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Permit with introductory note Environmental Permitting Regulations 2007 Mathers Foundry Limited Park Works Grimshaw Lane Newton Heath Manchester M40 2BA Permit Number PPC/B/26/05/AW

Permit and Introductory Note: EP Regulations 2007 Permit Number: PPC/B/26/05/AW

Permit date: 24 May 2005 Manchester City Council LAPPC Permit of 19

Introductory Note This introductory note does not form a part of the Permit The following Permit is issued under Regulation 21 and 13 of the Environmental Permitting (England and Wales) Regulation 2007 (“the EP Regulations”) to operate an installation carrying out one or more of the activities listed in Part 1 to Schedule 1 of those Regulations, to the extent authorised by the Permit. The Permit includes the conditions that have to be complied with. It should be noted that aspects of the operation of the installation which are not regulated by those conditions are subject to the guidance and recommendations detailed within the Process Guidance notes 2/3 and 2/4 (04) or their revisions. The Operator shall use the best available techniques for preventing or, where that is not practicable, reducing emissions from the installation. Techniques include both the technology used and the way in which the installation is designed, built, maintained, operated and decommissioned. Brief description of the installation regulated by this Permit

Summary The purpose of the activity at the installation is the production of steel castings by the melting of clean scrap metal and ferro-alloys in 2 (two) x 5 tonne, 2 (two) x 0.5 tonne, 1 (one) x 0.75 tonne and 1 (one) x 1.5 tonne electric induction furnaces, in conjunction with associated foundry and metal finishing activities, as defined in Part B of section 2.1 (ferrous metals) of Schedule 1 to the Environmental Permitting (England and Wales) Regulations 2007 SI 3538 (as amended).



Confidentiality The permit requires the Operator to provide information to the Environmental Health Division of the City Council (‘the Council’), which it will place onto the public register in accordance with the requirements of the EP Regulations. If the Operator considers that any information provided is commercially confidential, it may apply to the Council to have such information withheld from the register as provided in the EP Regulations. To enable the Council to determine whether the information is commercially confidential, the Operator should clearly identify the information in question and should specify clear and precise reasons. Variations to the Permit This Permit may be varied in the future. The Status Log within the Introductory Note to any such variation will include summary details of this Permit, variations issued up to that point in time and state whether a consolidated version of the Permit has been issued. Transfer of the Permit or part of the Permit Before the Permit can be wholly or partially transferred to another person, a joint application to transfer the Permit has to be made by both the existing and proposed holders, in accordance with Regulation 21 of the EP Regulations. A transfer will only be allowed when the Council considers that the proposed holder will be the person who will have control over the installation or will ensure compliance with the conditions of the transferred Permit. If the Permit authorises the carrying out of a specified waste management activity, then there is a further requirement that the transferee is considered to be a “fit and proper person” to carry out that activity.



Status log

Detail Date Comment

Request for Commercial Confidentiality

Not applicable

Permit Granted Permit Transfer & Review 30 September 2008

24 May 2005

End of introductory Note.



PERMIT

Environmental Permitting Regulations 2007

Manchester City Council Pollution Control Section

Regulatory & Enforcement Services 1 Hammerstone Road, Gorton,

Manchester M18 8EQ Permit Number PPC/B/26/05/AW The Pollution Control Section, Regulatory and Enforcement Services at Manchester City Council in exercise of its powers under Regulation 13 of the Environmental Permitting (England and Wales) Regulations 2007, SI 2007 No 3538, hereby permits Mathers Foundry Limited (“the Operator”) Whose Registered Office is:- PO Box 1 Doulton Road Cradley Heath West Midlands B64 5QS Company registration number:- 06699179 To operate an installation at Mathers Foundry Park Works Newton Heath Manchester M40 2BA to the extent permitted by and subject to the schedule of this Permit. Signed Dated: Fiona Sharkey Head of Regulatory and Enforcement Services

30 September 2008



Conditions

1. Emission Limits and Monitoring

1.1 The following emission limit values, expressed at reference conditions of 273K and 101.3 kPa shall not be exceeded in any emission to air. The oxygen and water references shall be those which correspond to the normal operating conditions of the process concerned.

Substance and source

Emission Limit

Type of Monitoring Monitoring frequency (subject to condition

1.17)

Compliance date, from

Indicative monitoring with continuous recording if the air flow is greater than 300m3/minute PLUS

Continuous

The date of issue of this

permit

50 mg/m3

Manual extractive tests

Annual

Indicative monitoring with continuous recording if the air flow is greater than 300m3/minute PLUS

Continuous

31 October 2006

Manual extractive tests

Annual

Total particulate matter from stack emissions with an air flow greater than 150m3/minute

20 mg/m3

See Conditions 1.10 to 1.24

Copper and its compounds

20 mg/m3 Manual extractive tests

Annual The date of issue of this

permit

Copper and its compounds (except where copper or copper alloys are being fettled)

5 mg/m3

Fettling of copper and its compounds

20 mg/m3

31 October 2006



Source Metals and

their salts Emission Limits

Type of monitoring

Compliance date, from

Where appropriate in relation to the metal alloy melted

Nickel, Cobalt, Chromium, and their compounds

Total emission in combination 5 mg/m3

Manual extractive Annual

Date of issue of this permit

Monitoring Records

1.2 The operator shall keep records of inspections, tests and monitoring,

including all non-continuous monitoring, inspections and visual assessments. The records shall be: • kept on site • kept by the operator for at least two years; and • made available for the Council regulator to examine.

Visible and Odorous Emissions

1.3 Emissions from combustion processes shall in normal operation be free from visible smoke and in any case shall not exceed the equivalent of Ringelmann Shade 1 as described in British Standard BS 2742:1969.

1.4 All releases to air, other condensed water vapour, shall be free from

persistent visible emissions. All emissions to air shall be free from droplets.

1.5 There shall be no offensive odour beyond the site boundary, as perceived by the Council regulator.

1.6 Where an emission point is not fitted with a continuous monitor and alarm

in accordance with Conditions 1.10 to 1.15, visual and olfactory assessments of emissions shall be made frequently and at least once each

Sulphur Dioxide Maximum concentration of sulphur in fuel

Type of Monitoring Monitoring frequency

0.2% wt/wt (before 01/01/2008) and

Gas oil

0.1% wt/wt (from 01/01/2008)

Certificate from supplier Not applicable



day whilst the process is in operation. The time, location and result of these assessments shall be recorded.

1.7 Emissions from core or mould making processes shall, where necessary to

avoid offensively odorous emissions, be passed through suitable abatement plant such as chemical scrubbers or incinerators, and ducted to a stack capable of being monitored in accordance with the requirements of Conditions 1 and X of this note. This is essential where dimethylethylamine (DMEA) is used but not usually necessary where triethylamine (TEA) is used.

Abnormal Events

1.8 The regulator shall be informed without delay

• if there is an emission that is likely to have an effect on the local community, or

• in the event of the failure of key arrestment plant.

1.9 In the case of abnormal emissions, malfunction or breakdown leading to abnormal emissions the operator shall • investigate and undertake remedial action immediately; • adjust the process or activity to minimise those emissions; • reduce or close down operations as soon as practicable, and • promptly record the events and actions taken. Continuous Monitoring

1.10 All continuous monitoring readings shall be on display to appropriately

trained staff. 1.11 Instruments shall be fitted with audible and visual alarms, situated

appropriately to warn the operator of arrestment plant failure or malfunction.

1.12 The activation of alarms shall be automatically recorded.

1.13 All continuous monitors shall be operated, maintained and calibrated (or

referenced) in accordance with the manufacturers' instructions, which shall be made available for inspection by the Council regulator. The relevant maintenance and calibration (or referencing) shall be recorded.

1.14 Where stack emissions with an airflow greater than 300m3/minute are being

monitored the emissions shall be continuously recorded.

1.15 All new continuous monitoring equipment installed after 31st October 2005 shall be designed for less than 5% downtime over any 3-month period. Calibration and Compliance Monitoring



1.16 Non-continuous emissions monitoring of particulate matter shall be carried

out according to the main procedural requirements of BS ISO 12141:2002 or BS EN 13284:Part 1, with averages taken over operating periods, excluding start-up and shutdown. Sampling equipment shall be capable of collecting particulate matter of 0.1 microns diameter or less with an efficiency of at least 75%.

1.17 Where monitoring is not in accordance with the main procedural

requirements of the relevant standards listed in Condition 1.16, deviations shall be reported as well as an estimation of any error invoked.

1.18 No result shall exceed the emission concentration limits specified in

Condition 1.1.

1.19 The introduction of dilution air to achieve the emission concentration limits is not permitted.

1.20 Contained particulate matter emissions within an airflow of more than

150m3/minute shall be continuously indicatively monitored in accordance with Condition 1.1 and Conditions 1.10 to 1.15 above if they are not abated or if dry filtration arrestment plant is used.

1.21 Where no arrestment plant is required to meet the emission limits, the

operating parameters applying at the time of the stack monitoring exercise shall be recorded. If the operator does not intend to vary these parameters during the course of the year then there is no need for a continuous indicative monitor. If the operator envisages significant variation in the operating parameters then a continuous indicative monitor shall be used to demonstrate compliance or stack sampling shall be undertaken to cover the range of parameters being used. If the Council regulator finds during the course of the year that different parameters are being applied and no continuous indicative monitor has been installed additional stack sampling to cover the particular conditions will be required. The relevant parameters shall include: feedstock type, maximum melt temperature, flux or other additions and emission flow rates.

1.22 Arrestment equipment with an airflow of 150m3/minute or less shall be fitted

with an indicative monitoring device, such as a pressure drop indicator, to warn of arrestment equipment failure.

1.23 Exhaust flow rates shall be consistent with efficient capture of emissions,

good operating practice and meeting the requirements of the legislation relating to the workplace environment.

1.24 The frequency of testing shall be increased as specified by the Council, for

example, as part of the commissioning of new or substantially changed processes, or where emission levels are near to or approach the emission concentration limit Sampling Provisions



1.25 The operator shall ensure that adequate, safe facilities for periodic manual

extractive sampling surveys are provided on stacks or ducts. 1.26 Sampling points on new plant shall be designed to comply with the

appropriate British or equivalent standards. e.g. BS ISO 12141:2002 or BS EN 13284:Part 1 for sampling particulate matter in stacks.

Information Required by the Council

1.27 In order to minimise adverse effects, the Operator shall provide a list of key

arrestment plant and shall have a written procedure for dealing with its failure.

1.28 The operator shall notify the Council at least 7 days before any periodic

monitoring exercise to determine compliance with emission limit values. A sampling protocol shall be submitted to the Council for approval at least two weeks prior to any such sampling exercise, stating at least the proposed time and date of monitoring, pollutants to be tested and the methods to be used.

1.29 The results of all non-continuous emission testing shall be forwarded to the

Council within 8 weeks of the completion of the sampling.

1.30 A summary of continuous indicative continuous monitoring data shall be submitted to the Council regulator at least every six months, identifying the times, dates and duration of all alarm events.

1.31 Adverse results from any monitoring activity (both continuous and non-

continuous) shall be investigated by the operator as soon as the monitoring data has been obtained/received. The operator shall: • identify the cause and take corrective action; • record as much detail as possible regarding the cause and extent of the

problem, and the action taken by the operator to rectify the situation; • re-test to demonstrate compliance as soon as possible; and • notify the Council of the investigation, findings and action. Emissions from Silos

1.32 All new or replacement silo filtration plant shall be designed to operate to an emission standard of less than 10mg/m3 for particulate matter.

1.33 Operators shall have a procedure in place to ensure that visual

assessment of emissions from silo inlet connections and the silo arrestment plant are undertaken throughout the duration of all bulk deliveries. The start and finish times of all deliveries shall be recorded.



1.34 Silo filtration plant shall be inspected at the frequency specified below.

Filter cleaning method Frequency of visual inspection

Filters fitted with reverse jets At least once a month

1.35 Silo outlets shall be checked for signs that emissions have occurred. The equipment shall also be checked for defects in the airflow or the cam shakers. If emissions or defects are detected then corrective action shall be taken promptly and before another delivery takes place. Any failure of the silo management system (e.g. high level alarms, filter, pressure relief valve) shall lead to full investigation of the operation of the plant and equipment.

2. Control Techniques

Particulate Matter, Metals and their Compounds

2.1 All new plant shall be contained such that emissions are extracted and ducted to a single emission point that is designed so that monitoring can take place in accordance with Conditions 1.10 to 1.24.

2.2 Emissions shall be abated where necessary to meet the limits and

provisions.

2.3 Finishing processes (including, for example, grinding, shot blasting, polishing, and arc air cutting) shall be undertaken in booths or areas with extraction of emissions or using equipment incorporating built in extraction equipment. Any extraction shall discharge via arrestment plant to meet the emission limits and provisions of Conditions 1.1 and 1.3 to 1.7.

2.4 All emissions from foundry sand reclamation processes shall be contained,

captured and where necessary vented to suitable arrestment plant to meet the provisions of Conditions 1.1 and 1.3 to 1.7.

Silos

2.5 When delivery to a silo or bulk storage tank takes place, displaced air shall either be vented to suitable arrestment plant (for example cartridge/bag filters) or back-vented to the delivery tanker, in order to minimise emissions. Arrestment plant fitted to silos shall be of sufficient size (and kept clean) to avoid pressurisation during delivery.

2.6 Seating of pressure relief valves shall be checked at least once a week or

before a delivery takes place, whichever is the longer interval. Immediately it appears that the valve may have become unseated, the delivery shall



cease and no further delivery shall take place. The valve shall be examined and reseated if necessary.

2.7 Bulk storage tanks and silos containing dry materials shall be equipped

with audible and/ or visual high level alarms to warn of overfilling. The correct operation of such alarms shall be checked regularly having regard to the frequency of delivery.

2.8 In order that fugitive emissions are minimised during the charging of silos,

care shall be taken to ensure that the transfer lines are securely connected to the tanker discharge point and the silo delivery inlet point.

2.9 If emissions of particulate matter are visible from ducting, pipework, the

pressure relief valve or dust arrestment plant during silo filling, the operation shall cease; the cause of the problem shall be rectified prior to further deliveries taking place. Tanker drivers shall be informed of the correct procedure to be followed.

2.10 All new silos shall be fitted with an automatic system to cut off delivery in

the event of pressurization or overfilling. Use of alternative techniques may be acceptable provided that they achieve an equivalent level of control with regard to potential for emissions to air.

Emissions from Ovens

2.11 The hot curing and/or baking of moulds and cores shall be carried out in an

oven designed for the purpose and the fuel shall comply with the requirements of Condition 1.1.

VOC and Odour Control 2.12 Emissions from casting processes shall be captured and vented to suitable

arrestment plant, where necessary to meet the provisions of Conditions 1.1 to 1.35 of this permit.

2.13 An inventory of organic solvents usage shall be maintained.

2.14 Emissions from local exhaust ventilation from any casting, cooling and

knockout areas shall be abated if necessary to meet the provisions of Condition 1.1.

2.15 Binder chemical additions shall be minimised to the greatest extent

possible. Records shall be kept of the level of necessary binder addition.

2.16 Emissions from mould and core production (including mixing operations) shall be discharged via a suitable arrestment plant where necessary to meet the Conditions of this Permit.



2.17 Burners in mould and core making equipment shall be regularly inspected and maintained and appropriate records kept.

Fugitive Emissions

2.18 All processes likely to emit into the air any particulate matter (for example oxy fuel cutting, burning off of casting residues, casting and knocking out) but excluding the storage and transfer of raw materials, shall be undertaken in an enclosed area or building of suitable construction to minimise emissions to air and meet the provisions of Condition 1.1 and Conditions 1.3 to 1.7.

2.19 Correctly designed extraction systems shall be used where necessary to

achieve the limits and provisions of Conditions 1.1 to 1.35 of this permit.

Materials Handling 2.20 All dusty or potentially dusty materials shall be stored in silos, in confined

storage areas within buildings, or in fully enclosed containers / packaging. Where the storage is open within a building, then suitable precautions shall be taken to prevent wind whipping.

2.21 All new or reclaimed dry sand stored outside shall be stored in purpose

built silos, sealed bags, or closed containers.

2.22 External above ground conveyors for dusty materials shall be fitted with protection against wind whipping. Transfer points shall be enclosed and ducted to suitable arrestment equipment where necessary to meet the provisions of Condition 1.1 and Conditions 1.3 to 1.7.

2.23 The method of collection of waste from dry arrestment plant shall be such

that dust emissions are minimised.

2.24 Dusty wastes shall be stored in closed containers and handled in a manner that avoids emissions of dust.

2.25 Internal transport of dusty materials shall be carried out so as to prevent or

minimise airborne dust emissions.

2.26 External surfaces of the process building, ancillary plant and open yards and storage areas shall be inspected at least annually and cleaned if necessary to prevent the accumulation of dusty material in circumstances where the dust may become wind entrained. Particular attention shall be paid to roofs, guttering, roadways, external storage areas and yards. Cleaning operations shall be carried out by methods which minimise emissions of particulate matter.

2.27 A high standard of housekeeping shall be maintained.



2.28 All spillages shall be cleared as soon as possible; solids by vacuum cleaning, wet methods, or other appropriate techniques. Dry sweeping of dusty spillages shall not be permitted in circumstances where it may result in the generation of airborne dust outside any building. Stacks, Vents and Process Exhausts

2.29 Flues and ductwork shall be cleaned to prevent accumulation of materials,

as part of the routine maintenance programme. 2.30 All discharges shall be vertically upwards, and stacks shall not be fitted with

any restriction at the final opening such as a plate, cap or cowl, with the exception of a cone which may be necessary to increase the exit velocity of the emissions.

2.31 Flues and discharge stacks shall be adequately insulated to minimise the

cooling of waste gases and prevent liquid condensation on internal surfaces.

2.32 Exhaust gases discharged through a stack or vent shall achieve an exit

velocity which is normally greater than 15m/s during normal operating conditions to achieve adequate dispersion. A lower velocity shall be acceptable to the Council provided that it achieves adequate dispersion and dilution, that aerodynamic downwash does not occur, and that any provisions of the Council’s statutory duties within any Air Quality Management Area are not compromised.

3. Management

3.1 Best available techniques shall be used to ensure effective control of emissions by the proper management, supervision and training for process operations, the proper use of equipment, and effective preventative maintenance on all plant and equipment concerned with the control of emissions to air.

3.2 Spares and consumables, in particular, those subject to continual wear,

shall be held on site, or shall be available at short notice from guaranteed suppliers, so that plant breakdowns can be rectified rapidly.



4. Training

4.1 Training of all staff with responsibility for operating the process and

associated activities within the installation shall include:

• awareness of their responsibilities under the permit, • minimising emissions on start up and shut down, and • action to minimise emissions during abnormal conditions

4.2 The operator shall maintain a statement of training requirements for each

operational post and keep a record of the training received by each person whose actions may have an impact on the environment. These documents shall be made available to the Council on request.

5. Maintenance and Cleaning

5.1 A written maintenance programme shall be implemented with respect to pollution control equipment, including all ducts and flues. A record of such maintenance and the cleaning schedule shall be made available for inspection by the Council regulator.



6. The Installation Boundary

6.1 The activities authorised within the Permit shall not extend beyond the Site,

being the area shown highlighted on the plan below.

PSO

N STR

EET

FLETCH

ER

STR

EET

M 68.02m

BOWER S

TREET

67.8m

256

44

30

21

31

Depot

Works

Towing P

ath

Rochda

le Cana

l

TanksDepot

Depot

Works

Bowling Green

Works

Warehouse

Tank

Tank

5

3 to 4

1 to 2

76.7m

73.7m

75

75.8m

BM 77.25m

Ten Acres LaneBridge

72.9m

70.3mWorks

Works

El Sub Sta

FB

FB

67.4m

Tanks

Works

Overflo

w

FB

69.8m

Pavilion

Bowling Green

Tanks

MoPs

FB

N

Map 1: Location of Mathers Foundry Limited, Park Works, Newton Heath, Manchester.,

CROWN COPYRIGHT RESERVED Based upon the Digital Ordnance Survey map with the permission of the controller of Her Majesty's Stationery Office. Unauthorised reproduction infringes Crown Copyright and may lead to prosecution or civil proceedings. Licence No. 100019568.



7. Interpretation

7.1 In this Permit, the following expressions shall have the following meanings:

“Permitted Installation” means the activities and the limits to those activities in the production

of steel castings by the melting of clean scrap metal and ferro-alloys in 2 (two) x 5 tonne, 2 (two) x 0.5 tonne, 1 (one) x 0.75 tonne and 1 (one) x 1.5 tonne electric induction furnaces, together with all associated metal finishing operations and all related storage and handling operations.

“ Permit ”

means the written permission to operate an installation prescribed for EPR – Environmental Permitting Regulations (the replacement for authorisation under (LAPPC and LAPC – Local Air Pollution Control).

“EP Regulations”

means the environmental Permitting (England and Wales) Regulations 2007 and words and expressions defined in the EP Regulations shall have the same meanings when used in this Permit.

“Daily” means a 24 hour period commencing at 00.00 hours

“Monitoring” includes the taking and analysis of samples, instrumental

measurements (periodic and continual), calibrations, examinations, test and surveys

“Staff”

includes employees, directors or other officers of the Operator, and any other person under the Operator’s direct or indirect control, including contractors

“year”

means calendar year ending 31 December



8. Written agreement to changes

8.1 When the qualification “or as otherwise agreed in writing” is used in a

condition of this Permit, the Operator shall seek such agreement in the following manner:

a the Operator shall give the Council written notice of the details of the

proposed change, indicating the relevant part(s) of this Permit; and

b such notice shall include an assessment of the possible effects of the proposed change (including waste production) on risks to the environment from the Permitted Installation.

8.2 Any change proposed and agreed in writing by the Council shall not be

implemented until the Operator has given the Council prior written notice of the implementation date for the change. As from that date, the Operator shall operate the Permitted Installation in accordance with that change, and any relevant documentation referred to in this Permit shall be deemed as amended.

8.3 The address for writing to the Council shall be as follows,

Manchester City Council Pollution Control Section Regulatory & Enforcement Services 1 Hammerstone Road, Gorton, Manchester M18 8EQ

Contact Officer: Rob Macdonald Telephone Number: 0161 234 4931 Fax Number: 0161 234 4871 e-mail [email protected]

or as otherwise notified by the Council. End of Permit



Appeal Against Permit Conditions

Anyone who is aggrieved by the conditions attached to a Permit can appeal to the Secretary of State for Environment, Food and Rural Affairs. Written appeals must be sent to the Secretary of State’s delegate (the Planning Inspectorate) no later than six months from the date of issue of the Permit to the following address:

The Planning Inspectorate Environment Appeals Administration Room 4/19 – Eagle Wing Temple Quay House

3 The Square Temple Quay Bristol BS1 6PN The letter of appeal must include the following:

• A statement of the grounds of appeal; • A statement indicating whether the appellant wishes the appeal to be

dealt with by written representations or at a hearing; • A copy of the relevant application; • A copy of any relevant Permit; • A copy of any relevant correspondence between the appellant and the

and the regulator

At the same time, a copy of the appeal document including the first two items above must be sent to the Council at the following address

Manchester City Council Pollution Control Section Regulatory & Enforcement Services 1 Hammerstone Road, Gorton, Manchester M18 8EQ

Contact Officer: Rob Macdonald Telephone Number: 0161 234 4931 Fax Number: 0161 234 4871

e-mail [email protected] Note: An appeal will not suspend the conditions of the Permit from coming into effect. In determining the appeal the Secretary of State, or the Planning Inspector, may direct the Local Authority to vary, remove or add conditions to the Permit and not solely make comment on those conditions that are the subject of the appeal itself.

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