Liebherr Container Cranes Ltd.

Transcription

1 Ms. Ann Kehoe, Office of Climate, Licensing & Resource Use, Environmental Protection Agency, PO Box 3000, Johnstown Castle Estate, Co. Wexford. Liebherr Container Cranes Ltd. Container Cranes. Rubber lyre Gantry Cranes. Your ref.: Your corr. of: Our ref.: Date: 2009EPAL From the desk of: Morgan Foley Telephone Fax Re.: IPPC Licence Review Application Reg. No. P Dear Ms. Kehoe, I refer to the above subject and your letter of 14Ih November requesting the supply of additional information. Please read our responses to the fourteen points that you raised, numbered accordingly below: 1. The power wash station is used sporadically with no set pattern. Company cars are washed on a monthly basis for a period of about 1 hour, each car taking approximately 5 minutes. In our transport department, the drivers of company forklifts (x6) and mobile cranes (x3) wash their vehicles themselves as required, the former taking minutes and the latter up to 30 minutes. Other items such as a dirtyldusty crane component can also be washed if required. It is estimated that on average the wash station is used for 3 hours per week. The Ehrle HSE1000 power wash unit has a flow rate of 500 up to a maximum of 1,000 Litres per hour (see letter to the Agency dated 3/07/00 - included in Attachment E3 of the application). 2. LCC keeps a detailed inventory of all paints, solvents, oils, etc. used and stored on site and provides robust bunding arrangements to contain spillage or potential spillage. A detailed Emergency Response Plan (IPPC Application Form, attachment J1) is in place with details of: a trained emergency response team; site maps; chemical storage arrangements; isolation of services; emergency spill kits; emergency procedures, and details of fire fighting equipment. Employees receive awareness training in the importance of protecting the local environment. LCC operates a vehicle wash station which passes through a maintained class 1 oil interceptor before discharging to sewer. This ensures that hydrocarbons are not present in the discharge from the site. ' Liebherr Container Cranes Lld., Killarney, Co. Kerw, Republic of Ireland. Telephone: Fax: , Web: VAT No. IE K Registered Oflice: 90 South Mail, Cork. Certificate of Incorporation Dublin, Ireland. Directors: P. O'Leary. G. Frainer (Austrian), Secretary. R. Ganser (German). M.C. Larkin.

2 In addition the bunded chemical storage areas have recently been fitted with automatic dry powder fire suppression units. This greatly reduces the risk of firewater contamination and also minimises the overall volume of firewater which would be required in the event of an emergency. Waste liquids are also stored in bunded locations and consigned for recycling/disposal via agreed licensed waste contractors. The above comprehensive measures ensure that the installation does not cause a significant impact on Lough Leane or Killarney National Park and risk to the environment is low. 3. Power ratings for heaters/boilers are indicated in the table below refer to section Attachment D1 of the application to identify locations. Location Boiler/Heater Fuel Type Rating (kw) Quantity Total Power (kw) Cutting Hall (MPC/7AC) Heater LPG Cutting Hall (MPC/7AC) Water boiler LPG Machine Room (MPM/7AM) Heater Oil Apprentice Workshop (FHA/1LA Heater Oil Maintenance Workshop (MSM/2BC) Heater Oil (MPS/2AS) Heater LPG (MPS/2AS) Heater LPG (MPS/2AS) Heater Oil (MPS/2AS) Water boiler Electric Electrical Maintenance (MPE/7AE) Heater LPG (Old) Carpenter shop (MPA/7AA) Heater LPG Office Block (west) Boiler/Heater Oil Main Office Block (east) Boiler/Heater Oil (MPF/2AS) Heater Oil (MPF/2AS) Heater Oil ,404.0 (MPF/2AS) Water boiler Electric Layout Hall (MPL/7AF) Heater Oil Final Assembly (MPA/7AA) Heater LPG Final Assembly (MPA/7AA) Water boiler LPG Main Stores (FPM/UBD) Heater LPG Cleaning Hall (MPW/7AW) Heater LPG Paint Shop (MPP/7AP) Heater LPG Paint Shop (MPP/7AP) spray booth Heater LPG Paint Shop (MPP/7AP) oven Heater LPG TOTAL: 7, Three Graco Extreme Mix paint pumps have been in operation for several months in the paint shop. Unfortunately, user trials have not produced favourable results for finish paints which contain the most solvent. When using the paint in the pumps, the curing agent crystallises in the pump making the system unworkable. The system does work however for primer paint. Two pumps are operating at the spray booth and one priming main beams. LCC operates 15 painting workstations in the paint shop and it was the intention in the replacement plan to phase in the changeover to the new technology by 2

3 the end of the first quarter 2009 pending feasibility. However, it is currently not feasible to expand the use of Graco Extreme Mix pumps because of the crystallisation problem with the finish paint. Conventional pumps will continue to be used until such time as this problem can be overcome or an alternative system is available. LCC is in consultation with the paint pump supplier to determine if the crystallisation problem can be overcome. In the interim, the existing 3 pumps can be used for priming operations. LCC will continue to investigate alternative BAT technology to improve paint application efficiency and minimise waste and has active projects in place as part of the Environmental Management Programme (submitted with the Annual Environmental Report) to achieve this objective. 5. The most recent and the maximum monitoring results for emission points A2-1 to A2-8 are included in the table below, the period of the most recent measurements being shown in parentheses. It is important to note that due to the fact that emission points A2-1 to A2-6 inclusive were not previously licensed, LCC was not obliged to conduct regular monitoring. The number of snap-shot measurement results for these six emission points therefore is quite small over a period of nine years, e.g. A2-5 and A2-6 have each only been measured once. Due the nature of the product painting times are sporadic and different components will require different painting styles as a result of their shape and size. Similar painting activities occur at each emission point A2-1 to A2-6 inclusive and these should therefore not be treated differently from each other with respect to licence limits judging A2-1 to A2-6 on their individual maximum values below will be misleading. Most recent result, TOC (mg/m 3 ) Maximum result, TOC (mg/m 3 ) No. of measurements since 2000 A2-1 A2-2 A2-3 A2-4 A2-5 A2-6 A2-7 A ( (2002 q2) 38.8 (2008 q4) 92.3 ( (2008 q4) ( ( ( (2005 q3) (2005 q3) 48.3 (2004 q2) 48.3 (2004 q2) 64.7 ( (2002 q2) ( (2001 The maximum emissions from each of A2-1 to A2-7 inclusive are significantly lower than the 300mg/Nm 3 Emission Limit Value applied for, and modelled in the dispersion modelling report. Although the maximum emission value recorded at A2-8 is above this value it should be noted that (a) this emission occurred early in 2001 soon after the installation of the machine and is put down to teething troubles and therefore considered abnormal (b) with the exception of one other abnormal measurement in 2007, only three others have been marginally above 300mg/Nm mg/nm 3 in 2002 quarter 2, 302 mg/nm 3 in 2005 quarter 4 and 315 mg/nm 3 in 2009 quarter 1 (c) this emission point is only occasionally in use and therefore the emissions are not continuous, (d) the modelling report effectively considers much higher emissions than these levels because it assumes continuous operation at the maximum level of 300mg/m3 even though this value is not routinely attained LCC is investigating ways of ensuring that 300 mg/nm 3 will not be exceeded in the future. Even if the maximum emission rate recorded during the period was attained continuously, the dispersion modelling assessment shows that the predicted 3

4 incremental contributions to ground level concentrations of any substance will be orders of magnitude lower than the relevant air quality standard (TMS Environment Ltd communication, March 2009). Thus there will be no adverse impact on ambient air quality even if the maximum emissions were attained continuously. In line with its Environmental Management Programme LCC is currently actively researching ways to reduce solvent emissions further. 6. The following response is provided by our consultant, TMS Environment Annex III of the Solvents Directive (1999/13/EC) describes how the fugitive emission value, expressed as a percentage of the solvent input for the installation should be calculated. The calculation is summarised as follows: F = I1 O1 O5 O6 O7 O8 Or F = O2 + O3 + O4 + O9 The fugitive emission value can be determined by direct measurement of the quantities. Alternatively, an equivalent calculation can be made by other means, for instance by using the capture efficiency of the process. The fugitive emission value is expressed as a proportion of the input, which can be calculated according to the following equation: I = I1 + I2 Determination of fugitive emissions can be done by a short but comprehensive set of measurements. It need not be done again until the equipment is modified. The terms in the equations are defined as follows: Inputs of organic solvents (I): I1 = I2 = The quantity of organic solvents or their quantity in preparations purchased which are used as input into the process in the time frame over which the mass balance is being calculated. The quantity of organic solvents or their quantity in preparations recovered and reused as solvent input into the process. (The recycled solvent is counted every time it is used to carry out the activity.) Outputs of organic solvents (O): O1 O2 O3 O4 O5 O6 O7 Emissions in waste gases. Organic solvents lost in water, if appropriate taking into account waste water treatment when calculating O5. The quantity of organic solvents which remains as contamination or residue in products output from the process. Uncaptured emissions of organic solvents to air. This includes the general ventilation of rooms, where air is released to the outside environment via windows, doors, vents and similar openings. Organic solvents and/or organic compounds lost due to chemical or physical reactions (including for example those which are destroyed, e.g. by incineration or other waste gas or waste water treatments, or captured, e.g. by adsorption, as long as they are not counted under O6, O7 or O8). Organic solvents contained in collected waste. Organic solvents, or organic solvents contained in preparations, which are sold or are intended to be sold as a commercially valuable product. 4

5 O8 O9 Organic solvents contained in preparations recovered for reuse but not as input into the process, as long as not counted under O7. Organic solvents released in other ways. For the purpose of the current application, the best available data for calculation of the fugitive emission value is the data for the second equation as follows: Fugitive Emission Value = F = O2 + O3 + O4 + O9 For the Liebherr facility, based on 2008 data, the following quantities were measured and assumptions made: O2 O3 O4 O9 Organic solvents lost in water, if appropriate taking into account waste water treatment when calculating O5. O2 (Liebherr 2007) = 0 kg/year There are no waste water treatment processes and no losses to wastewater from the facility The quantity of organic solvents which remains as contamination or residue in products output from the process. O3 (Liebherr 2007) = 0 kg/year All of the solvent is evaporated as the paints dry so there is no solvent remaining as residue in the products i.e. cranes Uncaptured emissions of organic solvents to air. This includes the general ventilation of rooms, where air is released to the outside environment via windows, doors, vents and similar openings. O4 = 750 kg/year This estimate is based on a very limited series of measurements carried out in March April The details were reported in TMS Environment Ltd report Ref 8177 Rev The very limited data showed that the fugitive emissions were extremely low as expected, with no measurable levels of VOCs detected at the doors and windows. Using an analytical Limit of Detection (LOD) of 1mg/Nm 3 and the measured escape velocity through open doors / windows as well as the cross sectional area of such escape pathways, an upper estimate of fugitive losses of 750kg/year loss through un-captured emissions was determined. Organic solvents released in other ways. O9 = 0kg/year There are no other emissions of VOCs at the facility. Fugitive Emission Value = F = O2 + O3 + O4 + O9 = 750kg/year Solvent Input for 2007 = I1 + I2 = 98, ,650 = 104,480kg/year Thus the Fugitive Emission Value, expressed as a percentage of the Solvent Input, based on 2008 data, is as follows: 5

6 Fugitive emission value = (750/104,480) x 100 = 0.72% 7. Painting at LCC is carried out within contained conditions appropriate to the size and nature of the product manufactured on site. Emission points A2-1 to A2-6 The main paint shop area comprises a large open hanger 56m wide, 79m long and 22m high. The extraction system consists of six under-floor channels leading to six extraction chimneys outside the western wall. The size of LCC crane components warrants a contained paint shop of this size. The large steel crane components for painting are currently up to 52 m long, up to 60 tonnes in weight and up to 7 m wide such as: crane main beams; derrick booms; crane legs; carriers; end-carriages; cill beams; holding arms; portal diagonals; A-frames; crane trolleys; machinery house bases; and cladding frames. The length of the components necessitates the 56m wide paint shop as components are painted laterally parallel to the extraction channels. While it would be desirable to further segregate these six extraction channels, wide components often are regularly spread over two extraction systems. It is also necessary to lift parts over one another along the length of the painting hall with the travelling overhead crane as they enter and leave the paint shop at different times depending on their state of completion. The paint shop was designed to allow for this level of flexibility and also to provide for an element of future planning whereby cranes have increased in size over the last nine years as dictated by the maritime industry, since the building was constructed. Size and shape of cranes may continue to increase over the coming years. On this basis it is concluded that the process is contained in an area appropriate to the activity and that additional containment works are not required at this time. Emission point A2-7 This emission point extracts NMVOCs from the paint shop spray booth for (relatively) small crane components. These components are hung from a monorail system and pushed into the contained spray booth with internal dimensions 8m x 5m x 4m high where they are manually sprayed. This is a well contained booth with an effective extraction system. Additional containment works are not required. Emission point A2-8 This emission point extracts NMVOC from a modern automatic shop priming plant which is used to paint steel profiles (steel boxes, I-beams, angles, etc.) prior to cutting and fabrication at the facility. The contained spray booth has a working width of 4m, a working height of 460mm and a throughput length of 2.5m. The process uses a quick drying shop primer which is dry to the touch upon leaving the machine for immediate transfer to cutting operations in the cutting hall. This is a well contained booth with an effective extraction system. Additional containment works are not required. LCC is a progressive company committed to continuous improvement with respect to the application of the BAT principle both in terms of environmental protection as well as operating a world class manufacturing facility. In particular LCC is open to new technologies that come to our attention to continually improve performance as demonstrated by the companies Environmental Management Programme projects which have set challenging targets with state-of-the art processes. LCC will continue to bear with this philosophy and endeavour to improve further as technologies and practicality allows. 6

7 8. Please refer to the enclosed document entitled BAT Assessment for VOC Abatement produced by our consultant TMS Environment Ltd. in response to this item. 9. Emission points A2-1 to A2-7 The best information that can be provided in this respect is average values. The nature of LCC s product, in particular the large size, significant variety and complexity of shape of the components does not lend itself to a simple pattern of painting that can be readily analysed in order to provide precise information on the period of emission per hour, per day, per emission point. Simple observation reveals that the period of emissions can vary from hour to hour and day to day depending on a number of factors. Different parts are applied with different paints depending upon their shape, e.g. high solids paints can be used on crane legs, end-carriages, carriers and cill beams, but not on main beams and derrick booms due to their lattice structure. Different size components will be sprayed for different lengths of time. Different cranes will use different paint specifications depending on customer requirements single colour finish will have a different spray pattern to a 2-colour finish. The same range of paints is used at each emission point A2-1 to A2.7 so a total usage figure is available rather than usage per emission point. A large component will require more preparation time by the painter than a smaller one. Painters spend between 20-30% of their time spraying, the rest of the time being for preparation and transport of the components. Components can be sprayed in different parts of the paint shop on different days depending on workspace availability while parts are drying or waiting to be painted. The variables, being practically random means that the best and most useful information that can be derived is by taking the total paint used in the paint shop and dividing by the known hours of operation of each of the extraction systems to arrive at an average value. This is the approach that has been taken in the IPPC application documents. This is the approach which has been taken with the air dispersion modelling report (IPPC licence application, Attachment I1) with an overestimation applied in the calculations to take into account any degree of uncertainty. It is not possible to give an accurate report of total mass emission per hour and per day for individual emission points for the reasons above. The annual and average daily emission times are presented in Table 1 of the air dispersion modelling report and mass balance for gross usage of VOC on site in appendix 1 of the same report (see IPPC licence application, Attachment I1). Emission points A2-8 The automatic spray booth in the cutting hall may be isolated for the purpose of estimating mass emission per unit time as the paint used at this location is specific to that area. However, averaging must again be used to estimate the data per hour as the painting process here is sporadic. For example, in 2007, LCC used 4,260L of Interplate 937 of with 2,731 kg of VOC. The extraction system was operating for approximately 996 hours during the year. 10. Trimethyl benzenes are not principal solvents at the facility. 1,2,4 and 1,3,5-trimethyl benzenes are present in some of the materials used at the facility in concentration ranges which range from 1% to 10% by weight of the paint / thinner in which they are present. The Material Safety Data Sheets for the materials specify only a range of concentrations for example 1 2.5% or 2.5% to 10%. These isomers are not principal solvents. In order to demonstrate this, data from the 2007 Usage figures for the materials was collated (Appendix I: 2007 TMB Use) and the range of concentrations of trimethylbenzenes for each material was used to calculate the range of VOC content in each material. When this data is processed as a percentage of annual VOC usage, the relevant conclusions are as follows: 1,2,4 TMB usage 2007 is between 2.1% and 7.7% of total NMVOC gross usage 7

8 1,3,5 TMB usage in 2007 is between 0.8% and 2.1% of total NMVOC gross usage Although the trimethylbenzenes could not be considered as principal solvents, the dispersion modelling report has been revised to evaluate the impact of emissions of these species at the stated levels on ambient air quality. It is clear from the revised modelling report that there is no significant impact on air quality as a result of emissions of these substances. 11. The atmospheric dispersion model was executed to consider the maximum emissions from the facility. A printout of the input and output files are enclosed and an electronic copy of the files as well as the meteorological data is also submitted. 12. A copy of the most recent noise measurement as submitted with LCC s Annual Environmental Report is enclosed inclusive of the information requested. 13. The shot-blasting system comprises two blast robots in the shot-blast hall with an adjacent shot-blasting plant room which incorporates 6 air filtration units. Dust-laden air is extracted from the shot-blasting hall at a low level through a filtration system in the adjacent plant room. The filtered air is then re-circulated back into the hall, thus conserving heat that would otherwise be lost if the air was emitted to atmosphere. Each of the 6 air filtration units has 24 cylindrical pleated dust cartridges giving a total of 144 dust filters in the system. The filtration system is self-cleaning with periodic pneumatic pulsations to perform the cleaning operation, the spend dust falling into a collection bag at the base. Pressure differential gauges are fitted on the filtration system to monitor the condition of the filters. The gauges are inspected on a regular basis by the maintenance department. The life of the filters is approximately 2 years. It is important to note that there is no external emission to atmosphere from the shotblast system. For information purposes, some details of the system are enclosed with this letter. 14. In order to demonstrate the company s ability to meet with its financial commitments or liabilities for carrying on or ceasing activities, enclosed please find the Liebherr Group Annual Report 2007, complete original and one copy of the relevant section on Global financial statements. This report demonstrates that the company has a sound financial position and the ability to carry out the measures detailed in the IPPC application form in the event that the facility should cease operations in Killarney. In addition, a copy of the company s certificate of insurance for 2009 is enclosed to provide cover in the event of any adverse incidents. 15. Additional Information During a telephone conversation with Mr. Stuart Huskisson, additional information was requested verbally with respect to the planned new production building at the east of the plant and water consumption figures With respect to the planned building, full planning permission was received from Kerry County Council on 8/01/09. The project was assigned the planning register number 08/2252 by Kerry County Council and full details including planning drawings can be viewed on the County Council website planning section, The activities to take place in the new building will be the same as those taking place in the existing areas detailed in Attachment D1 of the IPPC licence application, section 3.3 with no major emission points planned. An outline of the project has already been provided in Attachment A2 of the IPPC licence application and 8

9 coupled with the information above and the planning filesldrawings, this is the complete information that can be provided at this stage -a revision to Attachment A is enclosed along with a revised section A non-technical summary. LCC is however currently revisiting these plans and is considering a change to the layout and is not in a position to provide drawings at this point until such time as potential changes are fully considered. In the interim we refer the Agency to the Kerry County website to view the drawings for the planning permission received - changes being considered will not substantially vary from the planning permission already received and the planned usage will remain the same Water consumption figures are included each year in LCC's annual environmental report. The details from the latest report are enclosed with this letter We wish to advise that the incorrect cross-section dimension was reported for particulate atmospheric emission points A2-9 and A2-10. While the diameter is initially 600mm from the machine to the filtration system, this increases to 800mm downstream of the filters to atmosphere. As requested an updated non-technical summary is enclosed to reflect the information provided above. We trust that this answers your queries. Yours sincerely, LIEBHEM CONTAINER CRANES LTD. Enclosures: see reference below EPA Export :13:37:32

10 Enclosures Enclosure Reference item 8 - BAT Assessment for VOC Abatement Enclosure Reference item Air Dispersion Modelling Assessment Enclosure Reference item 12 - Noise Monitoring Assessment Report Enclosure Reference item 13 - Shot-blast System Enclosure Reference item 14 - Financial Commitments or Liabilities Enclosure Reference item Non Technical Summary and Attachment A Enclosure Reference item Additional Information Water Consumption 10 EPA Export :13:37:32