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1 Attachment NE Environmental Considerations and BAT The following BAT considerations/measures are presented: Environment Management As part of the EMS a schedule of significant environmental aspects was identified by assessing all operations and reviewing cleaner production methods and the reduction and minimisation of waste. A schedule of Objectives and Targets was drawn up and implemented as part of the Environmental Management Programme. In drawing up this schedule all aspects of the business was examined and improvement projects developed under the following headings: > Emissions to Atmosphere > Emissions to Sewer > Non-hazardous Waste > Hazardous Waste > Water Management > Energy Management > Process Improvement > Noise Emissions > Emissions to Groundwater A report on the progress of this programme is prepared and submitted as part of the Annual Environment Report. A planned programme of further improvements is drawn up for the following year and also included in the AER for approval. Progress over the last five years of the programme is summarised below. Emissions to Atmosphere Refer to attachment El.A Emissions to Sewer > An abatement unit was fitted to the final rinse tanks from the Cadmium process. This closed loop system eliminates emissions to sewer (SE2) from the Cadmium in the Electroplating Shop. > A new oil interceptor was installed on the sewer emission line (SE3) from the Garage operation and the vehicle fuelling area. > A silver recovery unit was installed on the film processing unit in the Non Destructive Test section to eliminate silver discharges to sewer (SE2). > A revised procedure for washing aircraft landing gear and wing flaps, which become contaminated with grease, dirt and oil, was drawn up. This procedure requires heavy grease, dirt and oil to be wiped off with cloths and disposed as solid waste, before power washing with hot eater. This process reduces the amount of discharges of heavy metals and oil fats and greases to all sewer lines. P Spill kits are strategically placed around the hangars and workshops to use for immediate clean up of spills. P An Environment Emergency Reaction Plan was drawn up and circulated to all staff to minimise emissions to sewer in the unlikely event of a major incident.

2 Non-hazardous Waste Management > Creation of a non-hazardous waste segregation1 storage compound > Increased waste diversion from landfill > Re-establishment of the Garage Environmental1 Waste Committee > Reuse of waste packaging material from customers > Upgraded waste collection > Improved waste documentation system > Reduction from two compactors going to landfill to one compactor Hazardous Waste Management P Improved waste documentation system > Waste segregation upgraded and extended to other areas > Increased usage of bunding for drums of chemicals P Diversion of targeted waste streams away from landfill (i.e. aerosol cans, oil contaminated waste) P Introduction of the Halon 1301 Recycler (HAL). To ensure safe removal of Halon 1301 from aircraft fire extinguishers during service > Introduction of non-flow drag out tanks in the plating shop to replace the free flowing rinse water system. The drag-out tanks incorporate plate out & ion exchange filters to remove metals from solutions P Introduction of a mobile vacuum waste oil unit to remove the waste oil from the oil drip trays in the garage > Creation of chemical database > Upgrading of hazardous waste labelling system a Reuse of waste Aviation Fuel as a fuel substitute k New oil interceptor for the Garage building and surrounding areas P Analysis of structural sealant (PR1436) usage showed a large amount of waste. Sealant now provided in smaller tubes Training P Specific environmental training has taken place including: o Foundation course in Environment Management o Environmental Management training for the environment committee o Environment Auditing o Maintaining an IPC licence o Spill control courses o Chemical Spill Training o Waste Management and Minimisation P SR Technics has an in-house training school where technical and staff development training is carried out. All courses have an environment module included as does induction training for all new entrants. Water Management See detailed water management plan Section G, Attachment N" G.2(c)

3 Energy Management See detailed energy management plan improvements Section G, Attachment N" G.2(b) Process Improvements > Triklone N was phased out and replaced by an alternative product, Solvon 5000 reducing emissions to atmosphere > Removal of trichloroethylene from APU Cleaning Shop and Plating Shop degreasing chemicals > Degreasers in plating and APU shops fitted with a range of opening options to reduce emissions > Change in product from Ardrox 9PR55 1 to Ardrox 9PR5. The 9PR55 1 contained Trichloroethene (Harmful substance), the 9PR5 does not contain this substance > Change in product from Ardrox 9D6F to Ardrox 9D1 B. The 9D6F contained Trichloroethene (Harmful substance), the 9D 1 B does not contain this substance > Defined and implemented the Tech Washings procedure to give improved process and monitoring results > Upgrade/Replace Wax Tank to a more efficient unit in the Plating Shop, Hangar 1 > Introduction of pre-impregnated sealant wipes (Diestone DLS) to reduce hgitive emissions > Improved techniques to reduce aircraft painting overspray by shielding spray area from drafts > Improved techniques to capture stripper waste more quickly through better preparation Noise Management > Installation of double acoustic air intake louver in Test Cell Installation of new Test Cell door with higher acoustic rating > Sealing all openings in compressor room and closing outside for emergency exit only P Repairs to louvers at compressor cooling tower. Groundwater > Upgraded the chemical storage area with custom built bunded storage > Upgraded the hazardous waste storage facility with custom built bunded storage > Upgraded the waste oil collection and storage facility to ensure handling and storage activities are carried out under cover in a bunded area. > De-commissioned two oil storage tanks > Replaced the main fuel storage tang with a double hulled bunded unit k Replaced two waste oil storage tanks at the Garage with double hulled bunded > Bund testing and repairs carried out > Underground drains surveyed and repairs carried out > Installed spill kits on fork trucks for transport of hazardous materials/waste > Installed borehole caps on groundwater wells

4 Attachment Nq.8 As part of the EMS a schedule of significant environmental aspects was identified by assessing all operations and reviewing cleaner production methods and the reduction and minimisation of waste. A schedule of Objectives and Targets was drawn up and implemented as part of the Environmental Management Programme. In drawing up this schedule all aspects of the business was examined and improvement projects developed under the following headings: P Emissions to Atmosphere > Emissions to Sewer > Non-hazardous Waste > Hazardous Waste > Water Management P Energy Management P Process Improvement P Noise Emissions > Emissions to Groundwater A report on the progress of this programme is prepared and submitted as part of the Annual Environment Report. A planned programme of further improvements is drawn up for the following year and also included in the AER for approval. Progress over the last five years of the programme is surnmarised below. The following BAT considerations/measures are presented: Emissions to Atmosphere Refer to attachment E 1.A Emissions to Sewer > An abatement unit was fitted to the final rinse tanks from the Cadmium process. This closed loop system eliminates emissions to sewer (SE2) fkom the Cadmium in the Electroplating Shop. > A new oil interceptor was installed on the sewer emission line (SE3) from the Garage operation and the vehicle fuelling area. > A silver recovery unit was installed on the film processing unit in the Non Destructive Test section to eliminate silver discharges to sewer (SE2). P A revised procedure for washing aircraft landing gear and wing flaps, which become contaminated with grease, dirt and oil, was drawn up. This procedure requires heavy grease, dirt and oil to be wiped off with cloths and disposed as solid waste, before power washing with hot eater. This process reduces the amount of discharges of heavy metals and oil fats and greases to all sewer lines. > Spill kits are strategically placed around the hangars and workshops to use for immediate clean up of spills. > An Environment Emergency Reaction Plan was drawn up and circulated to all staff to minimise emissions to sewer in the unlikely event of a major incident.

5 Non-hazardous Waste Management 3 Creation of a non-hazardous waste segregation/ storage compound 3 Increased waste diversion from landfill 3 Re-establishment of the Garage Environmental1 Waste Committee 3 Reuse of waste packaging material from customers 3 Upgraded waste collection 3 Improved waste documentation system 3 Reduction from two compactors going to landfill to one compactor Hazardous Waste Management 3 Improved waste documentation system 3 Waste segregation upgraded and extended to other areas 3 Increased usage of bunding for drums of chemicals 3 Diversion of targeted waste streams away from landfill (i.e. aerosol cans, oil contaminated waste) P Introduction of the Halon 1301 Recycler (HAL). To ensure safe removal of Halon 1301 from aircraft fire extinguishers during service 3 Introduction of non-flow drag out tanks in the plating shop to replace the free flowing rinse water system. The drag-out tanks incorporate plate out & ion exchange filters to remove metals from solutions P Introduction of a mobile vacuum waste oil unit to remove the waste oil from the oil drip trays in the garage P Creation of chemical database P Upgrading of hazardous waste labelling system k Reuse of waste Aviation Fuel as a fuel substitute k New oil interceptor for the Garage building and surrounding areas 3 Analysis of structural sealant (PR1436) usage showed a large amount of waste. Sealant now provided in smaller tubes Training 3 Specific environmental training has taken place including: o Foundation course in Environment Management o Environmental Management training for the environment committee o Environment Auditing o Maintaining an IPC licence o Spill control courses o Chemical Spill Training o Waste Management and Minimisation 3 SR Technics has an in-house training school where technical and staff development training is carried out, All courses have an environment module included as does induction training for all new entrants. Water Management See detailed water management plan Section G, Attachment N" G.2(c)

6 Energy Management See detailed energy management plan improvements Section G, Attachment N%G(b) Process Improvements > Triklone N was phased out and replaced by an alternative product, Solvon 5000 reducing emissions to atmosphere > Removal of trichloroethylene from APU Cleaning Shop and Plating Shop degreasing chemicals > Degreasers in plating and APU shops fitted with a range of opening options to reduce emissions > Change in product from Ardrox 9PR55 1 to Ardrox 9PR5. The 9PR55 1 contained Trichloroethene (Harmful substance), the 9PR5 does not contain this substance > Change in product from Ardrox 9D6F to Ardrox 9DlB. The 9D6F contained Trichloroethene (Harmful substance), the 9D1 B does not contain this substance > Defined and implemented the Tech Washings procedure to give improved process and monitoring results P UpgradeReplace Wax Tank to a more efficient unit in the Plating Shop, Hangar 1 > Introduction of pre-impregnated sealant wipes (Diestone DLS) to reduce fugitive emissions > Improved techniques to reduce aircraft painting overspray by shielding spray area from drafts > Improved techniques to capture stripper waste more quickly through better preparation Noise Management P Installation of double acoustic air intake louver in Test Cell P Installation of new Test Cell door with higher acoustic rating > Sealing all openings in compressor room and closing outside for emergency exit only > Repairs to louvers at compressor cooling tower. Groundwater > Upgraded the chemical storage area with custom built bunded storage P Upgraded the hazardous waste storage facility with custom built bunded storage > Upgraded the waste oil collection and storage facility to ensure handling and storage activities are carried out under cover in a bunded area. > De-commissioned two oil storage tanks > Replaced the main fuel storage tang with a double hulled bunded unit > Replaced two waste oil storage tanks at the Garage with double hulled bunded P Bund testing and repairs carried out P Underground drains surveyed and repairs carried out > Installed spill kits on fork trucks for transport of hazardous materialslwaste > Installed borehole caps on groundwater wells