Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 1 of 20

Superglass Insulation Limited Stirling Operator Initiated Permit Variation PPC/E/20021

CONTENTS

1 NON TECHNICAL SUMMARY OF DETERMINATION...... 3 2 EXTERNAL CONSULTATION AND SEPA’S RESPONSE ...... 3 3 ADMINISTRATIVE DETERMINATIONS...... 5 4 INTRODUCTION AND BACKGROUND ...... 5 4.1 Historical Background to the activity and application/variation...... 5 4.2 Description of activity...... 6 4.3 Outline details of the Variation applied for/proposed (delete if not dealing with a variation)6 4.4 Guidance/directions issued to SEPA by the Scottish Ministers under Reg.60 or 61...... 6 4.5 Identification of important and sensitive receptors...... 7 5 KEY ENVIRONMENTAL ISSUES...... 7 5.1 Summary of significant environmental impacts ...... 7 5.2 Implications of the Variation on - Point Sources to Air...... 7 5.3 Implications of the Variation on - Point Source Emissions to Surface Water and Sewer...... 8 5.4 Implications of the Variation on - Point Source Emissions to Groundwater ...... 9 5.5 Implications of the Variation on - Fugitive Emissions to Air...... 9 5.6 Implications of the Variation on - Fugitive Emissions to Water...... 10 5.7 Implications of the Variation on - Odour ...... 10 5.8 Implications of the Variation on - Management ...... 10 5.9 Implications of the Variation on - Raw Materials ...... 11 5.10 Implications of the Variation on - Raw Materials Selection...... 11 5.11 Implications of the Variation on - Waste Minimisation Requirements ...... 11 5.12 Implications of the Variation on - Water Use...... 11 5.13 Implications of the Variation on - Waste Handling ...... 12 5.14 Implications of the Variation on - Waste Recovery or Disposal ...... 12 5.15 Implications of the Variation on - Energy...... 12 5.16 Implications of the Variation for - Accidents and their Consequences...... 14 5.17 Implications of the Variation for - Noise...... 14 5.18 Implications of the Variation for - Monitoring ...... 15 5.19 Implications of the Variation for - Closure ...... 16 5.20 Implications of the Variation for - Site Condition Report ...... 16 Permit (Application) Number: Applicant:

5.21 Implications of the Variation for - Consideration of BAT ...... 16 6 OTHER LEGISLATION CONSIDERED...... 16 7 ENVIRONMENTAL IMPACT ASSESSMENT AND COMAH ...... 18 8 DETAILS OF NON STANDARD PERMIT CONDITIONS...... 18 9 EMISSION LIMIT VALUES OR EQUIVALENT TECHNICAL PARAMETERS/ MEASURES...... 19 10 PEER REVIEW ...... 20 11 FINAL DETERMINATION...... 20 12 REFERENCES AND GUIDANCE ...... 20

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 2 of 20 Permit (Application) Number: Applicant:

1 NON TECHNICAL SUMMARY OF DETERMINATION

The purpose of the PPC permit variation application is to capture Superglass’s planned upgrades to the factory in Stirling. Details of upgrades and changes are as follows:

 Replacement of the existing two furnaces with one larger single furnace resulting in reduced emissions and improved energy consumption. The furnace and equipment has been specified to be industry leading, BAT and comply with regulatory emissions, most notably NOx emissions which will become tighter from 2020 as a result of BREF and BAT-C Implementation for the glass industry.

 The existing furnaces are both 90 tonnes per day capacity (total 180 tonnes / day oxy: gas fuel) and coming to the end of their operational lives. Currently only one furnace is operational with the other mothballed for budget reasons in 2016.

 The new furnace (capacity of 187 tonnes per day on oxy:gas fuel) will require to be located in a new purpose built building adjacent to the existing furnace building.

 The company propose to replace all downstream equipment post furnace (referred to as Lines 1 and 3). This equipment includes new forehearth, curing ovens, trimming, chopping and wrapping machinery on both lines. Improved reliability and control will significantly improve energy performance and reduce waste generation.

 Superglass propose to remove from the permit several roof stacks previously made redundant as part of historic works. A single stack for white wool dust abatement will be relocated and served by a new higher performance dust abatement system.

 Removal of a submerged liquid tank used for the Line 3 scrubber system, replaced with an above ground system.

The upgrade to the installation will modernise all processes in line with BAT requirements for the industry. Environmental impact from the upgrade is not considered to be of high risk with production (glass melt tonnes /day) in line with existing permitted volumes. Upgraded technology and process equipment are considered to improve overall environmental performance and emissions from the process are anticipated to remain compliant with current and future industry BREF limits.

Glossary of terms

BAT - Best Available Techniques BAT-C - Best Available Techniques – Conclusions (inc. emissions standards) BREF - Best Available Techniques Reference Document CO - Coordinating Officer ELV - Emission Limit Value

2 EXTERNAL CONSULTATION AND SEPA’S RESPONSE

Is Public Consultation Required - Yes

Advertisements Check: Date Compliance with advertising requirements Edinburgh Gazette 12/03/2019 Yes.

Stirling Observer 13/03/2019 Yes.

No. of responses received: Zero

Summary of responses and how they were taken into account during the determination:

N/A

Is PPC Statutory Consultation Required – Yes

Food Standards Agency: Response received 21/02/2019: ‘Food Standards Scotland considers it unlikely that there will be any unacceptable effects on the human food chain from the emissions from this installation’.

Stirling Health Board: No response received.

Stirling Local Authority: Response received 14/03/2019: No concerns, welcome reduction in emissions including NOx, PM and Mass Emissions.

Scottish Natural Heritage (PPC Regs consultation): Response received 21/02/2019: ‘not aware of any current pressure from emissions on the designated sites you list below. We are satisfied that SEPA will, at this stage, identify any other impacts upon the natural heritage and address them without further reference to us but if subsequent assessment shows a likely significant effect on any SAC or SPA or likely damage to the natural features of any SSSI, you will consult with us as required by conservation statute’.

Discretionary Consultation - No

Enhanced SEPA public consultation - No

‘Off-site’ Consultation - No

Transboundary Consultation - No

Public Participation Consultation - Yes

 An application requesting a substantial change to a part A Installation

STATEMENT ON THE PUBLIC PARTICIPATION PROCESS The Pollution Prevention and Control (Scotland) Regulations 2012 (schedule 4, para 22) requires that SEPA’s draft determination of this application be placed on SEPA’s website and public register and be subject to 28 days’ public consultation. The dates between which this consultation took place, the number of representations received and SEPA’s response to these are outlined below. This statement should not be deleted if PPD applies

Date SEPA notified applicant of draft determination 08/08/2019

Date draft determination placed on SEPA’s Website tbc

Details of any other ‘appropriate means’ used to advertise n/a the draft. Seek advice from the communication department

Date public consultation on draft permit opened tbc

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 4 of 20 Date public consultation on draft permit consultation tbc closed

Number of representations received to the consultation tbc

Date final determination placed on the SEPA’s Website tbc

Summary of responses and how they were taken into account during the determination: tbc

3 ADMINISTRATIVE DETERMINATIONS

Guidance Notes - Where SEPA is happy to accept the proposal as detailed in an application please indicate this to be the case.

Determination of the Schedule 1 activity

No change

Determination of the stationary technical unit to be permitted:

Change from two Oxygas-fired melt tanks with a combined total capacity of 180 tonnes / day to a single melt tank with a capacity of 187 tonnes / day.

Determination of directly associated activities:

No change

Determination of ‘site boundary’

No change

4 INTRODUCTION AND BACKGROUND

4.1 Historical Background to the activity and variation.

Superglass have operated in the same site since 1987, initially under an IPC permit and since 2005 a PPC/A activity: Section 3.3 ‘Manufacturing of glass or glass fibre in an installation with a melting capacity exceeding 20 tonnes per day’.

The company manufactures yellow glass fibre (cured with resin) and white glass fibre insulation on two ‘yellow wool’ lines and one ‘white wool line’. Involving the fiberising (including the application of resin to the fibre), forming and curing of the yellow wool.

The site has historic record of poor compliance and complaints however change of management in 2012 and new ownership in 2016 has seen the performance of the installation improve and the site has benefited from significant investment.

Compliance with permit requirements since 2013 have been assessed as ‘Good’ or ‘Excellent’.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 5 of 20 Primary emissions from the installation include air emissions from the combustion process associated with the furnace(s), air emissions from the glass fibre processing, effluent from the manufacturing process, waste production and noise.

Emissions to air are from the Line 1 and Line 3 curing ovens and yellow wool productions lines, these are abated by three Wet Electrostatic Precipitators (WESP’s) EP1, EP2 and EP3.

Emissions from the furnaces are abated by a Dry Electro Static Precipitator (DESP) EP19.

Dust emissions from the Whitewool forming chamber are abated by a wet scrubber system (EP16) (EP9 – not in use).

Water emissions are collected in an effluent treatment system where solids are removed by screw press and recycled into the feedstock. Discharges of effluent are made to sewer via trade effluent consent.

In January 2019 the Operator invested in a significant upgrade of the plant, (under the title of New Horizons to which this variation application represents). Pre application discussions were made with SEPA from the outset.

The project includes:  A new furnace and associated equipment (i.e recuperator and batch feed system) housed in new purpose built building. The furnace shall replace the existing two furnaces and be abated by the existing DESP system.  Replacement off all downstream equipment on Lines 1 and 3 including new forehearth, curing ovens, trimming, chopping and wrapping machinery on both lines.  Replacement Whitewool forming hood increasing production capacity and new scrubber abatement system including and stack (new emission point). Removal of existing Whitewool scrubber system.  Removal of a number of redundant stacks no longer required as part of the upgrade, these include emergency stacks (as listed in permit). Stacks 1,2,3 and 15 shall be physically removed. Stack 4,5,6 and 9 shall be capped and made redundant.

4.2 Description of activity Manufacture of glass fibre insulation.

4.3 Outline details of the Variation applied for.

 Replacement of the existing two smaller furnaces with a large single furnace (emission point and emission abatement is the same).  Changes to Line 3 Whitewool abatement system (dust scrubber) and in Table 3.3 replacement of existing Emission Point 9 with a proposed new Emission Point ‘20’.  Update to groundwater monitoring Table 3.2 to reflect lost borehole number 105.  Removal from the permit of reference to emergency stacks 1,2,3,4, 4,5 and 6 (Table 3.6 and 3.7).  Update to emissions to air Table 3.5 to reflect new BREF limits, specifically NOx limits for EP19 furnace emissions.  The site plan shall be updated.  The emission point plan (appendix 2) shall be updated.

4.4 Guidance/directions issued to SEPA by the Scottish Ministers under Reg.60 or 61. None.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 6 of 20 4.5 Identification of important and sensitive receptors  Air, odour and noise emissions at nearby residential housing.

5 KEY ENVIRONMENTAL ISSUES

Summary of significant environmental impacts

5.1 Implications of the Variation on - Point Sources to Air

The proposed variation will result in the following changes to permitted emission points;

Current Emission Proposed Changes to Status Sources Emission Sources Stack 19: Glass Melt No Change (existing DESP 1x DESP Abatement furnace(s) . abatement). EP1: Line 1 Production Line (Combined forming, 1 x WESP Abatement No Change curing and curing emissions) EP2: Line 1 & 3 Curing 1 x WESP Abatement No Change Ovens EP3: Line 3 Production Line (Combined forming, 1 x WESP Abatement No Change curing and curing emissions) Stack 16: Line Whitewool forming chamber. 1 x Wet Scrubber Abatement No Change

Capped. Line 3 Whitewool stack will be Stack 9: Line 3 Whitewool 1 x Wet Scrubber Abatement served by new proposed ‘Stack forming chamber, 20’ including a new particulate scrubber system. Stack 3: Line 1 Forming Removed chamber Stack 4: Line 1 forming Emergency Stacks in event of EP1 WESP Capped chamber breakdown. Stack 12: Line 1 forming Capped chamber Stack 13: Line 1 Cooling No Change – emergency stack Air Stack 5: Line 3 Forming Capped chamber Stack 6: Line 3 Forming Capped chamber Emergency Stacks in event of EP3 WESP Stack 14: Line 3 Cooling breakdown. No Change – emergency stack Air Stack 15: Line 3 Forming Removed Chamber Both Removed - Stack 1: Furnace No.1 The new furnace will use Stack 19 as Emergency Stacks in event of DESP its abort system (a by-pass breakdown. line will be installed) and so Stack 2: Furnace No.3 dedicated emergency stacks will no longer be required.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 7 of 20 Changes to existing emission stacks will result in an overall reduction in the number of stacks at the installation.

Due to changes in the existing abatement by pass system for the furnace Stack 1 & 2 emergency stacks will be removed due to a DESP bypass system which now utilises the existing EP19 stack.

Emergency stacks 1, and 15 shall also be removed, these were made redundant in historic works and are now being removed from the permit. Emergency stacks 4, 5 and 6 shall be capped and unused.

Line 3 Whitewool scrubber system (stack 9) shall be capped and replaced by a modern abatement system and relocated to another location within the factory building. As a result a new emission point stack shall be required at this location and is proposed to be labelled ‘Stack 20’.

An Air Quality Assessment was submitted as part of the variation to consider particulate emissions from the new emission point (Stack 20 forming chamber) in aggregation with existing emissions with regard to particulate matter. The assessment concluded that based on predicted concentrations emissions from the installation would not result in breaches of air quality standards at sensitive receptors.

BAT conclusions 2012 have required BAT-AEL’s for monitoring of volatile organic compounds in emissions from forming and coating emissions. This was not an existing requirement, permit monitoring requirements have been updated accordingly. Current monitored VOC’s emissions comfortably comply with ELVs.

Overall emissions quality from the installation are predicted to improve considerably with regard to SOx and NOx improvement due to the state of the art furnace complying with BAT and low NOx performance.

The current permitted NOx emission limit value for the emissions from the furnace(s) is 1500mg/m3.

New BREF limit for NOx emissions from melting furnaces (mineral wool sector) is <500mg/m3 (and <0.5kg/tonne melted glass), Limits must be achieved at permitted installations by 2020. The new replacement furnace proposed in the variation is specified to meet a limit of 450mg/m3. This performance criteria would result in an overall reduction in emission of NOx to <0.5kg per tonne of glass melted. The permit shall be varied as part of this exercise to reflect these improved Emission Limit Values.

The operator has demonstrated that the existing abatement systems are sized appropriately to continue manage the emissions from the replacement furnace.

The DESP was originally specified to for two 90 tonne / day furnaces, and was designed to cope with a maximum total exhaust gas volume, including quenched air, of 8,700 Nm3/hr at 375C.

The maximum total exhaust gas volume, including quenched air, from the new furnace will be 4,800 Nm3/hr at 380C. This figure was calculated for emissions after 8 years, to allow for some leakage air as the furnace ages. A lower flow rate helps the performance of the DESP (provided the temperature is maintained). At lower flow rates the particulate has longer time in the vicinity of the electrostatic plates.

5.2 Implications of the Variation on - Point Source Emissions to Surface Water and Sewer There should be no implications on emissions to surface water or sewer as a result of the proposed variation. Effluent from the process shall continue to be collected in the sites sealed drainage system and diverted to the onsite effluent treatment plant for solids removal. The treated effluent is then reused throughout the plant as further process water for activities such as ‘impact jets’ in the abatement systems or for resin make up.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 8 of 20 Excess effluent is discharged to sewer via a trade effluent discharge.

Since 2016 Superglass have carried out significant improvements to water efficiency at the site to considerably reduce consumption of process water. In 2017-18 Superglass reported that over all fresh water usage was reduced by 40% and effluent discharge volumes were reduced by 58%.

The proposed variation does not anticipate any significant increase in water usage or effluent production and the current effluent treatment plant shall have capacity to deal with all relevant arising’s.

5.3 Implications of the Variation on - Point Source Emissions to Groundwater There will be no point source emissions to groundwater as a result of the proposed variation.

In line with BAT a submerged effluent storage tank (containment) has been decommissioned as part of the upgrade to the Line 3 dedicated dust abatement system. The submerged tank which was difficult to monitor and inspect and test (as per BAT) has been replaced as part of a new particulate scrubber system relocated to another part of the factory, the replacement effluent storage tank shall be above ground and eliminate any potential discharge to groundwater that would be difficult to detect.

The permit authorisation requires annual groundwater sampling via a suite of boreholes located around the installation boundary. The operator has indicated that a borehole location may be lost as a consequence to the upgrade works and is in discussions with SEPA on the appropriate replacement requirement. Potential impacts on emissions to groundwater shall continue to be monitored and reported to SEPA by the operator.

5.4 Implications of the Variation on - Fugitive Emissions to Air The proposed variation shall not result in negative impact on potential fugitive emissions to air.

Dust Management: The primary risk of fugitive emissions to air from the process is the cause of dust escaping from raw material delivery, handling and use. BAT states that handling of raw materials should prevent material loss by employment of closed conveyors and closed feeder screws, these are currently used at the site to transport bulk materials to the furnace. The operator reports that the distance traversed by the conveyor system shall be reduced due to the location of the new furnace building in closer proximity to the existing batching plant.

As per BAT raw material handling in the batching process has the ability to moisten the batch if required, and glass cullet is specified from customers to be moistened before delivery to Superglass, this results in reduced dust and diffuse emissions to air.

BAT states that a negative pressure on the furnace provides an inward draw from the batching materials and control fugitive emissions. Superglass confirm that the new furnace shall operate to the same specification of existing furnaces of negative pressure for diffuse emission control and also improved NOx emissions.

Volatile Emissions: BAT states that gaseous emissions from storage and handling of volatile raw materials should be prevented by use of insulated tanks (temperature control). Phonelic resin is reported as the only volatile raw material and is stored in a lagged tank for this purpose.

In line with BAT, an Inventory management system is in use at the site to monitor deliveries, storage and record consumption of materials to prevent losses and monitor for any process control losses.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 9 of 20 5.5 Implications of the Variation on - Fugitive Emissions to Water The proposed variation shall only result in a positive improvement to any changes to the liquid storage arrangements at the site, either storage volumes or locations. Potential spillages shall continue be controlled by appropriately sized bunding for substances such as Phenolic Resin and Ammonia Hydroxide. Bunds are inspected annually as part of the permit requirements. The ammonia tank is self-contained bunded tank with an alarm system to notify if ammonia enters the bund area.

Smaller quantities of more general use liquids such as mineral oils, lubricants and fuel oil are also stored in bunded areas within the factory building and served by impermeable surfaces.

Deliveries of raw material including liquids are overseen by procedures set up in the sites incident management system (IMS) to ensure against overfilling or spillages, all deliveries are supervised by a trained member of staff and recorded to ensure the IMS procedure is adhered to.

5.6 Implications of the Variation on - Odour There are no odour implications associated with the proposed variation. The site does not have a recent history of complaints related to odour and the changes proposed to the installation should not alter this performance.

5.7 Implications of the Variation on - Management The proposed variation is not considered to alter the management of the installation and relevant internal procedures shall be updated as required.

The management of the installation is considered be of high performance, with particular attention to environmental impact and compliance with the SEPA authorisation.

The company is found to comply with BAT standards which include the implementation of an Environmental Management System, Superglass achieved ISO EMS 140001 accreditation in 2017 and are audited periodically as part of this accreditation.

BAT states EMS features should include, ‘definition of an environmental policy’, ‘planning of procedures, objectives and targets in conjunction with financial planning and investment’, ‘training awareness and competence’, efficient process control’, maintenance procedures’ ‘continual improvement’

The company provides reference to the following documents - IMS Policy Statement, IMS Policy Manual, IMS Procedures including - competence training and awareness, preventative maintenance programme, efficient process control and management review.

Senior management further demonstrate a commitment to Environmental performance by the signing of a sustainable growth agreement with SEPA (in 2017) and strive to improve environmental performance with beyond compliance commitments in areas such as community engagement, innovation and transport.

The new Horizons Project initiating the requirement for the proposed variation is demonstration of significant reinvestment in the plant and is reported to be in the region of £37M over two years. The project included twenty four options being considered before the most cost effective and environmentally friendly option was pursued, including the replacement of two existing smaller furnaces with a larger single furnace to improve running costs and reduce environmental emissions.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 10 of 20 5.8 Implications of the Variation on - Raw Materials The proposed variation will not result in any new Raw Materials being utilised at the installation.

The main components for the glass fibre process are as follows:  Glass Blend: Glass Cullet (recycled glass), Soda Ash Borax, Manganese Dioxide  Resin Bland: Phenolic Resin, Ammonia Hydroxide, Ammonia Sulphate, Urea, Mineral oil, Silicone Oil

86% of the final product is sourced from Glass Cullet (recycled glass).

Fresh water is used in the process. Effluent waters are collected in onsite drainage and treated and reused (effluent treatment plant), some effluent is discharged via trade effluent consent to sewer. Fresh water is required due to evaporation losses in the process. Due to efficiency improvements water usage has reduced by 40% since 2016 and effluent discharge reduced by 58%.

5.9 Implications of the Variation on - Raw Materials Selection The proposed variation will not result in any new Raw Materials being utilised at the installation.

The process is considered to meet BAT in the raw material selection, such as; Use of Raw Materials and cullet with low levels of impurities: Glass cullet is specifically sourced that contains low levels of metals, chlorides and fluorides. Use of Fuels with Low Metal impurities: Natural Gas is the only fuel type used in the production process.

5.10 Implications of the Variation on - Waste Minimisation Requirements The proposed variation is considered to have significant benefit to waste minimisation, primarily from the upgrade of processing equipment on the manufacturing lines downstream of the furnace. Unplanned downtime in the process is anticipated to be reduced and will have a direct effect on scrap produce. New specification equipment includes modern trim saws resulting in a reduction of solid trim waste from 11% to 6%. The operator notes that trim wastes are recycled back into the process, although landfill disposal is still required for some waste and this will be directly saved from the new equipment.

5.11 Implications of the Variation on - Water Use The proposed variation is not anticipated to result in measured increases in water consumption.

Water is primarily used in the process to quench (cooling) rejected melt glass (cullet), maintenance / cleaning activities and operation of wet scrubber abatement equipment.

New equipment on site concerned with water use is the replacement White wool scrubber system. Specifications of the unit state a water recirculation rate of ~11m3/day which is a reduction from existing equipment currently operated at over 30m3/day.

The company complies with BAT where it is recognised in glass manufacturing most process waters can be ‘readily recycled or treated using standard techniques’. An onsite Effluent treatment plant is used to separate solids from effluent, treated waters are recirculated into the process. In recent years the company has significantly increased water monitoring measures to reduce consumption and wastage at the site. Water metering and quantification has found abatement equipment was historically operated at 137m3 / day. With trials and monitoring of

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 11 of 20 performances a reduction to 30-40m3/day is now achieved and new equipment replacing one system is anticipated to be :11m3 as mentioned above. These improvements have resulted in compliance with the sites SW discharge consent and cost savings from mains water consumption. Other improvements related to water use include training of staff to not use mains water for washing or other process activities when possible, the effluent capture and recirculation system can replace mains usage for works such as equipment wash downs for maintenance.

5.12 Implications of the Variation on - Waste Handling The proposed variation is not considered to affect the waste handling arrangements at the installation. The operator shall continue to use authorised Waste Management contractors for offsite disposal.

5.13 Implications of the Variation on - Waste Recovery or Disposal The proposed variation is not considered to negatively affect the waste recovery performance at the installation. The manufacturing process allows for the majority of recovered materials and wastes to be reintroduced for reprocessing.

BAT states that solid waste should be reduced by a combination of techniques including; Recycling of waste batch materials; Superglass report that waste batch materials and glass cullet from spillage, cleaning and maintenance are collected where practicable and reintroduced to the batching system. Minimise material losses during storage and handling of raw materials: Superglass report that bulk raw materials are stored in sealed silos or tanks and transferred by enclosed systems such as transfer belts and bucket elevators. During planned shutdowns melted glass is diverted to a ‘cullet capture system’ where it is cooled (quenched) and stored for reintroduction in to the furnace as ‘process cullet’ as a substitute for raw materials. The company utilises a cullet separator to separate quenching water from the glass. Waste water is recovered and used in a closed loop system.

Improved efficiencies in the new equipment are anticipated to result in a reduction 8,500 tonnes per year of process cullet, which requires re-melting and is considered less efficient than avoiding process cullet production.

5.14 Implications of the Variation on – Energy BAT for energy consumption in the glass industry includes the following techniques. i) Process optimisation through the control of the operating parameters. ii) Regular maintenance of the melting furnace. iii) Optimisation of the furnace design and the selection of the melting technique. iv) Application of combustion control techniques v) Use of increasing levels of cullet, where available and economically and technically viable. vi) Use of a waste heat boiler for energy recovery, where technically and economically viable. (not deemed viable). vii) Use of batch and cullet preheating where technically and economically viable. (not deemed viable).

The operator has demonstrated that energy savings in line with BAT are either already in practice or planned as a result of the proposed variation, as summarised below.

i) As with the current furnaces, Superglass monitors over 80 furnace parameters to ensure the furnace is operating at optimum levels. This information is reviewed daily.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 12 of 20 The proposed new furnace will feature the latest state of the art instrumentation including Carbon Monoxide laser to continuously monitor oxygen and carbon monoxide content of the exhaust gas stream and then automatically modify gas:oxygen (fuel) ratio to ensure the combustion is optimum.

ii) Current furnaces are subject to routine monitoring using third parity furnace specialist contractors. This includes both monthly thermographic surveys and monthly repair programmes. A similar planned maintenance regime shall be in place for the new furnace.

iii) With the option of a new build furnace the operator has taken the opportunity to consider the best design for the replacement furnace. Design features include;

Furnace geometry shall change from a 1:1 (square) aspect to a 2:1 aspect. This results in more energy efficient residence time of the flame due to better spread of the burners and heat saving required to achieve glass melt.

The 2:1 aspect also results in better defined glass melt zones to improve glass quality without excessive heating which would normally be dissipated within the forehearth and an efficiency loss.

The new design also considers a relocation of the waste gas exhaust port, due to the former designs being over sized and resulting in a cooling.

The company seeks to remain with an Oxy:Gas combustion design which is considered BAT with both energy efficiency and emissions benefits.

The new furnace will included electrical heating capability (electro-boost) which can provide up to 17% energy input the furnace when required. Electricity melting is considered 2.6 times more efficient than gas and does not produce direct emissions.

The company will also install electrically heated forehearths post furnace which are more efficient in heat transfer to glass than gas fired forehearths. The company anticipates energy savings of 12,840,000 kWh (76%) annually from this change.

iv) Combustion control techniques will include CO Laser monitoring oxygen and carbon monoxide in gas emissions. In addition a thermal imaging camera will be permanently installed to alert the operator of changing conditions more quickly and provide quicker response where necessary.

v) Superglass already report batch material including an industry leading 85% of recycled glass cullet used in their product. It is reported that cullet recycling saves 3% energy consumption for every 10% cullet use is increased, resulting in an approximate 25% energy saving over raw material batching only.

By installing a single large furnace over the existing design of two individual furnaces, the overall increase in efficiency is considerable at 35% reduction in energy consumption which equates to an annual saving of 32,475,000 kWh or 1,353kWh to 878 kWh for each tonne of glass melted.

Additional Energy Savings: The company also anticipates significant energy savings from the replacement of all ageing downstream preparation and packaging equipment Lines 1 and 3 (cold end) with more reliable and energy efficient modern equipment and methods. An example includes the two curing ovens for each manufacturing line will be replaced with modern items and result in annual savings of 9,870,000 kWh of gas. The company is also moving from compressed air to electrical power in packaging equipment (savings not yet quantified).

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 13 of 20 5.15 Implications of the Variation for - Accidents and their Consequences The company does not anticipate any detrimental impact on the potential for accidents from the proposed variation in relation to the permitted activity. The construction phase which is anticipated to take approximately 18 months will involve significant construction activities at the permitted installation, including construction of a dedicated building to house the furnace and replacement of both production line equipment. Documented procedures as part of the integrated management system have been updated to include necessary environmental aspects associated with the construction phase, such as construction material brought to site and required controls for safe handling and storage.

During the design of the new furnace a significant aspect has been addressed concerning the capture of molten glass from a catastrophic failure in the furnace. Current arrangements would result in any machinery or equipment sitting immediately below the furnace being destroyed in event of a furnace breach. The new design has incorporated a number of features to address this potential accident including; . The new furnace will be housed in its own dedicated building. . There will be no machinery or equipment located below the furnace. . A concrete bund will be installed below the furnace to capture any leakage of molten glass.

5.16 Implications of the Variation for - Noise The proposed variation considers the potential impact on noise and has been designed or controlled where applicable. Recent compliance assessment schemes have not indicated that noise emissions are generating complaint from the local community. The variation application states the following changes will have potential effects on noise emissions.

Replacing the existing two furnaces with larger single furnace which will be located in a new purpose built building acoustically insulated building.

Replacement of downstream equipment including ovens, saws, trimming mills, guillotine and packaging equipment located in the existing building.

A new whitewool scrubber abatement system, including extraction stack located in the downstream equipment building.

The removal of the external mechanical bucket elevator for batching located at the rear of the factory in close proximity to the nearest receptors.

Existing fans associated with the abatement systems and external conveyor systems for the batching plant will remain the same.

BAT states to reduce noise emissions in the glass industry include the following techniques. i) Make an environmental noise assessment to formulate a noise management plan as appropriate to the local environment. ii) Enclose noisy equipment / operations in a separate structure/unit. iii) Use embankment to screen the source of noise. iv) Carry out noisy outdoor activities during the day. v) Use noise protection walls or natural barriers between the installation and the protected area, on the basis of local conditions.

As part of the proposed variation the operator has considered BAT and these are summarised below;

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 14 of 20 i) As part of the permit requirements the company has completed a Noise assessment most recently in 2014 and is due to complete the next assessment in 2019. A desk based assessment of the proposed variations has considered the risks of noise from the proposed variations to be low.

The assessment planned for 2019 shall be used to verify the changes to the installation have not resulted in any significant impact on noise emissions from the installation or highlight potential unforeseen issues if applicable.

ii) The new furnace (including gas burners and air blowers) is to be located in a purpose designed building with thermally and acoustically insulated cladding. The operator reports the cladding panels achieving weighted sound reduction of 24dB. This is a considerable improvement to the existing furnace building which is located closer to the nearest receptors and includes only single skin cladding.

Downstream equipment shall be replaced and located within the existing building. The equipment is of modern design and the operator reports in the application it shall generate lower noise levels with all specified a maximum rating of between 70 and 80dB within the building. Reductions are considered to be due to electrical operation replacing several compressed air usage and hydraulic systems.

The roof covering the packaging area of the building has been covered with an insulated over cladding.

iii) Due to the proximity of a railway line on the immediate boundary between the installation and nearest receptors, the operator is unable to install or erect any screening.

iv) Noisy outdoor activities remain to only be completed during sociable hours, examples given are the operation of compactor and the deliveries of raw materials. Furthermore the operator has taken the opportunity to remove a mechanical batching elevator located on the boundary with the nearest receptors.

v) As per point (iii).

5.17 Implications of the Variation for - Monitoring The current emissions monitoring arrangements at the installation are compliant with Permit requirements and adhere to required frequencies and standards.

BAT states that monitoring techniques are (relevant to the installation); i) Continuous monitoring of critical process parameters to ensure process stability, e.g. temperature, fuel feed and airflow. ii) Regular monitoring of process parameters to prevent / reduce pollution e.g. O2 content of the combustion gases to control the fuel / air ratio. iii) Continuous measurements of dust, NOx and SO2 emissions or discontinuous measurements at least twice per year, associated with the control of surrogate parameters to ensure the treatment system is working properly between measurements.

As part of the proposed variation the operator already complies with or has considered BAT,and these are summarised below;

i) Superglass continuously monitors over 80 furnace parameters to ensure the furnace is operating at optimum levels. This information is reviewed daily to ensure process stability.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 15 of 20 ii) The proposed new furnace will feature the latest state of the art instrumentation including Carbon Monoxide laser to continuously monitor oxygen and carbon monoxide content of the exhaust gas stream and then automatically modify gas:oxygen (fuel) ratio to ensure the combustion is optimum and emissions are compliant.

iii) The site currently conducts spot sample emissions monitoring for NOx, SO2 and dust (amongst other parameters) twice per year.

iv) r. Parameters such as inlet / outlet temperature, voltage, fan speeds are monitored continuously on abatement equipment. Frequent inspections and maintenance are completed on the furnace and abatement systems to ensure operation is optimal between specific emissions monitoring rounds.

5.18 Implications of the Variation for - Closure A Decommissioning Management Plan is in place for the site and will be reviewed to include the proposed changes.

5.19 Implications of the Variation for - Site Condition Report (and where relevant the baseline report) No new land has been included as part of the proposed variation.

IED 2012 requires sites that use, produce or release Relevant Hazardous Substances (RHS) to complete soil and groundwater monitoring proportional to risk posed from the activities at the site. Technical Guidance Note 42 allows for these monitoring requirements where the possibility for release is not possible and suitably controlled.

The RHS dealt with by the site is Diesel fuel for operating mobile plant. Information provided in the application confirms that there is suitable containment, that the risk of emission to the environment from any spillages on site being controlled and contained by the impermeable surfaces and bunding. All diesel storage and relevant pipework is within bunded areas and not beneath the ground. All drainage in the bunded areas is to internal drainage and it is not possible for RHS to discharge to the external environment. As a result no soil or groundwater monitoring shall be required by the site as per IED.

Once operations cease, if there is any contamination then this would have been caused by the undertaking of the permitted activities, and SEPA would expect the Operator to take the necessary action to return the site to the baseline levels stated in the original application.

5.20 Implications of the Variation for - Consideration of BAT As listed in all relevant sections above.

6 OTHER LEGISLATION CONSIDERED

Nature Conservation (Scotland) Act 2004 & Conservation (Natural Habitats &c.) Regulations 1994

Is there any possibility that the proposal will have any impact on site designated under the above legislation? Yes

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 16 of 20 Screening distance(s) used – 10km

Are there any SSSIs within the area screened? Yes

Has SNH been consulted under section 15(5) of the 2004 Act? Yes

Date consultation letter sent – 19/02/2019

Summary of response received including date - 21/02/2019, SNH are ‘not aware of any current pressure from emissions on the designated sites you list below. We are satisfied that SEPA will, at this stage, identify any other impacts upon the natural heritage and address them without further reference to us but if subsequent assessment shows a likely significant effect on any SAC or SPA or likely damage to the natural features of any SSSI, you will consult with us as required by conservation statute’.

Actions taken including justification – no further action required.

Has SEPA reached agreement with SNH on protection of the SSSI? - Yes

Are there any SPA or SAC designated areas within the area screened? Yes

Have you carried out an appropriate assessment? Yes

Date appropriate assessment consultation letter sent – 19/02/2019

Summary of responses received from SNH including date - 21/02/2019, SNH are ‘not aware of any current pressure from emissions on the designated sites you list below. We are satisfied that SEPA will, at this stage, identify any other impacts upon the natural heritage and address them without further reference to us but if subsequent assessment shows a likely significant effect on any SAC or SPA or likely damage to the natural features of any SSSI, you will consult with us as required by conservation statute’

Has it been determined that there are ‘imperative reasons of over-riding public interest’, including where Scottish Ministers have given SEPA a direction on this decision? No

Other legislation? No

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 17 of 20 7 ENVIRONMENTAL IMPACT ASSESSMENT AND COMAH

How has any relevant information obtained or conclusion arrived at pursuant to Articles 5, 6 and 7 of Council Directive 85/337/EEC on the assessment of the effects certain public and private projects on the environment been taken into account? N/A

How has any information contained within a safety report within the meaning of Regulation 7 (safety report) of the Control of Major Accident Hazards Regulations 1999 been taken into account? N/A

8 DETAILS OF PERMIT

Do you propose placing any non standard conditions in the Permit No

Do you propose making changes to existing text, tables or diagrams within the permit? Yes

The applicant has applied to make changes to the existing text and tables of the permit as follows;

Condition 1.1.3.2. - changes to reword the condition to refer to a single furnace instead of the existing two furnaces.

Condition 1.1.3.4 - changes to reword the condition to replace stack 9 with new stack 20.

Schedule 3, Table 3.2 – change of table to reflect existing groundwater monitoring locations.

Table 3.6 - change of tables to reflect remaining Line 1 emergency stack.

Table 3.7 – change of table to reflect remaining Line 3 emergency stack.

Conditions 3.8.1 – changes to reword to refer to a single furnace.

Condition 3.8.2 – changes to reword to refer to furnace DESP emergency by-pass in event of DESP malfunction or maintenance.

Table 3.8 - deleted as furnace 1 & 3 emergency stacks no longer in use and replaced by DESP by- pass.

Appendix 2, Site Plan to update with process area remaining air emission points.

Appendix 3, Table 3.3 – change to table to replace stack 9 with new stack 20 and introduce reduced NOx ELV for stack 19.

Appendix 3, Table 3.4 – change of table to replace stack 9 with new stack 20.

Appendix 3, Table 3.5 - change of table to replace stack 9 with new stack 20 and to introduce reduced NOx mass emission limit for stack 19.

Details including justification:

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 18 of 20 All amendments are in line with technical guidance / BREF requirements, the latest permit template for this operation or for general administrative changes to the site which are not the inclusion of any new non standard conditions.

9 EMISSION LIMIT VALUES OR EQUIVALENT TECHNICAL PARAMETERS/ MEASURES

Are you are dealing with either a permit application, or a permit variation which would involve a review of existing ELVs or equivalent technical parameters? Yes

Emission limit values Air

Substance: Oxides of Nitrogen (NOx)

Relevant emission benchmarks:

ELV: Reduction from 1500mg/m3 to 500mg/m3 Mass Emission reduction from 1.25kg / tonnes 0.5kg / tonne of melted glass.

Emission point: Stack 19 (Furnace DESP abatement).

Rationale: In line with industry BREF / BAT Conclusions standards for 2012. Principles of PPC and BAT.

Substance: Oxides of Nitrogen (NOx).

Details of any equivalent technical parameters adopted to supplement or replace ELVs: n/a

Details of any derogations from the ELVs set out in the BAT conclusions; n/a

Has an Annex been inserted to the permit containing reasons, assessment and justifications for setting the value: n/a

Details of any temporary derogation for the use of emerging techniques. NB Such temporary derogations do not require PPD consultation or the insertion of reasons etc. into the permit n/a

Emission limit values Water n/a.

Emission limit values Land n/a

Emission limit values Noise and Vibration n/a

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 19 of 20 10 PEER REVIEW

Has the determination and draft permit been Peer Reviewed? Yes

11 FINAL DETERMINATION

Issue of a Permit - Based on the information available at the time

Based on the information available at the time of the determination SEPA is satisfied that;

 That the operator is in a position to use all appropriate preventative measures against pollution, in particular through the application of best available techniques.  That no significant pollution should be caused.

12 REFERENCES AND GUIDANCE

Guidance Notes – Identify key references, guidance (BREF, UK Technical Guidance, etc) used in determination

Manufacture of Glass – BREF Guidance Document. Manufacture of Glass – BAT Conclusions Document.

Part A Permit Application or Variation Dec. Doc (Pt. 2) Form: IED-DD-02 V 1 Page no: 20 of 20