5 attachment e – emissions · attachment e eli lilly ied licence review q:...

Attachment E Eli Lilly IED Licence Review

Q: 2014/LW14/020/02/Reports/IPPC Attachments_Rev.0.doc Page 70 of 193

5 ATTACHMENT E – EMISSIONS All emission points from the site are outlined in the following section and attachments. The locations are illustrated on Drawings No. 007 (Sheets 1-2) and 008 (Sheets 1-4). Labelling of the emission points have been renamed in this licence application to follow the convention set in the EPA guidance document. 5.1 Attachment E.1. Emissions to Atmosphere Atmospheric emissions from the site can be categorised into:

Boiler emissions Main emissions Minor Emissions Potential emissions

Details on all emissions to atmosphere are provided in Tables E.1(i) to E.1 (iii) in Annex 1 of the Application form. E.1.A Details of all Point Emissions to Atmosphere Details of all point emissions to atmosphere are supplied in Tables E.1.(i) for Boiler Emissions, E.I.(ii) E.1.(iii) for Main Emissions and Table E.1.(iv) for minor emission points in the accompanying IED application form. Tables E1.1 and E1.2 provide summary lists of point emissions to atmosphere. The introduction of IE43 results in two additional minor emission points. However, these are clean air releases and no abatement systems are required. A drawing of all atmospheric emissions points are provided in Attachment E.1 supporting information. Table E1.1: Main Atmospheric Emission Points

Main Emission Point Current label Proposed Label

Boilers 4-1 A1-1

Proposed additional boiler N/A A1-2

Reeco (RTO) 7-1 (a) A2-1

John Zink (KEU) Thermal oxidiser 7-1 (b) A2-2

Thermall thermal oxidiser 7-1 (c) A2-3

Proposed Carbon absorber IE3 A3-24 A2-4

Proposed Carbon absorber IE16 A3-30 A2-5

Proposed CHP unit N/A A2-06 Note 1 – while the Thermall unit has recently been demolished, the emission point will be retained in the licence for a possible replacement unit.

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Table E1.2: Minor Atmospheric Emission Points

Minor Emission Point Current Label Proposed Label

Extract from IE1 warehouse dispensing room IE1-V14 A3-01

Biofilter WWTP ---- A3-02

EF23 Exhaust Fan-IE2 IE02-V1 A3-03






*

EF7A Exhaust Fan-IE28 IE28-V1 A3-31

EF7B Exhaust Fan-IE28 IE28-V2 A3-32

EF7C Exhaust Fan-IE28 IE28-V3 A3-33

EF7D Exhaust Fan-IE28 IE28-V28 A3-34

EF32A Exhaust Fan-IE28 IE28-V29 A3- 35

EF32B Exhaust Fan-IE28 IE28-V30 A3- 36

*

IE42 Combined Process Vent IE42-V251 A3-100

*

IE43 combined process vent (Proposed) ---- A3-125

*

IE43 (Phase 2) combined process vent (Proposed) ---- A3-150 *Numbering system allows for the addition of new emission points in the event of building expansion

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Attachment E.1 Supporting Information

Air Emission Locations Drawing - Drawing 007 Sheets 1 and 2

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ORIGINAL DRAWING SIZE A1 - (841 x 594)

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Use figured dimensions only.on the project for which the document was originally issued.of Fehily Timoney & Company as copyright holder except as agreed for useor stored in any retrieval system of any nature without the written permissionNo part of this document may be reproduced or transmitted in any form

Do not scale. If in doubt - Ask!

Revision History

CONSULTANTS INENGINEERING &ENVIRONMENTALSCIENCES

Date

Rev Origin

(Gemma White)

W: www.fehilytimoney.ie, E: [email protected]

T:+353-21-4964133, F:+353-21-4964464Core House, Pouladuff Rd, Cork, Ireland.

T:+353-1-6583500, F:+353-1-6583501

J5 Plaza, North Park Business Park,North Road, Dublin 11, Ireland

This Drawing was printed toA3-

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Use figured dimensions only. on the project for which the document was originally issued.of Fehily Timoney & Company as copyright holder except as agreed for useor stored in any retrieval system of any nature without the written permissionNo part of this document may be reproduced or transmitted in any form


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IED LICENCE APPLICATIONISSUE FOR

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E.1.B Fugitive and Potential Emissions to Atmosphere Summary details of fugitive and potential emissions are in Table E.1.(v) in the accompanying IED application form. Tables E1.3 summarises the potential emission points to atmosphere. Supporting information is provided after the table. Table E1.3: Potential Atmospheric Emission Points

Potential Emission Point Current label Proposed Label*

IE8 Scrubber 31EF IE08-V1 A4-01

IE8-EF23 IE08-V4 A4-02

IE8-EF5 IE08-V5 A4-03

T13 Rupture Disc-IE8 IE08-V7 A4-04





T7 Hydrogen Vent-IE8 IE08-V24 A4-10

T19 Hydrogen Vent-IE8 IE08-V25 A4-11

T11B Rupture Disc-IE8 IE08-V32 A4-13

T7 Drowning Pot Vent-IE8 IE08-V48 A4-14





T22 Filter Rupture Disc-IE8 IE08-V57 A4-19

BL2 Rupture Line-IE8 IE08-V70 A4-20


T101 Rupture Line-IE8 IE08-V70 A4-22

VP101A/VP101B Rupture Line-IE8 IE08-V70 A4-23

T102/103 Rupture Line-IE8 IE08-V70 A4-24


IE8-EF22 IE08-V70 A4-26

DB2B Rupture Disc-IE8 IE08-V70 A4-27

DB2A Rupture Disc-IE8 IE08-V70 A4-28

DB3 Rupture Line-IE8 IE08-V70 A4-29


T77 Burst Tank Vent-IE8 IE08-V108 A4-31






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Q: 2014/LW14/020/02/Reports/IPPC Attachments_Rev.0.doc 6 of 193






DB6 Rupture Line-IE8 IE08-V133 A4-41


IE8-EF10 IE08-V138 A4-43

IE8-EF6 IE08-V139 A4-44

Ralox Fume Duct A-IE8 IE08-V171 A4-45

Ralox Fume Duct B–IE8 IE08-V172 A4-46

Ralox Fume Duct C-IE8 IE08-V177 A4-47

IE8-EF27 IE08-V193 A4-48

IE8-EF26 IE08-V194 A4-49


Carbon Absorber Bed1 Rupture Line-IE8 IE08-V213 A4-51

Carbon Absorber Bed2 Rupture Line-IE8 IE08-V214 A4-52

Carbon Absorber Exhaust Vent-IE8 IE08-V215 A4-53

FD5 Rupture Disc-IE8 IE08-V218 A4-54



T3B Rupture Disc-IE8 IE08-V228 A4-57

T14 Rupture Disc – IE8 IE08-V83 A4-58

Scrubber 106 VTA IE08-V90 A4-59

T103 Rupture Disc –IE8 IE08-V146 A4-60

*

DB1 Rupture line–IE16LS IE16-V101 A4-71

C1 Rupture line–IE16LS IE16-V102 A4-72

T-86 Rupture line–IE16LS IE16-V103 A4-73


BL1 Rupture line–IE16LS IE16-V115 A4-75

BR-BL1 Vent line–IE16LS IE16-V116 A4-76

Scrubber 99 Exhaust Fan–IE16LS IE16-V121 A4-77

FR5 Rupture line–IE16LS IE16-V136 A4-78

H-5 Rupture line–IE16LS IE16-V137 A4-79


FD-3 Rupture line–IE16LS IE16-V143 A4-81

MFLT-1 Rupture line–IE16LS IE16-V144 A4-82

Exhaust Fan EF7-IE16LS IE16-V126 A4-83

Exhaust Fan EF6-IE16LS IE16-V145 A4-84

Scrubber exhaust fan –IE16LS (Proposed)

---- A4-85

Drum charge booth exhaust-IE16LS ---- A4-86

Exhaust Fan – IE16LS (Proposed) ---- A4-87

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*

SV-51 rupture Disc-IE16SS IE16-V1 A4-101

DEF3 Exhaust Fan-IE16SS IE16-V5 A4-102

DEF4 Exhaust Fan-IE16SS IE16-V6 A4-103

EF1 Exhaust Fan-IE16SS IE16-V7 A4-104

Reeco Duct Burst Disc-IE16SS IE16-V8 A4-105

Jet Mill Exhaust Vent-IE16SS IE16-V10 A4-106

T-54 Vent Line-IE16SS IE16-V15 A4-107

T-56 Rupture Disc-IE16SS IE16-V17 A4-108

Scrubber 51 Exhaust Fan-IE16SS IE16-V18 A4-109

EF2 Exhaust Fan-IE16SS IE16-V19 A4-110

*









Scrubber 1 Exhaust – IE2 ---- A4-129

Scrubber 2 Exhaust – IE2 ---- A4-130

Scrubber 3 Exhaust – IE2 (proposed) ---- A4-131

Exhaust Fan-IE2 (proposed) ---- A4-132




K09 Hydrogenation vent –IE2 IE02-V118 A4-136

Rupture Disc Bay 7 – IE2 IE02-V119 A4-137











VP-2 Vent –IE2 IE02-V130 A4-148

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Hydrog. Reactor Vent (Cond 93A) – IE2 IE02-V148 A4-149

T10 Rupture Disc - IE2 IE02-V131 A4-310

T10 PSV Vent – IE2 IE02-V132 A4-311

Bay 7 Vent Line –IE2 IE02-V138 A4-312

Bay 8 Vent Line – IE2 IE02-V139 A4-313

Dry Process Room Vent – IE2 IE02-V140 A4-314





Hydrogenation Room Vent – IE2 IE02-V145 A4-319

Hydrogenation Room Vent – IE2 IE02-V146 A4-320

Bay 8 Vent Line – IE2 IE02-V147 A4-321

*

Scrubber 31 Exhaust Fan-IE3 IE03-V3 A4-151












RF3 Rupture Disc-IE3 IE03-V74 A4-163




FBD Exhaust Fan-IE3 IE03-87 A4-167

ST-1 Rupture Disc-IE3 IE03-V91 A4-168





ST1 Vent-IE3 IE03-V102 A4-173




SC53 Rupture Disc-IE3 IE03-V119 A4-177



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T33 Vent-IE3 IE03-V122 A4-180

SC53 Vent-IE3 IE03-V123 A4-181




T6A Rupture Disc-IE3 IE03-V137 A4-185

DT32 Vent Line-IE3 IE03-118 A4-186

*

T220 Vent-IE7 IE07-V38 A4-201

T221 Vent-IE7 IE07-V40 A4-202

T222 Vent-IE7 IE07-V42 A4-203

T225 Vent-IE7 IE07-V44 A4-204

T226 Vent-IE7 IE07-V46 A4-205

T227 Vent-IE7 IE07-V48 A4-206

T228 Vent-IE7 IE07-V50 A4-207

T210 Vent-IE7 IE07-V53 A4-208

*

T955 Vent –IE20 IEOY-V8 A4-220


T959 Vent –IE20 IEOY-12 A4-222
























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*

CH-1 Pressure Relief-IE30 IE30-V7 A4-276

CH-2 Pressure Relief-IE30 IE30-V8 A4-277

*

EF-VC30A Exhaust Fan-IE30 IE30-V14 A4-278

Reeco Duct Bypass vent-IE30 IE30-V15 A4-279

T-31 vent-IE30 IE30-V17 A4-280

T-30 vent-IE30 IE30-V18 A4-281

T-29 vent-IE30 IE30-V19 A4-282


T-19 vent-IE30 IE30-V22 A4-284

*

Solid Waste Baler Extract Fan-IE18 ---- A4-301 *Numbering system allows for the addition of new emission points in the event of building expansion Under Condition 6.7 of the facilities existing licence, the licensee shall maintain a programme for the identification and reduction of fugitive emissions. Sources of fugitive emissions onsite include:

RTO duct trips Building ventilation fans Solvent storage tank breathing losses Leaks from valves/pump seals / flanges Spills Emissions from wastewater treatment (e.g. volatile organics).

These fugitive emissions are discussed further below. 5.1.1 RTO Duct Trips Process and scrubber exhausts are ducted from the production buildings and routed to the RTO unit for further treatment/abatement before being discharged to the atmosphere. Within the RTO unit, the airborne VOCs, hydrocarbons and odour causing constituents are converted to carbon dioxide and water vapour. Significant improvements have been made in recent years in maximising the availability of both the RTO Duct System and the RTO unit itself. The following initiatives in addition to other measures have contributed to these improvements:

Various initiatives aimed at reducing the loading of the process emissions venting to the RTO duct system such as:

o Production process mapping to avoid overlapping high emissions steps. o Improved scrubber performance through the use of alternative scrubber solutions and

improved emissions venting control. o Such measures to reduce the potential for the creation of elevated Lower Explosive Limit

(LEL) atmospheres in the RTO ducts. The installation of dual LEL detectors in all production building RTO ducts to provide redundancy in

the event of an LEL detector system fault. Improved reliability of the RTO unit itself through equipment upgrades etc.

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However on occasion due to an equipment malfunction, as a result of process specific issues or for safety reasons (for example the detection of an elevated duct LEL) there remains a risk that the RTO Duct system or the RTO unit itself can become temporarily unavailable. This can in turn result in a short term by-pass of the primary emissions abatement system and results in a direct emission to atmosphere. In the event of such an abatement system by-pass, a response procedure (Ref: KIN-ED-011) has been developed outlining the steps that must be taken in order to minimise the environmental risk resulting from a by-pass event. The particulars of this response procedure have been agreed with the Agency and further details of the procedure are outlined below. In the event of most safety related RTO emissions abatement system by-passes (for example resulting from the detection of elevated RTO duct LEL or due to an LEL detector malfunction), the system will attempt an automated restart sequence, which will typically bring all processes back online to the RTO duct system within 5 to 15 minutes depending on the priority of the production process. If the automated restart sequence is unsuccessful and the system cannot be manually brought back online, the response procedure is implemented in order to minimise the potential environmental risk associated with the by-pass event. For some high priority processes, the most effective aspects of the risk minimisation procedure are implemented immediately. The immediate aim of the response procedure is to bring each production process to a stable hold point as soon as possible (with due consideration for safety and product quality) where the potential emissions are minimised until the primary emissions abatement system is available and full processing can resume. (Note: These hold points have been established and documented for all production processes). The typical emissions minimisation measures completed within the scope of the response procedure include:

Shutting off the Rig Scrubber Fans: When a production rig is offline to the RTO duct, the scrubber fans are typically the main factor influencing the rate at which emissions are vented from the rig. Therefore shutting down the fan (with due consideration for any safety concerns) is found to be particularly effective at minimising emissions during the time taken to bring the process to a stable hold point and/or to bring the emissions abatement system back online. This measure can therefore reduce the emission load from many processes to comparatively low levels relative to the emissions load with the scrubber fan running.

Replenishment of Scrubbers: Fresh scrubber solutions can be made up to maximise the emissions abatement effect of the scrubber.

Unit Operations Suspension: Process steps associated with elevated emissions such as centrifuging, distillation, drying, nitrogen blows, venting or inerting, charging, cleaning and transfers can all be suspended if required.

In addition, a back-up carbon adsorption based emissions abatement system was installed in 2007 and is dedicated to one priority production process. This back-up system is designed to handle the organic exhaust gases from this priority process in the event of a by-pass of the primary abatement system and further details of this system are outlined in section 6.1.1. In line with Agency guidance, in the event of an emission abatement system by-pass, the total daily emission based on actual measurements or established emissions profiles for the various processes must be calculated and documented in the associated incident record. The by-pass incident must be reported to the Agency, if the total calculated emission exceeds the daily TA Luft based reporting thresholds agreed with the Agency. The reporting thresholds agreed with the Agency in 2006 (see letter dated 31st August 2006 in Appendix 1) are: Class I < 0.5 Kgs/day Class II < 10 Kgs/day Class III < 15 Kgs/day An air dispersion model has been prepared for the site, to estimate the maximum emission of a solvent that could be released during an RTO duct trip, which does not breach relevant ambient limit values. This air model incorporates all scrubbers’ onsite and likely solvent emissions from these scrubbers.

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If an RTO event occurs onsite, the nature and extent of the event is recorded. The associated level of investigation and follow-up actions is a function of both the duration and severity of the event. Follow-up actions may include assessment of the emissions relative to atmospheric dispersion modelling in order to determine the potential for environmental significance in line with the Agency Protocol for the Bypass of Air Emissions Abatement Equipment. Environmentally significant bypass events will be reported to the Agency as soon as practicable as per Agency Guidance, while non-significant bypass events will be summarised and reported in the AER or on a frequency agreed with the Agency. 5.1.2 Building Ventilation Fans Building ventilation fans from production facilities could occasionally contain fugitive VOC emissions. Such emissions could occur as a result of a leak from the equipment train within the building from IE3, IE8, IE16, IE30 and IE2 for example. In general fugitive solvents (VOCs) are minimised by charging of solvents into vessels using trapped vacuum on the vessel or hard-piping of solvent addition lines. Any vapour generated is condensed back into the vessel using the tank condenser. Manways are also kept closed as much as practicably possible and low temperature condensers and scrubbers are used, where appropriate. Fugitive emission details are presented in Table E.1 (iv). Solids are charged from tote bags or similar container using an inflatable seal system on the tank manway. This ensures that the neck of the container is dust-tight thereby preventing any dust emissions in the vicinity of the charging area. As a precautionary measure all extracts from areas where solids are handled are fitted with a dust filtration system (HEPA Filter). 5.1.3 Process/Extraction Fans Emissions from process buildings IE42 and IE43 will constitute clean air. 5.1.4 Solvent Storage Tank Breathing Losses Eli Lilly has a number of volatile organic compounds (VOCs) and waste VOC storage tanks onsite. These tanks may occasionally emit VOC vapours as standing losses and working losses due to temperature changes or when the tanks are being filled with solvent. A number of mitigation measures have been installed onsite to minimise fugitive emissions from these tanks for example:

Weighted conservation vents are installed on the atmospheric solvent storage tanks thus minimising breathing losses.

Solvent transfers are carried out using solid piping systems, which are designed to the Lilly Piping Specification. This specification attempts to minimize flanges. Canned pumps are used where possible to minimise seal leaks.

Replacement of all the waste solvent storage tank farm tanks and a selection of the main tank farm solvent storage tanks by a number of new tanks with higher pressure rating thus enabling the pressure relief settings to be increased resulting in less potential for fugitive emissions.

The venting of all production building waste solvent storage tanks to the RTO system to prevent fugitive emissions from these tanks.

Nitrogen blanketing of all solvent storage tanks reduces potential for solvent volatilisation in the tank headspace and reduces tank breathing losses.

5.1.5 Leaks from Valves/Pump Seals/Flanges Although leaks from valves, pumps and flanges can occur, the majority of equipment used on site is typically integrated into a preventative maintenance programme. This ensures that any leaks are prevented from occurring or promptly remedied should they occur. Back up parts are available for most important process components. This ensures that leaks from the above are minimised.

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5.1.6 Spills/Relief Devices The most likely source of spills originates as small leaks at flange connections, pump seals and valves. Also, many pressure relief devices at the site relieve directly to the atmosphere and may therefore be a potential source of an emission in exceptional circumstance. Since pressure relief devices only activate in an emergency or by a failure, these events occur very infrequently. The area affected by solids and the quantity of chemical released, the pressure of the release, and the height of the release limit liquids released from a pressure-relieving device. Given the structures on site, any releases that could potentially happen in exceptional circumstances would be likely to occur at or above a height of approximately 23 meters. Most burst disks on site are rated to operate at the relatively low pressure of 30 psig. If liquids and solids were released from a pressure relief device, gravity would begin to pull the materials to the ground. Production buildings and other areas with pressure relief devices are located toward the centre of the developed area of the plant site and are not adjacent to the property boundaries. Therefore the potential for offsite impacts from such an event is limited. Emergency response procedures are in place to deal with any significant spills or other incidents. See Section J for more details. 5.1.7 Emissions from Wastewater Treatment Fugitive emissions can occur from the aeration tanks in the waste water treatment facility where trace amounts of organic solvents may be blown off due to the stripping action of the plant. Bio-sludge odours can also arise. Volatile emissions, including sludge odours from the wastewater treatment plant are collected and directed to a bio-filter. Therefore, the potential for fugitive emissions to occur is considerably reduced. 5.1.8 Monitoring of Fugitive Emissions A programme is in place for the evaluation of fugitive emissions from both production building air exhaust systems and site bulk solvent and waste solvent storage tanks. Storage tank working and breathing VOC losses are calculated using recognised modelling techniques taking into account both ambient conditions and annual solvent throughput for each vessel. Fugitive VOC losses from production buildings (seal/flange leaks etc.) are calculated by monitoring VOC emissions from the building exhaust fans. Data is compiled into an annual fugitive emission total for each solvent as listed in the table below. A summary of the fugitive emissions for 2013 is outlined below. The calculated fugitive emissions for 2013 represent <0.1% of the total solvent usage at the site over the year.

Parameter /Substance Annual fugitive emission (kg/annum)

TA Luft organic substances class 1 81

TA Luft organic substances class 2 511 TA Luft organic substances class 3 1110

Total 1,702

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5.3 Attachment E.2. Emissions to Surface Water Details on all emissions to surface water are provided in Tables E.2(i) and E.2(ii) in Annex 1 of the Application form. Table E.1.4 outlines the surface water emission points onsite. The locations of the surface water emission points are shown on Drawing 007 Sheets 3 and 4. Table E1.4: Surface Water Emission Points

Main Emission Point Current label Proposed Label

Treated effluent from the facility 6-1 SW1

Wastewater from incineration W2 SW2

Site storm water runoff W3 SW3 A summary list together with the relevant locations on Drawing 007 (Sheets 3 and 4) are provided in combined Attachment E.2/E.4 supporting information 5.4 E.3. Emissions to Sewers There are no emissions to sewer from the facility. This section is not relevant to Eli Lilly’s IED licence application therefore there is no Attachment E.3. 5.5 E.4. Emissions to Ground There are no direct emissions to ground from the facility. This section is not relevant to Eli Lilly’s IED Review therefore there is no Attachment E.4. 5.6 Attachment E.5. Noise Emissions The main sources of noise emissions onsite are detailed in Table E.5 (i) in Annex 1 of the Application form. The application of NG4 to the site noise conditions would introduce an evening time limit of 50dB. The site has shown ongoing compliance with its daytime and night-time limits of 55 and 45 dB(A) and it is likely that the site will meet the evening-time limit therefore an evaluation of existing noise abatement and a programme of improvement are not required as part of this submission. The noise monitoring locations are presented on Drawing 007 Sheets 1 to 4 provided in combined Attachment E.2/E.4 supporting information. 5.7 E.6 Tabular Data on Emission Points Emission point data has been tabulated in the excel format required by the EPA for each emission point and is included on the CD-Rom submitted to the EPA. The table is located in folder ‘Attachment E.6’ on the CD-Rom.

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Attachment E.2./ E.4 Supporting Information

Surface Water and Noise Emission Locations Drawing – Drawing 008 Sheets 1 to 4

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5 attachment e – emissions · attachment e eli lilly ied licence review q:...

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