Ref: FB2-Q3D

Form B2, Question 3D - Summary of Duvelco Limited’s Management System

Duvelco Limited was incorporated on 23rd January 2020. Due to the nature of the work that Duvelco Limited intend to undertake and in line with the requirements of a bespoke environmental permit, the company will develop a written management system. This is a set of procedures which describe what the company does to minimise the risk of pollution from the activities it will undertake.

Company Profile

Duvelco Limited is part of the Goodwin Group. Its parent company is Goodwin PLC and it is one of ten UK subsidiary companies, in a wider global group of 24 companies.

Within the group of companies, we have three UK subsidiaries that are accredited to ISO 14001:2015, with a further two working towards stage 2 of accreditation, which is planned for March 2020. At the company’s disposal, there is 7 QHSE Managers, as well as a HSE group manager. In total, our qualified team members have in excess of 100 years’ experience in environmental matters. The range of environmental management qualifications across our qualified team includes:

 50001 lead auditor;  ESOS lead assessor;  14001 internal and lead auditors;  CIEH environmental management training;  NEBOSH qualifications in a number of disciplines;  Annual legislation update training;  Chartered Institute of water and environmental management training;  Identification of root cause and corrective action training;  Practical management of the environment;  Approach to problem solving.

Our team also has a number of health and safety qualifications that complement this skillset.

We will draw from our group experience to create our management system, which will be in place by the time the company begins any commercial operations, as per permit requirements. Our management team will create a set of procedures which describe what the company will do to minimise the

risk of pollution from the activities which will be covered by the company’s bespoke permit.

The company’s risks have been identified as part of our risk assessment, which has been submitted as part of our permit application. The company’s management system will use this risk assessment as a basis to create its framework.

The company is committed to maintaining a management system which will meet the requirements of ISO14001:2015, as well as other standards and other client specific management systems / processes needed to achieve its long term vision.

Scope of Environmental Management System (EMS)

The company’s scope is as follows:

‘Development and manufacture of high temperature performing polyimide- based polymers for use in highly demanding and critical applications’.

Duvelco Limited is a highly specialised manufacturer, operating in a very narrow market segment of the polymer industry. It is focused on the manufacture and development of the highest temperature performing polyimide based polymers, for highly demanding and critical applications. Polymer resins produced by Duvelco Limited may be supplied as a basic resin for others to mold, or as finished components.

Organisation

The company’s proposed organisation structure related to environmental management can be seen in Figure 1.

Fig 1: Duvelco Limited’s proposed management structure. The success of an environmental management system depends on commitment from all levels and functions of an organisation, led by top management. Top management will effectively address risks and opportunities by integrating environmental management into the company’s business processes.

Roles and Responsibilities

Top Management – responsible for:

 Demonstrating leadership and commitment with respect to the environment management system.  Endorsing the environmental policy;  Ensuring appropriate resource allocation to enable the effective operation and continual improvement of the EMS;  Creation of company strategy;  Supporting relevant management roles.

Environmental Management Representative (EMR) – has the responsibility and authority for:

 Ensuring that EMS requirements are established, implemented and maintained in accordance with ISO 14001, as well as legislation, legal regulations and Local Authority (LA) rules;  Advising top management and the workforce about legal requirements;  Ensuring that sufficient resources are allocated for the proper implementation of the environmental policy and the EMS;  Regularly reviewing the effectiveness of the EMS and ensuring that the necessary changes are made;

 Leading the EMS committee to establish and implement the EMS according to ISO 14001 and monitoring the system’s performance;  Coordinating internal EMS audits to ensure the EMS has been properly implemented and maintained;  Leading and investigating nonconformities and root causes and ensuring corrective and preventive action have been taken to mitigate any impacts that have been caused;  Leading the investigations into accidents, incidents and near misses (AINMS);  Reporting to top management on the performance of the EMS;  Ensuring resources are planned and made available to support the EMS;  Ensuring that employees have the correct resources/training to perform their roles;  Liaising with any external bodies, e.g. the Environmental Agency (EA) and creation of any required reports/information;  Chairing the Environmental committee.

Environmental Management System Committee (EMS Committee) – responsible for:

 Supporting the establishment and implementation of the EMS;  Supporting the review of objectives, targets and initiatives;  Ensuring the effective implementation of environmentally-related operational controls and programmes;  The internal communication of environmental matters between management and employees and promoting environmental awareness amongst staff;  Reviewing of documents and records related to the EMS;  Supporting the EMR in investigating nonconformities and root causes.

Function/departmental manager – responsible for:

 Performing operational controls for the identified significant environmental aspects for his/her function team/department according to procedures and instructions;  Ensuring that the EMS is properly implemented and that environmental matters are properly handled at all stages.

All employees – responsible for:

 Working in accordance with the documented environmental procedures and instructions, specifics responsibilities defined in individual procedures and instructions;  Reporting problems or deviations associated with environmental issues and the EMS to the EMS committee.

Environmental Management System Requirements

The EMS of Duvelco Limited will be developed to manage significant environmental aspects to limit their impacts on the environment. The EMS will be established in accordance with ISO 14001:2015, which we intend to be accredited to within 12 months. Having had experience of implementing ISO 14001:2015 at other group sites in less time, we are confident in this 12 month timescale for accreditation.

The EMS shall consist of a manual, which will outline the activities undertaken by Duvelco Limited. From this, a number of procedures will be created to define the processes of the management system, including operational control. A series of forms, spreadsheets and data collection activities will be used to monitor the performance of the system. Internal audits will be conducted to establish the effectiveness of the company’s processes.

Environmental Management System Documents

The purpose of these EMS documents will be as follows:

Site Infrastructure Plan – A plan of the site is included, which highlights where activities are performed, which are covered by the permit, as well as vulnerable locations, drainage, water, gas and electricity.

Environmental Policy – Describes the intention and principles to be adopted in relation to environmental performance, including but not limited to legal compliance, continual improvements and pollution prevention.

Environmental Management System Manual (EMS Manual) – Describes the environmental management system and outlines how the requirements of the ISO 14001 are achieved.

Objective(s) – The overall environment goals that Duvelco Limited set to achieve.

Target(s) – The set of measurable performance requirements that Duvelco Limited establishes to achieve the objectives.

Environmental Procedures (EPs) – Define the roles, responsibilities and actions to be taken to ensure that activities are performed and the EMS implemented in accordance with the environmental policy and the requirements of ISO 14001.

Register of Environmental Aspects and Impacts – Compiles the environmental aspects that are derived from the activities and services of Duvelco Limited. The register also denotes the significance of the environmental aspects and the respective operational controls for significant environmental aspects.

Register of Legal and Other Requirements – Compiles the legal and other requirements, which include legislation, codes of practice, regulatory and non-regulatory guidelines that are applicable to Duvelco Limited.

Environmental Forms/Records – Record information for the audit trail and the assessment of environmental conditions and performance.

EMS Procedures

Below is a table of Duvelco’s EMS procedures which will be developed by our group’s environmentally-focused management team. We have also listed the applicable clause of ISO14001:2015, which will be covered by the new procedures.

ISO Procedure Document 14001:2015 Type Clause 4.1, 4.2, 4.3, Environmental Manual – context of the organisation, Manual 4.4, 5.1, 6.1.4, needs and expectations of interested parties, scope, 6.2, 7.1, 9.3 environmental management system, leadership and commitment, planning actions, objectives and plans to achieve them, resources, management review 5.2 Environmental Policy Policy 6.1.1 Business Continuity Management inc. contingency Procedure planning – actions to address risk and opportunity 6.1.2 Aspects and Impacts Procedure 6.1.2 Lifecycle (cradle to grave) Procedure 6.1.3 Waste Management Procedure 7.2, 7.3, 5.3 Competency, Training and Awareness (inc. Procedure succession planning, roles and responsibilities) 7.4 Communication and Complaints Procedure 7.5.1, 7.5.2 Control of Documents Procedure 7.5.3 Control of Records Procedure 8 Operational Controls inc. Standard Operating Procedure/ Procedures (SOPs e.g. waste management SOP, SOPs transfer of materials into storage tankers SOP) 8.1 Maintenance Procedure

8.2 Emergency Preparedness and Response inc. site plan Procedure 8.2 Accidents, Incidents and Near Misses Procedure 9.1 Energy inc. water usage (use of, monitoring and Procedure reporting) 9.1.1 Permit Controls Procedure 9.1.2, 6.1.3 Legal and Other Requirements – Evaluation of Procedure Compliance 9.2 Internal Audit Procedure 10.1 Management of Change Procedure 10.2 Nonconformity, Corrective Action and Preventive Procedure Action 10.3 Continual Improvement Procedure

Duvelco Limited’s adopted process for its EMS

Duvelco’s EMS framework will be based around the international standard ISO14001:2015, which uses the plan-do-check-act approach as its model for continual improvement, as can be seen in Figure 2.

Fig 2: Duvelco Limited will use the plan-do-check-act model to develop its management system framework. This model will; ensure environmental issues are systematically identified, controlled and monitored in accordance with Duvelco’s environmental policy, which will be periodically reviewed and updated.

The planning process includes the identification and updating of Duvelco’s register of environmental aspects and the register of legal and other

requirements. Together with Duvelco’s environmental policy, the company’s objectives and targets will be established and appropriate programmes will be formulated to achieve the objectives and targets.

The management system will use ISO14001:2015, as a minimum, to ensure that it complies with legislation, Local Authority (LA) rules and internal procedures/processes. As well as this, additional controls will be implemented above and beyond what is stated in the standard.

ISO14001 is written in line with both ISO9001 and ISO45001 (Annexe A). As such, this system will meet some of the requirements of these international standards, with a long-term view of having an integrated management system.

The EMS will provide top management with information to perform successfully and to contribute to a sustainable system by:

 Protecting the environment by preventing or mitigating adverse environmental impacts;  Mitigating the potential adverse affects of environmental conditions on the organisation;  Giving Develco a method to fulfil compliance obligations;  Controlling and influencing the way products and services are designed, manufactured, distributed, consumed and disposed of, by using a lifecycle perspective that can prevent environmental impacts from being unintentionally shifted elsewhere within the lifecycle;  Achieving financial and operational benefits that can result from implementing environmentally sound alternatives that strengthen the market position of the company;  Communicating relevant information to interested parties.

Duvelco Limited’s standardised procedures will detail the process steps and methods to achieve the above. The procedures will state what we do and our auditing system will check that we do what we say.

We will use the forms, spreadsheets and data collection activities to monitor our objectives, processes and Key Performance Indicators (KPIs), such as energy performance, emission outputs, financial costs and complaints, amongst others.

All process wastes and energy consumed will be minimised by the use of Best Available Techniques (BATs) and, with the continuous improvement culture in the company, should better technology or processes be developed

to further decrease the facilities environmental impact, then their viability will be assessed and implemented where possible.

The EMS will be reviewed annually during management review, as well in line with the requirements of the third party auditor used to assess the company’s ISO 14001 compliance. As well as this, there will be a 12-monthly legislative review to check for compliance. This will be controlled by the company’s annual audit plan.

Ref: FB2-Q4A

Form B2, Question 4A – Sewer managed by a sewerage undertaker.

Duvelco Limited’s sewerage is managed by Severn Trent. There is no process discharge; domestic use only. 652

Timber Yard 1

Duvelco Drawing Reference Number – EPA-Sept-2020: 30.9.2020

65 to 71 to 65

Duvelco Ltd: Installation Boundary 55 to 45 Installation Boundary

1

20 644 2 KELBROOK GROVE

347250 11 Drawbridge 28 2 Caldon Canal

LEEK ROAD WB 21 Tow Path MP

31 N

Foundry 120.5m 347200 LEEK ROAD

131.7m

Works

347150 LEEK ROAD

Smithy LEEK ROAD

347100 686

MELVILLE STREET

13

26 Distance to residental 686

347050

155m

BOTTESLOW STREET

14 672

Issues

2 to 6 to 2 672

29 23 50

12 CRESCENTHOWARD 658 46 93 17 91

347000 7 to 11 Issues

42 2 652

13 Timber Yard 1 11

12

19 29 644

to 5 to 2 23 50

50 LEEK ROAD

2 28

AMBASSADOR ROAD 388989 389039 46 389089 389139 389189 389239 389289 389339 389389 10 0 10 20 30 40 50 Produced on 19 February17 2020 from the Ordnance Survey National Geographic Database and incorporating surveyed revision available at this date. This map shows the area bounded by 388939,346950 388939,347275 389553,347275 389553,346950 Metres Duvelco Drawing Reference Number – EPA-Sept-2020: 30.9.2020 391000E 387000E 388000E 389000E 390000E

A53

349000N

1km radius fromA50 ST1 3NW

348000N

A5006 A5010 A5009

347000N

A50

346000N A52

A500 (T) A50

345000N A5007

c Copyright Reserved

Duvelco Ltd - Planning Site: 1km radius from site

Reproduced from the Explorer® 1:25,000 scale Licence Number 100019512 Duvelco Drawing Reference Number – EPA-Sept-2020: 30.9.2020 Duvelco Ltd - Production Area Plan Negative Pressure Area

Stack Discharge

POST REACTION Reaction Vessels PRODUCT PROCESSING MONOMER 1 MONOMER 2 Carbon Adsorption RAW MATERIALS RAW MATERIALS STORAGE STORAGE

Pre-mixing Vessels Wet Scrubber VACUUM DRYING Dividing Wall

Solvent Storage Area Waste Storage FINISHED GOODS Area AREA

Double Doors between units SOLVENT WC RECLAMATION AREA WC

Roller Shutter Roller Shutter Duvelco Ltd: Site Drainage Duvelco Drawing Reference Number – EPA-Sept-2020: 30.9.2020

N

Attenuation Tank

Attenuation Tank Gas

347100 Governor House

El Sub Sta

Smithy 686

347050 672

TCB

29 23

50 HOWARD 658 CRESCENT 121.7m

17 389239 389289 389339 389389 42

Installation Boundary Site Dirty (Sewer) Water Drainage Main Dirty (Sewer) Water652 Drainage Timber Yard 1 10 0 1110 20 30 40 50 Entrances / Exits Site Clean (Surface) Water Drainage Main Clean (Surface) Water Drainage

Site Dirty (Sewer) Water Drainage Access Main Dirty (Sewer) Water Junction Metres 644 Site Clean (Surface) Water Drainage Access Main Clean (Surface) Water Junction This map shows the area bounded by 388939,346950 388939,347275 389553,347275 389553,346950

LEEK ROAD

SITE CONDITION REPORT TEMPLATE

For full details, see H5 SCR guide for applicants v2.0 4 August 2008

COMPLETE SECTIONS 1-3 AND SUBMIT WITH APPLICATION

DURING THE LIFE OF THE PERMIT: MAINTAIN SECTIONS 4-7

AT SURRENDER: ADD NEW DOC REFERENCE IN 1.0; COMPLETE SECTIONS 8-10; & SUBMIT WITH YOUR SURRENDER APPLICATION.

V2.0 4 August 2008

1.0 SITE DETAILS

Name of the applicant DUVELCO LIMITED

Activity address Unit 1-3, Jubilee Site, Ivy House Road, Stoke- on-Trent, Staffordshire, ST1 3NW National grid reference SJ 89218 47078

Document reference and dates for Site FB2-Q5B Condition Report at permit application and surrender

Document references for site plans (including FB2-Q5B-Maps location and boundaries)

Note: In Part A of the application form you must give us details of the site’s location and provide us with a site plan. We need a detailed site plan (or plans) showing:

 Site location, the area covered by the site condition report, and the location and nature of the activities and/or waste facilities on the site.  Locations of receptors, sources of emissions/releases, and monitoring points.  Site drainage.  Site surfacing.

If this information is not shown on the site plan required by Part A of the application form then you should submit the additional plan or plans with this site condition report.

2.0 Condition of the land at permit issue

Environmental setting including: 1. INTRODUCTION

V2.0 4 August 2008 A comprehensive report “GOODWIN PLC, FORMER EAGLE POTTERY SITE, STOKE ON TRENT,  geology GROUND INVESTIGATION AND RECLAMATI0N STRATEGY, October 2012” was produced by hydrogeology  Messrs Wardell Armstrong LLP, prior to occupation of the site, by Goodwin PLC, the parent  surface waters company of the applicant DUVELCVO. That Report has been used to inform this Baseline Report and direct quotes from it are displayed in italics and indicated by “ …”.

2. THE SITE 2.1 The Site is located as shown on drawing ST12969-003 (attached), immediately south of the Caldon Canal.

2.2 The Site forms part of a larger site, North and South of the Caldon Canal, occupied from the late 1800’s, by the former Eagle Pottery, a ceramic manufacturing unit. The subject area formed a factory refuse tip (landfill). “The landfill is reported to have accepted pottery shraff (earthenware, china, moulds etc.) as well as semi liquid pottery slip. This is generally corroborated by the Envirocheck report, which indicates that the site operated as a landfill from 1910 to 1986 and was authorised to accept pottery and pottery making waste.”

2.3 “The landfill was closed in 1986 and a warehouse was subsequently constructed in the northern part of the site. This warehouse has subsequently been demolished. During the demolition of the pottery works to the north of the canal, demolition rubble, including crushed bricks and concrete, was imported and stockpiled within the current site. A number of these stockpiles have been regraded.

2.4 The Site is surrounded by a mixture of residential, commercial, industrial and derelict sites.

2.5 The near surface materials comprise crushed brick and concrete (essentially sand to cobble size) with numerous pottery fragments and some wood, plastic, metal, glass and tarmac..”

V2.0 4 August 2008 2.6 “The site history has been reviewed with reference to the historical mapping provided in the Envirocheck Report. Table 1 identifies the previous land uses at the Site including any significant potentially contaminative uses and summarises the history of the Site and its immediate vicinity over the period 1879 to 1994.”

“Table 1 Summary of Site History

Date Site Land Use Surrounding Land Use of Significance (Within 250 m Unless Stated 1879 The site consists of fields with an air shaft Directly adjacent to the north of the site is the Caldon located in the centre Canal and beyond this is the pottery works (Eagle Pottery), The area to the north and north west of the Site is generally industrialised including a paper mill, colour mill, flint mills, potteries, reservoirs and a colliery. Ivy house Colliery is located c,100m to the east of the site.

The River Trent is located c.150m south east of the Site orientated nor

the-east-south west. 1900 A refuse tip is recorded to be present in Ivy House Colliery is no longer present and its former area the north east of the Site. The air shaft is is occupied by refuse heaps (presumed to be colliery spoil). marked as being disused (“old coal A large pottery (Trent Works) has been constructed c,200m shaft). to the west of the Site.

Residential properties have partially replaced industrial land use to some extent in the area to the north west of the Site

V2.0 4 August 2008 1924 No significant changes in land use An iron foundry and crate works are present adjacent to the east of the Site. A further crate works is shown c,50m to the south of the Site. Allotments are shown adjacent to the south of the Site 1937 The size of the refuse tip in the north eats Several tanks are marked in the vicinity of the Site, at the of the Site is slightly increased two crate works to the east and south. Allotments to the south of the Site are no longer shown. The colour mill c.100m to the north west has been demolished. 1951-1952 The north and east of the Site are Industrial land use to the south of the Site includes occupied by a sports ground on a raised workshops, garages and additional individual tanks. Two area (which correlates with the former electricity sub stations are present to the south east if the refuse tip location). Aside form the south Site. The foundry to the east has increased in size. A refuse eastern corner (which remains as a refuse tip is present c. 100m north west od=f the Site tip), the remainder of the Site contains allotment gardens. A ditch/stream is marked along the western boundary, sinking at the south east corner of the Site. 1966 No significant change No significant change 1954-1972 1:1250 mapping (1968) indicates that the The crate works to the south has been replaced by a (mapping date allotment gardens have been replaced by garage and sawmills. for land within a refuse tip. The sports ground is also no the site longer shown on thus mapping. However, boundary is in contradiction to this, both the 1968/1969 allotments and sports ground remain in the 1:10,000 mapping 1977-1986 The mapping provides definitive evidence A small tank farm and a warehouse are present directly (1:1250 that the sports ground and the allotment adjacent to the Site. mapping date gardens are no longer present. The Site is for land within occupied by a refuse tip Industrial land use in the area to the south of the Site now the site predominantly consists of warehousing, garages and boundary Is buildings associated with the timber industry. 1980) “ The Site is no longer occupied by a refuse No significant change tip and appears largely derelict. Unidentified features are shown in the north of the Site which may be car parking associated with the warehouse

V2.0 4 August 2008 adjacent to the north. The ditch/stream along the western boundary is no longer shown. 1994 Th warehouse to the north of the Site has No significant change” been extended onto the northern part of the Site. The north of the Site contains unidentified features assumed to be car parking.

2.7 The Envirocheck Report commissioned by Wardell Armstrong (WA) to inform their 2012 Report, referenced above, identified a number of statutory sources (water abstractions, waste sites, permits and industrial land uses. It also identified one tier, COMAH site, Eagle Pottery (since demolished). The information is summarised by WA as follows; “There are several discharge consents in the vicinity of the Site. Predominantly these consents are for the discharge of storm water overflow to surface water by Sever Trent. However, the closest discharge of trade effluent (described by the Envirocheck report as “cooling water”) to the Caldon Canal by Tullis Russell Coaters Ltd (coated paper manufacturers). Due to the industrialised nature if the area surrounding the Site, there are numerous Local Authority Pollution n, Prevention and Control (LAPPC) records within the area. The closest LAPPC record is the Goodwins Foundry c.30m to the east. Other nearby (I.e., within 200m) LAPPC records include a timber yard, ceramics colours manufacturers and fuel stations The Site is recorded to overlie a landfill, as discussed above. There are also numerous other former landfills in the vicinity of the Site. Two of these are located within 250m of the site: Ivy House Foundry landfill located c.100m to the south east (this was licensed to Goodwin Steel Castings Ltd and authorised to accept foundry sand), a large landfill c.150m to the south east (located off Trentmill Road) abut which little information is available from the Envirocheck report (i.e., dates of operation, material types accepted etc.). Additionally, numerous landfills that accepted domestic waste are recorded in the area. 350-800m to the north and north west of the Site.

V2.0 4 August 2008

Mining

2.8 Mining is reported as having taken place beneath the site, an activity which ceased in 1947, with no recent or present mining in the vicinity of the Site.

2.9 One mine shaft was reported by WA within the site area, but which was reported as being subject to cement grouting and capping with a 6m2 “grouted cap”.

Hydrogeology

2.10 The Site is not situated in a Source Protection Zone and there are no groundwater abstractions for potable water within 1Km.

Hydrology

2.11The Caldon Canal is located due north of the site and the River Trent, app 150m to the south.

2.12The site is categorised as Flood Zone category 1 (source Environment Agency) and therefore not considered to be at risk from flooding.

SURFACE WATER 2.13Surface water was sampled from 3 locations (upstream, adjacent and downstream of the Site) on the Caldon Canal in 2005. All samples returned no exceedances of EQS/UKDWS standards for the same suite as was used for groundwater.

V2.0 4 August 2008 GEOLOGY 2.14 Made Ground The site history and published geological information indicate the Site ti be covered by a variable thickness of made ground including recorded landfill areas as indicated in Tables 1 and 2. This made ground is likely to comprise ash, clinker, foundry waste, colliery spoil, pottery shraff and other general non-putrescible waste materials.

2.15Natural Superficial Deposits Glacial Till deposits are recorded to underlie the Site at depths of 2-4 metres, becoming deeper to the south. Such deposits generally comprise firm to stiff clay with boulders, cobbles and gravel form underlying lithologies.

2.16Solid Strata The superficial deposits are underlain by the Upper Coal Measures of carboniferous age. This sequence of strata comprises mudstones and sandstones with numerous coal seams, seatearths and ironstones. Three coal seams are recorded to subcrop within the Site area (Chalkey, Bungilow and New Min

Pollution history including: 3. GROUND CONDITIONS/CONTAMINATION

 pollution incidents that may have affected land 3.1 A series of intrusive site investigations, in 5 stages, was conducted between November 2003  historical land-uses and associated and February 2011, using various combinations of dynamic windowless sampling, cable contaminants  any visual/olfactory evidence of existing percussive boreholes/dynamic sampling, machine excavated trial pits and rotary contamination

V2.0 4 August 2008  evidence of damage to pollution prevention boreholes/rotary cored boreholes. Site investigation points are shown on Wardell Armstrong measures Drawing ST12969-002, attached.

3.2 The results of these investigations were reported on by WA in their 2012 Report, referenced above.

3.3 The purposes of the site investigations were to characterise the site for redevelopment of the site by Goodwin PLC to provide a new factory building, car parking and provision of business units, also with car parking.

3.4 Geotechnical characteristics were investigated comprehensively and reported on by WA but are not reproduced here.

3.5 According to WA reporting, “made ground was encountered in all site investigation boreholes and trial pits drilled/excavated between 2003 and 2005 to depths of 1.60m to 8.80m. The made ground identified by the boreholes incudes a high proportion of clayey pottery waste (most probably pure kaolinite and various materials including bricks, ashy gravel, pottery fragments (e.g. plates) clinker, rock fragments, with occasional wood, plastic and metal.

3.6 A number of stockpiles of demolition materials from the demolition of buildings to the north of the Caldon Canal are reported to have been spread on the Site up to 1.50m in dept. These stockpiles comprised concrete, brick, including tarmac, wood, pottery waste (particularly broken plates), glass, plastic, crushed limestone and rebar.

3.7 “Four boreholes were monitored for groundwater depths, on three occasions in 2005 (BH5, BH6, BH7 and BH8)……..the results are summarised as follows:

V2.0 4 August 2008 Summary of Groundwater Monitoring (2005)

Borehole Depth to Water *Elevation to Water BH5 11.58 to 12.18 119.71 to 120.31 BH6 12.86 to 13.55 118.15 to 118.84 BH7 9.57 to 10.17 120.56 to121.16 BH8 8.16 to 8.56 118.15 to 118.55  Elevation-levels indicated to Ordnance Datum

3.8 Three gas monitoring standpipes installed at the site (BH6, BH7 and BH8) were monitored on two occasions in 2005. BH7 and BH8 were monitored on a further two occasions in July 2005. Additionally, BH5 (located c.30m north of the Site), was monitored on all four occasions. Monitoring involved the measurement of carbon dioxide, methane and oxygen concentrations, together with borehole relative pressure, in accordance with common practice in 2005, flow rate measurement was not undertaken.” 3.9 Methane concentrations up to 0.1%, carbon dioxide up to 5.9% (BH5 north of the Site) and a maximum carbon dioxide concentration, within the site, of 5.4% at BH8.

3.10“32 soil samples were retrieved during the site investigations in 2005 and 29 samples were submitted for analysis for, As, Cd, Cr, Cu, Pb, Hg, Ni, Se, Zn, B, total sulphate, 2:1 soluble sulphate, acid soluble sulphide, phenol, total cyanide, pH and solvent extractable matter (SEM). Table 7 summarises the chemical testing undertaken and the range of results obtained.

Table 7 Summary of Soil Results

V2.0 4 August 2008 Substance Number of Range of Results (mg/kg SGV or GAC Number of samples unless stated) (mg/kg exceedances of SGV/GAC Arsenic 32 <1 – 17 640* 0 Cadmium 32 <1 – 4 230* 0 Chromium 32 <1 – 101 30400** 0 Copper 32 6 – 95 71700** 0 Lead 32 12 – 6175 750* 0 Selenium 32 All <3 13000* 0 Mercury 32 <1 – 2 3600* 0 Phenol 32 <0.1 – 0.43 3200* 0 Nickel 32 2 – 54 1800* 0 Boron 32 <1 – 23 192000** 0 pH 32 6.49 – 8.36 N/A N/A Zinc 32 28 – 840 665000** N/A Sulphide-acid soluble 32 <5 – 726 N/A N/A Solvent Extractable Matter (SEM) 32 58 – 2899 N/A N/A Total Cyanide 32 All <1 N/A N/A Total Sulphur 7 0.03 -6.46 N/A N/A Total Sulphate 32 6.70 – 351100 N/A N/A Water Soluble Sulphate (2:1 32 0.055 – 1.73 g/l N/A N/A extract Calorific Value 1 720mg/kg N/A N/A TPH (C8-C40) 1 110 M/A N/A EPH (DRO) (C10-C40) 2 131 – 172 N/A N/A VOC 1 <0.001 N/A N/A Asbestos Screen 3 No ACM detected in any N/A N/A sample *Soil Guidance Value for Standard commercial use **Chartered Institute of Environmental Health and Land Quality Management Ltd. Generic Assessment Criteria (commercial land use) ACM = Asbestos containing material

3.11Additional leachability testing was conducted on soils in which elevated lead levels had been identified at sample points SA3, WS30, WS33 and BH10. 5 samples were tested having returned

V2.0 4 August 2008 total lead levels of between 352mg/kg and 2836mg/kg. leachable lead was recorded in these samples between 2µg/l and 141µg/l/.

4. GROUNDWATER

4.1 In 2005 the groundwater was sampled from 3 locations BH6, BH7 and BH5. BH5 was located c.30m north of the site but considered relevant to the site because of “similarities in historical land use and geology to the site.”

4.2 The results of groundwater sampling are summarised on Table 11 below taken from the WA Report.

Table 11 Summary of Groundwater Chemical Results

Determinand Unit Range EQS/UKDWS No of Samples No of Exceedances

Hardness mg/l 461-885 N/A 3 N/A Aluminium µg/l All<3 200* 3 0 Antimony All<5 5* 0 Arsenic µg/l <1-1 50* 3 0 Barium µg/l 31-297 1000* 3 0 Boron µg/l 645-21540 2000* 3 1 Cadmium µg/l All<0.4 0.15* 3 0 Calcium µg/l 14830-295400 250000* 3 1 Chromium µg/l 2-5 20* 3 0 Copper µg/l 1-5 10* 3 0 Iron µg/l 42-68 1000* 3 0

Lead µg/l All<1 7.2* 3 0 Magnesium µg/l 21970-35430 50000* 3 0 Manganese µg/l 1077-5395 50* 3 3

V2.0 4 August 2008 Molybdenum µg/l All<1 70*** 3 0 Nickel µg/l 7-32 20** 3 2 Selenium µg/l <1-2 10* 3 0 Tin µg/l All<1 25** 3 0 Vanadium µg/l <1-1 20** 3 0 Zinc µg/l 28-52 75** 3 0 Mercury µg/l All<0.05 0.05** 3 0 COD µg/l <10-415 N/A 3 N/A Electrical Conductivity mS/cm 0.943-1.826 1.5* 3 1 Potassium mg/l 0.9-8.6 12* 3 Sodium mg/l 10.1-31.5 200* 3 Nitrate mg/l 0.8-43.9 50* 3 Nitrite mg/l 0.1-1.55 0.1* 3 2 Sulphate mg/l 62-955 400* 3 1 Chloride mg/l 20-80 250** 3 0 Fluoride mg/l 0.6-0.9 5** 3 0 Phosphate mg/l All<0.08 N/A 3 N/A Sulphide mg/l All<0.05 0.00025* 3 0 Ammoniacal Nitrogen mg/l <0.2-0.3 0.2**** 3 1 Suspended Solids mg/l 29-11255 N/A 3 N/A Phenol mg/l <0.01-0.01 0.03** 3 0 Thiocyanate mg/l All<0.05 N/A 3 N/A Total Cyanide mg/l All<0.05 o.05* 3 0 Free Cyanide mg/l All<0.05 0.001** 3 0 pH pH units 8.07-8.21 N/A 3 0 EPH (DRO) C10-C40 µg/l All<10 10* 3 0

*United Kingdom Drinking Water Standard **Environmental Quality Standard (hardness dependant EQS selected based on hardness results from Caldon Canal ***World Health Organisation (WHO) Guidelines for Drinking Water Quality, 1984 ****Threshold Concentration fir “high” quality in rivers defined in “The River Basin Districts Typology, Standards and Groundwater Threshold Values (Water Framework Directive) (England and Wales) Directions 2010.

V2.0 4 August 2008 SURFACE WATER

4.3 Surface water was sampled from 3 locations (upstream, adjacent and downstream of the Site) on the Caldon Canal in 2005. All samples returned no exceedances of EQS/UKDWS standards for the same suite as was used for groundwater.

CONTAMINATION

4.4 The only contaminant identified from the site investigations, to exceed criteria was lead, which exceeded the Soil Guidance Value of 750mg/kg at six locations (WS1 (6175mg/kg)BH10 (2043mg/kg), BH11 (915mg/kg), TP7 (2975mg/kg), SA3 (1659mg/kg) and WS30 (2836mg/kg).

REMEDIATION

4.5 The Conclusions to the Wardell Armstrong Report if 2012 made the following recommendation; “9.10 In regard to ground contamination and risk to human health the only elevated contaminant which exceeds the assessment criteria is lead at number of locations within the Site area. The proposed development across the majority of the Site comprises buildings and hardstanding (e.g. car parking) which will mitigate the risk to human health. The north eastern corner of the Site however is to be retained as soft landscaping. In addition to elevated lead recorded in the made ground in thus area significantly leachable lead is present at borehole WS30, which presents a risk to controlled waters. Remediation is required in this area comprising the removal of the “hot- spot” of leachable lead contamination (WS30) to landfill and a recommended 450mm cover of clean soils within the soft landscaped area.”

4.6 According to the current site owners that work was undertaken as part of the redevelopment of the site.

V2.0 4 August 2008

POLLUTION PREVENTION MEASURES

5.1 The redevelopment of the site, consequent upon the detailed site investigation and reporting by Wardell, Armstrong, in 2012, included remediation of the “hot spot” areas of lead contamination, identified in the intrusive site investigations conducted at that time.

5.2 The redevelopment itself included the provision of hard surface concrete to the whole area subject to the permit application, with new drainage provision for soil and surface water for the whole of the site. There have been no fugitive or point source discharges to ground water or the single surface water feature (The Caldon Canal), from the site, following redevelopment.

5.3 The permitted Installation activities will be in undertaken in accordance with a comprehensive, accredited management system, entirely within a purpose constructed building, of modern design. All activities will be conducted on sealed concrete surfaces with no discharges to the exterior of the building, other than authorised discharge to public sewer. Storage of all raw materials, solid and liquid and product, will be conducted within the building in bunded tanks and on bunded, palletised storge areas. Spill, prevention and remediation procedures will be deployed.

5.4 Negative air pressure will be maintained in the building with mechanical air extraction via gas cleaning and a single, authorised and monitored, point source emission stack. Detailed records will be maintained of environmental monitoring, process inspections, maintenance, faults and remediation works.

5.5 No pollution risk to ground or aquatic environments are identified by the site risk assessment. The risk assessment and the Accredited Management System of which it forms part, will be subject to regular review throughout the operational life of the Installation and following breakdown/incident and any identified risks will be addressed without delay. Evidence of historic contamination, for example, historical site investigation, assessment,

V2.0 4 August 2008 remediation and verification reports (where SEE ABOVE available)

Baseline soil and groundwater reference data SEE ABOVE

Supporting  Source information identifying environmental setting and pollution incidents information  Historical Ordnance Survey plans  Site reconnaissance  Historical investigation / assessment / remediation / verification reports  Baseline soil and groundwater reference data

3.0 Permitted activities

Permitted activities Section 4.1: Part A(1) - a) viii Description - Plastic Materials e.g. polymers (polyimides)

Section 5.3 Part A(1) - (v) Description - Solvent reclamation and regeneration Non-permitted activities undertaken NIL

Document references for: FB2-Q5A FB2-Q6-Risk Assessment  plan showing activity layout; and  environmental risk assessment.

Note:

In Part B of the application form you must tell us about the activities that you will undertake at the site. You must also give us an environmental risk assessment. This risk assessment must be based on our guidance (Environmental Risk Assessment - EPR H1) or use an equivalent approach.

V2.0 4 August 2008

It is essential that you identify in your environmental risk assessment all the substances used and produced that could pollute the soil or groundwater if there were an accident, or if measures to protect land fail.

These include substances that would be classified as ‘dangerous’ under the Control of Major Accident Hazards (COMAH) regulations and also raw materials, fuels, intermediates, products, wastes and effluents.

If your submitted environmental risk assessment does not adequately address the risks to soil and groundwater we may need to request further information from you or even refuse your permit application.

V2.0 4 August 2008

4.0 Changes to the activity

Have there been any changes to the activity If yes, provide a plan showing the changes to boundary? the activity boundary.

Have there been any changes to the If yes, provide a description of the changes permitted activities? to the permitted activities

Have any ‘dangerous substances’ not If yes, list of them identified in the Application Site Condition Report been used or produced as a result of the permitted activities?

Checklist of  Plan showing any changes to the boundary (where relevant) supporting  Description of the changes to the permitted activities (where relevant) information  List of ‘dangerous substances’ used/produced by the permitted activities that were not identified in the Application Site Condition Report (where relevant)

5.0 Measures taken to protect land

Use records that you collected during the life of the permit to summarise whether pollution prevention measures worked. If you can’t, you need to collect land and/or groundwater data to assess whether the land has deteriorated.

Checklist of  Inspection records and summary of findings of inspections for all pollution supporting prevention measures information  Records of maintenance, repair and replacement of pollution prevention measures

6.0 Pollution incidents that may have had an impact on land, and their remediation

Summarise any pollution incidents that may have damaged the land. Describe how you investigated and remedied each one. If you can’t, you need to collect land and /or groundwater reference data to assess whether the land has deteriorated while you’ve been there.

Checklist of  Records of pollution incidents that may have impacted on land supporting  Records of their investigation and remediation information

7.0 Soil gas and water quality monitoring (where undertaken)

Provide details of any soil gas and/or water monitoring you did. Include a summary of the findings. Say whether it shows that the land deteriorated as a result of the permitted activities. If it did, outline how you investigated and remedied this.

Checklist of  Description of soil gas and/or water monitoring undertaken supporting  Monitoring results (including graphs) information

8.0 Decommissioning and removal of pollution risk

Describe how the site was decommissioned. Demonstrate that all sources of pollution risk have been removed. Describe whether the decommissioning had any impact on the land. Outline how you investigated and remedied this.

Checklist of  Site closure plan supporting  List of potential sources of pollution risk information  Investigation and remediation reports (where relevant)

9.0 Reference data and remediation (where relevant)

Say whether you had to collect land and/or groundwater data. Or say that you didn’t need to because the information from sections 3, 4, 5 and 6 of the Surrender Site Condition Report shows that the land has not deteriorated.

If you did collect land and/or groundwater reference data, summarise what this entailed, and what your data found. Say whether the data shows that the condition of the land has deteriorated, or whether the land at the site is in a “satisfactory state”. If it isn’t, summarise what you did to remedy this. Confirm that the land is now in a “satisfactory state” at surrender.

Checklist of  Land and/or groundwater data collected at application (if collected) supporting  Land and/or groundwater data collected at surrender (where needed) information  Assessment of satisfactory state  Remediation and verification reports (where undertaken)

10.0 Statement of site condition

Using the information from sections 3 to 7, give a statement about the condition of the land at the site. This should confirm that:

 the permitted activities have stopped  decommissioning is complete, and the pollution risk has been removed  the land is in a satisfactory condition.

FB2-Q5B Site Maps

ST12969-001B

KEY 389100E 389200E 389300E 389400E PLANNING APPLICATION BOUNDARY

CITY WATERSIDE DEVELOPMENT LAND

REGRADED AREA

CONCRETE/RUBBLE Drawbridge TREES/DENSE VEGETATION Tank Caldon Canal EXISTING VEGETATION

MP Towing Path EXISTING WALL

130.3 SPOT LEVEL

1m INTERVAL CONTOURS

FENCE

EDGE OF TREE CANOPY

TOP OF BATTER

MANHOLE

SURVEY STATION 347200N BOREHOLE

GATE

IVY HOUSE ROAD

TREE

NOTE: DUE TO THE DENSITY OF VEGETATION ON SOUTHERN BOUNDARY SLOPES THE SURVEY DATA / LEVELS IN THESE AREAS HAVE BEEN MERGED FROM PREVIOUS SURVEYS UNDERTAKEN IN SEPT 2006 BY TOWER SURVEYS LTD AND JULY 2004 BY SITE DATA (SUTTON COLDFIELD) LTD.

Gas Governor 347100N House

GRID AND LEVELS TO NATIONAL GRID El Sub Sta PROJECTION OSTN 02 AND OSGM 02

B Planning Application Boundary Amended. 25/10/12 SJB RDWL RDWL

A First Issue 21/08/12 SJB RDWL RDWL Warehouse

CLIENT Goodwin PLC

PROJECT Site Redevelopment, Eagle Pottery,

Stoke-on-Trent 672 DRAWING TITLE Topographic Survey

TCB DRG No. SCALE DATE ST12969-001 1:500 @ A1 13/07/12 23 DRAWN BY CHECKED BY APPROVED BY JD RDWL RDL

STOKE-ON-TRENT TEL 0845 111 7777 CARDIFF TEL 029 2072 9191

(HEAD OFFICE) LEIGH TEL 01942 260101 121.7m 658 NEWCASTLE UPON TYNE TEL 0191 232 0943 SHEFFIELD TEL 0114 245 6244 HOWARD WEST BROMWICH TEL 0121 580 0909 EDINBURGH TEL 0131 555 3311 CRESCENT 17 LONDON TEL 020 7287 2872 LIVERPOOL TEL 0151 494 5431

347000N Crown Copyright. All Rights Reserved. c Copyright Reserved Licence Number ES 100018275 www.duvelco.com FB2-Q5B Site Maps

ST12969-002

KEY 389100E 389200E 389300E 389400E

PLANNING APPLICATION BOUNDARY

REGRADED AREA

STOCKPILES

Drawbridge TREES/DENSE VEGETATION

EXISTING VEGETATION OF GRASS AND SHRUBS Tank Caldon Canal

1m INTERVAL CONTOURS MP Towing Path 4.0 APPROXIMATE MADE GROUND ISOPACHYTES

FENCE

AS24 WA's "BEST FIT" POSITION OF MINE SHAFT AS14 * COAL SUBCROP (CONJECTURED) 5.0 4.0 2.0 ZONE OF INSTABILITY ASSOCIATED WITH BUNGILOW SEAM AS13 ZONE OF INSTABILITY ASSOCIATED WITH NEW MINE SEAM

WINDOWLESS SAMPLING PROBE HOLE * LOCATION 2003 AS12 WINDOWLESS SAMPLING PROBE HOLE * LOCATION 2004/2005

347200N CABLE PERCUSSIVE BOREHOLE LOCATION 2004

3.0 ROTARY OPEN HOLES 2004

DYNAMIC SAMPLING / ROTARY BOREHOLE 2005

IVY HOUSE ROAD

S STANDPIPE 2005

TRIAL PIT 2005 3.0 AS13 * ASBESTOS SAMPLE LOCATIONS (2005) NONE DETECTED

2011 STOCKPILE SAMPLES 4.0 * DEPTH OF MADE GROUND THICKNESS (m) * 4.0 5.0 4.0 4.0 6.0 DEPTH TO ROCKHEAD (m)

AS17 ROCKHEAD NOT ENCOUNTERED * 7.0 7.0 8.0 * NATURAL DEPOSITS NOT ENCOUNTERED * ELEVATED LEVELS OF CONTAMINATION * * LEAD 5.0 * ARSENIC NICKEL

6.0 AS16 DEPTH OF CONTAMINATION INDICATED RELATIVE TO THE JULY 2005 5.0 SITE SURVEY.

6.0

5.0 2.0 5.0 AS15 4.0 3.0 * 6.0

6.0

NOTES: 7.0 1. DUE TO THE DENSITY OF VEGETATION ON SOUTHERN BOUNDARY SLOPES THE SURVEY DATA / LEVELS IN THESE AREAS HAVE BEEN MERGED FROM PREVIOUS SURVEYS Gas UNDERTAKEN IN SEPT 2006 BY TOWER SURVEYS LTD AND JULY 2004 BY SITE DATA (SUTTON COLDFIELD) LTD. 7.0 DIP OF SOLID STRATA CONJECTURED Governor 347100N 8.0 House 2. GRID AND LEVELS TO NATIONAL GRID PROJECTION OSTN 02 * AND OSGM 02 *

El Sub Sta

D Planning Application Boundary Amended. 30/10/12 SJB RB RDWL

C Asbestos Sample Locations added. 23/08/12 SJB RDWL RB 6.0 Revised Zones of Instability

B Revised Isopachytes 27/07/12 SJB RDL RDL Warehouse

CLIENT Goodwin PLC

PROJECT Site Redevelopment, Eagle Pottery,

Stoke-on-Trent 672 DRAWING TITLE Development Constraints

TCB DRG No. SCALE DATE ST12969-002 1:500 @ A1 23/07/12 23 DRAWN BY CHECKED BY APPROVED BY SJB RDL RDL

STOKE-ON-TRENT TEL 0845 111 7777 CARDIFF TEL 029 2072 9191

(HEAD OFFICE) LEIGH TEL 01942 260101 121.7m 658 NEWCASTLE UPON TYNE TEL 0191 232 0943 SHEFFIELD TEL 0114 245 6244 HOWARD WEST BROMWICH TEL 0121 580 0909 EDINBURGH TEL 0131 555 3311 CRESCENT 17 LONDON TEL 020 7287 2872 LIVERPOOL TEL 0151 494 5431

347000N Crown Copyright. All Rights Reserved. c Copyright Reserved Licence Number ES 100018275 www.duvelco.com FB2-Q5B Site Maps

ST12969-003 391000E 387000E 388000E 389000E 390000E

A53

349000N

A50

348000N

SITE LOCATION

A5006 A5010 A5009

347000N

A50

346000N A52

A500 (T) A50

345000N A5007

Reproduced from the Explorer R 1:25,000 scale. Licence Number 100019512 c Copyright Reserved

CLIENT DRG No. SCALE DATE Goodwin PLC ST12969-003 1:25,000 @ A4 30/07/12

PROJECT DRAWN BY CHECKED BY APPROVED BY Site Redevelopment, Eagle Pottery, Stoke-on-Trent SJB RDL RB

DRAWING TITLE Site Location

www.duvelco.com FB2-Q5B Site Maps

ST12969-005

KEY

PLANNING APPLICATION BOUNDARY 389400E 389100E 389200E 389300E FENCE

GATE

124 APPROXIMATE FINISHED LEVELS (m A.O.D.)

131.5 SURFACE LEVELS 133.0 131.7 131.5 131.5 131.6 TURNING AREA AS PREVIOUSLY 131.6 131.6 WL 131.4 PROPOSED BY REDROW WL 131.3 131.3 131.6 (DETAILS OF VEHICLE SWEPT 131.4 130.4 131.3 PATHS SHOWN IN DESIGN AND 131.4 131.3 131.7 ACCESS STATEMENT) 131.7

131.6 131.5

131.5

131.4 131.5 131.4 131.5 131.5 131.6 CITY WATERSIDE DEVELOPMENT LAND 131.5 131.6 131.6 131.6 131.6 131.6 131.5 131.4 131.5 131.4 131 131.6 131.5 131.5 131.5 131.5 347200N 131.6 131.4 131.4 131.4 131 130.0 131.6 131.5 130.7 130.6 131.5 129.1 131 130.5 131.4 130.6 129.3 128.7 131 130.5 130 128.6 128.7

130.5

IVY HOUSE ROAD

130 129

130.5

130.5 127.2

126.9

129 821

130.5 130.5 125.9 TRAINING SCHOOL TRAINING SCHOOL 125.7 WORKSHOP 721

126 031

130.5 125.1

124.7

124.3

124.0

128

125 124.0

130

127 126

130.5 129 130

125 130.5 127 124 129 130.5 130.5 126

127 130.5 347100N 125 130.5

128 130.5

126 130.5

124

128 GRID AND LEVELS TO NATIONAL GRID 130.5 PROJECTION OSTN 02 AND OSGM 02

130

125 129 C Planning Application Boundary amended. 30/10/12 SJB RDWL RDWL 127

130 126 B Revised Position of Existing 29/08/12 SJB RDWL RDWL 450Ø Public Surface Water Sewer

FOOTPATH

First Issue 22/08/12 SJB RDWL RDWL 124 A

129

CLIENT FOOTPATH 128 Goodwin PLC 127

130 128 125 125 127 123 129 PROJECT 124 126 126 Site Redevelopment, Eagle Pottery, Stoke-on-Trent

DRAWING TITLE 124 Proposed Development Layout and Finished Levels

DRG No. SCALE DATE ST12969-005 1:500 @ A1 21/08/12 DRAWN BY CHECKED BY APPROVED BY SJB RDWL RDL

STOKE-ON-TRENT TEL 0845 111 7777 CARDIFF TEL 029 2072 9191 (HEAD OFFICE) LEIGH TEL 01942 260101

NEWCASTLE UPON TYNE TEL 0191 232 0943 SHEFFIELD TEL 0114 245 6244 WEST BROMWICH TEL 0121 580 0909 EDINBURGH TEL 0131 555 3311 LONDON TEL 020 7287 2872 LIVERPOOL TEL 0151 494 5431

347000N Crown Copyright. All Rights Reserved. c Copyright Reserved Licence Number ES 100018275 www.duvelco.com

Ref FB2-Q5C

Form B2, Question 5C – Provide a non-technical summary of the application

Duvelco Limited is a highly specialised manufacturer, operating in a very narrow market segment of the polymer industry, focusing on manufacture and development of the highest temperature performing polyimide-based polymers, for highly demanding and critical applications. Polymer resins produced by Duvelco may be supplied as a basic resin for others to mold or as-molded and sold as finished components.

The proposed installation is sited at Units 1-3 Jubilee Site, Leek Road, Stoke- on-Trent, ST1 3NW. The site is located in a mixed heavy industrial/residential area, with a predominantly industrial, historical use.

Residential properties are in excess of 150m away from all boundaries. There are no SSSIs, RAMSAR, European or candidate sites within many kilometres of the locality. The site is not in a Source Protection Zone or flood risk area. There are no habitats within influencing distance of the site. The operation will have no effect on human health or any wildlife at the site identified.

It is housed in a purpose-built facility and will carry out the batch manufacture of organic polymer resins for a broad range of applications. The resins are produced by controlled mixing of raw materials within stirred batch reactors of a variety of sizes, under appropriate conditions, to initiate specific reactions. The risk of accidental emission of raw materials, products and waste materials is minimised via plant design and procedures.

The important raw materials used in the installation will be monomers, initiators, organic solvents and filler additives. Directly associated activities include solvent reclamation/recycling, warehousing and storage.

The site will be controlled by a detailed environmental permit, issued by the Environment Agency, which will include specific limits on discharges to all environmental media; water, land and air. However, there will be no actual discharges to water or land from the processes being carried out. All environmental impacts will have been risk assessed and detailed management procedures put in place to protect any identified key receptors to environmental risk. This will be achieved by a comprehensive environmental management system written in line with ISO 14001:2015. It will be kept subject to regular review and external accreditation to a recognised external accreditation body.

All process wastes and energy consumed will be minimised by the use of Best Available Techniques (BATs) and, with the continuous improvement culture in the company, should better technology or processes be developed to further decrease the facilities environmental impact, then their viability will be assessed and implemented where possible.

Ref FB2-Q6

Form B2, Question 6 – Environmental Risk Assessment Summary

Please find our risk assessment included within our documentation (reference FB2-Q6-Risk Assessment-Duvelco Limited).

As well as our risk assessment, we have completed a H1 assessment (reference FB2-Q6-H1 Assessment).

We have also included a risk assessment and method statement for the handling of chemicals, as this could be deemed a high risk activity (reference FB2-Q6-RAMS).

MS01 METHOD STATEMENT Revision 1 Page 1 of 2 Prepared By: T. Stanton Handling of Chemicals

STATEMENT OF ACTIVITY

Solvent handling in and out of the facility.

Removal of chemicals from the delivering vehicle to the storage area via a fork lift truck (containers could be either a 205 litre drum or an IBC).

REQUIREMENT PPE required: • Overalls; • Gloves; • Safety boots; • Hi-Vis jacket/vest; • Hearing protection.

Equipment required: • Method of securing load during transportation; • Fork Lift Truck (FLT); • Drum grab or straps; • Spill kits; • Fire extinguisher. STEP INSTRUCTIONS COMMENT YOU MUST ONLY PERFORM THIS ACTIVITY IF YOU ARE TRAINED AND AUTHORISED TO DO SO 1 Ensure that removal of consignment is performed in liaison and in agreement with the delivery driver at all times. 2 Area to be cordoned off from the general workforce. 3 Check housekeeping. Check the following:  Is the spill kit in good order and complete?  Are drains in a good condition and sealed?  Is the floor in good condition with no cracks/any areas that have the potential to allow fluids to seep in?  Is the closest fire extinguisher in good working order and in date? If you cannot answer ‘yes’ to each question, cease activities and inform a member of management. 4 Delivery vehicle to be positioned in the  Ensure the pre-user check of FLT has been performed best location for ease of removal of  Banksman to be used for positioning of vehicle containers. 5 Condition of consignment to be checked ANY concerns with the condition of delivered goods needs prior to removal. to be brought to the attention of the driver before removal. DO NOT remove any item that may have the potential to spill or leak. 6 Before the consignment is removed, plan Check the following: the route to be taken.  Is the vehicle used in a good working condition?  Have you ensured that there are no obstructions to your journey?  Is the floor is free from holes?  Do you need to travel in reverse (if needed)? 7 Using the FLT, remove the container form Ensure that the load is correctly stowed and secured to the the vehicle. FLT.

MS01 Revision 1

MS01 METHOD STATEMENT Revision 1 Page 2 of 2 Prepared By: T. Stanton Handling of Chemicals

8 Consignment to be located in the  Containers are to be identified with the correct signage. designated storage area.  Stored in secured, sealed containers in the designated storage area.  Check that surfaces are in good condition and free from deterioration.  Ensure drains are suitably sealed. 9 Loading of chemicals from IBCs into  Stainless steel storage tanks used to store chemicals storage, and from storage to process. needed for production.  Tanks to be filled from bottom to top using dip pipe methodology.  Bunded area for tanks, as well as barriers.  Spill kits are located near to the facilities and area is engineered to drain into a sump present in the vicinity of the reactor vessels. Self-contained chemical shower available on site. (See method statement for production). 10 Storage of wast e products .  All hazardous waste stored internally.  Removal of waste by approved contractor.  Waste consignment notes to be retained.  All waste will be stored in appropriate containers. 11 Removal of waste by carrier – follow steps 1 to 7.

MS01 Revision 1

RA Nº - RA001 Risk Assessment: Movement of Chemicals. RA performed by;- Tina Stanton To evaluate risk: HML Likelihood (Lk) x Severity (Sv) = Risk (R.) Defined as High (H), Medium (M) or Low (L) H X H = H - M X M = M - H X M = H - M X L = M - H X L = M - L X L = L Related Regulations:- HSAW Act 1974, MHSWR 1999, COSHH 2002, PPE Regs 1992

Approved Revision Issue Date Issued By Review Due Document Status Approval Signature By Every 2 years or if changes are 1 H & S Dept made to the work scope or activity Initial Risk Residual Risk Injuries/Harm without Persons with Control Hazard/Activity Associated with the Control Current Control Measures Comments/Further Recommendations Affected Measures Hazard/Activity Measures Lk Sv R Lk Sv R This is a general risk assessment intended to cover the main COSHH hazards on site. Please always refer to the individual product Material Safety Data Sheets (MSDS) and corresponding Risk Assessments for full Health & Safety information and Recommended Control Measures. Environmental spill - Contamination of Harm to Containers should be suitable for the chemical Staff trained in relevant procedures Run-off from site ground wildlife and contained in it. Drains are closed off to prevent Emergency preparedness across the ground and odour, nuisance local habitat pollution of water courses. Spill kit to be available in Accidental spills. entering the area. All loads being transferred to be correctly surface water drains HHH stowed and secured to avoid spillage, damage or LHM Product must be stored in a designated or natural loss during transfer (if load is a barrel, a drum grab area and must be indoors. Product is not to channels/ditches is to be used). be stored outside.

Appropriate fire extinuguisher in the area. Identification Mixed chemical fumes All in area All containers must be clearly and correctly labelled, so people are aware of their contents and hazards. All containers must be marked or labelled in a legible MMM LMM and indelible method. The appropriate hazard warning signs for both chemical labelling and packaging to be visible on container. Housekeeping - Contamination of Harm to Spill kit in area. Drains sealed. Floor in good condition of ground ground wildlife and condition with no cracks or areas that have the MMM LMM local habitat, potential to allow fluids to seep in. Fire extinguisher in locaton. Housekeeping audits in place.

1 of 3 Transportation Contamination of Harm to Containers should be suitable for the chemicals ground wildlife and contained. Drains are closed off to prevent pollution local habitat, of water courses. Spill kit to be available in the area. All loads being transferred are to be correctly stowed and secured to avoid spillage, damage or loss during MMM LMM transfer (if load is a barrel, a drum grab is to be used). FLT to be in good working condition.

Vapours: If inhaled can cause User, others in Correct PPE must be worn at all times including: Cases of suspected occupational dermatitis sickness, dizziness and immediate Eye protection: EN166 are referred for a skin assessment. in extreme cases brain area Hand protection: EN374 (Chemical) damage. Some products Respiratory protection: Flammable liquid to be stored in adequate produce vapours which Workwear (Overalls): containers on bunding. can be can be highly EN11612 A1,B1,C1,F1 flammable. MHH EN11611 Class 1 A1 LHM Barrier cream to be used by operative. Fire awareness training, fire extinguishers. Suitable COSHH storage cupboards/areas. Relevant testing carried out by approved professionals on those personnel who are identified as most at risk from exposure. Oils/lubricants Although not generally User Correct PPE to be worn at all times including: classed as harmful, Non-slip safety footwear,Eye protection: some oils can cause EN166 (where necessary / risk of splashing) mild skin sensitisation Hand protection: EN374 (Chemical) with prolonged use. MMM Workwear (Overalls): LMM EN11612 A1,B1,C1,F1 EN11611 Class 1 A1. Barrier cream to be used by operative. Training and awareness. Fire Burns, explosion, All Fire awareness training, fire extinguishers available. suffocation, smoke / Substances to be stored/used in accordance with fume inhalation, injuries manufacturer's guidelines - material safety data up to and including sheets available/COSHH risk assessments. COSHH fatality. MHH storage cupboards/areas. Suitable segregation of LHM hazardous/incompatible substances. Lids to be kept on containers, stock to be kept to a minimum.

Slips trips & falls Cuts, bruises, broken All in area Good Housekeeping, spillages to be cleared up bones. immediately. Correct PPE must be worn at all times: HMH Non-slip safety footwear. LMM

2 of 3 Manual Handling WRULD, strains and Operator Operatives trained in correct manual handling Ongoing refresher training for manual sprains techniques. Correct PPE to be worn at all times: handling Hand protection : EN388 (Mechanical) EN374 MMM (Chemical) EN407 (Thermal) LMM Eye protection : EN166 Safety footwear. General activities Crashing into All Good housekeeping standard. Fully trained Training of inexperienced personnel is to associated with the machinery. Hitting operatives only to operate cranes. All lifting take place under supervision. use of cranes people, Collision with equipment to have SWL and a unique ID number. All adjacent cranes. lifting equipment to have the correct 6 monthly Ongoing refresher training to take place at Mechanical and Lifting inspection colour coding. Correct PPE to be worn at regular intervals determined by company M H H LHM Equipment Failure. all times. policy Injuries due to falling Eye protection : EN166 objects/loads, Hand protection : EN388 (Mechanical) EN374 entrapment and crush (Chemical) injuries. Noisy processes Loss of hearing / short All Noise assessment, health surveillance, correct use of Consideration to mandatory hearing or long term PPE, noise monitors installed around shopfloor. Ear protection zones and use of PPE should be MMM LMM Protection : EN352 enforced.

Collision with other Crushing, entrapment Drivers and all FLT Training and licencing by RTITB Instructor. During a fire drill, no vehicle movements vehicles, plant or etc, Including Fatality. in area. Drivers must have attended and passed either an are permitted and all work in the area to pedestrians. internal or external driver training course. Refresher cease. HHH training will take place at intervals of 2 years. LHM Trained vehicle banksman guide vehicles into loading/unloading areas. Segregation of vehicles/pedestrians considered AFARP. Falls from height Cuts, bruises, sprain, Operator and Safety awareness, trained operators only. Climbing Personnel should never jump from a -vehicle access strains, broken bones. MMM Maintenance to be kept to a minimum. LMM vehicle/trailer bed.

Environmental Fatigue, slips, trips & All in area Regular breaks, hot and cold drinks available, sun During colder weather, vehicle/trailer beds conditions falls, sunburn, heat protect lotion available if required, barrier cream should be adequately defrosted before -Adverse weather stroke, dehydration, and moisturiser available, Correct PPE to be worn at loading. headaches, skin all times including: Safety footwear and high vis MMM LMM chapping - dermatitis, vest/jacket in the despatch yard. chill blains, UV damage to skin/eyes, wind chapping

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Ref FB3-Q3A

Form B3, Question 3A

Please find attached our analysis of EPR 4.01 and EPR 4.02. We have looked at each BAT and have stated how we will comply with each stated BAT. The document reference for you to view this information is FB3-Q3A-EPR4.01 and FB3-Q3A-EPR4.02.

The Schedule 1 Activity being undertaken is:

Section 4.1 Part A(1) a) viii – plastic materials e.g. polymers

Duvelco Limited’s operation for the manufacture of polyimide polymers has an annual production volume of less than 100T.

The activity will be operated on accordance with Best Available Techniques and has been assessed in accordance with:

 How to Comply With Your Permit The Production of Large Volume Organic Chemicals (EPR 4.01)  How to Comply With Your Permit, Additional Guidance for Speciality Organic Chemicals Sector (EPR 4.02)  Best Available Techniques in the production of Polymers 2007

1) Have an EMS (Environmental Management System) fully in line with ISO 14001:2015, with a view to obtaining formal ISO 14001 certification within 12 months.

2) Design the plant to minimise all fugitive emissions and air pollutants; by utilising sound engineering design principals. These will include:

 Closed loop venting back to solvent storage tanks;  Closed loop product sampling systems;  Solvent recycling (to negate thermal destruction);  Bespoke fabricated pipework to minimise flanged connections with effective gaskets;  Magnetically driven or canned pumps, or pumps with double seals and a liquid barrier;  Magnetically driven or canned agitators, or agitators with double seals and a liquid barrier;  LEV vented through a wet scrubber (BAT) or a cryogenic vapour trap and a wet scrubber (BAT).

3) Carry out a fugitive loss assessment and measurement to classify components in terms of type, service and process conditions to identify those elements with the highest potential for fugitive loss.

This will be done by way of a PFMEA (product mode failure effect analysis) on the plant to identify and score each element. This will be incorporated into the business risk register and equipment monitoring and maintenance plan.

4) Operationally, we will use minimise plant start-ups and stops to avoid peak emissions and reduce overall consumption which will be monitored and reported on annually in terms of kW/T of polymer produced.

5) Design the process which will allow us to secure the contents of the reactor in the case of a power failure or an emergency stop being activated. In either eventuality, Duvelco would recycle any in-process material.

6) Utilise closed loop, indirect process heating and chilling, thereby preventing the possibility of water pollution by design.

7) No wastewater or contaminated process effluent water will be discharged by the production activities at Duvelco

8) Comply with the BAT for polyimide production, which is to treat gases from polyimide production by wet scrubbing

As well as the above, whilst not yet law, we have assessed the BAT-AELs in the draft BREF for Common Waste Gas Treatment in the Chemical Sector. We will ensure that our processes will meet the new incoming requirements for the chemicals sector.

The chemical reaction occurring during the polymerization process is as per the below schematic:

EPR 4.01 BAT Compliance

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1.1 Environmental Performance Indicators

Indicative BAT You should, where appropriate: 1. Monitor and benchmark your environmental performance, and review this at least once a year. Your plans for minimising environmental impacts should be incorporated into ongoing Improvement Programmes. Indicators can be derived using the Horizontal Guidance Note H1 Environmental Risk Assessment (see GTBR Annex 1). It is suggested that indicators are based on tonnes of organics produced (tOP) as they provide a good basis for measuring performance within an installation or a single company year on year.

1.2 Accident Management In addition to the guidance in Getting the Basics Right , guidance prepared in support of the COMAH Regulations may help you in considering ways to reduce the risks and consequences of accidents, whether or not they are covered by the COMAH regime. Guidance is available on the Health and Safety Executive website as well as the Environment Agency website.

HOW WE WILL ACHIEVE

Duvelco Answer Following plant commissioning and commencement of production, emission benchmarking will be derived and set against which environmental performance will be measured. This will involve the benchmarking of the single planned emission and waste produced. This will be incorporated into the company’s the Environmental Management System (EMS), which is written around the framework of ISO 14001:2015. This will mandate regular reviews of the environmental performance and the ongoing appropriateness of the measures deployed. A minimum frequency of at least once per year will be set.

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Indicative BAT You should, where appropriate: 1. Assess the environmental impact of each process and choose the one with the lowest environmental impact. (However, we recognise that your choice may be constrained, for example, by the integration of processes on a complex site).

1.3 Energy Efficiency Some large processes are major users of heat and power and others produce energy from their exothermic reactions. For these there may be greater opportunities for optimising energy efficiency in comparison to the smaller installations in the sector and to many other industrial sectors. The integrated sites have the greatest scope for energy integration in the sector but there is a practical limit to the complexity of highly integrated systems which can be effectively operated. Knock-on difficulties can occur during sequential start up and during major upsets so the absolute maximum of process integration may not always produce the best environmental performance in practice.

HOW WE WILL ACHIEVE

Duvelco Answer When looking at energy efficiency of the processes, the chemical reactions utilised in the Duvelco process are fundamental to the operation and produce no harvestable energy. They are and done by batch in a reactor, which by experimentation has determined that the reactors have to be controlled precisely with indirect heating and cooling circuits. All electrical drives on equipment where possible will be inverter speed controlled to minimise the absorbed energy used for the different processes by optimising motor to run at the slowest speed that still deliveries the desired process outcome.

By utilising high quality, high purity feedstock for all the processes, residuals and waste will be minimised, thus lowering the environmental impact.

The additional process that utilise significant energy other than the chemical reaction processing is that of solvent recycling and vacuum drying, the environmental impact of solvent recycling is preferable to solvent disposal and vacuum drying is necessitated by way of health and safety process risk reduction. This process also minimises emissions.

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1.4 Efficient use of raw materials and water As a general principle, you need to demonstrate the measures you take to: • reduce your use of all raw materials and intermediates • substitute less harmful materials, or those which can be more readily abated and when abated lead to substances that are more readily dealt with • understand the fate of by-products and contaminants and their environmental impact.

In the chemical sectors raw material selection is usually fixed by the chemistry and chemical engineering design of the process. There may be several different processes that can be used to manufacture a particular product but these may differ in product yield, in the wastes that they generate and in the potential for environmental harm of their raw materials.

The purity of raw materials will often affect yields and the presence of impurities may result in the need for excessive recycle and/or recovery operations with consequent higher energy consumption. The use of high purity raw materials will generally minimise the environmental impact of that process but may have other adverse consequences, e.g. the use of oxygen rather than air may have benefits in reduced emissions to air but these have to be weighed against the energy requirements for air separation, as well as any cost implications.

Water is used widely for cooling, for process use and for cleaning. A recirculating system with indirect heat exchangers and a cooling tower is preferable to a once-through system for cooling purposes.

This avoids most of the heat transfer to the aquatic environment and reduces the risk of undetected contamination. It is also likely to reduce the quantity of treatment chemicals needed. However, you are likely to need a water make-up treatment plant and there will be a concentrated purge stream from the system. You can sometimes use air cooling in place of water but the fans needed use energy and may be noisy.

Water may be used in direct contact with process materials for either scrubbing or quench cooling. In most cases you can recirculate the water after stripping out the absorbed substances. You will normally need a purge stream to avoid the build-up of contaminants and to remove water that is produced in the process. This will need treatment before discharge (although in some cases it may be used in another process).

Water used for cleaning can be reduced by a number of techniques, e.g. by using dry methods where possible and spray cleaning rather than whole vessel filling. Water should be reused wherever possible and a hierarchy of sources and opportunities for reuse may be established using pinch analysis.

Indicative BAT You should where appropriate: 1. Maximise heat transfer between process streams where water is needed for cooling. Use a recirculating system with indirect heat exchangers and a cooling tower in preference to a once-through cooling system. 2. Where water is used in direct contact with process materials, recirculate the water after stripping out the absorbed substances. 3. Use cleaning techniques that reduce the quantity of water needed. 4. Establish opportunities for reuse using pinch analysis.

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HOW WE WILL ACHIEVE

Duvelco Answer The chemicals used are fixed by the chemical engineering design of the process, and we do not have knowledge of any other manufacturing route to produce the niche polyimide polymer that Duvelco will manufacture without a significant deterioration in the final material properties.

Water will be used for cooling and heating of the process via a closed loop indirect system. The system will be electrically heated and use forced air convection and/or a refrigerant chiller with a heat exchanger dependant upon the external air temperature for cooling.

Water will not be used for cleaning in the process; recycled solvents will be utilised for cleaning equipment after which they will be re-processed for re use again.

Due to the small batch nature of Duvelco Ltd’s operation a Pinch Analysis to look at a fully integrated system for heat recovery would not be feasible as it would be for the production of large volumes of organic chemicals. The permit applied for is less than 100t per annum of polymer production, with the likely output being just a few tonnes in the first year of production, with no way of re-utilising any process heat due to isolated batches being made in a non continuous production.

Water is not a raw material to the process.

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1.5 Avoidance, recovery and disposal of wastes Waste should be recovered unless it is technically or economically impractical to do so.

You should list in detail the nature and source of the waste from each activity as the response to the emissions inventory requirement of the Application. Where there are a very large number of relatively small streams it may be appropriate to aggregate similar and comparatively insignificant waste streams.

Indicative BAT You should, where appropriate: 1. Demonstrate that the chosen routes for recovery or disposal represent the best environmental option. Consider avenues for recycling back into the process or reworking for another process wherever possible. 2. Where you cannot avoid disposing of waste, provide a detailed assessment identifying the best environmental options for waste disposal.

HOW WE WILL ACHIEVE

Duvelco Answer Duvelco Ltd’s process chemically produces water as part of the reaction process. All the VOC solvents used in the processing will be dehydrated and recycled, leaving the produced water contaminated with a small percentage of VOC solvent used that cannot be reclaimed. This minimal waste stream from the production cannot be reduced further as all practical and economically viable recovery has been incorporated into the process from the onset.

This will be kept under constant review against the overall objective of greater recovery of the solvent stream where this can be shown to be economically / technically feasible.

The contaminated chemically produced waste water will be stored as hazardous waste in a bunded area. It will be removed via a registered contractor with a consignment note to a registered hazardous waste disposal facility.

Any out of specification product will be blended over time with higher performing product to make lower grade variants.

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2.1 Design of a new process During new project development, environmental issues should be an integral part of discussion at every stage of the design, beginning with the initial concepts. At the initial stage of the development of the process there should be a formal and comprehensive study - the first stage in a formal HAZOP study - of the likely environmental consequences from: • the use of all raw materials, and production of all intermediates and products • all routine emissions, discharges and solid/liquid waste streams and • non-routine or unplanned releases and disposals from, for example: – start-ups and shutdowns – off-specification products – spillages and – pressure relief.

You should plan to measure, control and record the quantity and quality of every emission, discharge and waste stream from the process. This includes releases generated from non-routine cleaning or maintenance operations. You should consider all realistic options for minimising pollution from the outset, and where end-of- pipe techniques are proposed, the costs of abatement, waste treatment and waste disposal should be formally compared with alternatives for waste minimisation at source. The whole study should use formal HAZOP techniques, and the quality and effectiveness of the study will depend upon the calibre and the commitment of the members of the team involved - which should include process engineers, design engineers, operational staff (including those who operate shared facilities like waste-water treatment plants, etc) and it is vital that environmental specialists are also members of the team.

A key purpose of the first part of the HAZOP study is the production of a preliminary environmental statement for the proposed operation, and this should cover the following points: • Identification and characterisation. This should identify all potential releases. • Segregation of all releases. This allows measurement and diagnosis; it also retains the flexibility to pursue recovery, recycling and other waste minimisation opportunities. • Treatment of waste streams at source. Most segregated waste streams are more concentrated, of lower volume, and less complex mixtures than combined flows so separate treatment should be considered. • Containment of spills. It is important to ensure that all potential spillages are contained, the potential for recovery considered and, where this is not feasible, suitable disposal routes developed. • Fugitive emissions. Specification of equipment should take into account the likelihood of fugitive emissions, and the positions of piping and of vessels should allow rapid detection and rectification of leaks. • Provision for effluent flow equalisation and for emergency discharges. If effluent treatment is on-site the installation must be capable of dealing with fluctuations in flow, composition and concentration, which usually means the provision of holding and balancing tanks. • Emergency effluent storage may be required to cope with unusual events such as fire-fighting water. • Abatement system reliability. If, in the event of primary system failure, the process cannot be stopped quickly enough to prevent an emission then strong consideration should be given to the provision of a secondary backup system.

Indicative BAT You should, where appropriate: 1. Consider all potential environmental impacts from the outset in any new project for manufacturing chemicals. 2. Undertake the appropriate stages of a formal HAZOP study as the project progresses through the process design and plant design phases. The HAZOP studies should consider amongst other things the points noted above. www.duvelco.com Page 6 Registered Office: Ivy House Foundry, Hanley, Stoke-on-Trent, ST1 3NR - Registered in England No. 12422228 EPR 4.01 BAT Compliance

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HOW WE WILL ACHIEVE

Duvelco Answer A risk assessment has been performed to identify all potential emissions and environmental impacts from raw materials, the process itself and waste mangement activities. All identified risks will be mitigated in the design of the plant itself and process and management systems. This will be embodied within the environmental management system for the site. Refer to formal environmental risk assessment (FB2-Q6).

The initial process design, although constrained by chemistry and the nature of the process itself, has been informed by the outcomes of the formal risk assessment from which the pilot plant design will be produced. Operation of the pilot plant will itself follow and inform the process more formalised HAZAOP-type studies. Outcomes of which will be used in the scale up process to commercial plant commissioning and operation. This is an iterative process which will be continued throughout these various stages. A cross-functional team will particpate in this ongoing process.

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2.2 Storage and handling of raw materials, products and wastes The design of storage facilities depends upon the properties of the raw materials, products and wastes that are being stored. This includes their toxicity, environmental persistence and flammability. Storage areas are subject to the same risks as the main processing areas: overpressure, leakage, equipment failure and fire. However the material inventories are generally greater and the level of surveillance is generally lower.

Additional guidance on the storage of chemicals is provided in the “Emissions from Storage” BREF (see Reference 3).

Indicative BAT You should, where appropriate: 1. Store reactive chemicals in such a way that they remain stable, such as under a steady gas stream, for example. If chemical additions are necessary then tests should be carried out to ensure the required chemical composition is maintained. Inhibitors may also be added to prevent reactions. 2. Vent storage tanks to a safe location. 3. Use measures to reduce the risk of contamination from large storage tanks. In addition to sealed bunds, use double-walled tanks and leak detection channels. 4. Use HAZOP studies to identify risks to the environment for all operations involving the storage and handling of chemicals and wastes. Where the risks are identified as significant, plans and timetables for improvements should be in place.

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HOW WE WILL ACHIEVE

Duvelco Answer The monimer raw materials that are reacted to manufacture the Polyimide Polymer at Duvelco Ltd are crystallised solids and are not classed as a flammable hazards. They will be palletized in separate areas in a restricted access area in part of the permitted activity area. There is no risk to watercourses or aquatic toxicity as the permitted area is not in a flood zone. They are inherently stable individually, with inhalable dust and manual handling presenting the biggest risks which are covered by training and risk assessments during the normal course of business. The whole processing area will be held at a negative pressure during operational hours preventing the escape of any dust without it going through the abatement plant.

All Solvents utilised in the processing are Category 2 flammable, presenting a bigger fire risk as well as giving rise to VOC fugitive emission possibilities. Solvents will be stored in enclosed corrosion resistant stainless steel (304 or 316 grade) self bunded storage tanks (110% individual bund volume). The storage tanks will be filled with dip pipes to reduce excessive splashing and vapour generation, the vents of all storage tanks will be into the facility exhaust abatement system.

The storage tanks will be located inside the factory and have barrier protection to prevent the possibility of impact.

The initial process design, although constrained by chemistry and the nature of the process itself, has been informed by the outcomes of the formal risk assessment from which the pilot plant design will be produced. Operation of the pilot plant will itself follow and inform the process more formalised HAZAOP-type studies. Outcomes of which will be used in the scale up process to commercial plant commissioning and operation. This is an iterative process which will be continued throughout these various stages. A cross-functional team will participate in this ongoing process.

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2.3 Plant systems and equipment A wide range of ancillary equipment is required throughout the process, which may include: ventilation, pressure relief, vacuum raising, pumps, compressors, agitators, valves, purging and heating/cooling. Some of these systems give rise to a waste stream, e.g. wet vacuum systems or dust extraction equipment, and all of them have the potential to give rise to fugitive emissions. You should formally consider potential emissions from plant systems and equipment such as: • the concentration, mass-flow and impact of the substances vented to atmosphere • the potential for contamination by extract air of rain-water run-off from the roof • whether the ventilation system should be fed to an abatement unit • noise levels and adequate silencing arrangements.

Valve leakage performance is significant in minimising fugitive losses and should be a major factor in valve selection. The duties and conditions in each vessel and section of piping should be considered in a systematic HAZOP study to identify and quantify significant risks to the environment from the valves chosen for those parts of the plant activity in question.

Indicative BAT You should, where appropriate: 1. Formally consider potential emissions from plant systems and equipment and have plans and timetables for improvements, where the potential for substance or noise pollution from plant systems and equipment has been identified. 2. Carry out systematic HAZOP studies on all plant systems and equipment to identify and quantify risks to the environment. 3. Choose vacuum systems that are designed for the load and keep them well maintained. Install sufficient instrumentation to detect reduced performance and to warn that remedial action should be taken.

HOW WE WILL ACHIEVE

Duvelco Answer In plant design and the subsequent selection and procurement of all equipment used in the processing, all forseeable steps will be taken to minimise fugitive emissions from VOCs and particulates that are used and generated in the processes ar Duvelco Ltd.

For in-process emissons that cannot be reasonably contained within the process (tank breathers; displaced gasses in vessels, exhausts from vacuum pumps etc.) they will be processed and minimised through the main building extraction system and directed to the abatement plant. The abatement plant will, amongst other things, be sized based on the vapour pressures of the solvents, the volumes of gas to be displaced based on the full production capability of the permit.

HAZOP studies are being conducted as part of the design, these will be reviewed at key stages throuout the process in order to validate the origional study and then modify as appropriate where indicated.

Vacuum systems will be specifically designed for the required satages of the process and solvent recovery fully instrumented to alarm to reduced performance standards and instigate approproate remedial actions.

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Over-pressure protection systems Most pressurised vessels will use relief valves or bursting discs, or a combination of the two, to provide emergency pressure relief. Venting may be through an absorption system, to a dump tank or directly to atmosphere, and the need to collect and treat the release will depend on the likely impact of a discharge. The relief system must be designed to cope with all conceivable conditions, because the vented stream might be liquid or a twophase foaming mixture, which would impose different design constraints from simple gas relief. All equipment installed in the venting system should be maintained in a state of readiness even though the system is rarely used. Sometimes a smallcapacity relief valve is installed, discharging to an abatement system, with, in parallel and at a slightly higher pressure setting and discharging directly to atmosphere, a large-capacity device to deal with fire induced relief.

Indicative BAT You should, where appropriate: 1. Carry out a systematic HAZOP study for all relief systems, to identify and quantify significant risks to the environment from the technique chosen. 2. Identify procedures to protect against overpressure of equipment. This requires the identification of all conceivable over-pressure situations, calculation of relief rates, selection of relief method, design of the vent system, discharge and disposal considerations, and dispersion calculations. In some cases careful design can provide intrinsic protection against all conceivable over-pressure scenarios, so relief systems and their consequential emissions can be avoided. 3. Maintain in a state of readiness all equipment installed in the venting system even though the system is rarely used.

HOW WE WILL ACHIEVE

Duvelco Answer The reaction chamber will be enclosed due to the nature of processing with VOC solvents. Furthermore as heat is required to initiate and sustain the reaction, by virtue of heating the contents in a vessel, they will expand and the volume available for gases could reduce, leading to over pressurisation of the reactor design.

To prevent any over-pressurisation events, the vessels will be designed to accommodate all potential liquid expansion without over-pressurisation. By ensuring the provision of an active system looking at two parameters (mass and level detection), the system would minimise the possibility of overfilling the vessel and/ or commencing with the next stage of the process. As an overall objective, by careful design, the intrinsic protection against all conceivable pressure scenarios will be the targeted outcome (HAZOP process).

As a fail-safe, a pressure relief valve will be installed in the system that would vent vapours to the facility adsorption abatement system. The over-filling and pressure relief systems would be subject to scheduled periodic testing to ensure their continued efficacy.

There are no self sustaining reactions within the Duvelco processes and with an array monitoring and sensors incorporated into the plant in the event that a process went outside any pre-set parameters the plant would shutdown.

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Heat exchanges and cooling systems All heat exchange systems have the potential for process streams to leak into the heating/cooling fluid, or vice versa. The “Industrial Cooling Systems” BREF (see Reference 3) provides detailed information on BAT for water-cooled heat exchangers and cooling-tower systems.

Indicative BAT You should, where appropriate: 1. Consider leak detection, corrosion monitoring and materials of construction, preferably in a formal HAZOP study. Plans and timetables for improved procedures or replacement by higher integrity designs should be in place where the risks are identified as significant. 2. If corrosion is likely, ensure methods for rapid detection of leaks are in place and a regime of corrosion monitoring in operation at critical points. Alternatively, use materials of construction that are inert to the process and heating/cooling fluids under the conditions of operation. 3. For cooling water systems, use techniques that compare favourably with relevant techniques described in the Industrial Cooling Systems BREF.

HOW WE WILL ACHIEVE

Duvelco Answer The heating and cooling of the process will be done with a closed loop, liquid, pressurised circuit. All heat exchangers and vessels that will be heated will have corrosion resistant stainless steel wetted parts in contact with the liquid to prevent the possibility of corrosion. The circuit will have constant pressure monitoring to ensure that there are no leaks in the system.

For the batch processing, as is required, the heating will be done electrically, and the cooling will be done with a heat exchanger using forced air convection and/or a refrigeration unit as may be required by the ambient temperature.

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Purging facilities Plant will normally require purging with air between batches and campaigns, and prior to maintenance activities; similarly, prior to start-up, air is often displaced from the system by an inert gas to ensure that a flammable atmosphere does not form. Purging leads to non-condensable gases carrying organic vapours being vented from the system.

Indicative BAT You should, where appropriate: 1. Assess the potential for the release to air of VOCs and other pollutants along with discharged purge gas and use abatement where necessary.

HOW WE WILL ACHIEVE

Duvelco Answer Duvelco will purge and seal vessels not in use with an inert gas OR vacuum and seal them, by doing this, whilst producing emissions when either vacuuming or expelling the gas; this will prevent much more waste being created by allowing a reduced in frequency stripping down and fully cleaning the vessels. Any vapour would be captured by way of a cold trap prior to a vacuum pump and/or in the facility abatement plant.

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2.4 Reaction stage It is important to consider how the chemistry and engineering options may contribute to releases to the environment from the reaction stage, both directly and as a consequence later in the process. It is also important that these considerations are made at the process design stage - before plant design and equipment selection is commenced. It is difficult to overstate the importance of an adequate understanding of the physical chemistry involved in the reaction scheme, followed by sound application of reactor engineering principles at the process design stage.

Indicative BAT You should, where appropriate: 1. With a clear understanding of the physical chemistry, evaluate options for suitable reactor types using chemical engineering principles. 2. Select the reactor system from a number of potentially suitable reactor designs - conventional stirred tank reactor (STR), process-intensive or novel-technology - by formal comparison of costs and business risks against the assessment of raw material efficiencies and environmental impacts for each of the options. 3. Undertake studies to review reactor design options based on process-optimisation where the activity is an existing activity and achieved raw material efficiencies and waste generation suggest there is significant potential for improvement. The studies should formally compare the costs and business risks, and raw material efficiencies and environmental impacts of the alternative systems with those of the existing system. The scope and depth of the studies should be in proportion to the potential for environmental improvement over the existing reaction system. 4. Maximise process yields from the selected reactor design, and minimise losses and emissions, by the formalised use of optimised process control and management procedures (both manual and computerised where appropriate). 5. Minimise the potential for the release of vapours to air from pressure relief systems and the potential for emissions of organic solvents into air or water, by formal consideration at the design stage - or formal review of the existing arrangements if that stage has passed.

HOW WE WILL ACHIEVE

Duvelco Answer The conventional reactor design is dictated by the chemical batch processes that Duvelco undertake, with the reactor requiring specific working parameters for compatibility based on the processing conditions and solvents used in the process.

The process will be scaled up from a pilot plant equipped with data loggers to ensure that, from the studies that will be conducted, any additional efficiencies can be identified and process yields can be maximised and losses minimised.

In line with section 2.3 ‘Over-pressurisation and purging’, formal design consideration will be given to minimise the potential release of VOC vapours to air.

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Minimisation of vapour losses There are many techniques for minimising the potential for vapour losses and for collection and abatement of vapour displaced into vent lines. For example, during the charging of vessels, vapour losses can be reduced by using dip-pipe or bottom-filling instead of splash-filling from the top. This also reduces the risks of static-induced explosion. Organics evaporated from reactor systems can be collected ahead of an abatement system in order to achieve direct recovery of the material, the most common method being condensation. You should always consider opportunities to enhance the performance of abatement systems, e.g. by increasing the heat transfer area or chilling the coolant medium for condensation, or by changing the packing or absorbent in absorption towers.

Indicative BAT You should, where appropriate: 1. Review your operating practices and review vent flows to see if improvements need to be made. 2. Consider opportunities to enhance the performance of abatement systems.

HOW WE WILL ACHIEVE

Duvelco Answer To minimise vapour losses, when filling solvent storage tanks, a vent line will be connected to the vessel that they are being filled from, so vapour is only displaced rather than introducing more air to be contaminated. The storage vessels will be filled via dip pipes to reduce turbulence and splashing. Vessels will be enclosed to reduce evaporation losses, the breather vents will vent into the facility abatement system.

As part of the process, the reactor will directly discharge into the next step to minimise in-process evaporation losses. In the next step, the product will be separated from the solvent via way of pressurised filtration with the solvent captured for re-processing. Solvents will be recovered and recycled via distillation techniques prior to discharge of residual vapours to the abatement system. All reactions will be conducted in enclosed vessels preventing the free release of organic vapours during normal processing.

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2.5 Separation stage On completion of the reaction it is usually necessary to separate the desired product from the other components in the reaction system.

Liquid-vapour separations The most widely used vapour-liquid separation techniques are evaporation, steam- or gas-stripping and distillation. Contaminants in the liquid phase can cause excessive foaming and the presence of inert non- condensable gases can depress the performance of condensers. .

Indicative BAT You should, where appropriate: 1. Choose your separation technique following a detailed process design and HAZOP study. Follow formal operating instructions to ensure effective separation and minimisation of losses. Adhere to design conditions such as heat input, reflux flows and ratios, etc. 2. Install instrumentation to warn of faults in the system, such as a temperature, pressure or low coolant- flow alarms.

HOW WE WILL ACHIEVE

Duvelco Answer Only solvent evaporation distillation is required for the Duvelco processes. A study of the most suitable commerically available equipment will be performed in conjunction with a HAZOP study as to how it will integrate with the plant, inclusive of sensors and transducers as may be required to give full feedback to the process control centre running the operation.

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Liquid-liquid separations The most widely used liquid-liquid separation techniques are 2-phase extraction with water or solvent, decantation, centrifuging and multi-stage contacting. Small quantities of surfactant substances can affect dispersion and coalescence, and even with good separation there is usually a secondary haze which, typically, accounts for up to 1% of the required substance remaining in the wrong phase and ending up in the waste stream.

Indicative BAT You should, where appropriate: 1. Use techniques which maximise physical separation of the phases (and also aim to minimise mutual solubility) where practicable. 2. When the phases are separated, use techniques which prevent (or minimise the probability and size of) breakthrough of the organics phase into a waste-water stream. This is particularly important where the environmental consequences of subsequent releases of organics to air or into controlled waters may be significant (e.g. where the effluent is treated in a DAF unit or some of the organic components are resistant to biological treatment). 3. Where you are discharging to drain, consider whether there should be an intermediate holding or “guard” tank to protect against accidental losses from the organics phase.

HOW WE WILL ACHIEVE

Duvelco Answer There is no liquid-liquid separation required for the process.

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Solid-liquid separations Different separation techniques will be BAT for different applications, with factors like solubility, crystallisation rate and granular size being important. The main solid-liquid techniques are centrifuging, filtration, sedimentation, clarification, drying and ion exchange.

Indicative BAT You should, where appropriate: 1. Use techniques to minimise, re-use and/or recycle rinse water, and to prevent breakthrough of solids. 2. Install instrumentation or other means of detecting malfunction as all of the techniques are vulnerable to solids breakthrough. 3. Consider installing “guard” filters of smaller capacity downstream which, in the event of breakthrough, rapidly ‘clog’ and prevent further losses. 4. Have good management procedures to minimise loss of solids, escape of volatiles to air and excessive production of waste water.

HOW WE WILL ACHIEVE

Duvelco Answer The produced product will be separated from the solvent via way of pressurised filtration with the solvent captured for re-processing, leaving the polymer cake as dehydrated as the process will allow, thus minimising the escape of all volatiles to air from the solid-liquid separation.

No rinse water will be utilised in the processes. Any cleaning/rinsing will be done with solvents with spray nozzles inside the equipment (known as CIP ‘Clean in Place’) minimising solvents used for cleaning and subsequent vapour losses. The solvents will then be subsequently recovered.

2.6 Purification stage Waste associated with the purification stage may arise from: • Impurities in the raw materials - so a change in the raw material specifications may reduce waste arisings. • By-products generated by the process - so a change in reaction conditions, catalyst, solvent, etc may improve the selectivity of the reaction and reduce or eliminate by-product formation.

Purification of liquid products Liquid products are usually refined by distillation, with filtration used to remove solid contaminants. Sources of loss are: • Gas entrainment. Gas or vapour flow will carry away volatile material either as vapour or as entrained droplets. Additional condenser heat-exchange area or colder heat-exchange fluid can improve the recovery rate, and coalescing demisters are relatively cheap and easy to install.

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• Ineffective separation. A better separation in the distillation column can be achieved by using more stages (theoretical plates) or more reflux. Modern types of packing or high efficiency trays can often produce a marked improvement for a modest capital investment. • Filtration. Enclosed filtration is usually used and this is not normally a source of great vapour loss to air. Liquid discharged during cleaning or changing of filters should be returned to the process.

Purification of solid products Washing and crystallising activities have the potential to produce large volumes of dilute liquors so counter-current systems of operation should be used wherever possible. During drying, you should aim to produce the maximum concentration of solvent in the gas to allow recovery of the solvent. The use of vacuum can improve both solvent recovery and energy efficiency.

2.7 Chemical process controls Reaction conditions such as temperatures, pressures, rocking or stirring rates, catalyst age, input and output flow rates, addition of materials (and so on) are imperative to the efficient conversion of raw materials to product.

Indicative BAT You should, where appropriate: 1. Monitor the relevant process controls and set with alarms to ensure they do not go out of the required range.

HOW WE WILL ACHIEVE

Duvelco Answer During all processes/stages of the polymer production, the plant will have numerous temperature, pressure, flow, position indicators, electrical current and voltage sensors, as well as instrumentation feedback, looking at process emissions. This comprehensive approach will give the plant control system the data required for the HAZOP team to agree normal, high and out of process limits to display alarms and react accordingly.

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2.8 Analysis

Indicative BAT You should, where appropriate: 1. Analyse the components and concentrations of by products and waste streams to ensure correct decisions are made regarding onward treatment or disposal. Keep detailed records of decisions based on this analysis in accordance with management systems.

HOW WE WILL ACHIEVE

Duvelco Answer The plant will operate on a fixed process basis, with all waste streams being initially categorised after analysis. Should there be a change in incoming raw material, specification or supplier, a re-anlysis of the waste stream will be conducted.

Should there have been no changes in the interim, analysis will be repeated every 12 months and will be conducted at the same time as management review as part of our waste management duty of care.

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3.1 Point source emissions Point source emissions to air The diversity of this broad sector is such that a wide range of different emissions will arise. You should aim first to prevent emissions and then to minimise emissions at source. Only when you have done this should you use abatement techniques as necessary. You will often need a combination of techniques to abate emissions. You should formally consider the following when dealing with your emissions to air: • the information in this guidance note • relevant equivalent sections in the guidance notes for the speciality organics chemical sector and the inorganic chemical sector • the abatement guidance note • the BREF on Common Waste Water and Waste Gas Treatment / Management Systems in the Chemical Sector • other specific BREFs as relevant to the activity.

The selection of BAT for a specific installation will depend on many factors including: • gas flow rate (average rate, range, rate of variation) • pollutant types and inlet concentrations • presence of impurities (e.g. water, dust, corrosives) • concentration required in the exhaust • safety • investment and operating cost • plant layout • availability of utilities.

Depending on these factors, a combination of techniques may be needed to satisfy the requirements of BAT. Measures for prevention and minimisation should be applied, then abatement techniques used if necessary. The benchmark values for point source emissions to air listed in Annex 1 are achievable using the techniques described in the BREF and we would expect you to use techniques that can achieve these values unless you have presented a cost benefit analysis to justify alternative values and we have agreed

Particulate matter The methods available for minimising or reducing discharges of particulate matter to the atmosphere are described in the Abatement Guidance Note A3 (see Reference 3, Annex 2).

General emissions There are many methods available for reducing and minimising discharges of gaseous pollutants in emissions to atmosphere. Some of the main types are as follows: • absorption • condensation • thermal decomposition • adsorption • filtration • electrostatic precipitation

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Indicative BAT You should, where appropriate: 1. Formally consider the information and recommendations in the BREF on Common Waste Water and Waste Gas Treatment/ Management Systems in the Chemical Sector (see Reference 1, Annex 2) as part of the assessment of BAT for point-source releases to air, in addition to the information in this guidance note. 2. Identify the main chemical constituents of the emissions, including VOC speciation where practicable. 3. Assess vent and chimney heights for dispersion capability and assess the fate of the substances emitted to the environment. 4. Use the following measures to minimise emissions to air: • recover emissions rich in organics by fractionation and then recycle • recover and reuse solvents • continuously monitor off-gas concentration from reaction vessels, dryers, condensers, evaporators and scrubbers where off-gases are shown to be environmentally significant.

HOW WE WILL ACHIEVE

Duvelco Answer All potential leaks from the production process are collected by the local extraction system and routed into the abatement system for discharge into the atmosphere.

Daily spot readings of the key VOCs will be carried out using indicative gas monitoring system i.e. gastech detector tubes. This would also help to identify any exposure in the workplace to any hazardous VOCs.

Monitoring the outlet of the abatement system will be carried out at regular intervals to ensure any specific emission limits are not exceeded. This can either be done through a standard monitoring techniques or, if needed, a continuous monitoring system.

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Control of emissions of volatile organic compounds (VOCs) The main issues that influence the selection and cost of VOC abatement techniques for this sector are: • the intermittent nature of releases from batch processes • and the complex nature of the gas streams involved, with many different VOCs often being present as well as moisture, particulates and acid gases.

Both of these issues have a profound influence on the selection of abatement techniques.

Abatement of volatile organic compounds (VOCs) is described in the Abatement Guidance Note A3 (see Reference 3, Annex 2) and that note should be consulted where VOC emissions are significant.

Before selecting the appropriate technique(s) it is important to quantify systematically flows, chemical compounds and concentrations over all potential operating conditions. Quantification allows opportunities for inprocess minimisation to be considered, as well as aiding in the selection of the appropriate abatement techniques. Particular attention may have to be given to vent header systems that receive gas streams from a number of different sources.

Techniques for the abatement of VOCs may be broadly characterised as those that: • recover the VOC and offer the potential for recycle/re-use (adsorption, absorption and condensation) • destroy the VOC (thermal, catalytic, flameless and biological oxidation, respectively)

Unless a viable recycle/re-use route is available for the former techniques, then there will still be a need for disposal. All of these techniques have been and will continue to be widely applied in the sector.

Point Source Emissions to Water Water is used for some reactions (process water), for cooling and for cleaning. Waste water streams can generally be categorized as: • contaminated with hydrocarbons • contaminated with heavy metals • contaminated with chlorinated hydrocarbons, and/or • acidic and alkaline.

It is unlikely that any single waste water treatment technique will be adequate to render harmless the waste water to be discharged. For example, a waste water stream with a low pH and a high organics content would require both pH adjustment and a means removing the organic compounds. Treatment methods should be applied as appropriate.

Useful in-plant treatment techniques include: • For hydrocarbons, combinations of: air or steam stripping; granular activated carbon; ion exchange; reverse osmosis; electrodialysis; oxidation, including wet oxidation. • For heavy metals, combinations of oxidation/reduction; precipitation; filtration. • For aqueous waste, wet air oxidation is generally more energy-efficient than incineration and is capable of oxidising complex molecules, including some pesticides, with up to 99.9% removal efficiencies. However, tests are normally required to confirm or otherwise the appropriateness of this technique.

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Advantages of wet oxidation include: • emissions of nitrogen oxides are virtually eliminated where the oxidation temperature is low • emissions of dust or inorganic oxides are eliminated, and • the oxidation is carried out in a closed system, which reduces the risk of release of unconverted material in the event of a process upset such as runaway reactions

Possible disadvantages include: • a minimum concentration of oxidisable material is required to allow autothermal operation; below this concentration an extra energy source is required.

Where recovery or chemical treatment of liquid wastes is not feasible, thermal destruction is the next preferred alternative. A correctly designed and operated incinerator ensures a high degree of controlled combustion, allows recovery of heat and abatement of polluting emissions.

Indicative BAT You should, where appropriate: 1. Control all emissions to avoid a breach of water quality standards as a minimum. Where another technique can deliver better results at reasonable cost it will be considered BAT and should be used. 2. Use the following measures to minimise water use and emissions to water: • where water is needed for cooling, minimize its use by maximising heat transfer between process streams • use water in recirculating systems with indirect heat exchangers and a cooling tower rather than a once through system. (A water make-up treatment plant and a concentrated purge stream from the system to avoid the build up of contaminants are likely to be necessary.) • leaks of process fluids into cooling water in heat exchangers are a frequent source of contamination. Monitoring of the cooling water at relevant points should be appropriate to the nature of the process fluids. In a recirculatory cooling system, leaks can be identified before significant emission to the environment has occurred. The potential for environmental impact is likely to be greater from a once through system. Planned maintenance can help to avoid such occurrences • water used for cleaning can be reduced by a number of techniques, e.g. by spray cleaning rather than whole vessel filling • strip process liquor and treat if necessary, then recycle/reuse • use wet air oxidation for low volumes of aqueous effluent with high levels of organic content, such as waste streams from condensers and scrubbers • neutralise waste streams containing acids or alkalis to achieve the required pH for the receiving water • strip chlorinated hydrocarbons in waste streams with air or steam and recycle by returning to process where possible • recover co-products for re-use or sale • periodically regenerate ion exchange columns • pass waste water containing solids through settling tanks, prior to disposal

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• treat waste waters containing chlorinated hydrocarbons separately where possible to ensure proper control and treatment of the chlorinated compounds. Contain released volatile chlorinated hydrocarbons and vent to suitably designed incineration equipment • non-biodegradable organic material can be treated by thermal incineration. However, the thermal destruction of mixed liquids can be highly inefficient and the waste should be dewatered prior to incineration.

HOW WE WILL ACHIEVE

Duvelco Answer The LEV system feeds into a water-based wet scrubber which acts as the first step of the abatement.

The process fumes are the routed into an activated carbon filter which will further reduce the concentrations of the VOCs. Then, the abated process air is then discharged via a vertical stack at a velocity in excess of 15m/s.

Note: Once spent, the scrubbing liquid will be treated as hazardous waste and collected by a registered waste carrier with a consignment note. No recover or re-use of this liquid is economically viable and therefore will not take place.

The activated carbon filter will be replenished at the recommended intervals specificed by the manufacturer.

Planned maintenance will take place on both abataement filters on a regular basis, as per the manufacturers instructions.

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Point Source Emissions to Land The wastes produced by the sector can be classified into types as follows: • by-products for which no internal use or external sale is available • residues from separation processes such as distillation • catalysts which have declined in performance and require replacement • filter cake, activated carbon, ion exchange resins, molecular sieves and other treatment materials • sludges from waste water treatment • emptied containers and packaging • maintenance and construction materials.

Landfill may be suitable for a limited number of wastes which are non polluting or are solidified or encapsulated to prevent release of contaminants. For example, some metal compounds when treated with lime are highly insoluble. Landfill of wastes should only be contemplated after all other alternatives have been thoroughly examined and rejected.

The following wastes are likely to be landfilled: • spent process residues • spent molecular sieve • spent ion exchange resins • polymer and sludge from reaction vessels.

Indicative BAT You should, where appropriate: 1. Use the following measures to minimise emissions to land: • use settling ponds to separate out sludge (Note: Sludge can be disposed of to incinerator, encapsulation, land or lagoon depending upon its make up.) • chlorinated residues should be incinerated and not released to land. (Chlorinated hydrocarbons are not to be released to the environment due to their high global warming and ozone depletion potentials.) • either recycle off spec product into the process or blend to make lower grade products where possible • many catalysts are based on precious metals and these should be recovered, usually by return to the supplier.

HOW WE WILL ACHIEVE

Duvelco Answer The process does not generate any emissions to land.

All storage and processes involving chemicals are contained in bunding tanks inside the proposed facility.

The only residues produced are from the wet scrubber and solvent recycling process. Both of these waste streams are collected at source and transferred away by a registered hazardous waste carrier. No re-use is undertaken. www.duvelco.com Page 26 Registered Office: Ivy House Foundry, Hanley, Stoke-on-Trent, ST1 3NR - Registered in England No. 12422228 EPR 4.01 BAT Compliance

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3.2 Fugitive emissions Fugitive emissions of VOCs Fugitive VOC emissions to air are often significant. Typical survey results show that leaks from glands on valves and pumps are responsible for 90% or more of estimated fugitive emissions and that a small proportion of valves, virtually all on gas or high-temperature light material streams, contribute almost all of the total. Abatement of fugitive emissions is of particular importance for VOCs with a high environmental impact.

Indicative BAT You should, where appropriate: 1. Establish a fugitive release inventory for the installation. This is a major undertaking, which involves the following steps: • identifying all potential sources of VOC emissions, by establishing population counts of equipment components in line with up-to-date piping and instrumentation drawings for processes. This survey should cover gas, vapour and light liquid duties • quantifying the VOC emissions, initially as baseline estimates, and subsequently to more refined levels. Suitable protocols for this include the US EPA Method 21 for process component losses and API methods for tankage losses. Some major companies have developed their own techniques and protocols • using appropriate dispersion modelling techniques to predict atmospheric mass flux and concentrations • monitoring to compare the predicted situation with the measured one. 2. Have a permanent on-going leak detection and repair (LDAR) programme for process component fugitive emissions. This should be developed and tailored to suit the situation concerned. It should provide estimates of fugitive VOC emissions for monitoring returns and enable action to be taken to minimise emissions. 3. To minimise fugitive emissions you should: • use low-emission valve stem packing (500 ppm) on critical valves, eg risingstem gate-type control valves in continuous operation, particularly on gas/light liquid high-pressure/temperature duties • use alternative proven types of low-release valves where gate valves are not essential, e.g. quarter-turn and sleeved plug valves, both of which have two independent seals • use balanced bellows-type relief valves to minimise valve leakage outside of design lift range and piping of reliefs to flare, normally via phase separation, without header back-pressure • minimise the number of flanged connections on pipelines and use highspecification jointing materials • use canned pumps, magnetically driven pumps, or double seals on conventional pumps • pipe compressor seals, vent and purge lines to flare systems • use end caps or plugs on open-ended lines and closed loop flush on liquid sampling points • minimise the emissions to air from process hydrocarbon analysers, by optimising sampling volume/ frequency and venting to flare systems • when transferring volatile liquids, use one or more of the following techniques: subsurface filling via filling pipes extended to the bottom of the container, vapour balance lines that transfer the vapour from the container being filled to the one being emptied, or an enclosed system with extraction to suitable abatement plant • choose vent systems to minimise breathing emissions (for example pressure/ vacuum valves) and, where relevant, fit knock-out pots and appropriate abatement equipment

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• keep bulk storage temperatures as low as practicable, taking into account changes due to solar heating etc • use the following techniques (together or in any combination) to reduce losses from storage tanks at atmospheric pressure: – tank paint with low solar absorbency – temperature control – tank insulation – inventory management – floating roof tanks – bladder roof tanks – pressure/vacuum valves, where tanks are designed to withstand pressure fluctuations – specific release treatment (such as adsorption condensation)

HOW WE WILL ACHIEVE

Duvelco Answer The only potential sources of fugitive VOC emissions are from pressure relief valves, tank vents and possible abatement system failure.

After issuing of permit, finalised drawings of the proposed plant can be confirmed. These will identify all potential sources of VOC emissions within the plant.

Baseline estimates of VOC emissions can be generated and used in a dispersion model to predict mass emission concentrations. As the plant is finalised/operational, a programme of emissions monitoring will be carried out to confirm the actual VOC emission concentrations.

Daily leak detection measurements will be carried out using indicative gastech tube detector systems.

The plant will be designed to incorporate all applicable methods of minimising fugitive emissions, as described by the indicative BAT i.e. low emission valves will be used at all critical points in the system, all solvent storage tanks will be filled via dip pipes, all pipework will be dedicated for process and welded to minimise flanged connections, any relevant vents are routed to localised extraction system feeding into the abatement system.

The temperature of the process and storage areas will be maintained at ambient temperature, with no direct sunlight.

There will be an inventory management system in place to control and account for the levels of raw materials stored on site and used in the production process. This would act to identify any losses were being made that were not being picked up by other measures.

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Fugitive emissions to surface water, sewer and groundwater Fugitive emissions, primarily from leaks and spillages, may occur into cooling water, site drainage water and groundwater. Their control must form part of a programme of good design, monitoring, maintenance and operating procedures.

Indicative BAT You should, where appropriate: 1. Provide hard surfacing in areas where accidental spillage or leakage may occur, e.g. beneath prime movers, pumps, in storage areas, and in handling, loading and unloading areas. The surfacing should be impermeable to process liquors. 2. Drain hard surfacing of areas subject to potential contamination so that potentially contaminated surface run-off does not discharge to ground. 3. Hold stocks of suitable absorbents at appropriate locations for use in mopping up minor leaks and spills, and dispose of to leak-proof containers. 4. Take particular care in areas of inherent sensitivity to groundwater pollution. Poorly maintained drainage systems are known to be the main cause of groundwater contamination and surface/above-ground drains are preferred to facilitate leak detection (and to reduce explosion risks). 5. Additional measures could be justified in locations of particular environmental sensitivity. Decisions on the measures to be taken should take account of the risk to groundwater. 6. Surveys of plant that may continue to contribute to leakage should also be considered, as part of an overall environmental management system. In particular, you should consider undertaking leakage tests and/or integrity surveys to confirm the containment of underground drains and tanks.

HOW WE WILL ACHIEVE

Duvelco Answer All chemical stroage and reaction areas are housed in bunded areas on an impermeable surface.

Spill kits are located within multiple areas of the facility to deal with any potential spillages that may occur.

Any spillages or effluent streams are treated as hazaroud waste and are therefore stored in a hazardous waste area and will be collected by a registered hazardous waste carrier and therefore there is no discharge to groundwater or the public drainage system.

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3.3 Odour The requirements for odour control will be installation-specific and depend on the sources and nature of the potential odour.

Indicative BAT You should, where appropriate: 1. Manage the operations to prevent release of odour at all times. 2. Where odour releases are expected to be acknowledged in the permit, (i.e. contained and treated prior to discharge or discharged for atmospheric dispersion): • for existing installations, the releases should be modelled to demonstrate the odour impact at sensitive receptors. The target should be to minimise the frequency of exposure to ground level concentrations that are likely to cause annoyance • for new installations, or for significant changes, the releases should be modelled and it is expected that you will achieve the highest level of protection that is achievable with BAT from the outset • where there is no history of odour problems then modelling may not be required although it should be remembered that there can still be an underlying level of annoyance without complaints being made • where, despite all reasonable steps in the design of the plant, extreme weather or other incidents are liable, in our view, to increase the odour impact at receptors, you should take appropriate and timely action, as agreed with us, to prevent further annoyance (these agreed actions will be defined either in the permit or in an odour management statement). 3. Where odour generating activities take place in the open, or potentially odorous materials are stored outside, a high level of management control and use of best practice will be expected. 4. Where an installation releases odours but has a low environmental impact by virtue of its remoteness from sensitive receptors, it is expected that you will work towards achieving the standards described in this guidance note, but the timescales allowed to achieve this might be adjusted according to the perceived risk. 5. Where further guidance is needed to meet local needs, refer to Horizontal Guidance Note H4 Odour (see GTBR).

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HOW WE WILL ACHIEVE

Duvelco Answer The site will operate and implement a site specific odour management plan. The site emissions will be modelled which will provide ground level concentrations of the VOCs at nearby receptors. The results of this will indicate that the impact of the site will achieve the highest level of protection that is achievable.

No odour generating activites are carried out outside. All processes are contained within a building that is operated under negative pressure, which minimises the potential of odorous releases. This includes any waste generated by the process.

All waste stream will be collected in line with the odour management plan, by a registered hazardous waste carrier.

The design of the facility has taken into account the requirements of BAT and will maintain this throughout its operational lifetime. However, the closest receptor is over 150m away, or in excess of 300m away in the prevailing wind direction.

The odour management plan will be reviewed on an annual basis to ensure that the relevant odour control measures are working effectively. The plan has been written in accordance with the H4 guidance note.

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3.4 Noise and vibration Noise surveys, measurement, investigation (which can involve detailed assessment of sound power levels for individual items of plant) or modelling may be necessary for either new or existing installations depending upon the potential for noise problems. You may have a noise management plan as part of your management system.

Flares are a particular source of noise, often associated with steam injection for smoke suppression. Good design of flares tips can lessen the need for high rates of steam injection and provide quieter operation. The operation of safety valves and other release devices for high pressure systems can be extremely noisy.

Indicative BAT You should, where appropriate: 1. Install particularly noisy machines such as compactors and pelletisers in a noise control booth or encapsulate the noise source. 2. Limit the use of flares to emergency conditions. 3. Where possible without compromising safety, fit suitable silencers on safety valves. 4. Minimise the blow-off from boilers and air compressors, for example during start up, and provide silencers.

HOW WE WILL ACHIEVE

Duvelco Answer For the Duvelco processes, there are no excessively noisy pieces of equipment, nor any equipment which may cause nuisance vibrations. The whole process will be conducted inside an insulated building with the only external feature being the single source emission stack. The velocity discharge of the stack will be kept at, or fractionally above, 15m per second by use of a variable speed drive, so as not to exacerbate any noise pollution from the stack itself. Inside the facility, as there will not be excessive noise generation, therefore mandatory hearing PPE will not be required. To confirm this fact, a noise survey will be undertaken by an occupational hygienist, so externally, we do not anticipate any noise other than that generated by the stack, which is BAT custom and practice, will be determinable. Should anything to the contrary be found during the noise survey, we will take appropriate measures to reduce it well below any potential nuisance thresholds.

www.duvelco.com Page 32 Registered Office: Ivy House Foundry, Hanley, Stoke-on-Trent, ST1 3NR - Registered in England No. 12422228 EPR 4.01 BAT Compliance

LIMITED

3.4 Monitoring and reporting of emissions to air and water There is a suite of Environment Agency guidance on monitoring, known as the M series, which is included in the list of references in Annex 1 of GTBR.

Indicative BAT You should, where appropriate: 1. Carry out an analysis covering a broad spectrum of substances to establish that all relevant substances have been taken into account when setting the release limits. The need to repeat such a test will depend upon the potential variability in the process and, for example, the potential for contamination of raw materials. Where there is such potential, tests may be appropriate. 2. Monitor more regularly any substances found to be of concern, or any other individual substances to which the local environment may be susceptible and upon which the operations may impact. This would particularly apply to the common pesticides and heavy metals. Using composite samples is the technique most likely to be appropriate where the concentration does not vary excessively. 3. If there are releases of substances that are more difficult to measure and whose capacity for harm is uncertain, particularly when combined with other substances, then “whole effluent toxicity” monitoring techniques can be appropriate to provide direct measurements of harm, for example, direct toxicity assessment.

HOW WE WILL ACHIEVE

Duvelco Answer Monitoring will be carried out at regular intervals to quantify the exact VOC emission concentrations that will be released from the stack emission point. An additional VOC screen test can also be carried out to confirm the extent of substances that are being released. The monitoring frequency will be reviewed on a regular basis and carried out in line with any permit conditions. If there is any change to the raw materials in the process, further testing will be carried out to quantify any additional VOC releases.

www.duvelco.com Page 33 Registered Office: Ivy House Foundry, Hanley, Stoke-on-Trent, ST1 3NR - Registered in England No. 12422228 EPR 4.01 BAT Compliance

LIMITED

Monitoring and reporting of waste emissions

Indicative BAT You should, where appropriate: 1. Monitor and record: • the physical and chemical composition of the waste • its hazard characteristics • handling precautions and substances with which it cannot be mixed.

HOW WE WILL ACHIEVE

Duvelco Answer The company’s COSHH and waste management procedures will detail the physical and chemical composition of waste that needs to be removed from site, as well as its hazard characteristics and any handling precautions. These will be detailed on consignment notes issued to the licenced waste carrier.

www.duvelco.com Page 34 Registered Office: Ivy House Foundry, Hanley, Stoke-on-Trent, ST1 3NR - Registered in England No. 12422228 EPR 4.01 BAT Compliance

LIMITED

Monitoring and reporting of waste emissions

Indicative BAT You should, where appropriate: 1. Consider the following in drawing up proposals: • determinands to be monitored, standard reference methods, sampling protocols • monitoring strategy, selection of monitoring points, optimisation of monitoring approach • determination of background levels contributed by other sources • uncertainty for the employed methodologies and the resultant overall uncertainty of measurement • quality assurance (QA) and quality control (QC) protocols, equipment calibration and maintenance, sample storage and chain of custody/audit trail • reporting procedures, data storage, interpretation and review of results, reporting format for the provision of information.

HOW WE WILL ACHIEVE

Duvelco Answer If required, in response to potential odour complaints, a programme of sniff test assessments can be carried out to substantiate the presence of offensive odours beyond the site boundary. This will be carried out in line with the Institute of Air Quality Management guidance on odour for planning. Daily boundary sniff tests will be carried out by personnel not involved with operational activities.

www.duvelco.com Page 35 Registered Office: Ivy House Foundry, Hanley, Stoke-on-Trent, ST1 3NR - Registered in England No. 12422228 EPR 4.02 BAT Compliance

LIMITED

Duvelco Ltd has performed a comparison review of EPR4.01 and EPR4.02 and have only addressed EPR4.02 BAT where the requirement is different than what is stated in EPR 4.01. 2.4 Reaction Stage

Minimisation of liquid losses from reaction systems Different products are often made in successive campaigns, and at the end of each campaign it is important to remove as much potential contamination by the preceding batch as possible. This gives rise to waste.

Indicative BAT You should where appropriate: 1. Use the following features that contribute to a reduction in waste arisings from clean-outs: • low-inventory continuous throughput reactors with minimum surface area for cleaning • minimum internals such as baffles and coils in the reactor • smooth reactor walls, no crevices • flush bottom outlet on reaction vessels • all associated piping to slope back to the reactor or to a drain point • sufficient headroom under the reactor for collection of all concentrated drainings in drums or other suitable vessel, if necessary • minimal pipework, designed to eliminate hold-up and to assist drainage • pipework designed to allow air or nitrogen blowing • system kept warm during emptying to facilitate draining • HAZOP studies used to assess the potential for the choking of lines by high-meltingpoint material • campaigns sequenced so that cleaning between batches is minimised • campaigns made as long as possible to reduce the number of product change-overs • where a complete clean is necessary, use cleaning methods that minimise the use of cleaning agents, (e.g. steam-cleaning, rotating spray jets or high-pressure cleaning) or use a solvent which can be re- used • carry out HAZOP studies to minimise the generation of wastes and to examine their treatment/ disposal • consider use of disposable plastic pipe-liners • eliminate or minimise.locations for solids to settle-out • consider duplicate or dedicated equipment where it can reduce the need for cleaning that is difficult.

HOW WE WILL ACHIEVE

Duvelco Answer The Duvelco process will utilise smooth wall reactors with surface scrapers to minimise any production residue left in situ prior to cleaning, with all associated pipework, sloping back to the reactor drain point. If possible, dependent on production demands, it may be possible to avoid cleaning in between batches by purging with an inert gas, such as nitrogen. This would avoid creating excess waste without deteriorating product quality. When cleaning has to be carried out, this will be done utilising process solvent that can be reclaimed via the use of high pressure CIP (Clean In Place) nozzles within the production equipment. Where the process requires, duplicate vessels will be utilised to eliminate the need for cleaning due to cross- contamination reasons. HAZOP studies will be conducted as a matter of course, assessing the whole plant.

www.duvelco.com Page 1 Registered Office: Ivy House Foundry, Hanley, Stoke-on-Trent, ST1 3NR - Registered in England No. 12422228 EPR 4.02 BAT Compliance

LIMITED

2.5 Separation Stage

Liquid-liquid Separations The most widely used liquid-liquid separation techniques are 2-phase extraction with water or solvent, decantation, centrifuging and multi-stage contacting. Small quantities of surfactant substances can affect dispersion and coalescence, and even with good separation there is usually a secondary haze which, typically, accounts for up to 1% of the required substance remaining in the wrong phase and ending up in the waste stream. In batch operations, a common problem which results in loss of organics to drain is detection of the interface between the aqueous phase and the organics phase and stopping the flow in time.

Indicative BAT You should where appropriate: 1. Use techniques which maximise physical separation of the phases (and also aim to minimise mutual solubility) where practicable. 2. When the phases are separated, use techniques which prevent (or minimise the probability and size of) breakthrough of the organics phase into a waste-water stream. This is particularly important where the environmental consequences of subsequent releases of organics to air or into controlled waters may be significant (eg. where the effluent is treated in a DAF unit or some of the organic components are resistant to biological treatment). 3. When a separation is done by hand, use a “dead man’s handle”, backed-up by good management, to improve the chance of the flow being properly controlled as the phaseboundary approaches. 4. Consider if automatic detection of the interface is practicable. 5. Where you are discharging to drain, consider whether there should be an intermediate holding or “guard” tank to protect against accidental losses from the organics phase.

HOW WE WILL ACHIEVE

Duvelco Answer There is no liquid-liquid separation required for the process.

www.duvelco.com Page 2 Registered Office: Ivy House Foundry, Hanley, Stoke-on-Trent, ST1 3NR - Registered in England No. 12422228 EPR 4.02 BAT Compliance

LIMITED 3.1 Point source emissions

Point source emissions to air The diversity of this broad sector is such that a wide range of different emissions will arise. You should aim first to prevent emissions and then to minimise emissions at source. Only when you have done this should you use abatement techniques as necessary. You will often need a combination of techniques to abate emissions.

You should formally consider the following when dealing with your emissions to air: • the information in this guidance note • relevant equivalent sections in the guidance notes for the large volume organics chemical sector and the inorganic chemical sector • the abatement guidance note • the BREF on Common Waste Water and Waste GasTreatment/ Management Systems in the Chemical • Sector • other specific BREFs as relevant to the activity.

The selection of BAT for a specific installation will depend on many factors including; • gas flow rate (average rate, range, rate of variation) • pollutant types and inlet concentrations • presence of impurities (e.g. water, dust, corrosives) • concentration required in the exhaust • safety • investment and operating cost • plant layout • availability of utilities.

Depending on these factors, a combination of techniques may be needed to satisfy the requirements of BAT. Measures for prevention and minimisation should be applied, then abatement techniques used if necessary.

The benchmark values for point source emissions to air listed in Annex 1 are achievable using the techniques described in the BREF and we would expect you to use techniques that can achieve these values unless you have presented a cost benefit analysis to justify alternative values and we have agreed

Particulate Matter The methods available for minimising or reducing discharges of particulate matter to the atmosphere are described in the Abatement Guidance Note A3 (see Reference 3, Annex 2).

General Emissions There are many methods available for reducing and minimising discharges of gaseous pollutants in emissions to atmosphere. Some of the main types are as follows: • absorption • condensation • thermal decomposition • adsorption • filtration • electrostatic precipitation www.duvelco.com Page 3 Registered Office: Ivy House Foundry, Hanley, Stoke-on-Trent, ST1 3NR - Registered in England No. 12422228 EPR 4.02 BAT Compliance

LIMITED

Indicative BAT You should where appropriate: 1. Formally consider the information and recommendations in the BREF on Common Waste Water and Waste Gas Treatment/ Management Systems in the Chemical Sector (see Reference 1) as part of the assessment of BAT for point-source releases to air, in addition to the information in this note. 2. Identify the main chemical constituents of the emissions, including VOC speciation where practicable. 3. Assess vent and chimney heights for dispersion capability and assess the fate of the substances emitted to the environment. 4. Use the following measures to minimise emissions to air: • recover emissions rich in organics by fractionation and then recycle • recover and reuse solvents • continuously monitor off-gas concentration from reaction vessels, dryers, condensers, evaporators and scrubbers where off-gases are shown to be environmentally significant

HOW WE WILL ACHIEVE

Duvelco Answer The polymer production process shall be contained and shall utilise closed loop systems where feasible. In addition to which, the whole process will be conducted in a negative pressure facility. This will minimise potential fugitive releases to air. All process extraction will then be routed through an abatement system which consists of wet scrubbing and carbon adsorption, with a single point source emission to air via a monitored stack.

The bespoke facility is being custom designed to address this and many other sections of the BAT. A no- compromise approach to the design of the building’s plant and equipment has been undertaken; it will be tailored purely for the processes that Duvelco will undetake in the facility.

Duvelco Ltd has formally engaged a professional air management consultant that specialises in minimising point source emissions to air. We will operate and meet the Best Available Techniques (BAT).

www.duvelco.com Page 4 Registered Office: Ivy House Foundry, Hanley, Stoke-on-Trent, ST1 3NR - Registered in England No. 12422228 EPR 4.02 BAT Compliance

LIMITED

3.2 Fugitive Emissions

Fugitive Emissions to Air On many installations fugitive emissions may be more significant than point source emissions. Fugitive VOC emissions are very likely from this sector - from phase-separations, valve glands and STR cleaning or charging, for example.

Indicative BAT You should where appropriate: 1. Identify all potential sources and develop and maintain procedures for monitoring and eliminating or minimising leaks and releases of VOCs from all non-process stream sources. 2. Choose vent systems to minimise breathing emissions (for example pressure/ vacuum valves) and, where relevant, should be fitted with knock-out pots and appropriate abatement equipment. 3. Use the following techniques (together or in any combination) to reduce losses from storage tanks at atmospheric pressure: • maintenance of bulk storage temperatures as low as practicable, taking into account changes due to solar heating etc. • tank paint with low solar absorbency • temperature control • tank insulation • inventory management • floating roof tanks • bladder roof tanks • pressure/vacuum valves, where tanks are designed to withstand pressure fluctuations • specific release treatment (such as adsorption condensation).

HOW WE WILL ACHIEVE

Duvelco Answer On receipt of a conditional permit, the plant design will be finalised in line with BAT to ensure that a robust approach is taken to ensure that there will be no figitive emissions to air. The plant and all storage tanks and therefore all potential fugitive emission release points will be contained within a negative pressure, insulated facility, with all extraction of potential fugitive emissions within the facility directed through an abatement system to the single point source emission of the site.

As it is bespoke plant and not multi-purpose, the design will not incorporate deadlegs, redundant equipment or other features, all of which would have flange connectors, leading to potential fugitive emissions. Pipework will be welded wherever practical to reduce joints, all contained in an indoor facility.

www.duvelco.com Page 5 Registered Office: Ivy House Foundry, Hanley, Stoke-on-Trent, ST1 3NR - Registered in England No. 12422228

Form B3, Question 3C, Table 5 – Fill in Table 5 for all schedule 1 activities. Fill in a separate table for each installation.

Name of the installation Duvelco Limited Capacity up to 250kg per day (0.25 tonnes per day) Schedule 1 Description of Raw Maximum Annual Description of use of Activity Material and Amount Throughput the raw material Composition (tonnes) (tonnes each including any of the year) main hazards (include safety data sheets) Polyimide Pyromellitic 27 Upto 50 Raw Ingredient manufacture dianhydride Polyimide 4,4’-Oxydianiline 27 Upto 50 Raw Ingredient manufacture Polyimide Class B VOC solvents 20 30 Used in Processing manufacture Polyimide Powdered Graphite 2 15 Polymer addition manufacture Polyimide Teflon 2 6 Polymer addition manufacture Polyimide Molybdenum 0.5 3 Polymer addition manufacture disulphide

Pyromellitic dianhydride hazards:

Serious eye damage (Category 1), H318

Respiratory sensitisation (Category 1), H334

Skin Sensitisation (Category 1), H317

4’4-Oxydianaline hazards:

Acute toxicity, Oral (Category 3), H301

Acute toxicity, Inhalation (Category 3), H331

Acute toxicity, Dermal (Category 3), H311

Skin Sensitisation (Category 1), H317

Germ cell mutagenicity (Category 1B), H340

Carcinogenicity (Category 1B), H340

Reproductive toxicity (Category 2), H361

Short-term (acute) aquatic hazard (category 1), H400

Long-term (chronic) aquatic hazard (Category 1), H410

Graphite hazards: not a hazardous substance or mixture inline with (EC) No. 1272/2008

Molybdenum disulphide hazards: not a hazardous substance or mixture inline with (EC) No. 1272/2008

PTFE hazards: not a hazardous substance or mixture inline with (EC) No. 1272/2008

Residential Area Commercial Area Jubilee Site Boundary Duvelco Ltd: Emission Monitoring Point source emission to air Fugitive emission monitoring points at boundary line

EM1

20 1 2 KELBROOK GROVE

347250 11 Drawbridge 28 Caldon Canal

WB 21 Tow Path MP

31 N

Foundry Fire Hydrant 347200 120.5m LEEK ROAD 131.7m

Distance to residental

295m

Works

347150

LEEK ROAD 347100 Smithy

EM1 686

MELVILLE STREET

13

26 Distance to residental 686

347050

155m

BOTTESLOW STREET

14

672

2 to 6 to 2 672 29 23 50

12 CRESCENTHOWARD 658 300m 46 93 Distance to residental 17 91

347000 7 to 11

Issues 42 2 652

13 Timber Yard 1 11 12

19 29 644

to 5 to 2 50

23 LEEK ROAD

2 50 28

AMBASSADOR ROAD 388989 389039 389089 389139 389189 389239 389289 389339 389389

10 0 10 20 30 40 50 Produced on 19 February 2020 from the Ordnance Survey National Geographic Database and incorporating surveyed revision available at this date. This map shows the area bounded by 388939,346950 388939,347275 389553,347275 389553,346950 Metres

Ref FB3-Q4B

Form B3, Question 4B

There will be one point source emission to air at the proposed site.

Under normal operating conditions, emissions to air from all operations shall be free from droplets and visible fume or mist.

The concentration of pollutants in emissions to atmosphere from contained sources shall not exceed the agreed permit emission limit values (ELVs).

The company will record all inspections, tests and monitoring. All records will be retained by the company at the site for at least 2 years and shall be made available for examination by an authorized person.

In addition to the in-process controls, there will also be the following provisions for emission sampling:

 A TGN M1-compliant sampling access point  A ladder with a lockable gate to a safe working access platform with adequate working area

Adverse results from any observations, inspection or test shall be investigated immediately and in all cases shall be recorded. The company shall ensure that the cause has been identified, corrective action taken and action recorded.

Ref FB3-Q4A

Form B3, Question 4A

There will be a single point source emission to air from the abatement system. The output of the abatement system will be closely monitored by means of infrared sensors capable of detecting very low PPM of organic VOCs.

The consequences of failure of the abatement plant could lead to the release of VOCs to the environment and odour beyond the site boundary. Therefore, for the detection of VOCs, there will be two independent sensors measuring concentration. The emission limits are twofold; they are set to control process contribution to air quality, as well as being set to manage odour determination beyond the boundary of the site.

VOC emissions will be continuously monitored during plant operation hours, which will include failure alarms, to alert the process controls. This will lead to shut down of the process plant if required, to ensure no further emissions are generated until the situation has been remediated.

In addition to monitoring VOCs and air quality, there will be other parameters closely monitored on the emissions stack and the abatement system. These will include:

 Discharge velocity in the stack  Current monitoring of the fans and pumps, as are required within the system

Details relating to the management and minimisation of odour from the operations will be dealt with within a subject specific odour management plan.

There is a potential for fugitive emission to air by way of noise, dust and odour, all of which have been mitigated as per our environmental risk assessment. Monitoring will be conducted by trained staff at set points on the site boundary having regards to prevailing weather and wind direction for the presence of dust, odour and noise emission. A weather station will be installed two metres above the site’s roof level to log and record prevailing wind direction and speed.

Detailed proposals will be contained within the site’s environmental management system, including frequency of monitoring, trigger events location and responses.

In the event of an alleged fugitive emission, which is brought to the company’s attention by an employee or an external source, we would, after investigation, put in additional monitoring to assess the efficacy of mitigation being done and consider the need for any additional provision and react accordingly.

Detailed on the site plan (attached as document reference FB3-Q4A-Map) below, both point source emissions and fugitive emission monitoring points have been identified.

Ref B3-Q6A

Form B3, Question 6A – Describe the basic measures for improving how energy efficient your activities are

Duvelco Limited shall:

 Take appropriate measures to ensure that energy is used efficiently in our activities;  Review and record at least every four years whether there are suitable opportunities to improve the energy efficiency of our activities; and  Take any further appropriate measures identified by a review

We have broken down the measures for improving energy efficiency into four categories:

 Supply  Process  Other  Monitoring

By utilising these categories as a framework, the management of Duvelco will ensure that the energy efficiency of the operation is under constant scrutiny, implementing improvements wherever practicable and economically feasible whilst also adhering to the legislative reporting requirements required.

SUPPLY

 Half-hourly meters for supplies over 100kW  Purchase energy from green energy suppliers  Use renewable energy where feasible i.e. sun, wind  Take advantage of off-peak periods  Use of power inverters

PROCESS

 Secondary meters o Installed to breakdown where energy is being used o Specific areas of a building/site or large consuming pieces of plant. o Recovery of waste energy (e.g. heat) o Look at the classification of motors for efficiency age etc.  General

o Check for leaks - faulty steam traps, pipework flanges and joints. o Seal off redundant pipework reduce length of dead legs - avoid unnecessary heat losses.  Compressor costs o Switch off at the end of shift and over weekends. An idling compressor still uses energy o Perform regular leak tests

OTHER

 Recovery of waste energy (e.g. heat)  Replacement of plant and equipment nearing end of useful life, to improve efficiency  Building fabric has been assessed to look at air infiltration/draughts and insulation levels  Infrared thermometer used to identify hot spots  Motors and drives to be maintained, TPM (total productive maintenance) to be introduced  Introduce Variable Speed electric Drives (VSDs) where possible to reduce running costs  Invest to upgrade boilers depending on age  Sensor lighting and timers installed where possible  Energy saving lighting  Turning down thermostats, which leads to 10% savings  Power down policy in place of equipment/machinery  Only heat and cool areas where necessary. i.e. not unoccupied areas  Ensure pipes/tanks are fully insulated  BEMS (Building energy management system)  Communication – staff awareness  Switch off policy  Reports and procedures to take action  Minimise the flow of cooling water – Most processes use cooling water that requires to pump the water around the cooling circuit. Minimising the flow of cooling water may save energy.  Cool water to an appropriate temperature - Refrigeration chillers, used to cool water, are big users of energy. Reduce costs by cooling water no lower than the required temperature.  Buy energy saving equipment. When buying new equipment, make sure they are designed to conserve energy  Process optimisation

MONITORING

 Smart meters o Gas and electricity meters expressed in energy, carbon & financial terms o Display instantaneous energy demand o Communicate directly with the supplier o No more estimated bills or meter readers  Meters & sub meters o Data collection o AMR & data transfer  Software analysis/reporting o Instant analysis of peaks o Trends and actions  Set energy target o Benchmarking o Actions to address issues o Continually amended to reflect improvements

Ref B3-Q6B

Form B3, Question 6B

As this is a simple installation, there will be changes to the amount of electrical energy consumed once operations begin as presently, there is no existing commercial production activity on the site.

Other than indirect electrical heating and cooling in the process, as is required for the chemistry of small, batch reactions, there will be no change to the energy in terms of input and output e.g. the site will not use a fossil- fuelled steam generation plant, or gas turbine to generate electricity.

The process is not compatible with continuous production and has to be conducted in line with the permit application to ensure a high quality product is produced, therefore the operation meets the basic requirements of the sector.

Ref B3-Q6C

Form B3, Question 6C – Describe the specific measures for improving how energy efficient your activities are

Duvelco Limited will:

 Purchase energy form green energy suppliers

 Achieve accreditation to ISO 14001 o This will ensure a positive culture towards energy saving o Using the objectives to set energy targets and corrective active and ensuring all legislation is adhered to. (ESOS audits will be performed as part of the group submission with individual recommendations for energy saving) o The following steps will be taken to obtain accreditation. 1) Obtain management support 2) Identify legal requirements 3) Define EMS scope 4) Define EMS procedures and processes 5) Implement EMS procedures and processes 6) Perform training and awareness 7) Choose a certification body 8) Operate the EMS; measure and keep records 9) Perform internal audits 10) Perform management review 11) Implement corrective action 12) 1) Certification audit – Stage 1 12) 2) Certification audit – Stage 2

 Improvements in maintenance for reducing the energy used o Introduce a system/schedule for total preventative maintenance (TPM) with use of: . Check sheets . Daily progress meetings . Monthly energy meeting o Introduce a method for reporting maintenance faults via the internet which is real time o Regular check to be performed for leaks - faulty steam traps, pipework flanges and joints. o Seal off redundant pipework reduce length of dead legs - avoid unnecessary heat losses. o Add all plant and equipment on an asset register to monitor end of useful life and replace when they become ineffective, reducing efficiency. o Procedure outlining the full system of maintenance including: . Details of the TPM system

. Who is responsible for the TPM schedule . How the maintenance is monitored to predict issues . How the maintenance reporting system is used. . Equipment power down. . Training requirements

 Variable speed electric drives (VSDs) where possible to reduce running costs. o Preventive maintenance schedule to minimise the risk of failure of equipment. Including troubleshooting, repair, lubrication, inspection, etc. enabling the equipment to be preserved, and ensuring the drivers stays efficient. Use the information to have a lessons learned when failures occur so that breakdowns and inefficient drivers can be predicted

 Maximising the efficiency of installed compressors o Purchase the most up to date compressor considering the following: . High performance . Maximum energy efficiency variable speed version . low energy consumption with high efficiency . low maintenance, low service . low noise level . Quick easy access to belts, filters & dryer . level indicator . Full control - intuitive smart controller

o Once it is fully commissioned . Switch off at the end of shift and over weekends. An idling compressor still uses energy. . Perform regular leak tests via the TPM . Action identified issues via the maintenance reporting system. . Action identified energy wasting via the maintenance reporting system.

 Building fabric to control wasted heat and energy reduction o Draughts to be repaired o Pipes/tanks to be fully insulated o Sensor lighting and timers installed

 Procedural initiatives o Power down of equipment/machinery when not in use. o Switch off policy in place for all equipment PCs and lights o Communication – staff awareness on energy saving methods and those procedures to control energy usage.

 Process optimisation o Apply the latest technology and equipment for the production processes to increase efficiency and energy o Avoid unplanned downtime

 Energy Monitoring o Gas and electricity meters shall be monitored o Monthly usage is monitored for use in: . Costings . Usage . Management review – Target setting . Continual improvement . Determine carbon foot print

Form B3, Question 6D – Explain and justify the raw and other materials, other substances and water that you will use

The process itself dictates the nature of the raw material and then end product specification, namely high grade polyimides demands a high level purity specification. The process is chemistry-led and quite simply, does not work and/or deliver a high grade product substituting any of the raw material constituents as detailed within the application.

No other materials are used in the manufacturing process, only nitrogen gas for purging and dilute acid within a wet scrubber.

Ref B3-Q6E

Form B3, Question 6E – Describe how you avoid producing waste in line with Council Directive 2008/98/EC on waste

Duvelco Limited will use the waste hierarchy model, as can be seen in Figure 1, to manage its waste in terms of what is best for the environment. As part of the company’s management system, Duvelco will consider the most appropriate management options for any waste produced. The company will document its duty of care to ensure that all reasonable steps have been taken to ensure waste is kept safe and that it is only removed from site, where it cannot be prevented, by an Environment Agency authorised company, to a place authorised by the Environment agency to dispose of or recycle that type of waste.

Fig 1: Using the waste hierarchy model to control, manage and remove waste created by Duvelco Limited. Where possible, the company will use waste prevention techniques such as using less material in design and manufacture, keeping products for longer and re-use of materials.

By utilising high quality, high purity raw materials and optimisation of the production process, waste product production will be minimised.

The separation of solvents from product will be done with the maximum efficiency to prevent a contaminated waste stream that cannot easily be re- processed at a later date. The solvents themselves will be recycled and re- used in the process to minimise solvent waste.

Any material that is produced out of specification will be, wherever possible, blended overtime with additional product and sold as a lower grade.

All waste streams that can be re-used or recycled have been addressed in the proposed process and the residuals from the solvent recovery process and abatement plant will be directed to waste treatment outlets where possible and, as a last resort, will be disposed of as hazardous waste.

Wherever possible, raw material containers such as fibre kegs and notionally empty drums/IBCs will be recycled.

The administrative office supporting the company production activity in line with the EMS will wherever practicable and feasible work on a paperless basis to minimise the non-production of waste generated.

Form B3, Question Appendix 2, Question 1 – Chemicals

 The Duvelco Limited process:

Duvelco will manufacture polyimides:

4’4-ODA and PMDA will be reacted in reaction vessels (up to 1500 litres capacity). Filler additions may be incorporated into the product at various stages of manufacture; filler and raw materials are detailed in Question 3C, Table 5.

Up to three reaction vessels may be installed in the installation to prevent cross-contamination of products.

 All reactions, including significant side reactions (that is, the chemistry of the process) are shown in the diagram at the end of this section.

 Any emission from the process would be captured by the extraction within the facility, which will all be discharged through a wet scrubber and carbon adsorption filter, in line with Best Available Techniques.

As detailed in our BAT analysis (FB3-Q3A-EPR4.01 and FB3-Q3A- EPR4.02) and the BREF (FB3-Q3A), a full HAZOP team will assess the whole process to ensure systems are put in place to minimise the possibility of any situation which could lead to a release of emissions.

Systems will be put in place to ensure vessels cannot be overfilled before an operation is started along with a fully automated PLC controller, which will stop the reaction should any parameter be out of a pre-determined limit. The reaction is not self-sustaining and can be shut down at any time.

This system will be operated by trained personnel, in line with the written environmental management system. A number of safe operating procedures and systems of work will be in place, outlining the company’s mechanism for the control of emissions.