Environmental activities 2015
The biomass-fuelled Combined Heat and Power Plant (CHP) has continued to run well during 2015. All site heat and power demands are satisfied and surplus renewable power is exported to the national grid. Air emissions are within the permitted levels. During March, the plant was shut down for its first planned major maintenance and statutory inspection shut. All planned work was carried out and no significant issues were raised. Later in the year, a high pressure steam leak was detected on the steam turbine. In discussion with the equipment supplier, this will be fixed in March 2016.
Also during the year, the implementation of the BAT reference document has been followed up. For the Workington mill, there is work to do in meeting the new BAT Associated Emission Limit (BAT-AEL) values for the emissions to water. In preparation for this, several studies have been completed, including a BAT options assessment and a mill water balance. The result is the development of a phased operational and investment plan to allow permit compliance to be achieved. The initial phase, started in 2014, is a capital investment project aimed at reducing the emissions of both fibre and coating pigment to the effluent. Reductions of at least 33% have already been achieved during 2015 in this respect. Following this, the focus will turn to the water balance to both stabilise and reduce the overall consumption and then to biological treatment. Alternative effluent treatment options are being evaluated to identify the best potential overall.
During the year, work has been on-going in the review of the new BREF document for the Pulp and Paper sector. This document was finalised in 2014 and subsequently the mill has received 2 regulation 60 notices, which are the formal mechanism that the authorities use to request information. The first is a simple review of information and data in support of the Large Combustion Plant Directive (LCPD). The second is a full BAT review of the Workington mill processes and emissions set against the BREF document, for which the mill replied formally during Quarter 1 2015.
The significant aspect for the Workington mill is the emissions levels to water. Time is being requested by the mill to carry out operational and investment activities to enable the revised permit levels to be met. This application for a derogation on the permit is being reviewed by the authorities, with the revised permit expected during 2016. This new permit will contain the emission limit values for the period to 2018 (based on the current permit) and for the period 2018 onwards. The limits will either reflect full or derogated compliance. This process is in line with the Industrial Emissions Directive (IED) and will be negotiated during 2016.
Workington has been certified to ISO 14001 since 2003, and the certification was renewed in 2015. Since 2005 the mill has been certified according to the FSC® (FSC-ID) standard.
All national certifications have been achieved associated with the production of renewable energy from the biomass CHP plant.
In 2015, the Workington mill also achieved certification to ISO 50001 for its Energy Management System, which is fully integrated with the ISO14001 environmental system.
As of 1st April 2014, the Government has introduced requirements that all renewable fuels need to meet the Sustainability Criteria as defined in the European Renewable Energy Directive (RED) and UK Renewables Obligation Order (ROO). This means that all fuels have to be classified by consignment and have to meet requirements and greenhouse gas emissions (GHG) and Land Criteria. This requires a monthly calculation and submission of carbon emissions throughout the full supply chain, back to the forest, and including all transport and processes stages. Threshold limits are applied in order to satisfy the requirements. For the land criteria, it has to be demonstrated that all fuel is legal and sustainable by applying the governments Timber Standard. In order to satisfy this, an assured report by an accredited organisation needs to be submitted by June each year. The requirement has been achieved during 2015 and will now become an annual event.
The government's regulatory body, OFGEM (The Office of Gas and Electricity Markets), carried out its first full audit of the CHP operation during 2015.
A revised permit has been received in quarter 4 which reflects the up-to-date requirements of the Large Combustion Plant (LCP) Directive.
Investments / environmental measures
Most of the environmental work during 2015 has been concerned with preparation work for the anticipated new limits which will be associated with the BAT document. Based on comprehensive process studies and engineering work a phased plan has been developed. The plan is based on firstly reducing the specific losses of pigment and fibre into the effluent streams, alongside balancing the mill water system and finally implementation of biological treatment. The plan will be phased over some years. As a start, work has begun on the pigment and fibre recovery part. Operational procedures and practices have and are being thoroughly investigated and supported by an investment plan to install new fibre recovery and coating screening plant during 2016.
Increased buffer storage capacity for the water systems is planned to be installed during 2016 with the aim of reduced consumption per tonne of board produced. Biological effluent treatment options are currently being investigated based on industry best practice and mill pilot trials to assess the potential for Workington.
Production disturbances and complaints
Noise concerns have been the main theme when it comes to external complaints received at the mill. Over 90% of complaints have been received from a single source and are dominated by low frequency noise nuisance. A noise management plan has been formulated which seeks to address the suspected causes. The attention is focused on the vacuum stack vent which is located on the west side of the mill and the buzzing from transformer pens also located on the west side of the mill. A device has been installed during 2015 into the vacuum system vent to alter the sound characteristics and reduce impact at the neighbouring property.
All incidents are reviewed and information fed back to the complainant. Incidents of this nature are also reviewed at the community liaison meeting which has representation from the local community and authorities.
Regarding the permit, 18 reports have been made to the authorities. Of these, there were 6 occasions for raised COD levels, related to higher bleaching requirements, 5 incidents of short-term sampling malfunctions, 2 small direct discharges to sea during clarifier maintenance activities, raised run-off water pH and 2 incidents on site which did not affect the final effluent. All have been reported and investigated.
There is also an open report relating to the unusual operating conditions in the CHP boiler which will be closed in March 2016.
Follow-up of environmental/energy targets 2015
- ISO 50001 certification achieved.
- BREF compliance review submitted to Environment Agency.
- Environmental improvement plan developed.
- Fibre and pigment recovery project (improvement plan phase 1) implemented.
- Further anaerobic digestion / biogas trial evaluation started.
Environment/energy targets for 2016
- Achieve new permit in line with the BREF requirements.
- Continue with the pre-study, pilot trials and development work in support of the BREF compliance requirements.
- Further anaerobic digestion / biogas trial evaluation to complete.