OFFICE OF LICENSING & GUIDANCE

Transcription

1 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 Proposed Determination for Lufthansa Shannon Turbine Technologies Ltd. t/a Lufthansa Technik Turbine Shannon, World Aviation Park, Shannon, Co. Clare Application Details Class(s) of activity: Class 12.3 Electroplating operations Location of activity: World Aviation Park, Shannon, Co. Clare Licence application received: 14 January 2003 PD issued: 06 May 2004 First party Objection received: 27 May 2004 Third Party Objection received None Company Lufthansa Technik Turbine Shannon is a wholly owned subsidiary of Lufthansa Technik AG located on a 7 acre site in the industrial zone of Shannon Airport. The facility commenced operations (the repair of aircraft engine components) in 1993 (not a licensable activity). They now propose to carry out an electroplating activity on the site. Consideration of the Objection The Technical Committee, comprising of Marie O Connor and Niamh O Donoghue, have on 08 June 2004 considered all of the issues raised in the First Party objection and this report details the Committee s comments and recommendations following the examination of the objections together with discussions with the inspector. L:\LICENSING UNIT\Licence Determination\IPPC\Licence Decisions\P0664\664TCRept.doc Page 1 of 6

2 The applicant makes 2 points of objection : First Party Objection A.1. Schedule 1(i) Emissions to Atmosphere The applicant objects to the emission limit values set in the PD for emission points A2-1, A2-2 and A2-3 as they state that they are too onerous on the company, reflect once-off monitoring and do not take into consideration any variances in the process. They request that the Agency consider using TA Luft or other industrial standards and provided a table with values they consider more appropriate and provide a table with proposed ELV s for nickel, chromium, fluorides and ammonia. In addition they point to a typographical error in Schedule 4 (i) Recording and Reporting to the Agency in relation to the frequency of reports. Technical Committee Comment: The ELV s were set in the PD on the basis of the monitoring returns and application information submitted to the Agency. The emission points A2-1, A2-2 and A2-3 are not associated with the electroplating operation which precipitated the licence application. Using the air dispersion modelling study submitted as part of the licence application the impact of any increases in ELV s was assessed by the TC. The main discharge point is A2-1 and an increase in ELV s of nickel and chromium is recommended. The ELV in relation to iron is not considered necessary as a Total Metals limit is proposed which will include all the metals used in the process. In relation to A2-2 the flow rate from this point is low (80m 3 /hr) with a stack height of 13.3m. The waste gas is discharged through a scrubber therefore the limits proposed in the PD should be achievable however it is recommended that the ELV for fluoride is increased in line with the Danish standards. In addition the ELV for aluminium can be increased to 0.1g/hr. In relation to ammonia it is proposed not to increase this as it is a pungent gas and at such low flowrates could cause local problems. The limit is currently 75mg/m 3. The TC recommend no change to A2-3 as the stack is relatively low (100m 3 /hr) with a low flowrate and there is a scrubber which if operated correctly should abate the waste gases to the levels in the PD. The TC recommend that the reporting requirements in relation to emissions to atmosphere should be amended to read annually as the monitoring is annually. Recommendation: Amend Schedules 1(i) to read as follows: Emission Point Reference No.: A2-1 Plasma spray filter system exhaust Main Roof Volume to be emitted: Maximum in any one day: 104,000 m 3 L:\LICENSING UNIT\Licence Determination\IPPC\Licence Decisions\P0664\664TCRept.doc Page 2 of 6

3 Maximum rate per hour: 6,500 m 3 Minimum discharge height: 13.3 m above ground Aluminium Nickel Chromium Titanium Total Metals Note g/h 2.5 g/h 2.5 g/h 0.3 g/h 5g/hr Note 1: The parameters to be monitored shall include all metals used in the processes to which the discharge point relates and shall be agreed with the Agency. Emission Point Reference No.: A2-2 GM Scrubber exhaust Main Roof Volume to be emitted: Maximum in any one day: 1,300 m 3 Maximum rate per hour: 80 m 3 Minimum discharge height: 13.2 m above ground Aluminium 1 mg/m 3 Fluoride (as HF) 3mg/m 3 Ammonia 75mg/m 3 Emission Point Reference No.: A2-3 DFIC Scrubber exhaust Main Roof Volume to be emitted: Maximum in any one day: 1,600 m 3 Maximum rate per hour: 100 m 3 Minimum discharge height: 9 m above ground Titanium g/h Aluminium 1 mg/m 3 Fluoride (as HF) 0.01g/h Amend Line 2 in Schedule 4(i) Reporting to the Agency to read as follows: Reporting Frequency Report Submission Date Monitoring of emissions to atmosphere Annually Ten days after end of the year being reported on. L:\LICENSING UNIT\Licence Determination\IPPC\Licence Decisions\P0664\664TCRept.doc Page 3 of 6

4 A.2. Schedule 2(i) Emissions to Sewer The applicant objects to the emission limit values set for the discharge to sewer. They state that the information submitted by the company was the average daily values in 2002 and do not allow for process variations. The company request that the ELV s which were stipulated in the SFADCo document are allowed. The company also ask for clarification on issues related to Heavy metals ELV and monitoring frequency for Colour. Technical Committee Comment: As the facility has an electroplating process the discharges are required to meet the PARCOM limits for discharge to sewer (Recommendation 92/4) which specifically sets limits for discharges of certain metals to sewer (chromium, copper, lead, nickel, silver, tin, zinc) and also cyanide and organohalogens. It is recommended that where the ELV s stipulated in the SFADCo consent to the Agency do not conflict with these limits they are allowed as this discharge is going to the Tradaree Treatment plant otherwise the PARCOM limits are applied. In relation to the clarification regarding the total heavy metals limit it is proposed to remove this limit as the individual limits apply to all the relevant parameters. Limits and monitoring have been set for all parameters specified in the SFADCo consent. The monitoring of the effluent for colour the table is amended to reflect annual monitoring. Recommendation: Amend Schedule 2(i) and Schedule 2(iii) to read as follows: Emission Point Reference No.: Monitoring point: SE1 At discharge point to Shannon Development sewer E14196, N16346 Volume to be emitted: Maximum in any one day: 160 m 3 Maximum rate per hour: 15 m 3 Temperature 43 C (max.) PH 6-9 Toxicity 10 TU mg/l BOD 600 COD 1000 Suspended Solids 400 Oils, Fats and Grease 200 Sulphate 500 Nitrates (as N) 70 Sulphide 0.5 L:\LICENSING UNIT\Licence Determination\IPPC\Licence Decisions\P0664\664TCRept.doc Page 4 of 6

5 Chloride 500 Cyanide 0.2 Total Chromium 0.5 Chromium (VI) 0.1 Cadmium 0.1 Cobalt 1.0 Copper 0.5 Zinc 0.5 Silver 0.1 Iron 10 Lead 0.5 Nickel 0.5 Arsenic 0.5 Tin 1.0 Aluminium 1.0 Detergents 0.1 Colour 100 mg/l pt/co Total Phosphorus (as P) 20 Total Phenols 0.5 Ammonia 50 Organohalogens 0.1 Mercury 0.05 Schedule 2(iii) Emission Point Reference No.: SE-1 Monitoring Frequency Note 1 Analysis Method/Technique Flow Continuous On-line flow meter with recorder Temperature Continuous On-line temperature probe with recorder PH Continuous ph electrode/meter and recorder Sulphate Weekly Standard Method Nitrates (as N) Weekly Standard Method Total Phosphorus (as P) Monthly Standard Method Iron Monthly Standard Method Chemical Oxygen Demand Monthly Standard Method Detergents Quarterly Standard Method Aluminium Quarterly Atomic Absorption/ICP Sulphide Quarterly Standard Method Biochemical Oxygen Demand Biannually Standard Method Chloride Biannually Standard Method Cyanide Biannually Standard Method Total Chromium Biannually Atomic Absorption/ICP L:\LICENSING UNIT\Licence Determination\IPPC\Licence Decisions\P0664\664TCRept.doc Page 5 of 6

6 Cobalt Biannually Atomic Absorption/ICP Copper Biannually Atomic Absorption/ICP Lead Biannually Atomic Absorption/ICP Suspended Solids Biannually Gravimetric Oils, fats & greases Biannually Standard Method Cadmium Annually Atomic Absorption/ICP Mercury Annually Atomic Absorption/ICP Nickel Annually Atomic Absorption/ICP Arsenic Annually Atomic Absorption/ICP Zinc Annually Atomic Absorption/ICP Tin Annually Atomic Absorption/ICP Total Phenols Annually Standard Method Toxicity Note 2 Annually To be agreed with the Agency Colour Annually To be agreed with the Agency Note 1: Note 2: All samples shall be collected on a 24 hour flow proportional composite sampling basis. The number of toxic units (Tu) = 100/x hour EC/LC 50 in percentage vol/vol so that higher Tu values reflect greater levels of toxicity. Overall Recommendation It is recommended that the Board of the Agency grant a licence to the applicant (i) (ii) and (iii) for the reasons outlined in the proposed determination and subject to the conditions and reasons for same in the Proposed Determination, subject to the amendments proposed in this report. Signed Marie O Connor for and on behalf of the Technical Committee L:\LICENSING UNIT\Licence Determination\IPPC\Licence Decisions\P0664\664TCRept.doc Page 6 of 6