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Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 1
Saint-Gobain Performance Plastics
Ireland
ANNUAL ENVIRONMENTAL REPORT
2012
Issued March 2013
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 2
CONTENTS PAGE
1. Introduction 5
2. Site Details 6
3. Policy Statement 7
4. Organisational Structure 8
5. Emissions to Atmosphere (PSA 6) 9
5.1 TOC Emissions 9
5.2 Particulate Emissions 11
5.3 Other Emissions to Atmosphere 12
5.3 Summary of Non-Compliances 12
6. Emissions to Sewer (F6) 13
6.1 Trend Analysis 13
6.2 Summary of Non-Compliances 14
7. Emissions to Surface Water (MH4) 15
7.1 Surface Water Checks 15
7.2 Summary of Non-Compliances 15
8. Waste 16
8.1 Waste Analysis 16
9. EPA Monitoring 20
9.1 Agency Monitoring and Enforcement 20
9.2 Agency Site Audit Non-Compliances 20
10. Energy Consumption 22
11. Water Consumption 23
12. PRTR 2011 23
13. Noise 25
13.1 Noise Report Summary 25
14. Environmental Incidents & Complaints 25
14.1 Environmental Incidents 25
14.2 Environmental Complaints 26
15. Electronic AER 27
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 3
16. Environmental Planning 34
16.1 Review of 2012 Objectives and Targets 34
16.2 Environmental Objectives and Targets For 2013 40
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 4
List of Tables
Table 1 TOC Air Emissions Summary
Table 2 Particulate Air Emissions Summary
Table 3 Other Emissions to Atmosphere
Table 4 Monthly Particulate Results
Table 5 Summary of Air Emissions Non-Compliances
Table 6 Effluent Emissions Summary
Table 7 Surface Water Emissions Summary
Table 8 Monthly Surface Water Checks
Table 9 Annual Waste Summary
Table 10 Hazardous Waste Details
Table 11 Non-Hazardous Waste Details
Table 12 Summary of Audit Findings
Table 13 Energy Consumption Summary
Table 14 PRTR Table
Table 15 Summary of Environmental Incidents
Table 16 Summary of Environmental Complaints
List of Figures
Figure 1 Air Emissions – TOC Concentrations
Figure 2 Air Emissions – Monthly Mass Flow
Figure 3 Air Emissions – Monthly Volume Flow
Figure 4 Air Emissions - Particulates
Figure 5 Fugitive Emission Trend
Figure 6 Monthly Effluent Data
Figure 7 Weekly COD Results
Figure 8 Monthly BOD Results
Figure 9 Annual Waste Trend
Figure 10 Hazardous Waste Production Ratio
Figure 11 Non Hazardous Waste Production Ratio
Figure 12 Energy / Production Ratio
Figure 13 Annual Water Consumption
List of Appendices
Appendix I ISO14001 Certificate
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 5
1. INTRODUCTION
License Register Number: P0096-02
Name & Location of site: Saint-Gobain Performance Plastics Ireland,
Kilrush,
Co. Clare.
Director of Operations: John Costelloe
Environmental contact person: Edward Cooke
Location of activity: Saint-Gobain Performance Plastics Ireland Ltd.,
Kilrush,
Co. Clare
National Grid Reference: 0998E: 1557N
Contact Phone Number 065-9080100
Contact Fax Number 065-9080101
Number of employees: 78
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 6
2. SITE DETAILS
Saint-Gobain Performance Plastics Ireland was granted a revised Integrated Pollution Prevention
& Control (IPPC) license in November 2006. This license grants Saint-Gobain Performance
Plastics permission to carry out the following activities:
Class 12.2.2:- the use of coating materials in processes with the capacity to use at least 10
tonnes per year of organic solvents, not included in Class 12.2.1.
This IPPC License (Reg. No. P0096-02) supersedes the installations previous license (Reg. No.
P0096-01), which had been issued in 2004.
Saint-Gobain Performance Plastics Ireland manufactures a variety of Teflon or PTFE
(Polytetraflouroethylene) coated and laminated fabrics which are used in the food processing,
electronics and packaging industries.
Main units, main products:
Saint-Gobain Performance Plastics Ireland manufacture a variety of PTFE coated and laminated
fabrics. This process is based on aqueous PTFE dispersions. The substrates used are either woven
fibre-glass or Kevlar. On some of our products we apply a pressure sensitive adhesive. We also
produce some silicone coated fabrics. The adhesive processes are currently based on organic
solvent. The plant can be divided into four zones:
- PTFE coating
- Inspection / Warehouse
- Adhesive + Rubber coating
- Office and Q.A. Laboratory
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 7
3. POLICY STATEMENT
Saint-Gobain Performance Plastics Ireland
ENVIRONMENTAL POLICY STATEMENT
Saint-Gobain Performance Plastics Ireland located in Kilrush Co. Clare manufactures a broad
range of high performance polymer-based, reinforced and un-reinforced fluoroplastics,
fluoroelastomers, silicone elastomers and adhesives. The Company’s products include
laminates, films, coated fabrics, and tapes.
It is the policy of Saint-Gobain Performance Plastics Ireland to operate an Environmental
Management System which not only meets all Corporate, E.P.A, Legal and Legislative
requirements but also strives to continuously improve to the benefit of our environment, local
community, neighbours and employees.
We will achieve this by:
Complying with all relevant environmental laws and regulations.
Identifying our environmental aspects and associated impacts and instituting appropriate
programs for the prevention of pollution and conservation of natural resources associated
with our processes.
Monitoring and measuring our key Environmental Performance Indicators.
Consistent review and re-evaluation of our set Objectives and Targets designed to
minimize our impacts.
Communicate our Policy and provide appropriate training to all our employees.
Communicate with our customers, suppliers and contractors to promote sound
environmental practice in the selection, use and disposal of all materials used in the
company’s business.
Make our environmental policy and records available to the public and interested parties.
The company has procedures and resources in place to plan, implement, monitor and review
this policy. This review shall take place annually. Whilst all employees have a duty to ensure
that our operations do not cause environmental pollution, the overall responsibility for
environmental protection lies with the Director of Operations.
Director of Operations
SGPPL Ireland
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 8
General Manager
Coated Fabrics
Business Manager Europe
Coated Fabrics
Marketing Manager
Coated Fabrics
Europe, Middle East & Africa
European Director of
Operations
European Customer
Service Manger
Facilities
ManagerManufacturing & Logistics
Manger
H.R &
Safety
Manger
European Financial
Controller
Customer
Service
RepresentativesShift 1
Supervisor
Shift 2
Supervisor
Shift 3
Supervisor
Planning &
Fulfillment
Manger
Materials &
Logistics Co-
Coordinator
Purchasing
Co-Ordinator
Production
Operators
Fulfillment
Operators
Accounts
Staff
Cost Accounts
Manger
Financial
Controller
Page 1
ORGANIZATIONAL CHART
Product Manager
Coated Fabrics &
Laminates
Process
EngineersAdmin.
Reception
Catering
PersonnelQuality
Engineer
Maintenance
Personnel Formulation
Quality &
Technology
Manager
I.T
Manager
QA Lab
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 9
5. EMISSIONS TO ATMOSPHERE (PSA 6)
5.1 TOC EMISSIONS
Solvent emissions are the major emission sources on the site. Depending on the parameter,
monitoring varies from continuous on-line monitors, to monthly analyses as specified in Schedule
C.1.1 (Control of Emissions to Air) of the IPPC license.
Total Organic Carbon (TOC) emissions were monitored monthly in 2012 in accordance with the
requirements of the IPPC license. All results were within compliance and a summary of the results
obtained is outlined in Table 1 below. The results of the air emissions monitoring demonstrated
compliance with the IPPC License limits.
PSA6 Mean Concentration
(mg/Nm3)
License Limit Mass Emission License Limit
(mg/Nm3) 2011 (Kgs/Yr) (Kgs/Yr)
Volume Flow 1011 m3/hr 4500 m
3/hr 4,367,880 19,440,000
TOC 12.8 50 55.8 972
Removal Eff 98.8% - - -
Table 1
Figure 1
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 10
Figure 2
Figure 3
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 11
5.2 PARTICULATE EMISSIONS
In 2011 Saint-Gobain Performance Plastics were issued a Technical Amendment to the IPPC
license. This amendment was to apply a limit on particulates being emitted from emission point
PSA 6.
Monitoring of these emissions began in January 2012 once the emission stack was modified to
allow suitable access. The results below in Figure 4 are for both oxygen corrected and uncorrected
values. All results are in non-compliance with the new license limit. Further details are in Program
#2 in section 16.1.
License Limit Mass Emission License Limit
(mg/Nm3) 2011 (Kgs/Yr) (Kgs/Yr)
Volume Flow 1011 m3/hr 4500 m
3/hr 4,367,880 19,440,000
Particulates 123.4 20 539.2 388.8
PSA6Mean Concentration
(mg/Nm3)
Table 2
Figure 4
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 12
5.3 OTHER EMISSIONS TO ATMOSPHERE
Air Emissions Calculation for 2012
CO2 Emissions from solvent sources burnt in the Thermal Oxidiser
Source Annual CO2 T.O. Estimated SOx Estimated Nox Estimated
Kg convert efficiency Tonne, CO2 convert Tonne SOx convert Tonne NOx
burnt factor % emitted factor emitted factor emitted
Xylene 7994 3.32 98.79% 26.22 N/A N/A
Toluene 3769 3.35 98.79% 12.46 N/A N/A
Ethyl Benzene 696 3.32 98.79% 2.28 N/A N/A
Ethyl Acetate 726 2 98.79% 1.43 N/A N/A
LPG Propane gas 2,895 0.0034 0.045 0.32 4.210
Tonnes Tonnes Tonnes
CO2 SOx NOx
TOTAL Emissions 2936.94 0.0447 4.210 Table 3
Figure 5
5.4 SUMMARY OF NON-CONFORMANCES
Details of non-conformances in section 5.2
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 13
6. EMISSIONS TO SEWER (F6)
Emissions to sewer are monitored on a weekly basis, the results of the analysis and the annual
quantities emitted to sewer are outlined in Table 6 below. The emissions to sewer data indicate
compliance with the IPPC emission limit values.
Mass Emission Mass Emission Mass Emission Licensed
2010 2011 2012 Mass Emission
Volume (m3) 2704 486 632 4600
BOD 533 181 267 9200
COD 3521 1485 2531 46000
OFG 138 28 8 230
F6
Table 6
6.1 TREND ANALYSIS
Figure 6
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 14
Figure 7
Figure 8
6.2 SUMMARY OF NON-CONFORMANCES
None
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 15
7 EMISSIONS TO SURFACE WATER (MH4)
Monitoring of surface water run-off from the site is undertaken at one discharge location referred
to as MH4. Monitoring results are summarised in Table 7 as the average value for the monitoring
period.
MH4 Mean Concentration
2012
Mass Emission
2012
COD 17.8 mg/L 16.6 Kgs/Yr
Conductivity 326 uS/cm -
pH 7.4 -
Table 7
7.1 SURFACE WATER CHECKS
Month Colour Odour
January Ok Ok
February Ok Ok
March Ok Ok
April Ok Ok
May Ok Ok
June Ok Ok
July Ok Ok
August Ok Ok
September Ok Ok
October Ok Ok
November Ok Ok
December Ok Ok
Table 8
7.2 SUMMARY OF SURFACE WATER NON-COMPLIANCES
None
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 16
8. WASTE
The waste data outlined in Tables 9 and 10 below represents all waste arisings for the AER
reporting period. All off-site recovery and disposal routes used comply with Condition 8 of the
IPPC licence.
8.1 WASTE ANALYSIS
Figure 9
Hazardous Waste 2006 2007 2008 2009 2010 2011 2012
Hazardous Waste 15948 19,640 20,310 13,734 19,243 12021 16063
Caustic / Triton neutralisation 7760 27,400 29060 16820 7940 8100 8900
Total Waste (Kgs) 23,708 47,040 49,370 30,554 27,183 20,121 24,963
Table 9
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 17
Description Weight Kgs EWC Proposal Waste
Agent
Method of Disposal /
Recovery
Disposal / Recovery Site Disposal
Date
PTFE Sludge 1290 080409* R12 ATM BV Apr 23, 2012
Water/Xylene/BPO 330 140603* R12 ATM BV Apr 24, 2012
Silica Ash 1,249 160507* D10 Abfall Verwertungs Gesellschaft Gmb Oct 22, 2012
Absorbent Pads with xylene, adhesive, rubber 3439 150202* R12 ATM BV Apr 24, 2012
Caustic Solution 8900 060204* S40178 Enva D9 Enva Ireland Ltd, Shannon, Co. Clare Aug 10, 2012
Lab Waste 1 22 070601* D10 Abfall Verwertungs Gesellschaft Gmb Jan 9, 2013
Lab Waste 2 226 080111* D10 Abfall Verwertungs Gesellschaft Gmb Jan 9, 2013
Lab Waste 3 149 080409* D10 Abfall Verwertungs Gesellschaft Gmb Jan 9, 2013
Lab Waste 4 181 080413* D10 Abfall Verwertungs Gesellschaft Gmb Jan 9, 2013
Lab Waste 5 9 150110* R1 ATM BV Nov 29, 2012
Lab Waste 6 3 160504* D10 Abfall Verwertungs Gesellschaft Gmb Jan 9, 2013
Lab Waste 7 161 160506* D10 Abfall Verwertungs Gesellschaft Gmb Jan 9, 2013
Lab Waste 8 405 160508* D10 Abfall Verwertungs Gesellschaft Gmb Jan 9, 2013
Aluminium Silver Sludge 274 080111* R12 Lindenschmidt 20/11/2012
PTFE Sludge 1864 080409* R12 Lindenschmidt 20/11/2012
PTFE Wipes 932 080409* R12 Recyfuel 15/11/2012
Water/Xylene/BPO 652 140603* R12/R2 Avanti Environmental Group Ltd 28/11/2012
Solvent Washings 842 140603* R12/R2 Avanti Environmental Group Ltd 28/11/2012
Absorbent Pads with xylene, adhesive, rubber 3,815 150202* R12 Recyfuel 15/11/2012
Empty drums smeared with rubber and adhesive 220 150110* R12 Recyfuel 15/11/2012
2012 Total 24963
HAZARDOUS WASTE GENERATION
PO120411 Indaver
PO120650 SRCL
PO120177 Indaver
Table 10
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 18
WASTE TYPES 2012 Quantity
Non
hazardous
but not
inert
Inert
onlyRecover
Heat
RecoveryRecycle Re-use
Internal Recycled Waste Tonne
Recycled timber boxes 8.200 No No No No No Yes
Recycled cardboard 1.980 No No No No No Yes
Clean Ireland Recycling
General Waste (Packer) 161.556
Inert (2/3) 107.704 No Yes No No No No
Non-Hazardous 53.852 Yes Yes No No No No
Composite Waste 0.927 No No Yes Yes No No
Timber 2.700 No No No No Yes No
Cardboard 4.220 No No Yes No Yes No
WEEE 0.664 No No No No Yes No
Steel (including empty drums) 2.400 No No Yes No Yes No
TOTAL 172.467
NON- HAZARDOUS WASTE GENERATION
Table 11
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 19
Figure 10
Figure 11
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 20
9. EPA MONITORING
9.1 AGENCY MONITORING & ENFORCEMENT
The EPA carried out monitoring tests on PSA6, F6 & MH4 once during 2012.
PSA6 (Air Emissions) within EVL Non-Compliant
MH4 (Surface Water) within EVL Compliant
F6 (Sewer) within EVL Compliant
9.2 AGENCY SITE AUDIT NON-COMPLIANCES
Non-Compliance Cause Corrective Action
Some of the bunds are untested with
some of the drums without labels
RSU No. 1 and 2 are not suitable for
IBC's yet they were stored in these units
Lab smalls still in RSU No. 3 that were
present during last audit.
Some waste and old
drums were being stored
in old stores that do not
meet bunding
requirements. Operators
were unaware of
chemical and waste
storage criteria
All lab smalls arranged
for disposal immediately.
Old empty drums
disposed and all RSU
area cleaned up. Arrange
training in Q1 2013 for
operators.
The Emergency Response Procedure
does not include actions to
prevent/reduce pollution in the event of
an incident the emergency plan needs to
include an up to date chemical inventory,
site plan with locations of chemicals
Inventory of pollution prevention stock
and file are in reception for the
emergency services
The Emergency
Response procedure was
based around a fire
evacuation procedure and
did not take into
consideration
environmental aspects.
Update procedure to
reflect the requirements
per the license
Air emissions - since January the current
particulates limit has been exceeded
monthly. Each breach needs to be logged
and reported as an incident and also
corrective actions carried out
Due to the lag between
on-site testing and test
reports were received
well after the incident
Ensure all incident are
reported per the EPA
guidelines and the
internal corrective action
procedure is followed
Corrective action procedure - the
procedure was not followed when
addressing incidents i.e. OFG or
particulates
Although all incidents
are addressed this the
corrective action
procedure was not
adhered to in these cases
For any incident that
occurs a new 8D report
shall be opened and this
will be completed as the
corrective and
preventative actions
occur
It has been 6 years since the Foul sewer
line has been tested for integrity
The municipal sewer line
was not tested in the last
All under-ground line are
due to be tested in 2013
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 21
survey due to a miss-
interpretation that only
process sewer lines are to
be tested.
and to this end it will be
scheduled for early 2013
and will include the
municipal sewer line
The site notice board does not comply
with condition 3.2.2 of the license and
needs to be addressed
Site notice was located at
employee entrance but
was not visible from road
New site notice placed at
site entrance with
corrected details of
emergency contact
details
No spill-kits located near the chemical
storage units.
Located skill kit near the
RSU chemical storage
units
No evidence of Bund Inspection records
being maintained by the licensee –
Records of these inspections are required
to be maintained in line with condition
11.6 of the license
All RSU units have bund
certificates. However
some old stores had
waste drums stored
within them and these
old stores are not suitable
for storage of any raw
materials or waste
Operators instructed not
to store any materials in
old units. The units are to
be removed / disposed
from the chemical
storage area
A number of procedures need to be
revised or updated: Emergency Response
Procedure, Accident Prevention
Procedure, Hazardous Waste
Management Procedure, Bund Test
Procedure
Following the audit it
was determined that
some of the procedures
do not comply fully with
the terms if the IPPC
license
Update procedures to
reflect both current
practice and meet the
terms of the license
Table 12 – Summary of Agency Audit Non-Compliances
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 22
10. ENERGY CONSUMPTION Summary energy data from 2008 to 2012
2008 2009 2010 2011 2012
Units MW/hr MW/hr MW/hr MW/hr MW/hr
Electricity 1663 1274 1594 1705 1914
LPG 13459 9493 13363 13202 13157
Total 15122 10767 14957 14907 15071
Energy/Production Ratio 7.88 7.32 8.18 7.44 7.81 Table 13
The graph in figure 12 below details the effect of the energy reduction programmes.
Figure 12
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 23
11. WATER CONSUMPTION
Figure 13
12. POLLUTION EMISSIONS REGISTER 2012
MOM – Method of Measurement
This refers to the method used in determining losses to Air, Water and Land.
The following codes are to be used to demonstrate the method used:
Method Code
Direct Measurement M
Engineering Estimates E
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 24
Pollution Emission Register 2012 List of solvent containing chemicals used in 2012
01-Jan to 31-Dec 2012 Item No. ] 04041 04033 04010 04031 04032 04036 04131
Kg/year Solvent CAS No. ] 1330-20-7
MOM i
2012 Opening balance (Dry Kg) M 1,200 150 64 124 183 312 299
2012 Purchases (Dry Kg) M 12,797 5,693 200 828 0 0 17802
2012 Returns or Shipments out (Dry Kg) M 0 0 0 0 0 0 0
2012 Closing Balance (Dry Kg) M 1,200 823 65 - 86 287 600
units Lit Dry Kg Dry Kg Dry Kg Dry Kg Dry Kg Dry Kg
Usage M 12,797 5,020 199 952 97 25 17,501
Density or conversion to gross Dry Kg E 0.88 1.00 1.00 1.00 1.00 1 1
Nett Usage (Dry Kg) M 11,261 5,020 199 952 97 25 17,501 35,055
% Solids E 0 48 35 40 48 50 55
% Solvent E 100 52 65 60 52 50 45
Gross Usage (Wet Kg) 11,261 10,458 569 2,380 202 50 31,820 56,740
% Xylene E 100% 45% 45% 40% 11%
New Xylene usage (Kg) M 11261 4706 91 20 3500 19579
Recycled Xylene used M 0 0 0 0
Total Xylene usage M 11261 4706 0 0 91 20 3500 19579
Xylene in product E 0 0 0 0 0 0 0 0
Xylene Treated (in own Thermal. Oxidiser) M 7994
Xylene sent out for recovery (inc heat recovery) M 0 0
Xylene in Haz Waste E 2539
Xylene in effluent M 0 0
Fugitive emissions (not throught Th.Ox) M 0 9010
Xylene remaining after TH Oxidiser treatment E 36.219 36.2
Unaccounted E 0
IGEE
INEE
% Toluene E 7% 15% 28%
New Toluene usage (Kg) M 39.80 357.00 8,909.60 9,306
Recycled Toluene used M 0 0 0 -
Total Toluene usage M 39.80 357.00 8909.6 9306
Toluene in product E -
Toluene Treated (in own Thermal. Oxidiser) M 3769
Toluene sent out for recovery (inc heat recovery) M -
Toluene in Waste E 205
Toluene in effluent M -
Fugitive emissions (not throught Th.Ox) M 5315
Toluene remaining after TH Oxidiser treatment E 17.22 17
Unaccounted E -
IGEE
INEE
% Ethyl Acetate E 45%
New Ethyl acetate usage (Kg) M 1,071.00 1,071
Recycled Ethyl acetate used M 0 -
Total Ethyl acetate usage M 1,071.00 1,071
Ethyl acetate in product E -
Ethyl acetate Treated (in own Thermal. Oxidiser) M 726
Ethyl acetate sent out for recovery (inc heat recovery) M -
Ethyl acetate in Waste E 22
Ethyl acetate in effluent M -
Fugitive emissions (not throught Th.Ox) M 321
Ethyl Acetate remaining after TH Oxidiser treatment E 1.98 2.0
Unaccounted E -
IGEE
INEE
% Ethyl Benzene E 7% 7% 11% 3%
New Ethyl Benzene usage (Kg) M 732.08 14.15 5.50 954.60 1,706
Recycled Ethyl Benzene used M 0 0 0 0 -
Total Ethyl Benzene usage M 732.08 14.15 5.50 954.60 1,706
Ethyl Benzene in product E 0 -
Ethyl Benzene Treated (in own Thermal. Oxidiser) M 696
Ethyl Benzene sent out for recovery (inc heat recovery) M 0 -
Ethyl Benzene in Waste E 54
Ethyl Benzene in effluent M 0 -
Fugitive emissions (not throught Th.Ox) M 0 952
Ethyl Benzene remaining after TH Oxidiser treatment E 3.156 3.2
Unaccounted E -
IGEE
INEE Table 14
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 25
13. NOISE
13.1 NOISE REPORT SUMMARY
2012 report submitted to Agency via ALDER system
14. ENVIRONMENTAL INCIDENTS & COMPLAINTS
14.1 ENVIRONMENTAL INCIDENTS
Date Non-Compliance Cause Corrective Action
January
February
March
April
May
June
July
August
September
November
December
Monthly EVL Breach
for Particulate
Emissions from PSA6
The particulates
(amorphous silica dust) are
a result of the destruction
of low molecular weight
(LMW) siloxanes that
evaporate from the
adhesive and pass the
burner flame within the
thermal oxidizer.
Air dispersion analysis
under way to establish
actual ground level
concentrations relative to
the air emission
regulations.
Engaged with Thermal
oxidizer to determine
optimum operating
conditions of the oxidizer.
Table 15
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 26
14.2 ENVIRONMENTAL COMPLAINTS
Date Non-Compliance Cause Corrective Action
13-Jun-12 Strong odour coming
from plant -
complainant visited
plant to discuss what
actions were been
taken.
Nuisance odour from
standard processing
conditions during
unfavorable weather
conditions
As per Program 1 in
section 16.1
14-Jun-12 Noise coming from
direction of plant
making it difficult to
sleep at night.
Contact independent body
to carry out noise
assessment at
Complainant's location
Noise assessment reports
uploaded on ALDER –
complaint considered
closed following EPA
audit
10-Jul-12 The complainant who
wished to remain
anonymous expressed
concerns at odours
from the site being
detected in Kilrush
from the Saint Gobain
Facility.
Nuisance odour from
standard processing
conditions during
unfavorable weather
conditions
As per Program 1 in
section 16.1
26-Oct-12 Complainant stated
that there was a
molten polyethylene
type smell coming
from the Saint Gobain
facility in Kilrush.
Nuisance odour from
standard processing
conditions during
unfavorable weather
conditions
As per Program 1 in
section 16.1
29-Nov-12 The complainant
stated that the
emissions from the
Saint-Gobain site are a
massive concern for
people in the West
Clare area.
Nuisance odour from
standard processing
conditions during
unfavorable weather
conditions
As per Program 1 in
section 16.1
01-Dec-12 A strong unbearable
smell from a local
factory on the
Cooraclare Road,
Kilrush.
Nuisance odour from
standard processing
conditions during
unfavorable weather
conditions
As per Program 1 in
section 16.1
Table 16
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15 ELECTRONIC AER
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16. ENVIRONMENTAL PLANNING
16.1 REVIEW OF OBJECTIVES & TARGETS 2012
Program No. 1
Program Goal Eliminate Odour Complaints
EPI Maintain odour levels below 1.5 OUe/m3 at boundary
Responsibility of E Cooke
Review Cycle At Monthly EHS Meeting
Following on from the result of the Pilot test it was decided to install a full scale Aerox Injection
system. After careful consideration into what lines could (a) potential cause the greatest odour and
(b) to which a single Aerox system could be installed – it was decided that emission points T16,
T17 & T18 would be combined and treated for odour.
Aerox - How it Works
Program Objective (Project Plan) Time-Line Responsibility Result/Status
Begin Capital Approval Request 01/06/12 Project Team Complete
Complete Capital Approval Request 08/10/12 Project Team Complete
Place order with AEROX 19/11/12 Purchasing Complete
Complete Manifold Design 21/12/12 Facilities Complete
Complete Validation Plan 21/12/12 AWN Complete
Factory Acceptance Testing 08/03/13 Engineering On-track
Test Manifold System 10/05/13 Engineering On-track
Carry out System Validation 17/05/13 AWN On-track
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 35
Program No. 2
Program Goal Ensure compliance of particulate emissions at PSA 6
EPI Particulate Emissions
Responsibility of J. Keane
Review Cycle At Monthly EHS Meeting
Program Objective Time-Line Responsibility Result/Status
Carry out a characterization study
into the structure of the particulate
ash
Jan-12 Engineering Report verifies that the
particulate is amorphous
silica ash
Open a best practice exchange
forum with another Saint-Gobain
adhesives coating site in USA
July-12 Engineering Exchange information
showed that the
processing conditions of
both sites are very
similar and the
particulates emitted are
also amorphous silica
ash. There are no local
regulations/limits for
amorphous silica
emissions in the USA
Carry-out Air Dispersion Analysis
of the Particulate emission and the
impact it has at ground level
concentrations
Dec-12 Odour-Ireland Results of the analysis
show that for the worst-
case scenario the
emission do not exceed
the ground level
concentrations at the site
boundary.
Program No. 3
Program Goal Reduce Non Hazardous Waste by 5%
EPI Non Haz Waste/ PSA Production ratio
Responsibility of J. Downes
Review Cycle At Monthly EHS Meeting
For Q1 & Q2 2012 the generation of non-hazardous wastes was in control, however in June 2012 a
new fabrication line was added to the facility. This new line resulted in a step increase in the
generation of non-hazardous wastes in Q3 & Q4 resulting in an overall net increase in the non-
hazardous waste to production ratio. The data will be re-normalized for 2013 and the same
programs implemented.
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 36
Program Objective Time-Line Responsibility Result/Status
Recycling of cardboard and timber
boxes
Continuous Production /
Shipping
Data shows the same
level of cardboard and
timer recycling as for
2011
Continuous running and reduction
on end defects
Continuous Production Successfully controlled
project that was
completed in 2011. The
waste from end defects
in products to remain in
control.
Width Optimization Oct-12 Engineering WCM Project carried
out to produce certain
products on more
efficient lines
Potential in trimming products
earlier
Continuous Engineering Two products identified
where the trimming was
carried out earlier in the
process to reduce PTFE
waste
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 37
Program No. 4
Program Goal Reduce Hazardous Waste by 3%
EPI Haz Waste / Production ratio
Responsibility of B. McNamara
Review Cycle Quarterly at EHS meeting
Program Objective Time-Line Responsibility Result/Status
PTFE Recovery Continuous Production Program is generally
effective however focus
on the project was lost
for a few months in Q2
& Q3 having a negative
impact on the program
Reduce Caustic solution
requirement during maintenance
shut-down
Aug-12 Facilities The amount of caustic
solution used during the
shut-down period has
stabilized in recent years
Disposal of Lab smalls / chemicals Aug-12 Engineering All lab smalls disposed
of correctly – however it
did have a negative
impact on the program
target as it was a one off
disposal the was not
directly related to
production
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 38
Program No. 5
Program Goal Energy Conservation - Defined Six-Sigma & Engineering Projects
EPI Energy Production Ratio
Responsibility of J. Downes
Review Cycle Quarterly at EHS meeting
Program Objective Time-Line Responsibility Result/Status
Install energy efficient fluorescent
lights
Apr-12 Facilities Complete
Installed energy efficient LPG
boilers
Oct-12 Facilities Complete
Width Optimization Oct-12 Engineering WCM Project carried
out to produce certain
products on more
efficient lines
WCM – Production speed increase Dec-12 Engineering Numerous WCM
projects on process
speed increases
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 39
Review of Other Programs;
Installation of Rain Water Harvesting System
o Due to the prioritization of other projects this project has been rescheduled for 2013
Evaluate use of Solar Panel(s) for heating water for wash area
o Following the completion of a cost-benefit analysis this program was cancelled
Evaluate use of low quality finished material in Landfill heat recovery projects
o Sample of material sent to a landfill waste contractor in Germany however the trials
did not prove successful and they are looking at other alternatives
Transition to Zero percent APFO in PTFE dispersions
o All PTFE used on site has been successfully transitioned to Zero APFO
Training – Handling and Disposal of Hazardous Waste
o Operators were given awareness training on the procedures in disposing of
hazardous wastes
Repeat Acute Toxicity Test once Zero APFO and LAE content have stabilized in PTFE
o The full transition was completed by Q4 2012 – the repeat of acute toxicity testing
rescheduled for 2013
Complete technical amendment or License review as determined by the agency
o Application made to licensing section
Annual Environmental Report 2012
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16.2 ENVIRONMENTAL OBJECTIVES & TARGETS FOR 2013
SGPPL reviews the plant Environmental Management System on an ongoing basis with the aim of
updating and refining the Environmental Management Program (EMP) to take account of progress
in meeting objectives and targets. In addition, new targets are added on the basis of achievement of
existing targets and where issues have been identified as requiring a formal and structured EMP
approach to drive their implementation.
The primary focus of the EMP in achieving significant environmental objectives during 2013 will
be the continued improvement of air emission quality, especially in terms of odour control and
particulate emissions. The following objectives and targets have been established for the calendar
year 2013 through the Environmental Management System.
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 41
Program No. 1
Program Goal Eliminate Odour Complaints
EPI Maintain odour levels below 1.5 OUe/m3 at boundary
Responsibility of J. Keane
Review Cycle At Monthly EHS Meeting
Program No. 2
Program Goal Evaluate Particulate limit in terms of BREF legislation
EPI Particulate Emissions
Responsibility of J. Keane
Review Cycle At Monthly EHS Meeting
Program No. 3
Program Goal Reduce Non Hazardous Waste by 5%
EPI Non Haz Waste/ Production ratio
Responsibility of J. Downes
Review Cycle At Monthly EHS Meeting
Program No. 4
Program Goal Reduce Hazardous Waste by 3%
EPI Haz Waste / Production ratio
Responsibility of C. Clohessy
Review Cycle Quarterly at EHS meeting
Program No. 5
Program Goal Energy Conservation - Reduce energy consumption by 5% over 3 years
EPI Energy Production Ratio
Responsibility of J. Downes
Review Cycle Quarterly at EHS meeting
Environmental Management Program 2013
Other Programs
Installation of Rain Water Harvesting System
Training – Handling and Disposal of Hazardous Waste
Repeat Acute Toxicity Test for F6 emissions
Complete testing of all on site Bunded areas
Complete integrity testing of all underground pipelines
Any other reports as required by the agency
Annual Environmental Report 2012
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APPENDIX I
ISO14001 Certificate
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 43
Annual Environmental Report 2012
IPPC LICENSE No. P0096-02 44