Attachment 8.5 Ground and /or grgsmdwater ~~a~at~~~ · ground water issues but that would also...

Attachment 8.5 Ground and /or grgsmdwater ~~~~a~~~at~~~ Schwarz Pharma Ltd revised IPCL Application

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EPA Export 25-07-2013:17:26:30

OESCONSULTINGFORSCHWARZPHARMA

Proposal To Address Ground Water Contamination Issues At Schwarz

Pharma, Shannon Free Zone, Co. Clare

May 2005

PROJECTNO.: 450501

ALL COMMUNICATIONS RELATED TO THIS DOCUMENT SHOULD BE DIRECTED TO

Eur. Geol. Shane O’Neill PGeo

O’Neill Ground Water Engineering

7 South Main Street

Naas,

Co. Kildare

soneil1Qroundwatereng.k

Tel: 045-895668

Fax 045-881705

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EPA Export 25-07-2013:17:26:30

VcJ~sirm No. : C‘ 1

~)0c11111c111 ‘J’itll! :

Lisl Of Authors :

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EPA Export 25-07-2013:17:26:30

proposal To Address Ground Water Contamination Issues At Schwarz Pharma, Shannon Free Zone, Co.

*

1.0 Background

1.1 Ground water monitoring is undertaken by Schwarz Pharma Ltd on an annual basis in

accordance with Condition 9.3 and Schedule 5(ii) of their IPCL No. 20. In all some eleven

monitoring wells are monitored. Certain organic contaminants have been determined from

certain of these monitoring wells after a period when sampling for the presence of any

contaminants had been determined to be below detection level. These monitoring wells are

e GS03

. GSll

1.2 The range of organic contaminants detected inchtdes :

Toluene

Acetone

m,p-Xylene

Ethyl Benzene

Tetrachloroethane

o-Xylene

2 butane, 3-methoxy, 3me:hyl

Propanoic acid, 2 methyl anhydride

2-Pentanone

Methyl isobutyl ketone

1.3 These organics chemicals are used on the site.

1.4 The objective of this proposal is to set out a framework to determine the extent of existing

ground water contamination, assess the risk of such contamination to receptors, devise a

ground water remediation strategy, improve the overall ground water monitoring network,

7, South Main Street, Naas, Co. Kildare T:045-895665 F:045-881705 IvllxOS7-2300933

&nail: infoQ~roundcvate~enn.ie Directors: S O’Neill (Managing) 0 O’Neill

Registered Office as above. Registered No. 354725. VAT No. 3900664V

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EPA Export 25-07-2013:17:26:30

OES Consulting Page 2 of 6 Project No. 340501

Ground Water Investigation at Schwarz Pharma Proposal Tuesday, 03 May 2005 . . . . ..i-: . . . .?.:: : :,.:

and determine if there are any other areas where there might be potential contamination of

ground water.

2.0 Historic Contamination Events

2.1 There had been a spillage of Xylene in 1997 which had been remediated by 1998. There was a

limited ground water investigation programme undertaken as part of the investigation of

subsidence of the floor slab in Bay 130. While there were elevated levels of nitrogenous

compounds in the ground water, no organic contaminants were detected.

2.2 There had not been any issues since 1997, prior to the current issues recently detected as part of

the annual routine monitoring of ground water.

3.0 Approach

3.1

3.2

3.3

3.4

3.5

. ” I .-. . . .

O’Neill Ground Water Engineering Ltd (OGE) were invited by OES to review the current

ground water issues and propose an approach to address those issues. OGE visited the site on

April 29 fl’, 2005 in the company of Mr. Peadar O’Loughlin of OES. All the areas of concern

were visited and OGE was given an overview of the issues.

It was agreed that OGE would develop a framework proposal that would address current

ground water issues but that would also address potential ground water issues that might arise

in the future.

The overall objective is to develop a valid conceptual model to permit the effective remediation

of the ground water. The development of the conceptual model requires a detailed

hydrogeological investigation, followed by verification of the model and finally the

implementation of the most appropriate remediation strategy.

The development of the conceptual model requires an understanding of the geology and

hydrogeology, an understanding of the historic spills at the site, and the properties of the

contaminants such as their movement in ground water, their dissolution, volatilization,

adsorption and diffusion.

For example Xylene is one of the potential contaminants. &owing its vapor pressure,

solubility, octanol factor, sorbtion factor and dis-association constant will enable its movement

in ground water to be predicted. Xylene is also susceptible to microbial decay.

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EPA Export 25-07-2013:17:26:30

OES Consulting

Ground Water Investigation at Schwarz Pharma

Page 3 of G Project No. 340501

Proposal Tuesday, 03 May 2005 :... ..: .,.:: :..z : i.::.::..:..:: i:.:.:~i:.:..::.:....i.:::....:..~:::.~:~:~:~::~:.~~.~.~:::~.:::::::.:~..::::::, 7 :.::ii:.:...:ii.i~:::l:.::::.:.:~.~..:::.::..::::::: . . . . . ii: ::: ,::::. ii,: .: ,::.

4.0 Phase 1 - Existing Contamination Events

4.1 The known contamination is in GS03 and GSll. The source of the contamination in both wells

is different. The source of contamination measured GS03 originates from that storage area. The

source of contamination in GSll is probably from the Nitration Plant. Both contamination

events will require similar investigative techniques but their remediation may be different.

4.2 In broad terms investigation of the known contamination events will require :

4.2.1 Detailed hydrogeological investigation to define the flow regime and the contaminant

transport processes;

5.0

3.6 The EPA will require to be copied with all reports. Their agreement will be required at each

stage before works commence.

4.2.2 A detailed understanding of the flow regime and the processes that control and

influence the contaminant transport;

4.2.3 Microbial testing (if monitored natural attenuation is a viable treatment option);

4.2.4 Monitoring to collect adequate and representative data.

4.3 Objectives Of Phase 1

* Definition of contamination plumes from known contamination events;

e Determination of extent of known contamination events;

8 Development of conceptual hydrogeological model;

0 Strategy for Phase 3.

Phase 2 - Investigation For Other Potential Contamination Events

The known contamination events have been identified from monitoring wells drilled down

gradient of potentially contaminating activities. There are other potentially ground water

contaminating activities occurring on the site. Ground water monitoring wells should be

drilled down gradient of these sites to establish the current ground water quality and to be

used as sentinel wells for future on-going monitoring.

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EPA Export 25-07-2013:17:26:30


Ground Water Investigation at S&war2 Pharma Proposal Tuesday, 03 May 2005 : .: : . ..=. .: =.: : ,:.:.i:.iiiii:.i.: ..: -:.: =:.: : L.i.. :.

5.2 The ground water monitoring wells will be constructed as part of the Phase 1 work so that the

full extent of any potential ground water issues are known and included into any investigative

work for Phase 1.


. Definition of contamination plumes from unknown contamination events or establishment

that there are no other, as of now, unknown contamination events;

. Integration of investigative work required as a consequence of determining extent of

unknown contamination events (if any) into the Phase 1 programme.

l Strategy for Phase 3.

6.0 Phase 3 -Assessing Risk To Receptors

6.1 All potential ground water receptors need to be identified. These could be the drainage ditch

along the north western perimeter, ground water seepages to surface, or buried drains or ducts

that are below the water table which in turn lead elsewhere.

6.2 Knowing the rate of ground water flow and the probable concentration of the contaminant in

ground water, it is possible to quantify the risk of the contaminant to a downgradient receptor.


a Identify all potential receptors;

0 Integrate conceptual model with receptors;

0 Quantify risk.

7.0 Phase 4 - Devise Ground Water Remediation Strategy

7.1 The extent of any ground wafer contamination will be determined. A conceptual model will

have been devised. The risk to the receptors will have been quantified. The most appropriate

remediation strategy will be devised. These could be :

* Monitored Natural Attenuation

8 Pump And Treat

a Bioremediation

e Reactive slurry wall

e Or any combination of the above.

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EPA Export 25-07-2013:17:26:30


Ground Water Investigation at Schwarz Pharma Proposal Tuesday, 03 May 2005 = : :... : .::::..:,.:,: :.i : /..s.: .:i:ji:.: ,,: ..,:::::.:.::::i:/::::.: 2 . : ..:::.:n:..!-.i. :.: .::: .: -. ::.:..:. :Y~-::::::-.i:.:..: : .: : :.: -.: : :.iii_i::::/:.ii.i~:=iili: :=:, ::::: . . . . . :. :./.~il.::::: .i.::::i;/..~:,: . . .._ :: ,,,,, i^ii,i :,,: ,: ,: ,,


0 Identify the most appropriate remediation strategies

- Implement the strategies

8.0 Phase 5 - Long Term Monitoring

8.1 Once the remediation strategy or strategies are in place then long term monitoring can

commence. It is normal to monitor quarterly for the first three years. The data are constantly

reviewed and the remediation strategy modified to respond to changing conditions. Long term

trends in hydrochemistry are used to update the conceptual model. The remediation strategy is

modified to reflect any changes in the conceptual model.

8.2 On the assumption that a long term remediation strategy is required, then monitoring is

reduced to twice per year after 3 years. Again the data is constantly reviewed and the

remediation strategy and conceptual model updated to reflect the new data.

8.3 After six years, monitoring reverts to an annual frequency. Again any remediation still being

undertaken will be reviewed annually to reflect the new data.

9.0 Schedule

9.1 The schedule for the work is as follows :

Phase Activity Duration

(Months)

Phase 1 Review all existing data, devise programme of works, draw up drilling 1

and 2 specification, sampling strategies, budgets and schedules (Acttd Cost)

Drilling 10 number boreholes with an upper and lower piezometer in each 2

(including supervision of drilling, interpretation of data and reporting)

Sampling all the piezometers (including existing holes) twice 1

Budget Time For Phase 1 and 2 4

Phase 3 Identification of receptors, assessment of risk based on conceptual model, 1

quantification of risk I 1 Budget Time For Phase 3

I 1

Phase 4 Devising remediation strategy; Providing cost estimates of optimal strategies and 1

cost benefit analyses; Devising targets for remediation; Determining time scales

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EPA Export 25-07-2013:17:26:30


Ground Water Investigation at Schwarz Pharma Proposal Tuesday, 03 May 2005 .i.. .- . . .ci ::. :.,. rri: ..: ::iz7 :.: .:/ . . . . -. i ..z*=.i:i L ....i

Activity Phase I / (Months) ,

Budget Time For Phase 4 1

Phase 5 Long term Monitoring assuming quarterly for Years 1 to 3; twice yearly for Years 4

to 6; Annually for Years 7 to 10

N/A

Running costs of remediation strategy if pump and treat for 10 years (o&r strategies

do not have rmning costs)

N/A

Time Budget Phase 1 and 2 4

Time Budget Phase 3 I

Time Budget Phase 4 1

9.2 There may be considerable time between each Phase as all the options are considered and

agreed for the next Phase. The EPA need to be kept appraised of the works at all times and

there may be a time delay before they agree to the next Phase. It would be prudent to allow

between one to two months between each Phase or even between stages within Phases. Overall

it is estimated that Phase 1 and 2 would be completed between 6 and 8 months. Phase 3 and

Phase 4 could each take up to three months to complete and obtain agreement from all

interested parties.

Yours Sincerely

EurGeol Shane O’Neill PGeo Dip. CECLA

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Ground Water Investigation at Schwarz Pharma Proposal Tuesday, 03 May 2005 ,/ ,.. ,:, :,. i :. :ii ..: ::.,:.,::.:.::i:.i./:..::.. z: .,: : .: i.:i :=.: :.:i::ii:::::::~.j::::.::.:.i ~.:::.i_i..:-i..:.::..: . :..: :::i::: ._.,. .:i.:i_::::_:.:.. :&...:: ::.::...~ ::,.: j .i:.:::: .: .:,:i i::. ._:: ..-... . . ,..,.......... ._

Phase Activity Duration

(Months)

Budget Time For Phase 4 1

Phase 5 Long term Monitoring assuming quarterly for Years 1 to 3; twice yearly for Years 4 N/A to 6; Annually for Years 7 to 10

Running costs of remediation strategy if pump and treat for 10 years (ofher strategies

do not have running costs)

N/A

Time Budget Phase 1 and 2 4



9.5 There may be considerable time between each Phase as all the options are considered and

agreed for the next Phase. The EPA need to be kept appraised of the works at all times and

there may be a time delay before they agree to the next Phase. It would be prudent to allow

between one to two months between each Phase or even between stages within Phases. Overall

it is estimated that Phase 1 and 2 would be completed between 6 and 8 months. Phase 3 and

Phase 4 could each take up to three months to complete and obtain agreement from all

interested parties.

Yours Sincerely

@.@ EurGeol Shane O’Neill PGeo pip. CECLA

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EPA Export 25-07-2013:17:26:31

Air Emissions Dispersion odelllin

May 2005 Final

Issue No1 45078370

Draft Reportdoc

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EPA Export 25-07-2013:17:26:31

warz PPC Licence Air Emissions Dispersi

ation elling

The following modelling results are presented in this report:

e Modelling of organ& emissions from main emission points VE-079 and WE-001 based on the limits for organics specified in TA Luft 1986 and subsequent revisions;

(B Modelling of particulate emissions from VE-135 based on the current IPC licence maximum emission rate;

B Modelling of organics emissions from main emission points VE-079 and WE-001 based on the limits for organics specified in TA Luft 2002;

Further explanation of the history of the dispersion modelling completed for the Schwarz site is included in Section I. A summary of the findings of the modelling assessments is presented below.

The main body of this report presents the results of dispersion modelling based on the 1986 TA Luft values. Appendix A presents results based on modelling at the TA Luft 2002 emission guideline values, while an odour impact assessment, based on release of organics at the TA Luft 1986 emission limits is presented in Appendix B. The following conclusions can be drawn from the results generated as part of this modelling assessment:

o It is considered that in practice, application of the TA Luft 1986 guideline values will not result in a breach of the applied Occupational Exposure Limit (OEL) derived ground level concentration guideline values or of the applicable Danish guideline values (C-values). The worst-case modelling scenario and assumptions indicates some cases in which the C-value may theoretically be breached (for TA Luft Class II and Ill organ&) however in practice these worst-case conditions are highly unlikely to occur. It can therefore be concluded that operation at or below the TA Luft 1986 limits will not result in any significant impact;

o Modelling of emissions from the two remaining main emission points based on the maximum emissions allowed under the latest TA Luft emission limit guidelines (TA Luft 2002). indicates that, in practice, compliance with the TA Luft 2002 emission guideline values will not result in any significant environmental impact in terms of breaching either the OEL derived guideline

values or the Danish C-values for the emitted compounds;

o Modelling of emissions to determine the potential odour impact of release of Class I, II and Ill organics indicates no likely significant odour impact;

o Modelling of particulate emissions from VE-135 indicates low ground level particulate concentrations due to the release, with no likely significant impact expected on ground level particulate concentrations.

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Final

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EPA Export 25-07-2013:17:26:31

Section Page WQ

1.1. 1.2. 1.3. 1.4.

2.

0. 2.1. 2.2. 2.3. 2.4. 2.5. 2.6.

3.

4.

4.1. 4.2.

5.

5.1. 5.2. 5.3.

a 5.4.

lNTRODUCTlON .............................................................................................................. i

Background ....................................................................................................................... 1 Approach to Dispersion Modelling Exercise ..................................................................... 2 Recent Process Improvements at the Schwarz Pharma Site .......................... :. ............. .3 Outline of this Report.. ...................................................................................................... 3

MODEL DESCRIPTION AND INPUTS ............................................................................ 5

Introduction ....................................................................................................................... 5 The ADMS Model ............................................................................................................. 5 Meteorology.. .................................................................................................................... 6 Topography.. ..................................................................................................................... 9 Building Effects and Stack Parameters .......................................................................... 10 Other Assumptions.. ....................................................................................................... 12

AIR QUALITY GUIDELIPIE VALUES ............................................................................ 13

MODELLED EMISSION RATES .................................................................................... 15

Modelling Based on 1986 TA Luft Emission Limits ........................................................ 15 Modelling of VE-135 Particulate Emissions.. .................................................................. 15

MODEL RESULTS AND DISCUSSION ........................................................................ 16

Introduction ..................................................................................................................... 16 Results of Modelling Based on 1986 TA Luft Methodology ........................................... 16 Results of Particulate Emissions Modelling. ................................................................... 20 General Comments and Conclusions on TA Luft 1986 and VE-135 Particulate Emissions Assessment ................................................................................................... 21

Appendix A - Modelling Assessment Based On 2002 TA Luft Guideline values

Appendix B - Odour Impact Assessment

Draft Reportdoc Page i lay 2005 Final

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EPA Export 25-07-2013:17:26:31

Air Emissions Dispersion Modelling

Dispersion modelling of emissions from the Schwarz Pharma site was carried out by URS

as part of an application to the Environmental Protection Agency (EPA) for an IPPC licence for the Schwarz Pharma site. The application was submitted to the EPA on September 17 2004. After review of the licence application additional dispersion modelling was requested by the EPA, including some revisions to the original report and also completion of an odour impact assessment and dispersion modelling of emissions based on the guideline emission values included in TA Luft 2002. The revised report, including the odour impact assessment and the TA Luft 2002 modelling was submitted to the EPA in November 2004. Subsequent to this, production ceased at a number of buildings within the plant, resulting in cessation of organic solvent emissions from previously modelled emissions points EWE-002, EWE-003, EVE-022 and VE-135. In January 2005 the EPA then requested additional modelling as follows:

o Modelling of emissions from the remaining main emission points (VE-079 and WE-001) based on the limits for organics specified in TA Luft 1986 and subsequent revisions;

o Modelling of emissions from the remaining emissions points based on the highest measured emissions during 2004;

o Modelling of emissions from the remaining emission points based on the limits for organics specified in TA Luft 2002 (including methanol and ethanol as Class I compounds).

The above modelling was completed and submitted to the EPA in February 2005. Subsequent to this the EPA then requested that the complete licence application be resubmitted, as information in the application was considered out of date due to ongoing upgrades at the site. In relation to air emissions the upgrades at the site are highly significant, with new scrubbing systems being installed on both VIZ-079 and WE-001

main emission points, with the aim of reducing emissions of organics to level below the limits specified in the TA Luft 1986 guidelines. These upgrades are now in place at the site.

Based on the proposed changes, the dispersion modelling report has been updated, with the following modelling results now being presented in this report:

o Modelling of organics emissions from main emission points VIZ-079 and NVE-001 based on the limits for organics specified in TA Luft 1986 and subsequent revisions;

0 Modelling of particulate emissions from VE-135 based on the current IPC licence maximum emission rate;

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EPA Export 25-07-2013:17:26:31

o Modelling of organics emissions from main emission points VE-079 and NVE-001 based on the limits for organics specified in TA Luft 2002;

o Assessment of the odour impact of releases from NVE-001 and VE-079 based on worst case assumption of continuous emissions at the TA Luft 1986 emission levels;

No monitoring data is yet available from the upgraded abatement equipment (VE-079 and NVE-OOI), hence modelling of actual emission rates cannot be completed at this time. As the upgraded systems are expected to result in significantly reduced organic emissions, there is not considered to be any benefit in presenting model results based on actual emissions measured prior to the upgrade. If required, after emissions data become available, modelling based on actual emissions can be completed.

Some emissions of inorganics are expected from VE-079 (BPC emission point) and also NOx emissions from NVE-001 . Assessment of these parameters was completed as part of the licence application submitted to the EPA on September 17 2004, with emissions being modelled at the current IPC licence emission limits (assessment of actual emission levels was also carried out, indicating no significant air quality impact) which as with the organics limits, are also based on the TA Luft 1986 guideline values. NOx emissions from NVE-001 were modelled at a release concentration of 300 mg/m3 based on the current IPC licence limit for the previous nitration process emission point at Bay 130 (BVE-001). The assessment indicated no likely significant impact on ground level concentrations of inorganic compounds, with predicted concentrations being below the applied ambient air quality guideline values. This modelling has therefore not been repeated in the current report.

As part of the IPPC licence application, details are required on any air emission points. There are currently three main emission points on’the Schwarz site. For these main emission points a significant amount of information is required, including information such as the stack location, temperature of release, volume of release, duration of release, details of any abatement equipment and information on the compounds released. As the Schwarz site already holds an IPC licence, monitoring of emissions is regularly carried out and this monitoring data was employed in identifying the likely range of organic emissions, although the actual mass emission rates are not expected to be representative of emissions from the upgraded abatement equipment. The TA Luft 1986 assessment is included in the main report, while the TA Luft 2002 assessment is presented in Appendix A.

Modelling of emissions to air was completed based on the TA Luft 1986 and 2002 emission guideline values, This classifies organics into separate classes depending on their potential environmental impact. Each class includes a.mass flow threshold (e.g. in kg/hour} above which a specific concentration limit value applies.

Assessment of odour impact was carried out based on a method recommended by the UK Environment Agency in their Guidance Note IPPC H4 - Horizontal Guidance for

. .

Draft ReporLdoc Page 2 May 2005 Final

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EPA Export 25-07-2013:17:26:31

Licence Dispersi

Odour Part 1, Regulation and Permitting. The odour impact assessment is presented separately in Appendix B.

1.3. Recent Process Improve ents at the SchwaE Pharma site

The alterations made to date are expected to result in compliance with the organics emissions guideline values specified in TA Luft 1986, with further improvements also to

be made at the site. A summary of proposed and completed upgrades are presented below:

Improve condenser efficiency by upgrading utilities - completed in Nitration Plant and will be completed by 30/09/2005 in BPC Plant;

Match cooling mediums to solvents - Complete. New Low temperature cooling installed for THF and DCM;

Monthly monitoring of individual condensers - Commenced;

Control Vacuum in Distillation and drying vessels- Installation commenced in BPC and to be installed in Nitration by June 2005;

Continuous monitoring of Building process exhaust with alarms for TOC - Monitors fitted in Both Buildings;

Leak test vessels. - Commenced;

Fit vent condensers to building storage tanks - To be complete by September 2005;

Install temperature monitors on Condenser vapour outlets to limit reactor temperature - 90% of condensers fitted in BPC, to be completed by June for all zondensers in BPC and Nitration;

Upgradehstall Scrubber systems on building exhaust - this has been completed for both the nitration piant and the BPC plant. Further details on the abatement systems are included in Attachment E.1;

Improve solvent charging systems - Part of upgrade of site.

1.4. Outline of this Report

Section 2 provides a brief description of the ADMS model and the required model input data. Available air quality guideline values are presented in Section 3. Section 4 presents the TA Luft based emission values which are also used in the modelling assessment. The results of the modelling assessment are presented in Section 5.

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EPA Export 25-07-2013:17:26:31

Additional information is presented in the appendices, including a modelling assessment based on the latest 2002 TA Luft Guideline emission values (Appendix A) and an odour impact assessment in relation to the release of organics (Appendix B).

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EPA Export 25-07-2013:17:26:32

chwarz FT6 Licence Air Emissions Dispersion WIodellincl

The ADMS model is an advanced modelling system which requires a variety of input data to ensure realistic predictions of ground level concentrations due to stack emissions. Required inputs include building dimension data, terrain data, surface roughness data, source data (Stack height, diameter, flow rate, emission rates for each compound to be modelled), meteorological data and receptor data.

This assessment considers the impact of releases of substances from the stacks. No account is taken of the effect of any fugitive or accidental releases. Air dispersion models are used for calculating air pollution concentrations given information about the pollutant emissions and the nature of the atmosphere (factors affecting the dispersion and dilution in the atmosphere). The resultant pollutant concentrations can be compared with air quality standards and objectives.

The ADMS model and the required input data are discussed in the following sections.

The impact of a release on the environment will be dependent on many factors, including:

the rate of release of each substance;

other release characteristics, such as release location, release velocity and the temperature of the released material;

the physical properties of the released substance (such as its physical form or particle size);

the chemical properties of the released substances;

the nature of the receiving medium, particularly its dispersive and transfer characteristics and how these vary with time;

ambient concentrations of released substances already present in the environment;

the locations of receptors in the environment sensitive to the released substances; and

the degree of sensitivity of these receptors to enhanced concentrations of released substances.

To quantify these effects and to establish the predicted ground level concentrations of species emitted from on-site sources, URS has undertaken detailed air dispersion modelling for the site. The selected model for use in this assessment is ADMS3, produced by Cambridge Environmental Research Consultants (CERC). This model is a

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EPA Export 25-07-2013:17:26:32

chwarz !PP@ Licence ~~~~~ca~~~~ Air Emissions Dispersion Modelling

‘new-generation’ model, which represents local meteorological conditions in a more technically correct way than the older models that utilise semi-empirical stability classes. The main features of ADMS3 are:

e all on-site sources can be modelled together in the same run, to provide an integrated assessment df the whole site;

e site-specific hourly sequential meteorological data is used in the modelling assessment to provide worst-case ground level concentrations for realistic conditions;

Q meteorology is treated in a more comprehensive way than in early dispersion models, using the Monin-Obukhov length instead of the semi-empirical stability classes;

0 worst-case conditions can be modelled e.g. adverse combinations of meteorology and emissions, which could result in pollution episodes;

0 effects such as steep terrain, coastline and building effects can be taken into account;

0 model outputs can be calculated for a wide range of averaging periods and percentiles, allowing direct comparison with all relevant ambient air pollutant standards and objectives.

The ADMS3 model takes a range of parameters including stack dimensions, emission conditions and representative meteorological data, and calculates the maximum concentrations at specified intervals from the emission source using sequential computer algorithms. It is generally considered that air dispersion models are conservative models, over-predicting ground level concentrations. All results quoted in this report are the maximum values predicted by the model, and therefore in the opinion of URS represent the worst case.

The use of an advanced model such as ADMSS rather than a simpler screening model is considered the best available analytical technique and enables the incorporation of terrain and building effects on dispersion (if required).

2.3. Meteorology

Prevailing weather conditions can have a significant impact on ground level concentrations of compounds released to air from stacks. Wind speed and direction, in particular, impact the location and magnitude of the maximum ground level concentrations.

A range of meteorological parameters are monitored by Met cireann at their synoptic monitoring stations, including wind speed, wind direction, temperature, rainfall, cloud cover and humidity. There are significant variations between different stations in Ireland hence it is important that a station is chosen which is representative of the area under investigation. The Schwarz site is located directly adjacent to Shannon Airport, which is

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Air Emissions Dispersion Modellinor

also the location of a Met cireann synoptic monitoring station. Data from this site will be representative of meteorological conditions in the vicinity of the Schwarz site. In order to ensure that a range of likely meteorological conditions are included in the modelling assessment, three complete years of hourly meteorological data are included in the assessment, for 2001,2002 and 2003.

The required input parameters for the model are:

8 Wind speed;

* Wind direction;

. Temperature;

e Cloud cover;

* Month, day and hour data.

A summary of the temperature, wind speed and cloud cover data for each of the years is presented below, while wind roses for each year are included in Figures 2.1, 2.2 and 2.3. Cloud cover is measured in ‘oktas’, 0 to 8 shows the fraction, in oktas, of the celestial dome covered by all clouds.

Table 2.1: Summary of Shannon Airport meteorological data used in the assessment

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Figure 2.1: Wind rose for 2001, Shannon Airport

180” 0 3 6 10 16 (lads)

0 1.5 3.1 5.1 6.2 (nvsq


202.5' - 157.5' 180'

0 3 6 10 16 (ms)

0 1.5 3.1 5.1 8.2 (m's)

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Iieation Air Emissions Dispersio odelling


2.4.

183 0 3 6 10 16 (k~cJ.$

Topography

Local topography can have a significant impact on the dispersion of released materials. The ADMS model is capable of including topographical data, if required. There are two parameters which can be employed in the model to describe local topography, as detailed below.

This parameter is specified in all modelling assessments. Surface roughness describes

the degree of ground turbulence caused by the passage of winds across surface structures. Ground turbulence is greater in urban areas than in rural areas, for example, due to the presence of tall buildings.

The area surrounding the Schwarz includes the industrial estate itself and the airport. Based on visits to the site a surface roughness value of 0.5 metres has been chosen which is typical of suburban/parkland areas and is considered to represent typical surface roughness in the site area.

The presence of steep hills (known as complex terrain) in the vicinity of a site can effect dispersion of emissions. A gradient of 1 :lO or greater is normally taken as the criteria for inclusion of terrain in a modelling assessment. The topography in the vicinity of the site is

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2.5.

generally flat, with the exception of a steep hill (gradient > 1:40) immediately to the northeast of the site. Because of this hill it has been decided to include terrain data in the model to improve the accuracy of the model outputs.

Figure 2.3: Topography surrounding the Schwarz Site, main site buildings shown as grey rectangles

Buildings and other structures can have a significant impact on the dispersion of materials released to air. The main effect is to entrain pollutants into the cavity (leeward side) of the building, which is isolated from the main flow and in which a reversal of flow can occur. This can result in rapid grounding of undiluted plumes.

Typically buildings are considered to have an impact on dispersion if the building height is greater than 40 % of the stack height.

A number of buildings on the Schwarz site have been included in the assessment as it is considered that the buildings may have some impact on plume dispersion due to their locaiion and height. The dimensions of the buildings included in the modelling

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Schwarz Air Emi

Licence Dispersi

lication odelling

assessment are included in Table 2.2. The model representation of the buildings with respect to the air emission points are included in Figure 2.4.

Table 2.2: Dimensions for buildings included in the assessment

Chemical Buildin

The dimensions of the release points are presented in Table 2.3, including the height of *

the release point from ground level. The maximum flow values are also presented, based on the current IPPC licence flow limit for VE-079, while the maximum flow for NVE-001 is based on the maximum flow measured during 2004. The release temperature is conservatively assumed at 20% based on available monitoring data for the emission points.

Table 2.3: Stack parameters

Release Height (metres) Point

VE-079 17.44

NVE-001 19

VE-135 15

Diameter Release (metres) Temp ‘(2

0.4 20

0.267 20

1.4 20

Maximum Flow (m?hr)

7,000

549

52,000

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‘, ‘:

! .’

c Licence ~~~l~~a~~~~ Air Emissions Dispersion Modelling

Figure 2.4: Model representation of site buildings and emission points included in the

model

II

11

II

I

I'

I'

1

1

1

62520~

52500.

62480.

62460.

62440-

62420-

62400-

62380-

The modelling assessment assumes continuous emissions throughout the modelled year at the set emission rate, which for this assessment are:

* The 1986 TA tuft emission guideline values (also used for the odour impact assessment in Appendix B);

e The TA Luft 2002 emission guideline values (Appendix A);

It should also be noted that the site boilers are not included as part of this assessment. This was agreed with the EPA prior to preparation of the IPPC licence application document.

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The 1986 TA Luft limit values for organics were used as part of this modelling assessment. There are no specific air quality limit values for TA Luft organic substances as a group, though some applicable guideline values can be identified for specific compounds within these classes.

Table 3.1 below details the individual TA luft organic substances measured in emissions from the Schwarz stacks. Available guideline values and their sources are also included.

It should be noted that the Danish C-values are applicable to short-term (l-hour) periods rather than long-term averages. The Danish C-value requires that 99 % of hourly values lie within the C-value (e.g. 99 % of values over the course of a month}. Also, the Danish C-value has been developed specifically for assessment of industrial emissions and does not require any background concentrations to be added to the modelled ground level, i.e. the value is related to the contribution to ground level concentrations due to the emission rather than the actual ambient concentration. The Danish C-values are considered to be highly conservative guideline values.

It should also be noted that although the Danish C-values and OEL derived guideline values are often used in dispersion modelling assessments, they have no statutory basis in Ireland for use as air quality limit values.

Particula tes

Statutory limit values for particulate matter are specified in S.I. No. 271 of 2002. This specifies ambient air quality limits for PMIo. As emission point VE-135 is fitted with a HEPA filter, the emitted particulates will be less than IO microns in diameter, hence the PMio limit is applicable. The regulations specifies the following short-term (daily average) for PM10 as follows:

0 &hour Urnit value of 50 pglm3, not to be exceeded more than 35 times per year (90.4’h percentile limit value) up to the end of 2005;

B 24 hour limit value of 50 pg/m3, not to be exceeded more than 28 times per year from 1 January 2006, and decreasing in equal annual increments to zero allowed exceedences from 1 January 2010;

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Table 3.1: Applicable ambient air quality limiffguideline values for individual organic compounds emitted from Schwarz emission points

C0~pCWK.l Source Short-Term OH. Denmark based Guideline ’ C-value

Mm3 mlm3 I I I

TA Lwft I OrganicsL Dichloromethane VIZ079 4,350 20

TA Lwft 11 Organics

Toluene VE079, NVEOOI 4,700 400

Tetrahydrofuran VE079 2,950 200

Xylene VE079 5,525 100

Acetic Acid NVEOOI 625 100 I ,

TA Lwft II\ Organics

Methanol VE079 6,500 300

Ethanol VE079 47,500 5,000

Acetone VE079 30,250 400

IPA VE079 24,500 1,000

MIBK NVEOOI 2,075 200

Ethyl Acetate VE079 35,000 1,000

IbIAs VE079, NVEOOI 6,500* 300*

Hexane VE079 45,000 400

6% Licence ~~~~~~a~~~~ Air Emissions Dispersion Modelling

Notes: A: Value for methanol used for methylated spirits (mixture of ethanol/methanol) B: Limit values derived from long-term (8-hour) occupational exposure limits (OELs) by applying a factor of .025. OEL data from the 2002 Code of Practice for the Safety, Health and Welfare at Work (Chemical Agents) Regulations 2001; C: Classification based on TA Luft 1986 and revisions where applicable. Revised guidelines were issued by TA Luff in 2002 however the current licence limits are based on TA Luft 1986(and revisions).

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4. DELLED EMlSSlO

Modelling was completed using emission rates based on the 1986 TA Luft emission limit values. Emission rate input to the model is required in grammes emitted per second. The 1986 TA Luft emission limit values have been used to calculate the emissions rates for input to the model. In order to identify the maximum emission rate to be used for each class, the mass flow limit for each class was compared to the concentration limit multiplied by the maximum volumetric flow rate. Whichever resulted in the highest mass flow was employed in the assessment as the TA Luft maximum emission rate. The volumetric flow used for VE-079 was the current licence limit at 7,000 Nm3/hr, while the maximum flow for NVE-001 was taken as the highest flow measured during 2004 at 549 Nm3/hr.

Table 4.1: 1986 TA tuft maximum emission rates for vent VE-079

Parameter

Class I Organics

Class II Organics

Class III Organics

Emission Rate (kglhr) Emission Rate (g/s)

0.14 0.039

2.0 0.556

3.0 0.833

Table 4.2: 1986 TA Luft maximum emission rates for WE-001

-I

Parameter

Class II Organics

Class Ill Organics

Emission Rate (kg/l-w)

2.0

3.0

Emission Rate (gls)

0.556

0.833 \

4.2. Modelling of VE-I 35 Particulate Emissims

As a worst case scenario the current IPC licence emission limit for particulate emissions from VE-135 is employed in the modelling exercise. The licence specifies a concentration limit of 0.3 mglm3 and a maximum volumetric flow rate of 52,000 Nm31hour. This would result in a maximum particulate mass flow rate of 15,600 mg/hour.

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5.

Dispersion modelling results’ based on 1986 TA Luft emission guideline values are presented in Section 5.2. In all cases the modelling was carried out using three years of meteorological data and including terrain effects due to local complex terrain. Maximum predicted hourly ground level concentrations are presented for each year of the three years of meteorological data employed, with maximum daily averages presented for PM,*. Available ambient air quality guideline values (short-term OEL derived values and Danish C values) are presented where available.

The Danish C-value is developed to be compared directly to the predicted ground level concentration due to the modelled emissions (i.e. background concentrations must not be added to the predicted ground level concentrations). The Danish C-value requires 99 % compliance (i.e. 99 % of hourly concentrations within the guideline value, hence the 99” percentile of the hourly concentrations are presented as the values for comparison with the C-values).

Dispersion modelling results for particulate emissions from VE-135 are presented in Section 5.3. The concentrations are compared to applicable legislative limits as defined in SI 271 of 2002.

The results of dispersion modelling based on the 1986 TA Luft emission guideline values are presented below.

The results are presented for each TA Luft class, however in some cases the TA Luft class may contain a number of compounds with no directly comparable limit value. In these cases, as a worst case, it is assumed that the emission is represented by the compound within the group with the most stringent ground level concentration guideline value.

Modelling of emissions from VE079 and NVEOOI was carried out based on the TA Luft emission guideline values as presented in Section 4. The volumetric flow rates and release temperatures used were as reported in Table 2.3. The results of the modelling assessment are presented in Tables 5.1 to 5.3.

Modelling of TA Luft Class I Organic emissions was carried out for emission point VE- 079. The only Class I compound emitted from VE-079 is dichloromethane (DCW Results are presented in Table 5.1.

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Table 5.1: Modelled TA Luft Class I (dichloromethane) ground level concentrations based on TA Luft emission guideline values, lug/m3 Parameter 1 XW 1 2002 / 2003 ( Guideline 1

Maximum Hourly Concentration 7.63 7.50

%P of percentile hourly concentrations 5.69 5.23

Note: Maximum hourly guideline value based on OEL derived short-term limit

Value 8.55 4,350

5.59 20

The maximum hourly DCM concentration throughout the three years of applied meteorological data is significantly below (4 %) the OEL derived short-term guideline value. The 9gth percentile hourly values are also less than 30 % of the Danish C-value for DCM. The worst case predicted ground level concentrations of Class I organics are therefore not considered to be significant.

5.2.2. TA Luft Class II Organics

Modelling of Class II Organics emissions was carried out for emission points VE-079 and NVE-001.

The TA Luft Class II organics emitted from the Schwarz site are acetic acid (from NVE- OOI), xylene (from VE-079), tetrahydrofuran (from VE-079) and toluene (from VE-079 and NVE-001). Of these compounds, acetic acid exhibits the most stringent ground level concentration guideline value, with an OEL derived limit of 625 pg/m3 and a C-value of 100 pg/m3. As a worst-case approach it is initially assumed that all the TA Luft Class II emissions are acetic acid for comparison with the acetic acid guideline value.

Table 5.2: Modelled TA Luft Class II ground level concentrations based on TA Luft emission guideline values, pg/m3 Parameter 2001 2002 2003 Guideline Guideline

Value Value (Tofuerie) (Acetic

Acid) Maximum Hourly Concentration 493.63 551.65 634.34 4,700 625

99’” percentiie of hourly 180.68 176.32 187.05 400 100 concentrations

Note: Maximum hourly concentration guideline value based on OEL derived short-term acetic acid guideline

value

The short-term hourly concentration is compared to the short-term OEL derived acetic acid guideline value and the Danish C-value for acetic acid. The predicted worst-case value slightly exceeds the acetic acid OEL derived guideline value of 625pg/m3 for the 2003 meteorological data scenario, but are significantly lower for the 2001 and the 2002 scenarios. Based on the modelling exercise it can be calculated that an applied mass emission of 1.97 kg/hour (rather than the 2 kg/hour employed in the assessment) would bring the reported concentration to below the acetic acid ambient guideline value, thus the extent of the potential breach is considered to be very small. Considering the highly conservative assumption usect in the assessment, i.e. maximum TA Luft limit Class II

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emissions (considered as acetic acid) from both emission point for the complete year (8,760 hours), the actual potential for breach of the acetic acid emission is not considered significant. The likelihood of 2 kg/hour of acetic acid being emitted continuously is further assessed in the next paragraph.

The comparison of the maximum predicted ground level concentration for TA Luft Class I! organics with the acetic acid ground level concentration guideline is not considered representative for several reasons:

o Based on maximum release rate data for these emission points, the proportion of each of the TA Luft Class II compounds in the maximum measured 2004 emissions from the site are of the following order:

o Acetic Acid - 3.2 %

0 Xylene - 2.0 %

o Tetrahydrofuran - 4.6 %

o Toluene - 90.2 %

The nitration building has operated up to March 2005 with a dedicated acetic acid scrubber installed in the plant, hence the acetic acid emissions are well controlled, as illustrated in the comparative emissions data presented in the previous bullet point. Additionally. the new abatement equipment installed on the nitration plant will further reduce emissions of acetic acid (and all organics released from the plant), however even based on worst case measured emissions from last year the highest mass emission rate of acetic acid based on approximately 120 measurements carried out on NVE-001 was 0.365 kg/hour, which is significantly lower than the TA Luft Class II emission rate of 2 kg/hour employed in the model. Using a mass emission rate of 0.365 kg/hour in the model rather than 2 kg/hour would result in a maximum ground level concentration approximately 82 % lower than the maximum predicted in Table 5.2 above). The maximum emissions are expected to reduce further with the additional abatement equipment, thus in effect providing an additional treatment step for acetic acid removal.

Therefore, the use of acetic acid as a representative compound for Class II is not considered appropriate. Using toluene for comparative purposes, which exhibits the highest mass emission of all Class II organics (90.2 %) based on 2004 data, the predicted Class II concentrations are compliant as the short-term OEL guideline for Toluene is 4,700 pg/m3. The maximum hourly TA Luft Class II concentration throughout the three years of applied meteorological data is significantly below (< 30 %) the OEL derived short-term guideline for toluene.

No ambient background concentration data for toluene is available for the site area, however based on the magnitude of the predicted concentrations (c 30 % of the guideline value), exceedence of the guideline value is considered unlikely.

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The predicted 99rh percentile Class ii concentration exceeds the Danish C-value for acetic acid of 100 pug/m3 (approximately, 1.87 times above acetic acid C-value). However, when compared to the Danish C-value for toluene (400 pg/m3), the 99’h percentile class 11 concentration is in compliance.

Based on this assessment it is therefore considered that the predicted ground level concentrations will not breach the OEL derived guideline values or the Danish C-values for any of the emitted Class II compounds.

52.3.

Modelling of Class Ill Organics emissions was carried out for emission points VE-079 and NVE-001 .

TA Luft Class III organics emitted from the VE079 and/or NVE-001 are methanol (VE- 079), ethanol (VE-079), acetone (VE-079), IPA (VE-OTS), hexane (VE-079), MIBK (NVE- 001 ), ethyl acetate (VE-079) and IMS O/E079 and NVE-001 ).

Of these compounds, MIBK exhibits the most stringent ground level concentration guideline value, with an OEL derived limit of 2,075 ,ugim3 and a C-value of 200 pg/m3. AS

a worst-case approach it is initially assumed that all the TA Luft Class Ill emissions are MIBK for comparison with the MIBK guideline value.

Table 5.3: Modelled TA Luft Class Ill ground level concentrations based on TA Luft emission guideline values, pug/m3 Parameter 2001 2002 2003 Guideline Guideline

Value Value (Acetone) (MIBK)

Maximum Hourly Concentration 740.44 827.47 951.51

9grn percentile of hourly 271 .Ol 264.47 280.58 concentrations

30,250 2,075

400 200

Note: Maximum hourly guideline value based on OEL derived shoe-term MIBK guideline value

The predicted maximum hourly Class Ill concentration is below the short-term OEL derived guideline for MIBK and also the guideline values for the other identified Class III organic compounds. Although the predicted concentrations do not include any background contributions, based on the low predicted concentrations breach of the limit is not considered likely.

The 99” percentile Class III organics concentration is above the Danish C-value for MIBK (approximately 1.40 times the MIBK C-value). The predicted concentration is below the the C-value for all other compounds (methanol, IMS, ethanol, acetone, Isopropyl alcohol, ethyl acetate and hexane). In reality the situation will not arise where 100 % of TA Luft Class III emissions from the identified stacks (NVE-001 and VE-079) will consist of 100 % MIBK, based on the following reasons:

e MIBK is released only from emission points NVE-001;

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e Based on maximum release rate data for the site (from 2004) the proportion of each of these compounds in the emissions from the site are:

o Methanol - 3.6 %;

o Ethanol - 2.1 %;

o Acetone - 48.9 %;

o Hexane - 7.2 %

o IPA- 15.3 %;

o MIBK - 9.9 %;

o Ethyl Acetate - 9.9 %;

o Industrial Methyiated Spirits (methanol/ethanol) - 3.1 %

B MIBK is released only from emission points NVE-001.

The above data indicates that the dominant emissions is most likely to be acetone, though it is expected that emissions of all compounds will be reduced significantly when compared to 2004 emissions monitoring, due to the installation of additional abatement on both the BPC and the Nitration plant emissions points.

When assumed that all the Class III emissions are acetone, the predicted 9gth percentile Class Ill concentration complies with the acetone Danish C-value of 400 pg/m3.

Based on the review of the 2004 data, it is considered that in practice the predicted ground level concentrations will not breach the OEL or the Danish C-values for any of the emitted Class III compounds. It should also be noted that reductions in emissions are expected due to the installation of new abatement equipment on both MVE-001 and VE- 079.

Modelling of particulate emissions from the Pharma Plant (emissions point VE-135) was completed based on the current maximum IPC licence emission limit. Ambient air quality limits for PMIO are reported in Section 3.

The results of the modelling assessment are presented in Table 5.4.

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ehwxz IPPC Licence Air Emissions Dispersion Modelling

5.4.

Table 5.4: Predicted ground level impact of particulate release from VE-135, pug/m3

Parameter 200’! 2002 2003 Limit Value

90.4’” Percentile 24 how concentration 0.13 0.13 0.13 50

Maximum 24 hour Concentration 0.30 0.35 0.27 50

Note: Maximum 24-hour concentration limit value only after 2010 {see Section 3)

The results presented in Section 5.4 do not consider background concentrations. However, the contribution from the VE-135 emissions to the ground level concentrations is low (< 0.3 % of the limit for the 90.4fh percentile results) and would have no significant impact on ground level particulate concentrations. The maximum daily average concentration is also low and again would not be expected to have any significant impact on ambient particulate concentrations or on local compliance with the limit value.

Based on the results presented above the impact of particulate emissions from VE-135 is considered to be insignificant..

General Comments and Conclusions on TA bu Particulate Emissions Assessmernt

URS Ireland has completed a conservative dispersion modelling assessment of emissions from the Schwarz Plant based on the 1986 TA Luft emission guideline values.

Modelling of 1986 TA Luft emission guideline values indicates that in practice, compliance with the TA Luft 1986 Limits will not result in exceedance of the OEL derived guideline values and is also unlikely to result in a breach of the Danish C-value. The conservative modelling assessment does indicate that continuous release of acetic acid at 2 kg/hour may potentially result in a 4.4 % exceedence of the OEL derived limit value (i.e. at a theoretical continuous emissions of 1.97 kg/hour or less the limit would not be breached). In practical terms, however, breach of the acetic acid limit is not considered likely. ’

New abatement equipment has been installed on emission point VE-079 and NVE-001, which are expected to result in emissions significantly below the TA Luft 1986 guideline values. Further modelling of actual emissions can be completed, if required by the EPA, once sufficient monitoring data becomes available to allow representative emissions data to be derived.

Modelling of particulate emissions from VE-135 indicates no likely significant impact on ground level particulate levels due to the emissions.

Based on the results of this modelling assessment it is therefore considered that actual emissions from the site are unlikely to have any significant environmental impact on the surrounding area, with actual ground level concentrations of organics likely to reduce with the installation of improved abatement on both solvent emission points.

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__

warz PPC Licence Air Emissions Dispersion Modellina

Draft Reporidoc

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Results and conclusions for the TA Lufi 2002 emissions assessment and the odour impact assessment are presented in Appendix A and B, respectively.

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Appendix A - Modelling Assessment Base On 2002 TA Luft Guideline values

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Appendix A- Modelling Assessment Based on TA kuft 2002 Limits

This section aims to assess the potential impact of emissions based on compliance with the organics emissions limits specified in TA Luft 2002 guidelines. The limits are presented below, with results and conclusions presented in Section A.3.

The latest TA Luft emission limits were published in 2002, ‘First General Administrative Regulation Pertaining the Federal lmmission Control Act (Technical Instructions on Air Quality Control - TA Luft)‘. In relation to the emissions from the Schwarz site, the guidance document contains revised guideline values for organics, inorganics and particulates. These are summarised briefly below.

Organic Substances

The classification system for organics in TA Luft 2002 has changed from that specified in TA Luft 1986. Section 5.25 of the guidelines states that with regard to organic substances contained in waste gas, except organic particulate matter:

A total mass flow of 0.50 kg/hour

Or

A total mass concentration of 50 mg/m3

Each of which to be indicated as total carbon, may not be exceeded.

There are also specific limits for Class I and Class II organic substances as defined in TA Luft 2002. Class I and Class II concentrations may not exceed the following mass concentrations or mass flows in waste gases, each of which to be indicated as mass of organic substances:

Mass flow 0.10 kg/hour

Or

Mass concentration 20 mg/m3.

c/ass II

Mass flow 0.50 kg/hour

Or

Mass concentration 0.10 g/m3.

TA Luft 2002 provides a partial list of compounds categorised in Class I, with a complete list (IO compounds) for Class Ii compounds. Criteria for classification of Class I compounds is also provided. It is assumed that any compound not

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categorised in Class l or Class II need only comply with the total organic substances emission limit as detailed above.

Classification of the compounds emitted from the Schwarz site was carried out based on the criteria in the TA Luft 2002 guidelines. No Class II compounds were identified in the Schwarm organics emissions, with the following classified as Class I:

o Dichioromethane (emitted from VE-079);

o Toluene (emitted from VE-079 and NVE-001);

o Methanol (emitted from VE-079);

o Ethanol (emitted from VE-079);

o IMS (emitted from VE-079 and NVE-001).

The remainder of the organic compounds therefore need to comply with the 50 mgC/m3 limit if the mass flow is above 0.50 kgC/hour.

A.2 Modelling lblethodology

The modelling methodology for each emission point is discussed below. In the modelling assessment the flow rate, stack diameter, stack height and temperature characteristics are as detailed in Table 2.3, i.e. identical to the modelling assessment in the main report. The buildings included in the assessment are as reported in Table 2.2. The terrain data employed in the modelling assessment detailed in the main report is also employed in this assessment.

Therefore, the only variation between the modelling assessment detailed in the main report and the current assessment is the mass emission rates as described below (and summarised in the following table). The data in this table is based on the TA Luft mass emission limit or the concentration limit, based on whichever results in the highest mass flow from the stack as explained in the following sections.

Table A.1 : Summary of mass emission data employed in modelling exercise

Parameter

General Organics (kgC/hour)

Class I Organics (kg/hour)

VE-079 tdVE-009

0.5 0.5

0.14 0.10

A.2.1 VE-079

Organic compounds emitted from this emission point are DCM, toluene, methanol, ethanol and IMS (all Class I), and tetrahydrofuran, xylene, acetone, IPA, hexane and ethyl acetate (general organics limit applies).

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The maximum flow rate from this stack is reported at 7,OOONm”Ihr. The maximum Class I mass emission from this stack would occur at the Class I concentration limit of 20 mg/m3, giving a mass flow of 0.14 kg/hour. This value is therefore employed in the modelling assessment as a worst case emission scenario.

In terms of the general organics emissions limit of 50 mgC/m3, this would result in a mass flow of 0.35 kgC/hour at 7,000 Nm3/hour. This is below the maximum allowed mass flow of 0.5 kgC/hour, hence the value of 0.5 kgC/hour is employed in the modelling scenario as a worst case emission scenario.

A.22 NVE-001

Reported organic emissions from this stack are toluene and IMS {Class I) and acetic acid and MIBK (general organics limit applies).

The maximum flow rate from this stack is reported at approximately 549 Nm3/hr (based on 2004 monitoring data). At the maximum Class I concentration limit, the Class I-mass flow would be 0.011 kg/hour. This is below the mass flow limit of 0.1 kg/hour hence this higher mass flow rate is employed in the assessment as a worst case emission scenario.

In terms of the general organics emissions limit of 50 mgC/m3, this would result in a mass flow of 0.027 kgclhour at 549 Nm3/hour. This is below the maximum allowed mass flow of 0.5 kgC/hour, hence the value of 0.5 kgC/hour is employed in the modelling scenario as a worst case emission scenario.

A.3 Results & Conclusions

A.3.1 Class I Organics

Class 1 organics emissions were modelled from emission Point VE-079 and NVE-001. The stack parameters employed were as detailed in Table 2.3 of the main report, while the Class I emission rates used were as detailed in Section A.2.

The worst-case short-term ground level concentrations are reported in Table A.2 below. As a worst-case assumption, ground level Class I concentrations are compared to the Class I compound with the lowest guideline limit value as detailed in Table 3.1 of the main report. In this case the chosen compound is dichloromethane (DCM).

The assessment conservatively assumes emissions from the stack at the maximum TA Luft rate throughout the course of each year, thus the results are considered highly conservative. The maximum predicted concentration for each year of meteorological data is below the OEL derived limit value for DCM, while the predicted 9gth percentile value is below the Danish C-value for DCM. No significant impact is therefore predicted.

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Table A.2: Worst-case short-term ground level Class I organics concentrations,

m/m3

Parameter 2001 2002 2003 OEL C-Value based Limit

100’” percentile 10.5 10.0 11.5 4,350 hourly concentration

99’” percentile hourly concentration

5.8 5.7 5.8 20

A.3.2 General Organics

General organics emissions were modelled from emission point VE-079 and NVE-001. The stack parameters employed were as detailed in Table 2.3 of the main report, while the general organics emission rates used were as detailed in Section A.2.

The worst-case short-term ground level concentrations are reported in Table A.3 below. As a worst-case assumption, ground level General Organics concentrations are compared to the organic compound (excluding Class I compounds) with the lowest guideline limit value as detailed in Table 3.1. In this case the chosen compound is acetic acid.

The assessment conservatively assumes emissions from all the stacks at the maximum TA Luft rate throughout the course of each year, thus the results are considered highly conservative. The maximum predicted concentration for each year of meteorological data is below the OEL derived limit value for acetic acid, while the predicted 9gth percentile value is above the Danish C-value for acetic acid. In reality acetic acid is released only from the nitration plant (NVE-001) and will not form 100 % of the predicted ground level concentrations. Other compounds are likely to be more dominant, i.e. acetone. This compound has higher ground level concentration guideline values (see Table 3.1) hence in practice the guideline values are unlikely to be breached for the individual compounds. Review of actual emissions monitoring data for 2004 indicates the following relative organics release rates (% of maximum measured 2004 mass release to air):

o Acetone - 51.4 %;

o Acetic Acid - 1.3 %;

o MIBK - 10.5 %;

o Ethyl acetate - ‘IO.4 %;

o THF - 1.9 %;

o Xylene - 0.8 %;

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o IPA-16.1 %;

o Hexane - 7.6 %.

Based on the figures above the assumption that 100 % of the emissions are acetic acid is overly conservative and cannot reasonably be assumed in this case. Assuming the predicted ground level concentrations are composed of the above compounds in the same relative proportions the Danish C-values would not be breached.

Based on the conservative assumptions employed in the modelling exercise (including the assumption that all stacks release at the maximum TA Luft 2002 rate) no significant impact is therefore predicted.

Table A.3: Worst-case short-term ground level General Organics concentrations, pglrn’ (assuming all general organics present as acetic acid)

Parameter 2004 2002 2003 OEL Limit

C-Value

100’” percentile hourly concentration

99” percentile hourly concentration

310.5 344.8 396.5 625

113.4 110.6 116.9 100

A.3.3 General Conclusions

Emissions modelling based on the TA Luft 2002 guidelines was carried out for NVE-001 and VE-079, the two main organics emission points currently operating at the Schwarz site. Modelling of Class I organics emissions indicated compliance with the relevant guideline values. Modelling of general organics indicated that the likely ground level concentration and organics composition would be within the OEL derived guideline values. If all general organics emissions were assumed to be acetic acid there is potential for exceedence of the Danish C-value for acetic acid, however in practice acetic acid emissions of this magnitude will not take place. No significant impact due to organics emissions is therefore likely.

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f’ - ! : . . . ,’

Schwarz IPPC Licence Application Air Emissions Dispersion Modeliing

DraftReportdoc

May2005

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Appendix 5 - Odour Assessment

The criteria for assessment of odour nuisance is based on the 98’h percentile value of a complete year of hourly predicted ground level concentrations in line with both Irish (EPA, 2001) and UK Guidelines (Environment Agency, 2002). The relationship between odour exposure and annoyance has been established in a number of epidemiological studies upon which the following benchmarks are based. However, the limit value for this exposure criteria can vary depending on the compound(s) under investigation. The UK Environment Agency base the indicative odour criterion on the relative ‘offensiveness’ of the odour as follows:

o High offensiveness: I .5 O&/m3 98” percentile;

o Medium offensiveness: 3.0 O&/m3 98’h percentile;

o Low offensiveness: 6 O&/m3 98’h percentile.

High ‘offensiveness’ odours can include those from facilities dealing with putrescible waste, creameries, fat and grease processing, oil refining and wastewater treatment facilities. Low ‘offensiveness’ odours include chocolate manufacture, coffee roasting, fragrances and flavourings and bakeries. Those which fit into neither of these categories are medium ‘offensiveness’ sources such as sugar beet processing facilities.

The description of typical odour sources given above for high offensiveness odour sources (e.g. wastewater treatment plants) is not considered similar to the odour types which may be expected in relation to air emissions from the main point source emissions at the Schwarz site (i.e. mainly organic solvent odours). For the purposes of this assessment the potential odour emissions from the Schwarz site are considered as medium offensiveness. There are no reduced sulphur compounds or amines in the point source releases from the Schwarz site. The assessment does not consider fugitive emissions from the site.

The odour threshold concentration values presented below (Table B.l) for the range of released solvents can be assumed equal to 1 odour unit per cubic metre (1 OUElm3).

This assessment does not consider the effect of mixtures of compound on odour impact, only at the potential for individual compound airborne concentrations to result in an odour nuisance, as it is difficult to estimate whether a number of separate odours will have a synergistic odour impact. In addition this assessment examines odour impact under worst case release conditions, which in practice is unlikely to occur for all compounds at the same instance and the same location, hence the investigation of the impact of individual compounds only has been completed.

It should also be noted that background odour concentrations are not required to be added to the predicted odour concentration, as the UK Environment Agency Technical Guidance Note IPPC H4 (Horizontal Guidance for Odour) states that the human brain has a tendency to screen out odours which are always present, hence odour impact assessment are based more on intermittent or fluctuating

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odour levels, where a change in the concentration of a particular compound will

lead to a perception of odour.

The airborne concentration of a compound at which the odour of that compound can be detected is known as the odour threshold. Odour thresholds can be determined using recognised test methodologies. Odour assessment is typically based on olfactometry, where a sample of gas is collected and tested by an odour panel at various levels of dilution with clean air (no perceptible odour). The odour threshold is typically based on the concentration that leads to a perception of odour for 50 % of the test panel.

The sensitivity to odour can vary significantly between individuals, hence odour threshold values only give an indication of the airborne concentration at which an odour will be detected. Odour thresholds reported by different organisations can be significantly different, however for the purposes of this assessment the lowest identified odour thresholds are employed, this is considered to be a highly conservative approach. The odour thresholds used are reported below. The reported concentration can be considered to be equivalent to 1 OUe/m3.

Table 8.1: Odour thresholds for emitted compounds from the Schwarz site

r Compound Threshold bg/m3)

Dichloromethane 3,420*

Toluene 644*

Tetrahydrofuran 90,000B

Yylene 78*

Acetic Acid 43*

Methanol 4,300e

Ethanot 280*

Acetone 13,900”

IPA 1,185*

MIBK 540*

Ethyl Acetate 2,41 O*

Bromine 6,540L

Ammonia 5ooB

Hexane

HCI

Information Sources:

230,000’

1 ,490”

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0 A: UK Environment Agency Technical Guidance Note IPPC H4 - Horizontal Guidance for Odour;

0 6: Handbook of Environmental Data on Organic Chemicals (2”d Edition); * C: www.gtz.de 0 D: vww.intox.orgldatabanWdocumentsl chemical/hydrocha/ciel3.htm

B.3 lwethodology & Results

Dispersion modelling was carried out based on the TA Luft 1986 maximum allowed emission rates as described in Section 4 of the main report. The model was set up to calculate the 98’h percentile ground level concentration values. These results are presented in Section B.3.1. The 98ti percentile ground level concentrations are presented in terms of odour units (OU,/m3) rather than as pg/m3 concentrations, this allows easier comparison with the criteria presented in Section B.l .

The modelling assessment was completed in terms of emissions of TA Luft Class I, II and III compounds, however no specific odours limits can be derived for this class as a whole, therefore the compound within each class with the lowest odour threshold is taken as representative of that class, again this is a highly conservative assumption:

Q Class I representative compound: Dichloromethane (3,420 pg/m3);

e Class II representative compound: Acetic acid (43 pglm3);

e Class Ill representative compound: Ethanol (280 pg/m3).

B.3.1 Results Based on TA Luft 1986 emission rates

The 98th percentile values ground level concentration values (as odour units) are presented below in Table B.2 (assuming all of each TA Luft Class is represented by the compounds as described above) based on release from both stacks at the maximum emission rate as specified in TA Luft 1986. The modelled scenarios are identical to those in the main report except that the 98rh percentile value has been calculated (and converted into odour units) rather than the maximum or the 9gth percentile values.

Table B.2: 98fh percentile off-site ground level concentrations

Parameter (98th percentile values for each year) Class I Organics Class II Organics Class I11 Organics

Worst case 2001 2002 2003 Compound O&/m3 O&/m3 O&/m3

DCM 0.001 0.001 0.001 Acetic Acid 3.4 3.2 3.5

Ethanol 0.8 0.7 0.8

Assuming a medium offensiveness odour criteria of 3.0 OUs as presented in Section B.l it can be seen immediately that Class I and Class III compounds worst case concentrations are both less than 1 OUE/m3, which is well below the specified criteria of 3 OU,/m3. For Class II, the results show that under the worst

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case assumptions of continuous emissions over the entire year of 2 kg/hour of acetic acid from both stacks, the worst case odour concentration may exceed the criteria by up to 0.5 OUE/m3. However, in practice the above scenario is unlikely, particularly when considered that even without the recently upgraded abatement system, the highest measured acetic acid emission during 2004 was 0.365 kg/hour (based on 120 measurements, with no acetic acid from the BPC plant). Further consideration of the relative emission levels of acetic acid is presented in Section 52.2 of the main modelling report.

The second most odorous Class II compound (xylene) emitted under the same conditions (2 kg/hour continuously) would result in a worst case odour concentration of 1.9 OUE/m3. Based on historical results by far the most dominant class II compound {in terms of mass emissions) is toluene. Again, based on continuous emissions of 2 kg/hour of toluene from both stacks, the worst case expected odour concentration of 0.2 OUE/m3.

In practice, based on the odour assessment criteria proposed above, there is not considered to be any likely significant potential odour impact at locations in the vicinity of the Schwarz site.

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Ref: 45078370

June I,2005

Dermot Hanrahan Schwatz Pharma Shannon Co. Clare

Re: Application of TA Luft 1986 to Nitration Plant

Dear Dermot:

1.0 Introduction

As requested I have prepared a short report below on the applicability of the TA Luft 1986 emission limits for organics to the ongoing operation of the nitration plant. This is based on the modelling completed in February 2005 and background information can be found in the February 2005 report if required. Limited additional modelling of emissions from NVE-001 was also carried out for the purposes of this assessment.

The purpose of this assessment is to identify emission levels for the nitration plant at which the Occupational Exposure Limit (OEL) derived ground level limit value would not be breached. The results from the February 2005 report are discussed in this context in the discussion below.

No specific references have been made to application of TA Luft 1986 limits to the BPC plant as limits already apply in the current IPC licence.

All emissions data for the TA Luft 1986 emissions scenario are as reported in the February 2005 report (e.g. volumetric flow rate for NVE-001 taken as 549 Nm3/hour).

2.0 Assessment of February 2005 Report

TA Luft Class I Organics

No TA Luft Class I organics are emitted from the nitration plant, hence there is no requirement to apply Class I limits to NVE-001 emissions.

TA Luff C/ass /I Organics

The TA Luft Class II organics emitted from NVE-001 are acetic acid and toluene. Toluene is also emitted from the BPC plant, though 2004 emissions measurement data indicates that toluene

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emissions from NVE-001 are significantly higher than from VE-079 (BPC emission point). Modelling of TA Luft Class II compounds from NVE-OO’l only (i.e. excluding VE-079 emissions) indicates that the hourly maximum and 99’” percentile ground level concentrations are the same as those reported in the February 2005 report for TA Luft Class II emissions from both VE-079 and NVE-001, indicating the area of maximum impact due to emissions from NVE-001 is not impacted by emissions from VE-079. The results are detailed in Table 1 below.

Of these compounds, acetic acid exhibits the most stringent ground level concentration guideline value, with an OEL derived limit of 625 pg/m3 and a C-value of 100 pg/m3. The ground level concentration guideline values for toluene are also included in Table 1. The results indicate that if it is assumed that all Class II emissions from NVE-001 are acetic acid, and emissions are at the maximum allowed TA Luft mass emission rate (2 kg/hour) throughout the year of applied meteorological data, there is potential for breach of the OEL derived acetic acid concentration for the 2003 meteorological data, though the predicted worst-case concentrations are below the acetic acid guideline value for both the 2001 and 2002 meteorological data.

Reducing the maximum allowed TA Luft Class II emissions from 2 kg/hour to 1.9 kg/hour will result in a 5 % reduction in worst-case ground level concentrations, assuming other all other factors remain the same, thus the emission limit can be ‘factored’ to ensure that the OEL derived limit would not be breached based on the modelling data. Based on the maximum predicted concentration in Table 1 (of 634 g/m3), application of a maximum emission limit of 1.9 kg/hour would reduce the ground level concentration value for 2003 to 602 pg/m3, which is below the OEL derived guideline values. This would also reduce the 99* percentile values reported in Table 1, but would not reduce them to below the Danish C-value for acetic acid.

Table 1: Modelled TA Luft Class II ground level concentrations based on TA Luft emission guideline va’ luc ~3, pglm”

Parameter 7

Maximum Hourly Concentration

99’” percentile of hourly concentrations

Note: Maximum hourly concentration guide1

TA Luft C/ass 111 Organics

2001

493.63

2002

551.65

176.31

l- ? value oased on OEL

2003

634.34

187.05

!rived

Guideline Value

(Toluene)

4,700

Guideline Value

(Acetic Acid) 625

400

. . . .

100

zrm acetic acla guideline value

TA Luft Class III organics emitted from the NVE-001 are MIBK and IMS, with IMS also being released from VE-079. Modelling of TA Luft Class Ill compounds from NVE-001 only (i.e. excluding VE-079 emissions) indicates that the hourly maximum and 9gth percentile ground level concentrations are the same as those reported in the February 2005 report for TA Luft Class III emissions from both VE-079 and NVE-001, indicating the area of maximum impact due to emissions from NVE-001 is not impacted by emissions from VE-079. The results are detailed in Table 2 below.

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:.*

Of the Class III compounds emitted from NVE-001, MlBK exhibits the most stringent ground level concentration guideline value, with an OEL derived limit of 2,075 ug/m3 and a C-value of 200 ug/m3. The guideline values for IMS (methanol limit employed) are also included in Table 2.

The results in Table 2 indicate that under the modelled conditions of continuous emissions from NVE-001 at the TA Luft Class III limit (3 kg/hour) the OEL derived guideline value for MIBK is not breached. The Danish C-value for MIBK is breached based on the model data, though the predicted concentrations are below the C-value for IMS.

Table 2: Mod-elled TA Luft Class III ground level concentrations based on TA Luft emission guideline values, pglm’

Parameter 2001 2002 2003 Guideline Guideline Value Value WW (MIBK)

Maximum Hourly Concentration 740.44 827.47 951.51 6,500 2,075


271 .Ol 264.47 280.58 300 200

Note: Maximum hourly guideline value based on OEL derived short-term MIBK guideline value

3.0 Discussion & Conclusions

The assessment above indicates that under the conservative conditions applied in the modelling scenario, in order to comply with the OEL derived ground level concentration guideline values a reduction is required in the TA Luft Class II organics mass emission limit of 2 kg/hour, with a limit of 1.9 kg/hour resulting in compliance for all modelled data. No changes are required in the TA Luft Class III organics mass emission limit in order comply with the OEL derived limit for emitted Class III compounds.

Compliance with the Danish C-values would require further reductions in the emission limits, however the C-values are typically considered to be highly conservative ground level concentration values, which in conjunction with the highly conservative modelling approach results in modelled

l breaches of the C-values. This is illustrated further in the February 2005 report, with even the implementation of TA Luft 2002 emission limits resulting in a breach of the C-values based on general organics emissions.

It is therefore recommended that emission limits be put in place for TA Luft Class II which would result in compliance with the OEL derived limit value. No changes are required in the TA Luft Class III emission limit in order to ensure compliance with the OEL derived limit values.

In practice it is expected that emissions from the nitration plant, with the new scrubbing system installed, should result in emissions below the TA Luft emission limits, hence actual ground levels concentrations are likely to be lower than the worst-case concentrations predicted above.

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Sincerely,

URS Ireland Limited

Dr. Ian Marnane Project Manager

Gerard Kelly Project Direct&

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:;

-,i’ ; j

: ,/,

” i

;::.,“~

l

Schwari Application

Air Emissions Dispersion Modelling of the Thermal Qxid isers

June2005

Issue No 1 45078370

TO ADM Draft Report.doc

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Schwarz IPPC Licence Application Air Emissions Dispersion Modelling of the Thermal Oxidisers

Project Title:

Report Title:

Project No:

Report Ref:

Status:

Client Contact Name:

Client Company Name:

Issued By:

Schwarz IPPC Licence Application

Air Emissions Dispersion Modelling of the Thermal Oxidisers

45078370

Draft

lvor Wills

Schwan Pharma Ltd.

URS Ireland 4th Floor, lveagh Court 6 - 8 Harcourt Road Dublin 2

Document Production I Approval Record

issue No: Name 1

Signature Date Position

Prepared by

Checked by

Irene Baker 20/06/05

Gerard Kelly 20/06/05

Environmental Consultant

Principal Environmental Consultant

Approved by

Fergus Hayes 20/06/05 Project Director

Document Revision Record

Issue No 1 Date Details of Revisions

I 1 I 15106105 I Original issue

I

TO ADM Draft Reportdoc

June 2005

Draft

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LIMITATION

URS has prepared this Report for the sole use of Schwarz Pharma Ltd. in accordance with the Agreement under which our services were performed. No other warranty, expressed or implied, is made as to the professional advice included in this Report or any other services provided by us. This Report may not be relied upon by any other party without the prior and express written agreement of URS. Unless otherwise stated in this Report, the assessments made assume that the sites and facilities will continue to be used for their current purpose without significant change. The conclusions and recommendations contained in this Report are based upon information provided by others and upon the assumption that all relevant information has been provided by those parties from whom it has been requested. Information obtained from third parties has not been independently verified by URS, unless otherwise stated in the Report.

* COPYRIGHT

0 This Report is the copyright of URS Ireland Limited. Any unauthorised reproduction or usage by any person other than the addressee is strictly prohibited.

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CONTENTS

Section Page No

1.

1.1. 1.2. 1.3.

2.

2.1. 2.2.

0 2.3. 2.4.

’

2.5. 2.6. 2.7.

3. AIR QUALITY GUlDELlNE VALUES ............................................................................ 12

4.

4.1. Introduction ..................................................................................................................... 14 4.2. Results ............................................................................................................................ 14 4.3. Conclusions .................................................................................................................... 17

INTRODUCTION .............................................................................................................. -I

Background.. ..................................................................................................................... 1 Approach to Dispersion Modelling Exercise ..................................................................... 1 Outline of this Report.. ...................................................................................................... I

MODEL DESCRIPTION AND INPUTS ............................................................................ 3

Introduction ...................................................................................................................... .3 The ADMS Model ............................................................................................................. 3 Meteorology ...................................................................................................................... . Topography ....................................................................................................................... 7 Building Effects and Stack Parameters ............................................................................ 8 Modelled Emission Rates ............................................................................................... 10 Other Assumptions ......................................................................................................... 1 I

MODEL RESULTS AND DISCUSSION ......................................................................... 14

Appendix A - Relevant emission limit values in WID and TA Luft 2002.

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Schwarz SPPC Licence Application Air Emissions Dispersion Modelling of the Thermal Oxidisers

1. INTRODUCTION

1.1. Background

URS Ireland was requested by Schwarz Pharma, Schwarz, to complete dispersion modelling of emissions from two proposed thermal oxidisers on the Schwarz site. The two thermal oxidisers will be associated the nitration plant (NVE TO) and bulk pharmaceutical chemicals building (BPC TO). Initial specifications have being drawn up for the thermal oxidisers and this forms the basis of the information used in this report. It is anticipated that the thermal oxidisers will be installed in 18 months.

This modelling assessment has been requested by Schwarz as part of work currently being carried by URS in relation to the application to the Environmental Protection Agency (EPA) for an IPPC licence.

1.2.

1.3.

Approach to Dispersion Modelling Exercise

This assessment aims to determine the impact of emissions to air from the two thermal oxidisers, NVE TO and BPC TO. In order to model these emission points a significant amount of information is required, including information such as the stack location, temperature of release, volume of release, duration of release and information on the compounds released.

Modelling of emissions to air was completed based on the 2000/76/EC Waste Incineration Directive (WID), Annex 5, half-hourly average emission guideline values with the exception of VOC emissions from the NVE TO which was based on TA Luft 2002 emission guideline values as per EPA agreement. These emission concentrations are outlined in Section 2.6.

In order to ensure a thorough assessment of the potential emissions from the two thermal oxidiser stacks, the following information was employed in the modelling assessment:

o 3 years of hourly meteorological data;

o Local terrain data.

The predicted ground level concentrations for each of the compounds from the two thermal oxidiser stacks are then compared to applicable ambient air quality guideline values.

Outline of this Report

Section 2 provides a brief description of the ADMS model and the required model input data. Section 2 includes the WID based emission values and the TA Luft 2002 based VOC emission value which are used in the modelling assessment. Available air quality

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Schwarz IPPC Licence Application Air Emissions Dispersion Modellinn of the Thermal Oxidisers

guideline values are presented in Section 3. The results of the modelling assessment are presented in Section 4.

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2. MODEL DESCRIPTION AND INPUTS

2.1. Introduction

The ADMS model is an advanced modelling system which requires a variety of input data to ensure realistic predictions of ground level concentrations due to stack emissions, Required inputs include building dimension data, terrain data, surface roughness data, source data (Stack height, diameter, flow rate, emission rates for each compound to be modelled), meteorological data and receptor data.



2.2. The ADMS Model










To quantify these effects and to establish the predicted ground level concentrations of species emitted from on-site sources, URS has undertaken detailed air dispersion modelling for the site. The selected model for use in this assessment is ADMSS, produced by Cambridge Environmental Research Consultants (CERC). This model is a

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2. MODEL DESCRIPTION AND INPUTS

2.1. Introduction

The ADMS model is an advanced modelling system which requires a variety of input data to ensure realistic predictions of ground level concentrations due to stack emissions, Required inputs include building dimension data, terrain data, surface roughness data, source data (Stack height, diameter, flow rate, emission rates for each compound to be modelled), meteorological data and receptor data.



2.2. The ADMS Model










To quantify these effects and to establish the predicted ground level concentrations of species emitted from on-site sources, URS has undertaken detailed air dispersion modelling for the site. The selected model for use in this assessment is ADMSS, produced by Cambridge Environmental Research Consultants (CERC). This model is a


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‘new-generation’ model, which represents local meteorological conditions in a more technically correct way than the older models that utilise semi-empirical stability classes. The main features of ADMS3 are:

all on-site sources can be modelled together in the same run, to provide an integrated assessment of the whole site;

site-specific hourly sequential meteorological data is used in the modelling assessment to provide worst-case ground level concentrations for realistic conditions;

meteorology is treated in a more comprehensive way than in early dispersion models, using the Monin-Obukhov length instead of the semi-empirical stability classes;

worst-case conditions can be modelled e.g. adverse combinations of meteorology and emissions, which could result in pollution episodes;

effects such as steep terrain, coastline and building effects can be taken into account;

model outputs can be calculated for a wide range of averaging periods and percentiles, allowing direct comparison with all relevant ambient air pollutant standards and objectives.

2.3.

The ADMS3 model takes a range of parameters including stack dimensions, emission conditions and representative meteorological data, and calculates the maximum concentrations at specified intervals from the emission source using sequential computer algorithms. It is generally considered that air dispersion models are conservative models, over-predicting ground level concentrations. All results quoted in this report are the maximum values predicted by the model, and therefore in the opinion of URS represent the worst case.

The use of an advanced model such as ADMS3 rather than a simpler screening model is e considered the best available analytical technique and enables the incorporation of

terrain and building effects on dispersion (if required).

Meteorology

Prevailing weather conditions can have a significant impact on ground level concentrations of compounds released to air from stacks. Wind speed and direction, in particular, impact the location and magnitude of the maximum ground level concentrations.

A range of meteorological parameters are monitored by Met cireann at their synoptic monitoring stations, including wind speed, wind direction, temperature, rainfall, cloud cover and humidity. There are significant variations between different stations in Ireland hence it is important that a station is chosen which is representative of the area under investigation, The Schwarz site is located directly adjacent to Shannon Airport, which is

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also the location of a Met l?ireann synoptic monitoring station. Data from this site will be representative of meteorological conditions in the vicinity of the Schwarz site. In order to ensure that a range of likely meteorological conditions are included in the modelling assessment, three complete years of hourly meteorological data are included in the assessment, for 2001,2002 and 2003.

The required input parameters for tine model are:

. Wind speed;

. Wind direction;

. Temperature;

. Cloud cover;

. Month, day and hour data.

A summary of the temperature, wind speed and cloud cover data for each of the years is presented below, while wind roses for each year are included in Figures 2.1, 2.2 and 2.3. Cloud cover is measured in ‘oktas’, 0 to 8 shows the fraction, in oktas, of the celestial dome covered by all clouds.

Table 2.1: Summary of Shannon Airport meteorological data used in the assessment

Maximum Temperature (“C) 25.60 22.5 28.50


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m5" I 157.5"

180" 0 3 6 10 16 (tmkj

wm=d

0 1.5 3.1 5.1 8.2 (nJ$


-.I-+-

2u2.5" 157.5" 180"

0 3 6 10 16 @'KQ

wmP=d

0 1.5 3.1 5.1 6.2 (Ids)

67.5"

--) 90”

1125"

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2.4. Topography


Local topography can have a significant impact on the dispersion of released materials. The ADMS model is capable of including topographical data, if required. There are two parameters which can be employed in the model to describe local topography, as detailed below.

Surface Roughness

This parameter is specified in all modelling assessments. Surface roughness describes the degree of ground turbulence caused by the passage of winds across surface structures. Ground turbulence is greater in urban areas than in rural areas, for example, due to the presence of tall buildings.

The area surrounding the Schwarz includes the industrial estate itself and the airport. Based on visits to the site a surface roughness value of 0.5 metres has been chosen which is typical of suburban/parkland areas and is considered to represent typical surface roughness in the site area.

Complex Terrain

The presence of steep hills (known as complex terrain) in the vicinity of a site can effect dispersion of emissions. A gradient of 1 :I0 or greater is normally taken as the criteria for inclusion of terrain in a modelling assessment. The topography in the vicinity of the site is

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2.5.

generally flat, with the exception of a steep hill (gradient > 1:lO) immediately to the northeast of the site. Because of this hill it has been decided to include terrain data in the model to improve the accuracy of the model outputs.

Figure 2.3: Topography surrounding the Schwan Site, main site buildings shown as grey

rectangles

Building Effects and Stack Parameters

Buildings and other structures can have a significant impact on the dispersion of materials released to air. The main effect is to entrain pollutants into the cavity (leeward side) of the building, which is isolated from the main flow and in which a reversal of flow can occur. This can result in rapid grounding of undiluted plumes.

Typically buildings are considered to have an impact on dispersion if the building height is greater than 40 % of the stack height.

A number of buildings on the Schwarz site have been included in the assessment as it is considered that the buildings may have some impact on plume dispersion due to their location and height. The dimensions of the buildings included in the modelling

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assessment are included in Table 2.2. The model representation of the buildings with respect to the air emission points are included in Figure 2.4.

Table 2.2: Dimensions for buildings included in the assessment

Building

Bulk Pharmaceutical Chemical Building

Pharma Building

Nitration Plant

Height(m) Length (m)

11.6 43

14 86

14 19

Width (m)

18

21

25

The dimensions of the release points are presented in Table 2.3, including the height of the release point from ground level. Temperatures and flow values are also presented, these have been conservatively assumed, based on information provided by Schwarz on the initial specification for the thermal oxidisers.

Table 2.3: Stack parameters

Release Height (metres) Diameter Release Maximum Point (metres)* Temp ‘C Flow (m3/hr)

NP TO 22 0.4 50 5,000

BPC TO 17 @g@ 50 10,000

* Diameters calculated by URS to allow an exit velocity >lOm/s at 5,000m3/hr and at lO,OOOm3/hr

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Figure 2.4: Model representation of site buildings and emission points included in the model

2.6. Modelled Emission Rates

16252C

1625OC

16248C

162460

162440

162420

162400

162380

16236C I-

N/ nt

WTONVE

YTOBPC

139280 139300 139320 139340 139360 139380 139400 139420

Modelling was completed using emission rates based on the WID emission guideline values with the exception of VOC emissions from the NVE TO which was based on TA Luft 2002 guideline values as per Schwarz agreement with EPA. These emission guideline values have been used to calculate the emissions rates in grammes per second for input to the model. The volumetric flow used for both thermal oxidisers is 5,000 Nm3/hr based on preliminary specifications for the thermal oxidisers as supplied by Schwarz. Emission concentration and emission rates are presented in Table 2.4.

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I , I I I

* Note: as mgC/m3 I

2.7. Other Assumptions

The modelling assessment assumes continuous emissions throughout the modelled year at the set emission rate, which for this assessment are the WID emission guideline values and the VOC TA Luft 2002 emission value (Appendix A).

It should also be noted that the site boilers are not included as part of this assessment. This was agreed with the EPA prior to preparation of the IPPC licence application document.


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3. AIR QUALITY GUIDELINE VALUES

Available guideline values for the each of the compounds are presented in Table 3.1

As only total VOC emissions are modelled, the ground level concentrations are compared to the solvent used on site with the lowest ground level guideline value, which is

methylene chloride.

Short-term OEL based guidelines for methylene chloride, HCI and CO are derived from long-term (8-hour) occupational exposure limits (OELs) by applying a factor of .025. OEL data is taken from the 2002 Code of Practice for the Safety, Health and Welfare at Work (Chemical Agents) Regulations 2001. Short-term OEL’s are presented in Table 3.1.

Danish C-values for methylene chloride, HCI and CO are taken from the Danish Environmental Protection Agency “Environmental Factors and Health, The Danish Experience and are presented in Table 3.1.

It should be noted that the Danish C-values are applicable to short-term (l-hour) periods rather than long-term averages. The Danish C-value requires that 99 % of hourly values lie within the C-value (e.g. 99 % of values over the course of a month). Also, the Danish C-value has been developed specifically for assessment of industrial emissions and does not require any background concentrations to be added to the modelled ground level, i.e. the value is related to the contribution to ground level concentrations due to the emission rather than the actual ambient concentration. The Danish C-values are considered to be highly conservative guideline values.

It should also be noted that although the Danish C-values and OEL derived guideline values are often used in dispersion modelling assessments, they have no statutory basis in Ireland for use as air quality limit values.

European Council Directive 1999/30/EC specifies ambient air quality limit values for NOx and NOa. This Directive has been transposed into Irish Legislation through S.I. No. 271 of 2002 (Air Quality Standards Regulations, 2002). The limit values and criteria specified in SI 271 for NO2 are reported in Table 3.1.

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e ,


Table 3.1: Applicable ambient air quality limit/guideline values for individual compounds to be emitted from the proposed thermal oxidiser stacks.

Compound Source

Methylene NP TO, BPC chloride TO (representative of VOC’S)

NOx 1 NP TO, BPC

I TO

CO HCL BPC TO

Annual Average Short-Term OEL Denmark based Guideline C-value

4,350

40 200

10,000

175

w/m” 20

1,000

50

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4. MODEL RESULTS AND DISCUSSION

4.1. Introduction

Dispersion modelling results based on WID emission guideline values for the BPC and based on TA Luft 2002 for the Nitration Plant are presented in Section 5.2. The modelling was carried out using three years of meteorological data and including terrain effects due to local complex terrain. Maximum predicted hourly ground level concentrations are presented for each year of the three years of meteorological data employed, with maximum annual averages presented for NOx. Available ambient air quality guideline values are presented where available.

The Danish C-value is developed to be compared directly to the predicted ground level concentration due to the modelled emissions (i.e. background concentrations must not be added to the predicted ground level concentrations). The Danish C-value requires 99 % e compliance (i.e. 99 % of hourly concentrations within the guideline value, hence the 9gth percentile of the hourly concentrations are presented as the values for comparison with the C-values).

4.2. Results

The results of dispersion modelling are presented below in Tables 4.1 to 4.5. The results are presented for each compound and are compared to their applicable guideline value, The results do not consider background concentrations.

4.2.1. VOC’S

Modelling of VOC emissions was carried out for both emission points. Results are compared to the methylene chloride guideline value as it is the most stringent guideline of all the VOC compounds. As an emission concentration in pgC/m3 was used in the model, the results have been converted to pg methylene chloride/m3 by multiplying by 84 (MW of methylene chloride) and dividing be 12 (MW of C). Results are presented in Table 4.1.

1)

Table 4.1: Modelled methylene chloride ground level concentrations based on WID emission guideline values for BPC TO & TA Luft emission guideline values for NVE TO, w/m” Parameter 2001” 2002* 2003* Guideline

Value Maximum Hourly Concentration 111.33 110.74 102.65 4,350

99”’ percentile of hourly concentrations 47.12 45.65 46.79 20

* As an emission concentration in mgClm3 was used the results have been converted to ug methylene chloride/m3 by multiplying by 84 (MW of methylene chloride) and dividing be 12 (MW of C).

The maximum hourly methylene chloride concentration throughout the three years of applied meteorological data is significantly below (‘3 % of) the OEL derived short-term guideline value.


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The 9gth percentile hourly values are in excess of the Danish C-value for methylene chloride. However, in reality total VOC emissions will not consist entirely of methylene chloride and the predicted ground level results do not exceed the Danish C-value for acetic acid, 100pg/m3, which is the second most stringent guideline of all the VOC’s. It is

therefore considered the predicted ground level concentrations will not breach the Danish C-values for any of the VOC’s-that will be emitted. It should also be noted that the Danish C-values are considered to be highly conservative guideline values.

4.2.2. NOx

Modelling of NOx emissions was carried out for both emission points. The majority of the released NOx from the stacks would be expected to be in the form of NO. However, NO is converted to NO2 after release to atmosphere. URS has previously employed a NOx to NO;! conversion ratio of 50 % in previous NOx emissions modelling submitted to the EPA, hence the same conservative ratio is applied to the current assessment. Therefore, the predicted ground level NOx concentrations are multiplied by 0.5 to estimate ground level NO2 concentrations. The results are presented in Table 5.2, including details of the appropriate guideline values. Results are presented separately for each year of modelled meteorological data.

Table 4.2: Modelled NOx ground level concentrations based on WID emission guideline values, pg/m3 Parameter 2001 2002 2003 Guideline Value

Annual Average 3.43 4.26 4.00 40

99.79’” percentile of hourly 61.33 49.99 47.78 200 concentrations

The predicted ground level annual average NOx concentration is significantly below (’ 11% of) the applicable long-term derived guideline for NOx.

Also, the modelled ground level concentrations for the 99.7gth percentile value will not exceed the limit value for any of the years of modelled data.

4.2.3. HCL

Modelling of VOC emissions was carried out for BPC TO emission point only. The results are presented in Table 5.3, including details of the appropriate guideline values. Results are presented separately for each year of modelled meteorological data.

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4.2.4. co

Table 4.3: Modelled HCI ground level concentrations based on WID emission guideline values, ug/m’ Parameter 2001 2002 2003 Guideline

Value Maximum Hourly Concentration 14.80 14.41 15.61 175

99I” percentile of hourly concentrations

7.53 6.36 6.65 50

The predicted maximum HCI concentration is below (<IO% of) the short-term OEL derived guideline for HCI.

In addition, the predicted ground level concentration is well below (~16% 09 the Danish C value for all of the years of modelled meteorological data.

Table 4.4: Modelled CO ground level concentrations based on WID, ug/m3 Parameter 2001 2002 2003 Guideline

Value Maximum Hourly Concentration 38.43 38.00 40.64 10,000


19.93 17.63 18.09 1,000

The maximum hourly CO concentration throughout the three years of applied meteorological data is significantly below (<I %) the OEL derived short-term guideline value.

Also, the 9gth percentile hourly values are significantly below (‘2 % 09 the Danish C- value for CO.

4.25 Dioxins

Table 4.5: Modelled ground level concentrations, ug/m3 Parameter 2001 2002 Maximum Hourly Concentration 2.0 x IO” 2.4 x IO-”

99’” percentile of hourly 1.0 x lo+ 1.1 x lo+

concentrations

2003 2.6 x IO-’

1.0 x 10-O

There are no available guideline values for dioxins. However, the predicted ground level results for dioxins are comparable to the atmospheric levels of dioxins (20-510 x IO-’ ug/m3) measured in urban locations in England as presented in “Dioxins in Ambient Air in Australia - Technical Report No.4”. Therefore, from an air quality perspective, dioxins

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4.3.

emitted from the thermal oxidisers are not likely to have any significant environmental impact.

Conclusions

URS Ireland has completed a dispersion modelling assessment of emissions from the proposed BPC TO and NVE TO at the Schwarz Plant based on the WID emission guideline values for thermal oxidisers, with the exception of VOC’s from the Nitration Plant Thermal Oxidiser, which was based on the TA Luft 2002 guideline value.

Modelling of WID emission guideline values and TA Luft 2002 guideline values for VOC’s from the Nitration Plant, indicates that in practice, compliance with these values will not result in exceedance of the OEL derived guideline values and is also unlikely to result in a breach of the Danish C-values (where applicable). In addition, results of modelling of WID emission guideline values for dioxins indicate that dioxin emissions are unlikely to impact air quality.

Based on the results of this modelling assessment it is therefore considered that actual emissions from the proposed thermal oxidisers will not have any significant environmental impact on the surrounding area.

This modelling assessment will be subject to review and confirmation when the final design specifications are available.

$,

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Luft 2002 emission limit valu.es TA

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~@~w, “;$p<: .>,i .^ ;:,. 28.12.2000 1 Official Journal of the European Communities -L 3321109 --

ANNEX V

AIR EMISSION LWT VALUES

(a) Daily average values

Totd dust

gaseous and vaporous organic substances, expressed as total organic carbon

IO mgjm’

10 tug/m’

Hydrogen chloride (HCI)

Hydrogen fluoride (HF)

Sulphur dioxide (SO,)

Nitrogen monoxide (NO) and nitrogen dioxide (NC+) expressed as nitrogen dioxide for existing incineration plants with a nominal capacity exceeding 5 tonnes per hour or new incineration plants

10 mgjm’

1 q/m3

50 mg/m’

200 mgfm’ (3

Nitmgen monoxide (NO) and nitrogen dioxide (NC+), expressed as nitrogen dioxide for existing incineration pants with a nominal capacity of 6 tonnes per hour or less

-100 mg/m’ (7

kemptious for NOX may be authorised by the competent authority for existing incineration phmts: - with a nominal capacity of 6 tonnes per hour, provided that the permit foresees the daily average Vaum do not

exceed 500 mg/m’ and this untif 1 January 2005. - with a nominal capacity of >6 tonnes per hour but equal or less than I6 tonnes per hour, provided the permit

foresees the daily average values do not exceed 400 mg(m’ and this until 1 January 2010, - wirb a nominal capacity of ~16 tonnes per hour but ~25 tonnes per hour and which do not produce wafer

discharges, provided that the permit foreseez the daily average vah~es do not exceed 400 mg)mr and this u&l L ]anuary 2008.

until 1 fannary 2008, exemptions for dust may be authorised by the competent authority for existing incinerating plants. provided that the permit foresees the daily average values do not exceed 20 rag/m’.

(b) Half-hourly average values

(100%) A ,q, (9?!x)c)B

Total dust '_,

30 mgfm’ 10 n&n

Gaseous and vaporous organic substances, expressed as total organic carbon

Hydrogen chloride (HCh

Hydrogen fluoride (f-F)

Sulphur dioxide (SO,)

20 urg/m 10 mgfrnr

GO mg/m’ 10 m&n’

4 mggfm’ 2 mg/n-G

200 mgJmr 50 mgJma

Nitrogen monoxide (NO) and nitrogen dioxide 400 mg/m’ r) 200 mg/m3 (7 (NOJ, expressed as nitrogen diioide for existing incineration plants with a nominal capacity exceeding 6 tonnes per hour or new in&era- tion plants I

I

I

(‘) Until I January 2007 aad witbout prejudice to relevant Community legislation the emission limit value far NO, does not apply to phknts only incinerating bardow: waste.

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m Official faumal of the European Commttnities 28.12.2000

, : : ; ‘y’

Until f January 2010, exemptions for NO, may be authorised by the competent authority for existing incineratioo $atlts with a nominal capacity between 6 and 16 tonnes pet hour, provided the half-hourly average value does oat exceed 600 n&n’ for column A or 400 mg/m” for column R.

(c) Aif average values over the sampIe period of a minimum of 30 minutes and a maximum of 8 hours

Cadmium and its compounds, expressed as cadmium (Cd) I

Thallium and its compounds, expressed as thallittm (Al) 1 total 0~5 mg/m’

Mercury and its compounds, expressed as mercury (HP;) 1 0,OS mgfm’

Antimony and its compounds, expressed as antimony (Sb) 1

Amnic and its compounds, expressed as arsenic (As)

Lead and its compounds, expressed as lead (pb)

Chromium and its compounds, expressed as chromium (Cc)

Cobalt and its compounds. expressed as cobalt (Co) total 0,s mg/rn’

Copper and its compounds. expressed as copper (Cu)

Manganese and its compounds. expressed F manganese (Mn)

Nickel and its compounds, expressed as nickel (Ni) I

Vanadium and its compounds, expressed as vanadium.(V) 1

total 0,I rng/m’ (*)

0.1 mg/m’ p)

These average values cover also gaseous and the vapour forms of the relevant heavy metal emissions as well as their compounds.

((1) Average values shall be measured over a sample period of a minimum of 6 hours and a maximum of 8 hours. The emission limit value refers to the total conc.?nrration of dioxins and furans caladated using the concept of toxic equivalence in accordance with Annex 1.

Dioxios and furans 0,i n&n’

(e) The following emission limit values of carbon monoxide (CO) concentrations shall not be exceeded in the combustion gases (excluding the start-up and shut-down phase):

- 50 milligrams/m’ of combustion gas determined as daily average value; - 1% milligrams~m of combustion gas of at least 95 % of all measuhmenrs detewined as lOminute average

values or 100 mg/m’ of combostion gas of all measurements determined as half-hourly average values taken io any #-hour period.

Exemptions may be authorised by the competent authority for incineration plants using fluidised bed technology, provided that the permit foresees an emission limit value for carbon monoxide (CO) of not more than 100 mgjml as an hourly average value.

(f) Member States may lay down rules governing the exemptions provided for in this Annex.

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52.5 Organic Substances

With regard to organic substances contained in waste gas, except organic

particle matter,

a total mass flow of 0.50 kg/h

or

a total mass concentration of

each of which to be indicated as total carbon,

may not be exceeded-

50 mg/m3,

With regard to existing facilitiies with an annual mass Aow of organic

substances amounting to as much as 1.5 Mgfa, to be indicated as total carbon,

the emissions of organic substances contained in waste gas may not exceed a

mass flow of 1.5 k& to be indicated as total carbon, notwithstanding para. 1.

The amount of hours of operation during which mass flows ranging above 0.5

kg/h up to I .5 kg/h shall not exceed 8 hours of operation per day.

a

With regard to organic particle matter, except for substances of class I, the

requirements under 5.2.1 shall apply.

Within the mass flow or the mass concentration for total carbon, the organic

substances allocated to classes f (substances pursuant to Annex 1) or II, even if

severa substances of identical class occur simultaneously, may not exceed the

following mass concentrations or mass flows contained in waste gas, each of

which to be indicated as mass of organic substances:

Class f

mass ff ow

or

mass concentration

0.10 kg/h

20 mg/m3;

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Attachment 8.5 Ground and /or grgsmdwater ~~a~at~~~ · ground water issues but that would also...

Documents

Transcript of Attachment 8.5 Ground and /or grgsmdwater ~~a~at~~~ · ground water issues but that would also...

Attachment 8.5 Ground and /or grgsmdwater ~~~~a~~~at~~~ · ground water issues but that would also...

Documents

Transcript of Attachment 8.5 Ground and /or grgsmdwater ~~~~a~~~at~~~ · ground water issues but that would also...

Attachment 8.5 Ground and /or grgsmdwater ~~a~at~~~ · ground water issues but that would also...

Transcript of Attachment 8.5 Ground and /or grgsmdwater ~~a~at~~~ · ground water issues but that would also...