refer to your letter dated 27th July 2006 and answer the questions you raise below

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1 BOC Gases PO Box TH September 2006 b/gb%'pb\1ephone (+353 1) (+353 1) Mr Frank Clinton Senior Scientist OLG Environmental Protection Agency PO Box 3000 Johnstown Castle Estate CO Wexford. Dear Mr Clinton, refer to your letter dated 27th July 2006 and answer the questions you raise below BOC is proposing to offer a range of services to allow customers to comply with a number of legal requirements Recovery of ozone depleting substances (EU Regulation 2037/2000) 0 Recovery of fluorinated gases (EU Regulation 842/2006) 0 Waste Management (Movement of Hazardous Waste) Regulations (1998) BOC has a fully licensed, top tier COMAH site at lmmingham near Grimsby and has been offering some of these services within the UK since Waste collected at our Dublin site is transferred to lmmingham Waste Activities (a) The type of waste brought to our site will be: 0 Recovered refrigerants with a European Waste Catalogue (EWC) code They will comprise of CFCs, HCFCs, HFCs used in refrigeration and air conditioning (RAC) service. Recovered Hydrocarbons - EWC code Recovered ammonia - EWC code x- 1. 1,e, flecovered Sulphur, Hexafluoride - EWC=code *M e annualised quantities expected would be up to 50 tonnes. Thi up over a number of'years but initially may be higher as we are aware that there is a build up of product at customer sites. This backlog represents c! 1 years demand in addition to ongoing demand. The average amount returned by individual customers will be small where cylinders contain an average of 4 kgs (smallkylinder) or 20 kg (large cylinders) of recovered refrigerant. (c) The maximum amount of waste that might be on our site could bqi 1 S0 container (18. tonnes). This quantity would be very rare. BOC has a dailyitransport to BOC sites in the UK so we would look to minimise the stocking on the D~dlin site. 1: ' BOC Gascs reland Ltd A inetnber of The BOC Group Registered Office: Bluebell. Dublin 12. Number rish Register 1

2 ll' ' ' (d) The reception facilities on the Dublin site are as follows 0 The site is a secure fenced site with 24 hour on site security. The site is also protected by CCTV. 0 Cylinders and drum tanks would be received on site from BOC vehicles, the loads will be checked against paperwork and transferred to a specific secure location on the site for onward transport to BOC in the UK. 0 The storage location will be suitable for refrigerants with concrete or hardcore and away from drains. 0 Cylinders are handled in pallets by forklift trucks. Drums are handled on cradles also manoeuvred by FLT. The cylinders and drums will be transferred to BOC UK for recovery or incineration. There is no processing on site. Waste is not transferred out of cylinders. Details of paperwork will be checked and further trans frontier shipment paperwork filled out in Dublin, which will also accompany the load. (e) The sources of waste will originate from: Refrigeration and air conditioning systems either from refrigeration contractors or a variety of end users e.g. supermarkets. These fluids have been used for providing cooling and are likely to contain the usual contaminants from a system such as oils and water. We also propose to offer a recovery service for Hydrocarbons Ammonia Sulphur hexafluoride Ammonia will be from refrigeration systems only. Hydrocarbons will be from refrigeration applications. SF6 will be from either radar application or high voltage switchgear operation. (f) The destination of the waste is as follows: BOC Special Products site at lmmingham in North Lincolnshire. Product that can be recovered is brought back to sales specification. f product is too contaminated then it is sent to one of three locations: lneos site at Runcorn where a recovery operation to retrieve the fluorine and chlorine salts and the rest is treated on their site. Cleanaway incinerator in Ellesmere Port where product undergoes high 1 4 Ammonia will be recovered in the gas phase on a dedicated recovery rig (an existing process) and the impurities will remain in the bottom of the cylinder, which will then be collected and disposed of in the usual way., SF6 will be cleaned through specially designed kit to clean the product back to sales specification and impurities will be trapped in filters and disposed of legally. (9) There will be no treatment of waste on the BOC Dublin site. All treatment will take place at our fully licensed site in lmmingham (UK). 2

3 ~ (h) There will be no mixing or blending on the site in Dublin. (i) EU Regulation 259/93 on the trans frontier shipment (TFS) of waste will be complied with in terms of A valid contract will exist between BOC Limited and BOC Gases reland. A financial bond will be lodged with the TFS documentation. 0 The Environment Agency have not raised any objections during informal discussions at the lmmingham site. BOC will apply to 10 local authorities to gain a national waste carriers licence to allow us to transport waste on BOC vehicles back to the Dublin site. t is worth noting that we have applied for and received waste management licence exemption for Belfast under Schedule 3 of the Waste Management Licence Regulations of 1994 in the UK. This exemption completes Northern reland licence requirements to handle refrigerant recovery within the business. We are currently pursuing a similar approach with Rachel Dunn in the Department of the Environment for the South of reland. (j) Regarding the PPC activities on site refer to previous correspondence in this regard sent to Mr Leo Sweeney on requesting an PC licence review. enclose a copy of the letter for your reference. The relevant class of activity is as follows: 5.5 The manufacture of inorganic chemicals, not included in paragraphs 5.12 to 5.17 We would welcome the opportunity to meet with you at our Dublin site where we could discuss all the issues above and show you the areas we propose to carry out the activities. Yours sincerely, h ill 1, ' Safety, Health, Environment & Quality Manager ',* ill 1 ' / j " / 3

4 r. Leo Sweeney, Senior nspector, Environmental Protection Regional inspectorate, McCumiskey House, Richview, Clons keag h road, Dublin 14 BOC Gases PO Box 201 Bluebell 27/01 /06 PA LCENCE REVEW Reg. No e Further to my letter to you of 25 h November please note the following - The PC Licence referenced above relates to the production of Dissolved Acetylene gas which was covered under the following activity The manufacture by way of chemical reaction processes of organic chemical products As previously noted - The Dissolved Acetylene process ceased production on 2gth March 02 The relevant environmental impacts relating to waste, emissions to atmosphere, emissions to sewer and potential nuisance off site have the ref0 re been eliminated. - The EPA carried out an exit audit in January 03 and all items raised were subsequently addressed to the satisfaction of the Agency. Due now to the revised classes of activities in the first Schedule of the EPA s reland Ltd now requests a review of the PC licence to the 1 f o ow i n g cl ass of act i+i t The manufacture of inorganic chemicals, not included in paragraphs 5.12 to 5.17 The hydrogen production plant is the relevant activity in this case. As previously communicated to the Agency as part of the original PC licence application, the Hydrogen Plant operates by splitting water into hydrogen and oxygen by the use of an electric current. Potassium hydroxide is used as an electrolyte and is not used up in the process. The only emissions to air arise from the venting of oxygen gas back to atmosphere. There is no waste generated during normal operations. BOC Gases reland Ltd A member of The BOC Group Rcgisiercd Officc: Bluebell. Dublin 12. Number rish Register 2

5 . refer to previous correspondence submitted to the Agency under PC Licence Application Supplementary nformation - April 1996 which included a description of the hydrogen plant and relevant impacts and enclose copies of the following for your information : a) Materials used in the Hydrogen plant (original information submitted in 1996) b) Maintenance materials used in the Hydrogen plant: The biocide water treatment system has been rationalised since the original PC licence application in 1996 leading to a reduction in the range of chemical types being used. (i) Sodium hypochlorite solution used as a microbiocide. (ii) Phoshonic acid mixture used as a corrosion inhibiter. 1 a This gives rise to the following emissions to sewer itres blow-down off per day ppm chlorine biocide present. - e lppm ortho phosphate c) Noise sources (original information submitted in1 996) Subsequent surveys submitted to the Agency as part of original PC licence conditions showed no change. BOC Gases reland is also proposing to introduce a waste refrigerant recovery service to our customers. A detailed description of the process is enclosed. We would propose that the site at Bluebell would simply act as a "Waste Transfer Station" with the actual recovery activity taking place in the UK. We therefore request a review of the PC licence to a) Take account of the reduced environment 1 ' ' ' " involved in transferri from our customers to the recovery site in the UK. enclose a cheque for as required by this review request Yours sincerely 7. gephbn Moran CChem MRSC MlCl Safety, Health, Environment & Qualitv Manaaer. 3