was not available) 5 RAW MATERIALS AND PRODUCTS Raw material information, production and by-production rates and emissions information are supplied in this section of the application. 5.1 Raw materials used Table 8: Raw materials used Raw Material Type Maximum Permitted Consumption Rate (Quantity) Design Consumption Rate (Quantity) Actual Consumption Rate (Quantity) Units (Quantity per Period) Lead ingots n/a 1 n/a kg per month Tin ingots n/a n/a 300 kg per month Antimony ingots n/a n/a 100 kg per month Copper ingots n/a n/a 30 kg per month Water soluble oil for cooling n/a n/a 40 litres per month 1 n/a, not available Page 12 of 24

14 5.2 Production rates Table 9: Production rates Raw Material Type Maximum Permitted Consumption Rate (Quantity) Design Consumption Rate (Quantity) Actual Consumption Rate (Quantity) Units (Quantity per Period) Lead billets, wire and shot n/a n/a Only if specifically ordered, maximum 500 kg per month Solders n/a n/a 200 kg per month Pewter n/a 300 kg per month Sash weights n/a n/a 500 kg per month Wheel balancing weights n/a n/a kg/month 5.3 Materials used in energy sources Table 10: Materials used in energy sources Materials for Energy Sulphur Content of the Material (%) Ash Content of Material (%) Maximum Permitted Consumption Rate (Quantity) Design Consumption Rate (Quantity) Actual Consumption Rate (Quantity) Units (Quantity per Period) Paraffin 0.05 Not applicable n/a n/a 700 litres per month Page 13 of 24

15 5.4 Sources of atmospheric emission (including all tiers of greenhouse gas) Point source parameters Table 11: Point source parameters Unique Stack ID Source Name Latitude (decimal degrees) 2 Longitude (decimal degrees) Height of Release Above Ground (m) Height Above Nearby Building (m) Diameter at Stack Tip / Vent Exit (m) Actual Gas Exit Temp. ( C) 3 Actual Gas Volumetric Flow (m³/hr) 4 Actual Gas Exit Velocity (m/s) S01 2% melting pot roof vent m above roof 0.25 Ambient, 20 ºC S02 9% melting pot roof vent m above roof 0.25 Ambient, 20 ºC S03 Combined roof vent of melting pots 1, 2, and m above roof 0.3 Ambient, 20 ºC S04 Combined vent for wheel balancing weight machines 1 to Below roof level on the side of the building 0.18 Ambient, 20 ºC S05 Wheel balancing weight machines 5 vent Below roof level on the side of the building 0.18 Ambient, 20 ºC Point sources are in very close proximity to each other and more accurate GPS readings not available. Point sources are grouped by approximate location. 3 Assumption 4 Actual values not available. Refer to Section (page 19) for a description of the method adopted to calculate volumetric flow rate and exit velocity Page 14 of 24

16 Unique Stack ID Source Name Latitude (decimal degrees) 2 Longitude (decimal degrees) Height of Release Above Ground (m) Height Above Nearby Building (m) Diameter at Stack Tip / Vent Exit (m) Actual Gas Exit Temp. ( C) 3 Actual Gas Volumetric Flow (m³/hr) 4 Actual Gas Exit Velocity (m/s) S06 Wheel balancing weight machine 6 vent Below roof level on the side of the building 0.18 Ambient, 20 ºC S07 Wheel balancing weight machine 7 vent Below roof level on the side of the building 0.18 Ambient, 20 ºC Page 15 of 24

17 5.4.2 Point source emissions Since emission values have not been measured at the LASS, emissions reported below (Table 12) are estimates based on Minimum Emission Standards reported under normal conditions of 273 K, kpa. Greenhouse gas emissions are included in Table 13. Table 12: Point source emissions ID Pollutant (mg/nm³) 5,6 (mg/am³) 7 g/s Averaging period Tons per annum Emission hours Type of emission Pb E-04 8-hour average h/d, 250 d/y Routine, continuous S01 PM (b) E-02 8-hour average h/d, 250 d/y Routine, continuous SO E-01 8-hour average h/d, 250 d/y Routine, continuous NOx as NO E-01 8-hour average h/d, 250 d/y Routine, continuous Pb E-04 8-hour average h/d, 250 d/y Routine, continuous S02 PM (b) E-02 8-hour average h/d, 250 d/y Routine, continuous SO E-01 8-hour average h/d, 250 d/y Routine, continuous NOx as NO E-01 8-hour average h/d, 250 d/y Routine, continuous Pb E-04 8-hour average h/d, 250 d/y Routine, continuous S03 PM (b) E-02 8-hour average h/d, 250 d/y Routine, continuous SO E-01 8-hour average h/d, 250 d/y Routine, continuous NOx as NO E-01 8-hour average h/d, 250 d/y Routine, continuous S04 Pb E-04 8-hour average h/d, 250 d/y Routine, continuous 5 Section 21 Minimum Emission Standards for Section 21 listed activity subcategory 4.2, 4.13 or 4.15, plant status existing 6 Were PM emissions from more than one listed activity are released from a combined point source (ID 1, 2, and 3), the maximum PM Minimum Emission Standard is applied 7 Reference conditions for actual pollutant concentrations, 293 K, 100 kpa Page 16 of 24

18 ID Pollutant (mg/nm³) 5,6 (mg/am³) 7 g/s Averaging period Tons per annum Emission hours Type of emission PM E-03 8-hour average h/d, 250 d/y Routine, continuous S05 S06 S07 Pb E-04 8-hour average h/d, 250 d/y Routine, continuous PM E-03 8-hour average h/d, 250 d/y Routine, continuous Pb E-04 8-hour average h/d, 250 d/y Routine, continuous PM E-03 8-hour average h/d, 250 d/y Routine, continuous Pb E-04 8-hour average h/d, 250 d/y Routine, continuous PM E-03 8-hour average h/d, 250 d/y Routine, continuous Table 13: Greenhouse gas emissions Source Pollutant Emission rate Paraffin combustion at: 2% melting pot, 9% melting pot, and melting pots 1 to 3 Total CO2eq 98.8 tonnes per annum Page 17 of 24

19 5.4.3 Point source emissions monitoring Emissions monitoring have, to date, not been conducted at LASS. Monitoring requirements are listed in Table 14. Table 14: Point source emissions monitoring requirements ID Emission Sampling / Monitoring Method Sampling Frequency Sampling Duration Measured Parameters S01 8 Annually Pb, PM, SO2, and NOx S02 Annually Pb, PM, SO2, and NOx S03 Annually Pb, PM, SO2, and NOx S04 Annually Pb, PM S05 Annually Pb, PM S06 Annually Pb, PM S07 Annually Pb, PM 8 Section 21 of the National Environmental Management Air Quality Act (Act 39 of 2004) Page 18 of 24

20 5.4.4 Point source emission estimation information Table 15: Point source emission information ID S01 S02 S03 S04 S05 S06 S07 Volumetric flow rates (S01 to S07) Basis for Emission Rates Existing plant minimum emission standard (MES) for; subcategory 4.2 listed activity Combustion processes, subcategory 4.13 listed activity Lead processes, and subcategory 4.15 listed activity Processing of arsenic, antimony, beryllium, chromium, and silicon. Existing plant MES for; subcategory 4.2 listed activity Combustion processes, subcategory 4.13 listed activity Lead processes, and subcategory 4.15 listed activity Processing of arsenic, antimony, beryllium, chromium, and silicon. Existing plant MES for; subcategory 4.2 listed activity Combustion processes, subcategory 4.13 listed activity Lead processes, and subcategory 4.15 listed activity Processing of arsenic, antimony, beryllium, chromium, and silicon. Existing plant MES for; subcategory 4.13 listed activity Lead processes, and subcategory 4.15 listed activity Processing of arsenic, antimony, beryllium, chromium, and silicon. Existing plant MES for; subcategory 4.13 listed activity Lead processes, and subcategory 4.15 listed activity Processing of arsenic, antimony, beryllium, chromium, and silicon. Existing plant MES for; subcategory 4.13 listed activity Lead processes, and subcategory 4.15 listed activity Processing of arsenic, antimony, beryllium, chromium, and silicon. Existing plant MES for; subcategory 4.13 listed activity Lead processes, and subcategory 4.15 listed activity Processing of arsenic, antimony, beryllium, chromium, and silicon. Calculation of point source volumetric flow rate: Information on the volumetric flow rate of the fume extraction systems at LASS is not currently available. Theoretical estimates of volumetric flow rates were made based on (a) available lead emission factors for solder manufacturing and (b) the MES of 2 mg/nm 3 lead for the lead smelting process. The methodology is explained stepwise: 1. The scrubber controlled emission factor for melting pots used in solder manufacturing facilities is kg Pb/tonne material processed. 2. A theoretical uncontrolled emission factor of 0.46 kg Pb/tonne material processed was calculated by conservatively assuming a theoretical scrubber control efficiency of 95%. 3. LASS processes a total kg of material per month. It was assumed that all material first passes through the 2% and 9% melting pots before entering the rest of the process. Per melting pot, the following material processing rates were assumed based on pot capacity: a. 2% melting pot, 850 kg/month b. 9% melting pot, 850 kg/month c. Melting pot 1, 203 kg/month d. Melting pot 2, 508 kg/month Page 19 of 24

21 ID Basis for Emission Rates e. Melting pot 3, 305 kg/month f. WBW machines 1 to 7, 145 kg/month-pot, kg/month-total 4. Total Pb emissions per pot were calculated using the emission factor from step (2) and the pot throughputs from step (3) using the following equation: emission rate ( mg s) = Emission factor ( kg tonne) throughput( tonne month ) ( mg kg ) 166 ( operational hours month ) ( s hour ) 5. The total emission rate (in mg/s) calculated per point source since some emission sources share a common stack. 6. The normalised volumetric flow rate requirement for each point source (in Nm3/s) was calculated by assuming the minimum emission standard of 2 mg/nm 3 will be met: mg volumetric flow rate ( Nm3 s ) = emission rate ( s ) minimum emission standard ( mg Nm 3) 7. Actual volumetric flow rates (in Am 3 /s) were calculated at 100 kpa and ambient air temperature (293 K). 8. Stack gas exit velocities were calculated as follows: exit velocity ( m s ) = voluetric flow rate ( Am3 s ) stack exit area (m 2 ) Greenhouse gas emissions (S01 to S04) Greenhouse gas emissions calculations are based on the carbon dioxide (CO2), methane (CH4) and nitrous oxide (N2O) emission factors for distillate fuel oil of 2.7, 0.11 and kg/l respectively. 4.2 L of paraffin is used per hour to heat the melting pots. The global warming potential of CO2, CH4, and N2O is 1, 25 and 298 respectively. Emissions are reported as the total CO2eq. Page 20 of 24

22 5.4.5 Area and/or line source parameters Not applicable to LASS Area and/or line source emissions Not applicable to LASS Area and/or line source management and mitigation measures Not applicable to LASS Area and/or line source emissions estimation information Not applicable to LASS. 6 APPLIANCES AND MEASURES TO PREVENT AIR POLLUTION 6.1 Appliances and control measures At the time of writing this application, no pollution control or appliances were installed at LASS. Page 21 of 24

23 6.2 Start-up, maintenance, and shut down conditions Due to the nature of the process, the variation in atmospheric emissions during start-up, operation, and shut down is considered immaterial. 6.3 Complaint register Is a complaint register maintained at the site of works? X Yes No complaints received No To be initiated, by date: 7 DISPOSAL OF WASTE AND EFFLUENT ARISING FROM ABATEMENT EQUIPMENT Not currently applicable to LASS. Page 22 of 24

24 8 ANNEX A SIMPLIFIED BLOCK DIAGRAM Page 23 of 24

25 9 ANNEX B BASIC SITE LAYOUT MAP Page 24 of 24