Annual Environmental Report 2013 · Annual Environmental Report 2013 5.2 Proposed Schedule of...

Annual Environmental Report 2013

ANNUAL ENVIRONMENTAL REPORT

2013

For

AB Converters Ltd

IPC Licence Number : P0197-02

Table of Contents

1 INTRODUCTION .................................................................................................................................. 3

Company Details ................................................................................................................................................ 3 Environmental Policy ......................................................................................................................................... 4 Company Organisation ....................................................................................................................................... 5

2 SUMMARY INFORMATION............................................................................................................... 6

Emissions to Atmosphere ................................................................................................................................... 6 Emissions to Surface Water ................................................................................................................................ 7 Waste Management Report ................................................................................................................................ 9 Resource Consumption ..................................................................................................................................... 10

2.1.1 Energy Consumption .............................................................................................................. 10 2.1.2 Water Consumption ................................................................................................................ 10

3 AGENCY MONITORING AND ENFORCEMENT ......................................................................... 11

3.2 SITE VISITS AND INSPECTIONS CARRIED OUT BY AN AGENCY INSPECTOR: .............. 11

4 ENVIRONMENTAL INCIDENTS AND COMPLAINTS ................................................................ 12

4.1 ENVIRONMENTAL INCIDENCES .................................................................................................. 12

4.2 ENVIRONMENTAL COMPLAINTS SUMMARY .......................................................................... 12

5 ENVIRONMENTAL MANAGEMENT ............................................................................................. 13

5.1 ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) REPORT ................................... 13

5.2 PROPOSED SCHEDULE OF ENVIRONMENTAL OBJECTIVES AND TARGETS FOR 2014 ..

................................................................................................................................................................ 14

5.3 ENVIRONMENTAL MANAGEMENT PROGRAMME PROPOSAL FOR 2013 ........................ 15

5.4 POLLUTION REGISTER AND TRANSFER (PRTR) – PROPOSAL ........................................... 23

5.5 POLLUTION REGISTER AND TRANSFER (PRTR) – REPORT ................................................ 23

1 Introduction

Condition 11.8 of the IPPC licence of AB Converters requests that an Annual

Environmental Report must be documented every year and submitted to the EPA in March

of the following year:

11.8 The licensee shall submit to the Agency, by the 31st March of each year, an AER

covering the previous calendar year. This report, which shall be to the satisfaction of the

Agency, shall include as a minimum the information specified in Schedule D: Annual

Environmental Report, of this licence and shall be prepared in accordance with any

relevant guidelines issued by the Agency.

Company Details

The following table shows particulars of the company:

Table 1 Company Details

Name AB Converters Ltd.

Location

Blessington Industrial Estate, Blessington,

Co. Wicklow.

IPPC Reg No. P0197-02

IPPC Class of Activity (Schedule 1 of

the EPA Act 1992 as amended by PoE

Act 2003)

12.2.2 The manufacturing or use of coating materials in

processes with a capacity to make or use at least 10

tonnes per year of organic solvent not included in

paragraph 12.2.1

NACE Code*1

DE – manufacture of pulp, paper and paper products,

publishing and printing

Contact Eithne Hendricken

Position Environmental & Quality Manager

Number of full-time staff equivalents 101

Telephone 045 865611 045 900070 (direct line)

Fax 045 865026

Email [email protected]

*1As according to NACE codes referenced from Commission Regulation EC No 29/2002 amending

Council Regulation (EEC) No 3037/90 on the statistical classification of economic activates in the

European Community

Environmental Policy

Environmental Policy

AB Converters Ltd. regards environmental protection as an essential requirement of its

operations. The company will undertake to conduct its business in a manner which protects

the environment in which it operates. The company’s objective is to balance the need to

achieve its business aims with the need to protect the environment.

To achieve this goal the company will adhere to the following guiding principles:

Guiding Principles:

Ensure continued compliance with all Irish and EU legislative environmental requirements.

Continually assess activities with the specific goal of preventing pollution, minimising and reducing the

environmental impact.

Ensure that Environmental Policy objectives and targets have equality with other business interests.

Communicate its Environmental Policy to employees, suppliers, visitors and interested parties.

Maintain an open information policy towards all parties affected, interested and involved in its activities

and to issues, which concern the environment.

Ensure that its employees have the knowledge, resources and authority to implement these guiding

principles.

In particular, AB Converters Ltd. will:

Comply with all conditions set in the IPC Licence.

Ensure submission of reports to the EPA shall meet target submission dates.

Meet targets set in Environmental Management Programme (defined in AER).

Establish and comply with an Environmental Management System.

Ensure all hazardous materials are stored in an environmentally safe manner

(bunded).

Reduce wherever practicable the level of effluent, air and noise emissions.

Ensure good Waste Management practices e.g. recycle rather than dispose whenever

possible, used licensed waste contractors and maintain waste records.

This Environmental Policy covers all activities at the AB Converters Ltd. site, and has the

full commitment and support of Management.

Signed: _____________________ Date: ____________________

(Company Director)

Signed: _____________________ Date: ____________________

(Environmental Manager)

Company Organisation

Dermot Brady is the Managing Director and joint owner of the company. Eithne

Hendricken is responsible for Environmental Management.

Managing Director

Dermot Brady

Quality Manager / Environmental Manager

Eithne Hendricken

Production Manager

Joe Mc Mahon

Technical Manager

Gerry Jackson

Maintenance

Declan Geraghty

Health and Safety

Eithne Hendricken

Financial Controller

Sandra Fisher

2 Summary Information

Emissions to Atmosphere

During B2 2007, the reviewed licence for AB Converters was granted on the 14 November

2007 and the required monitoring changed from biannual sampling of the two printers to

quarterly monitoring of the thermal oxidiser.

Table 2 Summary of atmospheric emissions from the thermal oxidiser (A2-01) in 2013

IPC ELV Q1 2013 Compliance

Sample Number - -

Volumetric Flow Rate (Nm3/hr) 22,500 8565.3 Compliant

Mass Emission Rate (kg/hr) None Compliant

TOC as C Concentration (mg/Nm3) 100 44.8 Compliant


Sample Number - -



TOC as C Concentration (mg/Nm3) 100 28 Compliant


Sample Number - -





Sample Number - -




Emissions to Surface Water

Table 3 Summary of Emissions to Surface Water 2013

Emission

Point Quarter pH

SS

mg/L

COD

mg/L

FOG

mg/L

Temperature oC

SW1

1st 8.12 <10 43.5 <10 8.9

2nd

7.99 <10 26.5 <10 13.4

3rd

7.41 <10 47.1 <10 11

4th 7 <10 82 <10 10.1

SW2

1st

7.42 <10 85.9 <10 9.7

2nd

7.56 <10 349 <10 12.8

3rd

7.32 12 33.2 <10 11.5

4th 7.5 <10 53.6 <10 11.3


Waste Management Report

Table 4 Waste Management EWC

Code Waste Type Tonnage

Method of

Disposal/Recovery*1

Location of

Disposal/Recovery*1

Agent & Transporter Licence/ Permit Ref.

Hazardous Waste

08 03 02*

08 03 03

08 03 06*

08 03 07

08 03 08

Ink / solvent 41718 R2

C – Offsite SRCL W0055-02; WCP: NWCPO-09-

01178-02

C – Offsite SRCL W0055-02; WCP: NWCPO-09-

01178-02

15 01 10* Drums 9600 kg R4

C – Offsite (National

Recycling t/a

Hammond Lane

Recycling Co.

Cooke & Sons Transport

Ltd WCP-DC-09-1184-01

Final recovery: Remet

Company NR80115

15 02 02* Used cloth wipes 14576 Recycling

SRCL

SRCL

W0055-02; WCP: NWCPO-09-

01178-02

08 04 09*

08 04 10 Glue N/R Recycling Burgess Galvin Burgess Galvin N/A

Other Waste

15 01 02

15 01 02

15 01 04

15 01 04

15 01 02

15 01 01

20 03 01

Shrink wrap

Plastic Buckets

Wire

Steel banding

Film (not recyclable)

Paper (not recyclable)

Office&canteen waste

55

D1

B – Offsite Ireland

Advance Waste

NER Recycling

W0183 - 01

15 01 01 Baled paper 612 R3 NER Recycling

NER Recycling

W0183 - 01

15 01 02 PP Film 67 Recycling NER Recycling

NER Recycling

W0183-01

15 01 03 Wood N/R N/A Sligo Pallets Sligo Pallets (N/R: Not Recorded) N/A = Information not available

*1 Codes taken from EPA Guidance Note for AER


Resource Consumption

2.1.1 Energy Consumption

The consumption of energy on-site for 2013 is shown in the following table:

Table 5 Energy Consumption Resource Supplier Consumption

2008

Consumption

2009

Consumption

2010

Consumption

2011

Electricity ESB 1,296,356KWh 1,359,164KWh 1,379,691KWh Gas Bord Gáis 798,322kWh 706,815kWh 816,376kWh 869440kWh Gasoil Clarke Oil 7,500 L Not in use Not in use Not in use

Resource Supplier Consumption

2012

Consumption 2013

Electricity Energia 1,817,160 1,840,380

Gas Energia 728,702 558,358

Gasoil Not in use Not in Use Not in use

2.1.2 Water Consumption

The consumption of water on-site for the year 2013 is shown in the table below.

Table 6 Water Consumption Resource Consumption

2006

Consumption

2007

Consumption

2008

Consumption

2009

Consumption

2010

Water 340,000L 454,000L 454,000L 454,000L 454,000L

Resource Consumption

2011

Consumption

2012

Consumption

2013

Water 454,000L 454,000L 454,000L


3 Agency Monitoring and Enforcement

Emission sampling and monitoring by Agency laboratory staff:

Air monitoring was carried out by Euro Environmental.

3.2 Site visits and inspections carried out by an Agency Inspector:

One site inspections were carried out by the Agency during the year 2013

A site inspection was carried out on the 20/02/2013 (Site Inspection Report issued

on the with reference (P0197- 02, 22022013 SI Report)

Date Reference Content

Notification of Non-Compliance/Site Inspection

Report associated with site inspection of Non Compliances:

Incident not reported of burst oil pipe at baler.

Underground pipeline testing needs to be

completed.

Observations

Bund integrity tests need to be done.

Staff need refresher training - & signed off

records

SW Q4 for 2012 detected ¾ Methlphenol.

When correction actions could not immediately be taken following these reports, they were

included in the Environmental Management Programme

There was no detailed audit carried out by the Agency in 2013


4 Environmental Incidents and Complaints

4.1 Environmental Incidences

As can be seen in the following table, there were no environmental incidences on site

during the course of 2013

4.2 Environmental Complaints Summary

There were no environmental complaints associated with the site during the course of 2013


5 Environmental Management

5.1 Environmental Management Programme (EMP) Report

The EMP Report addresses the implementation of each objective and target (O&T) set in a previous EMP.

Table 7 EMP Report

OT

No. Objective Target Progress Current Status

OT6 Reduce the quantity of waste sent for disposal Ongoing This objective is considered as an on-going project.

Waste is monitored tightly, with an excel

spreadsheet being completed daily.

Ongoing

OT7 Reduce compressed air leaks around the

factory

Ongoing Ongoing

OT9 Provide appropriate training for the newly

appointed environmental manager of the

company. Also, Eithne Hendricken is on an

ongoing basis bringing supervisors up to

speed with Environmental System and

Procedures.

Ongoing Training was given to the environmental manager

(Ms. Eithne Hendricken) in 2006.

Three of the supervisors were have been trained by

the Environmental Manager in 2008 and are now

involved in maintaining the EMS.

This objective is considered as ongoing.

Ongoing

OT14 Investigate the impact of surface water

discharge on the receiving ground

Under investigation in consultation with

hydrogeologist

Work in progress

OT16 Water Minimisation and Raw Materials

Assessment,

Ongoing As per Conditions 7.3 and 7.4 of the licence Ongoing

OT19 Change as much as possible inks to water

based inks by printing in line

Ongoing This is improving on an ongoing basis, as we have

bought improved rollers for in line printing on some

machines, as achieving better quality of print so able

to print more in line using water based inks.

Ongoing


5.2 Proposed Schedule of Environmental Objectives and Targets for 2014

The Objectives that were not complete for 2013 were carried over to the schedule for 2014. Also, our companywide project for 2013 is

reduction in waste which covers a few of the objectives below.

Basically, raw material assessment is the basis for this project and it is only by seeing issues as they arise that we know where waste is

coming from and we put corrective action in place to eliminate waste.

Table 8 Environmental Objectives & Targets

Objective

No. Objective

Target Date

(end of)

OT6 Reduce the quantity of waste sent for disposal Ongoing

OT7 Reduce compressed air leaks around the factory Ongoing

OT9 Provide appropriate training for the newly appointed environmental manager of the company Ongoing

OT14 Investigate the impact of surface water discharge on the receiving ground- further work required. Ongoing

OT16 Water Minimisation and Raw Materials Assessment Ongoing

OT17 Residual Management Plan (reviewed in March 2011) Ongoing

OT18 Environmental Liabilities Risk Assessment complete

OT19 Change as much as possible to using water based inks around the factory Ongoing

OT20 Raw Material Assessment – ensuring most efficient materials are used to get best production and

reduce waste.

Ongoing


5.3 Environmental Management Programme Proposal for 2013

Objective Number OT 6

Objective Title Ensure reduction in the quantity of solid waste sent for disposal

Target Ongoing

Responsibility Eithne Hendricken

Guiding Principles

According to the Waste Management Act and PoE Act 1996-2003, waste must not be

generated unnecessarily. All companies must attempt to reduce, reuse and recycle their

waste rather than dispose of it.

In 2007, a significant improvement in the quantities of wastes generated was achieved. In

2008, the tonnage of waste to landfill remained the same and production increased

significantly. We are aiming to reduce this to smaller bin this year from the open skip.

This objective is considered as ongoing as further improvements should always be

achievable.

Plan

Step Target

1. Create a database for waste to record

(i) The significant waste streams generated by AB Converters

(ii) Approximate quantities generated per annum

(iii) The route of reuse/recycling/disposal for all these wastes

(iv) The names and contact details of all contractors involved in

the movement and disposal of the waste

(v) The permit/licensing reference numbers of all contractors

Complete

2. Implement a Waste Reduction Programme e.g. select a team of employees

to provide suggestions on how solid waste can be

(a) Reduced

(b) Reused

(c) Recycled

(in particular determine if wastes can be segregated for baling and recycling)

We changed compactor to be used for recycling paper as there should be a

larger quantity of paper being recycled than MMW going to landfill so this

gives better use of the compactor. We are now compacting all paper and

segregating this to brown and white paper. We continuously review the

contents of the skip to see if there is any way to reduce the contents.

Ongoing

2. Supervisors are responsible for updating files on quantity of waste

leaving the factory, and so they keep a close eye on waste. Finance

director and quality / environmental manager meet with supervisors on

an ongoing basis to discuss ways to reduce waste.

ongoing



Objective Title Reduce compressed air leaks around the factory

Target Ongoing


Guiding Principles Surveys in the UK have shown that as much as 50% of the compressed air generated by

compressors in factories escapes the compressed air system through leaks. Reduction of

compressed air leaks can therefore significantly increase the energy efficiency of the

compressed air system and therefore reduce energy costs. Surveys have shown that in the

UK for typical industrial plant the average compressed air leakage was 39% and this could

usually be reduced to 18% leading to relatively large energy savings. Gerry Jackson

(Technical Manager) is working on this on an ongoing basis, as leaks are encountered.

Plan

Step Target

1. AB Converters will arrange for the leaks to be sealed as they are found. Ongoing



Objective Title Ensure back up for Environmental Manager

Target Ongoing


Guiding Principles AB Converters recruited a new environmental manager in 2006 (Ms. Eithne Hendricken).

Training was provided to Ms. Hendricken by Environmental Efficiency Consultants.

Training was then provided by Ms. Hendricken to the four supervisors of the production

floor (day shift, night shift, weekend day and night shift supervisors) to ensure that there is

a trained person (i.e. aware of the requirements of the IPPC licence) at all times on the site.

The Environmental Manager, is on an ongoing basis training, production manager, and

supervisors on various aspects of Environmental Management in AB Converters. Plan

Step Target

1. Any additional information/training to be provided by Environmental Efficiency

Consultants Ltd.

Complete

2. Any other training need for the personnel to be identified on an ongoing basis. Ongoing

3 Environmental Manager to ensure that all staff are aware of any new

environmental procedures, especially the segregation of waste currently.

Ongoing.

4. Plan to give training to all staff on environmental and H&S in second quarter of

2014, to ensure compliance with licence and ensure all staff are aware of all

procedures.

Ongoing



Objective Title Investigate the impact of the surface water discharge on the receiving

ground

Target


Guiding Principles The surface water discharge from the site consists of surface water from the company car

park. This surface water is currently routed through one of two interceptors and into a

percolation bed prior. The Agency has requested that an investigation be carried out on the

impact of this discharge on the receiving ground. AB Converters has contacted a specialist

company, S. M. Bennet & Co. Ltd, to propose a programme for this investigation. The

report was sent to the EPA, there was one chemical found, which would not have been

found in raw materials from AB Converters.

It is believed that this chemical came from neighbouring site.

S.M. Bennet suggested we leave this and retest in the future.

AB Converters will communicate again with Shane Bennet in 2nd

quarter 2014, to see how

he suggests we proceed.



Objective Title Water minimisation and raw materials assessment

Target Ongoing


Guiding Principles Condition 7.3 of the reviewed IPPC Licence states that “the licensee shall identify

opportunities for the reduction of quantity of water used on site including recycling and

reuse initiatives, whenever possible”.

Condition 7.4 of the reviewed IPPC Licence states that “The licensee shall undertake an

assessment of the efficiency of use of raw materials in all processes, having particular

regard to the reduction in waste generated”.

The Licence requests that these reports be completed within The recommendations made in

these two reports should be incorporated to the schedule of objectives and targets for the

next AER.

Plan

Step Target

Complete the assessments and submit to the Agency Water –

complete

Raw material –

ongoing.

Incorporate recommendations of the report into the Objectives and Targets of the

next AER

Ongoing

Water is not used on site so very little opportunities to improve.

Raw material Assessment is being carried out currently.

Raw material assessment and reduction of waste is new company wide project.

We have greatly reduced the quantity of MMW we send to landfill.

We recycle as much as possible, dividing into brown and white paper.

We purchased scales in Oct 09 to weight waste so we are currently analysing data.

AB Converters are working on continuous improvement in this area.

Training is ongoing, as once machine is running smoothly there will be less waste.

We invest alot of time and money in training with the hope of reducing waste of resources

and time.

We carry out ongoing trials on glues to ensure we are using the most effective glue.

If there is an issue with any raw material, we involve the supplier immediately to avoid

excess waste.



Objective Title Residual Management Plan

Target Ongoing


Guiding Principles Condition 10.2.1 of the reviewed IPPC Licence states that “the licensee shall prepare, to

the satisfaction of the Agency, a fully detailed and costed plan for the decommissioning or

closure of the site or part thereof. This plan shall be submitted to the Agency for agreement

within six months of the date of grant of this licence.”

Plan

Step Target

Compile the residual management plan and submit to the Agency for approval Complete

Submitted to EPA

March 2011 – RMP to be revised to reflect current market prices.

As a result of this, AB Converters must provide acceptable financial provision to the

agency.

The CRAMP was revised in 2013, by Environmental and Technical Managers in AB

Converters. EPA had some queries on this, so these are being investigated currently.



Objective Title Changing Inks to water based around the factory

Target Ongoing.


Guiding Principles

AB Converters are working on eliminating the use of solvent based inks where possible in

the printing process. This involves amendments to machinery and a full new water based

dispense for water based inks. This work will be ongoing.

Plan

Step Target

Build new water based ink dispensing system. Do trials on machine on different

jobs to investigate where water based inks can be used.

Ongoing.

AB Converters are working on putting in water based inks system so major projects are on

hold as all resources are going into building new area and purchasing new equipment to

move as much work as possible to water based inks.

There are now water based printers at 6 of our conversion machines so bag is being printed

and made in one step and also, water based instead of solvent based inks are being used.

On a daily basis the planner and print manager, work on reducing the number of jobs (pre

printed- solvent based ink) to print in line (water based ink).

Rollers have been upgraded on some of our in line printing machines to try to improve the

quality of print to allow us to print more jobs in line in water based inks.



Objective Title Raw material Assessment – in order to reduce waste by using most

effective raw materials.

Target December 2010


Guiding Principle

Under condition 7.4 , the licensee shall undertake an assessment of the efficiency of use of

raw materials in all processes, having particular regard to the reduction in waste

generated.

Plan

Step Target

All staff have been spoken to on the reduction of waste and where they come

across a situation that they have a significant amount of waste, they immediately

contact their supervisor.

Ongoing.

Waste is being measured on an ongoing basis and supervisors are working on ways of

reducing it on an ongoing basis.

Waste occurs for many reasons and each time we see significant waste we put corrective

action in place. Examples include the following:

1. Incoming raw material if damaged can result in waste so if any reel is damaged as it

arrives, we take photos and inform supplier and if it continues, we request credit to

eliminate it.

2. Printed reels can be damaged, after printing and before conversion to bags and we

are working at eliminating this by working with warehouse staff.

3. On occasions, reels are too large for certain machines, so our planner has to give

absolute maximums on reel diameter when purchasing various reels, eg handles or

patches, to avoid cutting back reels.

4. We are also looking at eliminating throwing out large amounts of glue.

We are ensuring we have at least 2 suppliers of all basic raw materials, so we have one for

comparison at all times.

We are working towards standardising bag sizes and encouraging customers to work with

our standard bags and packing them in our standard way, that works, rather than changing

specifications on an ongoing basis, where there is more waste produced.


5.4 Pollution Register and Transfer (PRTR) – Proposal

The company was given instruction by the Environmental Protection Agency regarding the

information to submit as part of the PRTR.

5.5 Pollution Register and Transfer (PRTR) – Report

The PRTR excel sheets sent to the Environmental Protection Agency are provided in this

section:


Pollution Emission Register

AB Converters were required under their previous Licence to track Total Organic Carbon

(as C), under the PER List in Appendix 2 of the EPA IPC Licensing Guidance Note for

Annual Environmental Report. Total Organic Carbon (as C) was tracked in the previous

years. Although the requirement has now changed and only the PRTR has to be reported,

the PER table 2009 is included here for completeness. Detailed explanation of the

calculations is provided in the Fugitive Emissions Assessment (Document No.526-24)

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