Hanson Cement Investigation: Environment Agency response ......In 2009, Castle Cement Limited was re-branded as Hanson Cement, which is owned by Heidelberg Cement. Should the Environment

Title here in 8pt Arial (change text colour to black) i

Hanson Cement Investigation:

Environment Agency response to Questions of Community Concern

ii Hanson Cement Investigation: Environment Agency response to Questions of Community Concern

Contents

Contents ii

1 Introduction 1

2 Regulation 2

2.1 How are the limits used determined and how are they verified? 2

2.2 Is the model for plume coverage, as detailed in the application for the company‟s licensing purposes still valid and if not, what is the difference? 4

2.3 How many complaints have been received by the Environment Agency in the last 10 years relating to Hanson and how many incidents involved dust, noise, odour and a combination? 4

2.4 How are complaints handled by the Environment Agency? 5

2.5 Are all complaints recorded or just those with a log number? 5

2.6 How many complaints are investigated by the Environment Agency? 6

2.7 How are complaints handled by Hanson Cement? 6

2.8 What are the control measures around breaches of permit conditions? 6

2.9 If a breach occurs at what point is it assessed for impact on public health? 6

3 Cement making process 8

3.1 What materials are being used in the plant? 8

3.2 When and for how long does the plant open and run? 8

3.3 Is the kiln used as an incinerator or co-incinerator? 8

3.4 Does the incinerator operate when the plant is not making cement? 8

3.5 What are the hazards associated with milling cement? 9

3.6 Why do we see different coloured smoke if the filters are working properly? 9

3.7 Why is there more smoke in the night and early hours compared to the day? 9

3.8 What is flushing of the kiln? 9

3.9 What are the chemical and dioxin emission rates and quantities and fuel type during start up and shut down (planned or emergency) compared to those during optimum running conditions? 10

3.10 How can the relevant authorities be properly aware of the full weight and chemical makeup of the total emissions from the site (high and low level point sources), when only stack emission measurements are the official record and no emission monitoring is required at lower throughputs of raw materials or during shut down process (emergency or planned)? 11

3.11 Why are odours worse during firing up and closing down the kiln? 12

3.12 Should the permit be changed to include monitoring during start up and cool down of the kiln? 12

4 Fuel 13

4.1 What alternative fuels are being burnt? 13

Hanson Cement Investigation: Environment Agency response to Questions of Community Concern iii

4.2 What is being incinerated? 13

4.3 Are carcinogenic and toxic material being burned? 13

4.4 What is the chemical composition of tyres? 13

4.5 What tests have been done for the dispersion of chemicals from a tyre upon combustion? 14

4.6 Who performs the independent test on the alternative fuels being used? 14

4.7 Are there differences in emissions when burning alternative fuels and is any difference significant to human health? 15

4.8 Are chipped tyres sourced entirely from tyres manufactured to UK standard or do they include tyres sourced from all manufacturers? 15

5 Landfill and waste 16

5.1 Has any hazardous waste been buried on site? 16

5.2 What monitoring of waste activities is carried out? 16

5.3 What is the impact of any waste activities on the community? 16

5.4 Have any discharges from the waste burial sites affected any water courses in the vicinity, purposefully or accidentally? 17

5.5 Water from the stream near the landfill waste has a tainted chemical smell, changes colour and the sediment may also be contaminated - is this monitored? 17

5.6 What are the impacts of the disposal of bottom and fly ash? 18

6 Emissions and monitoring 19

6.1 How are the emissions from overnight kiln flushes monitored? 19

6.2 What are the emissions from site? 19

6.3 What are the stack emission levels of dioxins? 20

6.4 How are dioxins prevented from entering the atmosphere? 20

6.5 Is there a need for on-going monitoring? 20

6.6 Are there heavy metal emissions – copper, magnesium and cadmium? 21

6.7 What are the results of dust tested from windowsills? 21

6.8 What monitoring is done for regulatory purposes (including air, soil, milk and human tests)? 21

6.9 Is the site monitored 24 hours a day? 22

6.10 At what stages of the process is it monitored? 22

6.11 Who analyses the data? 22

6.12 Is the monitoring sufficient? 22

6.13 How can we know the information / monitoring is conducted independently and accurately? 23

6.14 Who is responsible for the calibration and maintenance of the monitoring units and is this done appropriately? 23

6.15 Does the Environment Agency consider data gathered by Emissions Watch, particularly for the night time peaks? 23

6.16 Had the Environment Agency taken action following this data? 24

6.17 What were the results of the monitoring to detect low level fugitive emissions from the site by the Environment Agency over a summer period (this followed

iv Hanson Cement Investigation: Environment Agency response to Questions of Community Concern

the identification, by CANK, of 14 sites where visible unscheduled emissions occurred)? 24

7 General 25

7.1 Is there a better way to provide the products that Hanson provides? 25

7.2 Such a process was refused in the USA on the grounds of toxic pollution, if this is true why is it allowed in this country? 25

7.3 Has any information been gathered or used from other similar comparator plants across the UK / Europe and is there any thing that can be learned in other situations that can be applied here? 25

7.4 How many regulated industries are there within a ten mile radius of Hanson works? 26

7.5 Why has the „What‟s in my back yard‟ website of the Environment Agency been „dumbed down‟ and obfuscated to the point that annual comparisons of emissions of chemicals can no long be made? 27

Appendices 29

Appendix A – Monitoring of Waste Activities 29

Table A1 - Landfill gas monitoring and sampling programme- within waste 29

Table A2 - Landfill gas monitoring and sampling programme- external to site 29

Table A3 - Leachate monitoring and sampling programme 29

Table A4 - Groundwater Monitoring and Sampling Programme 30

Table A5 - Surface Water and Monitoring Programme 31

Appendix B – Monitoring of emissions 32

Table B1 - Emissions to air - kiln 32

Table B2 - Emissions to air - non-kiln 34

Table B3 - Emissions to surface water and land 35

Table B4 - Emissions to sewer 36

Table B5 - Noise 36

Table B6 - Ambient monitoring 36

Appendix C – Cement Manufacturing Process 37

Appendix D – Questions of Community Concern 38

Hanson Cement Investigation: Environment Agency response to Questions of Community Concern 1

1 Introduction

In April 2010, Mrs Edwina Hart AM MBE, the then Minister for Health and Social Services, requested that Public Health Wales work with other interested parties and the local community to gain a better understanding of the health concerns associated with Hanson Cement (formerly Castle Cement Ltd). An investigation response team has been established to provide expert advice and support in response to the concerns. The Environment Agency, along with other organisations such as the Health Protection Agency and the Food Standards Agency, is a member of the investigation team. As part of our contribution to the investigation, the Environment Agency has provided monitoring and complaints information for the Padeswood site, covering the last ten years. This information has been used by the other organisations in the investigation team to respond to concerns. The investigation team has sought the views and concerns of local residents and community leaders. This report forms one part of the overall response and provides answers to questions on the operation and regulation of the site. A full set of questions is provided in the document Questions of Community Concern (see Appendix D) published and further responses are provided in reports from other agencies. Castle Cement Limited holds an environmental permit issued by the Environment Agency for activities at the Padeswood site. In 2009, Castle Cement Limited was re-branded as Hanson Cement, which is owned by Heidelberg Cement. Should the Environment Agency take any enforcement action for a breach of the permit, it would be against Castle Cement Limited as the company who holds the permit. In the investigation documentation, where reference is made to Hanson Cement, this is because the re-branding has taken place and Castle Cement is now generally known as Hanson Cement .

2 Hanson Cement Investigation: Environment Agency response to Questions of Community Concern

2 Regulation

2.1 How are the limits used determined and how are they verified?

The emission limits in the environmental permit have been set to ensure they comply with the Environmental Permitting Regulations 2010 which transpose into England and Wales legislation the requirements of the EU Integrated Pollution Prevention and Control Directive 2008/1/EC (IPPC), and the EU Waste Incineration Directive 2000/76/EC (WID). Prior to the introduction of the Environmental Permitting Regulations, the site was regulated under earlier regulatory regimes – the Pollution Prevention and Control (England and Wales) Regulations 2000 and the Environmental Protection Act 1990. Best Available Techniques The Regulations require an operator to take all appropriate measures to prevent pollution by using „Best Available Techniques‟ (BAT), where BAT is defined in the IPPC Directive. Information on BAT is collated at an EU level for different types of industry e.g. the cement industry, and is published as a BAT Reference Document (BREF) which sets out the techniques that companies should use to achieve a high level of protection of the environment as a whole, including human health. The techniques must be technically and economically viable to operate at an industrial scale and to be commercially accessible to that industry. Site-specific limits The BREF also sets out indicative emission levels that should be achievable using BAT techniques. The Environment Agency uses these indicative emission levels as a reference when setting site-specific emission limit values (ELVs) in individual permits. We also take into account local site-specific factors such as:

the technical characteristics of the installation;

its geographical location;

local environmental conditions.

We use this information to consider whether we should set a tighter, or less strict, ELV than the indicative emission level. When setting ELVs for existing installations, as well as indicative standards, site specific and local considerations, we also take account of the current emission levels. We may require the operator to improve performance to meet a tighter ELV or to reduce emissions over a defined period of time. New installations are normally expected to comply with the indicative emission levels as a minimum, but also to demonstrate why it is not reasonable to expect them to achieve even lower emissions. We also expect most existing installations to comply, and where significant improvements are needed, allow an appropriate length of time to up-grade the plant to achieve this. The only exceptions are if the operator can justify, on the basis of costs and environmental benefits, why this might not be appropriate for the circumstances at a specific installation.


See 7.3 for further information. Waste Incineration Directive In addition to the above regulations which apply to a large range of industries, cement kilns that burn wastes as fuels - such as at Padeswood - must also comply with the specific requirements of the Waste Incineration Directive 2000/76/EC (WID). This sets mandatory emission limits for certain substances released to the environment, this includes emissions to air and water. Any operation to which WID applies must comply, as a minimum, with the limits in the Directive regardless of the costs - this may mean going beyond what is required by BAT. If the plant is unable to meet these standards it will not be permitted to operate. Air Quality standards Air Quality Standards have been set using the most recent information collected by the World Health Organisation on the impacts of air pollutants on health.

The standards apply to ambient or background air quality and are set to protect human health. To understand the effect of an operation on air quality, the Environment Agency creates a model of the way emissions are predicted to be distributed as part of the permit application. This takes account of the existing background concentrations of the same substances that are released by the process. More information on air quality standards is provided in the Health Protection Agency reports on particulates, dioxins, sulphur dioxide and oxides of nitrogen. Modelling also predicts the way dioxins are likely to be deposited in the environment. The primary route where humans may be exposed to dioxins is through the food chain. The modelling assesses the risk of food contamination, in comparison with dioxin limits. More information on dioxin limits is provided in the Food Standards Agency assessment of milk, soil and vegetation samples taken in the vicinity of the plant. Water Quality Standards The standards to protect a water body are set out in The River Basin Districts Typology, Standards and Groundwater threshold values (Water Framework Directive) (England and Wales) Directions 2010, which implement the requirements of the Water Framework Directive 2000/60/EC (WFD). Prior to the implementation of WFD, standards set under the Dangerous Substances Directive 76/464/EEC were used to assess impacts in surface waters. Dangerous Substances Directive standards will be repealed in 2013. The standards that apply to a particular water body will vary depending on the nature of the water body e.g. river or estuary, and what the water body is used for e.g. drinking water abstraction or fishery. Environmental Quality Standards (EQSs) that are designed to protect aquatic life e.g. fish and aquatic plants, are set for a range of chemicals. These apply to all surface water bodies. These EQSs are set by assessing how toxic a particular chemical is to a range of aquatic plants and animals. This looks at both long and short term toxicity. The persistence of the chemical in the environment and if it is likely to accumulate in aquatic species is also taken into consideration. The standard is set to protect the most sensitive species.


For water bodies where water is taken to be treated for drinking water, discharge limits need to ensure water quality does not deteriorate. This is required under the WFD (and is implemented in Wales by the Water Supply Regulations 2010) in order to reduce the level of treatment required for water, to produce public drinking water. Water quality limits in a permit will be set to take into account how much the discharge is diluted when it enters a watercourse. Calculations of the dilution required to achieve the EQS will take into account the existing background concentrations in the receiving water. Where there is more than one use of a water body, the most stringent standards will be applied.

2.2 Is the model for plume coverage, as detailed in the application for the company‟s licensing purposes still valid and if not, what is the difference?

The modelling undertaken at the time of the application is still valid. The software and associated guidance have not changed sufficiently to affect the conclusions we made at the time of permitting. There have been no changes to operations at the site that would change any of the data put in to the model.

2.3 How many complaints have been received by the Environment Agency in the last 10 years relating to Hanson and how many incidents involved dust, noise, odour and a combination?

The total number of complaints received in the last 10 years has been 623 for dust, 540 for noise, and 181 for odour. The graphs below show the number of complaints by year for dust, noise and odour.

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2.4 How are complaints handled by the Environment Agency?

The Environment Agency has a National Incident Recording System to record and report incidents and complaints. Calls are logged by our Regional Communications Centre (0800 807060), given a unique reference number and then forwarded directly to the Regulatory Team or Standby Officer to begin the assessment. For issues about regulated sites, details of the call are also forwarded to the site operator (subject to Data Protection Act and confidentiality arrangements) to investigate. The findings of the investigation are fed back to the complainant if requested.

2.5 Are all complaints recorded or just those with a log number?

All complaints received by the Regional Communications Centre are recorded and given a unique reference number.


2.6 How many complaints are investigated by the Environment Agency?

All complaints received by the Environment Agency are investigated. Details of the number of complaints received by the Environment Agency relating to Hanson Cement are included in the response to question 2.3.

2.7 How are complaints handled by Hanson Cement?

Hanson Cement has a management system for incident recording and reporting. Complaints are received, logged, investigated and they then report back to the complainant. If the investigation shows that the complaint resulted from a breach of permit conditions then Hanson Cement must notify the Environment Agency, put measures in place to stop the breach and prevent it happening again. These preventative measures are put into place after a review of the proposals by the Environment Agency.

2.8 What are the control measures around breaches of permit conditions?

If Hanson Cement breaches its permit conditions (for example exceeds an emission limit or has a fugitive release) it must take measures to return to compliance with its permit conditions. Hanson must notify the Environment Agency without delay, thoroughly investigate the incident, put measures in place to stop the breach and prevent it happening again. These measures are reviewed by the Environment Agency before they are implemented to ensure they will resolve the problem. We will also consider any appropriate enforcement response.

2.9 If a breach occurs at what point is it assessed for impact on public health?

If a breach occurs the Environment Agency will immediately assess whether or not the local population may be exposed to a hazard or potential hazard. The potential for exposure is assessed using the following criteria: Releases to air:

Can people breath it

Will it settle on food crops

Will food animals be exposed to it?

Release to water:

Is there a drinking water or crop watering abstraction point downstream?

Can people get into it?

Could people recover and eat dead fish?

Could groundwater be contaminated?


Releases to land:

Do people have direct contact with it?

Could they eat crops grown on it?

Could groundwater be affected?

If any of these criteria are met or the chemical released is likely to be of public concern e.g. dioxins, the Environment Agency will notify Public Health Wales and the Health Protection Agency, who will assess the potential consequence of any exposure.


3 Cement making process

3.1 What materials are being used in the plant?

The raw materials in the process are limestone, sand and pulverised fuel ash (which is produced in the generation of electricity from coal-fired power stations). Gypsum is added in the milling stage. Gas oil or kerosene are used to start up the kiln, it is then fuelled by coal and petcoke. Details of the waste derived fuels used in the kiln are given in response to 4.1.

3.2 When and for how long does the plant open and run?

The planning permission granted by Flintshire County Council allows the plant to run 24 hours a day, 365 days of the year. The environmental permit does not restrict the plant operating hours. The actual operating hours of the plant are decided by Hanson Cement, based on business need.

3.3 Is the kiln used as an incinerator or co-incinerator?

An incineration plant is used for the thermal treatment of waste whether or not the heat generated from combustion is recovered. Thermal treatment processes include pyrolysis, gasification or plasma processes where substances produced by the treatment are then incinerated. A co-incineration plant burns waste mainly to generate energy or produce a material product. The kiln is a co-incinerator. It is making use of the energy content directly in the manufacture of cement. The main purpose of the plant (kiln) at Padeswood is to make clinker. Clinker is mixed with gypsum and may be ground with additives, such as fillers, grinding aids and strength enhancers, to make the final cement product. Producing clinker is very energy intensive. The waste derived fuels, Cemfuel, used tyres, MBM, Profuel and SRF, may be used at Padeswood in addition to the base fuels, coal/petcoke (see 4.1 for additional information).

3.4 Does the incinerator operate when the plant is not making cement?

The kiln is used to manufacture cement clinker, it is a co-incinerator not an incinerator. The kiln does not operate if it is not making cement clinker.


See also the answer to 3.3.

3.5 What are the hazards associated with milling cement?

The Environment Agency's primary concern in the milling operation is the prevention of dust emissions from the mills. These dust emission are minimised using bag filters. Emissions from the cement mills are continuously monitored to make sure they comply with the limit included in the permit. The Health Protection Agency have undertaken a review of particulate matter in the Padeswood area. This is provided on the investigation website. http://www.wales.nhs.uk/sitesplus/888/page/49608

3.6 Why do we see different coloured smoke if the filters are working properly?

The plume from Hanson Cement is water vapour not smoke. This plume is caused when the warm, moist air leaving the stack mixes with ambient air and cools until it condenses to form small water droplets. The colour of the water vapour plume is influenced by the direction of the sun in relation to the plume. Back-lit plumes are darker and can look like smoke. Front-lit plumes are white.

3.7 Why is there more smoke in the night and early hours compared to the day?

Weather conditions, especially air temperature and humidity, will determine whether or not the plume is visible. It is more likely to be visible when the air is cooler and wetter. As the air cools and becomes more humid at night, the plume is more likely to be visible then. See 3.6 for more information. The kiln, when operating, runs continuously for 24 hours a day.

3.8 What is flushing of the kiln?

A kiln flush is an unplanned, non-permitted event. Operational contingencies are in place to reduce the likelihood of this happening. The kiln is supplied with material from a pre-heater tower. Raw material can sometimes build up in this tower and suddenly be released into the kiln. This causes a sudden build up of pressure in the system resulting in a release of dust to atmosphere. Hanson Cement would have to notify the Environment Agency if this happens. Further information on the response to breaches of the permit is provided in 2.8. Some of the contingencies in place include:

better operational control of the process


a system to regularly displace small amounts of build up

improved flow control between cyclones.

All these reduce the likelihood of a large build up of product within the system.

3.9 What are the chemical and dioxin emission rates and quantities and fuel type during start up and shut down (planned or emergency) compared to those during optimum running conditions?

What duration are these emissions present / created for, per procedure?

How do these emissions behave in terms of atmospheric dispersal compared to emission created during optimum running conditions?

How do these emissions compare to the licensed levels of emission for the site?

Start up When the kiln is started up from cold, care has to be taken to ensure that it is not heated too quickly as this could damage the kiln. A heating programme is used to control the rate at which the kiln warms up from cold. A substance known as gas oil is used as fuel to preheat the kiln and tower for 24 hours. Gas oil contains less than 0.1% sulphur. During this period the concentrations of sulphur dioxide emissions are low. The main mechanism for the production of nitrogen oxides in the process is the reaction between nitrogen and oxygen in the combustion air, this requires temperatures above 1050oC. Emissions of nitrogen oxides will be low during the heating with gas oil as the flame temperature is lower than the normal operating temperatures, to prevent heat damage to the kiln. Once the kiln lining has reached a temperature high enough to ensure coal ignition, coal is fed into the main burner and the addition of oil is gradually reduced. This additional warm up period is typically up to 12 hours before the raw material (limestone, sand etc) is added. During this period the higher sulphur content of coal results in a higher sulphur dioxide concentration in the emission, however, the volume flow rate is significantly lower than normal running so the mass rate of emissions is still lower than normal running. Once the coal flame is established the nitrogen oxides emissions start to increase due to the higher temperature of the coal flame. The main kiln filter and cooler filter are operated normally throughout the warm up period so concentrations of releases of particulate matter will be similar to those under normal operating conditions. Volatile organic compounds are reported as total organic carbon, these emissions during start up are significantly less than under normal operating conditions. Dioxin emissions have not been measured during start up and shutdown. During start up emissions will be similar to any other process burning gas oil or diesel.


Shut down a) Planned – The first step in a planned shut down is to stop the addition of alternative fuels, this is followed by reducing the amount of raw material added and slowing down the flow of coal. At this point the kiln raw material feed is still operating and so the scrubbing effect of the limestone in the feed is still absorbing the sulphur dioxide generated in the kiln. The next step is to reduce the air flow through the cooler so the gas flow through the kiln system is now much lower than that under normal operating conditions. This is followed by the stopping of the kiln Induced Draft fan which stops the flow of air to the kiln. The kiln raw material and coal feeds are then stopped, at this point there is no further production of nitrogen oxides nor sulphur dioxide. The main kiln filter and cooler filter continue to operate throughout the shut down until the kiln has cooled. Therefore particulate matter emission concentrations will be comparable with those under normal operating conditions although the volume flows will be lower and so the mass releases will be lower. b) Emergency – In an emergency shut down (e.g. following a power failure) releases from the kiln will be similar to those described above. The act of stopping the kiln – Induced Draft fan, raw material feed and fuel feed all off, is the same for planned and emergency shut down and takes about five minutes. Dispersion During start up and shut down the volume flow rates are significantly lower than during normal operations, therefore the mass rate of emissions will also be significantly lower. The temperature at the stack exit is typically slightly lower than the 125oC during normal operation and therefore dispersion will be over a slightly smaller area than normal operational conditions (given similar weather conditions).

3.10 How can the relevant authorities be properly aware of the full weight and chemical makeup of the total emissions from the site (high and low level point sources), when only stack emission measurements are the official record and no emission monitoring is required at lower throughputs of raw materials or during shut down process (emergency or planned)?

The regulated emission points comprise not only the stack but also the kiln 4 cooler exhaust and the mills. All have continuous emission monitors (CEMs). See 6.1 regarding fugitive emissions (a release to air from any part of the plant not controlled by an emission limit) and 2.8 regarding Hanson Cement reporting responsibilities. See also 6.2 regarding emissions from site and 3.12 for CEMs and start up and shut down.


3.11 Why are odours worse during firing up and closing down the kiln?

When the kiln is started it is warmed by oil until the kiln lining has reached a temperature high enough for coal to ignite, coal is fed to the main burner and the oil feed is gradually reduced. This warm up period is typically up to 12 hours before the addition of raw material (limestone, sand etc) is started. As coal contains higher levels of sulphur than alternative fuels, the concentration of sulphur dioxide in the emissions at this stage is higher than normal – and this may cause an increase in odour for a short time. The same thing can happen when the kiln is shut down. As much less coal is fed at this stage the likelihood of higher sulphur dioxide concentrations is reduced. See 6.1 for additional information.

3.12 Should the permit be changed to include monitoring during start up and cool down of the kiln?

No permit change is required because there is currently continuous emission monitoring of the kiln. This operates during start up and cool down of the kiln. See 6.2 for additional information.


4 Fuel

4.1 What alternative fuels are being burnt?

The waste derived fuels that are permitted for the kiln are: Chipped, used tyres Cemfuel which is a liquid that is manufactured to a detailed specification from a range of wastes including paint and ink residues, spent solvents and oils. Profuel which is manufactured from solid wastes, principally paper, plastics, fibre and textiles. SRF (Solid Recovered Fuel) which is bio-degraded and shredded combustible waste, mainly consisting of paper and plastics. MBM (Meat and Bone Meal) which is a solid non-hazardous biofuel produced by sterilising and grinding abattoir waste.

4.2 What is being incinerated?

The kiln is a co-incinerator (refer question 3.3). Waste derived fuels are used for the recovery of energy from wastes allowing the conservation of fossil fuels. Gas oil or kerosene are used to start up the kiln, which is then fuelled by coal and petcoke until stability is achieved. Once stability is achieved waste derived fuels (see above) may be used.

4.3 Are carcinogenic and toxic material being burned?

The waste derived fuels are classified as either non-hazardous or hazardous. A waste that has one or more properties, such as flammability, toxicity, corrosiveness etc, as defined in the waste regulations, is classified as hazardous. The only waste derived fuel used at the site that is categorised as hazardous is Cemfuel. See also 3.3.

4.4 What is the chemical composition of tyres?

In 2006, the Waste and Resources Action Programme (WRAP) described tyres as being made up of numerous different rubber compounds, many different types of carbon black, fillers like clay and silica, and chemicals & minerals added to allow or accelerate vulcanisation. The tyres also have several types of fabric for reinforcement and several kinds and sizes of steel. The composition of a common-sized all season passenger tyre was given by WRAP as:

30 kinds of synthetic rubber


8 kinds of natural rubber

8 kinds of carbon black

Steel cord for belts

Polyester and nylon fibre

Steel bead wire

40 different chemicals, waxes, oils, pigments, silicas and clays.

The current permit at Hanson‟s Padeswood plant specifies the minimum calorific value (energy value when burned) and the maximum concentration of sulphur in the tyres used in this process. Whole and chipped tyres have a high calorific value similar to coal. They also have the benefit that the steel reinforcing in the tyre is recycled and incorporated into the cement, thereby reducing the amount of iron which has to be added as a raw material into the cement. The high temperatures and residence times for the kiln are imposed by the Waste Incineration Directive (WID). Under these conditions the destruction and removal efficiency of the organic compounds is greater than 99.99%. Similarly WID specifies mandatory emission limit values.

4.5 What tests have been done for the dispersion of chemicals from a tyre upon combustion?

Studies reported by the Committee on the Medical Effects of Air Pollutants (COMEAP), in 2005 and 2008, on the use of waste derived fuels (including tyres) in cement kilns, reviewed the emissions during the use of these fuels. The committee concluded that when Substitute Liquid Fuel (SLF) and used tyres were used in accordance with a defined protocol, then their use “was, in comparison with the use of coal as a fuel, unlikely to cause an increased risk to health”. The protocol has now been superseded by legislation that has come into force since its introduction: the EC Waste Incineration Directive, the Pollution Prevention and Control Directive and the Public Participation Directive. It is a permit requirement that all new waste derived fuels require a feasibility trial (subject to EA approval) before their routine use. See also 4.4.

4.6 Who performs the independent test on the alternative fuels being used?

Waste derived fuels are analysed by the fuel supplier and audit samples are analysed by Hanson Cement. The sampling and analysis of each fuel is based on the potential for the fuel to vary - so analysis of materials such as tyres and MBM which are more consistent in nature is carried out less frequently than Cemfuel and SRF which are potentially more variable in quality.


All waste derived fuels are analysed for Calorific Value, carbon content and biomass by independent laboratories for EUETS (European Union Emission Trading Scheme) compliance purposes.

4.7 Are there differences in emissions when burning alternative fuels and is any difference significant to human health?

The emission limits remain the same for all permitted fuels. In 2009 the Committee on the Medical Effects of Air Pollutants (COMEAP) produced a statement reporting on an extension to their earlier statement (when Substitute Liquid Fuel and used tyres were evaluated, see response to 4.5) on the use of waste derived fuels in cement works. It was stated that earlier conclusions could be extended to the waste derived fuels PSP (Process Sewage Pellets – not included in the Padeswood permit), MBM (Meat & Bone Meal) and SRF (Solid Recovered Fuels) i.e. if these waste derived fuels were used in accordance with a defined protocol, then their use was unlikely to cause an increased risk to health. The new conclusions were also extended to combinations of the waste fuels. In addition COMEAP reported that the use of waste derived fuels reduced emissions of some key pollutants (e.g. nitrogen oxides). See 4.4 and 4.5.

4.8 Are chipped tyres sourced entirely from tyres manufactured to UK standard or do they include tyres sourced from all manufacturers?

End of life tyres include tyres sourced from all manufacturers.


5 Landfill and waste

5.1 Has any hazardous waste been buried on site?

Waste was deposited at a landfill on site between 1949 and 2002. A Waste Disposal Licence was issued by Alyn and Deeside Waste Regulation Authority in 1987 to cover this. This allowed the Hanson Cement to deposit cement manufacturing waste which was inert and non-toxic. Castle Cement (now Hanson Cement) applied to close the landfill in 2002 – at that time it was classified as non-hazardous. However, all the waste was deposited before the Hazardous Waste Regulations 2005 came into force – this changed the classification of a number of materials which may be in the landfill. It is possible that some waste which would now be considered hazardous, was accepted on site during the lifetime of the landfill. Castle (now Hanson) was granted a variation to its permit in 2007 to create a new landfill on site. Although the landfill was built it has never been used. This activity has now been removed from the permit and Hanson is looking to restore the area that had been engineered to accept waste.

5.2 What monitoring of waste activities is carried out?

The site ceased accepting waste in 2002. Hanson Cement must continue to monitor leachate, surface water, gas and groundwater periodically for a number of parameters as a requirement of their original licence. This will continue until the Environment Agency is satisfied that this landfill poses no future environmental risk .

See Appendix A for more detailed information. The Environment Agency has ensured that the monitoring requirements in the licence are strong enough to make certain that any landfill related issues can be detected and remediation plans implemented if required.

5.3 What is the impact of any waste activities on the community?

The environmental impact of the landfill is assessed using the monitoring discussed above. See also the response to 5.4. We understand the potential risks to the environment from landfills. However we are not health experts and so we take advice and information provided by health professionals in making decisions on the risks to health from landfills we regulate. As part of our permitting process for landfill sites we consult with Health Boards on any application we receive.


The Health Protection Agency have recently published a report, Impact on Health of Emission from Landfill Sites, which provides further information. http://www.hpa.org.uk/web/HPAwebFile/HPAweb_C/1309969974126

5.4 Have any discharges from the waste burial sites affected any water courses in the vicinity, purposefully or accidentally?

The landfill site does not have an engineered lining system, as historically this was not a regulatory requirement. This means that any water infiltrating the site could pass through the landfill and into the groundwater. An engineered cap was installed in 2004 /2005, which had the immediate effect of reducing the amount of water entering the waste mass and therefore reducing the amount of leachate produced. Leachate is any liquid or rainwater that has come into contact with the waste. The leachate, groundwater and surface water are all monitored by Hanson Cement. The data supplied to us show that the quality has been improving since the cap was installed. The groundwater has been impacted locally through the diffusion of leachate. This then has an impact on local surface water directly downstream where there are slightly elevated levels of ammoniacal nitrogen and pH. Hanson Cement recently proposed an outline for an improvement programme to further reduce the impact of the landfill on surface water and groundwater. This programme includes the improvement of the leachate collection system and installing additional monitoring boreholes.

5.5 Water from the stream near the landfill waste has a tainted chemical smell, changes colour and the sediment may also be contaminated - is this monitored?

As part of the environmental permit for the historic landfill, Hanson Cement are required to monitor groundwater and surface water. Details of the monitoring requirements are included in response to 5.2 and in Appendix A. Reports are submitted to the Environment Agency on a quarterly basis for assessment.

The site is also permitted to discharge drainage from the cement works via a settlement lagoon. This is monitored on a weekly basis. Results are submitted to the Environment Agency each quarter to be assessed. Details of these monitoring requirements are included in Appendix B, Table B3.

The Environment Agency currently undertakes monthly monitoring downstream of the discharges from Hanson Cement.

If further issues relating to odour or visual impact of the stream occur please log these with the Environment Agency on 0800 807060 so they can be investigated.

See 5.4 for additional information.


5.6 What are the impacts of the disposal of bottom and fly ash?

The Padeswood cement manufacturing process does not produce bottom and fly ash - it produces filtered dust and by-pass dust. Filtered dust is recycled on site within the process and by-pass dust is taken off-site for removal of soluble chlorides (which affect the quality of cement) by washing. The residual material is returned to use in the cement manufacturing process.


6 Emissions and monitoring

6.1 How are the emissions from overnight kiln flushes monitored?

A kiln flush is an unplanned non-permitted event. Operational contingencies are in place to reduce the likelihood of this happening (see response to 3.8). The kiln stack and kiln cooler exhaust are continuously monitored for dust emissions. Hanson Cement must notify the Environment Agency, without delay, if it breaches its emission limit. The main monitoring on the site for fugitive dust emissions (i.e. a release to air from any part of the plant not controlled by an emission limit, typically this is due to loss of containment such as failure of joints, spillages, dusty wagons etc) is by CCTV. In addition Hanson have regular housekeeping audits and the Environment Agency periodically inspect the site. Hanson Cement must inform the Environment Agency, without delay, following the detection of:

any malfunction, breakdown or failure of equipment or techniques, accident, or emission of a substance not controlled by an emission limit which has caused, is causing or may cause significant pollution;

the breach of a limit specified in the permit; or

any adverse environmental effects

See the response to 2.8 for further information on the process if a notifiable event occurs.

6.2 What are the emissions from site?

The permit lists a number of points where emissions can be made to air and water. Appendix B shows which emissions must be monitored as part of the environmental permit. The emissions to air include those from kiln 4 and the cement mills. Limits are set on emissions from both these sources. (See 6.8 for further information on monitoring of emissions). Surface water on the site, drains to a lagoon where any solids settle at the bottom. The water is discharged to a tributary of Black Brook. The site's environmental permit puts limits on the emissions contained in this water and sets frequency of monitoring. Emissions from the site's vehicle wash go into a sewer and are controlled by a trade effluent consent from Dwr Cymru Welsh Water. The environmental permit says that any emissions to air, land or water not controlled


by limits - either from the emission points listed in the permit or other localised or diffuse sources (i.e. fugitive releases) - must not cause pollution. Noise monitoring is also carried out by Hanson Cement to assess the impact at the site perimeter. The frequency of this monitoring is detailed in Appendix B.

Information relating to the landfill is provided in 5.2 and Appendix A.

6.3 What are the stack emission levels of dioxins?

The environmental permit sets a concentration limit for dioxin emissions of 0.1 ng/m3 (1 nanogram is equal to 1,000,000,000th of a gram). Apart from two instances (below) the monitoring results are well below this limit. High dioxin levels were recorded in the old kilns at the end of 2004 as a result of the type of raw material used at the time. The Environment Agency prosecuted Castle Cement (now Hanson Cement) in 2006, partly based on these high results. Dioxin levels above the limit were also recorded in 2008 during a trial to burn solid recovered fuel in the kiln. Investigations showed this breach happened as a result of feed arrangements and high temperatures in the conditioning tower. The trial was stopped until both these issues were resolved.

6.4 How are dioxins prevented from entering the atmosphere?

Kiln 4 has been designed to minimise the production of dioxins. The formation of dioxins requires, amongst other things, a temperature window of between 200 and 450oC with a long retention time in this temperature window. At temperatures above 925oC dioxins decompose rapidly. The temperature in the kiln is maintained at approximately 1450oC. The process design ensures that the temperature of gases leaving the stack are reduced rapidly to around 160oC. This minimises the production of dioxins in the gases at the cooling stage. At temperatures below 200oC dioxins are largely solid and absorbed onto the dust and collected in the bag filter. Bag filter dust is returned into the kiln process.

6.5 Is there a need for on-going monitoring?

The environmental permit requires Hanson Cement to monitor the kiln for dioxins twice a year. This requirement is in line with the Waste Incineration Directive.


6.6 Are there heavy metal emissions – copper, magnesium and cadmium?

The environmental permit requires the emissions from kiln 4 to be monitored for a number of substances on a regular basis. This includes copper, magnesium and cadmium. Details of monitoring frequencies and emission limits are in Table B1, Appendix B.

6.7 What are the results of dust tested from windowsills?

From January 2008 Hanson Cement has used an external laboratory to test dust samples arising from complaints. The techniques used are scanning electron microscopy and X-ray microanalysis which give high confidence in the results. Previous investigations had been mainly based on direct observation or simple optical magnification. Samples were taken from properties (including windowsills), cars and caravans. Evaluation of results provided by Hanson Cement indicated approximately 10% of the samples maybe attributable to the cement works (including both raw materials - limestone and sand and product - and cement clinker) and approximately 12% had a minor component which maybe attributable to the cement works. This means that less than a quarter of dust collected came from Hanson Cement. Samples which were not attributable to the cement works contained a range of substances including: weathered natural minerals, pollen, organic fibres, „general dust‟ – possibly of organic origin and also associated with road gritting. There has been significant improvement work done by Hanson Cement to reduce fugitive dust emissions since the issuing of Enforcement Notices by the Environment Agency in 2006 and 2007. In addition uncontrolled dust releases formed part of the prosecution that was successfully brought against Castle Cement (now Hanson Cement) by the Environment Agency.

6.8 What monitoring is done for regulatory purposes (including air, soil, milk and human tests)?

The kiln stack is monitored continually for particulate matter, volatile organic carbon, hydrogen chloride, carbon monoxide, sulphur dioxide and oxides of nitrogen – this is a requirement of the Waste Incineration Directive and is embedded in Hanson‟s environmental permit. Periodic monitoring also takes place on the kiln stack to measure a number of parameters including metals, dioxins and other trace chemicals. The cement mills are continuously monitored for emissions of particulate matter. Monitoring at both the kiln stack and mills is after they have gone through the abatement equipment. Standards - The monitors and techniques used comply with British Standards.


Water is monitored in the tributary to Black Brook for suspended solids, pH, biological oxygen demand, temperature, flow, oil and grease. Noise is monitored on the perimeter of the site. Particulates, sulphur dioxide and nitrogen dioxide are continuously monitored at the Penyffordd Bowling Club. Soil, moss and milk samples have been taken from various locations for dioxin and furan analysis. Soil and milk sampling was a pre-operating condition as part of the permit for kiln 4 and continued for a number of years after it was commissioned. This requirement is currently being reviewed. Refer to response to 6.2 and Appendix B for further information.

6.9 Is the site monitored 24 hours a day?

The kiln stack and the cement mills are monitored continuously. Additional monitoring also takes place every 6 months. Water sampling is completed on a weekly basis. Noise monitoring is monthly. The monitoring at Penyffordd Bowling Club is continuous. Refer to response to 6.2 for further information.

6.10 At what stages of the process is it monitored?

All site sampling takes place after emissions have passed through the abatement equipment. Refer to response to 6.2 for further information about what is monitored.

6.11 Who analyses the data?

Specialist data, such as noise, are generally analysed by a competent contractor. Process related data such as stack emissions are generally analysed by the site personnel who must inform the Environment Agency if permit breaches occur (see 2.8).

6.12 Is the monitoring sufficient?

The monitoring requirements in the environmental permit have been set to ensure they comply with the Environmental Permitting Regulations 2010 which transpose into England and Wales legislation the requirements of the EU Integrated Pollution Prevention and Control Directive 2008/1/EC (IPPC), and the EU Waste Incineration Directive 2000/76/EC (WID). They are sufficient to do this. See 2.1 for further details. This only details monitoring required by the site‟s environmental permit - it does not cover those required by other regulatory regimes


It should be noted that prior to the introduction of the Environmental Permitting Regulations the site was regulated under earlier regulatory regimes – the Pollution Prevention and Control (England and Wales) Regulations 2000 and the Environmental Protection Act 1990.

6.13 How can we know the information / monitoring is conducted independently and accurately?

The kiln is monitored continuously as required by the Waste Incineration Directive and Hanson‟s environmental permit. The permit requires monitoring equipment to meet MCERTS standards, where applicable (MCERTS is the Environment Agency‟s Monitoring Certification Scheme). Using specialist staff, the Environment Agency completes an annual check monitoring of selected process limits. The Environment Agency also has a scheme known as Operator Monitor Assessment (OMA) which applies to all processes regulated under the Environmental Permitting Regulations. An OMA audit involves interviewing relevant site personnel, viewing appropriate documentation and inspecting the monitoring location(s).

6.14 Who is responsible for the calibration and maintenance of the monitoring units and is this done appropriately?

Hanson Cement is required by their environmental permit to ensure all monitoring equipment is of MCERT standard, where applicable (see 6.12 and 6.13). As such this equipment has to be calibrated and maintained by competent MCERT accredited personnel. This is normally completed by an MCERT accredited contractor.

6.15 Does the Environment Agency consider data gathered by Emissions Watch, particularly for the night time peaks?

Emission Watch is a charity who have deployed atmospheric monitoring equipment at five (initially four) locations approximately one mile away from the Hanson Cement site. Monitoring has been for particulates. Results (unratified raw data) have been posted on the Emission Watch web site and occasionally sent to the Environment Agency. There have been a number of exchanges of correspondence between Emission Watch and the Environment Agency and several meetings including one at the monitoring equipment supplier‟s site to discuss the instrumentation, possible causes of error in readings (in particular the issue of high readings when water vapour is present), calibration and audit of the Emission Watch instruments, locations and data handling. We have offered to make available software for data analysis and help with set up, the offer has yet to be taken up by Emission Watch.


6.16 Had the Environment Agency taken action following this data?

An inspection of the Emission Watch monitoring was carried out by our monitoring specialists in January 2010. The inspection was mainly satisfactory, however, no ratified and analysed information has been received by us from Emission Watch.

6.17 What were the results of the monitoring to detect low level fugitive emissions from the site by the Environment Agency over a summer period (this followed the identification, by CANK, of 14 sites where visible unscheduled emissions occurred)?

As a result of a number of incidents and concerns (some arising from the use of covert CCTV surveillance by the Environment Agency) during the first half of 2007, we served an Enforcement Notice on Castle Cement (now Hanson Cement), Padeswood. Included in the Notice was the requirement to improve monitoring of fugitive dust emissions by appropriate deployment of staff and installation of additional CCTV cameras. Hanson Cement employed temporary staff to monitor for fugitive dust emissions until the additional CCTV cameras were installed and working.


7 General

7.1 Is there a better way to provide the products that Hanson provides?

New cement manufacturing techniques and alternatives to conventional cement are being developed, however, none appear to be at a significant commercially viable stage. See also 7.2 and 7.3 which comment on the Padeswood kiln system standard and comparison with similar cement plants in the UK/Europe.

7.2 Such a process was refused in the USA on the grounds of toxic pollution, if this is true why is it allowed in this country?

In the absence of clear identification of the plant and the process referred to it is only possible to make general comments. The Cement, Lime and Magnesium Oxide Manufacturing Industries BREF [BAT (Best Available Techniques) Reference document] issued by the European Commission in May 2010 commented “Kiln systems with up to five cyclone pre-heater stages and a pre-calciner are considered standard technique for new dry process plants” – this describes the Padeswood kiln system. A schematic of the process is provided in Appendix C. The BREF document also commented that “The European cement industry recovers a substantial amount of waste derived fuels, which replace fossil fuels up to a level of more than 80% in some plants. This enables the cement industry to contribute further to the reduction of greenhouse gas emissions and to the use of fewer natural resources”. In March 2011 Cemex UK‟s South Ferriby cement plant, in North Lincolnshire, was reported as setting a new record by replacing 100% of the fuel used to heat its cement kiln with fuels made from wastes.

7.3 Has any information been gathered or used from other similar comparator plants across the UK / Europe and is there any thing that can be learned in other situations that can be applied here?

The Environment Agency has carried out a statutory permit review of the England and Wales cement sector. A major part of the review was to compare current (at the time of the review) permit requirements with the very latest environmental standards described in the European Commission BREF [BAT (Best Available Techniques) Reference document] – see also 7.2. Subsequent to the review the cement sector permits were varied in 2010 to:


implement decisions following the statutory review;

bring earlier variations into an up-to-date, consolidated permit;

modernise the entire permit to reflect the change in legislation [the Pollution Prevention and Control (England and Wales) Regulations 2000 were replaced in 2008 by a new statutory regime under the Environmental Permitting Regulations 2007 (now the 2010 version)].

The only significant changes to the Padeswood permit were the inclusion for the first time of an ammonia limit on the stack (ammonia is added to reduce nitrogen oxide emissions) and two improvement conditions requiring Hanson Cement to:

assess and produce a report on the environmental impacts of ammonia emissions from the stack;

produce a project plan setting out how releases of particulates from all significant non-kiln sources will be minimised and at least reduced to < 10-20 mg/m3 as a daily average by 30 June 2014 (the current limit for the cement mills is 30 mg/m3 and for the clinker cooler exhaust 50 mg/m3).

As noted in 7.2 the Padeswood kiln system is standard for a new dry process plant.

7.4 How many regulated industries are there within a ten mile radius of Hanson works?

There are 136 sites within a ten mile radius of Hanson Cement that are regulated by the Environment Agency under the Environmental Permitting (England and Wales) Regulations 2010 (as previously covered by Waste Management Licensing Regulations 1994 and Pollution Prevention and Control Regulations). The map below shows the location of these sites breaking them down into installations and waste operations. These are only Environment Agency regulated sites – there will be additional sites regulated by the relevant Local Authority.


7.5 Why has the „What‟s in my back yard‟ website of the Environment Agency been „dumbed down‟ and obfuscated to the point that annual comparisons of emissions of chemicals can no long be made?

The information contained on “What‟s in your backyard” is still available at www.environment-agency.gov.uk. On the home page you will see a section entitled “At home and leisure” in this section click on “What‟s in your back yard”. Select "Go straight to maps" at the top of the page. This page gives a number of options and emissions to air are covered in sections “Air Pollution” and “Industrial Pollution”. Click on one of these options. Enter the postcode for the site (CH7 4HB). If you click on the icon on the map - this will take you to annual emissions data. If you have problems finding the specific information required or using the web page then please contact the Environment Agency with your concerns. Telephone: 08708 506 506 (Mon-Fri, 8am - 6pm) Minicom service: For the hard of hearing a minicom service is also available by calling 08702 422 549 Email: [email protected] (do not use for reporting environmental incidents)

http://www.environment-agency.gov.uk/

mailto:[email protected]


You can also use our enquiry form to request information. Postal address: National Customer Contact Centre PO Box 544 Rotherham S60 1BY Weekday Daytime calls to 0870 numbers cost 8p, plus up to 6p per minute from BT Weekend Unlimited. Mobile and other providers‟ charges may vary.

http://www.environment-agency.gov.uk/contactus/feedback.aspx


Appendices

Appendix A – Monitoring of Waste Activities

Table A1 - Landfill gas monitoring and sampling programme- within waste

Landfill gas monitoring determinands Monitoring Frequencies

Methane Monthly

Carbon Dioxide Monthly

Oxygen Monthly

Temperature Monthly

Differential Pressure Monthly

Atmospheric Pressure Monthly

Table A2 - Landfill gas monitoring and sampling programme- external to site

Landfill gas monitoring determinands Monitoring Frequencies

Methane Monthly

Carbon Dioxide Monthly

Oxygen Monthly

Temperature Monthly

Differential Pressure Monthly

Atmospheric Pressure Monthly

Table A3 - Leachate monitoring and sampling programme

Leachate Monitoring Determinands Frequency

Depth of leachate from the base of the site (reference to Ordnance Datum)

Monthly

pH Monthly

Temperature Monthly

Electrical Conductivity Monthly

Chloride Quarterly

Ammoniacal nitrogen Quarterly

Sulphate Quarterly

Alkalinity Quarterly

Chemical Oxygen Demand Quarterly

Biochemical Oxygen Demand Quarterly

Total Oxidised Nitrogen Quarterly

Total Organic Carbon Quarterly

Aluminium Quarterly

Sodium Quarterly

Potassium Quarterly


Calcium Quarterly

Magnesium Quarterly

Iron Quarterly

Manganese Quarterly

Cadmium Quarterly

Chromium Quarterly

Copper Quarterly

Nickel Quarterly

Lead Quarterly

Zinc Quarterly

Table A4 - Groundwater Monitoring and Sampling Programme

Determinands Monitoring Frequencies

Water level (reference to Ordnance Datum)

Weekly for the first 4 weeks, then monthly (and quarterly)

pH Weekly for the first 4 weeks, then monthly (and quarterly)

Temperature Weekly for the first 4 weeks, then monthly (and quarterly)

Electrical Conductivity Weekly for the first 4 weeks, then monthly (and quarterly)

Dissolved oxygen Weekly for the first 4 weeks, then monthly (and quarterly)

Chlorides Weekly for the first 4 weeks, then monthly (and quarterly)

Ammoniacal Nitrogen Weekly for the first 4 weeks, then monthly (and quarterly)

Sulphates Quarterly

Total Alkalinity (as CaCO3 at pH 4.5) Quarterly

Total oxidised nitrogen Quarterly

Total organic carbon Quarterly

Aluminium Quarterly

Sodium Quarterly

Potassium Quarterly

Calcium Quarterly

Magnesium Quarterly

Iron Quarterly

Manganese Quarterly

Cadmium Quarterly

Chromium Quarterly

Copper Quarterly

Nickel Quarterly

Lead Quarterly

Zinc Quarterly


Table A5 - Surface Water and Monitoring Programme

Determinands Monitoring Frequencies

pH Monthly (and quarterly)

Temperature Monthly (and quarterly)

Electrical Conductivity Monthly (and quarterly)

Dissolved Oxygen Monthly (and quarterly)

Ammoniacal nitrogen Monthly (and quarterly)

Chlorides Monthly (and quarterly)

Chemical Oxygen Demand Monthly (and quarterly)

Sulphates Quarterly

Total alkalinity (as CaCO3 at pH 4.5) Quarterly

Total oxidised nitrogen Quarterly

Total organic carbon Quarterly

Aluminium Quarterly

Sodium Quarterly

Potassium Quarterly

Calcium Quarterly

Magnesium Quarterly

Iron Quarterly

Manganese Quarterly

Cadmium Quarterly

Chromium Quarterly

Copper Quarterly

Nickel Quarterly

Lead Quarterly

Zinc Quarterly


Appendix B – Monitoring of emissions

Table B1 - Emissions to air - kiln

Table S3.1 Kiln Exhaust Emissions to air – emission limits and monitoring requirements

Emission point ref.

Parameter Source Limit (including unit)

Reference period

Monitoring frequency

Monitoring standard or method

A8 Particulate matter

Kiln 4 10 mg/m3 Daily average

Continuous measurement

BS EN 15267-3

A8

VOC as total organic carbon (TOC)



BS EN 15267-3

A8 Hydrogen chloride



BS EN 15267-3

A8 Carbon monoxide



BS EN 15267-3

A8 Sulphur Dioxide



BS EN 15267-3

A8 Oxides of nitrogen



BS EN 15267-3

A8 Ammonia Kiln 4

Limits to be set depending on BAT assessment


BS EN 15267-3

A8 Hydrogen fluoride

Kiln 4 1mg/m3

Periodic over minimum 30 minute, maximum 8 hour period

Bi-annual USEPA Method 26/26A

A8

Cadmium & thallium and their compounds (total)

Kiln 4 0.05 mg/m3


Bi-annual BS EN 14385

A8 Mercury and its compounds

Kiln 4 0.05 mg/m3



A8

Sb, As, Pb, Cr, Co, Cu, Mn, Ni and V and their compounds (total)

Kiln 4 0.5 mg/m3

periodic over minimum 30 minute, maximum 8 hour period




Emission point ref.


Reference period



A8 Zinc and its compounds

Kiln 4 No limit set


Bi-annual

A8

Dioxins / furans (I-TEQ) (Reported as a range. All congeners <LOD assumed to be zero and all congeners >LOD assumed to be at the detection limit as a max.

Kiln 4 0.1 ng/m3

Periodic average value over minimum 6 hours, maximum 8 hour period

Bi-annual BS EN 1948 Parts 1, 2 and 3

A8

Dioxins / furans (WHO-TEQ Humans / Mammals) /((fish)/ (birds)

Kiln 4 No limit set

Periodic average value over sample period of between 6 and 8 hours.

Bi-annual BS EN/TS 1948-4

A8

PCBs [Dioxin-like PCBs (WHO-TEQ Humans / Mammals / fish / birds)]

Kiln 4 No limit set

Periodic measurement average value over sample period of between 6 and 8 hours.

Bi-annual BS EN/TS 1948-4

A8

PAHs Specific individual poly-cyclic aromatic hydrocarbons (PAHs)

Kiln 4 No limit set

Periodic measurement average value over sample period of between 6 and 8 hours.

Bi-annual

Procedure shall use BS ISO 11338-1 and BS-ISO 11338-2.



Emission point ref.


Reference period



A8 Benzene Kiln 4 No limit set


Bi-annual

A8 1,3-Butadiene

Kiln 4 No limit set


Bi-annual

Table B2 - Emissions to air - non-kiln

Table S3.2 Non-kiln point source emissions to air – emission limits and monitoring requirements

Emission point ref.


Reference period




Cement Mill 1

30 mg/m3 Daily average


BS EN 15267-3


Cement Mill 2



BS EN 15267-3


Cement Mill 3



BS EN 15267-3


Cement Mill 4 mill filter



BS EN 15267-3


Cement Mill 4 Classifier



BS EN 15267-3


Kiln 4 cooler exhaust



BS EN 15267-3

A10 No parameter set

MBM storage vessel

No limit set

Permanent sampling access not required

Vents on storage silos and conveyor lines

No parameter set

storage silos and conveyor lines

No limit set


Table B3 - Emissions to surface water and land

Table S3.3 Point Source emissions to water (other than sewer) and land – emission limits and monitoring requirements

Emission point ref.

Parameter Source Limit (incl. unit)

Ref period


W1 on drawing number 401.00-11-0016-P00 emission to tributary of Black Brook

Suspended solids

Site surface water drainage via the settlement lagoon

50 mg/l Weekly spot sample


pH


6 min 9.5max

Instantaneous Continuous

6 min 9.5max

Spot sample Weekly


BOD


10mg/l Spot sample Weekly


Temperature


23oC Instantaneous Continuous

23oC Spot sample Weekly


Flow


No limit set

Instantaneous Continuous


Oil or grease


None visible

Spot Sample Weekly


Table B4 - Emissions to sewer

Table S3.4 Point source emissions to sewer, effluent treatment plant or other transfers off-site– emission limits and monitoring requirements

Emission point ref.

Parameter Source Limit (incl. Unit)

Reference period



S1 on drawing number 401.00-11-0016-P.00

Vehicle wash water via catch pit and oil/water separator

No limit set

Table B5 - Noise

Table S3.5 Noise monitoring requirement

Location or description of point of measurement

Parameter Monitoring frequency


Other specifications

Perimeter survey as detailed in Application section 2.9.

Noise Monthly BS 4142:1997

Table B6 - Ambient monitoring

Table S3.6 Ambient air monitoring requirements

Location or description of point of measurement

Parameter Monitoring frequency


Other specifications

Penyffordd and Penymynydd Bowling Club, Park Crescent, Off Abbots Lane, Penyffordd, NGR SJ 302 612

Particulate matter, sulphur dioxide, & nitrogen dioxide

Continuous

Data collected and ratified according to the guidelines used in the UK Automatic Urban and Rural Network (AURN) and those outlined in Technical Guidance Note LAQM.TG(03)


Appendix C – Cement Manufacturing Process

(IPPC S3.01 Sector Guidance Note EA 2001)


Appendix D – Questions of Community Concern

Question of Community Concern Environment Agency Response Reference

18 6.1

19 3.5

20a 6.2

21 3.9

22 3.10

24 2.2

26 6.6

29 6.7

33b 6.3

33c 6.4

33d 6.5

35 3.11

36 3.6

37 3.7

38a 5.1

38b 5.2

38c 5.3

40 5.4

41 5.5

44 3.3

45 3.3

46 3.4

47 3.8

48a 4.1

48b 4.2

48c 4.3

49 4.8

50 4.4

51 4.5

52 4.6

53 4.7

54 3.1

55 3.2

56 7.1

57 7.2

58 5.6

60a,b,c,d 2.3

61a 2.4

61b 2.5

61c 2.6

62 2.7

63 2.8

64 2.9

66a,b,c 2.1

67 3.12

68a 6.8

68b 6.9

68c 6.10


68e 6.11

68f 6.12

69 6.8, 6.10

70 6.13

71 6.14

72a 6.15

72b 6.16

72c 6.17

73a 7.4

74 7.5

83 7.3

Hanson Cement Investigation: Environment Agency response ......In 2009, Castle Cement Limited was re-branded as Hanson Cement, which is owned by Heidelberg Cement. Should the Environment

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