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Henkel (Ireland) Ltd., Ballyfermot Solvent Mass Balance & PRTR for 201 6

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Henkel (Ireland) Ltd. Solvent Mass Balance & PRTR 31 March 2017

CONTENTS

I. I NTRO DUCTI0 N 3

2. PRTR METHODOLOGY 4

3. INTERPRETATION OF RESULTS T

4. IMPROVEMENTS & RECOMMENDATIONS 8

5. 9 PRTR PROPOSAL FOR 2017 AT HENKEL (IRELAND) LTD., BALLYFERMOT

APPENDIX

Summary Form

APPENDIX 2

Solvent Input

APPENDIX 3

Gross Usage

APPENDIX 4

Output to Air

APPENDIX 5

Liquid Effluent

APPENDIX 6

Waste Solvent

APPENDIX 7

Recovered Solvent

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315 8F SOLVENFMASS BhlANCE ANDPRlR R€FURT..WC Page2of 16

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I. 1 NTRODUCTION

The preparation of a Pollutant Release and Transfer Register (PRTR) is a requirement of Regulation No 166/2006' . This Regulation amends the requirements of the Integrated Pollution Prevention and Control Licence (Reg. No. POO78-OI), as issued to Henkel (Ireland) Ltd.:

"Condition 2.2,

The licensee shall prepare a Pollution Emissions Register (PER) for the activity. The list of substances to be included in the PER shall be agreed with the Agency and include List I1 substances and priority candidate black list substances used on site (E. C. Directive 76/46#/EEC). As part of the PER, mass balances shall be prepared which shalt quantify each substance listed, their overall usage, as well as the routes of disposal or loss of substances from the operation, including discharges to air, water, incineration off-site, landfili, recovery and recycling and loss in product",

"Condition 2.3,

The licensee shall, not later than 6 months from the date of grant of fhis licence and each calendar year thereafter, prepare the programmes referred to in , . . . . . . and 2.2 above and submit these programmes to the Agency for approval. The results of all assessments, made in accordance with such approved programmes, shall be recorded and retained on-site for a period of not less than seven years and shall be available for inspection by authorised persons of the Agency. A report on these programmes, including the success in meeting approved targets, shall be prepared and submitted fo the Agency on an annual basis. "

The PRTR substances chosen for 2016 were dichlorornethane and NMVOCs (acetone and heptane).

REGULATION (EC) No 166/2006 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 18 January 2006 concerning the establishment of a European Pollutant Release and Transfer Register

2015 EFSOLVEW hMSS EALANC€AEIDPRTRR€PDRT.WC of 16

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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 I.

Input PROCESS

Recovered Material Recovered

’Treated I A

Air

Liquid Effluent

Waste

Unaccounted

The following is an explanation of the streams with particular reference to the Henkel site.

I. Input

The input of fresh solvent is determined from delivery records on the computer system. The following equation summarises this methodology:

Fresh Material = Purchased Material + Virgin Material Change of Inventory

Further details of the solvent input figures are shown in Appendix 2.

Principal Method of Measurement: Direct Measurement (M)

2. Gross Usage

The batch books record actual solvent usage for cleaning. Further details of the gross usage figures are shown in Appendix 3.

Principal Method of Measurement Direct IWeasurement (#)

3. Product

No PRTR solvents have been found leaving the site in product.

4. Air

Outputs to air are from fugitive emission sources only.

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The fugitive emissions from local extraction points and process vents have been updated based on gross usage. The breakdown of the air emissions is detailed in Appendix 4.

Principal Method af Measurement: Direct Measurement (M) and Engineering €stimaie (e)

5. Liquid Effluent

This category includes the solvent that leaves in the effluent stream from the wastewater treatment plant (WVVTP). Analysis figures were used together with volumes recorded during 2016. A summary of this calculation is given in Appendix 5.

Principal Method of Measurement: Direct Measurement (Ad)

6. Waste

The waste figure is the amount of waste produced by the site over the year. This is calculated by the following equation.

Waste Produced = Waste Sent Off-Site -Waste Change of Inventory.

Waste quantities recorded during 2016 and historical waste analysis are used. A summary of this calculation is given in Appendix 6.

Principal Method of Measurement: Direct #easuremenf (MI

7. Recovered

The quantity of solvent recovered includes solvent recovered on-site and recovered ofi-site. The quantity of solvent recovered on-site is calculated by the following equation.

Recovered = Gross Usage - Input - Recovered Change of Inventory

Solvent was also recovered off-site during 2016. Recovery figures are shown in Appendix 7.

Principal Method of Measurement: Material Balance (8)

8. Treated

This category includes materials which are consumed during production or treated on-site. This category is not relevant for the PRTR substances used in Hen kel .

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9. Unaccounted

This figure is obtained by difference between all inputs and outputs of the mass balance.

Principal Method of Measurement: Material Balance (B)

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2016 Result 2307

3.

O

INTERPRETATION OF RESULTS

Dichtorornethane

Copper and compounds (as Cu)

The PRTR Regulation sets thresholds for reporting of emission of pollutants. A summary of the 2016 data is presented below:

PRTR Threshold 1,ouo 2

2016 Result 381 0

PRTR Threshold 100 50

2016 Result Negligible Use Negligible Use

I Substance

Organotin compounds (as total Sn)

I I I I

NMVOCs 1 PRTRThreshold I 100,000 1

- PRTR Threshold 50 50

2016 Result Negligible Use Negligible Use

I

Therefore the releases to air, water and land of these pollutants do not exceed the applicable PRTR threshold values specified in Annex II and are therefore not required to be reported.

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Henkel (Ireland) Ltd. Solvent Mass Balance 8 PRTR 31 March 2017

4" IMPROVEMENTS I& RECOMMENDATIONS

Improvements

A number of improvements were made at the Ballyfermot site during 2016, namely:

A number of waste categories were analysed in 2016.

A project to substitute for acetone and DCM was commenced,

Recommendations

The following recommendations should be implemented in 201 7:

W A number of waste categories were analysed in 201 6. The following waste categories should be analysed again during 2017 to gather more accurate composition data:

b Category T

Category F

Category I

% Acetone, '36 Dichloromethane

% Dichtoromethane

% Acetone, % Dichloromethane

Category J % Dichloromethane

Category P (heptane and water)

Category P (heptane, paraformaldehyde & residue) % Heptane

Category P (acetone and crude)

% Heptane

% Acetone

Improve tracking of Acetone use on the SAP system

Continue the project to substitute for acetone and DCM

Review of air emissions calculations

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Henkel (Ireland) Ltd, Solvent Mass Balance & PRTR

NMVOCs (acetone & heptane)

Dichloramethane

Tin

Copper

5.

Gross usage in 2016 (kg) Chosen for Full Mass Balance in 2017

806242 Yes

101305 Yes

I .7 No (gross usage will be reported for 201 7)

No (gross usage will be reported for 201 7)

0.2

31 March 2017

PRTR PROPOSAL FOR 2017 AT HENKEL (IRELAND) LTD., BALLYFERMOT

A Pollutant Release and Transfer Register will be generated for the Ballyferrnot site for 2016. The PRTR to be submitted will be for Is* January 2017 to 3Ist December 201 7 and will be submitted to the Agency by March 2018.

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 for: Annual Environmental Report' and Annex I1 of the E-PRTR, dichloromethane, NMVOCs (acetone and heptane), copper and tin are the only PRTR compounds used on site. The gross usage of copper and tin are very low for mass balancing purposes (see Table 5.1). Therefore, the 2017 PRTR will include dichloromethane and NMVOCs (acetone and heptane) only.

Details of the Henkel Ballyferrnot PRTR substances are provided in the following table:

Table 5.1: Details of PRTR Substances at Henkel Ballyfermot

Substance

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Hen kel (Ireland) Ltd, Solvent Mass Balance & PRTR 31 March 2017

APPENDIX I

SUMMARY FORM

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IPPC Register No. I POO78-01

Production unfslamount

National Grid Reference I N233024, E310000

947 tonnes of crude Cyanoacrylate monomer

Reporting Period I January 2016 - December 2016

Pollutants Name

Dichloromethane

NMVOCs’

Unacc- Em- CAS Na. Input Gross Outputs ounted Productivrty

AI r Air MOM Liquid MOM Waste MOM Product MOM Recavered Treated IGEE INEE Usage Indices

Licensed Fugitive Effluent

7509-2 9,480 101,305 0 38 1 B 0 M 8,823 M 0 E 91,825 0 276 100 9.4

39,312 806,242 0 2,037 MI’E 0 M 26,450 M 0 E 766,930 0 10,826 100 4.9

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 Direct Measurement hgineering Estimates

Code M E

Method Code Material Balance B Other 0

NMVOCs inchde heptane and acetone 1

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Henkel (Ireland} Ltd. Solvent Mass Balance & PRTR 31 March 2017

APPENDIX 2

SOLVENT INPUT

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As detailed in the main report the Input figure for each solvent is calculated by evaluating the net new solvent delivered to the site and the virgin solvent change of inventory.

Virgin solvent is not purchased directly by Flenkel (Ireland) Ltd. (Ballyferrnot) but, it is delivered from Henkel (Ireland) Ltd. (Taflaght).

Dichloromethane

NMVOCs

Solvent Delivered Input 1 Solvent I 9,488 0 9,480

41,552 -2,240 39.3f2

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APPENDIX 3

GROSS USAGE

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Dichloromethane

The wash cards at Henkel Ballyferrnot record actual dichloromethane usage. This value, in addition to the number of washes of each vessel during the period in question, which was found from the records, facilitated the calculation of an accurate gross usage figure.

Vessel Part A Inline 1

400 I vessel Black Max

Myers 1200 I vessel

Inline 2 Part B 60L

TO1

' No. of washes Total (kg) 23 22 , 739 39 41 415 0

6,418 18,591

0 8,744 3,3 4

0 (

I (kg) 101 , a L i

NMVOCs

The wash cards at Henkel Ballyferrnot record actual acetone usage. This value, in addition to the number of washes of each vessel during the period in question, which was found from the records, facilitated the calculation of an accurate gross usage figure.

~. . - ___. Vessel

P-Plant F-Plant R-Plant K-P la nt Part A Part B

Adh. Vsl DC-Plant

Gel M-Plant - -

I Total (kg) 1 5t ,257

8 !4 0 0

' Total (kg) : - r

11 ,L,, 10,785 10,739 6,834

Q 0

Heptane gross usage is based on h e observation of its addition to batches over the year. A standard quantity of this solvent is added to each batch. Some variation from the quantity stated on the Bill of Materials for a batch was nQted

So, with the figure for the number of batches in 201 6 and the adjusted figure for the amount of solvent used in the batch, the gross usage can be calculated.

Appendix 3

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Henkei (Ireland) Lid. Solvent Mass Balance & PRTR 31 March 2017

APPENDIX 4

OUTPUT TO AIR

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For the PRTR substances, Dichloromethane and NMVOCs (Acetone and Heptane), three areas of fugitive air emissions were covered. These were local extraction, process vents and process components,

Heatane

Local Extraction Only Acetone and Dichloromethane, were considered in the local extraction study, since they are charged to the vessels from drums inside the production buildings. The following table demonstrates the total emissions to air emanating from the local extraction systems

1936.66

Annual Emissions from Local Extraction (kglyr)

Process Vente

The emissions of the three solvents were quantified in the process vent section.

The following table demonstrates the total emissions to air emanating from the process vents

Acetone

Solvent I Emissions (kglyr) I

13.50

I (kdvrl (knlvr)

Annual Emissions from Process Vents {kg/yr)

Local Extraction 272

Process Components Only, Heptane was considered in the process components study as if is the single process solvent under consideration.

The total annual emissions of Heptane from the process components in kglyr 7d.W

16

Overa I I These figures can be combined to yield overall emissions to air. This is shown in the following table:

Process Vents Process Components

Total

I ErnissionSource I DCM I NMVOCs I

109 1,950 0 71

381 2,B37

Appendix 4

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APPENDIX 5

LIQUID EFFLUENT

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In 2012-2016 samples were taken from the effluent stream and they were analysed for PRTR solvents. The following table shows the analysis results.

Total

Analysis of Liqufd Effluent

0.3'

The quantity of liquid effluent discharged to sewer was recorded for 2016. The recorded figure for effluent leaving the site is based on visual estimation of the batch volume emitted to sewer. The following table demonstrates the solvent quantities in the liquid effluent for the year.

NMVOCs

Solvent Quantity in Liquid Efffuent

Appendix 5

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Henkel (Ireland) Ltd. Solvent Mass Balance & PRTR

I,:..: i'r

31 March 2017

APPENDIX 6

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It was found that a number of the Henkel waste categories contain dichloromethane and acetone. A number of samples from of these categories was successfully analysed.

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:

Waste Produced = Waste Sent Of-Site - Waste Change of lnvenfory

The on line system, maintained by the contractor for Henkel (Ireland) Ltd., was used to track the quantities of each of these categories sent off-site in 2016.

The following table shows the waste sent off-site during and the waste change of jnventory.

Waste Produced

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Henkel (Ireland) Ltd, Solvent Mass Balance 8 PRTR 31 March 2017

APPENDIX 7

RECOVERED SOLVENT

2015 EF S O t M MASS W C € MID PRTRR€PORT.WC Page 16 of 16

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As stated in the main body of the report the recovered figure can consist of a combination of on-site and off-site recovery. During 2016, all PER substances were recovered on-site. Off-site recovery is also detailed below

NMVOCs

The equations for the calculation of the on-site recovery figure is: Recovered = Gross Usage - hput - Recovered Change of lnvenfory

0

The following table details these figures:

Total Solvent Recovered On-Site

Total Solvent Recovered Off-Site

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