Essidev SA Trading as Organic Lens Manufacturing IPPC License P Annual Environmental Report 2008
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1 ESSIDEV SA T/A ORGANIC LENS MANUFACTURING IPPC Licence P Essidev SA Trading as Organic Lens Manufacturing IPPC License P Annual Environmental Report 2008
2 2 Contents Section 1 INTRODUCTION 1.1 Company Description Environmental Management Overview Organic Lens Manufacturing Environmental Policy 4 Section 2. SUMMARY INFORMATION 2.1 Self-Monitoring Data Emissions to Sewer Summary Table for Surface Water Discharge Monitoring Emissions to Atmosphere Waste Management Agency Monitoring and Enforcement Energy and Water Consumption Environmental Complaints and Incidents 11 Section 3. ENVIRONMENTAL MANAGEMENT 3.1 Environmental Management Programme 2008 Report Environmental Management Programme Energy Efficiency Audit Summary 16 Section 4. OTHER REPORTS 4.1 Review of Residual Management Plan Annual Noise Survey Underground Pipe Testing 23 Organic Screening 23 Enforcement Category Summary 23 EPTR Report 24 2
3 3 SECTION 1 INTRODUCTION 3
4 4 1.1 Company Description Organic Lens Manufacturing Essidev S.A. (OLM) a branch of Essilor International is located in the Gort Road Industrial Estate, Ennis, Co. Clare. The company is a leading manufacturer of plastic ophthalmic lenses for the European market. Production at the plant began in 1991 and since that time has undergone a number of modular expansions. 1.2 Environmental Management Overview OLM have demonstrated a proactive approach to protecting the environment through continually improving environmental performance at the plant. The IPPC license has provided OLM with a framework for its Environmental Management System. The company is also registered to the Environmental Management System ISO 14001:2004. The initial accreditation was awarded in Organic Lens Manufacturing Environmental Policy Organic Lens Manufacturing (OLM) is committed to the principle of sustainable development and environmental protection. We aim to ensure that all activities relating to our operations are carried out in a safe manner for people and the environment, without compromising customer requirements. OLM is committed to pollution prevention and provides the necessary resources to maintain and continually improve our environmental management system. Our environmental management system will provide a framework for continual improvement by setting objectives and targets that are regularly monitored and reviewed. OLM commits to comply with the applicable legal environmental requirements and with other environmental requirements to which the organization subscribes and which relates to the organization's environmental aspects. In the operation of our manufacturing process OLM will seek to minimise waste, promote recycling, reduce energy and water consumption, minimise emissions and, where possible work with suppliers who have similar environmental aims. OLM aims to monitor and manage our environmental compliance through regular environmental compliance audits and corrective action management. OLM will consider the environmental impact of significant policy decisions OLM will communicate its commitment to this policy to all people working for or on behalf of the company and to other interested parties. OLM is committed to being an environmentally responsible neighbour in the local community. The plant will act promptly and responsibly in correcting incidents or conditions that endanger environment and inform those who may be affected. 4
5 5 SECTION 2 SUMMARY INFORMATION 5
6 6 2.1 Self Monitoring Data Emissions to Sewer Table 1 Emissions to Sewer Parameter Emission Mass Emissions 2007 (Kg) Mass Emissions 2008 (Kg) Limit Value C.O.D ,850 B.O.D ,600 Total Ammonia (as N) Suspended Solids ,425 Sodium (as Na) 8, ,000 Chloride (as Cl) 11, ,000 Sulphate (as SO4) 10, ,900 Zinc (as Zn) Kjeldahl Nitrogen (as N) Total Phosphorous (as P) Fats, Oils & Grease ,825 Table 2 Monitoring of Emission to Sewer Parameter Emissions 2007 Emissions 2008 Emission Limit Value Volume Emitted (m 3 ) 22, ,400 Temperature ( o C) ph Flow rate (m 3 /hour)
7 7 Parameter Surface Water Outfall Avg. Concentration 2007 (mg/l) Avg. Concentration 2008 (mg/l) SW1 SW2 SW3 SW1 SW2 SW3 C.O.D ph Summary Table for Surface Water Discharge Monitoring Table 3 Surface Water Discharge Monitoring Emissions to Atmosphere Table 4 Monitoring Results for Emission point AC 2008 Parameter Results mg/nm 3 Q1 Carbon Abatement Unit Results mg/nm 3 Q2 Results mg/nm 3 Q3 Results mg/nm 3 Q4 H 2 S < <0.08 1mg/m 3 Mercaptans <0.2 <0.2 <0.2 < mg/m 3 Isocyanates 0.04 <0.01 <0.01 < mg/m 3 ELV 7
8 Waste Management Table 5 Summary Waste Management Record ITEM Quantity (tonnes) 2007 Quantity (tonnes) 2008 Total Quantity Waste Produced Total quantity of waste disposed on site Total quantity of waste disposed off site Total quantity of waste recovered on site Total quantity of waste recovered off site Total Quantity Non Hazardous Waste Produced Total quantity of non hazardous waste disposed on site Total quantity of non hazardous waste disposed off site Total quantity of non hazardous waste recovered on site Total quantity of non hazardous waste recovered off site Total Quantity Waste hazardous Produced Total quantity of hazardous waste disposed on site Total quantity of hazardous waste disposed off site Total quantity of hazardous waste recovered on site Total quantity of hazardous waste recovered off site
9 9 2.2 Agency Monitoring and Enforcement Site Visits and Inspections The EPA conducted a site inspection of OLM on the 29/7/08 [Ref:(P ) 08SI05DD]. Firewater Retention Facility Observations Surface Water Drainage COD elevated at SW discharge points in May A manhole inspection was underway. The apron around rainwater gullies not of sufficient height An update will be submitted to the EPA regarding the progress on the installation Corrective of Action a firewater retention facility A proposed trigger and action value for COD in surface water discharging from the facility was submitted to the Agency Inspection of underground pipes and manholes was completed and progress reported to Agency Height of rainwater gullies increased Surface Water Discharge The surface water visual inspection sheet did not mention pathways were overgrown or littering was evident at the surface water discharge point. Access to surface water discharge monitoring points will be maintained. The surface water visual inspection sheets now include in the comments section the status of surface water monitoring points (eg document if littering such as aero foam is present and needs to be cleaned, that pathways are overgrown etc). The environment section liaises with maintenance when corrective action requires input from maintenance Storage of Materials Material spilt on ground outside its mobile bund Relevant materials are stored in larger drums to prevent overflow Waste Management Waste Segregation training will be provided on an ongoing basis to all employees whose work can have a significant impact on the environment to ensure that all waste is correctly segregated 9
10 Energy and Water Consumption Table 6 Energy Consumption Energy Source Electricity MWh Gas m Table 7 Water Consumption Water Source m 3 m 3 Municipal Supply Environmental Complaints and Incidents Table 8 Environmental Complaints 2008 Environmental Complaints Complaints Received Complaints requiring corrective action Categories of complaint Odour - Noise - Water - Air - Miscellaneous - Number of Complaints None None 10
11 Environmental Incidents 2008 Date Incident (Category) Notification 13/5/08 3 Our effluent monitor failed to record data from 20/4-1/5 Electrical storm tripped computer at night and it was not turned back on next day 14/8/08 3 High COD result in surface water outfall SW1 Corrective Action Routine checks of effluent monitoring system at beginning of shifts Small repair required in effluent manhole 4/12/08 3 Exceedance of sulphate ELV 11
12 ESSIDEV SA T/A ORGANIC LENS MANUFACTURING IPPC LECENSE 699 SECTION 3 ENVIRONMENTAL MANAGEMENT
13 Environmental Management Programme Report 2008 OBJECTIVE TARGET Decrease amount of 10-15%of waste sent to landfill 2007 Hazardous waste reduction N o Achievement 1 Reduced total quantity of non-hazardous waste generated by 17% of 2007 Reduced waste sent to landfill by 33% of %of Hazardous waste reduced by 5%/unit produced Energy use/cost reduction Water Consumption reduction 10% per unit produced of % of 2006/unit 3 Electricity KwH/unit consumption reduced by 9.8% of Gas KwH/unit consumption reduced by 11.75% of Combined KwH/unit for total energy consumption reduced 10.21% of CHP project put on hold until until energy reduction programmes in relation to gas reaches a baseline 4 4% reduction on 2008 for water consumption/unit Significant leak identified and repaired Water consuming equipment turned off at weekends Process improvements to reduce water Water saving devices installed in rest rooms Baseline data created Implement schedule to comply with IPPC licence requirements 100% All licence requirements complied with
14 Environmental Management Programme Proposal OBJECTIVE TARGET N o EMP Responsibility Indicator Q 1 Q 2 Q 3 Q 4 Q 1 Q 2 Q 3 Q Decrease amount of waste sent to landfill 10% of Introduce engineering improvements to reduce waste streams Engineering Manager Tonnage/Cost Segregation of food waste in canteen Env Co-Ordinator Replace hand towels in rest rooms with energy efficient dryers Purchasing Officer Refresher waste training in all areas Env Co-Ordinator Hazardous waste reduction 5%on Identify and where possible implement opportunities for hazardous waste reduction Chemical Env Team Tonnage/Cost Engineering changes to raw material preparation area, which will due to ergonomic improvements lead to a reduction of product residue in drums Waste Filter reduction Organisational changes to reduces quantity of waste PPE Improve process control Methods Manager Process Eng Purchasing officer & Area managers Engineering Manager
15 OBJECTIVE TARGET ESSIDEV SA T/A ORGANIC LENS MANUFACTURING IPPC Licence P Indicator Q Q Q Q Q Q Q N o EMP Resp Q Energy use/cost reduction 10%/ lens cast 3 Feasibility study on installation CHP unit Process Eng Install CHP unit Process Eng Energy Efficiency training & communication Energy Team Audit energy efficiency of site Process Eng Installation of flow transmitter on compressed air supply line Process Eng CGPP project: Recycling of Process Water Consumption 40% of Reduction Water with Heat Recovery Water Team Implement schedule to comply with IPPC licence requirements 5 Noise monitoring Env Co-Ordinator Monitoring air emissions from carbon abatement Env Co-Ordinator Monitoring effluent emissions Env Co-Ordinator Organic Screening Env Co-Ordinator Surface water monitoring Env Co-Ordinator Update Residual Management Plan Env Co-Ordinator EPTR Env Co-Ordinator Enforcement Category Env Co-Ordinator AER Env Co-Ordinator Consumption data Non Conformances Resource Minimisation 5-10% 2008 New packaging design for product Methods Manager New nitrogen unit Methods Manager New s product reduces raw material use Methods Manager
16 Energy Efficiency Audit Report Summary Date of Audit: 11/12/2008 Auditor: SEI Ref Recommended Opportunity for Energy Savings Air Compressors 01 Installation of flow transmitter on compressed air supply line 02 Energy measurement on the individual compressors 03 Trending of compressed air usage and development of KPIs for this utility 04 Reduce schedule for blowing down of receivers and compressors 05 Installation of coalescing filters down stream of the refrigerated dryers 06 Reduce or improve method for air delivery for the cleaning of the lenses HVAC (Heating, Ventilation, Air Conditioning) 07 Use of thermal storage to benefit from off peak electricity prices. 08 Use of slush ice as a cooling medium. 09 Better monitoring of performance to alert operations staff of out of specification performance. 10 Seasonal adjustment of temperature set points. 11 Challenge parameters such as %RH, Temperatures, Air changes, Pressure Gradients
17 17 Section 4 OTHER REPORTS
18 18 Review of Residual Management Plan
19 RESIDUAL MANAGEMENT PLAN 2008 ORGANIC LENS MANUFACTURING TRADING AS ESSIDEV S.A. LICENSE P PURPOSE The purpose of this residual management plan is to comply with condition 14 of IPC license P , which aims to insure that in the event of closure and decommissioning of OLM no environmental pollution will result. OLM is a Risk Category 2 site. A Clean Closure - upon cessation of operations and subsequent decommissioning at the facility, so that there are no remaining environmental liabilities - is expected. 2. SCOPE Following the termination or planned cessation for six months, of use or involvement of all or part of the site in the licensed activity; OLM shall decommission, render safe or remove for disposal/recovery, any of the following that may result in environmental pollution: Soil or subsoils Buildings Plant or equipment used on site for production/production related purposes and/or used for complying with requirement of IPC license. Waste material hazardous and non hazardous Raw materials - chemicals Other matter Warehouse materials 3. CRITERIA DEFINING SUCCESSFUL DECOMISSIONING 3.1 Criteria defining successful decommissioning at OLM include: No residual contamination on site Clean safe buildings Decommissioning & removal of all plant & equipment. Removal of all materials & product Removal of all waste- hazardous/non hazardous Documented Report No residual contamination on site The EHS manager will contract suitable consultants to determine if contamination to soil or groundwater has occurred as a result of operations at the facility. In the unlikely event this has occurred, the general manager will be responsible for ensuring that remedial action takes place Clean safe buildings The EHS Manager will ensure an environmental property assessment takes place. The main purpose of an assessment is to examine the building for the presence of hazardous materials or chemicals. If necessary, cleaning and decontamination will take place. A consultant engineer will determine the structural safety of the building. Repair works will be carried out if necessary Decommissioning & removal of all plant & equipment. The maintenance manager will be responsible for cleaning of all plant and equipment. The production manager will be responsible for determining if the plant and equipment can be reused in other Essilor facilities. Plant and equipment that cannot be reused be disposed of using a suitably licensed waste contractor.
20 3.1.4 Removal of all materials & product The production manager will contact relevant sources to determine a suitable vendor for excess materials and product. Any waste product or material will be disposed of using a suitably licensed contractor Removal of all waste- hazardous/non hazardous All hazardous and non-hazardous waste will be removed from site by a suitably licensed contractor and in accordance with the Waste Management Act 1996 and associated regulations Documented Report The General Manager will be responsible for preparing a final report outlining the successful decommissioning of the plant PROGRAMME FOR SUCCESSFUL DECOMMISSIONING AT OLM PROGRAMME RESPONSIBLE NO RESIDUAL CONTAMINATION ON SITE Soil sampling Groundwater survey if necessary Remediation if necessary Further sampling if necessary Decommissioning of effluent tank/pipework Decommissioning of carbon filtration unit Decommissioning of Laboratories CLEAN SAFE BUILDING Environmental property assessment Cleaning and decontamination of surfaces Repair work if necessary Disconnection of utilities water electricity gas DECOMMISSIONING & REMOVAL OF ALL PLANT & EQUIPMENT Decommission & clean all plant & equipment as appropriate Contact relevant source to discuss if plant & equipment can be reused Investigate suitable Waste Contractors if plant & equipment cannot be reused PROGRAMME EHS Manager EHS Manager EHS Manager EHS Manager Maintenance/EHS Mgr Maintenance Manager Chemical Process Mgr EHS Manager Manufacturing Manager Maintenance Manager Maintenance Manager Methods Manager Manufacturing Manager EHS Manager RESPONSIBLE REMOVAL OF ALL NON HAZARDOUS WASTE Identify all non hazardous waste on site Ensure waste is properly segregated Notify appropriate non hazardous waste contractor for waste hauloff REMOVAL OF ALL HAZARDOUS WASTE Identify all hazardous waste on site Ensure all hazardous waste is correctly contained and appropriately labelled Notify appropriate hazardous waste contractors for waste hauloff DOCUMENTED REPORT Compile Report on decommissioning process and final results EHS Manager EHS Manager EHS Manager Chemical Process Mgr Chemical Process Mgr EHS Manager General Manager
21 21 5. DETAILED COSTS OF DECOMMISSIONING TASK COST * 1. Groundwater Monitoring 2. Decommissioning of effluent tank/pipe work 3. Investigate possible environmental damage from use of tank & pipe work 4. Survey Soil sampling if necessary 5. Remediation if necessary 6. Decommissioning of Carbon filtration unit 7. Environmental property assessment- 8. Cleaning & decontamination of surfaces if necessary 9. Building repair work if necessary 10. Cleaning & transporting Plant & Equipment off site to other Essilor facilities for reuse. 11. Hazardous material removal for reuse in other Essilor facilities 12. Non hazardous material removal for reuse 13. Transport of product to customer 14. Non hazardous waste removal 15. Hazardous waste costs removal 16. Administration Costs (plus back up resources) 17. Miscellaneous costs TOTAL 3, , , , , , , , , , , , , , , , , *Costs will rise annually in accordance with changes in production and the annual rate of inflation 6. STATEMENT AS TO HOW COSTS WILL BE UNDERWRITTEN The costs are underwritten by a Financial Bond. The Security Amount is the sum of 200,000.
22 ANNUAL NOISE SURVEY SUMMARY An environmental noise survey was commissioned by Organic Lens Manufacturing, Ennis, to monitor compliance with the noise limits assigned in IPPC Licence Register No. P from the Environmental Protection Agency. The licence assigns a noise limit of 55dB(A) by day and 45dB(A) by night at the nearest noise sensitive locations. In addition, there shall be no clearly audible tonal or impulsive noise component in the noise emission from the activity at any noise sensitive location. The measured specific noise levels attributable to Organic Lens at the boundaries and the nearest noise sensitive locations are summarised in Table S1. The measurement locations and specific noise levels are shown in Figure S1. The daytime and nighttime noise limit was complied with at the nearest noise sensitive location. There was no clearly audible or measurable tonal or impulsive noise component in the noise emission from the activity at any noise sensitive location. Table S.1. Specific Noise Levels, Organic Lens Manufacturing, October 2008 Location Mean Specific Noise Level db(a) Label Description Daytime Nighttime B1 Southwest boundary, opposite IPP B2 Southeast boundary, opposite IPP B3 Eastern boundary, car park <50 45 B4 Western boundary, near gate to rear yard B5 Northern boundary of site NSL1 Nearest houses to south at Aughanteeroe <<43 34 Compliance With IPPC Licence Noise Limits The IPPC noise limits apply at the nearest noise sensitive location, which are the houses at Aughanteeroe (NSL1). There are no limits applicable at the plant boundaries. The daytime noise limit of 55 db(a), and the nighttime noise limit of 45 db(a) were complied with. Tonality/Impulsiveness There was no audible tonal or impulsive component in the noise at the noise sensitive locations.
23 UNDERGROUND PIPE TESTING As required by Condition of a survey of our active underground pipes was undertaken on 4/12/08. Minor problems occurred with 4 piping joints in our effluent system. These were repaired on the 23/2/ ORGANIC SCREENING REPORT SUMMARY Test Parameter 14/11/2008 Analytical Technique Result Units Semi Volatile Organic Compounds GC-MS 2 <1 ug/l Volatile Organic Compounds GC-MS ug/l 4.5 ENFORCEMENT CATEGORY SUMMARY Organisation Name ORGANIC LENS MANUFACTURING Case Number P Fixed Attributes Complexity Location Enforcement Category due to Fixed Attributes Sheet Reference Complexity Emissions Location Operator Management Enforcement Record OVERALL ENFORCEMENT CATEGORY Enforcement Category Mid Mid C1 Enforcement Category Mid Low Mid Low Low C1
24 24 EPTR Report
25 25
26 26
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