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1 Inf o-la b a. huberom group I Info-Lab Ltd. - Unit 14 * Annacotty Industrial Estate * Annacotty * Co. Limerick * Ireland 10/11/09 Info-Lab Ltd. Unit 14, Annacotty Industrial Estate, Annacotty, Co. Limerick, Ireland. Telephone: +353 (0) Fax: +353 (0) info@infolab.ie Office of Climate, Licensing and Resource Use, Environmental Protection Agency, PO Box 3000, Johnstown Castle Estate, Co. Wexford Licence Register Number: PO Dear Noeleen, With reference to a letter received from the Agency dated 06/11/09 in regard to a request for additional information relating to our recent application for a review of our IPPC licence. The Agency requested information regarding the total volume of water used (in M3) at the installation in I can confirm that we used 4438m. I have enclosed an update non-technical summary to reflect this information (1 signed original, 1 hardcopy and 2 copies in electronic searchable PDF format on CD-ROM). Helen McKeon Director Info-Lab Ltd. Directors: Dr. J. Erennan, Dr. Burkard Huber (Austria). Registered in Ireland No.: VAT No.: IE N. EPA Export :16:35:51

2 SECTION A: NON-TECHNICAL SUMMARY A non-technical summary of the application is to be included here. The summary should identify all environmental impacts of significance associated with the carrying on of the activity/activities, and describe mitigation measures proposed or existing to address these impacts. This description should also indicate the normal operating hours and days per week of the activity. The following information must be included in the non-technical summary: A description of: the installation and its activities, the raw and auxiliary materials, other substances and the energy used in or generated by the installation, the sources of emissions from the installation, the environmental conditions of the site of the installation (e.g. soil and groundwater, air, noise, s u rfa ce water), the nature and quantities of foreseeable emissions from the installation into each medium as well as identification of significant effects of the emissions on the environment, the proposed technology and other techniques for preventing or, where this is not possible, reducing emissions from the installation, where necessary, measures for the prevention and recovery of waste generated by the installation, further measures planned to comply with the general principles of the basic obligations of the operator i.e. (a) all the appropriate preventive measures are taken against pollution, in particular through application of the Best Available Techniques (BAT); (b) no significant pollution is caused; (c) waste production is avoided in accordance with Council Directive 75/442/EEC of 15 July 1975 on waste; where waste is produced, it is recovered or, where that is technically and economically impossible, it is disposed of while avoiding or reducing any impact on the environment; (d) energy and other resources are used efficiently; (e) the necessary measures are taken to prevent accidents and limit their consequences; (f) the necessary measures are taken upon definitive cessation of activities to avoid any pollution risk and return the site of operation to a satisfactory state. measures planned to monitor emissions into the environment. Supporting information should form Attachment N* A.l

3 SECTION A: ANSWER A.l General Info-Lab is a wholly owned subsidiary of MICHAEL HUBER GmbH, a company which was established in Munich in The Huber company is primarily involved in the manufacture of printing inks, including gravure and offset types and other speciality inks. Having regard for the Huber Company s ability in developing speciality inks Oce (formally Siemens) Germany invited the Huber company in 1978, to work with them in producing the dry powder ink-toner which is used in their non-impact laser printers. This development was successful and the Huber Company became an approved toner vendor to Siemens. The Huber company was also developing speciality inks for optic fibre marlung, with the optic fibre producers. This development work led into the development of fibre optic filling compound products. To service the growth demand for both laser toner and fibre optic filling compound, MHM established automatic manufacturing facilities in Ireland and incorporated Info-lab Ltd. Info-lab was set up in Annacotty, close to the University of Limerick in In July 1988, the company acquired the toner manufacturing assets of Gestetner Ltd. This provided the capacity to manufacture photocopying toner in Info-lab Ltd. In Sept. 1991, the board of M.H.M. decided to transfer the manufacturing of Dampening additives fi-om Germany to Info-lab Ltd. In January 1992 the R&D department located at Bishopstortford (U.K.) transferred its facilities to Info-lab Ltd. for the research & development of photocoping toners and developers. This was subsequently closed after the acquisition of Elfotec AG with R&D facilities then based in Switzerland. The Huber group acquired Elfotec AG, Monchaltdorf, Switzerland in This is a toner manufacturing/filling company servicing the office copier/printer aftermarket in particular. This toner business was formally integrated with the Info-Lab toner business in January 2002 with the establishment of Elfotec Ltd. The two Elfotec s, which together form the Huber toner division, were jointly managed by three directors -the financial controller of Elfotec AG,the sales & marketing manager and the Company director of Elfotec Ltd. In 2003 MHM decided that MGA inks manufacturing would take place at Info-Lab. To facilitate this a new unit (unit 13) was leased. The first product in Ireland was produced in November In December 2006 the Elfotec business was sold. In January 2008 the fibre optic cable business was sold (with a short term transitional agreement in place). We have since agreed to run the Irish plant here for them Total area: (Buildings) 65,324 Sq. Ft.

4 Unit 12 for Dampening additives 27,438 Sq. Ft. Unit 13 for MGA inks Unit 14 Office area 31,958 Sq. Ft. 5,928 Sq. Ft. Number of employees: 25 Work Day Ofice: Plant: Number of shifts: Hours See Attachment A.l Site location map; Site pladboundary map We currently hold an IPPC licence as at Info-Lab Ltd. we carry on the following activity : The manufacture or use of coating materials in processes with a capacity to make or use at least 50 tonnes per year, not included in paragraph A.2 Process Description Attachment A.2 - Process flow diagram for the production of Dampening Additives & MGA varnish & inks. The steps involved in the production of Dampening additives are: 1. Raw material manual weighing & automatic dosing. 2. Mixing - mixing is carried out for approximately 2hours in vessel varying in size of between Kgs. 3. QC testing and adjustment of ph as required. 4. Pumping & filtration. 5. Filling - filling is into a variety of packages fiom lltr bottles to loooltr one way containers. The steps involved in the production of MGA varnish are:

5 1. Dosing of raw materials 2. Heating of materials in varnish cooking vessel (5m3). Heating is achieved with oil from the boiler being circulated around the oil jacket. 3. Cooling of product in vessel by cooled oil being added to the jacket. 4. QC sampling & testing 5. Transfer of varnish to the bunded holding tanks. 6. Filling into containers for shipping to Parent company or doing into mixing vessel for production of Ink. The steps involved in the production of MGA concentrates & Inks are: 1. The dosing of raw materials. 2. Predispersing of pigment by mixing in an agitator. 3. Fine dispersion with Three roll mill. 4. Mixing with agitator to homogenise 5. QC sampling & testing. 6. Filling into drums, cans etc. A.3 Raw materials Details of the principle materials that are used are given in tables G. 1 (i) and G. 1 (ii) The following summarises the main raw materials used on site: 1. Water 2. Glycerine 3. Propylene Glycol 4. Biocides 5. Malic acid 6. IPA 7. Arabic Gum 8. PTO oil 9. Caustic soda 10. Citric Acid A.3.1 The principle utility demands for Info-Lab are: - Natural gas boilers (2008 usage was kWh) - Limerick county council water mains supply (2008 usage was 4438 cubic meters) - Electricity for all machinery, electrical equipment, lighting, pumps etc (2008 usage was kWh) - Compressed air

6 A.4 Waste management A.4.1 Non Hazardous Waste management Pallets, paper, cardboard, plastic & metal are segregated and collected for recyclingby licensed waste contractors. General non hazardous waste is compacted on-site and collected for disposal by a licensed waste disposal contractor. Records are maintained. A.4.2 Hazardous waste management All hazardous waste is labelled and stored in specific bunded production areas prior to being collected and disposed of by licensed waste contractors. This includes waste form effluent reatment system; caustic washing machine, lab wastes; obsolete raw materials or off-spec production batches that can not be reworked etc. Where possible these are sent for recycling or recovery. Records are maintained. A.5 Emissions to Air All atmospheric emissions kom MGA & DA production would be considered to be minor and insignificant in terms of impact on the environment. They are all described in section E. 1 of the application. A.6 Emissions to Waters We have no emission points to surface water. A.7 Emissions to Sewer There is one licensed emission to sewer at the Info-Lab site. This waste water is created fiom the cleaning of the mixing vessels and reusable packaging. All trade effluent waste waters fiom Info-Lab Ltd are treated firstly in-house by vacuum distillation. The distillate is piped to the Castletroy Waste water Treatment plant operated by Limerick County Council. There is - 10% concentrate waste that is collected and disposed of by an approved waste contractor. We have emission limit values on the effluent that we discharge to sewer. Infolab conducts daily, weekly, monthly and quarterly analysis on this discharge. We report these results monthly to the County council and also in our AER. A.8 Emissions to Ground Info-Lab have no emissions to ground at the Info-Lab site. Various containment measures (bunding etc) have been incorporated to prevent/contain any accidental release, which could potentially impact on ground or groundwater quality. A.9 Noise Emissions There are various items of equipment which generate noise associated with the normal operation of Info-Lab plant. Noise levels at the boundary locations and the noise sensitive location are monitored on a periodic basis. We have ELVs of 55dB(A) daytime & 45dB(A) night time for the noise

7 sensitive location - these have never been exceeded and no complaints of noise have been received. A.10 Sampling & monitoring Monitoring of emissions to the environment is carried out to ensure that all controvtreatment systems continue to perform to specification and that emission limit values are not exceeded. Provision for monitoring, sampling and analysis of environmental emissions has been incorporated into the design of the plant. Monitoring is carried out for discharges to sewer, surface water, emissions to atmosphere and noise levels to ensure the operation of the plant is not having any significant impact on the environment. A.11 Energy Efticiency The plant employs the latest technology and high efficiency equipment is used. Energy demand is optimised using high efficiency electrical drives on equipment (e.g. pump motors) and variable speed drives where appropriate. Regular servicing and maintenance of equipment ensures that all equipment continues to perform to specification. We operate a Environmental management programme on Energy and this programme continuously look at our Energy management. to ensure the continued efficient use of energy. A.12 Accident Prevention and Emergency Response Info-Lab s philosophy is based upon accident prevention, coupled with appropriate emergency response to deal effectively with an accident or emergency situation, both during & outside of normal working hours. Regular Safety & Environmental training takes place. All procedures are documented in our Environmental and Safety policies & manuals. It has been determined using the EPA Guidelines on the Requirements for fire water Retention facilities that a firewater run-off facility was not required. See attachment A. 12 A.13 Statutory requirements No activity on-site and no emission from the site will breach any statutory requirements. The activities on site will not have adverse impact on the surrounding environment. A.14 Environmental Management Info-Lab Ltd. has established and maintains an IS :2004 accredited Environmental Management System (EMS). This has been in place since A.15 Quality Management A Quality Management System (QMS) based on the requirements of IS0 9001:2000 standard has been developed and implemented at the plant. This had been in place since

8 A.16 Decommissioning In the event of termination or planned cessation of all or part of our site we have a Residuals Management Plan and a Restoration and aftercare management plan. These documents were drawn up by White, Young & Green using EPA Guidance on Environmental Liability risk assessment, residual Management plans and financial provision (Guidance document). Copies can be found in Attachment 1.8.