Emissions to Air Pfizer Cork Ltd., Inchera, Little Island ... · Attachment E.1 Emissions to Air Pfizer Cork ... Attachment E.1 Emissions to Air - Main Text_Final.doc Page 1 1

Attachment E.1 Emissions to Air Pfizer Cork Limited, Inchera, IPPCL Application

Attachment E.1 Emissions to Air - Main Text_Final.doc

Attachment E.1

Emissions to Air

Pfizer Cork Ltd., Inchera, Little Island, Cork

IPPCL Application

May 2007 Issue No: 2 45078720

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Attachment E.3

Page i

CONTENTS

Section Page No

1. CHARACTERISATION OF EMISSIONS TO AIR ........................................................... 1

1.1. Introduction....................................................................................................................... 1 1.2. Requested Changes ........................................................................................................ 1 1.2.1. Boiler Fuel ........................................................................................................................ 1 1.3. Main Emissions ................................................................................................................ 2 1.4. Minor Emissions ............................................................................................................... 2 1.5. Potential Emissions.......................................................................................................... 2 1.6. Assessment of Emissions to Air regarding S.I. No. 394 of 2004 ..................................... 3

2. ABATEMENT OF EMISSION TO AIR............................................................................. 4

2.1. Introduction....................................................................................................................... 4 2.2. Description of Abatement................................................................................................. 6 2.2.1. Condensation ................................................................................................................... 6 2.2.2. Scrubbers ......................................................................................................................... 9 2.2.3. HEPA Filtration............................................................................................................... 11 2.2.4. Carbon Adsorption ......................................................................................................... 12

Appendix E.1.1: - List of Emissions to Air

Appendix E.1.2: - Drawings indicating Emission to Air

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Page 1

1. CHARACTERISATION OF EMISSIONS TO AIR

1.1. Introduction

Emissions to air from the Pfizer facility at Inchera comprise:

1. Emissions from steam raising boilers;

2. Main Emissions;

3. Minor emissions, i.e., point source emissions to air that are less than pre-

determined EPA thresholds;

4. Fugitive emissions; and

5. Potential emissions.

Subsequent sections provide an overview of all other major and minor emission points

including a description of the abatement technologies used.

A full list of all point source emissions is presented in Appendix E.1.1.

The location of all main emissions and minor emissions are depicted on drawing FSK-

2022 contained in Appendix E.1.2.

1.2. Requested Changes

1.2.1. Boiler Fuel

There are a total of two operational steam-raising boilers on the Pfizer site (A17 & A18).

Demand is normally met by one boiler modulating according to steam demand with other

boiler on standby. The duty/standby mode is rotated between boilers to provide for even

operational hours.

Currently, both boilers use natural gas only but Pfizer is considering the future use of light

fuel oil or diesel as an occasional substitute for natural gas. The emissions from the

boilers are considered ‘significant’ in the context of declaring the emissions for IPPC

licensing purposes since, should light fuel oil be burned, then all boiler rated input thermal

capacities are significantly larger than 250 kW considered as a ‘rule-of-thumb’ for

declaring such emissions.

A general air dispersion modelling report has been completed dealing with all major

emission sources on the site. The use of light fuel oil with a sulphur content of up to 0.2 %

was included in the assessment specifically to assess the air quality impacts of the

proposed use of oil, and allowing for impending legislation on the maximum content of

sulphur in fuel oils. The details of the modelling methodology and the model inputs and

outputs are contained within the report. The report concluded that even when running the

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Page 2

two boilers at full load using a light fuel oil with 0.2 % S1, no exceedance of the statutory

limits from SO2, NOx or PM10 is anticipated. The normal operational mode, i.e. only one

boiler running, and the use of a fuel oil with substantially less than 0.2 % S will result in

no significant change to air quality in the vicinity of the Pfizer site.

1.3. Main Emissions

In addition to the boilers described in Section 1.2.1 above, there are a total of 9 point

source main emissions on the Pfizer site. All emissions are derived from production and

the main pollutants are organic solvents and particulate matter with occasional emissions

of inorganic substances.

All of the main emissions currently being used have some form of abatement equipment

to ensure that the emissions to atmosphere are very significantly reduced and that they

meet the requirements of discharge standards set by the EPA. Details of the abatement

systems employed are presented in Section 3 of this Attachment.

Emission point A6 is currently not in use. Pfizer plans to provide abatement for this unit

to ensure that the required EPA standards for emissions are met should the emission

point be required. One option is to tie this emission point into additional abatement

equipment.

1.4. Minor Emissions

There are approximately 50 minor emissions to atmosphere from the Pfizer site. These

emissions contain only very small quantities of pollutants. These emissions can be

categorised as follows:

• Laboratory fumehoods;

• Very small boilers used for space heating;

• Storage tank vents; and

• Building or non-production system extraction systems.

1.5. Potential Emissions

Potential emission at Pfizer are those emissions that may occur in the event of an

event that may occur outside of normal set points or operational conditions. The main

sources of potential emissions are:

• Pressure relief valves lifting;

• Bursting disks rupturing;

1 Light fuel oil was used for modeling as this presents the worst case scenario, because light fuel oil usually has

higher sulphur content than diesel.

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• Bypasses on abatement equipment.

A full list of all point source emissions is presented in Appendix E.1.1.

The location of all main emissions and minor emissions are depicted on drawing

FSK-2022 contained in Appendix E.1.2.

1.6. Assessment of Emissions to Air regarding S.I. No. 394 of 2004

Pfizer has carried out an assessment of the main emissions to air in respect of the

Schedule contained in S.I. No. 394 of 2004 (the revised Licensing Regulations).

The result of this assessment is presented in Table E.1.1.

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Page 4

2. ABATEMENT OF EMISSION TO AIR

2.1. Introduction

Pfizer has invested very significantly in emissions to air abatement. The abatement

systems employed are considered BAT for the nature of activities at Pfizer. In general,

the types of abatement may be summarised as follows:

Type of Abatement Target Pollutants

Primary and secondary

condensation

Condensable volatile organic solvents

Scrubbers:

- Water

- Caustic

- Hypochlorite

Miscible volatile organic solvents

Acid fumes, miscible volatile organic compounds

and soluble inorganic compounds

Deactivation of an active ingredient

HEPA Filtration & Filter Pad Particulate matter

Carbon adsorption Volatile organic solvents and including chlorinated

organic solvents.

Figure E.1.1 depict, very simply, the interconnection between the various means of

abatement equipment and the main emission points serviced by the abatement systems.

Excluded from Figure E.1.1 are the condensers, of which there are many and which are

located local to the process equipment within the production building

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2.2. Description of Abatement

2.2.1. Condensation

Condensation uses the principle of cooling condensable vapours to below their dew point

at process conditions so that the vapours condense to liquid which then drops out of the

gas stream being treated. The key pollutants targeted at Pfizer are condensable organic

solvents used in production and that are typically vented off from reactors, dryers and

other processing equipment.

The target compounds have differing thermodynamic properties and so will condense out

of the gas stream being treated at different temperatures and at different rates. Other

factors, such as the system pressure and condenser design, will also effect the efficiency

of condensation.

At Pfizer, there are different condenser layouts and designs employed and these systems

are contained within the production building and close to the equipment which they serve.

All condensation employed is carried out as indirect cooling with no intimate contact

between the cooling medium and the gas stream being cooled.

Condensation systems employed may be broadly classified as:

- Primary condensation, which uses water as the cooling medium, typically

cooling tower water at between approximately 18 C and 23 C;

- Secondary, or low temperature, condensation using glycol/water mix or

methanol/water mixes at temperatures approaching –10 C. The cooling

medium in each case is supplied from a closed loop refrigeration system

located in the utilities buildings.

For some processes, only primary condensation is used and in others both primary

condensation followed in series by secondary condensation. The latter, operating at a

much lower cold side temperature, will achieve very high rates of condensation of those

condensables that have not been removed in primary condensation.

Given the multi-product nature of Pfizer activities, the condenser systems on site are

arranged in such a manner that a high degree of flexibility in choosing condenser layout

is achieved.

Condensers used at Pfizers are generally one of two designs:

1. Shell and tube heat exchangers;

2. Graphite block heat exchangers.

Both types of condenser operate on a similar principle: - the gas is indirectly cooled by a

coolant.

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For shell and tube exchangers, the cooling medium flows through banks of metal tubes.

These tubes are bundled inside an outer shell through which the gas stream to be cooled

flows. As the warm gas contacts the cold tubes, the gas flow is cooled and liquid VOC’s

drop out and flow from the condenser shell to the receiving vessel.

Graphite exchangers are more suitable for primary condensation and so are very widely

used for reactor overhead condensers. The main reason for employing block type

graphite heat exchangers is their great flexibility. They can be used for all heat transfer

and mass transfer process involving corrosive media. Heat transfer takes place in solid

graphite blocks with a crosswise arrangement of drilled flow passages for the product and

service side. The size of the graphite blocks and the passage diameters vary according to

the application. Several graphite blocks can be assembled to form a column, which

provides the required heat transfer area in a single unit.

Condensers at Pfizers are generally only the first stage in abatement trains and are

viewed more not as abatement, rather as an important functional process unit operation

rather than abatement. This is particularly true for primary condensation where the

condensers are arranged for different process operations in a reactor, primarily:

- reflux (where the condensed solvent is returned directly to the reactor), and

- distillations (where the solvent is removed from the reactor and routed to a

receiver. From the receiver, the solvent is pumped to waste solvent storage

tanks).

A typical arrangement of primary and secondary condensers for a reactor system at

Pfizer is provided in Figure E.1.2.

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2.2.2. Scrubbers

Several scrubbers are employed at the Pfizer site. All scrubbers share common features

as follows:

- They are packed scrubbers. The packing, varying in design, substantially

increases the intimate mixing of the gas and liquid streams which then drives

contaminant removal from the gas stream to the liquid stream;

- The scrubbers operate on a counter flow basis: - i.e., the gas stream being

treated flows against the scrubber liquor flow in a counter-current flow. This is

considered the most efficient means of contaminant removal from the gas

stream;

- The scrubbers all have scrubber liquor sumps from which the scrubber liquor

is continuously recirculated by pumping through the scrubber column.

Occasionally, scrubber liquor is bled as a process effluent to the wastewater

treatment plant and the lost liquor is topped up to retain a constant sump

level.

A ‘caustic scrubber’ utilises a caustic scrubber solution (pH about 12). For those

processes that may emit acid fumes into the header system, the header used to take the

fumes is directed to the caustic scrubber. The caustic content of the scrubber liquor

converts the acid fumes to soluble salts in the scrubbing liquor, thus removing them from

the header extraction flow. The scrubber liquor in the caustic scrubber is continuously

monitored for pH and if the pH falls below a certain set point, then caustic solution is

automatically dosed into the scrubber solution, or liquor, to regain the pH.

A ‘water scrubber’ uses water at neutral pH. These scrubbers are designed primarily to

remove soluble volatile organic compounds but can also remove trace entrained

particulate matter and soluble inorganic compounds from the same gas flow should they

be present.

A typical scrubber flow diagram is provided in Figure E.1.3.

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2.2.3. HEPA Filtration

High Efficiency Particulate Absorbing (HEPA) filters are capable of very high (typically

greater than 99.9%) removal efficiencies of very fine dust particulate matter.

At Pfizer, these filters are employed in areas where process dust, mainly containing

active pharmaceutical dust, is likely to be generated (e.g., during milling and packing).

These filters are composed of a mat of randomly arranged fibers. Key metrics affecting

function are fiber density and diameter, and filter thickness. The common assumption that

a HEPA filter acts like a sieve where particles smaller than the largest opening can pass

through is incorrect. HEPA filters are designed to target much smaller pollutants and

particles are mainly trapped (they stick to a fiber) by one of the following three

mechanisms:

1. interception, where particles following a line of flow in the airstream come within

one radius of a fiber and adhere to it;

2. impaction, where larger particles are unable to avoid fibers by following the

curving contours of the airstream and are forced to embed in one of them directly;

this increases with diminishing fiber separation and higher air flow velocity;

3. diffusion, an enhancing mechanism which is a result of the collision with gas

molecules by the smallest particles, especially those below 0.1 µm in diameter,

which are thereby impeded and delayed in their path through the filter.

The initial filter air flow resistance and final filter air flow resistance are typically measured

as presure drop across the filters.

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2.2.4. Carbon Adsorption

There is a carbon adsorption system on the Pfizer site.

A simplified flow diagram of the carbon adsorption design is presented in Figure E.1.4.

2.2.4.1. The Carbon System

The carbon adsorption system installed on the Pfizer site is the main abatement

equipment for emissions to air and may be considered a central system for emissions to

air. That is, the system is connected to an incoming header which in turn takes extraction

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gas streams from various production facilities on the site and from some organic solvent

storage tanks in the Tank Farm 3.

The incoming gas flow containing gaseous organic solvents is passed through an

adsorber bed. The main organic solvent in the incoming gas stream is dichloromethane

(DCM). The volatile organic compounds (VOCs) are adsorbed onto the activated carbon

and retained within the vessel. The exhaust gas is discharged through the exhaust stack

to the environment.

Following the completion of the adsorption cycle, the activated carbon is regenerated by

passing low pressure steam through the bed in a counter flow direction. The VOCs

retained by the activated carbon are stripped from the carbon and carried out of the

adsorber.

The condensed steam/solvent mixture from the carbon adsorber flows to the decanter

where the liquid separates into 3 phases. Water and light solvents go from stage 1 to

stage 2 by overflowing an internal baffle as the level rises in stage 1. Also in stage 1 there

is an automatic valve and level switch in place in order to stop flow out of the first

separation chamber in the event of the heavy solvent being depleted or not present. This

is done by using a ball float which has a specific density equal to that of DCM. The valve

is opened when the ball float hits the upper level, pumping heavy solvents to

compartment 3 and closes when the ball hits the lower level.

In the second stage, the light solvents are separated from the water phase by the light

solvents overflowing an internal baffle as the level rises into stage 3. The water

containing dissolved solvents flows through an adjustable seal loop to the fourth stage

where it is pumped to the stripper feed tank FA-76. The light and heavy solvents collected

in stage 3 are pumped to the waste solvent tank ML-304.

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Appendix E.1.1 – List of Emissions to Air

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Appendix E.1.2 – Drawings indicating

Emission to Air

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Documents

Emissions to Air Pfizer Cork Ltd., Inchera, Little Island ... · Attachment E.1 Emissions to Air Pfizer Cork ... Attachment E.1 Emissions to Air - Main Text_Final.doc Page 1 1