liebherr container cranes ltd - environmental … · lcc’s most significant environmental aspects...

LIEBHERR CONTAINER CRANES LTD.

Annual Environmental Report –

2012

(Reporting Period – Jan to Dec 2011)

IPPC Licence No. P0146-02

Distribution: LCC Intranet, Programme for Public Information Environmental Protection Agency (EPA) – EPA website upload (http://aer.epa.ie/reporting)

Printed on Recycled Paper

http://aer.epa.ie/reporting

This page is intentionally blank

AER 2012

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Contents Page 1. Introduction ............................................................................................................. 5 1.1 IPPC Licence Registration Number ................................................................................... 5 1.2 Site Name and Location ................................................................................................... 5 1.3 Site Activities .................................................................................................................... 5 1.4 LCC Environmental Policy ................................................................................................ 6 1.5 LCC Environmental Organisation ..................................................................................... 7 2. Summary Information ............................................................................................... 8 2.1 Self-Monitoring Data........................................................................................................ 8 2.1.1 Emissions to Waters ......................................................................................................... 8 2.1.2 Emissions to Air ................................................................................................................ 10 2.1.3 Waste Arisings .................................................................................................................. 15 2.2 Agency Monitoring and Enforcement .............................................................................. 35 2.3 Energy and Water Consumption ...................................................................................... 36 2.4 Environmental Incidents and Complaints ........................................................................ 39 2.5 Pollutant Release and Transfer Register (PRTR) .............................................................. 41 3. Management of the Activity ..................................................................................... 43 3.1 Schedule of Environmental Objectives and Targets ........................................................ 43 3.2 Environmental Management Programme Report 2010/2011 ........................................ 46 3.3 Environmental Management Programme Proposal 2011/2012 ..................................... 48 3.4 Pollution Emissions Register (PER) Report 2010 .............................................................. 59 3.5 Pollution Emissions Register (PER) Proposal 2011 ........................................................... 69 4. Licence-Specific Reports ............................................................................................ 71 4.1 Noise Survey .................................................................................................................... 71 4.2 Bund Integrity Testing ...................................................................................................... 74 4.3 Underground Tank and Pipeline Inspection Report ........................................................ 76 4.4 Public Awareness & Communications Programme ......................................................... 78 4.5 Solvent Management Plan (SMP)

(incorporating a fugitive emissions reduction programme) ............................................ 79 4.6 Environmental Liabilities .................................................................................................. 86 4.7 Review of Decommissioning Management Plan (DMP) .................................................. 89 4.8 Energy efficiency audit report summary ......................................................................... 90 4.9 Report on the assessment of the efficiency of use of raw materials in

processes and the reduction in waste generated ............................................................ 93 4.10 Report on progress made and proposals being developed to minimise

water demand and the volume of trade effluent discharges .......................................... 98 4.11 Development/Infrastructural works summary

(completed in previous year or prepared for current year) ............................................ 100 4.12 Management and staffing structure of the installation .................................................. 101

AER 2012

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Appendices ........................................................................................................................... A0-1 A.1. Underground foul sewer pipe inspection reports. .......................................................... A1-1

A.2. Pollutant Release and Transfer Register (PRTR) report. .................................................. A2-1

Introduction

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1. Introduction This report has been produced in accordance with the EPA Guidance Note for Annual Environmental Report (AER). 1.1 IPPC Licence Registration Number

IPPC Licence Number : P0146-02 1.2 Site Name and Location

Liebherr Container Cranes Ltd., Gortroe, Killarney, Co. Kerry.

1.3 Site Activities

LCC is engaged in the production of rail-mounted and rubber-tyre container gantry cranes and straddle carriers at the facility in Killarney. The manufacturing process utilises such procedures as plasma cutting, gas-cutting, fabrication & welding of steel, machining, shot blasting and painting, mechanical assembly and electrical engineering. There is also a degree of office administration supporting manufacture through design, sales, production planning, purchasing, and after-sales. LCC’s most significant environmental aspects are emissions to atmosphere from painting and combustion of fuels, energy consumption, waste generation and potential for site run-off of paint/oils to water/sewer.

Introduction

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1.4 LCC Environmental Policy

Introduction

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1.5 LCC Environmental Organisation

ORGANISATION PLAN - Quality, Environment and Health & Safety

Executive Responsibility

for Policy

QMS, EMS & HSMS instruction &

Evaluation/Consultation advice

reporting &

advice Responsible for Quality, Environment

and Health & Safety in departments

Responsibility for

implementing policy Responsible for Quality, Environment

and Health & Safety in individual departments

Responsible for Quality, Environment and

Health & Safety in individual work areas

Board of Directors

External Consultants

Interested Parties

Certification body /

general public / EPA /

HSA / employeesQuality Manager /

Environmental

Control Manager /

Safety Engineer

Managers

Department

Supervisors

Emergency

Response TeamSafety Committee VisitorsEmployees Contractors

Summary Information

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2. Summary Information 2.1 Self-Monitoring Data 2.1.1 Emissions to Waters – 2011

The new IPPC licence no. P0146-02 introduced monitoring of emissions to Storm Water and Sewer in the latter part of 2010. Due to an extended period of cold and dry weather early in 2011, no flow in the storm water pipes prevented samples from being taken from SW1 and SW2 during quarter 1. Samples at SE1 were taken in the second half of the year as there was a blockage in the system due to construction work being carried out in this area.

Summary Information

2.1.1 Emissions to Waters - 2011

Storm Water Emission Point - SW1

ParameterEmission Limit

Value

Monitoring

FrequencyQtr 1 Qtr 2 Qtr 3 Qtr 4 Averages

Visual Inspection daily

pH quarterly no data 7.8 7.8 8.1 7.9

COD quarterly no data 7.1 23.0 15.0 15.0



Value

Monitoring



pH quarterly no data 7.7 8.0 7.9 7.9

COD quarterly no data 6.9 5.0 305.0 105.6



Value

Monitoring



pH quarterly 7.7 7.9 7.8 8.0 7.9

COD quarterly 9.0 2.6 5.0 89.0 26.4

Sewer Emission Point - SE1


Value

Monitoring


Visual Inspection weekly

pH 6-9 pH units biannually 11.0 7.3 9.2

COD not specified biannually 63.0 80.0 71.5

Oil, fats and grease 10 mg/l biannually 2.0 39.8 20.9

inspection log on file

no emissions of

environmental

significance


no emissions of

environmental

significance


no emissions of

environmental

significance


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Summary Information

2.1.2 Emissions to Air - (for year 2011)

2.1.2.1 Summary Information

Parameternote 1Mass Emission (kg) Mass Emission (kg) % Compliancenote 2

2010 2011 (Present Year)

TOC not available not available 100%

Non-methane VOC 66,779 78,323 N/A

Particulate 63 316 100%

Note 1: NMVOC figures have been taken from the PER mass balance (table 3.4.3),

as TOC data from quarterly monitoring do not generate an accurate

representation of mass emission.

Note 2: % Compliance = (Compliant Samples/Number of Samples)x100

2.1.2.3 Details of Non-compliance

Refer to section 2.4 of this report, environmental incidents and complaints

2.1.2.4 Calculations for Emissions to Air

(i) Total Annual Hours Emission

Emission Point

Total Annual Hours

Emission

A2-1 2,184

A2-2 2,541

A2-3 2,356

A2-4 2,021

A2-5 1,934

A2-6 26

A2-7 2,729

A2-8 894

A2-9 3,636A2-10 3,712

The information contained in the following tables is based upon data obtained from quarterly emissions monitoring reports at each named emission point. The Mass Emission Rate for each quarter is calculated as follows for each parameter: Concentration (mg/Nm3) x 10-6 x Flow Rate (Nm3/hr) = Mass Emission Rate (kg/hr) An average Mass Emission Rate is then determined by averaging available data. This is then multiplied by the number of hours which the emission fans were running for during the year. The totals for the parameters are then added for each emission source. The entry "No Data" appears in several cells in the tables the emission sources may have not been in operation at the time of the monitoring survey.

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Summary Information

(ii) A2‐1

Parameter Qtr.

Mass

Emission

Rate (kg/hr.)

Concentration

(mg/Nm 3 )

IPCL limit

(mg/Nm3)

Average

quarterly

mass

emission

(kg/hr.)

Emission

point

hours for

year

Mass

Emission

(kg) for

year Complia

nces

No. o

f Samples

TOC (as C) 1 no data no data 300 8.290 2,184 18,105 3 32 7.500 133.00 3003 15.600 257.00 3004 1.770 29.00 300

Particluate 1 n/a n/a 0.060 2,184 131 1 1

2 n/a n/a

3 n/a n/a

4 0.060 1.00

(iii) A2‐2

Parameter Qtr.

Mass

Emission

Rate (kg/hr.)

Concentration

(mg/Nm 3 )

IPCL limit

(mg/Nm3)

Average

quarterly

mass

emission

(kg/hr.)

Emission

point

hours for

year

Mass

Emission

(kg) for

year Complia

nces

No. o

f Samples



2 n/a n/a

3 n/a n/a

4 0.130 2.30

(iv) A2‐3

Parameter Qtr.

Mass

Emission

Rate (kg/hr.)

Concentration

(mg/Nm 3 )

IPCL limit

(mg/Nm3)

Average

quarterly

mass

emission

(kg/hr.)

Emission

point

hours for

year

Mass

Emission

(kg) for

year Complia

nces

No. o

f Samples



2 n/a n/a

3 n/a n/a

4 0.060 1.00

n/a

n/a

n/a

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Summary Information

(v) A2‐4

Parameter Qtr.

Mass

Emission

Rate (kg/hr.)

Concentration

(mg/Nm 3 )

IPCL limit

(mg/Nm3)

Average

quarterly

mass

emission

(kg/hr.)

Emission

point

hours for

year

Mass

Emission

(kg) for

year Complia

nces

No. o

f Samples



2 n/a n/a

3 n/a n/a

4 0.060 1.00

(vi) A2‐5

Parameter Qtr.

Mass

Emission

Rate (kg/hr.)

Concentration

(mg/Nm 3 )

IPCL limit

(mg/Nm3)

Average

quarterly

mass

emission

(kg/hr.)

Emission

point

hours for

year

Mass

Emission

(kg) for

year Complia

nces

No. o

f Samples



2 n/a n/a

3 n/a n/a

4 0.060 1.00

(vii) A2‐6

Parameter Qtr.

Mass

Emission

Rate (kg/hr.)

Concentration

(mg/Nm 3 )

IPCL limit

(mg/Nm3)

Average

quarterly

mass

emission

(kg/hr.)

Emission

point

hours for

year

Mass

Emission

(kg) for

year Complia

nces

No. o

f Samples

TOC (as C) 1 not in service not in service 300 #DIV/0! 26 0 0 02 not in service not in service 3003 not in service not in service 3004 not in service not in service 300

Particluate 1 n/a n/a #DIV/0! 26 0 0 0

2 n/a n/a

3 n/a n/a

4 not in service not in service

n/a

n/a

n/a

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Summary Information

(viii) A2‐7

Parameter Qtr.

Mass

Emission

Rate (kg/hr.)

Concentration

(mg/Nm 3 )

IPCL limit

(mg/Nm3)

Average

quarterly

mass

emission

(kg/hr.)

Emission

point

hours for

year

Mass

Emission

(kg) for

year Complia

nces

No. o

f Samples

TOC (as C) 1 1.070 148.80 300 1.422 2,729 3,881 3 32 1.396 289.00 3003 1.800 235.00 3004 not in service not in service 300

Particluate 1 n/a n/a #DIV/0! 2,729 #DIV/0! 0 0

2 n/a n/a

3 n/a n/a

4 not in service not in service

(ix) A2‐8

Parameter Qtr.

Mass

Emission

Rate (kg/hr.)

Concentration

(mg/Nm 3 )

IPCL limit

(mg/Nm3)

Average

quarterly

mass

emission

(kg/hr.)

Emission

point

hours for

year

Mass

Emission

(kg) for

year Complia

nces

No. o

f Samples

TOC (as C) 1 1.170 126.40 300 1.956 894 1,748 4 42 2.572 280.00 3003 2.500 228.00 3004 1.580 205.00 300

Particluate 1 n/a n/a 0.010 894 9 1 1

2 n/a n/a

3 n/a n/a

4 0.010 1.00

(x) A2‐9

Parameter Qtr.

Mass

Emission

Rate (kg/hr.)

Concentration

(mg/Nm 3 )

IPCL limit

(mg/Nm3)

Average

quarterly

mass

emission

(kg/hr.)

Emission

point

hours for

year

Mass

Emission

(kg) for

year Complia

nces

No. o

f Samples

Particulate 1 0.100 0.62 10 0.042 3,636 151 4 42 0.030 1.84 103 0.016 1.00 104 0.020 1.00 10

n/a

n/a

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Summary Information

(xi) A2‐10

Parameter Qtr.

Mass

Emission

Rate (kg/hr.)

Concentration

(mg/Nm 3 )

IPCL limit

(mg/Nm3)

Average

quarterly

mass

emission

(kg/hr.)

Emission

point

hours for

year

Mass

Emission

(kg) for

year Complia

nces

No. o

f Samples

Particulate 1 0.043 2.93 10 0.045 3,712 165 4 42 0.039 2.35 103 0.076 5.30 104 0.020 1.00 10

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Waste Arisings

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2.1.3 Waste Arisings 2.1.3.1 Waste Collection and Disposal 2011

Whereas all of the companies below have been used in the past those shaded were not used in 2011.

Waste Material Broker Waste Haulier Ultimate Disposal / Recovery

Contractor

Ultimate Destination of

Waste (see note 1)

1. Paint Related Material

Indaver Ireland, 4 Haddington Terrace, Dun Laoghaire, Co. Dublin www.indaver.ie


Abfall-Verwertungs Gesell echaft mbH (AVG), Borsigstrasse 2, 22113 Hamburg, Germany www.avg-hamburg.de


Johnston Haulage Company Ltd., Blackchurch, Rathcoole, Co. Dublin

Afvalstoffen Terminal Moerdijk B.V. (ATM), Vlasweg 12, 4782 PW Moerdijk, Netherlands www.atmmoerdijk.nl

ATM

S. Transport, Centre Park Road, Cork.

Tank Trans Ltd., Promenade Road, Tolka Quay, Dublin 3

Nehlsen GmbH & CO. KG, Louis-Kragas Strasse 10, D-28237 Bremen, Germany www.nehlsen.com

Nehlsen GmbH

J.P. Ryan & Sons, Bond Drive Extension, Dublin Port, Dublin 3

http://www.indaver.ie/


http://www.avg-hamburg.de/


http://www.atmmoerdijk.nl/

http://www.nehlsen.com/

Waste Arisings

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Contractor


Waste (see note 1)

Paint Related Material

SRCL/Ecosafe Systems Ltd., Unit 1A, Allied Industrial Estate, Kylemore Road, Ballyfermot, Dublin 10 www.ecosafesystems.ie www.srcl.com


Recyfuel, Zoning Industriel d’EHein, B-4480 Engis, Belgium www.recyfuel.be

Recyfuel

Lindenschmidt KG Umweltservice, Krombacher Strasse 42-46, 57223 Kreuztal-

Krombach, Germany www.lindenschmidt.de

Lindenschmidt KG

2. Paint solids from Abatement Booth

Kerry County Council

Killarney Waste Disposal Ltd., Aughacureen, Killarney. www.kwd.ie


North Kerry Landfill, Muingnaminnane Tralee, County Kerry

3. Scrubber liquor from Abatement Booth




Killarney Sewage Treatment Plant.

http://www.ecosafesystems.ie/

http://www.srcl.com/

http://www.recyfuel.be/

http://www.lindenschmidt.de/

http://www.kwd.ie/

http://www.kwd.ie/

Waste Arisings

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Contractor


Waste (see note 1)

4. Contaminated Oils: Oil, Oil Emulsion, Oily rags, Oil & Grinding Dust/ Grease/ Diesel




AVG

S. Transport, Centre Park Road, Cork.

Afvalstoffen Terminal Moerdijk B.V. (ATM), Vlasweg 12, 4782 PW Moerdijk, Netherlands www.atmmoerdijk.nl

ATM


Nehlsen GmbH & CO. KG, Louis-Kragas Strasse 10, D-28237 Bremen, Germany www.nehlsen.com

Nehlsen GmbH


SRCL/Ecosafe Systems Ltd., Unit 1A, Allied Industrial Estate, Kylemore Road, Ballyfermot, Dublin 10 www.ecosafesystems.ie www.srcl.com


Recyfuel, Zoning Industriel d’EHein, B-4480 Engis, Belgium www.recyfuel.be

Recyfuel

Lindenschmidt KG Umweltservice, Krombacher Strasse 42-46, 57223 Kreuztal-

Krombach, Germany www.lindenschmidt.de

Lindenschmidt KG




http://www.atmmoerdijk.nl/

http://www.nehlsen.com/

http://www.ecosafesystems.ie/

http://www.srcl.com/

http://www.recyfuel.be/

http://www.lindenschmidt.de/

Waste Arisings

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Contractor


Waste (see note 1)

5. Oil Enva Ireland, Clonminam Industrial Estate, Portlaoise, Co. Laois. www.enva.ie

Enva Ireland, Clonminam Industrial Estate, Portlaoise, Co. Laois. www.enva.ie



6. Oil Filters Enva Ireland, Clonminam Industrial Estate, Portlaoise, Co. Laois. www.enva.ie



R.D. Recycling N.V., Centrum Zuid 3017, 3530 Houthalen, Belgium

7.

Kerosene degreaser

Safety Kleen Ltd Unit 5, Airton Road, Tallaght, Dublin 24

Safety Kleen Ltd Unit 5, Airton Road, Tallaght, Dublin 24



Solvent Resource Management Ltd. (SRM), Weeland Road, Knottingley, West Yorkshire, WF11 8DZ, UK.

SRM UK

8. Fluorescent Lamps

Irish Lamp Recycling Co. Ltd., Blackpark, Kilkenny Rd., Athy, Co. Kildare www.ilr.ie



Mercury-Claushuis Metaalmaatschappij, 3899AH Zeewolde, Holland. www.claushuis.nl End Caps & Glass –

MSM Recycling / National Waste Management Ltd, 41 Cookstown Industrial Estate, Tallaght, Dublin 24 www.msmrecycling.com

http://www.enva.ie/

http://www.enva.ie/

http://www.enva.ie/

http://www.enva.ie/

http://www.enva.ie/

http://www.enva.ie/

http://www.enva.ie/

http://www.enva.ie/

http://www.enva.ie/

http://www.ilr.ie/

http://www.ilr.ie/

http://www.ilr.ie/

http://www.claushuis.nl/

http://www.msmrecycling.com/

Waste Arisings

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Contractor


Waste (see note 1)

9. Batteries Irish Lamp Recycling Co. Ltd., Blackpark, Kilkenny Rd., Athy, Co. Kildare www.ilr.ie


KMK Metals Recycling Ltd, Cappincur Industrial Estate, Daingean Road, Tullamore, Co. Offaly. www.metalsrecycling.ie


10. Lead-acid batteries




Campine Recycling NV, Nijverheidsstraat 2, 2340 Beerse, Belgium www.campine.be

11. Waste Electrical & Electronic Equipment





12. Aerosol Containers



Remondis Industrie Service GmbH, Austrasse 5, D-74238 Krautheim, Germany (Formerly SBH)

Remondis Industrie Service GmbH, Austrasse 5, D-74238 Krautheim, Germany (Formerly SBH)

http://www.ilr.ie/

http://www.ilr.ie/

http://www.metalsrecycling.ie/


http://www.enva.ie/

http://www.enva.ie/

http://www.enva.ie/

http://www.campine.be/

http://www.ilr.ie/

http://www.ilr.ie/

http://www.ilr.ie/


http://www.enva.ie/

http://www.enva.ie/

Waste Arisings

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Contractor


Waste (see note 1)

13. Steel Scrap

One51 ES Metals (Ireland) Ltd. TA Hegarty Metals, Galway Metal, A1 Metal, Cork Metal. c/o Hegarty Metals Processors (International) Ltd., Ballysimon Rd., Limerick www.hegartymetals.com

One51 ES Metals (Ireland) Ltd.






C.F. Booth Ltd., Clarence Metal Works, Armer Street, Rotherham, Yorkshire, UK, S60 1AF www.cfbooth.com

Molloy Metals Recycling Ltd., Tomgarrow, Ballycarney, Enniscorthy, Co.Wexford

14. Steel Shavings





http://www.hegartymetals.com/

http://www.kwd.ie/

http://www.kwd.ie/

http://www.kwd.ie/

http://www.cfbooth.com/


Waste Arisings

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Contractor


Waste (see note 1)

15. Copper Cables





16. Brass Scrap One51 ES Metals (Ireland) Ltd. TA Hegarty Metals, Galway Metal, A1 Metal, Cork Metal. c/o Hegarty Metals Processors (International) Ltd., Ballysimon Rd., Limerick www.hegartymetals.com




17. Timber Killarney Waste Disposal Ltd., Aughacureen, Killarney. www.kwd.ie



Woodchip sold to Eirebloc Ltd., Lissarda, Macroom, Co. Cork www.eirebloc.com



http://www.kwd.ie/

http://www.kwd.ie/

http://www.kwd.ie/

http://www.eirebloc.com/

Waste Arisings

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Contractor


Waste (see note 1)

18. Cardboard Killarney Waste Disposal Ltd., Aughacureen, Killarney. www.kwd.ie


Peute Papierrecycling, Baanhoekweg 4, 3313 LA Dordrecht, Netherlands www.peute.nl


19. Paper





20. General Domestic Waste




North Kerry Landfill, Muingnaminnane Tralee, County Kerry

21. Sewage

--- Pipeline --- Killarney Sewage Plant

http://www.kwd.ie/

http://www.kwd.ie/

http://www.peute.nl/


http://www.kwd.ie/

http://www.kwd.ie/



http://www.kwd.ie/

http://www.kwd.ie/

Waste Arisings

- 23 -


Contractor


Waste (see note 1)

22. Toner Cartridges

Systems 2000 Hill house Harbour veiw Kilbritain Co Cork

Systems 2000 Hill house Harbour veiw Kilbritain Co Cork

K2 Supplies (ERS Europe), D1 Longmead Business Centre, Felstead Road, Epsom, Surrey KT19 9QG, UK www.k2supplies.com/ K2 Supplies is a trading name of ERS Europe Ltd

K2 Supplies (ERS Europe), D1 Longmead Business Centre, Felstead Road, Epsom, Surrey KT19 9QG, UK www.k2supplies.com/ K2 Supplies is a trading name of ERS Europe Ltd

Recycling Appeal Unit 19 Ashbourne Ind Estate Ashbourne Co Meath. www.recyclingappeal.ie

Recycling Appeal Unit 19 Ashbourne Ind Estate Ashbourne Co Meath. www.recyclingappeal.ie

Redeem Plc t/a Recycling Appeal & Money4 URMobile, Unit No. 19, Ashbourne Industrial Estate, Ashbourne, Co. Meath. www.redeemplc.com www.recyclingappeal.ie

Redeem Plc t/a Recycling Appeal & Money4 URMobile, Unit No. 19, Ashbourne Industrial Estate, Ashbourne, Co. Meath. www.redeemplc.com www.recyclingappeal.ie

23. Glass Killarney Waste Disposal Ltd., Aughacureen, Killarney. www.kwd.ie


Glassco Recycling Ltd., Unit 4 Oberstown Business Park, Carragh Road, Naas, Co. Kildare www.rehabglassco.ie

Glassco Recycling Ltd., Unit 4 Oberstown Business Park, Carragh Road, Naas, Co. Kildare www.rehabglassco.ie

24. Plastic (plastic packaging, bottles, etc.)



Choice Waste Management Ltd., Denmark House, Brick Close, Milton Keynes, Buckinghamshire, MK11 3DP, UK www.choicewastemanagement.com

Choice Waste Management Ltd., Denmark House, Brick Close, Milton Keynes, Buckinghamshire, MK11 3DP, UK www.choicewastemanagement.com

http://www.k2supplies.com/

http://www.k2supplies.com/

http://www.recyclingappeal.ie/


http://www.redeemplc.com/


http://www.redeemplc.com/


http://www.kwd.ie/

http://www.kwd.ie/

http://www.rehabglassco.ie/

http://www.rehabglassco.ie/

http://www.kwd.ie/

http://www.kwd.ie/

http://www.choicewastemanagement.com/




Waste Arisings

- 24 -


Contractor


Waste (see note 1)

25. Dry Recyclables (paper, cardboard, plastic packaging, bottles, etc.)



Waste separated by KWD and sent to individual ultimate disposal contractors detailed.

Waste separated by KWD and sent to individual ultimate disposal contractors detailed.

26. Food Waste (for compost)



O'Toole Composting, Ballintrane, Co.Carlow www.otoolecomposting.ie

O'Toole Composting, Ballintrane, Co.Carlow www.otoolecomposting.ie

27. Cooking Oil/Fat Frylite (Dublin) Limited, Unit J1, Ballymount Industrial Estate, Dublin 12 www.frylite.com

Frylite (Dublin) Limited, Unit J1, Ballymount Industrial Estate, Dublin 12 www.frylite.com

Frylite Ltd, 34 Market Street, Strabane Co Tyrone, BT82 8 BH www.frylite.com

Frylite Ltd, 34 Market Street, Strabane Co Tyrone, BT82 8 BH www.frylite.com

28. Transformers and Capacitors (containing PCB)

Indaver Ireland, 4 Haddington Terrace, Dun Laoghaire, Co. Dublin


SITA Decontamination, 97 Westvaartdijk, 1850 Grimbergen, Belgium.

SITA Decontamination, 97 Westvaartdijk, 1850 Grimbergen, Belgium.

http://www.kwd.ie/

http://www.kwd.ie/

http://www.kwd.ie/

http://www.kwd.ie/

http://www.otoolecomposting.ie/

http://www.otoolecomposting.ie/

http://www.frylite.com/




Waste Arisings

- 25 -


Contractor


Waste (see note 1)

29. Soil and Stones n/a ML Lynch Civil Engineering Ltd., Brewsterfield, Headford, Killarney, Co. Kerry.

Patrick Lynch, Knockeenduff, Killarney, Co. Kerry. Waste Permit: WFP-KY-09-0004-01

____________ Shane O'Callaghan, Kilcummin GAA Club, Clashnagarrane, Kllcummin, Killarney, Co. Kerry. Waste Permit: WFP-KY-D9-002-01

____________ Mark Hallissey, Ards, Fossa, Killarney, Co. Kerry

____________ Killarney Waste Disposal, Sheans East, Killarney, Co. Kerry WP-08-10

Patrick Lynch, Knockeenduff, Killarney, Co. Kerry. Waste Permit: WFP-KY-09-0004-01

____________ Shane O'Callaghan, Kilcummin GAA Club, Clashnagarrane, Kllcummin, Killarney, Co. Kerry. Waste Permit: WFP-KY-D9-002-01

____________ Mark Hallissey, Ards, Fossa, Killarney, Co. Kerry

____________ Killarney Waste Disposal, Sheans East, Killarney, Co. Kerry WP-08-10

n/a Sugrue Excavations Ltd. Gortbee, Beaufort, Killarney, Co. Kerry

n/a

Nigel O'Connor, Coolgarriv, Killarney, Co. Kerry,

n/a

Healy Rae Plant Hire Ltd., Main St., Kilgarvan, Co. Kerry

Waste Arisings

- 26 -

2.1.3.2 Waste Contractor Licences and Permits

Contractor/Sub-contractor EPA (or relevant agency)

Licence No. Expiry Date

Waste Mgt./Facility Permit No.

Expiry Date Waste Collector

Permit No. Review Date

Indaver Ireland Ltd. W0036-2 Irish EPA

N/A WCP-DC-08-1121-01 Dublin City Council

30/04/2014

Nehlsen (Germany) D33300040 / 430 U

Free Hanseatic City of Bremen N/A

AVG (Germany) IB2234/AVG-GENB-2

Freie und Hansestadt Hamburg N/A

SITA (Belgium)

D/PMVC/01F28/33629 Department of economic affairs and

self-employed, agriculture horticulture, the environment

N/A

ATM (Netherlands) 1538449 Provincie Noord-Brabant

14/07/2019

JP Ryan and Sons Ltd. WCP-CK-09-0696-01 18/02/2015

Tank Trans WCP-DC-09-1213-01 24/09/2014

SRCL/EcoSafe Systems Ltd. W0054-2

Irish EPA N/A

Recyfuel P-ENV07-01

Provice de Liege, Commune de Engis N/A

Lindenschmidt KG Umweltservice 04 714 98089

Tüv Nord N/A

Tank Trans WCP-DC-09-1213-01 24/09/2014

Waste Arisings

- 27 -






Killarney Waste Disposal Ltd. (KWD) W0217-01

Irish EPA N/A

WCP-LK-08-72-04 Limerick/Kerry County

Councils 22/12/2013

Kerry County Council W0001-04

Irish EPA N/A

Eirebloc Ltd.

WFP-CK-11-0087-02

Cork County Council

7/11/2012

Peute Papierrecycling DO 02.2017 MDO DO2874 City Municipality of Dordrecht

Glassco Recycling Ltd.

WFP-KE-08-0357-01

Kildare County Council

09/03/2015

O’Toole Composting

WFP-CW-10-0003-01

Carlow County Council

3/08/2015

C.F. Booth Ltd. EAWML61595 Environment Agency, UK.

N/A

Choice Waste Management Ltd. CB/WE5536VU Environment Agency, UK

20/11/2013

Frylite (Dublin) Ltd. WCP-DC-10-1297-01

Dublin City Council 20/01/2016

Frylite Ltd. LN/08/11

Environment & Heritage Service, NI

Waste Arisings

- 28 -






One51 ES Metals (Ireland) Ltd. (inc. Hegarty Metals, Galway Metal, A1 Metal, Cork Metal)

WFP-LKC-11-001-01

Limerick County Council

31/03/2016 WCP/LK/08/589-01 Limerick County Council

24/02/2014

Enva Ireland (formerly Atlas/SES) W0184-01

Irish EPA

WCP- DC-08-1116-01 Dublin City Council

16/04/2014

R.D. Recycling N.V. 023.03.10/V2005NO14639 Belgian Authorities

Remondis Industrie Service GmbH H 09037950

Cert No. 11HRO03003 29/09/2012

Campine, Belgium OVAM Certificate

Safety Kleen W0099-01 Irish EPA

N/A WCP-DC-09-1223-01 Limerick County Council

23/12/2014

Solvent Resource Management Ltd TP3334SF Environment Agency, UK

N/A

Irish Lamp Recycling

WFP-KE-08-0348-01

Kildare County Council

25/02/2014 WCP-DC-08-1115-01

Dublin City Council 5/03/2014

Claushuis Metaalmaatschappij BV MB/04.040267/L GS van Flevoland

1/08/2013

MSM Recycling / National Waste Management Ltd.

W0079-01 Irish EPA

N/A

KMK Metals Recycling Ltd. 113-2 Irish EPA

N/A

Waste Arisings

- 29 -






Systems 2000 N/A – incidental to

main business activity; less than 2t

K2 Supplies (ERS Europe) CB/EP3110QM

Environment Agency, UK 20/05/2013

Recycling Appeal/Redeem PLC WFP/MH/09/00

04/01 Meath County Council

20/11/2014 WCP-DC-09-1187-01 Dublin City Council

28/07/2014

Patrick Lynch WFP-KY-09-

0004-01 Kerry County Council

21/01/2015

Kilcummin GAA Club WFP-KY-D9-


16/12/2014

Mark Hallissey COR-KY-11-


23/08/2012

Killarney Waste Disposal WP-08-10 Kerry County Council

09/10/2011

Ml. Lynch Civil Engineering Ltd. WCP-LK-09-602-01 Limerick/Kerry/Clare

County Councils 19/05/2014

Sugrue Excavations Ltd. WCP-LK-10-S41-02 Limerick/Kerry/Clare


Nigel O’Connor WCP-LK-10-S04-02 Limerick/Kerry/Clare


Waste Arisings

- 30 -






Healy Rae Plant Hire Ltd. WCP-LK-11-678-01 Limerick/Kerry/Clare


Notes 1. Copies of permits and licences including details of the ultimate disposal/recovery destination facility for the wastes and its appropriateness to accept the

consigned waste streams, including permit details and issuing authority, are held on file in accordance with IPPC Licence condition 11.9 (iii)

2.1.3.3 Annual Waste Arisings ‐ Hazardous WasteWaste Management Option

Waste Material

EWC

Code Source t

On‐site

treatment On‐Site Recovery Off‐Site Recovery On‐Site Disposal Off‐Site Disposal

Method t Method t Method t Method t

Paint Related Material 080111 Spray Painting 51.31 N/A N/A 0 R3/R4 51.31 N/A 0 Incineration 0

Paint Solvent 080121 Spray Painting 3.76 Yes N/A 0 R3/R4 3.76 N/A 0 N/A 0

Kerosene 110113 Degreasing 0.50 N/A N/A 0 R13 0.50 N/A 0 N/A 0

Oil Emulsion 120109 Metal Machining 1.96 N/A N/A 0 R3/R4 1.96 N/A 0 N/A 0

Metal grinding dust with oil 120120 Grinding machine 0.00 N/A N/A 0 N/A 0.00 N/A 0 D10 0

Oil 130208 Vehicles and machinery 3.42 N/A N/A 0 R9 3.42 N/A 0 N/A 0

Oily Water 130507 Interceptor cleanout 7.00 N/A N/A 0 R9 7.00 N/A 0 N/A 0

Oil/grease 130899 Waste from maintenance 0.00 N/A N/A 0 N/A 0.00 N/A 0 D10 0

Paint‐related Material (paint cans) 150110 Spray Painting 10.87 N/A N/A 0 R3/R4 10.87 N/A 0 N/A 0

Absorbant material 150202 Minor spillages 0.08 N/A N/A 0 R1 0.08 N/A 0 N/A 0

Oil filters 160107 Vehicles and machinery 0.00 N/A N/A 0 R3 0.00 N/A 0 N/A 0

Aerosols 160504 welding, lubrication, etc. 0.96 N/A N/A 0 R12 0.96 N/A 0 N/A 0

Lead‐acid batteries 160601 Vehicles 0.46 N/A N/A 0 R4 0.46 N/A 0 N/A 0

Fluorescent lamps 200121 Company lighting 0.12 N/A N/A 0 R5 0.12 N/A 0 N/A 0

Batteries 200133 Various instruments 0.05 N/A N/A 0 R4/R5 0.05 N/A 0 N/A 0

Electrical & Electronic Equipment 200135 Various 0.45 N/A N/A 0 R12 0.45 N/A 0 N/A 0

Totals 80.93 0 80.93 0 0

‐ 31 ‐ 2012 AER 2.1.3.3&4&5 haz waste

2.1.3.4 Hazardous Waste sent off‐site for Recovery/Disposal

Consignment

Note Number

(Form C1)

Date of

DespatchWaste Material EWC Code t Description & Nature of Waste Broker

Haulage

Contractor

Recovery /

Recycling

Contractor

Disposal

Contractor

Collection/ Disposal

Cert. No. (Note 3)

B 607751 10/01/11 Fluorescent/Gas‐ discharge Lamps 200121 0.02 Bulbs containing mercury vapourIrish Lamp

Recycling (ILR)ILR ILR N/A 19380

B 607751 10/01/11 Electrical & Electronic Equipment 200135 0.10 Miscellaneous componentsIrish Lamp


B 528645 25/01/11 Paint Related Material 080111 9.99 Note 2 Indaver Tank TransNehlsen,

GermanyN/A IE312944/27

B 528645 25/01/11 Paint thinners 080121 0.74Waste paint thinners containing

xyleneIndaver Tank Trans

Nehlsen,


B 528645 25/01/11 Paint Related Material (paint cans) 150110 4.63 Metal paint cans with paint residue Indaver Tank TransNehlsen,


B 607696 04/03/11 Aerosols 160504 0.30 Aerosols Enva Enva Remondis N/A 18095





B 607773 24/03/11 Batteries 200133 0.04 Waste unsorted batteriesIrish Lamp

Recycling (ILR)ILR KMK Metals N/A 19570





Nehlsen,




B 607809 23/03/11 Degreaser 110113 0.12 Kerosene Safetykleen Safetykleen SRM, UK N/A March 2011

B 607821 16/06/11 Degreaser 110113 0.12 Kerosene Safetykleen Safetykleen SRM, UK N/A June 2011

B 608102 05/07/11 Oily Water 130507 7.00 Oil separator cleanout Enva Enva Enva N/A 0004104827





B 608627 20/07/11 Aerosols 160504 0.36 Aerosols Enva Enva Remondis N/A 19578

‐ 32 ‐

2.1.3.4 Hazardous Waste sent off‐site for Recovery/Disposal

Consignment

Note Number

(Form C1)

Date of

DespatchWaste Material EWC Code t Description & Nature of Waste Broker

Haulage

Contractor

Recovery /

Recycling

Contractor

Disposal

Contractor

Collection/ Disposal

Cert. No. (Note 3)





Nehlsen,




B 608730 16/09/11 Degreaser 110113 0.12 Kerosene Safetykleen Safetykleen SRM, UK N/A September 2011





n/a 27/09/11 Oil 130208 3.42 Waste mineral oils Enva Enva Enva N/A 0002149250





B 607761 23/11/11 Batteries 200133 0.01 Waste unsorted batteriesIrish Lamp

Recycling (ILR)ILR KMK Metals N/A 20165

B 608658 28/11/11 Aerosols 160504 0.30 Aerosols Enva Enva Remondis N/A cert awaited

B 608658 28/11/11 Lead acid batteries 160601 0.46 Lead acid batteries Enva Enva Campine n/a 19739

B 608737 30/11/11 Degreaser 110113 0.12 Kerosene Safetykleen Safetykleen SRM, UK N/A November 2011

B 608521 06/12/11 Paint Related Material 080111 14.08 Note 2 EcoSafe/SRCL Tank TransLindenschmidt,

GermanyN/A IE 314043


xyleneEcoSafe/SRCL Tank Trans

Lindenschmidt,


B 608521 06/12/11 Oil Emulsion 120109 1.96Coolant ‐ >90% water, & <10%

mineral oil.EcoSafe/SRCL Tank Trans

Lindenschmidt,


B 608521 06/12/11 Paint Related Material (paint cans) 150110 0.18 Metal paint cans with paint residue EcoSafe/SRCL Tank TransLindenschmidt,

GermanyN/A cert awaited

B 608521 06/12/11 Absorbant material 150202 0.08absorbant of nuisance paint

spillageEcoSafe/SRCL Tank Trans

Lindenschmidt,

GermanyN/A cert awaited

Notes: 1. Any Consignments rejected must be recorded as a * in the first column and details presented in an attachment.

2. 95% Paint solids with 5% liquid containinng Xylene, Aliphatic Hydrocarbons, Polyamide & epoxy resins

‐ 33 ‐

2.1.3.6 Annual Waste Arisings ‐ Non‐Hazardous Waste Totals

Waste Material

EWC

Code Source t

On‐site

treatment

Method t Method t Method t Method t

Abatement Water 080199 Paint spray booth 68.2 N/A N/A 0.0 R5 ‐ water treatment 68.2 N/A 0.0 N/A 0.0

Toner Cartridges 080318 Printers, copiers, etc. 0.2 N/A N/A 0.0 R3 ‐ Re‐use 0.2 N/A 0.0 N/A 0.0

Steel Shavings 120101 Steel Machining 211.9 N/A N/A 0.0 R4 ‐ Melting 211.9 N/A 0.0 N/A 0.0

Bronze Shavings 120103 Bronze Machining 1.8 N/A N/A 0.0 R4 ‐ Melting 1.8 N/A 0.0 N/A 0.0

Cardboard 150101 Packaging 14.7 N/A N/A 0.0 R3 ‐ pulped & blended 14.7 N/A 0.0 N/A 0.0

Plastic 150102 Packaging ‐ shrink wrap 0.9 N/A N/A 0.0 R3 ‐ sorted for recycling 0.9 N/A 0.0 N/A 0.0

Dry Recyclables 150106 Plastic packaging, bottles, etc. 8.7 N/A N/A 0.0 R3 ‐ sorted for recycling 8.7 N/A 0.0 N/A 0.0

Soil and stones 170504 Site clearance 89,700.0 N/A N/A 0.0 R10 ‐ landspreading 89,700.0 N/A 0.0 N/A 0.0

Paper 200101 Office waste 18.2 N/A N/A 0.0 R3 ‐ pulped & blended 18.2 N/A 0.0 N/A 0.0

Glass 200102 broken/replaced windows 0.0 N/A N/A 0.0 R5 ‐ glass recycling 0.0 N/A 0.0 N/A 0.0

Canteen food 200108 Canteen 5.9 N/A N/A 0.0 R3 ‐ Composting 5.9 N/A 0.0 N/A 0.0

Timber 200138 Packaging, Pallets, etc. 163.8 N/A N/A 0.0 R3 ‐ Chipping 163.8 N/A 0.0 N/A 0.0

General Steel 200140 Steel Fabrication 2,208.7 N/A N/A 0.0 R4 ‐ Melting 2,208.7 N/A 0.0 N/A 0.0

Copper Cables 200140 Cores from electric cables 4.2 N/A N/A 0.0 R4 ‐ Melting 4.2 N/A 0.0 N/A 0.0

General Domestic 200301 General Domestic 180.7 N/A N/A 0.0 N/A 0.0 N/A 0.0 D1 ‐ Landfill 180.7

Totals 92,587.8 0.0 92,407.2 0.0 180.7

On‐Site DisposalOff‐Site RecoveryOn‐Site Recovery Off‐Site Disposal

Waste Management Option

‐ 34 ‐

- 35 -

2.2 Agency Monitoring and Enforcement 2.2.1 Emissions sampling and analysis by Agency laboratory staff

Emissions monitoring of LCC storm water was carried out on 05/12/2011 by David Galvin – the result was compliant with the IPPC licence.

2.2.2 Site visits & inspections by an Agency Inspector

One site inspection was conducted by EPA inspectors in 2011. This took place on 24/03/11, the inspector being Ms. Maria Lenihan. No non-compliance was raised during the visit.

2.2.3 Detailed Audit of facility carried out by Agency personnel

The last formal audit of LCC was conducted by the EPA on 21/11/02 – Mr. Sean O’Donoghue (lead auditor), Mr. John Feehan (inspector). No non-conformances were raised during the audit.

2.3 Energy and Water Consumption

2.3.1 Energy Consumption

Parameter \ Year 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

Electricity (MWh) 4,235 4,465 4,369 4,573 5,021 5,426 6,204 6,327 5,959 6,655

Diesel (m3) - heating 236 231 224 222 174 144 244 219 258 219

Diesel (m3) - transport 78 78 79 74 113 94 98 87 85 101

Acetylene (m3-gas) 22,179 22,907 22,374 21,492 21,078 18,252 18,998 23,635 19,576 23,356

LPG (litres) 173,933 175,171 155,187 195,056 318,913 311,264 450,729 342,039 606,514 610,928

0

2,000

4,000

6,000

8,000

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

MW

h

Year

Electricity Consumption

0

100

200

300

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

Cu

bic

Met

res

Year

Diesel Consumption

Diesel (m3) - heating Diesel (m3) - transport

- 36 -

0

5,000

10,000

15,000

20,000

25,000

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

Cu

bic

Met

res

Year

Acetylene Consumption

0 100,000 200,000 300,000 400,000 500,000 600,000 700,000

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

Cu

bic

Met

res

Year

LPG (litres)

- 37 -

2.3.2 Water Consumption

Parameter \ Year 2002 2003* 2004 2005 2006 2007 2008* 2009* 2010 2011

Water (m3) 3,367 10,618 5,329 5,250 6,716 5,732 19,469 17,517 6,572 23,694

Note: Underground leaks in an incoming water pipes during 2003, 2008/2009, and 2011 accounts for the high consumption for these years.

These have been repaired.

Consumption figures have sometimes been revised where meter readings were received after first publication and estimated figures corrected.

0

5,000

10,000

15,000

20,000

25,000

2002 2003* 2004 2005 2006 2007 2008* 2009* 2010 2011

Cu

bic

Met

res

Year

Water Consumption

- 38 -

Environmental Incidents &Complaints

- 39 -

2.4 Environmental Incidents and Complaints 2.4.1 Environmental Incidents 2.4.1.1 Any release to atmosphere from any potential emission point

Licensed/agreed emission points only. 2.4.1.2 Any emission which does not comply with the requirements of the licence.

See table below. 2.4.1.3 Any malfunction or breakdown of control equipment or monitoring equipment which is likely

to lead to loss of control of the abatement system.

See table below. 2.4.1.4 Any incident with the potential for environmental contamination of surface water or

groundwater, or posing an environmental threat to air or land, or requiring an emergency response by the Local Authority.

Nuisance (negligible) spillages only, cleaned up with proprietary absorbents.

Incident

Detected By

Date Action Taken Authority Contacted

Non-compliant emission at SE1: pH 11.0 (limit 6-9), during 3rd quarter emissions monitoring.

Southern Scientific Services

27/09/11 High pH from stagnant water in oil separator which was out of service for several months – high pH attributed to run-off from newly poured concrete yard (cement pH 13).

EPA

Non-compliant emission at SE1: Oils, fats & grease 39.8 mg/l (ELV 10 mg/l), during 4th quarter emissions monitoring.

Southern Scientific Services

17/11/11 Cause uncertain – may be linked to previous non-compliance. Report received on 20/02/12.

Oil separator emptied, checked and returned to service on 29/02/12.

EPA

Environmental Incidents &Complaints

- 40 -

2.4.2 Complaints 2.4.2.1 No complaints were received in respect of odour from the site. 2.4.2.2 No complaints were received in respect of noise from the site. 2.4.2.3 No complaints were received in respect of water from the site. 2.4.2.4 No procedural complaints were received in respect of the site. 2.4.2.5 No other complaints were received

Odour Noise Water Procedural Misc. Totals

Jan 0

Feb 0

Mar 0

Apr 0

May 0

June 0

July 0

Aug 0

Sept 0

Oct 0

Nov 0

Dec 0

Totals 0 0 0 0 0 0

Number of Complaints

PRTR

- 41 -

2.5 European Pollutant Release and Transfer Register (PRTR) for 2011 2.5.1 IPPC Licence Condition

“6.12 Pollutant Release and Transfer Register (PRTR) The licensee shall prepare and report a PRTR for the site. The substance and/or wastes to be included in the PRTR shall be as agreed by the Agency each year by reference to EC Regulations No. 166/2006 concerning the establishment of the European Pollutant Release and Transfer Register and amending Council Directives 91/689/EEC and 96/61/EC. The PRTR shall be prepared in accordance with any relevant guidelines issued by the Agency and shall be submitted electronically in specified format and as part of the AER.”

2.5.2 Scope of PRTR

The PRTR Regulation addresses 91 specific pollutants to be reported upon if they are released to air, water or land, either as permitted emissions or accidental releases, or transferred to off-site Waste Water Treatment Plants (WWTPs). The transfer of hazardous and non-hazardous wastes must also be reported. Annex II of the PRTR regulation lists the 91 specific pollutants including threshold values for releases to air, water and land. Where a release above any of these thresholds is made in a calendar year, this must be reported in the PRTR. In accordance with section 1.1.10 of the “European Commission Guidance Document for the implementation of the European PRTR”, operators shall report off-site transfers of

hazardous waste (HW) exceeding 2 tonnes per year

non-hazardous waste (non-HW) exceeding 2,000 tonnes per year

2.5.3 Methodology A review of the 91 specified pollutants as laid out in Annex II of the Regulation was carried out to identify those which are used or are present at LCC. Where it was anticipated that there could be a possibility of any of these pollutants approaching the threshold emission limits, a system was put in place for monitoring the emission for the year. One substance was identified with a potential to emit to air above the stated threshold:

Item No. 7 – Non-methane volatile organic compounds (NMVOC) – threshold for release to air = 100,000 kg/year.

Arrangements were made to quantify all deliberate, accidental, routine and non-routine releases to air with reference to section 1.1.11 of the guidance document. A mass balance approach was taken and the emission of NMVOC was established with the compilation of the PER Report in section 3.4. As a licensed emission, dust emissions were also measured quarterly and the annual mass emission calculated and compared to the PRTR threshold. Based on previous data it was established that LCC would most likely exceed the threshold stated in section 1.1.10 of the PRTR guidance of 2 tonnes for HW. For non-HW LCC has

PRTR

- 42 -

produced volumes both above and below the threshold of 2,000 tonnes in past years. Calculations would therefore need to be made to determine if this threshold would be exceeded during this reporting year. These calculations were made during the compilation of information for the Waste Arisings section of this annual report.

2.5.4 Releases to Air The PER report (section 3.4) revealed that NMVOC emission from LCC in 2011 was 78,323 kg, below the 100,000 kg/year threshold, but is included in the PRTR submission as a licensed emission. The dust emission for 2011 was negligible at 316 kg, but is included in the PRTR submission as a licensed emission

2.5.5 On-site Treatment and Off-site Transfers of Waste Comprehensive waste analysis for 2011 is contained in section 2.1.3 of this AER. The PRTR reporting threshold for hazardous waste (2 tonnes per year) was exceeded in 2011. This information has been entered into the EPA PRTR database. The PRTR reporting threshold for non-hazardous waste (2,000 tonnes per year) was also exceeded in 2011. This information has been entered into the EPA PRTR database.

A copy of the PRTR return is included in Appendix 2.

Schedule of Environmental Objectives and Targets

Next Review Date – by 31/03/2013

- 43 -

3. Management of the Activity 3.1 Schedule of Environmental Objectives and Targets These Objectives and Targets have been set in accordance with LCC Environmental System Procedure – Setting Objectives & Targets and IPPC licence no. P0146-02 Condition 2.2.2.2. These objectives and targets are set based upon the highest risk ratings Aspects and Associated Impacts Register and Rating Report reviewed annually.

Objectives Targets Aspect No.

EMP Project No.

1. Minimise VOC emissions to atmosphere (condition 2.2.2.2):

Further proposals to reduce solvent to atmosphere;

Fugitive Emissions Reduction Programme (condition 6.7);

Optimisation of spraying operations to increase coating efficiency (condition 2.2.2.2);

Conversion to in-line paint mixing equipment (condition 2.2.2.2);

Optimisation of solvent recovery and re-use (condition 2.2.2.2);

Substitution of solvent-based paints, with high-solids (lower solvent) coatings (condition 2.2.2.2)

Investigation carried out in line with BAT – on-going

Ongoing – see AER section 4.5

Substantially completed – residual improvements ongoing


ongoing

Investigation on-going.

2(a), 3(b)

N/A

2. Replacement of List I substances and substances with the risk phrase R40, R48, R50, R51, R52, R53 and R58 with less harmful alternatives (condition 2.2.2.2)

Diesel heating (R40) to be phased out in production buildings by March 2015

Paint replacement investigation ongoing (as practicable)

1(a), 2(a) 3/2012

3. Examination of the provision of a catchment system to collect any leaks from flanges and valves of all over-ground pipes used to transport material other than water for reduction of fugitive emissions (condition 3.11).

March 2015 – eliminate requirement for diesel transport in pipework, removal of diesel pipes and installation of catchment system for remaining non-water pipes.

1(a) 7/2012



- 44 -


EMP Project No.

4. Reduce risk of pollution to storm water (conditions 3.8.1 & 6.10.1):

Install interceptor(s) in storm water drainage system (conditions 3.8.1)

Separate roof water from yard run-off (condition 6.10.1)

2012-2013 for factory east; 2017 for factory west

2013 and ongoing with future factory developments

1(a) 4/2012

5/2012

5. Energy & Resource Management (condition 7.2):

Develop profile of energy usage through audit

Investigate and implement possible reduction measures

Replace old less efficient production equipment

Complete

Ongoing (refer to EMP projects)

Ongoing

8(a), 8(c), 8(d)

1/2012

2/2012

8/2012

9/2012

6. Reduce Water Usage (condition 7.3):

Investigate feasibility of rainwater harvesting;

Investigate feasibility of a groundwater well;

Investigate reduction/elimination of water use in production processes

2012-2013

2015

2015

8(b) 6/2012

7. Raw Material Efficiency (condition 7.4):

Review improvement possibilities and implement where feasible

Annual assessment 3 & 4 N/A

8. Improve waste management

Further reduction of hazardous waste

Identify additional waste streams with highest impact on landfill and propose reductions.


On-going

3, 4(g)

N/A



- 45 -


EMP Project No.

9. Rationalisation of the number of heaters/boilers at the installation (condition 2.2.2.2) – Phase out diesel-fired factory heating in favour of cleaner LPG – reduce CO2, NOX & SOX

March 2015 2(e), 8(c) 3/2012

3.2 EMP Report 2012 (Reporting Year 2011)

Additional Information

1Yes

2 Yes

3 Yes

4 Yes

Environmental Management Programme (EMP) reportObjective Category Target Status (% completed) How target was progressed Responsibility Intermediate outcomes

Energy Efficiency/Utility conservation

Project 1/2011

Energy Efficiency Audit:

Target Date - 30/03/2012

90

Audit has identified 5 general

areas for improvements in

energy efficiency to be made;

4 areas currently form active

projects underway with the

5th to be considered over the

next 2-3 years.

Section Head Installation of infrastructure


Project 2/2011

Energy Efficient Lighting:


20

Installation in new Boring &

Milling Hall completed; next

phase with the construction

of the New Fabrication Hall

East during 2012/2013



Project 3/2011

Efficient shot-blasting:


60

New machine selected and

schedule in place for supply

and installation by March

2013 (behind target)


Environmental Management Programme (EMP)/Continuous Improvement Programme

The EMS is in compliance with IPPC licence no. P0146-02,

condition 2.2; designed to conform with ISO 14001

Do you maintain an environmental documentation/communication system to inform the public on

environmental performance of the facility, as required by the licence

Highlighted cells contain dropdown menu click to view

Does the EMS reference the most significant environmental aspects and associated impacts on-site

Does the EMS maintain an Environmental Management Programme (EMP) as required in accordance

with the licence requirements

Do you maintain an Environmental Mangement System for the site. If yes, please detail in additional

information

- 46 -

3.2 EMP Report 2012 (Reporting Year 2011)

Environmental Management Programme (EMP) reportObjective Category Target Status (% completed) How target was progressed Responsibility Intermediate outcomes

Reduction of emissions to Air

Project 4/2011

'Cleaner' factory heating:


40

A phased transition from

diesel to LPG heating

underway building by

building; next phase with

conversion of layout hall in

2012; then the construction

of the New Fabrication Hall

East in 2012/2013.

Section Head Reduced emissions

Reduction of emissions to Water

Project 5/2011

Oil separaotrs/silt traps:


50

Investigations, feasibility

reports, design complete;

liaison with Agency in

progress; final decision

pending (behind target)

Section HeadIncreased compliance with

licence conditions

Reduction of emissions to Water

Project 6/2011

Roof/Yard water

separation:


10

Feasibility reports completed;

design work underway in

tandem with New Fabrication

Hall East.



Project 7/2011

Rainwater harvesting:


20

Feasibility established by

consulting engineers; design

work underway; construction

to be carried out with New

Fabrication Hall East.


Materials Handling/Storage/Bunding

Project 8/2011

Pipe leak catchment:


10

Relevant pipelines surveyed;

feasibility established to

remove all diesel pipelines

within 2 years, making leak

catchment system

unnecessary.

Section HeadIncreased compliance with

licence conditions

- 47 -

EMP Proposal 2012

- 48 -

3.3 Environmental Management Programme Proposal 2012

The following programme is proposed for EPA approval.

3.3.1 Project 1/2012

Installation of energy efficient lighting

Relationship to Objectives and

Targets:

This is linked to 2012 LCC objective number 5

Reason for undertaking

project:

Electricity consumption appears as the top rated item in the EMS Aspects

and Associated Impacts Register hierarchy of risk. Improving energy

efficiency is a goal of LCC both to continually improve environmental

performance and reduce operating costs. This is a continuation of

Project 2/2011. LCC’s energy audit has identified lighting as the highest

proportion of electricity consumption.

Target: End 2015

See Gantt chart for individual element targets

Progress

Project Summary: I. Source providers of high bay energy efficient

lighting

II. Select suitable replacement lighting

III. Install trial luminaries and monitor performance

IV. Evaluate environmental and cost benefits of

alternative lighting system and decide on

implementation

V. Install Prismalence energy efficient lighting in new

Boring & Milling Hall

VI. Project deferral until economic climate improves.

VII. Review energy efficient lighting options on the

market and select optimum solution

VIII. Construct New Fabrication Hall east and install

energy efficient lighting

IX. Review energy performance of new lighting

X. Install new lighting system in main fabrication hall,

if feasible (pending review).

XI. Review EMP for further phased-in of low energy

lighting.

100%

100%

100%

100%

100%

100%

100%

Designation of Responsibility: Manufacturing Director and Energy Management Engineer

EMP Proposal 2012

- 49 -

3.3.2 Project 2/2012

Investigate alternative energy-efficient technology for shot-blasting


Targets:

This is in line with 2012 LCC objective number 5


project:

Generation of compressed air for shot-blasting consumes the 2nd highest

proportion of electricity as identified in LCC’s energy audit. Investigation

of practicable opportunities for energy reduction is required under

condition 7.2 of IPPC Licence No. P0146-02. This is a continuation of

Project 3/2011.

Target: March 2013


Progress

Project Summary: I. Research alternative shot-blasting technologies

and suppliers

II. Review options and determine if practicable

III. Select supplier and purchase system

IV. Shot-blast machine manufacture (by supplier)

V. Installation works and commissioning

100%

100%

100%

20%

Designation of Responsibility: The Manufacturing Director and Paint Shop Supervisor are responsible

for this project.

EMP Proposal 2012

- 50 -

3.3.3 Project 3/2012

Install cleaner factory heating system


Targets:

This is linked to 2012 LCC objective numbers 3 & 9


project:

Emissions to atmosphere from diesel heaters/boilers appears as one of

the highest rated items of the EMS Aspects and Associated Impacts

Register. Minimisation of CO2, NOX and SOX from the site. This is a

continuation of Project 4/2011 as amended to incorporate changing

circumstances.

Target: Complete Factory changeover to LPG by March 2015

Final Assembly/Stores completed in 2000

Steel Fabrication 7AS completed in 2002

Cutting Hall 7AC completed at end 2006

Machine Room 7AM/Apprentice Shop/Maintenance MSM in 2010

Boring & Milling Hall in 2010

Layout Hall 7AF by Apr 2012

New Fabrication Hall East by Mar 2013

Steel Fabrication 7AF by March 2015

Progress

Project Summary: I. Final Assembly/Stores

II. Steel Fabrication 7AS

III. Cutting Hall (construct new hall/demolish old hall)

IV. Upgrade LPG vessel

V. Western building, remaining departments 7AM,

1LA & 2BC, pending review

VI. Boring & Milling Hall

VII. Review factory development plan

VIII. Layout Hall trial installation – combined heating

and fume extraction

IX. New Fabrication Hall East

X. Steel Fabrication 7AF

100%

100%

100%

100%

100%

100%

100%

50%

Designation of Responsibility: The manufacturing/project directors and the maintenance manager are

responsible for carrying out this project.

EMP Proposal 2012

- 51 -

3.3.4 Project 4/2012

Install storm water oil separators and silt traps


Targets:



project:

Site run-off appears in the top 10 highest rated items of the EMS Aspects

and Associated Impacts Register. Potential leak or spillage into storm

drains is the highest rated risk in the independent ELRA. This project is

also required under condition 3.8.1 of IPPC Licence No. P0146-02. This is

a continuation of Project 5/2011.

Target: March 2013 (eastern separators);

March 2017 (western separators)


Progress

Project Summary: I. Investigate oil separator options and feasibility of

direct installation.

II. Generate alternative design proposals for

installation

III. Review requirements for NFHE and design

proposals

IV. Select feasible design and liaise with EPA

V. Agree design and plan installation

VI. Installation (eastern oil separators x5)

VII. Review factory development plan

VIII. Installation (western oil separators x2)

100%

100%

100%

50%

50%

20%

Designation of Responsibility: The Manufacturing Director, Maintenance Manager and EHS Manager

are responsible for carrying out this project.

EMP Proposal 2012

- 52 -

3.3.5 Project 5/2012

Separation of Roof and Yard Storm Water Run-off


Targets:



project:

Site run-off appears in the top 10 highest rated items of the EMS Aspects

and Associated Impacts Register. Potential leak or spillage into storm

drains is the highest rated risk in the independent ELRA. This project is

also required under condition 6.10.1 of IPPC Licence No. P0146-02. This

is a continuation of Project 6/2011.

Target: March 2013 - See Gantt chart for individual element targets.

This project will be conducted in tandem with the development of the

new Fabrication Hall East and associated civil works

Progress

Project Summary: I. Conduct feasibility study and report

II. Design concept for separation system

III. Separation of Main Fabrication Hall, 7AF

IV. Separation of New Fabrication Hall East

100%

100%

Designation of Responsibility: The Manufacturing Director and Maintenance Manager are responsible

for carrying out this project.

EMP Proposal 2012

- 53 -

3.3.6 Project 6/2012

Water Conservation


Targets:



project:

In excess of 500 employees consume water from water mains on a daily

basis. Identification of opportunities for reduction in consumption of

water is specified under condition 6.10.1 of IPPC Licence No. P0146-02.

This is a continuation of Project 7/2011.

Target: March 2013 - See Gantt chart for individual element targets

This project will be conducted in tandem with the development of the

new Fabrication Hall East and associated civil works

Progress

Project Summary: I. Rainwater harvesting feasibility study.

II. Select location(s) and design system

III. Construction and plumbing installation.

IV. Commissioning

V. Investigate water meter data logger

VI. Installation where feasible

VII. Monitor water consumption

100%

100%

Designation of Responsibility: The Manufacturing Director, Maintenance Manager and EHS Manager

are responsible for carrying out this project.

EMP Proposal 2012

- 54 -

3.3.7 Project 7/2012

Examination of catchment system for over-ground liquid pipeline valves and flanges


Targets:



project:

Reduction of fugitive emissions, prevent site water run-off and

compliance with IPPC licence condition 3.11. This is a continuation of

Project 8/2011.

Target: March 2015 - See Gantt chart for individual element targets

This project is scheduled for completion over 2½ years to allow for

elimination of potentially redundant pipelines in line with planned

factory developments. It may be possible to completely eliminate

pipework with the completion of project 3/2012.

Progress

Project Summary: I. Survey over-ground pipelines for liquids other than

water.

II. Identify feasibility of pipework elimination and

develop removal plan.

III. Catalogue valves and flanges for remaining

pipework.

IV. Design system for catchment of leaks.

V. Install catchment system on pipework scheduled

to remain in service.

VI. Remove redundant pipework from service.

100%

50%

Designation of Responsibility: Maintenance Manager

EMP Proposal 2012

- 55 -

3.3.8 Project 8/2012

Insulation of Main Fabrication Hall


Targets:

This is in line with 2012 LCC objective number 5.


project:

Energy Efficiency

Target: 2014 - See Gantt chart for individual element targets

This project is scheduled for commencement following the construction

of the new Fabrication Hall East, to be completed within one year.

Progress

Project Summary: I. Survey building requirements

II. Establish insulation specification and bill of

materials

III. Tender process

IV. Building refurbishment

Designation of Responsibility: Manufacturing Director and Maintenance Manager

2012 AER 3.3 EMP Proposal Schedule.mpp

2012%20AER%203.3%20EMP%20Proposal%20Schedule.mpp

ID Task Name Start Finish

1 1/2012: Installation of energy efficient lighting Mon 01/10/07 Thu 31/12/15

2 Source providers Mon 01/10/07 Fri 30/11/07

3 Select suitable lighting system Mon 03/12/07 Mon 31/12/07

4 Trial installation & monitoring Wed 02/01/08 Mon 30/06/08

5 Evaluation & decision Tue 01/07/08 Fri 29/08/08

6 Lighting installation in boring & milling hall Mon 19/04/10 Fri 11/06/10

7 Project deferral pending review Fri 11/06/10 Fri 11/06/10

8 Review energy efficient lighting options Mon 02/01/12 Fri 13/04/12

9 Install (new Fabrication Hall East) Mon 16/04/12 Fri 29/03/13

10 Review energy performance of new lighting Mon 01/04/13 Thu 31/10/13

11 Install (Main Fabrication Hall) Fri 01/11/13 Thu 31/12/15

12 Review Thu 01/10/15 Thu 31/12/15

13

14 2/2012 Install alternative shot‐blast technology Fri 01/04/11 Fri 29/03/13

15 Research technologies and suppliers Fri 01/04/11 Thu 30/06/11

16 Review options and determine feasibility Fri 01/07/11 Fri 30/09/11

17 Select supplier and purchase (if feasible) Mon 03/10/11 Fri 30/12/11

18 Manufacture of machine (by supplier) Mon 06/02/12 Fri 23/11/12

19 Installation and commissioning Mon 26/11/12 Fri 29/03/13

20

11/06

Tentative Dates

2Q3Q4 Q2Q3Q4 Q2Q3Q4 Q Q3Q4Q1Q2Q3Q4 Q2Q3Q4 Q2Q3Q4 Q2Q3Q4Q1Q2Q3Q4 Q2Q3Q4 Q2Q3Q4 Q2Q3Q4Q1Q2Q3Q4 Q2Q3Q4 Q2Q304 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Task

Split

Progress

Milestone

Summary

Project Summary

External Tasks

External Milestone

Deadline

LIEBHERR CONTAINER CRANES LTD ‐ EMP SCHEDULE 2012

Date: Thu 29/03/12


21 3/2012 Cleaner Factory Heating Mon 05/07/04 Mon 30/03/15

22 Final Assembly/Stores Mon 05/07/04 Mon 05/07/04

23 Steel Fabrication 7AS Mon 05/07/04 Mon 05/07/04

24 Cutting Hall 7AC (construct new hall) Mon 05/07/04 Fri 29/12/06

25 Upgrade LPG vessel Tue 01/09/09 Fri 29/01/10

26 Western building remaining depts. Fri 01/01/10 Fri 11/06/10

27 Boring & Milling Hall Mon 03/05/10 Fri 11/06/10

28 Review factory development plan Mon 03/01/11 Fri 30/09/11

29 Layout Hall 7AF Mon 13/02/12 Fri 27/04/12

30 New Fabrication Hall East Mon 16/04/12 Fri 29/03/13

31 Steel Fabrication 7AF Mon 01/04/13 Mon 30/03/15

32

33 4/2012: Storm Water Oil Separators/Silt Traps Tue 04/01/11 Fri 31/03/17

34 Investigate options for separator installation Tue 04/01/11 Thu 31/03/11

35 Design Proposals Fri 01/04/11 Fri 09/12/11

36 Review NFHE requirements / design proposal Mon 12/12/11 Fri 30/03/12

37 Select feasible design and consult EPA Mon 16/05/11 Mon 30/04/12

38 Agree design and plan installation Tue 03/01/12 Fri 29/06/12

39 Installation (Eastern Oil Separators) Mon 09/01/12 Fri 29/03/13

40 Review Factory Plan Wed 02/01/13 Thu 31/03/16

41 Installation (Western Oil Separators) Wed 01/04/15 Fri 31/03/17

42

43 5/2012 Storm Water Separation Tue 04/01/11 Fri 29/03/13

44 Feasibility study and report Tue 04/01/11 Thu 31/03/11

45 Design concept Fri 01/04/11 Fri 30/03/12

46 Separation of Main Fabrication Hall Mon 16/04/12 Fri 29/03/13

47 Separation of new Fabrication Hall East Mon 16/04/12 Fri 29/03/13

05/07

05/07

Tentative Dates

Tentative Dates


Task

Split

Progress

Milestone

Summary

Project Summary

External Tasks

External Milestone

Deadline


Date: Thu 29/03/12


48

49 6/2012 Water Conservation Tue 03/05/11 Fri 29/03/13

50 Rainwater harvesting feasibility study Tue 03/05/11 Thu 30/06/11

51 Select location(s) and design system Mon 04/07/11 Fri 30/03/12

52 Rainwater harvesting system installation Mon 02/04/12 Fri 29/03/13

53 Commissioning and operation Mon 18/03/13 Fri 29/03/13

54 Investigate water meter data logger Thu 01/03/12 Mon 30/04/12

55 Installation where feasible Tue 01/05/12 Tue 31/07/12

56 Monitor mains water consumption Wed 01/08/12 Wed 01/08/12

57

58 7/2012 Overground pipe leak catchment system Tue 03/05/11 Tue 31/03/15

59 Survey pipelines containing liquids Tue 03/05/11 Tue 31/05/11

60 Identify feasibility of elimination & removal plan Wed 01/06/11 Mon 31/03/14

61 Catalogue remaining valves and flanges Tue 01/04/14 Mon 30/06/14

62 Design leak catchment system Tue 01/07/14 Mon 29/09/14

63 Install leak catchment system Tue 30/09/14 Tue 31/03/15

64 Remove redundant pipework Tue 01/04/14 Mon 30/03/15

65

66 8/2012 Insulation of Main Fabrication Hall Mon 01/04/13 Wed 31/12/14

67 Survey building requirements Mon 01/04/13 Fri 28/06/13

68 Specification and BOM Mon 01/07/13 Fri 30/08/13

69 Tender process Mon 02/09/13 Fri 20/12/13

70 Building reburbishment Thu 02/01/14 Wed 31/12/14

71

72

01/08


Task

Split

Progress

Milestone

Summary

Project Summary

External Tasks

External Milestone

Deadline


Date: Thu 29/03/12

PER Report

- 59 -

3.4 Pollution Emissions Register (PER) Report for 2011 3.4.1 Objectives

As part of the reporting requirements to the EPA, and to assist the company in managing their environmental performance, a Pollution Emission Register (PER) has been developed by Liebherr Container Cranes Ltd, which is included in the company’s Annual Environmental Report to the EPA. The PER is a register of potentially harmful pollutant releases from the facility. In April 2011, a proposal was submitted to the EPA, which described the proposed format of the PER, which would be included in the next Annual Environmental Report to the Agency. A brief summary of the protocols used in developing the PER is presented in the following sections.

3.4.2 Materials for inclusion in the PER The master list of materials in use at the site was reviewed and, in particular, the chemical composition of each material and the annual usage rate was considered (Table 3.4.1). It was established from chemical composition and data gathering techniques (PER report, AER 1999) that quantification of individual chemical substances in paint products could not be carried out with any degree of accuracy. From this information it was concluded that the PER would only be of value by a presenting a calculated total quantity of Volatile Organic Compounds (NMVOC) derived from paint usage figures for each subsequent year. The principal compounds were measured and are included in section 2.1.2 of this report. Non-methane NMVOC was selected for the PER.

3.4.3 Methodology for development of PER Calculation and use of engineering estimates was used as the principal means of establishing a Mass Balance for the total NMVOC. The compilation of the PER involves calculating the total input and total output of the substances during the year. A Mass Balance Equation for total NMVOC included in the scope of the PER was developed. The processes at the plant were analysed in detail to identify all inputs of the materials of interest, transfers between various units, and outputs in product, air emissions, and liquid waste. The overall approach was as follows:

Input = Output + Accumulation + Consumption – Generation

A detailed inventory of materials used at the plant during the year was compiled and the chemical outputs in this waste stream were calculated. The overall methodology is summarised as follows:

(i) Inventory of materials at beginning and end of year; (ii) Determination of materials in process at any time; (iii) Inventory of waste disposal by source.

PER Report

- 60 -

3.4.4 Production processes and PER substance usage The use of NMVOC’s at the Liebherr Container Cranes Ltd. plant is related exclusively to the painting activities. The detailed usage patterns for the substance of interest is summarised in the following section. The process flow diagram in Figure 3.4.1 outlines the pathway of NMVOC’s in the production process. The dominant sources of NMVOC’s are the paints and thinners used in the paint shop area. Since NMVOC is not incorporated in the finished product it can be assumed that gross usage (2) equals gross process waste (3). Outputs include emission to air via the eight stacks in the paining areas & fugitive emissions (4) and paint waste recovered (5).

(2) (3) (4)

(5)

(1b)

Figure 3.4.1 Process Diagram for NMVOC

Stream No. Description

New NMVOC

Recovered NMVOC for process

Gross Usage

Gross Process Waste

Nett Process Waste

Total NMVOC Recovered5

INPUTS OUTPUTS

4

1a

1b

2

3

New Paint &Solvent (1a)

PaintingProcess

Air - Stack & Fugitive

On-sitereuse/recovery

Off-siterecovery

3.4.5 Mass balance

All paints used are solvent based and are a source of NMVOC emission. The paints used are supplied in two pack units which are mixed on-site to the manufacturers’ specification. In addition, it is also used on its own as a solvent for cleaning purposes. The proportion of NMVOC in the paints used was obtained from information supplied by the manufacturer. Levels of paint usage were obtained from purchase records and stock inventories. Output is predominantly via seven stacks located in the paint shop area and fugitive emission and through an eighth stack in the cutting hall. Fugitive emission is an essential element of the process, the stack emissions being in place principally for operator health and safety. The level of emission was determined by calculation of total NMVOC with the estimated waste figure subtracted.

PER Report

- 61 -

3.4.6 Mass balance – detailed calculations

A Mass Balance Equation included in the scope of the PER was developed. The overall approach was as follows:

Input = Output + Accumulation + Consumption - Generation There is no Accumulation, Consumption, or Generation of NMVOC within the process itself, so therefore Input = Output

The detailed calculations involved in completing this equation are summarised in the following sections.

Input

Table 3.4.1 summarises input for NMVOC for the year

Input includes the following Stock usage of paint products Recovered solvent on-site Input of NMVOC for each individual paint product is calculated as follows:

Input NMVOC (kg) = Vol. material (litres) * NMVOC content (kg/litre)

Gross Usage

Gross usage refers to new paint & solvent plus solvent recovered on-site. As input is equal to output in this case then input and gross usage are the same.

Outputs

The total output for the substance of interest was determined as follows:

Emissions to atmosphere Liquid effluent Paint solids Paint scrubber liquor Incorporation into product Liquid waste

Outputs by each of these possible routes are considered in the following sections.

PER Report

- 62 -

Output to Air

All NMVOC not accounted for by waste or recovery is emitted to air.

Output in Liquid Effluent

There is no process waste or trade effluent. Therefore this figure was recorded as zero.

Output in Paint Waste

Table 3.4.2 outlines the calculation of solvent levels in paint waste for the year.

Hazardous paint solids are principally cured paint with a fractional NMVOC content remaining, estimated at 5%. Output via accumulation in Product

The product does not retain solvent so this value is zero.

Reuse/Recovery

This refers to solvent, which has been reused/recovered either on site or off site during the year. Solvent reused/recovered on site was put back into the process. The overall results of the PER calculations are shown in Table 3.4.3.

Table 3.4.1 Calculation of NMVOC Input and Gross Usage for 2011

Material Total Stock Stock VOC* VOC* Product Solids SolidsIDENT. NO. DESCRIPTION Stock Usage Usage Content Usage Weight Content Total

Usage (L) (L) (g/L) (kg) (g/l) (g/L)(L) Off-Site at LCC (kg)

8301 665 13 BRIGHT ZINC SPRAY WUERTH 400ML 27 0 27 540 15 900 360 108301 645 13 ETCHING PRIMER 15552 1163 4,540 1,960 2,580 525 1,355 1,400 875 2,2588304 031 08 HARDENER FARBLOS FEIDAL ZH70 150 0 150 588 88 980 392 598301 658 13 HEMPADUR 4588 1217 GREY 19,880 9,070 10,810 220 2,378 1,500 1,280 13,8378301 666 13 HEMPADUR ZINC 1734 GREY 1983 4,690 2,000 2,690 330 888 2,300 1,970 5,2998301 816 13 HEMPADUR PRIMER 4514 BLACK 435 0 435 375 163 1,300 925 4028301 824 13 HEMPADUR PRIMER 4514-1000 WHITE 26,580 3,000 23,580 375 8,843 1,300 925 21,8128301 818 13 HEMPADUR PRIMER 4514-5063 TERRACOTTA 23,480 2,940 20,540 375 7,703 1,300 925 19,0008306 089 13 HEMPATHANE 5521 BS356 YELLOW 120 0 120 445 53 1,200 755 918306 113 13 HEMPATHANE 5521 BS381C 356 910 0 910 445 405 1,200 755 6878306 110 13 HEMPATHANE 5521 RAL 1003 YELLOW 2,890 170 2,720 445 1,210 1,200 755 2,0548306 108 13 HEMPATHANE 5521 RAL 1018 YELLOW 120 0 120 445 53 1,200 755 918306 173 13 HEMPATHANE 5521 RAL 1999 BLACK 135 70 65 445 29 1,200 755 49830630013 HEMPATHANE 5521 RAL 3000 RED 1,820 880 940 445 418 1,200 755 7108306 147 13 HEMPATHANE 5521 RAL 3020 RED 4,740 540 4,200 445 1,869 1,200 755 3,1718306 301 13 HEMPATHANE 5521 RAL 5013 BLUE 3,060 1,760 1,300 445 579 1,200 755 9828306 171 13 HEMPATHANE 5521 RAL 7035 GREY 5,215 1,225 3,990 445 1,776 1,200 755 3,0128306 303 13 HEMPATHANE 5521 RAL 9002 GREY 190 0 190 445 85 1,200 755 1438306 304 13 HEMPATHANE 5521 RAL 9010 WHITE 2,100 880 1,220 445 543 1,200 755 9218301 592 13 INTERCURE 200HS BUFF EPA 15,790 4,920 10,870 232 2,522 1,670 1,438 15,6318301 799 13 INTERGARD 233 RED KGA250/KGA259 1,440 0 1,440 249 359 1,620 1,371 1,97410435853 INTERGARD 410 RAL 1002 SAND/YELLOW 2,440 0 2,440 439 1,071 1,300 861 2,1018301 805 13 INTERGARD 410 RAL 9010 WHITE 9,140 0 9,140 439 4,012 1,300 861 7,870830180813 INTERMEDIATE COAT INTERGARD 410 GOLDEN YELLOW 20 0 20 439 9 1,300 861 178301 612 13 INTERPLATE GREY 937 3,376 0 3,376 649 2,191 1,250 601 2,0298301 834 13 INTERPLUS 770 BLUE RAL 5014 20 20 0 233 0 1,440 1,207 08306 629 13 INTERTHANE 990 RAL 1007 YELLOW 20 20 0 413 0 1,210 797 08306 621 13 INTERTHANE 990 RAL 3020 BLACK 1,145 680 465 413 192 1,210 797 3718306 628 13 INTERTHANE 990 RAL 7035 GREY 4,000 860 3,140 413 1,297 1,210 797 2,5038306 636 13 INTERTHANE 990 RAL 9003 WHITE 1,660 0 1,660 413 686 1,210 797 1,3238306 630 13 INTERTHANE 990 RAL 9005 BLACK 910 195 715 413 295 1,210 797 5708306 632 13 INTERTHANE 990 RAL 1003 YELLOW 1,800 260 1,540 413 636 1,210 797 1,2278306 631 13 INTERTHANE 990 RAL 2003 YELLOW 13,273 10,300 2,973 413 1,228 1,210 797 2,3698306 645 13 INTERTHANE 990 RAL 3003 RED 15 0 15 413 6 1,210 797 128306 670 13 INTERTHANE 990 RAL 7012 GREY 10 10 0 413 0 1,210 797 08301 814 13 INTERZINC 22 GREY (14LT PACK) 912 249 663 555 368 2,501 1,946 1,29010486539 INTERZONE 954 RAL 7042 GREY 485 270 215 245 53 1,620 1,375 296830630613 PAINT HEMPATHANE 5521 5 0 5 445 2 1200 755 4830617313 PAINT HEMPATHANE 5521 BLACK RAL 9005 135 25 110 445 49 1200 755 83830631113 PAINT HEMPATHANE 5521 BLUE 80 0 80 445 36 1200 755 6011094033 PAINT HEMPATHANE 5521 BLUE RAL 5012 530 40 490 445 218 1200 755 37010694998 PAINT HEMPATHANE 5521 DARK BLUE RAL 5010 1,250 150 1,100 445 490 1200 755 8318504364 PAINT HEMPATHANE 5521 GREEN 20 0 20 445 9 1200 755 1510435095 PAINT HEMPATHANE 5521 GREEN 20 10 10 445 4 1200 755 8830614613 PAINT HEMPATHANE 5521 GREY 8,800 4,750 4,050 445 1,802 1200 755 3,05810694999 PAINT HEMPATHANE 5521 LIGHT BLUE RAL NCS 1060B 1,110 110 1,000 445 445 1200 755 755830611113 PAINT HEMPATHANE 5521 ORANGE 20 0 20 445 9 1200 755 15830617913 PAINT HEMPATHANE 5521 RAL 5002 BLUE 4,320 700 3,620 445 1,611 1200 755 2,733830630713 PAINT HEMPATHANE 5521 RAL 9003 WHITE 1,560 240 1,320 445 587 1200 755 997830630013 PAINT HEMPATHANE 5521 RED 1,820 0 1,820 445 810 1200 755 1,37410699528 PAINT HEMPATHANE 5521 TRAFFIC BLUE 3,100 700 2,400 445 1,068 1200 755 1,812830617213 PAINT HEMPATHANE 5521 YELLOW 260 0 260 445 116 1200 755 196830665113 PAINT INTERLAC 665 20 0 20 404 8 1,110 706 1410657573 PAINT INTERTHANE 990 20 0 20 413 8 1,210 797 16830665813 PAINT INTERTHANE 990 BLUE 4,740 620 4,120 413 1,702 1,210 797 3,284830663813 PAINT INTERTHANE 990 RAL 7001 GREY 80 0 80 413 33 1,210 797 64830665313 PAINT INTERTHANE 990 RED 1,060 120 940 413 388 1,210 797 749830666013 PAINT INTERTHANE 990 YELLOW 600 40 560 413 231 1,210 797 4468302669 PAINT RAL 7043 LIEBHERR GREY FEIDAL ZD53-7043 450 0 450 494 222 1300 806 3638303 397 13 PAINT STRIPPER SPC-203 41 0 41 0 0 1,040 1,040 4310437389 PEELABLE COATING FOR FLOORS (25LTR) 170 0 170 748 127 945 197 33830165713 PRIMER HEMPADUR 1556 2178 BUFF (20LT. TINS) 1,760 1,760 0 355 0 1,500 1,145 011092912 PRIMER HEMPADUR 4588 1148 DARK GREY 920 200 720 220 158 1,500 1,280 922830165913 PRIMER HEMPADUR 4588 1243 LIGHT GREY (5LT. TINS) 10 0 10 220 2 1,500 1,280 1310694997 PRIMER HEMPADUR ZINC 1736 2,420 440 1,980 332 657 2,700 2,368 4,689830166913 PRIMER HEMPEL ZINC 16490 GREY 19840 (4LT. TINS) 240 0 240 595 143 1,700 1,105 265830180313 PRIMER INTERGARD 251 532 EPA532/EPA501 F/C BUFF 320 0 320 404 129 1,380 976 312830182613 PRIMER INTERPLUS 256 ALUMINIUM GREY IN 5 LT. TIN 200 0 200 261 52 1,390 1,129 226830181313 PRIMER INTERPLUS 880 F/C SERIES PDB000 WHITE 1,280 1,280 0 196 0 1,700 1,504 0

On-Site LCC Killarney

- 63 -

Material Total Stock Stock VOC* VOC* Product Solids SolidsIDENT. NO. DESCRIPTION Stock Usage Usage Content Usage Weight Content Total

Usage (L) (L) (g/L) (kg) (g/l) (g/L)(L) Off-Site at LCC (kg)

On-Site LCC Killarney

830182013 PRIMER INTERZINC 52 GREY EPA142/EPA176 (10LT.TINS) 20 0 20 555 11 2,500 1,945 39830160213 PRIMER SHOPPRIMER 1528U HEMPELS 5089 RED 100 100 0 640 0 1,100 460 08304 032 08 THINNER ACRYL-LACK FEIDAL VZ46 240 0 240 910 218 910 0 08303 423 13 THINNER GTA 007 IN 25 LTR TIN 150 150 0 860 0 860 0 08303 422 13 THINNER GTA 220 IN 200 LTR DRUM 10,375 3,075 7,300 860 6,278 860 0 08303 421 13 THINNER GTA 713 IN 200 LTR DRUM 8,875 2,875 6,000 860 5,160 860 0 08303 394 13 THINNER GTA 820 in 25LT. Drum 1,000 0 1,000 860 860 860 0 0830342513 THINNER INTERNATIONAL GTA 713 25LT TIN 400 300 100 860 86 860 0 08303 405 01 THINNER NO.0808 IN 200 LTR DRUM 10,410 1,795 8,615 878 7,564 878 0 08303 403 13 THINNER NO.0808 IN 25 LTR TIN 200 0 200 878 176 878 0 08303 409 01 THINNER NO.0845 IN 200 LTR DRUM 10,360 1,745 8,615 850 7,323 850 0 08303 416 13 THINNER NO.0845 IN 25 LTR TIN 200 0 200 850 170 850 0 0

Totals 237,229 63,504 173,725 82,339 137,955

Note: Some paint was taken directly from paint shop stocks during the year and sent to sub-contractors - these figures were not recordedand therefore remain in the usage at LCC which is thus somewhat higher than the true figure.

SummaryTotal Volume

(L)Total Stock Usage 237,229Total Stock Usage (off site) 63,504Total Stock Usage (at LCC) 173,725

Inputs (on-site at LCC Killarney)

Total

Mass

(kg)

NMVOC

Mass

(kg)New Paint & thinners 220,294 82,339On-site Recovery 0 0Gross Usage 220,294 82,339

NMVOC as % Total paint usage (%w/w) 37.4%Solids as % Total paint usage (%w/w) 62.6%

Notes1. The paint systems comprise of a two pack units which are mixed on site prior to use. 2. VOC input (kg) = Stock Usage (litres) * VOC Content (g/litre) / 10003. Solid input (kg) = Stock Usage (litres) * Solid Content (g/litre) / 10004. Total mass = mass of VOC + mass of solids

* NMVOC - Non-Methane Volatile Organic CompoundVOC content (g/litre) obtained from product data sheetsSolid content (g/litre) = Product mass (g/litre) - VOC content (g/litre)Product weight (g/litre) obtained from product data sheets

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Table 3.4.2 NMVOC from waste stream

WasteMaterial Source Mass Fractional Mass of

kg Solvent SolventContent Kg

Paint Related Material (haz.) - disposed Spray painting 0 0.05 0Paint Related Material (haz.) - recovered Spray painting 5,131 0.05 257Paint Solvent (on-site recovery) Equipment Cleaning 0 1.00 0Paint Solvent (off-site recovery) Equipment Cleaning 3,759 1.00 3,759

4,016Total =

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Table 3.4.3 Pollution Emissions Register (PER)

FACILITY IDENTIFICATION

Facility Name LIEBHERR CONTAINER CRANES LTD.

IPC Register No. P0146-02

National Grid Reference 493728E, 591919N

Reporting Period 2011 January 1st to December 31st

Production Units/Amount Container Cranes; Rubber Tyre Gantry Cranes; Straddle Carriers

Employee No.

POLLUTANTS SUMMARYPollutant Name CAS No. Input Gross Usage Outputs (kg)

(kg) (kg) Air MOM Liquid MOM Waste MOM Product MOM Recovery Treated Unaccounted

Effluent

NMVOC ---- 82,339 82,339 78,323 B 0 --- 0 --- 0 --- 4,016 0 0

0

0

0

0

MOM - Method of MeasurementThis refers to the method used in determining losses to Air, Water, and Land.

The following codes are to be used to demonstrate the method used:

Method Code Method CodeDirect Measurement M Material Balance B

Engineering Estimates E Other O

- 66 -

PER Report

- 67 -

3.4.7 Gross and net Eco-efficiencies IGEE refers to the Index of Gross Eco-Efficiency. This is defined as the proportion of Gross Process Waste to Gross Usage.

IGEE = (Gross Process Waste / Gross Usage) x 100

= [(3)/(2)] x 100

Gross Process Waste is defined as the amount of pollutant that is emitted from the process via air, effluent and waste emissions. It does not include materials incorporated into the product but does include any material recovered. Gross Usage is defined as the total usage of a given pollutant in a facilities product line. Gross Process Waste differs from Gross Usage only by the amount of material incorporated into the product. Therefore, since none of the solvent being considered ends up in the final product, and all of the material used leaves the plant as some form of waste, the Index of Gross Eco- Efficiency is 100 in this case. IGEE = 100

INEE represents the Index of Nett Eco- Efficiency. It is defined as the proportion of Nett Process Waste to Gross Usage.

INEE = [(Gross Process Waste – Material recovered) / Gross Usage] * 100

= {[(3) – (5)] / (2)} x 100 or [(4) / (2)] x 100

Nett process waste is defined as the amount of pollutant that is emitted from the process minus the amount of that pollutant that is recovered on or off-site. A quantity of solvent was recovered on site and off site. INEE = 95

2005 2006 2007 2008 2009 2010 2011

IGEE 100 100 100 100 100 100 100INEE 86 87 82 90 86 83 95

0

25

50

75

100

125

2005 2006 2007 2008 2009 2010 2011

%

Year

IGEE

INEE

PER Report

- 68 -

3.4.8 Evaluation of PER results The results of the PER for Non-methane NMVOC are illustrated in Figure 3.4.2.

Figure 3.4.2 NMVOC Pie Chart

Based upon summary information, section 2.1.2, non-methane NMVOC emissions from stacks is presented with calculated figures from stocks. 1. Non-methane NMVOC emissions (Stock calculation) = 78,323 kg 2. Recovery = 4,016 kg 3. Disposal = 0 kg

Air 95%

Recycled 5%

Disposal 0%

PER Proposal

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3.5 Pollution Emissions Register (PER) Proposal for 2012 3.5.1 Background

Over the last few years two different approaches were taken in presenting a Pollution Emissions Register for LCC. In AER 1999, a PER was presented with an attempt to track the route of Xylene through the process. This attempt was unsuccessful, as it was established, for various reasons that it could not be done with any degree of accuracy and the results were of no value, being in fact misleading. In AER 2000, a PER was presented tracking the route of total NMVOC’s during 1999. It was found that data could be collected accurately and the information presented in the report was developed with a satisfactory degree of confidence. This approach has been repeated in each annual PER to date.

3.5.2 PER Proposal 2012

I. Compare all materials used/generated on site with PERL (Appendix II of AER guidelines)

Included in PERL (Y/N)

Raw steel (used in product – waste scrap recycled) N

Brass (used in product – waste shavings recycled) N

Plastic (used in product – waste shavings for disposal) N

Paints and solvents (Emission of NMVOC/TOC) Y

Hydraulic and gear oils and grease (used in product) N

Cutting oils (used in process – waste emulsion for disposal) N

Diesel (heating & transport – CO2 , SO2 & NOx combustion emissions) Y

CO2 (process weld shielding gas) Y

Argoshield (process weld shielding gas – Ar & CO2 mix) Y

Oxygen (process gas) N

Acetylene (process gas – CO2 generated from combustion) Y

LPG (heating - CO2 generated from combustion) Y

Miscellaneous product materials N

Miscellaneous consumables N

II. Determine PERL for site (substances matched with PERL list, Appendix II, AER guidelines)

NMVOC/TOC (=Total NMVOC)

CO2

SO2

NOx

PER Proposal

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III. Propose substances for PER tracking

NMVOC (see 3.5.1 above) is proposed.

It is not feasible to track CO2 , SO2 or NOx due to the nature and spread of their use/generation at LCC. Only a crude total emission calculation would be possible.

IV. Detailed methodology to be used in determination of material destinations.

Total NMVOC

Paint usage figures for the year will be calculated from stock control figures with the addition of the estimated quantity of solvent recycled.

Gross usage of NMVOC will be calculated from the figures gained as above and from figures obtained from the paint manufacturers.

The outputs will be calculated by an engineering estimate of NMVOC in the waste stream and a material balance equation to determine the NMVOC to atmosphere.

V. Agency Review/Approval

EPA correspondence is awaited.

VI. Collect data for PER report

To be carried out following EPA approval

VII. Submit PER report

To be submitted as part of AER 2013

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4. Licence-Specific Reports 4.1 Noise Emissions

Environmental noise emissions are to be measured once per year. 4.1.1 Noise Sources on-site

Noise emissions from the site arise from a combination of the following:

General production noise – overhead cranes, grinding, hammering, welding, steel cutting, machine tools, etc. This noise is generated inside all production buildings. Additional noise from extraction systems and high frequency generator are inaudible at the boundary noise-sensitive location.

Factory vehicles – fork lifts, mobile cranes, trucks, etc. This noise source occurs around the factory principally during daytime (08:00-22:00) which accounts for a higher noise level during these hours.

The period of noise emission will be as per company operating hours (see attachment C3 IPPC licence application)

The nature of this noise is fluctuating. 4.1.2 Noise Sensitive Locations

One noise-sensitive location exists at the south east boundary to the factory beyond where there are several private houses. These houses also border the main Killarney to Killorglin road.

LA10 : Traffic Noise LA90 : Background Noise (represents Leq,T for factory noise ISO1996) IPC limits = 55 dBA, day time 45 dBA, night time LAeq : Equivalent noise level (from all sources)

It is noted from simple listening that road traffic noise is significant at the noise sensitive location when compared to noise from the factory. It is also noted that no complaints have been received from neighbours with respect to noise from the facility.

4.1.3 Boundary Measurements

Boundary measurements were taken during 2010 at noise sensitive locations as detailed below.

Day-time, Factory Active dBA

Location Date LA10, 1hr. LA90, 1hr. LAeq, 1hr.

N1- South Inside boundary

29/9/11 63.0 41.0 61.0

Night-time, Factory Active dBA

Location Date LA10, ¼ hr. LA90, ¼ hr. LAeq, ¼ hr.

N1 - South Inside boundary

22/11/11 50.0 41.5 48.0

The noise measurement location at the noise-sensitive location is designated location “N1” at the south-east of the plant. The outline of private housing can be seen.

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Noise sensitive

location -

private housing

A2-4

A2-5

A2-6

A3-17

A3-18

A3-14

A3-16

A3-13

A3-15

A3-10

A3-9

A3-8

A3-7

A3-5

A3-4

A3-6

A3-11

A3-12

A3-3

A3-1

A3-2

A2-8Abatement: dry

filter system to

capture paint

overspray

A2-9

A2-10Abatement: dry

filter system to

capture dust

from A2-9 and

A2-10

A3-19

A3-22

A3-20

A3-21

A3-27

A3-28

A3-29

A3-30

A3-31

A3-26

A3-25

A3-24

A3-23

A2-3

A2-2

A2-1Abatement: dry filters beneath

floor extraction grids leading to

A2-1 to A2-6 to capture paint

overspray

A2-7Abatement: water curtain

at A2-7 to capture paint

overspray

A3-54

N1

A3-55

SE1

A3-32

A3-33A3-34

A3-35A3-36

A3-37

A3-39

A3-41

A3-43

A3-45

A3-47

A3-49

A3-38

A3-40

A3-42

A3-44

A3-46

A3-48

A3-50

A3-53A3-52

A3-51

SW2

SW1

SW30

4.1.4 Boundary Measurements

Source Emission Equipment Sound Pressure* Impulsive Period of Other

point reference dBA at or tonal Emission Comments

reference No. No. reference qualities

distance 31.5 63 125 250 500 1K 2K 4K 8K

Factory, 1 Norsonic LAeq,1h = 61.0 39.0 51.0 45.5 50.0 54.0 55.0 54.0 50.5 43.5 --- 1 hour 11:00-12:00

Road, 114 LA10,1h = 63.0 42.5 54.0 48.5 51.0 56.0 56.0 55.0 53.0 45.5 29/09/2011

etc. (dBA Fast) LA90,1h = 41.0 30.0 38.5 31.0 32.0 37.5 40.5 37.5 30.5 30.0

Factory, 1 Norsonic LAeq,15min = 48.0 30.5 36.5 36.0 32.5 38.0 44.5 41.0 33.0 31.5 --- 15 mins 07:10-07:25

Road, 114 LA10,15min = 50.0 31.0 39.0 36.5 34.0 40.0 47.5 44.0 32.0 30.0 22/11/2011

etc. (dBA Fast) LA90,15min = 41.5 30.0 32.0 32.0 30.0 33.5 37.0 33.5 30.0 30.0

* For items of plant Sound Power levels may be used.

Octave bands (Hz)

Sound Pressure* Levels dBA per band

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Bund Integrity Testing

- 74 -

4.2 Bund Integrity Testing

A new reinforced concrete bunding structure was constructed for LCC bulk liquid fuel storage in accordance with BS8007 and completed towards the end of 1999. Bund testing was carried out upon completion and certified accordingly. In accordance with condition 6.8 of IPPC Licence No. P0146-02 bund testing will be carried out at least once every three years. The most recent integrity test was carried out on the structure from 25/02/09 to 27/02/09. Some minor hairline cracks which had developed in the retaining walls resulted in a small seepage of water through to the outside. The certificate of test is included below. These minor cracks which have been deemed insignificant and were repaired on 2/03/09, verified on the test report. The next bund test is due to be carried out in Spring 2012.

Bund Integrity Testing

- 75 -

Underground Tank and Pipeline Inspection Report

- 76 -

4.3 Underground Tank and Pipeline Inspection Report

All underground tanks and foul sewer pipes are to be tested at least once every three years. 4.3.1 Underground Tank Inspection

LCC currently has three underground fuel tanks on site. There is one 28,000 litre underground diesel tank and two underground petrol tanks, with a capacity of 22,500 and 10,000 litres respectively.

4.3.1.1 The double skin 28,000 litre steel tank for diesel servicing office block heating was tested in

December 2011. See following test certificate. The next test is due at end 2014. 4.3.1.2 There are two underground petrol tanks at LCC, one of which (22,000 L) was completely

drained several years ago and it is not intended to reuse the tank again. The second tank (10,000 L) was more recently emptied and it is planned to decommission both tanks permanently either by concrete fill or remove the tanks entirely. The tanks were last tested in November 2005 and as they are no longer in use, retesting has been deemed unnecessary.

4.3.2 Underground Pipeline Test

A comprehensive underground foul sewer pipeline test was carried out on 15th March 2011. The report (Appendix A.1) shows that all foul sewer lines passed the test procedure. The next foul sewer pipe test is due in March 2014.

Underground Tank and Pipeline Inspection Report

- 77 -

Public Awareness & Communications Programme

- 78 -

4.4 Public Awareness & Communications Programme 4.4.1 This programme is in place so that members of the public can obtain information concerning

the environmental performance of LCC at all reasonable times. The information provided in the programme, as laid out in the contents below, is contained in two files which are available at LCC reception. Members of the public wishing to access this information may do so by requesting the files from the LCC receptionist who will supply the files for viewing. These files may be viewed at LCC between the hours 08:00 to 16:00, Monday to Friday, except on bank holidays and during company shut-down.

4.4.2 Contents 4.4.2.1 Public Awareness & Communications Programme - this document (file 1) 4.4.2.2 IPPC Licence - notification of grant of licence and licensing conditions (file 1) 4.4.2.3 IPPC Licence application (file 1) 4.4.2.4 Quarterly monitoring of emissions to atmosphere - current year (file 2) 4.4.2.5 Annual Environmental Report -for the previous year (file 2). 4.4.3 Additional Information

If any additional information is required that is not contained in these two files, members of the public may request an appointment with the environmental manager by completing the appropriate form. The person requesting information will be contacted in due course and an appointment time given.

4.4.4 Reporting

A register is included at the beginning of file 1 which the person viewing the files is requested to sign so as to provide evidence of the viewing. No signature was added to the register during 2011.

Solvent Management Plan

- 79 -

4.5 Solvent Management Plan 2012 (incorporating a Fugitive Emissions Reduction Programme)

4.5.1 Introduction

A Solvent Management Plan has been developed for the Liebherr Container Cranes Ltd (LCC) facility at Killarney, Co. Kerry. The project was initially undertaken by TMS Environment Ltd in co-operation with LCC in 2008 to assist LCC with achieving and demonstrating compliance with the requirements of the Volatile Organic Compounds (VOC) Regulations (SI No 543 of 2002). There were three possible approaches towards achieving compliance with the requirements of the VOC Regulations. Compliance could be achieved with either (a) the appropriate emission limit values as per Schedule 2 or (b) the requirements of the Reduction Scheme as per Schedule 3. Alternatively, exemptions to these requirements could be granted if the operator demonstrated to the satisfaction of the competent authority that:

activities at an installation posed no significant risk to human health or the environment

compliance requirements were not technically or economically feasible

Best Available Techniques (BAT) are being used at the facility. The above, having been satisfactorily demonstrated as part of LCC’s application for a revised IPPC licence, an exemption was granted under licence no. P0146-02. This Solvent Management Plant, which is both technically and economically viable and achieves the maximum in terms of solvent management, has been formulated for LCC. Over the last number of years LCC has made major progress in its efforts to reduce its use of solvents and hence its emissions to the atmosphere. Improvements have included materials substitution, reductions in the amount of priming needed and improved efficiency in the use of materials. Specific successes have included:

Complete phase-out of the use of the dichloromethane-based Absenta thinner. An alternative has been obtained.

Recycling of solvents from paint washings by distillation lead to the on-site recovery of VOCs and a decrease in emissions.

The introduction of new priming and shot blasting machinery lead to a huge reduction in the amount of primer used.

The initial introduction of a new 2-component mixer paint equipment leading to more efficient use of painting materials.

Adopting the use of high solids paints with lower VOC content than previous products.

Increased efficiency in painting. Reduction in the amount of VOCs used per tonne of steel painted.

Installation of a new Paint Kitchen. It has been demonstrated in the IPPC licence review application that activities at LCC pose negligible risk to human health or the environment, and the facility is Best Available Techniques (BAT) Complaint. LCC will manage solvents in accordance with the Solvent Management Plan described in this report.


- 80 -

4.5.2 Compliance Requirements

IPPC Licence Conditions

6.7 The licensee shall prepare a programme, to the satisfaction of the Agency, for the identification and reduction of fugitive emissions including those emitted through minor emission points using an appropriate combination of best available techniques. The time frame for the implementation of the reduction programme and the targets set shall be as agreed by the Agency. This programme shall be included in the Schedule of Environmental Objectives and Targets under Condition 2.2.2.2.

6.15 Solvent Management Plan 6.15.1 The licensee shall prepare a Solvent Management Plan (SMP) in accordance with any

relevant guidelines in Schedule No 6 of S.I. No. 543 of 2002 (Emissions of Volatile Organic Compounds from Organic Solvent Regulations, 2002) or as may be issued by the Agency and shall be submitted as part of the AER.

6.15.2 The substances to be included in the SMP shall be determined with reference to the

definition of an organic solvent in Council Directive 1999/13/EC and shall be as agreed by the Agency each year.

6.15.3 The licensee shall maintain a record of the monthly total of the operating hours for

each of the fans associated with emission points A2-1 to A2-8 (inclusive), which shall be available for inspection by authorised persons of the Agency, at all reasonable times. The licensee shall submit the monthly totals for each of the fans as part of the SMP.

6.15.4 The licensee shall determine and submit the emission factor (kg VOC/tonne crane

weight) for the installation annually as part of the SMP. 6.15.5 The licensee shall keep records of the data from which the reported information was

derived and supporting documentation including a description of the methodology used for data collection

SI2002/543 - SCHEDULE 6 2. Principles The solvent management plan serves the following purposes: –

(i) verification of compliance as specified in article 20(2) of the Regulations; (ii) identification of future reduction options; and (iii) enabling of the provision of information on solvent consumption, solvent

emissions and compliance with the Directive to the public.


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4.5.3 Solvent Management Plan for Liebherr Container Cranes Ltd. 4.5.3.1 Purpose of the Solvent Management Plan

In order to comply with the requirements of the Emissions of Volatile Organic Compounds from Organic Solvents Regulations 2002, Liebherr Container Cranes Ltd. (LCC) has developed a Solvent Management Plan. The main purpose of the Solvent Management Plan is to define a management programme for the use of solvents at the facility so that compliance with the regulations is assured. In particular, the Solvent Management Plan allows for the identification of possible options for the future reduction of emissions and provides information on solvent consumption, solvent emissions and compliance with the Regulations. The main features of the Solvent Management Plan proposed for the Liebherr Container Cranes Ltd. facility are summarized as follows: (i) Definition of a quantitative solvent tracking system to allow a reliable assessment of

efficiency of solvent usage; (ii) Definition of a programme for identification of usage and/or emission reduction

options; (iii) Definition of a reporting format for solvent usage at the facility. The detailed format of the Solvent Management Plan is presented in the following sections of this report.

4.5.3.2 Solvent Tracking and Reporting System

As described in the IPPC licence review application, the most reliable methodology for tracking the use of solvents at the facility and for evaluating the efficiency of solvent use is the emissions factor approach. LCC has maintained an inventory of the weight of each crane painted since 1999 along with a detailed breakdown of the materials used to paint these cranes. Using these data an Emission Factor expressed as the weight of VOCs used per tonne weight of crane painted can be calculated. As part of the Solvent Management Plan, the facility has tracked the amount of VOC usage per unit production. These calculations give an indication of the efficiency of painting and VOC use at the facility. The data is used to compile an annual summary of achievements, presented in the format described in Table 1.


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Table 1 Emission Factor (kg VOC/tonne crane painted)

Year Total VOC Content

(kg)

Total Crane Weight (tonne)

Emission Factor (VOC kg/tonne crane weight)

The VOC content of materials used to paint each crane are totalled on an annual basis. This is calculated from the detailed breakdown of materials used to paint the cranes in question

The weights of each crane painted are totalled on an annual basis. This is determined from the inventory of the weight of each crane

Total VOC content / total crane weight

Note: Painting of a particular crane may take place from one year to another and so annual values for the crane weight and VOC content used will be weighted according to the dates recorded.

Table 2 shows data shows emission factor data for 1998 to 2011. During the compilation of this data some difficulty arose both with data accuracy and its timely availability to comply with AER reporting deadlines. Increased use of subcontract work in recent years and the painting of individual projects across two different calendar years necessitates a degree of estimation, the accuracy of which may be questionable. An additional column is therefore introduced into table 2 showing the weight of VOCs as a percentage of the total weight of paint used year on year. This is presented an alternative tracking system to demonstrate an overall general trend to use lower solvent paints. Both the emission factor and VOC/paint weight (%w/w) are presented in graphical format below in figures 1 and 2.

Table 2 Emission factor (kg VOC/tonne crane painted) 1999 - 2011

Year

Total VOC content

(kg)

Total crane weight (tonne)

Emission Factor

(VOC kg/tonne crane weight)

NMVOC as % Total paint

usage (%w/w)

1998 69,655 not available not available 47.9%

1999 83,367 4,167 20.00 41.3%

2000 102,187 10,935 9.91 39.3%

2001 78,954 8,028 9.83 37.6%

2002 54,285 9,382 5.79 35.5%

2003 57,166 7,518 7.60 37.9%

2004 60,441 8,795 6.80 36.1%

2005 58,547 9,097 6.44 35.1%

2006 80,614 10,563 7.63 36.8%

2007 88,764 13,119 6.77 36.0%

2008 104,451 13,635 7.66 34.4%

2009 96,378 15,156 6.36 37.0%

2010 80,770 12,488 6.47 38.6%

2011 82,339 14,859 5.54 37.4%


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Figure 1 Emission factor (kg VOC/tonne crane painted) 1999 - 2011

Figure 2 VOC as % of Paint Use (%w/w) 1998 - 2010

Under IPPC licence condition 6.15.3 a record of the monthly total of the operating hours for each of the fans associated with emission points A2-1 to A2-8 (inclusive), will be included in the SMP. These figures are presented below.

0

5

10

15

20

25 1

99

9

20

00

20

01

20

02

20

03

20

04

20

05

20

06

20

07

20

08

20

09

20

10

20

11

Emission Factor

Emission Factor

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

19

98

19

99

20

00

20

01

20

02

20

03

20

04

20

05

20

06

20

07

20

08

20

09

20

10

20

11

VOC as % of Paint Use (%w/w)

VOC as % of Paint Use (%w/w)


- 84 -

2011

Extraction fan clock readings showing the number of hours operation at each emission point are to be recorded at the end of each month by the department supervision in the paint shop and cutting hall for solvent emission points A2-1 to A2-8. Readings for particulate emission points A2-9 to A2-10 are to be recorded at the end of the year. The date of the reading and the hours are to be entered into the table below (decimals can be omitted).

Air Emission Point Extraction Fan Clock Reading

MPP/7AP Paint Shop Cutting Hall MPC/7AC

Reading No.

Date A2-1 A2-2 A2-3 A2-4 A2-5 A2-6 A2-7 Date A2-8 A2-9 A2-10

1 31/01/2011 16,732 16,367 17,141 15,551 15,291 5,639 31,082 31/01/2011 12,620

2 29/02/2011 16,914 16,556 17,356 15,729 15,421 5,639 31,281 28/02/2011 12,680

3 31/03/2011 17,072 16,687 17,558 15,821 15,566 5,639 31,552 31/03/2011 12,773

4 03/05/2011 17,256 16,896 17,754 16,004 15,724 5,639 31,736 29/04/2011 12,874

5 31/05/2011 17,432 17,068 17,916 16,200 15,905 5,645 31,972 31/05/2011 12,946

6 31-06-2011 17,621 17,256 18,078 16,361 16,095 5,654 32,212 30/06/2011 13,017

7 09/08/2011 17,747 17,447 18,237 16,619 16,250 5,658 32,393 27/07/2011 13,074

8 01/09/2011 17,929 17,613 18,439 16,648 16,405 5,658 32,613 31/08/2011 13,160

9 01/10/2011 18,126 17,815 18,626 16,851 16,562 5,661 32,674 30/09/2011 13,272

10 01/11/2011 18,294 18,019 18,860 17,025 16,738 5,663 33,264 28/10/2011 13,327

11 30/11/2011 18,501 18,236 19,102 17,197 16,926 5,664 33,424 30/11/2011 13,411

12 23/12/2011 18,747 18,747 19,334 17,406 17,105 5,665 33,500 04/01/2012 13,471 14,646 15,039

Annual Hours 2,184 2,541 2,356 2,021 1,934 26 2,729

894 3,636 3,712


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4.5.3.3 (Fugitive) Emission Reduction Programme

LCC commissioned a detailed assessment of fugitive emission rates which was submitted to the Agency on 29/09/09 during the IPPC Licence review process. The report showed that average fugitive emission rates of 32.3% exist in LCC paint shop. In a letter to LCC on 12/11/09, the Agency asked if LCC could reduce the extraction velocity on emission points A2-1 to A2-6 inclusive. LCC held that this action would negatively impact on occupational health and safety in the paint shop and would also increase the fugitive emission level and was therefore not feasible, as detailed in our letter dated 1/03/10. LCC has made considerable progress in the reduction of solvent usage over the past number of years since the first IPC/IPPC licence was granted in 1997. The installation of a new automated spraying machine and shot-blasting plant led to considerable reductions in the quantities of materials used and subsequently to the amount of mass emissions to the atmosphere. The introduction of the recycling of solvent from paint washings and the use of the new 2-component mixing machine also contributed to improved efficiency of use of materials. The initial introduction of the use of a new 2-component mixing machine led to the improved efficiency of use of materials. 2-component mixing machines utilise Best Available Techniques (BAT) and automatically mix the required amounts of paint base and activator, therefore reducing the wastage of materials upon mixing. LCC has made a substantial investment in 2011 to extend the use of this technology over the entire facility with the installation of a new Paint Kitchen which was commissioned in May. This has led to significant reductions in the consumption of raw materials and in the amount of waste materials generated during painting activities at the facility and consequently a reduction in the VOC usage as well as improved efficiency in resource usage. Improvements in efficiency have reduced overall use of solvents and thus proportional reductions in solvent emissions and fugitive emissions. LCC has considered using water-based painting materials as part of the solvent management plan and has carried out a number of trials as part of the company’s Environmental Management Programme as reported in previous Annual Environmental Reports. Currently there are no suitable non-VOC containing paints available. On-going enquiries have been made with manufacturers as to the possibility of acquiring such new materials. If and when this technology becomes available that will be feasible to use with LCC’s products and conforms to the coating life expectancy (up to 20 years) and quality requirements of our clients in aggressive/corrosive marine environments, management will certainly consider using these alternatives. LCC will continue to identify and evaluate all possible strategies to reduce emissions from the facility. Details of the viability of such future reduction options will be included in the company’s annual EMP and the Annual Environmental Report

Environmental Liabilities

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4.6 Environmental Liabilities



“12.3 Environmental Liabilities 12.3.1 The licensee shall as part of the AER, provide an annual statement as to the

measures taken or adopted at the site in relation to the prevention of environmental damage, and the financial provisions in place in relation to the underwriting of costs for remedial actions following anticipated events (including closure) or accidents/incidents, as may be associated with the carrying on of the activity.

12.3.2 The licensee shall arrange for the completion, by an independent and appropriate

qualified consultant, of a comprehensive and fully costed Environmental Liabilities Risk Assessment (ELRA) to address the liabilities from past and present activities. The assessment shall include those liabilities and costs identified in Condition 10 for execution of the Decommissioning Management Plan. A report on this assessment shall be submitted to the Agency for agreement within twelve months of date of grant of this licence. The ELRA shall be reviewed as necessary to reflect any significant change on site, and in any case every three years following initial agreement. The results of the review shall be notified as part of the AER.

12.3.3 As part of the measures identified in Condition 12.3.1, the licensee shall, to the

satisfaction of the Agency, make financial provision to cover any liabilities identified in Condition 12.3.2. The amount of indemnity held shall be reviewed and revised as necessary, but at least annually. Proof of renewal or revision of such financial indemnity shall be included in the annual 'Statement of Measures' report identified in Condition 12.3.1.

12.3.4 The licensee shall have regard to the Environmental Protection Agency Guidance

on Environmental Liability Risk Assessment, Decommissioning Management Plans and Financial Provision when implementing Conditions 12.3.2 and 12.3.3 above.”

4.6.2 Statement of Measures for Prevention of Environmental Damage

Since the grant of the first IPC licence no. 146 in 1997, LCC has greatly improved its environmental performance on a continuous basis year by year. This has included: appointment of an Environmental Manager; development of an Environmental Management System; regular monitoring of atmospheric emissions for compliance with the IPC/IPPC licence and applicable legislation; purchase of bunded chemical storage vaults and spill trays with automatic fire suppression; construction of a large concrete bund under roof for storage of bulk diesel exceeding the applicable standards; periodic testing of underground storage tanks and foul sewer pipelines; construction of a new power washing station with installation of a class 1 oil interceptor; purchase of spill kits, development of an emergency response plan and training of an emergency response team to deal with spillages; adopting Best Available Techniques (BAT) with the construction of new shot-blasting facilities, eliminating a number of atmospheric dust emission points; construction of a new paint shop


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with BAT extraction equipment thereby reducing fugitive solvent emissions; a new automatic shop priming paint machine and process changes resulting in almost 90% reduction in shop priming VOC emissions to atmosphere; in-house recycling of paint solvents; new BAT painting equipment reducing the volume of hazardous waste; phasing in ‘greener’ fuel for factory heating; construction of a new cutting hall with state of the art processes such as plasma gas-cutting with extraction and filtration systems to improve health & safety as well as environmental performance; conduction of a Fire Water Risk Assessment; implementation of a Solvent Management Programme; installation of an energy management system; fitting of photocells to control lighting and save energy; reducing waste to landfill by 70%; introduction of more energy-efficient lighting; and increasing recycling of factory waste streams to over 90% in total; construction of a new tank farm to eliminate the use of neat CO2 in welding processes; preparation of an Environmental Liabilities Risk Assessment (ELRA) and Decommissioning Management Plan (DMP); daily/weekly visual inspections of storm water emission points and drainage network.

In 2011:

LCC conducted an investigation of alternative shot-blasting plants which will use a more efficient electrically driven impeller system rather than a compressed air driven system which has high energy consumption – a new machine will be delivered to LCC at the end of 2012 for commissioning in Spring 2013, demonstrating LCC’s continued commitment to the BAT principle.

A new tank farm was completed at the north of the plant with a bulk argon tank, allowing for on-site mixing of welding gas (79.5-87.8% Ar / 12-20% CO2 / 0.2-0.5% O2) replacing shielding gas in processes that previously used 100% CO2 and thus reducing greenhouse gas emission.

New emissions monitoring platforms were installed.

An underground foul sewer pipeline inspection was carried out.

The fire water risk assessment was reviewed.

ELRA and DMP reports were completed.

A new (BAT) paint kitchen was installed in the paint shop so that primers are now mixed as used and delivered to the paint guns, resulting in less waste.

Daily/weekly visual inspections of storm water emission points and gulleys was put in place.

Additional investigations as detailed in the EMP were continued and will mature over the next few years.

Looking to the future LCC’s policy is to continually improve production facilities while integrating the BAT principle with the factory’s development. LCC continues to seek ways of improving environmental performance with respect to its principal environmental aspects.

4.6.3 Statement of Financial Provisions to Underwrite Remedial Actions for Liabilities (including

those identified in the ELRA)

LCC is part of the Liebherr Group of Companies which has a sound financial position and the ability to carry out the measures detailed in the ELRA and DMP. The Liebherr Group produces an annual report which demonstrates the company’s ability to meet with its financial commitments or liabilities for carrying on or ceasing activities. As this report contains sensitive information that the company does not wish to be available in the public sphere to be accessed by competitors, LCC hereby confirms the above statement with


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respect to its sound financial position and will make the group report available for inspection by the EPA upon request. In 2011 LCC had a number of communications with the Agency regarding alternative financial provisions in accordance with the EPA guidance document. These communications extended into 2012 and measures to the satisfaction of the Agency will be finalised and put in place in 2012.

4.6.4 Review of Environmental Liabilities Risk Assessment (ELRA)

LCC submitted its ELRA to the EPA in February 2011. The Agency responded on 15/02/11 with a request for further information which would be sent in April. The ELRA will next be reviewed in January 2014 or following any significant changes on site (whichever is sooner). The details of the review will be included in this section of the AER.

Decommissioning Management Plan

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4.7 Decommissioning Management Plan (DMP)



“10.2 Decommissioning Management Plan (DMP) 10.2.1 The licensee shall prepare, to the satisfaction of the Agency, a fully detailed and

costed plan for the decommissioning or closure of the site or part thereof. This plan shall be submitted to the Agency for agreement within six months of the date of grant of the licence.

10.2.2 The plan shall be reviewed annually and proposed amendments thereto notified

to the Agency for agreement as part of the AER. No amendments may be implemented without the agreement of the Agency.

10.2.3 The licensee shall have regard to the Environmental Protection Agency Guidance

on Environmental Liability Risk Assessment, Decommissioning Management Plans and Financial Provision when implementing Condition 10.2.1 above.”

4.7.2 Review of DMP

LCC submitted its DMP to the EPA in February 2011. The Agency responded on 15/02/11 with a request for further information and a revised DMP was submitted to the Agency on 19/04/11 by TMS Environmental on LCC’s behalf. Upon review of the DMP, it is concluded that no changes of significance have occurred at the site since the publication of the last revision, which would require another revision to be made. The DMP will next be reviewed in January 2013 and on an annual basis. The details of each review will be included in this section of the AER.

Energy Efficiency Audit Report Summary

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4.8 Energy Efficiency Audit Report Summary



“7.1 The licensee shall carry out an audit of the energy efficiency of the site within one year of the date of grant of this licence. The audit shall be carried out in accordance with the guidance published by the Agency, “Guidance Note on Energy Efficiency Auditing”. The energy efficiency audit shall be repeated at intervals as required by the Agency.

7.2 The audit shall identify all practicable opportunities for energy use reduction and efficiency

and the recommendations of the audit will be incorporated into the Schedule of

Environmental Objectives and Targets under Condition 2 above.”

A copy of the audit summary report carried out in 2010/2011 is included in the following two

pages. Recommendations have been considered and included in the AER Objectives and Targets

and EMP where appropriate.


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4.8.2 PAST & PRESENT ENERGY USAGE

Table 1 shows LCC’s overall consumption of resources to reach Energy requirements over the past 3 years.

OVERALL CONSUMPTION OF ENERGY SOURCES 2008-2010 (kWhrs)

2008 2009 2010

Electricity 6,204,071 6,317,827 5,952,234

Diesel oil 2,656,058 2,386,610 2,813,301

Diesel 1,153,391 1,029,208 1,003,413

Acetylene 294,008 366,250 304,524

LPG 3,335,395 2,531,089 4,488,204

Table 1

4.8.3 ENERGY AUDIT RECOMMENDATIONS

Table 2 shows the energy audit recommendations outlining present and prospective projects being undertaken by LCC. It illustrates to LCC the perceived annual savings for introducing such projects into their facility.

Recommendation Description

Payback Period

Predicted Annual Energy

Savings

Annual CO2

Emissions Savings Responsibility Comments

[Year] [kWh] [Tonne]

Upgrade general lighting system with more efficient energy units.

2.5 708,222 kWh/year

347 MS Costs based on 10.3c/kWh (2011 prices).The CO2 factor calculations are based on 2008 figures and will be updated when the most recent figures become available.

Replace diesel heating systems with L.P.G. Heating systems.

1,008,534 kWh/year

296 MS Based on 2008/09 energy consumption figures. There are many unpredictable variants to consider when calculating these figures. Weather patterns can change the consumption dramatically. Some production halls already changed over, others under continuous assessment.

Investigate the use of turbine based shot blast to replace pneumatic shot blast.

810,000 kWh/year

397 MS Figures are based on estimates of 12-16hrs operating cycles, 50 week year. Based on shot blasting an item 50 metres long.

Incorporate correct wall/roof insulation in all new building projects.

Liebherr Container Cranes is committed to energy management and continual improvement in energy efficiency. In all future buildings commissioned for build by LCC, we will ensure to incorporate all modern design and energy saving techniques in relation to insulation and building material properties. It is noted by LCC that by using the correct wall/roof insulation with the correct u-values huge energy loss can be prevented.

Revamp of Old building 7AF with new wall/roof insulation.

Currently being discussed. Cannot present any valid information at this time.

Table 2

4.8.4 Overview of Energy Management

Energy Tracking Monitoring System (live monitoring of electrical use) A comprehensive energy monitoring system was installed in January 2008 to monitor electrical energy use at the LCC facility. It supports the development of an energy management structure and endorses an increased awareness of the importance of energy efficiency among employees.

Photocells. Lighting level control.


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The Photocell lighting control system has been installed since the late 1990’s to utilize the benefits of natural daylight. By incorporating fixtures equipped with a Photocell, LCC are ensuring that lights are not activated during occasions when not needed, consequently reducing energy consumption.

VSD compressors. Thanks to the variable speed drive technology, air demand and compressor capacity can be perfectly matched, eliminating unloaded power consumption completely. Variable speed drives compressors are been used within the LCC facility where production processes permit. By using VSD it has helped improve energy efficiency noticeably e.g. savings in excess of 50% can be achieved.

Diesel to LPG changeover. This process is ongoing, where existing building u-values make the change over feasible and more practical to initiate.

Any replacement buildings up to date insulation levels/energy saving techniques. All new building projects here in LCC apply all modern insulation materials in its construction phase to ensure future savings in energy conservation. Design and energy saving techniques are excessively researched prior to commissioning final building designs.

Continuous review of the best available techniques. Our engineers and architects here in LCC continuously review all modern concepts and techniques which emerge on the market. These sequentially are items which are discussed thoroughly and outcomes determined on what best suits our plant.

4.8.5 Implications of Audit Findings

Improvements in our energy consumption emerges from systematic reviews and by sharing experiences and results from our product Research and Development department. This resulted in workshop lighting upgrade and the use of energy efficient fittings for all future buildings.

Following careful scrutiny of Diesel and LPG systems weaknesses in older designs were evident. Serving onwards with newer technology, LPG has improved our consumption and decreased our fuel costs noticeably.

Production engineers continually demand higher production outputs without additional costs. This pushes us to examine newer and quicker process machines, machines that can execute operations without resulting in elevated operating cost. On investigation some significant savings can be made by changing our approach to a manufacturing process like the shot blasting.

What was noted also by LCC was by implementing the above elements in our plant it will cause substantial reduction in our C02 emissions. Reducing C02 emissions is something that concerns us all. LCC is committed to reducing its C02 emissions as part of the “Company Energy Policy”. We are currently trying to reduce emissions by avoiding unnecessary activities and using resources more efficiently: Lower emissions also mean lower energy costs. This also contributes to a better profitability of business running modern equipment.

Implications Persistence Continued maintenance of savings is an essential factor in insuring the success over time of a particular projects and retro commissioning older projects. It is in LCC’s interest to cut energy cost where possible but also simultaneously reducing our carbon footprint on the environment. LCC will aim to avoid energy wastage and reduce emissions to the environment caused by energy consumption.

Raw Material Assessment Report

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4.9 Report on the assessment of the efficiency of use of raw materials in processes and the

reduction in waste generated



“7.4 The licensee shall 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 for this type of activity.

Where improvements are identified, these shall be incorporated into the Schedule of

Environmental Objectives and Targets.”

4.9.2 Raw Materials

LCC is engaged in the production of rail-mounted and rubber-tyre container gantry cranes

and straddle carriers at the facility in Killarney. The manufacturing process utilises such

procedures as plasma cutting, gas-cutting, fabrication & welding of steel, machining, shot

blasting and painting, mechanical assembly and electrical engineering. The principal raw

material used at LCC is metal which is predominantly steel both in terms of volume and

weight and also includes relatively small quantities of bronze. Other raw materials that are

incorporated into the product are Oil & Grease and Paint products. The remaining

components that complete LCC’s products are purchased parts such as electric motors,

gearboxes, brakes, bindings and electric cables.

Raw materials not incorporated into the product are process and steel shot.

4.9.3 Metals Efficiency

Metals used at LCC are steel and bronze with steel accounting for the vast majority. Steel is

purchased in a variety grades and sizes for fabrication and machining to form the different

parts of the product as required by the design for structural and mechanical components.

Steel stock can be divided into steel plate and profiles. Profiles can be further subdivided

into several categories including I-beams, angle profiles, round, tubes, box profile, bar, and

channel. Steel welding wire is used for joining stock which has been prepared for

fabrication. A relatively small quantity of bronze tube is used in the product to provide

bearing surfaces.

Raw steel is stored in the Cutting Hall and external steel yard and is cleaned in the Cutting

Hall in an automatic shot-blasting machine. The steel shot in the blasting process is

automatically recovered and reused in the machine until such time as the shot has broken

down into fine dust and is removed and collected for disposal. This steel dust is retained for

recycling by scrap metal companies, thus maximising the efficiency of the process.


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The cleaned steel travels along the Cutting Hall conveyor system and steel plate is directed

to the CNC plasma/gas cutting machines. Steel profiles receive a thin coat of shop primer

and are directed to temporary storage and/or to a range of cutting machines.

Steel plate ranges from 1.5 to 150mm in thickness and up to 4m wide by 12m long. Plate is

placed on the CNC plasma/gas cutting machines and the CNC technicians plot the required

components to be cut from the plates using a dedicated nesting computer application.

During the nesting process, the technicians fit the maximum number of components

possible into the steel plate with the lowest amount of waste remaining. In the illustrated

job layout below, figure 4.9.1, it can be seen that the technicians fit as many parts as

possible, to the sheets of s355j2+n steel plate 3m x 2m x 120mm thick, using the CNC

nesting programme, thus minimising the waste produced. Once the usable cut parts have

been removed, the remaining steel is cut and segregated for recycling by scrap metal

merchants and sized up to be cut again into other parts where possible. Here again it can be

seen that this BAT processes maximises efficiency of use for raw steel.

Figure 4.9.1

Where simple straight-edge shapes are required from thin steel plates, these can be cut

using a metal shears and once more the maximum usage of steel for production is gained

through the skill of the operator and waste segregated for recycling.

Steel profiles are cut to the required lengths by a range of machines appropriate to the size

and shape of material, such as band saws, circular saws and profile shears. Waste off-cuts

are either segregated for scrap metal recovery or returned to stock for later use as

appropriate. Shavings produced during steel cutting are also collected for recycling so that

nothing is wasted.

Cut parts are then prepared for fabrication by chamfering edges for weld preparation using

mechanical and gas-chamfering process with scrap segregated once more.

Steel and bronze are taken from stock and transferred from the Cutting Hall to the Machine

Room and machined to the desired shape and size by a range of machining processes

including lathes, milling/boring machines, grinding machines, gear-hobbing machines,

centring machines and drilling machines. In all cases, the raw material is selected to be as


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close as possible in shape and size to the finished component to minimise the volume of

waste metal shavings. Machining work on large fabricated structures is also carried out in

the Machining Hall where a state of the art (BAT) milling & boring machined was installed in

the plant in 2010. This is a new part of the facility, which demonstrates again the dynamic

improvements made in the factory and shows the company’s dedication to improve

technology when and where necessary. All waste metal is segregated and collected for

subsequent recycling.

The bulk of waste metals are produced during cutting and machining operations and the

Fabrication processes result in a negligible quantity. This waste is in the form of light off-

cuts and dust from grinding. In each department where metal waste can be produced are

provided with 1m3 dedicated skips for waste metal segregation so that no metal needs to be

wasted. Annual metal waste quantities are presented in section 2 of the AER.

Efficiency of use of raw metals is dependent on operator skill and existing advanced

machinery at LCC and there are currently no apparent opportunities to improve metal use

efficiency further as BAT (best available techniques) are being utilised.

4.9.4 Oil and Grease Efficiency

LCC uses a range of oils and greases in its processes such as machining coolants, gear

lubricants, hydraulic and transmission oils, and bearing greases. These materials are

provided in a range of different grades and viscosities suitable for their particular application

operation location. The particular material and grade selected is dependent on the eventual

operating environment of the cranes produced which can be exported to any country in the

world ranging from extremely cold to high temperature destinations. Oils and greases are

also used in factory machinery.

Machining coolants/lubricants are used in machining operations such as lathes, milling,

drilling, gear-hobbing, slotting and tapping. Oil and grease are used in production machines

to ensure that they are operating productively and in transport vehicles in accordance with

manufacturers’ recommendations. These materials are a necessary part of the process and

have a limited lifespan after which they must be removed and replaced with clean oils and

grease. Used oils and grease are collected for recycling or disposal as appropriate. The

newly installed boring & milling machine in the machining uses a micro-lubrication system

which minimises the quantity of oil used for machining of fabricated crane components.

Oils and grease are incorporated into the product in crane gearboxes, hydraulic systems and

bearings. These materials are dispensed into the crane parts as required and no waste is

generated.


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4.9.5 Paint Product Efficiency

LCC uses currently uses up to 220,000L of solvent-based 2-component paint products at the

facility on an annual basis to provide corrosion protection and positive aesthetics for its

products which operate in corrosion-aggressive marine environments. Painting takes place

in two areas in the plant, namely the Cutting Hall and Paint shop, accounting for

approximately 1.5% and 98.5% of paint usage by volume respectively.

In the Cutting Hall an automatic shop priming machine is used to apply a thin coat of primer

(≈15µm) to steel profiles to protect them during the lengthy crane manufacturing process

which takes several months. Paint efficiency in this process was studied in detail with the

installation of the current machine which was installed in 2000 along with the construction

of a new state of the art shot-blasting hall at the north-west of the plant. Coupled with the

flexibility afforded to the company by the large shot-blasting plant which eliminated the

previous requirement to apply shop primer to all steel plates before cutting, the automatic

priming machine is fitted with a range of sensors and film spraying controls that enable the

machine to automatically sense when material is passing through and what width of the

conveyor is loaded. The machine therefore uses only a minimum quantity of paint. Prior to

2000, up to 30,000 L of paint was used annually in the shop priming process whereas only

2,500L was used in 2010 while production output has increased. This process utilises BAT

and there are no further opportunities for improving paint use efficiency.

Prior to 2011, the Paint Shop process involved the use of 20L drums in which a base and

curing agent were mixed as required for the components to be painted. Once mixed, the

paint started curing and any paint that was not used following mixing was wasted as the

curing process continued. Waste paint, paint thinner and empty drums were by-products of

this system. Waste paint was collected in 200L steel drums and small drums were crushed

and also placed into 200L steel drums for consignment as hazardous waste. Up to 92t of

paint related waste (inclusive of packaging) is produced annually up to 2011 (66t in 2011).

Over the last number of years LCC has been investigating ways of improving efficiency of use

of paint products and this was included in the company’s environmental objectives and

targets and environmental management programme. The culmination of these

investigations has resulted in the installation of a new paint kitchen which was

commissioned during May 2011. This new technology has greatly improved the efficiency of

paint usage and packaging at LCC. The paint kitchen automatically mixes the paint primers

as needed and distributes them throughout the paint shop through a pipework system.

Paint is delivered IBCs (intermediate bulk containers) which are returned to the supplier for

refilling. Finish paints are delivered in 200L drums (subject to minimum order quantities)

and mixed and sprayed using other automatic mixing stations. Some use of smaller 20L

drums will remain where small quantities of non-standard colours may be requested by

customers, which results in a quantity of associated waste as before. The new painting

process utilises BAT and this system represents the maximum efficiency of paint use

available at this present time.


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4.9.6 Process Gas Efficiency

LCC uses acetylene, oxygen, argon, carbon dioxide and compressed air gases in its

production processes and are piped throughout the facility. Acetylene is used and mixed

with oxygen for cutting and heating of steel. Argon and carbon dioxide are mixed to

produce a shielding gas for welding operations. Compressed air is used for shot-blasting and

compressed air tools.

Each of the process gases are used at the specified concentrations (where relevant) and

quantities required for production. Efficient use of these gases is to minimise waste by

means of effective maintenance of gas lines and minimisation and repair of leaks. Gas

pipelines are leak-tested annually departments are required to report any leaks in hoses as

they arise for subsequent repair.

LCC continues to examine ways of improving efficiency in all forms at the plant such as raw material

use efficiency, energy efficiency, and production efficiency on a continuous basis.

Water Demand Minimisation Report

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4.10 Report on progress made and proposals being developed to minimise water demand and

the volume of trade effluent discharges



“7.3 The licensee shall identify opportunities for reduction in the quantity of water used

on site including recycling and reuse initiatives, wherever possible. Reductions in

water usage shall be incorporated into Schedule of Environmental Objectives and

Targets.”

4.10.2 Water Usage at LCC

LCC is supplied with water from Kerry County Council through two incoming mains pipes

from the south of the facility. One mains pipe services the west and north of the facility

while the second pipeline supplies water to the centre and east of the plant. Water

consumption is typically approximately 6,500 m3 and this has fluctuated over the years as a

result of fluctuating employment rates at the company as well as leakages.

The principal use of water in the company is in the provision of sanitary and washing

facilities. There are 23 toilet facilities on site ranging from single cubicles to multi-lavatory

facilities for large numbers of employees, spread out among the various company

departments. Water is also used for drinking and cooking purposes, obtained from

dedicated drinking water fountains, kitchenettes and the main company canteen.

Water is used in one location as part of the production process, as a water abatement

system in the spray booth in the paint shop – this uses approximately 22,720L (5,000

gallons) and is a closed system that is circulated. This water is removed 2-3 times per year

and transported to Killarney waste water treatment plant, and the system is refilled. Finally,

water is used at a wash station at the north of the plant that is used sporadically to clean

company vehicles.

4.10.3 Water Efficiency

Buildings and facilities in the company range from 1958 to the present time and the

efficiency of water-using equipment is relative to the age of the buildings. Newer buildings

constructed since 1999 are fitted with personal urinals for men with manual flush whereas

older building lavatories have trough-type communal urinals which are automatically flushed

according to a fixed schedule whether or not the urinal has been recently used or

irrespective of the number of people that have used it (it is noted that LCC has a male-

dominated workforce). This latter system does not indicate an efficient use of water. These

systems are present in the sub-assembly building to the west and main fabrication hall to

the east, providing toilet facilities for approximately 240 people. It is apparent that these

self-flushing urinals should be phased out and replaced by personal manually flushing urinals

Water Demand Minimisation Report

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to improve water efficiency. This may be considered for incorporation to the factory

development plans to upgrade fabrication departments over the next few years. As an

interim water-saving measure, LCC has recently installed a senor on the ceiling over the

trough urinals such that flushing will not occur unless 5 people have passed beneath since

the last flush which reduces water consumption.

In line with plans for development of a new production hall to the east of the facility, it is intended to install a rain-water harvesting for toilet facilities. This development will reduce LCC’s water consumption requirements.

A number of substantial leaks resulted in significant water wastage in 2003, 2008-2009, and

2011 which have subsequently been rectified. Identification of the location of leaks in the

factory has been difficult and has taken some time to establish as much of the plant is

surfaced with 300mm of reinforced concrete. LCC is recommended to take greater note of

meter readings and conduct appropriate timely investigations if future leaks will be

identified in this way.

Development/Infrastructural Works Summary

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4.11 Development/Infrastructural works summary.



“SCHEDULE D: Annual Environmental Report

Development/Infrastructural works summary (completed in previous year or prepared for

current year).”

4.11.2 Development/Infrastructural works completed in 2011

A new tank farm for oxygen, argon and carbon dioxide was planned for constructed and

commissioned in April 2011. This development reduces the requirement for carbon dioxide

in the welding process whereby processes that previously 100% carbon dioxide as a

shielding gas now use and Ar/CO2 mix, the Ar percentage being over 80-88% (depending on

the process).

A new paint kitchen was installed in 2011 and commissioned in May. This new technology

has greatly improved the efficiency of paint usage and packaging at LCC. The paint kitchen

automatically mixes the paint primers as needed and distributes them throughout the paint

shop through a pipework system. This development reduces paint consumption and waste

and a proportional reduction in emissions.

4.11.3 Development/Infrastructural works planned for 2012

A new production hall is planned for the east of the facility for construction during 2012 and

2013. The new building will enable transfer of fabrication from the old western hall which

has little or no insulation to a modern state of the art facility.

Full retention oil separators will be installed in the eastern yard area in tandem with the new

development into which storm water runoff from hard standing yard areas will be

channelled.

A rain water harvesting system is planned for the new development to reduce LCC’s water

intake from the mains supply. The rain water will be used as grey water for the flushing of

toilets.

A new combined heating and welding fume extraction system will be installed in LCC’s layout

hall in 2012, replacing the oil-fired heating system. No external emissions will result from

the extraction system. This is a large-scale experiment of interest to LCC for other buildings

should it prove successful and also of interest to other companies in the LIEBHERR group.

A new shot-blasting machine will be installed in 2012/2013 using an impeller system instead

of compressed air which will improve efficiency and reduce compressed air consumption at

LCC, which has been identified as one of the highest energy consumers in the plant.

Management & Staffing Structure

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4.12 Management and staffing structure of the installation



“SCHEDULE D: Annual Environmental Report

Reports on financial provision made under this licence, management and staffing structure of

the installation, and a programme for public information.”

4.12.2 Liebherr Container Cranes Ltd. – Organisational Plan

A copy of the current LCC Organisational Plan is shown on the following page.

Management & Staffing Structure

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AER2012- Appendix A1

A1-1

Appendix A.1.

Underground foul sewer pipe inspection report. Following is a report of the underground foul sewer pipe test undertaken at LCC on 15/03/11 by Kerry Drain Services. All pipelines passed the testing procedure.

AER2012- Appendix A2

A2-1

Appendix A.2.

European Pollutant Release and Transfer Register (PRTR) for 2011. The following PRTR information was submitted electronically to the Agency on 23/03/12.

Appendix 2: PRTR

| PRTR# : P0146 | Facility Name : Liebherr Container Cranes Limited | Filename P0146_2011 to print.xls | Return Year : 2011 | 3681 23/03/2012 16:46

Guidance to completing the PRTR workbook

Version 1.1.13REFERENCE YEAR 2011

1. FACILITY IDENTIFICATIONParent Company Name Liebherr Container Cranes Limited

Facility Name Liebherr Container Cranes LimitedPRTR Identification Number P0146

Licence Number P0146-02

Waste or IPPC Classes of ActivityNo. class_name

12.2.2 #####################################################

Address 1 GortroeAddress 2 `-Address 3 Co. KerryAddress 4

KerryCountry Ireland

Coordinates of Location -9.55098 52.0690River Basin District IESW

NACE Code 2822Main Economic Activity Manufacture of lifting and handling equipment

AER Returns Contact Name Morgan FoleyAER Returns Contact Email Address [email protected]

AER Returns Contact Position EHS manager

AER Returns Workbook

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AER Returns Contact Position EHS managerAER Returns Contact Telephone Number 064-6670200

AER Returns Contact Mobile Phone NumberAER Returns Contact Fax Number 064-6634041

Production Volume 0.0Production Volume Units

Number of Installations 2Number of Operating Hours in Year 0

Number of Employees 0User Feedback/Comments

Web Address

2. PRTR CLASS ACTIVITIESActivity Number Activity Name50.1 General

3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002)Is it applicable? Yes

Have you been granted an exemption ? YesIf applicable which activity class applies (as per

Schedule 2 of the regulations) ? 8Is the reduction scheme compliance route being

used ? No

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Appendix 2: PRTR

4.1 RELEASES TO AIR Link to previous years emissions data | PRTR# : P0146 | Facility Name : Liebherr Container Cranes Limited | Filename : P0146_2011 to print.xls | Return Year : 2011 | 23/03/2012 16:468 8 16 16 24 24 6 6 6 6 6 7 24

SECTION A : SECTOR SPECIFIC PRTR POLLUTANTSPlease enter all quantities in this section in KGs

QUANTITY

No. Annex I Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year0.0 0.0 0.0 0.0

* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION B : REMAINING PRTR POLLUTANTSPlease enter all quantities in this section in KGs

QUANTITYtotal from all 8 emission

points for NMVOCNo. Annex I Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year

07 Non-methane volatile organic compounds (NMVOC) C MAB input/output calculation 78323.0 78323.0 0.0 0.0* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION C : REMAINING POLLUTANT EMISSIONS (As required in your LicencePlease enter all quantities in this section in KGs

QUANTITYextraction from plasma steel-

cuttingextraction from plasma

steel-cutting

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 Emission Point 2 T (Total) KG/YearA (Accidental) KG/Year

F (Fugitive) KG/Year

244 Total Particulates M PER isokinetic 151.0 165.0 316.0 0.0 0.0* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

Additional Data Requested from Landfill operators

Landfill: Liebherr Container Cranes Limited

Please enter summary data on the quantities of methane flared and / or utilised

additional_pollutant_no T (Total) kg/Year M/C/E Method CodeDesignation or

DescriptionFacility Total Capacity m3

per hourTotal estimated methane generation (as per site

model) 0.0 N/AMethane flared 0.0 0.0 (Total Flaring Capacity)

Methane utilised in engine/s 0.0 0.0 (Total Utilising Capacity)Net methane emission (as reported in Section A

above) 0.0 N/A

Method Used

Method Used

RELEASES TO AIRPOLLUTANT METHOD

Method Used

POLLUTANT

RELEASES TO AIR

RELEASES TO AIRMETHOD

POLLUTANT METHOD

Method Used

For the purposes of the National Inventory on Greenhouse Gases, landfill operators are requested to provide summary data on landfill gas (Methane) flared or utilised on their facilities to accompany the figures for total methane generated. Operators should only report their Net methane (CH4) emission to the environment under T(total) KG/yr for Section A: Sector specific PRTR pollutants above. Please complete the table below:

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Appendix 2: PRTR

5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE | PRTR# : P0146 | Facility Name : Liebherr Container Cranes Limited | Filename : P0146_2011 to print.xls | Return Year : 2011 | 23/03/2012 16:465 38 Please enter all quantities on this sheet in Tonnes 21

Quantity (Tonnes per

Year)

Haz Waste : Name and Licence/Permit No of Next

Destination Facility Non Haz Waste: Name and Licence/Permit No of

Recover/Disposer

Haz Waste : Address of Next Destination Facility

Non Haz Waste: Address of Recover/Disposer

Name and License / Permit No. and Address of Final Recoverer /

Disposer (HAZARDOUS WASTE ONLY)

Actual Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)

Transfer DestinationEuropean Waste

Code Hazardous Quantity T/Year Description of Waste

Waste Treatment Operation M/C/E Method Used

Location of Treatment Name and Licence / Permit No. of Recoverer / Disposer / Broker Address of Recoverer / Disposer / Broker Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY) Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)

To Other Countries 08 01 11 Yes 37.229waste paint and varnish containing organic solvents or other dangerous substances R3 M Weighed Abroad Indaver Ireland Ltd.,W0036-2

Tolka Quay Road,Dublin Port,Dublin,1,Ireland

Nehlsen GmbH & CO. KG,D33300040 / 430 U,Louis-Kragas Strasse 10,Bremen,.,D-28237,Germany

Louis-Kragas Strasse 10,Bremen,.,D-28237,Germany

To Other Countries 08 01 11 Yes 14.077waste paint and varnish containing organic solvents or other dangerous substances R3 M Weighed Abroad

Eco-Safe Systems Ltd.,W0054-2

Kylemore Road Ballyfermot,Unit 1A Allied Insustrial Estate,Dublin 10,.,Ireland

Lindenschmidt KG Umweltservice,04 714 98089,Krombacher Strasse ,42-46,Kreuztal-Krombach,57223,Germany

Krombacher Strasse ,42-46,Kreuztal-Krombach,57223,Germany

To Other Countries 08 01 21 Yes 2.378 waste paint or varnish remover R3 M Weighed Abroad Indaver Ireland Ltd.,W0036-2Tolka Quay Road,Dublin Port,Dublin,1,Ireland



To Other Countries 08 01 21 Yes 1.381 waste paint or varnish remover R3 M Weighed AbroadEco-Safe Systems Ltd.,W0054-2




To Other Countries 11 01 13 Yes 0.498degreasing wastes containing dangerous substances R13 C Volume Calculation Abroad Safety Kleen Ltd.,W0099-01

Airton Road,Unit 5,Tallaght Dublin 24,.,Ireland

Solvent Resource Management Ltd.,TP3334SF,Weeland Road,Knottingley,West Yorkshire,WF11 8DZ,United Kingdom

Weeland Road,Knottingley,West Yorkshire,WF11 8DZ,United Kingdom

To Other Countries 12 01 09 Yes 1.96machining emulsions and solutions free of halogens R3 M Weighed Abroad





Method Used

Within the Country 13 02 08 Yes 3.42 other engine, gear and lubricating oils R9 C Volume Calculation Offsite in Ireland Enva Ireland,W0184-01

Clonminam Industrial Estate,.,Portlaoise Co. Laois,.,Ireland

Enva Ireland,W0184-01,Clonminam Industrial Estate,.,Portlaoise Co. Laois,.,Ireland


Within the Country 13 05 07 Yes 7.0 oily water from oil/water separators R9 C Volume Calculation Offsite in Ireland Enva Ireland,W0184-01


Enva Ireland,W0184-01,Clonminam Industrial Estate,.,Portlaoise Co. Laois,.,Ireland


To Other Countries 15 01 10 Yes 10.69packaging containing residues of or contaminated by dangerous substances R3 M Weighed Abroad Indaver Ireland Ltd.,W0036-2

Tolka Quay Road,Dublin Port,Dublin,1,Ireland



To Other Countries 15 01 10 Yes 0.18packaging containing residues of or contaminated by dangerous substances R3 M Weighed Abroad





To Other Countries 15 02 02 Yes 0.08

absorbents, filter materials (including oil filters not otherwise specified), wiping cloths, protective clothing contaminated by dangerous substances R1 M Weighed Abroad





To Other Countries 16 05 04 Yes 0.96gases in pressure containers (including halons) containing dangerous substances R4 E Volume Calculation Abroad Enva Ireland,W0184-01


Remondis Industrie Service GmbH,H 09037950,Austrasse,5,Krautheim,D-74238,Germany

Austrasse,5,Krautheim,D-74238,Germany

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Appendix 2: PRTR


Year)



Recover/Disposer










Method Used

To Other Countries 16 06 01 Yes 0.46 lead batteries R4 M Volume Calculation Abroad Enva Ireland,W0184-01


Campine Recycling NV,OVAM cert,Nijverheidsstraat,2,Beerse,2340,Belgium

Nijverheidsstraat,2,Beerse,2340,Belgium

Within the Country 20 01 21 Yes 0.115fluorescent tubes and other mercury-containing waste R5 E Volume Calculation Offsite in Ireland

Irish Lamp Recycling Co. Ltd.,WFP-KE-08-0348-01

Kilkenny Rd.,Blackpark,Athy Co. Kildare,.,Ireland

Irish Lamp Recycling Co. Ltd.,WFP-KE-08-0348-01,Kilkenny Rd.,Blackpark,Athy Co. Kildare,.,Ireland


Within the Country 20 01 33 Yes 0.05

batteries and accumulators included in 16 06 01, 16 06 02 or 16 06 03 and unsorted batteries and accumulators containing these batteries R4 E Volume Calculation Offsite in Ireland



KMK Metals Recycling Ltd.,113-2,Daingean Road,Cappincur Industrial Estate,Tullamore,Co. Offaly,Ireland

Daingean Road,Cappincur Industrial Estate,Tullamore,Co. Offaly,Ireland

Within the Country 20 01 35 Yes 0.45

discarded electrical and electronic equipment other than those mentioned in 20 01 21 and and 20 01 23 containing hazardous components R12 E Volume Calculation Offsite in Ireland



Irish Lamp Recycling Co. Ltd.,WFP-KE-08-0348-01,Kilkenny Rd.,Blackpark,Athy Co. Kildare,.,Ireland


Within the Country 08 01 99 No 68.2 wastes not otherwise specified R5 E Volume Calculation Offsite in Ireland

Kerry County Council Waste Water Treatment Plant,D0037-01

Ross Road,.,Killarney,.,Ireland

Within the Country 08 03 18 No 0.18waste printing toner other than those mentioned in 08 03 17 R3 M Weighed Offsite in Ireland

Redeem PLC,WFP/MH/09/0004/01

Ashbourne Industrial Estate,Unit No. 19,Ashbourne Co. Meath,.,Ireland

To Other Countries 08 03 18 No 0.05waste printing toner other than those mentioned in 08 03 17 R3 E Volume Calculation Abroad Systems 2000,n/a

Harbour veiw,Hill house,Kilbritain Co. Cork,.,Ireland

K2 Supplies (ERS Europe),CB/EP3110QM,Felstead Road,D1 Longmead Business Centre,Epsom Surray,KT19 9QG,United Kingdom

Felstead Road,D1 Longmead Business Centre,Epsom Surray,KT19 9QG,United Kingdom

Hegarty Metals Processors

Within the Country 12 01 01 No 211.9 ferrous metal filings and turnings R4 M Weighed Offsite in Ireland(International) Ltd.,WFP-LKC-11-001-01

Ballysimon Rd.,.,Limerick,.,Ireland

Within the Country 12 01 03 No 1.8 non-ferrous metal filings and turnings R4 M Weighed Offsite in Ireland

Hegarty Metals Processors (International) Ltd.,WFP-LKC-11-001-01


To Other Countries 15 01 01 No 14.7 paper and cardboard packaging R3 C Volume Calculation AbroadPeute Papierrecycling,DO 02.2017 MDO DO2874

Baanhoekweg,4,Dordrecht,3313 LA,Netherlands

To Other Countries 15 01 02 No 0.9 plastic packaging R3 E Volume Calculation AbroadChoice Waste Management Ltd.,CB/WE5536VU

Brick Close,Denmark House,Milton Keynes Buckinghamshire,MK11 3DP,United Kingdom

Within the Country 15 01 06 No 8.7 mixed packaging R3 E Volume Calculation Offsite in IrelandKillarney Waste Disposal Ltd.,W0217-01

Aughacureen,.,Killarney,.,Ireland

To Other Countries 20 01 01 No 18.2 paper and cardboard R3 E Volume Calculation AbroadPeute Papierrecycling,DO 02.2017 MDO DO2874

Baanhoekweg,4,Dordrecht,3313 LA,Netherlands

Within the Country 20 01 08 No 5.9 biodegradable kitchen and canteen waste R3 C Volume Calculation Offsite in IrelandO’Toole Composting,WFP-CW-10-0003-01

Ballintrane,.,Co. Carlow,.,Ireland

Within the Country 20 01 38 No 163.8 wood other than that mentioned in 20 01 37 R3 M Weighed Offsite in IrelandKillarney Waste Disposal Ltd.,W0217-01

Aughacureen,.,Killarney,.,Ireland

Within the Country 20 01 40 No 1633.4 metals R4 M Weighed Offsite in Ireland

Hegarty Metals Processors (International) Ltd.,WFP-LKC-11-001-01


To Other Countries 20 01 40 No 579.5 metals R4 M Weighed AbroadC.F. Booth Ltd.,EAWML61595

Armer Street,Clarence Metal Works,Rotherham Yorkshire,S60 1AF,United Kingdom

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Appendix 2: PRTR


Year)



Recover/Disposer










Method Used

Within the Country 20 03 01 No 180.7 mixed municipal waste D1 M Weighed Offsite in IrelandKerry County Council,W0001-04

Muingnaminnane,.,Tralee,.,Ireland

Within the Country 17 05 04 No 59000.0soil and stones other than those mentioned in 17 05 03 R10 E Volume Calculation Offsite in Ireland

Patrick Lynch,WFP-KY-09-0004-01

Knockeenduff,.,Killarney,.,Ireland


Shane O'Callaghan Kilcummin GAA Club,WFP-KY-D9-0002-01

Kllcummin,Clashnagarrane,Killarney,.,Ireland


Mark Hallissey,COR-KY-11-0004-01 Fossa,Ards,Killarney,.,Ireland


Killarney Waste Disposal,WP-08-1

Sheans East,.,Killarney,.,Ireland

* Select a row by double-clicking the Description of Waste then click the delete button

Link to previous years waste dataLink to previous years waste summary data & percentage change

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