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Decision Document for PPC Part B Activities

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Decision Document for PPC Part B Activities SCOTTISH ENVIRONMENT PROTECTION AGENCY Operational Quality Manual Form No: IED-T-DAT POLLUTION PREVENTION AND CONTROL (SCOTLAND) REGULATIONS 2012 Page no 1 of 12 Derogation Assessment Template Issue No: 1 Petroineos Manufacturing Scotland Ltd Grangemouth Refinery Grangemouth PPC/A/1013141 Derogation Assessment for Sulphur Dioxide from Petroineos Manufacturing Scotland Ltd Final outcome of Derogation SEPA minded to approve Derogation subject to PPD Assessment consultation. 1. Non-Technical Summary Introduction Petroineos Manufacturing Scotland Ltd, the owner and operator of the oil refinery in Grangemouth, have applied to SEPA for a time limited derogation for two of the 58 requirements of the Refining BAT Reference (BREF) document, published by the European Bureau in 2014. This decision document sets out the steps that SEPA have followed in assessing what the application would mean for Scotland’s Environment, People and Economy, and determining whether the request is considered to be acceptable. BREF Process BREF documents are published on an eight year cycle, with sites having four years to comply with the requirements, following publication. The BREF document sets out the techniques and technologies that are considered to be the most effective at reducing emissions for a specific industry. Following the BREF issue, SEPA reviews the site’s Pollution Prevention and Control permit to determine the necessary changes to deliver the updated requirements. The review process involves detailed examination of current and proposed operations and the drafting of changes to the permit. In the event that a site cannot comply with any of the BREF requirements a derogated limit can be requested. This requires significant discussion and agreement from SEPA that it is an acceptable route. There are strict legal tests that must be passed for a derogation to be acceptable. These are all detailed below, with the Primary tests being that no Environmental Quality Standards are being breached and that the Environment is protected. Following agreement from SEPA, a Cost Benefit Assessment is completed, using a Spreadsheet tool developed by the UK Environmental Regulators. This is freely available on the Gov.UK website. If the costs exceed benefits then SEPA will assess the application at a Derogation panel to ensure consistent and rigorous testing is applied. If the panel approves the application then the Decision Derogation Assessment Template Form: : IED-T-DAT Page no: 1 of 12 IS DOCUMENT IS UNCONTROLLED WHEN IN HARD COPY OR STORED IN ANY ELECTRONIC FORMAT OTHER THAN IN THE BUSINESS MANAGEMENT SYSTEM Permit Number: PPC/A/1013141/CP01 Document and relevant section of the proposed permit will be placed on SEPA’s website for 30 days for public comment. These comments are then reviewed and taken into account before the permit variation may be issued. Petroineos permit review SEPA have been reviewing the entire Pollution Prevention and Control permit of the site against the BREF Requirements. The site will comply with 56 (excluding those that are N/A) of the BREF Requirements by 28 October 2018. Petroineos are currently investing across large areas of the site to improve operations. This has been reflected in a recent improvement in the SEPA Compliance Assessment Scheme rating of the site to Broadly Compliant. The reviewed permit will include reduced Emission Limit Values (ELVs) for air and water emissions, improved data gathering and reporting measures and will result in a marked reduction in combustion emissions to air of NOx, SOx, Particulates and Carbon Dioxide. Derogation application The site is applying for derogation from the requirements to reduce Sulphur emissions to air from combustion units and the Fluidised Catalytic Cracking Unit (FCCU). These two emissions are dealt with separately by the BREF, but are the same substance, Sulphur Dioxide. The detail of the application is set out below, but in summary there are three time limited parts to the derogation: 1. Conversion of large combustion units from gas and oil firing to gas only in April 2019. 2. Treatment of gas to remove Sulphur and cessation of remaining oil firing by April 2023. 3. The continued use of the FCCU in its current form until 2026 (the next BREF review). SEPA Assessment SEPA have carried out a rigorous assessment to firstly establish whether a derogation would be legally permissible and then to complete a thorough Cost Benefit Analysis. SEPA have concluded that no Environmental Quality Standards will be breached, with emissions falling, a high level of protection will be maintained and that the site meets the technical characteristics test for derogation. The CBA concluded that costs would exceed benefits by £310 million. Environmental Impact Sulphur Dioxide emissions will continue their downward trend of recent years following the Tail Gas Treatment Unit upgrade of 2013, flaring reductions in 2017 and a large gas conversion project in April 2018. Sulphur Dioxide emissions from combustion are predicted to fall by a further 68% by Mid-2019 and by another 25% of 2018 emission levels by 2023. This is expected to allow the Air Quality Management Area in Grangemouth to be lifted once sufficient data is available (typically three years). NOx, Particulate and Carbon Dioxide emissions will also see significant reductions. Conclusion SEPA are minded to grant the time limited derogation and so have proceeded to the public consultation step of the process. Derogation Assessment Template Form: : IED-T-DAT Page no: 2 of 12 THIS DOCUMENT IS UNCONTROLLED WHEN IN HARD COPY OR STORED IN ANY ELECTRONIC FORMAT OTHER THAN IN THE BUSINESS MANAGEMENT SYSTEM Permit Number: PPC/A/1013141/CP01 2. Basic Information BREF Refining of mineral oil and gas BAT Conclusions reference number and date of publication 2014/738/EU, 28/10/2014 BAT Conclusions compliance date 29/10/2018 Associated derogations at Installation None 3. Derogation Description Derogation from the BAT-AEL for Sulphur Dioxide from oil refining activities. Short Description The operator has requested derogation from compliance with the BAT Conclusion No. 26 for SO2 emissions to air from the regenerator in the catalytic cracking process and BAT Conclusion No. 36 for SO2 emissions to air from the combustion units. The proposed Derogation comprises three parts: Part Derogation detail Duration BAT-AEL ELVs 1 Derogation on converting heaters on 6 months BAT 36 Currently Crude Distillation Unit (CDU2) and achieving ELV of Vacuum Distillation Unit (VDU2) from BAT-AEL is 35 - 1000mg/Nm3. oil to gas firing. This is requested by 600mg/Nm3 for the operator due to the major Multi fuel fired Propose leaving turnaround schedule and associated (MFF) plant (gas ELV unchanged costs in changing this and is and liquid fuels). until May 2019, considered a straightforward upgrade, when gas fired forming a necessary step towards derogated ELV of achieving Best Available Techniques 500mg/Nm3 would (BAT). apply. 2 Derogation on sulphur removal from 4.5 years BAT 36 Current ELVs the fuel gas used across the site. It is across the site are proposed that this will be a part of the BAT-AEL’s 5 - up to 1700mg/Nm3 CDU4 (the construction of a brand new 35mg/Nm3 for for Multi fuel fired distillation unit) / Repositioning project gas fired plant plant and (refurbishing existing equipment). A and 35 - 500mg/Nm3 for Cost Benefit Assessment (CBA) has 600mg/Nm3 for gas fired units. been completed for this element. MFF plant. It is proposed to update the MFF ELV to 1000mg/Nm3 and leave existing gas fired ELVs unchanged at 500 mg/Nm3. Derogation Assessment Template Form: : IED-T-DAT Page no: 3 of 12 THIS DOCUMENT IS UNCONTROLLED WHEN IN HARD COPY OR STORED IN ANY ELECTRONIC FORMAT OTHER THAN IN THE BUSINESS MANAGEMENT SYSTEM Permit Number: PPC/A/1013141/CP01 3 Derogation on abatement of sulphur 8 years BAT 26 No existing ELV. from the Fluidised Catalytic Cracker Unit (FCCU). A CBA has been BAT-AEL 100 - Propose monthly completed for this element. 1200mg/Nm3for ELV based on existing current units/partial performance at combustion 1600mg/Nm3. Duration of Derogation The proposed derogation is time limited in three steps, as detailed above to 28 October 2026 (the time of the next permit review). 1. 29 April 2019 2. 01 January 2023 (except CDU 3, with a date of 29 April 2023) 3. 28 October 2026 4. BAT Assessment Is the proposed derogation BAT? Considerable discussion has taken place with the Operator on the determination of site specific BAT. For Part 1 of the proposed Derogation site specific BAT is to use gas firing only on CDU2 and VDU2 This will be achieved within a six month timescale. For Part 2 site specific BAT is to achieve the derogated ELV of 500mg/Nm3 on all plant firing Refinery Fuel Gas (RFG) and 1000mg/Nm3 on all plant firing Oil and Gas until 2023. For Part 3 site specific BAT is to continue the current operation of the FCCU with the imposition of an ELV at 1600mg/Nm3. 5. Legal requirements Environmental Quality Standards (EQS) The Refinery is located within an AQMA, designated for breaches of the Sulphur Dioxide AQS of 266ug/m3 (15 minute mean). The air quality has improved significantly since a major upgrade to the Refinery’s Sulphur treatment plant in 2013. Falkirk Council currently do not propose to revoke the AQMA. Mandatory Emission Limit Values The mandatory minimum emission limit values in Annex V of the IED apply to this release but the proposed emission does not exceed the Annex V limits of Sulphur Dioxide. Derogation Assessment Template Form: : IED-T-DAT Page no: 4 of 12 THIS DOCUMENT IS UNCONTROLLED WHEN IN HARD COPY OR STORED IN ANY ELECTRONIC FORMAT OTHER THAN IN THE BUSINESS MANAGEMENT SYSTEM Permit Number: PPC/A/1013141/CP01 No Significant Pollution/High Level of Environmental Protection The Refinery is not causing significant pollution.
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