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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



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


7. Emissions to Surface Water (MH4) 15

7.1 Surface Water Checks 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



16. Environmental Planning 34

16.1 Review of 2012 Objectives and Targets 34

16.2 Environmental Objectives and Targets For 2013 40



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



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



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



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



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



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



Figure 2

Figure 3



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



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



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



Figure 7

Figure 8

6.2 SUMMARY OF NON-CONFORMANCES

None



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



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



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 5 9 150110* R1 ATM BV Nov 29, 2012




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



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



Figure 10

Figure 11



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



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



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



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



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



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



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



15 ELECTRONIC AER



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



Program No. 2

Program Goal Ensure compliance of particulate emissions at PSA 6

EPI Particulate Emissions

Responsibility of J. Keane


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


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.




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



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


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



Program No. 5

Program Goal Energy Conservation - Defined Six-Sigma & Engineering Projects

EPI Energy Production Ratio




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



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



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.



Program No. 1

Program Goal Eliminate Odour Complaints

EPI Maintain odour levels below 1.5 OUe/m3 at boundary



Program No. 2

Program Goal Evaluate Particulate limit in terms of BREF legislation

EPI Particulate Emissions



Program No. 3

Program Goal Reduce Non Hazardous Waste by 5%

EPI Non Haz Waste/ Production ratio



Program No. 4

Program Goal Reduce Hazardous Waste by 3%

EPI Haz Waste / Production ratio

Responsibility of C. Clohessy


Program No. 5

Program Goal Energy Conservation - Reduce energy consumption by 5% over 3 years

EPI Energy Production Ratio



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



APPENDIX I

ISO14001 Certificate

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