Annual Environmental Report 2013 · lCC is engaged in the production of rail-mounted and...

Annual Environmental Report –

2013

(Reporting Period – Jan to Dec 2012)

IPPC Licence No. P0146-02

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

http://aer.epa.ie/reporting

AER 2013

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Contents Page 1. Summary Information ............................................................................................. 3 1.1 Facility Information Summary .......................................................................................... 3 1.2 AER summary template-AIR emissions ............................................................................ 4 1.3 AER Monitoring returns summary template-WATER/WASTEWATER(SEWER) ............... 8 1.4 Bund/pipe testing report summary ................................................................................. 11 1.5 Groundwater/Contaminated land summary report ........................................................ 12 1.6 Environmental Liability Risk Assessment (ELRA)/

Closure Restoration Aftercare management Plan (CRAMP)/ Restoration Management Plan (RMP)/Financial Provision (FP) ...................................... 14

1.7 Environmental Management Programme (EMP) / Continuous Improvement Programme Report ................................................................ 15

1.8 Noise Monitoring Report Summary ................................................................................. 18 1.9 Resource Usage/Energy Efficiency/Waste Reduction ..................................................... 19 1.10 Summary of Complaints/Incidents .................................................................................. 21 1.11 Waste ............................................................................................................................... 22 1.12 Pollutant Release and Transfer Register (PRTR) .............................................................. 24 2. Management of the Activity .................................................................................... 31 2.1 Schedule of Environmental Objectives and Targets ........................................................ 31 2.2 Environmental Management Programme Proposal 2013 ............................................... 34 3. Licence-Specific Reports .......................................................................................... 40 3.1 Public Awareness & Communications Programme ......................................................... 40 3.2 Solvent Management Plan (SMP)

(incorporating a fugitive emissions reduction programme) ............................................ 41 3.3 Environmental Liabilities, Statement of Measures for Prevention

of Environmental Damage, and Financial Provisions ....................................................... 47 3.4 Review of Decommissioning Management Plan (DMP) .................................................. 50 3.5 Energy efficiency audit report summary ......................................................................... 51 3.6 Report on the assessment of the efficiency of use of raw materials in

processes and the reduction in waste generated ............................................................ 54 3.7 Report on progress made and proposals being developed to minimise

water demand and the volume of trade effluent discharges .......................................... 59 3.8 Development/Infrastructural works summary

(completed in previous year or prepared for current year) ............................................ 61 3.9 Management and staffing structure of the installation .................................................. 62

11,1 Facility Information Summary

Licence Register Number

Name of site

Site location

NACE Code

Class of Activ ity

RBME risk category

National Grid Reference (6E, 6 N)

A brief description of the activities/process

at the site for the reporting year. This

should include information such as

production increases or decreases on Site, any infrastructural changes, environmental

performance improvements which were

measured during the reporting year;

P0146-02

liebherr Container Cranes ltd_

Gortroe, Killarney, Co_ Kerry.

2822

12.2.2, 11.1

B3

493728E, 591919N

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. lCe'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.

The construction of a new steel fabrication hall commenced in October 2012, due for completion in autumn

2013. A programme for installation of storm water oil separators commenced in 2012.

ation presented in this report has been checked and certified as being accurate. The

edto

Ca te

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1.2 AER summary template‐AIR emissions

Parameter

/Substance

Annual fugitive

emission (kg/annum)

Quantificaton

method M/C/E

Total Organic

Carbon (as C)Not Quantified

SELECT

2

No

3Basic air

monitoring

checklist AGN2 Yes

Table 2: Licensed Mass Emissions/Ambient data‐periodic monitoring (non‐continuous)

Emission

reference no: Parameter/ SubstanceDate of Monitoring

ELV in licence

or any revision

therof Licence Compliance criteria Measured valueUnit of

measurement

Compliant with

licence limit Method of analysis

Annual mass

load (kg)

% change in

mass load

from

previous

year +/‐ Comments

A2‐1

Total Organic Carbon (as

C) 21/02/2012 300 100 % of values < ELV 44 mg/Nm3 yes ALT

A2‐2



A2‐3



A2‐4



A2‐5



A2‐6



A2‐7


C) no data 300 100 % of values < ELV out of service mg/Nm3 SELECT SELECT

Periodic/Non‐Continuous Monitoring

Are there any results in breach of licence requirements? If yes please provide brief details in the comment

section of Table 2 below

Was all monitoring carried out in accordance with EPA

guidance note AG2 and using the basic air monitoring

checklist? Confirmed by contractor, Southern Scientific Services

Table 1 Fugitive emissions

Additional information

1

Does your site have licensed air emissions? If yes please complete table 1, 2 and 3 below for the

current reporting year and answer further questions. If you do not have licenced emissions and

do not complete a solvent management plan (table 5 and 6) you only need to complete table 1

fugitive emissions on site belowYes

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A2‐8



A2‐9 Total Particulates 22/02/2012 10 100 % of values < ELV 1 mg/Nm3 yes ALT

A2‐10 Total Particulates 22/02/2012 10 100 % of values < ELV 1.2 mg/Nm3 yes ALT

A2‐1



A2‐2



A2‐3



A2‐4



A2‐5



A2‐6



A2‐7



A2‐8





A2‐1



A2‐2



A2‐3



A2‐4



A2‐5



A2‐6



A2‐7



A2‐8





A2‐1



A2‐2



A2‐3



A2‐4



A2‐5



- 5 -

A2‐6



A2‐7



A2‐8



A2‐9 Total Particulates 22/11/2012 10 100 % of values < ELV 1.8 mg/Nm3 yes ALT

A2‐10 Total Particulates 22/11/2012 10 100 % of values < ELV 4.3 mg/Nm3 yes ALTSELECT SELECT SELECT SELECT SELECT

Note 1: Volumetric flow shall be included as a reportable parameter

4 No

5SELECT

6SELECT

7SELECT

Table 3: Summary of average emissions ‐continuous monitoring

Emission

reference no:

Parameter/ Substance

ELV in licence or

any revision

therof

Averaging

Period

Compliance Criteria Units of

measurement

Annual Emission Annual maximum Monitoring

Equipment

downtime (hours)

% compliance

current

reporting year

Comments

SELECT SELECT SELECT

note 1: Volumetric flow shall be included as a reportable parameter.

Table 4: Abatement system bypass reporting table Bypass protocol

Date* Duration** (hours) Location

8 Do you have a total Emission Limit Value of direct and fugitive emissions on site? if yes please fill out table 5SELECT

* this should include all dates that an abatement system bypass occurred

** an accurate record of time bypass beginning and end should be logged on site and maintained for future

Agency inspections please refer to bypass protocol link

Do you have a proactive service agreement for each piece of continuous monitoring equipment?

Did your site experience any abatement system bypasses? If yes please detail them in table 4 below

Reason for bypass Corrective action

Continuous Monitoring Does your site carry out continuous air emissions monitoring?

If yes please review your continuous monitoring data and report the required fields below in Table 3 and

compare it to its relevant Emission Limit Value (ELV)

Did continuous monitoring equipment experience downtime? If yes please record downtime in table 3

below

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Solvent

regulations

Reporting year Total solvent input on

site (kg)

Total VOC

emissions to Air

from entire site

(direct and

fugitive)

Total VOC

emissions as

%of solvent

input Total Emission Limit Value

(ELV) in licence or any revision

therof

Compliance

SELECT

SELECT

(I) Inputs (kg)

Solvent

(I) Inputs (kg)

Organic solvent

emission in

waste gases(kg)

Solvents lost in

water (kg)

Collected waste solvent (kg) Fugitive Organic

Solvent (kg)

Solvent released

in other ways e.g.

by‐passes (kg)

Solvents destroyed

onsite through

physical reaction

e.g.

incineration(kg)

Total emission of

Solvent to air (kg)

Total

Table 6: Solvent Mass Balance summary

(O) Outputs (kg)

Table 5: Solvent Management Plan Summary

Total VOC Emission limit value

Please refer to linked solvent regulations to

complete table 5 and 6

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1.3 AER Monitoring returns summary template‐WATER/WASTEWATER(SEWER)

2

Yes

Location

reference

Location relative to

site activitiesPRTR Parameter

Licenced

Parameter

Monitoring

date

ELV or trigger

level in licence or

any revision

thereof*Licence Compliance criteria Measured value

Unit of

measurement

Compliant with

licence Comments

SW1 SELECT SELECT SELECT SELECT SELECT SELECT

*trigger values may be agreed by the Agency outside of licence conditions

Location

Reference Date of inspection Source of

contamination

SELECT

SELECT

3SELECT

4

External /Internal

Lab Quality

checklist

Assessment of

results checklist SELECT

Table 3: Licensed Emissions to water and /or wastewater (sewer)‐periodic monitoring (non‐continuous)

Emission

reference no: Emission released toParameter/

SubstanceNote 1 Type of sampleDate of Monitoring Averaging period

ELV or trigger

values in licence or

any revision

therofNote 2

Licence Compliance criteria Measured value

Unit of

measurement

Compliant with

licence Method of analysis

Procedural

reference source

Procedural

reference

standard numberAnnual mass load

(kg)

% change in mass

load from

previous year +/‐ Comments

SW1 Water pH discrete 16/03/2012 n/a

no emission of

environmental

significance

8 pH units yes pH Meter (Electrode)

APHA / AWWA

"Standard

Methods" 4500‐H+

SW1 Water COD discrete 16/03/2012 n/a

no emission of

environmental

significance

45 mg/L yesDigestion +

Spectrophotometry

APHA / AWWA

"Standard

Methods" 5220 D


no emission of

environmental

significance

6.8 pH units yes pH Meter (Electrode)

APHA / AWWA

"Standard

Methods" 4500‐H+


no emission of

environmental

significance


Spectrophotometry

APHA / AWWA

"Standard

Methods" 5220 D


no emission of

environmental

significance


APHA / AWWA

"Standard

Methods" 4500‐H+


no emission of

environmental

significance

<2 mg/L yesDigestion +

Spectrophotometry

APHA / AWWA

"Standard

Methods" 5220 D

SE1 Wastewater/Sewer pH discrete 26/03/2012 n/a 6‐9

No pH value

shall deviate

from the

specified range.


APHA / AWWA

"Standard

Methods"4500‐H+

Licensed Emissions to water and /or wastewater(sewer)‐periodic monitoring (non‐continuous)

Was there any result in breach of licence requirements? If yes please provide brief details in the

comment section of Table 3 below Additional information

Was all monitoring carried out in accordance with EPA guidance

and checklists for Quality of Aqueous Monitoring Data Reported to

the EPA? If no please detail what areas require improvement in

additional information box

CommentsDescription of contamination Corrective action

Was it a requirement of your licence to carry out visual inspections on any surface water

discharges or watercourses on or near your site? If yes please complete table 2 below

summarising only any evidence of contamination noted during visual inspections

Table 1 Ambient monitoring

Table 2 Visual inspections‐Please only enter details where contamination was observed.


1

Does your site have licensed emissions direct to surface water or direct to sewer? If yes please

complete table 3 and 4 below for the current reporting year and answer further questions. If

you do not have licenced emissions you only need to complete table 1 and /table 2 below for

ambient monitoring and visual inspectionsYes

‐ 8 ‐

Emission



ELV or trigger


any revision

therofNote 2


Unit of

measurement

Compliant with


Procedural

reference source

Procedural

reference


(kg)

% change in mass

load from


SE1 Wastewater/Sewer COD discrete 26/03/2012 n/a not specified 6 mg/L yesDigestion +

Spectrophotometry

APHA / AWWA

"Standard

Methods" 5220 D

SE1 Wastewater/Sewer Fats, Oils and Greases discrete 26/03/2012 n/a 10 All values < ELV <2 mg/L yes Gravimetric analysis

APHA / AWWA

"Standard

Methods" 5520 B


no emission of

environmental

significance


APHA / AWWA

"Standard

Methods" 4500‐H+


no emission of

environmental

significance

<5 mg/L yesDigestion +

Spectrophotometry

APHA / AWWA

"Standard

Methods" 5220 D


no emission of

environmental

significance


APHA / AWWA

"Standard

Methods" 4500‐H+


no emission of

environmental

significance


Spectrophotometry

APHA / AWWA

"Standard

Methods" 5220 D


no emission of

environmental

significance


APHA / AWWA

"Standard

Methods" 4500‐H+


no emission of

environmental

significance


Spectrophotometry

APHA / AWWA

"Standard

Methods" 5220 D


no emission of

environmental

significance


APHA / AWWA

"Standard

Methods" 4500‐H+


no emission of

environmental

significance


Spectrophotometry

APHA / AWWA

"Standard

Methods" 5220 D


no emission of

environmental

significance


APHA / AWWA

"Standard

Methods" 4500‐H+


no emission of

environmental

significance


Spectrophotometry

APHA / AWWA

"Standard

Methods" 5220 D


no emission of

environmental

significance


APHA / AWWA

"Standard

Methods" 4500‐H+


no emission of

environmental

significance


Spectrophotometry

APHA / AWWA

"Standard

Methods" 5220 D


No pH value

shall deviate

from the

specified range.


APHA / AWWA

"Standard

Methods"4500‐H+


Spectrophotometry

APHA / AWWA

"Standard

Methods" 5220 D

SE1 Wastewater/Sewer Fats, Oils and Greases discrete 10/07/2012 n/a 10 All values < ELV <2 mg/L yes Gravimetric analysis

APHA / AWWA

"Standard

Methods" 5520 B


no emission of

environmental

significance


APHA / AWWA

"Standard

Methods" 4500‐H+


no emission of

environmental

significance


Spectrophotometry

APHA / AWWA

"Standard

Methods" 5220 D


no emission of

environmental

significance


APHA / AWWA

"Standard

Methods" 4500‐H+


no emission of

environmental

significance


Spectrophotometry

APHA / AWWA

"Standard

Methods" 5220 D


no emission of

environmental

significance


APHA / AWWA

"Standard

Methods" 4500‐H+

‐ 9 ‐

Emission



ELV or trigger


any revision

therofNote 2


Unit of

measurement

Compliant with


Procedural

reference source

Procedural

reference


(kg)

% change in mass

load from



no emission of

environmental

significance


Spectrophotometry

APHA / AWWA

"Standard

Methods" 5220 D


No pH value

shall deviate

from the

specified range.


APHA / AWWA

"Standard

Methods"4500‐H+


Spectrophotometry

APHA / AWWA

"Standard

Methods" 5220 D

SE1 Wastewater/Sewer Fats, Oils and Greases discrete 20/11/2012 n/a 10 All values < ELV 4.2 mg/L yes Gravimetric analysis

APHA / AWWA

"Standard

Methods" 5520 B

Note 1: Volumetric flow shall be included as a reportable parameter

5 SELECT

6SELECT

7SELECT

8SELECT

Table 4: Summary of average emissions ‐continuous monitoring

Emission

reference no: Emission released to Parameter/ Substance

ELV or trigger

values in licence

or any revision

thereof

Averaging

Period

Compliance

Criteria

Units of

measurement

Annual Emission

for current

reporting year

(kg)

% change +/‐ from

previous reporting

yearMonitoring

Equipment

downtime (hours)

% compliance

current reporting

year

SELECT SELECT SELECT SELECT SELECT

SELECT SELECT SELECT SELECT SELECT

note 1: Volumetric flow shall be included as a reportable parameter.

Table 5: Abatement system bypass reporting tableDate Duration (hours) Location Resultant

emissions

Reason for

bypass

Corrective

action*

Was a report

submitted to the

EPA?

When was this

report

submitted?

SELECT

*Measures taken or proposed to reduce or limit bypass frequency

Did continuous monitoring equipment experience downtime? If yes please record downtime in table 4

below

Do you have a proactive service contract for each piece of continuous monitoring equipment on site?

Did abatement system bypass occur during the reporting year? If yes please complete table 5 below

Comments

If yes please summarise your continuous monitoring data below in Table 4 and compare it to its

relevant Emission Limit Value (ELV)

Note 2: Where Emission Limit Values (ELV) do not apply to your licence please compare results against EQS for Surface water or relevant receptor quality standards

Continuous monitoring Additional Information

Does your site carry out continuous emissions to water/sewer monitoring?

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1.4

Bund testing Additional information

1 Yes

2 Please provide integrity testing frequency period 3 years next test due in March 2015

3 Yes

not all mobile bunds are

documented on a register

Bund/Containment

structure ID Type Specify Other type Product containment Actual capacity Capacity required* Type of integrity test Other test type Test date

Integrity reports

maintained on

site? Results of test

Integrity test failure

explanation <50 words Corrective action taken

Scheduled date

for retest

Results of

retest(if in

current

reporting year)

Diesel Tank Farm reinforced concrete Diesel Oil 124m3 136.4m3

Hydraulic test 28/03/2012 Yes Pass Repaired crack

SELECT SELECT SELECT SELECT SELECT* Capacity required should comply with 25% or 110% containment rule as detailed in your licence Commentary

4 bunding and storage guidelines Yes

Testing carried out but not as per

BS8007 duration which is considered

unsafe and therefore shortened

5 Are channels/transfer systems to remote containment systems tested? SELECT not applicable

6 Are channels/transfer systems compliant in both integrity and available volume? SELECT not applicable

7 Yes

following clarification with the EPA

verifying applicable areas, high level

liquid alarms have been fitted to

one underground diesel tank and

above‐ground tank

8 No

1 Yes

2 Please provide integrity testing frequency period 3 years

next diesel tank test due, end 2014;

next foul sewer pipe test due,

March 2014

Structure ID Type system Material of construction:

Does this structure have

Secondary containment?

Type of secondary

containment

Type integrity testing

Integrity reports

maintained on site? Results of test

Integrity test

failure explanation

<50 words

Corrective action

taken

Scheduled date

for retest

Results of retest(if in current

reporting year)

Underground diesel

tank Process steel Yes double‐skinned tank

Air Yes Pass SELECT

Foul Sewer Pipeline Foul pvc No Hydraulic Yes Pass

Please use commentary for additional details not answered by tables/ questions above

Pipeline/underground structure testing

Are you required by your licence to undertake integrity testing on underground structures e.g. pipelines or sumps etc ? if yes please fill out table 2 below listing

all underground structures and pipelines on site

Intensive agriculture facilities please use alternative template

Are you required by your licence to undertake integrity testing on bunds and containment structures ? if yes please fill out table 1 below listing all bunds and

containment structures on site

Does the site maintain a register of bunds, underground pipelines (including stormwater and foul), Tanks, sumps and containers? (containers refers to

"Chemstore" type units and mobile bunds)

Table 1: Summary details of bund integrity test

Do all sumps and chambers have high level liquid alarms?

If yes to Q7 are these failsafe systems included in a maintenance and testing programme?

Table 2: Summary details of underground structures/pipeline integrity test

Has integrity testing been carried out in accordance with licence requirements and are all structures tested

in line with BS8007/EPA Guidance?

dropdown menu click to see options

Bund/pipe testing report summary ALL IPPC/WASTE licensed facilities

‐ 11 ‐

1.5

Comments

1no

2 no

3no

4no

5SELECT

6

7 SELECT

8 SELECT

9 SELECT

10 SELECT

11 SELECT

12 SELECT

Table 1: Upgradient Groundwater monitoring results

Date of sampling

Sample location reference

Parameter/ Substance Methodology Monitoring frequency

Maximum Concentration++

Average Concentration+ unit GTV's* SELECT**

% change in

average

concentration

previous year +/‐

Upward trend in

pollutant

concentration over last

5 years of monitoring

data

SELECT SELECT

SELECT SELECT

.+ where average indicates arithmetic mean

.++ maximum concentration indicates the maximum measured concentration from all monitoring results produced during the reporting year

Table 2: Downgradient Groundwater monitoring results

Date of sampling



Maximum Concentration

Average Concentration unit GTV's* SELECT**

% change in

average

concentration

previous year +/‐

Upward trend in yearly

average pollutant

concentration over last

5 years of monitoring

data

SELECT SELECT

SELECT SELECT

Surface

water EQS

Groundwater

regulations

GTV's

Drinking water

(private supply)

standards

Drinking water (public

supply) standards

Interim Guideline

Values (IGV)

Groundwater /Contaminated land summary report

Are you required to carry out groundwater monitoring as part of your licence

requirements?

Are you required to carry out soil monitoring as part of your licence requirements?

Do you extract groundwater for use on site? If yes please specify use in comment section

Is there contaminated land and /or groundwater on site? If yes please answer q's 5‐12

Is the contamination related to operations at the facility (either current and/or historic)

Have actions been taken to address contamination issues?If yes please summarise

remediation strategies proposed/undertaken for the site SELECT

Please specify the proposed time frame for the remediation strategy

Is there a licence condition to carry out/update ELRA for the site?

Has any type of risk assesment been carried out for the site?

Has a Conceptual Site Model been developed for the site?

Have potential receptors been identified on and off site?

Is there evidence that contamination is migrating offsite?

* please note exceedance of a relevant Groundwater threshold value (GTV) at a representative monitoring point does not indicate non compliance, an exceedance triggers further investigation to

confirm whether the criteria for poor groundwater chemical status are being met.

**Depending on location of the site and proximity to other sensitive receptors alternative Receptor based Water Quality standards should be used in addition to

the GTV e.g. if the site is close to surface water compare to Surface Water Environmental Quality Standards (SWEQS), If the site is close to a drinking water supply

compare results to the Drinking Water Standards (DWS)

‐ 12 ‐

1.5

Table 3: Soil results

Date of sampling



Maximum Concentration

Average Concentration unit

SELECT

SELECT

Where additional detail is required please enter it here in 200 words or less

‐ 13 ‐

1.6

Commentary

1Yes

2 Yes

3 23/02/2011

4 24/06/2011

5 Cash in bank €194,000

6 No

7 n/a

8 Jan‐14

9 Please list the top 10 risks assessed on your site in table 1 below

Table 1 ELRA summary information

Click here to access EPA

guidance on ELRA Operational Risk Assessment Category SELECT

Action

Date of

implementation of

mitigation

measures Comment

Revised Risk score for

current reporting

year ELRA costing

e.g20. Storm Drains Potential leak or spill of paint/solvent/oil into drain Contamination of stream and lake 12 Infrastructural improvements

EMP project in place and EPA

agreement for installation of oil

separators

12 Yes

17. Unbunded plastic

diesel tankPotential spillage/leak to soils/groundwater Contamination of soils, surface water & 9 Infrastructural improvements

Will be agreed following

completion of mitigation works

associated with Risk No 20

above.

9 Yes

16. Underground diesel

tank Potential leak to soils/groundwater Contamination of soils & groundwater 8 Infrastructural improvements

Tank is double skinned and

regularly integrity tested 8 Yes

1. Main Stores Spillage of paints/solvents/oils

Ground and surface water

contamination 6 Nothing Low Risk 6 Yes

3. Cutting Hall –

production Floor Spillage of pains/solvents



15. Diesel & Oil Tanks

(bunded) Potential spillage/leak to soils/groundwater Contamination of soils & groundwater 6 Nothing Low Risk 6 Yes

5. Machine Shop ‐

Production Floor Spillage of Oil



6. Shot Blast Paint Shop –

Production Floor Spillage of paints/solvents/oils



7.Paint Shop – Production

Floor Fire Air Contamination 3 Nothing Low Risk 3 Yes

8. Shot Blast Fire Air Contamination 3 Nothing Low Risk 3 Yes

Total SELECT SELECT SELECT SELECT

1 Yes DMP for clean closure2 Yes

3

4 Cash in bank €305,400

5 n/a

6 implementation not required

Table 2 CRAMP summary information (NON Landfill)

Date of submission of plan Risk category Closure plan in place Clean closure

Restoration Aftercare

Management Plan

Change in Risk

category since

previous year Increase in risk category

Does the current

financial provision

cover the risk score?

Value of current

financial provision

for site

23/02/2011 3 Yes Yes N/A No No Yes €305,400.00

What financial instrument/s do you have in place to cover unknown liabilities?

Environmental Liability Risk Assessment

Is it a requirement of your licence to complete an ELRA?

Has an initial ELRA been submitted to and approved by the Agency?

Please enter the date of submission of the initial ELRA

Date of most recent substantial ELRA update

Has this financial instrument/s been verified by the Agency?

What is the date of expiry of this financial instrument?

Date of next required review of the ELRA?

Risk ID Potential hazards Environmental effect

What is the date of expiry of this financial instrument?

What is the status of implementation of the plan?

ELRA

Does the current

financial provision

(FP) cover the risk

score?

Has a closure plan submission been approved by the Agency?

What is the timescale for submission?

What financial instrument do you have in place to cover known liabilities?

Closure Restoration Aftercare Management Plan/ Restoration plan (CRAMP/RP)Was a closure or restoration plan a requirement of the licence?

Previous risk score

Mitigation measures to reduce risk

‐ 14 ‐

1.7

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 1/2012

Installation of energy

efficient lighting:

Target Date ‐ End 2015

20

Trial installation completed;

Installation in new Machining

Hall completed; next phase

with the construction of the

new Fabrication Hall East

during 2012/2013 (behind

schedule);

Review of other buildings and

installation in Main

Fabrication Hall to follow.

Section Head Installation of infrastructure


Project 2/2012

Investigate alternative

energy‐efficient technology

for shot‐blasting:

Target Date ‐ March 2013

90

Research of new technology

and feasibility for LCC carried

out in 2011;

Machine selected and

manufactured by supplier in

2012;

Installation at LCC in

2012/2013


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

‐ 15 ‐

1.7


Reduction of emissions to Air

Project 3/2012

Install cleaner factory

heating system:


60

A phased transition from

diesel to LPG heating

underway building by

building;

conversion of layout hall

achieved in 2012;

construction of the new

Fabrication Hall East

underway in 2012/2013

(behind schedule);

conversation of Main

Fabrication Hall to follow.

Section Head Reduced emissions

Reduction of emissions to Water

Project 4/2012

Install storm water oil

separators and silt traps:

Target Date ‐

March 2013 (east)

March 2017 (west)

30

Investigations and feasibility

reports completed in 2011;

agreement with EPA in April

2012;

further technical difficulties

emerged in late 2012

requiring further design

review;

further consultation with the

Agency required.

Section HeadIncreased compliance with

licence conditions

Reduction of emissions to Water

Project 5/2012

Separation of roof and yard

storm water run‐off:


20

Feasibility reports completed;

design work underway in

tandem with new Fabrication

Hall East.


‐ 16 ‐

1.7



Project 6/2012

Water conservation:


10

Technical feasibility for

rainwater harvesting for the

new Fabrication Hall East

completed by consulting

engineers and preliminary

design carried out ‐ the cost

of installation that emerged

made this element of the

project economically

unfeasible;

installation of the data

loggers on water meters has

been delayed as new meters

needed to be fitted by the

County Council.


licence conditions

Materials Handling/Storage/Bunding

Project 7/2012

Examination of catchment

system for over‐ground

liquid pipeline valves and

flanges:


30

Relevant pipelines surveyed;

feasibility established to

remove all diesel pipelines

within 2 years, making leak

catchment system

unnecessary.


licence conditions


Project 8/2012

Insulation of Main

Fabrication Hall:

Target Date ‐ End 2014

0

Design work was due to

commence in early 2013 with

installation in 2014.

Following the delay with the

construction of the new

Fabrication Hall East, this

project has subsequenlty

been delayed also. Schedule

to be reviewed.


‐ 17 ‐

1.8

1 Yes

2 Draft Noise

Guidance

Yes

3 No

4

5 No

Date of

monitoring Time period

Noise location

(on site)

Noise

sensitive

location ‐NSL

(if applicable) LAeq LA90 LA10 LAmax

Tonal or Impulsive

noise* (Y/N)

If tonal /impulsive noise was

identified was 5dB penalty

applied?

Comments (ex. main

noise sources on site,

& extraneous noise

ex. road traffic)

Is site compliant with

noise limits

(day/evening/night)?

13/03/2012 14:30‐15:30 factory N1 55.0 49.5 57.0 No SELECT main road close by Yes

07/09/2012 04:47‐05:02 factory N1 44.0 41.5 45.0 No main road close by Yes

07/09/2012 05:07‐05:22 factory N1 44.5 41.5 46.0 No main road close by Yes

*Please ensure that a tonal analysis has been carried out as per guidance note NG4. These records must be maintained onsite for future inspection

SELECT

** please explain the reason for not taking action/resolution of noise issues?

Any additional comments? (less than 200 words)

Noise Monitoring Report Summary

Table 1: Noise monitoring summary

If noise limits exceeded as a result of noise attributed to site activities, please choose the corrective action from the following options?

Was noise monitoring carried out using the EPA Guidance note including completion of the

"Checklist for noise measurement report" included in the guidance note as table 6?

Does your site have a noise reduction plan

When was the noise reduction plan last updated?

Was noise monitoring a licence requirement for the AER period?

If yes please fill in table 1 noise summary below

Have there been changes relevant to site noise emissions (e.g. plant or operational changes) since the last

noise survey?

‐ 18 ‐

1.9


1 2010/2011

2

SEAI ‐ Large

Industry Energy

Network (LIEN) no

3 SELECT

no licence condition

specified

Energy Use Previous year kWh Current year kWh

Production +/‐ %

compared to

previous reporting

year**

Energy

Consumption +/‐ %

vs overall site

production*

Total 14,611,575 16,647,290

Electricity 6,654,696 7,925,485

Fossil Fuels:

Heavy Fuel Oil 3,436,012 3,410,092

Light Fuel Oil

Natural gas 4,520,867 5,311,713

Coal/Solid fuel

Renewable energy generated on site

* where consumption of energy can be compared to overall site production please enter this information as percentage increase or decrease compared to the previous reporting year

** where site production information is available please enter percentage increase or decrease compared to previous year

Water use Previous year m3/yr. Current year m3/yr.

Production +/‐ %

compared to

previous reporting

year**

Energy

Consumption +/‐ %

vs overall site

production*

Groundwater 0 0

Surface water 0 0

Public supply 23,694 7,833

Total 23,694 7,833

* where consumption of water can be compared to overall site production please enter this information as percentage increase or decrease compared to the previous reporting year

** where site production information is available please enter percentage increase or decrease compared to previous year

Resource usage/ Energy Efficiency

When did the site carry out the most recent energy efficiency audit? Please list the recommendations in table 3 below

Where Fuel Oil is used in boilers on site is the sulphur content compliant with licence conditions? Please state percentage in

additional information

Table 1 Energy usage on site

Table 2 Water usage on site

Is the site a member of any accredited programmes for reducing energy usage/water conservation

such as the SEAI programme linked to the right? If yes please list them in additional information

‐ 19 ‐

1.9

Date of audit Recommendations

Description of

Measures proposed Origin of measures

Predicted energy

savings % Implementation date Responsibility Completion date Status and comments

2010/2011

Upgrade general

lighting system with

more efficient energy

units.

see EMPEnergy audit and

Energy Efficiency708,222 kWh/year see EMP see EMP see EMP

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.

2010/2011

Replace diesel heating

systems with L.P.G.

Heating systems.


Energy Efficiency1,008,534 kWh/year see EMP see EMP see EMP

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.

2010/2011

Investigate the use of

turbine based shot

blast to replace

pneumatic shot blast.

see EMP

Energy audit and

productivity

improvement

810,000 kWh/year see EMP see EMP see EMP

Figures are based on estimates of 12‐

16hrs operating cycles, 50 week year.

Based on shot blasting an item 50 metres

long.

2010/2011

Incorporate correct

wall/roof insulation in

all new building

projects.


Energy Efficiency

not available at

presentsee EMP see EMP see EMP

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.

2010/2011

Revamp of Old

building 7AF with new

wall/roof insulation.


Energy Efficiencysee EMP see EMP see EMP

Currently being discussed.

Cannot present any valid information at

this time.

SELECT

Table 3: Energy Audit finding recommendations

‐ 20 ‐

1.10


No

Date Category Other type (please specify)

Brief description of

complaint (Free txt <20

words)

Corrective action< 20

words Resolution status Resolution date

Further

information

SELECT SELECT

SELECT SELECT

SELECT SELECT

SELECT SELECT

SELECT SELECT

Total complaints

open at start of

reporting year

Total new

complaints

received during

reporting year

Total complaints

closed during

reporting year

Balance of

complaints end of

reporting year


No

What is an incident

Table 2 Incidents summary

Date of occurrence Incident nature Location of occurrence

Incident category*please

refer to guidance Receptor Cause of incident

Other

cause(please

specify)

Activity in

progress at time

of incident Communication Occurrence

Corrective

action<20

words

Preventative

action <20

words Resolution status

Resolution

date

Liklihood of

reoccurence

SELECT SELECT SELECT SELECT SELECT SELECT SELECT SELECT SELECT SELECT





Total number of

incidents current

year

Total number of

incidents previous

year

% reduction/

increase

*For information on how to report and what

constitutes an incident

Complaints

Have you received any environmental complaints in the current reporting year? If yes please complete

summary details of complaints received on site in table 1 below

Incidents

Have any incidents occurred on site in the current reporting year? Please list all incidents for current reporting

year in Table 2 below

Table 1 Complaints summary

‐ 21 ‐

1.11

PRTR facility logon

Additional Information

1 No

2 SELECT

3 SELECT

Table 1 Details of waste accepted onto your site for recovery, disposal or treatment (do not include wastes generated at your site, as these will have been reported in your PRTR workbook)EWC code Description of waste

accepted

Please enter an

accurate and detailed

description ‐ which

Quantity of waste

accepted in current

reporting year (tonnes)

Reason for

reduction/increase

from previous

reporting year

Packaging Content (%)‐

only applies if the

waste has a packaging

component

European Waste Catalogue

EWC codes

European Waste

Catalogue EWC codes

E.g. #DIV/0! SELECTE.g. #DIV/0! SELECT

SELECT #DIV/0! SELECT

SELECT #DIV/0! SELECT

4 Yes

SELECT

5 Yes

6 N/A

7 Do you have an odour management system in place for your facility? If no why? N/A

8 Do you maintain a sludge register on site? N/A

Table 2 Waste type and tonnage‐landfill only

Waste types permitted

for disposal

Authorised/licenced annual intake

for disposal (tpa)

Actual intake for disposal in

reporting year (tpa)

Remaining licensed

capacity at end of

reporting year (m3) Comments

e.g. Household (residual)

e.g.Industrial non

hazardous solids

Table 3 General information‐Landfill only

Total disposal

area occupied by

waste

Lined disposal

area occupied by

waste

Unlined area

SELECT UNIT SELECT UNIT SELECT UNIT

Cell 8

Table 4 Environmental monitoring‐landfill o Landfill Manual‐Monitoring Standards

Inert or non‐hazardous

Predicted date

to cease

landfilling

Licence permits

asbestos

Is there a separate cell

for asbestos?

Accepted asbestos in reporting

year

Comments on

liner type

SECTION D‐TO BE COMPLETED BY LANDFILL SITES ONLY

Area ID Date landfilling commenced Date landfilling ceased Currently landfilling Private or Public

Operated

Is all waste storage infrastructure as required by your licence and approved by the Agency in place? If no please list waste storage infrastructure required on site

Does your facility have relevant nuisance controls in place?

Quantity of

waste

remaining on

site at the end

of reporting

year (tonnes)

Comments ‐

SECTION C‐TO BE COMPLETED BY ALL WASTE FACILITIES (waste transfer stations, Composters, Material recovery facilities etc) EXCEPT LANDFILL SITES

Is all waste processing infrastructure as required by your licence and approved by the Agency in place? If no please list waste processing infrastructure required

onsiteClass 11.1 is included in LCC's IPPC licence as a secondary activity ‐ however,

no such recycling was carried out during the reporting year

Reduction/Incr

ease over

previous year

+/ ‐ %

Disposal/Recovery or

treatment operation carried

out at your site and the

description of this operation

Did your site have any rejected consignments of waste in the current reporting year? If yes please give a brief explanation in the additional information

Was waste accepted onto your site that was generated outside the Republic of Ireland? If yes please state the quantity in tonnes in additional information

Licenced annual

tonnage limit for your

site (total

tonnes/annum)

Source of waste accepted Quantity of waste accepted in

previous reporting year (tonnes)

If yes please enter details in table 1 below

SECTION A‐PRTR WASTE TRANSFERS TAB‐ TO BE COMPLETED BY ALL IPPC AND WASTE FACILITIES dropdown list click to see options

SECTION B‐ WASTE ACCEPTED ONTO SITE‐TO BE COMPLETED BY ALL IPPC AND WASTE FACILITIES

Were any wastes accepted onto your site for recovery or disposal or treatment prior to recovery or disposal within the boundaries of your facility ?; (waste generated within your boundaries is to be captured through PRTR reporting)

- 22 -

1.11

Was meterological

monitoring in

compliance with Landfill

Directive (LD) standard

in reporting year +

Was leachate monitored in

compliance with LD standard in

reporting year

Was Landfill Gas monitored in

compliance with LD standard in

reporting year

Was SW monitored in

compliance with LD

standard in reporting year

Have GW trigger levels

been established

Were emission limit values agreed with

the Agency (ELVs)

Was

topography of

the site

surveyed in

reporting year

Has the statement

under S53(A)(5) of

WMA been

submitted in

reporting year Comments

.+ please refer to Landfill Manual linked above for relevant Landfill Directive monitoring standards

Table 5 Capping‐Landfill only

Area uncapped* Area with temporary cap

SELECT UNIT SELECT UNIT

*please note this includes daily cover area

Table 6 Leachate‐Landfill only9 Is leachate from your site treated in a Waste Water Treatment Plant? SELECT

10 Is leachate released to surface water? If yes please complete leachate mass load information below SELECT

Volume of leachate in

reporting year(m3)

Leachate (BOD) mass load

(kg/annum)

Leachate (COD) mass load

(kg/annum)

Leachate (NH4) mass load

(kg/annum)

Leachate (Chloride)

mass load kg/annum Leachate treatment on‐site

Specify type of

leachate

treatment Comments

Table 7 Landfill Gas‐Landfill only

Gas Captured&Treated

by LFG System m3 Power generated (MW / KWh) Used on‐site or to national grid

Was surface emissions

monitoring performed

during the reporting year? Comments

SELECT

Please ensure that all information reported in the landfill gas section is consistent with the Landfill Gas Survey submitted in conjunction with PRTR returns

Area with final cap to LD

Standard m2 ha, a Area capped other

Area with waste that

should be permanently

capped to date under

licence What materials are used in the cap Comments

- 23 -

PRTR

- 24 -

1.12 European Pollutant Release and Transfer Register (PRTR) 1.12.1 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.”

1.12.2 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

1.12.3 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 using data from annual stock usage. 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

- 25 -

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 for the year.

1.12.4 Releases to Air (previous year) It was calculated that that NMVOC emission from LCC in 2012 was 100,003 kg, marginally above the 100,000 kg/year threshold. This information is required in the PRTR submission as a licensed emission irrespective of the threshold. The dust emission for 2012 was low at 1,147 kg, but is included in the PRTR submission as a licensed emission

1.12.5 On-site Treatment and Off-site Transfers of Waste (previous year) Comprehensive waste analysis for 2012 is on file and summarised in the PRTR submission. The PRTR reporting threshold for hazardous waste (2 tonnes per year) was exceeded in 2012. 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 provided below. 1.12.6 PRTR Proposal (current year)

The methodology for the PRTR proposed for the current year is the same as the previous year.

| PRTR# : P0146 | Facility Name : Liebherr Container Cranes Limited | Filename : 2013 AER 1.12 - PRTR - TO PRINT.xlsx | Return Year : 2012 |

Guidance to completing the PRTR workbook

Version 1.1.15REFERENCE YEAR 2012

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

The manufacture or use of coating materials in processes with a capacity to make or use at least 10 tonnes per year of organic solvents, and powder coating manufacture with a capacity to produce at least 50 tonnes per year, not included in paragraph 12.2.1.

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 ManagerAER Returns Contact Telephone Number 064 667 0200

AER Returns Contact Mobile Phone NumberAER Returns Contact Fax Number 064 663 4041

Production Volume 0.0Production Volume Units

Number of Installations 2Number of Operating Hours in Year 0

Number of Employees 645User 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

4. WASTE IMPORTED/ACCEPTED ONTO SITE Guidance on waste imported/accepted onto siteDo you import/accept waste onto your site for on-

site treatment (either recovery or disposal activities) ? No

This question is only applicable if you are an IPPC or Quarry site

AER Returns Workbook

- 26 -

4.1 RELEASES TO AIR Link to previous years emissions data | PRTR# : P0146 | Facility Name : Liebherr Container Cranes Limited | Filename : 2013 AER 1.12 - PRTR - TO PRINT.xlsx | Return Year : 2012 | 21/03/2013 09:348 8 16 16 24 24 6 6 6 6 6 14 14

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

QUANTITY

No. Annex II 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 emissionpoints A2-1 to A2-8 for

NMVOCNo. Annex II 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 OTH input/output calculation 100002.0 100002.0 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 Licence)Please enter all quantities in this section in KGs

QUANTITYA2-1 A2.2 A2-3 A2-4 A2-5 A2-6 A2-8 A2-9 A2-10

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 Emission Point 2 Emission Point 3 Emission Point 4 Emission Point 5 Emission Point 6 Emission Point 7Emission

Point 8Emission Point 9

T (Total) KG/Year

A (Accidental) KG/Year

F (Fugitive) KG/Year

244 Total Particulates E OTH

average mass emissionmultiplied by total extraction fan hours 175.0 164.0 179.0 126.0 220.0 78.0 8.0 89.0 108.0 1147.0 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 LimitedPlease 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 pe

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

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:

Method Used

Method Used

- 27 -

5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE | PRTR# : P0146 | Facility Name : Liebherr Container Cranes Limited | Filename : 2013 AER 1.12 - PRTR - TO PRINT.xlsx | Return Year : 2012 | 21/03/2013 09:475 44 Please enter all quantities on this sheet in Tonnes 13

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 42.57waste paint and varnish containing organic solvents or other dangerous substances R12 M Weighed Abroad

Eco-Safe Systems Ltd.,W0054-2

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

Recyfuel,P-ENV07-01,Zoning Industriel d’Ehein,.,Engis,B-4480,Belgium

Zoning Industriel d’Ehein,.,Engis,B-4480,Belgium

To Other Countries 08 01 11 Yes 1.09waste paint and varnish containing organic solvents or other dangerous substances R12 M Weighed Abroad



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 0.34 waste paint or varnish remover R12 M Weighed Abroad Indaver Ireland Ltd.,W0036-2Tolka Quay Road,Dublin Port,Dublin,1,Ireland



To Other Countries 08 01 21 Yes 1.13 waste paint or varnish remover R12 M Weighed AbroadEco-Safe Systems Ltd.,W0054-2




Within the Country 08 01 99 No 0.0 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 0.02waste 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 0.0waste 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

To Other Countries 11 01 13 Yes 0.37degreasing wastes containing dangerous substances R13 C Volume Calculation Abroad Safety Kleen Ltd.,W0099-01

Airton Road,Unit 5,Tallaght Dublin 24,.,Ireland

Tradebe Solvent Recycling ,TP3334SF,Weeland Road,.,Knottingley,WF11 8DZ,United Kingdom

Weeland Road,.,Knottingley,WF11 8DZ,United Kingdom

Within the Country 12 01 01 No 153.56 ferrous metal filings and turnings R4 M Weighed Offsite in Ireland

Hegarty Metals Processors (International) Ltd.,WFP-LKC-11-001-01

Ballysimon Rd.,.,Limerick,.,Ireland

Within the Country 12 01 03 No 0.78 non-ferrous metal filings and turnings R4 M Weighed Offsite in Ireland



To Other Countries 12 01 09 Yes 0.4machining emulsions and solutions free of halogens R12 M Weighed Abroad





Within the Country 13 02 08 Yes 2.43 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 08 Yes 5.38mixtures of wastes from grit chambers and oil/water separators R9 C Volume Calculation Offsite in Ireland Enva Ireland,W0184-01




To Other Countries 15 01 01 No 17.1 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 1.4 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 8.3 mixed packaging R3 E Volume Calculation Offsite in IrelandKillarney Waste Disposal Ltd.,W0217-01

Aughacureen,.,Killarney,.,Ireland

Method Used

- 28 -


Year)



Recover/Disposer










Method Used

To Other Countries 15 01 10 Yes 12.86packaging containing residues of or contaminated by dangerous substances R12 M Weighed Abroad





To Other Countries 15 01 10 Yes 0.34packaging containing residues of or contaminated by dangerous substances D9 M Weighed Abroad



Remondis Industrie Service GmbH,H 09037950,Austrasse,5,Krautheim,D-74238,Germany

Austrasse,5,Krautheim,D-74238,Germany

To Other Countries 15 02 02 Yes 0.45

absorbents, filter materials (including oil filters not otherwise specified), wiping cloths, protective clothing contaminated by dangerous substances R12 M Weighed Abroad





To Other Countries 16 05 04 Yes 0.48gases 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

To Other Countries 16 06 01 Yes 0.0 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 17 05 04 No 41.9soil and stones other than those mentioned in 17 05 03 R10 E Volume Calculation Offsite in Ireland

Liebherr Container Cranes Ltd.,WFP-KY-11-0017-01

Knoppoge,.,Killarney,Co. Kerry,Ireland


Killarney Rugby Football Club,COR-KY-12-0001-01

Caher,Aghadoe,Killarney,Co. Kerry,Ireland


Mark Hallissey,COR-KY-11-0004-01 Fossa,Ards,Killarney,.,Ireland


Killarney Waste Disposal,WP-08-1

Sheans East,.,Killarney,.,Ireland

To Other Countries 20 01 01 No 19.5 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 4.96 biodegradable kitchen and canteen waste R3 C Volume Calculation Offsite in Ireland Acorn Recycling,W0249-01

Ballybeg Composting Facility,Ballybeg,Littleton,Co. Tipperary,Ireland

Within the Country 20 01 21 Yes 0.19fluorescent 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 0.03

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 0.58

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 20 01 38 No 232.0 wood other than that mentioned in 20 01 37 R3 M Weighed Offsite in IrelandKillarney Waste Disposal Ltd.,W0217-01


Within the Country 20 01 40 No 1058.51 metals R4 M Weighed Offsite in IrelandKillarney Waste Disposal Ltd.,W0217-01


Within the Country 20 01 40 No 1290.66 metals R4 M Weighed Offsite in Ireland



Within the Country 20 03 01 No 234.62 mixed municipal waste D1 M Weighed Offsite in IrelandKerry County Council,W0001-04

Muingnaminnane,.,Tralee,.,Ireland

To Other Countries 12 01 09 Yes 1.2machining emulsions and solutions free of halogens R12 M Weighed Abroad





Within the Country 16 01 07 Yes 0.18 oil filters R13 M Weighed Offsite in Ireland Enva Ireland,W0184-01




- 29 -


Year)



Recover/Disposer










Method Used

To Other Countries 16 01 14 Yes 0.43antifreeze fluids containing dangerous substances R12 M Weighed Abroad





Within the Country 12 01 01 No 148.62 ferrous metal filings and turnings R4 M Weighed Offsite in IrelandUnited Metals,WFP LK 2011 147 R1

Eastway Business Park,Ballysimon,Limerick,.,Ireland

Within the Country 12 01 03 No 1.42 non-ferrous metal filings and turnings R4 M Weighed Offsite in IrelandUnited Metals,WFP LK 2011 147 R1


Within the Country 20 01 40 No 697.34 metals R4 M Weighed Offsite in IrelandUnited Metals,WFP LK 2011 147 R1


* 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

- 30 -

Schedule of Environmental Objectives and Targets

Next Review Date – by 31/03/2014

- 31 -

2. Management of the Activity 2.1 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 3.2

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 the end of 2015

Paint replacement investigation ongoing (as practicable)

1(a), 2(a) 2/2013

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).

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

1(a) 6/2013



- 32 -


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; 2015 submission of detailed report (ref. EPA letter 24/04/12) 2017 for factory south 2017 for factory west (ref. EPA letter 24/04/12)

2013 and on-going with future factory developments

1(a) 3/2013

4/2013

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)

On-going (refer to EMP projects)

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

1/2013

2/2013

7/2013

8/2013

6. Reduce Water Usage (condition 7.3):

Investigate feasibility of rainwater harvesting;

Investigate reduction/elimination of water use in production processes

2012-2013 - DEFERRED

2015 - COMPLETE

8(b) 5/2013

7. Raw Material Efficiency (condition 7.4):

Review improvement possibilities and implement where feasible

Annual assessment 3 & 4 8/3013



- 33 -


EMP Project No.

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)

9/3013

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

End 2015 2(e), 8(c) 2/2013

EMP Proposal 2013

- 34 -

2.2 Environmental Management Programme Proposal 2013

The following programme is proposed for EPA approval.

Project 1/2013 Installation of energy efficient lighting

Relationship to Objectives and Targets: This is linked to 2013 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 1/2012.

LCC’s energy audit has identified lighting as the highest

proportion of electricity consumption.

Project Summary: Target: Progress

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.

30/11/07

31/12/07

30/06/08

29/08/08

11/06/10

13/04/12

29/03/13

31/10/13

31/12/14

31/12/15

2016

100%

100%

100%

100%

100%

100%

100%

50%

Designation of Responsibility: Manufacturing Director and Energy Management Engineer

EMP Proposal 2013

- 35 -

Project 2/2013 Install cleaner factory heating system

Relationship to Objectives and Targets: This is linked to 2013 LCC objective number 3 & 9

Reason for undertaking 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 3/2012 as

amended to incorporate changing circumstances.


I. Final Assembly/Stores

I. Steel Fabrication 7AS

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

III. Upgrade LPG vessel

IV. Western building, remaining departments 7AM, 1LA & 2BC, pending review

V. Boring & Milling Hall

VI. Review factory development plan

VII. Layout Hall trial installation – combined heating and fume extraction

VIII. New Fabrication Hall East

IX. Steel Fabrication 7AF

2000

2002

2006

2010

2010

2010

2012

31/10/2013

31/12/15

100%

100%

100%

100%

100%

100%

100%

100%

Designation of Responsibility: Manufacturing Director, Maintenance Manager

EMP Proposal 2013

- 36 -

Project 3/2013 Install storm water interceptor(s) and silt traps


Reason for undertaking 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 4/2012.


I. Investigate interceptor 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 x3)

VII. Review factory development plan

VIII. Installation (southern oil separator x1; western oil separators x2)

Mar 2011

Dec 2011

Mar 2012

Apr 2012

Jun 2012

May 2013

Mar 2016

2017

100%

100%

100%

100%

100%

60%

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

Project 4/2013 Separation of Roof and Yard Storm Water Run-off


Reason for undertaking project: 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



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

Mar 2011

Mar 2012

Oct 2013

Oct 2013

100%

100%

Designation of Responsibility: Manufacturing Director, Maintenance Manager

EMP Proposal 2013

- 37 -

Project 5/2013 Water Conservation


Reason for undertaking 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

6/2012.


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

Jun 2011

Mar 2012

Mar 2013

Mar 2013

Apr 2012

Apr 2013

Dec 2013

100%

100%

Cancelled

Cancelled

100%

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

Project 6/2013 Examination of catchment system for over-ground liquid

pipeline valves and flanges


Reason for undertaking project: Reduction of fugitive emissions, prevent site water run-off and

compliance with IPPC licence condition 3.11. This is a



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.

May 2011

Mar 2014

Jun 2014

Sept 2014

Mar 2015

Mar 2015

100%

50%

Designation of Responsibility: Maintenance Manager

EMP Proposal 2013

- 38 -

Project 7/2013 Insulation of Main Fabrication Hall


Reason for undertaking project: Energy Efficiency


I. Survey building requirements

II. Establish insulation specification and bill of materials

III. Tender process

IV. Building refurbishment

Jun 2013

Dec 2013

Mar 2014

Sept 2014

Designation of Responsibility: Manufacturing Director and Maintenance Manager

Project 8/2013 Upgrade production machinery – improve productivity and

energy efficiency


Reason for undertaking project: Replacement of old less efficient machine tools and processes

with state of the art energy efficient production equipment.


I. Boring & Milling

a. Purchase and Install new SHW boring & milling machine

II. Plasma/Bevel-cutting

a. Investigate suitability of plasma/bevel-cutting machine for

LCC operations (reduction in acetylene use for chamfering)

b. Research suppliers and conduct trials for producing LCC

components. Decision and purchase

c. Delivery, Installation and commissioning (if feasible)

III. Crane Portal Plate Fabrication

a. Investigate feasibility of automated process and potential

suppliers

b. Receive specification and proposal from supplier; decision on

implementation

c. Install and commission automated system

Oct 2013

Jun 2013

Sept 2013

Mar 2014

Feb 2013

Jun 2013

Mar 2014

50%

100%

Designation of Responsibility: Manufacturing Director

EMP Proposal 2013

- 39 -

Project 9/2013 Review of Office Waste


Reason for undertaking project: Improve waste management


I. Review waste streams generated in offices

II. Identify additional recycling possibilities and contact potential

waste contractor(s).

III. If feasible, implement appropriate waste collection method.

Jun 2013

Aug 2013

Dec 2013

Designation of Responsibility: EHS Manager

Public Awareness & Communications Programme

- 40 -

3. Licence Specific Reports 3.1 Public Awareness & Communications Programme

IPPC Licence Conditions

2.2.2.7 Communications Programme The licensee shall maintain a Public Awareness and Communications Programme to ensure that members of the public can obtain information at the installation, at all reasonable times, concerning the environmental performance of the installation.

Schedule D: Annual Environmental Report Content Reports on financial provision made under this licence, management and staffing structure of the installation, and a programme for public information

3.1.1 This programme is in place so that members of the public can obtain information concerning

the environmental performance of LCC at all reasonable times and reviewed as part of the AER as required by Schedule D of the licence. 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.

3.1.2 Contents

3.1.2.1 Public Awareness & Communications Programme - this document (file 1)

3.1.2.2 IPPC Licence - notification of grant of licence and licensing conditions (file 1)

3.1.2.3 IPPC Licence application (file 1)

3.1.2.4 Quarterly monitoring of emissions to atmosphere - current year (file 2)

3.1.2.5 Annual Environmental Report -for the previous year (file 2).

3.1.3 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.

3.1.4 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 2012.

Solvent Management Plan

- 41 -

3.2 Solvent Management Plan 2013 (incorporating a Fugitive Emissions Reduction Programme)

3.2.1 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 was obtained.

Recycling of solvents from paint washings by distillation lead to the on-site recovery of VOCs and a decrease in emissions – this has been discontinued since the installation of the new paint kitchen (see below).

The introduction of new priming and shot blasting machinery lead to a huge reduction in the amount of shop 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 for primers. This has resulted in a significant reduction in solvent waste because 2-component paint is mixed as it is used and there is no waste paint remaining in paint drums.

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.


- 42 -

LCC will manage solvents in accordance with the Solvent Management Plan described in this report.

3.2.2 Compliance Requirements


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.

amended by EPA letter of 21/12/12, ref. P0146-02/ap07ml.doc “the Agency approves the reporting of VOC as % of Paint Use instead of the Emission Factor, in future SMPs.”

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.


- 43 -

3.2.3 Solvent Management Plan for Liebherr Container Cranes Ltd. 3.2.3.1 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.

3.2.3.2 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 previously maintained an inventory of the weight of each crane painted since 1999 to 2011 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 was calculated. As part of the Solvent Management Plan, the facility tracked the amount of VOC usage per unit production. These calculations gave an indication of the efficiency of painting and VOC use at the facility. The data was used to compile an annual summary of achievements, presented in tabular format below

Since the original SMP proposal was made in 2005 however, the profile of crane manufacture at LCC has changed considerably. The production output has increased and substantial components are manufactured by sub-contract. These developments have significantly complicated the process of deriving meaningful data about crane weights manufactured and painted in a calendar year that can be relied on. In order to arrive at a single cumulative crane weight for a calendar year, this involves the input of a number of departments over a period of several weeks, the application of assumptions regarding how much of some cranes are painted at either side of the years end, and the estimation of weights of sub-contracted items. This entails the significant use of valuable resources which result in dubious conclusions at best due to the variables involved. The result of this was that the emission factor could no longer be arrived at with any degree of confidence. The second method which was originally considered for the SMP is therefore submitted in future in place of an emission factor, namely VOC as % of Paint Use, as agreed with the Agency.


- 44 -

Table 1 NMVOC as % Paint Use (%w/w)

Year Total VOC Content

(kg)

NMVOC as % Total paint usage (%w/w)

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 Total VOC Content calculation (kg) is divided by the total weight of paint used

The weights of each crane painted were totalled on an annual basis from 1999 to 2011. This was 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 and NMVOC as % of Paint Use for 1998 to 2012. The emission factor previously used up to 2011 is also shown.

Table 2 NMVOC as % Paint Use (%w/w) 1999 - 2012

Year

Total VOC content

(kg)

NMVOC as % Total paint usage

(%w/w)

Total crane weight (tonne)

Emission Factor

(VOC kg/tonne crane weight)

1998 69,655 47.9% not available not available

1999 83,367 41.3% 4,167 20.00

2000 102,187 39.3% 10,935 9.91

2001 78,954 37.6% 8,028 9.83

2002 54,285 35.5% 9,382 5.79

2003 57,166 37.9% 7,518 7.60

2004 60,441 36.1% 8,795 6.80

2005 58,547 35.1% 9,097 6.44

2006 80,614 36.8% 10,563 7.63

2007 88,764 36.0% 13,119 6.77

2008 104,451 34.4% 13,635 7.66

2009 96,378 37.0% 15,156 6.36

2010 80,770 38.6% 12,488 6.47

2011 82,339 37.4% 14,859 5.54

2012 103,656 37.4% Not available Not available

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.


- 45 -

2012

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 31/01/2012 19,032 18,753 19,583 17,643 17,241 5,686 33,500 31/01/2012 13,541

2 01/03/2012 19,298 18,992 19,823 17,826 17,417 5,752 33,520 29/02/2012 13,609

3 30/03/2012 19,475 19,259 20,040 18,022 17,660 5,825 33,600 02/04/2012 13,700

4 30/04/2012 19,705 19,479 20,280 18,163 17,851 5,919 33,752 30/04/2012 13,780

5 31/05/2012 19,930 19,724 20,538 18,281 18,040 6,026 33,779 31/05/2012 13,876

6 29/06/2012 20,113 19,907 20,743 18,439 18,278 6,139 33,790 29/06/2012 13,951

7 31/07/2012 20,362 20,113 21,047 18,683 18,576 6,262 33,805 31/07/2012 14,052

8 31/08/2012 20,622 20,383 21,329 18,914 18,824 6,350 33,810 31/08/2012 14,118

9 28/09/2012 20,870 20,565 21,536 19,124 19,067 6,465 33,928 28/09/2012 14,205

10 31/10/2012 21,126 20,774 21,792 19,317 19,226 6,571 33,937 31/10/2012 14,287

11 30/11/2012 21,335 21,005 22,050 19,513 19,427 6,688 33,995 30/11/2012 14,376

12 21/12/2012 21,466 21,127 22,138 19,611 19,565 6,795 34,001 20/12/2012 14,436 19,015 18,553

Annual Hours 2,719 2,380 2,804 2,205 2,460 1,130 310

965 4,369 3,514

A2-7 was confirmed out of commission to the EPA on 12/09/2012 (2012ELA-L22) – operation hours from October to December are not totaled as the clock reading also includes the operation of the oven.


- 46 -

3.2.3.3 (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. The calculated fugitive emission rate for 2012 (estimated) is 30.3%. 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 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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3.3 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.”

3.3.2 Statement of Measures for Prevention of Environmental Damage

Since the grant of the first IPC licence no. 146 in 1997 and revised IPPC licence no. P146-02 in 2010, 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


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dust emission points; construction of a new paint shop 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; installation of a new automatic shot-blasting machine using motor-driven impellers instead of compressed air to improve efficiency; commence installation of storm water oil separators; infrastructure to enable separation of roof and yard water; commencement of the construction of a new energy efficient state-of-the-art fabrication building.

In 2012:

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 – this large new machine was delivered in sections to LCC at the end of 2012 requiring a number of months to build it on site and commission it for operation in 2013. This investment demonstrates LCC’s continued commitment to the BAT principle.

Agreement was reached with the Agency in 2012 for the installation of oil separators on storm water drainage from the site over a 5-year period. Two separators were installed in the north east of the plant in 2012 awaiting connection in 2013.

Bund testing was carried out.

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.

3.3.3 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 respect to its sound financial position and will make the group report available for inspection by the EPA upon request. LCC had a number of communications with the Agency regarding alternative financial provisions in accordance with the EPA guidance document. These communications are on-


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going and measures to the satisfaction of the Agency will be finalised and put in place in due course.

3.3.4 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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3.4 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.”

3.4.2 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 2014 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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3.5 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

in accordance with the licence requirement to include same in the AER. Recommendations have

been considered and included in the AER Objectives and Targets and EMP where appropriate.


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3.5.2 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

3.5.3 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

3.5.4 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.

3.5.5 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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3.6 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.”

3.6.2 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.

3.6.3 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 4.6.1

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.

3.6.4 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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3.6.5 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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3.6.6 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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3.7 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.”

3.7.2 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 has typically been 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 has been 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 was removed 2-3 times

per year and transported to Killarney waste water treatment plant, and the system is

refilled. This paint booth however was removed from service in 2012 for an unspecified

time. Finally, water is used at a wash station at the north of the plant that is used

sporadically to clean company vehicles.

3.7.3 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

Water Demand Minimisation Report

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

to improve water efficiency. This is 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 had intended to install a rain-water harvesting for toilet facilities. However, the cost of installation that emerged made this plan economically unfeasible.

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. To this end new water meters were installed in October 2012 and

steps are underway to fit on-line data logging equipment for water consumption so that any

leaks that may develop may be identified quickly.

Development/Infrastructural Works Summary

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3.8 Development/Infrastructural works summary.



“SCHEDULE D: Annual Environmental Report

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

current year).”

3.8.2 Development/Infrastructural works completed in 2012

Construction of new production hall at the east of the facility commenced in 2012 and is

expected to be completed in 2013.

Two full retention oil separators were installed in the north-eastern yard area in tandem

with the new development works but will not be connected until 2013.

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

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

the extraction system.

3.8.3 Development/Infrastructural works planned for 2013

The new production hall which commenced construction in 2012 will be completed in 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.

Separation of roof water and yard water will be implemented in the new Fabrication Hall

East and the existing Main Fabrication Hall which will ease flow through the oil separators

rendering them more effective.

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

Fabrication Hall East in 2013, similar to the installation in the Layout Hall in 2012. No

external emissions will result from the extraction system.

A new shot-blasting machine, the installation of which commenced in 2012 will be

completed in 2013. The system will use 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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3.9 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.”

3.9.2 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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Annual Environmental Report 2013 · lCC is engaged in the production of rail-mounted and...

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