Document 4pQ2vmyvMY8eyq1e8Own1J1R

EPR Compliance Assessment Report Report ID: BU5453IY/0451578 This form will report compliance with your permit as determined by an Environment Agency officer Site AG Fluoropolymers, Hillhouse EPR/BU5453IY Permit Ref BU5453IY Operator/ Permit holder AGC CHEMICALS EUROPE LIMITED Date 30/12/2022 Time in 12:00 Out 12:01 What parts of the permit were assessed Assessment Chlorodifluoromethane (R22) emission above limits 23/12/2022 Report/data review EPR Activity: Installation X Waste Op Water Discharge Recipient's name/position Officer's name Date issued 23/02/2023 Section 1 Compliance Assessment Summary This is based on the requirements of the permit under the Environmental Permitting Regulations (EPR). A detailed explanation and any action you may need to take are given in the "Detailed Assessment of Compliance" (section 3). This summary details where we believe any noncompliance with the permit has occurred, the relevant condition and how the noncompliance has been categorised using our Compliance Classification Scheme (CCS). CCS scores can be consolidated or suspended, where appropriate, to reflect the impact of some noncompliances more accurately. For more details of our CCS scheme, contact your local office. Permit Conditions and Compliance Summary Condition(s) breached a) Permitted activities b) Infrastructure c) General management d) Incident management 1. Specified by permit A 1. Engineering for prevention & control of pollution N 2. Closure & decommissioning N 3. Site drainage engineering (clean & foul) N 4. Containment of stored materials N 5. Plant and equipment N 1. Staff competency/ training N 2. Management system & operating procedures N 3. Materials acceptance A 4. Storage handling, labelling, segregation N 1. Site security N 2. Accident, emergency & incident planning N e) Emissions 1. Air 2. Land & Groundwater 3. Surface water 4. Sewer 5. Waste C4 3.1.2; N N A N f) Amenity 1. Odour N 2. Noise N 3. Dust/fibres/particulates & litter N 4. Pests, birds & scavengers N 5. Deposits on road N g) Monitoring and records, 1. Monitoring of emissions & environment N maintenance and reporting 2. Records of activity, site diary, journal & events N 3. Maintenance records N 4. Reporting & notification A h) Resource efficiency 1. Efficient use of raw materials N 2. Energy N KEY: C1, C2, C3, C4 = CCS breach category ( * suspended scores are marked with an asterisk), A = Assessed (no evidence of noncompliance), N = Not assessed, NA = Not Applicable, O = Ongoing noncompliance - not scored MSA, MSB, TCM = Management System condition A, Management System Condition B and Technically Competent Manager condition which are environmental permit conditions from Part 3 of schedule9 EPR (see notes in Section 5/6). Number of breaches recorded 1 Total compliance score (see section 5 for scoring scheme) If the Total No Breaches is greater than zero, then please see Section 3 for details of our proposed enforcement response CAR 2 V2.0 0.1 Page 1 of 5 Section 2 - Compliance Assessment Report Detail This section contains a report of our findings and will usually include information on: the part(s) of the permit that were assessed (e.g. maintenance, training, combustion plant, etc) where the type of assessment was `Data Review' details of the report/results triggering the assessment any noncompliances identified any noncompliances with directly applicable legislation details of any multiple noncompliances information on the compliance score accrued inc. details of suspended or consolidated scores. details of advice given any other areas of concern all actions requested any examples of good practice. a reference to photos taken This report should be clear, comprehensive, unambiguous and normally completed within 14 days of an assessment. Our Decision The company reported an incident relating to the "acid scrubber" / pyrolysis plant or A2 Waste Acid Stack The limit for emissions set in the permit is 800g R22/hour weekly average. The company reported that they average weekly average was 810.6g/hour. This represents a breach of the limit. However, the breach is just 1.3% above the limit. Following a meeting with the company, I was provided with 2022 data summary showing that they had not breached the limits previously and that the average for the year was well below the limits, has it been an annual limit. The harm of R22 is as a climate change effecting gas and as an ozone depleting substance, not as harm to human health, therefore the total cumulative mass, rather than the weekly release is of more significance. Permit condition 3.1.2 states that the limits given in schedule 3 shall not be exceeded. I regard the emission to be a trivial exceedance in the context of the entire years data it is of no marginal significance Therefore I have attributed a CCS4 score (the lowest rating available). I will deal with management conditions in my response to another incident for A1 reported on 19 December 2022 and updated on 21/12/2022. I commend the company for a very thorough response and setting the breach in context. Our advice and guidance is to review procedures to ensue reduced probability of recurrence. [this report was written in February 2023 but has been attributed to compliance year 2022] The text of the report from the company as follows: The environmental permit limit for both Chlorodifluoromethane (R22) and Pentafluoroethane (R125) for emission point A1 Low Boiler Stack is 100g/hr (weekly average). During the week commencing 12 December 2022 the weekly R22 and R125 average for the Low Boiler Stack was exceeded due to a higher than normal result on the 16 December. This resulted in the weekly average results being: 458.0 g/hour for R22 CAR 2 V2.0 Page 2 of 5  280.3 g/hour for R125 All other daily R22 and R125 results for the Low Boiler Stack, for the w/c 12 December were within environmental permit limits On the 15 December there had been issues with freezing. Steam is used to control the temperature of the distillation columns. Due to the extreme cold weather, it is believed condensate in the instrument impulse line to the steam supply instruments froze, this resulted in abnormal steam supply rates and insufficient heating was provided to the distillation column (2A still). The insufficient heating of the distillation column led to excess impurities being fed forward (including R22 and R125) causing abnormal operating conditions and increasing levels of R22 and R125 being discharged to the low boiler stack. Measures taken, or intended to be taken to prevent a recurrence of the incident During the extreme cold weather, the AGCCE operations team worked to ensure temperature control within the distillation process was maintained. Once the problem with 2A still the steam flow was identified this impulse line was defrosted and 2A still temperature brought back up to normal levels. Following this, normal operating conditions were established preventing further abnormal emissions. Since the breach on 16 December the Low Boiler Stack has demonstrated results within environmental permit limits. Measures taken, or intended to be taken, to rectify, limit or prevent any pollution of the environment which has been or may be caused by the emission See above details of the action taken by the AGCCE operations team. In addition to this the lagging around the impulse lines will be reviewed to ensure this is sufficient to prevent further issues associated with freezing condensate in impulse lines. The weekly average R22 and R125 for the Low Boiler Stack have been within permitted limits as follows: w/c 19 December 26.2 g/hour for R22 0 g/hour for R125 w/c 26 December 0 g/hour for R22 0 g/hour for R125 w/c 02 January 6.5 g/hour for R22 0 g/hour for R125 w/c 09 January CAR 2 V2.0 Page 3 of 5