Application for a Revised IPPC Licence
Attachment ID.1 -
Operational Information Requirements
53460-004
Attachment 01 Enal
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:42
SmartPly Europe Limited Application for a Revised IPPC Licence Attachment D.1 - Operational Information Requirements
CONTENTS
Section Page No
1. SITE OPERATIONS ...................................................................................................... 1
2. UNIT PROCESSES ....................................................................................................... 2
3. LABORATORY TESTING ............................................................................................. 4
Appendix D.1 .I SmartPly Europe Limited Process flow diagram
Attachment Dl final Page i
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:42
SmartPly Europe Limited Application for a Revised IPPC Licence Attachment D.l - Operational Information Requirements
I. SITE OPERATIONS
Operations at the SmartPly Europe Limited site may be summarised as follows,
The primary raw material, untreated cut logs, are delivered to the site by trucks and are inspected for quality and weighed on the weighbridge at the site entrance. Current delivery times are restricted to between O&:00 and 21:OO hours Monday to Friday and 08:OO - 13:00 hours on Saturdays.
SmartPly Europe Limited request as part of this IPPC Licence review application that the Agency review the current permitted delivery hours and allow unrestricted 24-hour deliveries to the site in order to reduce traffic congestion along the public access road to the site and to improve the safety of access to the weighbridge.
Following inspection and weighing, the delivery trucks are unloaded by a loader unit in the yard area. Logs are sorted and stacked according to their species.
Logs are transported to the log infeed system by the loaders where they are conveyed to the debarker system which removes all of the bark on the logs.
Debarked logs are then conveyed to the strander where logs are shredded into flakes. Flakes are stored in the wet bins.
Stored flakes are transported to either of four dryer units. Emissions from the dryers are passed through the air pollution abatement system (WESP’s).
Dry flakes are then conveyed to the blenders where resins are added to bind the strands together.
The strands then pass to the forming line which orientates the strands in the desired nature.
The product then enters the press where heat and pressure are applied to form the final orientated strand board (OSB) product. Emissions from the press are vented to the WESPs.
Finally, the OSB is cut to size as per customer requirements.
All product is transported from the site via trucks.
!
,’ ,I ‘.
,,,,’ 1,
i(, ‘1, ”
”
Attachment D I operational information
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:42
SmartPIy Europe Limited Application for a Revised IPPC Licence Attachment D.1 - Operational Information Requirements
2. UNIT PROCESSES
The SmartPly Europe Limited production unit processes are described in detail below. A process flow diagram is presented in Attachment D.l .I.
Debarking
To prepare wood for Waferizing, it is necessary to remove all bark from the incoming logs. The logs are conveyed into the debarker infeed system. The debarkers are of drum type design. The bark removed at the debarkers is dropped into a waste conveyer system and feeds to the log fuel system where it is burned or to the stockpile for offsite disposal.
Washing
Following debarking the logs are washed in the log wash system. The main purpose of this is to remove sand and grit from the logs. It also aids the flow of logs (the logs flow better when they are wet.
Waferiring
The logs are then conveyed from the debarker to the waferiser infeed system where wood is stacked in bundles prior to being waferised. A machine called a waferiser produces the strands which are between 75 to IOOmm long, 15 to 25mm wide and approximately 0.7mm thick. The freshly cut green wafers, which contain approximately 55% moisture by weight are then transferred to a green storage bin prior to the introduction to the dryers. The sequential events for a controlled flow of logs, through the debarker and into the waferiser and the conveying to the wet storage bins of strands thereafter are automatically supervised and interlocked so a malfunction of equipment will shut down the process. The operator also has overriding power to shut down all equipment instantaneously in case of an emergency.
Drying
The next step in the process is the drying of strands. The process utilises four direct fired triple pass rotary drum dryers. The strands are pneumatically conveyed through these triple pass dryers while exposed to a stream of hot air that is generated in each of the dryers. The strands exit the driers at a significantly reduced moisture content.
The ignition and precisely controlled burning of fine wood and dust particles generate the heat for each dryer. The wood fines and dust are collected as fines from the dry flakes screening, the board cutting and trimmings that are pulverised in the hammermills as well as dust collected from the board surface sanding.
The flame and temperature of each dryer is continuously monitored. The dryers are controlled to an outlet temperature representing an outlet moisture content of the product, suitable for the thickness of the final board and type of resin being used.
The exhaust gases contain ash, carbon monoxide, sulphur dioxide and nitrogen oxides from the combustion of wood in the dryer burners. In the dryer chamber, small quantities of wood fines result from the abrasion of wafers moving through the dryers. In addition,
Attachment D 1 operational information
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:42
SmartPly Europe Limited Application for a Revised IPPC Licence Attachment D.l - Operational Information Requirements
organic compounds naturally occurring in the wood are driven from the wafers due to the heat in the driers.
Organic compounds are emitted from the wood gases with some condensing to form aerosols as the gas cools during passage through the dryer exhaust system. Condensation occurs when the exhaust gas from the dryers are cooled to temperatures below the boiling point of the organic compounds. The organics attach themselves to the fine solid particles which act as a condensation nuclei. These aerosols are sub-micron in size and difficult to capture.
After exiting the driers, the wafers are transferred pneumatically along the drier exhaust to the primary cyclones which separate the wafers from the dryer exhaust gases. The exhaust gases along with the entrained fines exit the primary cyclones and then pass through a wet electrostatic precipitator where fines, condensible organics and small amounts of VOC’s are removed. The collected material is dewatered and the solids are fed to the thermal oil heater and the water is returned to the WESP’s. Exhaust gases exit to atmosphere via a 90m stack.
Screening
After drying, the material is screened to remove all sub-sized strands and all dry fines material. This rejected material goes through a grinding process to ensure uniformity and compliance with requirements and is then transported to the dry fuel metering and storage bins prior to being burned.
Blending
The next step in the process is the blending of the strands with a mixture of wax and resin that will fuse the strands together when heated and under pressure in the press. The dry, screened strands are conveyed into the blenders. Here the strands are tumbled in a drum while extremely precise metering systems determine the exact amount of liquid wax and resin to enter the distribution spinner heads.
These spinner heads rotate at very high speeds and distribute the resin and wax inside the rotating drum over the tumbling flake surface to ensure even bonding in the press, The forming stations and press line requirements, depending on production line speed and product thickness, determine the flake flow through the blenders.
Forming and Pressing
The resin-coated strands must be laid down in a mat which when subjected to heat and pressure becomes the finished board. This mat lay arrangement takes place through the use of four separate forming machines, a bottom face, a bottom core, a top core and a top face.
Each of the four machines discharges a continuous ribbon of product, which is stacked on a carrying device called a caul, and/or on top of the previous layer to form a loose mat.
Attachment 0 1 operational information
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:42
Smart/J/y Europe Limited Application for a Revised IPPC Licence Attachment D.l - Operational Information Requirements
3.
The continuous mat of loose strands leaving the formers will be weighed and conveyed. Crosscut saws cut the mats to the length by cutting out a crosswise section of the mat.
The individual cauls each loaded with its own formed mats can now be accelerated away from the forming station to be fed into a multi-opening press loading cage.
The caul is used to carry the loose mat to the loader and into the press. The loader acts as an accumulator and transitional device from a continuous process to a batch process.
The loose mats will be compressed between thermal oil heated steel platen, after being loaded into the press. Equally, the resin has to cure and set so that the board thickness, properties and dimensions taken under pressure do not change once pressure is released from the main press.
When the press opens, it unloads a batch of boards into the unloader cage while simultaneously loading a new batch from the loader cage to resume a new press cycle.
Emissions from the pressing operation consist of VOC’s which are emitted from the resins and VOC’s which are given off from the wafers in the boards. Emissions of water vapour and VOc’s result from the pressure and heat applied during the pressing operation which decreases the amount of moisture in the board considerably. VOC emissions which are emitted from the wafers during the pressing operation are primarily terpenes which were not driven off in the drying process. Emissions are vented to the WESP’s prior to discharge to atmosphere.
Trimming, Sanding, Stacking, Painting, Strapping, Storage
The product exiting the press will be separated at the board caul separator. The empty cauls return for refill to the forming station, the board is routed to the sawline.
The pressed boards are trimmed to final product size with a portion routed to the sander and tongue and grove machine. Each board is grade stamped. Boards are stacked and bundled together with a band-strapping machine. The edges of the boards may be sprayed coated with a water resistant edge seal. The finished product is then spray stencilled with the Company logo and stored or despatched.
LABORATORY TESTING
SmartPly Europe Limited have a quality testing laboratory in which they conduct quality checks on samples of product. In accordance with SmartPly Europe Limited’s quality accreditation (EN 300) Smartfly Europe Limited are obliged to test a number of boards of each thickness per shift. These boards are measures and cut up for a series of destructive tests as described in Table 1. The results of the tests are compared to the required standard and pass or fail according to the criteria set down in the EN 300 standard.
Attachment 0 1 operational information
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:43
SmartPly Europe Limited Application for a Revised iPPC Licence Attachment D.1 - Operational Information Requirements
Table 1 Test methods
Test
Internal lnstron tensile test Bond machine
MoeIMor lnstron test machine
2 hour boil internal bond 24 hour swell
Moisture content
Dimensions A.
Equipment
Waterbath, lnstron tensile test machine
Waterbath
Oven
Measuring tape
Synopsis
50mmX50mm OSB samples are glued to aluminium blocks, cooled in water and placed in test machine. Machine pulls sample apart recording the stress and strain Individual samples tested for flexural properties Similar to internal bond, sample is boiled in water for 2 hours and then dried at 70°C for 16 hours 50mmX50mm OSB samples measured prior to immersion in water for 24 hours and measured after for swell % 1 OOmmXl OOmm OSB sample are weighed prior to drying in an oven for 24 hours Calibrated measurement of board length, widths and diagonals
Duration
30 mins
30 mins
18 hours
24 hours
24 hours
60 mins
Attachment D 1 operational information
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:43
SmartPly Europe Limited Application for a Revised IPPC Licence Attachment Il.1 - Operational Information Requirements
Appendix D.1 .I
Process flow diagram
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:43
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:43
IPPC Licence
Attachment D.2 - Development & Operational History of the Site
Issue No
53460-004
Attachment 02 final
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:43
Smart/J/y Europe Limited Application for a Revised IPPC Licence Attachment D.2 - Development and Operational History of the Site
CONTENTS
Section Page No
1. DEVELOPMENTAL AND OPERATIONAL HISTORY . . . . . . . . ..*....................................... I
2. FUTURE DEVELOPMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3. PROSECUTIONS .,......,....,..................................................................*.................*....... 4
4. RECORDED INCIDENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..~........................................... 5
Appendix D.2.1 SmartPly Europe Limited Newsletter October 2004
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:43
SmartPly Europe Limited Application for a Revised IPPC Licence Attachment D.2 - Development and Operational History of the Site
1. DEVELOPMENTAL AND OPERATIONAL HISTORY
SmartPly Europe Limited is a wholly owned subsidiary of Coillte and was formerly known as Louisiana Pacific Coillte Ireland Ltd. LPCI was incorporated in Ireland in 1993 as a joint venture concern of Coillte and the U.S. Fortune 500 multi-national building products company Louisiana Pacific Corporation headquartered in Portland, Oregon. The relative ownership stakes were 25% and 65%, respectively.
Discussions began with Louisiana Pacific in January 1993 with a flnalised joint venture contract and construction budget of f39.3 million agreed in September, 1993. Site preparation began in July, 1994 with the first board being produced in March, 1996. The final cost of construction was f47.0 million. Budget overruns were due to planning permission and EPA requirements, delays in equipment delivery and the incorporation of a T&G line for the production of flooring and sanded panels.
The Smartfly Europe Limited facility was developed on a greenfield site which was formerly used for agricultural purposes. There are no recorded disused underground tanks or storage areas within the site boundaries. A review of historical Ordnance Survey Ireland maps for the site area confirm that there were no industrial buildings or workings at the site prior to the development of the Smartfly Europe Limited facility.
The single facility co-located with the EU-funded Belview Port in County Kilkenny produces commodity, (OSB2), and construction grade, (OSB3), oriented strand board products. Oriented strand board or OSB is a composite wood-based panel product composed of thin wafers of pine and spruce pulp-grade wood pressed under heat and pressure with wax and synthetic resins.
The resulting product is an environmentally responsible and cost effective substitute for softwood. The origins of the product in North America in the 1970’s coincided with the protection of large old growth “peeler” logs used for plywood. OSB being produced instead from renewable plantation grown softwood species. A brief 30 years later the product enjoys a 56% share of the U.S. structural panel market and more than a 70% share of the wall sheeting segment.
In relative terms, OSB is a recent market entry in Europe with the first production facilities in France and Scotland having their origins in the 1980’s. The commercial rationale for the product in Europe is to provide the market with a cost effective softwood plywood substitute that eliminates the foreign exchange and logistical risk of sourcing panels from North and South America. The panel enjoys the fastest growth rate of any in Europe: in excess of 18% per annum.
The Belview facility utilises a single multi-opening press with fourteen flights and a nameplate capacity of 350,000m3. With the complexities of a European product mix the effective capacity is approximately 310,OOOm3. The current product mix is some 57% commodity grade in thicknesses from 8mm to 18mm and 43% construction grade in thicknesses from 9mm to 22mm.
Attachment 02
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:43
SmartPly Europe Limited Application for a Revised IPPC Licence Attachment D.2 - Development and Operational History of the Site
End uses for the commodity grade products include industrial and export packaging, furniture forming, DIY, site hoarding, agricultural and garden sheds and structural uses in dry environments while the construction grade products find their way into flooring, roofing and wall sheeting.
There is a long-term supply agreement with parent company, Coillte, in place for a maximum of 650,000m3 of pulpwood per annum. The facility is free to source wood from independent growers, but in practice the amount is negligible.
The facility is the largest single consumer of pulpwood in Ireland and is expected to accept and estimated 390,000m3 of timber this year. Resins and wax are sourced from the UK and Benelux.
While the Belview facility serves the domestic Irish construction and industrial markets, more than 75% of the output is directed to the export market, the target being the UK and Benelux. There are also occasional seasonal exports to the United States.
The gains in market share made by Smartfly Europe Limited, the overall outlook for OSB as the fastest growing panel product in Europe and the strategic position that the Belview business occupies in the overall economics of the supply chain for pulpwood in Ireland assure the economic future of the panel product business.
Background to the Environmental Requirement for Stack Height Extension
The manufacture of OSB at Belview involves the drying of large amounts of un-treated wet timber in four wood fuel fired rotary dryers. Potential air pollutants such as wood dust, ash, volatile organic carbons from the drying process are removed using state of the art air pollution devices known as wet electrostatic precipitators (WESP’s). The EU has determined that the WESP system is best available technology (BAT) for the treatment of emissions from panel board manufacturing operations. SmartPly Europe Limited consider that the most appropriate guidance in BAT for Integrated Pollution Prevention and Control (IPPC) for the Oriented Strand Board Sector is comprehensively detailed in the document entitled “IPPC Secretary of State’s Guidance for the Parficleboard, Oriented Strand Board and Dry Process Fibreboard Sector”, Sector Guidance Note IPPC SGI (June 2003) as published by the UK Governments Department for Environment Food and Rural Affair (DEFRA).
The WESP’s remove air borne pollutants by passing the dryer exhaust gases through a wet scrubber system and an extremely high voltage electro-filter. An additional effect of the WESP action is that the exhaust gases are cooled from approximately 200 degrees centigrade to an average of 45 degrees. The final treated emissions are released from the single emissions stack which is currently being increased from 42 meters to 90 meters above ground level.
While the air pollution devices are extremely effective for removal of most timber related pollutants, in the regions of 99% efficiency for removal of particulate loading, in the region of 99% efficiency for removal of the particulate loading from the exhaust gases, they were not designed for removing timber related odours that are liberated during the drying of
Attachment 02
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:43
Smart/J/y Europe Limited Application for a Revised IPPC Licence Attachment D.2 - Development and Operational History of the Site
untreated wood. It is these natural odours that can give rise to nuisance complaints from around the site. Another disadvantage of the WESP system is that it adds excess moisture to the plume increasing its visibility while decreasing its temperature and thermal buoyancy.
The SmartPly Europe Limited facility is located in a hollow at the side of a valley that runs parallel with Snow hill, Drumdowney. The location of the facility in this hollow to the East of Snow hill has resulted in the exit point from the emission stack being approximately at the same level, or below, some residences on Snow hill. During the prevailing westerly winds, air currents are swept over the building and are dragged down into the valley below the site due to the aerodynamic effect of the building and the surrounding terrain. This wind and complex terrain interaction results in the emissions form the facility coming to ground at or near residences on Snow hill, Drumdowney. The problem is exacerbated by the cooling and wetting effect of WESP has on the emissions. As the moisture content increases and the temperature decreases the plume becomes less buoyant and increases its tendency to sink towards the ground. Plume grounding is not recorded as a problem in Easterly or Northerly winds, but may occur occasionally during Southerly winds.
The Smartply facility has been in operation for approximately seven years. In that time there have been a number of complaints from local residents in relation to plume grounding. Both the facility and the EPA have received and attempted to deal with these complaints. Since 1999, thirty-three complaints have been received from local residents relating to plume grounding, the vast majority of them from residents of Snow hill.
The company, towards mitigation of the plume grounding effect has taken a number of actions. Ground level concentrations of significant emissions were initially determined to ensure that there was no potential health impact. Ground level concentration measurements of formaldehyde are conducted on a fortnightly basis and to date no measurements have exceeded relevant limit values. The increase in stack height to 90m will further ensure that ambient ground levels of formaldehyde will be negligible and as such, SmartPly Europe Limited request that the Agency remove the requirement for ambient formaldehyde monitoring. This conclusion has been validated by the results of an air dispersion moclelling study of formaldehyde emissions from the 90m stack which was conducted to establish maximum ground level concentrations (GLC’s) within a 5km radius of the SmartPly Europe Limited facility. The results of the modelling study conclude that GLC’s of formaldehyde are significantly below recommended limit values for both environmental and human health protection. A comprehensive report is included in Section 1.1 -Assessment of Impact of Emissions to Atmosphere of this IPPC Licence review application.
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:43
SmarWy Europe Limited Application for a Re\iised IPPC Licence Attachment D-2 - Development and Operational History of the Site
2. FUTURE DEVELOPMENT
SmartPly Europe Limited intend as part of a f&year programme of on-going continual improvement relating to the environmental performance of the facility, to reduce all sources of environmental emissions to minimise the impact of site activities on the local receiving environment and on local residents living in the vicinity of the site. Details of Smartfly Europe Limited’s Targets and Objectives for 2004-2005 are presented in Appendix C.1.3 of Attachment C. I - Site Management and Control of this IPPC Licence Review.
As part of SmartPly Europe Limited’s community relations, a recent (October 2004) company newsletter has been published and distributed to residents and businesses in the area which clearly explains the current stack extension project. A copy of this newsletter is presented in Appendix D-2.1.
3. PROSECUTIONS
SmartPly Europe Limited have not been convicted or prosecuted under the Environmental Protection Agency Act 1992 or the Protection of the Environment Act 2003.
SmartPly Europe Limited have not been convicted or prosecuted under the Waste Management Act 1996, or the Local Government (Water Pollution) Acts 1977 and 1990. Smartply Ltd. have had no other prosecutions brought against them.
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:43
SmartPly Europe Limited Application for a Revised IPPC Licence Attachment D.2 - Development and Operational History of the Site
4. RECORDED INCIDENTS
The following incidents have been recorded and reported to the EPA between the period 1998 - 2003
N
Date Incident
12-12-2003 Fire in WESP 2 resulting in damage to droplet eliminator
26-09-2003 Fire at unloader hoist motor
23-1 I-2001 Fire in WESPs
14-09-2001 Resin spill
20-02-2001 Fire in dry flake storage bin
25-1 O-2000 Fire in bark pile conveyor
31-03-2000 Leak from WESP abort stack
25-02-2000 Fire in enclosed flake conveyor.
20-01-2000 Fire in main fire dump conveyor
23-1 l-l 999 Dust release from the fire dump
19-05-1999 Baghouse filter leak
18-03-I 999 WESP malfunction
21-08-1996 Baghouse filter leak
IOTE
All external complaints are included in SmartPly Europe Limited’s Annual Environmental Reports as submitted to the Agency.
Attachment D2
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:44
SmartPIy Europe Limited Application for a Revised IPPC Licence Attachment D.2 - Development and Operational History of the Site
Appendix D.2.1
SmartIVy Europe Limited
Newsletter - October 2004
Anacnment uf tmal Page 1
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:44
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:44
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:44
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:44
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:15:28:44
