Soltec (Ireland) Ltd Waste Licence No W /12/12

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1

Soltec (Ireland) Ltd EPA License W0115-01 Report Type: AER Reporting Period: 1 st Jan 2012-31 st Dec 2012 Document Name Function Date Signature Written by Mary Lynam - Dunne Accounts Manager 7-1-13 Edited by David Corcoran Environmental Manager 10-1-13 Approved by Michael Corcoran Managing Director 25-1-13 2

Table of Content Section No. Section Name Page no. Front page 1 Title page 2 Table of content 3 List of figure, tables and graphs 5-7 1 Introduction 7 Reporting Period 7 2 Waste activities carried out at the facility 7 3 Quantity and composition of waste received, disposed of and 8-9 recovered during the reporting period and each previous year 4 Quantity and nature of recovered solvent dispatched from the 10 facility 5 Reports on emissions 11 6 Resource and energy consumption summary 12 7 Proposed development of the facility and time scale of such 13 development 8 Report on development works undertaken during the reporting 14 period and a time scale for those proposed during the coming year 9 Estimated annual and cumulative quantity of indirect emissions to groundwater 15 10 Report on the progress towards achievement of the 15 environmental objectives and targets contained in previous year s report 11 Schedule of environmental objectives and targets for the forthcoming year 16 12 Full title and a written summary of any procedures developed by 17 3

the licence in the year which relates to the facility operation 13 Tank, pipeline and bund testing and inspection report 18 14 Reported incidents and complaints summaries 18 15 Reports on financial provision made under the Licence, 18 management and staffing structure of the facility, and program for public information. 16 Report on training of staff 20 17 Boiler efficiency test results 20 4

Lists of tables and graphs Tables Table 1: Waste accepted into Soltec in 2012. Table shows quantities accepted, quantities recycled and quantities sent off-site for recovery Table 2: The quantity of waste liquid recycled in Soltec and its use as a paint thinner Table 3: The quantity of solid accepted and its use as a product Table 4: The quantity of waste accepted into Soltec which was unusable for recovery or is a bi-product product of recovery. Table 5: Energy Consumption Table 6: Proposed site development for 2013 Table 7: Site development in 2012 Table 8: Environmental Objectives and targets Table 9: Environmental objectives Table 10: List of written procedures Table 12: Staff Training 5

6

1 Reporting period 1.1 Report period of W0115-01 is Jan 1 st 2012 until 31 st of Dec 2012. 2 Waste activities carried out at the facility. 2.1 The licensed activities carried out at Soltec s facility as per Waste Licence no. W0115-01 are as follows: Fourth, Schedule of the waste management act 1996. Class 1: Solvent reclamation or regeneration and Class 13: Storage prior to recovery Soltec are also allowed to accept solid hazardous waste under an Agency Approved pilot program. 7

3 Quantity and composition of waste received disposed of and recovered. 3.1 The types, quantities and destinations of waste handled by Soltec s hazardous Waste Management facility over the 12-month period 1/01/12-31/12/12 have been calculated using site waste records. 3.2 Table 1 summarizes the types, quantities and destinations of waste brought to Soltec s facility over the 12- month period 01/01/12-31/12/12. Year Solvent Composition Solvent Received (Kgs) Solvent Recycled (Kgs) Solvent Sent for off-site recovery(kgs) 2012 Waste Solvent 993,223 625,287 270,900 97,035 2012 Solid Hazardous Waste 247,765 0 224,979.30 22785.7 Solvent still on site Total 1240988 625,287 495,879 119820.7 Table 1: Waste accepted into Soltec in 2012. Table shows quantities accepted, quantities recycled and quantities sent off-site for recovery 8

3.3 Schedule A, of Waste Licence W0115-01 allows Soltec to accept up to 5,000- tonnes/year of organic solvents at the facility. The above table shows that the Soltec facility received 993,223 Kgs of waste solvent over the period January 2012 to December 2012. Therefore Soltec is in compliance with that condition of its license. The total of solid waste received in was 247,765 Kgs. 9

4. Quantity and Nature of recovered solvent dispatched from the facility. 4.1 Table 2, 3 and 4 summarises the quantities and nature of recovered solvent and solid waste that was dispatched from the facility over the last 12 months. The figures are based on site records held by Soltec management. Period Jan 12 To Dec 12 Recovered Solvent Liquid (Tonnes) 625 Use Used as thinners by commercial & private consumers Table 2: The quantity of waste liquid recycled in Soltec and its use as a product Period Solid Waste Recovered as Fuel for Cement Kilns (Tonnes) Jan 12 To Dec 12 224.9 Table 3: The quantity of Solid waste accepted into Soltec and its subsequent outlet for recovery in the production of cement. Period Jan 12 To Dec 12 Liquid Waste sent off-site unsuitable for recovery 270.9 Table 4: The quantity of liquid waste sent off-site which was unsuitable for on-site recovery waste. 10

5. Reports on Emissions 6.1 Soltec employed Axis Environmental Services to carry the following analysis. Reports available on-site for inspection. Emissions to the Atmosphere - Report No. 3220-12-05 dated 26 th September 2012 Emissions to the Atmosphere - Report No. 3220-12-04 dated 6 th June 2012 Environmental Noise Survey- Report No. 3220-12-01 dated 18 th April 2012 Groundwater Monitoring Water Report Report No.3220-12-03 dated 17 th May 2012 All monitoring carried out in the 2012 period was in compliance with ELVs set out in W0115-01. However noise monitoring results shown a number of elevations due to external sources from a nearby busy road and industrial park, sound sources from the Soltec site are in compliance. 11

6. Resource and Energy Consumption Summary 6.1 The main energy use at the Soltec facility includes: Electricity Heating Oil Water 6.2 A review of utility bills over the last 12 months shows that Soltec used the following quantities. Energy Quantity Cost Electricity 72,588KwH 24,793 Heating Oil 29,158litres 23,158 Water 259,000Litres 567 Table 5: Energy and Resource Consumption 2012 12

7. Proposed Development of the facility and a time scale for such development. 7.1 The following Table outlines the proposed plant and site development and approximate time scale. There are no further proposed developments at this stage. 7.2 Proposed Site Development. Item Detail Development of New IBC store New VOC vent system for process vessels and storage tanks 2013 2013 Upgrade of internal production facility to include the decommission of solvent storage tanks. 2013 Table 6: Proposed site development for 2012 13

8. Report on development works undertaken during the reporting period. 8.1 Site developments implemented by Soltec during the reporting period are tabulated below. Site Developments: Completed Development 2012 Installation of larger chiller unit, chilling current & future process requirements Installation of new distillation unit Upgrade of current liquid waste storage from IBC to stainless steel tanks Installation of new bund to provide bunding to new storage tanks Upgrade of ground water monitoring wells, to include construction of concrete over ground protection pylon Upgrade bund no.3. This involved the construction of sliding doors and a roof. This is within lines with previous EPA inspection findings. Submitted License Review Table 7: Site development in 2012 14

9. Estimated annual and cumulative quantity of indirect emissions to groundwater. 9.1 The main solvent handling, storage and processing areas at the Soltec facility are covered in concrete or tarmac. Rainwater runs off drains from the building roof and external concrete areas directly to sewer. Groundwater sampling and analysis has shown that there are no detectable traces of solvent in the groundwater. Bund water from central bund is tested and sent off site for treatment. 9.2 There are no indirect emissions from the Soltec facility to groundwater. Soltec sends the bund water for disposal off site. 10. Report on the progress towards the achievement of the environmental Objectives & Targets contained in the previous year s report. Objective Target Action Date Progress Submit EPA license review Upgrade solvent vent system to reduce VOC emission Table 8: Environmental Objectives and targets Sep 2013 Completed Planning stage 15

11. Schedule of Environmental Objectives & Targets for the forthcoming year. 11.1 The environmental objectives for 2012-2013 are shown below. Objectives Date Reduce VOC emission 2013 Table 9: Environmental objectives 16

12 Summary of written procedures developed during the previous 12 months. 12.1 Soltec has developed a series of written procedures, which relate to the operation of the facility. The following table details the procedure titles and a summary of their content: Title Summary of the Procedure SOP 2.1 Quality System SOP 9A.3 Production of Solvents SOP 9A.4 Toxic & Dangerous Waste Regulations SOP 9A.5 Determination of Distillation Range SOP 9A.6 Determination of Boiling Point SOP 9A.7 Determination of weight per Milliliters & Density SOP 9A.8 Determination of Moisture Content SOP 9A.9 Solvent Recovery Unit SOP 9A.10 Satorius Scales SOP 9A.12 Discharge of Bulk Solvent SOP 9A.13 Proscon Soltec Batch Recovery SOP 9A.14 To Transfer Product SOP 9A.15 Waste Discharge SOP 9A.16 Soltec Emergency Plan SOP 9A.17 Clean Mode SOP 9A.19 Epa Licence Application SOP 9A.20 Quality Inspection SOP 9A.21 Calibration ph Meter SOP 9A.22 Waste Water Discharge SOP 9A.23 Handling Storage & Disposal EWC Codes 150202 UN No 1325 Un No 3175 SOP 9A.24 Production of Solvent for Bulk Tankers SOP 9A.25 Karl Fisher Titration SOP 9A.26 Paint Test SOP 9A.27 Rinsing the Lines SOP 9A.28 Operating Instructions Jean Briel Machine SOP 9A.29 Lone Working Policy SOP 9A.30 Servicing Machines SOP 9A.31 Calibration on Ecocan SOP 9A.32 Safe Guard for Bund B3 Capacity SOP 9A.33 Loading and Unloading IBC onto Bund 3 SOP 9A.34 Cleaning and Returning of Combination Barrels Table 10: List of written procedures 12.2 The above procedures are available for inspection at the Soltec facility if required. 17

13. Tank, pipeline and bund testing and inspection report. 13.1 A bund integrity assessment was carried out at the site and a copy of the report is available on-site for inspection. 14 Reported Incidents and complaints summary. 14.1 There were no reported incidents or complaints in relation to Soltec s facility during the reported period covered in this AER. 18

15 Report on financial provision made under this licence, management, and staffing structure of the facility. Soltec has recently invested heavily to upgrade the existing site and install additional solvent recycling plant. There are no immediate plans to stop trading. However should Soltec cease its current operations all machinery plant and stock would either be relocated to an alternative site or sold. All solvent/chemical storage tanks would be emptied site wastes would be appropriately disposed of and the site secured against vandalism. Soltec will render safe or remove from the site all reasonable materials waste plant or equipment contained on or in the site that may result in environmental pollution. Soltec will consider any reasonable request by the EPA to deposit a security bond in the case of insolvency. This bond will be used to cover the cost of any site decommissioning if required. The environmental risks associated with Soltec activities include soil groundwater and surface water contamination. These risks only occur during site operations Soltec do not store waste for long periods or dispose of any waste materials on site. If operations were to cease the potential environmental risks would be significantly reduced, there would not be any expected long-term environment effects after the site has closed. As a result of the above Soltec, do not foresee the need for a long term site monitoring or an aftercare management plan once the operation has ceased. 15.1 An Environmental Liabilities Risk Assessment was carried out and submitted to the agency. 19

16 Report on staff training Soltec has implemented an environmental training schedule for relevant staff, including attendance and completion of the F.A.S. Waste Management Course. Attendances at further relevant training courses are detailed below. Name Training All Staff David Corcoran Fire Safety Training Manual Handling Emergency Response training jointly with Westmeath Fire Service DGSA Course Table 11: Staff Training 17. Boiler Efficiency Test Results 17.1 The Soltec facility has two boiler used for the heating of distillation columns. The boilers were tested for efficiency in 2012. Reports are available for viewing in Soltec. 20

Appendix PRTR PRTR# : W0115 Facility Name : Soltec (Ireland) Limited Filename : W0115_2012 PRTR Completed.xls Return Year : 2012 REFERENCE YEAR 2012 Guidance to completing the PRTR workbook AER Returns Workbook Version 1.1.16 1. FACILITY IDENTIFICATION Parent Company Name Soltec (Ireland) Limited Facility Name Soltec (Ireland) Limited PRTR Identification Number W0115 Licence Number W0115-01 Waste or IPPC Classes of Activity No. class_name 4.1 Solvent reclamation or regeneration. Storage of waste intended for submission to any activity referred to in a preceding paragraph of this Schedule, other than temporary storage, pending collection, on the 4.13 premises where such waste is produced. Address 1 Zone A Address 2 Mullingar Business Park Address 3 Mullingar Address 4 County Westmeath Westmeath Country Ireland Coordinates of Location -7.34319 53.5222 River Basin District IEGBNISH NACE Code 3832 Main Economic Activity Recovery of sorted materials AER Returns Contact Name Mary Lynam-Dunne AER Returns Contact Email Address mary@soltec.ie AER Returns Contact Position Accounts Manager AER Returns Contact Telephone Number 044 9335133 AER Returns Contact Mobile Phone Number AER Returns Contact Fax Number 044 9345248 Production Volume 1240788.0 Production Volume Units Kgs Number of Installations 1 Number of Operating Hours in Year 2288 Number of Employees 11 User Feedback/Comments Web Address www.soltec.ie 2. PRTR CLASS ACTIVITIES Activity Number Activity Name 5(a) Installations for the recovery or disposal of hazardous waste 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 Do you import/accept waste onto your site for onsite treatment (either recovery or disposal activities)? This question is only applicable if you are an IPPC or Quarry site 21

4.1 RELEASES TO AIR Link to previous years emissions data PRTR# : W0115 Facility Name : Soltec (Ireland) Limited Filename : W0115_2012 PRTR Completed.xls Return Year : 2012 09/05/2013 12:57 16 16 24 25 6 8 8 6 6 SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS ADD RELEASES TO AIR Please enter all quantities in this section in KGs POLLUTANT METHOD QUANTITY ADD NEW DELETE 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 ADD 0.0 0.0 0.0 0.0 * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button ADD NEW DELETE SECTION B : REMAINING PRTR POLLUTANTS RELEASES TO AIR Please enter all quantities in this section in KGs ADD 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 ADD NEW DELETE 0.0 0.0 0.0 0.0 * 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 A02 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 Toluene) M OTH EN13258 435.0 0.0 0.0 352 Total Organic Carbon (as 435.0 230 TA Luft organic substances class 1 M OTH EN13649 1379.0 1379.0 0.0 0.0 * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button 22

5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE PRTR# : W0115 Facility Name : Soltec (Ireland) Limited Filename : W0115_2012 PRTR Completed.xls Return Year : 2012 09/05/2013 13:59 5 21 Please enter all quantities on this sheet in Tonnes 5 Haz Waste : Name and Licence/Permit No of Next Destination Facility Haz Waste : Address of Next Name and License / Permit No. Actual Address of Final Quantity Non Haz Waste: Name and Destination Facility and Address of Final Recoverer / Destination i.e. Final Recovery / (Tonnes per Licence/Permit No of Non Haz Waste: Address of Disposer (HAZARDOUS WASTE Disposal Site (HAZARDOUS Year) Method Used Recover/Disposer Recover/Disposer ONLY) WASTE ONLY) Waste European Waste Treatment Location of Transfer Destination Code Hazardous Description of Waste Operation M/C/E Method Used Treatment Ellesmere Port Incinerator Cleanway Cleanaway Ltd,Bridges Ltd,B55193IE,Bridges Road,Ellesmere Port South Road,Ellesmere Port,South Ellesmere Port,South Wirral Veolia Ellesmere Port Wirral,CH65 4EQ,United Wirral,Cheshire,United,Cheshire,CH654EQ,United To Other Countries 07 02 08 Yes 0.19 other still bottoms and reaction residues D10 M Weighed Abroad Incinerator,BS5193IE Ellesmere Port Incinerator Cleanway Cleanaway Ltd,Bridges Ltd,B55193IE,Bridges Road,Ellesmere Port South Road,Ellesmere Port,South Ellesmere Port,South Wirral organic halogenated solvents, washing Veolia Ellesmere Port Wirral,CH65 4EQ,United Wirral,Cheshire,United,Cheshire,CH654EQ,United To Other Countries 07 05 03 Yes 7.62 liquids and mother liquors D10 M Weighed Abroad Incinerator,BS5193IE Afvalstoffen Terminal Moerdijk Afvalstoffen Terminal Terminal Moerdijk BV,1538449,Industrrieterrein Moerdijk BV,Industrrieterrein BV,Industrrieterrin Seaport Seaport M152,.,Vlasweg Seaport M152,Vlasweg other organic solvents, washing liquids and M152,Vlasweg 12,NL 12,NL 4752 PW 12,NL 4752 PW To Other Countries 07 05 04 Yes 18.6 mother liquors R1 M Weighed Abroad AFVALSTOFFEN,1538449 4752,Netherlands Moerdijk,Netherlands Moerdijk,Netherlands Afvalstoffen Terminal Moerdijk Afvalstoffen Terminal Terminal Moerdijk BV,1538449,Industrrieterrein Moerdijk BV,Industrrieterrein sludges from paint or varnish containing BV,Industrrieterrin Seaport Seaport M152,.,Vlasweg Seaport M152,Vlasweg organic solvents or other dangerous M152,Vlasweg 12,NL 12,NL 4752 PW 12,NL 4752 PW To Other Countries 08 01 13 Yes 86.16 substances R1 M Weighed Abroad AFVALSTOFFEN,1538449 4752,Netherlands Moerdijk,Netherlands Moerdijk,Netherlands Ellesmere Port Incinerator Cleanway Cleanaway Ltd,Bridges Ltd,B55193IE,Bridges Road,Ellesmere Port South Road,Ellesmere Port,South Ellesmere Port,South Wirral Veolia Ellesmere Port Wirral,CH65 4EQ,United Wirral,Cheshire,United,Cheshire,CH654EQ,United To Other Countries 08 03 08 No 16.23 aqueous liquid waste containing ink D10 M Weighed Abroad Incinerator,BS5193IE Cleanaway Ltd,Bridges Veolia Technical Road,Ellesmere Port South Services,WOO50- water-based developer and activator Veolia Ellesmere Port Wirral,CH65 4EQ,United 02,Corrin,Fermoy,.,Co Cork Corrin,.,Fermoy,Co Cork To Other Countries 09 01 01 Yes 3.0 solutions D10 M Weighed Abroad Incinerator,BS5193IE,Ireland,Ireland Cleanaway Ltd,Bridges Veolia Technical Road,Ellesmere Port South Services,WOO50- Veolia Ellesmere Port Wirral,CH65 4EQ,United 02,Corrin,Fermoy,.,Co Cork Corrin,.,Fermoy,Co Cork To Other Countries 13 02 08 Yes 1.2 other engine, gear and lubricating oils D10 M Weighed Abroad Incinerator,BS5193IE,Ireland,Ireland Veolia Technical Services,WOO50- paint, inks, adhesives and resins Veolia Environmental Corrin,.,Fermoy,Co 02,Corrin,Fermoy,.,Co Cork Corrin,.,Fermoy,Co Cork Within the Country 20 01 27 Yes 21.58 containing dangerous substances R1 M Weighed Offsite in Ireland Services,WOO50-02 Cork,Ireland,Ireland,Ireland Afvalstoffen Terminal Moerdijk Afvalstoffen Terminal Cleanaway Ltd,Bridges BV,1538449,Industrrieterrein Moerdijk BV,Industrrieterrein Road,Ellesmere Port South Seaport M152,.,Vlasweg Seaport M152,Vlasweg Veolia Ellesmere Port Wirral,CH65 4EQ,United 12,NL 4752 PW 12,NL 4752 PW To ADD Other NEW Countries DELETE 14 06 03 Yes 0.8 other solvents and solvent mixtures D10 M Weighed Abroad Incinerator,BS5193IE Moerdijk,Netherlands Moerdijk,Netherlands Ellesmere Port Incinerator Cleanway Terminal Moerdijk Ltd,B55193IE,Bridges BV,Industrrieterrin Seaport Road,Ellesmere Port,South Ellesmere Port,South Wirral M152,Vlasweg 12,NL Wirral,Cheshire,United,Cheshire,CH654EQ,United To Other Countries 14 06 03 Yes 0.53 other solvents and solvent mixtures R1 M Weighed Abroad AFVALSTOFFEN,1538449 4752,Netherlands Afvalstoffen Terminal Moerdijk Afvalstoffen Terminal PRINT THIS Terminal Moerdijk BV,1538449,Industrrieterrein Moerdijk BV,Industrrieterrein BV,Industrrieterrin Seaport Seaport M152,.,Vlasweg Seaport M152,Vlasweg HELP discarded organic chemicals consisting of M152,Vlasweg 12,NL 12,NL 4752 PW 12,NL 4752 PW To Other Countries 16 05 08 Yes 0.53 or containing dangerous substances R1 M Weighed Abroad AFVALSTOFFEN,1538449 4752,Netherlands Moerdijk,Netherlands Moerdijk,Netherlands Shannon Industrial ENVA,Enva aqueous washing liquids and mother Est,Shannon,Co Shannon,W0041- Within the Country 07 05 01 Yes 28.0 liquors D9 M Weighed Offsite in Ireland Enva Shannon I,W0041-01 Clare,.,Ireland 01,.,.,.,Ireland.,.,Shannon,Co Clare,Ireland Veolia Technical Services,WOO50- aqueous washing liquids and mother Veolia Environmental Corrin,.,Fermoy,Co 02,Corrin,Fermoy,.,Co Cork Corrin,.,Fermoy,Co Cork Within the Country 07 05 01 Yes 33.02 liquors D10 M Weighed Offsite in Ireland Services,WOO50-02 Cork,Ireland,Ireland,Ireland Ellesmere Port Incinerator Cleanway Cleanaway Ltd,Bridges Ltd,B55193IE,Bridges Road,Ellesmere Port South Road,Ellesmere Port,South Ellesmere Port,South Wirral aqueous washing liquids and mother Veolia Ellesmere Port Wirral,CH65 4EQ,United Wirral,Cheshire,United,Cheshire,CH654EQ,United To Other Countries 07 05 01 Yes 53.45 liquors D10 M Weighed Abroad Incinerator,BS5193IE Afvalstoffen Terminal Moerdijk Afvalstoffen Terminal absorbents, filter materials (including oil Terminal Moerdijk BV,1538449,Industrrieterrein Moerdijk BV,Industrrieterrein filters not otherwise specified), wiping BV,Industrrieterrin Seaport Seaport M152,.,Vlasweg Seaport M152,Vlasweg cloths, protective clothing contaminated by M152,Vlasweg 12,NL 12,NL 4752 PW 12,NL 4752 PW To Other Countries 15 02 02 Yes 155.83225 dangerous substances R1 M Weighed Abroad AFVALSTOFFEN,1538449 4752,Netherlands Moerdijk,Netherlands Moerdijk,Netherlands absorbents, filter materials (including oil filters not otherwise specified), wiping cloths, protective clothing contaminated by dangerous substances To Other Countries 15 02 02 Yes 68.947 D10 M Weighed Abroad Veolia Ellesmere Port Incinerator,BS5193IE Ellesmere Port Incinerator Cleanway Cleanaway Ltd,Bridges Ltd,B55193IE,Bridges Road,Ellesmere Port South Road,Ellesmere Port,South Ellesmere Port,South Wirral Wirral,CH65 4EQ,United Wirral,Cheshire,United,Cheshire,CH654EQ,United 23