Environmental Licensing Programme (ELP), Environmental Protection Agency, P.O. Box 3000, Johnstown Castle Estate.

SR Technics Ireland Limited OHSE Office, 1'' Floor, Hangar 5,

Co. Wexford. Dublin Airport

R Technics Ref: Environ I

CC. Mr. Thomas Sexton (I ispeqIf&

23* November 2010

EPA Offices Clonskeagh, gublin Agency NVlPPCSURRl61 O.epa

I elephone: 00353-1 -81 2-691 8

I 2u10

IK-Mail: sean.lawlor@srtechnics.com - IPPC Licence No: PO480-02 Company SR Technics Ireland Limited

Reauest for a Technical Amendment to

Subject

move location of Air Emission Point A46 And Request for a Technical Amendment to Reduce IPPC Licence Site Boundary. And Request for a Transfer of Interest in IPPC Licence PO480-02 (as amended by Request 2), to Dublin Aerospace Limited

Reporting Period N/A Required Submission Date N/A

Dear Sir/ Madam,

Please note that there are three parts to this letter. The first part (Request 1) deals with the

relocation of an air monitoring point known as A46 from Hangar 6 to Hangar 1. The second

part (Request 2) deals with the reduction of the IPPC Licence (PO480-02) Boundary to

cover only hangar 1 and Hangar 5 areas only. The third part (Request 3) deals with the

transfer of the IPPC Licence (PO480-02) as amended by Request 2 from SR Technics

Ireland Limited to Dublin Aerospace Limited.

Request 1 :

I would like to make a request to relocate Air Emission Point A46 from its current location in

the Painting Workshop in Hangar 6 a new location in a Painting Workshop in Hangar 1.

I have been in contact with our IPPC Licence Inspector from the Environmental Protection

Agency (EPA) in Clonskeagh and he (Mr. Thomas Sexton) has informed me that in order to

facilitate this request that our IPPC Licence must be amended by a Technical Amendment

which can be facilitated by the Agency's Environmental Licensing Programme (ELP) at the

SR Technics Ireland Limited Dublin Airport, Ireland

Tel: + 353 1 812 6000, Fax +353 1 888 8889 Directors: James Stuart, CEO (British), Angelo Quabba (Swiss)

www.srtechnics.com Registered in Ireland as a private company limited by shares, number 268659

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EPA Export 27-07-2013:23:08:44

SRTeC'- EPAs Headquarters in

02/gcl3ts).

Wexford (please see attached EPA letter reference P0480-

that, in order to facilitate the operation of SR Technics's IPPC I am formally requesting

Licence, that SR Technics's IPPC Licence be amended by way of Technical Amendments

so that air emission point A46 currently in Hangar 6, is transferred to Hangar 1.

I am making this request because the Hangar 6 painting workshop is no longer required in

that building. A new state of the art painting workshop has been established in Hangar 1

and this emission point A46 will be needed to operate it. We are currently in the process of

downsizing our IPPC Licence to cover Hangar 1 and Hangar 5 only (see attached EPA

letter reference P0480-02/gcl2ts) but need this emission point to transfer to Hangar 1 pr&

to completinq this downsizing process and the removal of Hangar 6 from our IPPC Licence.

Once downsized, we will apply to the Agency to transfer the IPPC Licence to Dublin

Aerospace Limited. SR Technics will then finally close its Dublin Facility.

Dublin Aerospace are a new start up company and require this emission point to enable

them to carry out their operations in Hangar 1. They will carry out their operations in the

Hangar 1 and Hangar 5 buildings and carry out similar processes to SR Technics (SR

Technics began closure operations in March 2009), but on a much smaller scale (SR

Technics >1,200 employees, Dublin Aerospace 4 0 0 employees). The type of paintl

primers, etc and the painting processes will be identical to the SR Technics processes as

these are defined (for safety reasons) by the aircraft manufacturers and customer

requirements.

Attached to this letter (for Request 1) I have included (three copies of each):

0 A drawing detailing the proposal,

0 A copy of the IPPC Licence Inspectors letter (in relation to this request, EPA Ref.

0 Two rounds of air monitoring for the new painting workshop,

0 Table E.l(ii) and E.l(iii) from IPPC Application Form V1/07 and

0 An air quality impact assessment report (for the new location in Hangar 1) we have

had commissioned from URS Ireland Limited.

P0480-02/g~l3t~),

SR Technics Ireland Limited Dublin Airport, Ireland

Tel: + 353 I 812 6000, Fax +353 I 888 8889 Directors: James Stuart, CEO (British), Angelo Quabba (Swiss)

www.srtechnics.com Registered in Ireland as a private company limited by shares, number 268659

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Please note that the ‘location of the emission point in Hangar 1 will remain within the

footprint of the IPPC Licence which is proposed to transfer to Dublin Aerospace.

Request 2:

Assuming ‘Request 1’ is to the agreement of the Agency, I would like to request that the

IPPC Licence Boundary as shown with red border in Drawing titled ‘IPPC Boundary Issue 2’ (see attached drawing) be reduced to the IPPC Licence Boundary as shown with red border

in Drawing titled ‘IPPC Boundary Issue 4’ (see attached drawing). Our site EPA Inspector

has commented on this second request, 1 have attached his correspondence. You will note

that he states that “the reports demonstrate that the condition of the area proposed for

removal from the licensed installation is not causing or likely to cause environmental

pollution and the site is in satisfactory state”. Therefore, in our view it is appropriate to vary

SR Technics’s IPPC Licence so as to exclude the areas referred to in our inspectors

correspondence, in order to facilitate the operation of the IPPC Licence going forward. As

stated above, Dublin Aerospace’s activities in the revised IPPC licence boundary are similar

to those carried out by SR Technics, but on a smaller scale, and should not result in any

increased or new emissions.

In relation to monitoring and emission points, the following monitoring and emission points

will be retained as part of the IPPC Boundary Change.

Summary Table 01: IPPC Licence P0480-02 Revised Boundary Monitoring and Emission M

Description

Points

1 Location (Worthing! Westing)

- Emission Point or Monitoring Point

Hangar 1 - 53”25’49.85”N/ Hangar 1 Plating Workshop Chromic Acid Scrubber. 6’14’37.76” A9 (Air)

Hangar 1 - 53’25’50.25”N/ Hangar 1 Plating Workshop A1 8 (Air) Degreasing Unit. 6’1 4’36.36”W

Hangar 1 Landing Gear Paint Hangar 1 - 53’25’50.1 1”N/ Spray Booths. 6’1 4’38.45”W A46 (Air)

Hangar 5 - 53’25’50.84”N/ Hangar 5 Painting/ Sanding Burntwood Booth. 6’14’25.97”W A42 (Air)

Hangar 1 Effluent Discharge Hangar 1 - 53’25’46.92”N/ 6’1 4’37.32”W SE1 (Effluent) Point.

Hangar 5 Effluent Discharge Hangar 5 - 53’25’47.1 2”N/ 6’14’27.69”W SE2 (Effluent) Point. Hangar 1 - 53’25’52.16”N/ 6’1 4’32.36“W

swl (furface Hangar 1 Monitoring Point. Water

Hangar 5 - 53’25’51.29”N/ 6’14’26.78”W

sw2 (furface Hangar 5 Monitoring Point Water

6014,26.47”w

Both

Both

Both

Both

Both

Both

Monitoring Point

Monitoring Point

NS2 (Noise) Point at Burntwood Painting/ Both Hangar Noise Monitoring Hangar 5 - 53025’50.92”N/

Sanding Booth.

SR Technics Ireland Limited Dublin Airport, Ireland

Tel: + 353 1 812 6000, Fax +353 1 888 8889 Directors: James Stuart, CEO (British), Angelo Quabba (Swiss)

www.srtechnics.com Registered in Ireland as a private company limited by shares, number 268659

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SR Technics NS3 (North) (Noise)

NS3 (South) (Noise)

NS4 (Noise)

NS5 (Noise)

GW008 (Groundwater) GW003D (Groundwater) GW004 (Groundwater) GWOO1 IGroundwater) GW002D (Groundwater) GW005D (Groundwater) GW006 (Groundwater) GW007 (Groundwater)

Hangar 5 Noise Monitoring Point at North of APU Test Cell. Hangar 5 Noise Monitoring Point at South of APU Test Cell. Hangar 5 Noise Monitoring Point at East Wall of Hangar 5 Pedestrian Entrance (Water Coolina Tower). Hangar 5 Noise Monitoring Point at South Wall of Broomwade Plant Room. Hangar 5 Groundwater Monitoring and Sampling Well. Hangar 1 Groundwater Monitoring and Sampling Well. Hangar 1 Groundwater Monitoring and Sampling Well. Hangar 1 Groundwater Monitoring and Sampling Well. Hanaar 1 Groundwater Monitoring and Sampling Well. Hangar 1 Groundwater Monitoring and Sampling Well. Hangar 1 Groundwater Monitoring and Sampling Well. Hangar 1 Groundwater Monitoring and Sampling Well.

Hangar 5 - 53’25’48.1 1 ”N/ 6’1 4’20.1 2”W

Hangar 5 - 53’25’46.55”N/ 6’14’20.40”W

Hangar 5 - 53’25’47.1 O”N/ 6’1 4’24.1 0”W

Hangar 5 - 53’25’47.1 4”N/ 6’1 4’24.63”W

Hangar 1 - 53’25’47.1 6”N/ 6’1 4’26.29W Hangar 1 - 53’25’50.89”N/ 6’14’36.18”W Hangar 1 - 53’25’50.84”N/ 6’14’36.10”W Hanaar 1 - 53’25’51.48”N/ 6’14‘36.69”W Hangar 1 - 53’25’51.53”N/ 6’1436.65”W Hangar 1 - 53’25’51.84”N/ 6’14’34.04”W Hangar 1 - 53’25’51.75N/ 6’14’34.1 5”W Hangar 1 - 53’25’51.82”N/ 6’1 4’33.89”W

Both

Both

Both

Both

Monitoring Point

Monitoring Point

Monitoring Point

Monitoring Point

Monitoring Point

Monitoring Point

Monitoring Point

Monitoring Point

Attached to this letter (for Request 2) I have included (three copies of each):

0 A drawing detailing the current IPPC Site Boundary (drawing titled IPPC Boundary

Issue 2),

0 A drawing detailing the required IPPC Site Boundary (drawing titled IPPC Boundary

Issue 4),

0 A copy of the IPPC Licence Inspectors letter (in relation to the request to reduce

the IPPC Licence boundary, EPA Ref. P0480-02/gcl2ts) and

0 A copy of the closure audit and validation report (issue 3 and 4) [please note that

‘Issue 4’ contains the correct version of the site boundary drawing which we hope

to downsize to].

Request 3

SR Technics is also applying for a transfer of the IPPC licence (which we request be

consented to, following amendment of the IPPC licence as requested herein) to Dublin

Aerospace Limited and hereby enclose the transfer of IPPC licence application form

SR Technics Ireland Limited Dublin Airport, Ireland

Tel: + 353 1 812 6000. Fax +353 1 888 8889 Directors: James Stuart, CEO (British), Angelo Quabba (Swiss)

www.srtechnics.com Registered in Ireland as a private company limited by shares, number 268659

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EPA Export 27-07-2013:23:08:45

“v- together with the appropriate fee. The Technical Amendment arising from Request 2 above

should be attached to Attachment A of the transfer application form.

Because of contractual agreements between Dublin Airport Authority, SR Technics and

Dublin Aerospace we are severely restricted in the time available within which to amend SR

Technics’s IPPC licence as required by way of Technical Amendment and complete the

transfer of the IPPC Licence to Dublin Aerospace. Your prompt attention to this matter is

greatly appreciated.

If you require any further information on this topic please contact me direct by email

(sean.lawlor@-srtechnicsxom) or by phone 01 812 6918.

Yours sincerely,

Sean Lawlor,

Environment Manager for SR Technics Ireland Limited.

SR Technics Ireland Limited Dublin Airport, Ireland

Tel: + 353 1 812 6000, Fax +353 1 888 8889 Directors: James Stuart, CEO (British), Angelo Quabba (Swiss)

w.srtechnics.com Registered in Ireland as a private company limited bv shares, number 268659

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equest 1

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Mr. Sean Lawlor Environment Manager 2.3, T?Kh Mh:C Ci,umaxa!cJi1,

SK 'Technics Ireland Liniited ! iihd Ciiath id, &e SR Technics

1 st Floor Hangar 5, MD 1 I2 Dublin Airport

OSH E/Engineering/Planni ng/salcs office +353 ! 268 0199

Ref: Relocation of IPPC Licensed Emission to Atmosphere Location Ref. No. A46

Dear Mr. Lawlor,

I refer to your proposal of Sth September 2010 and URS, Environmental Consultants report entitled "Air Qiinlity Impncl Assessment, SR Technics Limited" of 23rd September 2010 Issue No. 2, Agency correspondence of 5['' November 2010 (Our Ref. P0480- 02/AP 1 613) and your additional information of 1 91h November 20 10 (ReC: ENV1210.epa) in relation to your proposal to relocate IPPC Licensed Emission to Atmosphere Location Ref. No. A46 at Hangar 6 to Hangar 1.

I am to advise you that the proposed change cannot be accommodated under the terms of your existing liccncc. A technical amendment (Section 96( 1) o f the Environnzenlul Pro/ection Agency Act 1992, as amended (the Act)) or a review of your licence (Section 90( 1) of the Act) will be required to provide for the proposed changes.

To determine if the proposed change can be accommodated by technical amendment, you should submit the following information to the Agency's Environmental Licensing Programme (ELP), EPA, P.O. Box 3000, Johnstown Castle Estate, Co. Wexford: a o Details of the requested change; o Reasons for the change requested; o Details o f any increase or changes in emissions resulting from the change; o URS, Environmental Consultants report entitled "Air Qudily Zmpnct Assassnzenf.

SR Teclznics Liiniteti" of 23'd September 2010 Issue No. 2, and your additional information of 1 9'h Novein ber 20 10 ( Ref: ENV 1 2 1 O.cpa); A copy o f this correspondence; Appropriate drawings detailine: vow proposal,

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