devcon ltd annual environmental report · devcon ltd. or itw engineered polymers, shannon, co....
TRANSCRIPT
Devcon Ltd
Annual Environmental Report
2015
Licence No: P0072-03
IPPC Licence Annual Environmental Report Register No.P0072-03 January- December 2015
1 Introduction ............................................................................................... 3
1.1 Company Details ............................................................................... 3 1.2 Environmental Policy ......................................................................... 5
Environmental Policy ....................................................................................... 5 1.3 Company Organisational Structure .................................................... 7
2 Summary Information ............................................................................... 8 2.1 Emissions to Atmosphere .................................................................. 8 2.2 Storm Water Results .......................................................................... 9 2.3 Waste Management ........................................................................... 9
2.3.1 Non Hazardous Waste ................................................................... 9 2.3.2 Hazardous Waste......................................................................... 10
2.4 Resource Consumption ................................................................... 13 2.5 Noise Emissions .............................................................................. 14 2.6 Agency Monitoring and Enforcement ............................................... 14 2.7 IPPC Licence Conditions ................................................................. 15 2.8 Complaints Summary ...................................................................... 15 2.9 Reported Incidents Summary .......................................................... 15 2.10 Tank and Pipeline Testing and Inspection Report ........................... 16 2.11 PRTR Data – Explanation of Changes in Data ............................... 16
3 Management of Environmental Impacts ................................................. 17 3.1 Summary of Environmental Objectives and Targets 2015 ............... 17 3.2 Environmental Objectives 2015 ....................................................... 19
IPPC Licence Annual Environmental Report Register No.P0072-03 January- December 2015
1 Introduction
1.1 Company Details
Licence Register Number: P0072-03
Company Name: Devcon Ltd
Company Address: Bay 150
Shannon Industrial Estate
Shannon
Co. Clare
Description of Site Activities:
Devcon Ltd. or ITW Engineered Polymers, Shannon, Co. Clare is the
European manufacturing facility for ITW Polymers and Fluids Group. Devcon
Ltd. Shannon has a total of 33 employees, two of whom are temporary. The
company operates a five-day week and the normal operating hours are
between 8:00am to 4:30pm. Devcon Ltd was granted its current licence in
November 2008.
The Shannon facility manufactures adhesive surface-coatings, sealants, and
chemical anchoring products. The products are categorised as epoxies,
methacrylates and polyurethane resins. Manufacturing is carried out in two EX
rated areas. The Plexus grades MA300 and MA310 are manufactured in an
EX rated Zone 1 area that came on stream in May 2011. All other products
manufactured onsite are manufactured in an EX rated Zone 2 area. All
products are manufactured according to the ISO 9001 standard. Ninety
percent of the waste generated during production is reworked. No water is
used in the process. Dust collection and extraction systems are applied
IPPC Licence Annual Environmental Report Register No.P0072-03 January- December 2015
throughout the facility. Solid inert waste is disposed off-site in a suitable
landfill-site and a licensed operator treats the solvent waste.
A point of clarification in relation to the company naming. ITW Ireland and
Devcon Ltd both appear on the company registrations website in Ireland.
Devcon Ltd has not traded for years and this came to light in our submission
of an Industrial Emissions Activities Licence application at the end of 2014.
Thus the IPPC Licence for Devcon Ltd. needs to be transferred to ITW
Ireland. The site in Shannon is called ITW Engineered Polymers and are a
Division of ITW Ireland. ITW Engineered Polymers is a trading name of ITW
Ireland. The process of the licence transfer is ongoing in 2016 but an
Environmental Liabilities Risk Assessment and Decommissioning
Management Plan were completed in 2015 along with the licence transfer
application form.
This Annual Environmental Report reports on the period January to December
2015.
IPPC Licence Annual Environmental Report Register No.P0072-03 January- December 2015
1.2 Environmental Policy
DEVCON PLEXUS
IRATHANE FUTURA POLYMER TECHNOLOGIES
KORROFLEX MAZEL
Environmental Policy
ITW Engineered Polymers is committed to the best practices of environmental management. This will be achieved by continuous quality improvement, by waste reduction and recycling programmes in our processes and by encouraging environmental values in all our employees. The Regulatory Affairs Officer with the co-operation of management is responsible for environmental protection and implementation of this policy.
Our Key Policy Objectives To achieve and maintain an Environmental Management System in line with the principles of ISO14001 To prevent pollution from any activity carried out on site To ensure 100% compliance with all aspects of our Integrated Pollution Prevention Control Licence. Ensure compliance with any environmental legislation applicable to our facility and compliance with any other requirements that we must adhere to also. To train and educate all employees in the skills and understanding necessary to minimise risks and to ensure a competent response in dealing with the environmental consequences of any site incident and to enable them to contribute to the attainment of environment targets and goals. To establish relationships with local and national government authorities, industrial agencies and the local community to promote respect of the Environment and build a mutual understanding, in the interest of all. ITW Engineered Polymers will commit the necessary resources to promote and implement plans and strategies to achieve Environmental Objectives and Targets. ITW Shannon is committed to continual improvement in all Environmental Aspects of the company.
IPPC Licence Annual Environmental Report Register No.P0072-03 January- December 2015
____________________ _____________________ Brian Rainsford Jason Brogan Operations Manager Regulatory Affairs Officer ITW Engineered Polymers ITW Engineered Polymers
IPPC Licence Annual Environmental Report Register No P0072-03 January- December 2015
1.3 Company Organisational Structure
Steve ReidVice President
General Manager (USA)
Brian RainsfordOperations
Manager (IRE)
Kevin GarveyEngineering Co-
Ordinator
Paul ColesTechnical Services Manager - Europe
Tommy MallonPlant Manager
(IRE)
Jason Brogan Regulatory Affairs
Officer
Fintan GinnaneProduction Supervisor
Sean Wren Maintenance
Fitter
Sinead Burke Planning/Purchasing
Corina KirbyKay O’Gorman
Michael MooneyCustomer Service RepresentativesDon O Shea
Nicole MoloneyTeam Leaders
Production Formulators &
Operators
Brian MullinsMark Vincent
Kevin GinnaneShipping/Warehouse
Shannon PlantOrganisational Chart
Frederik Sommer Gleerup
HSE Manager(DK)
Dave RobinsonTechnical Director
(USA)
Jacob WernbergCommercial
Manager (DK)
Lone ImerDistribution
Manager (DK)
Anna PyneREACH
Coordinator
Jennifer AllisonFinance Manager
Ciara BurkeAccounts Assistant
Chow Yee ChuController
Division(USA)
Laura BrowneAccounts Payable
Noreen O’NeillQA Supervisor
Chris McGorrianZsolt Tanka
QC Laboratory Technicians
Michael R. MikkelsenDivisional Purchasing
Manager (DK)
IPPC Licence Annual Environmental Report Register No P0072-03 January- December 2015
2 Summary Information
2.1 Emissions to Atmosphere As per IPPC Licence conditions we monitor for TA Luft Organics Class I, II and III once a quarter. Epcon production ceased at the facility a number of years ago and we have agreed with the EPA that as mercaptans are no longer used on site, there is no need to monitor for these in atmospheric emissions from A2/1. Our volumetric flowrate from emission point A2/1 continues to exceed the limit quoted in our licence. The limit in our licence is 4900m3/hr while our actual flowrate is approximately 21000m3/hr. This flowrate is required mainly for Health and Safety reasons, so that we can provide a healthy working atmosphere for all employees by having adequate ventilation in the production and filling/packing areas and also to give the required number of air changes in our ATEX production zone. Quarterly monitoring is also completed for our Plexus manufacturing area AEP in line with the request from the EPA for this to be the case. This emission point remains unlicensed. Emissions from the Plexus filling area were also leaving the building through the Plexus AEP. Following an EPA inspection on the 6th June 2015 we completed monitoring on this area in Q3. The results showed that this could not be considered a minor emission point. The Plexus cartridge filling operation was outsourced in any case at the end of November 2015 and is no longer carried out in Shannon except for pail filling. Please see tables below for results for Air Monitoring for 2015. Figures are given in mg/Nm3 (where N = Normalised).
Emission Quarter 1 Quarter 2 Quarter 3 Quarter 4 Mercaptans n/a n/a n/a n/a TA Luft I Not recorded 2.69 3.04 1.0938 TA Luft II 4.32 2.69 3.04 1.0938 TA Luft III Not recorded 0.64 3.04 1.0938
Table 1: A2-1 Atmospheric Emission Monitoring Results 2015
Emission Stage Number
Quarter 1 Quarter 2 Quarter 3 Quarter 4
Methyl Methacrylate
1 76.5 3.3 21.6 16.7 2 95.8 3.3 23.3 48.8 3 34 11 9.07 39.5 4 24.1 15.1 10.22 64.9 5 85 15.0 21 6 9.5 7 7.2
Table 2: Plexus AEP Atmospheric Emission Monitoring Results 2015
IPPC Licence Annual Environmental Report Register No.P0072-03 January- December 2015
2.2 Storm Water Results Each quarter a sample of storm water is sent off site for analysis for COD check and pH which is completed by BHP Laboratories the COD result for stormwater monitoring in Q3 of 2015 was out of normal for the site. An investigation was conducted on site and there was no evidence of any spillage or any possible source of contamination of the stormwater system. There was no direct explanation for the elevated results. Parameter Quarter 1 Quarter 2 Quarter 3 Quarter 4 pH 7.47 7.95 7.6 7.58 COD 6.5 mg/L 31 mg/L 259 mg/L 8 mg/L
Table 2: Storm Water Test Results
2.3 Waste Management
2.3.1 Non Hazardous Waste All waste that is collected from our site is collected by approved waste contractors all details are listed below for these:
Details EWC Code
Waste Carrier Destination Waste
Treatment Operation
paper and cardboard packaging 15 01 01
Clare Waste and Recycling,WCP/LK/10/652/01
Raheen,.,Tuamgraney,Co. Clare,Ireland R3
plastic packaging 15 01 02
Clare Waste and Recycling,WCP/LK/10/652/01
Raheen,.,Tuamgraney,Co. Clare,Ireland R3
metallic packaging 15 01 04
Hegarty Metal Processors ‐ ClearCircle Environmental,WCP‐LK‐08‐589‐01
Ballysimon Road,.,.,Limerick,Ireland R4
wooden packaging 15 01 03
Clare Waste and Recycling,WCP/LK/10/652/01
Raheen,.,Tuamgraney,Co. Clare,Ireland R3
biodegradable kitchen and canteen waste 20 01 08
Clare Waste and Recycling,WCP/LK/10/652/01
Raheen,.,Tuamgraney,Co. Clare,Ireland R3
wastes not otherwise specified 08 04 99
Clare Waste and Recycling,WCP/LK/10/652/01
Raheen,.,Tuamgraney,Co. Clare,Ireland D1
Table 3: Non Hazardous Waste Contractor Details Compactor waste is very much similar to 2014 figures with just 1.12 tonnes more in 2015 the difference. This is partly attributed to the disposal of empty 1 tonne bags to landfill as we have been unsuccessful in being able to reuse or
IPPC Licence Annual Environmental Report Register No.P0072-03 January- December 2015
find a reuse for these. Previously these were being used by a local business for holding sand and aggregate.
2.3.2 Hazardous Waste As always, throughout 2015 great effort was made to keep the amount of hazardous chemical waste to a minimum. With the arrival of the sunset dates for a number of Phthalates in February 2015 we had to dispose of a large quantity of product which we could no longer legally place on the market.
Details EWC Code
Waste Carrier
Destination Waste
Treatment Operation
paint, inks, adhesives and resins containing dangerous substances 20 01 27
Rilta Environmental Ltd.,W192‐3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland R1
absorbents, filter materials (including oil filters not otherwise specified), wiping cloths, protective clothing contaminated by dangerous substances 15 02 02
Rilta Environmental Ltd.,W192‐3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland R1
packaging containing residues of or contaminated by dangerous substances 15 01 10
Rilta Environmental Ltd.,W192‐3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland R1
laboratory chemicals, consisting of or containing dangerous substances, including mixtures of laboratory chemicals 16 05 06
Rilta Environmental Ltd.,W192‐3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland R1
other solvents and solvent mixtures 14 06 03
Rilta Environmental Ltd.,W192‐3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland R1
IPPC Licence Annual Environmental Report Register No.P0072-03 January- December 2015
Details EWC Code
Waste Carrier
Destination Waste
Treatment Operation
paint, inks, adhesives and resins containing dangerous substances 20 01 27
Rilta Environmental Ltd.,W192‐3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland R1
paint, inks, adhesives and resins containing dangerous substances 20 01 27
Rilta Environmental Ltd.,W192‐3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland R1
packaging containing residues of or contaminated by dangerous substances 15 01 10
Rilta Environmental Ltd.,W192‐3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland R1
discarded organic chemicals consisting of or containing dangerous substances 16 05 08
Rilta Environmental Ltd.,W192‐3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland R1
paint, inks, adhesives and resins containing dangerous substances 20 01 27
Rilta Environmental Ltd.,W192‐3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland R1
paint, inks, adhesives and resins containing dangerous substances 20 01 27
Rilta Environmental Ltd.,W192‐3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland R1
other solvents and solvent mixtures 14 06 03
Rilta Environmental Ltd.,W192‐3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland R1
IPPC Licence Annual Environmental Report Register No.P0072-03 January- December 2015
Details EWC Code
Waste Carrier
Destination Waste
Treatment Operation
laboratory chemicals, consisting of or containing dangerous substances, including mixtures of laboratory chemicals 16 05 06
Rilta Environmental Ltd.,W192‐3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland R1
paint, inks, adhesives and resins containing dangerous substances 20 01 27
Rilta Environmental Ltd.,W192‐3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland R1
paint, inks, adhesives and resins containing dangerous substances 20 01 27
Rilta Environmental Ltd.,W192‐3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland R1
packaging containing residues of or contaminated by dangerous substances 15 01 10
Rilta Environmental Ltd.,W192‐3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland R4
packaging containing residues of or contaminated by dangerous substances 15 01 10
Rilta Environmental Ltd.,W192‐3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland R3
Table 5: Hazardous Waste Details
2015 did see a large increase in hazardous chemical waste. In terms of production it was a very busy year with a high volume of product output. This in turn led to a lot of extra cleaning of equipment and thus more solvent consumption. We imported some new products from our sister company in the US with a view to placing them on the EU market. However with a combination of short shelf life and slow sales, we were forced to dispose of the new material. Our annual stocktake also showed poor inventory management in relation to the shelf life of materials. This is a focus this year to manage this better and not to have to write off so much good product that is simply out of shelf life and was left to go unused. Raw material wastage was minimal and the bigger issue is with finished goods write off.
IPPC Licence Annual Environmental Report Register No.P0072-03 January- December 2015
The major increase in hazardous waste was in the disposal of empty contaminated packaging. Previously our barrels were crushed and sent for recycling. They are now being collected by Rilta and washed before recycling. Also our IBCs were returned to Schutz (manufacturer of IBCs) previously but this is no longer possible with changes in the UK WM2 environmental regulations in 2014. All IBCs are now sent to Rilta for washing and recycling. We participate in the HP recycling program for used cartridges and toners from our main office printers/photocopiers.
2.4 Resource Consumption Energy consumption in 2015 averaged quite similar to 2014 and can be linked with the level of production at the facility. Despite being a busy year in terms of production, efficiencies in work practises meant efficiencies in energy consumption too.
Month Consumption 2013 kWh
Consumption 2014 kWh
Consumption 2015 kWh
January 41709 43674 44458 February 41472 41525 42500 March 45483 42059 42263 April 42802 39188 39657 May 41558 39704 37245 June 34442 38111 39202 July 38752 44247 44271 August 36036 37765 36924 September 36294 42105 41361 October 38903 43113 43110 November 39242 38252 38236 December 33410 39553 34013
Table 6: Energy Consumption Comparison 2013-2015
Water Consumption for year ended December 2015 was 1,550.4m3. Oil consumption by the boilers on site (steam generation and facility heating) remained static over the year with 10,000L of oil being consumed every month except for June and August.
IPPC Licence Annual Environmental Report Register No.P0072-03 January- December 2015
2.5 Noise Emissions Following the noise survey carried out in 2014, there was no requirement for a similar survey in 2015 as there is agreement with the EPA to only conduct this monitoring every 3 years. This is down to a combination of previous noise readings, hours of operation and the location of the facility and the nearest noise sensitive location. There have been no changes to the site in 2015 that would have led to an increase in noise emissions.
2.6 Agency Monitoring and Enforcement On the 1st April 2015 a member of the EPA staff attended the site to retrieve a stormwater sample. The subsequent report showed a pH of 7.6 and COD of 33mg/L, both of which are within our own specified limits. On the 18th June 2015, Fitz Scientific were commissioned by the EPA to conduct atmospheric emission point monitoring on emission point A2/1. The results of the TA Luft monitoring were all within specification. However the volumetric flowrate from the emission point exceeded the limit as set out in our IPPC licence. This has always been the flowrate from the emission point and readings can be traced back to the late 90’s of similar values. This was mentioned during the course of the latest licence review in 2007. This flowrate is required as we operate an ATEX zone within the facility and we are required to ensure a minimum number of air changes per hour. 2 non-compliances were raised in 2015 in relation to this matter.
On the 9th June 2016 we had an EPA inspector visit on site for an entire site evaluation. A number of observations were made during the inspection and three non-compliances were issued. Details of the non-compliances are as follows:
Firstly in relation to the atmospheric monitoring test reports:
1. The licence lists limits for TA Luft Organics Class I, II and III. Results for all these parameters are not listed in each report. 2. The results are listed as non-accredited; however, no deviations in the sampling and monitoring were recorded. It was not clear from the reports why the results were not accredited.
Secondly in relation to bunding:
1. Condition 8.3 requires that all loading and unloading occurs in areas protected against spillage. There are a number of storm water drains in the backyard area and these are only covered during loading and unloading of epoxy resin. On the day of the visit approximately 32 IBCs of Ultrathane, which is toxic to the environment, was stored unbunded in the back yard area.
2. Peroxide was being stored unbunded in the Plexus room.
IPPC Licence Annual Environmental Report Register No.P0072-03 January- December 2015
3. The operators who do the loading and unloading have not been trained in the operation of the storm water shut of valve.
4. There is only one small spill kit in a corner of the backyard area.
5. The storm water line between the back yard and the discharge point has not been hydrostatically tested.
6. Weekly bund inspections had not been completed since April 13th 2015. This is a non-compliance with condition 6.10.
Thirdly in relation to particulate emissions:
A) During the site tour the issue of controls for the A2/2 emission point was discussed. This identified an issue with the current licence. The emission point listed in the licence had been decommissioned a number of years ago and a new abatement system and new emission point placed at a nearly location. This should not have been done without prior approval of the Agency.
B) The licensee informed me that emission point A2/1 contains particulates which were not listed in the original licence application.
2.7 IPPC Licence Conditions A number of reports have been completed in accordance with IPPC requirements: - Monitoring continued to be completed every quarter on the Plexus AEP
(as per request from EPA) - Bund integrity testing for 20 bund trays in our external chemical storage
sheds – all bunds passed inspection - Environmental Liabilities Risk Assessment - Decommissioning Management Plan
2.8 Complaints Summary There were no external environmental complaints made against the ITW company premises in Shannon in 2015.
2.9 Reported Incidents Summary There were no reported incidents from ITW Engineered Polymers Shannon in 2015. The elevated COD reading in the stormwater results in Q3 should have been reported as an incident.
IPPC Licence Annual Environmental Report Register No.P0072-03 January- December 2015
2.10 Tank and Pipeline Testing and Inspection Report There was no requirement for tank or pipeline testing in 2015. Our only underground pipeline was within test.
2.11 PRTR Data – Explanation of Changes in Data
There is a significant increase in hazardous waste as empty uncleaned packagings (namely steel barrels and IBCs) are not being sent to Rilta for washing and subsequent recycling. As mentioned above, IBCs used to be returned to Schitz for reuse but this is no longer possible from Ireland without washing.
Releases to air are significantly higher as this is a calculated figure now. Q3 atmospheric monitoring results used as a basis as these were the results with the highest readings for TA Luft in 2015. This is based on a 251 working day year and 4 hour shift average as batches will be covered for the remaining period of time in a working day. This is the best approximation that can be given for actual TA Luft generation throughout the year. TA Lufts are not continuously monitored so the Q3 figures are being taken as a worst case scenario.
MDI releases to air have reduced, this value reflects the unaccounted for stock in the 2015 stocktake.
IPPC Licence Annual Environmental Report Register No P0072-03 January- December 2015
3 Management of Environmental Impacts
3.1 Summary of Environmental Objectives and Targets 2015 In line with our IPPC Licence requirements and ISO 14001:2004 requirements, the following table highlights the Environmental Management Programs that were in place for 2015. Ref Project Title Details Work Completed
1 Achieve transfer of the current IEA licence from Devcon Ltd to ITW Engineered Polymers – plant is currently operating without a licence
ELRA and DMP/CRAMP to be completed and agreed with EPA
Licence transfer application form to be lodged with appropriate fee
Financial provision to be put in place to cover the figures agreed in the ELRA and CRAMP
ELRA and DMP were completed and revisions made that were satisfactory to the EPA
Licence transfer application was lodged and fee paid
Financial provision was being worked on and was close to agreement at the end of 2015
2 Complete the firewater retention study Complete the firewater retention study
Put in place a plan to cope with any findings from the report
Review of environmentally hazardous substances on site was conducted and we far exceed the requirements for firewater retention
Agreed with EPA to have a whole new study completed by an external contractor that reflects the site situation today.
3 Carry out chemical spill response training
Compile a training presentation and deliver it to all employees
Training not yet completed.
IPPC Licence Annual Environmental Report Register No.P0072-03 January- December 2015
involved in the handling of chemicals
4 Assess the efficiency of use of raw materials in all process and reduce waste
Look at raw materials used and where used on site
Look at delivery of materials on site
Review waste lists for the last two years and determine % of raw materials disposed of and form this baseline can be formed to allow for action to be taken
Raw material waste was relatively minimal in the overall hazardous waste volume.
Write off of finished goods is a much bigger issue and this was highlighted in the 2015 stocktake
5 Continue energy reduction schemes Replace more of the existing warehouse lights with more energy efficient LED lighting. 4 LED lights can be run for the same cost as one of the existing lights
Repair the steam lagging on the pipework for the epoxy resin lines outside the main building
Improve the pipework lagging in the boiler house
Replacement of the warehouse lighting was cost prohibitive in 2015. It will be attempted again in 2016
Lagging in general was not completed due to time constraints, particularly with machine outsourcing
IPPC Licence Annual Environmental Report Register No.P0072-03 January- December 2015
3.2 Environmental Objectives 2015
Ref Project Title Details 1 Conduct a study on chemical segregation on site –
recommendation from firewater retention report Review locations of chemicals on site and their
hazard classifications. Segregate chemicals in line with best chemical storage practise. This will in turn reduce the fire risk from incompatible chemicals on site.
2 Secure an IPPC licence transfer to ITW Ireland from Devcon Ltd and successfully submit an Industrial Emissions Activities (IEA) Licence
Finalise the implementation of the financial provision to cover the ELRA and DMP that were completed in 2015
Oversee the transfer of the current IPPC licence from Devcon Ltd. to ITW Ireland
Successfully apply for a new IEA licence for ITW Ireland
3 Carry out radon gas survey Purchase radon gas monitors for the facility from a monitoring company and install them around the facility for 3 months. Follow any recommendations in the subsequent report.
4 Assess the sale of finished goods in relation to their expiry date and management of stock
Review waste lists for the last two years and determine % of finished goods disposed of. Highlight issues to production and shipping departments.
5 Continue energy reduction schemes Replace more of the existing warehouse lights with more energy efficient LED lighting. 4 LED lights can be run for the same cost as one of the existing lights
Repair the steam lagging on the pipework for the epoxy resin lines outside the main building
Improve the pipework lagging in the boiler house
IPPC Licence Annual Environmental Report Register No.P0072-03 January- December 2015
Revisit the energy efficiency audit completed in 2010 to see what else can be worked on
IPPC Licence Annual Environmental Report Register No.P0072-03 January- December 2014
Appendix 1
PRTR Data
Sheet : Facility ID Activities AER Returns Workbook 31/3/2016 15:58
| PRTR# : P0072 | Facility Name : Devcon Limited | Filename : P0072_2015.xls | Return Year : 2015 |
Guidance to completing the PRTR workbook
REFERENCE YEAR 2015
1. FACILITY IDENTIFICATIONParent Company Name Devcon Limited
Facility Name Devcon LimitedPRTR Identification Number P0072
Licence Number P0072-03
Classes of ActivityNo. class_name
- Refer to PRTR class activities below
Address 1 Bay 150Address 2 Shannon Industrial EstateAddress 3 ShannonAddress 4
ClareCountry Ireland
Coordinates of Location -8.89082 52.7112River Basin District IEGBNISH
NACE Code 2052Main Economic Activity Manufacture of glues
AER Returns Contact Name Jason BroganAER Returns Contact Email Address [email protected]
AER Returns Contact Position Regulatory Affairs OfficerAER Returns Contact Telephone Number (061) 771521
AER Returns Contact Mobile Phone NumberAER Returns Contact Fax Number (061) 471 285
Production VolumeProduction Volume Units
Number of InstallationsNumber of Operating Hours in Year
Number of EmployeesUser Feedback/Comments Significant increase in hazardous waste as empty uncleaned packagings (steel barrels and IBCs) are not being sent to Rilta for washing and s
air are significantly higher as this is a calculated figure now. Q3 atmospheric monitoring results used as a basis as these were the results with2015. This is based on a 251 working day year and 4 hour shift average as batches will be covered for the remaining period of time in a workiapproximation that can be given for actual TA Luft generation throughout the year. MDI releases to air have reduced, this value reflects the un
Web Address http://eu.itwengineeredpolymers.com/
2. PRTR CLASS ACTIVITIESActivity Number Activity Name
4(a)(ii) Oxygen-containing hydrocarbons such as alcohols, aldehydes, ketones, carboxylic acids, esters, acetates, ethers, peroxides, epoxy resins
3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002)Is it applicable? No
Have you been granted an exemption ? NoIf 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 waDo you import/accept waste onto your site for on-
site treatment (either recovery or disposalactivities) ? No
PRTR Returns Workbook
| PRTR# : P0072 | Facility Name : Devcon Limited | Filename : P0072_2015.xls | Return Year : 2015 | Page 1 of 1
Sheet : Releases to Air AER Returns Workbook 31/3/2016 15:59
4.1 RELEASES TO AIR Link to previous years emissions data | PRTR# : P0072 | Facility Name : Devcon Limited | Filename : P0072_2015.xls | Return Year : 2015 | 31/03/2016 15:59
8 8 16 16 24 28 6 6 6SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS
Please enter all quantities in this section in KGsQUANTITY
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/Year86 Particulate matter (PM10) E ESTIMATE 270.0 270.0 0.0 0.0
* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button
SECTION B : REMAINING PRTR POLLUTANTSPlease enter all quantities in this section in KGs
QUANTITY
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/Year0.0 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)Please enter all quantities in this section in KGs
QUANTITY
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/Year201 1,2 trichloroethylene E ESTIMATE 6.0 6.0 0.0 0.0219 MDI E ESTIMATE 22.83 22.83 0.0 0.0
230 TA Luft organic substances class 1 C OTHESG Technical Procedure AE118 20.08 20.08 0.0 0.0
231 TA Luft organic substances class 2 C OTHESG Technical Procedure AE118 70.28 70.28 0.0 0.0
232 TA Luft organic substances class 3 C OTHESG Technical Procedure AE118 20.08 20.08 0.0 0.0
* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button
Additional Data Requested from Landfill operators
Landfill: Devcon Limited
Please enter summary data on the quantities of methane flared and / or utilised
additional_pollutant_no T (Total) kg/Year M/C/E Method CodeDesignation or
DescriptionFacility Total Capacity m3
per hourTotal estimated methane generation (as per
site model) 0.0 N/AMethane flared 0.0 0.0 (Total Flaring Capacity)
Methane utilised in engine/s 0.0 0.0 (Total Utilising Capacity)Net methane emission (as reported in Section
A above) 0.0 N/A
Method Used
For the purposes of the National Inventory on Greenhouse Gases, landfill operators are requested to provide summary data on landfill gas (Methane) flaredor 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:
Method Used
Method Used
RELEASES TO AIRPOLLUTANT METHOD
Method Used
POLLUTANT
RELEASES TO AIR
RELEASES TO AIRMETHOD
POLLUTANT METHOD
| PRTR# : P0072 | Facility Name : Devcon Limited | Filename : P0072_2015.xls | Return Year : 2015 | Page 1 of 1
Sheet : Treatment Transfers of Waste AER Returns Workbook 31/3/2016 16:0
5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE | PRTR# : P0072 | Facility Name : Devcon Limited | Filename : P0072_2015.xls | Return Year : 2015 | 31/03/2016 16:00
5 20 Please enter all quantities on this sheet in Tonnes 0
Quantity (Tonnes per
Year)
Haz Waste : Name and Licence/Permit No of Next
Destination Facility Non Haz Waste: Name and Licence/Permit No of
Recover/Disposer
Haz Waste : Address of Next Destination Facility
Non Haz Waste: Address of Recover/Disposer
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)
Transfer DestinationEuropean Waste
Code Hazardous Quantity T/Year Description of Waste
Waste Treatment Operation M/C/E Method Used
Location of Treatment Name 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)
To Other Countries 20 01 27 Yes 18.174paint, inks, adhesives and resins containing dangerous substances R1 M Weighed Abroad
Rilta Environmental Ltd.,W192-3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland
RECYFUEL S.A.,SA D3200/61080/RGPED/2/,Zoning Industriel d?Ehein,ENGIS ,ENGIS ,B-4480 ,Belgium
Zoning Industriel d?Ehein,Rue Du Parc Industriel 16,ENGIS ,B-4480 ,Belgium
To Other Countries 15 02 02 Yes 0.196
absorbents, filter materials (including oil filters not otherwise specified), wiping cloths, protective clothing contaminated by dangerous substances R1 M Weighed Abroad
Rilta Environmental Ltd.,W192-3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland
RECYFUEL S.A.,SA D3200/61080/RGPED/2/,Zoning Industriel d?Ehein,ENGIS ,ENGIS ,B-4480 ,Belgium
Zoning Industriel d?Ehein,Rue Du Parc Industriel 16,ENGIS ,B-4480 ,Belgium
Within the Country 15 01 10 Yes 4.616packaging containing residues of or contaminated by dangerous substances R1 M Weighed Offsite in Ireland
Rilta Environmental Ltd.,W192-3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland .,.,.,.,.,.,Ireland .,.,.,.,Ireland
To Other Countries 16 05 06 Yes 1.923
laboratory chemicals, consisting of or containing dangerous substances, including mixtures of laboratory chemicals R1 M Weighed Abroad
Rilta Environmental Ltd.,W192-3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland
Afvalstoffen Terminal,Moerdijk 1538449,Vlasveg 12 4872,Moerdijk ,Holland,.,Netherlands
Vlasweg,12 4872,Moerdijk,Holland,Netherlands
To Other Countries 14 06 03 Yes 8.935 other solvents and solvent mixtures R1 M Weighed AbroadRilta Environmental Ltd.,W192-3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland
Afvalstoffen Terminal,Moerdijk 1538449,Vlasveg 12 4872,Moerdijk ,Holland,.,Netherlands
Vlasweg,12 4872,Moerdijk,Holland,Netherlands
To Other Countries 15 01 10 Yes 4.151packaging containing residues of or contaminated by dangerous substances R1 M Weighed Abroad
Rilta Environmental Ltd.,W192-3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland
RECYFUEL S.A.,SA D3200/61080/RGPED/2/,Zoning Industriel d?Ehein,ENGIS ,ENGIS ,B-4480 ,Belgium
Zoning Industriel d?Ehein,Rue Du Parc Industriel 16,ENGIS ,B-4480 ,Belgium
To Other Countries 16 05 08 Yes 2.669discarded organic chemicals consisting of or containing dangerous substances R1 M Weighed Abroad
Rilta Environmental Ltd.,W192-3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland
RECYFUEL S.A.,SA D3200/61080/RGPED/2/,Zoning Industriel d?Ehein,ENGIS ,ENGIS ,B-4480 ,Belgium
Zoning Industriel d?Ehein,Rue Du Parc Industriel 16,ENGIS ,B-4480 ,Belgium
To Other Countries 20 01 27 Yes 0.257paint, inks, adhesives and resins containing dangerous substances R1 M Weighed Abroad
Rilta Environmental Ltd.,W192-3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland
Afvalstoffen Terminal,Moerdijk 1538449,Vlasveg 12 4872,Moerdijk ,Holland,.,Netherlands
Vlasweg,12 4872,Moerdijk,Holland,Netherlands
Within the Country 08 04 99 No 41.9 wastes not otherwise specified D1 M Weighed Offsite in Ireland
Clare Waste and Recycling,WCP/LK/10/652/01
Raheen,.,Tuamgraney,Co. Clare,Ireland
Within the Country 15 01 01 No 9.0 paper and cardboard packaging R3 E Weighed Offsite in Ireland
Clare Waste and Recycling,WCP/LK/10/652/01
Raheen,.,Tuamgraney,Co. Clare,Ireland
Within the Country 15 01 02 No 3.24 plastic packaging R3 E Weighed Offsite in Ireland
Clare Waste and Recycling,WCP/LK/10/652/01
Raheen,.,Tuamgraney,Co. Clare,Ireland
Within the Country 15 01 04 No 6.0 metallic packaging R4 E Weighed Offsite in Ireland
Hegarty Metal Processors - ClearCircle Environmental,WCP-LK-08-589-01
Ballysimon Road,.,.,Limerick,Ireland
Method Used
| PRTR# : P0072 | Facility Name : Devcon Limited | Filename : P0072_2015.xls | Return Year : 2015 | Page 1 of 2
Sheet : Treatment Transfers of Waste AER Returns Workbook 31/3/2016 16:0
Quantity (Tonnes per
Year)
Haz Waste : Name and Licence/Permit No of Next
Destination Facility Non Haz Waste: Name and Licence/Permit No of
Recover/Disposer
Haz Waste : Address of Next Destination Facility
Non Haz Waste: Address of Recover/Disposer
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)
Transfer DestinationEuropean Waste
Code Hazardous Quantity T/Year Description of Waste
Waste Treatment Operation M/C/E Method Used
Location of Treatment Name 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)
Method Used
Within the Country 15 01 03 No 1.68 wooden packaging R3 E Weighed Offsite in Ireland
Clare Waste and Recycling,WCP/LK/10/652/01
Raheen,.,Tuamgraney,Co. Clare,Ireland
Within the Country 20 01 08 No 0.66 biodegradable kitchen and canteen waste R3 E Weighed Offsite in Ireland
Clare Waste and Recycling,WCP/LK/10/652/01
Raheen,.,Tuamgraney,Co. Clare,Ireland
Within the Country 15 01 10 Yes 41.406packaging containing residues of or contaminated by dangerous substances R4 E Weighed Offsite in Ireland
Rilta Environmental Ltd.,W192-3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland
Rilta Environmental,W192-3,Block 402,Greenogue Business Park,Rathcoole ,Co. Dublin ,Ireland
Block 402,Greenogue Business Park,Rathcoole ,Co. Dublin ,Ireland
Within the Country 15 01 10 Yes 3.24packaging containing residues of or contaminated by dangerous substances R3 E Weighed Offsite in Ireland
Rilta Environmental Ltd.,W192-3
Block 402,Greenogue Business Park,Rathcoole,Co Dublin,Ireland
Rilta Environmental,W192-3,Block 402,Greenogue Business Park,Rathcoole ,Co. Dublin ,Ireland
Block 402,Greenogue Business Park,Rathcoole ,Co. Dublin ,Ireland
* Select a row by double-clicking the Description of Waste then click the delete button
| PRTR# : P0072 | Facility Name : Devcon Limited | Filename : P0072_2015.xls | Return Year : 2015 | Page 2 of 2