OFFICE OF LICENSING & GUIDANCE

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Randall Short
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1 OFFICE OF LICENSING & GUIDANCE INSPECTORS REPORT ON A LICENCE APPLICATION To: DIRECTORS From: SEÁN O DONOGHUE - LICENSING UNIT Date: 5/4/04 RE: APPLICATION FOR AN IPC LICENCE FROM LUFTHANSA SHANNON TURBINE TECHNOLOGIES LIMITED TRADING AS LUFTHANSA TECHNIK TURBINE SHANNON, LICENCE REGISTER 664 Application Details Class of activity: Class Electroplating License application received: 14/01/03 Notices under Article 11(2)(b)(ii) issued: 26/02/03, 14/05/03 Information under Article 11(2)(b)(ii) received: 25/03/03, 10/02/04, 25/03/04 Submissions 1. Shannon Development 2. Dúchas (Now DoEHLG) Site visits: 11/03/03, 26/02/04 Company Lufthansa Technik Turbine Shannon is an aircraft engine components repair facility. The company is a wholly owned subsidiary of Lufthansa Technik AG, and is located at the World Aviation Park, adjacent to the Smithstown Road and the Limerick to Ennis Road (N18), in the industrial zone of Shannon, Co. Clare. It is located on a seven acre site, the facility consisting of a single storey workshop, together with a two storey office facility and mezzanine area. The total floor area is 8,900 m 2, and the normal working hours are am to 4pm and 4pm to p.m., Monday to Friday. Approximately 200 people are employed at the facility. The facility was constructed in 1992 and the company commenced operation in The company installed a platinum plating line in January 2002 for plating of blades and vanes, and applied for an IPC licence in order to operate the plant. A fire in the plant in June 2003 destroyed the plating and chemical lines, requiring the installation of new plating and chemical cleaning plant. These plants are currently being installed. Page 1 of 5

2 Process: The company is involved in the overhaul, maintenance and repair of aircraft engine components. The following aircraft engine components are processed on site: blades, shrouds, vanes and combustors. The main process steps are: Inspection (visual, x-ray, fluorescent penetrant inspection and ultrasonic). Cleaning (mechanical and chemical) Repair (brazing, heat treatment, blending, welding, coating) Testing (metallurgical). The main activities with an environmental implication are grit blast, plasma spray, heat treatment, diffusion fluoride ion cleaning (DFIC), chemical cleaning, GM furnace and fluorescent penetrant inspection. The main functions of these processes are removal of corrosion, identifying and treating cracks and mechanical weaknesses, treatment to withstand high temperatures, and applying new protective coatings. Proposed Determination Air There are four main emission points. These arise from the plasma spray system, the GM scrubber system, the DFIC scrubber, and the chemical clean scrubber. Abatement is employed on all these emissions, filtration on the plasma spray system, and caustic scrubbers to the GM furnace, the DFIC gas, and the chemical cleaning system. The PD requires all scrubbers to have ph controllers, and requires quarterly calibration of ph probes and a spare to be held on site for each probe. Particulate metals (Iron, Aluminium, Nickel, Chromium, Titanium, Cobalt) and Fluorides, have been measured from the plasma spray, GM furnace and DFIC exhausts at levels below 1g/hr, complying with the relevant TA Luft emission limit values. Ammonia is emitted from the GM furnace scrubber at approximately 5g/hr, well below the TA Luft emission limit value of 150g/hr. The PD sets emission limit values for these parameters well below TA Luft and meets the emission limit values recommended in the BATNEEC note for the sector. Acid emissions from the chemical cleaning line will meet TA Luft limits of 30 mg/m 3, and the PD has set limits accordingly. Main air emissions were modelled for dispersion by the applicant using the USEPA ISC3 model. The results showed predicted ground level concentrations (GLCs) of metals, HCl and NH 3 to be well below corresponding Danish C values, with GLCs for the remaining parameters, which do not have specified C values, predicted to be well below ambient guide values derived from TLV occupational exposure limits. Predicted NOx GLCs were well below corresponding Air Quality Standards. There is a 1.6 MW LPG boiler on site, which is designated a minor emission source. There are four minor emissions on site arising from unabated furnace pump system exhausts. Monitoring of these sources indicate insignificant mass emissions of the order of 1mg/hr down to the order of 10ug/hr of Aluminium, Chromium, Cobalt, Nickel, Fluoride, and Ammonia. Effluent: Effluent containing nitric acid will be separated from the other effluents (chemical clean line rinses) and fed to a vacuum evaporator. The evaporated water will be used to top up the scrubber sumps. Wastewater from the scrubbers is then returned to the evaporator. The residual sludge will be disposed of off-site. This system will be installed by April 2004 to address previous breaches of emission limit values for nitrate, and the PD has been written accordingly. Page 2 of 5

3 Rinses from the chemical clean line which do not contain nitric acid discharge via three oil, interceptors to a neutralization pit. Rinse waters contaminated with penetrant from the fluorescent penetrant inspection units also pass through activated carbon filters prior to entering the oil separators and the neutralization pit. A ph control system consisting of mechanical agitator, ph meters/controller and acid/alkali dosing pumps, ensures the ph in the pit is between 6 and 9 prior to pumping the effluent to a 1,000 litre balance tank, from where it is discharged to Tradaree (Shannon development) effluent treatment plant. If the ph goes outside the acceptable range due to plant or other malfunction, an audible alarm is raised, effluent discharge is automatically ceased, and an emergency pump transfers the effluent from the neutralisation pit to a 9,000 litre holding tank. The ph, temperature, and flowrate of the discharge is continuously monitored, with ph and flow values being recorded, and a composite sampler is fitted to the outflow. The emissons are currently monitored in accordance with the Shannon Development effluent control regulations. The discharge meets all PARCOM limits for sewer as specified in the relevant BATNEEC note. The proposed electroplating activity will not have any discharge. Surface Water: Surface water on site, which includes roof water, is discharged via a single inspection chamber to a Shannon Development culvert. Fuel and chemical storage practices on site are good, and there appears to be little threat to the quality of this water. A weekly visual check is required in Condition 9 of the PD. Groundwater: This was a greenfield site prior to 1992 when the facility was built. There are no emissions to ground on the site, and the application states that no historical incidents occurred which could have affected groundwater quality. Fuel and chemical storage practices on site are good, and there appears to be little threat to groundwater quality on site. A once off survey of groundwater on site is required by Condition 9 of the PD to assess groundwater quality, with further surveys required at the discretion of the Agency. The company will be required to submit the proposed survey details for agreement with the agency in advance. Waste: Hazardous wastes generated on site consist of the following: Liquid wastes from the chemical cleaning line, which consists mainly of waste acid and base solutions and salts. Also waste fixer/developer solution from the X ray unit and scrubber sump solutions/sludges. All these wastes are sent off site as hazardous waste Solid wastes such as plasma powder, blast media, GM furnace waste (containing waste metals and contaminated metal oxides), waste oil filters and activated carbon waste are incinerated off site. Used batteries and mercury lamps are sent to Returnbatt and Irish Lamp Recycling respectively. Waste oil and coolants are recovered off site. Non hazardous wastes: Paper, cardboard, scrap metal, and plastic bottles are treated and/or recovered off site by appropriately permitted contractors. Machining waste (oil, metal filings, filter paper etc) and Aluminium Oxide from mechanical cleaning are incinerated in Germany. Municipal waste is sent to Local Authority landfill. All waste contractors are appropriately licensed or permitted. Noise: The company is based in an industrial area near Shannon Airport, and adjacent to the N18. Major construction work was being carried out on the Ennis/Shannon/Limerick Roads at the time of the noise survey carried out for the application, and so heavy traffic and construction Page 3 of 5

4 activity was the dominant noise contributor. Noise is also contributed by Shannon Airport and nearby industries. Daytime measurements conducted for the application indicated that noise from a compressor at the rear of the plant was causing elevated (58dBA) levels at the site boundary to the rear. Although there are no noise sensitive locations to the rear of the plant the company has replaced the compressor, the specification of which indicates that noise levels at the site boundary will now not exceed 55dBA. The PD requires that noise levels from the plant do not exceed 55dB A by day and 45dB A by night at the site boundary. Energy: Electricity is used on site for power, and LPG for heating. A Building Management System is in place which monitors electricity and LPG consumption. Thermostatic control of workplace temperature ensures economic use of fuel. Condition 10 requires an energy audit to be conducted and the recommendations of the audit to be implemented as part of the EMP. List I and II substances: There are several List II substances in use on site, including Ammonia and Ammonium salts, and Fluoride compounds and hydrocarbons. No List I substances are in use, apart from Cadmium in batteries. List II substances in the discharge are Copper, Lead, Nickel, Arsenic, Tin, mineral oils, and hydrocarbons, fluorides and ammonia. Storage: Waste and raw material storage practices on site are good. The plating plant has a dedicated bund, and any spillages from the chemical cleaning plant will drain to the effluent sump. Liquid raw materials and wastes are stored indoors, in or on special bunded storage units. Only metal wastes are stored outdoors, in locked and covered skips. Protected sites: The River Shannon candidate Special Area of Conservation (csac) stretches from Killaloe to Loop Head/Kerry Head, encompassing the Shannon, Feale, Mulkear, Deel, Maigue and Fergus Estuaries. The site is of great ecological interest due to the high number of habitats and species listed on Annexes I and II of the EU habitats directive. Most of the estuarine part of the site has been designated a Special Protection Area (SPA) under the EU Birds Directive, primarily to protect the large number of migratory birds present in winter. Effluent from the Lufthansa facility undergoes ph neutralisation on site as outlined above, followed by further ph balancing and flocculation at Tradaree Point effluent treatment plant, and discharges to the Fergus Estuary. Surface water on site discharges directly to the Fergus Estuary via a Shannon Development culvert. Firewater Retention: There is no specific firewater containment facility on site. In the event of fire, firewater in the process area would drain to the effluent pit, with associated balance tank and holding tank, with a total capacity of 20m 3. The company discharges surface waters via a Shannon Development culvert to ecologically sensitive waters and so, according to Appendix A of the relevant EPA guidance note, is required to conduct a risk assessment. Condition 9 of the PD requires this assessment to be conducted in accordance with this guidance note, and a suitable risk management programme to be implemented on the basis of the findings. Environmental Liabilities: Considering the operation in terms of the nature and quantities of wastes stored on site, storage practices on site, and other relevant criteria in accordance with EPA assessment methodology, the company are not required to conduct an Environmental Liabilities Risk Assessment as part of the PD. Page 4 of 5

5 Submissions: 1. Mr. Ken Power, Shannon Development submitted a copy of Shannon Development s effluent control regulations for the applicant. The emission limit values and monitoring requirements of the regulations have been incorporated in the PD. 2. Ms Kaye McInerney of Dúchas submitted a letter highlighting the csac status of the Lower River Shannon (see above). She noted that the facility discharges nitrates and phosphates to Clare County Council s effluent treatment plant at Tradaree Point, and that these are not treated due to the lack of tertiary treatment at Tradaree. She recommended that Clare County Council be advised of the need to upgrade the plant to tertiary treatment to prevent nutrient loading of the csac. It is beyond the Agency s remit to request any upgrade of Tradaree point effluent treatment plant. The applicant is however in the process of eliminating the discharge of nitrates (see above) in the effluent and the maximum daily discharge of Total Phosphorus allowed under the PD is 0.96 kg (current daily discharges rarely exceed 0.4 kg). These figures do not constitute a significant contribution to the nutrient loading in the Fergus Estuary, given the sizeable contribution of the local population and industry in the area. It should also be noted that lime addition at Tradaree point results in Phosphorus removal. Recommendations: That the board approve the proposed determination as submitted. Signed Seán O Donoghue Procedural Note In the event that no objections are received to the Proposed Determination of the application, a licence will be granted in accordance with Section 85(4) of the Environmental Protection Agency Act 1992 as soon as may be. Page 5 of 5

OFFICE OF LICENSING & GUIDANCE

OFFICE OF LICENSING & GUIDANCE TO: REPORT OF THE TECHNICAL COMMITTEE ON OBJECTIONS TO LICENCE CONDITIONS Directors FROM: Technical Committee LICENSING UNIT DATE: 08 June 2004 RE: Reg. 664 Objection to