PERMIT WITH INTRODUCTORY NOTES · 2020-07-21 · Ferrous Foundry Iron castings are manufactured from clean pig iron, steel scrap and reject castings using a two tonne capacity oil

PERMIT WITH INTRODUCTORY NOTES

Local Authority Pollution Prevention and Control Pollution Prevention and Control Act 1999 Environmental Permitting (England & Wales) Regulations 2010

13/03/2017 LAPPC 07

Contact Details at Ashford Borough Council:

Trevor Ford (Chartered Environmental Health Practitioner)

Ashford Borough Council

Environmental Services,

Tannery Lane, Ashford,

Kent, TN23 1PL

Email: [email protected]

Tel: (01233) 330397

Permitted Installation Address:

M J Allen (Holdings) Ltd

Foundries Division of Hilton Road,

Cobbs Wood Industrial Estate,

Ashford, Kent, TN23 1EW.

mailto:[email protected]


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PERMIT WITH INTRODUCTORY NOTES LAPPC07

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PERMIT WITH INTRODUCTORY NOTES L A P P C 0 7

INTRODUCTORY NOTES

These introductory notes do not form part of the Permit

The following Permit is issued under Regulations 12 and 13 of the Environmental Permitting

(England and Wales) Regulations 2010 (henceforth referred to as the EP Regulations)

The Permit includes conditions that have to be complied with. The conditions contained within this

Permit are based upon Guidance Notes;

PG 2/03 (13) Statutory guidance for Electrical Furnaces;

PG 2/04 (13) Statutory guidance Iron, Steel and Non-Ferrous Metal Foundry Processes;

PG 2/05 (13) Statutory guidance for Cold Blast Cupolas and Rotary Furnaces;

PG 2/06 (13) Statutory guidance for Melting Aluminium and its Alloys;

PG 2/08 (13) Statutory guidance for Copper and Copper Alloy Processes;

and is referred to for compliance under the above EP Regulations.

BRIEF DESCRIPTION OF THE INSTALLATION REGULATED BY THIS PERMIT

The process installation is transcribed into the EP Regulations Schedule 1, Section 2.1 Part B (a)

(b) and Section 2.2 Part B (b) of the Environmental Permitting (England and Wales) Regulations

2010

“Best Available Techniques” (BAT), Condition 32 of this permit, includes a requirement for the

permit holder to use the best available techniques for preventing or, where that is not practical,

reducing emissions to air from the installation. Techniques include both the technology used and

the manner in which the installation is designed, constructed, operated, maintained and

decommissioned.


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Further definitions;

Standard Temperature and Pressure (STP)

All pollutant concentrations are expressed at standard temperature (273K) and pressure

(101.3kPa) without correction for water vapour.

Organic Solvent

Any organic liquid (at 293K and 101.3kPa) that is used or acts as a medium for dissolving or

dispersing another substance, as a viscosity adjuster or for cleaning operations.

Abnormal Emissions

Any emissions that are outside the normal range of the installation and include emissions that by-

pass the arrestment plant to avoid an explosion or uncontrolled reaction.

Adjustment of Process Operations

The adjustment may include operating the installation at a reduced level or suspending part or all

of the installation to enable further investigation and/or remedial action.

Odour Masking

Using an overpowering “pleasant” odour to reduce the perception of an offensive odour.

Odour Counter-Actant

Achieving the mutual reduction of two odours by applying a second odour to neutralise the original

odour.

Schedule 5 Pollutants

Any pollutant(s) contained in Schedule 5 of the Pollution Prevention and Control (England and

Wales) Regulations 2000.


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Sticky Board Test

With reference to Condition 9 of this permit the permit holder may adopt the following procedure to

obtain a representative sample of particulates from the arrestment plant:

Adhesive paper (e.g. fablon or similar) measuring at least 150mm x 150mm shall be fixed to

a board with the adherent surface exposed;

The board shall then be exposed to the exhaust air from the arrestment plant for at least 60

seconds;

After close examination the adhesive paper shall be labelled for identification purposes and

stored in a plastic sleeve or similar covering to prevent further contamination.

DESCRIPTION OF INSTALLATION

Iron castings are manufactured from clean pig iron, steel scrap and reject castings using a two

tonne capacity oil fired rotary furnace (with afterburner) producing a maximum of 8 tonnes of grey

iron each day. A 350kg capacity electric furnace is also used to produce a maximum of 10.5

tonnes of malleable iron per week.

PERMIT HOLDER:

CURRENT PERMIT ISSUED:

M J Allen (Holdings) Limited,

Foundries Division of Hilton Road,

Cobbs Wood Industrial Estate,

Ashford, Kent,

TN23 1EW.

13th March 2017


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CONFIDENTIALITY

The Permit requires the Operator to provide information to Ashford Borough Council. Ashford

Borough Council will place the information onto the public registers in accordance with the

requirements of the EP Regulations. If the Operator considers that any information provided is

commercially confidential, it may apply to Ashford Borough Council to have such information

withheld from the register as provided in the Regulations.

To enable Ashford Borough Council to determine whether the information is commercially

confidential, the Operator should clearly identify the information in question and should specify

clear and precise reasons.

VARIATIONS TO THE PERMIT

This Permit may be varied in the future. If at any time the activity or any aspect of the activity

regulated by the following conditions changes such that the conditions no longer reflect the activity

and require alteration, Ashford Borough Council should be contacted. Additionally Ashford Borough

Council may vary the permit in line with alterations to regulations.

SURRENDER OF THE PERMIT

Where an Operator intends to cease the operation of an installation (in whole or in part) Ashford

Borough Council should be informed in writing, such notifications must include the information

specified in Regulation 24 of the EP Regulations.

TRANSFER OF THE PERMIT OR PART OF THE PERMIT

Before the Permit can be wholly or partially transferred to another person, a joint application to

transfer the Permit has to be made by both the existing and proposed holders, in accordance with

Regulation 21 of the EP Regulations. A transfer will be allowed unless Ashford Borough Council

considers that the proposed holder will not be the person who will have control over the operation

of the installation or will not ensure compliance with the conditions of the transferred Permit.


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RESPONSIBILITY UNDER WORKPLACE HEALTH AND SAFETY LEGISLATION

This Permit is given in relation to the requirements of the EP Regulations. It must not be taken to

replace any responsibilities you may have under workplace Health and Safety legislation.

APPEAL AGAINST PERMIT CONDITIONS

There is a right of appeal against permit conditions and Regulation 31 and Schedule 6 of the

Environmental Permitting (England and Wales) Regulations 2010 will apply.

Appeals should be addressed to the Secretary of State for Environment, Food and Rural Affairs at

the following address:

The Planning Inspectorate

Environmental Appeals Administration,

Room 4 / 19 Eagle Wing,

Temple Quay House,

2 The Square,

Temple Quay,

BRISTOL,

BS1 6PN.


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Please Note

An appeal bought under paragraph (1) (c) or (d) in relation to the conditions in a permit will not

suspend the effect of the conditions appealed against; the conditions must still be complied with.

In determining an appeal against one or more conditions, the Act allows the Secretary of State in

addition to quash any of the other conditions not subject to the appeal and to direct Ashford

Borough Council either to vary any of these other conditions or to add new conditions.

Further guidance relating to the procedure for regulating installations and issuing permits is

contained in a manual on the DEFRA website at:

https://www.gov.uk/government/publications/environmental-permitting-general-guidance-manual-on-

policy-and-procedures-for-a2-and-b-installations

END OF INTRODUCTORY NOTES

https://www.gov.uk/government/publications/environmental-permitting-general-guidance-manual-on-policy-and-procedures-for-a2-and-b-installations

https://www.gov.uk/government/publications/environmental-permitting-general-guidance-manual-on-policy-and-procedures-for-a2-and-b-installations


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ASHFORD BOROUGH COUNCIL

POLLUTION PREVENTION AND CONTROL ACT 1999

THE ENVIRONMENTAL PERMITTING (ENGLAND AND WALES) REGULATIONS 2010

Permit Reference No: LAPPC07

MJ ALLEN (Holdings) Limited, Foundries Division of Hilton Road, Cobbs Wood Industrial

Estate, Ashford, Kent, TN23 1EW (registered no. 699347) (the ‘permit holder’) (see attached plan

ref LAPPC07 / P1 [Appendix 1]) is hereby permitted to manufacture aluminium, copper based and

iron castings in a foundry with a maximum production capacity of 20 tonnes per day, within the

boundary marked in orange on the attached plan ref LAPPC07 / P2 [Appendix 2].

Address of permitted installation: Hilton Road

Cobbs Wood Industrial Estate

Ashford

Kent

TN23 1EW

DESCRIPTION OF PERMITTED INSTALLATION

Ferrous Foundry

Iron castings are manufactured from clean pig iron, steel scrap and reject castings using a two

tonne capacity oil fired rotary furnace (with afterburner) producing a maximum of 8 tonnes of grey

iron each day. A 350kg capacity electric furnace is also used to produce a maximum of 10.5

tonnes of malleable iron per week.


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Ancillary foundry operations include the manufacture of sand moulds, sand recovery, fettling,

grinding, shot blasting, paint spraying / coating of metal products and pattern making. These

operations utilise the following plant and equipment:

4 no. Storage silos for new and recovered sand incorporating dry arrestment filters;

1 no. Baldwin and Stanton Tilghman Wheelbrator pressure shot blasting room with a dust

extraction unit incorporating dry arrestment filters;

1 no. Dry attrition sand reclaimer exhausting to an AB Dust Control Ltd dust extraction unit

incorporating type PCC42 reverse pulse jet cartridge filters;

3 no. Fettling booths exhausting to a DCE Series MG Multi-swirl induced spray collector;

1 no. gas fired 300kg bale out furnace;

1 no. 350kg electric induction furnace;

1 no. purpose built paint spray room extracting via a standard RDM NWB5000-1 water wash

booth;

P and J Dust arrestment (PJ1-4-B-H-AS-2.2-3-I) from the circular and band saws in the

pattern making shop

This is a permitted installation by virtue of Regulation 12 and 13 and Schedule 1, Section 2.1

Part B (a) and (b) of the Environmental Permitting (England and Wales) Regulations 2010

Non-Ferrous Foundry

Aluminium and copper based castings are manufactured from clean ingots, runners, risers,

returned castings and machinings using the following plant and equipment:

6 no. 171kg electric resistance bale-out furnaces;

1 no. 1200 lbs electric resistance tilting furnace;

1 no. oil fired pit furnace;

1 no. oil fired tilting furnace;

4 gas fired 300kg resistance bale out furnaces.


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Ancillary foundry operations include the manufacture of sand moulds, sand recovery, fettling,

grinding, shot blasting and oil quenching. These operations utilise the following plant and

equipment:

2 no. Storage silos for new and recovered sand venting to an Airmaster bag filter;

1 no. Storage silo for sand venting to an AB Dust Control Ltd dry arrestment filter unit;

1 no. Dry attrition sand reclaimer exhausting to an Economech dust control unit;

3 no. Fettling bays exhausting via an Airmaster Auto M dust extraction unit;

Shot blasting facilities comprising type 20AS pressure blast machine, abrasive vacuum

recovery unit and type FWB250 dust extraction unit supplied by West London Shotblast

Centre Ltd.

This is a permitted installation by virtue of Regulation 12 and 13 and Schedule 1, Section 2.2

Part B (a) of the Environmental Permitting (England and Wales) Regulations 2010

CONDITIONS

The following conditions shall apply:

Emission Limits and Controls

1. All emissions to air from the permitted installation, other than steam or condensed water

vapour, shall be free from droplets, persistent mist and persistent fume.

2. During normal operating conditions no persistent visible emissions to air shall be emitted

from the building containing the oil fired rotary furnace or from any process vents or

chimney, other than visible emissions permitted by Condition 3.


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3. Emissions to air from the oil fired rotary furnace shall in normal operation be free from

visible emissions, except when lighting up, charging and pouring when emissions shall not

exceed the equivalent of Ringelmann Shade 1 as described in British Standard

BS 2742:2009.

Processing and Process Controls

4. The concentration of particulate matter in the final discharge to air from the chimney serving

the oil fired rotary furnace shall not exceed 100 mg/m3.

5. The concentration of particulate matter in the final discharge to air from the arrestment plant

listed under the description of the permitted installation on page 10, 11 and 12 shall not

exceed 50 mg/m3.

6. The permit holder will be using Processed Fuel Oil (PFO) not exceeding 0.65% m/m sulphur

content. The permit holder will demonstrate compliance with the requirements of this

condition by providing a copy of a certificate of analysis from the supplier of the gas oil. In

the event of a change in the supplier of gas oil the permit holder shall provide a copy of a

certificate of analysis from the new supplier of gas oil within 28 days of the date of change

in supplier.

7. Odour masking agents and counter-actants shall not be used as a method of odour control.

8. Dilution air shall not be introduced to any part of the permitted installation to achieve

compliance with the emission limits specified in Condition 4 and 5.


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Monitoring, Sampling and Measurement of Emissions

9. The permit holder shall monitor emissions to air and carry out tests and inspections of the

process in accordance with the following requirements:

Daily observations of emissions to air from the,

Chimney serving the oil fired rotary furnace in particular, the colour or shade of any

visible emissions during lighting up, charging and pouring;

Electric roof mounted fans providing extract ventilation to the area containing the

furnaces used for melting aluminium and copper in particular, the colour or shade of

any visible emissions during charging and pouring;

Weekly monitoring of emissions to air from the,

Dust extraction unit attached to the Baldwin and Stanton Tilghman Wheelbrator

pressure shot-blasting room;

Extract ventilation to the fettling bays;

Arrestment plant described on page 10, 11 and 12 of this permit

Monthly observations of emissions to air from the,

Arrestment plant attached to each bulk storage silo for new and recovered sand. The

observation shall (as a minimum) coincide with the first and last five minutes of a bulk

delivery of new sand

emission test (every 2 years) for particulates emitted from the,


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Chimney serving the oil fired rotary furnace in accordance with the main procedural

requirements of BS ISO 12141:2002 or BS EN 13284: Part 1 with samples taken during

periods of maximum emission. The sampling equipment shall be capable of collecting

particulate matter of 0.1 microns diameter or less with an efficiency of at least 75%.

Where emission testing is not in accordance with the main procedural requirements of

the relevant standard, any deviations shall be reported together with an estimation of

any error invoked.

10. The permit holder shall advise an authorised person of Ashford Borough Council at least 7

days in advance of any periodic monitoring exercise to demonstrate compliance with the

emission limits specified in Condition 4. The permit holder shall also provide sufficient

details of the proposed monitoring protocol used by any contractor acting on his behalf.

11. On no account shall the permit holder use recovered fuel oil on the rotary furnace without

the express written approval of an authorised person of Ashford Borough Council. Such

use will require the permit holder to apply for an LA-IPPC permit and to comply with the

technical requirements of The Waste Incineration Directive.

12. All monitoring results and inspections undertaken in accordance with Condition 9 shall be

recorded in a logbook kept available for inspection by an authorised person of Ashford

Borough Council on the premises occupied by the permitted installation. The records shall

include the date and time of the monitoring and/or inspection and the name of the person

responsible for undertaking it. Such records shall be maintained for a minimum period of

two years.

The permit holder shall investigate any adverse monitoring results and inspections to

identify the cause and shall implement appropriate corrective action (e.g. repair or replace

arrestment plant and equipment). The permit holder shall ensure that details of the

corrective action are recorded in the logbook.


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13. If the results of any periodic monitoring exercise undertaken in accordance with Condition 9

exceed the emission limit in Condition 4 the permit holder shall advise an authorised person

of Ashford Borough Council. A copy of the results shall be provided within 28 days of the

emission sampling.

If the results of any periodic monitoring exercise are equal to or greater than twice the

emission limit in Condition 4 the permit holder shall immediately notify an authorised person

of Ashford Borough Council by telephone or facsimile.

14. Adequate facilities shall continue to be provided for sampling particulates emitted to air from

the chimney serving the oil fired rotary furnace.

Materials Handling

15. The permit holder shall ensure that transportation and handling of dusty and potentially

dusty materials and/or wastes within the site boundary are undertaken using methods that

will minimise emissions to air.

16. All stocks of dusty and potentially dusty materials and/or wastes shall be stored in such a

manner as to prevent wind whipping (e.g. by containment or covering). The loading of

materials to and from individual stockpiles, charging the oil fired rotary furnace, removal of

ash, dross and slag shall be undertaken using methods that will minimise emissions to air

(e.g. reduced “drop heights”).

17. All new and reclaimed dry sand that is stored outside the process building marked on plan

ref. LAPPC07 / P1 [Appendix 1] shall be contained in purpose built silos, sealed bags or

closed bays. Adequate provision shall be made for containing liquid and solid spillage(s)

and dry sweeping of solid spillage(s) shall not be permitted if it is likely to cause emissions

to air outside the process boundary.


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18. All processes that are likely to cause particulate emissions to air (e.g. casting, “knockout”,

oxyacetylene cutting and burning off casting residues), excluding storage and transfer of

raw materials shall be undertaken in enclosed areas and/or building(s) of suitable design

and construction to minimise emissions to air.

Casting “finishing” processes (e.g. grinding, shot blasting, polishing and arc air cutting) shall

be undertaken in booths or enclosed areas with adequate air extraction or by using

equipment with built in air extraction.

All emissions to air from foundry sand reclamation processes shall be adequately

contained, captured and discharged via suitable and sufficient arrestment plant.

19. Each bulk storage silo provided for new and reclaimed sand shall be vented to suitable and

sufficient arrestment plant to ensure that air displaced during delivery is effectively treated

before it is discharged to atmosphere.

Each bulk storage silo shall be equipped with an audible or visual high-level alarm to warn

the permit holder of overfilling. The correct operation of each alarm shall be examined

regularly having regard to the normal frequency of delivery.

If a pressure relief valve has been fitted to one or more bulk storage silo(s) the permit holder

shall ensure that the seating of the valve(s) is examined at least weekly or immediately

before a delivery, whichever is the longer period.

If a pressure relief valve becomes unseated during a delivery the permit holder shall ensure

that the delivery is suspended until the valve has been examined and re-seated as found

necessary.

The permit holder shall ensure that all tanker drivers are aware of the correct procedure to

be adopted during each delivery to ensure that over pressurisation of a bulk storage silo

does not occur.


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Materials Handling

20. The permit holder shall ensure that the use of resins, hardeners and catalysts during sand

mould and core making is minimised and consistent with the correct functioning of the

binder system.

Emissions to air from organic solvents contained in die and mould dressing materials shall

be minimised (e.g. water borne die lubricants and low solvent mould and core coatings may

be used).

Emissions to air from propanol based mould and core coatings shall be minimised by

igniting as soon as reasonably practicable after application.

21. Gas oil shall be stored in a sealed tank fitted with a high level alarm or volume indicator to warn

the permit holder of overfilling. The tank shall be enclosed by an impervious bund that is

capable of holding 110% of the capacity of the tank. Any air displaced from the tank during

delivery shall be discharged in such a manner as to minimise offensive odour at or beyond the

process boundary.

22. All charge material shall be substantially free from oil, paint and grease. The aluminium and

copper melting furnaces shall only use clean ingots, runners, risers, returned castings and

machinings.

The permit holder shall implement an assessment and selection process to ensure that only

“clean scrap” is melted by the permitted installation. Sufficient evidence shall be provided to

an authorised person of Ashford Borough Council to demonstrate that the necessary

assessment and selection process for identifying “clean scrap” is operating as well as

details of the person(s) who has been trained to use it.

The permit holder shall provide six monthly returns to an authorised person of Ashford

Borough Council to confirm the production capacity of cast ferrous metal in tonnes of

product.


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23. The permit holder shall not use any of the following metal treatment materials;

Hexachloroethane;

Sulphur powder;

Chlorine gas.

The use of grain modifiers, oxidation control materials, fluxes and de-gassing agents shall

be reduced to a minimum that is consistent with good operating practice.

24. Each furnace shall be fitted with adequate temperature controls to minimise the emission of

Schedule 5 pollutants. The melt temperature shall be measured at least once during each

melt and when the potential for fume emission is greatest (e.g. before pouring). A covered

ladle shall be used to minimise emissions of magnesium oxide fume for the 350 kg capacity

electric furnace.

Chimneys, Vents and Process Exhausts

25. Emissions to air from the oil fired rotary furnace shall be discharged to a chimney with a

minimum height of 17 metres above ground. The final outlet of the chimney shall not be

fitted with any restriction (e.g. plate, cap or cowl). Chimney flues and ductwork shall be

adequately insulated to minimise the cooling of waste gases and development of

condensation on internal surfaces.


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General Operations

26. The external surfaces of process building(s), ancillary plant and storage areas shall be

examined at least annually by the permit holder and cleaned in accordance with a schedule

of works approved by an authorised person of Ashford Borough Council. Cleaning methods

shall be adopted that minimise particulate emissions to air (e.g. vacuum sweeping).

27. Any process breakdown or malfunction that is likely to cause abnormal emissions to air shall

be dealt with immediately and operations shall be adjusted until the cause of the process

breakdown or malfunction has been rectified. The cause and corrective action taken by the

permit holder shall be recorded in the logbook provided in accordance with Condition 12. If

the nature of the process breakdown or malfunction is likely to cause any person outside

the process boundary to observe or perceive the abnormal emission, the permit holder shall

inform an authorised person of Ashford Borough Council within one hour of the process

breakdown or malfunction.

28. The permit holder shall provide an authorised person of Ashford Borough Council a list of

key arrestment plant and shall have a written procedure for dealing with its failure, in order

to minimise any adverse emissions to air.

29. The permit holder shall prepare a written maintenance programme for all plant and

equipment directly associated with controlling emissions to air. Essential spares and

consumables shall be held on site or be available at short notice from a supplier in order to

rectify breakdowns rapidly. The permit holder shall record any maintenance undertaken to

the arrestment plant listed under the description of the permitted installation on pages 10,

11 and 12 and retain such records for a minimum period of two years.


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30. The permit holder shall maintain a statement of training requirements for each operational

post and keep a record of training received by each person whose actions may have an

impact on the environment. The permit holder shall make these documents available for

inspection by an authorised person of Ashford Borough Council.

31. If the operator proposes to make a change in operation of the installation, he must, at least

14 days before making the change, notify an Authorised Officer of Ashford Borough

Council, in writing. The notification must contain a description of the proposed change in

operation. It is not necessary to make such a notification if an application to vary this permit

has been made and the application contains a description of the proposed change. In this

condition ‘change in operation’ means a change in the nature or functioning, or an

extension, of the installation, which may have consequences for the environment.

32. The Best Available Techniques (BAT) shall be used to prevent or, where that is not

practicable, reduce emissions from the installation in relation to any aspect of the operation

of the installation which is not regulated by any other condition of this permit.

Signed:

Officer: Trevor Ford

Designation: Chartered Environmental Health Practitioner

Dated: 13/03/2017


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LIST OF APPENDICES

Appendix 1 : LAPPC07 / P1 [Site Location Plan]

Appendix 2 : LAPPC07 / P2 [Site Boundary]


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Appendix 1 : LAPPC07 / P1 [Site Location Plan]


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Appendix 2 : LAPPC07 / P2 [Site Boundary]


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END OF PERMIT

PERMIT WITH INTRODUCTORY NOTES · 2020-07-21 · Ferrous Foundry Iron castings are manufactured from clean pig iron, steel scrap and reject castings using a two tonne capacity oil

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