Cognis Ireland Ltd. Little Island, Co. Cork Ireland Phone (+353)21 451 71 00 Fax (+353) 21 435 35 59 www.cognis.com Noleen Roche Administration Officer Office of Licensing and Guidance Environmental Protection Agency P.O. Box 3000,, Johnstown Castle Estate County Wexford, Dear Sirs, Company Name; Cognis (Irl) Ltd/Henkel Ireland Detergents Ltd. Reg No. P0052-02 22 nd Dec. 2006 With reference to your letter dated 8 th December 2006 the following information is provided, as requested; 1. In relation to the categories of activities referred to in Annex I of the IPPC Directive (96/61/EC) it is our opinion that we have applicability under categories 4.1 (Chemical installations for the production of basic organic chemicals such as (b)oxygen containing hydrocarbons such as alcohols, aldehydes, ketones, carboxylic acids, esters, acetates, ethers, peroxides, epoxy resins), and 5.1 (installations for the disposal or recovery of hazardous waste as defined in the list referred to in Article 1 (4) of Directive 91/689/EEC, as defined in Annexes II A and II B to Directive 75/442/EEC and in Council Directive 85/439/EEC of June 16 1975 on the disposal of waste oils (3), with a capacity exceeding 10 tonnes per day). 2. It is our determination that the provisions of Article 3(2) of EC Directive 2000/76/EC do not apply to our installation due to the fact that the Net Calorific value of our combined residues is greater than 30MJ per kilogramme. By Product description Annual Quantity Kgs Calorific value mj/kg Aldoxime residue 1,203,222 38.93 Ketoxime forecut/residue 651,492 37.55 Registered in Ireland No. 42876 I.S. EN ISO 14001.I.S. EN ISO 9002 Directors: Paul Allen E.G. Quigley (Managing Director),
Toluene Distillate 653,906 22.84 Taed Residue 783,100 22.88 Average net energy content per Kg process by- product = 31.6 MJ 3. Boiler 5 only is connected to our CHP Plant. 4. Boilers 4 and 5 are fitted with NOx reduction technologies. Boilers 4 and 5 are fitted with NOx reducing firing nozzles and boiler 5 also comprises over fire air technology for additional NOx reduction. 5. The supplementary fuels which may be utilized in the boilers comprise distillation residues (bottoms) and the distillate from our Toluene Distillation Plant. These materials are listed in the EWC as 07 07 08 and 07 07 04 respectively. 6. Toluene Distillate from the top of the Toluene Distillation column is used as a supplementary fuel to our boiler plant. This distillate comprises toluene, methyl formate and methanol and has a calorific value of 22.84Mj/Kg The bottoms from the toluene distillation plant comprise the purified toluene and this is returned for re-use in the manufacturing process. 7. Cognis Ireland Ltd. / Henkel Ireland Detergents Ltd are subject to the requirements of the European Communities (Control of Major Accident Hazards Involving Dangerous Substances) Regulations 2006. These regulations implement the provisions of EC Directive 96/82/EC and the subsequent amendments as outlined in Directive 2003/105/EC. Under the requirements EC Directive 96/82/EC Cognis Ireland Ltd. / Henkel Ireland Detergents Ltd were categorised as an Article 6 & 7 site (i.e. a Lower Tier Site) principally due to the quantities of material classed as being dangerous to the environment that are processed and stored within the Little Island site. The amendments made to EC Directive 96/82/EC as outlined in Directive 2003/105EC and as enforced through the 2006 regulations have reduced the qualifying thresholds of dangerous substances to which the regulations apply. The effect of these changes within the regulations is that Cognis Ireland Ltd. / Henkel Ireland Detergents Ltd is now categorised as an Article 9 site (i.e. a Top Tier Site). Consequently Cognis Ireland Ltd. / Henkel Ireland Detergents Ltd is required to produce a Safety Report as stipulated within the 2006 regulations. Cognis Ireland Ltd. / Henkel Ireland Detergents Ltd are currently
preparing a Safety Report for submission to the HSA in Jan 2007. The required date of submission is no later than the 15 th Feb 2006. If you require any further information in relation to the information provided in this correspondence please do not hesitate to contact me. Yours Sincerely, Ciaran McCabe EHS Manager
Non-Technical Summary of IPC Licence Application 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 conditions of the site of the installation, 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 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; (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 is 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 o A.1
Company Background: Cognis Ireland Ltd was founded in 1974 as General Mills Chemicals Ireland, a subsidiary of a US Corporation, manufacturing LIX reagents for the mining industry. Following the purchase of the chemical division of General Mills in 1978 by Henkel KGaA, an international company specialising in the production of detergents, adhesives, cosmetics, and cleaning/sanitising systems, the Irish company was subsequently renamed Henkel Ireland Limited. In January 2000 following a corporate re-organisation Henkel Ireland became Cognis Ireland Ltd and Henkel Ireland Detergents Ltd., both companies being wholly owned subsidiaries of Henkel KgaA. Subsequently on 30 th November 2001 Henkel KGaA sold Cognis Ireland Ltd to a private equity consortium comprising Permira Funds, GC Capital Partners and the Schroder Ventures Life Sciences Funds. Henkel Ireland Detergents Limited remains a subsidiary of Henkel KgaA and owns certain assets on the site. However for the purpose of this application and with respect to any environmental permits pertaining to the site, Cognis Ireland Limited is the company to whom the permit(s) are issued and whom in liason with Henkel Ireland Detergents ensure compliance to such permits. Site Activities. Cognis Ireland Ltd.(CIL) manufactures LIX reagents, which are designed to extract non-ferrous metals at very high purity levels from their ores by solvent extraction. This technology has both environmental and economic advantages over traditional smelting technologies. Cognis Ireland Ltd also manufactures Alumat, a by-product Aluminium Chloride solution, which is recovered as a saleable product through a combination of recycling, concentration and purification technologies. Henkel Ireland Detergents (HIDL) manufactures Tetra acetyl ethylene Di-amine (TAED) which is used as a bleach activator in low temperature detergents. HIDL also produces technical grade acetic acid which is extracted from process waste streams which contain the acid as a by product. The Company operates a 4-shift cycle and runs 24 hours per day, 7 days per week. Cognis Ireland Ltd. / Henkel Ireland Detergents Ltd are subject to the requirements of the European Communities (Control of Major Accident Hazards Involving Dangerous Substances) Regulations 2006. These regulations implement the provisions of EC Directive 96/82/EC and the subsequent amendments as outlined in Directive 2003/105/EC. Under the requirements EC Directive 96/82/EC Cognis Ireland Ltd. / Henkel Ireland Detergents Ltd were categorised as an Article 6 & 7 site (i.e. a Lower Tier Site) principally due to the quantities of material classed as being dangerous to the environment that are processed and stored within the Little Island site.
The amendments made to EC Directive 96/82/EC as outlined in Directive 2003/105EC and as enforced through the 2006 regulations have reduced the qualifying thresholds of dangerous substances to which the regulations apply. The effect of these changes within the regulations is that Cognis Ireland Ltd. / Henkel Ireland Detergents Ltd is now categorised as an Article 9 site (i.e. a Top Tier Site). Consequently Cognis Ireland Ltd. / Henkel Ireland Detergents Ltd is required to produce a Safety Report as stipulated within the 2006 regulations. Cognis Ireland Ltd. / Henkel Ireland Detergents Ltd are currently preparing a Safety Report for submission to the HSA in Jan 2007. The required date of submission is no later than the 15 th Feb 2006. Site Inventories: The maximum inventory of all raw and auxiliary materials and other substances used on site is outlined in attachment no. A.1.1 Sources of Emissions: Cognis Ireland Ltd has six major point source atmospheric emission points on the site, as follows; EP1/1 services emissions from our Aldoxime process and this emission is fitted with a twin Carbon Adsorption Unit that removes organic components from the air before discharge. The emission is fitted with a continuous F.I.D detector which records V.O.C emissions. EP 1/2. This emission emanates from the T.A.E.D. process and it is fitted with two scrubbers that remove acetic acid vapours from the air prior to emission. Emissions are analysed quarterly to verify licence compliance. EP 1/3. This is a filter unit that is designed to remove particulate matter from the air that arises from T.A.E.D. production. The emission is analysed isokinetically annually to verify licence compliance. EP 1/4 and EP 1/6 relate to emissions from boilers 1, 2, and 3. Emissions from these boilers are analysed biannually to verify compliance with licence. EP 1/8. This is the emission point from boilers 4 and 5. EP 1/8 is monitored continuously using the MIR 9000 and RM10 Analysers. Parameters analysed are NOx, SOx, CO, VOC s, and Particulates. EP 1/11. This emission point relates to the Ketoxime process and is fitted with a thermal oxidiser to remove organic impurities prior to discharge. The emission is fitted with a continuous monitor to record emission concentrations The Company also has a biological wastewater treatment plant which discharges from emission point WP1 to the municipal wastewater treatment plant at Carraigrennan. There are continuous monitors for ph, temperature and flow at the discharge from the plant. In addition to this the company undertakes daily analysis for suspended solids, ph, C.O.D., weekly B.O.D. and phosphate analysis and monthly analysis for volatile and semi-volatile organics, oils, fats and grease, heavy metals, aluminium and phenols.
The nature and quantities of emissions from the installation: The following table quantifies our emissions to atmosphere for VOC s NOx, and SOx for the period 2001 to 2004. Emissions to Atmosphere 2001 to 2004 (Kg) 140000 120000 100000 Kg of Emission 80000 60000 Mass Emission (Kg) 2001 Mass Emission (Kg) 2002 Mass Emission (Kg) 2003 Mass Emission(Kg) 2004 40000 20000 0 EP1/1, EP 1/2,EP1/3, EP1/11, fugitives - VOC's EP 1/4, EP 1/6,EP 1/8 - Sulphur Oxides EP 1/4, EP 1/6, EP 1/8 - Nitrogen Oxides In terms of our emissions to water Cognis Irelands operating philosophy is to engage in sound environmental management practices, with particular focus on source reduction initiatives. We have continually selected key environmental aspects for attention in our Environmental Management Programmes (EMP s). A particular focus of the Company has been in the area of hydraulic and chemical load reduction to our wastewater treatment plant (WWTP). Cognis Irelands effluent discharge loads for 2004 were 262939m3 (51% of permitted discharge volume allowance) 143635Kg COD (26% of permitted discharge COD allowance) 22350Kg BOD (<9% of permitted discharge BOD allowance) 360Kg Total Ox. N (<1% of permitted discharge N allowance) 11832 Kg NH3 (46% of extrapolated discharge NH3 allowance) Methodology for prevention and recovery of waste: Cognis is committed to progressive reductions in site emissions and its programmes for waste recycle and re-use have been well documented. The Company has won several National Awards for its waste reduction/clean technology programmes, the most recent being the IBEC National Environment Award for Waste Management/Clean Technology in 2003. Cognis Ireland Ltd
was also honoured to have been selected to represent Ireland at the EU Sponsored European Environment Awards, held in Brussels in May 2004. Our Toluene Distillation and Energy Recovery Project was also chosen by the European Solvents Industry Group (a sector group within CEFIC) as the overall European Winner in the category of Environmental Stewardship at the European Responsible Care Conference in Rome, in October 2004 Cognis Ireland Ltd was previously successful at the National Environment Awards in 1996 and 1998. Cognis actively supports programmes for the recycle and reuse of packaging waste that arise on site. Packaging materials that are suitable for recycle and reuse are available to interested parties for collection. Our 2004 Annual Environmental Report highlights the following waste management statistics; 75% of all waste generated during 2004 was recovered, an increase of 12% since 2002. 97.5% of Hazardous waste generated in 2004 was recovered. Cognis Ireland Ltd has reduced its total waste generation per unit of manufacturing output by 14% since 2001. We have reduced the quantity of waste requiring disposal by landfill by 56% since 2000, and by 19% since 2003. Our strategy going forward is focussed on further reductions in waste generation, specifically on the generation of sludge for disposal from our wastewater treatment plant. Cognis Ireland Ltd endorses the approach that waste prevention is the favoured approach, followed by minimisation, re-use and recycling, with disposal being the least favoured management option. Our targets for the next 3-5 years are designed to minimise our waste generation at source; firstly, within our production processes and, subsequently, to minimise the output of sludge from the site by utilising cleaner and more efficient waste management technologies. Measures in place to monitor emissions into the environment: Cognis Ireland Ltd has installed continuous monitoring equipment to at emission points from its boilers 4 and 5, thermal oxidiser, carbon adsorption unit and wastewater treatment plant. Additionally the Company employs 2 environmental analysts on a 4 shift cycle thereby ensuring 7-day cover on site for environmental monitoring. We employ the services of external consultants to monitor groundwater quality and environmental noise monitoring. Further measures planned to comply with the general principles of the basic obligations:
Environmental Policy. Cognis Ireland Ltd is committed to excellence in all aspects of its operations, instilling high environmental values in all employees, utilising the best environmental and operational practices in all of its processes, and continual improvement in pursuit of overall excellence. Cognis subscribe to the belief that the integration of Safety, Health, Environment, and Quality into a single Management System (SHEQ) provides the best template for development and progress on a going forward basis and subsequently has committed itself to an integrated SHEQ Management System for the site. The Company believes that the development of an integrated approach to SHEQ Management will enhance our status as a quality manufacturer and supplier of Fine Chemicals and Nutrition products. Cognis Ireland Ltd is committed to building on its good relations with customers, suppliers, neighbours, and regulatory authorities. Products manufactured and supplied to the market by Cognis Ireland are expected to conform to the technical specifications under which they are manufactured and sold; are produced safely with due regard for employees, neighbours and the environment; are correctly packaged and labelled in accordance with appropriate regulations; are delivered on time and in good condition, using approved distribution channels. Likewise Cognis management are insistent that, in its operations, the Company will comply with all applicable laws and regulations. Compliance with its Integrated Pollution Control Licence is a minimum standard required and management programmes, which are designed, are approved by senior management and drive the Company down a path of continual improvement. Results of environmental performance and targets are freely available to employees and to the public and the Company meets regularly with interested parties, including local residents, to discuss issues of mutual interest and concern. 1.4 Environmental Performance. Cognis Ireland Ltd has long recognised the need to ensure that environmental protection is a central part of its overall operational strategy. This has been reflected by our success in winning National Better Environment Awards for Irish Industry on three occasions, in 1996, 1998, and 2003, as well as a European Environment Award in 2004 for our Toluene Distillation Project. We also received commendations at the EU Sponsored European Environment Awards in 1996 and 2004 for our efforts in the area s of environmental sustainability and waste reduction respectively.
The National Awards were presented to Cognis for its achievements in the areas of waste reduction and re-use; firstly for its Acetic Acid Recovery plant which was constructed at a cost of 3.5 million and which recovers for sale a technical grade acetic acid from a variety of waste streams on site. This plant has contributed significantly to our sites good environmental performance through the elimination of several high concentration waste streams that had previously required treatment in the company s biological effluent treatment plant. The second award was presented for an innovative process, which enables the Company to recycle, concentrate, purify and market an aluminium chloride based waste stream generated in one of its processes. The most recent national award in 2003 was presented for our Toluene Distillation/Energy recovery plant which as well as reducing our demand on natural resources has contributed to reduced waste generation and improved effluent quality from the site s wastewater treatment plant. Other environmental initiatives undertaken on site over the years include the complete elimination of chlorinated solvents from our processes (late 1980 s); energy recovery from process residues; and the recent installation of a Combined Heat and Power Plant which is anticipated will provide up to 50% of the company s energy requirements, thus reducing the burden on the environment through a lessening on the demand for non renewable resources. Cognis Ireland Ltd is accredited to the international standards of ISO 9002 and ISO 14001 and also subscribes to the chemical industry s Responsible Care initiative In line with the requirements of ISO 14001 Cognis Ireland Ltd has set ambitious targets for continual improvement in environmental performance. These targets and their associated management programmes are included in this Annual Environmental Report (Chapters 7 and 8). Targets set are reviewed and approved annually by senior management and form the foundations for the design of the Company s development strategy. Cognis Ireland continuously monitors its consumption of resources and is actively involved in Energy and Resource awareness initiatives. In 2003 we installed an Energy Monitoring System which enables us to monitor electrical consumption throughout the site and to target reduction possibilities. This system will be expanded in phase two of its development to include site water usage. As a participant in the Irish Energy Centre s Self -Audit Scheme Cognis has targeted improvements in its energy performance. As a consequence of various site initiatives and investments (VSD s, etc.) Cognis Ireland Ltd has reduced its
total electricity requirements by 7.7% per unit of manufacturing output since 1999. The Irish Energy Centre publishes an annual report detailing company specific successes. Cognis Ireland actively promotes Energy Awareness Week on site through quiz s, special offers and information bulletins.