Document Mg8D9RKn8yG4abKr97vqvLkM

INDEX Relevant to lobbying Notes and summary from the documents in order of time My questions and comments Title of the EIR document, with link to the document in google drive Summary of main findings: (AGC are producing 30g of PFOA annually as a by-product of their PTFE processes - although this doesn't add up with the mass balance reports.) They say they are releasing over 4kg of PFOA into the river from historic use & background levels??, into air from current by-product emissions, and landfill, as well as in product. All residues from the PFAS waste abatement equipment is sent for hazardous waste incineration. Filter cake form the Solids Removal Plant have been shown to contain low levels of EEA-NH4 and PFOA. This material is sent to hazardous waste landfill at the Whitemoss Landfill in Skelemeresdale since Feb 2014. Filter cake waste was previously disposed at Jameson Road landfill site, Fleetwood. There are dumping pools and runoff pools to test. A section of Royles Brook runs through King Georges playing fields https://wyreriverstrust.org/king-georges and Hillylaid pools: https://wyreriverstrust.org/hillylaid-wetland, both are community restoration projects. AGC thanks the Environment Agency for "advice and support during a site visit on PFAS issues and adverse media campaigns (but let's hope we don't get to that!).....We are doing some investigating on setting up a Teams site to enable us to share documents with you. Please could you confirm if this needs to be a system that does not allow the EA to download or add documents - as these will be classed as being available to the EA and hence in the public domain?" Cover letter for my EIR request AGC Reg 61 notice 3_Redacted No date Notice requiring information - the Regulation 61 notice PFAS_REDACTED 21 Dec 2022 I am on the PFAS working group and I want to give you some advance notice of the sort of information we are likely to ask from the company. You don't have to take action now, I am just letting you know our thinking. 2. We are interested in historic information about the PFOA from the dryer, such as stack height etc. We understand about 70 tonnes was emitted historically. 3. We are likely to ask about the PFOA emissions. It is understood that about 2kg of PFOA is emitted from the site due to historic contamination. 4. For ongoing emissions, we are likely to serve you with a section 61 notice under the EPR. We will consult you first. RE_ Site visit_Redacted 20/3/23 Can the new Area Director come to the site visit RE_ AGC reg 61 notice - update and next steps_Redacted 20/3/23 10:27am - EA sending draft notice of the reg 61, offer to arrange a teams to discuss it 31/3/23 14:08 - AGC reviews draft and will give input in the attachment (below) Draft Regulation 61 Feedback 31/3/23 *Response to the EA asking for more analysis. AGC wants EA to withdraw what they said in a cover letter to the section 61 notice: "Throughout correspondence in 2022 you have provided limited information concerning the releases of PFAS from your site" *Talk of costs and methods of testing. *AGCCE has invested significantly in abatement equipment to minimise PFAS emissions already (in excess of 6m) and has plans to invest further (circa 3m) to further reduce emissions by the end of 2024 so this isn't simply a cost issue, rather we are trying to understand the exact information you are seeking and to agree something with you that is feasible and proportionate. *HFP is also generated as an unwanted impurity in pyrolysis - the majority is destroyed via High Boilers either on site or via Veolia, there are traces trace in Waste Acid Stack (emission point A2) (Info on HFP: https://assets.publishing.service.gov.uk/media/6421a6d52fdbff000cb023f3/2._Environmental_risk_evaluat ion_report_Hexafluoropropene.pdf) *Proposals to reduce PFOA releases to water - As outlined in CAR Forms BU5453IY/0451214 issued 16/02/2023 and BU5453IY/0457216 issued. 01/03/23 AGCCE has already discussed outline plans with the Environment Agency Mass balance data for PFOA is available from 2003 to 2012 and a summary of this data has already been provided to the Environment Agency. *Mass release emissions of PFOA between 1950 - 2012 Of the approximate 250 tonnes of PFOA used on site releases were estimated as follows: 75 tonnes to river 70 tonnes to atmosphere 80 tonnes to customers 15 tonnes incinerated. <5 tonnes to landfill. 20230404_Meeting minutes - Draft Regulation 61 Feedback_Redacted (1) Meeting Minutes 4/4/23 13:30-14:30 Subject is the overview of the Regulation 61 notice. *EA confirmed they're not targeting fluoropolymer emissions....as they are not of current interest *EA confirmed they're looking at historic emissions and where depositions would have occurred to understand any residual risk. *AGCCE feedback: There is reference in the cover letter and notice to "Throughout correspondence in 2022 you have provided limited information concerning the releases of PFAS from your site', we are concerned, that to somebody who has not been part of our discussions, this reference might suggest that AGCCE has been less than co-operative........Would you consider changing the language so that it says we provided information in 2022 and you now require additional information? *EA agree AGCCE suggested wording. *Action : AGCCE to discuss requesting Manchester Metropolitan University PFAS results. *AGC requests to scale back the testing required and The EA agree that costs should be proportionate. The key focus is to provide a comprehensive understanding of all emissions in the most cost-effective manner. *Action : AGCCE to confirm technical feasibility of monitoring Annex II, EA open to discussion on alternative way of obtaining this data, e.g. mass balance. Was doing it by mass balance AGC's idea? Because it's making it very hard to work out if they're breaking any convention, as it's not the usual concentration method. *AGCCE confirm production consistent on AGCCE plant 24 hours a day, 7 days a week, 365 days a year. The flow rate of discharge from W1 is approximately 30-40m3/hr normally but raises to 80-90m3/hr in periods of heavy rainfall. *There are 3rd party reports on GW monitoring eg Conceptual Site Model, which they'll give the EA. Do we have these reports? *Treated PTFE micro powders go through ovens (abated through ARK plant ~30g/year from 400t PTFE micro powders) no route to effluent. *ACCGE identified that a large number of assumptions were made in estimating the quantities of PFOA used and emissions between 1950 and 2012. RE_Technical group visit (4) 6/4/23 1:58pm EA says thanks for the visit to AGC. "They didn't understand a lot of the technical aspects of the presentation but they did get why it's important to maintain the environmentally sustainable manufacturing of PTFE and ETFE." Asks for their tech guys to visit. AGC replies 6/4/23 15:48 : "also thank you for the offer advice and support on PFAS issues and adverse media campaigns (but let's hope we don't get to that!).....We are doing some investigating on setting up a Teams site to enable us to share documents with you. Please could you confirm if this needs to be a system that does not allow the EA to download or add documents - as these will be classed as being available to the EA and hence in the public domain?" We're investigating a Teams sites tp enable us to share documents. Plse could you confirm is this needs to be a system that doesn't not allow the EA to download or add documents - as these will be classed as being available to the EA and hence in the public domain? I'l get Part A process gas emissions to you Tues & still need to complete Part P for annual CO emissions breach. 14/4/23 2:04 is 17th free? 18/4/23 can make 17th May work 19/4/23 13:51 - can we do June? 20/4/23 14:01 suggested dates RE_ Technical group visit (9)_Redacted 19/4/23 14:24 Will get June/July dates over EA Regulation 61 notice_Redacted (1) 19/4/23 12:21 EA: Reviewing Reg 61 following the 4th April meeting. Plse send over list of PFAS release from site with release quantities. Discuss dates for site visit. 20/4/23 17:02 AGC: have tidied the notes, will get these to you early next week with suggested list of PFAS analysis. 21/4/23 10:22 EA: thanks for pulling this together 4/5/23 12:48 EA: where are you at with those documents? 5/5/24 4:27pm AGC: apologies will be there on Tuesday 9/5/23 12:37 AGC see attached meeting minutes from 4th April initial Reg 61 feedback discussion. We also have excel sheet with commentary against Annex l and ll analytes. Let's plan site visit. 22/5/23 11:34 EA: will review draft before site visit on the 4th July. 25/5/23 2:10pm AGC: sorry for delay, do you want to have a call before site visit, we're approaching labs for water/air analysis. 1/6/23 12:20 AGC: we've updated agenda for 4th july meeting. We'll walk through the process identifying where PFAS is generated and emission points. EMT-SSP-05959 AGC Chemicals Europe Ltd (May 2023)_Redacted Element doc 2/5/23 Version 1 Release point ref A4 L168 Lubricant Oven Hydrogen Fluoride 1mg/m3, sample duration 60 minutes, sample flowrate (actual) l/min 10, samples volume (ref) m3 0.550, Projected MU (%) 15% PFOA 1mg/m3, sample duration 60 minutes, sample flowrate (actual) l/min 10, samples volume (ref) m3 0.550, Projected MU (%) 15% Release Point Ref A5 ARK Inlet (release from the oven irradiation process) PFOA 1mg/m3, sample duration (mins) 240, sample flowrate (actual) 1l/min 10, sample volume (Ref) (m3) 2.216, projected MU (%) 15% EA Regulation 61 notice_Redacted 1/6/23 12:20 We've updated agenda for 4th July. Tim, worth inviting Ines? EA technical visit PFAS & Regulation 61 26 June 2023 14:58 Look forward to coming to AGC next week FW_ EA PFAS Site Visit_Redacted 7 July 2023 See attached presentation slides (below) Overview Information July 2023 AGC's presentation to the EA, presumably for their site visit. Details what they produce, their permit, NW/ 0172900384/001 Jan 1999. Permit site managed by TFM and is directly to Royles Brook (west effluent pit) - no permit limits set. AGC and Victrex discharge effluent in the river Wyre via emission point W1 permit limits set for suspended solids and Fluoride, effluent is monitored. Surface water goes into Hillylaid Pools W2 - no permit limits set. In heavy rainfall overflow from the West Effluent Pit (effluent treatment plant) occurs to Royles Brook W3. (selection from the slide show. See link for all slides) Then lots of slides of chemistry diagrams of how they make PTFE. No limit set AGC are member of the Fluoropolymer Product Group in PlasticsEurope All residues from the PFAS waste abatement equipment is sent for hazardous waste incineration Filter cake form the Solids Removal Plant have been shown to contain low levels of EEA-NH4 and PFOA. This material is sent to hazardous waste landfill at the Whitemoss Landfill in Skelemeresdale since Feb 2014. Filter cake waste was previously disposed at Jamieson Road landfill site, Fleetwood. What3words sample locations (We need to test some of these overflow dumping pools. A section of Royles Brook runs through King Georges playing fields https://wyreriverstrust.org/king-georges and Hillylaid pools: https://wyreriverstrust.org/hillylaid-wetland, both are community restoration projects! Could kids be exposed on the football pitch? See W2 and W3 Samples Locations for the what3words. They send waste containing PFOA and EEA-NH4 to Whitemoss Landfill Site, Skelemeresdale since Feb 2014, White Moss Rd S, Skelmersdale WN8 9TH. Also test the previous landfill site Jamieson Road, Fleetwood, FY7 8TW. ) W2 and W3 sample locations Automatic reply_ EA technical visit PFAS & Regulation 61 3/7/23 14:21 out of office reply RE_ Reg 61_ questions from site visit (5)_Redacted 25/7/23 11:52 EA: Can you clarify what sections on the site drain to W2 & W3? Supply drainage plans? Any PFAS testing completed? Photos of bund areas? 25/7/23 13:01 AGC: did you get the presentation slide? Have removed some for confidentiality, but is there something specific you need? Will review and mark drainage plans and send. Not completed PFAS monitoring of W2 Hillylaid Pools / W3 Royles Brook. Not sure we have access to W2. Photos-have shared a link to download 25/7/23 1:09 Slides very useful, have downloaded photos RE_ Reg 61_ questions from site visit_Redacted 2/8/23 AGC: Plse see document 20230802 shared with the EA in response to queries following your visit & our comments on updated draft reg 61 notice. Will call you tomorrow. IP16 drainable report permit BU45531Y, updated drainage drawings, manhole card included for MH2H07 grid ref J3, MH3J02 grid ref P6 connection from storm water to AGC effluent 3/8/23 9:18 Can call this afternoon 3/8/23 9:46 no need, just update before holiday RE_ Reg 61 - final version and deadlines_Redacted (1) 5 Sept 2023 1:59pm 7 Sept 2023 15:15pm Discuss meeting times. RE_ AGCCE Regulations 61 Final Discussion with EA 11 Sept 2023 They talk about arranging a teams video to discuss it on 2/10/23 - can we EIR this or the minutes of it? 26 Sept 2023 AGC are given plenty of notice before the EA tests their overflow points and discharge W2 and W3 not defined in the permit (no monitoring at W2, W3 just screening) Location to be agreed via Reg 61, likely AGC will monitor from Shard Bridge, assume the plume does not extend this far. Discussed that if there is uncertainty in the data maximum recorded values would be used. Discussion of a plume! 2 Oct 2023 Thanks for the call and checking if the dates of testing under the Regulation 61 could be changed. Essentially they can before they are included formally within the Reg 61 document for the methodology purpose? We can achieve other dates for air emissions points A4 & A5. If as things progress it looks like some of the dates may need to move, and this is for legimate reasons, we would take a pragmac approach to discussing, reviewing, and resolving this. 2/10/23 11:52 Noted that the Environment Agency will take a pragmatic approach on this, and we will continue to work closely with the Environment Agency on this. FW_ AGCCE Regulation 61 Final Draft discussion with EA_Redacted 26/9/23 10:00 - 15:00 teams meeting to finalise Reg 61 to be issued on 2/10/23 RE_ AGCCE Regulation 61 Final Draft discussion with EA (3)_Redacted 29/9/23 16:43 AGC: can you call? We have new abatement project for emission point A7. Hoping to combine commissioning of this project and validation life with GC screening. Would mean pushing back dates for later in 2024/2025. Is there scope to amend Reg 61? Regulation 61 Notice - EPRBU5453IY_Redacted 3 Oct 2023 15:55 AGC cover letter 3/10/23 The EA is assessing the need to review their permit. They require more information on PFAS emissions AGC Regulation 61 notice 3/10/23 Lists all the PFAS testing the EA requires. (Make sure we have all the data that they've listed and put in another EIR if we don't have everything.) Regulation 61 programme Timeline of testing planned following the Reg 61 notice from 2/10/23-10/4/25 AGC Guidance 2 All monitoring is to take place over a 3/6-month period, minimum 12 samples from each effluent discharge point. AGC Guidance V2_feedback Not dated, about the testing methodology, which includes some notes/questions presumably from AGC to the EA, asking for more detail on how to conduct testing. All monitoring is to take place over a 12 month period, minimum 24 samples from each effluent discharge point with a minimum of 2 samples taken per month. AGC Guidance V2_feedback_Redacted No date. The same document as above, but without the notes in the margin. So must be what the EA first sent AGC. AGCCE Regulation 61_Redacted 23 November 2023 10:40 Can we move meeting? Regulation 61 AGCCE_Redacted 24 Nov 2023 15:05 Attachment: EMT-SSP-05959 AGC Chemicals Europe Ltd (May 2023).pdf (sampling methodology) For A5 we propose to take 2x4 hr samples over 4 days throughout 2024 - this follows monitoring we have been previously undertaken for EEA-NH4 & PFOA and data could also be submitted? Methodology is included in the attached. For A4 we'll review but have previously taken 10x1hr samples for PFOA and HF (HF from Permit requirement) and over the full 10 hour oven cycle. Methodology is included in the attached, however this doesn't include EEA-NH4, this would likely be 1x10hr sample over the full oven cycle. We recently attended a workshop by AECOM where they mentioned they have written an internal guidance document for the EA on PFAS and had undertaken some catchment sampling for PFAS. I believe these documents would be useful context for use and for writing sampling methodology, particularly for our background river samples. RE_ AGC site visit_Redacted 27/11/23 Invitation sent for 26/10/23 1-3pm teams meeting to discuss a site visit AGCCE Regulation 61 - Progress meeting_Redacted 11/12/23 11:48 Main challenge is that labs don't have capability to test for all PFAS identified EA to share requested documents to assist with AGC sampling methodology Next progress meeting 21/3/24 AGC Chemicals - A7 Method Proposal DRAFT_Redacted (2) Element doc 11/12/23 Version 1 PFBA/PFHxA - units ug/m3, sample duration 360 mins, sample flowrate (actual) l/min 18, samples volume (ref) m3 6.480 AGC Chemicals - A7 Method Proposal DRAFT_Redacted 11/12/23 Version 1 - same as above EPRBU5453IY - Reg 61 Notice - submission 01_Redacted 20/12/23 Cover letter - plse find enclosed historic release of PFOA PFOA Mass balance summary 20/12/23 EA request to AGC: We require you to provide total mass releases of PFOA to air, land, water and in products from first production (ICI period) on site to 03/10/2023. Since first production at the Hillhouse site the total mass releases of PFOA to air, land, water and in product is approximately 178 tonnes. The approximate breakdown of these emissions is set out below: Emission to air 49.1 tonnes Emission to land (i.e. landfill) 6.2 tonnes Emission to water 54.3 tonnes Within product (sent to customers) 63.3 tonnes Captured and destroyed through incineration 5.1 tonnes Residual PFOA mass emissions from Q2 2012 onwards are already accounted for in the in the 178 tonnes total mass release from legacy PFTE production. Since Q2 2012 PFOA emission from the Hillhouse site are typically: Emission to air <255g per year due to PFOA presence as an impurity in PTFE lubricant grades Emission to land approximately 1.2 kg per year to landfill (filter cake from effluent treatment process) Approximately 4 kg per year PFOA emission to water (residual effluent contamination from historic use of PFOA and environmental background levels) Within product <125g PFOA per year is inadvertently generated in the PTFE lubricant manufacturing process Approximately 750g per year PFOA captured in the atmospheric scrubber and then destroyed though high temperature incineration at an external site. (What does this mean in terms of the Stockholm convention, which gives concentrations not amounts. In order to reinforce the application and enforcement in the Union of Article 3 of Regulation (EU) 2019/1021, a limit value should be set for PFOA, its salts and PFOA-related compounds occurring as an unintentional trace contaminant in substances, mixtures and articles. That limit value should be set at 0,025 mg/kg for PFOA including its salts, and at 1 mg/kg for the individual PFOA-related compounds or a combination of those compounds. For applications where those concentration limits cannot currently be met, higher concentration limits should be established, subject to review by the Commission within 2 years with a view to lowering the limits. Context: Between 1951-2003 DuPont dumped 7100 tonnes of PFOA. Here's a link to cases settled and ongoing. https://www.business-humanrights.org/en/latest-news/dupont-lawsuits-re-pfoa-pollution-in-usa/ The Hillhouse Plant has dumped 178 tonnes of PFOA into the environment from 1952 - 2023 1981 ICI/AGC joint venture 1999 AGC sole owner 2012 PFOA not used. There are reports that PTFE production started in the UK in 1947, as a result of a technology sharing agreement between DuPont and ICI. Manufacturing in Widnes commenced until the plant exploded in 1950, so production was moved to the Hillhouse facility near Blackpool, where in 1956 some 200 tons per annum of PTFE was being produced. https://environment-analyst.com/uk/106678/expert-opinion-is-theuk-sleepwalking-into-a-pfas-contamination-nightmare ) FW_ AGCCE Regulation 61 - Air screening_monitoring_Redacted 11/12/23 12:09 on the screening and monitoring proposal 11/1/24 Enhanced Pre-application Request - EPR_BU5453IY_Redacted (1) 27/12/23 Enhanced Pre-application Request - EPR/BU5453IY. EA wants to know what AGC want from them. AGC applying for permit variation for: Eluent improvement project Installation of a secondary carbon adsorption unit Installation boundary minor amendment (current permit boundary does not include all AGCCE land and small area outside the current permit boundary will be utilised for the eluent improvement project). Approach to permit limits and risk assessment requirements alongside existing Regulation 61 notice (issued 03/10/2023) updated surface water risk screening and air emissions risk assessments are a requirement of the Regulation 61 notice. Inconsistency in the HF monitoring requirements in our current permit. Other minor changes required: Update to address Removal of OPE monitoring (no longer used in our processes) Additional PFAS analysis List of other PFAS, including PFOA, that could be generated from irradiation of PTFE PFOA is found in AGCCE effluent - the source is not from current manufacturing process (PFOA is not in use), but likely associated with historic use of PFOA on the site. Potential to generate from PTFE micropowder manufacture during thermal degredation and irraditaion. The degraded micropowder is then heat treated to remove PFOA approx. 30g removed from the product annually which is directed to the ARK plant. Potential trace contaminant in EEA-NH4. No credible mechanism to generate PFOA from ETFE manufacture unless present as a contaminant in the raw materials (such as AC-2000 or PFBE) Can I have the raw data to prove the amounts? ELEMENT DOCS give flow rate, can this help us work out the mass balance in concentration? I've sent it to Roger Klein. Roger answered: How many samples did they collect within the year - then I should be able to work out the concentrations. However, there are 2 versions of the guidance documents and they don't have dates on them. So I email the EA on 26/6/24: "I have a question about a couple of the documents, as they don't have dates on them. There are 3 guidance documents that you sent to AGC. Guidance 2 stipulates AGC should take 12 samples in 3/6 months and the other says AGC should take 24 samples over 12 months. So how many samples did AGC take and over what timeframe please?" EA confirmed that the minimum LOD is 10 ng/l (based on PFOS, PFOA analysis). Also we can put in an EIR to ask for water samples taken close to the landfill sites - check the groundwater concentration by the landfill. We should check our own PFAS map. The Environment Agency said AGC took 24 samples over a 12-month period, 2 samples per month. The method document is the only thing I saw and it said: PFOA 1mg/m3, sample duration 60 minutes, sample flowrate (actual) l/min 10, samples volume (ref) m3 0.550, Projected MU (%) 15% You also have a PFOA concentration 1mg per cubic metre = 1 mg per 1000 litres = 1 mg per 1000 x 1000 gm = 1 part per billion. Apparently. If we just take the 4kg going into the protected SSSi River Wyre estuary annually, AGC would have to be discharging that in 4 million tonnes of water for the concentration to be 0.1ug/l, which is the Drinking Water Inspectorate's maximum Tier 3 level allowed. https://dwi-content.s3.eu-west2.amazonaws.com/wp-content/uploads/2023/01/13123351/IL_03-2022_PFAS_Guidance-4-1.pdf I don't think it's breaking any laws though. https://www.pinsentmasons.com/out-law/guides/pfasregulation-in-the-uk