/
PC Application Form
-.
5. Non-Technical Summary of IPC Licence Application
This Non-Technical Summary is a concise summation of the primary environmental
aspectsas outlined in the main Integrated Pollution Control Licence application.
Bord na Mona Environmerkl Consultancy Services was commissioned lkalco to complete
an Integrated Pollution Control Licence application concerning the activity which is
undertaken at the facility which is classed as:
n
The manufacture or use of coating materials in processes with a capacity to
make OYuse at least 10 tonnes per year
organic solvents, and powder coating
manufacture with a capacity to produce at least 30 tonnes per yeav.
of
ot
to
f c Fo
op r i
yr ns
ig pe
ht ct
ow ion
ne pu
r r rp
eq os
ui es
re o
d nl
fo y.
ra
ny
SECTION A -GENERALINFORMATION
he
ru
se
.
as per the Fir;t Schedule of the EPA Act, 1992 (12.2).
ns
en
IraIco is a wholly owned Irish company with registered offices at Collinstown,
Mullingar, Co. Westmeath, and currently employs 415 people. The plant is located
approximately 1.5 lun south of Collinstown on a 10.97 hectare site. Collinstown is
situated approximately 6.25 kilometres south-west of Castlepollard on the R395
Regional Road between Castlepollard and Delvin, Co. Westmeath.
Co
Since the 1960’s Iralco has involved in the development and manufacturing of
functional and decorative car trim for export to companies such as Audi, Volkswagen
and Volvo.
“’
halco is located within the functional area of Westmeath County Council, and
notification was given in writing of the intention to apply on the 2gthNovember 2003.
SECTION&PLANT,PROCESSESANDPROCEDURES
Operational Information
The primary raw material in the manufacture of functional and decorative car - trim in
the Iralco facility is aluminium. Aluminium is delivered in three formats, as rolls on
pallets; strips of wooden boxes; and extruded aluminium in stillages.
Novetnber
2003
[licence
applicatiot~.doc]
Page I I of78
EPA Export 25-07-2013:14:23:27
PC Application Form
The process involves some or all of the following activities, the order of which being
dependent on the final product,
cutting
Milling
.Heading
,
Bending
sanding
Polishing
Electrobrightening
Powder Coating
Spray Painting
he
ru
se
.
In conducting the above activities, solid, liquid and gaseous wastes are generated for
which abatement measures include hazardous and non-hazardous waste disposal via
permitted contractors, cyclones, scrubbers and wastewater treatment.
to
f c Fo
op r i
yr ns
ig pe
ht ct
ow ion
ne pu
r r rp
eq os
ui es
re o
d nl
fo y.
ra
ny
ot
After quality inspection the finished products are packed and palleted for shipment by
truck.
The facility operates on a seven day week basis, with a number of working cycles:
Co
ns
en
Shift Cycles: 0600 to 1400 hours
1400 to 2200 hours
2200 to 0600 hours
Day Shift:
0800 to 1630 hours
On a Friday working shift cycles are of 7 hours duration. Some maintenance activities
or overtime working can occur outside these hours.
Seveso Regulations
The site is not subject to the Seveso regulations due to the nature of the activity and the
material used on site.
November
2003
[licence
applicariomiocj
Page 12 of 78
EPA Export 25-07-2013:14:23:27
IPC AppIication Form
SECTION C -EMISSIONS
Emissions to Atrnosuhere
As part of the IPC licensing application, Iralco undertook a comprehensive atmospheric
emissions monitoring programme on 24 point sources located throughout the facility for
volumetric flow, particulate matter, metals, Total Organic Carbon (as C), acid gases,
ammonia and sodium hydroxide.
Emissions to Surface Waters
to
f c Fo
op r i
yr ns
ig pe
ht ct
ow ion
ne pu
r r rp
eq os
ui es
re o
d nl
fo y.
ra
ny
ot
he
ru
se
.
The results of this monitoring programme indicated that four point emissions were
elevated above the relevant particulate matter BATNEEC limit values as denoted for an
activity classed as 12.2, and that three point emissions were elevated above the TOC T
A Lufi (2001) guide values. All remaining emission points that were monitored were
determined to be within the respective parametric limit values. III the case where a
BATNEEC limit value does not exist limit values fi-om either the internationally
recognised German T.A. Luft, the Danish EPA or one fortieth of the relevant
Occupational Exposure Limit (OEL) was used.
Co
ns
en
The main source of emissions to surface waters from the Iralco facility is from the
industrial wastewaters. Wastewater is generated from four sources on-site, namely the
Pyrolyser, the Paint Plant, the Powder Coating Plant and the Electrobrightening Plant.
Wastewater is treated prior to discharge from the facility via pH stabilisation and
through the addition of flocculating agents. Iralco currently are regulated by Westmeath
County Council, through a water discharge licence for the emissions of these industrial
wastewaters from the facility.
Iralco currently do not discharge municipal wastewaters to sewer.
In order to assessthe existing nature and quality of surface waters in the vicinity of the
lralco facility it was deemed necessary to conduct a comprehensive water quality
assessment. On review of cartographic evidence and on-site walking surveys it is
evident that the hydrology of the area is dominated by the Yellow River. The Yellow
River is formed from a number of individual waterways located in the Clondraveen,
Barbavilla Bog, Drumcree, Ballymacahil and Denies, all located within a radius of 4
kimometres south-east of Collinstown. The Yellow River flows approximately 11
kilometres in a primarily north-easterly direction prior to discharging into Lough
Novenlber
2003
[licence
applicationdoc]
Page 13 of78
--
i
EPA Export 25-07-2013:14:23:27
PC Application Form
Derravaragh. Lough Derravaragh is the source of the River Itmy which is one of the
main tributaries of the River Shannon confluencing at Lough Ree.
The lands surrounding the Ii&o plant tend to be slightly undulating. The main land use
in the vicinity of the plant is agricultural, with a conifer plantation at the edge of the
southern boundary. The fields surrounding the plant are artificially drained by a series of
_.
underground pipes.
The overall quality of the surface water adjacent to the Iralco facility appears to be of
good quality, and does not appear to deteriorate on receiving the wastewater discharge
from the Iralco facility. The overall quality of the wastewater samples extracted from the
Iralco facility was of reasonable quality.
Emissions to Ground
to
f c Fo
op r i
yr ns
ig pe
ht ct
ow ion
ne pu
r r rp
eq os
ui es
re o
d nl
fo y.
ra
ny
ot
he
ru
se
.
Geological information obtained for the Iralco facility indicate that the quaternary
geology of the site provides some protection to the groundwater due to the low to
moderate permeability of the glacial tills.
Co
ns
en
Bedrock Geology: Desk-based and site specific information on the underlying
hydrogeological characteristics of the site were obtained through the Geological Survey
of Ireland. The Iralco facility is underlain by Carboniferous Rocks which make up part
of Lucan Formation f&U). This formation is classified by the Geological Survey of
Ireland as a locally important bedrock aquifer which is moderately productive (Lm).
Quaternary Geology: The bedrock geology is overlain by deposits of glacial till/boulder
clay. The deposits covering the study area are derived from the last glaciation period
known as the MidZandian (Weichsel) when a glacier moved in a south-easterly direction
across the study area. Glacial tills have a generally low to moderate permeability
characteristics.
Soils: The soils of the area are made up of grey brown podzolics, These are generally
sandy-gravelly loams overlying a more clayey loam. The soils are generally moderate to
well drained.
Mrusive investigations to date (see Attachment 1.58) indicate that the groundwater
located at the facility is of reasonable quality.
liovetnber 2003 [licence applicatiotdoc]
Page 14 o/ 78
EPA Export 25-07-2013:14:23:27
IPC’ Application Form
Noise Emissions
A noise survey (daytime and night time acoustic assessment) was undertaken at the
facility. Noise measurements were obtained from three boundaries (namely south west,
north north west, north north east comers) and from a noise sensitive location at the
south east comer.
A significant contributor of the noise occurring within the environs of the site is
transitory (on-site and external trafk) related as noted Ad as evidenced by the recorded
values obtained during the survey. The assessmentindicated four on-site sources that are
tonal in character in terms of noise emissions, namely cyclones and scrubbers servicing
the facility.
to
f c Fo
op r i
yr ns
ig pe
ht ct
ow ion
ne pu
r r rp
eq os
ui es
re o
d nl
fo y.
ra
ny
ot
he
ru
se
.
The preliminary noise assessmentsundertaken at the facility indicate that the levels of
noise determined at the nearest noise sensitive location are deemed to be satisfactory.
However, the character of the noise discernible is tonal and may emanate from a number
of units located as the Iralco facility. Considering the customary night-time level noise
level that may be set of 45 dl3 A and adding the 5 dB A penalty as outlined in the
guidance fkom the Agency the company may exceed the limit. In any event the presence
of tonal noise is objectionable especially at night-time when sensitivity to such
emissions is greater.
Co
ns
en
In order to addresssuch noise issue it is recommended that a noise reduction programme
be carried. This shall require the formulation and implementation of a three phase noise
control programme requires techniques of planning (Phase 1 of study), management and
economics as well as the knowledge of engineering principles that are outlined as
follows.
The first step of the programme is the measurement of the noise level and diagnosis of
the important sources. The establishment of a target noise level for the particular
situation. The amount of noise reduction can them be estimated. The target level or
standard will be set to meet current Environmental Protection Agency limits as per the
company likely noise conditions and guidance as per International Standard
Organisation 1996 Parts 1,2, and 3 in addition to relevant guidance issued by the EPA
for scheduled activities.
Having establishedthe required reduction, the next stageis the application of noise control
engineering principles to design the reduction treatment. Other factors such as cost, safety
and fire-hazards implications of the proposed noise reduction measures and their possible
November
2003
[licence
applicationdoc]
Page IS of 78
EPA Export 25-07-2013:14:23:27
LPC Application Form
a
effects on the working proceduresand production processesare considered. (Phase Two of
Programme).
The final stage (Phase Three) of the programme is the assessmentof the effectiveness of
the noise-reduction measures when installed. If the required reduction is not achieved,
the process may have to be repeated. It must be emphasised that many noise sources
may contribute to a particular problem, or there may be many .transmission paths
associated with one particular source. This means that the effective solution to a noise
problem may involve more than one noise control measure (e.g. absorption as well as
screening, or isolation as well as insulation).
ru
se
.
Waste Management
ns
en
to
f c Fo
op r i
yr ns
ig pe
ht ct
ow ion
ne pu
r r rp
eq os
ui es
re o
d nl
fo y.
ra
ny
ot
he
Iralco currently produce approximately 8.3 tonnes and 23.9 m3 of hazardous waste per
annum, of which 3.5 m3 is recovered via a licenced recovery agent, with the remaining
being disposed via licenced waste contractors. Of the 58.55 tonnes and 9.83 m3 of nonhazardous waste that is produced approximately 23.3 tonnes is recycled with the
remainder being disposed via a licenced contractor to landfill. Iralco do not dispose of
any waste through on-site landfilling.
Monitoring and Sampling points
Co
a
The above programme is cyclical and subject to as yet undetermined variables that shall
influence the specific time fkme in which such a noise attenuation programme shall be
scheduled. It is therefore not feasible to be prescriptive with set dates at this time.
All sampling locations with regard to atmosphere, surface waters, and noise have
developed with safe and easy access for monitoring. The major atmospheric emission
points identified at the facility shall be monitored quarterly at the facility for XXXXX.
The surface water emissions, including the wastewater discharges Tom the facility, shall
be monitored on a monthly and quarterly basis for the range of parameters as outlined in
the Water Discharge Licence as issued by Westmeath County Council. Surface water
sampling shall be undertaken at the receiving watercourse on an annual basis to ensure
that the impact of the facility continues to be negligible.
The noise emissions from the facility shall be monitored annually at four locations,
determining both daytime and night time contributions, to determine the impact of the
facility on the environs.
November
2003
[licence
application.doc]
Page 16 of 76
EPA Export 25-07-2013:14:23:27
IPC Application Form
Monitoring of ah identified emissions shall employ standard methodologies. All
analysis carried out on samples obtained during monitoring shall be undertaken by an
ILAB accredited laboratory.
Environmental Considerations
ot
he
ru
se
.
At part of the operational design of the Iralco facility, a number of environmental
considerations have been employed to reduce the potential impact of the facility on the
environment. Water usage on site is optimised through the re-circulation of rinse waters
within the electrobrightening process, which would be one of the largest users of water
on site. All process tanks within the electrobrightening plant, the new effluent plant and
the paint plant pre-treatment are bunded to prevent any accidental discharges to the
environment. Phosphoric Acid is recovered from the rinse waters by vacuum
evaporation. All transfer piping in the Electrobrightening Plant, Effluent Treatment
Plant and Phosphoric Acid Recovery Plant are located overground.
to
f c Fo
op r i
yr ns
ig pe
ht ct
ow ion
ne pu
r r rp
eq os
ui es
re o
d nl
fo y.
ra
ny
Some of the major atmospheric emissions points within the facility are treated via
cyclones or wet chemical scrubbers to remove both aluminium and dust,
Co
ns
en
Wastewaters are treated via the on-site treatment plant which employs a pH balancing
and a sedimentation process to remove hannfitl constituents from the wastewater stream
prior to discharge to the receiving watercourse.
All raw material paints and solvents are stored in temperature controlled, bunded
storage buildings. It is the intention of Iralco to construct a custom designed, bunded,
chemical storage area on-site so that all bulk chemicals stored on-site will be done so in
an environmentally responsible manner, and to bund the diesel storage tank on site.
Accidental Emissions
As part of the Environmental Management System that is currently being implemented
at the facility, an Emergency Responseprocedure governing spillages, fire, flooding and
malicious damage. This procedure identifies the responsibility of the staff in the event of
an accident. Fire fighting training together with fire drills are carried out on a regular
basis and a fire alarm system is in place at the facility.
November
2003
[licence
applicakm.doc]
Page I7 of 78
EPA Export 25-07-2013:14:23:28
IPC Application Form
It is the intention of Iralco to construct a bunded, chemical storage area on-site so that
all bulk chemicals stored on site will be done so in an environmentally responsible
manner.
Statutorv Requirements
Iralco will adhere to all relevant legislative requirements pertaining to their emissions to
the environment. The use of best available technology not entailing excessive costs, will
be used to prevent or eliminate, or where that is not practicable, to limit, abate or reduce
an emission from the activity.
SECTION D - CESSATION, DECOMMISSIONING AND POST- CLOSURE CARE
Cessation of Activity
to
f c Fo
op r i
yr ns
ig pe
ht ct
ow ion
ne pu
r r rp
eq os
ui es
re o
d nl
fo y.
ra
ny
ot
he
ru
se
.
In the event of decommissioning and closure of the Iralco manufacturing facility, a final
closure plan will be prepared and adopted before it is proposed to cease operation at the
site. The following steps will be implemented and as such form the basis of the final
closure plan;
ns
en
An environmental exit audit will be conducted. On completion of the audit a
residuals report will be prepared in which the disposal routes for all waste, disused
plant and machinery and other waste materials will be identified.
Co
All waste materials (Spent brightener, solvents, etc.) will be transported off-site and
treated or disposed of by an appropriately licensed waste contractor. Subsequently
the potentisil for the generation of residual contaminants at the site is removed.
All machinery and buildings will be decommissioned as per standard procedures.
Building structures may be demolished and the site subsequently landscaped.
On-going environmental monitoring will be extended in order to ensure that no
residuals exist on-site. The findings of this monitoring programme will dictate the
nature, extent and duration of additional aftercare, if any, required. A full appraisal
of the infiastructural requirements on-site during the afkercarephase together with
the pollution control and abatement equipment necessary to minimise or eliminate
the impacts of the facility will subsequently be evaluated in detail.
November
2003
[licence
appiicatiomiocj
Page 18 of 78
EPA Export 25-07-2013:14:23:28
IPC Applica tion Form
.i
:i
r
l
1.
.:
Site Management and Control
Co
ns
en
to
f c Fo
op r i
yr ns
ig pe
ht ct
ow ion
ne pu
r r rp
eq os
ui es
re o
d nl
fo y.
ra
ny
ot
he
ru
se
.
Al1 hectors and managers are committed to the effective implementation of the
Environmental Policy that has been adopted at the Iralco facility. They are responsible
for ensuring that all employees are aware of their individual requirement pertaining to
the environmerit and for supplying relevant training f6r the specific environmental
responsibilities of eachjob.
I
._
November
2003
[licence
application.doc]
..-...
-
Page 19 of 78
-
EPA Export 25-07-2013:14:23:28