The former ICI Runcorn site, bought by Ineos in 2001, is one of the largest centres of chlorine chemistry in Europe. Operation is split between four companies, all within the Ineos group.
The chlor-alkali process is operated by Ineos Chlor. The chlorine produced is the main raw material for PVC made by the European Vinyls Corporation, in which Ineos has a majority stake. Ineos Fluor manufactures fluorinated chemicals such as refrigerants, and Ineos Chlor Enterprises makes sulphur chemicals.
The site must fall under IPPC by December. The Environment Agency says there are 63 prescribed activities at the site.
Ineos Chlor has 33 of them, grouped into five processes: chlorine production, manufacture of chlorinated ethane/ethylene, methane and paraffins, and power generation. Under the current integrated pollution control (IPC) regime, Ineos Chlor has five separate authorisations, one for each process. The other three companies together have seven IPC authorisations.
The transition from IPC to IPPC means that each company will now have a single permit, replacing the existing authorisations. However, because of the highly integrated nature of the complex, the entire site is to be classified as a single "installation".
The EU Directive on IPPC requires that any listed activity "directly associated" with another activity should be regulated as a single installation. Operators are required to use the "best available techniques" to control impacts across the installation. There may, therefore, be a number of installation-wide issues that all of the operators may have to address together.
One example is the incineration of waste liquid residues with a high organic content, which are produced by both Ineos Chlor and EVC. The waste is incinerated at a plant operated by EVC with recovered hydrochloric acid being used by both companies.
An agreement between the companies specifies the parameters of the waste Ineos Chlor can dispose of because this would affect emissions.
Another example is the site condition report. The site is likely to be extensively contaminated. In 1998, ICI was fined £300,000 for a major chloroform spill and £80,000 for spilling chlorinated solvents (ENDS Reports 281, p 50 and 278, pp 47-48 ). Groundwater is contaminated with chloroform and other substances.
There are likely to be benefits from considering land quality on an installation-wide, rather than permit-specific, basis. Other potential installation-wide issues include energy, noise and odour.
Ian Grady, Agency inspector for Ineos Chlor, Ineos Chlor Enterprises and EVC, said that one benefit of IPPC is that it puts the Agency in a much better position to advise operators of opportunities to improve the installation.
For instance, waste heat generated at one operation could be used at another. The Agency would also be aware of potential differences in management procedures and how to improve their effectiveness.
Each application and permit will be a weighty affair, especially at Ineos Chlor. Mr Grady said it was likely that the permit would be broken down into sections focusing on each production process for use by the separate plant managers.
Among the issues confronting the Agency is that the complexity of the four permits and associated documentation could make it difficult to engage meaningfully with the local community and other stakeholders through the permitting process.
Ineos did not wish to discuss the permitting issues at this stage, but it issued a statement: "Each company operating on the Runcorn site will be responsible under its permit for the processes that it operates. This is no different to the situation as at present. The environmental controls under the PPC permits will remain effective in regulating the environmental performance of the companies. We do not see that the structure of permitting under the PPC regulations will give rise to any problems."
Although Runcorn is easily the largest example, there are other multi-operator installations in the chemicals sector. At Wilton, another former ICI site, Dow and Uniqema occupy a single installation at which Uniqema manufactures ethoxylates.