Saint-Gobain Performance Plastics Ireland

Transcription

1 Saint-Gobain Performance Plastics Ireland ANNUAL ENVIRONMENTAL REPORT 2011 Issued March 2012 IPPC LICENSE No. P

2 CONTENTS PAGE 1. Introduction 5 2. Site Details 6 3. Policy Statement 7 4. Organisational Structure 8 5. Emissions to Atmosphere (PSA 6) Trend Analysis Other Emission to Atmosphere Summary of Non-Compliances Emissions to Sewer (F6) Trend Analysis Summary of Non-Compliances Emissions to Surface Water (MH4) Surface Water Checks Summary of Non-Compliances Waste Waste Analysis EPA Monitoring Agency Monitoring and Enforcement Agency Site Audit Non-Compliances Energy Consumption Water Consumption PRTR Noise Noise Report Summary Environmental Incidents & Complaints Environmental Incidents Environmental Complaints Electronic AER 25 IPPC LICENSE No. P

3 16. Environmental Planning Review of 2011 Objectives and Targets Environmental Objectives and Targets For IPPC LICENSE No. P

4 List of Tables Table 1 Table 2 Table 3 Table 4 Table 5 Table 6 Table 7 Table 8 Table 9 Table 10 Table 11 Table 12 Table 13 Table 14 Table 15 Table 16 Air Emissions Summary Other Emissions to Atmosphere Monthly Particulate Results Summary of Air Emissions Non-Compliances Effluent Emissions Summary Summary of Effluent Emissions Non-Compliances Surface Water Emissions Summary Monthly Surface Water Checks Annual Special Waste Summary Hazardous Waste Details Non-Hazardous Waste Details Summary of Audit Findings Energy Consumption Summary PRTR Table Summary of Environmental Incidents Summary of Environmental Complaints List of Figures Figure 1 Figure 2 Figure 3 Figure 4 Figure 5 Figure 6 Figure 7 Figure 8 Figure 9 Figure 10 Figure 11 Figure 12 Figure 13 Air Emissions TOC Concentrations Air Emissions Monthly Mass Flow Air Emissions Monthly Volume Flow Fugitive Emission Trend Monthly Effluent Data Weekly COD Results Monthly BOD Results Weekly OFG Results Annual Special Waste Trend Hazardous Waste Production Ratio Non Hazardous Waste Production Ratio Energy / Production Ratio Annual Water Consumption List of Appendices Appendix I Appendix II ISO14001 Certificate 2011 Noise Survey IPPC LICENSE No. P

5 1. INTRODUCTION License Register Number: P Name & Location of site: Saint-Gobain Performance Plastics Ireland, Kilrush, Co. Clare. Director of Operations: John Costelloe Environmental contact person: Edward Cooke Location of activity: Saint-Gobain Performance Plastics Ireland Ltd., Kilrush, Co. Clare National Grid Reference: 0998E: 1557N Contact Phone Number Contact Fax Number Number of employees: 70 IPPC LICENSE No. P

6 2. SITE DETAILS Saint-Gobain Performance Plastics Ireland was granted a revised Integrated Pollution Prevention & Control (IPPC) license in November This license grants Saint-Gobain Performance Plastics permission to carry out the following activities: Class :- the use of coating materials in processes with the capacity to use at least 10 tonnes per year of organic solvents, not included in Class This IPPC License (Reg. No. P ) supersedes the installations previous license (Reg. No. P ), which had been issued in Saint-Gobain Performance Plastics Ireland manufactures a variety of Teflon or PTFE (Polytetraflouroethylene) coated and laminated fabrics which are used in the food processing, electronics and packaging industries. Main units, main products: Saint-Gobain Performance Plastics Ireland manufacture a variety of PTFE coated and laminated fabrics. This process is based on aqueous PTFE dispersions. The substrates used are either woven fibre-glass or Kevlar. On some of our products we apply a pressure sensitive adhesive. We also produce some silicone coated fabrics. The adhesive processes are currently based on organic solvent. The plant can be divided into four zones: - PTFE coating - Inspection / Warehouse - Adhesive + Rubber coating - Office and Q.A. Laboratory IPPC LICENSE No. P

7 3. POLICY STATEMENT Saint-Gobain Performance Plastics Ireland ENVIRONMENTAL POLICY STATEMENT Saint-Gobain Performance Plastics Ireland located in Kilrush Co. Clare manufactures a broad range of high performance polymer-based, reinforced and un-reinforced fluoroplastics, fluoroelastomers, silicone elastomers and adhesives. The Company s products include laminates, films, coated fabrics, and tapes. It is the policy of Saint-Gobain Performance Plastics Ireland to operate an Environmental Management System which not only meets all Corporate, E.P.A, Legal and Legislative requirements but also strives to continuously improve to the benefit of our environment, local community, neighbours and employees. We will achieve this by: Complying with all relevant environmental laws and regulations. Identifying our environmental aspects and associated impacts and instituting appropriate programs for the prevention of pollution and conservation of natural resources associated with our processes. Monitoring and measuring our key Environmental Performance Indicators. Consistent review and re-evaluation of our set Objectives and Targets designed to minimize our impacts. Communicate our Policy and provide appropriate training to all our employees. Communicate with our customers, suppliers and contractors to promote sound environmental practice in the selection, use and disposal of all materials used in the company s business. Make our environmental policy and records available to the public and interested parties. The company has procedures and resources in place to plan, implement, monitor and review this policy. This review shall take place annually. Whilst all employees have a duty to ensure that our operations do not cause environmental pollution, the overall responsibility for environmental protection lies with the Director of Operations. Director of Operations SGPPL Ireland IPPC LICENSE No. P

8 ORGANIZATIONAL CHART 04TH JANUARY 2012 General Manager Coated Fabrics Business Manager Europe Coated Fabrics Marketing Manager Coated Fabrics Europe, Middle East & Africa European Director of Operations European Financial Controller European Customer Service Manger H.R & Safety Manger I.T Manager Manufacturing & Logistics Manger Facilities Manager Quality & Technology Manager Financial Controller Customer Service Representatives Product Manager Coated Fabrics & Laminates Admin. Reception Catering Personnel Shift 1 Supervisor Shift 3 Supervisor Shift 2 Supervisor Planning & Fulfillment Manger Fulfillment Operators Purchasing Co-Ordinator Materials & Logistics Co- Coordinator Maintenance Personnel Process Engineers Formulation Quality Engineer QA Lab Production Operators Cost Accounts Manger Accounts Staff Page 1 IPPC LICENSE No. P

9 5. EMISSIONS TO ATMOSPHERE (PSA 6) Solvent emissions are the major emission sources on the site. Depending on the parameter, monitoring varies from continuous on-line monitors, to monthly analyses as specified in Schedule C.1.1 (Control of Emissions to Air) of the IPPC license. Total Organic Carbon (TOC) emissions were monitored monthly in 2011 in accordance with the requirements of the IPPC license. All results were within compliance and a summary of the results obtained is outlined in Table 1 below. The results of the air emissions monitoring demonstrated compliance with the IPPC License limits. PSA6 Mean Concentration (mg/nm3) License Limit Mass Emission License Limit (mg/nm3) 2011 (Kgs/Yr) (Kgs/Yr) Volume Flow 876 Nm 3 /hr 4500 Nm 3 /hr 3,784,320 19,440,000 TOC Removal Eff 97.47% Table TREND ANALYSIS Figure 1 IPPC LICENSE No. P

10 Figure 2 Figure 3 IPPC LICENSE No. P

11 5.2 OTHER EMISSIONS TO ATMOSPHERE Air Emissions Calculation for 2011 CO 2 Emissions from solvent sources burnt in the Thermal Oxidiser Source Annual CO 2 T.O. Estimated SOx Estimated Nox Estimated Kg convert efficiency Tonne, CO 2 convert Tonne SOx convert Tonne NOx burnt factor % emitted factor emitted factor emitted Xylene % N/A N/A Toluene % N/A N/A Ethyl Benzene % 3.93 N/A N/A Ethyl Acetate % 1.94 N/A N/A LPG Propane gas 927 2, Tonnes Tonnes Tonnes CO 2 SOx NOx TOTAL Emissions 2, Table 2 Figure 4 IPPC LICENSE No. P

12 5.3 SUMMARY OF NON-CONFORMANCES None 6. EMISSIONS TO SEWER (F6) Emissions to sewer are monitored on a weekly basis, the results of the analysis and the annual quantities emitted to sewer are outlined in Table 5 below. The emissions to sewer data indicate compliance with the IPPC emission limit values. There were non-compliances in relation to OFG during 2011 and these are outlined in Section 6.2. F6 Mean Concentration (mg/l) License Limit (mg/l) Mass Emission 2010 (Kgs/Yr) License Limit (Kgs/Yr) Volume (m 3 ) BOD COD OFG Table TREND ANALYSIS Figure 5 IPPC LICENSE No. P

13 Figure 6 Figure 7 IPPC LICENSE No. P

14 6.2 SUMMARY OF NON-CONFORMANCES Date Non-Compliance Cause Corrective Action January February March April May June July August September November December OFG concentration exceeded emission limit value in effluent. The clean-out of the emission line sludge tanks was not carried to the required frequency resulting in a build-up of sludge at end of year. Table 6 Clean out sludge tanks and test OFG weekly. All results at start of 2012 remaining within EVL. Implement formal sludge clean out schedule and include as part of ISO14001 surveillance audits. Figure 8 IPPC LICENSE No. P

15 7 EMISSIONS TO SURFACE WATER (MH4) Monitoring of surface water run-off from the site is undertaken at one discharge location referred to as MH4. Monitoring results are summarised in Table 7 as the average value for the monitoring period. MH4 Mean Concentration 2011 Mass Emission 2011 COD 10.5 mg/l 8.3 Kgs/Yr Conductivity 305 us/cm - ph Table SURFACE WATER CHECKS Month Colour Odour January Ok Ok February Ok Ok March Ok Ok April Ok Ok May Ok Ok June Ok Ok July Ok Ok August Ok Ok September Ok Ok October Ok Ok November Ok Ok December Ok Ok Table SUMMARY OF SURFACE WATER NON-COMPLIANCES None IPPC LICENSE No. P

16 8. WASTE The waste data outlined in Tables 10 and 11 below represents all waste arisings for the AER reporting period. All off-site recovery and disposal routes used are approved with the Agency in accordance with Condition 8 of the IPPC licence. 8.1 WASTE ANALYSIS Figure 9 IPPC LICENSE No. P

17 Haz / Non-Haz Hazardous Waste ,640 20,310 13,734 19, Caustic / Triton neutralisation , Total Waste (Kgs) 23,708 47,040 49,370 30,554 27,183 20,121 Table 9 EWC Hazardous Waste Description Weight Method of disposal / Name of Waste Disposal Disposal / Recovery Site (Kgs) Recovery Recovery Contractor * Yes Medium Viscosity Adhesive waste 463 R3 - Recycling Nehlsen GmbH & Co. Indaver Ireland Ltd, W * Yes PTFE Sludge 1026 R12 - Exchange ATM B.V Indaver Ireland Ltd, W * Yes Absorbent Pads with xylene, adhesive, rubber 3137 D9 - Chemical Treatment Nehlsen GmbH & Co. Indaver Ireland Ltd, W * Yes Xylene / Aqueous / BPO 648 D10 - Incineration AVG GmbH Indaver Ireland Ltd, W * Yes Caustic Solution 8100 D9 - Chemical Treatment On Site - ENVA Enva Ireland Ltd, W * Yes PTFE Sludge 3252 R12 - Exchange ATM B.V Indaver Ireland Ltd, W * Yes Xylene / Aqueous / BPO 305 D10 - Incineration AVG GmbH Indaver Ireland Ltd, W * Yes Solvent Washings 536 D10 - Incineration AVG GmbH Indaver Ireland Ltd, W * Yes Absorbent Pads with xylene, adhesive, rubber 2429 D9 - Chemical Treatment Nehlsen GmbH & Co. Indaver Ireland Ltd, W * Yes Medium Viscosity Adhesive waste 151 R3 - Recycling Nehlsen GmbH & Co. Indaver Ireland Ltd, W * Yes Carbon Black - PTFE 74 R12 - Exchange ATM B.V Indaver Ireland Ltd, W TOTAL HAZARDOUS WASTE (Kgs) HAZARDOUS WASTE GENERATION Table 10 IPPC LICENSE No. P

18 WASTE TYPES 2011 Internal Recycled Waste Quantity Tonne Non hazardous but not inert Inert only Recover Heat Recovery Recycle Re-use Recycled timber boxes No No No No No Yes Recycled cardboard No No No No No Yes Clean Ireland Recycling NON- HAZARDOUS WASTE GENERATION General Waste (Packer) Inert (2/3) No Yes No No No No Non-Hazardous Yes Yes No No No No Mixed Waste Yes No No No No No Composite Waste No No Yes Yes No No Timber No No No No Yes No Cardboard No No Yes No Yes No Dry recyclables No No Yes No Yes No Steel (including empty drums) No No Yes No Yes No TOTAL Table 11 IPPC LICENSE No. P

19 Figure 10 Figure 11 IPPC LICENSE No. P

20 9. EPA MONITORING 9.1 AGENCY MONITORING & ENFORCEMENT Annual Environmental Report 2011 The EPA carried out monitoring tests on PSA6 once and F6 & MH4 twice during PSA6 (Air emissions) within EVL Compliant MH4 (Surface water) within EVL Compliant F6 (Sewer) within EVL Compliant 9.2 AGENCY SITE AUDIT NON-COMPLIANCES Date Non-Compliance Cause Corrective Action 21/04/2011 Waste records in AER apply non-hazardous waste with EWC of hazardous wastes 21/04/2011 Agency continue to receive periodic odour complaints 21/04/2011 On-going breech of OFG levels in F6 21/04/2011 Old samples and chemicals stored in Remote Storage Unit. 21/04/2011 Complaint records did not include date of closing an action Some items are being disposed of as hazardous waste as a precaution Nuisance odour from standard processing conditions during unfavorable weather conditions The clean-out of the emission line sludge tanks was not carried to the required frequency resulting in a build-up of sludge at end of year. Costs and difficulty of proper disposal resulted in a build-up of one-off samples Over 90% of complaints are in relation to odour and this is an on-going issue Table 12 Summary of Agency Audit Non-Compliances Wastes updated to reflect accurately the wastes generated Satisfactorily implement the odour abatement programme Implement formal sludge clean out schedule and include as part of ISO14001 surveillance audits. Some samples have been disposed of. Contacted waste contractor to find suitable method of disposing lab smalls. Complaints log updated to ensure the closing date of an action is included IPPC LICENSE No. P

21 10. ENERGY CONSUMPTION Summary energy data from 2008 to Units MW/hr MW/hr MW/hr MW/hr Electricity LPG Total Energy/Production Ratio Table 13 The graph in figure 12 below details the effect of the energy reduction programmes. Energy consumption is higher due to slowing of production due to odour and product mix. Figure 12 IPPC LICENSE No. P

22 11. WATER CONSUMPTION Annual Environmental Report 2011 Figure POLLUTION EMISSIONS REGISTER 2011 MOM Method of Measurement This refers to the method used in determining losses to Air, Water and Land. The following codes are to be used to demonstrate the method used: Method Direct Measurement Engineering Estimates Code M E IPPC LICENSE No. P

23 Pollution Emission Register 2011 List of solvent containing chemicals used in Jan to 31-Dec 2011 Item No. ] Kg/year Solvent CAS No. ] MOM i 2010 Opening balance (Dry Kg) M 1, Purchases (Dry Kg) M 14,413 5, Returns or Shipments out (Dry Kg) M Closing Balance (Dry Kg) M 1, units Lit Dry Kg Dry Kg Dry Kg Dry Kg Dry Kg Dry Kg Usage M 14,833 6, ,870 Density or conversion to gross Dry Kg E Nett Usage (Dry Kg) M 13,053 6, ,870 41,993 % Solids E % Solvent E Gross Usage (Wet Kg) 13,053 14, , ,945 68,320 % Xylene E 100% 45% 45% 40% 11% New Xylene usage in 2009 (Kg) M Recycled Xylene used M Total Xylene usage M Xylene in product E Xylene Treated (in own Thermal. Oxidiser) M Xylene sent out for recovery (inc heat recovery) M 0 0 Xylene in Haz Waste E 2539 Xylene in effluent M 0 0 Fugitive emissions (not throught Th.Ox) M Xylene remaining after TH Oxidiser treatment E Unaccounted E 0 IGEE INEE % Toluene E 7% 15% 28% New Toluene usage in 2009 (Kg) M , ,011 Recycled Toluene used M Total Toluene usage M Toluene in product E - Toluene Treated (in own Thermal. Oxidiser) M 6159 Toluene sent out for recovery (inc heat recovery) M - Toluene in Waste E 205 Toluene in effluent M - Fugitive emissions (not throught Th.Ox) M 4626 Toluene remaining after TH Oxidiser treatment E Unaccounted E - IGEE INEE % Ethyl Acetate E 45% New Ethyl acetate usage in 2009 (Kg) M 1, ,068 Recycled Ethyl acetate used M 0 - Total Ethyl acetate usage M 1, ,068 Ethyl acetate in product E - Ethyl acetate Treated (in own Thermal. Oxidiser) M 1000 Ethyl acetate sent out for recovery (inc heat recovery) M - Ethyl acetate in Waste E 22 Ethyl acetate in effluent M - Fugitive emissions (not throught Th.Ox) M 44 Ethyl Acetate remaining after TH Oxidiser treatment E Unaccounted E - IGEE INEE % Ethyl Benzene E 7% 7% 11% 3% New Ethyl Benzene usage in 2009 (Kg) M , ,159 Recycled Ethyl Benzene used M Total Ethyl Benzene usage M , ,159 Ethyl Benzene in product E 0 - Ethyl Benzene Treated (in own Thermal. Oxidiser) M 1,217 Ethyl Benzene sent out for recovery (inc heat recovery M 0 - Ethyl Benzene in Waste E 54 Ethyl Benzene in effluent M 0 - Fugitive emissions (not throught Th.Ox) M Ethyl Benzene remaining after TH Oxidiser treatment E Unaccounted E - IGEE INEE Table 14 IPPC LICENSE No. P

24 13. NOISE 13.1 NOISE REPORT SUMMARY 2011 report attached in appendix II 14. ENVIRONMENTAL INCIDENTS & COMPLAINTS 14.1 ENVIRONMENTAL INCIDENTS Date Non-Compliance Cause Corrective Action January February March April May June July August September November December OFG concentration exceeded emission limit value in effluent ENVIRONMENTAL COMPLAINTS The clean-out of the emission line sludge tanks was not carried to the required frequency resulting in a build-up of sludge at end of year. Table 15 Implement formal sludge clean out schedule and include as part of ISO14001 surveillance audits. Date Non-Compliance Cause Corrective Action 12-Apr-11 Odour from plant particularly during the morning and evening causing a dryness in the throat. Nuisance odour from standard processing conditions during unfavorable weather conditions As per EMP #1 in section Apr Aug-11 Fumes from Plant at Shannon Doc Facility at 8pm. Odour detected from plant near woods on Kilimer road Nuisance odour from standard processing conditions during unfavorable weather conditions Nuisance odour from standard processing conditions during unfavorable weather conditions Table 16 As per EMP #1 in section 16.1 As per EMP #1 in section 16.1 IPPC LICENSE No. P

25 15 ELECTRONIC AER PRTR# : P0096 Facility Name : Saint-Gobain Performance Plastics Ireland Filename : P0096_ Rev 0.xls Return Year : 2011 REFERENCE YEAR 2011 Guidance to completing the PRTR workbook AER Returns Workbook 1. FACILITY IDENTIFICATION Parent Company Name Saint-Gobain Performance Plastics Ireland Facility Name Saint-Gobain Performance Plastics Ireland PRTR Identification Number P0096 Licence Number P Version Waste or IPPC Classes of Activity No. class_name The manufacture or use of coating materials in processes with a capacity to make or use at least 10 tonnes per year of organic solvents, and powder coating manufacture with a capacity to produce at least 50 tonnes per year, not included in paragraph Address 1 Kilrush Address 2 County Clare Address 3 Address 4 Clare Country Ireland Coordinates of Location River Basin District IEGBNISH NACE Code 2016 Main Economic Activity Manufacture of plastics in primary forms AER Returns Contact Name Eddie Cooke AER Returns Contact Address edward.cooke@saint-gobain.com AER Returns Contact Position Quality & Technology Manager AER Returns Contact Telephone Number AER Returns Contact Mobile Phone Number AER Returns Contact Fax Number Production Volume 0.0 Production Volume Units Number of Installations 0 Number of Operating Hours in Year 0 Number of Employees 70 User Feedback/Comments Web Address 2. PRTR CLASS ACTIVITIES Activity Number Activity Name 50.1 General 3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002) Is it applicable? Yes Have you been granted an exemption? No If applicable which activity class applies (as per Schedule 2 of the regulations)? 16. Adhesive Coating Is the reduction scheme compliance route being used? No IPPC LICENSE No. P

26 4.1 RELEASES TO AIR Link to previous years emissions data PRTR# : P0096 Facility Name : Saint-Gobain Performance Plastics Ireland Filename : P0096_ Rev 0.xls Return Year : /03/ : SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS RELEASES TO AIR Please enter all quantities in this section in KGs POLLUTANT METHOD ADD EMISSION POINT QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year ADD NEW ROW DELETE ROW * * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION B : REMAINING PRTR POLLUTANTS RELEASES TO AIR Please enter all quantities in this section in KGs POLLUTANT METHOD ADD EMISSION POINT QUANTITY Method Used All Emission Points No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year From propane/solvent 03 Carbon dioxide (CO2) C MAB consumption Sulphur oxides (SOx/SO2) C MAB From propane/solvent consumption Nitrogen oxides (NOx/NO2) C MAB From propane/solvent consumption ADD NEW ROW DELETE ROW * * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION C : REMAINING POLLUTANT EMISSIONS (As required in your Licence) RELEASES TO AIR Please enter all quantities in this section in KGs POLLUTANT METHOD ADD EMISSION POINT QUANTITY Method Used PSA 6 Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year 351 Total Organic Carbon (as C) M ALT EN 13526: ADD NEW ROW DELETE ROW * * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button Additional Data Requested from Landfill operators For the purposes of the National Inventory on Greenhouse Gases, landfill operators are requested to provide summary data on landfill gas (Methane) flared or utilised on their facilities to accompany the figures for total methane generated. Operators should only report their Net methane (CH4) emission to the environment under T(total) KG/yr for Section A: Sector specific PRTR pollutants above. Please complete the table below : Landfill: Please enter summary data on the quantities of methane flared and / or utilised Saint-Gobain Performance Plastics Ireland Method Used Designation or Description Facility Total Capacity m3 per hour additional_pollutant_no T (Total) kg/year M/C/E Method Code Total estimated methane generation (as per site model) 0.0 N/A Methane flared (Total Flaring Capacity) Methane utilised in engine/s (Total Utilising Capacity) Net methane emission (as reported in Section A above) 0.0 N/A IPPC LICENSE No. P

27 4.2 RELEASES TO WATERS Link to previous years emissions data PRTR# : P0096 Facility Name : Saint-Gobain Performance Plastics Ireland Filename : P0096_ Rev 0.xls Return Year : /03/ : SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS Data on ambient monitoring of storm/surface water or groundwater, conducted as part of your licence requirements, should NOT be submitted under AER / PRTR RELEASES TO WATERS Please enter all quantities in this section in KGs POLLUTANT ADD EMISSION POINT QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year ADD NEW ROW DELETE ROW * * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION B : REMAINING PRTR POLLUTANTS RELEASES TO WATERS Please enter all quantities in this section in KGs POLLUTANT ADD EMISSION POINT QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year ADD NEW ROW DELETE ROW * * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION C : REMAINING POLLUTANT EMISSIONS (as required in your Licence) RELEASES TO WATERS Please enter all quantities in this section in KGs POLLUTANT ADD EMISSION POINT QUANTITY Method Used MH4 Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year Standard Method (Bord Na 306 COD M ALT Mona D) ADD NEW ROW DELETE ROW * * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button IPPC LICENSE No. P

28 4.3 RELEASES TO WASTEWATER OR SEWER Link to previous years emissions data PRTR# : P0096 Facility Name : Saint-Gobain Performance Plastics Ireland Filename : P0096_2 29/03/ : SECTION A : PRTR POLLUTANTS OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER Please enter all quantities in this section in KGs POLLUTANT METHOD ADD EMISSION POINT QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year ADD NEW ROW DELETE ROW * * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence) OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER Please enter all quantities in this section in KGs POLLUTANT METHOD ADD EMISSION POINT QUANTITY Method Used F6 Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year Standard Method (Bord Na 303 BOD M ALT Mona B) COD M ALT Standard Method (Bord Na Mona D) Fats, Oils and Greases M ALT ET 083 Based on APHA 5520 D ADD NEW ROW DELETE ROW * * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button IPPC LICENSE No. P

29 4.4 RELEASES TO LAND Link to previous years emissions data PRTR# : P0096 Facility Name : Saint-Gobain Performance Plastics Ireland Filename : P0096_ Rev 0.xls Return Year : /03/ : SECTION A : PRTR POLLUTANTS RELEASES TO LAND Please enter all quantities in this section in KGs POLLUTANT METHOD ADD EMISSION POINT QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year ADD NEW ROW DELETE ROW * * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence) RELEASES TO LAND Please enter all quantities in this section in KGs POLLUTANT METHOD ADD EMISSION POINT QUANTITY Method Used Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year ADD NEW ROW DELETE ROW * * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button IPPC LICENSE No. P

30 5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE PRTR# : P0096 Facility Name : Saint-Gobain Performance Plastics Ireland Filename : P0096_ Rev 0.xls Return Year : /03/ : Please enter all quantities on this sheet in Tonnes 3 Quantity (Tonnes per Year) Method Used Haz Waste : Name and Licence/Permit No of Next Destination Facility Non Haz Waste: Name and Licence/Permit No of Recover/Disposer Haz Waste : Address of Next Destination Facility Non Haz Waste: Address of Recover/Disposer Name and License / Permit No. and Address of Final Recoverer / Disposer (HAZARDOUS WASTE ONLY) Actual Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY) Transfer Destination European Waste Code Hazardous Description of Waste Waste Treatment Operation M/C/E Method Used Location of Treatment aqueous sludges containing adhesives or sealants containing organic solvents or To Other Countries Yes other dangerous substances R12 M Weighed Abroad Indaver Ireland,W ,Tolka Quay Road,Dublin,.,Ireland Afvalstoffen Terminal Moerdijk B.V,BVG- 010/2,.,Vlasweg 12,4782 PW,Moerdijk,Germany.,Vlasweg 12,4782 PW,Moerdijk,Germany To Other Countries Yes waste adhesives and sealants containing organic solvents or other dangerous substances R3 M Weighed Abroad Indaver Ireland,W To Other Countries Yes other solvents and solvent mixtures D10 M Volume Calculation Abroad Indaver Ireland,W ,Tolka Quay Road,Dublin,.,Ireland.,Tolka Quay Road,Dublin,.,Ireland Nehlsen GmbH & Co. K G,A- 4187/02 HH,.,Louis-Krages.,Louis-Krages Strabe Strabe 10,Bremen,D- 10,Bremen,D ,Germany 28237,Germany AVG Abfall-Verwertungs GmbH,110ZEB002,.,Borsigs tr..,borsigstr. 2,Hamburg,D22113,German 2,Hamburg,D22113,German y y To Other Countries Yes absorbents, filter materials (including oil filters not otherwise specified), wiping cloths, protective clothing contaminated by dangerous substances D9 M Weighed Abroad Indaver Ireland,W Within the Country Yes 8.1 sodium and potassium hydroxide D9 M Volume Calculation Offsite in Ireland Enva Ireland Ltd,W Clean Ireland Recycling,WCP-LK Within the Country No mixed municipal waste D1 M Weighed Offsite in Ireland 01.,Tolka Quay Road,Dublin,.,Ireland.,Smithstown Industrial Estate,Shannon,Co. Clare,Ireland Ballinagun,Cree Kilrush,Clare,.,Ireland Clean Ireland Within the Country No 7.72 paper and cardboard R13 M Weighed Offsite in Ireland Recycling,WCP-LK Ballinagun,Cree Kilrush,Clare,.,Ireland Clean Ireland Recycling,WCP-LK Ballinagun,Cree Within the Country No 4.7 wood other than that mentioned in R13 M Weighed Offsite in Ireland 01 Kilrush,Clare,.,Ireland Clean Ireland Recycling,WCP-LK Ballinagun,Cree Within the Country No 6.0 metals R13 M Weighed Offsite in Ireland 01 Kilrush,Clare,.,Ireland ADD NEW ROW DELETE ROW * * Select a row by double-clicking the Description of Waste then click the delete button Nehlsen GmbH & Co. K G,A- 4187/02 HH,.,Louis-Krages.,Louis-Krages Strabe Strabe 10,Bremen,D- 10,Bremen,D ,Germany 28237,Germany Enva Ireland Ltd,W ,.,Smithstown Industrial Estate,Shannon,Co. Clare,Ireland.,Smithstown Industrial Estate,Shannon,Co. Clare,Ireland IPPC LICENSE No. P

31 16. ENVIRONMENTAL PLANNING 16.1 REVIEW OF OBJECTIVES & TARGETS 2011 Annual Environmental Report 2011 Program No. 1 Program Goal Eliminate Odour Complaints EPI Maintain odour levels below 1.5 OUe/m3 Target Achieve limit within two years Responsibility of E Cooke Review Cycle At Monthly EHS Meeting Environmental Consultants AWN were requested to prepare a Front End Study focusing on possible odour abatement technology, with a view to selecting the most appropriate technology to deal with the odours in the air emissions from the site. The outcome of that study was that the AEROX Abatement technology, which relies on rapid oxidation of odourous compounds through a combination of ozone and free radicals, was selected for pilot plant trial at St Gobain Kilrush. The AEROX technology has a number of advantages with respect to the unique characteristics of the St Gobain Odour Emissions: The exhaust stacks in St Gobain over time develop an internal coating of sticky organic material, which requires regular cleaning this material will over time tend to block or coat any filtration system. The AEROX technology does not require the exhaust gasses to pass over or through a filtration or oxidation cell, instead the AEROX technology generates an ozone and free radical rich stream and this is blown into a mixing cell within the exhaust duct, so avoiding the risk of filter blocking or coating. The AEROX technology is therefore one of the few technologies that we have found appropriate for dealing with these kind of emissions. The odours at St Gobain vary in nature, depending on the stage of the process being run, with some smoke and burnt cloth type smells being generated during the early stages of a process run, and a more burnt plastic/acrid type smell being generated later in the process therefore the abatement process needs to be able to treat an odour source with varying characteristics and concentrations consistently. The AEROX system is able to achieve this by generating an excess of ozone and free radicals to ensure all odourous material is oxidised. The AEROX unit is relatively small in footprint and relatively light, so it can be roof mounted. The particular nature of the St Gobain process is such that there can be no deviation from current back pressures within the ducting system above the application process within the overall system, and therefore ducting the exhaust air to a stand-alone treatment plant on the ground is not a possibility, as this would introduce significant backpressures in the system, which would in turn affect product quality, which is not acceptable, IPPC LICENSE No. P

32 in order for the St Gobain site to continue to thrive, employ people and generate income for the town of Kilrush, it need to maintain the excellent quality standards and reputation it has built up over many decades in operation. Therefore, a system that generates the minimum back-pressure and requires the minimum alterations to the ducting system is essential. The AEROX system meets these criteria. The nature of odour complaints at St Gobain is such that for the vast majority of the year, no complaints are received, and generally no more than 3 odour complaints have been received annually over the last 3 years. The incidence of odour complaints occurring is a combination of particular weather effects and when particular processes may be operating at the site. St Gobain has made great efforts to minimise the risk of odour complaints by changing production schedules where commercial factors allow, to ensure specific emission scenarios and weather criteria do not combine to generate complaints. While this has a cost implication for the operational efficiency of the St Gobain Kilrush site, it has continued to operate in this manner in recent years, to minimise the risk of odour impacts occurring. Therefore, it is only occasionally that odour abatement technology is actually required at the St Gobain Kilrush site, and it therefore is important that the capital cost is addressed such that significant capital is not invested in abatement equipment that is not used more than a small number of occasions each year. The nature of the infrequent occurrence of odour complaint scenarios (where particular weather conditions and odour emitting processes) is such that if abatement is required it must be brought on-line quickly, without an extensive warm-up process or optimisation process each time it starts up. The AEROX technology can be brought on line within minutes as once the power is switched on and the electrical cell is in operation, the unit is operating fully. For these many and significant reasons, it was decided at the conclusion of the Front End Study to commission AEROX Pilot plant testing at St Gobain Kilrush. IPPC LICENSE No. P

33 Aerox Trial Results A trial was conducted on 29 th November 2011 at St Gobain, using the AEROX Pilot Plant. The trial was attended by AWN Consulting in order to observe and advise on trial operation. The Trial Results are summarised as follows: Pilot Plant Test Results Summary 29/11/11 Ground Level Concentrations AWN previously conducted an air dispersion modeling study in November 2011 which concluded: Reducing odour emissions from Tower E and Tower J1 by 50% is sufficient to achieve compliance with the relevant odour guideline value of 1.5 OUE/m 3 with the modeled ground level concentrations of odour peaking at 92% of the guideline value. Reducing Odour Emissions from Tower E, Tower F and Tower J1 achieves compliance with the relevant odour guideline value of 1.5 OUE/m 3 with the odour concentration peaking at 85% of the guideline value. Therefore, it can be concluded that a 60% reduction will also ensure compliance. IPPC LICENSE No. P

34 Nature of the Odour It is a well-established fact that odour impacts are related to both odour concentration and also the nature of the odour, and in addition to reducing the odour concentrations the AEROX system denatures the odours emitted at St Gobain to reduce the offensive nature of the odours. It was observed by Fergal Callaghan of AWN, and Saint Gobain personnel present during the pilot plant trial that the nature of the odour changed substantially through the trials. Based on our observations on the roof on the day it was noted that the burnt acrid plastic smell was eliminated downstream of the AEROX Unit. It was consistently noted that this odour was essentially gone from the treated emission, hence the observation that in the region of 90% odour reduction was achieved. It must be remembered that odour measurement is not an exact science, unlike measuring a substance in mg/m 3, and emphasis must be placed on the observations of persons who smell odour at the time, and it was certainly the observation of the personnel present for the pilot plant trial that the AEROX system denatured the odour to a large extent and removed its offensive characteristics. Planning Permission for Stack Extensions In parallel with the Aerox Project we have received Planning Permission from the Local Authority for the extension of six of our stacks (ref 11/18); to (a) re-locate and extend 2 No. exhaust stacks, (b) extend 4 no. exhaust stacks, (c) to erect a steel platform to base of exhaust stacks and (d) to install bracing to exhaust stacks. However, we will not commence any works until the full scale Aerox unit has been fully evaluated. IPPC LICENSE No. P

35 Program No. 2 Program Goal Determine source of OFG at Process Sewer / Composite Sampling EPI OFG results Target Maintain OFG levels below 50mg/L Responsibility of J. Keane Review Cycle At Monthly EHS Meeting Program Objective Time-Line Responsibility Result Install Composite sampler at F6 March-11 J. Keane Unit installed and fully operational all samples submitted for analysis are 24hr flow proportionate composite samples Continue to test samples weekly Weekly J. Keane On-going Implement scheduled sludge tank clean-out Dec-11 Facilities After cleaning out sludge tanks the OFG levels dropped and have remained low since As per section 6.2 Summary of Non-Conformances the weekly OFG results have fallen to pre-2009 levels and have maintained this level going into IPPC LICENSE No. P

36 Program No. 3 Program Goal Reduce Particulate Emissions at PSA 6 EPI Particulate Emission Target Level to be agreed with EPA Responsibility of J. Keane Review Cycle At Monthly EHS Meeting Technical Amendment A to IPPC License IPPC LICENSE No. P

37 Program No. 4 Program Goal Reduce Non Hazardous Waste by 3% EPI Non Haz Waste/ PSA Production ratio Target Reduce waste from 0.063kgs/m2 to 0.061kgs/m2 Responsibility of J. Downes Review Cycle Quarterly at EHS meeting Programs to reduce waste to landfill: Recycling of cardboard and timber boxes Minimize size of samples for lab testing Continuous running and reduction on end defects Width Optimization Potential in capturing trimming IPPC LICENSE No. P

38 Program No. 5 Program Goal Energy Conservation - Defined Six-Sigma & Engineering Projects EPI Energy Production Ratio Target Reduce energy consumption from 9.1 Kw/m2 to 8.6 Kw/m2 in Year 3 (2012) Responsibility of J. Downes Review Cycle Quarterly at EHS meeting Program 3 Year Target = 8.6Kw/m2 Program 3 Year Actual = 8.9Kw/m2 Program Objective Time-Line Responsibility Result Install 22Kw Variable Speed Aug 2009 J. Downes Complete Compressor Tower Exhaust fans modified for Aug 2009 J. Downes Complete inverter control Tower Stopped & Hot Alarming Nov 2009 M. Phelan Complete Control of Air handling units Aug 2010 J. Downes Complete Width Optimization #1 Dec 2010 J. McInerney Complete SMED Project quick changeovers Dec 2010 M. Phelan Complete Roll out of continuous running project Mar 2011 J. Downes Complete Width Optimization #2 Aug 2011 J. McInerney Complete Changes in product mix and tower slowing worked negatively against the program in year 3; this is indicated by the rise in relative energy consumption in the above chart. IPPC LICENSE No. P

39 16.2 ENVIRONMENTAL OBJECTIVES & TARGETS FOR 2012 SGPPL reviews the plant Environmental Management System on an ongoing basis with the aim of updating and refining the Environmental Management Program (EMP) to take account of progress in meeting objectives and targets. In addition, new targets are added on the basis of achievement of existing targets and where issues have been identified as requiring a formal and structured EMP approach to drive their implementation. New targets, which have been added for 2012 are summarised below. The primary focus of the EMP in achieving significant environmental objectives during 2012 will be the continued improvement of air emission quality, especially in terms of odour control and particulate emissions. The following objectives and targets have been established for the calendar year 2012 through the Environmental Management System. IPPC LICENSE No. P

40 Environmental Management Program 2012 Program No. 1 Program Goal Eliminate Odour Complaints EPI Maintain odour levels below 1.5 OUe/m3 at boundary Target Measure impact after installation of Aerox unit Responsibility of E Cooke Review Cycle At Monthly EHS Meeting Program No. 2 Program Goal Ensure compliance of particulate emissions at PSA 6 EPI Particulate Emissions Target Maintain emissions values below Limit Responsibility of J. Keane Review Cycle At Monthly EHS Meeting Program No. 3 Program Goal Reduce Non Hazardous Waste by 5% EPI Non Haz Waste/ PSA Production ratio Target Reduce waste from 87.3 g/m2 to 82.9 g/m2 Responsibility of J. Downes Review Cycle At Monthly EHS Meeting Program No. 4 Program Goal Reduce Hazardous Waste by 3% EPI Haz Waste / Production ratio Target Reduce waste from g/m2 to g/m2 Responsibility of B. McNamara Review Cycle Quarterly at EHS meeting Program No. 5 Program Goal Energy Conservation - Defined Six-Sigma & Engineering Projects EPI Energy Production Ratio Target Reduce energy consumption by 5% over 3 Years Responsibility of J. Downes Review Cycle Quarterly at EHS meeting Other Programs Installation of Rain Water Harvesting System Evaluate use of Solar Panel(s) for heating water for wash area Evaluate use of low quality finished material in Landfill heat recovery projects Transition to Zero percent APFO in PTFE dispersions PTFE Recovery and re-use Training Handling and Disposal of Hazardous Waste Repeat Acute Toxicity Test once Zero APFO and LAE content have stabilized in PTFE Complete technical amendment or License review as determined by the agency IPPC LICENSE No. P

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