Environmental activities 2017
The biomass-fuelled Combined Heat and Power Plant (CHP) continued to run well during 2017. All site heat and power demands were satisfied and surplus renewable power was exported to the national grid. Air emissions were within the permitted levels. The CHP plant has maintained all of the required certifications, including the Good Quality CHP (GQCHP) quality assurance. All certifications were audited by government authorities during 2017.
The Workington Mill's environmental permit was reissued at the end of 2016, taking into account implementation of the BAT reference document and its requirements. Work is ongoing towards 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 already in 2014, was a capital investment project aimed at reducing the emissions of both fibre and coating pigment to the effluent. Continued work during 2017 consolidated the reductions already achieved and set a new performance level which is close to half of the previous baseline.
Following this, the focus has turned to the water balance to both stabilise and reduce the overall consumption and to modified bleaching chemistry. Increased process water storage capacity has been created to enable greater re-use of water streams and so reduce fresh water requirements.
A phased approach to heat recovery was started during 2017 and is already showing early signs of improved power generation and fuel usage.
Biological treatment will be implemented as a final stage once the internal improvements have been established. Alternative effluent treatment options are being evaluated to identify the best potential overall.
During the year, work has been ongoing in the development of an environmental programme towards the requirements in the latest BREF document for the Pulp and Paper sector. This document was finalised in 2014 and subsequently the mill responded to two Regulation 60 notices, which are the formal mechanism used by the authorities to request information. The first was a simple review of information and data in support of the Large Combustion Plant Directive (LCPD). The second was 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 Workington mill meets or exceeds the updated BAT Conclusion requirements other than in some aspects relating to emissions to water, where the new limits are significantly tighter than previously. Time has been requested by the mill to carry out operational and investment activities to enable the revised permit levels to be met. An environmental programme is in place towards achieving these requirements by the end of 2021.
This application for a derogation on the permit has been reviewed by the authorities, and the revised permit was achieved in Quarter 4 2016. This process is in accordance with the Industrial Emissions Directive (IED).
Environmental/Energy Management System Certification
Workington has been certified to ISO 14001 since 2003, and the certification was renewed in 2017. The mill also successfully completed the transition to the updated ISO 14001:2015 standard.
Workington has been certified to ISO 50001 since 2015 for its Energy Management System, which is fully integrated with the ISO 14001 environmental system.
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.
As of 1st April 2014, the UK Government 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 government's Timber Standard. In order to satisfy this, an assured report by an accredited organisation (to standard ISAE3000) has been submitted annually. This has been approved by the UK Government's regulatory body, Ofgem (The Office of Gas and Electricity Markets).
Ofgem carried out its first full audit of the CHP operation during 2015. The audit was successfully closed in the beginning of 2016. During 2017 additional audits were carried out on EUETS, CHPQA and Sustainability Criteria, with successful outcomes.
A review has been carried out against the Large Combustion Plant (LCP) BREF requirements, in line with the Industrial Emissions Directive (IED). All measures have been accounted for in the revised consolidated permit issued in 2016.
Investments / environmental measures
Most of the environmental work during 2017 has been concerned with preparation work for the revised limits which are 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 and forms the basis of a time-limited permit derogation for the mill's emissions to water.
The first phase of fibre and pigment recovery work has been completed and is now managed within normal operations. Measurable reductions have been seen over 4 years, with the focus now on consolidating this improvement and identifying the next steps. Operational procedures and routines are fundamental to this.
COD reductions have been measured resulting from work to optimise the bleaching recipe and conditions. Investment plans are being developed towards making this change permanent.
Water consumption per tonne of product has been further reduced during 2017. Increased buffer storage capacity for the water systems has been installed and is being commissioned. The focus is now on identifying applications where recovered water can be used in place of fresh water (surface water from a river) supplies and so continue to reduce consumption.
Biological effluent treatment options have been investigated based on industry best practice and mill pilot trials to assess the potential for Workington. The findings have been incorporated into the activity plan supporting the revised permit.
A phased approach to increased heat recovery is underway, aiming to optimize energy usage across the range of process conditions.
Production disturbances and complaints
Noise concerns have been the main theme in recent years when it comes to external complaints received at the mill. Over 90 per cent of complaints have been received from a single source and were dominated by low frequency noise nuisance. A noise management plan was formulated 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 buzzing from transformer pens also located on the west side of the mill. A device was installed during 2015 into the vacuum system vent to alter the sound characteristics and reduce impact at the neighbouring property. Noise monitoring has been carried out during 2017, in co-operation with the Environment Agency, which is being used to identify further opportunities. Complaints for noise were fewer during 2017.
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, 7 reports were made to the authorities, which is a clear reduction on 2016. Of these, there were 5 occasions for partial overflow from the effluent system to the Solway Firth, one occurrence where the weekly total of COD exceeded the permit level and one incident of slightly high suspended solids concentration. All have been reported and investigated and no environmental impact has been identified. The incident reports have been closed.
Follow-up of the environmental work 2017
Environmental activities underway in support of new permit:
ongoing activities to sustain benefits of reduced suspended solids in emissions to water.
ongoing bleaching optimisation work, resulting in new bleaching chemistry
sustained level of water consumption per tonne of board, at a lower level again than previous years
project to increase water systems' buffer storage capacity towards further reduced water consumption.
Identification of opportunity for water efficiency improvements, with clear potential identified for reduction overall.
Continued optimization of renewable electricity generation.
Capital investment projects carried out for improved heat recovery from process to support energy plant efficiencies and reduce water consumption.
Removal of redundant gas CHP plant and associated equipment is close to completion, with remaining work planned for 2018.
Environment/energy targets for 2018
Continue with the project work in support of the BREF compliance requirements.
Complete project to increase water systems' buffer storage capacityContinue activities towards reduced COD and suspended solids in emissions to water
Define future effluent treatment plant requirements, building on process optimization activities already identified and carried out.
Continue with optimization of energy generation and consumption.
Completion of removal of redundant gas CHP plant and associated equipment.