Environmental Protection Agency, P.O. Box 3000, Johnstown Castle Estate, Co. Wexford.

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1 (I , I , , < C H R I S K A Y

Farm Lane, Kinsale

County Cork

I re land

Telephone: +353 (0) 21 4772050 Fax: +353 (0) 21 4772900

Em ai I: world sa les Q c h ris ka y. ie

ISDN: +353 (0) 21 4702100 www.chriskay.com

04th July 2008

REF: IPPC Licence Application

Dear Sir/Madam,

Please find enclosed our Integrated Pollution Control Licence Application Form and licence application fee of €8,888.

The company is in the process of moving manufacturing equipment Gom the UK to Kinsale and will shortly be placing an order for a Regenerative Thermal Oxidiser for installation on-site to treat process emissions. It is planned that equipment installation and commissioning will take place this Summer and Autumn. We plan to be in a position to be fully operational with the new Polyurethane Heat Transfer printing lines by the end of the current year. We acknowledge that a 10 tonnes per annum solvent consumption threshold for IPPC applies to activities on-site. We will not exceed this solvent consumption threshold by commissioning and testing the soon-to-be installed new process lines.

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We would be extremely gratefiul if you could ensure that this application is given your urgent consideration.

Yours Sincerely, - d- ‘3

Celine Cremin Quality and Environmental, Health & Safety Manager

D i r e c t o r s : G. H u d s o n ( U K ) , C . O ’Her l ihy . G . U d a l 1 ( U K )

R e g i s t e r e d C o m p a n y N a m e ; I T W I r e l a n d R e g i s t e r e d O f f i c e ; 2 5 / 2 8 N o r t h W a l l Q u a y

D u b l i n 2 , I r e l a n d R e g i s t e r e d C o m p a n y N u m b e r 5 8 1 5 6

V A T R e g i s t e r e d N u m b e r 9 2 6 8 6 6 2 6

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EPA Export 26-07-2013:01:00:43

Integrated Pollution Prevention and? Control

(IPPC) Licensing

Application Form

Environmental Protection Agency P.O. Box 3000, Johnstown Castle Estate, Co. Wexford

Web: www.epa.ie Email: info@epa.ie Lo Call: 1890 335599 Telephone: 053-9160600 Fax: 053-9160699

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IPK Appkation Fbnn Vl/07

CONTENTS

ABOUT THIS APPLICATION FORM ................................................................... 3

SECTION A: NON-TECHNICAL SUMMARY ..................................................... 4

SECTION B: GENERAL ........................................................................................ 14

SECTION C: MANAGEMENT OF THE INSTALLATION .............................. 18

SECTION D: INFRASTRUCTZJRE & OPERATION ......................................... 18

SECTION E: EMISSIONS ...................................................................................... 19

SECTION F: CONTROL & MONITORING ....................................................... 22

SECTION G: RESOURCE USE, AND ENERGY EFFICIENCY ....................... 23

SECTION H: MATERIALS HANDLING ............................................................ 24

SECTION I: EXISTING ENVIFIONMENT & IMPACT OF THE ACTIVITY26 SECTION J: ACCIDENT PREVENTION & EMERGENCY RESPONSE ...... 30

SECTION K: REMEDIATION. ]DECOMMISSIONING. RESTORATION & AFTERCARE ........................................................................................................... 30

SECTION L: STATUTORY REQUIREMENTS ................................................. 31

SECTION M: DECLARATION ............................................................................. 34

ANNEX 1 : TABLES/ATTACHMENTS ............................................................... 35 ANNEX 2: CHECKLIST FOR ARTICLE 10 COMPLIANCE ............................. 93

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IPPC Application Fbrm W O 7

ABOUT THIS APPLICATION FORM

This form is for the purpose of malting an application for an Integrated Pollution Prevention and Control (IPPC) Licence under the Environmental Protection Agency Acts, 1992 and 2003. There are separate application forms for Licencees who wish to apply for a review of existing licences and for Pig & Poultry sector applicants.

The Application Form must be completed in accordance with the instructions provided in the IPPC Licensing Application Guiddnce Note, The Guidance Note gives an overview of IPPC Licensing, outlines the licence application process (including number of copies required) and specifies the information to be submitted in the application. The Guidance Note and application fornis are available to download from the IPPC Licensing pages of the EPA's website at www.epa.ie. A valid application for an IPPC licence must contain the information prescribed in the Environmental Protection Agency (Licensing) Regulations, 1994 to 2004. Article 10 of the Regulations sets out the statutory requirements for information to accompany a licence application. The

- application form is designed in such a way as to set out these questions in a structured manner and not necessarily in the order presented in Article 10. I n order to ensure a legally valid application in respect of Article 10 requirements, please complete the Article 10 Checklist provided in Annex 2.

This Application Form does not purport to be and should not be considered a legal interpretation of the provisions and requirements of the Environmental Protection Agency Acts, 1992 and 2003 and the Environmental Protection Agency (Licensing) Regulations 1994 to 2004. While eveiy effort has been made to ensure the accuracy of the material contained in the Application Form, the EPA assumes no responsibility and gives no guarantees, undertakings and warranties concerning the accuracy, completeness or up-to-date nature of the information provided herein and does not accept any liability whatsoever arising from any errors or omissions.

Should there be any contradiction between the information requirements set out in the Application Form and any clarifying explanation contained in the accompanying Guidance Note, then the requirements in this Application Form shall take precedence.

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IPPC Application Fbnn Vl/07

I, 1. NICAL iSU,MMARY'

A non-technical summary of the application is to be included here. The summary should identify all environmental impacts of significance associated with the carrying on of the activity/activities, and describe mitigation measures proposed or existing to address these impacts. This description should also indicate the normal operating hours and days per week of the activity.

The following information must be included in the non-technical summary:

A description of:

- the installation and its activities, - the raw and auxiliary materials, other substances and the energy used in or

generated by the i nsta I la t ion, - the sources of emissions from the installation, - the environmental conditions of the site of the installation (e.g. soil and

groundwater, air, noise, surface water), - the nature and quantities of foreseeable emissions from the installation into each

medium as well as identification of significant effects of the emissions on the environment,

- the proposed technology and other techniques for preventing or, where this is not possible, reducing emissions from the installation,

- where necessary, measures for the prevention and recovery of waste generated by the installation,

- further measures planned to comply with the general principles of the basic obligations of the operator i.e.

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(a) all the appropriate preventive measures are taken against pollution, in particular through application of the Best Available Techniques (BAT);

(b) no significant pollution is caused; (c) waste production is avoided in accordance with Council Directive 75/442/EEC

of 15 July 1975 on waste; where waste is produced, it is recovered or, where that is technically and economically impossible, it is disposed of while avoiding or reducing any impact on the (environment;

(d) energy and other resources are used efficiently; (e) the necessary measures are taken to prevent accidents and limit their

consequences; (f) the necessary measures are taken upon definitive cessation of activities to

avoided any pollution risk and return the site of operation to a satisfactory state.

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- measures planned to monitor emissions into the environment.

Non Executive Summary

Introduction Chris Kay a division of ITW Ireland manufactures heat applied and high frequency welded graphic transfers at its facility in Kinsale, Co. Cork. The Company's main customers are Adidas, Nike, Puma, Reebok, Canterbury, Umbro and Fruit of the Loom. Up until now all heat transfer and high frequency welded graphics have been manufactured using water based technologies. These badges are a direct replacement for trad,itional embroidery badges found in all clothing and offer customer a variety of benefits, including price, time saving and technological advantages. These products have the Textile Safety Mark, Oeko- Tex Cert No 2569, Class I. The b,adges can be found mostly on sports wear, for

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IPPC Applwtion Form V1/07

example the Irish Football and Rugby Teams, European and International Football Teams, Premiership Football Teams and both player, replica and training gear clothing. The plant is introducing a new product line, Polyurethane Heat Transfers which currently involves the use of solvent based inks and adhesives in the manufacturing process. Polyurethane Heat Transfer are used in sports wear as detailed above and can be most often found on Football Shirts as numbers, letters and name blocks. Solvent based raw materials consumption is likely to exceed the IPPC threshold of 10 tonnes per annum, therefore the Company is applying to the EPA for an IPPC licence. The Company is actively looking at material substitution for solvent based PU Heat Transfer systems. Water based inks and adhesives manufacturers are carrying out trials on the Company's behalf Chris Kay a Division of ITW Ireland Limited operates from a manufacturing facility based in Kinsale, Co. Cork, Ireland. It is a wholly owned subsidiary of ITW Inc (Illinois Tool Works Inc., 3600 West Lake Avenue, Glenview Illinois, 60026- 121 5 USA). Illinois Tool Works is a diversified manufacturer of engineered products and specialty systems. ITW is a global industrial company that operates 825 Businesses located in 52 coiintries spanning the globe. ITW Inc. develop thousands of engineered products and specialty systems that are created and later improved in direct partnership with customers. These Business units serve diverse end markets and customer segments. A multibillion dollar company with nearly 100 years of history, ITW today designs and manufactures fasteners and components, equipment and consumable systems and a variety of specialty products and equipment for customers around the world. The company's more than 825 Businesses are small, decentralized and focused on their customers. By actively practicing team work with customers and suppliers, the men and women of ITW are creating competitively superior products, solutions and work environments. It has over 62,000 employees worldwide and an annual Revenue of $1 7 Billion USD. ITW is involved in a broad section of industries including:

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o Industrial Packaging o Power & System Electronics o Transportation o Construction Products o Food Equipment o Decorative Surfaces o Polymers and Fluids o Other Business including o Plastic consumables

o Equipment and related software for testing of materials and structures o Foil and film and related equipment used to decorate consumer products o Paint spray equipment o Graphics

1 o Plastic and metal fasteners

ITW Graphics has the professionals, the skills and the expertise to quickly supply high volume transfer images for ,industrial application to flexible and rigid substrates for every kind of prod,uct anywhere in the world. The main applications for ITW Graphics are Industrial Branding, Apparel Branding and Sports Licensed Branding.

Chris Kay Ltd was established in 1982. The Company's products are now accepted as a benchmark in many sectors. The Company became part of ITW Inc in November 2004. Our patented' formulations and processes together with our Licensed processes offer our customers maximum choice and the highest quality standards at competitive prices. The Company relocated its manufacturing operation to Farm Lane, Kinsale in 1998.

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IPPC Application firm V1/07

Site Location and Condition Chris Kay a Division of ITW Ireland is located approximately 1 Km north of the town of Kinsale, South of Cork City. The facility was constructed in 1997 on a green field site which was previously used for agriculture and manufacturing operations have increased signifiicantly in the intervening years. Over 95% of our total production is exported to over 60 countries from our factory in Ireland.

The long-standing relationship we enjoy with our marketing partners ensures that the latest developments and improvements in all our product ranges can be made available to our customer bases effectively and rapidly, staying up to date with changing trends and innova tion techniques. Products supplied to customers are:

o Lextra Transfers - Plush Feel - high density velour with a tactile feel Badge

o Lextra 30 Plush Feel - hi!gh density velour with a stunning tactile 30 effect heat applied Badge

o Artflock Felt Feel - with a wide variety of printable colours available in this heat applied Badge

o Softweld Felt Feel - with a wide variety of printable colours available in this high frequency weldable Badge

o Lextra Transfers - Plush Feel - high density velour with a tactile feel in this high frequency weldable Badge

o Satin - Material used in Lextra 30 badges to give its 30 effect o Polyurethane - flat transter with a wide variety of printable colours and

applications heat applied Badge

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Chris Kay is currently in the process of expanding the existing operations to facilitate centralisation of the European heat transfer manufacturing operations. The following changes to the plant will be required in order to facilitate this expansion: Separation of the existing shop fbor area into Polyurethane Manufacturing Unit and Non Polyurethane Manufacturing Units. Provision of a new Polyurethane Plant Equipment and Utilities Bunded & Refrigerated warehouse to house Polyurethane Raw Materials. Air Handling Unit for building air exchange. Regenerative Thermal Oxidiser Unit and associated Stack @

! Installation and its activities Chris Kay a division of ITW Ireland manufactures heat applied and high frequency welded graphic transfirs at its facility in Kinsale, Co. Cork. The Company’s QMS is registered to IS09001 : 2000 registration number GB02/55550, there is no exclusion clauses to the standard “Design, Development and Manufacture of heat applied transfers and graphics for the textile industry”.

Occupancy and hours of opefiation The installation consists of the four manufacturing Business units, (Lextra, Satin, Ink & Glue and Polyurethane) which houses the manufacturing and packaging operations. The plant employees approximately 93 people. In general the site operates 5 days a week 24 hours a day, however like many industries due to market demands, for a few weeks every year the Company operates 7 days a week 24 hours a day. There are 2 separate shift patterns in the manufacturing operations. In the general work week production follows the following pattern:

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IPK Appliwtion Form V1/07

Monday Tuesday

15:OO 1 5: 00

23:OO 23:OO

07:OO 07: 00

Morning 07:OO - 07:OO -

Afternoon 15:OO - 15:OO -

Night 23:OO - 23:OC’ -

Shift Patterns

Wednesday Thursday Friday 07:OO - 07:OO - 07:OO - 15: 00 15:OO 14:OO 15:OO - 15:OO - 14:OO - 23: 00 23: 00 21 :oo 23:OO - 23:OO - 21 :OO - 07: 00 07: 00 04:OO

Wednesday 8:30 - 17:OO

12 Hour Shift Pattern:

Thursday Friday

17:OO 16:30 8:30 - 8:30 -

Screen Makinq Blending

Flocking

Inspection

Cycle 1 Cycle 2 5 x 8 hours 5 days a shift week 3 x 12 hours 3 days a 3 x 12 hours 3.5 days a shift week shift week 3 x 12 hours 3 days a 3 x 12 hours 3.5 days a shift week shift week 3 x 12 hours 3 days a 3 x 12 hours 3.5 days a shift week shift week

Satin Business Unit: P I

Application

Inspection

Packaging

Cutting 5 x 8 hours 5 days a I shift I week I 5 x 8 hours 5 days a

week

Day workers week

Day workers week: I shift 5 x 8 hours 5 days a

5 x 8 hours 5 days a

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. .

IPPC Applation Forin W O 7

Ink Blen dinq Glue Blendinq Printing

Inspection

Cutting

Packaging

Ink & Glue Printing Business Unit: I I

5 x 8 hours 5 Day workers 5 x 8 hours 5 Day workers 5 x 8 hours

Day workers 5 x 8 hours Day workers

Day workers

shift 5 x 8 hours

5 x 8 hours 5 days a

Ink 1 5 x 8 hours I 5 d a r I Day workers 5 x 8 hours

Blendinq Glue

5 x 8 hours

5 x 8 hours

5 x 8 hours 5 days a

Blending shift Ink Printing shift Ink Inspection Day workers Glue Printing shift Sintering 5 x 8 hours

shift week

I Day workers I week I Ink & Glue Printing Business Unit: Manufacturing operations consist of Screen Making, Blending, Ink Printing, Ink Inspection, Glue Printing, Sintering, Inspection, Cutting and Packaging, all liquid phase operations are waterbased.

Polyurethane Business Unit: I

Ink & Glue Printing Business Unil: Manufacturing operations will consist of Screen Making, Blending, Printimg, Inspection, Cutting and Packaging, all liquid phase operations are solvent based. A Regenerative Thermal Oxidiser will be installed to meet requirements of solvent directive and an Air Handling Unit will also be installed.

Environmental Emissions

Lextra Business Unit: There are no significant air or waste water emissions from this Business Unit. There are minor dust emissions trom this area (textile dust).

Ink and Glue Print Business Unit:

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IPK Applwtion Form V1/07

Waste Water from this business (unit is treated in the Waste Water Treatment Plant, in accordance with the Licence to discharge Trade Effluent Licence Ref W. P. (S) 06/97. Effluence discharges are detailed in table E.3 of the application. Exhausts from the Stat Ovens will be treated by the Regenerative Thermal Oxidiser.

Satin Business Unit: There are no air or waste water emissions from this Business Unit.

Polyurethane Business Unit: Solvent, Ink and Adhesive Waste is taken away for treatment by a Licensed Hazardous Waste Contractor. Solvent emissions exhausts from Polyurethane Printing Dryers will be treated by the Regenerative Thermal Oxidiser. Environmental considerations have been taken into account at the design stage of the Polyurethane Business Unit to ensure process wastes are minimised. Emissions from the RTO will meet ELVs in accordance with the Solvent Directive. Non hazardous wastes from all process are segregated for disposal / recycling through authorised waste contractors only. Hazardous wastes from the processes are segregated and incinerated / recovered via licensed facilities. The Company is actively looking at material substitution for solvent based systems. Water based inks and adhesives manufacturers are carrying out trials on the Company’s behalf.

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Raw Materials / Auxiliary Materials / Energy Raw Materials used in the process consist primarily of Waterbased Inks, Waterbased Adhesives, Flock Fibres and Satin. The expansion of the manufacturing unit will introduce solvents, solvent based polyurethane inks and adhesives into the facility. All solvents and solvent based inks and adhesives are stored in a bunded warehouse. A full list of all raw materials, intermediates, used and stored on site are detailed in tables Gl(i) and Gl(ii).

The Company‘s electricity requirements are provided through the national grid. The RTO and sintering oven uses Bulk propane as a fuel. The expansion to include the Polyurethane Business Unit requires the installation of a 6kV substation. The Company continuously review energy and resources consumption on site.

Emissions Prevention / Abatement Technologies In accordance with the requirements of BAT Chris Kay a division of ITW Ireland ensure that pollution preventativle measure are taken and that suitable abatement technologies are implemented to reduce the impact on the environment. All technologies on site to date have been water based and therefore no atmospheric emissions abatement treatment was required. However with the installation of the Polyurethane Business Unit this requires the installation of a Regenerative Thermal Oxidiser and associated stack, to meet with Emission Limit Values. Process wastewater is treated in the onsite wastewater treatment plant which consists of pH correction. Final etfluent discharges to the Kinsale Sewer. The WWTP operates 24 hours/7 days. Waste from the Polyurethane Business unit is not treated on site. Full descriptions of these technologies are included in Attachment F.

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i

.~~~ _. . _ .~ . ____.__ .__... .____

IPPCAppkition Form W O 7

Nature and Quality of Foreseeab!e Emissions Air The expansion to manufacturing activities requires the installation of a Regenerative Thermal Oxidiser and associated stack. This will have a throughput of 10,000 m3/hr. Air Dispersion Modelling has bee undertaken to determine the impact on air quality of this emission. This has shown there will be no significant impact. The report is included in Attachment 1.1 Minor and potential atmospheric emission points have been identified and are listed in section E.l of the application form.

Water Process wastewater is treated in the onsite wastewater treatment plant which consists of pH balancing. Final eisfluent discharges to the Kinsale Sewer. The WWTP operates 24 hours/7 days. Current throughput of this system is 15 m3/da y, approx. This will increase to 60 m3/da y due to the expansion (normal throughput is estimated at 45 m3/day). The WWTP is operated in accordance with the requirements of Cork County Council Licence to discharge Trade Effluent Licence Ref W.P. (S) 06/97. Waste Sludge from the treatment plant is collected by a Licensed contractor and disposed of appropriately. The precautionary principle has been applied and this sludge is treated as hazardous At present the volume of surface waster discharged will increase slightly with the additional roof surface to the Burided warehouse. Surface water collection will not need to be upgraded and sutface water emissions are monitored in accordance with Cork County Council Licence W. P. (S) 06/97.

Gormley Announces Progress on the €20m Wastewater Collection System in Kinsale 18/12/07

Mr John Gormley, TD, Minister far the Environment, Heritage and Local Government, announced today (18 December 2007) that he has approved funding to allow Cork County Council to accept the tender of €6.8 million from Sorensen Civil Engineering Ltd to upgrade the waste water collection system in Kinsale, under the Kinsale Sewerage Scheme. The Kinsale scheme is being funded under his Department's Water Services Investment Programme 2007 - 2009 at an overall estimated cost of €20 million.

The Minister's decision to provide the necessary funding reflects the Government's commitment to the continuing investment in the country's wastewater schemes to ensure that discharges into rivers, lakes and coastal water meet the highest international standards.

"I am well aware of the importance of this scheme locally," the Minister said. He pointed out that "The contract to upgrade the collection system in Kinsale is a major step in providing the town with modern sewerage infrastructure. A new wastewater treatment plant at Cammoge, which will be built under a separate contract, will address the environmental problem of untreated sewage currently being discharged to Kinsale Harbour. When completed, the Kinsale Sewerage Scheme will meet the current dernand for wastewater services and cater for future residential and commercial development in the town for years to come."

Given the importance of the Kinsale Sewerage Scheme to the town, the Minister urged the Council to complete the contract formalities with the successful tenderer as quickly as possible so that work on upgrading the collection system can start at the earliest possible date.

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IPPC Appliwtion Fotm W O 7

Source: httD://www. en viron. ie/en/Environment/CVater/WaterSen/ices/News/MainBodv. 1631 7,en. htm

Cork County Council's Water Services Design Team are currently progressing the following schemes: Schemes Est. cost.

Kinsale Sewerage Scheme €1 9,600,000 Kinsale Water Supply -Commoge € 88,400 httD://ww w. corkcoco.ie/co/web/Cork%2c)Countv~02OCounci~De~artments/Divisional~02OSen/ices/W ater?h20Services/Ne wV020Schemes

Noise Regular noise monitoring is carried out and modifications to plant and equipment have been planned to ensure that noise will be within the required limits. It is anticipated that the addition of the Polyurethane Business Unit will not contribute significantly to noise emissions and it is expected that existing limits will be met. Design review of the Regenerative Thermal Oxidiser and the Air Handling Unit include noise emission assessment to ensure compliance with limits. A noise report, which was carried out before the planned expansion was carried out, is

Polyurethane Business Unit is installed. 1 included in Attachment I. 7 and another noise study will be carried out once the

: I I

Waste Solid Waste (hazardous and non hazardous) is disposed or recycled by Licensed waste contractors. A full record of all waste take off site will be maintained. The volume of hazardous and non hazardous waste will increase given the expansion to the manufacturing activities. Details of anticipated volumes of waste is included in table H.1

Accident Prevention The Emergency Response Plan which is contained in Attachment J contains information on the measures in operation to reduce the impact of an accidental emission or spillage. The Emergency Response Plan also includes the provisions for response to accidental emissions and emergency situations which arise outside of normal working hours i.e. night-time, weekends and holidays.

Cessation of Activities The Company have considered requirements for decommissioning and decontamination of all process related structures. This is outlined in the companies Residuals Management Plan which is included in attachment K. ITW is a global industrial company that operates 825 Businesses located in 52 countries spanning the globe and with an alnnual Revenue of $1 7 Billion USD and Cash Reserves of $2 Billion USD. The Corporation would be able to meet any decommissioning costs in the event of cessation of activities.

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Measures planned to comply with principles of the basic obligations of the Opera tor The measures proposed or already in place to ensure that

a) The best available techniques are or will be used to prevent or eliminate or where that is not practicable generally reduce an emission from the activity. A Regenerative Thermal Oxidiser will be used to minimise atmospheric emissions of volatile organic compounds. Screen cleaning is

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IPPC Application Form W O 7

optimised in terms of water volume and temperature. The use of detergents is avoided in water going to the WWTP plant. There is an active programme in Raw Material waste reduction through use of 80:20 tools. Substitution of solvent based (Polyurethane) process with water based processes is currently under investigation by ink suppliers, adhesive suppliers and IlW Graphics Research Facility (UK/China). No significant pollution is caused. A Waste Water Treatment Plant has operated effectively on-site since 1997. A Regenerative Thermal Oxidiser will be used to minimise atmospheric emissions. Waste production is avoided in accordance with Council Directive 75/442/EEC of 15 July 1975 on waste; where waste is produced, it is recovered or, where that is technically and economically impossible, it is disposed of while avoiding or reducing any impact on the environment. There is an active prograinme in Raw Material waste reduction utilising good manufacturing practice and including lean manufacturing techniques. Energy is used efficiently. The RTO was partly chosen because of it's low energy consumption requirements. The necessary measures (are taken to prevent accidents and limit their consequences. Hazards and associated risks have been identified in the safety statement and where practical hazards have been engineered out of the process. There is a high level of operator awareness safety and of safety training forms part of all training carried out in the company. The necessary measures (are taken upon definitive cessation of activities to avoided any pollution risk and return the site of operation to a satisfactory state; are as follows:

One controlled emission point will be in place. This Regenerative Thermal Oxidiser is one of the techniques mentioned for consideration in the determination of BAT'.

0 Modelling of air emissions using worst case scenarios indicated no significant impact in terms of guide values, limit values and odour thresholds. The modelled results indicated that worst-case maximum emissions from the RTO stack during normal operation are within the relevant guideline values for Vt3C (as cyclohexanone), CO and NOx and are therefore, are not likely to have any significant environmental impact. Predicted emissions during a bypass have been modelled and are not likely to result in a significant environmental impact. All process waste water undergoes treatment which includes pH correction / neutralisation BAT^). Apart from recycling of certain materials, non hazardous wastes are sent for engineered landfill, while hazardous wastes are sent for overseas incineration with heat recovery where possible. A Bunded warehouse r's planned for Polyurethane Business Unit Raw Materials.

0

0

Section 20.22.4.3. Reference Document of Best Available Techniques for Surface Treatment using Organic Solvents (September 2005) and Section 20.11.4.3 page 488, Reference Document on Best Available Techniques for Surface Treatment using Organic Solvents (September 2005). Section 4.3.1 page 281 and page 288, Reference Document on Best Available

Techniques in common Waste Water and Waste Gas Treatment / Management Systems in the Chemical Sector (February 2003) ; and section 20.12.5 page 507, Reference Document on best Available Techniques for Surface Treatment using Organic Solvent (September 2005).

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IPPC Applwtion Fom V1/07

Monitoring The Company has a programme in place to ensure that all emissions are monitored in accordance with requirements. Details of monitoring points and methodologies are included in section F.2 and associated attachments.

Supporting information should form Attachment NP A . l Copy of Oeko-Tex Certificate is includead in Attachment A. 1

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IPK Application Form W O 7

r

1

I ' I I 1 1 ' I I ' SECl'IONrB: GENERAL

Address: Illinois Tool Works Inc., 3600 West Lake Avenue, Glenview, Illinois 6002tj-1215 U. S. A.

Tel: 001 847657 4843 Fax: 001 847 657 7892 e-mail: As above

5.1. Owner/Operator

Name*: Address: Farm Lane,

Chris Kay a Division of ITW Ireland

I Kinsale, Co. Cork

Tel: 02 1 4 772 050 Fax: 021 4772900 e- ma i I: env@chriskav. ie

* This should be the name of the applicant which is current on the date this IPPC Licence Application is lodged with the Agency. It should be the name of the legal entity (which can be a limited company or a sole trader). A trading/business name is not acceptable.

Name and Address for Correspondence Only application documentation submitted by the applicant and by the nominated person will be deemed to have come from the applicant. '@ Name: Address: Farm Lane.

Chris Kay a Division of ITW Ireland

Kinsale, Co. Cork

Tel: 02 1 4 772 050 Fax: 021 4772900 e-ma i I: envachriskav. ie

I f the applicant is a body corporate, the following information must be attached as Attachment B l :

a) a Certified Copy of the Certificate of Incorporation. Reference Attachment B.l b) the Company's Registration Number from the Companies Registry Office. Reference

Attachment B. 1 c) Particulars of Registered Office of the Company. Registered Company Name: ITW Ireland Registered Office: 25/28 North Wall Qua y, Dublin 2, Ireland Registered Company Number 581 56 Note Attachment 8.1 Chris Kay a Division of ITW Ireland was originally know as Chris Kay Ltd. In 2004 the U S . Corporation ITW purchased the Company and its assets. ITW changed the name of the Company from Chris Kay Ltd to Chris ,Kay a Division of ITW Ireland. ITW has several companies registered in Ireland, the first ITW Company set up in Ireland, was ITW Hi-Cone in Mallow.

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ZPPC Application Fbrm Vl/07

National Grid Rkference I (12 diqit 6E,6N)

Name and address of the proprietor(s) of the Land on which the Activity is situated (if different from applicaint named above):

E l 6431 2, NO51 21 7

Proprietor's Name: Address: Farm Lane,

Chris Kay a Division of ITW Ireland

Kinsale, Co. Cork

e-mail:

Name and address of the owner(s) of the building and ancillary plant in which the activity is situated ( if different from applicant named above):

Tel: Fax: e-mail:

B.2. Location of Activity

of ITW Ireland

Contact Name: Peter Gleeson Ms Celine Cremin General Manager Quality Manager adminenv@chriska y. ie

* Include any townland.

Location maps (IA3), appropriately scaled, with legible grid references should be enclosed in Attachment 8.2. The site boundary must be outlined on the map in colour.

Geo-referenced digital drawing files (e.g. AutoCAD files) in Irish Grid projection of the site boundary and overall site plan, including labelled emission, monitoring and sampling points, are also required. This data should be provided to the Agency on a separate CD- Rom containing sections 8.2, E.6 and F.3.

Ordinance Survey Map of Plant Master; 27;?94-62-002 Site Plan Showing Boundary

Site Services Plan Master;

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IPPC Appkation Form W O 7

Schedule Schedule 1

I digital drawing files I I

Class DescriptionNote 12.2.2 The manufacture or use of coating materials in

6.3. Class of Activity

Identify the relevant activities in the IFirst, Third or Fourth Schedule of the PoE Act 2004 to which the activity relates:

has been obtained is not yet applied for

is being processed is not required 4

processes with a capacity to make or use at least 10 tonnes per year of organic solvents, not included in aragraph 12.2.1.

Note 1: I n order to give a precisie identification select onlv those words from the description of the class or classes that best describes the nature of the activity for which the licence is being applied for.

6.4. Employees/ Capital Cost

Give-

(i) I n the case of an established activity, the number of employees and other persons working or engaged in connection with the activity on the date after which a licence is required and during normal levels of operation, or

(ii) I n any other case, the gross capital cost of the activity to which the application relates.

Number of Employees (existing facilities): I 93 Not applicable. Moving existing plant from UK.

8.5. Relevant Planning Authority

Give the name of the planning authority in whose functional area the activity is or will be carried out.

Name:

Tel: 021 4276891 el 6 , .I I Fax: 021 4276321

Planning Permission relating to this application:

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IPPC Appltcation 13rm Vl/07

Attachment B.5 should contain all planning permissions, including a copy of all conditions, and the required copies of any EIS should also be enclosed. For existing activities, Attachment NQ B.5 should also contain all licences and permits past and present in force at the time of submission.

8.6. Relevant Sanitary Authority.

In the case of a discharge of any tralde effluent or other matter to a sewer of a sanitary authority, give the name of the sanitary authority in which the sewer is vested or by which it is controlled.

Name: Address:

Tel: 021 4276891 Fax: 021 4276321

In the case of a discharge of any trade effluent or other matter to a sewer not vested by a sanitary authority, the applicant must. supply as Attachment NQ B.6; (a) the name and address of the owner(s) of the sewer and the waste water treatment plant to which the sewer discharges and who are responsible for the quality of the treated effluent discharging to waters and (b) a copy of the effluent regulations and the agreement between the applicant and the aforementioned.

Name: Not Applicable Address:

Tel: Fax:

8.7. Relevant Health Board Region

The applicant should indicate the Health Board Region where the activity is or will be located.

Name: Address: Wilton Road,

Health Service Executive (HSE) Southern

I I

Tel: 021 454501 1 Fax: 021 4345638

B.8 Site Notice, Newspaper Advertisement and Planning Authority Notice.

Attachment NQ B.8 should contain a copy of the text of the site notice, a map (no larger than A3) showing its location on site (in accordance with Article 7 of the Regulations) and a copy of the newspaper advertisement:. A copy of the notice given to the Planning Authority should also be included.

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IPPC Application Fbnn Vl/07

B.9 Seveso I1 Regulations

State whether the activity is an establishment to which the EC (Control of Major Accident Hazards involving Dangerous Substances) Regulations (S.I. No. 74 of 2006) apply. S.I. No. 74 of 2006 does not apply

I f yes, outline how the process comes under these regulations.

Supporting information should be included in Attachment NQ B.9.

B.10 IPPC Directive

Specify whether the activity is a category of industrial activity referred to in Annex I of the IPPC Directive (96/61/EC) and if yes specify the category.

The activity is below the solvent consumption capacity as per Annex I of the IPPC Directive (96/61/EC) 6.7. Installations for the surface treatment of substances, objects or products using organic solvents, in particular for dressing, printing, coating, degreasing, waterproofing, sizing, painting, cleaning or impregnating, with a consumption capacity of more than 150 kg per hour or more than 200 tonnes per year

Supporting information should be included in Attachment NQ B.10. - None

fiN.A(GEMENT'OF THE

C. l Site Management & Control

Details should be provided on the management structures for the activity. Organisational charts and all relevant environmental management policy statements, including provisions for on-going assessment of environmental performance, are required.

C.2 Environmental Management System (EMS)

Indicate whether an Environmental Management System has been developed for the installation. I f yes, specify which standard and include a copy of the accreditation certificate. Site has environmental procedures in place but does not have a certified EMS, it does however have a Certified QMS, certified to IS09001 :2000.

C.3 Hours of Operation

@

Provide details of the hours of operation for the installation, including: (a) Proposed hours of operation. (b) Proposed hours of construction and development works and timeframes. (c) Any other relevant hours of operation expected.

This information should form Attachment NQ C.

I t STRUCXURE,~~ OPERATION , I

D. 1. Operational Information Requirements

Describe the plant, methods, processes, ancillary processes, abatement, recovery and treatment systems, and operating procedures for the activity, to include a copy of such

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IPPCAppkcition Fbrm V1/07

plans, drawings or maps, (site plans and location maps, process flow diagrams), and such other particulars, reports and supporting documentation as are necessary to describe all aspects of the activity. Maps and drawings must be no larger than A3 size.

A development and operational history of the site should be included here.

Attachment NQ D should contain a list of all unit operations (processes) to be carried out, including flow diagrams of each with any relevant additional information.

Attachment D contains flow diagrams of all unit operations

I SECT1:ON E: EMISSIONS 1 1 , I

E.1. Emissions to Atmosphere

E.l.A. Details of all point emissions to atmosphere

Details of all point emissions to atmosphere should be supplied. Complete Table E.l(i) for Boiler Emissions and Table E.l(ii) and E.l(iii) for all other main emission points. Complete Table E.l(iv) for minor emission points.

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A summary list of the emission points, together with maps and/or drawings (no larger than A3), and supporting documentation should be included as Attachment NQ E. Plans of emission elevations, relevant roof heights, etc., should also be included, as should detailed descriptions and schematics of all abatement systems.

The applicant should address in particular any emission point where the substances listed in the Schedule of S.I. 394 of 2004 are emitted.

For emissions outside the BAT guidance limit, a full evaluation of the existing abatement/treatment system must be provided. A planned proaramme of improvement towards meetina uparaded standards is required. This should highlight specific goals and a time scale, together with options for modification, upgrading or replacement as required to bring the emissions within the limits as set out in the BAT guidance note(s). These notes can be found on the EPA website at www.epa.ie. An RTO is being installed to ensure that Polyurethane process emissions comply with BAT, all existing emissions comply with BAT.

$ 1

/ I E.l.B. Fugitive and Potential emissiorls 4

Give summary details of fugitive and potential emissions in Table E.l(v).

I n relation to activities listed in the Schedule of Council Directive 1999/13/EC on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations;

- -

specify the relevant category of activity in the Schedule specify how the requirements in relation to fugitive emissions will be met.

Full details and any supporting information should form Attachment E.l.B

Council Directive 1999/13/EC - Activity 8, other coating including metal, plastic, textile, fabric, film and paper coating.

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IPFC App/ication Fom W O 7

Collection and treatment of process emissions in RTO. Inks and adhesives stored in closed containers in dedicated warehouse. Batches made up in small lots to minimise fugitive emissions.

I

E.2 Emissions to Surface Waters There are no emissions to surface waters. All aqueous emissions are to sewer.

Tables E.2(i) and E.2(ii) should be completed.

A summary list of the emission points, together with maps/drawings (no larger than A3) and supporting documentation should be included as Attachment NP E.2.

The applicant should address in particular any emission point where the substances listed in the Schedule of S.I. No. 394 of 2004 are emitted.

Details of all List I and List I1 substances listed in the Annex to EU Directive 76/464/EEC (as amended), contained in any emission must be presented. All surface water runoff and storm water drains discharging tlo surface water bodies must be included. A National Grid References (12 digit, 6E, 6N) niust be given for all discharge points. The identity and type of receiving water (river, ditch, estuary, lake, etc.) must be stated.

For emissions outside the BAT guidance limit, a full evaluation of the existing abatement/treatment system must be provided. A danned proqramme of improvement towards meetina uparaded standards is required. This should highlight specific goals and a time scale, together with optioris for modification, upgrading or replacement as required to bring the emissions within the limits as set out in the BAT guidance note(s).

E.3 Emissions to Sewer

Tables E.3(i) and E.3(ii) should be completed.

A summary list of the emission points, together with maps and/or drawings (no larger than A3) and supporting documentation should be included as Attachment NP E.3. Details of all List I and List I1 substances listed in the Annex to EU Directive 76/464/EEC (as amended), contained in any emission must be presented. All relevant information on the receiving sewer, including any effluent treatment/abatement systems, not already described, with schematics as appropriate should also be included in Attachment WE.3.

For emissions outside BAT guidance limit (where given), a full evaluation of the existing abatement/treatment system must be provided. A planned proaramme of improvement towards meeting uparaded standards is required. This should highlight specific goals and a time scale, together with options for modification, upgrading or replacement as required to bring the emissions within any limits set out in the BAT guidance note(s). The existing Total Nitrogen limit of 15 mg/l is not achievable on a consistent basis as a result of < 1 % traces of ammonia in one of the raw material adhesives. This results in a typical daily effluent concentration of 40 mg/l of Total Nitrogen and is equivalent to a discharge of < 0.6 kg of Nitrogen/da:y. The Company is looking at an alternative for this raw material with low or zero ammonia content. The Company has been working with suppliers on this substitution for over 4 years. Currently there is no viable alternative available. Chris Kay a Division of ITCY Ireland is requesting a higher discharge limit for this parameter, namely an increase from 15 mg/l to 100 mg/l. This will still be within the C0D:N:P ratio of 100:S:l suitable for effluent treatment.

The WP (S) 06/97 states that "The total daily volume of both treated wastewater and domestic wastewater shall not exceed 15 metres/day (sic) or 5 cubic metres/hour. " The increase in production resulting from the installation of three Polyurethane Heat Transfer Manufacturing lines, will result in a significant increase in the number of print screens

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IPPC Application f i rm V1/07

washed on a daily basis. It is anticipated that the volume of water required for screen washing will increase to an average of 45 cubic metres/day. To allow for this increase the applicant is requesting an increase in the volumetric limit from 15 cubic metres/day to 60 cubic metres/da y.

E.4. Emissions to Ground There are no emissions to ground.

Describe the existing or proposed arrangements necessary to give effect to Articles 3,4,5,6, and 7 of Council Directive 80/68/EEC of 17 December 1979 on the protection of groundwater against pollution by certain dangerous substances.

The applicant should supply details of the nature and quality of the substance (agricultural and non-agricultural waste) to be landspread (slurry, effluent, sludges etc) as well as the proposed application rates, periods of application and mode of application (e.g., pipe discharge, tanker).

For emissions outside the BAT guidance limit, a full evaluation of the existing abatement/treatment system must be provided. A planned programme of improvement towards meetina uparaded standards is required. This should highlight specific goals and a time scale, together with options for modification, upgrading or replacement as required to bring the emissions within the limits as set out in the BAT guidance note(s).

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E.5 Noise Emissions

Give particulars of the source, location, nature, level, and the period or periods during which the noise emissions are made or are to be made.

Table E.5(i) should be completed, as i-elevant, for each source.

Supporting -information should form Attachment NP E.5

For emissions outside the EPA Guidance Note for Noise in elation to Scheduled Activities 2"d Edition (2006), a full evaluation of the existing abatement/treatment system must be provided. A planned proaramme of improvement towards meetina uparaded standards is required. This should highlight specific goals and a time scale, together with options for modification, upgrading or replacement as required to bring the emissions within the limits as set out in the Guidance Note.

The site is located in the Farm Lane IDA Industrial Estate. The facility has been in operation at this location since 1997 and has not received a noise complaint in that time. There is a planned programme of improvement to minimise noise emissions from the facility in particular to minimise the impact at the potentially noise sensitive northern boundary and to reduce the noise emissions from the glue sieving exhaust (which operates intermittently during da y-tinie hours only). The pump associated with the glue- sieving exhaust is to be modified by 43 2008 to achieve noise emissions reduction. The Stat ovens exhaust will be routed to the new regenerative thermal oxidiser (RTO) which will resulting in a damping down of this noise source. An accoustic enclosure in the form of an insulation material cladded around the casing of the regenerative thermal oxidiser fan will be provided to offer sound reduction to around 75 dba at l m away. The proposed new air handling unit is also designed to comply with the 45dBA (night) limit at the site boundary. Both the RTO and the AHU are planned to be installed and commissioned before the end of 2008. They are to be located on the western side of the site to again minimise noise levels at the northern boundary. Flock brushing vacuum system is planned for replacement in Q3 2008. This will reduce noise from the flock production

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IPPC Application Form Vl/07

process (water based system). Chris Kay a Division of ITW Ireland is actively working with Moloney & Associates Acoustic and Environmental Consultants to meet regulatory requirements. A copy of Environmental Noise Assessment (2008 report) is included in Attachment E.5. When the modifications are made a repeat noise survey will be carried out by our noise consultants.

E.6 Tabular Data on Emission Points

Applicants should submit the following information for each emission point:

Point Code Provide label ID'S assigned in section E

Point Type

A=Atmospheric S W = Su rface Water SE = Sewer GW=Groundwater N = Noise SL= Soi I/G rou nd WS= Waste

Easting

6E-digit GPS Irish National Grid Reference

Northing

6N-d ig it GPS Irish National Grid Reference

Verified

Y = GPS used N = GPS not used

Emission

e.g. SOz, HCI, NH3

An individual record (i.e. row) is required for each emission point. Acceptable file formats include Excel, Access or other upon agreement with the Agency. A standard Excel template can be downloaded from the EPA website at www.epa.ie. This data should be submitted to the Agency on a separate CD-Rom containing sections 6.2, E.6 and F.3. Attachment E.6 contains the following files: 27294-E-002 Site Plan Showing Emission Points & E. 6 EPA Emission Points Data 1

1%$

8i MONITORZNG I / ' * i i

Describe the proposed technology and other techniques for preventing or, where this is not possible, reducing emissions from the installation/facility.

F.l: Treatment, Abatement and Control Systems

Details of treatment/abatement systems (air and effluent emissions) should be included, together with schematics as appropriate.

For each Emission Point identified cornplete Table F. l(i) and include detailed descriptions and schematics of all abatement systems.

Attachment NQ F.1 should contain aiiy supporting information.

F.2: Emissions Monitoring and Sampling Points

Identify monitoring and sampling points and outline proposals for monitoring emissions. Table F.2(i) should be completed (where relevant) for air emissions, for emissions to surface waters, for emissions to sewers, for emissions to ground, and for waste emissions. Where ambient environment monitoring is carried out or proposed, Table F.2(ii) should be completed as relevant for each environmental medium.

Include details of monitoring/sampling locations and methods.

Attachment NQ F.2 should contain any supporting information.

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IPPC Applwtion Form V1/07

F.3: Tabular Data on Monitoring aind Sampling Points

Point Point Type Eastiqg Northing Code Provide M=Monitoring 6E-digit 6N-digit label ID'S S=Sampling GPS Irish GPS Irish assigned National National in section Grid Grid F3 Reference Reference

Applicants should submit the following information for each monitoring and sampling point:

Verified Poll uta nt

Y = GPS used N = GPS not used

e.g. SOz, HCI, NH3

Point source monitoring/sampling refers to monitoring from specific emission points (e.g. from a boiler stack or outlet from a wastewater treatment plant). Examples of ambient monitoring includes monitoring of ambient air quality (e.g. boundary or off-site) or monitoring of river quality upstream/downstream of an effluent discharge.

' I ENERGY EFFICI

G. l fuels and energy which will be produced by or utilised in the activity.

Give a list of the raw and ancillary materials, substances, preparations,

The list(s) given should be very comprehensive, all materials used, fuels, intermediates, laboratory chemicals and product should be included.

Particular attention should be paid to materials and product consisting of, or containing, dangerous substances as described iin the EU (Classification, Packaging, Labelling and Notification of Dangerous Substances) Regulations 1994 [SI 77/94]. The list must classify these materials in accordance with Article 2 of these Regulations, and must specify the designated Risk Phrases (R-Phrases) of each substance in accordance with Schedule 2 of the Regulations

Tables G.l(i) and G.l(ii) must be completed. Copy as required.

Supporting information should be given in Attachment NP G.

G.2 Energy Efficiency

A description of the energy used in or generated by the activity must be provided. Outline the measures taken to ensure that energy is used efficiently and where

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IPFC Appkation Form V1.07

appropriate, an energy audit with reference to the EPA Guidance document on Energy Audits should be carried out.

The energy sources used are electricity and bulk propane. The annual usage of Bulk propane will be < 100 tonnes per annum and electricity consumption will be < 2000 M Wh/Annum, when the new RTO, AhU and Polyurethane Printing Machines are installed. The new equipment is specified with !ow energy requirements. The choice of RTO as an abatement solution was based on compliance with Solvent Directive EL Vs and energy efficiency. Variable speed drives will he fitted on motors where possible. The Company has embedded ITW Corporate 80/20 corporate policy in the plant operation. Known internally as the ITW Toolbox, this repository of proven strategies and techniques guides our business process. Specific strategies that help us reach our goals include: product line simplification, segmentation, in-lining, cellular manufacturing and outsourcing. We are in the process of in-lining the Business Units, in Kinsale and equipment is being modified / replaced to improve efficiency both from a manufacturing point of view and energy usage. Attachment G.2 contains a breakdown of gas energy consumption per production line.

MATERIALS ,HANQLING' I

H.l All materials should be listed in Tables G.l(i) and G.(ii) of Section G.

Raw Materials, Intermediates and Product Handling @

Details of the storage conditions, location within the site, segregation system used and transport systems within the site should be outlined here. I n addition, information relating to the integrity, impermeability and recent testing of pipes, tanks and bund areas should be outlined. Bunded Warehouses/Compound Large capacity Bunded Warehouses to be installed to suit Chemical Storage needs. Bunded Chemical Warehouse Specification: Dimensions: External: 10,l OOw x 7,450d x 4500h mm(see drawing) Storage:24 no. Pallets (1250 x 1250mm). 3 no. storage modules positioned around a 6.5m aisle: *Heated compartment for 8 no. pallets. Waste/Empty Drums - 8 no. Pallets.

.Solvents Drums -8 no. pallets good stock & waste. Shelf Heights: 1650mm (1 850mm for Solvent drums with pumps) Bund: Epoxy coated steel (3. Omm) Bunds. Total Bund Capacity: 5,500 litres Separate Bunds to segregate non compatible Chemicals. (exceeds 11 0% and 25% guidelines, ref. EPA). Bunds tested before dispatch. Bund Test Certificate issued with Store. Ventilation: Ventilation louvers at high and low level. Shelf grating:Galvanised Open mesh grating allows spilled liquids to pass into the Bund below. Access/Security: Twin Sliding, lockable doors - ope: 3000mm. Anti Tamper Pad Lock Box fitted as standard. Fire Escape: Emergency Fire Escape Door c/w Panic Latch fitted at back wall. Signage:Sa fety / Warning Signs fitted' to doors as standard. Static Protecti0n:Anti Static Grounding Kit fitted along right hand wall where Solvents are being pumped and waste solvents are being collected to prevent ignition of flammable vapours by static discharge. 4 no. Bonding Cables. Frost Protection: For 8 no. Pallets. 3 no. 750 watt Ex Air Warmers (EExe 11 T3) c/w Thermostat control(Eexd IIC T6). Single Phase, terminated at external Junction Box.

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IPFC Application Form V1/07

Sliding insulated doors. Spill Kit :250 litre General Purpose Mobile Spill Kit supplied with Warehouse to deal with chemical spillages which occur outside the Bunds (during loading / off loading). Safety Centre: Wall mounted MSDS holders, Hazards symbol identification poster, First Aid box & Wall mounted Eye Wash StiWon located inside main door of warehouse.

Material Storage Locations within the site 27294-H. 1-001 Ground Floor Plant Material Storage 27294-H. 1-003 First Floor Plant Material Storage 27294-H. 1-003 Site Plant Material Storage

Transport systems within the site A battery powered forklift is used to move goods on site, excluding internal factory floor. Movement of goods on the factory floor is by hand pallet truck and movement between floors is using a caged hoist.

Pipes, tanks and bund areas Effluent pipework is PVC/PPE dia 225rnm discharging to dia 325 mm sewer Foul sewer pipework is 1 SO mm PVC Pipes Storm Water pipework is dia 225 mm PVC Pipes This material allows for the safe tranqport of effluent, stormwater and foul sewage. Historically process effluent has arisen from screen washing using to wnswater, this will continue to be the case. When the Polyurethane Printing Machines are installed, pipe integrity testing will be carried out.

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H.2 liquid wastes accepted into or generated by the installation/facility.

Describe the arrangemends for the recovery or disposal of solid and

For each waste material, give full particulars of:

(a) Name

(b) Description & nature of waste

(c) Source

(d) Where stored and integrity/impermeability of storage areas @ (e) Amount (m3) and tonnage

(f) Period or Periods of generation

(9) Analysis ( include test methods and Q.C. )

(h) European Waste Catalogue Code

(i) Waste’ Category per EC Reg 1774/2002/EC where relevant

Where any waste would be classified as Hazardous Waste as defined in the Waste Management Acts, 1996 to 2003, this should be made clear in the information provided.

Summary Tables H.l(i) and H.l(ii) should also be completed, as appropriate, for each waste. The licence/permit register number of the waste collection agent or disposal/recovery operator should be supplied as well as the expiry date of the relevant permits.

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'1

IPK Appkation Form Vl/07

Supporting information should form Attachment NP H . 2

H.3 Waste disposal by on-site lanldfilling

For wastes to be disposed of by landfilling on-site, full details of the disposal site should be submitted (to include inter alia, site selection procedures, location maps, (no larger than A3) geology, hydrogeology, operational plan, containment, gas and leachate management, post-closure care).

Supporting information should form AJtachment NP H.3. Not Applicable

SECTION I: .EXISTING E NV ERON M ENT &&:IM PACTIO FI TH E ACTIVI' @ I t i Describe the conditions of the sits of the installation.

Provide an assessment of the effects of any emissions on the environment, including on an environmental me!dium other than that into which the emissions are made.

Describe, where appropriate, measures for minimising pollution over long distances or in the territory of other states.

1.1.Assessment of atmospheric emissions Describe the existing environment in terms of air quality with particular reference to ambient air quality standards.

Provide a statement whether or not eimissions of main polluting substances (as defined in the Schedule of S.I. 394 of 2004) to the atmosphere are likely to impair the environment.

Give summary details and an assessment of the impacts of any existing or proposed emissions on the environment, including environmental media other than those into which the emissions are to be made.

Attachment NP 1.1 should also contain full details of any dispersion modelling of atmospheric emissions from the activity, where required. When carrying out dispersion modelling, regard should be had to the "Guidelines for the Preparation of Dispersion Modelling Assessments for Compliance with Regulatory Requirements - an Update to Royal Meteorological Society Guidance" or similar guidelines from a recognised authority. An atmospheric emissions model carried out by URS can be found in attachment L l

1.2. Assessment of ImDact on Receiviria Surface Water Describe the existing environment in terms of water quality with particular reference to environmental quality standards or (other legislative standards. Table 1.2(i) should be completed

Provide a statement whether or not emissions of main polluting substances (as defined in the Schedule of S.I. 394 of 2004) to water are likely to impair the environment.

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IPK Application Form V1/07

Give summary details and an assessment of the impacts of any existing or proposed emissions on the environment, including environmental media other than those into which the emissions are to be made.

Full details of the assessment and any other relevant information on the receiving environment should be submitted as Attachment NQ 1.2. There are no emissions to surface waters.

1.3. Assessment of Imuact of Sewaae IDischarae.

Give summary details and an assessment of the impacts of any existing or proposed emissions on the environment, including environmental media other than those into which the emissions are to be made.

Full details of the assessment and any other supporting information should form Attachment NQ 1.3. The nature and characteristics of the process effluent and domestic sewage (as outlined in tables E.3.i & E.3.ii) that discharge to the Cork County Council sewer at emission point SE-3 will not impact on the integrity of the material of construction of the sewer (Foul sewer pipework is 150 mm PVC Pipes & Effluent pipework is PVC/PPE dia 225mm discharging to dia 325 mm sewer). Suspended solids from process effluent are of a low concentration (<100mg/l) and are not likely to give rise to any settling out in the pipework which could result in flow restriction. Wastewater treatment is pH correction only and there is no biological treatment where microorganisms (as suspended solids) could settle in the sewer. The nature and characteristics of the storm water discharge (as outlined in tables E.3.i & E.3.i) that discharges to the Cork County Council sewer at emission point SE-4 will not impact on the integrity of the sewer(Storm Water pipework is dia 225 mm PVC Pipes).

@

1.4 Assessment of ImDact of Ground/Groundwater Emissions

Describe the existing groundwater quality. Tables 1.4(i) should be completed. Give summary details and an assessment of the impacts of any existing or proposed emissions on the ground (aquifers, soils, sub-soils and rock environment), including any impact on environmental media other than those into which the emissions are to be made. This includes landspreading, land injection etc. @ Land on which material may be landspread shall be identified on a suitable scaled map (1:10,560 and 1:50,000) and submitted as no greater than A3 size. All vulnerable (as a result of ground emissions) surface water bodies must be identified on these maps. Additional information should be included in Attachment NP 1.4.

La ndspread i ng of Ag ricu Itu ra I/Non Agricu Itu ral Wastes

Tables I.4(ii) and 1.4.(iii) should be complete where applicable. Further information is available in the Application Guidance IDocument. There are no emissions to ground/groundwater.

1.5 Ground and/or Groundwater Contamination

Summary details of known ground andl/or groundwater contamination, historical or current, on or under the site must be given.

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IPK Applwtion Form V1/07

Full details including all relevant investigative studies, assessments, or reports, monitoring results, location and design of monitoring installations, plans, drawings, documentation, including containment engineering, remedial works, and any other supporting information should be included in Attachment NP 1.5. A due diligence assessment was carried out by ERM in 2004 on behalf of ITW. A copy of this report which includes a section on ground/groundwater quality can be found in Attachment I. 5.

1.6 Assessment of the Environmental Impact of On-site Waste Recovery and/or Disposal.

Describe the arrangements for the prevention and recovery of waste generated by the activity.

Give details, and an assessment of the impact of any existing or proposed on-site waste recovery/disposal on the environment, including environmental media other than those into which the emissions are to be made. There has never been any on-site waste recovery or disposal operations carried out. This information should form Attachment NQ 1.6. - 1.7 Noise Impact @ Give details and an assessment of the impacts of any existing or proposed emissions on the environment, including environmental media other than those into which the emissions are to be made.

Ambient noise measurements Complete Table I.7(i) in relation to the information required below:

(i) State the maximum Sound Pressure Levels which will be experienced at typical points on the boundary of the operation. (State sampling interval and duration)

(ii) State the maximum Sound Pressure Levels which will be experienced at typical noise sensitive locations, outside the boundary of the operation.

(iii) Give details of the background noise levels experienced at the site in the absence of noise from this operation.

@ Prediction models, maps (no larger than A3), diagrams and supporting documents, including details of noise attenuatilon and noise proposed control measures to be employed, should form Attachment IYP 1.7. A copy of Environmental Noise Assessment (Moloney & Associates 2008 report) is included in Attachment I. 7.

1.8 Environmental Considerations and tKT

Describe in outline the main alternatives, if any, to the proposals contained in the application.

Describe any environmental considerations which have been made with respect to the use of cleaner technologies, waste minimisation and raw material substitution.

Describe the measures proposed or in place to ensure that:

(a) The best available techniques are or will be used to prevent or eliminate or, where that is not practicable, generally reduce an emission from the activity;

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IPPC Appkwtion Form Vl/07

The Surface Treatment using Solvent BREF was consulted in the design of materials storage, handling and abatement equipment for the introduction of solvent using processes to site to prevent, eliminate or reduce emissions from the activity wherever possible. (b) The Regenerative Thermal Oxidiser was chosen as the atmospheric emissions abatement option to comply with Solvent Directive ELVs and also to maximise energy efficiency. The process effluent arises from the hot vvashing of printing screens which contain trace inks and solvent. Solid wastes (hazardous and non-hazardous are only collected by permitted contractors and recovered or disposeld of in Licensed facilities). (c)

no significant pollution is caused;

waste production is avoided in accordance with Council Directive 75/442/EEC of 15 July 1975 on waste; where waste is produced, it is recovered or, where that is technically and economically impossible, it is disposed of while avoiding or reducing any impact on the environment;

The Company has embedded ITW Corporate 80/20 corporate policy in the plant operation to achieve greater operational efficiency. Tools utilised include: product line simplification, segmentation, in -lining, cellular manu fa cturing and outsourcing . In -lining the Business Units is underway and equipment is being modified / replaced to improve yield and reduce waste. Where possible waste sent off-site is recovered (waste inks) or recycled (cardboard packaging and metal). Significant improvements have been achieved in waste reduction in the Lextra Business Unit and Printing Business Unit by reducing the number of set-ups, recycling adhesives, cutting WIP by 85% and reducing rejects by 70 TO.

@

(d) The energy sources used are electricity and bulk propane. The annual usage of Bulk propane will be e 100 tonnes per annum and electricity consumption will be e 2000 MWh/Annum, when the new RTO, AHU and Polyurethane Printing Machines are installed. The new equipment is specified with low energy requirements. The choice of RTO as an abatement solution was based on compliance with Solvent Directive EL Vs and energy efficiency. Variable speed drives will be fitted on motors where possible.

energy and other resources are used efficiently;

(e) the necessary measures are taken to prevent accidents and limit their consequences;

The company has a Safety Statement which outlines the main hazards and their associated risks. Chemical risk assessments have been carried out and can be reviewed in attachment 1.8. An overview of Aclrident Prevention and Emergency Response can also be found in attachment 1.8

(f) the necessary measures are taken upon definitive cessation of activities to avoided any pollution risk and return the site of operation to a satisfactory state.

Cessation of Activities The company shall process or remove all remaining raw materials from the site in the event of cessation of activities. All equipment shall be decontaminated through rinsing to process effluent, in a controlled manner, to ensure compliance with discharge limits and the machines then sold or scrapped. The buildings and site are owned by ITW Ireland and the Company have considered requirements for decommissioning and decontamination of all process related structures. This is outlined in the companies Residuals Management Plan which is included in attachment K. ITW is a global industrial company that operates 825 Businesses located in 52 countries spanning the globe and with an annual Revenue of $17 Billion USD and Cash Reserves of $2 Billion USD. The Corporation would be able to meet any decommissioning costs in the event of cessation of activities.

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IPPC Applcation Form Vl/07

Supporting information should form Attachment NP 1.8.

,’ : I I , ~ ~ ~ f r ~ ~ ~ ’ ~ i ACCIDENT’ PIREVENTION EMERGENCY

Describe the existing or proposed measures, including emergency procedures, to minimise the impact on the environment of an accidental emission or spillage.

Also outline what provisions have been made for response to emergency situations outside of normal working hours, i.e. during night-time, weekends and holiday periods.

Describe the arrangements for abnormal operating conditions including start-up, leaks, malfunctions or momentary stoppages.

Supporting information should form Attachment NP 1. Refer to attachment J

ECTION lK:;,REMEDIATION ECOMMISSPON

Describe the existing or proposed measures to minimise the impact on the environment after the activity or part of the activity ceases operation, including provision for post- closure care of any potentially polluting residuals.

Supporting information should be included as Attachment No. K.

Remediation, Decommissioning, R!estoration & Aftercare

REMEDIATION EMERGENCY RESCUE PLAN In the unlikely event that the building or site is damaged in unforeseen circumstances the company is committed to restoring the site to its operations status. As an member of an international group of companies and highly dependent on the export market it is important that an emergency rescue plan is put in place to cope with a sudden loss of manufacturing capacity due to fire or otherwise so as to minimise any inconveniences caused to our broad customer base world wide. Chris Kay a Division of ITW Ireland has implemented such a plan, its objectives are:

To design an emergency rescue plan to allow the continuation of current operations with the minimum of delay to the customer.

To source alternative manufacturing sites for all products currently manufactured at Chris Kay a Division of ITW Ireland..

To set up a central control location for coordinating all subcontracted work, process control, merchandising and Sales, Order Processing, Stock Control.

To set up a temporary manrifacturing facility for Lextra, Lextra 30, Arfflock, Polyurethane,, Softweld and Hi- Weld and for the storage of Raw Materials.

To identifjt equipment requirements and lead time and period of commissioning Full Procedure in place; available upon request.

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IPPC Appliwtion Fbrm Vl/07

DECOMMISSIOINING, RESTORATION & AFTERCARE PLAN The company shall process or remove all remaining raw materials from the site in the event of cessation of activities. All equipment shall be decontaminated through rinsing to process effluent, in a controlled manner, to ensure compliance with discharge limits and the machines then sold or scrapped. The buildings and site are owned by ITW Ireland and the Company have considered requirements for decommissioning and decontamination of all process related structures. This is outlined in the companies Residuals Management Plan which is included in attachment K. ITW is a global industrial company that operates 825 Businesses located in 52 countries spanning the globe and with an annual Revenue of $17 Billion USD and Cash Reserves of $2 Billion USD. The Corporation would be able to meet any decommissioning costs in the event of cessation of activities.

Indicate how the requirements of Section 83(5)(a)(i) to (v) and (vii) to (x) of the EPA Acts, 1992 and 2003 shall be met, having regard, where appropriate, to any relevant specification issued by the Agency under section 5 (3) of the Act and the reasons for the selection of the arrangements proposed. Chris Kay a Division of ITW Ireland undertakes to meet the requirements of Section 83(5)(a)(i) to (v) and (vii) to (x) of the EPA Acts, 1992 and 2003 through the following: The new thermal oxidiser is dedicate to treat emission from the Polyurethane Heat Transfer production processes. Regenerative Thermal Oxidation is one of the Techniques mentioned for consideration in the determination of BAT. Modelling of these emissions using worst case scenarios indicate no significant impact in terms of guide values, limit values and odour thresholds. Bulk Propane gas is in use at the site, which will minimise the likelihood of exceedence of the air quality standards under the Air Pollutions Act. All process aqueous discharges undergo treatment which includes pH correction/neutralisation Stormwater and process effluents are kept separate to permit appropriate treatment options. Since Chris Kay a Division of ITW Ireland discharges to sewer, the requirements for emissions to waters do not apply Programmes to reduce resource consumption and reduce waste are ongoing as part pf the 80:20 tools implementation process. Apart from recycling of certain materials, non- hazardous wastes are sent to engineered landfill, while hazardous wastes are sent for overseas incineration or recovery. Chlorine based oxidising substances are not in use at the site. Noise emissions are detailed in section E.5. Techniques for controlling noise in the EPA'S Guidance Note for Noise in Relation to Scheduled Activities as well as in BAT, have been considered in equipment specification and selection. The monitoring provisions outlined in Section F will be undertaken to ensure compliance with licence requirements. Bunding of raw materials are in place The site has IS09001 :2000 Accreditation Chris Kay a Division of ITW Ireland operates programmes to reduce resource consumption, improve energy efficiency and reduce waste. A Lean manufacturing programme was launched in 2006 and is continuing to be developed on site. Chris Kay monitors energy efficiency and water consumption closely.

@

Indicate whether or not the activity ik carried out, or may be carried out, or is located such that it is liable to have an adverse effect on -

(a) a site placed on a list in accordance with Chapter 1 of SI 94 of 1997, or

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IPPC Appkation Form Vl/07

I

(b) a site where consultation has been initiated in accordance with Article 5 of the

Fit and Proper Person

The PoE Act in Section 83(5)(xi) specifies that the Agency shall not grant a licence unless it is satisfied that the applicant or Licencee or transferee as the case may be is a fit and proper person. Section 84(4) of the F'oE Act specifies the information required to enable a determination to be made by the Agency.

0 Indicate whether the applicant or other relevant person has been convicted under the PoE Act, the Waste Management Act 1996, the Local Government (Water pollution) Acts 1977 and 1990 01- the Air Pollution Act 1987.

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IPPC Applicaon Fbnn W O 7

Neither Chris Kay a Division of ITW Ireland nor any of its employees have Convictions under the PoE Act, the Waste Management Act 1996, the Local Government (Water pollution) Acts 1977 and 1990 or the Air Pollution Act 1987. Provide details of the applicant's technical knowledge and/or qualifications, along with that of other relevant employees. Dr Peter Gleeson, General Manager. Qualifications: BSc Industrial Chemistry University of Limerick 1989; PhD Catalytic Chemistry (U. L.) 1992. Technical knowledge from Managing Production facilities in UK and Ireland since 1992.

o

0 Provide information to show that the person is likely to be in a position to meet any financial commitments or liabilities that may have been or will be entered into or incurred in carrying on the activity to which the application relates or in consequence of ceasing to carry out that activity.

Supporting information should be included as Attachment NP L with reference to where the information can be found in the application.

The Company have considered requirements for decommissioning and decontamination of all process related structures. This is outlined in the companies Residuals Management Plan which is included in attachment K. ITW is a global industrial company that operates 825 Businesses located in 52 countries spanning the globe and with an annual Revenue of $1 7 Billion USD and Cash Reserves of $2 Billion USD. The Corporation would be able to meet any decommissioning costs in the event of cessation of activities. Copy of the Company's Certificate of Insurance Policy is included in attachment L.

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IPPC Application B r m V1/07

SECTION M: DECLARATION

Declaration

I hereby make application for a licence /- kewte, pursuant to the provisions of the Environmental Protection Agency Acts, 1992 and 2003 and Regulations made thereunder.

I certify that the information given in this application is truthful, accurate and complete.

I give consent to the EPA to copy this application for its own use and to make it available for inspection and copying by the public, both in the form of paper files available for inspection at EPA and local authority offices, and via the EPA's website. This consent relates to this application itself and to any further information, submission, objection, or submission to an objection whether provided by me as Applicant, any person acting on the Applicant's behalf, or any other plerson.

Date: 04/07/2008

Print signature name: Dr v eter Glee=

Position in organisation: General Manaaer

Company stamp or seal:

Chris Kay a division of IlW Ireland, , Farm Lane, Kinsale, Co. Cork, Ireland.

Tel : +353 21 4772050

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