Document zbv9mw0LnO3OpO6YXwg9mxJa0
Regards the change in Mercury results do I understand it right that all the lab results for this year that are not below the detection limit are right at the detection limit, and then you multiply the concentration by the monthly effluent volume?
Kind Regards
From: Sent: 17 March 2023 14:40 To:
Subject: RE: queries regards your pollution inventory report
Hi
Thank you for the reminder and apologies for the delay comments below for the pollution inventory data and have resubmitted.
Waste: As discussed, happy with values entered. Waste data obtained from our waste transfer notes.
Air: Increased emissions of Hydrofluorocarbons (HFCs) and Perfluorocarbons (PFCs) due to the Thermal Treatment Plant being offline during 2022 and variation in process gas composition due to production demands and raw material sourcing.
Water: Mercury emission of 1.35kg is based on mercury concentration from our monthly composite effluent sample (discharge to river W1) and discharge volume to river. It is possible that this increase in 2022 is from contamination on wider site as there has been no change in process/material used which would lead to an increase emission of mercury.
Caustic soda (sodium hydroxide) used on site is produced using a non-mercury process with a product specification of Mercury <0.001 mg/kg. When reviewing previous calculations for environment agency data submissions, the maximum possible release of Mercury is based on the usage of sodium hydroxide. This is consistent with Table S3.5 of our permit which in Note 3 identifies that the annual limit of Mercury is obtained using a mass balance calculation. In 2022 our usage was 240412 kg and with a worst-case Mercury concentration of 0.001 mg/kg gives 0 kg Mercury emission. This is what has been reported in our Annual data submission.
We do not believe this is a permit breach as the Mercury isnt coming from our process. you give me a call to discuss if we need to submit a Part A for this?
please can
We have included the results from the lab over the past 2 years below and will follow up with the lab as we typically get less than detect results but last year we received and increased number of results at the level of detection.
Kind regards,
2
make this message and any reply to it public if asked to under the Freedom of Information Act, Data Protection Act or for litigation. Email messages and attachments sent to or from any Environment Agency address may also be accessed by someone other than the sender or recipient, for business purposes.
6