Print & Display Limited, Cookstown Industrial Estate, Tallaght, Dublin 24. IPC Licence Registration No: 116

Transcription

1 Print & Display Limited, Cookstown Industrial Estate, Tallaght, Dublin 24. IPC Licence Registration No: 116 Annual Environmental Report 2016

2 Print & Display Limited, Cookstown Industrial Estate, Tallaght, Dublin 24. Re: IPC Licence Registration No: Annual Environmental Report 2016 The Annual Environmental Report 2016 describes the facility's performance and all data and information presented in the report has been checked and verified as being accurate. The quality of the information is assured to meet licence requirements. I authorise the report to be uploaded to the AER I PRTR Annual Environmental Reporting Website on behalf of Print & Display Limited. Signed:.. 11.f.~~. Michael Collins, Director of Operations Date: c:

3 Sheet : Facility ID Activities AER Returns Workbook 15/9/ :51 PRTR# : P0116 Facility Name : Print & Display Limited Filename : P0116_2016.xls Return Year : 2016 REFERENCE YEAR FACILITY IDENTIFICATION Parent Company Name Print & Display Limited Facility Name Print & Display Limited PRTR Identification Number P0116 Licence Number P Guidance to completing the PRTR workbook PRTR Returns Workbook Classes of Activity No. class_name - Refer to PRTR class activities below Version Address 1 80 Cookstown Industrial Estate Address 2 Tallaght Address 3 Dublin 24 Address 4 Dublin Country Ireland Coordinates of Location River Basin District IEEA NACE Code 1812 Main Economic Activity Other printing AER Returns Contact Name Dermot Moloney AER Returns Contact Address moloneyd@env.ie AER Returns Contact Position Consultant AER Returns Contact Telephone Number AER Returns Contact Mobile Phone Number AER Returns Contact Fax Number Production Volume Production Volume Units square metres of substrate printed per year Number of Installations 1 Number of Operating Hours in Year 3672 Number of Employees 41 User Feedback/Comments Web Address 2. PRTR CLASS ACTIVITIES Activity Number Activity Name 50.1 General 3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002) Is it applicable? No Have you been granted an exemption? No If applicable which activity class applies (as per Schedule 2 of the regulations)? Is the reduction scheme compliance route being used? 4. WASTE IMPORTED/ACCEPTED ONTO SITE Guidance on waste imported/accepted onto site PRTR# : P0116 Facility Name : Print Display Limited Filename : P0116_2016.xls Return Year : 2016 Page 1 of 2

4 Sheet : Facility ID Activities AER Returns Workbook 15/9/ :51 Do you import/accept waste onto your site for onsite treatment (either recovery or disposal activities)? No PRTR# : P0116 Facility Name : Print Display Limited Filename : P0116_2016.xls Return Year : 2016 Page 2 of 2

5 Sheet : Releases to Air AER Returns Workbook 15/9/ : RELEASES TO AIR Link to previous years emissions data PRTR# : P0116 Facility Name : Print & Display Limited Filename : P0116_2016.xls Return Year : /09/ : SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS RELEASES TO AIR Please enter all quantities in this section in KGs POLLUTANT METHOD QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION B : REMAINING PRTR POLLUTANTS RELEASES TO AIR Please enter all quantities in this section in KGs POLLUTANT METHOD QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year 03 Carbon dioxide (CO2) E ESTIMATE * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION C : REMAINING POLLUTANT EMISSIONS (As required in your Licence) RELEASES TO AIR Please enter all quantities in this section in KGs POLLUTANT METHOD QUANTITY Method Used Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year 330 Organic solvents M OTH sampling & mass balance * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button Additional Data Requested from Landfill operators For the purposes of the National Inventory on Greenhouse Gases, landfill operators are requested to provide summary data on landfill gas (Methane) flared or utilised on their facilities to accompany the figures for total methane generated. Operators should only report their Net methane (CH4) emission to the environment under T(total) KG/yr for Section A: Sector specific PRTR pollutants above. Please complete the table below: Landfill: Print & Display Limited Please enter summary data on the quantities of methane flared and / or utilised Method Used Designation or Description Facility Total Capacity m3 per hour additional_pollutant_no T (Total) kg/year M/C/E Method Code Total estimated methane generation (as per site model) 0.0 N/A Methane flared (Total Flaring Capacity) Methane utilised in engine/s (Total Utilising Capacity) Net methane emission (as reported in Section A above) 0.0 N/A PRTR# : P0116 Facility Name : Print Display Limited Filename : P0116_2016.xls Return Year : 2016 Page 1 of 1

6 Sheet : Releases to Wastewater or Sewer AER Returns Workbook 15/9/ : RELEASES TO WASTEWATER OR SEWER Link to previous years emissions data PRTR# : P0116 Facility Name : Print & Display Limited Filename : P0116_2016.xls Return Year : 15/09/ : SECTION A : PRTR POLLUTANTS OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER Please enter all quantities in this section in KGs POLLUTANT METHOD QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence) OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER Please enter all quantities in this section in KGs POLLUTANT METHOD QUANTITY Method Used Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year 303 BOD M CRM Hach Lange COD M CRM Hach Lange Suspended Solids M CRM Filtration/Gravimetric Sulphate M CRM Hach Lange Detergents (as MBAS) M CRM Hach Lange Silver M CRM ICP-MS * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button Link to previous years emissions data Page 1 of 1

7 T/Year Description and Licence / Permit No. of Recoverer / Disposer / Broker Address of Recoverer / Disposer / Broker Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY) Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY) Sheet : Treatment Transfers of Waste AER Returns Workbook 15/9/ :0 5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE PRTR# : P0116 Facility Name : Print & Display Limited Filename : P0116_2016.xls Return Year : /09/ : Please enter all quantities on this sheet in Tonnes 3 Transfer Destination European Waste Code Hazardous Quantity Quantity (Tonnes per Year) of Waste Method Used Waste Treatment Operation M/C/E Method Used Location of Treatment Name Haz Waste : Name and Licence/Permit No of Next Destination Facility Non Haz Waste: Name and Licence/Permit No of Recover/Disposer Within the Country No wastes not otherwise specified D1 M Weighed Offsite in Ireland Greenstar,W Within the Country No wooden packaging R13 M Weighed Offsite in Ireland Greenstar,W Within the Country No paper and cardboard R3 M Weighed Offsite in Ireland Greenstar,W Haz Waste : Address of Next Destination Facility Non Haz Waste: Address of Recover/Disposer Road 3A,Greenogue Industrial Estate,Rathcoole,Co. Dublin,Ireland Road 3A,Greenogue Industrial Estate,Rathcoole,Co. Dublin,Ireland Road 3A,Greenogue Industrial Estate,Rathcoole,Co. Dublin,Ireland Name and License / Permit No. and Address of Final Recoverer / Disposer (HAZARDOUS WASTE ONLY) Actual Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY) To Other Countries Yes 3.89 solvents D10 M Weighed Abroad EcoSafe Systems Ltd,W54-02 Unit 1A Allied Industrial Estate, Kylemore Road,Ballyfermot,Dublin 10,Ireland Unweltservice Lindsenschmidt KG,AZ : ,Krombacher Krombacher Strabe,42- Strabe,57223,Kreuzal- 46,Kreuzal- Krombach,".",Germany Krombach,".",Germany * Select a row by double-clicking the Description of Waste then click the delete button PRTR# : P0116 Facility Name : Print Display Limited Filename : P0116_2016.xls Return Year : 2016 Page 1 of 1

8 Contents Page 1 INTRODUCTION 1 2 GENERAL OVERVIEW OF THE ACTIVITY Company Profile Location and Environmental Conditions Printing Processes Principal Emissions 4 3 DATA Emissions to Atmosphere Emissions to Sewer Surface Water Runoff Noise Waste Management Energy and Water Usage Environmental Incidents and Complaints Pollution Emission Register 14 4 ENVIRONMENTAL MANAGEMENT Site Management Environmental Management System Human Resources and Training Environmental Objectives and Targets Environmental Management Programme 17 LIST OF ATTACHMENTS Attachment I Annual Waste Arising 2016 Attachment II Environmental Objectives and Targets Review, June 2016 Attachment III Implementation of Environmental Management Programme 2016 Attachment IV Proposed Environmental Management Programme 2016/2017

9 Annual Environmental Report INTRODUCTION Print & Display Ltd. is licensed under the Environmental Protection Act, 1992 to operate a screen printing business at Cookstown Industrial Estate, Tallaght, Dublin 20. The licensed activity is situated within the Cookstown Industrial Estate, approximately two kilometres to the southeast of Newlands Cross. The Print & Display Ltd. facility is a Class 12.2 activity, under the First Schedule of the EPA, Act The Integrated Pollution Control (IPC) licence register number for the activity is 116. Condition of the Print & Display Ltd. facility s IPC Licence requires the Company to produce an Annual Environmental Report (AER) and to submit it to the Environmental Protection Agency (EPA). This report constitutes the AER for the licensed period 1 January to 31 December The format of this report is in general compliance with the EPA s 2000 Guidance Note for AERs. All the data and information presented in this report has been checked and certified as being accurate. The quality of the information is assured to meet licence requirements Print & Display Ltd. Page 1 of 17

10 Annual Environmental Report GENERAL OVERVIEW OF THE ACTIVITY 2.1 Company Profile Print & Display Limited operate a screen printing business which manufactures printed material for use in advertising, e.g. posters, point of sale displays etc. The existing plant was established in 1988 in an industrial unit on the Cookstown Industrial Estate. Approximately 40 people are employed at the plant and most of the output is for the home market, however, a small proportion is for the export market. 2.2 Location and Environmental Conditions The Print & Display facility is subject to IPC licensing due to the fact that the company currently uses coating materials in processes with a capacity to use at least 10 tonnes per year of organic solvent. Located within the industrial estate, the printing plant is situated a considerable distance from any residential areas and the plant causes no known significant environmental impact. Print & Display Ltd. was granted an IPC licence on 22 January Waste disposal, noise control, atmospheric emissions and discharges of effluent and surface water run-off are all regulated by the Company s IPC licence. Prior to being licensed under the IPC regime Print & Display Ltd. was regulated by Dublin County Council under a licence to discharge trade effluent. There are no discharges made to ground and surface run-off is discharged to the local authority system. All waste is disposed of or recycled off-site and no on-site waste disposal or recovery is undertaken. The plant discharges atmospheric emissions directly to air, however, the impact of these emissions is not significant. Print & Display Ltd. Page 2 of 17

11 Annual Environmental Report Printing Processes The Print & Display screen printing plant utilises manufacturing processes which have been designed to apply ink to a variety of substrates including: paper, board and vinyl etc. These finished printed materials are used in advertising e.g. point of sale displays, billboards etc. There are a number of distinct processing stages involved in the production of the printed material. These steps can be regarded as unit operations, as follows: Design/Artwork Graphic/Film Production Preparation Process Printing Process Finishing and Dispatch. In screen printing, the screen with the required image (stencil) is loaded into the printing machine. All of the P&D printing lines are either fully automatic or semi automatic. The material to be printed is loaded into the feeder. The feeder then presents the material to the printing machine. In the printing unit, ink is forced through the image area of the screen mesh and onto the material (substrate) by the action of rubber squeegees. The substrate with the wet ink image then passes to the drying stage where drying is achieved by either hot air or by UV light, depending on the ink system in use. The final stage of printing involves stacking the dried prints on a pallet. After the screen has been used in the printing machine, excess ink is removed and returned to the ink container. The used screen is then returned to the Preparation Department for washing prior to being reused. Screen washing is carried out in an automatic screen washing machine (Screen Washer). Print and Display operate one of the most advanced screen printing plants in Ireland having installed a five-colour and a four-colour automatic printing line along with a series of specialist digital machines. In the state-of-the-art five-colour and four-colour lines, the material to be printed is generally loaded into the machine only once and passes through a series of printing units and driers. This once through process has major advantages over conventional systems, where the material to be printed is loaded into the machine repeatedly for the application of one ink colour at a time. Print and Display also operate digital printing machines which produce printed materials directly from digital format. There is thus no screen preparation involved and no chemicals used in graphic production with the new digital printing process. Raw material usage is therefore reduced and there will be reductions in hazardous and packaging waste arising from the Preparation and Graphics Departments. Print & Display Ltd. Page 3 of 17

12 Annual Environmental Report Principal Emissions A wide range of raw materials are used in the various different stages of processing. The screen preparation process involves the use of screen washing solutions, photoemulsion and screenfiller. Inks, display board and miscellaneous substrates constitute the predominant raw materials which are used during printing. Other materials used in the printing process include: paper, self-adhesive vinyl, plastics, and varnishes. The Finishing and Dispatch Departments utilise a range of raw materials which include printed goods, packaging materials, adhesive tapes, etc. The principal environmental emissions from the plant arise from the use of screen washing chemicals and solvent based inks. These emissions are mainly organic solvents which are evolved and discharged directly to atmosphere, via licensed emission points. Process effluent from the Print & Display Ltd. facility arises primarily from the screen washing area. This effluent is discharged to the foul sewer via an interceptor trap on the north-western side of the Print & Display Ltd. site (Licensed Emission Point SE1). There are no waste treatment facilities at the plant and no atmospheric abatement plant or effluent treatment systems are warranted. On this basis, the plant is relatively simple to manage and Print & Display Ltd. operates and maintains an Environmental Management System in line with the requirements of the IPC licence. There is currently one licensed atmospheric emission point which is active at the facility and one licensed effluent discharge point. Details of the overall emissions are provided in Section 3 of this report. Print & Display Ltd. Page 4 of 17

13 Annual Environmental Report DATA All of the data presented in this section of the report is based upon independent monitoring undertaken on behalf of Print & Display Limited, unless otherwise stated. The Agency and South Dublin County Council also monitor emissions from the facility and there is generally a high degree of consistency between the various monitoring data. 3.1 Emissions to Atmosphere The principal environmental emissions from the printing plant arise from the use of inks and screen washing chemicals. These emissions are mainly in the form of organic solvents which are evolved and discharged directly to atmosphere. Table Licensed Atmospheric Emission Points: Emission Point Source of Emission A 1 Composite Printing Emission A2 Side-Wall Printing Machine (not operational) A3 Screen-Washer (not operational) The Side-Wall Printing Machine emission point (A2) has been decommissioned for a number of years and the use of solvent based cleaning solutions in the screen-wash bay has been phased out. This has effectively made emission point A3 redundant and during 2016, the A3 emission point was not operational. Details of the Print & Display atmospheric process emissions for 2016 are presented in Table overleaf. The data is based on the monitoring undertaken on behalf of the company by Environmental Scientifics Group. The sampling and analytical methods involved collecting representative samples and analysing these in situ by Flame Ionisation Detection using a Thermo- FID. Print & Display Ltd. Page 5 of 17

14 Annual Environmental Report 2016 During 2016, there was a 100% level of compliance with the atmospheric emission limit values at A1. This maintains the 100% compliance standard since A summary of the annual atmospheric emission details is presented in Table Table 3.1.3: 2016 Atmospheric Process Emissions. Emission Point 2016 Mass Emission (kg VOC per annum) A1 375 The data in Table is based on the mean emission monitoring results (Environmental Scientifics Group data) and a mean run time of 3672 hours per annum. Print & Display Ltd. Page 6 of 17

15 Annual Environmental Report Emissions to Sewer Process effluent from the Print & Display Ltd. facility arises primarily from the screen washing area. This effluent is discharged to the foul sewer via an interceptor trap on the north-western side of the Print & Display Ltd. site (Emission Point SE1). Trade effluent is generated in the screen wash area of the plant. While a dedicated screen cleaning machine has been used in this area to clean the screens, the machine was taken out of production in June This was due to the fact that most printing is now undertaken on the digital machines and any occasional screen washing is now undertaken manually. For the purpose of comparing the annual mass emissions, the total process effluent generated at the facility (based upon meter readings and the annual water consumption) was assumed to be an average of 8.61 m 3 per day (up to 2013). Although there has been a noticeable reduction in the volume of trade effluent, this mean daily discharge was previously used to compute the annual discharge, based on 255 working days per annum in the screen wash area. Details of the process effluent emissions for the period 2013 to 2016 are presented in Table This data was computed using the quarterly compliance monitoring results for these years. Analysis of quarterly grab samples was undertaken and based on the mean concentrations and daily discharge rates, the annual mass emission was computed. During 2016 sampling and analysis was undertaken by Independent Laboratory for a range of parameters on four separate days. These data have been evaluated and the mass emissions have been calculated using an average discharge of 6.27 m 3 per day through SE1. It is important to note that this volumetric discharge is based on the total water use and, significantly, it excludes all domestic effluent. Since the automatic screen cleaning system has been disused (June 2016) the actual volumetric discharge has reduced significantly and therefore the presented data over-estimate the 2016 SE1 emissions. During 2017 volumetric flow rates will be determined for SE1. Table 3.2.1: Waste Water Emissions 2013 to Parameter 2013 Mass Emission (kg per annum) 2014 Mass Emission (kg per annum) 2015 Mass Emission (kg per annum) 2016 Mass Emission (kg per annum) Licensed Mass Emission (kg per annum) BOD ,500 COD ,000 Suspended ,760 Solids Sulphate ,140 MBAS ,190 Silver < < 0.03 < Print & Display Ltd. Page 7 of 17

16 Annual Environmental Report 2016 It can be seen from the data in Table that, compared with the licensed mass emission, the overall discharge is relatively small. During 2016 there were no non-compliances with any of the effluent limit values. Overall the environmental impact of the plant s effluent is not considered to be significant. This is because the effluent from the plant is treated (along with all of the industrial estate effluent, and Dublin s municipal waste water) in the city s effluent treatment plant at Ringsend, Dublin 4. Print & Display Ltd. Page 8 of 17

17 Annual Environmental Report Surface Water Runoff Storm water arising on the Print & Display Ltd. facility is discharged into the County Council surface water drainage system. The combined storm water discharge exits the Print & Display Ltd. site via a manhole which is located at the north-eastern corner of the facility. In accordance with the licence requirements, samples of surface water were previously analysed for ph and COD on a biannual basis. Two sampling points (SW1 and SW2) were designated for monitoring but difficulties with off-site contamination of the surface water entering the P&D site has caused intermittent monitoring problems. In 2016, SW1 was sampled and analysed for COD and ph, with no evidence of significant contamination arising on the site. Grab samples of surface runoff are taken periodically for visual inspection. The surface water monitoring programme has not detected any spillage or contamination arising from the plant. In addition, the visual monitoring programme has not necessitated any further assessment or monitoring. Print & Display Ltd. Page 9 of 17

18 Annual Environmental Report Noise The Print & Display Ltd. facility is located within a busy industrial estate and is removed and well screened from any noise sensitive location. The plant does not cause any significant impact on the noise environment and for this reason there is no requirement to undertake environmental noise monitoring at the plant. Print & Display Ltd. Page 10 of 17

19 Annual Environmental Report Waste Management All waste management operations are regulated at the site in accordance with the terms and conditions of the Company s IPC licence. There are a number of distinct waste streams generated throughout the plant, including: Miscellaneous non-segregated waste Waste solvent Waste cardboard Waste timber. In recent years major improvements in the on-site management of waste have occurred. The handling and segregation of waste have been improved with modifications to the on-site bailing and compacting systems and with on the job training. The details of the annual waste sent for off-site disposal in 2016 are presented in Table (Attachment I of this report) and a summary of the total annual tonnage of hazardous and nonhazardous waste for the period 2011 to 2016 is presented in Table Table 3.5.1: Waste Arising Data (tonne) (tonne) (tonne) (tonne) (tonne) (tonne) Hazardous Waste Non-Hazardous Waste There have been a number of significant changes at the plant in recent years and variations in production output arise from time to time. For these reasons, caution is necessary when drawing conclusions from the above data and it may not be possible to directly compare data from one year with that of another. A review of the classification of wastes has been undertaken on site and during 2017 consultations will be held with waste contractors regarding amendments to any of the waste classification codes. For the purpose of this AER, the original waste classification codes have been maintained. Training on waste management will be provided to on-site staff and improved signage for bins will be provided during Print & Display Ltd. Page 11 of 17

20 Annual Environmental Report Energy and Water Usage Details of electricity consumption, natural gas and water consumption for the years 2013 to 2016 are presented in Table below: Table 3.6.1: Utilities Summary Report: Utility 2013 Consumption 2014 Consumption 2015 Consumption 2016 Consumption Electricity (kwh) 911,689 1,006,957 1,020, ,435 Space heating natural gas (kwh) 824, , , ,350 Water (m 3 ) As with waste management data, direct comparisons cannot always be made between one year and another. Print & Display Ltd. Page 12 of 17

21 Annual Environmental Report Environmental Incidents and Complaints The only environmental incident which has ever arisen at the plant related to the discharge of effluent and atmospheric emissions which did not fully comply with all of the licence limits. There were two such incidents during 2014 (relating to effluent samples) and all subsequent sampling and analysis of emissions have demonstrated the plant to be fully compliant. Print & Display Ltd. have a documented procedure for recording environmentally related complaints as part of their Environmental Management System. There were no such complaints received since the company was granted its IPC licence up to the end of December Print & Display Ltd. Page 13 of 17

22 Annual Environmental Report Pollution Emission Register Detailed PER assessment work was undertaken during the initial years of the company s IPC licence. The main emissions arising from the activity are the organic solvents which are discharged directly to atmosphere. These organic solvents are used in the manufacture of ink and they are evolved during the ink drying stage of the printing process. In addition, screen wash solutions are mainly solvent based and these are emitted to atmosphere during the screen cleaning process. A wide range of solvents are used in the manufacturing of the Print & Display raw materials (predominantly inks and screen washing chemicals). For this reason it is necessary to focus upon the total VOC emissions, as opposed to the individual solvent emissions or the emission of specific compounds. Some GC/MS work has been undertaken on samples collected at the plant, however, a huge range of organic solvents was detected and these solvents were difficult to quantify individually. In addition, data furnished from the raw material suppliers in the form of MSDSs do not accurately identify the full range of solvents present in some of the raw materials. Sampling of effluent suggests that there are negligible losses of solvent to sewer and the solvent losses to product have not been quantified. While the bulk of the VOC is discharged from the licensed emission point (A1), the remainder is evolved as fugitive emissions. It was previously agreed with the Agency that the facility would not be subject to a detailed PER assessment. However, the principal VOCs have been tracked by simple mass balancing and a summary of the data is presented below. For comparison purposes, the VOC consumption data for the period 1999 to 2016 is presented. Table Summary of solvent consumption Year Total Solvent Consumption (kg) , , , , , , , , , , , , , , , , , Print & Display Ltd. Page 14 of 17

23 Annual Environmental Report 2016 There has been a marked decrease in the total solvent consumption over the period 2011 to This is consistent with a reduction in plant throughput and the increase in digital printing. Details of the PER data for 2016 are presented below. Table 3.8.2: 2016 PER Data. Pollutant Total Organic Carbon Usage (kg solvent) per year Air Emission (kg TOC per annum Fugitive and point source) MOM Effluent Emission (kg VOC per annum) MOM Waste (kg VOC per annum) MOM M & C 0 C 3885 M Print & Display Ltd. Page 15 of 17

24 Annual Environmental Report ENVIRONMENTAL MANAGEMENT 4.1 Site Management The Managing Director is ultimately responsible for site management and control. Specific responsibilities are delegated through the Operations Manager and the Plant Manager. The Plant Manager assumes the role of Environmental Manager and as such is responsible for environmental and safety management including all monitoring and reporting functions. Day to day environmental management activities are carried out in conjunction with an Environmental Management Committee. 4.2 Environmental Management System Print & Display Ltd. does not have a formalised Environmental Management System which meets the criteria specified by ISO However, Print & Display Ltd. does operate and maintain an Environmental Management System in line with the requirements of the IPC licence. 4.3 Human Resources and Training Under Condition 2.7 of the Company s IPC licence Print & Display Ltd. are required to establish and maintain procedures for identifying training needs, and for providing appropriate training, for all personnel whose work can have a significant effect upon the environment. Print & Display Ltd. is also required to provide appropriate training for personnel who perform certain tasks which have significant environmental implications. In response to this requirement, Print & Display Ltd. have undertaken a series of training initiatives in the past including: in-house Environmental Training Workshops and the participation in external workshops and seminars. Budgetary constraints and the implementation of a staff redundancy programme in 2016 have limited recent environmental training undertaken at the plant. However, on-the-job training has been undertaken in It is planned that this will be supplemented with additional training during 2017 and this is addressed in the proposed Environmental Management Programme. Print & Display Ltd. Page 16 of 17

25 Annual Environmental Report Environmental Objectives and Targets Condition of the Print & Display IPC licence requires a schedule of Environmental Objectives and Targets to be drawn up. The Environmental Objectives and Targets form the basis of an Environmental Management Programme at the facility. Considerable resources have been devoted to environmental management over the years and major progress has been achieved in implementing the firm s Environmental Objectives and Targets. Many of the original targets had a time-frame of more than three years and many of the current Environmental Objectives and Targets are a natural extension of the original ones. A review of the Environmental Objectives and Targets was undertaken during June 2016 and this is documented in Appendix II. There have been no major changes to the Environmental Objectives and Targets and it is proposed that a review of this is undertaken in January Environmental Management Programme An Environmental Management Programme (EMP) proposal was developed for the Print & Display Ltd. facility under Condition of the IPC licence. Details of the implementation of the EMP are presented on a project by project basis in a report presented in Attachment III. A total of nine projects were proposed for the 2016/2017 EMP. Six of these have been successfully implemented, however, due to a range of factors three projects were partly completed and some of the project work has been carried over into In certain cases project work will need to be repeated from year to year and some are still on-going. An EMP proposal has been drafted for 2017/2018 (Attachment IV). Print & Display Ltd. Page 17 of 17

26 Attachment I Annual Waste Arising

27 Table Annual Waste Arising Waste Material EWC Code Hazardous (yes or no) Quantity (Tonnes) per annum Method of Disposal/Recovery Location of Disposal/Recovery Name of waste Disposal/Recovery Contractor Miscellaneous office and plant waste (not segregated) No Landfill (D1) Road 3A,Greenogue Industrial Estate, Rathcoole, Co. Dublin. Cardboard No Recycling (R3) Road 3A,Greenogue Industrial Estate, Rathcoole, Co. Dublin. Waste timber packaging No Recycling (R13) Road 3A,Greenogue Industrial Estate, Rathcoole, Co. Dublin. Waste solvents * yes 3.89 Incineration (D10) Unit 1A, Allied Industrial Estate, Kylemore Rd., Ballyfermot, Dublin 10. Greenstar Limited Greenstar Limited Greenstar Limited EcoSafe Systems Ltd

28 Attachment II Environmental Objectives and Targets Review, June 2016

29 Print & Display Ltd. 80, Cookstown Industrial Estate, Tallaght, Co. Dublin IPC Licence Registration No: 116 Environmental Objectives and Targets Review June 2016

30 Contents Page 1. INTRODUCTION 1 2. REVIEW OF THE OBJECTIVES & TARGETS 2 3. ITEMISED OBJECTIVES & TARGETS 4 4. CONCLUSION 5 APPENDIX 1 TABLE 1: Summary of objectives and targets review.

31 1. INTRODUCTION: Print & Display Ltd. are licensed under the Environmental Protection Act 1992 to carry on a screen printing operation with a capacity to use at least 10 tonnes per annum of organic solvents. Condition of the Company s Integrated Pollution Control (IPC) Licence requires the licensee to prepare a schedule of objectives and targets. Condition also requires the objectives and targets to be reviewed and amendments to be notified to the Agency, as part of the AER. This submission presents a review of the company s objectives and targets and sets out the proposed amendments for Environmental Objectives and Targets Review - June 2016 Page 1 of 5

32 2. REVIEW OF THE OBJECTIVES AND TARGETS: A series of principal objectives and targets were initially established in These objectives and targets related to the following issues: The implementation of a raw material substitution programme. The evaluation of alternative raw materials for the screen wash area. The assessment of the ventilation needs of the printing plant. Consulting with the Agency in connection with the licensing implications of all the plant s development plans. The development of appropriate monitoring systems for the printing plant. Investigating means of minimizing waste. Upgrading the plant s environmental documentation system. Reviewing the environmental training and awareness needs of the facility. Considerable progress has been made with regard to all of these targets and objectives, however, some have long term implications and have been adopted form year to year. Once the facility s atmospheric and effluent emissions were successfully reduced and controlled, secondary areas of attention have been targeted for environmental improvement. In particular, in-house training and the development of systems to ensure full compliance became the focus. From time to time the Environmental Documentation System needs to be updated and this work has featured in the EMP. In addition, a periodic review of the Enforcement Category is also undertaken in line with EPA guidance. New objectives which arose in 2011 related to an assessment of on-site bunds and an evaluation of potential obligations arising from the use of fluorinated greenhouse gases and ozone depleting substances. Additional bund management procedures have been developed in and these were reviewed in 2015 along with the development of a new bund testing regime. Resource efficiency and waste minimisation initiatives have been undertaken including an assessment conducted by Green-business. Their Resource Efficiency Assessment (REA) has focussed on waste minimisation, water minimisation, energy minimisation, raw material optimisation and packaging optimisation and further consultations regarding the REA findings are planned. Environmental Objectives and Targets Review - June 2016 Page 2 of 5

33 From January 2014, the EPA required that emissions monitoring work at EPA licensed sites must be undertaken by an ISO accredited organisation. Consultations were held with suitably accredited contractors and appropriate documentation and management systems need to be put in place to transfer and oversee the new monitoring arrangements. Environmental Objectives and Targets Review - June 2016 Page 3 of 5

34 3. ITEMISED OBJECTIVES AND TARGETS: A series of objectives and targets has been developed for 2014/2016. Some of these are a natural continuation of the earlier targets and some have arisen out of new developments. The objectives and targets are set out in tabular form in Appendix I. Environmental Objectives and Targets Review - June 2016 Page 4 of 5

35 4. CONCLUSION: A summary of the objectives and targets is set out in tabular form in Appendix I. The licensee has reviewed these objectives and targets for the 2015 AER. In view of a number having a lifespan of a few years, an internal review will be undertaken during December Environmental Objectives and Targets Review - June 2016 Page 5 of 5

36 APPENDIX I Table 1: Summary of Objectives and Targets Review.

37 TABLE 1: Summary of objectives and targets review. OBJECTIVES PRIMARY GOALS PRIMARY DEADLINES/ ACCOMPLISHMENTS 3.1 The licensee will review all waste disposal operations. 3.2 The licensee will evaluate all waste labelling and storage arrangements. A review of all waste contracts was completed and new arrangements and recycling outlets were identified and the necessary approvals were sought through the Agency. Waste contractors have also been subject to a questionnaire and/or to an audit or inspection where appropriate. An evaluation of the current storage and labelling arrangements for waste will be undertaken with a view to reducing hazards and preventing pollution. Any necessary improvements will be made to ensure that 100% of all waste storage vessels are properly labelled and appropriate for the waste material. Major improvements in waste segregation and disposal have been implemented. A number of new issues and contracts have arisen over the past number of years and new waste management objectives were also established. (Refer to objective 3.6 and 3.14). Approval has been sought for new contractors in 2011 and consultations have been undertaken with the Agency and with Dublin City Council regarding waste licences and Waste Disposal permits of certain contractors. A review of the contracts was made in Another review will be made in This project was undertaken during 2009 and additional labelling and storage arrangements have been put in place. Bund tests were completed in 2012 and during Periodic checks on operational practices and bund labelling will be maintained during 2016.

38 TABLE 1: Summary of objectives and targets review (continued). OBJECTIVES PRIMARY GOALS PRIMARY DEADLINES/ ACCOMPLISHMENTS 3.3 The licensee will evaluate the current surface water monitoring programme and make any necessary improvements. 3.4 The licensee will examine the screen-wash floor to determine the extent of any necessary improvements. Any necessary upgrade to the floor will be completed at the soonest possible plant shut-down. 3.5 The licensee will evaluate all effluent generating processes and develop appropriate monitoring systems for the screen wash area. The company is required to monitor surface water in accordance with Condition 9.1 of the IPC licence. The sampling and reporting procedure is in need of updating. The sampling and the reporting procedures will be reviewed and updated to ensure full compliance with the licence requirements. The project was completed during 2010 and will be the subject of a review during A review of screen-wash area floor to determine the extent of any necessary improvements will be undertaken. The aim will be to ensure that the grouting is repaired to prevent seepage of cleaning agents from this area. The effluent ELVs are expected to be revised in accordance with Dublin County Council consent. It is envisaged that recent improvements will ensure full compliance; however, this will require detailed effluent monitoring work. Where necessary additional measures will be adopted to ensure consistent compliance with all licence limits. This objective has been updated as a result of issues of off-site surface water contamination. (refer to Objective 3.9) A decision to modernise the entire screen washing system was taken and the resulted in an Environmatic Screen washing system being installed during The screen wash bay is no longer used to any extent and the potential for significant seepage does not exist anymore. The Environmatic Screen washing system has resulted in consistently good effluent quality. During 2009 a potential issue arose due to a build up of sludge in the interceptor trap. Arrangements were subsequently made in consultation with The Agency for appropriate removal and off-site disposal. In May 2010 an effluent sample was reported to have a ph of 4.4 (limit 6 10). This matter has been investigated and no apparent cause has yet been identified. Additional ph sampling is being undertaken at the facility and systems to minimise the number of screens which are spot cleaned have been developed. A procedure which regularly rinses out the stencil washing reservoir was also developed in 2015.

39 TABLE 1: Summary of objectives and targets review (continued). OBJECTIVES PRIMARY GOALS PRIMARY DEADLINES/ ACCOMPLISHMENTS 3.6 The licensee undertakes to investigate means of minimising waste. 3.7 The licensee will upgrade the plant s environmental documentation system. 3.8 The licensee will review the environmental training and awareness needs of key personnel. A series of measures will be adopted to ensure that waste is avoided at source and that unavoidable waste is recycled or reused where possible. Waste minimisation practices were identified by closely collating and benchmarking waste output for individual print runs. Improvements were subsequently phased into the activity over a period of years and P&D set itself a target to reduce the tonnage of landfilled waste by 5%. During 2012 efforts will be made to reduce waste arising from ink bottles. The existing environmental documentation system will be reviewed and appropriate improvements to the documentation system will be made. It is envisaged that key parts of the EMS will require ongoing documentation changes and updates. During 2010 a register of all standard operating procedures (SOPs) will be prepared and any necessary updates will be made. A review of key staff s environmental awareness and training will be completed. A programme will be developed to ensure that all relevant personnel are provided with appropriate training. A series of waste minimisation measures were adopted and during 2007 a detailed waste packaging audit was undertaken. This concluded that the facility was in compliance of its packaging waste obligations. P&D does not believe that there are further improvements to be made although a review of waste management options will be undertaken in consultation with waste contractors. During 2012 consultations were made with suppliers regarding a take back scheme for ink bottles. This is periodically reviewed and options to reduce packaging are evaluated on an intermittent basis. An evaluation and review of the documentation system was made 2013 and updates were implemented in surface water and bund management. Additional documentation updates were implemented during 2014 and 2015 and another review will be completed before the end of December An environmental training needs assessment has been completed for key staff. A training programme was implemented between 2011 and June Additional training will be completed before the end of December 2016.

40 TABLE 1: Summary of objectives and targets review (continued). OBJECTIVES PRIMARY GOALS PRIMARY DEADLINES/ ACCOMPLISHMENTS The existing drainage system was examined and improvements to the system were made, where necessary. Questions have been raised about where certain drains discharge to and whether any run-off emanates from the adjacent sites. One of the main objectives was to determine precisely where all drains discharge. An up to date site drainage plan was compiled. Subsequent consultations with South Dublin County Council have confirmed that contaminated surface water enters the P&D site from other parts of the industrial estate and this gives rise to a difficult monitoring scheme which needs to be updated. 3.9 The licensee will review the site drainage system and any necessary improvements will be made The licensee will review the potential for recycling screen wash solvent on-site. The Environmatic Screen washing system has resulted in consistently good effluent quality and it has reduced the emissions to atmosphere. An evaluation of ways to reduce raw material usage will be evaluated and in particular the benefits of solvent recovery will be assessed. Consultations will be held with equipment suppliers and with the EPA and the environmental benefits of available systems will be assessed. In the event that a viable system can be sourced, prior notification will be given to the Agency and all safety and environmental issues will be investigated. Issues regarding the discharge of surface water from other sites have arisen. Relatively small volumes of surface water arise on the P&D site, but the combined surface water of the industrial estate passes though the P&D drain. This project was implemented in 2009 and some modifications in the surface water monitoring procedure were called for during 2010 (see Objective 3.3). A formal request to modify the surface water monitoring programme was made in July 2012 following further consultations with South Dublin County Council. Additional efforts will be made to close off this issue during This project was originally commenced in April 2007 and was fully completed by the purchase and commissioning of the new Environmatic Screen wash system.

41 TABLE 1: Summary of objectives and targets review (continued). OBJECTIVES PRIMARY GOALS PRIMARY DEADLINES/ ACCOMPLISHMENTS 3.11 An energy conservation programme and awareness strategy will be developed for the company The licensee shall establish formal procedures to ensure that the requirements of the IPC licence are being complied with The licensee shall review of the enforcement category for the facility in consultation with the EPA A review of all waste disposal contracts will be made. Good housekeeping practices and energy conservation initiatives will be introduced. An internal review off all IPC licence conditions and schedules will be undertaken. A series of checklists and questionnaires will then be developed to facilitate P&D personnel to undertake internal audits. A review of the EPA s guidance will be made. All pertinent data will be compiled and consultations will be held where necessary. An electronic submission will be made to the Agency based upon the 2009 AER data. During 2010 the acquisition of Veolia Environmental Services by Greenstar Limited has proceeded. In addition, P&D has evaluated the suitability of certain waste contractors and this may result in new outlets being used for waste disposal. These developments require a formal notification to the Agency and/or an update of internal documentation systems. Ongoing energy consumption data has been maintained during Staff awareness and training initiatives will be introduced where necessary. During 2012 energy minimisation initiatives were pursued by eliminating leaks and ensuring that compressors run at optimum efficiency. An ongoing review of compressor performance is undertaken at the plant. An internal audit of the facility was commenced in 2011 and checklists were developed to remind staff of their environmental obligations. Internal audits now proceed on an annual basis as part of the preparation work for the AER. The next audit will be completed in Notification that guidance has been issued was received by P&D in July 2010 (RBME guidance). An annual RBME submission is now made to the Agency. The project commenced during April 2011 and consultations were made with the EPA in 2013 regarding the approval of new waste contactors. In order to provide greater flexibility, further consultations may be made regarding contractors who have not as yet been approved. This will proceed again during 2016 as required.