Fugitive Emissions Assessment 2013 - EPA · 2017. 6. 25. · Table 2-1 Solvent Consumption 2016...

Registered Office: Parnell House, 19 Quinsboro Road, Bray, Co. Wicklow A98 XV04. Registered Number 243 412 Directors: Robert B. Sutcliffe, Ronan T. Sutcliffe

Environmental Services for Industry Including – ► Air, Noise & Water Monitoring ► Energy & Water use reduction ► Bund Testing ► IPC/IED/Waste Licence Compliance ► Environmental Management Systems to ISO 14001 ► EIS & Planning ► Air & Noise Modelling ► Occupational Dust & Noise

Affiliations & Accreditations ► ISO9001:2008 Registration No. 2015/2170 ► ISO14001:2004 Registration No. 2012/1427 ► MCERTS Certified personnel for stack testing ► Member of Royal Society for Prevention of Accidents ► EMPI Membership

Bray (Co. Wicklow) 01 276 1428 Lisburn (Co. Antrim) 028 9262 6733 Birmingham (U.K.) 0121 673 1804

Fugitive Emissions Assessment 2016

for

Sleever International Ltd

Document No.: 1929-01 Version 1.01

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Sleever International Fugitive Emissions Assessment 2016

Environmental Efficiency Document No.: 1929-01 v.1.00; of 19

Project Start Form

Task

Task (summary) AER PRTR Fug Emissions

Order logged by RBS Date

Proj Manager RD Target hours

MS required? No Analysis cost, €

Involves lab? No Hire costs, €

Site visit required? No Fee (specify € or £)

UIK 5715 Date invoiced

Sage Invoice Number VAT Rate

Contact address 65 Heather Road, Sandyford Industrial Estate, Dublin

Client phone

Client email [email protected]

PO covers Multiple documents

Document Lead Sheet

Clie

nt

Organisation Flight Group Ltd. Aka Sleever

Site 65 Heather Road

Permit/Lic No. (if applic) P0674-01

Client contact Sydney Osthuizen

Ord

er Description of task AER PRTR Fug Emissions

Proposal number None

Client PO

Invoice on Issue of this document

Del

iver

able

Report title Solvent Management Plan

Document number 1929-01

Report template As per previous report

Type of document Report

Method Statement N/A Date written N/A

Format for issue PDF

Ap

pro

val &

Issu

e Site visit by N/A Date last site visit N/A

Document author VB Date written 08/03/2017

Approved by Choose Date approved 20/03/2017

Report version nr 1.01

Issued by RD Date report issued 20/03/2017

Doc issued to [email protected]

Method issue Email

Act

ion

All results satisfactory Yes

If not satisfactory, further testing required N/A

If satisfactory, when is next test due?

Key to personnel

RBS Bob Sutcliffe, Director, CEng, MIMechE, MIEI,CEM

RTS Ronan Sutcliffe, Director, Dip. Environmental Protection

GB George Byrne, MSc Biosystems Engineering

RD Richard Deeney, B.Sc. AIEMA

JC John Cullen, BAgSc, P.Grad.Dip Environmental Engineering

VB Valerie Browne, BSc Environmental and Earth System Science

Conditions relating to the issue of this report: 1. No alteration to this report by third parties is permitted 2. Where this report is reproduced, it shall only be reproduced in full. 3. Reports remain the property of Environmental & Efficiency Consultants (Ireland) Limited until paid for in full.

Report History V1.00 – First Issue V1.01 – Formatting changes

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Table of Contents

1 INTRODUCTION ....................................................................................................... 4

2 EXECUTIVE SUMMARY ............................................................................................. 5

3 FUGITIVE EMISSION ASSESSMENT METHODOLOGY ................................................... 7

3.1 DETERMINATION OF THE DIFFERENT INPUTS AND OUTPUTS: ..................................................... 8 3.2 DETERMINATION OF THE ENVIRONMENTAL SIGNIFICANCE OF THE FUGITIVE EMISSIONS ............... 10

4 CALCULATIONS ...................................................................................................... 11

4.1 DETERMINATION OF I1 .................................................................................................... 11 4.2 DETERMINATION OF O1 ................................................................................................... 11 4.3 DETERMINATION OF O6 ................................................................................................... 12

4.3.1 Solvent/Solvent-based Ink/Solvent Sludge ........................................................ 12 4.3.2 Empty containers ............................................................................................... 13 4.3.3 Solvent contaminated rags ................................................................................ 14 4.3.4 Calculation of O6 ............................................................................................... 15

4.4 DETERMINATION OF FUGITIVE EMISSIONS ........................................................................... 15

5 CONCLUSION ......................................................................................................... 16

Table of Tables Table 2-1 Solvent Consumption 2016 ....................................................................................... 6 Table 4-1 Summary .................................................................................................................. 11 Table 4-2 O1 Summary ............................................................................................................ 12 Table 4-3 Solvent/Ink/Sludge Waste ....................................................................................... 13 Table 4-4 Solvent Output in Empty Containers ....................................................................... 14 Table 4-5 Solvent Output on Rag Waste ................................................................................. 14 Table 4-6 O6 Summary ............................................................................................................ 15

Table of Figures Figure 3-1 Solvent mass balance framework ............................................................................ 8

Table of Appendix Appendix 1 Details of calculation of the quantities of inks put into the process .................... 17 Appendix 2 Details of calculation of the quantities of solvents put into the process ............. 18 Appendix 3: Additional Fugitive Emission Calculations based on varying air emissions. ........ 19

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1 Introduction Sleever International operates in accordance with an Integrated Pollution Control

Licence (IPC Licence No. P0674-01) administered by the EPA. Under this licence

Sleever International are required to prepare an annual Fugitive Emissions

Assessment for the purpose of evaluating emissions to air as a result of the

unintended loss or release of volatile vapours associated with solvent-based

materials utilized on-site during processing.

Sleever International falls under the scope of the S.I. 565 of 2012 European Union

(Installations and Activities using Organic Solvents) Regulations 2012 (herein labelled

as the Solvent Regulations 2012), as they are involved in the use of surface coating

materials with a capacity to use greater than 15 tonnes per year of organic solvents.

As such, the obligation to conduct a Fugitive Emissions Assessment on an annual

basis, as per these regulations (and pre-existing superseded regulations), has been

incorporated into their IPC licence. Condition 5.9 of their IPC licence stipulates that;

‘The licensee shall prepare a programme, to the satisfaction of the Agency, for the

monitoring of fugitive emissions to air. This programme shall be submitted to the

Agency for agreement, within six months of the date of grant of this licence and shall

be fully implemented within three months of the date of such approval or such other

time as the Agency may allow. A full report on fugitive emissions to air shall be

included annually in the AER.’

Environmental Efficiency Consultants Ltd has been commissioned by Sleever

International to carry out this work. This assessment has been carried out in

accordance with the mass balance methodology outlined in Schedule 6 of Solvent

Regulations 2012.

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2 Executive Summary With reference to Schedule 2 of the Solvent Regulations 2012 it was determined that the

fugitive emission limit value for the activity concerned (where greater than 15 tonnes of

solvent is consumed annually) is 20% of total solvent input. In 2016 Sleever International had

a total solvent consumption of 25.3 tonnes; see Table 1-1 below for solvent use figures.

A mass balance analysis of Total Organic Carbon as Carbon (TOC as C) inputs and outputs

took place in order to estimate fugitive emission levels. TOC as C is considered a

representative parameter that correlates to organic solvent use. Fugitive emissions or in

other words, the unintended loss of solvent vapours, are represented by the difference

between TOC as C inputs and outputs relating to solvent use (i.e. the loss differential

between input and output). This figure is subsequently expressed as a percentage of the

total TOC input into solvent using processes and compared with the fugitive emission level

stipulated.

Calculations from the mass balance analysis conducted show that Sleever International has a

fugitive emission level of 8% of total TOC as C inputs arising from solvent use. This fugitive

emission level therefore is in compliance with the fugitive emission limit value of 20% for

such surface coating operations, as stipulated in the Solvent Regulations 2012.

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Table 2-1 Solvent Consumption 2016

Total Solvent Component

Product kg Component kg TOC as C kg

Solvent Based Inks Total Purchases 17,732 12,191 6,558

Stock 01/01/2016 4,665 3,207 1,725

Stock 31/12/2016 4,454 3,062 1,647

Total Consumption (inks) 17,943 12,336 6,636

Solvent Products Total Purchases 20,490 20,490 11,156

Stock 01/01/2016 2,140 2,140 1,165

Stock 31/12/2016 2,060 2,060 1,122

Consumption (Solvent Products) 20,570 20,570 11,200

Total Solvent Consumption 38,513 25,306 17,836

Solvent Waste Total Solvent Waste 20,544 14,630 12,604

Total Air waste 8,134 6,950 3,767

Total Waste 28,678 21,580 16,371

Consumption minus waste output 9,835 3,727 1,465

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3 Fugitive Emission Assessment Methodology

The following fugitive emission assessment methodology is outlined in Schedule 6 of the

Solvent Regulations. The calculation of the fugitive emissions is done through mass balance

analysis, using one of the two following equations:

F = I1 – O1 – O5 – O6 – O7 – O8

F = O2 + O3 + O4 + O9

The definitions for the terms used in these equations are as follows:

Inputs of organic solvents (I)

I1: The quantity of organic solvents or their quantity in preparation purchased which

are used as inputs into the process in the time frame over which the mass balance is

being calculated

I2: The quantity of organic solvents or their quantity in preparations recovered and

reused as solvent input into the processes

Outputs of organic solvents (O)

Emissions in extracted waste gases (O1)

Organic solvents lost in water (O2)

The quantity of organic solvent which remains as contamination or residue in

products manufactured during processing (O3)

Uncaptured emissions to organics solvents to air (O4)

Organic solvents lost due to chemical or physical reactions (O5)

Organic solvents contained in collected waste (O6)

Organic solvents or organic solvents contained in preparations which are sold or are

intended to be sold as a commercially valuable product (O7)

Organic solvents contained in preparations recovered for reuse but not as input back

into the process (O8)

Organic released in other ways (O9)

These inputs and outputs are shown in the following figure;

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Figure 3-1 Solvent mass balance framework

(Source: EPA July 2003, Best Practice guide produced by the Environmental Protection Agency

Approved date 17th July 2003 www.epa.ie)

3.1 Determination of the different Inputs and Outputs:

The information that is available at the site and from the various monitoring carried out

suggests that the following equation is the most suitable to determine the fugitive emission

value for the site:

F = I1 – O1 – O5 – O6 – O7 – O8

It is therefore proposed that this equation be used for the assessment.

The different parameters of this equation will be calculated as TOC as C and for the same

period to be comparable.

I1: The quantity of solvent purchased during the given period:

I1 = Opening Stock + Purchases during the period – Closing Stock

The TOC as C contribution of the inks and solvents will be calculated with reference to the

MSDS sheets for each of the individual substances and the molecular formula of the

constituents.

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O1: Emissions in waste gases/vapours:

TOC as C mass emissions from stacks situated on-site will be calculated with reference to air

monitoring conducted during 2016. The concentration of TOC as C obtained from this

monitoring will be multiplied by the estimated volume flow of waste air emissions to derive

TOC as C mass flow for a set time period. The total amount of operating hours over which

processing took place during 2016 will be identified, and the mass emissions of TOC as C for

the study period will be calculated. It should be noted that stack emissions differ from

fugitive emissions as they are intended losses to the environment through a designated

route. As such, stack emissions are controlled, monitored and evaluated in accordance with

Schedule 1 of the IPC licence P0674-01.

O5: Organic solvents lost due to chemical or physical reactions:

At present, none of the processes used by the company leads to the loss of solvent due to

chemical or physical reactions.

O6: Organic solvents contained in collected waste:

In 2016 organic solvents were contained in three types of collected waste at the site:

Solvent/ink/solvent sludge: The quantity of ink, solvent and solvent sludge disposed

of is recorded. The average proportion of TOC as C in each waste stream was

assumed to be the same as in the purchased products.

Solvent residues on empty containers: According to 40 CFR 261.7, a container

holding non-acute hazardous waste can be considered as empty if:

o all wastes have been removed using practices commonly employed industry-

wide to remove wastes from containers or liners, such as pouring, pumping,

aspirating, and draining (§261.7(b)(1)(i)), and

o no more than 2.5 centimetres (1 inch) of material remains in the container

or liner (§261.7(b)(1)(ii)), or

o no more than 3 percent by weight of the container remains for containers

with a capacity of 110 gallons or less, and no more than 0.3 percent by

weight remains for containers with a capacity greater than 110 gallons

(§261.7(b)(1)(iii)).

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Therefore, the quantity of solvent residues in empty containers will be calculated on the

basis that 3% by weight of the purchased solvent ultimately remains in the containers (All

containers have a capacity that is lower than 110 gallons or 416L).

Solvent residues on cleaning rags: The amount of solvent residues in the cleaning

rags is believed to be very low as most of the solvent evaporates. The quantity of

solvent remaining in the rags is believed to be inferior to 5%. For the purpose of the

assessment and to be conservative, it is proposed to take a percentage of 2.5% for

the calculation.

O7: Organic solvents or organic solvents contained in preparations which are sold or are

intended to be sold as a commercially valuable product: The products sold by the company

do not contain any solvent. All the solvent applied onto the unfinished products during the

printing operation are believed to be emitted to the atmosphere by the air emissions stacks

or as part of the fugitive emissions.

O8: Organic solvents contained in preparations recovered for reuse but not as input into the

process, as long as not counted under O7:

The company does not recover solvent on-site.

3.2 Determination of the environmental significance of the fugitive emissions

As suggested in Schedule 6 of the Regulations, the fugitive emission value obtained following

the methodology outlined in Section 3.1 will be expressed as a proportion of the input,

which can be calculated using the following equation:

I = I1 + I2 With

I1: The quantity of organic solvents or their quantity in preparation purchased which

are used as inputs into the process in the time frame over which the mass balance is

being calculated (2016 Calendar year)

I2: The quantity of organic solvents or their quantity in preparations recovered and

reused as solvent input into the processes.

The company does not recover any solvent and therefore in this case: I = I1

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Determination of the environmental significance of the fugitive emissions at the site:

The obtained figure will then be compared to the fugitive emission value threshold set out in

Schedule 2 of the Solvent Regulations 2012. For surface coating activities carried out within

Sleever Internationals facility, the maximum permissible value for fugitive emission levels is:

25% of total solvent input where the solvent consumption is between 5 and 15

tonnes, or;

20% of total solvent input where the solvent consumption is above 15 tonnes.

4 Calculations 4.1 Determination of I1

The quantities of solvents and inks purchased in 2016 and the stock figures for the beginning

and the end of the year were reviewed, in order to calculate the solvent input to the

process. All the available MSDS’s for the organic solvent were also reviewed so that the

quantities could be expressed in TOC as C.

The summary figures for the calculation of I1 are presented in the following table and the

details of the calculation are provided in Appendix 1 and Appendix 2.

Table 4-1 Summary

Ink input into the process (kg of C)

6,636

Solvent input into the process (kg of C)

11,200

Total (kg of C) = I1 17,836

4.2 Determination of O1

Air emission monitoring which was conducted on-site during 2016 was reviewed. TOC as C

mass emissions were averaged calculated in kg/hour and multiplied by the hours of

operation of the printers for the year in order estimate annual TOC as C output through

stack air emissions.

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Table 4-2 O1 Summary

A2-01 A2-02

TOC as C result (kg/hr) TOC as C result (kg/hr)

Average 2016 0.64 0.02

Annual running hours 5700 6100

Annual emissions (TOC as C in kg/yr) 3640 127

Total (kg/yr) = O1 3,767

4.3 Determination of O6

As mentioned in Section 3.1 of this report, there were three types of waste stream

containing solvents generated at the site in 2016:

Solvent/ink/solvent sludge

Empty containers

Solvent contaminated rags

4.3.1 Solvent/Solvent-based Ink/Solvent Sludge The amount of solvent-based waste disposed of in 2016 was recorded by the company. The

composition of waste solvent is considered to be proportionate to the composition of

solvent input. As such, the average TOC as C content of solvent/solvent-based ink inputs was

used to determine the TOC as C content of the sludge.

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Table 4-3 Solvent/Ink/Sludge Waste

TOC as C in Solvent/Ink/Sludge

Solvent waste(kg) 7,600

% TOC as C in solvent waste 54%

Total solvent waste (as C) (kg) 4,138

Solvent sludge waste 7,600

% TOC as C in solvent sludge waste 100%

Total solvent sludge waste (as C) 7600

Average TOC as C content in inks and solvent (%) 46%

TOC as C (kg/yr) 11,378

Note 1: Weighted average based on solvent/solvent ink input 4.3.2 Empty containers The number of empty containers disposed of is recorded by the company as part of their

environmental management system. As explained in Section 3, it is considered that empty

containers (<415 l) still hold 3% of their content when they are empty. An average density of

0.95kg/L of the product waste per litre has been calculated based on recorded volumes and

weights of disposed sludge. (N.B. Weighted average TOC as C content in inks/solvent is 46%).

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Table 4-4 Solvent Output in Empty Containers

TOC as C in Empty 200L Barrels

No: of barrels 104

Percentage residue in barrels (%) 3

Density of product kg/L 0.95

Weight of product kg 622

Weight of solvent kg 532

TOC as C (kg/yr) 288

TOC as C in Empty 25L containers

No: of containers 1,680

Percentage residue in barrels (%) 3

Density of product kg/L 0.95

Weight of product kg 1,197

Weight of solvent kg 1,023

TOC as C (kg/yr) 554

TOC as C in Empty containers

Total TOC as C (kg/yr) 843

4.3.3 Solvent contaminated rags The volume of solvent contaminated rags disposed of each year is known. The average

weight of rags calculated from this recorded volume is 333 kg per 1,000 litre haz box. As

previously mentioned in Section 3 of this report, a concentration of solvent in the rags of

2.5% was used for the calculations. (N.B. Weighted average TOC as C content in inks/solvent

is 46%).

Table 4-5 Solvent Output on Rag Waste

TOC as C in Solvent Rags

Quantity of solvent rags (kg) 3525

Weight of solvent in rags (kg) 50

TOC as C (kg/yr) 23.16

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4.3.4 Calculation of O6

Table 4-6 O6 Summary

O6

Solvent/Ink sludge (kg) 11,738

Empty Containers (kg) 843

Solvent rags (kg) 23.16

O6 - TOC as C (kg/yr) 12,604

4.4 Determination of Fugitive emissions

As previously mentioned, the formula used to calculate the fugitive emissions is: F = I1 – O1 – O5 – O6 – O7 – O8

Or in this instance F = I1 – O1 – O6

Where:

F= I - O1-O6

F% = F/Total Inputs ( C based solvents/inks)

I = I1 + I2

I1 = 6,636 kg

I2 = 11,200 kg

I = 17,836 kg

O1 = 3,767 kg

O6 = 12,604 kg

F =17,836 – 3,767 – 12,604 = 1,465kg

F% = I

F = 1,465/17,836 = 8% of solvent input

Fugitive emissions represent 8% of organic solvent input.

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5 Conclusion The quantity of solvents used during processing during 2016 was 25.3 tonnes.

All records obtained and reviewed regarding solvent consumption, emissions to atmosphere,

and waste quantities were readily available on-site and in a form conducive to the

completion of mass balance analysis.

Fugitive emission levels were calculated at 8% of total solvent input. As such, Sleever

International Ltd is in compliance with the applicable fugitive emission limit value of 20%, for

their onsite activities.

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Appendix 1 Details of calculation of the quantities of inks put into the process

Solvent KG total Solvent component % kg solvent TOC as C

INK - EVASION CAP

WHITE 5,000 Ethyl Acetate 47.50 2,375.00 1,295.45

Ethanol 25.00 1,250.00 652.17

2-ethylhexyl

diphenyl phosphate 2.50 125.00 83.80

FARDALAGE - Unknown 70.00 - -

SOLVENT PRIMER 3,870 Unknown 72.50 2,805.75 1,509.30

PVC SHRINK TEC VSH 1,375 Ethanol 50 688 358.70

Propan-2-ol 5 68.75 41.25

STILETTO TONER 328 Ethanol 37.5 123.00 64.17

Ethyl Acetate 12.5 41.00 22.36

N-Propyl Acetate 12.5 41.00 24.12

Propan-1-ol 12.5 41.00 24.60

STILETTO WHITE 40 Ethanol 37.50 15.00 7.83



Propan-1-ol 12.50 5.00 3.00

STILETTO COLOUR 1,555 Ethanol 37.5 583.13 304.24

Ethyl Acetate 12.5 194.38 106.02


Propan-1-ol 12.5 194.38 116.63

STILETTO

VARNISH/MEDIUM 400 Ethanol 37.5 150.00 78.26



Propan-1-ol 12.5 50.00 30.00

EVASION COLOUR 422 Ethanol 55 232.10 121.10


EVASION

VARNISH/MEDIUM 200 Ethanol 55 110.00 57.39


PVC SHRINK WHITE 2,701 Ethanol 50 1,351 704.61

Propan-2-ol 5 135.05 81.03

PVC COLOUR 766 Ethanol 50 383 199.83

Propan-2-ol 5 38.30 22.98

BLANC HELIOVYL WHITE 1,075 Unknown 73.50 790.13 419.25

Total Purchases 17,732 12,191 6,558.09

Opening Stock 01/01/2016 4,665 3,207 1,725.33

Closing Stock 31/12/2016 4,454 3,062.21 1,647.29

Total Consumption 17,943 12,336 6,636

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Appendix 2 Details of calculation of the quantities of solvents put into the process

Quantity purchased (kg)Composition

concentration

% Weight (kg)

TOC as C

Equivalent

M22 (MIX) 1700 N Proponal 75 1275.00 740.32

N-propyl acetate 25 425.00 250.00

M01 (MIX) 10,187 Methanol 4 407.48 135.83

Ethanol 76 7742.12 4039.37

Ethyl Acetate 20 2037.40 1111.31

NPA 4371 N-propyl acetate 100 4371.00 2571.18

THF 0 Tetra hydrofuran 100 0.00 0.00

EA 4,232 Ethyl Acetate 100 4232.00 2308.36

EP 0 Ethoxy Proponal 100 0.00 0.00

NIMROD REDUCER 0 Ethanol 100 0.00 0.00

Ethyl Acetate 0.00 0.00

TSDA3 0 Alcohol 100 0.00 0.00

Total Purchased 20,490 20,490 11,156

Stock 01/01/2016 2,140 2,140 1,165.18

Stock 31/12/2016 2,060 2,060 1,122

Total Consumption 20,570 11,199.92 20,570 11,200

Average TOC as C

proporation 54%

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Appendix 3: Additional Fugitive Emission Calculations based on varying air emissions.

A3.1: Fugitive Emissions based on air emissions at 100% ELV Where:

F= I - O1-O6


I = I1 + I2

I1 = 6,636 kg

I2 = 11,200 kg

I = 17,836 kg

O1 = 4736 kg

O6 = 12,604 kg


A3.2: Fugitive Emissions based on air emissions at 75% ELV

Where:

F= I - O1-O6


I = I1 + I2

I1 = 6,636 kg

I2 = 11,200 kg

I = 17,836 kg

O1 = 2664 kg

O6 = 12,604 kg


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Fugitive Emissions Assessment 2013 - EPA · 2017. 6. 25. · Table 2-1 Solvent Consumption 2016...

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Transcript of Fugitive Emissions Assessment 2013 - EPA · 2017. 6. 25. · Table 2-1 Solvent Consumption 2016...