The Board of Directors Gerard Kelly Waterford Crystal Limited (Dungarvan) - Application for an IPCL.

Transcription

1 M E M O R A N D U M DATE: 7 th May 1998 TO: FROM: RE: CC: The Board of Directors Gerard Kelly Waterford Crystal Limited (Dungarvan) - Application for an IPCL. Application Details: Waterford Crystal Limited (Dungarvan) Dungarvan County Waterford Reg. No. 156 Class of Activity: 4.3 The production of glass (special) in plants with a capacity exceeding 5,000 tonnes per year. Application received 16 August 1996 Article 11 (2)(b)(ii) issued 8 October 1996 Article 11 (2)(b)(ii) reminder issued 27 November 1996 Article 11 (2)(b)(ii) (Partial reply) 10 January 1997 Section 97 issued 15 October 1996 Section 97 Information received 14 November 1996 Article 11 (2)(b)(ii) Information received 23 April 1997 Article 17 issued 17 June 1997 Section 26 Notice issued 17 June 1997 Article 17 Information received 27 June 1997, 18 July 1997,22 July 1997, 5 August 1997, 10 December 1997, 5 February 1998 Article 17(3) Clarification issued 12 March 1998 Article 17(3) Information Received 26 March 1998 Section 84(4) Notice to Planning Authority 30 March 1998 Site Visits 26 June 1996, 23 September 1996

2 Existing Permits Water Pollution Act Air Pollution Act Trade Effluent Licence from Waterford County Council Ref. No. WPS/01/89 None Introduction: A Proposed Determination for this facility was before the Board on 10 June The Report to the Board regarding analysis of herbage samples from a field adjacent to the facility stated; The results of this analysis are attached and while much lower than the levels recorded in 1990, it would seem that emissions from the facility are still causing environmental impacts outside its boundary. As a result the Board considered that the Agency could not grant a licence if it was possible that significant pollution was being caused beyond the site boundary. Accordingly a Section 26 notice under the Air Pollution Act, 1987 was issued along with an Article 17 request for information. Company Profile: Waterford Crystal Ltd. (Dungarvan) manufacture lead crystal glass and employ 433 people. The production capacity of the site is 6,500 tonnes of glass per annum. The principal operations include Batching, Blowing, Finishing, Cutting, Washing and Acid Polishing. Batching The purpose of the batching operation is to screen, weigh and mix the various solid raw materials to form a precisely measured batch mix for subsequent melting. Batch raw materials include arsenic trioxide, litharge (lead oxide), silica sand and antimony trioxide. Blowing Batch and cullet (waste glass) are added to the tank furnace and melted. The modern electrically powered tank furnace is a continuous process. Following blowing and shaping the glass is annealed.

3 Finishing Individual glass pieces are prepared for the cutting shop and excess caps are cut from the blown/moulded glass. Waste cullet generated as a result of this step is reused in the furnace. Cutting At this stage individual items formed at the blowing stage are converted into decorative pieces. Glass fines are produced as a consequence of this operation and these form part of the wastewater stream. Washing Prior to acid polishing the glass is washed after cutting to remove residual marking. These markings were used by the glass cutters as guides. Acid wastewater is collected and transported to the Waterford Crystal (Kilbarry) acid wastewater treatment plant. Acid polishing This step removes the outer layer of the rough cut crystal to leave a smooth polished glass surface. Sulphuric and hydrofluoric acids are used and fumes are extracted to double scrubbing. Air Emissions: There are three emission points of significance: 1. A2-1 Batch Mixer Filter 2. A2-2 Tank Furnace Melter Extract 3. A2-3 2 Stage Acid Scrubber Stack Dust from workspace areas where batch is prepared and weighed is vented through a wet dust collector. Lead, arsenic, nickel and antimony dusts are emitted in quantities less than the new plant BATNEEC Guidance Note emission limit values and new plant BATNEEC Guidance Note ELVs have been applied. Substances from the A2-2 electric tank furnace include lead, arsenic, nickel, antimony, sulphur dioxide and nitrogen dioxide. Measured emissions are within the new plant BATNEEC Guidance Note ELVs and new plant BATNEEC Guidance Note ELVs have been applied for all parameters except sulphur dioxide and nitrogen dioxide where the maximum measured values were set, which are well below new plant BATNEEC Guidance Note limits.

4 Acid polishing fumes are vented to one 2 stage scrubber. ELVs below the new plant BATNEEC Guidance Note have been set for this emission as discussed below. Impact of Air Emissions: The TA-Luft nomogram for stack height was used to check the relevant parameters from both the Batch Mixer Filter (A2-1) and the Tank Furnace Melter Extract (A2-2) and dispersion was found to be adequate. Following the Section 26 notice further air dispersion modelling has been carried out on the acid scrubber emission point (A2-3) using the ISCST3 model which calculated expected ground level concentrations (GLCs) for HF. It was found that if the stack was increased by 5 meters then the TA Luft IW2 ground level concentration value (3 µg/m 3 ) would be met. TA Luft IW2 value is the 98%ile of the maximum average hourly concentration of a pollutant. It is recommended that it is this figure and not the more lenient OEL/40 (25 µg/m 3 ) that the applicant should meet due to the aggressive nature of hydrogen fluoride. The PD requires the applicant to increase the stack within 3 months of date of grant of the licence. In a submission to the Agency concerning this application a local farmer Mr. Leonard Sheridan, whose farm is next to the facility, detailed problems he has been having over the past 7 years in relation to cattle refusing to graze fields close to the acid scrubber emission point. In 1990 levels of fluoride in grass samples were 840 mg/kg dry matter. Levels of fluoride in uncontaminated grass would be expected to be in the range mg/kg dry matter ( Investigation of animal health problems at Askeaton, Limerick, 1995, EPA). Under the Article 17 request issued by the Agency on 17 June 1997 the applicant has submitted analysis of both soil and herbage samples carried out by Teagasc. Soil sampling was requested in order to determine if soil was contaminated by past emissions of fluoride. Samples were taken on 1 December 1997 on 7 plots adjacent to the factory. The report found uncontaminated levels of flouride in soil and concluded that significant deposition in the past of fluoride is not indicated. Samples of herbage taken on 21 January 1998 show significant reductions in Fluorine with levels varying from mg/kg dry matter. This compares very favourably with the 1990 sample of 840 mg/kg dry matter. Continuous measurements of HF have been available for the emission point and show values < 1 mg/m 3. By raising the stack by 5 m the facility could emit at up to 3 mg/m 3 and still not exceed their ground level concentration TA-Luft limit of 3 µg/m 3. However it is considered that as the facility is capable of continuously achieving 1

5 mg/m 3 that this limit should be set. The new plant BATNEEC Guidance Note ELV is 5 mg/m 3 at a mass emission threshold > 0.05 kg/h. As a result of the study carried out under the Section 26 notice the applicant has found that a potassium hydroxide solution when used in the secondary scrubber is more effective than water as the scrubber medium. This system has now been installed with a probe and potassium hydroxide dosing system controlling the ph. Surface Water Discharge: The applicant has one surface water discharge point (SE2) to a Dungarvan UDC storm water pipeline. The pipeline discharges to Dungarvan Harbour. The applicant is required to install a continuous ph monitor on their surface water discharge and under condition to submit proposals for warning and action levels within nine months of the date of grant of licence. Emissions to Sewer: The two main effluent types are acid wastewaters and wash water from the glass cutting operation. Acid wastewaters are transported to Waterford Crystal (Kilbarry) while wash water containing glass fines passes through a settling tank where ferric sulphate and polyelectrolyte are added to aid precipitation of glass fines. The supernatant from the glass fines tank goes to SE1. Dungarvan UDC did not specify ELVs in their section 97 response. ELVs have been set based on new plant BATNEEC and the existing single media licence. While the applicant discharges trade effluent to sewer there is no existing wastewater treatment plant. The applicant has had problems meeting the single media licence limit for lead of 0.5 mg/l. Analysis shows that the activity would be able to meet a limit of 5 mg/l at present. Taking dilution in the sewer and harbour into account it is not expected that this level of discharge will have an adverse impact. The applicant will have to meet the new plant BATNEEC level of 0.5 mg/l lead by January As part of the EMP the applicant has been asked to investigate methods of recycling wash water used in the glass cutting operation. Emissions to Ground: There are two existing emissions to ground at the facility from roof surface water runoff. Condition requires the applicant to divert this runoff via an oil interceptor to the storm water pipeline. This has been deemed necessary due to the importance and vulnerability of the aquifer. Groundwater:

6 The applicant is, under condition of the proposed determination, required to carry out a hydrogeological assessment of the site. This was judged necessary as the facility is located on a regionally important aquifer with an extreme vulnerability rating. Springmount well is located approximately 400 m to the south of the site and augments the Dungarvan water supply. Should the assessment require the installation of groundwater monitoring wells, sampling will be as set out in Schedule 4(ii) Groundwater Monitoring. Noise Emissions: The following limits for noise have been set for noise sensitive locations: Day: 55 db(a) Night: 45 db(a) In order to meet these limits the applicant will be required, under condition 8.2 of the proposed determination, to submit a proposal to modify/upgrade/replace an existing extract fan and second stage scrubber fan. A further noise survey will then be carried out to ensure that the remedial work has been effective. Wastes Management: Hazardous and non-hazardous waste generated on site is handled by licensed contractors and undertakers. Acid wastewater is tankered to the Waterford Crystal plant at Kilbarry for treatment. This has been dealt with in Schedule 3(i) Hazardous Wastes for Disposal/Recovery. Use of Carcinogens, Class I Organics and List 1 & List II Substances: There is one category I carcinogen used in the production area, Arsenic Trioxide. Its emission is limited both from the tank furnace and the effluent discharge points. No TA-Luft Class I Organics are used in the production. The following List I and List II substances are used in significant quantities; Lead, Arsenic, Antimony, Hydrofluoric Acid and Sulphuric Acid. As part of the EMP the company is required to reduce/eliminate the use of carcinogens along with reducing heavy metal consumption.

7 Submissions: Two submissions were received from: 1. Leonard Sheridan, Local Farmer. 2. Department of the Marine. 1. This submission concerned high fluoride levels in pasture land and was dealt with in the Impact of Air Emissions section of this report. 2. The submission states that the Department of the Marine usually insist on a 20/30 BOD/Suspended Solids limit and request that stringent limits are put on phosphorus levels from the plant. Taking the 25:1 dilution the effluent receives in the sewer, expected existing concentrations in the sewer and the BOD, suspended solids and phosphorus levels set in the proposed determination it is not expected that the industry will have any adverse impact in relation to these parameters. Residuals Management: It is suggested that residuals management is necessary due to the quantity of materials that may be present on the site if production ceases. This could include process batch materials, waste sludges from the acid wastewater treatment plant, glass fines from settling tanks and scrubber liquids. Environmental Liabilities: The site is classed as a SEVESO site due to the quantity of Arsenic Trioxide stored. It is recommended that the applicant be required to assess environmental liabilities and obtain any indemnity deemed necessary as outlined in condition 14.3 of the proposed determination. It is recommended that the Board approve the proposed determination as submitted. Gerard Kelly Licensing & Control