Environmental activities 2016
The biomass-fuelled Combined Heat and Power Plant (CHP) has continued to run well during 2016. 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 2015, a high pressure steam leak was detected on the steam turbine, which was fixed in March 2016. In the interim period the turbine steam systems were stabilised through partial supply of process steam to the mill from the auxiliary gas boilers. All electricity continued to be generated from renewable fuel; the CHP plant has maintained its Good Quality CHP (GQCHP) certification. The mill's environmental permit has now been revised to allow natural gas to be burned to generate steam, in order to be able to increase the production of net renewable power during periods of high national demand.
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, was a capital investment project aimed at reducing the emissions of both fibre and coating pigment to the effluent. Following this, the focus has turned to the water balance to both stabilise and reduce the overall consumption and to modified bleaching chemistry. 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 on-going in the development of an environmental programme towards the requirements in the new 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 last renewed in 2015. 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. The transition to the updated ISO 14001:2015 standard will take place during 2017.
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. This audit was successfully closed during Quarter 1 of 2016.
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 2016 has been concerned with preparation work for the anticipated new 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. Measureable reductions have been seen from the new fibre recovery plant and coating system modifications, with the focus now on consolidating this improvement. Operational procedures and routines are fundamental to this.
COD reductions have been measured resulting from work to optimize the bleaching recipe and conditions. Investment plans are being developed towards making this change permanent.
Water consumption per tonne of product has been sustained at 2015's low levels. Increased buffer storage capacity for the water systems is planned to be installed during 2017 to reduce consumption further.
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.
Production disturbances and complaints
Noise concerns have been the main theme when it comes to external complaints received at the mill. Over 90 per cent of complaints have been received from a single source and are 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 will be carried out during 2017, in co-operation with the Environment Agency, to identify any further steps which can be taken.
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, 15 reports have been made to the authorities. Of these, there were 10 occasions for raised COD concentration levels, related to higher bleaching requirements combined with reduced water consumption, three incidents of short-term sampling malfunctions, one chemical spillage on site and one incident of raised ammonia in the emissions to air. All have been reported and investigated and no environmental impact has been identified. The incident reports have been closed.
Follow-up of environmental/energy targets 2016
Achievement of new environmental permit, based on Pulp & Paper and Large Combustion Plant BREF documents.
Increased generation of renewable electricity.
Environmental activities underway in support of new permit:
pilot-scale trials completed for evaluation of anaerobic digestion of effluent
fibre & pigment recovery project completed
ongoing bleaching optimisation work, resulting in new bleaching chemistry
sustained level of water consumption per tonne of board, at a lower level than previous years
project underway to increase water systems' buffer storage capacity towards further reduced water consumption.
Environment/energy targets for 2017
Continue with the pre-study, pilot trials and development work in support of the BREF compliance requirements.
Continue with optimization of energy generation and consumption.
Removal of redundant gas CHP plant and associated equipment.