Document jyy9jRVg3rBnV8V8GZ43v82YQ

From: Sent: To: Subject: 02 October 2023 11:52 RE: AGCCE Regulation 61 Final Draft discussion with EA Hi Noted on the breakdown of dates and including these in the Regulation 61 notice. Yes, as explained below we provided outline programme dates based on information available at the time. As we begin to engage external laboratories/consultants and write the methodology for screening/monitoring for delivering the Regulation 61 requirements we will be able to provide a more accurate programme and will discuss any changes to outline dates with you. 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. As we discussed last week regular communication throughout the delivery of the Regulation 61 programme will be essential. I'll put some Teams meetings in the diary. Who from the Environment Agency would you like me to include? In addition to these catch-up meetings, it will be beneficial to have discussions with those reviewing our proposed methodologies for screening/monitoring/mass balance to ensure any comments/questions can be quickly resolved to ensure dates for provision of results/information can be achieved. Kind regards, AGC Chemicals Europe, Ltd. www.agcce.com Disclaimer: This email and the information contained therein and within any attachments is confidential and may be privileged. If you have received this email in error please notify us immediately. If you are not the intended recipient, you are not authorised to, and must not use, disclose, copy, distribute, retain or rely on this email or any part of it. AGC Chemicals Europe, Ltd. may monitor email traffic data and also the content of email for the purposes of security and staff training. A list of Directors' names is open to inspection at the address below. AGC Chemicals Europe, Ltd. is registered in England. Registration Number: 3825057 Registered Office: York House, Hillhouse International, Fleetwood Road North, Thornton-Cleveleys, Lancashire, FY5 4QD VAT: 732803742. 1 From: Sent: Monday, October 2, 2023 10:18 AM To: Subject: RE: AGCCE Regulation 61 Final Draft discussion with EA *** External email: Please be cautious when opening attachments or clicking links. *** Hi , It is best pracce for us to specify dates which are broken down for individual tasks when it es into a large project. The dates cannot be changed once the noce is issued and they are enforceable. However, we understand that for projects like this it is difficult to accurately predict exact melines and we appreciate your efforts in producing a detailed plan thus far, which is the basis of the dates in the noce. 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. Happy to take a call to discuss today but we will issue this week and the individual breakdown dates for 1.1, 1.2 etc would need to stay. Kind regards, Environment Agency Working days: Monday to Friday From: Sent: Monday, October 2, 2023 9:39 AM To: Subject: RE: AGCCE Regulation 61 Final Draft discussion with EA Hi Thank you for the call and checking if the below dates could be amended in the Regulation 61 document. We just wanted to highlight the proposed dates we discussed last week and provided for the Regulation 61 information were our initial thoughts based on the information available at the time. We will work to achieve these, however they are dependent on external factors e.g. EA review/approval time, discussions with external laboratories/consultants. You mentioned dates could not be amended once included within the Regulation 61 notice. Is there a mechanism within the Regulation 61 to amend dates, for example as part of submitting procedures for review? This is most relevant for (1) Quantification of PFAS releases to water and (2) Quantification of PFAS releases to air where there is series of sequential tasks. Would it be possible to put the end date for (1) and (2) and remove dates for 1.1, 1.2, etc. 2 Happy to arrange a Teams call on this to discuss with you/those issuing the Regulation 61. We can make ourselves available at a time which suits you. Kind regards, AGC Chemicals Europe, Ltd. www.agcce.com Disclaimer: This email and the information contained therein and within any attachments is confidential and may be privileged. If you have received this email in error please notify us immediately. If you are not the intended recipient, you are not authorised to, and must not use, disclose, copy, distribute, retain or rely on this email or any part of it. AGC Chemicals Europe, Ltd. may monitor email traffic data and also the content of email for the purposes of security and staff training. A list of Directors' names is open to inspection at the address below. AGC Chemicals Europe, Ltd. is registered in England. Registration Number: 3825057 Registered Office: York House, Hillhouse International, Fleetwood Road North, Thornton-Cleveleys, Lancashire, FY5 4QD VAT: 732803742. From: Sent: Friday, September 29, 2023 4:43 PM To: Subject: RE: AGCCE Regulation 61 Final Draft discussion with EA Hi , Please could you give me a call on Monday? We have had some internal discussions today regarding our new abatement project for emission point A7. We are hoping to combine commissioning of this project and validation of our inline GC with screening for A7. This would mean pushing the dates back for this later in 2024/2025? Is there scope to amend Regulation 61 dates though the methodology we propose? 2.1 Screening Results - August 2024 2.2 Monitoring - procedures for review - September 2024 Other dates would remain the same for the 2.2 monitoring results by December 2024. We could still achieve other dates for other air emission points A4 and A5, and perhaps we break down submission of monitoring procedures for monitoring for different emission points... Please let us know your thoughts. Thanks, 3 From: Sent: Tuesday, September 26, 2023 4:31 PM To: Subject: RE: AGCCE Regulation 61 Final Draft discussion with EA Hi all, As discussed, please see attached and notes below. 1.1 Screening W2 and W3 locations not defined in permit (no monitoring at W2, W3 just screening). o See attached where it would be possible to access W2 and W3 locations for screening (4 spot samples total) I assume the downstream locations would be preferable? Locations to be agreed via Regulation 61 screening procedures for review (1.1) (Reg 61 to be updated to reflect this) 1.2 Background chemical data, e.g. tidal/non-tidal... to talk though this. No TOF analysis identified for background chemical quality data. Why monitor all Annex I if not screened present in AGCCE W1 effluent? o confirmed TOF analysis and only screened in Annex I would be required for background chemical quality data (Reg 61 to be updated to reflect this) o Location to be agreed via Reg 61, likely AGC will monitor from Shard Bridge at high tide, assume the plume does not extend this far. Discussed that if there is uncertainty in the data maximum recorded values would be used. 1.2, 2.2 Note, installation of AGCCE abatement equiptment during/prior to monitoring (impacts to monitoring of W1 and A7). o Water emissions from W1 likely to get approx. 12 No. samples pre/post installation of additional abatement for effluent improvement o Air emissions from A7 likely that analysis would be completed post installation of additional abatement o Dates are identified on programme shared. 1.3, 2.3, and 3 Mass release method approval isn't identified in Regulation 61, assume it will be need? Assume AGCCE will report mass balance for 2023 -2024, potential to complete 2022-2023 if existing mass balance method is acceptable and data is available. o Reg 61 to be updated to include approval, EA likely to approve existing method already in place o Mass balance report annually - added note to our programme, this is likely to be releases to you by March 2024, March 2025 or March 2026 3 Other PFAS releases: AGCCE request definition of `aware', do you mean `Have the company obtained measurement of any other PFAS, as defined by the....' o A large number of PFAS could be theoretically possible, Reg 61 to be updated to reflect what AGC are aware of through existing monitoring. Feasibility for 3 Other PFAS releases: For substances listed in Annex I, II and III, provide details of annual mass releases via waste and product for 2 consecutive years. o Where Annex I PFAS are not directly attributed to fluoropolymer manufacture mass balance not required, this will limit this action to 10 No. Annex I PFAS not in use but potential to generate from PTFE micropowder manufacture during thermal degradation and irradiation. 4  Milestone dates/deadlines, outline programme to be shared. March 2026 for all data/information (including staggered release of information/data). Opportunity to improve on this date (see comment above on mass balance) but expect it to be at least 24 months. o Please see attached. o Quarterly check ins and release of monitoring data where available (without interpretation) - we can add these to the programme and schedule in once the Regulation 61 notice is submitted. Kind regards, -----Original Appointment----From: Sent: Monday, September 11, 2023 9:36 AM To: Subject: AGCCE Regulation 61 Final Draft discussion with EA When: 26 September 2023 14:00-15:30 (UTC+00:00) Dublin, Edinburgh, Lisbon, London. Where: YH-Training Room Hi , Meeting to finalise AGCCE Regulation 61 to be issued w/c 2nd October (booked 90 mins but this may not be required). Discussion points: 1.1 Screening W2 and W3 locations not defined in permit, to share where AGCCE could access for sampling as part of screening method proposals (no monitoring at W2, W3 just screening). 1.2 Background chemical data, e.g. tidal/non-tidal... to talk though this. No TOF analysis identified for background chemical quality data. Why monitor all Annex I if not screened present in AGCCE W1 effluent? 1.2, 2.2 Note, installation of AGCCE abatement equiptment during/prior to monitoring (impacts to monitoring of W1 and A7). 1.3, 2.3, and 3 Mass release method approval isn't identified in Regulation 61, assume it will be need? Assume AGCCE will report mass balance for 2023 -2024, potential to complete 2022-2023 if existing mass balance method is acceptable and data is available. 3 Other PFAS releases: AGCCE request definition of `aware', do you mean `Have the company obtained measurement of any other PFAS, as defined by the....' Feasibility for 3 Other PFAS releases: For substances listed in Annex I, II and III, provide details of annual mass releases via waste and product for 2 consecutive years. Milestone dates/deadlines, outline programme to be shared. March 2026 for all data/information (including staggered release of information/data). Opportunity to improve on this date (see comment above on mass balance) but expect it to be at least 24 months. Please forward this invite to your other EA colleagues as needed. Kind regards, ________________________________________________________________________________ Microsoft Teams meeting Join on your computer, mobile app or room device Click here to join the meeting 5 Meeting ID: 490 548 652 030 Passcode: 92bkrY Download Teams | Join on the web Learn More | Meeting options ________________________________________________________________________________ Information in this message may be confidential and may be legally privileged. If you have received this message by mistake, please notify the sender immediately, delete it and do not copy it to anyone else. We have checked this email and its attachments for viruses. But you should still check any attachment before opening it. 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