Annual Environmental Report 2013

Transcription

1 Annual Environmental Report 2013 For Woodland Products Ltd., Drumully, Emyvale, Co. Monaghan IPPC Reg. No. P By QED Engineering Ltd., M-TEK Building 1 Armagh Road Monaghan July 2014

2 Table of Contents 1. INTRODUCTION 2 2. SUMMARY INFORMATION Water Monitoring Emissions to Atmosphere Waste Management Resource Consumption Environmental Incidents Environmental Complaints ENVIRONMENTAL MANAGEMENT Schedule of Environmental Objectives & Targets Environmental Management Programme Report on EMP Proposal EMP proposal for Pollution Emissions Register Report on PER PER Proposal for LICENCE-SPECIFIC REPORTS Noise Monitoring Report Bund Testing Report (every 3 years) Tank and Pipeline Testing & Inspection Report Dry Filter Spraybooth & Bagfilter Dust Abatement/ 14 Treatment Systems Summary Report 4.5 Package Treatment System Assessment Report 14 1

3 1. Introduction Woodland Products Ltd. manufactures furniture at Drumully, Emyvale, Co. Monaghan. Woodlands Products was issued with an IPC licence on 23 rd April 1999 as they fell under Class of IPC Licensing The use of coating materials in processes with a capacity to use at least 10 tons per year of organic solvents. Since obtaining the IPC Licence the company has decreased the volume of organic solvent coating materials used at the site. This decrease has come around predominantly as the site has changed from solvent based paints to water based paints and also due to a downturn in the level of sales for the site. Until all environmental issues at the site are resolved, it is understood that the site can t get out of the IPC licence system, although they fall outside the category requiring a licence. Condition and Schedule 4(i) of the IPC licence requires that the company submit an Annual Environmental Report (AER), to include the following content: 1. Emissions to Atmosphere Summary 2. Dry Filter Spraybooth & Bagfilter Dust Abatement/Treatment Systems Summary Report. 3. Emissions to Surface Water Summary 4. Waste Management Report 5. Resource Consumption Summary 6. Complaints Summary 7. Schedule of Environmental Objectives & Targets 8. Environmental Management Programme (EMP) Report 9. Environmental Management Programme (EMP) Proposal 10. Pollution Emission Register (PER) Report 11. Pollution Emission Register (PER) Proposal 12. Noise Monitoring Report 13. Tank and Pipeline Testing & Inspection Report 14. Reported Incidents Summary 15. Bund Testing Report (every 3 years) 16. Package Treatment System Assessment Report The following AER is submitted to the Agency for approval. This AER was drawn up following the EPA Guidance Note for Annual Environmental Report, It covers the reporting period January to December Brief description of site activities Raw materials are delivered to site and stored. Wood is cut to size, veneered and trimmed. These panels are bored/routed to specification in the machine shop. Pieces are then assembled and taken to the polish room where the furniture is sanded, stained, base-coated, shaded and lacquered. The furniture is then sent to the fitting shop where glass, hinges, etc. are attached. Finished items are packaged, stored and eventually dispatched off site. Responsibility for Environmental Management The Managing Director, Mr. Harry Gillanders has the ultimate responsibility for environmental matters related to site activities. The Maintenance Manager has responsibility for the technical element of environmental management, e.g. maintaining dust extraction systems, monitoring 2

4 points (water, air, etc.). In addition the office staff is responsible for maintenance of the IPPC public file and for the up-keep of some of the environmental records e.g. waste records. 2. Summary Information 2.1 Water Monitoring Surface Water discharge points i.e. Rain water run off from roofs and yard areas to the mountain river are required to be monitored quarterly for ph, Suspended Solids and COD. A visual inspection of these points for colouration and odour is also carried out, when there is water flow. In addition, location SW6 is to be monitored monthly. The Agency s correspondence dated 11 th January 2006, ref M198/ap07ap.doc requires that quarterly water monitoring at two wells on site, the puraflo system and the river be carried out at Woodland Products. Subsequently, the Agency s correspondence dated the 17 th of January 2013 approved the cessation of monitoring of the Mountain Water River following the submission of a Hydrogeological Risk Assessment Report and a request for cessation of this monitoring based on the findings of the report. Monitoring of the two wells on site and the puraflo system was not carried out in All IPPC monitoring at the site was halted in 2013 with the objective of surrendering the IPPC licence taking priority. This objective has also been the priority in 2014 and it is hoped that considerable progress can be made before the end of Therefore the only monitoring results available for 2013 are from an EPA sample collected at SW6 on the 27 th of March Monitoring results for 2013 are as follows: SW6 COD Suspended DATE mg/l ph Solids mg/l 27/03/ All results were low and not problematic. 3

5 2.2 Emissions to Atmosphere All IPPC monitoring at the site was halted in 2013 with the objective of surrendering the IPPC licence taking priority. This objective has also been the priority in 2014 and it is hoped that considerable progress can be made before the end of Therefore the most recent air emission monitoring results for emission points EP1 and EP2 from 2012 and the Spraybooths in 2011 are reported in the 2013 AER to represent the air emissions from the site. (i) Oil Boiler, EP1: The Oil Boiler, EP1, was sampled once in 2012 for CO and NOx. The Frequency of monitoring of EP1 was reduced from Bi-annual to annual for all parameters as stated in EPA correspondence of the 24/11/11. Emission from Oil Burning Boiler EP1: 21/03/12 Concentration mg/nm 3 Parameter As Emitted Corrected to 3% Oxygen IPC Licence Limit Carbon Monoxide (CO) Nitrogen Oxides (as NO 2 ) Oxygen % Temperature 0 C

6 (ii) Wood Fuel Boiler, EP2: The Wood Waste Boiler, EP2, is to be sampled for CO, NOx, TOC, Particulates and Smoke, as per Condition 5.2 and Schedule 1(ii) of the IPC Licence. Monitoring results are available for the 1 st monitoring period. Monitoring was conducted during normal operation on the 21 st of March 2012 for particulates, CO, and NO 2 at EP2. Monitoring of Total Organics at EP2 was conducted on the 26 th of June Emission from Wood Burning Boiler EP2: 21/03/12 (TOC: 26/06/12) Parameter As Emitted Concentration mg/nm 3 Corrected to 6% Oxygen Corrected to 11% Oxygen Mass Emission Rate kg/hr Particulates IPC Licence Limit mg/nm Carbon Monoxide (CO) Nitrogen Oxides (as NO 2 ) TOC (as C) Oxygen % Temperature 0 C Gas Flow Actual m 3 /hr Gas Flow Normal Nm 3 /hr The IPC Licence specifies an oxygen correction of 6% for solid fuel combustion gases. However for wood burning boilers, 11% reference oxygen correction is the more appropriate correction, following the TA Luft (German Standard). The IPC licence does not specify a mass emission limit. 5

7 (iii) Spray Booths: The company s IPPC Licence requires that emissions to atmosphere from three spray booths (EP5, EP13 & EP19) be monitored for Total Organics (as C) on an annual basis. The results from monitoring conducted in 2011 are shown in the table below. There have been no changes to spraying operations at the site since the monitoring events in 2011, therefore results are expected to be similar to those recorded in Table 1: Woodland Products, Air Monitoring Results, 27/10/11, 02/11/11 Stack ID Parameter Emission value Nmg/m 3 Emission value Limit mg/m 3 Volume emitted/hour m 3 Actual Limit Actual Volume emitted/day m 3 Limit EP-5 TOC (as C) ,366 17, , ,095 EP-13 TOC (as C) ,493 17, , ,188 EP-19 TOC (as C) ,568 3,352 19,980 18,821 EP-19 Re-monitoring of Vol. Flowrate ,895 3,352 16,255 18,821 Emissions from the oil boiler were low in 2012 and were within the IPPC Licence limits. Total Particulate, Carbon Monoxide, and Total Organics (as C) results were within the Licence Limits at Wood Fuel Boiler EP2 in Nitrogen Oxide results when corrected to 11% O2 were within the licence limits, but when Nitrogen Oxide results were corrected to 6% O2 they were over the IPC Licence limit. All of the spraybooths monitored in 2011 were below the Emission Limit Values for mg/m3 TOC (as C) as stipulated in the IPC Licence. All laboratory results were below the Limit of Quantification or lowest value that can be reported for the test. The emission volumes discharged per hour and per day were under the volume limits as per licence for EP-5 and EP-13. The emission volume for EP-19 was slightly above the licence limit. It is understood that on the date of the initial monitoring the filter which is normally in place at this emission point was removed for repair. This led to an increase in volume flowrate per hour at emission point EP-19. The filter was repaired and re-fitted at emission point EP-19 and re-monitoring of volume flowrates at emission point EP-19 was subsequently carried out on the 15th of February 2012 by QED Engineering Ltd. to determine the volume flowrate per hour of EP-19 with the filter in place. The results showed that the volume flowrate per hour and per day of EP-19 with the filter in place had reduced significantly from the previous monitoring event on the 02 nd of November 2011 and that the volume flowrate per hour was below the licence limit for maximum rate per hour of 3,352 m3, and for maximum rate per day of 18,821 m3. It is considered that the 2011 and 2012 air monitoring results are a good indication of emissions at the site in 2013 as there were no changes made to the boilers or spraybooths and demand for the boilers and spraybooths was reduced to 3 days per week due to site operations. 6

8 2.3 Waste Management Details EWC Waste Carrier Destination General Skip Waste General Skip Waste McElvaney s Waste & Recycling NWCPO Blue Dolphin Environmental Ltd. WFP/MN Cardboard Blue Dolphin Environmental Waste Wood & Sawdust Septic Tank Sludge Waste Glue Washwater Liquid Sealer/Lacquers Ltd. WFP/MN Scotch Corner Landfill, Annyalla, Castleblaney, Co. Monaghan W Indaver Ireland Ltd, Carranstown, Duleek, Co. Meath W Kincorragh, Smithborough, Co. Monaghan None Recycled in Wood McElvaney s Waste & Recycling NWCPO Burning Boiler Corcaghan, County Monaghan ENVA Ireland Ltd. 41/01 Smithstown Industrial Estate, Shanon, County Clare ENVA Ireland Ltd. 41/01 Smithstown Industrial Estate, Shanon, County Clare Skip Waste There is one main skip on the site which is collected approximately once per month. The skip waste collected in January 2013 was disposed to Landfill by McElvaney s Waste & Recycling. After January all the skip waste was sent for incineration by Blue Dolphin Environmental Ltd. Details of skip waste disposed from 2002 to 2013 are presented in the following table. Period Weight (Tonnes) Total Tonnage Total Tonnage Total Tonnage Total Tonnage Total Tonnage Total Tonnage Total Tonnage

9 Total Tonnage Total Tonnage Total Tonnage Total Tonnage Total Tonnage The amount of waste disposed to landfill has decreased dramatically in recent years, due to better waste management practices at the site, including reducing waste at source, recycling and re-using, where possible, and also changes in waste treatment with a move away from disposal due to increasing landfill levy costs. In 2013 the volume of waste decreased by 19% on 2012 figures. Cardboard Waste Cardboard waste has been segregated from general waste since 2003 and sent for recycling to Blue Dolphin Environmental Ltd. The amount of waste recycled to date: Period Weight (Tonnes) Total Tonnage Total Tonnage Total Tonnage Total Tonnage Total Tonnage Total Tonnage Total Tonnage Total Tonnage Total Tonnage Total Tonnage Total Tonnage Wood Waste All wood waste offcuts and sawdust extracted via the dust extraction system are burned in the solid fuel boiler. Hazardous Waste Septic Tank Sludge The sewerage system was emptied by McElvaney Waste Disposal Contractor in No sludge was removed from the sewerage system in Liquid Sealer/Lacquers There were no liquid sealers or lacquers removed from the site in Waste Glue Washwater There was no waste glue washwater removed from the site in

10 Waste Oil Period Litres Total Litres Total Litres Total Litres Total Litres Total Litres Total Litres Total Litres Total Litres Total Litres Total Litres Resource Consumption Electricity Consumption in kwh Year Electricity Consumption in kwh , , , , , , , , , ,480 Electricity consumption increased by 32% in 2013 from 2012 figures. Heating Oil Consumption Year Heating Oil Consumption litres , , , , , , , , , ,947 Heating oil consumption increased by 9.6% in 2013 from 2012 figures. 9

11 Automotive Oil Consumption Year Automotive Oil Consumption litres , , , , , , , , , ,496 Automotive oil consumption decreased by 41% in 2013 from 2012 figures. 2.5 Environmental Incidents There have been no environmental incidents at the site in Environmental Complaints No complaints of an environmental nature have been issued to the company in the past year. A record file exists for the recording of environmental complaints, should any arise in the future. 10

12 3. Environmental Management 3.1 Schedule of Environmental Objectives & Targets OBJECTIVE 1 TARGET 1 AND IMPLEMENTATION DETAILS Reduce VOC emissions from spraying operations. The company will continue to strive to reduce VOC consumption. RESPONSIBILITY: Harry Gillanders TIMEFRAME: On-going OBJECTIVE 2 TARGET 2 AND IMPLEMENTATION DETAILS RESPONSIBILITY: Harry Gillanders To ensure emissions from the wood and oil boilers are kept below the licence limits at all times The controls placed on the wood boiler in 2004 will be carefully monitored to ensure that the boiler set-up maintains emissions below the licence limits, particularly for CO and NOx. TIMEFRAME: On-going OBJECTIVE 3 TARGET 3 AND IMPLEMENTATION DETAILS RESPONSIBILITY: Harry Gillanders TIMEFRAME: On-going Apply for the surrender of the IPPC licence Since obtaining the IPC Licence the company has decreased the volume of organic solvent coating materials used at the site as a result of changing from solvent based paints to water based paints and also due to a downturn in the level of sales for the site. The company intends to submit a Surrender of Licence Application that will satisfy the Agency. 11

13 3.2 Environmental Management Programme Report on EMP Proposal of Reduce VOC emissions from Spraying Operations The total tonnes of VOC used in 2013 decreased by 83% compared to 2012 figures. The volume of solvent based product used decreased by 58% compared to 2012 figures. This is the result of the company purchasing low solvent based paints. The company hopes to follow this trend in 2014 by increasing the use of water based and low solvent products to reduce VOC usage further. The company now fall well below the 10 tonnes per year of organic solvents licence figure and have done so since 2006, thereby falling outside the scope of IPPC licensing. 2. To ensure emissions from the boiler are kept below the licence limits at all times Automatic controls were placed on the boiler in In March 2004, prior to installing the controls, NOx emission rate was high. After the controls were installed the NOx limit was much reduced and all parameters were within the limits. Nitrogen Oxide results in the last monitoring event on site in March 2012 when corrected to 11% O2 were within the licence limits, but when Nitrogen Oxide results were corrected to 6% O2 they were over the IPC Licence limit. 3. Increasing waste segregation and reduction in the amount of waste going to landfill The amount of waste disposed to landfill has decreased dramatically in recent years, due to better waste management practices at the site, including reducing waste at source, recycling and re-using, where possible and also changes in waste treatment with a move away from disposal due to increasing landfill levy costs. In 2013 the volume of skip waste decreased by 19% on 2012 figures and most of this was incinerated rather than disposed to landfill. The company is still segregating and recycling all wastes generated, with the main effort being to stop waste generation at source. 12

14 3.2.2 EMP Proposal for 2014 The Environmental Management Program for 2014 is a continuation of that in 2013, with some inclusions. Environmental Management Program for Woodland Products Ltd OBJECTIVE 1 Reduce VOC emissions from spraying operations. TARGET 1 AND IMPLEMENTATION DETAILS The company will continue to strive to reduce VOC consumption. RESPONSIBILITY: Harry Gillanders TIMEFRAME: On-going OBJECTIVE 2 TARGET 2 AND IMPLEMENTATION DETAILS RESPONSIBILITY: Harry Gillanders To ensure emissions from the wood and oil boilers are kept below the licence limits at all times The controls placed on the wood boiler in 2004 will be carefully monitored to ensure that the boiler set-up maintains emissions below the licence limits, particularly for CO and NOx. TIMEFRAME: On-going OBJECTIVE 3 TARGET 3 AND IMPLEMENTATION DETAILS RESPONSIBILITY: Harry Gillanders TIMEFRAME: On-going Apply for the surrender of the IPPC licence Since obtaining the IPC Licence the company has decreased the volume of organic solvent coating materials used at the site as a result of changing from solvent based paints to water based paints and also due to a downturn in the level of sales for the site. The company intends to submit a Surrender of Licence Application that will satisfy the Agency. 13

15 3.3 Pollution Emissions Register Report on PER 2013 The statistics for usage of solvent based materials and water based materials at the site for 2013 and previous years are provided in the table below. Date No. of solvent based products used Amount of solvent based products - litres VOC total - tonnes Amount of water based products - litres Jan-Dec Jan-Dec , Jan-Dec , ,732 Jan-Dec , ,445 Jan-Dec , ,279 Jan-Dec , ,925 Jan-Dec , ,516 Jan-Dec , ,654 Jan-Dec , ,355 Jan-Dec , ,895 Jan-Dec , ,799 Jan- Dec , ,850 Jan- Dec , ,532 Jan-Dec , , PER Proposal for Calculate the total tonnage of VOC utilised in 2014 and compare this total with previous year s figure to see if it is increasing or decreasing, and provide explanations for the increase or decrease. 4. Licence Specific Reports 4.1 Noise Monitoring Report All IPPC monitoring at the site was halted in 2013 with the objective of surrendering the IPPC licence taking priority. This objective has also been the priority in 2014 and it is hoped that considerable progress can be made before the end of The results from the most recent noise monitoring conducted in 2011 were submitted with the 2011 AER. There have been no significant changes to operations at the site since the monitoring events in 2011; therefore results are expected to be similar to those recorded in 2011 which were licence compliant. No complaints relating to noise have been issued to the company in the past year. 14

16 4.2 Bund Testing Report A Bund Integrity Assessment was carried out on all bunds at Woodland Products Ltd. in August All bunds were deemed watertight and fit for the purpose intended. The Bund Integrity Assessment Report was included in the 2011 AER report. 4.3 Tank & Pipeline Inspection Report The company has a service agreement with Bord Na Mona for the maintenance of the Puraflo system. During this service the distribution pipework is examined. A service of the Puraflo system was carried out on the 17/02/12 by Bord na mona. 4.4 Dry Filter Spraybooth & Bagfilter Dust Abatement / Treatment Systems Summary Report Spray Booth Maintenance Dry back spray booth filters are changed regularly and the booths are hoovered out. The level of cleaning each spray booth receives is directly related to its usage. Some spray booths that are continuously used may be cleaned out weekly and others, which receive limited usage may be cleaned out every 2-3 weeks. A log of all spray booth maintenance is kept on-site. Dust Extraction System Cades Ltd., the supplier, service the dust extraction system. Maintenance personnel on site maintain the bag filters. A record of all maintenance is kept on site. 4.5 Package Treatment System Assessment Report The company has brought out a service agreement with Bord Na Mona for the maintenance of the Puraflo system. This was implemented on 8 May A service of the Puraflo system was carried out on the 17/02/12 by Bord na Mona. 15

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