Henkel (Ireland) Ltd., Tallaght Solvent Mass Balance · PDF filelb Recovered Material Acetone...
Transcript of Henkel (Ireland) Ltd., Tallaght Solvent Mass Balance · PDF filelb Recovered Material Acetone...
Henkel (Ireland) Ltd, Solvent Mass Balance & PRTR 31 March 2017
Henkel (Ireland) Ltd., Tallaght Solvent Mass Balance & PRTR 2016
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:57
Henkel (Ireland) Ltd. Solvent Mass Balance 8r PRTR 31 March 2017
CONTENTS
4 . INTRODUCTION
2. PRTR METHODOLOGY
3. INTERPRETATION OF PRTR RESULTS
4. IMPROVEMENTS AND RECOMMENDATIONS
5 PRTR PROPOSAL FOR 2017 AT HENKEL (IRELAND) LTD., TALLAGHT
APPENDIX I
Summary Form
APPENDIX 2
Material Input
APPENDIX 3
Recovered
APPENDIX 4
Gross Usage
APPENDIX 5
Product
APPENDIX 6
Output to Air
APPENDIX 7
Waste
9
9
10
10
11
11
12
42
13
13
14
14
15
15
Page 2 of 15
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:57
Henkel (Ireland) Ltd. Solvent Mass Balance & PRTR 31 March 2017
I. INTRODUCTION
The preparation of a Pollutant Release and Transfer Register (PRTR) is a requirement of Regulation No 166/2006l . This Regulation amends the requirements of the Integrated Pollution Prevention and Control Licence (Reg. No. POO79-03), as issued to Henkel (Ireland) Ltd.:
”Condition 2.3.2.7
The substances to be included in the PER shall be agreed with the Agency each year by reference to the list specified in the AER guidance nofe, The P€R shall be prepared in accordance with any relevant guidelines issued by the Agency and shall be submitted as paif of the AER.
“Condifion 2.3.2.2
The licensee shall, not later than six months from the date of grant of this licence and thereafter as pad of the AER, agree with the Agency the list of substances to be included in the PER, and the methodology to be used in their defemination. I’
The PRTR substances chosen for 2016 were NMVOCs (acetone), toluene and copper. During 2016, there was no usage of toluene on-site; therefore this substance has not been included in this PRTR.
’ REGULATION (EC) No 766/2006 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 18 January 2006 concerning the establishment of a European Pollutant Release and Transfer Register
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:57
Henkel (fretand) Ltd. Solvent Mass Balance & PRTR 31 March 2017
2" PRTR METHODOLOGY
The objective of the PRTR is to ensure that the destination of major pollutants is tracked. A schematic representation of the PRTR is shown below. The stream numbers are discussed subsequently. The PRTR is summarized in Appendix 1.
A Product
Air
Liquid Emuent
Input PROCESS
Waste
Recovered Material Recovcred 4
L Unaccounted Treated f
The following is an explanation of the streams with particular reference to the Henkel site.
l a Input
The input of NMVOCs (acetone) and copper is determined from delivery records on the SAP system. The following equation summarises this methodology:
Fresh Material = Purchased Material f Virgin Material Change of Inventory.
Further details of the input of fresh material are provided in Appendix 2.
Principal Method of Measurement: Direct Measurement (M)
l b Recovered Material
Acetone is the only substance recovered on-site. The quantity of recovered acetone is determined from the SAP system.
Full details are given in Appendix 3.
Principal Method of Measurement: Material Balance (B) and Direct Measurement (W
2 Gross Usage
Acetone gross usage is obtained from altoeation records on the SAP system.
The gross usage figure for copper was obtained from the SAP system and Bill of Materials.
A breakdown of the gross usage figures is shown in Appendix 4.
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:57
Henkel (Ireland) Ltd. Solvent Mass Balance & PRTR 31 March 2017
Principal Mdhod of Measurement: Direct Measurement (M)
3 Product
Copper compounds are used in the manufacture of a number of products on site. The quantity of copper leaving the site was calculated based on the quantity of copper containing product manufactured during the year and the expected copper content of these products. A breakdown of these figures is shown in Appendix 5.
Principal Method of Measurement: Direct Measurement (#) and Material Balance (B)
4 Air
Outputs to air are from fugitive emission sources. The breakdown of the fugitive NMVOCs (acetone) emissions are detailed in Appendix 6. There are no licensed emission points relevant to the PRTR substances.
Principal Method of Measurement: Direct Measurement (M)
5 Liquid Effluent
This figure was calculated based on analysis results from trade effluent discharged to sewer.
Principal Method of Measurement: Direct Measurement (M)
6 Waste
The waste figure is the amount of waste produced by the site over the PRTR year. This is calculated by the following equation:
Waste Produced = Waste Sent Off-Site - Waste Change of Inventory
Several waste samples were analysed for PRTR material content during 201 6. A summary of this calculation is given in Appendix 7.
7 Recovered
The quantity of material recovered includes material recovered on-site and materia I recovered off-si te.
The quantity of material recovered on-site is equal to the quantity reused in the pilot plant and reused in the cleaning station. The quantification of this stream is detailed previously in this report.
Acetone from the cleaning station was recovered off-site during 2016.
Principal Method of Measurement: Direct Measurement (M)
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:57
Henkel (Ireland) Ltd. Solvent Mass Balance & PRTR 31 March 2017
a Treated
This category includes PRTR materials, which are consumed during production or treated on-site. This category is irrelevant for the Henkel site.
9 Unaccounted
This figure is obtained by difference between all inputs and outputs of the mass balance.
Principal Method of Measurement: Material Balance (8)
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:57
Henkel (Ireland) Ltd. Solvent Mass Balance 15 PRTR 31 March 2017
3. INTERPRETATION OF PRTR RESULTS
The PRTR Regulation sets thresholds for reporting of emission of pollutants. A summary of the 201 6 data is presented below:
Substance
NMVOGs (Acetone)
Copper
PRTR Threshold
2016 Result
PRTR Threshold
2016 Result
IO0 I 50 1 50
0 1 0 . 9 1 - I Therefore the releases to air, water and land of these pollutants da not exceed the applicable PRTR threshoid values specified in Annex II and are therefore not required to be reported.
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:58
Henkel (Ireland) Lld. Solvent Mass Balance & PRTR 31 March 2017
4.
5.
IMPROVEMENTS AND RECOMMENDATIONS
Improvements
Since 2007, waste acetone from EBF is being re-used in the Cleaning Station, This has resulted in less acetone being purchased at the site.
Nitromors has been removed from standard use
A number of waste categories were analysed in 2016.
Recommendations
Henkel (Ireland) Ltd. Tallaght aims to decrease this unaccounted figure, even further, by implementing the following recommendations during the next study period.
a It is important that regular analysis of the acetone waste streams at Henkel be continued during 201 7.These waste streams include Waste Category I (Pilot Plant), Waste Category I (Biomedical Facility), Waste Category 0 (Cleaning Station) and Waste Category P (Waste Acetone).
Check for other products containing raw materials with Copper
Check for other waste streams potentialIy containing Acetone
Improve tracking of Acetone use on the SAP system
PRTR PROPOSAL FOR 2017 AT HENKEL (IRELAND) LTD., TALLAGHT
A Pollutant Release and Transfer Register will be generated for the Tallaght site for 201 7. The PRTR to be submitted will be for Is' January 201 7 to 3Ist December 201 7 and will be submitted to the Agency by end of March 201 7.
The PRTR will be compiled in accordance with the latest guides as issued by the Agency. Upon consultation with Appendix II of the 'Guidance Note fur: Annual Environmental Report' and Annex II of the E-PRTR, NMVOCs (acetone) and copper cornpounds are the only PRTR compounds used on site. A full mass balance will be conducted on NMVQCs (acetone) and copper for 2017.
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:58
Henkel (Ireland) Ltd. Solvent Mass Balance & PRTR 31 March 2017
APPENDIX I
SUMMARY FORM
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:58
d z
P a - -
0 2
a
D m
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:58
Henkel (Ireland) Ltd. Solvent Mass Balance & PRTR 31 March 2017
APPENDIX 2
MATERIAL INPUT
2016FWF9WVENT hlASSBAWNCEAElO PRTRREWRT WC Page 10 of 15
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:58
The input of materials for 2016 is detailed below:
Copper i0 56 '8ls NMVOCs 20,122 -ea 20,062
Material Input
Appendix 2
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:58
Henkel (Ireland) Ltd. Solvent Mass Balance & PRTR 31 March 2017
APPENDIX 3
RECOVERED
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:58
The recovered on-site figure refers to the reuse of material in the pilot plant and cleaning station
Total Material Recovered &?-Site
Acetone was also recovered off-site
Appendix 3
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:58
Henkel (Ireland) Ltd. Solvent Mass Balance & PRTR 31 March 2017
APPENDIX 4
GROSS USAGE
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:58
Copper
Capper gross usage was obtained from the bill of materials for products that contain copper.
NMVOCs (Acetone)
Acetone gross usage is obtained from computer records maintained on site
Appendix 4
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:58
Henkel (Ireland) Ltd. Solvent Mass Balance & PRTR
APPENDIX 5
PRODUCT
31 March 2017
Page13of 15
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:58
A number of products from the Henkel (Tallaght) site contain copper. The quantity of copper leaving the site in the product is detailed below:
Compound I Total in Product (kg) Cooner I 43
Appendix 5
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:58
Henkel (Ireland) Ltd. Solvent Mass Balance & PRTR 31 March 2017
APPENDIX 6
OUTPUT T 9 AIR
?a% qO7S SDLYENTMASS W C E h4lDPRTRREWRT.W Page 14 of 15
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:58
Acetone is last from the pilot plant, the tanks in the cleaning station and the acetone bath room in the Biomedical Facility.
The following table demonstrates the total emissions to air for both solvents:
Acetone 232 Total 232 Annual Fugitive Emissions
Appendix 6
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:58
Hen kel (Ireland) Ltd. Solvent Mass Balance & PRTR 31 March 2017
APPENDIX 7
WASTE
I ' I
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:58
It was found that a number of the Henkel waste categories contain PRTR compounds These waste categories were sampled to determine the fraction of the PRTR compounds in each category.
The waste produced by the site is calculated by quantifying the amount of relevant waste sent off-site and the waste change of inventory. The calculation is provided in the main report.
Henkel's waste contractor on line reports were used to track the quantities of each relevant category sent off-site in 2016
The following table summarises the waste sent off-site and the waste change of inventory.
Material Waste Produced
(ks) waste Sent OH-
Site (kqs) Waste CO1 (kgs)
Acetone
Appendix 7
18,104 -1,852 19,966
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 01-06-2017:03:20:58