Annual Environmental Report 2009 - EPA
Annual Environmental Report 2009
Page 1 of 32 March 31st, 2010
Saint-Gobain Performance Plastics Ireland
ANNUAL ENVIRONMENTAL REPORT 2009 Issued March 2010 (For Calendar Year 2009)
IPPC LICENSE No. P0096-02
1
Annual Environmental Report 2009
Page 2 of 32 March 31st, 2010
TABLE OF CONTENTS
PAGE
1.
Introduction
4
2.
Site Details
4
3.
Policy Statement
5
4.
Organisational Structure
6
5.
Self Monitoring
7
5.1
6.
Review of Monitoring Results 5.1.1 F6 (Sewer) 5.1.2 PSA 6 (Air) 5.1.3 MH4 (Storm Water) 5.1.4 Main Emissions to Atmosphere
EPA Monitoring 6.1
8
Summary of Non-Compliances
7.
Pollutant Emissions Register 2009
8
8.
Waste
8
8.1
Hazardous & Special Waste
9
8.2
Miscellaneous Dispatches
9
9.
Energy Consumption
9
10.
Water Consumption
10
11.
Environmental Incidents & Complaints
10
12.
Environmental Planning
11
13.
12.1
Review of 2009 Objectives and Targets
12.2
Environmental Objectives and Targets for 2010
12
Notes on Electronic AER
IPPC LICENSE No. P0096-02
13
2
Annual Environmental Report 2009
Page 3 of 32 March 31st, 2010
APPENDIX A
Emissions Monitoring Charts
14
APPENDIX B
Hazardous Waste Shipped 2009
22
APPENDIX C
Pollutant & Release Transfer Register (PRTR)
25
APPENDIX D
Electronic AER Workbook 2009
27
IPPC LICENSE No. P0096-02
3
Annual Environmental Report 2009
Page 4 of 32 March 31st, 2010
1. INTRODUCTION License Register Number:
P0096-02
Name & Location of site:
Saint-Gobain Performance Plastics Ireland, Kilrush, Co. Clare.
Director of Operations 2008:
John Costelloe
Environmental contact person:
Edward Cooke
Location of activity:
Saint-Gobain Performance Plastics Ireland Ltd., Kilrush, Co. Clare
National Grid Reference:
0998E: 1557N
Contact Phone Number
065-9080100
Contact Fax Number
065-9080101
Number of employees:
66
2. SITE DETAILS Main units, main products: Saint-Gobain Performance Plastics Ireland manufacture a variety of PTFE coated and laminated fabrics. This process is based on aqueous PTFE dispersions. The substrates used are either woven fibre-glass, Kevlar or Nomex. On some of our products we apply a pressure sensitive adhesive. We also produce some silicone coated fabrics. The adhesive processes are currently based on organic solvent. The plant can be divided into four zones: -
PTFE coating Inspection / Warehouse Adhesive + Rubber coating Office and Q.A. Laboratory
IPPC LICENSE No. P0096-02
4
Annual Environmental Report 2009
Page 5 of 32 March 31st, 2010
3. POLICY STATEMENT Saint-Gobain Performance Plastics Ireland ENVIRONMENTAL POLICY STATEMENT Saint-Gobain Performance Plastics Ireland located in Kilrush Co. Clare manufactures a broad range of high performance polymer-based, reinforced and un-reinforced fluoroplastics, fluoroelastomers, silicone elastomers and adhesives. The Company's products include laminates, films, coated fabrics, and tapes. It is the policy of Saint-Gobain Performance Plastics Ireland to operate an Environmental Management System which not only meets all Corporate, E.P.A, Legal and Legislative requirements but also strives to continuously improve to the benefit of our environment, local community, neighbours and employees. We will achieve this by:
Complying with all relevant environmental laws and regulations. Identifying our environmental aspects and associated impacts and instituting appropriate programs for the prevention of pollution and conservation of natural resources associated with our processes. Monitoring and measuring our key Environmental Performance Indicators. Consistent review and re-evaluation of our set Objectives and Targets designed to minimise our impacts. Communicate our Policy and provide appropriate training to all our employees. Communicate with our customers, suppliers and contractors to promote sound environmental practice in the selection, use and disposal of all materials used in the company’s business. Make our environmental policy and records available to the public and interested parties.
The company has procedures and resources in place to plan, implement, monitor and review this policy. This review shall take place annually. Whilst all employees have a duty to ensure that our operations do not cause environmental pollution, the overall responsibility for environmental protection lies with the Director of Operations.
Director of Operations SGPPL Ireland
IPPC LICENSE No. P0096-02
5
Annual Environmental Report 2009
Page 6 of 32 March 31st, 2010
4. ORGANIZATIONAL CHART General Manager Coated Fabrics
Business Manager Europe Coated Fabrics
Marketing Development Manger (Europe)
European Customer Service Manger
Customer Service Representatives
Director of Operations SGPPL Ireland
H.R & Safety Manger
Admin. Reception Catering Personnel
Product CoCoordinator
I.T Manager
Shift 1 Supervisor
Manufacturing & Logistics Manger
Planning & Fulfillment Manger
Shift 3 Supervisor Shift 2 Supervisor
European Financial Controller
Purchasing Assistant
Facilities Manager
Quality & Technology Manager
Financial Controller
Process Engineers Maintenance Personnel
Formulation Quality Engineer
Materials CoCoordinator
QA Lab Fulfillment Operators Cost Accounts Manger Accounts Staff
Production Operators
Page 1
IPPC LICENSE No. P0096-02
6
Page 7 of 32
Annual Environmental Report 2009
March 31st, 2010
5. SELF MONITORING 5.1 Review of monitoring results 5.1.1
F-6 (Sewer)
Issue Oils, Fats & Greases (OFG) analysis done by Bord Na Mona in Q2 shows that an OFG value of 128mg/L exceeded the our EVL of 50mg/L.
5.1.2
Result Actual source indeterminate but OFG levels decreased to pre 2009 levels as production levels increased - continue to monitor weekly
No Issues
MH4 (Storm Water) -
5.1.4
Corrective Action Take OFG samples weekly to determine source.
PSA 6 & 7 (Air Emissions) -
5.1.3
Date May-09
No issues
Main Emissions to atmosphere
Main sources of “Green House Gas” emissions to atmosphere o LPG propane gas heating of tower drying ovens and thermal oxidizer o PSA Solvent destruction in the thermal oxidizer Air Emissions Calculation for 2009 CO2 Emissions from solvent sources burnt in the Thermal Oxidiser
Source
Xylene
CO2 convert factor
Annual Kg burnt
T.O. efficiency %
Estimated Tonne, CO2 emitted
SOx convert factor
Estimated Tonne SOx emitted
Nox convert factor
Estimated Tonne NOx emitted
11754
3.32
99.75%
38.92
N/A
N/A
4713
3.35
99.75%
15.74
N/A
N/A
Ethyl Benzene
937
3.32
99.75%
3.10
N/A
N/A
Ethyl Acetate
479
2
99.75%
0.96
N/A
N/A
LPG Propane gas
684
Toluene
2,088 Tonnes
TOTAL Emissions
IPPC LICENSE No. P0096-02
CO2 2,147
0.0034
0.032
3.037
0.32
Tonnes
Tonnes
SOx 0.0323
NOx 3.037
7
Annual Environmental Report 2009
Page 8 of 32 March 31st, 2010
6. EPA MONITORING The EPA carried out monitoring tests on PSA6 once and F6 & MH4 twice during 2009. PSA6 (Air emissions) MH4 (Surface water) F6 (Sewer)
within EVL within ELV within ELV
Compliant Compliant Compliant
6.1 Summary of non compliances -
No issues
7. POLLUTION EMISSIONS REGISTER 2008 MOM – Method of Measurement This refers to the method used in determining losses to Air, Water and Land. The following codes are to be used to demonstrate the method used: Method Direct Measurement Engineering Estimates
Code M E
Details of the PRTR are in Appendix C.
8. WASTE (Tonnes)
2009
2008
2007
2006
Total Waste Produced
131.10
206.31
261.45
259.31
Total non-hazardous
98.02
165.35
214.21
240.9
50.23 47.77
79.96 85.39
99.8 114.41
123.59 117.32
Total Hazardous
33.08
40.96
47.24
18.4
Total waste recovered
31.57
48.76
68.52
59.76
Total landfill
78.61
127.86
158.74
184
Inert Other non hazardous
IPPC LICENSE No. P0096-02
8
Page 9 of 32
Annual Environmental Report 2009
March 31st, 2010
8.1 Hazardous and Special Waste Quantity
Haz / Non-Haz Hazardous Waste Caustic / Triton neutralisation Non- Hazardous Waste
Total Kg
2005
2006
2007
2008
2009
15200 23470 3675
10502 7760 5446
10,900 27,400 8,740
12230 29060 8,080
16260 16820 200
42,345
23,708
47,040
49,370
33,280
8.2 Miscellaneous Dispatches
320 x 45 gallon empty drums were sent to Kilrush Plant Hire to be crushed and recycled in 2009
Details of shipped Hazardous Waste are in Appendix B
9. ENERGY CONSUMPTION Resourse Units Electricity KW hours LPG Gas Litres
2006 1,865,269 2,630,844
2007 1,678,613 2,367,579
2008 1,459,663 2,058,764
2009 1,273,693 1,338,787
Energy Consumption 3,000,000
2,000,000
2,500,000 Litres
1,500,000
1,000,000
1,000,000
KW Hrs
1,500,000 2,000,000
500,000 500,000 0
0 2006
2007
LPG Gas Litres
IPPC LICENSE No. P0096-02
2008
2009
Electricity KW hours
9
Page 10 of 32
Annual Environmental Report 2009
March 31st, 2010
10. WATER CONSUMPTION
Water consumption 2009:
3,430 m3
Water consumption 2008:
4,644 m3
Water consumption 2007:
9,882 m3
Water consumption 2006:
6,901 m3
11. ENVIRONMENTAL INCIDENTS & COMPLAINTS
Environmental Incidents ELI No.
Date
Incident Catogery
EI 09-01
22/05/2009
EVL Exceedence
3
EI 09-02
26/06/2009
Chemical Spill
3
Details Oils, fats and greases (OFG) were high for the Q2 testing 128mg/l against a limit of 50mg/l. Letter forwarded to EPA While Brian Mc Keown was walking past the main PTFE mixing room this morning he notice a chemical smell – he opened the doors to find a large amount of FC104 spilling on the floor from a puncture hole in the barrel.
Corrective Action(s) Take OFG readings weekly to determine possible source of contamiant OFI 09003 - 1. To replace all drums with high ammonia formulations over the next 2 weeks. 2. To replace all other drums systematically. 3. Implement that all new mixes to be made the drum to be checked by the formulator prior to use.
Environmental Complaints
No. ECL18
Date
Complainaint
19th Mar. 2009
Kilrush Furniture
22nd Jun. 2009
EPA(Anonymous)
25th Jun. 2009
EPA(Anonymous)
ECL19
ECL20
IPPC LICENSE No. P0096-02
Issue Strong smell and haze/smoke being emitted from plant, EPA informed prior to contact with site Bad odour around the Cooraclare Rd area of Kilrush town. It is very distinctive and is similar to that of burning brakes of clutch on a motor vehicle. Downwind of plant there is a distinct odour as described previously - wind was coming from south to south-east
10
Annual Environmental Report 2009
Page 11 of 32 March 31st, 2010
12. ENVIRONMENTAL PLANNING 12.1 Review of 2009 Objectives and Targets Ensure that all emissions are in compliance with the requirements - All the Air and Storm Water emissions were compliant with the IPPC license. Sewer emissions from F6 exceeded the Oils, Fats & Greases EVL as per 5.1.1 – Self Monitoring. Environmental Training - Chemical Awareness Training - ISO 14001 Audit Training - Up-skill Emergency Response Teams - Environmental Awareness Training
Done Scheduled for Q3 2010 Done Done
Perform annual testing in accordance with NOS standard and EPA requirements by the end of the year - Both internal and external noise surveys completed in December 2009 Ensure site remains in compliance with Legal, legislative and other requirements - All relevant updates reviewed by management and necessary actions taken.
ENVIRONMENTAL MANAGEMENT PROGRAM RESULTS 2009 Program No Program Name 1 Eliminate Odour Complaints
2 3
4
5
Result Failed to meet objective of eliminating the No. of complaints. Odour elimination has now become a six-sigma project. Control of Emissions from Keep TOC emissions under Target has been achieved and program PSA 6 UCL of 12 mg/Nm3 in Year 1 is now closed Reduce Hazardous Waste by Reduce Hazardous Waste from Target has been achieved with a end of 3% per Annum 0.0326 Kgs/m2 to 0.0317 year waste ratio of 0.029Kgs/m2 Kgs/m2 in Year 1 PTFE Recovery Project Reduce COD & BOD emission Target has been achieved and program Reduce contaminants to sewer to sewer by 5% in Year 1 is now closed (F6) Energy Conservation Reduce energy consumption Performing well in Year 1 Defined Six-Sigma & from 39.56 MWh/Ton to 37.58 Engineering Projects MWh/Ton in Year 3
IPPC LICENSE No. P0096-02
Target Reduce odour complaints to Zero in Year 1
11
Annual Environmental Report 2009
Page 12 of 32 March 31st, 2010
12.2 Environmental Objectives and Targets For 2010 The following objectives and targets have been established for the calendar year 2010 through the Environmental Management System. Environmental Management Program 2010 Program No. Program Goal EPI Target Responsibility of Review Cycle
1 Eliminate Odour Complaints % Production days slowed Reduce slowing by 10% in Year 1 J. Keane At Monthly EHS Meeting
Program No. Program Goal EPI Target Responsibility of Review Cycle
2 Reduce Hazardous Waste by 3% Hazardous Waste/ PSA Production ratio Reduce Hazardous Waste from 0.0287 Kgs/m2 to 0.0273 Kgs/m2 in Year 1 B. McNamara At Monthly EHS Meeting
Program No. Program Goal EPI Target Responsibility of Review Cycle
3 Energy Conservation - Defined Six-Sigma & Engineering Projects Energy Production Ratio Reduce energy consumption from 39.56 MWh/Ton to 37.58 MWh/Ton in Year 3 J. Downes Quarterly at EHS meeting
Program No. Program Goal EPI Target Responsibility of Review Cycle
4 Maintain Fugitive Emissions below 20% % Fugitive emissions
Page 1 of 32 March 31st, 2010
Saint-Gobain Performance Plastics Ireland
ANNUAL ENVIRONMENTAL REPORT 2009 Issued March 2010 (For Calendar Year 2009)
IPPC LICENSE No. P0096-02
1
Annual Environmental Report 2009
Page 2 of 32 March 31st, 2010
TABLE OF CONTENTS
PAGE
1.
Introduction
4
2.
Site Details
4
3.
Policy Statement
5
4.
Organisational Structure
6
5.
Self Monitoring
7
5.1
6.
Review of Monitoring Results 5.1.1 F6 (Sewer) 5.1.2 PSA 6 (Air) 5.1.3 MH4 (Storm Water) 5.1.4 Main Emissions to Atmosphere
EPA Monitoring 6.1
8
Summary of Non-Compliances
7.
Pollutant Emissions Register 2009
8
8.
Waste
8
8.1
Hazardous & Special Waste
9
8.2
Miscellaneous Dispatches
9
9.
Energy Consumption
9
10.
Water Consumption
10
11.
Environmental Incidents & Complaints
10
12.
Environmental Planning
11
13.
12.1
Review of 2009 Objectives and Targets
12.2
Environmental Objectives and Targets for 2010
12
Notes on Electronic AER
IPPC LICENSE No. P0096-02
13
2
Annual Environmental Report 2009
Page 3 of 32 March 31st, 2010
APPENDIX A
Emissions Monitoring Charts
14
APPENDIX B
Hazardous Waste Shipped 2009
22
APPENDIX C
Pollutant & Release Transfer Register (PRTR)
25
APPENDIX D
Electronic AER Workbook 2009
27
IPPC LICENSE No. P0096-02
3
Annual Environmental Report 2009
Page 4 of 32 March 31st, 2010
1. INTRODUCTION License Register Number:
P0096-02
Name & Location of site:
Saint-Gobain Performance Plastics Ireland, Kilrush, Co. Clare.
Director of Operations 2008:
John Costelloe
Environmental contact person:
Edward Cooke
Location of activity:
Saint-Gobain Performance Plastics Ireland Ltd., Kilrush, Co. Clare
National Grid Reference:
0998E: 1557N
Contact Phone Number
065-9080100
Contact Fax Number
065-9080101
Number of employees:
66
2. SITE DETAILS Main units, main products: Saint-Gobain Performance Plastics Ireland manufacture a variety of PTFE coated and laminated fabrics. This process is based on aqueous PTFE dispersions. The substrates used are either woven fibre-glass, Kevlar or Nomex. On some of our products we apply a pressure sensitive adhesive. We also produce some silicone coated fabrics. The adhesive processes are currently based on organic solvent. The plant can be divided into four zones: -
PTFE coating Inspection / Warehouse Adhesive + Rubber coating Office and Q.A. Laboratory
IPPC LICENSE No. P0096-02
4
Annual Environmental Report 2009
Page 5 of 32 March 31st, 2010
3. POLICY STATEMENT Saint-Gobain Performance Plastics Ireland ENVIRONMENTAL POLICY STATEMENT Saint-Gobain Performance Plastics Ireland located in Kilrush Co. Clare manufactures a broad range of high performance polymer-based, reinforced and un-reinforced fluoroplastics, fluoroelastomers, silicone elastomers and adhesives. The Company's products include laminates, films, coated fabrics, and tapes. It is the policy of Saint-Gobain Performance Plastics Ireland to operate an Environmental Management System which not only meets all Corporate, E.P.A, Legal and Legislative requirements but also strives to continuously improve to the benefit of our environment, local community, neighbours and employees. We will achieve this by:
Complying with all relevant environmental laws and regulations. Identifying our environmental aspects and associated impacts and instituting appropriate programs for the prevention of pollution and conservation of natural resources associated with our processes. Monitoring and measuring our key Environmental Performance Indicators. Consistent review and re-evaluation of our set Objectives and Targets designed to minimise our impacts. Communicate our Policy and provide appropriate training to all our employees. Communicate with our customers, suppliers and contractors to promote sound environmental practice in the selection, use and disposal of all materials used in the company’s business. Make our environmental policy and records available to the public and interested parties.
The company has procedures and resources in place to plan, implement, monitor and review this policy. This review shall take place annually. Whilst all employees have a duty to ensure that our operations do not cause environmental pollution, the overall responsibility for environmental protection lies with the Director of Operations.
Director of Operations SGPPL Ireland
IPPC LICENSE No. P0096-02
5
Annual Environmental Report 2009
Page 6 of 32 March 31st, 2010
4. ORGANIZATIONAL CHART General Manager Coated Fabrics
Business Manager Europe Coated Fabrics
Marketing Development Manger (Europe)
European Customer Service Manger
Customer Service Representatives
Director of Operations SGPPL Ireland
H.R & Safety Manger
Admin. Reception Catering Personnel
Product CoCoordinator
I.T Manager
Shift 1 Supervisor
Manufacturing & Logistics Manger
Planning & Fulfillment Manger
Shift 3 Supervisor Shift 2 Supervisor
European Financial Controller
Purchasing Assistant
Facilities Manager
Quality & Technology Manager
Financial Controller
Process Engineers Maintenance Personnel
Formulation Quality Engineer
Materials CoCoordinator
QA Lab Fulfillment Operators Cost Accounts Manger Accounts Staff
Production Operators
Page 1
IPPC LICENSE No. P0096-02
6
Page 7 of 32
Annual Environmental Report 2009
March 31st, 2010
5. SELF MONITORING 5.1 Review of monitoring results 5.1.1
F-6 (Sewer)
Issue Oils, Fats & Greases (OFG) analysis done by Bord Na Mona in Q2 shows that an OFG value of 128mg/L exceeded the our EVL of 50mg/L.
5.1.2
Result Actual source indeterminate but OFG levels decreased to pre 2009 levels as production levels increased - continue to monitor weekly
No Issues
MH4 (Storm Water) -
5.1.4
Corrective Action Take OFG samples weekly to determine source.
PSA 6 & 7 (Air Emissions) -
5.1.3
Date May-09
No issues
Main Emissions to atmosphere
Main sources of “Green House Gas” emissions to atmosphere o LPG propane gas heating of tower drying ovens and thermal oxidizer o PSA Solvent destruction in the thermal oxidizer Air Emissions Calculation for 2009 CO2 Emissions from solvent sources burnt in the Thermal Oxidiser
Source
Xylene
CO2 convert factor
Annual Kg burnt
T.O. efficiency %
Estimated Tonne, CO2 emitted
SOx convert factor
Estimated Tonne SOx emitted
Nox convert factor
Estimated Tonne NOx emitted
11754
3.32
99.75%
38.92
N/A
N/A
4713
3.35
99.75%
15.74
N/A
N/A
Ethyl Benzene
937
3.32
99.75%
3.10
N/A
N/A
Ethyl Acetate
479
2
99.75%
0.96
N/A
N/A
LPG Propane gas
684
Toluene
2,088 Tonnes
TOTAL Emissions
IPPC LICENSE No. P0096-02
CO2 2,147
0.0034
0.032
3.037
0.32
Tonnes
Tonnes
SOx 0.0323
NOx 3.037
7
Annual Environmental Report 2009
Page 8 of 32 March 31st, 2010
6. EPA MONITORING The EPA carried out monitoring tests on PSA6 once and F6 & MH4 twice during 2009. PSA6 (Air emissions) MH4 (Surface water) F6 (Sewer)
within EVL within ELV within ELV
Compliant Compliant Compliant
6.1 Summary of non compliances -
No issues
7. POLLUTION EMISSIONS REGISTER 2008 MOM – Method of Measurement This refers to the method used in determining losses to Air, Water and Land. The following codes are to be used to demonstrate the method used: Method Direct Measurement Engineering Estimates
Code M E
Details of the PRTR are in Appendix C.
8. WASTE (Tonnes)
2009
2008
2007
2006
Total Waste Produced
131.10
206.31
261.45
259.31
Total non-hazardous
98.02
165.35
214.21
240.9
50.23 47.77
79.96 85.39
99.8 114.41
123.59 117.32
Total Hazardous
33.08
40.96
47.24
18.4
Total waste recovered
31.57
48.76
68.52
59.76
Total landfill
78.61
127.86
158.74
184
Inert Other non hazardous
IPPC LICENSE No. P0096-02
8
Page 9 of 32
Annual Environmental Report 2009
March 31st, 2010
8.1 Hazardous and Special Waste Quantity
Haz / Non-Haz Hazardous Waste Caustic / Triton neutralisation Non- Hazardous Waste
Total Kg
2005
2006
2007
2008
2009
15200 23470 3675
10502 7760 5446
10,900 27,400 8,740
12230 29060 8,080
16260 16820 200
42,345
23,708
47,040
49,370
33,280
8.2 Miscellaneous Dispatches
320 x 45 gallon empty drums were sent to Kilrush Plant Hire to be crushed and recycled in 2009
Details of shipped Hazardous Waste are in Appendix B
9. ENERGY CONSUMPTION Resourse Units Electricity KW hours LPG Gas Litres
2006 1,865,269 2,630,844
2007 1,678,613 2,367,579
2008 1,459,663 2,058,764
2009 1,273,693 1,338,787
Energy Consumption 3,000,000
2,000,000
2,500,000 Litres
1,500,000
1,000,000
1,000,000
KW Hrs
1,500,000 2,000,000
500,000 500,000 0
0 2006
2007
LPG Gas Litres
IPPC LICENSE No. P0096-02
2008
2009
Electricity KW hours
9
Page 10 of 32
Annual Environmental Report 2009
March 31st, 2010
10. WATER CONSUMPTION
Water consumption 2009:
3,430 m3
Water consumption 2008:
4,644 m3
Water consumption 2007:
9,882 m3
Water consumption 2006:
6,901 m3
11. ENVIRONMENTAL INCIDENTS & COMPLAINTS
Environmental Incidents ELI No.
Date
Incident Catogery
EI 09-01
22/05/2009
EVL Exceedence
3
EI 09-02
26/06/2009
Chemical Spill
3
Details Oils, fats and greases (OFG) were high for the Q2 testing 128mg/l against a limit of 50mg/l. Letter forwarded to EPA While Brian Mc Keown was walking past the main PTFE mixing room this morning he notice a chemical smell – he opened the doors to find a large amount of FC104 spilling on the floor from a puncture hole in the barrel.
Corrective Action(s) Take OFG readings weekly to determine possible source of contamiant OFI 09003 - 1. To replace all drums with high ammonia formulations over the next 2 weeks. 2. To replace all other drums systematically. 3. Implement that all new mixes to be made the drum to be checked by the formulator prior to use.
Environmental Complaints
No. ECL18
Date
Complainaint
19th Mar. 2009
Kilrush Furniture
22nd Jun. 2009
EPA(Anonymous)
25th Jun. 2009
EPA(Anonymous)
ECL19
ECL20
IPPC LICENSE No. P0096-02
Issue Strong smell and haze/smoke being emitted from plant, EPA informed prior to contact with site Bad odour around the Cooraclare Rd area of Kilrush town. It is very distinctive and is similar to that of burning brakes of clutch on a motor vehicle. Downwind of plant there is a distinct odour as described previously - wind was coming from south to south-east
10
Annual Environmental Report 2009
Page 11 of 32 March 31st, 2010
12. ENVIRONMENTAL PLANNING 12.1 Review of 2009 Objectives and Targets Ensure that all emissions are in compliance with the requirements - All the Air and Storm Water emissions were compliant with the IPPC license. Sewer emissions from F6 exceeded the Oils, Fats & Greases EVL as per 5.1.1 – Self Monitoring. Environmental Training - Chemical Awareness Training - ISO 14001 Audit Training - Up-skill Emergency Response Teams - Environmental Awareness Training
Done Scheduled for Q3 2010 Done Done
Perform annual testing in accordance with NOS standard and EPA requirements by the end of the year - Both internal and external noise surveys completed in December 2009 Ensure site remains in compliance with Legal, legislative and other requirements - All relevant updates reviewed by management and necessary actions taken.
ENVIRONMENTAL MANAGEMENT PROGRAM RESULTS 2009 Program No Program Name 1 Eliminate Odour Complaints
2 3
4
5
Result Failed to meet objective of eliminating the No. of complaints. Odour elimination has now become a six-sigma project. Control of Emissions from Keep TOC emissions under Target has been achieved and program PSA 6 UCL of 12 mg/Nm3 in Year 1 is now closed Reduce Hazardous Waste by Reduce Hazardous Waste from Target has been achieved with a end of 3% per Annum 0.0326 Kgs/m2 to 0.0317 year waste ratio of 0.029Kgs/m2 Kgs/m2 in Year 1 PTFE Recovery Project Reduce COD & BOD emission Target has been achieved and program Reduce contaminants to sewer to sewer by 5% in Year 1 is now closed (F6) Energy Conservation Reduce energy consumption Performing well in Year 1 Defined Six-Sigma & from 39.56 MWh/Ton to 37.58 Engineering Projects MWh/Ton in Year 3
IPPC LICENSE No. P0096-02
Target Reduce odour complaints to Zero in Year 1
11
Annual Environmental Report 2009
Page 12 of 32 March 31st, 2010
12.2 Environmental Objectives and Targets For 2010 The following objectives and targets have been established for the calendar year 2010 through the Environmental Management System. Environmental Management Program 2010 Program No. Program Goal EPI Target Responsibility of Review Cycle
1 Eliminate Odour Complaints % Production days slowed Reduce slowing by 10% in Year 1 J. Keane At Monthly EHS Meeting
Program No. Program Goal EPI Target Responsibility of Review Cycle
2 Reduce Hazardous Waste by 3% Hazardous Waste/ PSA Production ratio Reduce Hazardous Waste from 0.0287 Kgs/m2 to 0.0273 Kgs/m2 in Year 1 B. McNamara At Monthly EHS Meeting
Program No. Program Goal EPI Target Responsibility of Review Cycle
3 Energy Conservation - Defined Six-Sigma & Engineering Projects Energy Production Ratio Reduce energy consumption from 39.56 MWh/Ton to 37.58 MWh/Ton in Year 3 J. Downes Quarterly at EHS meeting
Program No. Program Goal EPI Target Responsibility of Review Cycle
4 Maintain Fugitive Emissions below 20% % Fugitive emissions
