annual environmental report 2010 shannon aerospace limited ippc licence … · 2014. 12. 16. ·...

Annual Environmental Report 2010 Shannon Aerospace Limited IPPC Licence Number P0069-02

- 1 -

ANNUAL ENVIRONMENTAL REPORT

2010

SHANNON AEROSPACE LIMITED

IPPC LICENCE NO. P0069-02


- 2 -

CONTENTS

Section Page No. 1.0 Introduction 4

1.1 IPPC Licence Number 4 1.2 Name and Location of Site 4 1.3 Environmental Policy 5

2.0 Site Description 6 2.1 Company Background 6 2.2 Economic Contribution 6 2.3 Local Environmental Conditions 6 2.4 Company Organisation Chart 2010 7

3.0 Environmental Data 8

3.1 Self Monitoring Data 8 3.1.1 Emissions to Water 8 3.1.2 Emissions to Atmosphere 13 3.1.3 Waste 15

3.2 Agency Monitoring and Enforcement 23 3.3 Energy and Water Consumption 24 3.4 Incidents and Complaints 25

3.4.1 Environmental Incidents 25 3.4.2 Environmental Complaints 26

3.5 Summary Information 26

4.0 Environmental Management 27 4.1 Schedule of Objectives & Targets 27 4.2 Environmental Management Programme Report 26 4.3 Environmental Management Programme Proposal 33 4.4 Pollution Emission Register 33

5.0 Licence Specific Reports 33

5.1 Noise Monitoring 33 5.2 Pipeline Inspection 33

APPENDICES Appendix One Environmental Management Programme 34 Proposal for 2011

Appendix Two Solvent Management Programme 47

Appendix Three Noise Survey and Assessment 2010 72 Appendix Four Residuals Management Plan 89 Appendix Five AER/E-PRTR Summary Information 2010 108


- 3 -

LIST OF TABLES

Page No.

Table 1 Emission Point Reference No. S-1 8

Table 2 S1 Effluent Pump 9

Table 3 Flow Rate Compliance 9

Table 4 Organic Solvents Emission in Effluent at S-1 10

Table 5 Oils, Fats & Greases Emissions in Effluent at S-1 10

Table 6 Toxicity 10

Table 7 S-1 Non-Conformances Summary 2010 11

Table 8 SW-1 Surface Water Culvert 2010 11

Table 9 SW-1 Non-Conformances Summary 12

Table 10 Emissions to Atmosphere – Particulates 13

Table 11 Emissions to Atmosphere – TOC 13

Table 12 Emissions to Atmosphere – Chromium (VI) 14

Table 13 Air Emissions Non-Conformances Summary 2010 14

Table 14 Waste Disposal/Recovery Contract Licensing Status 16

Table 15 Wastes Arising 2010 17

Table 16 Wastes Produced 2010 21

Table 17 Waste Recovery as a Percentage 21

Table 18 Waste Management Indicators 22

Table 19 Energy and Water Consumption 24

Table 20 Environmental Incidents 25

Table 21 Complaint Type 26

Table 22 Schedule of Objectives & Targets 27

LIST OF FIGURES

Figure 1 Effluent Emission at S-1 10

Figure 2 Particulate Emissions 13

Figure 3 TOC Emissions 14

Figure 4 Waste Recovery as a Percentage 22

Figure 5 Waste Minimisation Indicators 23

Figure 6 Electricity, Gas and Kerosene Consumption 24

Figure 7 Total Energy Consumption (GJ) 24


- 4 -

INTRODUCTION 1.1 IPPC Licence no. P0069-02 1.2 Shannon Aerospace Limited,

Shannon Airport, County Clare.

This is the eleventh Annual Environmental Report submitted to the EPA in fulfilment of condition 11.8 of Shannon Aerospace’s Integrated Pollution Prevention Control licence no. P0069-02, issued on the 25th July 2005. This Annual Environment Report (AER) was prepared in accordance with the EPA Guidelines for Annual Environmental Reports, published in November 2000. Other reports and proposals in this AER include: • Pollution Emission Register for 2010 • Report of Progress of Environmental Management Programme during 2010 • Proposed Environmental Management Programme for 2011 _______________________ ________________ Mr. Tom Caffrey Date Head of Production Support


- 5 -

1.3 The current text of Shannon Aerospace Limited’s Environmental Policy is set out below.

ENVIRONMENTAL POLICY Shannon Aerospace Limited, providers of aircraft maintenance services, are committed to the protection and enhancement of the environment by: • Undertaking process and production operations, which will minimise any risk to

the environment and prevent pollution as far as is practically possible. • Adhering to all relevant environmental, legislative and regulation requirements. • Seeking to reduce waste and conserve resources through the responsible use of

energy and materials. • Seeking to reduce emissions to atmosphere and water through environmental

objectives and targets. • Promoting environmental awareness and undertaking education programmes

with all employees to develop a responsibility for environmental performance. • Communicating the policy to all interested parties and making it publicly

available.


- 6 -

SITE DESCRIPTION 2.1 Company Background Shannon Aerospace Limited is an aircraft maintenance provider. It is 100% owned by Lufthansa Technik and has been in operation since 1992. There is currently approximately 750 staff employed at Shannon Aerospace. Shannon Aerospace is located to the North-East of Shannon Airport and comprises a 25 hectare site with a 240 x 90 meter building which houses 4 maintenance bays and 2 paint bays as well as various workshops and administrative units. A smaller (40 x 91m) building was added in 1999. This comprises additional workshop space and a lead lined non-destructive testing (NDT) room. The external works include: taxi-way, apron and engine run-up areas with a total of 24,000 square meter concrete surface. The main activities performed at Shannon Aerospace are overhaul of Boeing 737, 757, 767, MD80, Airbus 319 and Airbus 320 aircraft. This work may also involve stripping paint from the fuselage and repainting the aircraft. Shannon Aerospace was required to apply for an IPPC licence as it “uses coating materials in processes with a capacity to use at least 10 tonnes per year of organic solvents”. An Environmental Management System was implemented as part of the requirements of the IPPC licence and was certified to ISO 14001 in October 1999. Since then Shannon Aerospace has continually improved its Environmental Management System following reviews and audits. Shannon Aerospace received a revised IPPC licence in 2005 (licence number 737). Following a change to the EPA’s licence numbering system in July 2006, the licence number was changed to P0069-02. 2.2 Economic Contribution Shannon Aerospace provides employment to people from various countries, mainly resident in the Limerick, Shannon and Ennis area. A significant factor influencing Shannon Aerospace’s operations during 2005 was the continued downturn in the aviation industry following the Iraq war, competition from eastern European countries etc. 2.3 Local Environmental Conditions Shannon Aerospace is situated some 2 miles from Shannon Town Centre. All effluent wastes are sent to the Clare County Council (formerly SFADCO) treatment plant. This treatment plant discharges into the Shannon Estuary and is shared by industrial units from the Shannon Industrial Estate and Shannon town.

- 7 -

Chief Executive Thomas Rückert

Head of Production Support Tom Caffrey

Head of Quality

Paul Finn

Head of Production Pat Foley

Health & Safety Officer Angela Cahir

Facilities & Tooling

Manager Cathal

O’Loufghlin

Head of Human

Resources Niamh

O’Connor

Head of Marketing and Sales

Paul Murray

Production Managers Environmental

Engineer Claire Lynch

Facilities Engineers

John O’Connor & Clem Ryan

Occupational Health Nurse

The organisational chart below outlines the environmental responsibility and reporting structure within Shannon Aerospace Limited.

- 8 -

ENVIRONMENTAL DATA This section contains summary information in relation to emissions, waste arisings, resource consumption, incidents and complaints. 3.1 Self Monitoring Data Information relating to water emissions, air emissions and waste is summarised below. Tables 1 to 5 and 10 to 11 show mass emissions to water and air as well as percentage compliance with IPPC licence limits. Tables 7, 9 and 13 summarise non-conformances, which arose during the report period. 3.1.1 Emissions to Sewer Table 1: Emission Point Reference no. S-1

Parameter pH COD BOD SS Ammonia January 7.40 106 January (ii) 6.91 240

January (iii) 6.91 240 125 6.9 0.01 January (iv) 6.83 430 138 8.1 0.01 January (v) 7.02 1,700 Feb. 7.40 198 105 28.8 0.02 February (ii) 7.06 500 February (iii) 7.38 480 95 32.8


- 9 -

September (ii) 6.96 481 September (iii) 7.19 196 60 14.4 0.11 September (iv) 6.80 395 September (v) 7.20 620 286 9.6 0.3 October 7.01 565 118 23 1.2 October (ii) 7.4 396 October (iii) 7.72 620 October (iv) 7.69 90

October (v) 7.18 144 61 4.4 0.35 November 8.02 270 69 16 0.12 November (ii) 7.78 20 November (iii) 7.98 260 168 7 1.63 November (iv) 7.1 15 December 6.71 310 79 23.5 1.55 December (ii) 8.17 137 December (iii) 8.00 122 44 24 0.47 December (iv) 6.91 73

Table 2: Reference no. S-1 Effluent Pump Parameter Licensed

Mass Emissions (Kg)

Mass Emissions 2007 (Kg)




% of compliant Samples 2010

pH --- --- --- --- --- 100% COD 65,700 11,658 9,036 8,889 5,735 98% BOD 35,040 3,479 2,325 2,881 2,156 100% Susp. Solids

17,520 754 500 801 282 100%

Ammonia (as N)

876 4 55 5 5 100%

Oils, Fats & Greases

NA 52 81 625 146 NA

Flow Rate

43,800m3 18,715m3 21,937m3 23,481m3 18,832m3 See Table 3

Table 3: Flow Rate Compliance Flow Rate

2007 2008 2009 2010 % Compliance with flow rate limits 2010

1. Daily 18,715 m3

21,937 m3 23,481 m3 18,832m3 100%

2. Hourly 18,715 m3

21,937 m3 23,481 m3 18,832m3 99.99%

*regarding days and hours for which flow rate logger was not operational as non-conformances.


- 10 -

Figure 1 – Effluent Emissions at S-1

CO

D

S.S

.

OF

G

99/00

2003

20070

5,000

10,000

15,000

20,000

25,000

30,000

35,000

99/00

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

Table 4: Organic Solvent Emissions in effluent at S -1 10/2/10 All volatiles reported as below 0.01mg/l, apart from White Spirit which

were 0.076mg/l 1/9/10 All volatiles reported as below 0.05mg/l. Table 5: Oils, Fats & Greases Emissions in effluent at S-1 10/03/10 20mgl 1/09/10 4mg/l Table 6: Toxicity Organism Toxic Units

2006 Toxic Units 2007

Toxic Units 2008

Toxic Units 2009

Toxic Units 2010

Tisbe battagliai 48hr EC 50

3.1 45.4 3.1


- 11 -

Table 7: S-1 Non-Conformances Summary 2010 Date Non Compliance Cause Corrective Action 12/05/10 COD exceedance

3,600mg/l vs. 1,500mg/l IPPC licence limit

A number of events took place over a short period of time (e.g. two tech-washes and all-day use of the cleaning bay). This increased production activity is believed to have caused the exceedance.

Drains M1-M4 cleaned out on 11th June 2010 Review of white spirits usage underway. Use of alternative products approved for aircraft use was investigated with a number of suppliers. Trials of new products were carried out in 2010. However, during trials none of the alternative materials proved as effective as white spirits and were also considerably more expensive. Further trials will be carried out in 2011.

7/10/10 Hourly Flow Rate exceedance:18.761m3/hr vs. 15m3/hr IPPC hourly flow rate limit

The pump became clogged with debris. Once the blockage was cleaned, the water that had built up over the few hours was released altogether and hence caused the hourly flow-rate exceedance.

The blockage was removed from the pump which is now working correctly.

*As per condition 4.3.2 this was not technically an exceedance as eight out of ten consecutive composite results, based on flow proportional composite sampling, did not exceed the emission limit value. Table 8: SW-1 Surface Water Culvert 2010 Month Visual

Inspection Odour Inspection

pH COD (mg/l)

January OK OK 7.25


- 12 -

April (iv) OK OK 7.64 20 May OK OK 7.84 10 May (ii) OK OK 8.08 25 May (iii) OK OK 7.87 13 May (iv) OK OK 7.90 15 June OK OK 6.86


- 13 -

3.1.2 Emissions to Atmosphere The table below outlines estimated mass emissions to atmosphere. All dust monitoring results were below emission limit values Table 10: Emissions to Atmosphere – Particulates Reference Point

Mass Emissions 2007*




% of Compliant Samples 2010

EF 4.2 0.527 157 187 147 100% EF 5.1 3 202 270 316 100% EF 6.1 0.69 105 52 107 100% EF 6.6 0.82 305.39 157 127 100% EF 8/9 0.02 0 0 0 100% EF 10/11 0.32 63 138 49 100% *It is assumed that the recorded concentrations of emissions hold for total time that the extract fans were on throughout the year. Figure 2: Particulate Emissions

EF

4.2

EF

6.1

EF

8/9

2010

20040

100

200

300

400

Emission Points

Particulates2010200920082007200620052004200320022001200099/00

Table 11: Emissions to Atmosphere – TOC Reference Point





% Compliance 2010

EF 8/9 0 0 0 0 100% EF 10/11 574 1,725 1,143 933 100% *Note sampling is carried out when peak concentrations are expected. Compliance values are for percentage of time during which monitoring was carried out. Calculated based on flow rates 128,000m3/hr for EF8/9 and 117,000m3hr for EF10/11).


- 14 -

Figure 3: TOC Emissions

EF

8/9

2010

2005

2000

0

2000

4000

6000

8000

Kg

2010

2009

2008

2007

2006

2005

2004

2003

2002

2001

2000

Table 12: Emission to atmosphere – Chromium (VI) Reference Point





% Compliance 2010

EF 8/9 0 0 0 0 100% EF 10/11 0.022 0.031 0.015 0.01 100% Of the air monitoring successfully carried out during January 2010 to end December 2010, the following table summarise the non-compliances indicated. Table 13: Air Emissions Non-Conformances Summary 20 10 Date Non-Compliance Cause Corrective Action


- 15 -

3.1.3 Waste The tables on the following pages outline the waste arising from Shannon Aerospace Limited and disposal routes from Shannon Aerospace for the year January to end December 2010. The overall percentage recovery of waste for 2010 was 38%. This is a slight decrease from last year’s figures; reason for this is due to a quiet summer period in 2010 and less recyclable waste (e.g. batteries etc). significant increase from the previous recovery rates achieved. The main reason for the reduction in hazardous waste recovery was due to large volumes of paint booth sludge, wash-water etc. which were sent for treatment & disposal and cannot be recovered/recycled. The waste management indicators indicate a slight decrease in 2010, compared to 2009. This is due to the greater number of aircraft checks (most of them were only minor checks and did require stripping/painting to be carried out). For details of waste production and recovery see table 16. There is no on-site treatment or recovery of waste at Shannon Aerospace Limited. All waste is recovered, treated or disposed of by licenced external waste management companies.


- 16 -

Table 14: Waste Disposal/Recovery Contractors Licen sing Status Waste Disposal/ Recovery Contractor

Waste Permit or Waste Licence Number

Licensing Authority

Waste Type Collected

Irish Lamp Recycling

WCP/LK/057/02b Limerick County Council*

Fluorescent lamps WEEE

Enva (Shannon Environmental Services, Atlas Oil)

Waste Licence 41-01 Waste Licence 184-01 WCP-DC-08-1116-01

EPA New multi-region permit issued by Dublin City Council

Hazardous Waste Waste Stripper Solvent Waste Wash-water Waste Oil Oil filters All other hazardous waste

Returnbatt WCP/LK/060/02b Waste Licence 105-1

Limerick County Council* EPA

Lead-acid batteries Ni-Cd Batteries Primary Household Batteries

SRCL (Transafe Limited)

WCP/LK/0007/02b

Limerick County Council*

Clinical Waste from on-site medical clinic

Connaught Waste Recycling T/A Confidential Schredding Specialists Ireland

WCP-MO-08-0582-01

Mayo County Council – new multi-region permit

Shredding of confidential paper documents

One 51 (Hegarty Hammond Ltd)

WCP/LK/027/02b WP WR01-2001

Limerick County Council*

Waste metal

Mr. Binman WCP/LK/069/02b Waste Licence 61-2

Limerick County Council* EPA

General refuse Canteen waste Timber Waste Paper/cardboard

Recycling Appeal – Concern.

Laser Printer Cartridges

Aer Rianta Regulated by the Dept. of Agriculture for the disposal of aircraft food waste

N/A Aircraft Food Waste

Frylite WCP/LK/174/04b Limerick County Council*

Cooking Oil

*Permitting Authorities for the purpose of the Waste Management (Collection Permit) Regulations 2001

- 17 -

Table 15: WASTE ARISING 2010 EWC Code Haz

Y/N Description of waste Quantity

(Tonnes/annum) Method of Disposal/ Recovery

Location of Disposal/Recovery

Name of Waste Disposal/Recovery Contractor (if applicable)

0 6 0 1 0 4 Y Phosphoric acid 12% 0.01 D9 b) Shannon, Co. Clare Enva 0 6 0 1 0 5 Y Nitric acid 20% 0.005 D9 b) Shannon, Co. Clare Enva 0 6 0 1 0 6 Y Waste Alochrome –

chromium solution diluted with water

2 D9 b) Shannon, Co. Clare Enva

0 6 0 2 0 4 Y Potassium hydroxide 0.121 D9 b) Shannon, Co. Clare Enva 0 7 0 1 0 4 Y Neodol 91-6 (0.018)

Dinitrol (0.096) Rhenofol (0.035)

0.149 R13 R1 R1

c) Lindenschmidt KG, Germany “ c) Geocycle, Belgium

Enva

0 8 0 1 1 1 Y Solvents/Thinners (12.545) Solvents/Thinners (0.79) Paint Related Material (1.91)

15.245 R1 D9 R1

c) Lindenschmidt KG, Germany

“ “

Enva

0 8 0 1 1 3 Y Waste stripper from aircraft strip

3.027 R1 c) Lindenschmidt KG, Germany

Enva

0 8 0 1 1 7 Y Waste stripper from aircraft strip (4.779) Unused stripper (0.302) Waste stripper (0.722)

5.803 R1 “ D9


Enva

0 8 0 1 1 9 Y Wash Water

44 D9

b) Shannon, Co. Clare Enva

0 8 0 1 2 1 Y Unused Turco 6776 paint stripper

0.966 R1 c) Lindenschmidt KG, Germany

Enva


- 18 -

EWC Code HazY/N

Description of waste Quantity (Tonnes/annum)

Method of Disposal/ Recovery



0 8 0 3 1 8 N Laser Printer Cartridges 0.015 R5 c) Ashbourne, Co. Meath Recycling Appeal 0 8 0 4 0 9 Y Adhesives/Hardeners –

out of date materials 0.255 R1


Enva

0 9 0 1 0 1 Y Developer

0.162 D9 b) Shannon, Co. Clare Enva

0 9 0 1 0 4 Y Fixer 0.150 D9 b) Shannon, Co. Clare

Enva

1 1 0 1 9 8 Y Waste Alochrome – chromium solution diluted with water (1) Ardrox 6440 (0.025) Ardrox 3140 (0.028)

1.053 D9 D9 R1

b) Shannon, Co. Clare “ c) Lindenschmidt KG, Germany

Enva

1 2 0 1 0 7 Y Aeroshell Grease 0.2 ? Enva 1 2 0 1 0 9 Y Ardrox 2814 0.05 R1 c) Lindenschmidt KG,

Germany Enva

1 2 0 1 1 7 Y Sanding Dust 0.762 R1 c) Lindenschmidt KG, Germany

Enva

1 2 0 1 9 9 N Honeybee 60 (0.018)

0.018 R1


Enva

1 3 0 1 1 3 Y Oil and water mixture from cleaning out oil interceptors

39 D9

b) Shannon, Co. Clare

Enva

1 3 0 2 0 8 Y Engine oil & aviation fuel removed from aircraft

34 R1

b) Portlaoise, Co. Laois Enva


- 19 -

EWC Code HazY/N





1 3 0 5 0 3 Oil and water mixture from cleaning out oil interceptors

3 D9 b) Shannon, Co. Clare Enva

1 3 0 7 0 3 Skydrol 3 R1 b) Portlaoise, Co. Laois Enva 1 3 0 8 0 2 Y Drain Cleaning Sludge 6.526 R1 c) Lindenschmidt KG,

Germany Enva

1 3 0 8 9 9 Y Oil filters (0.6)

0.6 R9

b) Portlaoise, Co. Laois

Enva

1 5 0 1 1 0 N Empty Plastic Barrels/Containers


1 5 0 2 0 2 Y Mixed hazardous waste – contaminated wipes, brushes etc. (51.621) Ammonia Absorber (0.38)

51.659 R1 c) Lindenschmidt KG

Enva

1 6 0 5 0 4 Y Empty Aerosols from workshops, lines etc.

0.654 R1 b) Portalaoise, Co. Laois Enva

1 6 0 5 0 7 Y Paint Booth Sludge (44) Oxygen Generators (0.108)

44.108 D9 D15

b) Shannon, Co. Clare c) Lindenschmidt KG, Germany

Enva

1 6 0 6 0 1 Y Lead-acid batteries 0.895 R4 b) Co. Kildare Returnbatt Ltd. 1 6 0 6 0 4 N Primary (Household)

batteries 0.311 R4 b) Co. Kildare Returnbatt Ltd.

1 6 0 7 0 9 Y Paint Booth Sludge 57.448 D9 b) Shannon, Co. Clare Enva 1 6 0 9 0 4 Y Ammonium persulphate 0.015 D9 b) Shannon, Co. Clare

Enva


- 20 -

EWC Code HazY/N





1 8 0 1 0 1 N Clinical Waste 0.045 D8 b) KTK Landfill, Kilcullen, Co. Kildare

SRCL

2 0 0 1 0 1 N Paper/cardboard

44.68 R3 b) Co. Limerick Mr. Binman

2 0 0 1 2 1 Y Lamps and bulbs of varying length taken from aircraft when expired

0.474 R4/R5 b) Athy, Co. Kildare. Irish Lamp Recycling Ltd.

2 0 0 1 2 5 N Cooking Oil 1.56 R1 b) Kilcolgan, Co. Galway Frylite Ltd. 2 0 0 1 2 9 Y Cee Bee Cleaner Alko


2 0 0 1 3 5 Y Electrical Equipment e.g. computer monitors, printers etc.

1.384 R4/R5 b) Athy, Co. Kildare. Irish Lamp Recycling Co. Ltd.

2 0 0 1 3 8 N Timber Waste 34.7 R5 b) Scariff, Co. Clare Mr. Binman 2 0 0 1 4 0 N Steel/Aluminium 17.12 R4 b) Co. Limerick One 51 2 0 0 2 0 1 N Compost 3.36 R3 b) Co. Limerick Mr. Binman 2 0 0 3 0 1 N General Refuse 171.04 D1 b) Gortnadromma

Landfill, Co. Limerick b)Ballybeg, Inagh, Co. Clare

Mr. Binman

- 21 -

Table 16: Waste Produced 2010 Waste Produced 2010 Tonnes/annum Total quantity of waste produced in 2010 590.128 Total quantity of waste disposed of on-site 0.00 Total quantity of waste disposed of off-site 364.199 Total quantity of waste recovered on-site 0.00 Total quantity of waste recovered off-site 225.929 Quantity of non-hazardous waste produced in 2010 273.566 Total quantity of non-hazardous waste disposed of on-site 0.00 Total quantity of non-hazardous waste disposed of off-site 171.04 Total quantity of non-hazardous waste recovered on-site 0.00 Total quantity of non-hazardous waste recovered off-site 102.526 Quantity of hazardous waste produced in 2010 316.562 Total quantity of hazardous waste disposed of on-site 0.00 Total quantity of hazardous waste disposed of off-site 193.159 Total quantity of hazardous waste recovered on-site 0.00 Total quantity of hazardous waste recovered off-site 123.403 Table 17: Waste Recovery as a Percentage Recovery 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 Hazardous Waste Recovered

20% 16% 16% 17% 12% 14% 16% 41% 47% 39%

Non-hazardous waste recovered

29% 31% 30% 34% 27% 39% 40% 33% 40% 38%

Overall waste recovery

26% 23% 25%

26% 20% 29% 28% 37% 43% 38%


- 22 -

Figure 4: Waste Recovery as a Percentage

Hazardous

Overall

2010

2007

2004

2001

98/99

0

10

20

30

40

50

2010200920082007200620052004200320022001200099/00

Waste Management Indicators In previous AER’s a “Gross Waste Management Indicator” (GWMI) and a “Nett Waste Management Indicator” (NWMI) based on the number of aircraft processed each year were developed. These indicators are comparable on a year by year basis and in both cases a decreasing trend is desirable. The indicators are calculated as follows: Gross Waste Management Indicator = Waste produced Number of aircraft serviced Nett Waste Management Indicator = Waste produced – waste recovered Number of aircraft serviced Table 18: Waste Management Indicators 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 Gross WMI 7.8 18.2 21.1 24.1 8.6 10.5 12.1 7.8 8.1 6.8 Nett WMI 5.7 14 15.9 17.7 6.9 7.5 8.8 4.9 4.6 4.2


- 23 -

Figure 5: Waste Minimisation Indicators

0

5

10

15

20

25

30

97/88

99/00

2001

2003

2005

2007

2009

Was

te G

ener

atio

n (T

/airc

raft)

Gross WMI

Nett WMI

The Gross WMI and Net WMI have stayed relatively stable in 2010 from the 2009 figures. A large number of aircraft pass through the hangar every year – 87 in 2010, 75 in 2009, 90 in 2008. Most of these aircraft came in for line maintenance or smaller checks which did not involve painting or stripping of aircraft. Out of the 87 aircraft in 2010, 29 aircraft were painted and 17 chemically stripped in Shannon Aerospace 3.2 Agency Monitoring and Enforcement The Agency visited the Shannon Aerospace site on four occasions in 2010 to carry out site audits and to take monitoring samples for both effluent emissions and atmospheric emissions. Scientifics (sub-contractors for the EPA) carried out particulate monitoring on the 6th August 2010 at emission point EF6.6. Results indicated compliance with IPPC limits. A composite sample was taken from monitoring point S1 on 20th April 2010. Results indicated compliance with IPPC limits. A composite sample was taken from monitoring point S1 on 7th October 2010. Results indicated compliance with IPPC limits. A site inspection was carried out on the 3rd June 2010.


- 24 -

3.3 Energy and Water Consumption The table below outlines the consumption of energy and water resources at Shannon Aerospace. Table 19: Energy and Water Consumption Electricity

kWh LPG m3 Natural

Gas m3 Kerosene Litres

Water Supply* m 3

2010 6,253,497 112,988 138,807 499,099 18,832m3 Equivalent Gj 22,513 21,326 138 21,112 *All water in Shannon Aerospace is supplied from a municipal water source Figure 6: Electricity, Gas and Kerosene Consumption

Ele

ctric

ity

Gas

Ker

osen

e

0

10000

20000

30000

40000

50000

60000

70000

GJ

97/98

99/00

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

* Gas shows LPG and Natural Gas combined Figure 7: Energy Consumption (Gj)

TOTAL ENERGY CONSUMPTION (GJ)

020000400006000080000

100000120000

97/9

8

98/9

9

99/0

0

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

* Building no. 2 became operational during 99/00.


- 25 -

3.4 Incidents and Complaints 3.4.1 Environmental Incidents Table 20: Environmental Incidents Date Non Compliance Cause Corrective Action 12/05/10 COD exceedance

3,600mg/l vs. 1,500mg/l IPPC licence limit

A number of events took place over a short period of time (e.g. two tech-washes and all-day use of the cleaning bay). This increased production activity is believed to have caused the exceedance.

Drains M1-M4 cleaned out on 11th June 2010 Review of white spirits usage underway. Use of alternative products approved for aircraft use was investigated with a number of suppliers. Trials of new products were carried out in 2010. However, during trials none of the alternative materials proved as effective as white spirits and were also considerably more expensive. Further trials will be carried out in 2011.

7/10/10 Hourly Flow Rate exceedance:18.761m3/hr vs. 15m3/hr IPPC hourly flow rate limit

The pump became clogged with debris. Once the blockage was cleaned, the water that had built up over the few hours was released altogether and hence caused the hourly flow-rate exceedance.

The blockage was removed from the pump which is now working correctly.

8/12/10 COD exceedance of120mg/l vs. trigger limit of 100mg/l

Exceedance is believed to have been caused by the use of urea to de-ice apron area during the recent spell of cold weather

De-icing of apron area & runways are carried by Aer Rianta in accordance with airport requirements.


- 26 -

3.4.2 Environmental Complaints Table 21: Complaint Type Complaint Class IPPC P0069-02

Noise Odour Water Dust Procedural Misc. Total

Total 0 0 0 0 0 0 0 There were 0 environmental complaints, as defined in Condition 6.11.2 of the IPPC licence, during 2010. 3.5 Summary Information The summary information in relation to E-PRT, Annual Environmental Reports etc. has been submitted via the EPA’s new web-based data reporting system. The AER/PRTR Emissions Data information is attached to this AER report as Appendix Five.


- 27 -

ENVIRONMENTAL MANAGEMENT 4.1 Schedule of Environmental Objectives and Target s The following table shows the schedule of environmental objectives and targets in operation during 2010. For the full text of each objective and/or target the EMP for 2010 (submitted with AER 2009) should be consulted. Table 22: SCHEDULE OF ENVIRONMENTAL OBJECTIVES AND TARGETS OBJ TAR SUMMARY 04 05 06 07 08 09 10 11 12 2.9 2.9.2 LAUNCH LUFTHANSA-BASED IQ-MOVE

INTRANET PLATFORM

2.10 2.10.1 DEVELOP AN ENVIRONMENTAL METRIC TO ADD TO THE SAL BALANCED SCORECARD

2.10 2.10.2 DEVELOP A SYSTEM SO THAT ENVIRONMENTAL DATA CAN BE UPDATED IN THE METRIC SYSTEM MONTHLY

3.12 3.12.1 ESTABLISH IF HFCS ARE BEING USED ON-SITE AND THE AMOUNT OF REFRIGERANT IN EACH SYSTEM

3.12 3.12.2 DEFINE AN APPROPRIATE LEAK TESTING PROGRAMME FOR EACH PLANT

3.12 3.12.3 ASSESS WHETHER ANY OF THE REFRIGERATION GASES CAN BE REPLACED IN SOME OF THE UNITS

4.7 4.7.1 MODIFY TABLE USED FOR CLEANING AIRCRAFT PARTS IN THE CLEANING BAY

5.7 5.7.1 REDUCE WASTE GOING TO LANDFILL BY 50% OVER 15 YEARS

5.7 5.7.2 REDUCE BIODEGRADABLE WASTE TO LANDFILL BY 65%, OVER 15 YEARS

5.9 5.9.2 EXAMINE POTENTIAL FOR REDUCTION OF LANDFILLED WASTE

5.9 5.9.3 IMPLEMENT CHANGES TO WASTE MANAGEMENT IN THE CANTEEN

5.9 5.9.4 INCREASE PLASTIC RECYCLING IN SAL

5.9 5.9.5 SET UP A COMPOSTING SYSTEM IN SAL

5.13 5.13.1 OFFER EMPLOYEES AN OPPORTUNITY TO PURCHASE DESKTOP COMPUTERS FOR €5 EACH

5.13 5.13.2 ARRANGE COLLECTION OF OLDER COMPUTER MODELS BY EMPLOYEES

9.5 9.5.3 CARRY OUT CHANGES TO WORK PRACTICES

11.2 11.2.1 DETERMINE IF SAFETY DATA SHEETS CAN BE ADDED TO THE INFONET SYSTEM

11.2 11.2.2 ADD SIGNIFICANT SAFETY DATA SHEETS TO THE COMPANY INFONET SYSTEM

4.2 Environmental Management Programme Report A report on the progress in achieving our environmental objectives and targets is set out below.


- 28 -

1 Introduction This report summarises the progress made in implementing the Environmental Management Programme to date. The current revision of the environmental management programme is revision 17. Prioritisation of projects associated with this EMP is a key feature underpinning its implementation. This is due to the historically large number of projects, which were originally proposed in earlier years. OBJECTIVE 2.9 Develop environmental procedures and documentation as

part of IQ Move IQ Move is an integrated, process oriented and Intranet based management documentation system which will supersede the conventional "paper" Manual and Procedure Instructions currently used. A group Lufthansa meeting relating to Environmental, Health & Safety issues was held at Lufthansa Technik Airmotive Ireland in early March 2009 where preliminary discussions were held about IQ Move. A further group Lufthansa conference made up of Irish, British, German, Maltese, Bulgarian and Hungarian environmental, health & safety staff was held in Seeheim, Germany in late March 2009. During this meeting it was decided to start cross-referencing of environmental, health & safety requirements between the companies – Irish companies would cross-reference each other as the legislative requirements would be similar. This would avoid repetition of developing the IQ Move system between the companies. A further process mapping took place between the Irish Lufthansa companies later on in the year. In November 2009, environmental and health & safety staff in SAL received IQ Move Requirement Manager Training. Only the requirement managers will be able to update the database of IQ Move. Clearance from the Irish Aviation Authority (IAA) to ensure that the online system conforms to aircraft regulations was given in 2010. Training on the use of IQ Move to all SAL staff was also carried out in 2010 to ensure familiarity with the system. Process modellers put the information into the IQ Move system. A process modeller was due to trained up and input the environmental procedures into IQ Move, however due to the recent redundancies in the company this has now been delayed. OBJECTIVE 2.9 OVERALL STATUS On-going 50% complete Timeframe 2009-2012 OBJECTIVE 2.10 Add an environmental metric to the S hannon Aerospace

Balanced Scorecard system. A balanced scorecard is a strategic performance management tool used by companies to keep track of company activities and monitor the consequences arising from these actions. SAL set up a Balanced Scorecard system in 2010 to monitor all


- 29 -

areas (including environmental). However, due to the redundancies in SAL this project was scrapped in 2011. OBJECTIVE 2.10 OVERALL STATUS Completed 100% complete Timeframe 2010 OBJECTIVE # 3.12 Control and management of HCFC’s i n refrigeration and

air-conditioning units Regulation (EC) no. 1005/2009 and Regulation (EC) no. 842/2006 have brought in new requirements regarding the use of HCFCs (such as R22) in refrigeration gases. The legislation places significant obligations on the end users of the gases e.g. leak testing with the frequency determined by the charge of the refrigeration or air conditioning units, ensuring that operators have appropriate qualifications, ensure that waste controlled substances are appropriately managed etc. A survey of all refrigerant gases on-site was carried out in May 2010. An excel spread-sheet has been set up with up with details from this survey e.g. type of refrigerant gas, volumes etc, maintenance contractors etc. This survey also determined that one unit requires 6-month testing, the rest are all annual leak-checks. Companies now have to check that refrigeration contractors used on-site are adequately qualified. SAL uses two refrigeration companies – Cross Refrigeration and Mulvaney Air Conditioning Services. Cross Refrigeration is listed on the www.fgasregistration.ie website and has Category I qualifications. Mulvaney Air Conditioning Services was not listed on the website. SAL contacted this company for further details about their qualifications, and has established that they are currently undergoing training courses on F-gas company certification. All F-gas training has to be completed by July 2011. OBJECTIVE 3.12 OVERALL STATUS On-going 70% complete Timeframe 2010-2014 OBJECTIVE # 4.7 Carry out improvements to the use o f white spirits in the

cleaning bay Modifications have been carried out to a table in the cleaning bay which will enable the collection of white spirits. This table is used for cleaning floor-boards, which are usually soaked in white spirits to soften the glues & various adhesives. This new method ensures that this white spirit can be collected and emptied in the waste white spirits barrel; reducing the volume of white spirits entering the drain. In 2010, an environmental alert was issued to all staff about white spirits usage and urging staff to only use this chemical in moderation. Decals about correct disposal of white spirits have been made up in four different languages for the cleaning bay. This will help ensure that all staff (including contract cleaning staff) are familiar with correct disposal of white spirits.


- 30 -

In 2010, SAL contacted a number of companies to source and trial alternatives to white spirits. Because of aircraft approvals, only a certain number of products are approved to be used on aircraft which severely restricts the chemicals which can be used. PT Technologies produce a number of cleaning products which are approved for use on aircraft. PT Technologies carried out an audit of the tech-washing products and the use of solvents/white spirits in SAL. Feedback received from them indicated that SAL does use a number of water-based cleaners, but there are a few areas that could be improved or different products trialled. Trials were carried out on some new products in late 2010, but haven’t worked sufficiently well to be considered as replacements to white spirits. Further trials of alternatives products will also be carried out in 2011. OBJECTIVE 4.7 OVERALL STATUS On-going 70% complete Timeframe 2010-2014 OBJECTIVE 5.7 Waste Management at Shannon Aerospace to be

consistent with Irish National Targets for waste management where equivalent comparisons can be made .

Waste recovery of non-hazardous waste in 2010 was 38%. This is close to the target of 50% reduction of waste going to landfill. The reduction has been achieved by removing all recyclable streams from this waste stream. Nearly all possible areas for recycling of non-hazardous waste are being carried out at present. Plastics recycling in the canteen area was set up in 2010, which is further helping to reduce non-hazardous waste going to landfill. Segregation & off-site composting of food waste from the canteen has also reduced biodegradable waste consigned to landfill. Target 5.7.2 (reduce biodegradable waste consigned to landfill by 65% over 15years) has now been achieved. OBJECTIVE 5.7 OVERALL STATUS On target 90% complete Timeframe 1998 to 2013 OBJECTIVE 5.9 Identify areas where reduction of lan dfilled waste is

possible. A number of options for reuse/recycling of landfilled waste were identified and assessed. A recycling unit from JFC products was purchased to allow for greater recycling and segregation of waste from the canteen – also increases the visibility of recycling efforts. The unit now allows for the collection of plastic glasses, plastic bottles, papers etc. – this waste is now segregated from the general waste and sent off-site for recycling. A composting system was also set up in SAL in 2010 in conjunction with Mr. Binman. 3.36 tonnes of compost waste was sent off-site for composting in 2010; this equates to a 1.2% reduction in non-hazardous waste sent off-site for land-filling.


- 31 -

OBJECTIVE 5.9 OVERALL STATUS Completed 100% complete Timeframe 2004-2010 OBJECTIVE 5.13 Offer employees an opportunity to pu rchase old SAL

desktop computers In 2010, an upgrade of all desktop computers was carried out in SAL. The upgrade was needed to ensure that computers would be able to run the Lufthansa IQ Move program. Instead of sending the computers for recycling, the company decided to offer the current desktop computers to employees at a nominal cost of €5 (reuse instead of recycling). The computers were offered on a first come first served basis and computers with monitors were sold first. An ad for the computer scheme was set up on the company Infonet page in December 2010. More than 350 employees indicated that they would like to purchase the computers. 320 PC’s were sold to employees. OBJECTIVE 5.13 OVERALL STATUS Closed 100% complete Timeframe 2010 OBJECTIVE 9.5 Efficiency of raw materials. The aerospace industry is a specification-driven business with detailed approval required for every product used on an aircraft. Initiatives to eliminate harmful materials (e.g. lead and cadmium pigments, chromates and solvent emissions) from formulations over the years has forced high levels of research before development can even take place.

Aerospace coatings manufacturers are under constant pressure to improve the quality and durability of the products used to protect and decorate aircraft. They are trying to balance all the influencing factors including the environment and manufacturer requirements such as weight reduction and accelerating application and dry times.

There are limited opportunities for changing products as the industry is highly regulated and all chemicals used in an aircraft environment are specified by the airframe manufacturers. Due to potential contamination and damage to aircraft structures and systems, unapproved products cannot be used on the aircraft.

Shannon Aerospace is a small non-research based organisation when viewed in the context of the global Aerospace maintenance industry, and in any case the relevant aircraft manufacturers carry out development of new products. Therefore SAL’s most effective contribution is to identify and purchase those products with the lowest VOC content available, as appropriate, thereby helping to increase market demand for the development of lower VOC products.

The changeover to new products is a slow process, which involves getting manufacturers approval e.g. Boeing and Airbus. The primary development topics by aircraft and paint manufacturers at present are in water-based technologies for


- 32 -

structural primers and lower VOC products in several special use coating applications.

In an effort to reduce costs and improve efficiency, SAL decided to implement the LEAN process. As part of this process, all processes and work activities have been identified as per LEAN methodology. This involved the mapping of all the steps involved in every process, from the initial ordering of parts to disposal of materials etc. Most of the mapping out of the steps took place in late 2005. Once this work was done, rapid improvement events (RIE’s) were then carried out on different processes. A number of RIE’s have been carried out in 2006-2009. This process is still continuing in 2009-2010. In the computer network storage infrastructure, SAL achieved performance gains of almost 300% and reduced energy consumption by 28% after implementing an end-to-end datacentre solution in 2010. The savings are based on reductions in power and cooling, as well as the deployment and management costs of the database infrastructure. The computer storage network needed to be upgraded, as it was no longer able to meet the growing demands of the organisation. The Information Services (I.S.) Department worked with Dell Computers to find a solution that would simplify the existing infrastructure, reduce management and maintenance costs and increase computing power. Shannon Aerospace’s server was virtualised to provide up to 15 virtual servers, offering redundancy in a cluster environment, increase storage capacity and top performance through optimised storage tiering and utilisation of the latest server technology. In late 2009, a redundancy program was announced which will result in over 120 redundancies (mostly in the support staff area) in 2010. This will result in further changes to work practices to ensure that work can still be carried out with less staff. OBJECTIVE 9.5 OVERALL STATUS On-target 80% complete Timeframe 2010 OBJECTIVE 11.2 Add significant safety data sheets t o the company Infonet

system Safety data sheets (SDS) had been kept on-site in paper format, which meant that there were not available for viewing 24-7.To ensure that safety data sheets were readily available to all members of staff, a system was developed where important SDS’s could be put up on the company infonet. This system has made them easier to access and ensure that they are readily available to all staff 24 hours a day. Most of the significant chemicals in use in SAL are on-line, and some SDS have been added upon request from the workshops, workstations etc. When new chemicals to the SAP system are added & evaluated, they are being placed on the on-line system where appropriate. A paper format of the SDS is still being kept on-file in the Facilities & Tooling Office. OBJECTIVE 11.2 OVERALL STATUS Completed 100% complete Timeframe 2010


- 33 -

4.3 Environmental Management Programme Proposal The proposed Environmental Management Programme for 2011 is attached as Appendix I. 4.4 Pollution Emission Register A pollution emission register provides information on the final destination of substances used in a process. Its purpose is to allow tracking of principle pollutants. Under E-PRTR an expanded list of 91 chemicals must be reported. The EPA set up a web-based data reporting system in 2007 to report for E-PRTR pollutants. A copy of the PRTR releases to air & waste-water (as required by the web-form format) is attached to this AER as Appendix Five.

LICENCE SPECIFIC REPORTS 5.1 Noise Monitoring Monitoring was carried out at five site boundary locations at Shannon Aerospace and at Noise Sensitive Location B in March 2010. This is the 1st year of the 5th three-year cycle of noise monitoring. A copy of the report for the noise monitoring carried out in February 2010 is attached as Appendix Three. 5.2 Pipeline Inspection In August 2010, Cured-in-Place Pipelines Ltd. carried out hydraulic testing of the pipelines on-site on behalf of SAL. As a result of the survey, one area of the line (outside Bay 4) was identified as requiring maintenance work. All other areas of the pipeline passed the hydraulic testing. Relining of the pipeline outside Bay 4 is due to be carried out in 2011 (EMP objective 7.9).


- 34 -

APPENDIX I

ENVIRONMENTAL MANAGEMENT PROGRAMME

PROPOSAL FOR 2011

Document: Environmental Management Programme Effective date: 16/3/11 Reference: END 004 Revision: 17 Page 35 of 133

- 35 -

ENVIRONMENTAL MANAGEMENT PROGRAMME 1.0 INTRODUCTION This is the environmental management programme for 2011 at Shannon Aerospace. It is intended to meet the requirements of Shannon Aerospace IPPC licence conditions 2.2.1 and 2.2.2.2 and addresses more than a five year period.

Changes from the previous revision are highlighted in italics. The projects sections are divided as follows;

2.0 Environmental Management Systems

Projects regarding improvements to overall environmental management at Shannon Aerospace.

3.0 Control of Air Emissions

This corresponds to section D, Atmospheric Emissions in the Register of Environmental Aspects and Impacts.

4.0 Control of Emissions to Sewer

This corresponds to section B, Aqueous Discharges in the Register of Environmental Aspects and Impacts.

5.0 Waste Management

This corresponds to sections F, Hazardous Waste and E, Non-Hazardous Waste in the Register Environmental of Aspects and Impacts.

6.0 Surface Water Protection

This corresponds to section B, Aqueous Discharges in the Register of Environmental Aspects and Impacts.

7.0 Groundwater Protection

This corresponds to section K, Past Activities / Groundwater and Soil Contamination in the Register of Environmental Aspects and Impacts.

8.0 Noise

This corresponds to section G, Noise in the Register of Environmental Aspects and Impacts.

9.0 Resource Minimisation

This corresponds to sections A, Water Usage and C, Energy Usage in the Register of Environmental Aspects and Impacts.

10.0 Storage of Hazardous Materials

Projects involving hazardous stores areas and storage of hazardous materials generally.

11.0 Hazardous Compounds

This corresponds to section I, Use of Hazardous Chemicals in the Register of Environmental Aspects and Impacts.

12.0 Visual Impact

This corresponds to section H, Visual Impact in the Register of Environmental Aspects and Impacts.

13.0 Radiation

This corresponds to section N, Radiation in the Register of Environmental Aspects and Impacts.


- 36 -

SECTION 2.0 ENVIRONMENTAL MANAGEMENT SYSTEMS OBJECTIVE # 2.9 Develop environmental procedures and documentation as part of IQ Move. REASON Lufthansa IQ move is an integrated, process oriented and Intranet based management documentation system. IQ MOVE will supersede the conventional "paper" Manual and Procedure Instructions. PROJECT METHOD

STEP METHOD PERSON RESPONSIBLE

DEADLINE

1 Participate in Lufthansa events to set up IQ move in Shannon Aerospace

Facilities Manager/ Environmental Engineer

JUL 2009 DONE

2 Define and agree Environmental, Health & Safety Key Performance Indicators

Environmental Engineer

DEC 2009 DONE

3 Launch internet based Lufthansa based E, H & S communication platform (IQ Move Intranet Application)

Environmental Engineer/I.S. Dept.

DEC 2010

4 Staff member to be selected/trained up as an Environmental Process Modeller

Head of Production Support

DEC 2011

5 Carry out modelling of environmental processes and procedures

Environmental Engineer/Process Modeller

JUN 2012

6 Launch environmental procedures as part of IQ Move processes

Environmental Engineer/Process Modeller/I.S. Dept.

DEC 2012

Overall responsibility for objective #2.9 Environmental Engineer Overall target date for achievement of objective #2 .9 DEC 2012

Associated Targets Responsibility Date 2.9.2 Launch Lufthansa based IQ move intranet

platform Quality Dept./ Environmental Engineer

DEC 2010 DONE

2.9.3 Person to be trained as an Environmental Process Modeller

Head of Production Support

DEC 2011

2.9.4 Carry out modelling/mapping of environmental processes and procedures

Environmental Engineer/Process Modeller

JUN 2012

2.9.5 Launch environmental procedures as part of IQ Move.

Environmental Engineer/Process Modeller/I.S. Dept.

DEC 2012


- 37 -

SECTION 2.0 ENVIRONMENTAL MANAGEMENT SYSTEMS OBJECTIVE # 2.11 Incorporate EPA’s incident notification requirements into company procedures REASON In 2011, the EPA issued a guidance note on revised incident notification requirements. This includes a change in categorisation of incidents, incident notification form which must be used etc. PROJECT METHOD


DEADLINE

1 Review updated guidance note Environmental Engineer

APR. 2011

2 Ensure requirements of the guidance note are incorporated into environmental procedures

Finance Dept./ Environmental Engineer

JUNE 2011

3 Incorporate the EPA’s Incident Notification Form into SAL’s environmental documentation system


JUNE 2011

Overall responsibility for objective #2.12 Environmental Engineer Overall target date for achievement of objective #2 .12 JUN 2011

Associated Targets Responsibility Date 2.11.1 Review updated guidance note Environmental

Engineer APR. 2011

2.11.2 Ensure requirements are documented in environmental procedures


MAY 2011

2.11.3 Incorporate incident notification form as an environmental record


JAN 2011


- 38 -

SECTION 2.0 ENVIRONMENTAL MANAGEMENT SYSTEMS OBJECTIVE # 2.12 Carry out environmental training with new SAL managers REASON In 2010, a major restructuring programme in Shannon Aerospace was announced. A redundancy scheme was put in place, in which 140 people were made redundant. This has resulted in a number of new departments, new managers etc. Training of new managers and certain other staff will need to be carried out. PROJECT METHOD


DEADLINE

1 Determine which SAL staff (new managers, new department heads etc.) require environmental training in light of the company restructuring.


JUNE 2011

2 Carry out environmental training Finance Dept./ Environmental Engineer

JUNE 2011

3 Update training records Environmental Engineer

JUNE 2011

Overall responsibility for objective #2.12 Environmental Engineer Overall target date for achievement of objective #2 .12 JUN 2011

Associated Targets Responsibility Date 2.12.1 Carry out environmental training Environmental

Engineer JUNE 2011


- 39 -

SECTION 3.0 CONTROL OF AIR EMISSIONS OBJECTIVE # 3.12 Control and management on HCFC’s in refrigeration and air-conditioning units. REASON Regulation (EC) no. 1005/2009 and Regulation (EC) no. 842/2006 have brought in new requirements regarding the use of HCFCs (such as R22) in refrigeration gases. The legislation places significant obligations on the end users of the gases e.g. leak testing with the frequency determined by the charge of the refrigeration or air conditioning units, ensuring that operators have appropriate qualifications, ensure that waste controlled substances are appropriately managed etc. PROJECT METHOD


DEADLINE

1 Establish if HFC’s are being used on-site, and the amount of refrigerant in each system.

Facilities Engineer/ Environmental Engineer

JUN 2010 DONE

2 Start to keep the required records about each HFC plant

Facilities Engineer JUN 2010 DONE

3 Define an appropriate leak testing programme for each plant. Frequency of leak checking programme depends on size of unit and type of refrigerant gas.

Facilities Engineer JUL 2010 DONE

4 Ensure that leak testing is carried out by suitably qualified personnel.

Facilities Engineer JUL 2010

5 Assess whether HFC gases can be totally replaced in some of the smaller refrigeration systems

Facilities Manager/ Facilities Engineer

DEC 2014

Overall responsibility for objective #3.11 Facilities Manager Overall target date for achievement of objective #3 .12 DEC 2014

Associated Targets Responsibility Date 3.12.1 Establish if HFCs are being used on-

site and the amount of refrigerant in each system

Facilities Engineer JUN 2010 DONE

3.12.2 Define an appropriate leak testing programme for each plant

Facilities Engineer JUL 2010 DONE

3.12.3 Assess whether any of the refrigeration gases can be replaced in some of the units

Facilities Manager/ Facilities Engineer

DEC 2014

3.12.4 Ensure that refrigeration contractors are appropriately qualified

Facilities Engineer/ Env. Engineer

AUG 2011


- 40 -

SECTION 3.0 CONTROL OF AIR EMISSIONS OBJECTIVE # 3.13 Ensure SAL meets EPA minimum standards for air emissions monitoring. REASON Licensees must maintain documentation to demonstrate the competency of the companies and individual personnel involved in carrying out monitoring of emissions to atmosphere from the site. PROJECT METHOD


DEADLINE

1 Review EPA minimum standards for air emissions monitoring e.g. Guidance Note #2


JUN 2011

2 Assess current air sampling methods Environmental Engineer

JUN 2011

3 Carry out any changes to monitoring practices if required


AUG 2011

4 Ensure that external monitoring consultants are competent to carry out monitoring of emissions to atmosphere


DEC 2011

Overall responsibility for objective #3.13 Facilities & Tooling Manager Overall target date for achievement of objective #3 .13 DEC 2011

Associated Targets Responsibility Date 3.13.1 Review EPA minimum standards for air

emissions monitoring Environmental Engineer

JUN 2011

3.13.2 Assess current air sampling methods Environmental Engineer

JUN 2011

3.13.3 Carry out changes to monitoring practices if required


AUG 2011

3.13.4 Ensure external monitoring consultants are competent to carry out air monitoring


DEC 2011


- 41 -

SECTION 4 EFFLUENT OBJECTIVE # 4.7 Carry out improvements to the use of white spirits in the cleaning bay REASON There have been occasional COD exceedances over the past years, which are believed to have been caused by the use of white spirit in the cleaning bay. This project will investigate methods of reducing white spirits from the effluent stream. PROJECT METHOD


DEADLINE

1 Modify table used for cleaning a/c parts in cleaning bay e.g. install sump etc. to allow water to be contained.

Interiors & Paint Shops Manager/ Environmental Engineer

MAR 2010 DONE

2 Determine if other solvent containment measures can be put in place


JUL 2010 DONE

3 Evaluate other solvent waste recycling/reuse options e.g. solvent recycling unit for white spirits


AUG 2010 DONE

4 If feasible, set up solvent recycling unit in the cleaning bay


DEC 2010 CLOSED OUT

5 Determine if measures have resulted in improved effluent test results


DEC 2010

6 Liaise with companies who may have alternatives to white spirits

Environmental Engineer/ Facilities & Tooling Manager/Materials

DEC 2012

Overall responsibility for objective #4.7 Facilities & Tooling Manager Overall target date for achievement of objective #4 .7 DEC 2012

Associated Targets Responsibility Date 4.7.1 Modify table used for cleaning aircraft

parts in the cleaning bay Interiors & Paint Shops Manager/

MAR 2010 DONE

4.7.2 Liaise with companies who may have alternatives to white spirits

Environmental Engineer/ Facilities & Tooling Manager/Materials

DEC 2012


- 42 -

SECTION 5.0 WASTE MANAGEMENT OBJECTIVE 5.7 Waste management at Shannon Aerospace to be consistent with Irish National Targets for waste management where equivalent comparisons can be made. REASON This is in line with the Irish National Targets for waste management. PROJECT METHOD STEP METHOD PERSON

RESPONSIBLE DEADLINE

1 Categorise all types of waste being landfilled. [By carrying out analysis of landfilled waste etc]


July 2011

2 Identify alternative routes and/or changes in waste management practices for the most significant contributors to landfilled waste.


August 2011

3 Implement the necessary changes to waste management on site.


December 2011

4 Repeat steps 1 to 3 each year until this objective has been achieved.


2013

Overall responsibility for objective 5.7 Environmental Engineer Overall target date for achievement of objective 5. 7 Dec 2013 Associated Targets Responsibility Date 5.7.1 Reduce waste going to landfill by

50% Environmental Engineer

Dec 2013

5.7.2 Reduce biodegradable wastes consigned to landfill by 65%


Dec 2013 DONE


- 43 -

SECTION 7.0 GROUNDWATER PROTECTION OBJECTIVE 7.9 Ensure bunding structures for materials are adequately impervious/bunded to protect groundwater REASON Bunds could leak and give rise to soil and groundwater contamination. A check of bunds is required under condition 6.6 of the IPPC licence. PROJECT METHOD STEP METHOD PERSON


1 Carry out integrity testing on pipelines

Facilities Engineer DEC 2011

2 Establish a programme for carrying out any necessary repairs.


DEC 2011

3 Carry out repairs to drain outside Bay 4


DEC 2012

5 Carry out bund integrity testing on all bunds and underground tanks


DEC 2012

5 Carry out second three year test as per programme defined above.


DEC 2009

Overall responsibility for objective 7.9 Facilities & Tooling Manager Overall target date for achievement of objective 7. 9 December 2012 Associated Targets Responsibility Date 7.9.1 Carry out pipeline integrity

testing Facilities Engineer DEC 2011

7.9.2 Carry out repairs to drain outside

Bay 4 Facilities Engineer DEC 2011

7.9.3 Carry out 2012 bund integrity testing


DEC 2012


- 44 -

SECTION 8.0 NOISE OBJECTIVE 8.6 Carry out modifications to door leading to employee smoking area near the canteen. REASON Noise monitoring report from 2011 indicated that one area was causing an increase in noise levels. The noise was caused by the almost continuous opening and closing of a door that leads to the employee smoking area. Each time it was opened and closed, it was allowed to bang shut. PROJECT METHOD STEP METHOD PERSON


1 Carry out modifications to door leading to employee smoking area


Overall responsibility for objective 8.6 Facilities & Tooling Manager Overall target date for achievement of objective 8. 6 December 2012 Associated Targets Responsibility Date 8.6.1 Carry out modifications to door

leading to employee smoking area



- 45 -

SECTION 9.0 RESOURCE MINIMISATION OBJECTIVE 9.5 Assess efficiency of use of raw materials in all processes. REASON Undertake an assessment of the efficiency of use of raw materials in all processes, having particular regard to the reduction in waste generated. The assessment should take account of best international practice. Shannon Aerospace is currently reviewing all processes (via LEAN methodology) in an effort to reduce raw material usage, costs, waste production etc. PROJECT METHOD STEP METHOD PERSON


1 Evaluate all processes and work activity as per LEAN methodology

LEAN Team OCT 2005 DONE

1 Identify steps in the process which produce a product or service

LEAN Team OCT 2005 DONE

3 Carry out value stream mapping

of different processes LEAN Team OCT 2005

DONE 2 Carry out Rapid Improvement

Events (RIE’s)on different processes

LEAN Team/RIE Team/

DEC 2005 DONE

3 Carry out changes to work practices

LEAN Team/RIE Team/

DEC 2011

4 Reductions in raw material usage, if any, shall be incorporated into the Environmental Management Programme


DEC 2012

Overall responsibility for objective 9.5 Environmental Engineer Overall target date for achievement of objective 9. 5 DEC 2012 Associated Targets Responsibility Date 9.5.1 Carry out Value Stream Mapping

of different processes LEAN team DEC 2005

DONE 9.5.2 Carry out Rapid Improvement

Events (RIE) on process areas LEAN team/RIE teams

FEB 2006 DONE

9.5.3 Carry out changes to work practices

LEAN Team DEC 2011

- 46 -

14.0 SCHEDULE OF ENVIRONMENTAL OBJECTIVES AND TARGE TS TIMEFRAME OBJECTIVE TARGET SUMMARY

05 06 07 08 09 10 11 12 13 14 2.9 2.9.3 PERSON TO BE TRAINED AS AN ENVIRONMENTAL PROCESS

MODELLER

2.9 2.9.4 CARRY OUT MODELLING/MAPPING OF ENVIRONMETNTAL PROCESSES AND PROCEDURES

2.9 2.9.5 LAUNCH ENVIRONMENTAL PROCEDURES AS PART OF IQ MOVE

2.11 2.11.1 REVIEW UPDATED GUIDANCE NOTE ON INCIDENT NOTIFICATION REQUIREMENTS

2.11 2.11.2 ENSURE REQUIREMENTS ARE DOCUMENTED IN ENVIRONMENTAL PROCEDURES

2.11 2.11.3 INCORPORATE INCIDENT NOTIFICATION FORM AS AN ENVIRONMENTAL RECORD

2.12 2.12.1 CARRY OUT ENVIRONMENTAL TRAINING OF NEW MANAGERS 3.12 3.12.3 ASSESS WHETHER ANY OF THE REFRIGERATION GASES CAN

BE REPLACED IN SOME OF THE UNITS

3.12 3.12.4 ENSURE THAT REFRIGERATION CONTRACTORS ARE APPROPRIATELY QUALIFIED

3.13 3.13.1 REIVEW EPA MINIMUM STANDARDS FOR AIR EMISSION MONITORING

3.13 3.13.2 ASSESS CURRENT SAMPLING METHODS 3.13 3.13.3 CARRY OUT CHANGES TO MONITORING PRACTICES IF

REQUIRED

3.13 3.13.4 ENSURE EXTERNAL MONITORING CONSULTANTS ARE COMPETENT TO CARRY OUT AIR MONITORING

4.7 4.7.2 LIAISE WITH COMPANIES WHO MAY HAVE ALTERNATIVES TO WHITE SPIRITS

5.7 5.7.1 REDUCE WASTE GOING TO LANDFILL BY 50% OVER 15 YEARS FROM 1998 FIGURES

7.9 7.9.1 CARRY OUT PIPELINE INTEGRITY TESTING 7.9 7.9.2 CARRY OUT REPAIRS TO DRAIN OUTSIDE BAY 4 7.9 7.9.3 CARRY OUT BUND INTEGRITY TESTING IN 2012 8.6 8.6.1 CARRY OUT MODIFICATIONS TO DOOR LEADING TO

SMOKING SHELTER (CANTEEN EXIT)

9.5 9.5.3 CARRY OUT CHANGES TO WORK PRACTICES

- 47 -

APPENDIX II

SOLVENT

MANAGEMENT PROGRAMME

2010

- 48 -

Solvent Management Plan for

Shannon Aerospace Limited

As required under Condition 6.13.2 of IPPC licence no. P0069-02

February 2010

Prepared by Claire Lynch B.Sc. Env. Sc. PgDip. Dip. EIA Mgmt. Dip. H, S & Welfare at Work

- 49 -

CONTENTS Page

1. SUMMARY 50

2. INTRODUCTION 51 2.1 Introduction 51 2.2 Summary of achievements to date 51

3. COMPLIANCE WITH THE EU SOLVENTS DIRECTIVE 53 3.1 Requirements for Compliance 53 3.2 Recycle and Re-use Opportunities 54 3.3 Demonstration of Compliance for SAL until 2011 55

4. QUANTIFYING REDUCTION IN VOC 57 4.1 Evaluating VOC Reduction 57 4.2 Methodology Used and Approximations Made 57 4.3 Sources of VOC Use and Emission in 2010 58

5. VOC REDUCTIONS ACHIEVED 61 5.1 Observed Reduction in VOC 61 5.2 The Impact of High Solids Painting Systems on VOC 62 5.3 The Impact of Low VOC Stripper 62 5.4 The Impact of High Transfer Efficiency Spray Guns 63 5.5 Future Developments in Paint Manufacture 64

6. FUTURE TARGETS AND OPTIONS, FOR VOC REDUCTION 64 6.1 Calculation of Options for Achieving VOC Reductions by 2011 65 APPENDIX I VOC/SOLIDS RESULTS BIBLIOGRAPHY LIST OF TABLES Table 1 VOC Emitted/Paint Solids used at Shannon Aerospace Table 2 Verification of Compliance, as per Annex III of the Solvents Directive Table 3 Comparison of Current Situation and Best Scenario for 2011 Table 4 VOC Reduction over Time Table 5 Options for Achieving VOC Reductions by 2011 LIST OF FIGURES Figure 1 Sources of VOC Use Figure 2 Aircraft Repainting Process and VOC Use based on all 29 aircraft projects studied Figure 3 VOC Reduction over Time

- 50 -

1. SUMMARY

This document reports on reductions in the use and emission of Volatile Organic Compounds (VOCs) achieved at Shannon Aerospace Limited (SAL) over recent years. Future VOC reduction options are also evaluated. This document can be viewed as a Solvent Management Plan, as required under condition 6.13.2 of IPPC licence P0069-02, the EU Solvents Emissions Directive EU 1999/13/EC (1) and Emissions of Volatile Organic Compounds from Organic Solvents Regulations 2002 (9).

Sources of VOC use were identified based on the study of the materials consumed in aircraft repainting jobs. It was found that approximately 954 Kg of VOC was used for the average aircraft for 1998 – 2010. The actual emission is lower because much VOC is recycled or treated offsite. An accurate value for VOC emission cannot be determined however due to uncertainty surrounding quantities of VOC recycled or treated per project (see Section 3.2 for further details on solvent waste).

The EU solvent emissions directive sets target ratios based on Solvent emitted /Solids used in the aerospace coatings sector. (See Annex IIB). Values for this ratio at SAL are compared with the EU targets in table 1.1. (NB. No values for VOC contained were available so a pessimistic estimate of 200 Kg of VOC contained per project was used – this figure is based on amount of solvent waste produced.)

Table 1 VOC Emitted/Paint Solids Used at SAL

Total VOC Emitted / Paint Solids Used

SAL Pre 1995 (estimated) 4.6

SAL 1998 – 2001 3.4

SAL 2002 2.8

SAL 2003 2.8

SAL 2004 2.7

SAL 2005 2.4

SAL 2006 1.98

SAL 2007 2.79

SAL 2008 2.67

SAL 2009 0.73

SAL 2010 1.03

EU 2005 Target < 3.5

EU 2007 Target < 2.33

These figures show that Shannon Aerospace Limited has implemented significant VOC reductions, is meeting EU 2005 and 2007 targets and is also in compliance with Best Available Technique (BAT) in relation to VOC management. Reductions in VOC use have been achieved through the substitution of high VOC Paint and Paint Strippers with lower VOC alternatives.

- 51 -

The reason for the significant drop in VOC emitted/paint solids for 2009 is due to a change in calculation for solids content – other years should also have lower VOC emitted/paint solids than previously estimated. Future options for reducing VOC emitted/ Solids used by 2010 are evaluated (see section 7 for details).

Three areas are identified as representing the best opportunities for achieving further reductions.

1. The development of new low-VOC products and technologies that satisfy manufacturer’s approvals, Aviation Authority and Customer Requirements.

2. Improving General Work Practices in the Painting Department, including Minimization of, and Improved Management of, Waste Solvent and Paint.

3. Improving the management of stripper waste.

Shannon Aerospace was able to meet the 2007 targets and is in compliance with EU legislation because it is using Best Available Technique (BAT) with regards to VOC management. Shannon Aerospace, Lufthansa Aircraft Painting Shannon and FLS Aerospace have worked in association with Akzo Nobel to produce a BAT guidance note for the Irish aerospace industry.

2. INTRODUCTION

2.1 Introduction

This solvent management plan is prepared in accordance with Condition 6.13.2 of IPPC licence no. P0069-02. The format of this Solvent Management Plan follows the format of the solvent management plans submitted to the EPA on 5/12/2003 as part of a joint Irish Aerospace submission in relation to VOC limits etc.

2.2 Summary of achievements to date

In addition to the advances made to date, this coatings sector is undergoing rapid technological developments. The entire technology of surface preparation and finishes has undergone and will continue to undergo marked changes.

The result has been the displacement of higher hazard materials with lower hazard substitutes. The following details some of the major changes to date.

2.2.1 Strippers

A chemical stripper (Turco 5873 - containing methylene chloride) was used as the main stripper in Shannon Aerospace. In-house restrictions meant that over the past few years this stripper was used in progressively smaller quantities (approx. 10 litres) when for technical reasons alternatives wouldn’t work. This compares with previous practice when such paint strippers were used in quantities of approximately 500litres per paint stripping event.

This stripper has recently been banned in Shannon Aerospace as part of a Lufthansa Group Policy on chlorinated solvents. This means that a further VOC reduction has been achieved.

- 52 -

The main chemical stripper now in use (Turco 6776 LO) is known as an “environmentally advantaged” product as it is less harmful to the environment than previous stripper types. This is a standard paint stripper used in European aircraft paint stripping operations.

Over the past year Shannon Aerospace has been trialling another paint stripper; Cee-Bee E-1004J. This stripper removes the paint faster at the higher temperatures using for paint stripping. This faster removal of paint means that there is a slight decrease in energy consumption.

New strippers were trialled in 2010 which were hydrogen peroxide based.

2.2.2 Paints

Due to current developments in paint high solids paints are now being used in greater frequency in Shannon Aerospace. High solids paints are now used as the default paints, unless the customer specifies a particular paint type, in Shannon Aerospace.

- 53 -

3. COMPLIANCE WITH THE EU SOLVENTS DIRECTIVE

3.1 Requirements for Compliance

The EU Solvent directive (1999/13/EC) responds to concerns surrounding the emission of VOC to the environment particularly the production of ground level photochemical pollution which can be harmful to public health and to vegetation when concentrations are high enough. (This might indeed be a relevant concern in the vicinity of Shannon airport considering the photochemical pollution from aircraft taking off and landing, and the operations of Shannon Aerospace and others).

Shannon Aerospace carried out an Air Dispersion Modelling Study in 2002 (11) to assess VOC emissions from the two paint stacks. The aim of this study was to assess maximum ground level concentrations (GLC) under different emission concentration scenarios from the stacks. The GLCs were compared with derived ambient air quality guidelines to assess the significance of each emission scenario in comparison to environmental quality objectives. The modelling study was carried out using the United States Environmental Protection Agency approved ISC3 model. The ISC3 model was selected for this project for it suitability in modelling all types of releases and the model has had widespread regulatory application throughout Europe. The study indicated that ground level concentrations of VOC were within applied environmental assessment levels (based on occupational exposure limits and German TA Luft “S” values for Class I, II and III VOCs for use in stack height determinations).

The directive gives three possibilities for an operator to achieve compliance:

3.1.1 Compliance with Emission Limit Values

The directive states that compliance with emission limit values is not the primary method of achieving VOC reduction with regards to the painting of aircraft, See Annex IIA, and article 5(3)(b).

As will be seen from the initial process description the majority of the solvent lost in stripping and painting is total loss, hence the exemption from containment. Therefore it is not clear on what percentage the reference fugitive emission should be based. Referring to Annex IIA of the Solvents Directive the reference to 20% fugitive emissions is equally covered by the exemption under footnote 4 and is not applicable in a like manner to the emission limit values. Therefore the basis of our calculations is that all solvent used in the stripping and painting process is 100% loss. Notwithstanding that fact, the industry does employ as part of a BAT approach the following general housekeeping measures to reduce other fugitive/incidental emissions:

• Close containers after use

• Use of lidded bins for wipe rags

• Only mix correct amount of paint and mix immediately prior to use

• Enclosed gun cleaning where ever practical

• Barrel stripper waste as soon as reasonably practicable after stripping has taken place.

- 54 -

3.1.2 Compliance with Reduction Scheme Targets

The directive sets target ratios of solvents emitted/ solids used in a process. For aerospace coatings this target is set as 2.33 for 2007, with a target of 3.5 to be achieved by 2005. (These targets are given in the Reduction Scheme of Annex IIB. The table at the end of the annex gives the value of 2.33 while the other table gives the 2005 value of Target emission * 1.5.) The directive requires that a Solvent Management Plan be drawn up by the operator in order to verify compliance, identify future reduction options, and in order to communicate information on VOC use to the national authorities and to the public.

Previously, when estimating VOC content and solids content of paints – if no information was given on solids content then solids content was taken as being zero. However, after researching further most VOC calculations assume that after VOC content is excluded, the remainder can be assumed to be the solids content (unless further information is supplied). Hence the calculations for 2009 have been updated to reflect this change and this is the reason for the decrease in the VOC emitted/paint solids used. This means that the other years will have lower VOC emitted/paint solids used values than previously estimated.

3.1.3 Compliance with Best Available Technique

In the case where it is not technically or economically feasible to achieve compliance with the reduction scheme targets, the directive then states that the operator must demonstrate to the satisfaction of the national authorities that ‘Best Available Technique’ with regard to VOC use has been implemented. However no standard has yet been referenced for BAT in the Aerospace sector.

Shannon Aerospace, Lufthansa Technik Painting Shannon and FLS Aerospace have worked together with Akzo Nobel to produce an Irish BAT Note. This BAT Note describes best available techniques in relation to cleaning of tools and equipment, paint types etc. (2).

In Germany, the French-German Institute of Environmental Research worked on the German contribution to a BREF about paint and adhesive application. In their report the following are the recommended Best Available Techniques for painting aircraft (4):

• Paint removal via a mixture of benzyl alcohol and formic acid

• Application of chrome-free ground coats

• Application of high-solids topcoats without an additional clear coat layer

• Electrostatic spray application for most paint materials.

3.2 Recycle and Re-use Opportunities

There are limited opportunities for recycling as the industry is highly regulated and all chemicals used in an aircraft environment are specified by the airframe manufacturers. Due to potential contamination and damage to aircraft structures and systems, solvent cannot be recycled for use on the aircraft.

However, there are the following opportunities for re-use:

• Gun cleaning – a small percentage can be re-used for gun cleaning purposes

• The vast majority of waste solvent is currently sent off-site to licensed waste contractors for re-use.

- 55 -

All solvent waste produced in Shannon Aerospace is sent off-site to a licensed waste contractor for recycling and recovery. The volume of solvent waste produced each year varies depending on numbers of aircraft processed, size and type of aircraft etc.

On average, 13,000 litres of solvent waste is recycled every year in SAL (10,810litres in 2010). This means that approximately 530 litres of solvent waste is not emitted to air/aircraft.

Estimating the waste to have an average VOC content of 700g/l, gives a figure of 358kg VOC recycled per aircraft. An accurate value for VOC emission cannot be determined however due to uncertainty surrounding quantities of VOC recycled or treated per project. Also, the VOC value for each project will depend on types of paint used etc. In order to account for this variability a pessimistic value of 200 kg VOC contained is used, which would be the worst-case scenario in relation to VOC contained.

3.3 Demonstration of Compliance for SAL until 2010

Table 2 displays the results of the 189 painting projects studied in 2002 - 2009. The categories ‘O1’, ‘I1’ etc. are those given in Annex III of the Directive. A worst possible scenario where only 200Kg of VOC is contained (recycled or incinerated offsite) per project and the rest is emitted as ‘waste gas emissions’ has been assumed. This means that the value for VOC emitted/ Solids used is in all likelihood lower than what is shown below.

A best possible scenario for 2011 is also given.

Shannon Aerospace is still in compliance with EU legislation because it is using Best Available Technique (BAT) with regards to VOC management. Shannon Aerospace, Lufthansa Aircraft Painting Shannon and FLS Aerospace have worked in association with Akzo Nobel to produce a BAT guidance note for the Irish aerospace industry.

Refer to Appendix II for more detailed mass balances of aircraft repainting in 2010.

Table 2 Verification of Compliance, as per Annex III of the Directive

2002 2003 2004 2005 2006 2007 2008 2009 2010 Best Scenario

for 2010

E/Solids for SAL 2.8 2.8 2.7 2.4 1.98 2.79 2.67 0.74 1.03 0.74

E/Solids Target for the Aerospace Coatings

sector (As per Annex Iib)

3.5

(2005 Target)

3.5

(2005 Target)

3.5

(2005 target)

3.5

(2005 target)

2.33

(2007 target)

2.33

(2007 target)

N/A N/A N/A N/A

- 56 -

Table 3 Comparison of Current Situation (based on 2010 figures) and Best Scenario for 2011

Values as defined in Annex III

Current Situation

Best Scenario for 2010

Kg % of Total Kg % of Total

E = O1 + O2 + O3 + O4 + O9 731 78 731 78

Solids 703 - 703 -

I1 (total use) 931 - 931 -

I2 (internally reused/recycled) Negligible opportunities (see section 3.1)

Negligible opportunities (see section 3.1)

O1(waste gas emissions) 731 78 731 78

O2 (lost to water) Assumed to be negligible Assumed to be negligible

O3 (product residue) 0 0 0 0

O4 (fug

annual environmental report 2010 shannon aerospace limited ippc licence … · 2014. 12. 16. ·...

Documents