ODOUR & ENVIRONMENTAL ENGINEERING CONSULTANTS Unit 32 De Granville Court, Dublin Rd, Trim, Co. Meath Tel: +353 46 9437922 Mobile: +353 86 8550401 E-mail: [email protected] www.odourireland.com DISPERSION MODELLING ASSESSMENT OF STACK PROCESSES LOCATED IN ALPS ELECTRIC (IRELAND), CLARA RD, MILLSTREET, CO. CORK. PERFORMED BY ODOUR MONITORING IRELAND ON THE BEHALF OF ALPS ELECTRIC (IRELAND) LTD, CLARA RD, MILLSTREET, CO CORK. REPORT PREPARED BY: REPORT VERSION: ATTENTION: DATE: REPORT NUMBER: REVIEWERS: Dr. Brian Sheridan Document Ver.4 Ms. Marie Walsh 03rd Jan 2008 2007.A145(4) Ms. Marie Walsh & Ms Margaret Stokes Confidential Report 2007A145(4) Alps Electric (Ireland) Ltd TABLE OF CONTENTS Section Page number TABLE OF CONTENTS i ii iii DOCUMENT AMMENDMENT RECORD EXECUTIVE SUMMARY 1. 1.1 1.2 2. 2.1 2.1.1 2.1.2 2.1.3. 2.1.3.1 2.1.3.2 2.2 2.3 2.3.1 2.3.2 2.4 2.4.1 2.5 2.6 2.7 2.8 2.9 3. 3.1 3.2 3.3. 3.4. 3.5 3.5.1 3.5.2 3.5.2.1 3.5.2.2 3.5.2.3 3.5.2.4 4. 4.1 4.1.1 4.1.2 Introduction and scope 1 Introduction Scope of the work 1 1 Materials and methods 3 VOC measurements and techniques Airflow rate measurement Flame ionisation detector (FID) measurement Speciated VOC monitoring of exhaust emission points A2-1, A2-2, A2-3. A2-6 and A2-7. Sampling of VOC from exhaust emission points A2-1, A2-2, A2-3, A2-6 and A2-7. Sorbent tube pre-concentration Review of historical measurement data Dispersion modelling assessment Atmospheric dispersion modelling of air quality: What is dispersion modelling? Atmospheric dispersion modelling of air quality: dispersion model selection Air quality impact assessment criteria Air Quality Guidelines for classical pollutants in Ireland and Europe Existing Baseline Air Quality Site location, and locations of sensitive receptors 14 Meteorological data Terrain data Building wake effects Results 5 5 5 5 6 6 7 7 9 12 15 15 15 16 Volumetric airflow rate results for all emission points. Historic and measured Total organic carbon emission concentration results (as measured on a FID) Measured and historical speciated VOC results from emission points located in Alps Electric (Ireland) Ltd. Measured and historical classical air pollutants from emission points located in Alps Electric (Ireland) Ltd. Dispersion modelling assessment Results of dispersion modelling assessment for Classical air pollutants. Results of dispersion modelling assessment for Volatile organic compound pollutants. BAT Volatile organic compound abatement strategy Review of BREF document for surface treatment using organic solvents-treatment techniques in general. Suggested treatment techniques applicable to Alps Electric (Ireland) Ltd and taken from BREF. Technical issue to be addressed in any technologies. Discussion of results 16 18 20 23 26 26 29 35 35 36 38 40 Assessment of air quality impacts due to classical air pollutants Carbon monoxide (CO) Oxides of nitrogen (NO2 as NOX) [email protected] 3 3 4 i 43 43 43 Confidential Report 2007A145(4) 4.1.3 4.1.4 4.1.5 4.2 Alps Electric (Ireland) Ltd Sulphur dioxide (SO2) Total particulates as PM10 Particulate based Lead Assessment of air quality impacts due to volatile organic compound air pollutants. 5. Conclusions 6. Appendix VI-Air dispersion modelling contour plots. 6.1 6.2 6.3 7. 43 44 44 45 48 Classical air pollutants for Scenario 2-proposed plant operation Total volatile organic compounds for Scenario 3-existing plant operation Total volatile organic compounds for Scenario 4-proposed plant operation 50 50 56 58 Appendix II-Meteorological data used within the Dispersion modelling study. 60 Appendix III: Checklist for EPA requirements for air dispersion modelling reporting 61 9. Appendix IV-Proposed emission guideline/limit values for emission points in Alps Electric (Ireland) Ltd. 62 8. [email protected] ii Confidential Report 2007A145(4) Alps Electric (Ireland) Ltd Document Amendment Record Client: Alps Electric (Ireland) Ltd) Title: Dispersion modelling assessment of stack processes located in Alps Electric (Ireland), Clara Rd, Millstreet, Co. Cork. Dispersion Document Reference: modelling assessment of stack process located in Alps Electric (Ireland), Clara Rd, Millstreet, Co. Cork. Project Number: 2007A145(4) 2007A145(1) 2007A145(2) 2007A145(3) 2007A145(4) Revision Document for review Minor amendments EPA comments Minor edits Purpose/Description [email protected] B.A.S. MW/MS AMD MW Originated iii JMC BAS BAS BAS Checked B.A.S B.A.S B.A.S B.A.S Authorised 20/06/2007 15/08/2007 12/12/2007 03/01/2008 Date Confidential Report 2007A145(4) Alps Electric (Ireland) Ltd EXECUTIVE SUMMARY Odour Monitoring Ireland was commissioned by Alps Electric (Ireland) Ltd, to perform a review of previous air quality data collected onsite, an air quality measurement and dispersion modelling assessment of emissions from ten emission points located within Alps Electric (Ireland) manufacturing facility, Clara, Rd, Millstreet, Co. Cork. The operation of processes within Alps Electric (Ireland) can lead to emissions of air pollutants and by using atmospheric dispersion modelling, the potential impact of these pollutants are assessed and compared to relevant ambient air quality objectives and limits including SI 271 of 2002, TA Luft 2002 and H1 Horizontal Guidance notes limit values. Background air quality data was obtained from available baseline air quality data generated by the Irish EPA. Data used within the air dispersion model was collated from previous monitoring reports generated by an environmental consultancy company while additional measurements were performed upon 5 emission points by staff from Odour Monitoring Ireland. All measurements performed by Odour Monitoring Ireland on the 27th April 2007 were performed in accordance with European standards where possible. These included: • • • • ISO10780:1994- Stationary source emissions-Measurement of velocity and volume flowrate of gas streams in ducts. IS EN13526:2002-Stationary source emissions-Determination of the mass concentration of total gaseous organic carbon in flue gases from solvent using processes-Continuous flame ionisation detector method. IS EN12619:1999-Stationary source emissions-Determination of the mass concentration of total gaseous organic carbon at low concentrations in flue gasesContinuous flame ionisation detector method. I.S. EN13649:2002-Stationary source emissions-Determination of the mass concentration of individual gaseous organic compounds-Activated carbon and solvent desorption method. The main compounds emissions from processes operating within Alps Electric (Ireland) include Oxides of nitrogen (NOX as NO2), Carbon monoxide (CO), Sulphur dioxide (SO2) and Particulate matter (PM as PM10) from boiler and Electric generator (process emission points A1-1 and A1-2) while various volatile organic compounds are emitted from the other eight emission points. Average modelling scenarios were performed to allow for comparison with relevant air quality criteria. These included 1-hour mean, 8-hour mean, 24-hour mean, Annual mean and maximum number of exceedence expressed as percentiles (see Table 2.1 and 2.2). All processes and source characteristics are outlined within the emission tables. Five years worth of meteorological was selected (Cork Airport 1993 to 1997) in order to ascertain average ground level concentrations of pollutants in accordance with the regulatory assessment criterion. Two scenarios were assessed to take account of percentile values and ground level concentrations (GLC’s) during routine operation and following the implementation of proposed mitigation techniques. This allowed for the assessment of the effectiveness of proposed mitigation techniques on predicted GLC’s. The following conclusions are drawn from the air quality impact assessment of process vents located in Alps Electric (Ireland) Ltd: 1. Twelve emission points are located within the Alps Electric (Ireland) Ltd boundary. In terms of emission characteristics, emission points A1-1 and A1-2 are combustion based for the production of steam and electricity while Emission points A2-1, A2-2, A23, A2-4, A2-6 and A2-7 are scheduled emission points from process operations located within the production building. Emission points A2-5, A4-1, A4-2 and A4-3 are considered fugitive emission points ventilated storage rooms located within the facility operations. In terms of significant emissions of VOC’s, vents A2-2, A2-6 and A2-7 would be considered highest with all other VOC emission points negligible in terms of mass emission. It proposed during future operations to operate emission point A1-2 [email protected] iv Confidential Report 2007A145(4) Alps Electric (Ireland) Ltd during the time period 16.45PM to 19.15PM Monday to Friday October to March on the winter demand scheme. 2. The existing and proposed boiler and generator (i.e. emission points A1-1 and A1-2) operations will not cause any significant classical air pollutant impact with all predicted ground level concentrations of Carbon monoxide, Oxides of nitrogen, Sulphur dioxide and Particulate matter within the regulatory guideline and limit values. In order to ensure compliance with statutory limit values, emission point A1-2 (generator) stack will require increasing up to a final height of 16.50 metres above ground level. 3. Following a review of historical particulate based lead emissions and dispersion modelling it was concluded that lead emissions are insignificant from process vents A2-2, A2-3 and A2-4. Particulate-based emission from these process vents is also insignificant. 4. Following a review of measured and historical emission profile data on speciated VOC’s (over two years), all maximum emission concentration of VOC’s are within their respective environmental assessment concentration level for the protection of human health. A screening mechanism was used to ascertain the maximum potential speciated VOC concentrations impact. Advanced dispersion modelling was used to predict maximum ground level and downwind concentration in order to allow for comparison with the assessment criteria. Isopropyl alcohol, Xylene isomers, Toluene, Butyl acetate, Ethyl benzene and Methyl isobutyl ketone were used for the screening exercise. 5. The overall individual impact of screened compounds Isopropyl alcohol, Xylene isomers, Toluene, Butyl acetate, Ethyl benzene and Methyl isobutyl ketone is within proposed Environmental Assessment Levels (EALs), and therefore in accordance with the requirements of H1 Guidance will not cause any significant impact. 6. Total volatile organic compounds as carbon as measured over a two-year period were used in conjunction with dispersion modelling to ascertain the maximum GLC’s of total VOC in the vicinity of the facility. This was compared to the regulatory assessment criteria contained within the Ta Luft guidance document. During existing operations, the overall plume spread and maximum GLC values are above the regulatory guideline values. Predictive modelling was used to ascertain the emission sources that contributed greatest to overall plume spread. Emission points A2-2, A2-6, A2-7 and to a lesser extent emission point A2-1 were found to contribute most while all other emission points contributing negligibly to ground level impact. 7. This was used to construct the basis of a predictive mitigation strategy where investigation of VOC emission minimisation (process optimisation and end of pipe abatement). Due to the air stream characteristics, three technologies may be suitable including regenerative thermal oxidation and non-thermal plasma technology. It was assumed for the dispersion modelling assessment that an exhaust gas concentration of less than or equal to 50 mg/Nm3 would be achieved (i.e. this is achievable on such technologies). Following implementation upon emission points A2-2, A2-6 and A2-7, the overall Total VOC impact will be less than 233 and 351 μg/m3 for the 98th and 99th percentile isopleths for 5 years of meteorological data utilising Aermod Prime dispersion model. [email protected] v Document No. 2007A145(1) 1. Introduction and scope 1.1 Introduction Alps Electric (Ireland) Ltd Following a conversation with Ms. Marie Walsh, Alps Electric (Ireland) Ltd, Odour Monitoring Ireland was requested to perform: • Volatile Organic Compound (VOC’s) monitoring assessment of five exhaust stacks ventilating five separate processes and projection of mass emission rates of VOC and classical air pollutant to atmosphere, • Review of historic monitoring data performed by an environmental consultancy company and projection of mass emission rates of VOC and classical air pollutant to atmosphere, • Dispersion modelling assessment of existing plant operation and comparison with relevant air quality criterion, • Dispersion modelling of proposed plant operation following the implementation of process optimisation, mitigation techniques and comparison with relevant air quality criterion. This allowed for the robust presentation of existing and proposed GLC’s of pollutants in the vicinity of the operating plant. Dispersion modelling was performed in accordance with recommended methodologies using three years of hourly sequential meteorological data in order to provide a statistical significant GLC profile of pollutants in the vicinity of the facility. Predicted dispersion modelling data was compared to National and European regulatory ground level guideline values. The proposed process optimisation and implementation of mitigation on a number of emission points will lead to the achievements of regulatory ground level guideline value for all assessed pollutants. 1.2 Scope of the work The main aims of the study included: • Volatile Organic Compound (VOC’s) monitoring assessment of five exhaust stacks ventilating five separate processes and projection of mass emission rates of VOC and classical air pollutant to atmosphere, • Review of historic monitoring data performed by an environmental consultancy company and projection of mass emission rates of VOC and classical air pollutant to atmosphere, • Dispersion modelling assessment of existing plant operation and comparison with relevant air quality criterion, • Development of VOC and classical air pollutant mitigation strategy to be implemented within the operating facility. • Dispersion modelling of proposed plant operation following the implementation of mitigation techniques and comparison with relevant air quality criterion. The approach adopted in this assessment is considered a worst-case investigation in respect of emissions to the atmosphere from the facility for the outlined scheduled emission sources. These predictions are therefore most likely to slightly over estimate the GLC’s that may actually occur for each modelled scenario. These assumptions are summarised and include: • Emissions to the atmosphere from the Boiler A1-1 process operation were assumed to occur 24 hours each day over a standard year; • Emissions to the atmosphere from the Electric Generator A1-2 process operation were assumed to occur between the hours 16.45PM to 19.15PM over the period October to March; • The Particulate matter is treated as an ideal gas and therefore no removal due to deposition (wet or dry) is accounted for in modelling scenarios, • The total particulate matter emitted from the stack sources is assumed to be all PM10. This is unlikely since varying particulate fraction size may be emitted. [email protected] 1 Document No. 2007A145(1) • • • • • Alps Electric (Ireland) Ltd All emissions were assumed to occur at maximum potential emission concentration and mass emission rates for each scenario. All emission points were assumed to emit simultaneously. All emissions of total VOC’s were assumed to occur simultaneously 24/7 365 days per year. This provides a conservative approach to the assessment of Total VOC’s. Maximum GLC’s + Background were compared with relevant air quality guidelines and limits. Worst-case available meteorological input data was assumed in the study with five years of hourly sequential met data used to provide more statistical significant results. This is in keeping with current national and international recommendations. AERMOD Prime dispersion modelling was utilised throughout the assessment. [email protected] 2 Document No. 2007A145(1) 2. Alps Electric (Ireland) Ltd Materials and methods This section describes the materials and methods used throughout the survey and dispersion modelling assessment. 2.1 VOC measurements and techniques. The following measurement methods were used by Odour Monitoring Ireland within Alps Electric (Ireland) Ltd to perform VOC emission rate calculation on 27th April 2007 on the specified emission points A2-1, A2-2, A2-3, A2-6 and A2-7. These included: • ISO10780:1994- Stationary source emissions-Measurement of velocity and volume flowrate of gas streams in ducts. • IS EN13526:2002-Stationary source emissions-Determination of the mass concentration of total gaseous organic carbon in flue gases from solvent using processes-Continuous flame ionisation detector method. • IS EN12619:1999-Stationary source emissions-Determination of the mass concentration of total gaseous organic carbon at low concentrations in flue gasesContinuous flame ionisation detector method. • I.S. EN13649:2002-Stationary source emissions-Determination of the mass concentration of individual gaseous organic compounds-Activated carbon and solvent desorption method. 2.1.1 Airflow rate measurement Airflow rate measurement was performed in accordance with ISO10780:1994-Stationary source emissions-Measurement of velocity and volume flowrate of gas streams in ducts. The following equipment was used through the airflow rate assessment. These included: • Testo 400 and 350/454 MXL handheld and differential pressure sensors, • L type pitot probe, • PT100 temperature probe, The following control procedure was used through the measurement sequence: 1. Measurement was performed at two diameters where possible at right angles to each other where possible, 2. The internal diameter of the ductwork was measured and verified using a SS rod, 3. Approximately, 5 duct diameters were available between the measurement point and the nearest obstruction for emission points A2-2 and A2-3. This was not available for emission point A2-1, Two methods were used on Points A2-2 and A2-3. Five duct diameters were available for A2-6 and A2-7. 4. The temperature profile across the stack was verified and did not differ by more than 5% from the average absolute temperature of the duct cross section, 5. Eight individual samples points excluding the duct centre point was used to determine the average flow at specified locations across the duct diameter. No sample point was located within 20 mm of the duct wall. 6. The difference in the average airflow velocity across each diameter did not exceed 5% of the mean for all the diameters (2 in total). 7. The number of sample points across the 2 diameters were determined in accordance with Table 7.1.4 of ISO10780:1994. The sample locations were marked upon the L type pitot using a water resistant marker. 8. The L type pitot was checked for any burrs and obstructions in the pitot orifices, 9. The absence of swirling flow was determined in accordance with Section 7.2 and Annex C-ISO10780:1994. 10. The measurement sequence was performed in accordance with the procedure described in Section 7.2-ISO10780:1994. The airflow rate measurement was used to ascertain the volumetric airflow from each emission points in order to determine the mass emission rate of VOC from each emission point. [email protected] 3 Document No. 2007A145(1) 2.1.2 Alps Electric (Ireland) Ltd Flame ionisation detector (FID) measurement A heated portable FID (Signal 3030PM) (MCERT certified to 15 & 500 mg/Nm3), heated line, controller and data logger was used to analyse the duct air stream for total hydrocarbon concentration as propane. An FID operates on the principle where influent contaminated gas is mixed with hydrogen and the mixture is burned at the tip of a jet with air or oxygen. Ions and free electrons are formed in the flame and enter a gap between two electrodes, the flame jet and a collector, mounted 0.51.0 centimetres above the flame tip. A potential (400 volts) is applied across the two electrodes and with the help of produced ions, a very small current flows between the two electrodes. When an organic substance is introduced this is burned in the flame; a complex process takes place in which positively charged carbon species and electrons are formed. The current is greatly increased and therefore the sample is detected. The FID is a mass flow detector, its response depending directly on the flow rate of the carrier gas. Its response also varies with applied voltage and the temperature of the flame. The following procedure was used for operating the FID: 1. The FID was switched on and the oven temperature and sample line temperature were allowed to stabilise. The set-point temperatures were 180 0C sample line temperature and 2000C oven temperature. This took approximately 45 minutes. 2. The Hydrogen/He fuel, and Propane calibration gases (50 and 500 ppm) were individually attached to the instrument. 3. Once temperatures had stabilised, the instrument was started and the ignition procedure was commenced. 4. Once ignited, the sample procedure was commenced and any VOC upon the sample line was baked off. 5. The analyser was zero calibrated and span calibrated. Zero air is supplied via the clean air supply catalytic oxidiser. There is less than 1% of range or 1.6 mg/m3 drift in eight hours whichever is greater (see Section 6.1 of EN12619:1999 and Section 6.2.1 EN13526:2001. 6. The analyser calibration procedure was rechecked and recorded, 7. The sample line was checked by presenting calibration gas in the sample line. The value was confirmed to be the value and recorded. This reading must be less than 5% difference from the span/zero reading. 8. The probe was inserted into the stack. 9. The datalogger was commenced (10 second intervals) and manual readings were taking and recorded (every 10 minutes). 10. The instrument was re-spanned every approximately 60 minutes to confirm calibration reading and to isolate any drift. 11. The recorded concentrations were converted for ppm TOC propane to mg/m3 TOC using the equation contained in Annex E and F of EN12619:1999 and EN13526:2001, respectively. The analyser is MCERT approved for both low and medium range VOC concentration levels. The MCERTS certification covers EN12619:1999. The FID remained analysing continuously in the duct air stream. Results were presented as mg [TOC] m-3 as propane. This was used to assess the VOC emission from each emission point and allowed the determination of cyclic emissions. [email protected] 4 Document No. 2007A145(1) Alps Electric (Ireland) Ltd 2.1.3. Speciated VOC monitoring of exhaust emission points A2-1, A2-2, A2-3. A2-6 and A2-7. 2.1.3.1 Sampling of VOC from exhaust emission points A2-1, A2-2, A2-3, A2-6 and A2-7. In order to obtain air samples for speciated VOC assessment, a static sampling method was used where air samples were collected in 10 litre pre-conditioned Tedlar sampling bags using a vacuum sampling device over a 20-minute period. The sampler operates on the 'lung principle', whereby the air is removed from a rigid container around the bag by a battery powered SKC vacuum pump at a rate of 0.50 l min-1. This caused the bag to fill through a stainless steel and PTFE tube whose inlet is placed in the air stream, with the volume of sample equal to the volume of air evacuated from the rigid container. Three Tedlar sample bags were taken from each exhaust stack process. All sample bags were pre-flushed with sample air in order to prevent any reductions in the actual VOC due to sample bag surface binding. A leak check was performed on the sample set-up by placing a Primary flow calibrator inline after the carbon/anasorb sorption tube (SKC 226-09). Once sample acquisition was completed, the sample bag was transferred to another location and connected to the sample pump, sorption tube and Primary flow calibrator. A charcoal/anasorb sorbent was chosen to efficiently bind and pre-concentrate speciated VOC for analysis by GCFID/GCMS in accordance with established and accredited methodologies. Sealed SKC sorbent tubes (SKC 226-09) were used throughout the study to maintain repeatability and integrity. In addition, the sorbent tube has a second plug to detect any breakthrough. Each tube contained a minimum of 200 mg of sorbent. All sampling for speciated VOC’s was performed in accordance with EN13649:2002. 2.1.3.2 Sorbent tube pre-concentration In order to pre-concentrate speciated VOC upon each sorbent, a pre-calibrated controlled volume of sample air was drawn through each tube by a SKC pump for a period range of 90 minutes depending on recorded results from the onsite FID analysis (Active sampling/pumped sampling). Each SKC pump was pre-calibrated with their specific sorbent using a Bios Primary flow calibrator (NIST traceable certified). Each pump was calibrated to a flow rate of approximately 111 ml min-1 depending on the sample, sample pump and sorbent tube as recommended by the sorbent manufacturer, analysing laboratory and sampling/test methodology. When sampling was completed all tubes were sealed and stored in flexible air tight containers and transported to the gas chromatography laboratory and analysed by means of thermal desorption/solvent extraction GCFID/GCMS in a UKAS accredited laboratory (RPS Laboratories, Manchester). All sample blanks were handled in the same manner to the sample tubes with the exception of being exposed to the flue gas. 2.2 Review of historical measurement data Over the past 2 years Alps Electric (Ireland) have performed through another Environmental consultancy company various measurements on emission points A1-1, A1-2, A2-1, A2-2, A2-3, A2-4 and A2-5. Measurements for classical air pollutants were performed upon A1-1 and A1-2 (i.e. boiler and Electric generator emission points (see Table 3.4) using standard techniques. Concentrations of Carbon monoxide (CO), Oxides of nitrogen (NOX as NO2), SO2, Total particulates, airflow rate and temperature were used to develop mass emission rates for use in conjunction with dispersion modelling to ascertain the ground level impacts of such pollutants and to allow for comparison with regulatory guidelines and limits. Measurements of Speciated Volatile organic compounds (SVOC’s), Total volatile organic compounds (TVOC’s), airflow rate and temperature were performed upon emission points A21, A2-2, A2-3, A2-4, and A2-5 (see Table 3.2 and 3.3). Mass emission rates of these [email protected] 5 Document No. 2007A145(1) Alps Electric (Ireland) Ltd compounds were used in conjunction with dispersion modelling in order to allow for the assessment of ground level impact of such compounds and to allow for comparison with regulatory guidelines and limits. Particulate based lead and total particulates were also assessed from emission points A1-1, A1-2, A2-2, A2-3 and A2-4. Mass emission rates of these compounds were used in conjunction with dispersion modelling in order to allow for the assessment of ground level impact of such compounds and to allow for comparison with regulatory guidelines and limits. All emission data and assumptions used in the dispersion modelling assessment are contained in Tables 3.1, 3.4 to 3.8. 2.3 Dispersion modelling assessment 2.3.1 Atmospheric dispersion modelling of air quality: What is dispersion modelling? Any material discharged into the atmosphere is carried along by the wind and diluted by wind turbulence, which is always present in the atmosphere. This process has the effect of producing a plume of air that is roughly cone shaped with the apex towards the source and can be mathematically described by the Gaussian equation. Atmospheric dispersion modelling has been applied to the assessment and control of emissions for many years, originally using Gaussian form ISCST 3. Once the compound emission rate from the source is known, (g s-1), the impact on the vicinity can be estimated. These models can effectively be used in three different ways: • Firstly, to assess the dispersion of compounds; • Secondly, in a “reverse” mode, to estimate the maximum compound emissions which can be permitted from a site in order to prevent air quality impact occurring; • And thirdly, to determine which process is contributing greatest to the compound impact and estimate the amount of required abatement to reduce this impact within acceptable levels (McIntyre et al. 2000). In this latter mode, models have been employed for imposing emission limits on industrial processes, control systems and proposed facilities and processes (Sheridan et al., 2002). Any dispersion modelling approach will exhibit variability between the predicted values and the measured or observed values due to the natural randomness of atmospheric environment. A model prediction can, at best, represent only the most likely outcome given the apparent environmental conditions at the time. Uncertainty depends on the completeness of the information used as input to the model as well as the knowledge of the atmospheric environment and the ability to represent that process mathematically. Good input information (emission rates, source parameters, meteorological data and land use characteristics) entered into a dispersion model that treats the atmospheric environment simplistically will produce equally uncertain results as poor information entered into a dispersion model that seeks to simulate the atmospheric environment in a robust manner. It is assumed in this discussion that pollutant emission rates are representative of maximum emission events, source parameters accurately define the point of release and surrounding structures, meteorological conditions define the local atmospheric environment and land use characteristics describe the surrounding natural environment. These conditions are employed within the dispersion modelling assessment therefore providing good confidence in the generated predicted exposure concentration values. [email protected] 6 Document No. 2007A145(1) 2.3.2 Alps Electric (Ireland) Ltd Atmospheric dispersion modelling of air quality: dispersion model selection The AERMOD model was developed through a formal collaboration between the American Meteorological Society (AMS) and U.S. Environmental Protection Agency (U.S. EPA). AERMOD is a Gaussian plume model and replaced the ISC3 model in demonstrating compliance with the National Ambient Air Quality Standards (Porter et al., 2003) AERMIC (USEPA and AMS working group) is emphasizing development of a platform that includes air turbulence structure, scaling, and concepts; treatment of both surface and elevated sources; and simple and complex terrain. The modelling platform system has three main components: AERMOD, which is the air dispersion model; AERMET, a meteorological data pre-processor; and AERMAP, a terrain data pre-processor (Cora and Hung, 2003). AERMOD is a Gaussian steady-state model which was developed with the main intention of superseding ISCST3 (NZME, 2002). The AERMOD modeling system is a significant departure from ISCST3 in that it is based on a theoretical understanding of the atmosphere rather than depend on empirical derived values. The dispersion environment is characterized by turbulence theory that defines convective (daytime) and stable (nocturnal) boundary layers instead of the stability categories in ISCST3. Dispersion coefficients derived from turbulence theories are not based on sampling data or a specific averaging period. AERMOD was especially designed to support the U.S. EPA’s regulatory modeling programs (Porter at al., 2003) Special features of AERMOD include its ability to treat the vertical in-homogeneity of the planetary boundary layer, special treatment of surface releases, irregularly-shaped area sources, a three plume model for the convective boundary layer, limitation of vertical mixing in the stable boundary layer, and fixing the reflecting surface at the stack base (Curran et al., 2006). A treatment of dispersion in the presence of intermediate and complex terrain is used that improves on that currently in use in ISCST3 and other models, yet without the complexity of the Complex Terrain Dispersion Model-Plus (CTDMPLUS) (Diosey et al., 2002). Input data from stack emissions, and source characteristics will be used to construct the basis of the modelling scenarios. 2.4 Air quality impact assessment criteria The predicted air quality impact from the proposed operation located in Alps Electric (Ireland) Ltd is compared to relevant air quality objectives and limits. Air quality standards and guidelines referenced in this report include: • • • • • • SI 271 of 2002 Air Quality legislation, EU limit values laid out in the EU Daughter directives on Air Quality 99/30/EC, Ta Luft of 2002 Air Quality Regulations, SI543 of 2002-Emissions of Volatile organic compounds from organic solvents regulations, 2002. Environmental Guidelines No.1 of 2002,-Guidelines for air emission regulation, Danish EPA. Horizontal guidance Note, IPPC H1, Environmental assessment and appraisal of BAT, UK Environment Agency. Air quality is judged relative to the relevant Air Quality Standards, which are concentrations of pollutants in the atmosphere, which achieve a certain standard of environmental quality. Air quality Standards are formulated on the basis of an assessment of the effects of the pollutant on public health and ecosystems. In general terms, air quality standards have been framed in two categories, limit values and guideline values. Limit values are concentrations that cannot be exceeded and are based on WHO guidelines for the protection of human health. Guideline values have been established for long-term precautionary measures for the protection of human health and the environment. [email protected] 7 Document No. 2007A145(1) Alps Electric (Ireland) Ltd European legislation has also considered standards for the protection of vegetation and ecosystems. Where ambient air quality criteria do not exist as in the case for some of the speciated substances of interest, it is usual to use • 1/100th of the 8-hour time weighted average occupational exposure limit (OEL)-Long term EAL as an annual average. • 1/500th of the 8 hour MEL time weighted average occupational exposure limit (OEL) Long term EAL as an annual average. • 1/10th of the 15-minute time weighted average occupational exposure limit (OEL)-Short term EAL as an hourly average. • 1/50th of the 15 minute MEL time weighted average occupational exposure limit (OEL) –short term EAL as an hourly average. Occupational exposure limits are published by the Occupational Safety and Heath Authority EH 40 notes and subsequent reviews. The relevant air quality standards for the Alps Electric (Ireland) Ltd facility are presented in Tables 2.1 and Table 2.2. [email protected] 8 Document No. 2007A145(1) 2.4.1 Alps Electric (Ireland) Ltd Air Quality Guidelines for classical pollutants in Ireland and Europe Table 2.1 illustrates the guideline and limit values for classical air quality pollutants in Ireland. 1 Table 2.1. EU and Irish Limit values laid out in the EU Daughter directive on Air Quality 99/30/EC and SI 271 of 2002 Objective Pollutant Exceedence expressed as Maximum No. Of 2 Concentration Measured as percentile3 exceedence allowed3 -3 300 μg m NO2 Nitrogen 1 hour mean 18 times in a year 99.79th percentile 200 μg m-3 NO2 dioxide and 1 hour mean th 18 times in a year 99.79 percentile -3 oxides of Annual mean 40 μg m NO2 ---3 nitrogen Annual mean (vegetation) 30 μg m NO2 -3 th 50 μg m 7 times in a year 98.08 percentile 24 hour mean Particulates -3 (PM10) 40 μg m Annual mean --20 μg m-3 Carbon 10 mg m-3 None 100th percentile Running 8 hour mean monoxide (CO) To be 4 achieved by 19 Jul 19994 1 Jan 2010 1 Jan 2010 ---1 Jan 20106 1 Jan 2005 1 Jan 20106 31st Dec 2003 1st Jan 2005 1 hour mean 24 hour mean 1st Jan 2005 Sulphur Annual mean and winter dioxide (SO2) 19th Jul 20015 mean (1st Oct to 31st March 0.50 μg m-3 01st Jan 2005 -Annual limit -3 th 2.50 μg m 98 percentile 175 times in a year TA Luft 2002 1 hour mean Lead 87 times in a year C Value Annual limit 0.50 μg m-3 -Danish EPA 1 hour mean 99th percentile 0.40 μg m-3 1/100th EH40 Annual mean 1.50 μg m-3 Notes: 1 denotes Directive 99/30/EC: Council Directive 1999/30/EC of 22nd April 1999 relating to limit values for sulphur dioxide, nitrogen dioxide and oxides of nitrogen and particulate matter in ambient air; 2 denotes conversions of ppb and ppm to μg m-3 and mg m-3 at 293.15 Kelvin and 101.3 Kpa; 3 denotes Number of exceedence are quoted in the directive, exceedence or percentiles are used in AMDS; 4 A margin of tolerance is accepted while limit value is phased in; this will reduce progressively every year; 5 denotes limit value for the protection of vegetation/ecosystem; 6 denotes Stage 2 values to be achieved by EU following the implementation of Stage 1. 350 μg m-3 125 μg m-3 20 μg m-3 [email protected] 99.73th percentile 99.18th percentile -- 24 times in a year 3 times in a year -- 9 Document No. 2007A145(1) Alps Electric (Ireland) Ltd Table 2.2 illustrates the guideline and limit values for VOC based pollutants as taken from specified references. Both a limit for total VOC and individual identified VOC’s are presented to allow comparison of impact with guideline values. Table 2.2. EU regulatory limit and guideline values for Total VOC and Speciated VOC compounds as laid out in the Ta Luft of 2002, Danish EPA Notes, 2002, Horizontal H1 guidance documents and fractional exposure from EH40 values. Pollutant Concentration 2 Objective Maximum No. Of exceedence allowed3 Exceedence expressed as percentile3 Measured as Class III Class II Class I Total VOC as Carbon 1000 μg m-3 -3 200 μg m -3 50 μg m 100 μg m-3 175 times in a year 175 times in a year 175 times in a year 175 times in a year 98 percentile th 98 percentile 98th percentile 98th percentile 1 hour mean Class III 1 hour mean Class II 1 hour mean Class I 1 hour mean Class I Class II Class III ≤10 μg m-3 > 10 ≤ 200 μg m-3 > 200 μg m-3 87.60 times in a year 87.60 times in a year 87.60 times in a year 99th percentile th 99 percentile 99th percentile 1 hour mean 1 hour mean 1 hour mean [email protected] 10 th Source Ta Luft of 1986 Ta Luft 2002 & 1996 Industrial Air Pollution Control Guidelines No. 9/1992, Danish EPA Document No. 2007A145(1) Alps Electric (Ireland) Ltd Table 2.2 continued. EU regulatory limit and guideline values for Total VOC and Speciated VOC compounds as laid out in the Ta Luft of 2002, Danish EPA Notes, 2002, Horizontal H1 guidance documents and fractional exposure from EH40 values Speciated VOC identified in air stream in Alps Electric over 2 year period EAL-Long termannual mean EAL-short term- 1 hour mean Isopropyl alcohol Xylene isomers Cyclo pentane 2 propanol 1 ethoxy 2 hexanone 5 methyl 1-methoxy-2 propyl acetate Methyl isobutyl ketone Methyl ethyl ketone Ethyl benzene Butyl acetate Ethyl acetate Methyl cyclopentane Cyclohexane 1,3,5 Trimethylbenzene Toluene Ethanol Acetone Tetrahydrofuran Hexane Heptane Cyclohexanone 1-Pentene 2,710 4,410 ---3,750 --4,410 7,240 14,600 -3,500 1,250 1,910 19,200 18,100 3000 720 -1020 -- 81,300 66,200 ---112,000 --55,200 96,600 420,000 -105,000 37,500 8,000 576,000 362,000 59,900 21,600 -40,800 -- Source: Fractional OEL 8 hourAnnual mean 9800 2210 1720 -950 -830 6000 1000 7100 14000 -3400 1000 500 19000 12100 1180 18000 16000 408 -- Fractional OEL 15 minute-1 hour mean 122500 44200 ----20800 90000 -95000 --103000 ----29500 360000 200000 8,160 -- Maximum No. Of 3 exceedence allowed Annual limit for Long term exposure data Exceedence expressed as 3 percentile 100th percentile 1 hour mean for short term exposure data Ta Luft of 2002 Air Quality Regulations, Environmental Guidelines No.1 of 2002,-guidelines for air emission regulation, Danish EPA. Horizontal guidance Note, IPPC H1, Environmental assessment and appraisal of BAT, UK Environment Agency. EH40 notes, National Authority for Occupational Safety and Health (2002). [email protected] 11 Measured as Annual mean 1 hour mean Source H1 Guidance notes. EH40 exposure data and fractional analysis Document No. 2007A145(4) 2.5 Alps Electric (Ireland) Ltd Existing Baseline Air Quality The EPA has been monitoring national Air quality from a number of sites around the country. This information is available from the EPA’s website. The values presented for PM10, SO2, NO2, CO and Lead give an indication of expected urban and suburban emissions of the compounds listed in Table 2.1. Table 2.3 illustrates the baseline data expected to be obtained from Zone C/D sites. Since Alps Electric (Ireland) Ltd site is located in a suburban area of a small town, it would be considered located in a Zone C area according to the EPA’s classification of zones for air quality. Traffic and industrial related emissions would be medium. [email protected] 12 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Table 2.3. Baseline air quality data used to assess air quality impact criterion in Zone C/D regions. Nitrogen dioxideParticulate matter-PM10 Reference air quality data-Source NO2 (μg m-3) hourly -3 (μg m )-Daily/Annual identity max and annual mean mean Naas (Zone C) Mountrath (Zone C/D) Kilkenny (Zone D) Tralee (Zone C) Notes: 1 Maximum 2.30 Mean hourly value 28.30 Maximum 2.60 Annual mean 13.0 Annual mean 9.0 --- Mean daily value 16.90 Mean hourly value 9.60 Mean daily value 22.50 13 Sulphur dioxideLead (μg m-3) SO2 (μg m-3) maximum Maximum 24 hour mean 23.60 Mean hourly value 25.90 Mean daily value 17.30 denotes EPA monitoring reports 2003, 2004 to 2005, [email protected] Carbon monoxide-CO -3 (mg m ) 8 hour running max Maximum hourly value 64.60 Maximum 24 hour mean 12 Maximum hourly value 28.20 Maximum 1.90 Annual mean 5.0 Details Annual mean Measured 2004 0.006 to 2005 Annual mean Measured 2004 0.03 to 2005 Annual mean Measured 2004 0.01 to 2005 Maximum 24 hour Annual mean Measured 2003 17.70 0.01 to 2004 Maximum 1 hour 63.60 Document No. 2007A145(4) 2.6 Alps Electric (Ireland) Ltd Site location, and locations of sensitive receptors Figure 2.1. Site location map for Alps Electric (Ireland) Ltd illustrating relative location of sensitive receptors and boundary ( [email protected] 14 ). Document No. 2007A145(4) Alps Electric (Ireland) Ltd Figures 2.1 illustrate Alps Electric (Ireland) Ltd site and the relative location of boundary and receiving environment. Approximately 10 residential properties are located 25 metres from the northwest and northeastern boundary of the facility. The dispersion modelling assessment accounts for all sensitive receptors approximately 1.04 Km radius inside and outside the boundary of the facility with no dependencies on location. A 40 metre Cartesian grid network was established providing 725 and 1341 receptor points inside and outside the boundary depending on model run. In addition, all receptors were established at a height of 1.80 metres within the dispersion model assessment. 10 metre spaced boundary receptors were also established within the dispersion modelling scenarios providing an additional 49 receptors. Building structures are examined within the dispersion modelling assessment at varying heights to account for building wake effects (i.e. Building structures located within the Alps Electric (Ireland) site, while all stack heights and efflux velocities were provided from scaled maps and measurements. 2.7 Meteorological data Three years of hourly sequential meteorological data was chosen for the modelling exercise (i.e. Cork Airport 1993 to 1997 inclusive). Cork Airport was chosen as the representative meteorological station. A schematic wind rose and tabular cumulative wind speed and directions of all five years is presented in Section 7. All five years of met data was used to provide more statistical significant result output from the dispersion model. This is in keeping with national and international recommendations on quality assurance in operating dispersion models. 2.8 Terrain data Topography effects were accounted for within the dispersion modelling assessment, as terrain effects in the vicinity of the site were considered complex. Ten metre spaced topographical data was processed and inputted into the dispersion model through the AERMAP software tool. This allow for the accurate assessment of terrain effects on the dispersion of pollutants in the vicinity of the operating site. 2.9 Building wake effects Building wake effects are accounted for in modelling scenarios (i.e. all building features located within Alps Electric (Ireland) facility) as this can have a significant effect on the compound plume dispersion at short distances from the source and can significantly increase GLC’s in close proximity to the facility. Since there are residential properties close to the facility boundary it was prudent to take account of such effects. [email protected] 15 Document No. 2007A145(4) 3. Alps Electric (Ireland) Ltd Results This section describes the results obtained during the survey. 3.1 Volumetric airflow rate results for all emission points. Table 3.1 illustrates the average airflow rates and volumetric airflow emission rates from process vents A2-1, A2-2, A2-3, A2-6, A2-7 as measured onsite on the 27th April 2007. In addition, the historical data for airflow rate for emission points A1-1, A2-4 and A2-5 is provided. Estimated airflow rate were obtained from the equipment manufacturer for emission point A12. Based on existing data from emission points on site, a theoretical volumetric airflow rate was estimated for emission point A4-1, A4-2 and A4-3. Emission point gas temperature and source characteristics such as vent area and height are also included to allow for review of the data. [email protected] 16 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Table 3.1. Historical and measured airflow velocity and volumetric airflow rate process vent point results. Sample ID A1-1 Sample location description Existing Existing Normalised Average Normalised Temperature X Y ground stack Stack Duct area volume flow rate volume flow rate Airflow velocity 2 (K) coordinate coordinate level height height (m) (m ) level 3 -1 3 (Nm hr ) (m/s) (m /s) (m) height (m) Main boiler 126863.3 89628.6 133.71 142.78 9.07 0.05 8.20 420 942 0.35 1 Standby generator 126881.2 89603.7 133.71 141.83 8.12 0.11 11.90 410 3,151 1.09 A2-1 1 89545.4 133.71 144.23 10.52 1.23 3.99 291 16,619 4.62 A2-2 126860.8 89615.4 133.71 140.51 6.8 0.20 16.30 301 10,451 2.90 A2-3 1 126870 89610.4 133.71 141.14 7.43 0.13 7.30 294 3,067 0.85 A2-4 1 PAL room extraction stack Solderwave/Concoat machine extraction point Spot dip machine extraction point SMT machine extraction point 126868.4 1 A2-5 1 A1-2 126895.5 89559.7 133.71 141.12 7.41 0.20 6 309 3,748 1.04 Storage shed extraction point 126879.4 89536.4 133.71 135.7 1.99 0.20 5 298 3,339 0.93 A2-6 PAL area extraction stack 126858.4 89547 133.71 142.9 9.19 0.28 9.30 291 8,882 2.47 A2-7 PAL area extraction stack 126853.2 89556.7 133.71 142.9 9.19 0.28 8.70 292 8,280 2.30 Sludge storage area extraction Paint and laser tray cleaning area extraction point Hazardous waste storage area extract point 126855.8 89552 133.71 142.9 9.19 0.28 3.38 298 3,339 0.93 126905.4 89551 133.71 135.7 1.99 0.20 5.0 298 3,339 0.93 126880.3 89536.7 133.71 135.7 1.99 0.20 5.0 298 3,339 0.93 A4-1 A4-2 1 A4-3 1 Notes: 1 denotes that due to constraints within the ISO10780:1994, measurement did not concur to the standard. The required 5 duct diameters were not available between the nearest obstructions. [email protected] 17 Document No. 2007A145(4) Alps Electric (Ireland) Ltd 3.2 Historic and measured Total organic concentration results (as measured on a FID) carbon emission Table 3.2 illustrates the average TOC concentration and mass emission rates from process vents A2-1, A2-2, A2-3, A2-6 and A2-7 as measured onsite between the hours of 13.00 PM and 16.55 PM on the 27th April 2007. During the measurement sequence on the 27th April 2007, intermittent instrument span check were performed. VOC hang-up in the sample line was also assessed to ensure no bias in results in the outlet stack. This was performed by removing the sample probe from the stack and checking displayed VOC readings and comparing to initial start-up reading. In addition, historical data was reviewed for emission points A2-4 and A2-5. Estimations were calculated for emission vents A4-1, A4-2 and A4-3 since these emission points are similar in characteristics to emission points A2-5. All data is presented as total carbon results in accordance with European standards EN12619: 1999 and EN13526: 2002. [email protected] 18 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Table 3.2. Measured and historical Total organic carbon (as carbon) (TOC) emissions from process vents in Alps Electric (Ireland) Ltd. Sample location Sample location description TOC concentration 3 1 (mg/Nm ) Volumetric airflow rate 3 (Nm /s) Normalised Mass loading/emission 1,3 (g/s) Normalised Mass loading/emission 1,3 (kg/hr) Notes Minimum TOC reading 7.98 mg/Nm3 Maximum TOC reading 58.54 mg/Nm3 Minimum TOC reading 252 mg/Nm3 Maximum TOC reading 386 mg/Nm3 Minimum TOC reading 42.57 mg/Nm3 Maximum TOC reading 87.81 mg/Nm3 --Minimum TOC reading 212.86 mg/Nm3 Maximum TOC reading 367.19mg/Nm3 Minimum TOC reading 478.95 mg/Nm3 3 Maximum TOC reading 651.90 mg/Nm -- A2-11,2 PAL room extraction stack 42.57 4.62 0.20 0.71 A2-21,2 Solderwave/Concoat machine extraction point 292.6 2.90 0.85 3.0 A2-31,2 Spot dip machine extraction point 63.86 0.85 0.05 0.20 SMT machine extraction point Storage shed extraction point 0.50 31.20 1.04 0.93 0.0005 0.03 0.0019 0.10 A2-61,2 PAL area extraction stack 303.33 2.47 0.75 2.70 A2-71,2 PAL area extraction stack 598.68 2.30 1.38 4.96 Sludge storage area extraction Paint and laser tray cleaning area extraction point Hazardous waste storage area extract point 31.20 0.93 0.03 0.10 31.20 0.93 0.03 0.10 -- 31.20 0.93 0.03 0.10 -- - - - 12.032 A2-4 A2-5 3 A4-1 3 A4-2 3 A4-33 Total VOC - Total average mass emission rate of VOC from ALPS Electric Notes:1 denotes that normalised to 273.15 K and 101.3 kPa and converted to TOC as carbon from propane using conversion factor of 1.60 (see EN12619:1999). 2 both zero, span and VOC hang-up checks performed intermittently on the FID analyser in order to verify correct operation. In addition, the FID oven and sample line temperature were checked and verified intermittently. 3 denotes data extracted from historical monitoring reports. [email protected] 19 Document No. 2007A145(4) Alps Electric (Ireland) Ltd 3.3. Measured and historical speciated VOC results from emission points located in Alps Electric (Ireland) Ltd. Table 3.3 illustrates the results obtained from active sorbent tube sampling and analysis both performed on site and extracted from historical data. An indirect sampling methodology (i.e. Static) was used whereby sample air was vacuumed using the lung principle into pre-flushed Tedlar sampling bags. Samples were taken from five process vent points during routine operation on the 27th April 2007. Sample bags were sealed and pre-concentration as performed in a separate location using pre-calibrated sampling pumps. Calibration of pumps was performed using a Primary flow calibrator (NIST traceable) and checked for calibration before and after sampling. Sample tubes were then sealed and transported to the analytical laboratory for analysis via solvent extraction GCMS analysis in a UKAS accredited laboratory (RPS Labs, Manchester). In addition, historical reports were reviewed and available data extracted to allow for characterisation of the emission vent points. The results of the measurement and historical report survey are presented in Table 3.3. Currently process emission points A2-2, A2-6 and A2-7 will be regulated under the Solvent Regulations SI543 of 2002. [email protected] 20 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Table 3.3. Average measured and historical speciated VOC sampling and analysis results for each emission point located in Alps Electric (Ireland) Ltd. Sample identity Process identity Compound identity Isopropyl alcohol Butyl acetate Ethyl benzene Other VOC's Total VOC’s Isopropyl alcohol Methyl isobutyl ketone Methyl ethyl ketone Ethyl benzene Butyl acetate Other VOC's Total VOC Butyl acetate Isopropyl alcohol Methyl ethyl ketone Other VOC's Total VOC Detected conc. as C (mg/Nm3) 4.90 16.40 3.80 13.40 38.50 49.60 12.60 11.40 9.50 18.40 42.60 144.10 4.4 8.40 2.20 14.60 29.60 Volumetric airflow rate (m3/s) 4.62 4.62 4.62 4.62 4.62 2.90 2.90 2.90 2.90 2.90 2.90 2.90 0.85 0.85 0.85 0.85 0.85 Mass emission rate (g/s) 0.0226 0.0758 0.0176 0.0619 0.1779 0.1438 0.0365 0.0331 0.0276 0.0534 0.1235 0.4179 0.0037 0.0071 0.0019 0.0124 0.0252 Mass emission rate (kg/hr) 0.0815 0.2728 0.0632 0.2229 0.6403 0.5178 0.1315 0.1190 0.0992 0.1921 0.4447 1.5044 0.0135 0.0257 0.0067 0.0447 0.0906 Sample No. 1898403160 A2-1-PAL room extraction stack Sample No. 1898403162 A2-2-Solderwave/ Concoat machine extraction point Sample No. 1898403169 A2-3-Spot dip machine extraction point Historical data A2-4- SMT machine extraction point Total VOC’s <0.50 1.04 0.0005 0.0019 A2-5- Storage shed extraction point2 Ethanol Butyl acetate Toluene Ethyl benzene Xylene isomers Acetone Tetrahydrofuran Methyl ethyl ketone Methyl isobutyl ketone Cyclohexanone 1,3,5 Trimethylbenzene Hexane Heptane Total VOC 0.18 30 1.63 3.06 3.18 2.28 0.03 0.29 10.3 1.31 0.03 0.07 0.04 31.20 0.93 0.93 0.93 0.93 0.93 0.93 0.93 0.93 0.93 0.93 0.93 0.93 0.93 0.93 0.0002 0.0279 0.0015 0.0028 0.0030 0.0021 0.0000 0.0003 0.0096 0.0012 0.0000 0.0001 0.0000 0.0290 0.0006 0.1004 0.0055 0.0102 0.0106 0.0076 0.0001 0.0010 0.0345 0.0044 0.0001 0.0002 0.0001 0.1045 Historical data [email protected] 21 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Table 3.3 continued. Average measured and historical speciated VOC sampling and analysis results for each emission point located in Alps Electric (Ireland) Ltd. Sample No. 1898403165 A2-6- PAL area extraction stack Sample No. 1898403164 A2-7- PAL area extraction stack Estimated data A4-1- Sludge storage area extraction Estimated data A4-2- Paint and laser tray cleaning area extraction point Estimated data A4-3- Hazardous waste storage area extract point Notes: Ethyl acetate Methyl cyclopentane Heptane Cyclohexane Other VOC's Total VOC Butyl acetate Methyl cyclopentane Ethyl benzene P+M Xylene Other VOC's Total VOC Total VOC-Assume similar gas phase profile to Emission point A2-5 Total VOC-Assume similar gas phase profile to Emission point A2-5 Total VOC-Assume similar gas phase profile to Emission point A2-5 1 71.77 20.71 25.38 16.92 107.36 242.15 58.16 31.51 78.59 33.24 184.50 386.00 2.47 2.47 2.47 2.47 2.47 2.47 2.30 2.30 2.30 2.30 2.30 2.30 0.1773 0.0512 0.0627 0.0418 0.2652 0.5981 0.1338 0.0725 0.1808 0.0765 0.4244 0.8878 0.6382 0.1842 0.2257 0.1505 0.9546 2.1532 0.4816 0.2609 0.6507 0.2752 1.5277 3.1961 31.20 0.93 0.0290 0.1045 31.20 0.93 0.0290 0.1045 31.20 0.93 0.0290 0.1045 denotes an ambient temperature of 293K during pre-concentration. denotes that two separate sampling events were performed upon the headspace of the building. In order to assess the EAL and fractional 3 exposure the profiles for both surveys are combined. The maximum total concentration measured was 31.20 mg/Nm with the butyl acetate the predominant compound. All other VOC’s were detected during sample event 2 with a total VOC concentration of 23 mg/Nm3 detected. 2 [email protected] 22 Document No. 2007A145(4) Alps Electric (Ireland) Ltd 3.4. Measured and historical classical air pollutants from emission points located in Alps Electric (Ireland) Ltd. Table 3.4, 3.5, 3.6, 3.7 and 3.8 illustrates the results obtained from review of historical emission monitoring data from emission point A1-1, A1-2, A2-2, A2-3 and A2-4 for classical air pollutants. This data was used to construct the mass emission profile of the vents identified. In order to allow for the predictive analysis of downwind concentrations of such pollutants. Carbon monoxide, Oxides of nitrogen, sulphur dioxide, Total particulates as PM10, Lead, Temperature and volumetric airflow rate were measured onsite. The results of the review of the historical report surveys are presented in Table 3.4 to 3.8. In terms of emission point A1-2 operation, the generator has the following characteristics: • • • • • • • Proposed hours of operation 16.45PM to 19.15PM Monday to Friday, October to March each year. Type of ignition is standard starter motor as per all diesel engines, Output power is rated at 1500 kVA Thermal efficiency is unknown Burn strategy is unknown Maximum fuel rate is unknown Maintenance on generator is every 250 to 300 hours operation or annually which ever occurs first. The operation of the generator will occur under the winter demand scheme for a time period 16.45PM to 19.15PM Monday to Friday October to March. In terms of BAT consideration for such operation this limited operation is considered BAT. Coupled with an increase in stack height up to 16.50 m, ground level impact of pollutants will remain within the SI 271 of 2002 limit values. Emergency operation will only occur when power outages occur during production hours. [email protected] 23 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Table 3.4. Historically measured concentration of classical air pollutants for emission vents A11 and A1-2 in Alps Electric (Ireland) Ltd. Emission point A1-1 Emission point 1-2 Compound identity 3 3 (mg/Nm ) (mg/Nm ) Oxygen (%) 3.8 17 3 Carbon monoxide (CO) (mg/Nm ) 1.25 251.25 Oxides of nitrogen (NOx as NO2) 160.18 1047.32 (mg/Nm3) 3 Sulphur dioxide (SO2) (mg/Nm ) 131.43 23 Total particulates (TP as PM10) 9.9 8 (mg/Nm3) Temperature (K) 420 410 Volumetric airflow rate (Nm3/hr) 942 3151 Diameter (m) 0.25 0.375 Area (m2) 0.049 0.110 Airflow rate (m/s) 8.2 11.9 Table 3.5. Historically measured concentration of classical air pollutants referenced to 3% Oxygen for emission point A1-1 and 5% Oxygen for emission point A1-2 in Alps Electric (Ireland) Ltd. Emission point A1-1 (mg/Nm3 Emission point 1-2 (mg/Nm3 Compound identity ref to 3% O2) ref to 5% O2) Oxygen (%) 3.8 17 Carbon monoxide (CO) 1.31 1024 (mg/Nm3) Oxides of nitrogen (NOx as 168 4,270 NO2) (mg/Nm3) Sulphur dioxide (SO2) 138 94 (mg/Nm3) Total particulates (TP as PM10) 10 33 (mg/Nm3) Temperature (K) 420 410 Volumetric airflow rate 942 3151 (Nm3/hr) Diameter (m) 0.25 0.375 2 Area (m ) 0.049 0.110 Airflow rate (m/s) 8.2 11.9 Table 3.6. Mass emission rate of classical air pollutants for emission points A1-1 located within Alps Electric (Ireland) Ltd. Total emission rate for Volumetric airflow Compound conc. Compound identity emission point A1-1 3 3 (mg/Nm ) rate (Nm /s) (g/s) Carbon monoxide (CO) 0.261 1.25 0.0003 (mg/Nm3) Oxides of nitrogen (NOx as 0.261 160.18 0.0418 NO2) (mg/Nm3) Sulphur dioxide (SO2) 0.261 131.43 0.0343 (mg/Nm3) Total particulates (TP as 0.261 9.90 0.0026 3 PM10) (mg/Nm ) Notes: 1 denotes boiler operates on demand and therefore would not emit pollutants continuously. [email protected] 24 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Table 3.7. Mass emission rate of classical air pollutants for emission points A1-2 located within Alps Electric (Ireland) Ltd. Total emission rate for Volumetric airflow Compound conc. Compound identity emission point A1-2 3 3 rate (Nm /s) (mg/Nm ) 1 (g/s) Carbon monoxide (CO) 0.88 251.25 0.2211 (mg/Nm3) Oxides of nitrogen (NOx as 0.88 1047.23 0.9216 NO2) (mg/Nm3) Sulphur dioxide (SO2) 0.88 23 0.0202 (mg/Nm3) Total particulates (TP as 0.88 8.0 0.0070 PM10) (mg/Nm3) Notes: 1 denotes standby generator will only operated from Monday to Friday October to March 16.45PM to 19.15PM during this period. Mechanical servicing and tuning of generator should occur once per year. Table 3.8. Mass emission rate of Total particulates for emission points A2-2, A2-3 and A2-4 located within Alps Electric (Ireland) Ltd. Sample location Process description Solderwave/Concoat machine extraction point Spot dip machine extraction point SMT machine extraction point A2-21 A2-3 A2-4 Total mass emission -- Volumetric air flow rate (Nm3/s) Total Particulates as PM10 3 g/s mg/Nm Lead (Pb)2 mg/Nm 3 g/s 2.90 <10 2.90E-02 <0.001 2.90E-06 0.85 <10 8.52E-03 <0.001 8.52E-07 1.04 <10 1.04E-02 <0.001 1.04E-06 -- -- <6.23E-02 -- <4.80E-06 1 denotes historical particulate measurements have only detected particulate in emission point 2-2. 2 denotes historical Lead emission data (particulate based lead only) has been below 1 μg/Nm3. [email protected] 25 Document No. 2007A145(4) 3.5 Alps Electric (Ireland) Ltd Dispersion modelling assessment AERMOD Prime was used to determine the overall air quality impact of Alps Electric (Ireland) Ltd emission point operations located in Millstreet, Co. cork. These computations give the relevant GLC’s at each 40-meter X Y Z Cartesian grid receptor location that is predicted to be exceeded for the specific air quality impact criteria. The results of the dispersion modelling assessment are divided into two distinct sections in order to provide clarity on the existing and proposed site operations for each pollutant dataset. Section 3.5.1 will present the results for the classical air pollutant impact assessment, while Section 3.5.2 and 4.2 will present the results for the volatile organic compound air pollutant impact assessment. 3.5.1 Results of dispersion modelling assessment for Classical air pollutants. Various averaging intervals were chosen to allow direct comparison of predicted GLC’s with the relevant air quality assessment criteria as outline in Table 2.1. In particular, 1-hour, 8hour, 24 hour, and annual average GLC’s of the various pollutants were calculated at various distances from the site. Relevant percentiles of these GLC’s were also computed for comparison with the relevant Air Quality Standards presented in Table 2.1 (see Table 3.4 to 3.8 for input data) (ref: Scenario 1 and 2 below). Ref: Scenario 1: Dispersion modelling assessment of existing operations located within Alps Electric (Ireland) Ltd for classical air pollutants (Emission points A1-1, A2-2, A2-3 and A2-4 for Carbon monoxide, Oxides of nitrogen, Sulphur dioxide, Total particulates and Lead). Ref: Scenario 2: Dispersion modelling assessment of proposed operations located within Alps Electric (Ireland) Ltd for classical air pollutants (i.e. the addition of emission point A1-2 to Scenario 1, increase in emission point A1-2 stack height to 16.50 metres and operation hours of 16.45PM to 19.15PM Monday to Friday between October to March). Table 3.9 and 3.10 illustrates the tabular results obtained from the dispersion modelling assessment for Scenarios 1 and 2. Maximum predicted GLC’s for the percentile scenario are presented within this table to allow for comparison with SI 271 of 2002 and other specified regulations and assessment criterion. In addition, graphical contour plots are provided for information within Appendix I (ref: Section 6) for the proposed scenarios only. [email protected] 26 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Table 3.9. Tabular illustration of Predicted maximum percentile GLC’s in the vicinity of Alps Electric (Ireland) Ltd emission points (see Table 3.6 and 3.8) for Scenario 1-existing site operations. Identity-Scenario 1 existing operation using existing stack Compound characteristics Maximum percentile predicted GLC conc. Percentile value (%) -3 (μg m ) Maximum 8 hour concentration CO 0.42 100th Maximum 1 hour concentration NO2 as NOX 84.14 100th Maximum 1 hour concentration NO2 as NOX 61.40 99.79th Maximum annual mean concentration NO2 as NOX 7.05 - Maximum 24 hour concentration PM as PM10 32 100th Maximum 24 hour concentration PM as PM10 20.50 98.08th Maximum annual mean concentration PM as PM10 8.95 - Maximum 1 hour concentration SO2 69 100th Maximum 1 hour concentration SO2 47 99.73th Maximum 24 hour concentration SO2 28.40 100th Maximum 24 hour concentration SO2 20.12 99.18 Maximum annual mean concentration SO2 5.79 - Maximum 1 hour Pb (as particulate) 0.035 100 Maximum 1 hour Pb (as particulate) 0.0124 99th Maximum 1 hour Pb (as particulate) 0.0093 98th Maximum annual mean concentration Pb (as particulate) 0.00257 - [email protected] 27 th th Document No. 2007A145(4) Alps Electric (Ireland) Ltd For Scenario 2 operations, the generator emission point A1-2 will be operated between the periods of October to March between the hours of 16.45 PM to 19.15 PM Monday to Friday. This will result in emissions of Carbon monoxide, Oxides of nitrogen, Sulphur dioxide, and Particulate matter. At present the existing stack height of the generator is 8.12m. This will be increased to a height of 16.50 metres in order to achieve ground level limit values. No other source characteristics will change. This will result in a reduction in the short-term impact of such classical air pollutants to within their respective GLC’s limit values. Table 3.10. Tabular illustration of Predicted maximum percentile GLC’s in the vicinity of Alps Electric (Ireland) Ltd emission points (see Table 3.6, 3.7 and 3.8) for Scenario 2-proposed site operations. Identity-Scenario 2 proposed operation using proposed stack characteristics Maximum percentile predicted GLC conc. Percentile value (%) Compound -3 (μg m ) Maximum 8 hour concentration CO 49.50 100th Maximum 1 hour concentration NO2 as NOX 181 100th Maximum 1 hour concentration NO2 as NOX 61.40 99.79th Maximum annual mean concentration NO2 as NOX 7.05 - Maximum 24 hour concentration PM as PM10 32 100th Maximum 24 hour concentration PM as PM10 20.50 98.08th Maximum annual mean concentration PM as PM10 8.95 - Maximum 1 hour concentration SO2 69 100th Maximum 1 hour concentration SO2 46.50 99.73 Maximum 24 hour concentration SO2 28.40 100th Maximum 24 hour concentration SO2 20.10 99.18 Maximum annual mean concentration SO2 5.79 - Maximum 1 hour Pb (as particulate) 0.035 100th Maximum 1 hour Pb (as particulate) 0.0124 99th Maximum 1 hour Pb (as particulate) 0.0093 98th Maximum annual mean concentration Pb (as particulate) 0.00257 - [email protected] 28 th th Document No. 2007A145(4) Alps Electric (Ireland) Ltd 3.5.2 Results of dispersion modelling assessment for Volatile organic compound pollutants. Various averaging intervals were chosen to allow direct comparison of predicted GLC’s with the relevant air quality assessment criteria as outline in Table 2.1. In particular, 1-hour and percentile average GLC’s of Total volatile organic compounds were calculated at various distances from the site. Relevant percentiles of these GLC’s were also computed for comparison with the relevant proposed assessment criteria presented in Table 2.2 (see Table 3.2 and 3.3 for input data for existing site operations) (ref: Scenario 3). Ref: Scenario 3: Dispersion modelling assessment of existing operations located within Alps Electric (Ireland) Ltd for Total volatile organic compounds (see Table 3.2 for input data). In terms of overall VOC’s currently, emission points A2-2, A2-6 and A2-7 emit the greatest mass of VOC from the facility operations. The overall mass emission rate for Total VOC’s from all emission points within the site is an average 12.032 kg/hr. Emission points A2-2, A2-6 and A2-7 account for up to 67% of there total VOC emission with a total mass emission rate of 8.012 kg/hr (see Table 3.2). In term of ground level concentrations in the vicinity of the site operations it is necessary to provide VOC mitigation. In terms of mitigation it is fair to assume that greatest reduction in GLC’s will be achieved by abating the greatest emission rate source. Multiple dispersion modelling scenarios were utilised to select those sources, which provide greatest reduction in GLC. In order to present the results of this assessment, Scenario 4 was used to demonstrate the overall results of this study. Table 3.11 illustrates the input data utilised within the dispersion model following the implementation of VOC mitigation. Section 3.5.2.1 provides specific details on the potential VOC mitigation techniques to be utilised within the site to achieve the emission limits and ground level concentrations. Section 4.2 provides additional results in relation to the maximum predicted GLC’s for Total VOC’s before and after abatement. Ref: Scenario 4: [email protected] Dispersion modelling assessment of proposed operations located within Alps Electric (Ireland) Ltd for Total volatile organic compounds following the implementation of VOC abatement strategy on Emission points A2-2, A2-6, and A2-7. A detailed description of the emission reduction strategy is contained in 3.5.2.1 (see Table 3.11 for input data). 29 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Table 3.11. Total VOC emissions from process vents in Alps Electric (Ireland) Ltd following the implementation of VOC abatement on emission points A2-2, A2-6 and A2-7. Sample location A2-1 Sample location description PAL room extraction stack Solderwave/Concoat machine extraction point Spot dip machine extraction point SMT machine extraction point Storage shed extraction point PAL area extraction stack PAL area extraction stack Sludge storage area extraction Paint and laser tray cleaning area extraction point Hazardous waste storage area extract point A2-2 A2-3 A2-4 A2-5 A2-6 A2-7 A4-1 A4-2 A4-3 Proposed A131, 2 3, 4 Total VOC VOC abatement system - 4.62 Normalised Mass loading/emission (g/s)1,3 0.20 Normalised Mass loading/emission (kg/hr)1,3 0.71 See VOC abatement - - - 63.86 0.50 31.20 See VOC abatement See VOC abatement 31.20 0.85 1.04 0.93 0.93 0.05 0.0005 0.03 0.03 0.20 0.0019 0.10 0.10 31.20 0.93 0.03 0.10 31.20 0.93 0.03 0.10 50 12.16 0.608 2.188 - - - 3.512 TOC concentration 3 1 (mg/Nm ) Volumetric airflow 3 rate (Nm /s) 42.57 Notes: 1denotes that it is assumed that the VOC abatement technology will achieve a stack VOC concentration of 50 mg/Nm3 as detailed in BREF. 2 denotes that it is assumed that the total treatment volume of 12.16 Nm3/s will be treated from emission point sources A2-2, A2-6 and A2-7. The total exhaust emission stack height attached to the abatement equipment will be a total 16.5 m from existing ground level of 136 m. The exhaust emission point efflux will be 19 m/s and the exhaust temperature will be 433 K assuming regenerative thermal oxidation is the chosen technology. 3 denotes that the overall mass rate emission rate reduction of approximately 67% will be achieved from the site. 4 denotes it is assumed that emissions from all sources occur 24 hours per day and simultaneously. This assessment can be considered worst case and conservative. [email protected] 30 Document No. 2007A145(4) Alps Electric (Ireland) Ltd In addition to the assessment of Total volatile organic compound GLC’s, the individual EAL’s for the speciated VOC’s were screened in order to ascertain the GLC’s for such compounds in the vicinity of the operating facility. Since there exists at least 22 compounds emitted to atmosphere from the various processes, a screening mechanism was used to ascertain the highest risk impact compound criterion. If such selected compounds pass the screening mechanism, then it would be unlikely that any other speciated VOC’s would impact in the vicinity of the site location since the presented data is maximum detected air phase concentration and mass emission rate over the time period (i.e. such chosen compounds are maximum emissions of speciated VOC’s). This facilitates the assessment of worst-case impact assessment of the individual compounds, which provides added safety factor for maximum emission occurring at similar times (which would not be the case in real time operation). Table 3.12 illustrates the maximum detected air phase concentration of most common VOC’s detected in the emission points located in Alps Electric (Ireland) Ltd. Primarily, 6 individual compounds were close to or above their respective EAL 1 hour short term limit value at the emission point source; therefore based on this fact, there is the potential that such compounds could result in an EAL impact downwind of the facility (i.e. next the residential dwellings). These compounds included: • • • • • • Isopropyl alcohol, Xylene isomers, Butyl acetate, Toluene, Methyl isobutyl ketone and Ethyl benzene. All other compounds were below their respective 1-hour short term EAL values at the emission source (highest concentration that can be perceived) and therefore were not considered significant in terms of environmental impact. It would be fair to conclude that those compounds below their respective 1-hour short term EAL value at source would not breach the GLC value downwind of the facility. In addition, the long term EAL value (annual mean) was used to assess long term impact as recommended in the H1 guidance notes. In order to rank the mass emission of a compound in terms of dispersion modelling, the source concentration of each compound is divided by its known EAL value and the significance of the compound in terms of dispersion modelling impact assessment becomes clearer (see Table 3.12). The compounds presented in Table 3.13 are those maximum detected concentration of compounds reviewed from the historical dataset thereby facilitating worst-case estimate. Total worst case mass emission rates over a 2 year period from identified emission points, and respective EAL’s are presented to allow the reader to ascertain the significance of speciated VOC’s in terms of impact. [email protected] 31 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Table 3.12. Review of speciated VOC data and presentation of maximum emission concentration for selected emission points. Compounds with highest detected air phase concentration from historical reports over 2 year period Ethyl Trimethyl 1 Xylene Acetic acid Butyl Cyclohexane Cyclohexanone Hexane MIBK Toluene Emission point Isopropyl alcohol (mg/Nm3) benzene benzene Pentene isomers ethyl ester acetate (mg/Nm3) (mg/Nm3) (mg/Nm3) (mg/Nm3) (mg/Nm3) (mg/Nm3) (mg/Nm3) (mg/Nm3) (mg/Nm3) (mg/Nm3) (mg/Nm3) A2-1 22.6 21.3 14 25.6 3.8 0.31 3.8 A2-2 200.8 1.34 7.3 18.4 0.5 - 4 - - 12.6 9.5 - A2-3 18.2 - 0.5 4.4 - - 1.5 - - - - - A2-4 - - - - - - - - - - - - A2-5 - 3.18 - 30 1.63 0.03 - 1.31 0.07 10.3 - - A2-6 - - - - - - - - - - - 16.9 A2-7 Total conc. at source (mg/Nm3) Short term EAL1 hour impact (mg/Nm3) Long term EALAnnual mean (mg/Nm3) Ratio of short term EAL to air phase conc. - 33.24 - 58.16 - - - - - - 78.59 - 241.6 59.06 21.8 136.56 5.93 0.34 5.5 1.31 0.07 22.9 91.89 16.9 81.30 66.20 420 96.60 8.00 37.50 - 40.80 21.60 20.80 55.20 105.00 2.71 4.41 14.60 7.24 1.91 1.25 - 1.02 0.72 0.83 4.41 3.50 2.97 0.89 - 1.44 0.74 - - - - 1.10 1.66 - [email protected] 32 Document No. 2007A145(4) Alps Electric (Ireland) Ltd The main interim conclusions before detailed dispersion modelling from this screening exercise included: Only 4 compounds including Isopropyl alcohol, Butyl acetate, Methyl isobutyl ketone and Ethyl benzene were above their respective 1-hour short term EAL. All other compounds were below their respective EAL in term of source-based ratio to EAL concentration levels. In order to be conservative throughout the assessment Xylene isomers, and Toluene are also assessed for the existing situation (ref Scenario 3). In addition, the long term EAL annual mean value is also compared to the proposed short term EAL’s in Table 2.2. The overall mass emission rates of the maximum measured speciated VOC concentrations can be observed in Table 3.13. This data was used in conjunction with the source characteristics presented in Table 3.1 to predict the worst case 1 hour and Annual mean concentration of these individual compounds in the vicinity of the existing facility only. [email protected] 33 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Table 3.13. Maximum worst-case mass emission rates of identified speciated VOC’s for Alps Electric (Ireland) Ltd existing facility operation. Acetic acid Butyl Toluene ethyl ester acetate (g/s) (g/s) (g/s) 0.06463 0.11818 0.01754 Trimethyl benzene (g/s) 0.00143 1 Cyclohexanone Hexane MIBK (g/s) Pentene (g/s) (g/s) (g/s) - A2-1 Isopropyl alcohol (g/s) 0.10433 Xylene isomers (g/s) 0.09833 0.01754 - A2-2 0.58295 0.00389 0.02119 .05342 0.00145 - 0.01161 - - 0.03658 0.02758 - A2-3 0.01551 - 0.00043 0.00375 - - 0.00128 - - - - - A2-4 - - - - - - - - - - - - A2-5 - 0.00295 - 0.02783 0.00151 0.00003 - 0.00122 0.00006 0.00955 - - Emission point Ethyl benzene (g/s) Cyclohexane (g/s) A2-6 - - - - - - - - - - - 0.04170 A2-7 Total mass emission rate (g/s) - 0.07646 - 0.13377 - - - - - - 0.18077 - 0.70279 0.18162 0.08625 0.33694 0.02051 0.00146 0.01289 0.00122 0.00006 0.04613 0.22589 0.04170 Notes: Compounds with highest mass emission rate from historical reports over 2 year period using average volumetric air flow rate data in Table 3.1. [email protected] 34 Document No. 2007A145(4) Alps Electric (Ireland) Ltd In addition to this screening, the TA Luft GLC assessment criterion is also assessed to provide a picture of the total VOC GLC levels at the sensitive receptor locations and would be termed worst case catch all technique in terms of composite VOC impact assessment. Table 4.3, 4.4 and 4.5 illustrates the tabular results obtained from the dispersion modelling assessment for Scenarios 3 and 4 for Total and Speciated VOC’s. Maximum predicted GLC’s for the percentile scenario are presented within this table to allow for comparison with proposed regulatory guidelines and other specified regulations and assessment criterion contained in Table 2.2. In addition, graphical contour plots are provided for information within Appendix I (ref: Section 6) for the existing and proposed Scenarios 3 and 4. For Scenario 4, it is assumed that VOC mitigation will be applied to emission points A2-2, A2-6 and A2-7 due to their respective high total VOC concentration and mass emission level in the exhaust vent (i.e. account for up to 67% of Total VOC emissions) and the fact that these emission points come under the regulation of SI543 of 2002. The overall type of installed mitigation may change in future months depending on process optimisation and air handling reduction strategies occurring at the individual emission points in the coming months. For the sake of this assessment, worst-case volumetric airflow rate is utilised in order to allow the regulatory body to establish emission limit values. 3.5.2.1 BAT Volatile organic compound abatement strategy In order to reduce the overall mass emission of VOC from the facility, a combination of techniques will be investigated to achieve this reduction. Primarily, process optimisation and recycling of air will form a large part of the overall mitigation plan. In addition to this and where deemed necessary following the implementation of the process optimisation mitigation technique, a number of end of pipe techniques will be considered. For this assessment, it is assumed that all waste air generated within the processes will be ducted to a VOC abatement technology. The final design and type of VOC abatement system has not been finalised but for this assessment it is assumed that a two canister with buffer tank regenerative thermal oxidiser operating on LPG will be utilised. A buffer tank will be implemented into the design to prevent cyclic emissions from the system when valve switching is occurring. Specific details of the various applicable technologies are provided in Section 3.5.2.2 to 3.5.2.4 of this document. The specific treatment volumes, VOC emission rates as non-methane VOC’s and overall VOC emission rate from the abatement system is provided in Section 3.5.2. It is assumed for the dispersion modelling assessment for the proposed facility operation, that this VOC abatement strategy will achieve greater than 95% removal efficiency on emission points A2-2, A2-6 and A2-7. A stack limit concentration of Total VOC will be approximately less than or equal to 50 mg/Nm3 which is in keeping with literature and BAT. 3.5.2.2 Review of BREF document for surface treatment using organic solvents-treatment techniques in general. BAT is to provide for design, operation and maintenance of the proposed waste treatment plant installation. The following elements should be considered: 1. Minimise emissions at source, recover solvent from emissions or destroy solvents in waste gases. Using low solvent materials can lead to excessive energy demands to operate thermal oxidisers. Oxidisers may be decommissioned where the negative cross-media effects outweigh the benefits of destroying the VOC) 2. Seek opportunities to recover and use excess heat generated in VOC destruction and minimise the energy used in extraction and destruction of VOCs 3. Reduce solvent emissions and energy consumption by using the techniques described, including reducing the volume extracted and optimising and/or concentrating the solvent content. In the case of Alps electric Ireland catalyst based oxidizers are considered high risk due to possibilities of poisoning the catalyst. For the machines not connected to waste gas treatment, BAT is one of: 1. Use low solvent or solvent free products on these machines [email protected] 35 Document No. 2007A145(4) Alps Electric (Ireland) Ltd 2. Connect to the waste gas abatement equipment when there is capacity 3. Preferentially run high solvent content work on machines connected to waste gas abatement. This is addressed in detail within Point 13 reply for request for addition information. Where installations have no waste gas abatement equipment and are using substitution, it is BAT to follow the developments of low solvent and organic solvent free paints, varnishes and adhesives, and continuously decreases the amount of solvents consumed. This is been considered by Alps Electric Ireland Ltd and will be implemented where possible. BAT is also to: 1. Minimise energy consumption when optimising waste gas treatment in all sites 2. Seek opportunities to recover and use any surplus energy in all sites. In terms of system maintenance, all waste gas systems need maintenance, both preventative and for breakdowns. Untreated emissions can be minimised by: • Planned maintenance (see Section 20.2.6-BREF). Where it is necessary to shut down key emission abatement equipment (and this may include some days for cooling before the equipment can be touched), the emissions can be minimised by carrying out maintenance: • During low or no-production times (e.g. vacation shutdown periods), • During periods when emissions will have least impact, i.e. for VOC emissions, during periods of low sunlight levels, low probability of inversion layers, etc. This is dependent on weather, time of year and local conditions. • Monitoring key equipment for problems such as vibration, emission leaks and planning repairs (as above), using decentralised/dedicated treatment systems so breakdown/repair only affects the systems in question (see Section 20.11.1.6), dealing with breakdowns efficiently and detected faults as rapidly as possible. 3.5.2.3 Suggested treatment techniques applicable to Alps Electric (Ireland) Ltd and taken from BREF. Thermal oxidation Thermal oxidation involves the destruction of solvent vapours in the presence of heat and Oxygen. The destruction process is complex whereby solvent air is fed into the combustion zone of the thermal oxidiser and heated to a temperature of approximately 680 to 750 Deg C. the air stream is passed through a heated ceramic zone whereby sufficient retention time is maintained to allow for full oxidation of the VOC to be completed. Retention times vary from 1 sec to 2 sec and are directly dependent on the inlet VOC and its oxidation potential. Higher temperatures are required for low retention times and are indeed interlinked to the type of media utilised (surface area). In recent years up to three ceramic beds are provided in order to allow for the efficient capture of waste heat within the ceramic bed and to prevent the cyclic emissions of VOC’s during valve switching. In some cases two canister system can be utilised in conjunction with an outlet buffer tank whereby the cooled air is directed to the buffer tank to prevent such cyclic emissions. The thermal oxidiser can be operated on different fuel types including Gas oil, LPG and natural gas. In the case of Alps Electric Ireland LPG would be the preferred fuel while either a two canister coupled to a buffer tank or a three-canister system would be utilised. Up to 96% thermal recovery can be achieved on properly designed and insulated system (4% energy loss to stack). In addition, the overall thermal efficiency of the thermal oxidiser is improved if it can be operated in auto thermal mode (if sufficient VOC’s are present). In the case of Alps Electric Ireland if an oxidiser is chosen as end of pipe, direct gas lance injection will be performed into the ceramic. This will reduce the fuel consumption costs by up to approximately 25% since the preheating of combustion air is not required. Achieved environmental benefits: Reduction in overall emission loads. Generally, defects in Thermal oxidation equipment can give rise to VOC emissions equivalent to 0.4 % of the annual input per day, see Section 2.4.2.5.4-BREF. In terms of operating temperature, BREF suggests [email protected] 36 Document No. 2007A145(4) Alps Electric (Ireland) Ltd temperature ranges of 680 to 750 Deg C for thermal oxidizers. For a waste gas with a VOC concentration of 10 g/Nm3, the removal efficiency is about 95 to 98%. VOC concentrations in the treated waste gas of 25 - 50 mg/Nm3 are achievable. The higher the inlet solvent concentration the lower the running costs. Cross-media effects: Energy consumption from the exhaust ventilator and fuel can vary depending on system design. Gas consumptions of up to 0.8 m3 /1000 m3 waste gas treated are anticipated. Particulate filtration of the waste gas stream will be required in the case of Alps to prevent paint residues affecting the thermal efficiency. A burn out cycle will be implemented into the system to reduce shut down time. Noise levels might increase. Operational data: The temperature of the waste gas should if possible be high and the humidity should be low to reduce energy consumption in the combustion process. Economics: Thermal oxidation is operation costs can be considered high if proper engineering design is not incorporated into the system design. In terms of any installation, high efficiency thermal insulation, direct gas lance injection into the ceramic bed should be achieved, inlet air stream should be low in aerosols and moisture and pressure loss across the ceramic should be lowered. High efficiency fans should be utilised and VSD controlled. Twin burners should be installed and LPG would be preferred fuel type. At least two canisters should be utilised while the delta T should be no greater than 40 Deg C. Manufacturer data 3 3 suggests a LPG consumption rate of 0.80 m / 1000 m of waste gas treated. Lowering the treatment volume results in a near directly proportional reduction in the operation costs for this technology. UV oxidation Solvent-laden air is routed through a series of UV lamps. VOC molecules are fragmented by the short wavelength energy and ozone is formed from the oxygen. The ozone reacts with the fragmented VOC molecules, which lead it to partly oxidised. The subsequent unit contains a catalytic agent (mainly TiO2), the oxidation of the ozone and VOC molecules continues and the excess ozone is destroyed. Achieved environmental benefits: For a waste gas with a VOC concentration of 0.5 g/Nm3, the removal efficiency is about 95 %. VOC concentrations in the treated waste gas of 25 - 50 mg/Nm3 are achievable. Cross-media effects: Energy consumption from the lamps and exhaust ventilator together are 50 kWh per 1000 m3 waste gas treated. The lamps emit O3 (which is destroyed), and contain mercury, which has to be disposed of with suitable precautions. Noise levels might increase. In the case of Alps Electric Operational data: The temperature of the waste gas should not exceed 60 ºC and the humidity should be less than 85 %. The technique was originally developed to achieve odour reduction and for the destruction of toxic substances. However, increasingly the technique is used for the complete destruction of VOCs, especially in waste gases containing low concentrations (on average <0.5 g/Nm3 and occasionally peaks of <1.0 g/Nm3). Economics: In an installation that can treat several 10,000 m3/h, investment costs are about EUR 5000 – 7000 per 1000 m3/h waste gas. After 8000 hours the UV lamps need to be replaced; costs are about EUR 0.06 – 0.2 per 1000 m3/h waste gas. Energy costs are about EUR 4 per 1000 m3/h waste gas. The operational costs (including lamps, energy and catalyser) are in the range EUR 3 – 25 per kilo VOC removed. In the specific situations where this technique is used, UV oxidation has been reported to be cheaper compared to adsorption to activated carbon or any type of thermal oxidation. Non-thermal plasma treatment In the waste gas, a plasma is created at low temperatures (30 – 120 ºC) by routing the waste gas through two electrodes with an alternating current of 20 – 30 kV. In the plasma, the VOC vapours react very quickly with oxygen to form CO2 and water vapour. In a plasma, the [email protected] 37 Document No. 2007A145(4) Alps Electric (Ireland) Ltd molecules of the gasflow are in a partly ionised condition. This condition is normally achieved by extremely high temperatures, such as that caused by lightning. However, it can also be created at ambient temperatures if enough energy is added. Achieved environmental benefits: Efficiencies of 97 - 99.9 % are achieved without heating the waste gas. The installation for this technique is very compact compared to thermal oxidation and also consumes far less energy. Cross-media effects: Energy consumption of 0.5 – 3.0 kWh electric energy per 1000 m3 waste gas treated. Operational data: Different layouts are available. Sometimes the space between the electrodes is filled with small glass balls to amplify the electric field. Applicability: This technique has only been commercially applied for a few years to reduce odour emissions and sometimes to treat waste gases containing VOC. In theory, there is no restriction in applications concerning the VOC concentrations in the waste gas; however, it is currently applied for treating low concentrations. Also small or large flows can be treated In terms of all treatment technologies, the author has experience in operating and trailing all technology types included above, therefore their individual limitation are realised. In terms of moving forward in Alps Electric (Ireland) any technology chosen other then thermal oxidation will be trailed on site to ascertain their respective removal efficiency before placement of order. The EPA will be included in the process of isolation of the equipment. Specified engineering works will be submitted to the EPA for review before placement of order. This process has been used successfully on other Waste and IPCC licensed sites throughout Ireland (Dublin office). 3.5.2.4 Technical issue to be addressed in any technologies. The elements form a significant part of the technology selection process. These include: • Applicability to air stream, • Published performance data for review and if not available perform trial works on site to ensure technology achieved performance guarantees. • Air stream preparation forms a significant part of the system operation. The air stream will be conditioned for aerosols to prevent issues with operation. • Where possible volumes of air treatment will be reduced through optimisation. This is currently under review in Alps Electric Ireland Ltd and will be finalised before isolation of technology. • Design the system with energy efficiency in mind. Eff 1 motors to be used on all fans, VSD to be fitted to all motors, and thermal insulation provided where necessary. • 100% duty 50% standby on major components will be provided (i.e. fans, pumps, burners,) and the system will be designed to allow for partial operation (50%) if necessary. • Necessary spares on consumables will be maintenance on site to ensure continued operation. • A full maintenance schedule in accordance with manufacturers instructions will be incorporated into the operation cycle and controlled through the Environmental Management system for the site. • Energy recovery where possible will be considered with each specific technology. • Emission and environmental benefits will be considered through Life system cost analysis and CO2 eq will be calculated. • The VOC abatement plant will be designed to deal with maximum emission events. • Abnormal operation will only occur if maintenance needs are not addressed adequately within the Environmental Management System. • Emergency operation conditions will only occur if plant failure occurs. Production operations will be limited till plant system is operational or emergency VOC abatement system will be installed on site. This is considered BAT. [email protected] 38 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Table 3.14 illustrates the approach and time line will be utilised to realise the installation of end of pipe abatement where necessary for Alps electric (Ireland) Ltd. Table 3.14. Schedule for isolation, installation and operation of VOC abatement plant in Alps Electric (Ireland) Ltd. Time required Objective Item (weeks) To define the works required and Development of scope of works 4 weeks agree the full procurement process with Alps electric (Ireland) Ltd Alps Electric Ltd to finalise process Optimisation of process emission optimisation and air recirculation points A2-2, A2-6 and A2-7 for scheme to allow for reduction in development of contract overall treatment volume. In addition 5 weeks specifications. Full characterisation trials will be performed on study performed in terms of technologies that have limited interrelationship between process process data. and end of pipe abatement Development of contract To develop performance specifications, performance specifications and minimum electrical 4 weeks specifications, Terms of reference and mechanical specifications for the and selection of 5 proven companies contract with capabilities to supply technology To allow for sufficient time line to Receipt of tender submissions and 4 weeks allow contractors to provide details review process and initial design tender submission Clarification requests forwarded to To allow for clarifications of 2 weeks preferred bidders presented bids. Detailed clarification process and if Interview and Selection of preferred possible visit installed plants in bidder and signing of operation. Contracts will be signed 4 weeks contracts/placement of order on and detailed design process agreed time frame commences. Submission of Specified Engineering Specified engineering works 5 weeks works on initial design to EPA for submitted to EPA for review. review and receipt of agreement Detailed design stage and Detailed design, development of agreement of general layout and 6 weeks drawings and installed plan for the design contract. Some technologies may require up to Delivery of all major items to site for Up to 20 20 weeks for delivery. This time line installation weeks could be reduced to 14 week if available slot on production line. Installation of abatement plant and Installation of abatement plant Up to 3 weeks initial optimisation Final snag items before Snagging of installed plant before 1 week commissioning operation Commissioning and performance Commissioning and performance testing to be complete before full 1 week time operation. All P&ID values testing of system installed included on O&M Training on operation and Full training provided to Alps Electric 1 week maintenance of installed system. staff before signoff on plant build. Submission of final testing and Performance testing reports, all performance reports to the EPA for 1 week certificated submitted to the EPA for review. information. Plant operation commences in full Operation of abatement plant N/A flow To ensure all service and Incorporation of service and N/A maintenance needs identified and maintenance schedule into flagged to plant personnel. Environmental Management system. [email protected] 39 Document No. 2007A145(4) 4. Alps Electric (Ireland) Ltd Discussion of results This section will describe the results obtained throughout the study. 4.1 Assessment of air quality impacts due to classical air pollutants Table 4.1 and 4.2 presents the comparison between model predictions for classical air quality impacts, baseline air quality concentrations for the compounds and the percentage impact of the air quality criterion for Scenarios 1 and 2 (i.e. existing and proposed operations). As can be observed, all predicted GLC’s (ref: Scenarios 1 and 2) are within the relevant air quality impact criteria for all assessed compounds and therefore it is predicted that the facility will contribute negligibly to air quality impact in the vicinity of the site. [email protected] 40 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Table 4.1. Comparison between predicted GLC’s + baseline national air quality data and regulatory guideline and limit GLC’s for Scenario 1. Identity Compound Maximum predicted GLC -Scenario 2 (μg m-3) Maximum 8 hour concentration (100th ile) Maximum 1 hour concentration (100th ile) Maximum 1 hour concentration (99.79th ile) Maximum annual mean concentration th Maximum 24 hour concentration (100 ile) Maximum 24 hour concentration (98.09th ile) Maximum annual mean concentration Maximum 1 hour concentration (100th ile) Maximum 1 hour concentration (99.73th ile) Maximum 24 hour concentration (100th ile) Maximum 24 hour concentration (99.18th ile) Maximum annual mean concentration Maximum 1 hour (100th ile) Maximum 1 hour (99th ile) Maximum 1 hour (98th ile) Maximum annual mean concentration CO NO2 as NOX NO2 as NOX NO2 as NOX PM as PM10 0.42 84.14 61.40 7.05 32 1900 9.60 9.60 9.0 16.90 Baseline + Maximum predicted GLC (μg m-3) 1900.42 93.74 71 16.05 48.9 PM as PM10 20.50 16.90 PM as PM10 SO2 SO2 SO2 8.95 69 47 28.40 SO2 Notes: SO2 Pb (as particulate) Pb (as particulate) Pb (as particulate) Pb (as particulate) Impact criterion (μg m-3)2 % of Criterion 10000 200 200 40 50 19.00 46.87 35.50 40.13 97.80 37.4 50 74.80 13.0 63.60 63.60 17.70 21.95 132.6 110.6 46.10 40 350 350 125 54.88 37.89 31.60 36.80 20.12 17.70 37.82 125 30.26 5.79 0.035 0.0124 0.0093 0.00257 5.0 0.010 10.79 0.035 0.0124 0.0093 0.01257 20 0.5 0.5 0.5 0.5 53.95 7.00 2.48 1.86 2.51 1 denotes based on data presented in Table 3.4, 3.6, 3.7 and 3.8. denotes for impact criterion see Table 2.1 3 denotes for baseline data see Table 2.3 2 [email protected] Baseline conc. value (μg m-3)1 41 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Table 4.2. Comparison between predicted GLC’s + baseline national air quality data and regulatory guideline and limit GLC’s for Scenario 2. Identity Compound Maximum predicted GLC -Scenario 2 (μg m-3) Maximum 8 hour concentration (100th ile) Maximum 1 hour concentration (100th ile) Maximum 1 hour concentration (99.79th ile) Maximum annual mean concentration th Maximum 24 hour concentration (100 ile) Maximum 24 hour concentration (98.09th ile) Maximum annual mean concentration Maximum 1 hour concentration (100th ile) Maximum 1 hour concentration (99.73th ile) Maximum 24 hour concentration (100th ile) Maximum 24 hour concentration (99.18th ile) Maximum annual mean concentration Maximum 1 hour (100th ile) Maximum 1 hour (99th ile) Maximum 1 hour (98th ile) Maximum annual mean concentration CO NO2 as NOX NO2 as NOX NO2 as NOX PM as PM10 49.50 181 61.40 7.05 32 1900 9.60 9.60 9.0 16.90 Baseline + Maximum predicted GLC (μg m-3) 1949.5 190.6 71 16.05 48.9 PM as PM10 20.50 16.90 PM as PM10 SO2 SO2 SO2 8.95 69 47 28.40 SO2 Notes: SO2 Pb (as particulate) Pb (as particulate) Pb (as particulate) Pb (as particulate) Impact criterion (μg m-3)2 % of Criterion 10000 200 200 40 50 19.50 95.30 35.50 40.13 97.80 37.4 50 74.80 13.0 63.60 63.60 17.70 21.95 132.6 110.1 46.10 40 350 350 125 54.88 37.89 31.46 36.80 20.10 17.70 37.8 125 30.24 5.79 0.035 0.0124 0.0093 0.00257 5.0 0.010 10.79 0.035 0.0124 0.0093 0.01257 20 0.5 0.5 0.5 0.5 53.95 7.00 2.48 1.86 2.51 1 denotes based on data presented in Table 3.4, 3.6, 3.7 and 3.8. denotes for impact criterion see Table 2.1 3 denotes for baseline data see Table 2.3 2 [email protected] Baseline conc. value (μg m-3)1 42 Document No. 2007A145(4) 4.1.1 Alps Electric (Ireland) Ltd Carbon monoxide (CO) The results for the potential air quality impact for dispersion modelling of CO for both Scenario 1 and 2 (i.e. existing and proposed facility operation) based on the emission rates in Tables 3.4 to 3.8 are presented in Table 3.9 and 3.10, respectively. Results are presented for the identified maximum emission regime. As can be observed in Tables 4.1 and 4.2, the maximum GLC+Baseline for CO for both Scenarios 1 and 2 from the operation of emission points A1-1 and A1-2 is 0.42 and 49.50 μg m-3 for the 100th percentile for a 8-hour mean worst-case concentration. When combined predicted and baseline conditions are compared to the Irish guideline/limit values and EU Limit values laid out in the EU Daughter directive on Air Quality 99/30/EC, this is up to 80.50% times lower than the set target limits. Figure 6.1 provides graphical illustration of the contour plume spread in the vicinity of the facility. 4.1.2 Oxides of nitrogen (NO2 as NOX) The results for the potential air quality impact for dispersion modelling of NOX as NO2 for both Scenario 1 and 2 (i.e. existing and proposed facility operation) based on the emission rates in Tables 3.4 to 3.8 are presented in Table 3.9 and 3.10, respectively. Results are presented for the identified maximum emission regime. As can be observed in Tables 4.1 and 4.2, the maximum GLC+Baseline for NO2 as NOX for both Scenarios 1 and 2 is 93.74 and 190.60 μg m-3 for the 100th percentile and 84.14 μg m-3 for the 99.79th percentile for a 1-hour mean worst-case concentration. When combined predicted and baseline conditions are compared to the Irish guideline/limit values and EU Limit values laid out in the EU Daughter directive on Air Quality 99/30/EC, this is from 4.70 to 54% lower than the set target guidelines for the 100th percentile. An annual average was also generated for Scenarios 1 and 2 to allow comparison with the SI 271 of 2002. When compared to the impact criteria, the annual average NO2 air quality impact for Scenarios 1 and 2 are up to 60 % lower than the set target guideline (see Table 4.1 and 4.2) assuming a baseline concentration of 9 μg m-3. The implementation of a stack height up to 16.50 metres on emission point A1-2 ensures no ground level impact of NO2 in the vicinity of the site for the proposed operation cycle. Figure 6.2 provides graphical illustration of the contour plume spread in the vicinity of the facility. 4.1.3 Sulphur dioxide (SO2) The results for the potential air quality impact for dispersion modelling of SO2 for both Scenario 1 and 2 (i.e. existing and proposed facility operation) based on the emission rates in Tables 3.4 to 3.8 are presented in Table 3.9 and 3.10, respectively. Results are presented for the identified maximum emission regime. As can be observed in Tables 4.1 and 4.2, the maximum GLC+Baseline for SO2 for Scenarios 1 and 2 is 69 μg m-3 for the 100th percentile and 47 μg m-3 for the 99.73th percentile for a 1-hour mean worst-case concentration. When combined predicted and baseline conditions are compared to the Irish guideline/limit values and EU Limit values laid out in the EU Daughter directive on Air Quality 99/30/EC, this is up to 63% lower than the set target limits. In addition, Tables 4.1 and 4.2 illustrates the maximum 100th and 99.18th percentile 24-hour GLC+Baseline concentration for SO2 for Scenarios 1 and 2. As can be observed in Tables 4.1 and 4.2, the maximum GLC+Baseline for SO2 for Scenarios 1 and 2 is 28.4 μg m-3 for the 100th percentile and 20.10μg m-3 for the 99.18th percentile for a 24-hour mean worst-case concentration. When combined predicted and baseline conditions are compared to the Irish guideline/limit values and EU Limit values laid out in the EU Daughter directive on Air Quality 99/30/EC, this is up to 60% lower than the set target guidelines. [email protected] 43 Document No. 2007A145(4) Alps Electric (Ireland) Ltd An annual average was also generated for Scenarios 1 and 2 to allow comparison with the SI 271 of 2002. When compared to the impact criteria, the annual average SO2 air quality impact for Scenario 2 is up to 47% lower than the set target guideline (see Table 4.1 and 4.2) assuming a baseline concentration of 5 μg m-3. The implementation of a stack height up to 16.50 metres on emission point A1-2 ensures no ground level impact of SO2 in the vicinity of the site for the proposed operation cycle. Figures 6.4 and 6.5 provide graphical illustration of the contour plume spread in the vicinity of the facility. 4.1.4 Total particulates as PM10 The results for the potential air quality impact for dispersion modelling of Total particulates as PM10 for both Scenarios 1 and 2 (i.e. existing and proposed facility operation) based on the emission rates in Tables 3.4 to 3.8 are presented in Table 3.9 and 3.10, respectively. Results are presented for the identified maximum emission regime. As can be observed in Tables 4.1 and 4.2, the maximum GLC+Baseline for PM10 for Scenarios 1 and 2 is 32μg m-3 for the 100th percentile and 20.50 μg m-3 for the 98.08th percentile for a 24-hour mean worst-case concentration. When combined predicted and baseline conditions are compared to the Irish guideline/limit values and EU Limit values laid out in the EU Daughter directive on Air Quality 99/30/EC, this is up to 2.20% lower than the set target guidelines. An annual average was also generated for Scenarios 1 and 2 to allow comparison with the SI 271 of 2002. When compared to the impact criteria, the annual average PM10 air quality impact for Scenarios 2 are up to 46 % than the set target guideline (see Table 4.1 and 4.2) assuming -3 a baseline concentration of 13μg m . The implementation of a stack height up to 16.50 metres on emission point A1-2 ensures no ground level impact of PM10 in the vicinity of the site for the proposed operation cycle. Figure 6.3 provides graphical illustration of the contour plume spread in the vicinity of the facility. 4.1.5 Particulate based Lead The results for the potential air quality impact for dispersion modelling of Total particulates as PM10 for both Scenarios 1 and 2 (i.e. existing and proposed facility operation) based on the emission rates in Tables 3.4 to 3.8 are presented in Table 3.9 and 3.10, respectively. Both, Scenarios 1 and 2 are identical in exhaust emission rates for particulate-based lead. All lead values were obtained from historic reports generated on site through grab based monitoring over a 2-year period. In terms of impact, the predicted ground level concentrations of lead were compared to both annual and 1-hour percentile impact criterion. As can be observed in Tables 4.1 and 4.2, the over predicted lead impact for the operating site is negligible and less than 3% of the proposed impact criteria contained in Table 2.1. Figure 6.6 provides graphical illustration of the contour plume spread in the vicinity of the facility. [email protected] 44 Document No. 2007A145(4) Alps Electric (Ireland) Ltd 4.2 Assessment of air quality impacts due to volatile organic compound air pollutants. Predictive air dispersion modelling was used to ascertain the ground level concentrations of selected worst case speciated volatile organic compound concentrations and total volatile organic compound concentrations as carbon to allow for comparison with published Environmental assessment levels (EAL’s as specified in H1 guidance document) and regulatory guideline values. Table 4.3 illustrates the results of the dispersion modelling assessment of selected speciated VOC’s. These VOC’s were selected as they represented the worst-case emission concentration of individual VOC’s emitted from the site operations over the past 2 years. Data was collated from historical measured values (see Section 3.5.2). As can be observed, the overall impact of speciated VOC’s from existing operations (ref Scenario 3) is negligible in terms of the individual EAL’s for each compound with all predicted concentration less than 58% of their respective assessment levels. The maximum predicted GLC for each screened compounds is illustrates in Table 4.3. The VOC impact assessment and review of historical data suggests the existing facility operation will have negligible impact on surrounding receptors in terms of speciated VOC’s. Total VOC’s mass emission rates as presented in Table 3.2 and Table 3.11 were used to assess the overall predicted impact of existing and proposed operations (ref: Scenarios 3 and 4). As can be observed in Figures 6.7 to 6.8, when total VOC’s is modelled it is predicted that some impact may occur outside the boundary of the facility for existing operations (ref: Scenario 3) with maximum ground level concentrations of 1,459 and 2003 μg/m3 at the 98th th and 99 percentile of hourly averages been predicted. Further investigation of individual source characteristics predicted that emission points A2-2, A2-6, A2-7 and to a lesser extent A2-1 contributing greatest to VOC plume spread in the vicinity of the facility operations. Following the application of VOC mitigation, the overall predicted ground level concentration (GLC’s) of total VOC’s is significantly reduced with GLC’s of 233 and 351 μg/m3 at the 98th and 99th percentile of hourly averages been predicted. This is a result of an overall reduction of approximately 67% in the mass of VOC’s emitted by the facility through the application of mitigation of mitigation to emission points A2-2, A2-6 and A2-7 (see Table 3.11). Taking into account that the predictive analysis assumes that all emission points emit VOC simultaneously 24/7 365 days per year, this assessment is considered conservative in terms of actual conditions. This will allow compliance with the proposed regulatory guideline vale of less than 1000 μg/m3 at the 98th for grouped compounds classified as Class 3 (see Figures 6.9 and 6.10). Tables 4.4 and 4.5 illustrate the predicted maximum GLC’s for the existing and proposed plant operations (ref: Scenario 3 and 4) for the 98th and 99th percentile of hourly averages for 5 years of meteorological data. As can be observed there is a predicted overall reduction of 84% and 83% for the 98th and 99th percentile of 1-hour averages, respectively. [email protected] 45 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Table 4.3. Predicted worst-case ground level concentrations of individual VOC’s emitted from processes located in Alps Electric (Ireland) Ltd and comparison with individual Environmental assessment levels. Worst case compound conc. Assessed for EAL's Predicted Annual average maximum GLC (ug/m3) Long term Annual EAL (ug/m3) Isopropyl alcohol 1132 81,300 105 2,710 Xylene isomers 219 44,200 11.10 2,210 7,100 Butyl acetate 409 95,000 18.90 22.47 8,000 1.03 500 Methyl isobutyl ketone 76 20,800 6.66 830 Ethyl benzene 371 55,200 16.11 1,000 Toluene [email protected] Predicted 100th Short term 1 hour percentile 1 hour EAL (ug/m3) maximum GLC (ug/m3) 46 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Table 4.4. Predicted maximum total VOC GLC’s for existing facility (ref: Scenario 3). Location of maximum detected value X coordinate X coordinate 126918.1719 126918.1719 89648.1172 89648.1172 Percentile Value (%ile) 1 hour Maximum GLC (μg/m3) 98 99 1,459 2,003 Table 4.5. Predicted maximum total VOC GLC’s for proposed facility (ref: Scenario 4). Location of maximum detected value X coordinate X coordinate 126886.7031 126886.7031 [email protected] 89534.7969 89534.7969 47 Percentile Value (%ile) 1 hour Maximum GLC 3 (μg/m ) 98th 99th 233 351 Document No. 2007A145(4) 5. Alps Electric (Ireland) Ltd Conclusions Twelve emission points are located within the Alps Electric (Ireland) Ltd boundary. In terms of emission characteristics, emission points A1-1 and A1-2 are combustion based for the production of steam and electricity while Emission points A2-1, A2-2, A2-3, A2-4, A2-6 and A27 are scheduled emission points from process operations located within the production building. Emission points A2-5, A4-1, A4-2 and A4-3 are considered fugitive emission points ventilated storage rooms located within the facility operations. In terms of significant emissions of VOC’s, vents A2-2, A2-6 and A2-7 would be considered highest with all other VOC emission points negligible in terms of mass emission. It proposed during future operations to operate emission point A1-2 during the time period 16.45PM to 19.15PM Monday to Friday October to March on the winter demand scheme. The following conclusions are drawn from the air quality impact assessment of process vents located in Alps Electric (Ireland) Ltd: 1. The existing and proposed boiler and generator (i.e. emission points A1-1 and A1-2) operations will not cause any significant classical air pollutant impact with all predicted ground level concentrations of Carbon monoxide, Oxides of nitrogen, Sulphur dioxide and Particulate matter within the regulatory guideline and limit values. In order to ensure compliance with statutory limit values, emission point A1-2 (generator) stack will require increasing up to a final height of 16.50 metres above ground level. 2. Following a review of historical particulate based lead emissions and dispersion modelling it was concluded that lead emissions are insignificant from process vents A2-2, A2-3 and A2-4. Particulate-based emission from these process vents are also insignificant. 3. Following a review of measured and historical emission profile data on speciated VOC’s (over two years), all maximum emission concentration of VOC’s are within their respective environmental assessment concentration level for the protection of human health. A screening mechanism was used to ascertain the maximum potential speciated VOC concentrations impact. Advanced dispersion modelling was used to predict maximum ground level and downwind concentration in order to allow for comparison with the assessment criteria. Isopropyl alcohol, Xylene isomers, Toluene, Butyl acetate, Ethyl benzene and Methyl isobutyl ketone were used for the screening exercise. 4. The overall individual impact of screened compounds Isopropyl alcohol, Xylene isomers, Toluene, Butyl acetate, Ethyl benzene and Methyl isobutyl ketone is within proposed Environmental Assessment Levels (EALs), and therefore in accordance with the requirements of H1 Guidance will not cause any significant impact. 5. Total volatile organic compounds as carbon as measured over a two-year period were used in conjunction with dispersion modelling to ascertain the maximum GLC’s of total VOC in the vicinity of the facility. This was compared to the regulatory assessment criteria contained within the Ta Luft guidance document. During existing operations, the overall plume spread and maximum GLC values are above the regulatory guideline values. Predictive modelling was used to ascertain the emission sources that contributed greatest to overall plume spread. Emission points A2-2, A2-6, A2-7 and to a lesser extent emission point A2-1 were found to contribute most while all other emission points contributing negligibly to ground level impact. 6. This was used to construct the basis of a predictive mitigation strategy where investigation of VOC emission minimisation (process optimisation and end of pipe abatement). Due to the air stream characteristics, three technologies may be suitable including regenerative thermal oxidation and non-thermal plasma technology. It was assumed for the dispersion modelling assessment that an exhaust gas concentration of less than or equal to 50 mg/Nm3 would be achieved (i.e. this is achievable on such technologies). Following implementation upon emission points A2-2, A2-6 and A2-7, [email protected] 48 Document No. 2007A145(4) Alps Electric (Ireland) Ltd the overall Total VOC impact will be less than 233 and 351 μg/m3 for the 98th and 99th percentile isopleths for 5 years of meteorological data utilising Aermod Prime dispersion model. [email protected] 49 Document No. 2007A145(4) 6. Alps Electric (Ireland) Ltd Appendix VI-Air dispersion modelling contour plots. Only NO2 as NOX, SO2, and PM as PM10 percentile contour plots for the classical air pollutants are illustrated in this section due to the large number of contour graphic files. Annual average plots are not included for NO2 as NOX, SO2, and PM10 due to the large file size. Contour plots are only supplied in this section for illustrative purposes only and refer to Scenarios 2, 3 and 4. 6.1 Classical air pollutants for Scenario 2-proposed plant operation -3 Figure 6.1. Predicted CO ground level concentration of 36 μg m ( percentile of 8-hour maximum GLC values for emission points A1-1 and A1-2. [email protected] 50 th )at the 100 Document No. 2007A145(4) Alps Electric (Ireland) Ltd -3 Figure 6.2. Predicted NO2 ground level concentration of 150 μg m ( percentile of 1-hour maximum GLC values for emission points A1-1 and A1-2. [email protected] 51 ) at the 100th Document No. 2007A145(4) Alps Electric (Ireland) Ltd Figure 6.3. Predicted PM ground level concentration of 20 μg m-3 ( ) at the 100th percentile of 24-hour maximum GLC values for emission points A1-1, A1-2, A2-2, A2-3 and A2-4 [email protected] 52 Document No. 2007A145(4) Alps Electric (Ireland) Ltd -3 Figure 6.4. Predicted SO2 ground level concentration of 30 μg m ( of 1-hour maximum GLC values for emission points A1-1 and A1-2. [email protected] 53 th ) at the 100 percentile Document No. 2007A145(4) Alps Electric (Ireland) Ltd -3 th Figure 6.5. Predicted SO2 ground level concentration of 20 μg m ( ) at the 100 percentile of 24-hour maximum GLC values for emission points A1-1 and A1-2. [email protected] 54 Document No. 2007A145(4) Alps Electric (Ireland) Ltd -3 ) at the 100th Figure 6.6. Predicted Lead ground level concentration of 0.020 μg m ( percentile of 1-hour maximum GLC values for emission points A2-2, A2-3 and A2-4. [email protected] 55 Document No. 2007A145(4) Alps Electric (Ireland) Ltd 6.2 Total volatile organic compounds for Scenario 3-existing plant operation Figure 6.7. Predicted VOC impact contribution of existing facility operation to VOC plume dispersal for Scenario 3 at the 98th percentile for combined VOC concentrations ≤ 650 μg m-3 ( ). [email protected] 56 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Figure 6.8. Predicted VOC impact contribution of existing facility operation to VOC plume th -3 dispersal for Scenario 3 at the 99 percentile for combined VOC concentrations ≤ 1000 μg m ( ). [email protected] 57 Document No. 2007A145(4) Alps Electric (Ireland) Ltd 6.3 Total volatile organic compounds for Scenario 4-proposed plant operation Figure 6.9. Predicted VOC emission contribution of proposed facility operation with the th implementation of VOC abatement protocols to VOC plume dispersal for Scenario 4 at the 98 -3 percentile for VOC (as C) concentrations ≤ 100 μg m ( ). [email protected] 58 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Figure 6.10. Predicted VOC emission contribution of proposed facility operation with the th implementation of VOC abatement protocols to VOC plume dispersal for Scenario 4 at the 99 -3 percentile for VOC (as C) concentrations ≤ 150 μg m ( ). [email protected] 59 Document No. 2007A145(4) Alps Electric (Ireland) Ltd 7. Appendix II-Meteorological data used within the Dispersion modelling study. 7.1 Meteorological file Cork 1993 to 1997 inclusive Figure 7.1. Schematic illustrating windrose for meteorological data used for atmospheric dispersion modelling, Dublin 1993 to 1997 inclusive. Table 7.1. Cumulative wind speed and direction for meteorological data used for atmospheric dispersion modelling, Cork 1993 to 1997 inclusive. Cumulative Wind Speed Categories Relative Direction > 1.54 >3.09 >5.14 >8.23 > 10.80 < 10.80 Total 0 0.56 0.67 1.45 0.80 0.12 0.02 3.61 22.5 0.55 0.68 1.41 0.78 0.07 0.00 3.49 45 0.43 0.59 1.10 0.44 0.11 0.00 2.67 67.5 0.63 0.77 1.62 0.61 0.23 0.03 3.90 90 0.62 0.77 1.76 0.77 0.29 0.07 4.30 112.5 0.83 1.09 1.98 0.86 0.29 0.16 5.20 135 0.57 0.71 1.62 1.01 0.34 0.22 4.47 157.5 0.87 1.04 2.15 1.68 0.73 0.33 6.81 180 0.91 1.10 2.22 1.39 0.52 0.23 6.38 202.5 1.21 1.53 3.53 1.78 0.51 0.27 8.84 225 1.11 1.54 4.31 2.00 0.63 0.23 9.80 247.5 1.16 1.40 3.74 2.41 0.77 0.36 9.84 270 1.10 1.10 2.02 1.23 0.45 0.13 6.03 292.5 1.41 1.62 2.60 1.45 0.50 0.25 7.83 315 1.29 1.74 3.04 1.18 0.31 0.11 7.67 337.5 1.25 1.70 3.42 1.31 0.14 0.02 7.84 Total 14.49 18.06 37.97 19.70 6.01 2.42 98.67 Calms -1.05 Missing 0.28 Total 100 [email protected] 60 Document No. 2007A145(4) Alps Electric (Ireland) Ltd 8. Appendix III: Checklist for EPA requirements for air dispersion modelling reporting Table 8.1. EPA checklist as taken from their air dispersion modelling requirements report. Item Location map Site plan List of pollutants modelled and relevant air quality guidelines Details of modelled scenarios Details of relevant concentrations used ambient Model description and justification Special model treatments used Table of emission parameters used Details of modelled domain and receptors Details of meteorological data used (including origin) and justification Details of terrain treatment Details of building treatment Details of deposition modelled wet/dry Yes/No Section 2 Section 2 Reason for omission/Notes - Yes - Yes Baseline dataSection 2 Yes Yes - - Yes - Yes - Yes - Yes Yes No mass fraction data, particle densities and no particle distribution data for specific operation. Particulates emission not significant from site processes. Three years of hourly sequential data used from nearest valid met station. Terrain effects are accounted for in the modelling assessment. Flue gas, VOC, and particulate emissions assessment from processes identified. E-mailed upon request No Sensitivity analysis No Assessment of impacts Yes Model input files No [email protected] 61 - Document No. 2007A145(4) Alps Electric (Ireland) Ltd 9. Appendix IV-Proposed emission guideline/limit values for emission points in Alps Electric (Ireland) Ltd. Table 9.1. Proposed emission guideline/limit values for emission points located in Alps Electric (Ireland) Ltd. Process Compound Oil fired boilers emission limit identity values ref. to 3% Oxygen Boiler/generator Carbon monoxide 800 mg/Nm3 Boiler/generator Oxides of nitrogen 450 mg/Nm3 Boiler/generator Sulphur di/trioxide 500 mg/Nm3 Boiler/generator Particulate matter Less than 50 mg/Nm3 Other emission pointsTVOC Other emission pointsTVOC Other emission pointsTVOC VOC emission Points (SI543 of 2002) Other emission points Particulate based Lead Other emission pointsParticulates (for inorganic particulates see Lead above) Health risk 3 Class I Class II Class III Category 8 Class II 20 mg/Nm at mass flow of less than 0.10 kg/hr 100 mg/Nm3 at mass flow of less than 2 kg/hr 150 mg/Nm3 at mass flow of less than 3 kg/hr1 3 Less than 75 mgC/Nm with less than 20% fugitive emissions. 3 Less than 0.50 mg/Nm with a mass flow less than 0.0025 kg/hr -- Less than 10 mg/Nm3 -- See EAL’s in Table 2.2 Notes: When Class I, II and III present the Class III guideline limits will apply. When Class I and II present the Class II guideline limits will apply. For more specific information on emission guideline limit values see TA Luft 1996, 2002 and BATNEEC Notes EPA Manufacture of Integrated circuits and printed circuit boards. SI543 of 2002-Emissions of Volatile Organic compounds from organic solvent regulations 2002. Specific output data from dispersion model to be adapted where necessary. Ref: Ta Luft 2002, EPA BAT Note for the waste sector (2003). According to the Danish legislation the guideline limits and threshold values in Table 9.2 apply. Threshold values and limits for solvents in accordance with Directive 1999/13/EG, Appendix II A. The regulation means that each company shall fulfil the limits for exhaust gases and diffuse emissions or the total emission limit (then the limit for exhaust gases can be exceeded.). [email protected] 62 Document No. 2007A145(4) Alps Electric (Ireland) Ltd Table 9.2. Threshold limit values for VOC emitting processes. Process Solvent emitting processes Activity Threshold value t/a Emissions limit for exhaust gases (mg C/Nm³) Limits for diffuse emissions (%) Total emission limit (%) Manufacture of coating materials, clear lacquers, printing inks and adhesives 100-1,000 >1,000 150 150 5 3 5 3 It may be assumed that more stringent limit or threshold values arising from the specific situation at the site or from any other officially imposed conditions will continue to apply. Ref: Environmental Guidelines No.1 of 2002,-Guidelines for air emission regulation, Danish EPA. [email protected] 63
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