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1 Environmental Efficiency Consulting Engineers Psrnell House, 19 Quinsbdro Road, Bray Co.Wicklow, Ireland. 29/10/2008 Office of Climate Change, Licensing and Resource Use Headquarters PO Box 3000 Johnstown Castle Estate Co. Wexford Ireland 98-01: Request for Technical Amendment Dear Sir or Madam, On behalf of Irish Flexible Packaging, we would like to formally request an amendment of a technical nature under section 96 of POE act 2003 to our IPC Licence PO This is required, as the company intends to install an abatement system to treat the emissions from the new printing machine (Emission points A7 and A8 (4'h printer)). Need for an abatement technology: Irish Flexible Packaging is currently operating under the conditions of IPPC Licence P (and associated Technical Amendment). Since 2005, the company has been actively researching the possibility to minimise the amount of solvent-based inks. The company was able to achieve complete switchover from solvent-based to water-based inks for all their paper packaging products. In 2008, the company made several successful trials to extend this switchover to their film packaging products. Unfortunately, these trials could not be applied to full production following complaints from customers regarding smudging of the inks. The company identified the cause of this ite. &e Amien i formulation. increases the curing time and makes based inks unsu certain applications. It was with regrets that the company therefore had to abandon this project until the inks can be reformulated or a quicker way of curing the inks is found. In order to comply with the emission limit values in the IPPC Licence, the company now has to install an abatement system. Tel: Fax: energy@iol.ie &.enviro-consult.com Registered Office as above. Registered Number Directors : Noel J. McGrath, Robert B. Sutcliffe (British)

2 . - Selection of the abatement system: - - As a result, the company is now in the process of selecting an abatement system for their qth Printer. Only the 4th printer will require to be connected to the abatement system as all the other printers are using water-based inks and thinners. Several different systems were envisaged: 0 Thermal Oxidiser 0 Scrubber 0 Activated Carbon Adsorber 0 Bioscrubber After evaluating all these options in collaboration with the potential contractors, it was decided that thermal oxidation is the most adequate technology for the site. The reasons for this choice include: 0 Thermal oxidation does not produce any liquid effluent or waste e Thermal oxidation is well suited for the high concentrations of solvents that 0 are generated by the printing process. 1 1, i / The operating costs of a thermal oxidiser are competitive in comphrison tol the other options (operating costs are lower when the concentrationslare high). I At this stage, the company has not yet selected the unit which will be installed at the site but has reduced the choice of the unit to two options: 1. A new unit: LESNI Regenerative Thermal Oxidiser type REF 10 designed to provide 95% heat recovery and better than 98.5% purification efficiency. The unit will have the following specifications:. Airflow: 1 0,000Nm3h. The unit will be a two canisters RTO supplied with an additional buffer tank (a puff cleaning chamber acting as the third chamber) to contain and control spikes expected during switching of flow between the two chambers. -. Fuel: LPG Overall plant dimensions: 9.5m x 6.0m x 6.0m. 9 Efficiency: Guaranteed to maintain levels below 50mgC/Nm3. A technical description of the proposed unit is provided in Enclosure A second hand unit: LESNI is also investigating a second-hand unit which is -_ currently-available in County Mayo and-which would be suitable for Irish Flexible -- Packaging. Another unit is also available in Arklow but this unit contains a rotating concentrator which would not be required for the company. - Changes to the licence: The main change to the licence will therefore be the addition of the RTO as a main emission point. Emission points A7 and AS will become potential emission points as they will only be used in the event of the bypass of the thermal oxidiser (breakdown or maintenance). Emission points A5 and A6 will no longer be main emission points as this printer is now used for water-based jobs. However, there is a possibility that this printer is used

3 I_ for solvent-based jobs, i.e. in the event of a breakdown of the 4th printer and only if the stocks are not sufficient to satisfy the customer demand, the 3'd printer will be used to print solvent-based jobs as a last resort. It is therefore proposed that these two emission points be reclassified as potential emission points (as for A7 and AS) and that this unlikely event be notified to the Environmental Protection Agency. This is not considered to be a significant change to the company's processes and the quantities of solvents used at the company did not increase and are not expected to increase significantly as can be seen in the tables below: Solvent Usage during _ - I Meths Based solvent reducer I 25,869 I 24,432 I _ - _- I -. -_ Solvent based ink Water-based Inks Water-based medium Total Raw Materials Used ~ -I _ " 80 13, , , , Not applicable 41, , Paper & film I kg I 1,650,000 I 1,805,000 I 1,750,000 I 1,228,980 I 1,420,083 I If you have any questions regarding the above please contact me on s or aricoux@energv. iol. ie With kind regards, I On behalf of Irish Flexible Packaging CC: Eamon Farrell - Irish Flexible Packaging

4 r 1, Enclosure 1 Technical Sheet for proposed Thermal Oxidiser Kommarken 7. DK-7190 Billund 1 Technical sheet Ref.. I,ESNI REGENERATIVE OXlDlSERlTYPE REF -he LESNI system combines very efficient regenerative heat recovery with high VOC deitruction and control. Our installation consists of two or three vertical energy recovery chamiers packed with ceramic and one incineration chamber complete with burner. -he polluted air enters the inlet manifold through disk operating valves into the chamber that 5 in the inlet mode. The air passes through the stoneware chamber, which has been prefiously heated to about 800 C at the top surface, and takes the heat from the ceramic. Then, t enters the incineration chamber at a high temperature where total combustion and oxidaion is completed. Very often the hear from the-combustion of the solvents in the vertical :hamber is sufficient to provide the necessary energy for the process to continue without any idditional fuel consumption. :he purified air is now directed towards the chamber in the outlet mode, where the heat from he hot purified air is given off and retained in the stoneware before exiting through the operiting valves to the stack. n order to keep a balanced distribution of heat inside the oxidiser, the air direction through he vertical chambers is alternated about every 1-2 minutes. Thus, energy from the clean iurified air can be absorbed and stored in the stoneware, for preheating the inlet process air n the next cycle of the process. \ small fan provides the necessary purge of purified air into the chambers during switching of tir direction within the chambers to avoid escape of any polluted air through the stack. he LESNI system will be designed to obtain the purification required by the authorities with he highest degree of security and efficiency. Jote: \ buffer chamber is constructed in the duct to control the air leaks expected during the :witching of chambers (thus ensuring near 99 YO VOC destruction efficiency) when a 2 bed mister is selected.

5 LESNI% Inaenier- og hondelfjelshab Kornmartcen 7 - DK-7190 Billund I Technical sheet Case no Ref.: I I -.>.,.,. I ",I I I '. - -

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