Process Guidance Note 2/2 (04)

Secretary of State's Guidance for Hot Dip Galvanizing Processes

 Crown copyright 2004 Copyright in the typographical arrangement and design rests with the Crown. This publication (excluding the logo) may be reproduced free of charge in any format or medium provided that it is reproduced accurately and not used in a misleading context. The material must be acknowledged as Crown copyright with the title and source of the publication specified.

Defra would like to acknowledge the work of the Environment Agency's Local Authority Unit in the drafting of this guidance note.

Environment Agency

Contents
1 Introduction ...............................................................................................1 2 Timetable for compliance and reviews ...................................................4
Existing processes or activities ....................................................................................4 New processes or activities ..........................................................................................4 Substantially changed processes or activities ..............................................................4 Permit reviews .............................................................................................................5

3 Process description .................................................................................6

Pretreatment ................................................................................................................6 Fluxing ..........................................................................................................................7 Galvanizing ..................................................................................................................8 Post treatment ..............................................................................................................9

4 Potential releases ...................................................................................12 5 Emission limits, monitoring and other provisions ..............................13 6 Control techniques .................................................................................18
Techniques to control emissions from contained sources .........................................18 Techniques to control fugitive emissions ...................................................................18 Air quality ...................................................................................................................20 Management .............................................................................................................21

7 Summary of changes ..............................................................................23 8 Definitions and further information .......................................................24

Health and safety ......................................................................................................25 EMS additional information ........................................................................................25 References .................................................................................................................26 Web addresses ..........................................................................................................26

Appendix 1:Extract from Pollution Prevention and Control (England and Wales) Regulations 2000 SI 1973 ........................................27

List of Figures
Figure 3.1: Flow diagram of a typical galvanizing process ...................................................11

List of Tables
Table 1: Compliance timetable ...............................................................................................4 Table 2: Emission limits, monitoring and other provisions ...................................................13 Table 3: Summary of control techniques ..............................................................................18 Table 4: Summary of changes .............................................................................................23

Process Guidance Note 2/2

| Issue 1.0 | Published October 2004

LAPPC and LAPC

1 Introduction
1.1 This note is issued by the Secretary of State, the Welsh Assembly Government (WAG) and the Scottish Ministers ("the Government") to give guidance on the conditions appropriate for the control of emissions into the air from hot dip galvanizing processes/installations1. It supersedes guidance note PG 2/2(96) published in March 1996. This is one of a series of notes giving guidance on Best Available Techniques (BAT) and Best Available Techniques Not Entailing Excessive Cost (BATNEEC)2. The notes are all aimed at providing a strong framework for consistent and transparent regulation of installations. This note is for use under both Local Air Pollution Control (LAPC) established by Part I of the Environmental Protection Act 1990, and Local Air Pollution Prevention and Control (LAPPC) established by the Pollution Prevention and Control Act 19993. It constitutes statutory guidance to regulators under regulation 37 of The Pollution Prevention and Control (England and Wales) Regulations 2000, SI 19734. To the extent it provides guidance on techniques, it also constitutes statutory guidance to regulators under section 7(11) of the 1990 Act, and in any event regulators are expected to have regard to it. The note will be treated as one of the material considerations when determining any appeals made against a decision under either the 1990 or 1999 Acts. The note also (where appropriate) gives details of any mandatory requirements affecting air emissions which are in force at the time of publication, such as those contained in Directions from the Government. All processes are subject to BAT/ BATNEEC. In general terms, what is BAT/ BATNEEC for one process in a sector is likely to be BAT/ BATNEEC for a comparable process; but in each case it is, in practice, for regulators (subject to appeal) to decide what is BAT/ BATNEEC for the individual process and the regulator should take into account variable factors (such as configuration, size and other individual characteristics of the process) and the locality (such as proximity of particularly sensitive receptors5). Ultimately, therefore, what constitutes BAT/ BATNEEC is site specific but this guidance note comprises guidance for the generality of processes in the sector and careful regard should be had to it, in order to maximise consistency of permits as appropriate. This guidance is for: regulators: who must have regard to the guidance when determining applications and reviewing extant authorisations and permits operators: who are best advised also to have regard to it when making applications, and in the subsequent operation of their process members of the public: who may be interested to know what the Government considers (in accordance with the legislation) amounts to appropriate conditions for controlling air emissions for the generality of processes in this particular industry sector

1.2

1.3

1.4

Site specific BAT/ BATNEEC

1.5

Who is affected

1.6

1. 2. 3.

4. 5.

The term "process(es)" is used in the remainder of the note to mean both "processes" under the Environmental Protection Act 1990 and "installations" under the Pollution Prevention and Control Act 1999. BATNEEC is the formulation used in the Environmental Protection Act 1990 and BAT is used in the Pollution Prevention and Control Act 1999. For the purpose of this guidance note, the two concepts are regarded as having essentially the same effect. In accordance with with the Pollution Prevention & Control (England and Wales) (Amendment) Regulations 2002, SI 2002/275, hot dip galvanizing processes transfer from regulation under the 1990 Act to the 1999 Act from 1 April 2004. The relevant date in Scotland under Part 2 of schedule 3 to SSI 2000/323 is 31 December 2002. In Scotland section 24 of the Pollution Prevention and Control (Scotland) Regulations 2000. Guidance on the relationship between BAT/BATNEEC and air quality objectives is contained in the General Guidance Manual on policy and procedures for A2 and B installations.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

LAPPC and LAPC

1.7

The guidance is based on the state of knowledge and understanding at the time of writing of: hot dip galvanizing processes their potential impact on the environment and what constitutes BAT/ BATNEEC for preventing and reducing air emissions

1.8

The note may be amended from time to time in order to keep abreast with developments in BAT/BATNEEC including improvements in techniques and new understanding of environmental impacts and risks. Such changes may be issued in a complete revision of this document, or in separate additional guidance notes which address specific issues. (It may not always be possible to issue amending guidance quickly enough to keep in absolute step with rapid changes, which is another circumstance where paragraph 1.5 above might apply.) Steps will be taken to ensure that those who need to know about changes are informed. Operators (and their advisers) are, however, strongly advised to check with the regulator whether there have been any changes before relying on this note for the purposes of making an application under the 1990 or 1999 Acts or making any other decisions where BAT/ BATNEEC may be a consideration.

1.9

Consultation

1.10 This note has been produced in consultation with relevant trade bodies, representatives of regulators including members of the Industrial Pollution Liaison Committee, and other interested organisations. 1.11 This and the other published guidance in this series is available, free of charge, via Defra at www.defra.gov.uk. There are links to this site from the following web sites: Scottish Executive at www.scotland.gov.uk. Environment Agency at www.environment-agency.gov.uk. Scottish Environment Protection Agency at www.sepa.org.uk.

Publication

Printed copies of this and other PG notes are available from Defra Publications. They are priced separately and can be purchased in the following ways: By writing to Defra Publications, Admail 6000, London, SW1A 2XX. Cheques or postal orders to cover the cost of priced items must be enclosed with your order, and should be made payable to 'Defra Publications'. See also the Defra Publications order form available from www.defra.gov.uk/corporate/ publications/orderform.htm. Or by telephoning 08459 556000 (calls charged at local rate) or +44 20 8957 5242 from outside the UK. Debit and credit cards are accepted. When ordering, always quote the title in full and the order code (PB XXXX) given. Further information on ordering can be found on the Defra website at www.defra.gov.uk/corporate/publications/ordering.htm 1.12 General guidance explaining LAPPC and setting out the policy and procedures, is contained in the General Guidance Manual on Policy and Procedures for A2 and B Installations available from www.defra.gov.uk/environment/ppc/index.htm, referred to in this document as the "General Guidance Manual. This is designed for operators and members of the public, as well as for local authority regulators. In Scotland there is the SEPA Practical Guide for Part B activities available from www.sepa.org.uk/ppc/guidance/practicalguidepartbactivities.pdf

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

LAPPC and LAPC

1.13 In addition to the General Guidance Manual referred to above, explanation or clarification of certain terms used in this guidance note may be found in a general guidance note issued under Part I of the Environmental Protection Act 1991: Interpretation of terms used in process guidance notes, known as General Guidance Note 4 - GG4 - published by HMSO in 1991. Where there is any conflict between GG4 and the guidance issued in this note or in the General Guidance Manual, the latter two documents should prevail, as should any subsequent guidance issued in relation to LAPPC.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

LAPPC and LAPC

2 Timetable for compliance and reviews

Existing processes or activities
2.1 The previous guidance advised that upgrading to that standard should usually have been completed by 1 October 1996. Requirements still outstanding from any existing upgrading programme should be completed. The new provisions of this note and the dates by which compliance with these provisions is expected are listed in the table below, together with the paragraph number where the provision is to be found. Compliance with the new provisions should normally be achieved by the dates shown. Authorisations/permits should be varied as necessary, having regard to the changes and the timetable.

Upgrading for this note

2.2

Table 1: Compliance timetable

Provision

Relevant paragraph/ row in this note Table 2 Row 3

Compliance date

Emission limit of 20 mg/m3 for contained sources of particulate matter, other than galvanizing. Emission limit for lead (for wire galvanizers) of 0.25 mg/m3. All other provisions.

12 months from the date of publication of this note. 12 months from the date of publication of this note. To be complied with as soon as practicable, which should normally be within 12 months of this note being published.

Table 2 Row 6 -

2.3

Replacement plant should normally be designed to meet the appropriate standards specified for new installations or activities. Where provisions in the preceding guidance note have been deleted or relaxed, authorisations should be varied as necessary as soon as reasonably practicable. Section 7 provides a summary of all changes.

Relaxation of conditions

2.4

New processes or activities

2.5 For new processes or activities, the authorisation/permit should have regard to the full standards of this guidance from the first day of operation.

Substantially changed processes or activities

2.6 For substantially changed processes or activities, the authorisation/permit should normally have regard to the full standards of this guidance with respect to the parts of the process that have been substantially changed and any part of the process affected by the change, from the first day of operation.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

LAPPC and LAPC

Permit reviews Reviewing permits

2.7 Under LAPC the requirement is to review conditions in authorisations at least every four years. (Section 6(6) Environmental Protection Act 1990). Under LAPPC the legislation requires permits to be reviewed periodically but does not specify a frequency. It is considered for this sector that a frequency of once every six years ought normally to be sufficient for the purposes of Regulation 15(1) Pollution Prevention and Control Regulations 2000. More frequent review may be necessary in individual cases for the reasons given in Regulation 15(2). Further guidance on permit reviews is contained in chapter 26 of the General Guidance Manual. Regulators should use any opportunities to determine the variations to authorisations/permits necessitated by paragraph 2.2 above in conjunction with these reviews. 2.9 Under both LAPC and LAPPC, conditions should be reviewed where complaint is attributable to the operation of the process and is, in the opinion of the regulator, justified.

2.8

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

LAPPC and LAPC

3 Process description
Regulations
3.1 Hot dip galvanizing processes are prescribed for: Local air pollution control, LAPC, under section 2.2 of Schedule 1 to the Environmental Protection (Prescribed Processes and Substances) Regulations 1991, SI 472 (as amended). Local air pollution prevention and control, LAPPC, under section 2.2 Part B (c) of Schedule 1 of the Pollution Prevention and Control Regulations 2000 SI 1973.

3.2

This note refers to processes for the melting of zinc or its alloys in conjunction with hot dip galvanizing. For the purpose of this note the term galvanizing will be used to mean hot dip galvanizing. Where they have an input of more than 2 tonnes of crude steel per hour, processes applying protective fused metal coatings will become Part A(2) prescribed processes under Pollution Prevention and Control Regulations 2000, in accordance with Schedule 1 section 2.1 Part A(2) (c). This note does not apply to such processes which will be the subject of Integrated Pollution Prevention and Control.

3.3

General galvanizing

Pretreatment
3.4 The requirement for successful galvanizing is that the item to be dipped must be free from contaminants prior to dipping. Pretreatment to achieve the surface required for galvanizing may include cleaning, pickling and fluxing. Some items, e.g. structural steel, may arrive on site in a clean state and not require any cleaning. The cleaning of iron and steel items may include any of the following physical and chemical treatments: Shot blasting removes contamination such as paint, sand or grease. It may also be used to create a greater surface area allowing a thicker zinc coating when galvanizing. Degreasing removes surface oils and grease using proprietary solutions which may be alkaline, neutral or acidic. Some galvanizers use surfactant additives in the acid pickling bath for degreasing. Although it is not normal practice, vapour degreasing with organic solvents may be undertaken. In this event PG6/23 (coating of metal and plastic) should be consulted for the appropriate standards of control and emission limits. Rinsing may be used after alkaline degreasing to minimise carryover of alkaline solution into the acid pickling tank. Pickling is a process whereby the surface of the items are prepared for galvanizing. It involves removal of surface oxidation products (eg rust) and millscale (arising from the steel rolling process). Generally hydrochloric acid (36% or 28%) is bought in bulk and diluted on site for use in pickling baths at ambient temperature, (concentrations up to 18% acid is generally used). The acid used is co-product acid, which means it is derived from a commercial process involving chlorination of an organic compound, (if the co-product acid meets BS 3993 (1996) then the organic content is controlled. It is not a necessary requirement however.) It is possible on occasion that co-product acid may have an odour associated with its organic content. This should be acceptable provided it is not noticeable outside the process boundary (Sometimes 15% sulphuric acid is used for pickling at 40oC. In combination with a pickling inhibitor, emissions from use of sulphuric acid are not problematic). The reaction in the pickling bath is slightly exothermic. Use of heated pickling solutions reduces pickling times. Stronger acids or heated acids may generate more fume and may require arrestment and control under COSHH regulations.

3.5

3.6

3.7

3.8

3.9

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

LAPPC and LAPC

3.10 The acid needs to be at about 10 oC to start the pickling process. If the temperature falls below this it is acceptable to apply indirect heating to raise the temperature (Direct injection of steam may give rise to unacceptable fuming and should not be used). 3.11 An acid inhibitor may be added to the pickling bath which prevents the acid from attacking the steel itself. Fume suppressants may also be used. 3.12 As pickling proceeds, the iron content of the acid builds up and the acid strength decreases. When the bath reaches a composition of approximately 5% acid and 150 g/l of iron it is no longer effective as a pickling solution and is described as "spent". The rate at which this occurs depends upon the work being pickled. Operators may top up an acid bath with fresh acid from time to time. There is usually a number of acid pickling baths that range in strength from fresh acid to spent acid. When a tank is spent and can no longer be used for pickling it may be used for stripping the zinc from any rejected galvanized work. Some operators have a dedicated acid bath for zinc stripping only. Waste acid is tankered off site for treatment. 3.13 Good practice when taking delivery of acid directly into an acid bath or when remaking acid baths is to secure the discharge hose to the bath. As delivery of acid from the tanker is usually air pressure assisted there may be an air surge caused by the release of pressure towards the end of a delivery. Good control of the delivery rate and pressure release is required. This is managed by the tanker driver. There are developments towards vehicle mounted or ground mounted pump delivery which avoids this problem and reduces fuming. The INEOS- chlor Hydrochloric Acid Bulk Storage document (Ref 7) provides guidance for acid storage and fume minimisation, which may be useful where acid is stored on site prior to use. 3.14 Rinsing after pickling washes off acid and prevents carryover of iron salts on the surface of the workpiece. Such carryover would cause additional dross to be formed in the zinc bath. Water is used for rinsing. Two rinse tanks may sometimes be used.

Fluxing
3.15 A flux is usually applied to the work surface in order to prevent any oxidation of the work piece before it is dipped. It covers the whole surface and enhances the zinc "wetting" of the steel allowing a uniform coating to be achieved. 3.16 Zinc chloride can be used as a flux but most fluxes consist of zinc ammonium chloride (ZAC). This is a mixture of zinc chloride and ammonium chloride salts. The proportions of each may vary. They are sometimes described as double or triple salts, where double salt is made of 55% zinc chloride 45% ammonium chloride and triple salt is made of 45% zinc chloride 55% ammonium chloride. (These salts comprise a molecular mix which is crystallised out during manufacture - "double salt" has 1 molecule of zinc chloride to 2 molecules of ammonium chloride, "triple salt" has 1 molecule of zinc chloride to 3 molecules of ammonium chloride - they store much better than a mixture of zinc chloride and ammonium chloride which goes very hard as zinc chloride is deliquescent). Ammonium chloride from the flux is one of the main components of the fume when the workpiece is dipped. 3.17 There are now different types of flux available. Fluxes described as "low fuming" have been developed. These are proprietary mixtures where the ammonium chloride constituent of traditional fluxes has been reduced and partially replaced with other salts. These fluxes require technical management and may not be acceptable to all operators or applicable to all types of work. Due to the technicalities of the use of low fuming flux more frequent emission monitoring may be considered if a galvanizer chooses it as a new technique. Once use of the flux has become established and it has been demonstrated that the emission limit can be consistently achieved then any increased monitoring requirement may be relaxed.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

LAPPC and LAPC

3.18 There are two methods of fluxing. conjunction with each other.

They may be used independently or in

3.19 Dry fluxing is where the work is dipped into an aqueous flux solution (sometimes referred to as preflux) after rinsing and before immersion into the galvanizing bath. The properties of ZAC fluxes can be improved by adding a wetting agent which reduces the surface tension of the flux solution. After dry fluxing the work may be placed into a drying chamber prior to dipping to remove as much water from the aqueous preflux as possible. Water carryover into the zinc bath can cause spattering of molten zinc during immersion and bare patches on the finished article. A drying chamber is not essential. Heating the flux solution to 70 oC helps to speed up the fluxing action as well as the drying process. When zinc chloride flux is used it is common to pre-heat the work pieces in a furnace. 3.20 Wet fluxing is where the dried work is immersed through a flux blanket which lies on the molten zinc surface. This technique is now less commonly used than dry fluxing as it is a slow process and usage rate of flux is high. Wet fluxing systems are more commonly used for specialist processes such as spin galvanizing and hand dipping. 3.21 The prepared items are then ready to be galvanized.

Galvanizing
3.22 The galvanizing bath contains molten zinc or zinc alloy at about 440 - 460 oC. Specialist plants operate at about 555oC. Alloy formation is different at this temperature. (98.5% zinc is the lowest grade of zinc that is usually used). Metal additives in small quantities are used to enhance the characteristics of the galvanizing process. Such techniques are continually being developed world-wide within the industry. 3.23 The galvanizing process is a metallurgical reaction which creates zinc/iron alloy layers. The composition of the alloy layers changes. The layers closest to the base metal are iron rich with the percentage of zinc increasing through the layers until there is 100% zinc layer at the surface. The quality of the final product can be affected by the make up of the steel article. 3.24 Where ammonium chloride or ZAC type of fluxes are used, fume is created instantaneously at the point of dipping. The content includes ammonium chloride, zinc oxide, zinc chloride and steam. These arise from the flux and the molten zinc. 3.25 Containment of the fume from dipping is usually effected by the use of enclosures which may be fixed or mobile. During dipping the enclosure should be in place and the extractor fans switched on. 3.26 Double dipping is a technique which is sometimes used for extremely large work pieces. Where the length of the item is such that one door of the enclosure can not be closed during dipping, then fugitive fume emissions should be contained in the building. (Note: items may be double dipped for reasons other than that the work is too large for the bath. In these cases the issue of doors being left open does not arise). 3.27 When semi -automatic tube galvanizing, full enclosure is impractical and a canopy is considered BAT in these circumstances, provided that there is sufficient extraction so that there is not significant escape of fume into the workplace. Tube blowing is carried out to remove zinc oxide buildup on the inner surface of the tube. 3.28 Dusting (also described as hand salting) - ammonium chloride salt is occasionally sprayed as a powder or a solution, or hand applied to work as it is withdrawn from the bath, in order to remove excess zinc or impurities that may have adhered to the work surface. This gives rise to fumes and should be avoided wherever possible. The use of a spray gun allows more control over the process and is to be preferred to hand application. The extraction should be operational during dusting.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

LAPPC and LAPC

3.29 The ash, which is mainly zinc oxide, forms on the surface of the molten zinc and is skimmed back before the work is withdrawn from the bath to avoid it contaminating the coating. 3.30 The dross is a solid consisting of about 95% zinc/5% iron alloy. It is heavier than zinc and sinks to the bottom of the zinc bath. It is removed periodically with perforated grabs or spoons.

Post treatment
3.31 The work may be left to air cool to room temperature but often it is quenched in water (boshed) after galvanizing. 3.32 "Passivation" is an optional step in the process whereby the reactivity of the surface is reduced. The choice of passivation techniques will depend upon any further process requirements or particular end uses of the product. Chromic acids or chromate salts may be added to the quench water to prevent "wet storage stain" appearing subsequently. Phosphate treatments and complex oxide treatments are also sometimes used. 3.33 The application of other coatings, for example paint, liable to emit volatile organic compounds or particulate matter where the process uses more than 5 tonnes of organic solvents in any 12 month period is the subject of separate guidance.

Zinc recovery

3.34

The recovery of zinc from dross or ash removed from the galvanizing bath by separate heat or chemical treatment methods is a refining operation and subject to control under Part A of the definition in Appendix 1 and is not considered further in this note.

3.35 However, the removal of metallic zinc from ash produced by the galvanizing process, achieved by physical separation techniques is within the scope of this note. 3.36 The majority of galvanizers "rework" their ash carefully on the zinc bath surface in order to reduce zinc losses into the ash. The residual ash is then taken offsite for zinc recovery. Some galvanizers may prefer to remove the ash more quickly from the surface of the bath and later "rework" their ash. Typically the ash may either be melted in a small furnace or transferred back into the galvanizing bath below the zinc surface via a screw feed. Any zinc left in the ash will melt and the ash that remains on the surface will contain less zinc. This process is likely to give rise to substantial amounts of fume. Adequate provisions must be made to ensure compliance with the emission limits.

Spin or centrifuge galvanizing

3.37 The terms spin galvanizing or centrifuge galvanizing are used to describe the process for hot dipping threaded components and other small parts. They are immersed into the molten zinc in a perforated basket. After the coating has formed the basket is removed from the melt and is centrifuged at high speed to throw off the surplus zinc and ensure a clean profile. The work is normally quenched after the centrifuging operation. Flux blankets are occasionally used for this process. 3.38 Certain pieces of work due to their intricate shape cannot be wired or jig mounted. Others due to their potential to trap air give rise to quality and/or safety issues. Such pieces may be galvanized by hand dipping. One item is dipped at a time. Hand dipping may sometimes take place through a flux blanket. 3.39 Continuous sheet or strip galvanizing processes are normally undertaken using an oven with a reducing atmosphere for pretreatment prior to direct immersion into a zinc bath not involving the use of fluxes. 3.40 Wire galvanizing is normally a continuous process and can involve some or all of the following pre-treatment processes - annealing, degreasing, pickling, rinsing and fluxing before the actual galvanizing.

Hand dip galvanizing

Continuous sheet galvanizing Wire galvanizing

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

LAPPC and LAPC

3.41 A similar process is used for galvanizing fabricated welded wire mesh and for hexagonal wire netting. 3.42 Up to 60 individual wire strands (normally 20 - 40) pass through the galvanizing process in parallel. Lines stretch for up to 500 m, of which the galvanizing bath is likely to be no more than about 8 m, with a zinc capacity of up to 100 tonnes. A lead emission limit applies to processes using lead annealing or quenching baths. 3.43 Galvanized wire can be divided into two types, mild steel and highly carbon steel. Mild steel galvanized wire is used for the manufacture of barbed wire, hexagonal netting, field fencing etc. High carbon steel galvanized wire is used for the manufacture of springs, ropes, cables etc (items requiring its high tensile strength). The mild steel galvanizing process generally requires a soft wire, which is achieved by annealing through molten lead baths or furnaces of several different types. The high carbon steel galvanizing process requires a re-crystallised structure which is achieved by heating through a furnace and quenching in a lead bath or other medium (can be specially designed water quench) in order to freeze the recrystallised structure and provide a ductile and workable finished product, this process is known as "patenting". Any of the above wires may be galvanized hard in which process the wire will pass through a low temperature lead bath or furnace in order to stress relieve the wire and degrease. 3.44 The lead bath or baths will be subject to Part A1 of the definition in Appendix 1 where it results in a release into the air of particulate matter or smoke containing lead, unless exempted by virtue of Regulation 4 of the Environmental Protection (Prescribed Processes and Substances) Regulations 1991. 3.45 The galvanizing process itself is achieved by passing the wires through the zinc bath under a sinker. The sinker may be a roller which rotates with the wire or a solid block of ceramic or refractory concrete under which the wire skids. The wire exits the zinc normally vertically as this gives the simplest conditions for a concentric coating. It is then wiped by a range of techniques in order to achieve the required coating weight. The most common today are "jet wiping" which uses nitrogen gas to achieve heavier coat weights and "pad wiping" which uses mineral fibre pads to achieve light coating weights. The zinc bath itself will be run at about 450 oC. 3.46 An alternative coating can be achieved by a double dip process with the first bath containing a conventional zinc coating and the second containing an alloy of zinc and 5% aluminium (known as Galfan) which gives enhanced corrosion protection.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

10

LAPPC and LAPC

Pollutants and sources

Figure 3.1: Flow diagram of a typical galvanizing process

Storage area

Preparation, drilling holes, wiring up

Grit blasting

Degreasing

Rinsing

Pickling

Rinsing

Pre-fluxing

Drying

Dry galvanizing

Wet galvanizing

Centrifuging

Boshing

Finishing

Despatch

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

11

LAPPC and LAPC

4 Potential releases
4.1 The key emissions from hot dip galvanizing processes that constitute pollution for the purposes of Part I of the Environmental Protection Act 1990 or the Pollution Prevention and Control Regulations 2000 and therefore warrant control are those consisting of particulate matter. Wire galvanizing processes have the added potential to emit lead to atmosphere as they use molten lead baths in addition to zinc baths. Ash handling may give rise to particulate matter in the form of dust (Being hygroscopic, zinc ammonium chloride is not considered to be a dusty material). The galvanizing bath may give rise to dust, fume and steam. Steam blowing of tube may give rise to zinc (in particulate form) and zinc oxide. The following parts of the process have the potential to give rise to other pollutants: use of zinc ammonium chloride fluxes may give rise to chloride emissions at the galvanizing bath pickling may give rise to acid fumes. The acid may contain some organic material, but this should not be allowed to give rise to an organic odour across the site boundary visible steam emissions may arise from degreasing, prefluxing and post-galvanizing treatments due to the temperature of the operations lead baths used in wire galvanizing have the potential to give rise to lead emissions

4.2

4.3 4.4 4.5

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

12

LAPPC and LAPC

5 Emission limits, monitoring and other provisions

5.1 The emission limit values and provisions described in this section are achievable using the best available techniques described in Section 6. Monitoring of emissions should be carried out according to the method specified in this section or by an equivalent method agreed by the regulator. (See Ref. (e) (M1) and Ref. (f) (M2)) 273K, 101.3kPa, the oxygen and water references should be that which corresponds to the normal operating conditions in the process concerned.

 The reference conditions for limits in Table 2 are:

Table 2: Emission limits, monitoring and other provisions

Row

Source

Substance

Emission limits / provisions 15 mg/m3

Type of monitoring

Monitoring frequency (subject to paragragraph 5.12) Continuous

Galvanizing baths not using low fuming flux but using arrestment plant All galvanizing baths

Total particulate matter

Indicative monitoring

Total particulate matter

15 mg/m3

Manual extractive test

At least once a year and quarterly for low fuming flux operations where continuous indicative monitoring is not being used Continuous

Flue or duct emissions from contained sources other than galvanizing e.g. shot blasting plant, ash reclamation All authorised emission points from low fuming flux operations without arrestment prior to discharge Source

Total particulate matter

20 mg/m3

Indicative monitoring Plus Manual extractive test

Annual

Total particulate matter

No persistent visible emission

Operator observations

At least daily

Row

Substance

Emission limits / provisions 30 mg/m3

Type of monitoring

Monitoring frequency (subject to paragragraph 5.12) Annual

Hydrochloric acid pickling plant, where emissions are contained and extracted

Chloride (expressed as hydrogen chloride)

Manual extractive test

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

13

LAPPC and LAPC

Row

Source

Substance

Emission limit as the metal 0.25 mg/m3

Type of monitoring

Monitoring frequency (subject to paragragraph 5.12) Annual

Lead annealing baths (wire galvanizing) where emissions are extracted to atmosphere

Lead and its compounds

Manual extractive test Results should be expressed as 15 minute mean

Monitoring, investigations and recording

5.2

The need for and scope of testing, and the frequency and time of sampling depend on local circumstances, operational practice and the scale of operation. As part of proper supervision the operator will monitor emissions, make tests and inspections of the process and keep records, in particular:

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

Information required by the regulator

5.3

The regulator needs to be informed of monitoring to be carried out and the results; the results should include process conditions at the time of monitoring.

 The operator should provide a list of key arrestment plant and should have a written procedure for dealing with its failure, in order to minimise any adverse effects.  The operator should notify the regulator at least 7 days before any periodic monitoring exercise to determine compliance with emission limit values. The operator should state the provisional time and date of monitoring, pollutants to be tested and the methods to be used.  The results of non-continuous emission testing should be forwarded to the regulator within 8 weeks of the completion of the sampling.  Adverse results from any monitoring activity (both continuous and non-continuous) should be investigated by the operator as soon as the monitoring data has been obtained/received. The operator should: 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 regulator

Visible emissions

5.4

Visible emissions should be limited and monitored. Abnormal emissions require action as described in paragraph 5.6.

 Emissions from combustion processes should in normal operation be free from visible smoke and in any case should not exceed the equivalent of Ringelmann Shade 1 as described in British Standard BS 2742:1969.  All releases to air, other than condensed water vapour, should be free from persistent visible emissions.  All emissions to air should be free from droplets.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

14

LAPPC and LAPC

5.5

Poor operation or management of the galvanizing process may give rise to visible flux emissions originating in the galvanizing bath. Arrestment is usually required to ensure compliance with the emission limit for particulate matter. However, it is possible that low fuming fluxes may meet the emission limit without requiring arrestment. The use of these fluxes is a specialist technique and it is not guaranteed that the emission limit will be met simply by the use of such fluxes. Monitoring the condition of the flux in use is very important as carry over from the pickling process may affect its fuming qualities.

 Where extracted emissions from the galvanizing baths discharge to atmosphere without arrestment, visual assessments of emissions to atmosphere should be made frequently, and at least once a day whilst the process is in operation. The time, location and result of these assessments should be recorded. Where persistent visible emissions are observed, the cause should be identified and remedial action should be carried out. Records of such incidents and the remedial action taken should be kept in accordance with paragraph 5.3. This condition should not be applied to continuous wire galvanizers where the particulate emissions have been demonstrated to meet the limits in Table 2, unless there is a change in the fluxing operation.

Abnormal events

5.6

The regulator needs to be notified about certain events, whether or not there is related monitoring showing an adverse result, and the operator should respond to problems which may have an adverse effect on emissions to air.

 In the case of abnormal emissions, malfunction or breakdown leading to abnormal emissions the operator should: investigate and undertake remedial action immediately adjust the process or activity to minimise those emissions; and promptly record the events and actions taken 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, for example, bag filtration plant or scrubber units.

 The regulator should be informed without delay:

Continuous monitoring

5.7

Continuous indicative monitoring can be used as a management tool. In conjunction with continuous recording it identifies any trends in emissions; for example, that emissions are gradually increasing, which may indicate a need for maintenance. It can also be used with or without continuous recording to trigger an alarm when there is a sudden increase in emissions; for example, if arrestment plant fails. For a given concentration of particulate the output level varies with the instrument. It should be noted that not all monitors provide a linear response to an increase in particulate matter. The monitor should be set up to provide a baseline output when the plant is known to be operating under the best possible conditions; i.e. such that emissions are fully compliant with the requirements. The instrument manufacturer should be able to set an output level which corresponds to around 75% of the emission limit, to trigger the alarms. Thus the alarms are activated in response to this significant increase in particulate loading above the baseline, so that warning of the changed state is given before an unacceptable emission occurs.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

15

LAPPC and LAPC

5.8

All new continuous monitoring equipment should be designed for less than 5% downtime over any 3-month period. Where continuous indicative monitoring of particulate emissions is required it should be carried out as follows: all continuous monitoring readings should be on display to appropriately trained operating staff instruments should be fitted with audible and visual alarms, situated appropriately to warn of particulate arrestment plant failure or malfunction the activation of alarms should be automatically recorded all continuous monitors should be operated, maintained and referenced in accordance with the manufacturer's instructions, which should be made available for inspection by the regulator. The relevant maintenance and calibration (or referencing) should be recorded purchasers of new or replacement monitoring equipment should specify the requirement for less than 5% downtime over any three-month period, on ordering

5.9

Wet scrubbers may be used to abate emissions of particulate matter from the galvanising bath and may also be used to control acidic emissions from pickling areas, in which case the pH of the scrubbing solution would be of relevance.

 Where arrestment plant includes a wet scrubber, the liquid flow should be continuously monitored, for example by a variable orifice flow meter. The liquor pH should be continuously monitored where the efficiency of the scrubber unit relies on this.

Calibration and compliance monitoring

5.10 Calibration and compliance monitoring should meet the following requirements, as appropriate:  Non-continuous emissions monitoring of particulate matter should be carried out according to the main procedural requirements of BS ISO 12141:2002 or BS EN 13284:Part 1, with samples taken during periods of maximum emission.  No result should exceed the emission concentration limits specified in Table 2. 5.11 Exhaust flow rates should be consistent with efficient capture of emissions, good operating practice and meeting the requirements of the legislation relating to the workplace environment.  The introduction of dilution air to achieve emission concentration limits should not be permitted.

Varying monitoring frequency

5.12 Where particulate monitoring or operator observations are required in order to demonstrate the correct use of low fuming fluxes or the correct functioning of arrestment equipment, it is not appropriate that the frequency of such monitoring or observations be reduced. There are however circumstances where the regulator may vary the frequency of monitoring, as follows:  The frequency of testing should be increased, 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 limits.  If three or more periodic monitoring exercises carried out over a period of at least 2 years, indicate consistent compliance with emission limits, regulators should consider increasing the interval between future monitoring exercises. Such a relaxation should be considered sooner if the monitoring is supported by continuous monitoring which shows consistent compliance.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

16

In determining "consistent compliance" factors to consider include: the variability of monitoring results, for example, results which range from 5 -15 mg/m3, against an emission limit of 15 mg/m3 might not qualify for a reduction in monitoring, as there is an implication that there may be a problem with the arrestment system if it is not operating consistently. the margin between the results and the emission limit e.g. results which range from 10 -15 mg/m3 when the limit is 15 mg/m3 might not qualify for a reduction in monitoring as there are some results very close to exceeding the limit. whether the process has been subject to significant change which might affect the emission being monitored.

5.13 Where emission limit values are consistently met without the use of arrestment equipment, the monitoring requirement for those pollutants should be dispensed with, subject to the caveats above. 5.14 The frequency of testing should be increased, 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 limits.

Sampling provisions

5.15 Care is needed in the design and location of sampling systems in order to obtain representative samples for all release points.  Sampling points on new plant should be designed to comply with the appropriate British or equivalent standards. e.g. BS EN 13284-1or BS ISO 12141:2002 for sampling particulate matter in stacks.  The operator should ensure that adequate facilities for sampling are provided on stacks or ducts.  Where monitoring is not in accordance with the main procedural requirements of the relevant standard, deviations should be reported as well as an estimation of any error invoked.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

17

6 Control techniques
Summary of best available techniques
6.1 The following table provides a summary of the best available techniques that can be used to control the process in order to meet the emission limits and provisions in Section 5. Provided that it is demonstrated to the satisfaction of the regulator that an equivalent level of control will be achieved, then other techniques may be used.

Table 3: Summary of control techniques

Release source Galvanizing bath Ash reworking Tube blowing Storage of ash and other dusty wastes - Movement of ash onsite - Movement of ash offsite Abrasive blasting Where there is extraction from pickling areas Where used in pickling areas Annealing or quenching in lead bath (wire galvanizing)

Substance Particulate matter Particulate matter Particulate matter Particulate matter Particulate matter Particulate matter Particulate matter Chloride Sulphuric Acid Lead

Control techniques Enclosures and extraction, followed by arrestment plant where necessary Enclosures and extraction, followed by arrestment plant where necessary Enclosures and extraction, followed by arrestment plant where necessary Within enclosed building or covered containers - Covered containers - Sheeted lorries Bag filtration Scrubbing of acidic content Use of a pickling inhibitor Temperature control Anthracite covering

Techniques to control emissions from contained sources

6.2 Best available techniques are required to control emissions. The main principles for preventing emissions are the use of operational controls to minimise emissions, then containment and arrestment of emissions. Filtered particulate emissions can be expected to be below 10 mg/m3 if modern plant designed for the purpose is used.

Techniques to control fugitive emissions

6.3 The control techniques described below address the sources of pollutants listed in Table 3.

Pre-cleaning and acid pickling

 Abrasive blasting should be carried out in a specially designed booth and exhausts should be vented to suitable dust arrestment plant to meet the emission concentration limit specified in Table 2 Row 3.  Where heated hydrochloric acid baths are used and mist or fume is emitted, emissions should be contained and vented to suitable arrestment plant, for example a scrubber, to meet the requirements of Table 2 Row 5 of this note.  Direct injection of steam into hydrochloric acid pickling baths should not be used.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

18

Fluxing and hot-dip galvanizing

6.4

The use of solid flux should be reduced by prefluxing with zinc ammonium chloride solution where practicable in relation to the process characteristics. The application of flux for both blanket replenishment and dusting should be reduced to a minimum consistent with good operational practice and should be applied carefully in order to the minimise emissions to air (The emission is due mainly to the sublimation of ammonium chloride which occurs at the temperature of the molten metal). It should be noted that full fume enclosures will not achieve 100 percent fume capture but when used correctly provide adequate capture. In the event that full fume enclosures are not able to be used, for example some spin galvanizing or hand dipping processes, lip extraction may achieve sufficient fume capture provided the work is handled appropriately. Lip extraction is not suitable where galvanizing leads to fume being generated outside of the zone of influence of the extraction. When double dipping it may be necessary for the end door at one end of the bath to remain open. Where semi-continuous tube galvanizing the canopy is considered sufficient provided the extraction system ensures there is no significant escape of fume into the workplace.

6.5

 Emissions from the galvanizing process should be adequately contained and extracted to prevent fugitive emissions from the building.  Full fume containment enclosure should be provided. There are exceptions which include, for example, small hand dipped items and spin galvanizing, provided adequate lip extraction is used; also semi -automatic tube galvanizing where a canopy is used.  If the fume containment enclosure is mobile, it should be in place above the galvanizing bath prior to making up or replenishing flux blankets and when articles are being immersed. The enclosure should also be in place above the galvanizing bath during flux dusting and should remain in place until the fume produced subsides.  Sufficient fume containment measures should be provided to collect fume produced when working the ash; for example by working ash with the enclosure in place or by the use of peripheral extraction.  All doors to fume enclosures should be closed during immersion of articles into the galvanizing bath.

Materials handling

6.6

Hygroscopic materials are unlikely to give rise to dust. Ashes from the zinc bath need to be kept dry to avoid the risk of toxic arsine gas (arsenic trihydride) being formed.

 Ash, and any other potentially dusty materials, should be stored in such a manner as to prevent wind whipping. All such materials should be stored in covered containers or within an enclosed area, and handled in a manner that avoids emissions of dust.  Ashes from the zinc bath should be kept dry at all times.  The method of collection of waste from dry arrestment plant should be such that dust emissions are minimised.  A high standard of housekeeping should be maintained.  Lorries transporting ash or other potentially dusty materials should be sheeted immediately after loading.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

19

Air quality Ambient air quality management

6.7 In areas where air quality standards or objectives are being breached or are in serious risk of breach and it is clear from the detailed review and assessment work under Local Air Quality Management that the Part B process itself is a significant contributor to the problem, it may be necessary to impose tighter emission limits. If the air quality standard that is in danger of being exceeded is not an EC Directive requirement, then industry is not expected to go beyond BAT to meet it. Decisions should be taken in the context of a local authority's Local Air Quality Management action plan. For example, where a Part B process is only responsible to a very small extent for an air quality problem, the authority should not unduly penalise the operator of the process by requiring disproportionate emissions reductions. More guidance on this is provided in paragraph 360 of the Air Quality Strategy which gives the following advice: The approach from local authorities to tackling air quality should be an integrated one, involving all strands of local authority activity which impact on air quality and underpinned by a series of principles in which local authorities should aim to secure improvements in the most cost-effective manner, with regard to local environmental needs while avoiding unnecessary regulation. Their approach should seek an appropriate balance between controls on emissions from domestic, industrial and transport sources and draw on a combination and interaction of public, private and voluntary effort.

Dispersion and dilution

6.8

Pollutants that are emitted via a stack require sufficient dispersion and dilution in the atmosphere to ensure that they ground at concentrations that are harmless. This is the basis upon which stack heights are calculated using HMIP Technical Guidance Note D1 (D1). The stack height so obtained is adjusted to take into account local meteorological data, local topography, nearby emissions and the influence of plant structure. It is necessary that the assessment also take into account the relevant air quality standards that apply for the emitted pollutants. The calculation procedure of D1 is usually used to calculate the required stack height but alternative dispersion models may be used in agreement with the regulator. D1 relies upon the unimpeded vertical emission of the pollutant. A cap or other restriction over the stack impedes the vertical emission and hinders dispersion. For this reason where dispersion is required such flow impeders should not be used. A cone may sometimes be useful to increase the exit velocity and achieve greater dispersion. Revised stack height calculations should not be required unless it is considered necessary because of a breach or serious risk of breach of an EC Directive limit value and because it is clear from the detailed review and assessment work that the Part B process itself is a significant contributor to the problem. An operator may choose to meet tighter emission limits in order to reduce the required stack height.

Stacks, vents and process exhausts

6.9

Liquid condensation on internal surfaces of stacks and exhaust ducts might lead to corrosion and ductwork failure or to droplet emission. Adequate insulation will minimise the cooling of waste gases and prevent liquid condensation by keeping the temperature of the exhaust gases above the dewpoint. Stacks and ductwork should be leakproof.

6.10 The dispersion from all stacks and vents can be impaired by low exit velocity at the point of discharge, or deflection of the discharge. Unacceptable emissions of droplets could possibly occur from wet arrestment plant where the linear velocity within the associated ductwork exceeds 9 m/sec. The use of mist eliminators reduces the potential for droplet emissions.  Where a linear velocity of 9 m/sec is exceeded in the ductwork of existing wet arrestment plant, it should be reduced to the extent that is practicable to ensure that droplet fallout does not occur.  Flues and ductwork should be cleaned to prevent accumulation of materials, as part of the routine maintenance programme.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

20

 Exhaust gases discharged through a stack or vent should achieve an exit velocity which is normally greater than 15 m/sec during normal operating conditions to achieve adequate dispersion. A lower velocity may be acceptable provided it achieves adequate dispersion and dilution in accordance with paragraph 6.8 above.  Stacks or vents should 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.  Where a wet scrubber is installed the stack should be constructed of impervious material, lined or coated so as to minimise the effect of corrosion.

Management Management techniques

6.11 Important elements for effective control of emissions include: proper management, supervision and training for process operations; proper use of equipment; effective preventative maintenance on all plant and equipment concerned with the control of emissions to the air; and it is good practice to ensure that spares and consumables are available at short notice in order to rectify breakdowns rapidly. This is important with respect to arrestment plant and other necessary environmental controls. It is useful to have an audited list of essential items.

 Spares and consumables - in particular, those subject to continual wear - should be held on site, or should be available at short notice from guaranteed suppliers, so that plant breakdowns can be rectified rapidly.

Appropriate management systems

6.12 Effective management is central to environmental performance; It is an important component of BAT and of achieving compliance with permit conditions. It requires a commitment to establishing objectives, setting targets, measuring progress and revising the objectives according to results. This includes managing risks under normal operating conditions and in accidents and emergencies. It is therefore desirable that processes put in place some form of structured environmental management approach, whether by adopting published standards (ISO 14001 or the EU Eco Management and Audit Scheme [EMAS]) or by setting up an environmental management system (EMS) tailored to the nature and size of the particular process. Operators may also find that an EMS will help identify business savings. Regulators should use their discretion, in consultation with individual operators, in agreeing the appropriate level of environmental management. Simple systems which ensure that LAPC considerations are taken account of in the day-to-day running of a process may well suffice, especially for small and medium-sized enterprises. While authorities may wish to encourage wider adoption of EMS, it is outside the legal scope of an LAPC authorisation/LAPPC permit to require an EMS for purposes other than LAPC/LA-PPC compliance. For further information/advice on EMS refer to EMS Additional Information in Section 8.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

21

Training

6.13 Staff at all levels need the necessary training and instruction in their duties relating to control of the process and emissions to air. In order to minimise risk of emissions, particular emphasis should be given to control procedures during start-up, shut down and abnormal conditions. Training may often sensibly be addressed in the EMS referred to above.  Training of all staff with responsibility for operating the process should include: awareness of their responsibilities under the authorisation/permit; minimising emissions on start up and shut down action to minimise emissions during abnormal conditions

 The operator should 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 should be made available to the regulator on request.

Maintenance

6.14 Effective preventative maintenance should be employed on all aspects of the process including all plant, buildings and the equipment concerned with the control of emissions to air. In particular:  A written maintenance programme should be provided to the regulator with respect to pollution control equipment; and  A record of such maintenance should be made available for inspection.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

22

7 Summary of changes
Reasons for the main changes are summarised below.
Table 4: Summary of changes

Section and paragraph

Change

Reason

Comment

Emission limits, monitoring and other provisions Olfactory assessments Removed requirement for daily monitoring Experience has demonstrated that offensive odours are not usually associated with galvanizing Possibility of odour associated with the organic content of acid used in pickling. This should be controlled by control of the source of acid, where necessary Due to the limited solubility of lead in zinc, the vapour pressure of lead at galvanizing temperature is virtually zero The emission limit for particulate matter provides the necessary control with regard to fluxing operations. This indirectly controls gaseous chloride emissions The emission level is such that the national ambient air quality objectives are not compromised The use of these fluxes is a specialist technique The main procedures of BS ISO 12141:2002 or BS EN 13284:Part 1 should be followed and any points of diversion from the standard noted. The effect on the results of any deviation from the standard should be estimated and reported

Annual lead monitoring for general galvanizing processes

Removed clause 23 of old note (Note the requirement for lead monitoring where lead baths are used in the process) Removed requirement in clause 22 of old note

Monitoring has consistently shown lead levels at or below the level of detection (0.02 mg/ m3 ) Gaseous phase chloride is not directly abated. Control of fluxing operations provides the necessary controls of the emission of chloride which is created predominantly due to the dissociation of the flux Best available techniques achieves this emission concentration To ensure correct operating conditions for low fuming flux BS ISO 12141:2002 or BS EN 13284:Part 1 designed to measure concentrations below those for which BS 3405 was written

Annual testing for gaseous chloride from galvanizing bath

Table 2 Row 6 Lead limit for wire galvanizing

Changed from 2 mg per cubic metre to 0.25 mg per cubic metre Where no arrestment is used frequent visual assessments of emissions are required Use of BS 3405 for monitoring particulate matter emissions replaced by BS ISO 12141:2002 or BS EN 13284:Part 1 Sampling points on new plant should be designed to comply with BS ISO 12141:2002 or BS EN 13284:Part 1 requirements

5.5

5.11 and 5.15

Control techniques Containment and venting of emissions to air from chromate and/or phosphate coatings after galvanizing 6.3 Remove requirement clause 51 No COSHH requirement for extraction

Direct steam injection into pickling baths should not be used Ashes from the zinc bath should be kept dry

Direct steam injection creates unacceptable fuming To avoid the risk of toxic arsenic trihydride gas being formed

6.6

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

23

8 Definitions and further information

This guidance Previous guidance LAPC LAPPC Permit Authorisation Local enforcing authority Regulator Existing process Process Guidance Note 2/2(04) Process Guidance Note 2/2(95) which in its turn replaced PG2/ 2(91) explained in the Introduction of this guidance explained in the Introduction of this guidance the written permission to operate an installation prescribed for LAPPC (the replacement for authorisation under LAPC) the written authority to operate a process prescribed for LAPC (will be replaced by permit under LAPPC) is replaced by the word regulator in LAPPC replaces the phrase local enforcing authority from LAPC should be taken to have the following meaning (which is based on paragraph 14 of Schedule 3 to SI 1991 /472): a process which was being carried on at some time in the 12 months immediately preceding the first day of the month following publication of this guidance note a process which is to be carried on at a works, plant or factory or by means of mobile plant which was under construction or in the course of manufacture or in the course of commission on the first day of the month following publication of this guidance note, or the construction or supply of which was the subject of a contract entered into before that date New process Authorised person Installation not an existing process. under section 108 of the Environment Act 1995, authorised person has replaced the term inspector should be interpreted in accordance with the guidance contained in the the General Guidance Manual on Policy and Procedures for A2 and B Installations. www.defra.gov.uk/environment/ppc/manual/index.htm the term process has been used in this guidance note to refer to both processes under the Environmental Protection Act 1990 and installations under the Pollution Prevention and Control Act 1999

Process

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

24

Health and safety

Operators of processes and installations must protect people at work as well as the environment: requirements of a permit or authorisation should not put at risk the health, safety or welfare of people at work equally, the permit or authorisation must not contain conditions whose only purpose is to secure the health of people at work. That is the job of the health and safety enforcing authorities

Where emission limits quoted in this guidance conflict with health and safety limits, the tighter limit should prevail because: emission limits under the Environment Protection Act 1990 or Pollution Prevention and Control Act 1999 relate to the concentration of pollutant released into the air from prescribed activities exposure limits under health and safety legislation relate to the concentration of pollutant in the air breathed by workers these limits may differ since they are set according to different criteria. It will normally be quite appropriate to have different standards for the same pollutant, but in some cases they may be in conflict (for example, where air discharged from a process is breathed by workers). In such cases, the tighter limit should be applied to prevent a relaxation of control

EMS additional information

Further information/advice on EMS may be found from the following: Envirowise at www.envirowise.gov.uk and www.energy-efficiency.gov.uk and Environment and Energy Helpline freephone 0800 585794 ISO 14001 www.bsi.org.uk or telephone BSI information centre (020 8966 7022) EU Eco Management and Audit Scheme (EMAS) www.emas.co.uk or telephone the Institute of Environmental Management and Assessment (01522 540069)

Regulators and process operators may also like to be aware of: BS 8555: a new standard to help SMEs implement an EMS, by offering a five-phase approach, is contained in BS 8555 which was published in 2003 following on from work undertaken by the Acorn Trust. The Institute of Environmental Management and Assessment, which has taken over the Trust's activities, is developing a scheme of accredited recognition for companies achieving different phases of BS 8555. BS 8555 can be used to achieve ISO 14001 and registration to the higher standard, EMAS. Some of the High Street banks, such as NatWest and the Coop, now offer preferential loan rates to organisations that can demonstrate they are committed to improving their environmental performance. The NatWest also produce a self help guide for SMEs, The Better Business Pack, focusing on waste, utilities, transport and supply chain issues. It gives tools, guidance and examples. Contact: WWF-UK on 01483 426444.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

25

References
(a) Secretary of State's Guidance (England and Wales): General Guidance Manual on Policy and Procedures for A2 and B Installations , March 2003 - available from the Defra website and, in hard copy, from the Defra Publications line 08459 556000 www.defra.gov.uk/ environment/ppc/index.htm (b) DOE/WO Additional Guidance AQ17(94), issued to local authorities by the Air and Environment Quality Division of DEFRA and by the Welsh Office, provides further advice on the assessment of odour. The Scottish equivalent of AQ17(94) is SN 11(94). (c) Current air quality objectives are specified in: - The Air Quality (England) Regulations 2002 SI 3043 - The Air Quality (Wales) Regulations 2002 WSI 3182 (W.298) - The Air Quality (Scotland) Regulations 2002 SSI 297 (d) HMIP Technical Guidance Note D1: "Guidelines on Discharge Stack Heights for Polluting Emissions", published by The Stationery Office, ISBN 0-11-752794-7. (e) M1 Sampling requirements for monitoring stack emissions to air from industrial installations, Environment Agency July 2002 (EA website) (f) M2 Monitoring of stack emissions to air. Environment Agency May 2003 (EA website) (g) Chemical storage tank systems - good practice. CIRIA July 2003 ISBN 0 860 17 598 7 (h) BS 2742:1969: "Notes on the use of Ringelmann and miniature smoke charts". (i) BS 3993: 1996: "Specification for hydrochloric acid, commercial types 1 and 2" (j) BS ISO 12141:2002: Stationary source emissions - Determination of mass concentration of particulate matter (dust) at low concentrations - Manual gravimetric method (k) BS EN 13284-1:2002: Stationary source emissions - Determination of low range mass concentration of dust - Part 1: Manual gravimetric method

Web addresses
The final consultation drafts and final published versions of all guidance notes in this series can be found on www.defra.gov.uk/environment/index.htm. Welsh Assembly Government web-site www.wales.gov.uk. Local Authority Unit of the Environment Agency for England and Wales. www.environmentagency.gov.uk. Scottish Environment Protection Agency (SEPA) www.sepa.org.uk. Energy saving and environmental management measures can increase industry profits. Envirowise (formerly ETBPP) show how at www.envirowise.gov.uk (or freephone 0800 585794).

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

26

Appendix 1: Extract from Pollution Prevention and Control (England and Wales)6 Regulations 2000 SI 19737
DEFINITION OF NON-FERROUS METAL PROCESSES IN SCHEDULE 1. (The processes for local air pollution prevention and control are listed under "Part B". The "Part A1" processes are for national regulatory control. The "Part A2" processes are subject to local authority integrated pollution prevention and control.) Section 2.2 - Non-Ferrous Metals Part A(1) (a) Unless falling within Part A(2) of this Section, producing non-ferrous metals from ore, concentrates or secondary raw materials by metallurgical, chemical or electrolytic activities. (b) Melting, including making alloys, of non-ferrous metals, including recovered products (refining, foundry casting etc.) where (i) the plant has a melting capacity of more than 4 tonnes per day for lead or cadmium or 20 tonnes per day for all other metals; and (ii) any furnace, bath or other holding vessel used in the plant for the melting has a design holding capacity of 5 tonnes or more. (c) Refining any non-ferrous metal or alloy, other than the electrolytic refining of copper, except where the activity is related to an activity described in paragraph (a) of Part A(2), or paragraph (a), (d), or (e) of Part B, of this Section. (d) Producing, melting or recovering by chemicals means or by the use of heat, lead or any lead alloy, if (i) the activity may result in the release into the air of lead; and (ii) in the case of lead alloy, the percentage by weight of lead in the alloy in molten form is more than 23 per cent if the alloy contains copper and 2 per cent in other cases. (e) Recovering any of the following elements if the activity may result in their release into the air: gallium; indium; palladium; tellurium; thallium. (f) Producing, melting or recovering (whether by chemical means or by electrolysis or by the use of heat) cadmium or mercury or any alloy containing more than 0.05 per cent by weight of either of those metals or, in aggregate, of both. (g) Mining zinc or tin bearing ores where the activity may result in the release into water of cadmium or any compound of cadmium in a concentration which is greater than the background concentration.

(h) Manufacturing or repairing involving the use of beryllium or selenium or an alloy containing one or both of those metals if the activity may result in the release into the air of any of the substances listed in paragraph 12 of Part 2 to this Schedule; but an activity does not fall within this paragraph by reason of it involving an alloy that contains beryllium if that alloy in molten form contains less than 0.1 per cent by weight of beryllium and the activity falls within paragraph (a) or (d) of Part B of this Section.
6. 7. For activities carried out in Scotland the PPC (Scotland) Regulations should be referred to. For activities carried out in Ireland the PPC (Ireland) Regulations should be referred to. Every effort has been taken to ensure that this Appendix is correct at the date of publication, but readers should note that the Regulations are likely to be subject to periodic amendment, and this Appendix should not therefore be relied upon as representing the up-to-date position after the publication date.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

27

(i) Pelletising, calcining, roasting or sintering any non-ferrous metal ore or any mixture of such ore and other materials.

Interpretation of Part A(1) In paragraph (g), "background concentration" means any concentration of cadmium or any compound of cadmium which would be present in the release irrespective of any effect the activity may have had on the composition of the release and, without prejudice to the generality of the foregoing, includes such concentration of those substances as is present in (i) water supplied to the site where the activity is carried out; (ii) water abstracted for use in the activity; and (iii)precipitation onto the site on which the activity is carried out. Part A(2) (a) Melting, including making alloys, of non-ferrous metals, including recovered products (refining, foundry casting, etc.) where (i) the plant has a melting capacity of more than 4 tonnes per day for lead or cadmium or 20 tonnes per day for all other metals; and (ii) no furnace, bath or other holding vessel used in the plant for the melting has a design holding capacity of 5 tonnes or more. Part B (a) Melting, including making alloys, of non-ferrous metals (other than tin or any alloy which in molten form contains 50 per cent or more by weight of tin), including recovered products (refining, foundry casting, etc.) in plant with a melting capacity of 4 tonnes or less per day for lead or cadmium or 20 tonnes or less per day for all other metals. (b) The heating in a furnace or any other appliance of any non-ferrous metal or non-ferrous metal alloy for the purpose of removing grease, oil or any other non-metallic contaminant, including such operations as the removal by heat of plastic or rubber covering from scrap cable, if not related to another activity described in this Part of this Section; but an activity does not fall within this paragraph if (i) it involves the use of one or more furnaces or other appliances the primary combustion chambers of which have in aggregate a net rated thermal input of less than 0.2 megawatts; and (ii) it does not involve the removal by heat of plastic or rubber covering from scrap cable or of any asbestos contaminant. (c) Melting zinc or a zinc alloy in conjunction with a galvanising activity at a rate of 20 tonnes or less per day. (d) Melting zinc, aluminium or magnesium or an alloy of one or more of these metals in conjunction with a die-casting activity at a rate of 20 tonnes or less per day. (e) Unless falling within Part A(1) or A(2) of this Section, the separation of copper, aluminium, magnesium or zinc from mixed scrap by differential melting.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

28

Interpretation of Part B In this Part "net rated thermal input" is the rate at which fuel can be burned at the maximum continuous rating of the appliance multiplied by the net calorific value of the fuel and expressed as megawatts thermal. Interpretation of Section 2.2 (1) In this Section "non-ferrous metal alloy" means an alloy which is not a ferrous alloy, as defined in Section 2.1. (2) Nothing in paragraphs (c) to (h) of Part A(1) or in Part B of this Section shall be taken to refer to the activities of hand soldering, flow soldering or wave soldering.

Process Guidance Note 2/2 | Issue 1.0 | Published October 2004

29