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Responsible Care Performance Report

Grimsby 2004

Interim EMAS Statement


EXECUTIVE SUMMARY:

Highlights of 2004:

- We were in full compliance against our statutory requirements for all our
discharges to air, land and water from our Grimsby Site

- We had, for the first time, no loss time accidents for the full calendar year

- We won the Tioxide Group Quality Award

- We achieved our lowest ever Site SOx emission from calcination and
digestion of 3.2kgSOx/tonne TiO2

- We achieved the European eco-label target, more challenging than statutory


requirements, for aqueous discharge of sulphate

- We had no justified off-site complaints relating to our activities at our


Grimsby Site

- We were short-listed in the final four for the Chemical Industries Association
(CIA) Responsible Care Award

- We successfully completed the restructuring of the analyses of environmental


aqueous samples utilising the resources available in Huntsman Tioxide
Analytical Services at Billingham

- We completed the bulk of the Site IPPC Application allowing it to be


submitted in January 2005 – seven months ahead of the original deadline

- We submitted our PPC Permit Application for our Nettleton Bottom Quarry
Landfill Site on time in November 2004

- We carried out the large amount of work, both administrative and technical,
necessary to implement the single streaming structure without any significant
EHS impact.

Concerns of 2004:

- We did not achieve 100% compliance for discharges from our copperas drying
satellite site at E&A West, Killingholme

- We had three justified off-site environmental complaints relating to our


operation at E&A West, Killingholme

- We did not achieve our internal company target for environmental loss of
titanium dioxide to effluent
UPDATE ON 2003 RESPONSIBLE CARE REPORT

SINGLE STREAMING:
During 2004 it was recognised that Tioxide Europe Limited, Grimsby needed to take
significant actions in order to regain competitiveness. Strategic issues relating to
excess or uneconomic production capacity had to be addressed to restore a position of
positive cash flow at all points of the business cycle

This action comprised:


• Reduction in nameplate capacity to 40 ktpa (reduction of ~ 50%)
• Reconfiguration of the plant to utilise newer and inherently more
reliable equipment
• Implementation of a new management organisation
• Significant reduction in cash costs.

This reconfiguration was called “single streaming” as it basically realigned the


Grimsby Site to one kiln operation and one single process stream.

In this EMAS Interim Statement, this phrase “single streaming” is used to reference
this key change to Site operation and management.

The reconfigured Site will be able to respond positively to the new environmental
challenges it will face through its continued commitment to statutory compliance,
continual improvement and minimisation of its environmental impact.

GRIMSBY SITE:

What do we do?

Huntsman Tioxide is one of the world’s largest producers of titanium dioxide (TiO2)
pigments employing 2,600 people worldwide. Its factories in seven countries have a
nameplate production capacity of approximately 550,000 tonnes per year.

The Grimsby Site has been making pigments continuously since 1949.

In addition, Huntsman Tioxide makes hundreds of thousands of tonnes of beneficial


co-products such as gypsum (used for example in plasterboard manufacture and soil
conditioning) and ferric sulphate (used in water treatment). These are produced as a
consequence of our environmental improvement projects and marketed by our
Materials Business set up in 1993.

The scope of this statement covers all aspects of titanium dioxide pigments
manufacture including co-products up to and including packaging but does not
include distribution, sales and marketing.

This is an interim EMAS Environmental Statement. It highlights what has changed


since the previous full EMAS Statement (the 2003 Site Responsible Care Report) and
should be read in conjunction with that Report. The next interim Statement will be the
2005 Site Environmental Performance Report. It will be published in May 2006 after
completion of the verification process in April 2006. The next full Statement will be
published in May 2007.
How do we make titanium dioxide at Grimsby Site?

We extract it from a beach sand called ilmenite using sulphuric acid. All the ilmenite
currently used at Grimsby Site is sourced from Australia, arriving by boat at
Immingham Docks and being transported by road to the factory. The titanium dioxide
produced is coated and milled to produce a range of versatile pigments for differing
key end uses.

What has changed since 2003?

In 2004, we commenced the “single streaming” process. This reduced the nameplate
capacity of the Site and its workforce by approximately 50%. The Site now uses one
kiln and the newer, more automated process equipment. This will have an impact on
the environmental emissions from site.

As part of this initiative, Mr. Neil Graham became Site Manager.

In December 2004, operation ceased at the satellite E&A West, Killingholme Site
(EAWK) that dried copperas (ferrous sulphate) for sale into horticulture and animal
feed markets. This facility, which was only incorporated within the overall Tioxide
Grimsby ISO14001 registration in March 2004, was no longer aligned with overall
Site priorities after “single streaming”.

During the year, the Site began contracting its effluent analyses (heavy metals) to the
Tioxide Group Analytical Services Department at Billingham.

In 2004, we also completed two Integrated Pollution Prevention and Control (IPPC)
Applications. The first, for our landfill site at Nettleton Bottom Quarry, Lincolnshire,
was submitted to the Environment Agency in November 2004. The second, for the
main Grimsby Site process facility was submitted in January 2005.

What is the Huntsman group of companies?

In July 1999, Tioxide became part of Huntsman. Huntsman is a global manufacturer


and marketer of commodity and differentiated chemicals. Its operating companies
manufacture basic products for a variety of global industries including chemicals,
plastics, automotive, aviation, footwear, paints and coatings, construction, technology,
agriculture, health care, textiles, detergent, personal care, furniture, appliances and
packaging. Originally known for pioneering innovations in packaging, and later, rapid
and integrated growth in petrochemicals, Huntsman today has revenues of $11.5
billion, 11,300 employees and 62 operations in 22 countries.
ACHIEVEMENT OF 2004 TARGETS AND EMISSIONS INVENTORY

2004 Targets Review:


Out of a total of 25 environmental targets for 2004, 20 were achieved and 5 were not
achieved (80% achievement). In 2004, no targets are recorded as “partially achieved”.

In 2003, 81% of the targets were achieved.

Discharges to Water:

Statutory Compliance:
All discharges from Grimsby Site were in compliance with statutory limits.

However, two effluent samples from our EAWK Site exceeded their suspended solids
consent. The overall compliance for all discharges under the management control of
Grimsby Site was 99.98%.

The Site achieved 622kgSO4/tonne TiO2 for effluent discharges well within the
statutory limit of 800kgSO4/tonne TiO2 and also meeting the more challenging Site
internal target of 625kgSO4/tonne TiO2.

Grimsby Site - Aqueous Sulphate


Emissions
800
kgSO4/tonne TiO2

750

700

650

600
5

4
9

0
19

19

19

19

19

20

20

20

20

20

Emissions Inventory:
The liquid effluent emissions inventory is given in the first section of the Grimsby
Site Waste Emission Table.

Many of the parameters show decreases from the previous year. However, there are
increases recorded in the emissions of cadmium, mercury and arsenic. When Site
effluent analyses began to be carried out at Billingham, initial method development
resulted in samples being analysed by techniques with different limits of detection
from those methods used in previous years. This accounts for the differences in these
emissions.

Despite completion of a range of Plant modifications designed to reduce process TiO2


losses to effluent, the Site did not meet its target and further work, including
commissioning of new continuous monitoring equipment, is planned for 2005.
Emissions to Air:

Statutory Compliance:
All discharges from Grimsby Site were in compliance with statutory limits.

The Site achieved 3.2kgSOx/tonne TiO2 for discharges from digestion and
calcination well within the statutory limit of 10kgSOx/tonne TiO2. In fact, this was
the best ever Site performance recorded against this statutory limit.

Grimsby Site - Gaseous SOx Emissions


kgSOx/tonne TiO2

3
5

4
9

0
19

19

19

19

19

20

20

20

20

20
Emissions Inventory:
The total sulphur oxides (SOx) emissions were reduced to their lowest ever level from
Site due to the best ever performance of the Site Sulfacid Plant that cleans off-gases
from pigment calcination.

Nitrogen oxides (NOx) emissions remained constant and particulate emissions fell
slightly due to reduced emissions from ilmenite milling.

Carbon dioxide (CO2) emissions reduced slightly during 2004 (6% overall). Reduced
pigment production meant less fuel was needed at the calcination stage of the process
and therefore less CO2 emissions were generated from Site. In addition, less steam
and electricity was needed from our partner Combined Heat and Power (CHP) Plant
and so the CO2 emissions associated with off-site generation also reduced.

Wastes to Land:

Hazardous waste (Special), non-hazardous waste and recycled waste production


showed large reductions in 2004. This was due to no demolition or site remediation
works being carried out compared with previous years. The overall Site waste
production was therefore more typical of that generated solely from a standard year’s
production operation.

Water Usage:

Total Site water usage fell by 3%. Site process improvements, allowed the potable
water used on Site to be reduced to the lowest ever level recorded. In 2001, the Site
used over 2,000,000 m3 of potable water – in 2004 this was just over 120,000m3 (a
reduction of 94%). In 2005, it is planned to virtually totally eliminate potable water
usage on Site.
Energy Usage:

The benefits of the CHP Plant continued to be realised with the best ever Site
performance of 37.4GJ/tonne TiO2 recorded. This represented a reduction of 24.6% in
unit energy consumption against the 2000 baseline. The objective of reducing unit
energy consumption by 25% by the end of 2005 was therefore realised one year early.
However, the reduction in TiO2 production in single streaming now means that unit
energy consumption will increase and a new baseline must be set during 2005 to
allow realistic objectives to be set for the future.
2004 GRIMSBY ENVIRONMENTAL TARGETS AND OBJECTIVES

OBJECTIVES 2004 TARGETS Performance Comments


1 GASEOUS EMISSIONS
1.1 100% Compliance 1.1.1 100% Compliance ACHIEVED
1.1.2 Review MCERTS requirement for ACHIEVED Site formulating MCERTS strategy with other
Site analytical monitoring & Huntsman facilities. Commitment on MCERTS in
continue training to agreed levels Site IPPC Application.

1.2 Reduce site SOx and NOx 1.2.1 Continue optimisation of ACHIEVED 2004 was the lowest ever emission of SOx in terms
emissions by 70% against 2000 calcination and ilmenite digestion of kgSOx/tonne TiO2 from calcination and
baseline by 2005. scrubbing systems to ensure internal digestion systems (3.2kgSOx/tonne TiO2).
& external gaseous SOx emission
requirements are met.

1.3 Droplet Emissions Elimination. 1.3.1 Continue monitoring potential ACHIEVED Monitoring indicates no potential areas for concern.
droplet fallout sources to ensure
improvements are sustained.

1.4 Reduce particulate/dust 1.4.1 Install and commission new ACHIEVED Equipment installed and commissioned in Q1 2004.
emissions pigment milling equipment in
Finishing Plant.

2 LIQUID EMISSIONS
2.1 100% Compliance 2.1.1 100% Compliance. NOT ACHIEVED Two breaches of suspended solids consent at E&A
West (Killingholme) satellite Site. Overall
compliance was 99.98%.

2.2 Reduce TiO2 losses to drain to 2.2.1 Reduce losses of TiO2 in liquid NOT ACHIEVED TiO2 losses were 3.9%.
<2.0% by 2005. emissions to <2.9% of final packed
pigment
2.2.2 Carry out defined programmes to ACHIEVED Programme carried out but success was limited.
reduce TiO2 losses in Black and
White Sections

2.3 Reduce sulphate discharge by at 2.3.1 Consolidate annual site discharge ACHIEVED Annual performance = 622kgSO4/tonne TiO2
least 25% against 2000 baseline levels at no greater than
by 2005. 625kgSO4/tonne TiO2.
2004 GRIMSBY ENVIRONMENTAL TARGETS AND OBJECTIVES

OBJECTIVES 2004 TARGETS Performance Comments


3 SOLID WASTE AND SITE
RENEWAL
3.1 Control and manage solid waste 3.1.1 100% compliance to all landfill site ACHIEVED PPC Permit Application for Nettleton Bottom
production & disposal licence conditions Quarry submitted on time.
3.1.2 Initiate agreed programme with the ACHIEVED Programme of additional monitoring was initiated
Environment Agency to progress in June 2004. Results to be reviewed in mid-2005.
surrender of Humber Road landfill
site licence.
3.1.3 Increase copperas extraction ratio to ACHIEVED Achieved for period of operation in 2004 but not
1.90 tonnes per tonne calciner sustained due to other operational priorities.
discharge against 2000 baseline of
1.67 helping Site strategy to
minimise red gypsum production.
3.1.4 Review site waste arisings and ACHIEVED Review carried out with Site waste disposal
determine the reduction, recycling contractor.
& disposal options existing after
implementation of the Landfill
Directive.

3.2 Maximise the amount of waste 3.2.1 Ensure at least 40% of general Site NOT ACHIEVED Yearly performance was 30.3% due to a reduction
recycled waste is sent for recycle. in total waste disposals.

3.3 Improve the visual appearance 3.3.1 Carry out trial of Site housekeeping ACHIEVED Housekeeping tours trialled successfully.
and layout of the site tours based on the standards of
acceptable site conditions produced
in 2003.
4 NON-RENEWABLE
RESOURCES
4.1 Continue to reduce unit water 4.1.1 Reduce water usage to no greater NOT ACHIEVED Annual consumption was 97.3m3/tonne TiO2.
3
consumption. than 93m /tonne TiO2 with respect
to budgeted TiO2 production
rate. (Note: 2003 figure was
3
95m /tonne TiO2).
4.2 Reduce unit energy consumption 4.2.1 Consolidate energy consumption at ACHIEVED Annual performance was 37.4GJ/tonne TiO2.
by 25% by 2005 compared to 78% of 2000 baseline with respect
2000 baseline. to budgeted TiO2 production rate
(NOTE:=38.7GJ/tonne TiO2)
4.3 Increase TiO2 efficiency to 4.3.1 Improve the robustness of the TiO2 ACHIEVED New loss/efficiency calculation developed and in
88.4% by 2005. loss/efficiency calculation used in use.
routine plant monitoring.

4.4 Continue to sustain acid recycle 4.4.1 Complete development of ilmenite ACHIEVED Model development completed but of limited use
once all acid is sourced digestion model to help reduce under Site operational conditions.
externally. sulphuric acid use.

4.5 Work with suppliers to achieve 4.5.1 Utilise Project Victoria tracking to ACHIEVED Tracking used to monitor reductions and report
sustainable raw materials highlight reductions in Site raw annual usages.
material usage.
2004 GRIMSBY ENVIRONMENTAL TARGETS AND OBJECTIVES

OBJECTIVES 2004 TARGETS Performance Comments


5 CONTAINMENT
5.1 Sustain zero serious losses 5.1.1 Develop the Site IPPC Application ACHIEVED IPPC Application completed and submitted to meet
(Category C) year on year. to agreed timescale. revised EA deadline of 31st January 2005.

5.1.2 Carry out a review of the Site ACHIEVED New emergency response system and training were
emergency response facilities initiated to meet changed operational set up.
initiating improvements actions
where appropriate.

6 GENERAL
6.1 Increase the scope of the site 6.1.1 Carry out independent audit of ACHIEVED Successful audit carried out in Q1 2005 and E&A
environmental management E&A West (Killingholme) with a West (Killingholme) was added to the scope of Site
system (EMS) view to achieving accreditation to ISO14001 registration.
the environmental management
system, ISO14001, by 2005.
6.1.2 Communicate the progress of the ACHIEVED Internal presentation carried out. Responsible Care
site EMS internally and externally Reports issued to external stakeholders.
during 2004.

6.2 Continue to maintain good high 6.2.1 Carry out, for Grimsby Site, a risk NOT ACHIEVED Awaiting developments from EA and other
profile community relations. assessment of flooding from the Humber Bank industries.
River Humber.
2005 GRIMSBY ENVIRONMENTAL TARGETS AND OBJECTIVES

OBJECTIVES 2005 TARGETS


1 GASEOUS EMISSIONS
1.1 100% Compliance 1.1.1 100% Compliance
1.1.2 Carry out sufficient measurements
of Site gaseous release points to
allow validated emission data to be
obtained for single stream
operation.
1.1.3 Initiate a feasibility study with
atmospheric dispersion modelling
on the environmental impact of
reducing the height of the main
calciner stack.

1.2 Reduce site SOx and NOx No target necessary – objective


emissions by 70% against 2000 achieved.
baseline by 2005.

1.3 Droplet Emissions Elimination. 1.3.1 Continue monitoring potential


droplet fallout sources to ensure
improvements are sustained.

1.4 Reduce particulate/dust 1.4.1 Install access to band drier sampling


emissions points to enable a comprehensive
particulate monitoring regime to be
initiated

2 LIQUID EMISSIONS
2.1 100% Compliance 2.1.1 100% Compliance.
2.1.2 Carry out sufficient measurements
of Site liquid effluent discharge to
allow validated data to be obtained
for single stream operation.

2.2 Reduce TiO2 losses to drain to 2.2.1 Carry out sufficient


<2.0% by 2005. measurements/monitoring to allow
a new baseline for TiO2 losses to be
set for single stream operation.
2.2.2 Install and commission new effluent
continuous monitoring equipment.

2.3 Reduce sulphate discharge by at 2.3.1 No specific target for 2005 –


least 25% against 2000 baseline incorporated in target 2.1.2.
by 2005.
2005 GRIMSBY ENVIRONMENTAL TARGETS AND OBJECTIVES

OBJECTIVES 2005 TARGETS


3 SOLID WASTE AND SITE
RENEWAL
3.1 Control and manage solid waste 3.1.1 100% compliance to all landfill site
production & disposal licence conditions
3.1.2 Continue programme agreed with
the Environment Agency to
progress surrender of Humber Road
landfill site licence.
3.1.3 Review the location of all
Hazardous (Special) Waste skips on
site to ensure that they are located
on hardstanding.

3.2 Maximise the amount of waste 3.2.1 Install and commission agreed
recycled projects at reduction stage of the
process and review their impact on
solid waste generation.

3.3 Improve the visual appearance 3.3.1 Prepare a preliminary Site


and layout of the site decommissioning plan that meets
IPPC requirements.
3.3.2 Initiate a series of housekeeping
initiatives to improve Site
appearance.
4 NON-RENEWABLE
RESOURCES
4.1 Continue to reduce unit water 4.1.1 Carry out sufficient measurements
consumption. and monitoring to allow a new
baseline for water consumption to
be set for single stream operation.
4.2 Reduce unit energy consumption 4.2.1 Carry out sufficient measurements
by 25% by 2005 compared to and monitoring to allow a new
2000 baseline. baseline for energy consumption to
be set for single stream operation.
4.3 Increase TiO2 efficiency to No specific target set for 2005–
88.4% by 2005. incorporated in targets 2.2.1 and
2.2.2.
4.4 Continue to sustain acid recycle No specific target set for 2005.
once all acid is sourced
externally.
4.5 Work with suppliers to achieve 4.5.1 Carry out sufficient monitoring to
sustainable raw materials allow a new baseline for raw
materials consumption to be set for
single stream operation.
2005 GRIMSBY ENVIRONMENTAL TARGETS AND OBJECTIVES

OBJECTIVES 2005 TARGETS


5 CONTAINMENT
5.1 Sustain zero serious losses 5.1.2 Implement and review new
(Category C) year on year. emergency response facilities to
reflect single stream operation.

6 GENERAL
6.1 Increase the scope of the site 6.1.1 Review and update the Site
environmental management environmental management system
system (EMS) such that it is compliant to the
revised ISO14001:2004.
6.1.2 Review all Site manual laboratory
methods to ensure they are traceable
to standard reference methods.
6.2 Continue to maintain good high No specific target set for 2005
profile community relations.
Grimsby Site Waste Emissions (c)
2000 2001 2002 2003 2004 % Change
(tonnes) (tonnes) (tonnes) (tonnes) (tonnes) on 2003
Discharges to Water (tonnes)
H2SO4 10770 8070 10380 11070 9200 -17
Fe 11085 7740 8340 8840 8440 -5
Solids 2310 1640 3630 3100 2650 -15
Ti 360 290 370 430 320 -26
Mn 540 380 420 470 420 -11
V 19 14 12 17 17 Nil
Zn 15.9 9.3 11.1 14.1 10.8 -23
Cr 6.9 5.7 4.8 5.0 4.6 -8
Pb 0.58 0.53 0.57 0.58 0.59 +2
Cu 1.4 1.2 1.2 1.5 1.0 -33
Ni 1.8 0.6 0.8 1.0 0.9 -10
As 0.09 0.04 0.05 0.03 0.045 +50
Cd 0.027 0.013 0.025 0.019 0.022 +16
Hg (d) 0.0006 0.0007 0.0017 0.0008 0.0028 +250

Emissions to Air (tonnes)


SOx 2430 1810 290 270 230 -15
Particulates 160 120 40 40 35 -13
NOx 370 280 30 20 20 Nil
HCl 0.9 2.0 0.008 0.1 0.025 -75
CO 54 35 3 4 11 +175
CO2 (from off-site generation) (e) 25600 47200 121100 106150 97490 -8
CO2 (from fuel) (e) 150800 112800 47600 46160 43300 -6
CO2 (from Gypsum Plant) (f) 49900 43200 48800 44270 43780 -1

Wastes to Land (tonnes)


Gypsum 96500 85910 50140 45150 54860 +22
Neutralised Digester Residue 22440 19500 21270 21540 22310 +4
Misc. Industrial Wastes 9880 3780 3340 2300 930 -60
Misc. Hazardous Wastes (a) 573 508 450 750 130 -83
Recycled /Recovered/Reused Waste 2600 1140 1700 2785 380 -86
Mixed lime (b) N/A N/A 1800 2450 N/A N/A

Energy Usage
(TJ)(1) 2730 2270 2470 2370 2180 -8
(1) 1TJ=1 x 1012 Joules or approximately 278,000 Kilowatt-Hours, Energy use calculated by converting total site energy consumption in Kilowatt-Hours (for electricity and fuel usage) to
TJ by appropriate conversion factors.
(a) Special waste including asbestos, solvents, oils and greases. (b) Mixed lime sent for spreading on land to improve soils. (c) Data for 1995 to 1999 are available in the 1999 Grimsby
Site Environment Report. (d) Mercury emissions calculated from external laboratory analyses that have differing limits of detection than Huntsman Tioxide methods. (e) Calculated using
new factors proposed by the Chemical Industries Association for current Climate Change Levy reporting. (f) Data for 2003 and 2004 calculated using more reliable process data on chalk
consumption.
Huntsman Tioxide is committed to continually improving its
Environmental, Health and Safety Performance.

You can offer your feedback or make further enquiries by contacting:

Maureen Gates
Environmental and Process Manager
Huntsman Tioxide
Moody Lane
Grimsby
North East Lincolnshire
DN31 2SW

Telephone: (01472) 264246


E-Mail: maureen_gates@huntsman.com

Further details of other Huntsman Tioxide manufacturing locations can be found on


our internet site:
www.huntsman.com/tioxide

This Statement has been validated by DNV Certification Limited which is accredited
by the United Kingdom Accreditation Service (Ref. No. UK-V-004) 11th May 2005.