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11/06/2014
1
In conjunction with
Present
Advanced Seminar (IX)
The Metals Sector
Advanced Seminar (ix)
Session 5
Case studies – when things go wrong
Nigel Gibson & Tim Glews
11/06/2014
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Session 6 – Case studies
Aims:
- To understand better the role of regulator - actions
and responsibilities - when a regulated plant has
‘issues’
- To agree the relevant conditions to enforce in the
specific circumstances discussed in the case studies.
Session 6 – Case studies
Reminder of the ideal permit condition :
CLARITY
RELEVENT
ENFORCEABLE
WORKABLE
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Session 6 – Case studies
Case study 1
On-going complaints of particulate fallout at
the houses and gardens around the
installation – has also been confirmed by
officers.
Emission measurement reports on process
discharge stacks and vents haven’t indicated
a breach of emission limit concentrations.
Q: What action do you take at this point?
Session 6 – Case studies
Case study 1
Review of emission test reports and a visit to
site to view sampling process suggest that
testing was less than rigorous and not to
requirement of permit conditions.
Q: What further action may you consider now?
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Session 6 – Case studies
Case study 1
Simple sticky pad monitoring at the emission
points indicating that abatement on Local
Exhaust Ventilation not effective.
Session 6 – Case studies
Case study 1
A walk round the site suggests very dusty
atmosphere in places – fugitive emissions
escaping from roofline and from doorways.
Q: What does this condition suggest?
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Session 6 – Case studies
Case study 1
Finally, an inspection of the abatement plant
(fabric BFU) by the operator & regulator
shows damage to the bags & support frames
leading to bypass of the bag filters by PM.
Q: What action do you take next…….
1. Serve a suspension notice?
2. Serve an enforcement notice?
3. Caution the operator & take evidence?
4. Other?
Session 6 – Case studies
Case study 1
So, (in groups) what permit conditions would
you want in place to address the issues we
have discussed in case study 1?
10 Minutes work time & then report back.
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Session 6 – Case studies
Case study 2
As part of an improvement programme, the
operator renews ducting to furnaces and
other process areas and fits a larger
extraction fan.
Part of the ducting and flexible joints
connecting the fan to the stack are also
renewed but not the stack itself.
Q: Any comments so far?
Session 6 – Case studies
Ariel photo of the exhaust stack in question.
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Session 6 – Case studies
Case study 2
After the planned works are complete the
operator (excitedly!) switches on the power to
test the replacment ducting and new fan.
It all works beautifully!
Session 6 – Case studies
Case study 2
However! the next day a number of local
residents complain to the regulator that
particulate matter has been deposited on
cars, windows washing and vegetation.
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Session 6 – Case studies
Case study 2
• The regulator visits the complainants
properties to investigate. White UPVC
window frames & doors, light coloured cars &
3 caravans located to the South-West of the
foundry building exhibit orange particulate
coloration which is rough to the touch. The
deposit will not brush off?
Session 6 – Case studies
What is the mystery fall out?
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Session 6 – Case studies
Case study 2
So, (in groups);
1. What was the cause of the deposit?
What action should the regulator take?
2. What permit conditions would you want in
place to address the issues we have
discussed in case study 2?
10 Minutes work time & then report back.
Session 6 – Case studies
Case study 3
The foundry melts using traditional cupola
technology. Residents regularly & frequently
complain of particulate fallout from
operations. Black and orange dust on
windows, window frames, garden, washing,
cars.
Q: What are the possible sources of the PM?
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Session 6 – Case studies
Case study 3
Regulator visits the installation and residential
properties in the near neighbourhood and
reviews complaints.
Q: What is the regulator looking for at the
installation / residential properties?
Session 6 – Case studies
Case study 3
Regulator witnesses uncovered delivery of coke
& accumulations on the floor surface of fine
black sand.
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Session 6 – Case studies
Case study 3
Regulator witnesses burned scrap delivery
Session 6 – Case studies
Case study 3
Regulator witnesses a coke delivery by lorry.
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Session 6 – Case studies
Case study 3
Regulator witnesses delivery by lorry!
Poor Quality Scrap! Too hasty to deliver!
Session 6 – Case studies
Case study 3
So, (in groups) what permit conditions would
you want in place to address the issues we
have discussed in case study 3?
10 Minutes work time & then report back.
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Case studies
Reminder (again) :
CLARITY
RELEVENT
ENFORCEABLE
WORKABLE
