IPPC Form - EPA · 2013. 7. 25. · The former IFI/Dynea site is bounded to the east by the railway...

IPPC Amlication Form

6 SECTION I EXISTING ENVIRONMENT & IMPACT OF THE ACTlVITY

Description of Site and its Environment

Site Location

The Dynea Ireland Ltd site is located on a 6 acre site formerly leased from Irish Fertiliser Industries (at time of writing the new ownership structure is being clarified) on the eastern side of Cork Harbour. The Dynea site is at the northern end of the Marino Point site.

The land has been reclaimed from the sea, i.e. it is “made ground”, and the site level is a few meters above sea level. At this point the River Lee is about 60m wide.

The former IFI/Dynea site is bounded to the east by the railway line and by the R624 road to Cobh. Further to the east the land is primarily agricultural (mixed farming), and rises to a height of about lOOm above sea level. @ To the west, across the River Lee, lies the village of Passage West, and further to the south Monkstown, total population of about 41 87 (CSO 2002) the land here rises to over 400 m.

To the north lies Little Island, with several industrial estates. The latter contain a number of bulk pharmaceutical manufacturing companies. Fota Island has a zoological park, a golf course and a country house.

Immediately to the south is the former IF1 site. A new development plan for this site is awaited at the time of writing. The area will, most likely, still be zoned for industrial use.

Access to Great Island, on which the site is located, is by a single roadway and a railway line. Access is also gained by sea by a small ferry that plies between Monkstown and Great Island.

@ Site History The site is constructed on land reclaimed from the harbour at the time of the construction of the, now closed, IF1 facility.

The production site of Dynea Ireland Ltd. is located at Marino Point, Cobh, Co. Cork. Dynea Ireland (then operating as Dynochem Ireland Ltd.) commenced resin and formalin production in mid 1997 and 1998 was the first full year of production. Dynea is a multinational company with its headquarters in Helsinki. The company was formed by the merger of two multinational companies, Dyno Industrie, a Norwegian chemical company and Neste Chemicals, a Finnish state owned chemical company, in 2000. The Dynea group of companies is now owned by the Finnish company Dynea Oy.

A number of products are manufactured at the Marino Point site in the following categories:

Formalin solution - 50%

IPPC Licence Application Page 57 of 92

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IPPC Application Form L A

0

0

0

0

0

0

Urea Formaldehyde Panelboard Resins for the domestic market Melamine Urea Formaldehyde Panelboard Resins for the domestic market Urea solution for the domestic market Urea Formaldehyde Industrial Resins for the domestic market Melamine Formaldehyde Impregnating Resin for the UK market Urea Formaldehyde Impregnating Resin for the UK market

e,

The raw materials for the process are methanol, urea and melamine. The plant has the capacity to produce approximately 100,000 Tonnes per annum of liquid resin.

Environment

The environment within which the Dynea site is located is considered under the following headings:

People 0

0 The built environment 0 The natural environment 0

Features contributing to a major accident

External factors contributing to major accidents

The ordinance survey map (Error! Reference source not found.) shows Dynea Ireland Ltd in relation to the immediate area.

People

The nearest school is in Passage F a t , a distance of approximately Harbour Figure 8.

.5km across Cork

Q The immediate surroundings of the plant to the east are rural while across the river to the southwest lies the town of Passage West with a population of 4,000.

The nearest hospital is in Cork City, a distance of approximately 1 O h .

The nearest old persons’ home is in Douglas/Rochestown, where a number of nursing homes are located a distance of approximately 5 km.

The immediate surrounding area is lightly populated. The attached Table 5 shows the resident population numbers within various distances from the centre of the site.


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a IPPC Application Form cp_a_=

3 OOm

400m

of Site Residcn ts *

0

0

I 200m I 0 I

1 OOOm 32

I 500m I 4 I TABLE 5: POPULATION

* Based on 4 persons per house

The fatal effects as summarised in MAS section would occur 432m from the Dynea site (Formalin spill in tank farm). At present due to the closure of IF1 the only people who would be directly affected from an accident would be Dynea staff. The main road from Cobh passes within a few hundred meters of the site centre. The amount of people that uses the road varies between 600-1000 pcu (passenger car units) per day. There will be extra car numbers on the road over the summer months as Cobh is a tourist town. The car ferry is situated at the south of the plant has a capacity of 1000 vehicles per day. Approximately 15 trains from Cork to Cobh pass by the site each day. The trains pass within 400m of the site.

4 IPPC LIcence Application ( I Page 59 of 92

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a IPPC Application Form eP_a_=


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2 OP_aL IPPC Application Form

Features Contributing to a Major Accident

Factors that could affect the impact of a major accident include:

0 Meteorological conditions 0 Topography 0 Geology

Hydrogeology 0 Hydrology

Meteorological Conditions The consequences of any release of hazardous material depend on the meteorological conditions.

Table 6 shows the frequency of occurrence of wind speed and atmospheric stability at Roche's Point Meteorological Station. The table shows that some combinations of wind speed and atmospheric stability are relatively rare. Hence common practice is to restrict assessment to those conditions which are more common. Category D applies to overcast conditions during day or night for all wind speeds (D5 is condition D and wind speed of 5ms- '). F represents clear conditions at night - less than 3/8 of the sky covered by cloud - and low wind speeds - less than 3ms" (F2 is condition F and wind speed of 2ms-I). A wind rose for the area is shown in Figure 9.

Wind ro s e ".-

Calm haws

i--" + .c: 1.54 mts /

* /

1.54 - 3.09 mts

3.09 - 5.1 4 mls

5 14 - 8 23 mis

8 23 - 10 80 mls

' >

I

I d

I i

'I I

I 10.8U m k /

/

FIGURE 9: WIND ROSE FOR ROCHE'S POINT

I .

IPPC Licence Application Puge 61 of92

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2 eP_a=== IPPC Application Form

Pasquill Number of YO of Time Average Wind Stability Readings Occurring Speed ( d s ) Category

A 770 0.33 0.84

0 Average Wind Speed (knots)

1.63

B 5,000 2.1 1 2.83 5.50

C 1 1,342 4.80 2.59

TABLE 6: FREQUENCY OF OCCURRENCE OF WIND SPEED AND PASQUILL STABILITY - ROCHE'S POINT METEOROLOGICAL STATION - 20 YEARS DATA

5.03

Q)

li I

j/

D

E

F

G

Total

IPPC Licence Application

191,558 81.03 6.45 12.53

15,859 6.71 4.20 8.16

11,212 4.74 1.16 2.25

670 0.28 0.72 1.40

236,4 1 1 100.00 5.75 11.17

Page 62 of92

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Monthly and Annual Average of Rainfall (mm) Over the 30 Year Period 1951 - 1980 Jan Feb Mar APr May Jun Jul Aug SeP Oct Nov Dec Year

Cork Airport 148 106 103 70 87 64 73 90 115 120 115 139 1229 Mean Number of Days with l.Omm or More for Period 1960 - 1984

Jan Feb Mar APr May JUn Jul Aug SeP Oct Nov Dec Year Roche’s Point 14 12 11 9 12 9 8 10 11 12 13 13 136

Jan Feb Mar APr May Jun Jul Aug SeP Oct Nov Dec Year Roche’s Point 4 3 2 2 2 1 2 2 3 3 3 3 29

Mean Duration of Rainfall (In Hours and Tenths) Over the 25 Year Period 1960 - 1984 Jan Feb Mar APr May JUn Jul Aug SeP Oct Nov Dec Year

Roche’s Point 71.8 62.6 53.1 40.8 47.1 33.7 29.2 36.4 44.3 51.0 56.9 65.1 136 Mean Annual Duration of Rainfall (In Hours and Tenths) Between Exact Hours GMT Over the 25 Year Period 1960 - 1984

01 02 03 04 05 06 07 08 09 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 24. 25. 25. 25. 26. 26. 27. 26. 22. 23. 21. 21. 21. 22. 23. 23. 24. 25. 24. 26. 25. 24. 24. 24. 7 6 6 8 3 9 4 8 7 7 8 9 9 3 3 6 8 5 9 3 0 4 7 8

Roche’s Point

Cork Airport 151 1229 79.9 123.3 129.3 165.4 342.7 Roche’s Point 40 934 78.8 94.4 95.2 116.2 220.5

TABLE 7: RAINFALL DATA


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I I

i

Geology and Hydrogeology The groundwater is described in the application for an IPC licence as follows:

The geology of the Marino Point industrial site comprises a complex combination of subsurface strata varying from soft mudstones and shales to marine silts and construction Jill material. The hydrogeology of the site is strongly influenced by the nature of the subsurface materials and the proximity of the sea harbour. The variation in the degree and extent of saline intrusion is another complicating factor. It is, however, considered that groundwater movements at the site are very slow and along discrete layers within the subsurface strata.

Analysis of the groundwater beneath the selected section of the former IFI site demonstrated varying degrees of contamination by nitrogenous compounds. Extreme saline intrusion at many of the locations indicates that the groundwater resources beneath the site are of limited use.

Cork Harbour and the River Lee. To the north also, the land is flat, and is a few meters above sea level for 4 km.

The land to the east rises to about 300 m within 1 km.

1

The source of contamination recorded is likely to have originatedfrom diffuse inputs of urea product. However, the contaminant inputs are likely to have occurred prior to upgrading of the storage and handling facilities at the site and the installation of an extensive hard core surface.

I a

11

IPPC Licence Application Page 64 of92

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FIGURE 10: UNDERLYING GEOLOGY

8 SlIEET YO

Rec , AREA PERIMETER UNlTNAhl E DIAGENETIC DESCRIPT

i Puiple mudstone with some sandstone 22 i 1 I 1 i 724800360 9 1340353 557 j Ihllytrasna Foimation 2 19887391 42 15 1204 724 ' Gylzen rormation i I Sandstone with mudstone & siltstone 122 i

I I 308987 894 12966526 ' Cuskinny Member Flarer-bedded sandstone & mudstone 22 i 12 ' 139677 003 12734 55 a Old fledd Sand\tone Formation ' Flaser-bedded sandstone Cy: minor mudstone 22 3 10217O1 321 14572 185

3 '4186685 134 j10190245

TABLE 8: UNDERLYING ROCK IN ABOVE MAP - TOP DOWN

The plant has no history of flooding. During spring tides the maximum average height of the water is 4.5m. The harbour is at a wide point at the Marino Point site, which means it can retain a substantial amount of water before an increase in water height would be noticed.


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Tidal heights have been recorded at the jetty since 1980 and the highest tide recorded there was 5.lm with a height of 5.0m being reached three times. Figure 11 shows the ground heights at the plant prior to raising the ground levels.

The plant buildings which include formox area, resin area, administration building, powder manufacturing facility (decommissioned), and main storage area have their floors suspended on piles which are 24metres below the surface. Subsurface intrusion has no effect on these areas due to the depth the piles are below the surface which offers great stability. The resin tank farm is not piled. This is due to the fact that the tank farm covers a wide expansive area and the force exerted over that area due to the tanks is small.

Basin 1 tank is not piled and effects of subsurface intrusion would include the force exerted by the underground water exerting an upward force on the floor of the basin which could dislodge the base. This is counteracted by the fact that the base of the tank extends well beyond the four walls of the basin. This means that the base will not move in an upward direction. The wastewater treatment was not piled either. This has lead to subsidence of the large aeration tank. Work has now been completed in piling this area by the installers EPS/Ascon.

FIGURE 11: ORDINANCE SURVEY MAP OF SITE BEFORE CONSTRUCTION

Hydrology The principal watercourse in the area is Cork Harbour. This is a large, varied and complex water body. Many studies dealing with such aspects as waste inputs, assimilative capacity, water quality, fish disease and benthic quality have been carried by bodies including Cork County Council, the Department of the Marine, U.C.C., U.C.G., EOLAS and private companies.


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The harbour, a drowned river valley, is the tidal estuary of the River Lee and extends about 20km from Cork City to the open sea.

Q A schematic of the harbour is given in Figure 12 and the vector plots are shown in Figure 13 and Figure 14.

The major freshwater input is from the Lee, which becomes tidal at Cork City. Other freshwater inputs come from the Owenboy, Tramore, Glashaboy and Owencurra rivers.

In simple terms, the upper harbour estuary widens uniformly in the direction of the open sea and the tidal currents move simply up and down the estuary as the tide ebbs and flows. Patterns of tidal flow in the lower harbour part of the estuary are more complex (see Figure 13 and Figure 14 below).

The lower harbour receives a tidal flow from the open sea at Roche's Point on an incoming tide which tends to follow the eastern side of the harbour (off Whitegate) before splitting in two to flow up the East and West Passages around Great Island. On an outgoing tide these two flows rejoin and tend to move towards the western side, close to Spike Island. This effect, over a full tidal cycle, gives rise to a well mixed body of water between Cobh and the harbour mouth. Q

Cork County Council has calculated' the tidal prism volume in the Cork Harbour Pollution Report. That report indicated that the tidal prism at Ram's Head on a neap tide was 172 x 1 O6 m3 per tide. As the Dog Nose Bank is not as near to the mouth of Cork Harbour as Ram's Head Bank, the County Council estimated the tidal prism volume to be 100 x lo6 m3 per tide. This provides a very substantial dilution for regular discharges of effluent into the harbour.

A report by M. C. O'Sullivan in 1978 examined assimilative capacities at a number of locations. The report concluded that the estuary at Marino Point has an assimilative capacity for approx. 30,000 kg/d of B.O.D. and that a capacity of up to 300,000 kg/d of B.O.D. could be available at the Ram's Head Bank.

An earlier study (1 97 1 - 1 972) carried out by Metcalfe and Eddy, Consulting Engineers, on behalf of Pfizer, had concluded that an assimilative capacity of around 135,000 kg/d of B.O.D. was available for a discharge at the Dog Nose Bank.

A further detailed study of the Dog Nose Bank area was carried out in 1980 under the direction of E. G. Pettit, Consulting Engineers, to determine by means of dye-tracing the assimilative capacity that would be available to an outfall at that location. The report of the consultant to that latter study, Mr. A. Dowley of U.C.D., concluded that "the Dog Nose Bank outfall location is satisfactory for the discharge of 90,000 kg/d of B.O.D. while maintaining water quality standards".

@

Environmental Impact Statement for development by Sandoz at Ringaskiddy, 1989.

i IPPC Licence Applzcation Page 67 of 92

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FIGURE 12: HARBOUR CHART FOR REGION CLOSE TO DYNEA


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FIGURE 13: VECTOR PLOT OF CURRENT VELOCITIES IN CORK HARBOUR AT HIGH WATER, SPRING.

FIGURE 14: VECTOR PLOT OF CURRENT VELOCITIES IN CORK HARBOUR AT MID-EBB, SPRING.


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Archaeology

Monuments and antiquities within 2 km of the site are shown in the figure below.

FIGURE 15: HISTORIC SITES IN THE LOCALITY

The historic sites marked on the map in Figure 15 above are as follows:

1. Ring fort - Ballyfouloo 2. Ring fort - Rathanker

Page 70 of 92 IPPC Licence Application

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3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14.

Q Standing stone - Passage West Midden - Carrigrenan Folly - Fota Historic house - Fota Martello tower - Belvelly Martello tower - Belvelly Castle - Belvelly Martello tower - Belvelly Ring fort - Lissanisky Ring fort - Lissanisky Holy well - Ballyleary Holy well - Cuskinny

The Natural Environment

Terrestrial Flora In the Cork harbour area the vegetation is mostly the result of intensive agriculture. 90% of the land is under grass and approximately 10% is under cereal or other crops. Only a small percentage of the land area was found not to be for agricultural use. Grasslands are primarily grazed by cattle and to a lesser extent sheep and horses. Perennial rye grass, smooth -stalked meadow grass and Yorkshire fog dominate the makeup of this grassland. The common weeds associated with this type of grass are ragwort, thistle, white clover, dandelion and common chickweed.

Q

Non agricultural land can be divided into a number of different sections including lowland wet grassland, woodlands, scrub, freshwater marsh and reedbeds, saltmarsh/ mudflat, open water areas, weedy waste ground areas and quarry. These areas contain varied flora including rushes and sedge, trees such as beech, horse chestnut, pine and spruce, scrub such as hawthorn, gorse and willow. To-date there is no evidence that the general vegetation in any part of the harbour is adversely affected by emissions from industries. However there has been some evidence of localised tree canopy damage near Marino Point and in Carrigrennan.

Terrestrial Fauna The terrestrial fauna associated with this area include insects such as butterflies moths and bark lice, animals such as the badger, fox, stoat, hare, rabbit, red squirrel, brown rat, house mouse, wood mouse, pygmy shrew, and the long eared bat have been recorded on the island.

@

The saltmarsh flats are important feeding grounds for waterfowl as they support rich invertebrate fauna. Cork Harbour is of international importance for the wildfowl which the harbour’s wetlands support and these wetlands are within the Cork Harbour Special Protection Area which is designated as an important bird area under the Birds Directive. Overall the harbour regularly holds over 20,000 waterfowl.

A bird survey carried out by the Aquatics Services Unit in 1994, indicate that between 1978 and 1991 there had been no evidence that any overall change had taken place in the numbers of wetland species using the area. It was shown that numbers of black-tailed godwit and shelduck had diminished.

Two of the National Heritage Areas have part of their boundaries close to the factory, the most important being the Belvelly-Marino Point area which is extremely important for @


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wintering waterfowl and waders. The Great Island channel of which Belvelly-Marino Point is a part, contain sheltered tidal mudflats and Atlantic salt meadows, both habitats listed on Annex 1 of the EU Habitats Directive. Across the river, the Douglas River Estuary National Heritage Area extends to Passage west from Douglas and Blackrock. The prime importance of the site is the bird life with some species in this area occurring in nationally important numbers.

e

Areas of scientific interest are listed in Table 9.

Parks and Wildlife Parks

Fota Wildlife Park (approx. 2 km across the estuary from Dynea), holds a number of species that are managed co-operatively under the European Endangered Species Breeding Programme. These are species in which the captive population might make a difference to the species’ survival.

Fota Gardens and Arboretum (located close to the Wildlife Park) is located on 47 hectares of parkland and the Arboretum is now of international importance, its reputation deriving from the diversity of planting and from its collection of exotic specimens from all over the world.

@

The vicinity of sensitive environmental receptors is shown in Figure 16 and the areas of scientific interest are given in Table 9.


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Name Importance Grid Extent Reference

& Point section

Great Island National 900ha 1 I Channel I I I

Tivoli- National w7273 I I Dunkettle Shore

Caves section

Rock Farm Regional W 76 71 30 ha Quarry, Little Island

Mudflats at Local Douglas River, Lough Beg

TABLE 9: AREAS OF SCIENTIFIC INTEREST

Habitat Interest Description

Mudflats

Geomorphological, Geological

Ecological (0)

A low drift cliff sloping down below high water mark and covering a raised platform which has been striated by moving ice. At Ringabella Point there is a small exposure of black pyritous mudstone with interesting goniatite fossils. It is the type known locally for one species, unknown elsewhere in western Europe.

One of the most important areas for wildfowl within Cork Harbour. Shelduck occur in internationally important numbers (1,500 during March) with mallard, wigeon, teal and a substantial wader population, e.g. dunlin (5,000)

Mudflats Ecological (0) The largest roost and feeding area for waders in Cork Harbour on the mudflats and newly reclaimed land. Up to 7,000 present during winter, including black- tailed godwit (2,000), bar-tailed godwit (500), dunlin (1,500) and oystercatcher (1,000). Black-tailed godwit numbers are of international imDortance.

Geomorphological A cave system containing fine examples of dripstone formation.

Geomorphological One of the only eskers in Cork whose origin is associated with the CorkKerry ice cap.

A series of limestone quarries in which the limestone is divided into three distinctive zones of the Visean (Lower Carboniferous). A rich calcicole flora occurs, including dense-flowered orchid, Neotinea.

Grassland Ecological (B), Geological

Ecological (0)


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FIGURE 16: SENSITIVE ENVIRONMENTAL RECEPTORS IN THE VICINITY

@ IPPC Licence Application Page 74 of 92

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Establishment

@ Establishment Overview

I

The site operator is Dynea Ireland Ltd. The Registered Office of the company is Marino Point, Cobh, CO Cork. The company’s registered number is 230920. The company was formerly known as Dynochem Ireland Ltd. The Dynea group of companies is now owned by the Finnish company Dynea Oy.

The plant was built to manufacture urea formaldehyde, melamine urea formaldehyde and melamine formaldehyde resins for the panelboard, paper impregnation, firelighter, and glass fibre tissue industries, primarily within Ireland. These resins are sold as liquids (in bulk). The resin is dispatched to customers in bulk road tankers.

The annual output is approximately 80,000 tonnes of resins and 34,000 tonnes of 50% formaldehyde.

The Dynea site is leased from the former IF1 company (new ownership structure not formally in place at time of writing), some of whose facilities are shared, including:

Jetty. Fire water storage Security

Production takes place throughout the year with downtime only for ‘maintenance.

Methanol is converted to formaldehyde gas on site and this is then absorbed in water to forma 50% formalin solution. The methanol is stored in a bulk tank with a capacity of 4,500m3 and this is refilled from ships which berth at the jetty. A continuously welded line joins the jetty and the methanol tank. The methanol tankers which arrive at the jetty are typically at the end of a two port run and so have only the quantity for delivery to Dynea Ireland on board. The offloaded amount is typically in the order of 3,000 tonnes with the ships being typically having a capacity of 6-7kT.

c)

Urea is also imported by ship from, typically, Russia or Poland (or other Baltic states). The quantity discharged tends to be in the order of 4,500 tonnes. This urea is either offloaded at the former IF1 jetty (preferred option) or offloaded and stored on behalf of Dynea Ireland by a shipping agent somewhere in the Cork region.

Dynes's site occupies 6 acres on the north-west corner of the former IF1 site, opposite the eastern end of Little Island (Carrigrenan).

@ IPPC Licence Application Page 75 of92

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Site Description/ Overview 0

Dynea currently employ 33 people with 2 contractors. The production areas operate on a continuous basis so a 5-team continuous 12-hour shift system is in operation. At night and at weekends there will be between 3 and 8 people on site. The normal maximum on site, including contractors and drivers, is 22 people. During a major shutdown this may rise to 40 people.

The majority of staff are located in the control/office building which houses support fbnctions such as quality control, accounts, engineering as well as the plant control room. Figure 17 below shows a site map giving the locations of the main buildings etc as well as the numbers and locations of personnel.

dynes Dynea Ireland Limited, Marino Point

FIGURE 17: SITE MAP SHOWING NUMBERS OF PERSONNEL ETC.

Areas of the site where a major accident hazard could occur on the site are marked with numbers on an orange background as follows: q)


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1. 2. 3. 4.

The methanol storage tank, marked in red, is located at the south-west of the site. The resin production area located close to the centre of the site. The formaldehyde production (Formox) area to the East of No. 2 above. The formalin storage tanks, marked in yellow, are approximately in the centre of the site.

Escape routes to the assembly point are marked in solid light blue line. Alternate escape routes are in the dotted light blue line.

Appendix 8 shows a 3-D Map of the Dynea site with locations of buildings, storage tanks and emergency equipment.

Plant Operations

Loading of Resin Road Tankers Resin tankers are loaded from the bulk tanks at the resin loading bay located immediately to the north of the tank farm. Resin out loading takes place through a manifold connected to each of the resin tanks. The operator monitors the operation from either the screen in the control room or a local display on the loading bay. The operator is present for the filling of the last 5m3 of resin to ensure that a spillage does not take place. If, despite this, a spill takes place, absorbent materials are provided to stop the resin getting as far as the loading area drains which are themselves isolated from the surface water system. The resin is non- hazardous but will result in an excessive nutrient loading if allowed to enter a watercourse. All surface waters collected from the Dynea site are tested before discharge.

Approximately 10 tankers with 25 Tonne loads leave the site each day.

Loading of Methanol Road Tankers Approximately 4 methanol road tankers leave the site each week with 24 Tonne loads. These tankers are filled at the methanol filling station where an operator is on duty at all times during the loading operation.

The tanker i s earthed by connection to an earthing/earth proving system. The amount to be filled is keyed into the flow meter and the filling operation is begun. If a fire alarm is triggered during this operation, the methanol pump feeding the loading area will shut off.

Emergency stop buttons are provided adjacent to the operator’s position as are foam monitors as detailed in the “Fire Fighting Facilities” section.

Jetty installation and Operation The jetty is a T- head type which protrudes into the river lee estuary. The jetty, with details of the fire fighting equipment is shown on drawing no. 023 .O. 1.10 1, “IF1 Site Layout Plan” in Appendix 8.

The jetty effectively contains two operational areas, one area is associated with handling bulk solids whereas down river end is associated with liquids or gaseous compounds and it is here where methanol will be unloaded. Methanol is offloaded via a flexible hose line attached to a lifting beam. The other end is permanently connected to the methanol import line.

P P C Licence Application Page 77 of 92

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Urea is also unloaded at the jetty whereby a crane is brought onto the jetty and road tankers e

are loaded and urea is taken off the jetty to storage. . The ships that dock at the jetty would contain approximately 4000 tonnes of urea. Urea is non hazardous and the risk associated with it is from a major spillage. This would have the effect of an increased BOD loading in the harbour. The safety checks on the jetty are similar to unloading methanol.

Methanol Bulk Storage

There is a high level transmitter and high level float switch on the tank which will trip the pumps on the jetty and methanol transfer will stop. This in turn will sound the fire alarm on the jetty. There is a Nitrogen blanket above the methanol floating roof. This blanket is supplied from a Nitrogen compressor. There is also a backup Nitrogen skid for the times that the Nitrogen compressor is unavailable. Nitrogen regulator on top of the tank regulates the Nitrogen flow to the tank. In the unlikely event that the floating roof sticks there is pressurehacuum relief (4879) on the tank. The tank is earthed for protection during electrical storms. There is also a flame arrester on the tank. Entry to the methanol bund area is on a restricted basis. There are five foam pourers positioned around the tank. The line is connected to the foam tank which contains 1 OOOlts of Foam. In the vicinity of the tank there are two pumps P480, P485, which are used for loading methanol to road tankers. It is proposed to reposition these pumps outside the bund wall. All flanges have an earth straps across them to equalise any potential that could arise due to liquid flow. The pumps that supply the formox process are outside the bund wall (P301A, P301B). There is a separate methanol line for supplying methanol to the reactors.

Formalin Bulk Storage

Formalin solution 55% concentration is pumped to two designated tanks (T402, T403) in the tank farm. These tanks are made of 304L Austenitic Stainless Steel. These tanks have a capacity of 300m The tanks supply the reactors with formalin at approximately 50% concentration .The dilution is carried out using distillate produced (waste) during resin manufacture. The tanks are lagged and are kept at a temperature of 50 degrees C; this is to prevent the formation of paraformaldehyde. The tanks contents are mixed using agitators in the tanks (A402, A403). The vents from each of the formalin tanks are fed into a scrubber system which removes formaldehyde vapours to the distillate tank (T408). This vent is tested bimonthly for Formaldehyde content, Methanol and Dimethylether. The bund will contain the contents of a formalin tank however some of the formalin will splash onto the roadway during a catastrophic failure of the tank. This will be contained within the confines of the site.

Resin Manufacture

Urea is brought on site by lorry and trailer from the urea store at the former IFI. This urea is then stored in Dynea’s urea store. The capacity of the Dynea store is approximately 800 tonnes. Melamine is bought in from a number of international suppliers in 25kg, 500kg and 1,000kg bags. Formalin is stored in from the storage tanks T402 and T403. Three batch reaction vessels are used with approximate capacities of 25T, 75T and 75T for reactors 1 ,2

~~

and 3 respectively. 0


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Resin is manufactured by first bringing 50% formalin in to the reactor. This is then adjusted to a more neutral pH before the addition of urea or melamine or both. The reactions are acid and temperature catalysed so, once the raw materials are mixed, the temperature is increased to approximately 90°C and the pH is dropped to approximately 5.5. The pH drop is carried out using ammonium sulphate which reacts in the presence of formaldehyde to form sulphuric acid. The progress of the reaction is typically tracked by viscosity as the formation of the polymer chain results in an increase in the viscosity of the product in the reactor. When the end-point is about to be reached, cooling is applied and 28% Sodium hydroxide is added to bring the pH back up to neutral. The resin is then pumped to the tank farm.

Bulk Tank Farm

There are 19 bulk tanks in the tank farm ranging in size from 300m3 (main resins and formalin) to 75m3 (small scale resins and distillate) with a smaller GRP tank for the storage of diethylene glycol. Most of the tanks are carbon steel with the exception of the sodium hydroxide and formalin storage tanks (due to the corrosive nature of these materials).

Formox process

Methanol is vaporised in the vaporiser at a temperature of approx 130°C. The Methanol flow rate is regulated by control valve FCV 101. This methanol is atomised and mixed with incoming air (approx. 20k Nm3/hr) (measured on Annubar FT 100). It passes from here into the Formox reactor.

Formaldehyde is produced in the FORMOX process by the direct oxidation of methanol. The reaction is carried out with the aid of a catalyst which consists of balls, granules or rings containing molybdenum and iron oxides. The process gas or air containing 10.2% to 2 1 % (by volume) oxygen is measured by oxygen analysers on line (AIT 1 O0,AIT 10 1) and up to 10.0 moles methanol per 100 moles gas is passed through the catalyst which is contained in a multiple tube unit called a converter where the reaction takes place. The first layer that the methanol/air stream comes into contact with in the tubes is a layer of non-reactive ceramic rings which would be at the same temperature as the Dowtherm oil - approx. 250°C. Dowtherm liquid serves as a heat transfer media in the converter. It both heats the air methanol mixture to the reaction temperature in the upper part of the catalyst tube and removes the heat of reaction in the lower part. The Dowtherm is operated at its boiling point, and the excess heat of reaction is carried away by the Dowtherm vapours which are condensed in the Dowtherm condenser to produce high pressure steam for the process. The gas stream then passes onto the iron-molybdate catalyst rings and the reaction brings the temperature up to approx. 35O0C.-4O0"C (depending on the life stage of the catalyst and the throughput).

B)

The gases which leave the converter are cooled in an aftercooler where low pressure steam is produced. The gas then enters an absorber where the formaldehyde is absorbed into water to produce up to 55% formaldehyde solution. The product solution contains small amounts of formic acid and unreacted methanol (less than 1%).

In order to reach the maximum production rate, it is necessary to operate the plant under recycle conditions. Part of the gas mixture leaving the absorber stack is returned to the recycle tank where it is mixed with fresh air at a controlled rate so as to maintain an oxygen @


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content of 10.3% by volume at the air compressor intake (Actuated control valve ACV 100 controls airflow to recycle tank, this valve is opened or closed depending on readingsfrom oxygen analysers AIT 100, AIT 101). With this lower oxygen content, it is possible to increase the amount and, hence the concentration of the methanol in the mixture fed to the converter from 5.0 moles per 100 moles of air to 9.3 moles (design rate) and to 10.0 moles (maximum rate) per 100 moles of recycle gas mixture without forming an explosive mixture.

Q

Warehouse

The warehouse is used mostly for the storage of melamine in 500kg, 1,000kg and 25kg bags. Engineering materials are also stored there as are smaller volumes of other raw materials and process chemicals such as ammonium sulphate, caprolactam, sodium sulphite and Dowtherm oil in 200 litre drums.

Services 8 , I Electricity Dynea's site is supplied by one feeder cable from the former IF1 main sub station to our main incoming 6.3 kV switchboard. Our maximum demand usage is approximately 1.1 MW. There are 3 No. 6.3 kV to 400 volt transformers located site wide 1 at MCCl 1.6 MVA, 1 at MCC2 630 kVA and 1 at MCC3 3 MVA. It is at each of these MCC's that the voltage is distributed for use on motors pumps drives etc.

There is a main fire man's switch which shuts off the 6.3 kV supply to the 3 No site transformers located up above the door at the 6.3 kV switch room. This is indicated on the site plan drawing. The high tension cables run underground and are protected from damage due to excavation etc by wooden sleepers running over the cables.

There is a UPS (Uninterruptible Power Supply) back up supplying the UniProcess DCS and has approximately 1 hour back up in the event of a power failure.

In the event of a power failure at the site the following plant facilities would be affected: @ Formoxarea

0 Resin Reactors 0 Plant Utilities

In the event of a power failure the formox process will shutdown in the safe mode. This process has occurred in the past and the plant behaved as was expected. Simulations of plant shutdown have been carried to ensure that safe plant shutdown systems are operating correctly.

The most critical part of batch production is during condensation. In the event of a power failure emergency caustic is available to "kill" the condensation reaction. Agitation of the batch is provided by a diesel compressor that is left on standby by the reactor floor which provides air to the base of the reactor and agitates the liquid. Other steps of the batch process are not affected critically by loss of power.

@ ( I !

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Plant utilities will also be affected by loss of power. Methanol loading will cease once the power has failed and all valves will close in the safe position. Methanol loading at the Jetty will also cease once power between Dynea and former IF1 is no longer available. An alarm is sounded on the jetty and all pumps are stopped and valves are automatically closed. Pumps on the ship will be turned off. Other utilities around the site will not have a major consequence once power is lost.

Gas The gas pipe enters the Dynea site on the south eastern side of the plant from the former IF1 site. The gas passes a reducing substation and then into the plant for usage. Consumption of gas has reduced considerably since the closure of the powder plant. The gas line is spaded off at the point of entry at the powder plant. In the year 2003, Dynea used 33,128 m3 of gas only. Gas is used specifically for running the boiler when steam is not available from the Dowtherm condenser to service reactors. The main risk associated with the gas line would be due to a rupture in the pipe itself or if a problem arose at the boiler house. The gas pipe is made from plastic and is built to a recognised standard.

Instrument Air Supply All Dynea's instrumentation and utilities are fed from a common compressed air supply. This is supplied by 3 No air compressors 1 No Kaser 110 kW compressor 1 No. Compair 95 kW compressor and 1 No 70 kW compare compressor. The air is stored in two air receivers 1 m3 each at 6.5 bar approximately.

The air is then fed through two air dryers 1 No set of Dominic Hunter dryers or 1 No Ultra Filter and from there the air is fed around to the end users.

If the air is lost, for whatever reason, all pneumatic valves will shut down in the safe mode. This will have the effect of shutting down the methanol valves to the formox. High level oxygen alarms will also be triggered on UniProcess. This is a safe condition as the molar ratio is zero between oxygen and methanol.

Valves on the reactors will also shut. If this occurs during condensation caustic will not be added in the conventional manner. In this scenario emergency caustic is added manually to the batch and the reaction stopped and full cooling will be put on.

The valves in the methanol loading will also shut. This means that methanol cannot be loaded until compressed air is restored. On the jetty there is an independent compressor which supplies air to the actuated valves. If this fails the valves on the jetty will shutdown safely.

Cooling Water The temperature of the cooling water entering the tower is approximately 35°C and exiting the tower at approximately 20°C. Cooling water is used to cool the batches during manufacture and for process vessels in the formox process. If cooling water is lost during batch production the batch will hold its temperature in the reactor. In this case caustic will be added to slow the rate of reaction if this occurs during condensation. Since the temperature can be 85OC or above, sampling of the reactor will continue, to check viscosity. If the viscosity is still rising formalin can be added so as to get the molar ratio in the safe area to prevent gelation. Cooling water also supplies excess steam drum and the heat exchangers around the plant. If cooling water is lost to the formox process controllers in the formox


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process as described in earlier sections will shut down the plant. There are three cooling water pumps and one of these pumps is on standby in case one of the other pumps fail. @ Service Water Service water is fed to the demineralisation plant where it is treated and then it is fed to the condensate tank. The condensate tank keeps the Dowtherm condenser topped up with water. If the service water is stopped for any reason the condensate level indicator would trigger an alarm in the control room. If the service water is not restored, temperature in the Dowtherm condenser will increase and plant will go into alarm and shutdown.

Also with the loss of service water there would be no supply of water to the absorber tower. This means the incinerator bed is being supplied with a formaldehyde richer stream than normal, which will increase the temperature in the catalyst bed. An audible alarm signifying high temperature in the catalyst bed will be heard. If the temperature increases above 6OO0C the formox plant will shut down. An alarm from the THC analyser signifying high concentration of formaldehyde in air emissions will also be heard in the control room.

I There are two ways in which steam is produced at the plant. It is produced from a gas powered boiler and as a result of the formox process. 5 bar steam is produced from this boiler which services the reactors. The condensate is returned to the condensate tank where it is pumped back to the steam boiler by (P301A or P301B)

I

I

The Dowtherm condenser produces high pressure steam (20bar Gauge) from the formox process. This high pressure steam is reduced by pressure control valve PCV129 to 10 Bar Gauge. The remainder of the steam passes to the excess steam drum where it is cooled returned to the condensate tank. The 20 bar steam line is then split between vessels requiring steam in the formox process (i.e. vaporiser) and the reactors. PCV134 reduces the 1OBar Gauge steam to 4 Bar Gauge servicing formox vessels and PCV133 reduces steam pressure to reactors to 5 Bar Gauge.

Drainage

All plant surface water is collected in Basin 1 where it is sent to the wastewater treatment plant. (The plant generates no liquid effluent streams - all wastewater generated is as a results of rainwater collection. A combination of grab sampling and continuous analysers is in place to ensure compliance with the plant’s Integrated Pollution Control (IPC) Licence. As of January 2004 the plant is still discharging on a kg/day mass emission limit rather than a mg/litre limit. Work is currently ongoing to build a new wastewater outfall pipe (the use of the former IF1 facilities Bonna discharge pipe no longer being permitted) and a new wastewater treatment plant is currently undergoing pilot scale work before the full upgrade is built.

1

The grab and composite samples are analysed for the following parameters:

0 Biochemical Oxygen Demand (BOD) 0 Chemical Oxygen Demand (COD) 0 Total Suspended Solids (TSS) 0 Total Nitrogen @ 0 Formaldehyde


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0 Ammonia PH

0 Phosphorous 0 Oils, Fats and Grease

@

The continuous analyser is a Siemens Aquascan system designed for the analysis of liquid effluents fiom a plant. The unit analyses the following parameters:

0 Biochemical Oxygen Demand (BOD) 0 Chemical Oxygen Demand (COD) 0 Total Organic Carbon (TOC) 0 Total Suspended Solids (TSS)

Ammonia PH

0 Conductivity 0 Turbidity

Colour 0 Sample Temperature

I

External Factors contributing to Major Accidents

The risk of earthquakes in the area is very low.

The facility is built on reclaimed land, i.e. made ground. However, this has been well- compacted, and site investigations were undertaken prior to the design of the facility to ensure that adequate founding would be given to all structures on the site, including storage tanks, etc

There are neither underground workings, subways nor any history of mining on the site. Prior to the former IF1 site being developed, the site was used for agriculture. There is, therefore, no risk of any released gadliquid collecting underground. All he1 for mobile plant is stored above ground.

I , The plant has no history of flooding and, as the factory is located well within Cork Harbour,

south of the Dynea facility. The former IF1 site has been a Seveso Directive “top tier site”, and stored large quantities of liquid ammonia which is manufactured from natural gas.

I is immune to high wave action. The Irish Fertilizer Industries site is located directly to the

Other existing major accident sites in the area include Irish Refining plc, and Calor Teo’s LPG storage and filling facility. Both of these are 8 km to the south-east. Calor Teo and Flogas plc have LPG storage and filling facilities at Tivoli, 8-9 km to the west.

Cork Airport is located 12 km to the south-west. The Dynea facility is not in the direct flight path to the main (north-south) runway, but at times commercial aircraft over fly the site (although in the vast majority of cases they tend to fly to one side of the site rather than over the site), principally if the auxiliary (east-west) runway is being used. Aircraft flying over the site are restricted to a minimum height of 300m. The history of aircraft crashes in Ireland shows that crashes fall into two categories:

I

IPPC Licence Application I Page 83 of 92

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@ !

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1. Accidents in the immediate vicinity of airports during take-off or landing. 2. Light aircraft crashing into fog covered mountains.

As neither of these scenarios applies to Dynea Ireland Ltd., it follows that the risk of an aircraft crashing into the plant is no more than any other area of the country situated in the vicinity of an airport, This would be seen as less than lx10-6/yr if compared to BNFL’s data in the UK for accidental aircraft impact on the Sellafield facility - an area with greater aircraft movement.

The former IF1 jetty is located in the main shipping channel to the upper harbour of Cork City. However, most of the large tonnage ships use facilities downstream of the jetty, including the container, RoRo and car terminals at Ringaskiddy, Pfizer’s jetty at Ringaskiddy (molasses and some other bulk liquids), and Irish Refining’s jetty at Whitegate (crude oil, LPG and oil products). There are approximately 2,500 shipping movements per annum through the channel which is about 250m wide in the area of the former IF1 Marino Point jetty. All ships are piloted by Cork Harbour Commissioner pilots. Shipping using Cork Harbour and Tivoli include bulk chemical and petroleum product carriers, LPG ships for Calor and Flogas, and some bulk chemicals.

Power is supplied to the site via underground cables from former IFI’s substation. No power cables cross the site or pass close to the site.

The site is relatively isolated, and is bounded by Cork Harbour on two sides. 24-hour security is maintained so that the scope for arson, vandalism, theft, and criminal damage is very limited.

The former IFI/Dynea site is served by twin high tension supplies from the ESB’s trunk line at Cobh. That trunk line runs from northeast to southwest.

Several radio transmission masts are located in the area. These could produce electric fields that could interfere with safety control systems or communication systems, or initiate electro-explosive devices. However, all of Dynea’s electrical and electronic systems are protected against such interference.

For further detail on the above see Section 5.2.

I. 1 .Assessment of atmospheric emissions

Attachment I1 contains details of the original assessment of the proposed emissions from the site. As can be seen this identified no impact as a result of the site’s activities. Given that this assessment was made on the basis on the spray dryer plant being in operation and that the emissions never reached the levels forecast in that document then we can say that the establishment will have no impact on the receiving environment. Just looking at formaldehyde, the licenced limts from startup were 15,768kg/yr and last years emissions were just under 400kg, just over 2.5% of the originally predicted emissions.


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.. .- . . .

Formaldehyde 4309 427 9.9 Methanol 4302 752 17.5

VOC 7815 2247 28.8

An updated impact assessment against current best practice will begin within the next month (July 2006) and its results will be made available to the Agency as soon as they are received.

1.2. Assessment of Impact on Receiving Surface Water

The original impact assessment for the site is attached in attachment 1.2. As can be seen the figures for 2004 were well within the mass emission limits. Since the original assessment was carried out, the available assimilative capacity of the harbour area will have increased due to construction of the sewage treatment plant at Carrigrenan. This combined with the considerable decrease in total emissions from the site (the wastewater treatment plant having been designed to treat effluent from the spray dryer scrubber (closed in 2000) means that Dynea are confident that no adverse effects will accrue as a result of the plant's operations.

4)

1.3. Assessment of Impact of Sewage Discharge. e

This area is currently undergoing analysis as part of the review of the operations of the wastewater treatment plant. Any load generated on a mg/l basis will be at least as low as that generated by the municipal wastewater treatment plant at Carrigrenan.

1.4 Assessment of impact of groundlaroundwater emissions

No discharge to ground or groundwater takes place. A comprehensive review of groundwater quality was carried out in 2005 by White Young Green and this is attached in Attachment No. I5

1.5 Ground and/or groundwater contamination

See attachment 15.

0 IPPC Licence Application / I I Page 85 of 92

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1.6 Assessment of the environmental impact of on-site waste recovery and/or disposal. Q)

The only waste recovery operation on site is the proposed recovery of waste resin through reworking into the process. This will all but eliminate that waste stream through the grinding of the hardened resin into small chips which are filled into IBC bags (FIBCs) in the warehouse area and then dissolved in the formalin at the start of the batch. The rework area is segregated and would be kept in a clean fashion to ensure that chips are not carried out on shoes etc. This has worked successfully on a lab basis. The operation would reduce the environmental impact of waste generation on site and would not have any measurable environmental impact beyond that.

1.7 Noise Impact.

No further impact on the environment would result due to any new operations on site as no new noise sources will be in operation which will have an impact off site. The melamine conveying fan may class as a noise emission source once it is operation but this will not be for another month. If it is deemed significant then measurements will be taken and submitted and the noise emission sources tables modified accordingly

IPPC Licence Application

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1.8 Environmental Considerations and BAT

The emission control measures described for air emissions control are the industry standard and are best practice for this type of plant in Europe. The proposals have previously been submitted to, and approved by, the Agency.

Wastewater emissions control measures are still in plant scale evaluation stage but Dynea will commit to ensuring that any abatement system employed will meet the standards of BAT.

Describe the measures proposed or in place to ensure that:

(a) The best available techniques are or will be used to prevent or eliminate or, where that is not practicable, generally reduce an emission from the activity - See Section F;

(b) no significant pollution is caused - See Sections E, F and the attachment to Section I;

(c) waste production is avoided in accordance with Council Directive 75/442/EEC of 15 July 1975 on waste; where waste is produced, it is recovered or, where that is technically and economically impossible, it is disposed of while avoiding or reducing any impact on the environment - see Section H;

(d) energy is used efficiently - see Section G; (e) the necessary measures are taken to prevent accidents and limit their consequences; -

see Section J (f) the necessary measures are taken upon definitive cessation of activities to avoid any

pollution risk and return the site of operation to a satisfactory state - see Section K.

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IPPC Form - EPA · 2013. 7. 25. · The former IFI/Dynea site is bounded to the east by the railway...

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Transcript of IPPC Form - EPA · 2013. 7. 25. · The former IFI/Dynea site is bounded to the east by the railway...