SOLVENT MANAGEMENT PLAN 2015

Transcription

1 ALPS Electric (Ireland) Limited. IPPC Licence (Reg: P ) Clara Road, Millstreet, Co. Cork. SOLVENT MANAGEMENT PLAN 2015

2 Solvent Management Plan 2015 Contents 1. INTRODUCTION PROCESS DESCRIPTION SOLVENT EMISSIONS DIRECTIVE COMPLIANCE REQUIREMENTS COMPLIANCE QUALITY CONTROL ALPS ELECTRIC (IRELAND) LTD. SOLVENT STORAGE AND DISTRIBUTION DISPOSAL OF USED SOLVENT FROM SITE LICENCE EMISSION MONITORING LOCATIONS SUMMARY OF AIR EMISSIONS AIR COMPLIANCE SUMMARY SOLVENT CONSUMPTION AND MANAGEMENT SOLVENT CONSUMPTION QUANTIFICATION OF SOLVENT SOLVENT MASS BALANCE CONCLUSION Appendix 1 Glossy of Terminology Appendix 2 Summary of all Solvents used at ALPS Electric (Ireland) Ltd. in 2015

3 1. Introduction The Solvent Management Plan has been prepared by ALPS Electric (Ireland) Ltd. to fulfill Condition 6.15 of the Integrated Pollution Prevention Control (IPPC) Licence (Register No. P ). ALPS Electric (Ireland) Ltd. is located in Clara Road, Millstreet, Co. Cork. ALPS Electric (Ireland) Ltd. is licenced for the principal activity of Surface Coatings under Class the Environmental Protection Agency Acts, 1992 to The activity description in the IPPC Licence is as follows: 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 Condition 6.15 of the IPPC Licence is as follows: The licensee shall prepare and report a Solvent Management Plan for the site for each calendar year. The organic solvents to be included in the SMP shall be determined by reference to the definition of an organic solvent in Council Directive 1999/13/EC. The SMP shall be prepared in accordance with any relevant guidelines in Annex Ill of the Directive or as issued by the Agency and shall be submitted as part of the AER. The licensee shall keep records of the data from which the reported information was derived and supporting documentation including a description of the methodology used for data collection. 1.1 Purpose of the Report The SMP has been prepared to verify compliance with the conditions of the IPPC Licence by undertaking a mass balance of the annual solvent consumption throughout the facility. The inputs amount of solvent to the site were weighed against the outputs through emissions to air, water and waste. The resultant difference between input and outputs is classified as fugitive emissions and is evaluated to determine compliance with licenced limit values. There are a number of pathways through which solvent can be lost as a result of process within the ALPS Electric (Ireland) Ltd. facility as outlined in Figure 1. Page 1

4 Solvent Waste Gas Emission O1 Uncaptured Solvent Air Emission O5 Solvent A1-3,A2-1,A2-3 incinerated/adsorbed O4 O6 Collected Waste Solvent Solvent Waste Collected Solvent Input O8 Solvent for Reuse Elsewhere Solvent for reuse elsewhere Solvent Purchased Solvent Purchased I2 I2 Solvent Recycled O5 O5 O7 O3 Solvent lost to waste water treatment Chemical/ Physical Reaction Chemical/ physical reaction Product Product Residue O2 Solvent lost to wastewater Figure 1 Pathways of Solvent Loss Page 2

5 2. Process Description ALPS Electric (Ireland) Ltd. production process involves fabrication of plastic parts and assembly of components onto printed wiring boards. The main processes involved in the manufacture of the product are as follows: Injection moulding of non-cosmetic plastic parts used in the assembly of the products Paint and lasering of decorative cosmetic parts. Surface Mounting Process and wave soldering mount processes (Printed wiring board stuffing) Final assembly of units (assembling plastic parts to Printed wiring boards) and including inspection and testing of finished units. There are six key steps involved in the production of the wiring boards. A description of the production process and how it relates to the Solvent Directive is outlined in the following section. Fabrication of plastic parts: Fabrication of plastic parts: 1. Moulding Process Plastic granules undergo injection moulding. The moulds are annealed, cooled and cleaned. 2. Painting And Laser Tech Process Moulds (plastic parts) requiring cosmetic coating are coated with a mixture of paint, thinner and hardener using high volume low pressure (HVLP) technology. Coated parts undergo a flash period of 15 minutes followed by curing in an oven at 80 o C. Moulds are coated in two enclosed booths using automatic high volume low pressure (HVLP) spray guns. Overspray is captured by a water curtain and solvents are emitted without further abatement to emission point A1-3. Solvent losses from mixing areas, flash off area and curing ovens are emitted unabated through emission point reference A2-1. Solvent losses from manual assembly process (flux and conformance coating) are directed unabated to emission point A1-3 and A2-3. Emissions from these points vary on an annual basis based on productivity however are approximately 3 kg/hr. Laser etching of some parts is also undertaken. Annual solvent usage for this coating activity varies on an annual basis based on productivity however is estimated between tonnes. Licenced Activity: "Other Coating" Solvents Directive Annex IIA Activity 8. Page 3

6 3. Raw Material Detrashing Printed wiring boards and components are delivered to the site and packaging is removed. 4. Surface Mount Technology (SMT) Process Printed wiring boards are loaded onto a surface mount technology machine. The boards are applied with solder paste, cleaned with solvent to remove dirt and applied with glue (adhesive coating). Components are mounted automatically onto the boards. The solder paste is cured and the boards are inspected. Solvent used for adhesive coating in this area is approximately 1-2 tones per year. Licenced Activity: "Adhesive Coating" Solvents Directive Annex IIA Activity 16. EPA Agreement for use >5 tonnes/year. 5. Manual Assembly Process Larger components are manually placed onto the printed wiring boards from the SMT process. Solder is applied by point spraying application. A solvent based protective coating (conformance coating) is applied to the wiring board followed by curing for certain products. The amount of solvent is used in this process varies on an annual basis depending on productivity however is approximately tonnes per year. 6. Final Assembly Moulds and wiring boards are assembled and parts are manually cleaned using solvent. Solvent usage in final assembly varies on an annual basis depending on productivity however is approximately 1.5 tonnes per annum. Licenced Activity: "Other Coating" Solvents Directive Annex IIA Activity 8. Licenced Activity: "Other Surface Cleaning" Solvents Directive Annex IIA Activity 5. EPA agreement for use >2. 7. Cleaning of Pallets Pallets from the manufacturing facility are cleaned within the chemical store prior to reuse for transporting components within the processing areas. Licenced Activity: Other Coating Solvents Directive Annex IIA Activity 8. The amount of solvent utilized at the facility is influenced by customer demand therefore input and output quantities may vary from year to year. Table 2.1. provides indicative quantities of solvent used per annum for each of the onsite processes. Page 4

7 Table 2.1. Solvent Use and Estimated Quantities at Licence Emission Points Process Coating of moulds: - Spray booths - Mixing, flash off, ovens Manual assembly: - Conformance coating - Flux coating Indicative Solvent Use Tonnes Per Year Emission Point Solvent Directive Activity/Threshold Tonnes A Other coating / >5 tonnes/year 3 A1-3,A Other coating / >5 tonnes/year -SAM (Semi automaeted manufacturin) Surface Mount Technology process (adhesive coating) 1 A Adhesive coating / >5 tonnes/year Cleaning of Products 1.5 Fugitive 5. Other surface cleaning / >2 tonnes/year Cleaning of Pallets 3 Fugitive 8. Other coating / >5 tonnes/year In order to achieve compliance with licenced emission limit ALPS Electric (Ireland) Ltd. installed an abatement plant (A1-3). The abatement plant was commissioned in April 2009 and replaced historical monitoring emission points A2-6, and A2-7 (the Paint and Laser process stacks) and A2-2 (Solderwave/Concoat process stack). The abatement plant is based on a zeolite concentrator followed by a regenerative thermal oxidiser. The exhaust air, loaded with solvents from the process, is routed through a rotating activated zeolite adsorption wheel. The Volatile Organic Carbons (VOC s) are adsorbed in the pores of the zeolite of the wheel in adsorption mode. The adsorption is performed in one site while desorption is performed on the other site. The outlet stream from the adsorption wheel is clean air and is discharged directly to the atmosphere via a new stack (A1-3). A small portion of the clean air (10%) is diverted to a heat exchange unit to be heated by the clean air leaving the oxidation chamber. This warm air is then directed back over a small isolated section of the spent zeolite in the desorption section. The heated stream of gas is required to remove the VOC and allows them to overcome the physical attraction forces of the zeolite adsorbent. By using a smaller stream of air than the original VOC laden air stream the system has effectively concentrated the exhaust gas. The resulting low-volume, high concentration air is then directed to the oxidiser for oxidation of the VOC s prior to discharge to atmosphere. Page 5

8 3. Solvent Emissions Directive The European Council Directive (Limitation of Emissions of Volatile Organic Compounds due to the Use of Organic Solvents in Certain Activities and Installations) 1999/13/EEC has been implemented in Ireland by European Union (Installations and Activities Using Organic Solvents) Regulations 2012 (S.I. No. 565 of 2012) and formerly through the Emissions of Volatile Organic Compounds from Organic Solvents Regulations (SI. No. 543 of 2002) which are now revoked by the 2012 Regulations. The Regulations aim to prevent or reduce direct and indirect effects of emissions of volatile organic compounds (VOC s) into the environment and the potential risks to human health by providing measures and procedures to be implemented for specified activities and also to phase out the use of more harmful solvents such as carcinogens, mutagens and those toxic to reproduction. The First Schedule of these Regulations requires that coating activity be subject to compliance with the Regulations. Under the Second Schedule of the Regulations the activity defined as Other Coating including metal, plastic, textile (i.e. Activity number 8) detail the solvent consumption thresholds under which ALPS Electric (Ireland) Ltd. must comply. 3.1 Compliance Requirements An installation or activity operating above the solvent consumption threshold will need to either: Meet an emission limit value (Schedule 2) in waste gases (mg C/Nm 3 ) and a fugitive emission limit value (percentage of solvent use); or Implement a solvent reduction scheme (Schedule 5) to reduce emissions from the installation to equal to those that would be achieved by meeting the total emission value. Certain substances classified as carcinogenic, mutagenic or toxic (Risk Phrases R45, R46, R49, R60, R61) must be replaced with less harmful substances, and these substances along with halogenated volatile organic compounds with Risk Phrase R40 must comply with separate emission limit values regardless of the overall compliance method. The Solvent Emission Directive states: For discharges of the VOCs with Risk Phrases R45, R46, R49, R60, R61, where the mass flow of the sum of the compounds causing the labeling referred to in that paragraph is greater than, or equal to, 10g/h, an emission limit value of 2 Page 6

9 mg/nm 3 shall be complied with. The emission limit refers to the mass sum of the individual compounds. And; For discharges of halogenated VOCs which are assigned the risk phrase R40, where the mass flow of the sum of the compounds causing the labeling R40 is greater than, or equal to, 100g/h, an emission limit value of 20 mg/nm 3 shall be complied with. The emission limit value refers to the mass sum of the individual compounds. To demonstrate compliance with the Regulations, ALPS Electric (Ireland) Ltd. will use the Emission Limit Value Scheme. Under the Second Schedule of the Regulations the activity defines as Other Coating including metal, plastic, textile (i.e. Activity Number 8) detail the solvent consumption and Emission Limit Value thresholds under ALPS Electric (Ireland) Ltd. must comply. Table 3.1: ALPS Electric (Ireland) Ltd. Emission Limit Values Activity Type Activity (solvent consumption in tonnes/year) 8 Other coating, including metal, plastic, textile( 5 ), fabric, film and paper coating (>5) Threshold (solvent consumption threshold in tonnes/year) 5-15 > 15 Emission limit values in waste gases (mg/c/nm 3 100( 1 )( 1 ) 50/75 ( 2 )( 3 )( 4 ) ( 1 ) Emission limit value applies to coating application and drying processes, operated under contained conditions ( 2 ) The first emission limit value applies to drying processes, the second to coating application processes. ( 3 ) For textile coating installations which use techniques which allow reuse of recovered solvents, the emission limit applied to coating application and drying processes taken together shall be 150. ( 4 ) Coating activities which cannot be applied under contained conditions (such as shipbuilding. aircraft painting) may be exempted from these values, in accordance with Article 13(3). ( 5 ) Rotary screen printing on textile is covered by activity 3.2 Compliance The following sections outline the methodologies adopted for the determination of solvent (including R-phrase solvents) and fugitive emission levels from the ALPS Electric (Ireland) Ltd. facility and for the verification of compliance. Page 7

10 The solvent emission levels from the ALPS Electric (Ireland) Ltd. facility were determined through a screening assessment of solvent (VOC) consumption inventories and evaluation of VOC emission discharges. For the purpose of this assessment, VOCs were defined as: Any organic compound having at K a vapour pressure of 0.01 kpa or more, or having a corresponding volatility under the particular conditions of use Only organic solvents used in process activities and in volumes exceeding 100 litres or named R phrases and deemed to satisfy the above definition for a VOC (as defined in the Solvent Emission Directive) were included in the assessment. Measurement of VOC emission at point source discharges was carried out to determine compliance with the Regulations. All measurements were carried by MCERTS accredited personnel. 3.3 Quality Control ALPS Electric (Ireland) Ltd. utilize a wide variety of paints and thinners the volumes of which are influenced by consumer demand. When a new paint is ordered for a customer the Safety Data Sheet (SDS) sheet is reviewed by the ALPS Electric (Ireland) Ltd. Health & Safety Engineer. The Risk Phrases for the product are reviewed to assess the environmental and health hazards of a substance. Once deemed acceptable ALPS Electric (Ireland) Ltd. approve the product for use within the site. Any product containing Risk Phrases R45, R46, R49, R60, R61, or R40 and halogenated compounds will be issued for approval to the Environmental Protection Agency prior to use onsite. ALPS Electric (Ireland) Ltd. have an electronic quality control system known as MAPICS (Manufacturing, Accounting and Production Information Control Systems) which enables the monitoring of inputs (paints, and thinners) containing solvents onsite. The MAPICS system allows ALPS Electric (Ireland) Ltd. to monitor the amount of paint and solvent requested at the different process areas. Once an order has been placed for the paint/solvent it will be logged on the MAPICS system and all this information will be captured allowing a report on the amounts consumed for process activities to be generated. 3.4 ALPS Electric (Ireland) Ltd. Solvent Storage & Distribution Paints and thinners are stored within bunded storage rooms prior to dispatch to processing areas within the facility. Page 8

11 3.5 Disposal of Used Solvent from Site Once used, solvents from waste paint, and paint sludge is removed offsite by a licenced waste contractor. Some of the solvents are sent for disposal via incineration, while some of the solvent is sent for recovery. A report detailing the amounts of paint/thinners sent for disposal/recovery is received every month by the Environmental Manager and is utilized to determine the amount of waste solvent from the facility. Page 9

12 4. Licence Emission Monitoring Locations 4.1 Summary of Air Emissions The coating of moulds and printed circuit boards has been addressed within the IPPC licence by the application of Emission Limit Values (ELV s) for emission points A1-3, A2-1 and A2-3 in accordance with activity No. 8 (Schedule 2 of S.I. No. 565 of 2012) coating of moulds and printed circuit boards. Air monitoring is undertaken in accordance with the IPPC licence requirements. Monitoring was undertaken at the process vent stacks A1-3, A2-1, A2-3 and A2-4 in 2015 by Odour Monitoring Ireland. A description of the process area from which the air emission locations were tested is provided in Table 4.1. Table 4.1 Description of Process Area Emission Points Monitoring Location Description A1-3 Outlet from VOC Abatement system A2-1 Paint and Lazer Process A2-2 (Made redundant by A1-3) Concoat process & Wave solder 1&2 A2-3 Spot Dip (x3) and manual soldering A2-4 SMT machine extract point A2-6 (Made redundant by A1-3) PAL Area Extract 1 A2-7 (Made redundant by A1-3) PAL Area Extract 1 In order to achieve licenced emission limit values ALPS Electric (Ireland) Ltd. installed an abatement plant to treat the exhaust air from the Paint and Laser process stacks (A2-6 & A2-7) and the Solderwave/Concoat process stack (A2-2). The abatement treatment plant was installed in April 2009 and a new emission point A1-3 replaced previous emission points A2-2, A2-6, and A2-7. The abatement plant comprised of a system based on a zeolite concentrator followed by a regenerative thermal oxidiser. The exhausted air loaded with solvents from the process is routed through a rotating activated zeolite adsorption wheel. The VOCs are adsorbed in the pores of the zeolite in the area of the wheel in the adsorption mode. The adsorption is performed in one site while desorption is performed on the other site. The outlet stream from the adsorption wheel is clean air and can be discharged directly to the atmosphere via the new stack (A1-3). Total Organic Carbon is monitored on a quarterly basis for emission points A3-1, A2-1, A2-3, A2-4. The results of analysis for the 2015 reporting period are outlined in Table 4.2 Page 10

13 Table 4.2 Total Organic Carbon Emissions from Process Vents during the 2015 Survey Period Monitoring Location IPPC Licence Limit Value mg/m3 Measurement Period TOC conc. Normalised Volumetric airflow rate (Nm 3 /s) Emission Limit Value Volumetric airflow rate (Nm3/hr) Mass loading/ emission Annual Mass Emission Permitted Mass Emission (mgc/nm 3 ) (kg/hr) Kg/Yr Kg/Yr A A A A2-4 N/A Quarter Quarter ,000 Quarter Quarter Quarter , Quarter Quarter Quarter Quarter , Quarter Quarter Quarter Quarter Quarter Not Licenced Quarter Quarter Not Licenced Page 11

14 4.2 Air Compliance Summary The overall combined annual mass emissions for TOC from all process sources are significantly lower than annual permitted mass emissions. As a result ALPS Electric (Ireland) Ltd. have demonstrated 100% compliance with monitoring results were noted for the 2015 monitoring period. Therefore as demonstrated above ALPS Electric (Ireland) Ltd. is in compliance with Schedule two of the Regulations SI. No. 565 of 2012 (European Union (Installations and Activities Using Organic Solvents) for the activity defined as Other Coating including metal, plastic, textile (i.e. Activity number 8). Page 12

15 5. Solvent Consumption and Management The management and consumption of solvent onsite is outlined in the following section of the report. 5.1 Solvent Consumption The following tasks were considered as part of the scope of work in preparing the SMP for: Identification of all organic solvents used at the site and determination of the amount of solvent used per annum. Assessment to ensure that no carcinogenic, mutagenic or toxic (Risk Phrases R45, R46, R49, R60, R61) solvent were used onsite Identification and quantification of the potential loss pathways for the various solvents used at the site, Table 5.1 presents a summary of all organic solvents and materials which contain organic solvents that are currently used at the site. The VOC content of each material was determined by reference to the corresponding Safety Data which are stored onsite. Page 13

16 Condition 16.6 of the IPPC licence states that solvent consumption in the cleaning of product and adhesive coating shall not exceed 2 and 5 tonnes respectively unless otherwise agreed by the agency. The amount of solvent used onsite for activities associated with cleaning of product and adhesive coating was assessed with respect to Condition 6.16 of the IPPC Licence is summarised in Table 5.2. Table 5.2 Solvent Consumption for Cleaning of Product and Adhesive Coating 2015 S.I. No.543 of 2002) Activity Category Process Activity Solvent Consumed in 2015 (Tonnes) Threshold Consumption Emission Limit Value Activity 5 Cleaning of Product Activity 16 Adhesive Coating As can be seen in Table 5.2 the quantities of solvent consumed onsite for 2015 are below the threshold consumption ELV s and are compliant with Condition 6.16 of the Licence. Page 14

17 Table 5.3 Solvent Management Description and Relevance to ALPS Electric (Ireland) Ltd. Solvent Management Reference Description Relevance to process Where site Information can be obtained I1 The quantity of organic solvents (tonnes)/or their quantity in preparations purchased which are used as input into the process in the timeframe over which the mass balance is being calculated. I2 The quantity of organic solvents or their quantity in preparations recovered and reused as solvent input into the process (tonnes). (The recycled solvent is counted every time it is used to carry out the activity). Consumption (C = I1 O8) corresponds to the quantity of organic solvent which is input into the process minus any that is recovered and reused but not as input into the process. Annual solvent (paint & thinners) purchases for the ALPS Electric (Ireland) Ltd. facility. This does not take place at the ALPS Electric (Ireland) Ltd. facility. All solvent is used and sent for recovery/disposal. C As no solvent is recycled within the ALPS Electric (Ireland) Ltd. facility consumption is solely based on the annual use of solvent. O1 Emissions in waste gases (tonnes) The amount of solvent emitted to air through licenced IPPC emission points. O2 Organic solvents lost in water (tonnes), if appropriate taking into account waste water treatment when calculating O5. Solvent from the Paint and Laser process is absorbed and removed from the site in a liquid sludge. Mapics quality control system will log all paint and thinner uses with in the plant. Not Applicable to operations. Obtain via monitoring of the waste gases. Complying with the ELV s or obtain via the solvent management plan by difference if complying with the reduction scheme. Laboratory analysis will determine the percentage of solvent lost to water. ALPS Electric (Ireland) Ltd. Reference Annual Solvent Input. Recovered & Reused Input or Usage Air Emissions Licenced. Monitoring of gases from Pallet Cleaning Store. O3 The quantity of organic solvents (tonnes) Paint residue in containers, Laboratory analysis will determine Lost to Product Page 15

18 Solvent Management Reference O4 Description Relevance to process Where site Information can be obtained which remain as contamination or residue in products output from the process. Uncaptured emissions of organic solvents to air (tonnes). This includes the general ventilation of rooms, where air is released to the outside environment via windows, doors, vents and similar openings. O5 Organic solvents and/or organic compounds lost due to chemical or physical reactions (tonnes) (including for example those which are destroyed, e.g. by incineration or other waste gas or waste water treatments, or captured, e.g. by adsorption, as long as they are not counted under O6, O7 or O8). O6 Organic solvents contained in collected waste (tonnes) spray guns, and connection tubes. Solvents lost to air other than though unlicensed emission points. Solvent emissions from areas which are not covered by booth extraction systems, e.g. some drying booths, gun cleaning station, distillation unit, paint mixing & storage area, waste storage area (containers, rags), spills, etc. The abatement plant comprised of a system is based on a zeolite concentrator followed by a regenerative thermal oxidiser. This has an 95% efficiency rate. - The quantity of solvent generated at the site. Consists of waste sent off-site for disposal and the change in inventory of the waste. the percentage of solvent remaining in used containers. Obtain via the mass balance by difference. Quarterly Air Monitoring Results for the abatement plant (A1-3) Records on weight of solvent waste sent off-site for disposal. If there is no record of disposal of the waste by an authorised outlet, no credit will be allowed for the waste. Analysis of VOC content of any solvent waste sent off-site is required (this may need to be ALPS Electric (Ireland) Ltd. Reference Preparation. Air Fugitive Emission Abatement Plant Waste Collected. Page 16

19 Solvent Management Reference O7 Description Relevance to process Where site Information can be obtained Organic solvents, or organic solvents contained in preparations, which are sold or are intended to be sold as a commercially valuable product (tonnes). Solvent in finished products/semi finished product, intermediates/rejects sold for use elsewhere. repeated on a periodic basis). Representative sampling methods should be used. No solvent remains in the finished product and is burned off through the curing process and/or diverted by water through curtain the site. ALPS Electric (Ireland) Ltd. Reference Finished Product O8 Organic solvents contained in preparations recovered for reuse but not as input into the process (tonnes), as long as not counted under O7 It is important to distinguish between waste sent for disposal and waste sent for reuse, as solvent sent for reuse will reduce the Consumption term. O9 Organic solvents released in other ways (tonnes) Solvent sent offsite for recovery or reuse in other applications (including use as fuel). Solvent is sent off site to Veolia who recover some of it for reuse offsite. Should not occur under normal operating conditions. This would include that nototherwise accounted for proportions of VOC released following, for instance an accidental release of solvent from a bund. Records on weight of solvent waste sent off-site for recovery & reuse elsewhere. Sent offsite for Reuse. Page 17

20 6. Quantification of Solvent The waste register was used to determine the amount of waste solvent that was sent offsite in In order to confirm the percentage of solvent present within the waste paint, flux and thinners samples were collected in October and November 2010 and sent to for solvent analysis. The samples were analysed using GC-MS Headspace for the identification of solvent composition. The percentage solvent concentrations were estimated by utilising available solvents, namely Butan-l-ol, Propan -2-ol, m-xylene and ethyl acetate. Quantitative analysis of the solvent composition was compromised due to the sensitivity of the GC-MS. It was noted from the GC-MS scans that each sample type varied in composition. This caused difficulties for absolute quantization; therefore the results are semi-quantitative in nature. A summary of the results of analysis are outlined in Table 6.1 Table 6.1 Percent of Solvent Analysis in Emissions to Waste Date of Analysis Percentage Solvent Wipes Waste Flux and Thinners Waste Paint and Thinners 14/10/ /11/ Average Paint Sludge The results of analysis were used to quantify the percentage of solvent within the waste categories removed from the site. Page 18

21 7. Solvent Mass Balance A solvent mass balance has been completed for the facility which evaluates the solvent throughout consumption facility, and respective outputs via abatement, air, waste, and recovery with the remainder accounting for fugitive emissions Table 7.1. Table 7.1 Solvent Inputs ALPS Electric (Ireland) Ltd.2015 I1 INPUTS Amount Consumed in 2015 (Tonnes) Paint & Laser Wave solder process 0.00 Concoat 0.4 SMT 0.29 Final Assembly 0.78 Total Amount of Solvent Input (Tonnes) 35.8 Condition 5.3 of the licence notes that the Total fugitive emissions to air of volatile organic compounds shall not exceed 20% of solvent input per calendar year. Table 7.2 presents the outputs of solvent through the facility and the resultant fugitive emissions. Table 7.2 Solvent Outputs and Resultant Fugitive Emissions 2015 Total Outputs Solvent Outputs (Tonnes) Organic Solvent Emissions to Air O A A A A Total Inlet to Abatement Plant (A1-3) Annual Mass Emission 27 Organic solvents via Incineration O Solvent Emissions as Waste (Disposal) O Organic Solvents for Reuse as Fuel O8 Total VOC emissions F=I1-O1-O5-O6-O7-O8 Fugitive Emission 4.37 Paint & Lazer (Cleaning of Pallets) 0.14 Total Fugitive Emissions 4.51 Percentage of Total Fugitive Emissions 12.5% As can be seen in the Solvent Mass Balance the amount of fugitive emissions for the facility is estimated at 4.51 tonnes which comprises 12.5% of the overall mass balance and as a result demonstrates compliance with Condition 5.3. of the licence. Page 19

22 8. Conclusion ALPS Electric (Ireland) Ltd. are compliant will all licenced air monitoring emission requirements as set out in the Schedule B of the IPPC Licence as demonstrated in Section 4 of the report. Compliance with solvent consumption onsite is demonstrated in Table 8.1 and 8.2 for each of the licenced conditions. Table 8.1 Licence Compliance with IPPC licence Conditions IPPC Licence Licence Requirement 6.16 Solvent consumption in the cleaning of product and adhesive coating shall not exceed 2 and 5 tonnes respectively unless otherwise agreed by the agency. Process Activity Cleaning of Product Adhesive Coating Table 8.2 Licence Compliance with IPPC licence Conditions IPPC Licence Licence Requirement 5.13 Total fugitive emissions to air of volatile organic compounds shall not exceed 20% of solvent input per calendar year. Process Activity Solvent Consumed in 2015 (Tonnes) Percentage Fugitive Emissions Fugitive Emissions Threshold Consumption Emission Limit Value Threshold Consumption Emission Limit Value 12.5% 20% In conclusion the Solvent Management Plan for 2015 has demonstrated compliance the conditions of the IPPC Licence by providing information on solvent consumption throughout the facility, demonstrating the resultant solvent emissions via air and water, and compliance with the emission limit values within the IPPC Licence.

23 Appendix 1 Glossary of Terminology

24 Glossary of Terminology Activity Definition within the Schedule 1 of the of Solvent Directive S.I. No. 565 of 2012 Coating Activity Any activity in which a single or multiple application of a continuous film of a coating is applied to: (a) either of the following vehicles: (i) new cars, defined as vehicles of category M1 in Directive 2007/46/EC of the European Parliament and of the Council of 5 September 2007 establishing a framework for the approval of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles3 and of category N1 in so far as they are coated at the same installation as M1 vehicles; (ii) truck cabins, defined as the housing for the driver, and all integrated housing for the technical equipment, of vehicles of categories N2 and N3 in Directive 2007/46/EC; (iii) vans and trucks, defined as vehicles of categories N1, N2 and N3 in Directive 2007/46/EC, but not including truck cabins; (iv) buses, defined as vehicles of categories M2 and M3 in Directive 2007/46/EC; (v) trailers, defined in categories O1, O2, O3 and O4 in Directive 2007/46/EC; (b) metallic and plastic surfaces including surfaces of airplanes, ships, trains, etc.; (c) wooden surfaces; (d) textile, fabric, film and paper surfaces; (e) leather. Coating activities do not include the coating of substrate with metals by electrophoretic and chemical spraying techniques. If the coating activity includes a step in which the same article is printed by whatever technique used, that printing step is considered part of the coating activity. However, printing activities operated as a separate activity are not included, but may be covered by these Regulations if the printing activity falls within the scope thereof.

25 Surface Cleaning Adhesive Coating Any activity except dry cleaning using organic solvents to remove contamination from the surface of material including degreasing. A cleaning activity consisting of more than one step before or after any other activity shall be considered as one surface cleaning activity. This activity does not refer to the cleaning of the equipment but to the cleaning of the surface products. Any activity in which an adhesive is applied to a surface, with the exception of adhesive coating and laminating associated with printing activities.

26 Appendix 2 Summary of Solvents used in 2015

27 Summary of all Solvents used at ALPS Electric (Ireland) Ltd. in 2015 Area Item Description Percentage Solvent Total Received (Tonnes) R Phrases Total Solvent Used 2015 (Tonnes) Concoat Thinners R10/R36/R37/R Concoat Loctite Ultra Chemseal R40/43 0 Concoat Humiseal IR32A (Con 007 IR32A) R11/R63/R48/R20/R65/R38//R66/R Concoat Humiseal 503 (Con 005 Thinners 503) R11/R20/R36/R66/R SMT Loctite Glue None Identified PAL N-BUTYLACETATE FLUID R10/R66/R PAL PAINT 94:367 E079A V CH S GL R20/21 R38 R66 R68 0 PAL PAINT 94:369 E1416 ADM V CH MA R20/21 R38 R66 R PAL HARDNER 90:CA: R42/R43/R66/R67/R36/R20/R21/R38/R PAL THINNER 09: R10 R PAL JAXA THINNERS R11/R36/R PAL PAINT 2LL K BLACK BMW R11R20/21 R36 R38 R66 R67 0 PAL HARDENER 2HA K BMW R42/43 R10 R20/21 R36/37/38 R11 R66 R PAL THINNER VC001 FOR BMW R11/R36/R66/R PAL PAINT 94:D62/91/2:E2043/A GRAP R20/21 R38 R66 R68 0 PAL PAINT SOMACRYL CA101 NOIR LASE R11/R36/R66/R67/R10/R37/R41/R10/R11/ PAL THINNER DILUANT R11/R36/R38/R48/R20/R51/R53/R62/R65/R PAL PAINT SOMACRYL CA301 FXT NOIR R11/R36/R66/R67/R10/R37/R PAL THINNER DILUANT R10 R11R20 R36/37/38 R41 R48 R51/53 R65/ PAL PAINT SOMACRYL CC721 FBJ LAMA R11/R36/R66/R67/R10/R21/R21/R38/R43/R53/R43/R PAL HARDENER DURCISSEUR R10/R43/R66/R67/R23/R36/R37/R38/R42/R PAL THINNER DILUANT R11/R20/R36/R37/R66/R10/R21/R PAL SOMACRYL AC066 HZD MISTRAL R11 / R52/53 R67 0 PAL THINNER DILUANT R11/R20/R36/R37/R66/R10/R21/R38 0

28 Area Item Description Percentage Solvent Total Received (Tonnes) R Phrases Total Solvent Used 2015 (Tonnes) PAL PAINT NUVOVERN NP NOIR R11/R36/R66/R67/R10/R20/R21/R38/ 0 PAL THINNER DILUANT R20/ PAL INK M3817 OFF WHITE R PAL HARDENER FOR PSA INKS H R42/43 R10 R11 R20 R23 R36/37/ PAL TPV DILUANT R10/ PAL M Amber ITPL PAL TPL Off White M R22/41/53/65/ PAL M MIDRED ITPL R10 R PAL M BLUEG9 ITPL PAL M MED BLUE R10 0 PAL JAXALAC RNLT X61 BLK MATT TPCT R20/21 R38 R66 R PAL PAINT WHITE E3097/A PAL PAINT BLACK TC 94:368:E3098/A R20/21 R38 R66 R PAL CLEANING AGENT UR R10 R36/37 R51/53 R65 R66 R PAL PAINT:PRIMAQUA NOIR R36 0 PAL THINNERS S&R 09: R10 R67 R11 R36 R PAL PNT C9297 CARBONE FONCE R10 R43 R52/53 0 PAL HARDNER PD 4700/ R43 R52/ PAL THINNER R11 R36/37 R66 R PAL AQUA DEKOR HAP MISTRAL HZDK R36/R38/R65/R10/R51/R53/R50 0 PAL HA 4105 HARDENER R10 R20/21/22 R34 R36/37/38 R41/42/43 R51/53 0 PAL INK HONDA RED M R10, R36 0 PAL INK HONDA BLUE M R10,R36 0 PAL THINNERS R11 R20 R36/37 R PAL INK M Y283 GREEN PAL INK M % 910 BLUE PAL PAINT 2 K SOFTFEEL TOPCOAT R10/R66/R67/R52/R

29 Area Item Description Percentage Solvent Total Received (Tonnes) R Phrases Total Solvent Used 2015 (Tonnes) PAL PAINT 2 K HARDNER F SOFTFEEL PAL HARDNER R10/R43/R66/R67/R52/R PAL PAINT 2 K BASECOAT DEEP BLACK R10/R36/R37/R41/R66/R PAL THINNERS VC R66/R PAL PAINT 35F 37M E R11/R36/R66/R PAL THINNERS RECRACK STD R11/R51/R53/R36/R37/R38/R None Identified PAL PAINT E4976/A NH1L PAL PRIMER R36 0 PAL ALEXIT Comforlack CR Oyster None Identified 0 PAL ALEXIT Comforlack CR Beige None Identified 0 PAL ALEXIT Comforlack CR VAA None Identified 0 PAL PAINT SCHWARZ R43 0 PAL HARDNER R PAL PAINT HM TXL R11/R20/R36/R37/R52/R53/R PAL PAINT SACE HG 300TXL R11/R36/R66/R PAL HARDNER STRON R10/R43/R66/R PAL HARDNER STRON R11/R36/R43/R66/R PAL INK T18LW R10/R20 0 PAL THINNERS RUCO R10/R67 0 PAL HARDNER RUCO R10/R66/R67 0 PAL Ink T18 Series R10/20 0 PAL Ink T18 Series R10/21 0 PAL PAINT E5491/ALP None Identified 0.1 PAL PAINT ALEXIT IVORY WHITE None Identified 0 PAL VARNISH BASE RUCO R10/R20 0 PAL PAINT /A GLOSS TC C None Identified 0.06

30 Area Item Description Percentage Solvent Total Received (Tonnes) R Phrases Total Solvent Used 2015 (Tonnes) PAL THINNER DILUANT 1H None Identified 0 PAL INK T18 RED RF None Identified PAL INK T18 BLUE RF None Identified 0 PAL INK TPL DARK GREY M None Identified PAL PAINT E0223/ADM None Identified PAL PAINT A JAX BLK None Identified 0 PAL THINNERS None Identified 0.4 PAL THINNER 01:D51/734/ R12/36/63/ PAL HARDNER 90 CA None Identified 0.5 PAL INK 88PD WHITE None Identified PAL INK 88PD 100 MEDIUM CLEAR None Identified PAL PAINT 94 D71 89/1 E5873/A None Identified PAL THINNER None Identified 1.82 PAL PAINT BASECOAT R10,R37 0 PAL PAINT BASECOAT R10/43/53/66/ PAL HARDNER None Identified 0.39 PAL PAINT TC LX PIANO BLACK None Identified 1.99 PAL THINNER None Identified 0.35 PAL HARDNER None Identified 0.51 PAL Paint 94:369 E R10/20/21/ PAL PAINT 94;57 D55/ R11/20/21/43/ PAL PAINT R10/67/52/ PAL HARDNER R10/43/66/ PAL THINNER R11/36/66/ PAL THINNERS 100VR R10/ PAL Pad Ink 88PD None Identified PAL Ink Tampo blue None Identified

31 Area Item Description Percentage Solvent Total Received (Tonnes) R Phrases Total Solvent Used 2015 (Tonnes) PAL HARDNER 88PD TAMPO None Identified 0.02 PAL THINNER PV-7 TAMPO None Identified PAL Isppropylalchol R11 R36 R67 0 SMT SC 400 Surclean Cleaner R20/21/22/ FA IC5E R11 R52/ Wave Solder Sparkle Flux PO F R11/36/43/67 0 Total Solvent used in