APPENDIX 2.Assessment of Emissions to Athmosphere from the Iralco Facility.
Iralco Air Modelling 2005
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Iralco
Integrated Pollution Control Licence Appkation
ATTACHMENTNO. 12(A)
DETAILSOFALLPOINTEMISSIONSTO ATMOSPHERE
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A3 Minor Emissions
Paint Plant
I Stack No. I Stack Description I Source of Emission
A3-1 Process Emissions A3-2 Process Emissions A3-3 1 Water drier cooling zone A3-4 1 Water drier exhaust
Conversion Coating Pre-treatment end exhaust vent Water drier cooling zone (exhaust fan)
I Water drier exhaust vent 1 A3-5
A3-6 A3-7 A3-8 A3-9
) Water drier burner unit 1 Burner exhaust 1 Burner exhaust Primer oven burner unit 1 Primer Process emissions Primer oven cooling zone
Burner exhaust Clear-coat oven burner unit Clear-coat Process emissions Ciear-coat oven natural vent
’ A3-10 A3-11 A3-12 A3-13 A3-14 A3-15 A3-16 A3-17
Boiler emissions Compressor em&sons Compressor emissons Compressor emissons
\ Heater exhaust 1 Heater exhaust
Process emissions
Process emissions
Reillo Boiler Unit Compressor cooling air outlet Compressor cooling air outlet Compressor cooling air outlet Hardening Oven Mark Eire heater Mark Eire heater Emissions from 3 sanding tables/Porsche 996 area
Mechanical 2
A3-18 A3-19
Mechanical lb A3-20 Khanban Area A3-2 1
Process emissions Heater exhaust Space heater Suace heater
Emissions Tom 3 sanding benches Emissions from 1 sanding machine Mark Eire Space heater Mark Eire Space heater
Volvo Forming
VW Passat
A3-22 A3-23 A3-24 A3-25 A3-26 A3-27 A3-28 A3-29
Heater exhaust Compressor emissions Space heater Space heater Space heater Space heater Space heater Heater exhaust
) Benson heater Compressor Mark Eire Space heater Mark Eire Space heater Mark Eire Space heater Mark Eire Space heater Mark Eire Space heater Benson heater
A3-30 A3-3 1 A3-32
Space heater Space heater Space heater Space heater Space heater Space heater Process emissions
Oven exhaust
Mark Eire Space heater Mark Eire Space heater Mark Eire Space heater
A3-33 is34 A3-35 A3-36
A3-37
Mark Eire Space heater Mark En-e Space heater Mark Eire Space heater Exhaust from 2 welders/deburring machine Carbolite oven exhaust
1 A3-38 1 Process emissions (new)
A3-39
A3-40
A3-41
A3-42
A333
Oven emissions
Oven emissions
Space heater
Boiler exhaust
Space heater
1 Exhaust from 1 sanding wheel and 1 polisher 1
Emissions from drying/pretreatment oven
burner
Emissions from powder coat oven
Mark Eire space heater
Boiler stack
Mark Eire Space heater
Powder Coating
Electro- brightening
New effhrent ’ A3-44 I I
treatment olant Space heater Mark Eire space heater
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1 A3 Minor Emissions
Plant Stack No. Stack Description Source of Emission
Calor Gas discharge point
A3-45 Gas exhaust
A3-46 Process exhaust
Gas Heating Unit (Mynute .X&e) Exhaust
Welding unit- 1 welder
Pyrolyser Unit
New Maintenance Shop
Sanding Area
Stores
Toolmakers i workshop
recess exhaust ( Welding tit- 2 welders
1 A3-60 Heater exhaust Benson Heater
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I I D I
I I I D I I I I I I I I I
A4 Potential Emissions
None
.
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In
TTACHMENT No. 12(B)
Fucnm EMISSIONS TO ATMOSPHERE
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FugitiveEmissions
Plant Stack No. Source of Emission
Mechanical lb n/a Enclosed system internal scrubber from sanding machines, deburring I(hanban Area wheels, polishing wheels
n/a Packing
Glues, TPA.
Dispatch Area 2 Toilet blocks lo& exhaust ventilation Ofice chiller with exhaust vent.
Mechanical 1 1 n/a ) Lime in vicinity of B6 Automatic Polisher Caroentrv I nla I Dust emissions
1 4
Paint Stores da Toolmakers n/a Workshop
Hydrocarbon emissions
Hardening ovens
J
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Iralco I
Pollutioaz coxktr 1 lliamx Application
ATTACHMENT No. i 2(C)
ASSESSMENT OF ATMOSPH~NC EMISSIONS
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For the Attention of: Mr. Richard D’Arcy
IEilCO
Collinstown
Mullingas Co. Westmeath
BORD NA MONA ENViRONMENTAL LIMITED
Report Ko: T191-A Date: December 2003
Prepared by: Ms. Catherine Grimes Environmental Consultant
Reviewed by: Mr. John Conway Air Quality Section Head
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IdCO ReDon’ No. Tl91-A
Executive Swnmary/Certification of Results
Iralco are in the process of applyin, 0 to the Environmental Trotection Agency (EPA) for an Integrated Pollution Control (IEX) Licence for activities classified under Section 12.2 of the First Schedule of the Environmental Protection Agency Act, 1992, S.I. No. 07 of 1992, as
‘The manufacture or use of coating materials in processes with a capacity to make OY use at least IO tonnes per year of organic solvents and powder coatings with a capacity to produce at
least 50 tonnes per year ’
Jialco is required to monitor its emissions to atmosphere as part of a baseline environmental investigation programme associated with acquisition of the @PC) Licence. A comprehensive atmospheric emission monitoring programme was undertaken on 24 point sources located throughout the facility by Bord na Mona Environ-mental Consultants and Scientists between the 12th of September and the 26’ of November 2002 for the following parameters: volumetric flow, particulate matter, metals, Total Organic Carbon (TOC as C), acid gases, ammonia and sodium hydroxide.
For spray painting operations, the BATNEEC emission limit value for particulates is 3 mg/m3. This limit is exceeded by emission points A2-2, A2-6 and AZ8 and A2-20. The BATNEEC Guidance Note for the Manufacture or Use of Coating Materials does not specify an ELV for particulate matter for other processes. In this absence, the T A L&t, Technical Instructions on Air Quality 2001 may be referenced. All non spraying operations do not exceed the 20mg/m3 BATNEEC guide value.
Results obtained for all metals for all emission points sampled were detected at levels Iess than the relevant analytical limit of detection for individual metals and subsequently for total metal content. However, due to the high analytical detection limits for the metal analysis, the results appear to exceed the T A Luft Class III guide vaIue for total metals. However, as the metal content cannot exceed the particulate matter level (see Tables 4.2 and 4.3), there are only two emission points, namely A2-6 and A2-8, that may have exceeded the T A Lufi (2001) guide value of lmg/m3.
The TOC (as C) emissions from A?!-1, A2-6 and A2-10 determined during this monitoring event, exceed BATNEEC limit values of 100 mg/m3 for coating processes within Class 12.2 activities. However, for all other emission points monitored, the relevant emission limit value is not being exceeded. Levels of hydrofluoric acid (HI?) obtained in all point source emissions monitored are below the T.A. Luft Class TI concentration and mass emission limits of 3mgIm3 and 15g/h respectively. The level of ammonia detected at the outlet of AI-22
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Iralco Repari No. TZ 91-A
(Electrobrightening Plant) during this monitoring event is considered low at 0.36 mg/m3 and is below the T A Luft ELV of 30mg/m3.
Emission point A2-22 exceeds the relevant guide value (one fortieth the Occupational Exposure Limit) for nitric acid. The guide value for sulphuric acid is exceeded for emission points AI-1 and A2-22. Emission point A2-21 exceeds the 0.05 mg/m3 guide value (l/40” the OEL) for phosphoric acid. The WaOH concentration for emission point A2-22 exceeds its guide value (1/40th the OEL). All other parameters monitored fall within the relevant guide
values. Furthermore, the concentrations of the above acids and NaOH are considered low.
This report is certified as accurate and representative of the sampling and associated analysis carried out.
G Mr. John Conway
Air Quality Section Head
[L ,/ Pl? ‘3L tKf@ If
Ms. Catherine Gvimes
Environmental Consultant
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I 1 I t t t 1 t I t I t 8 t I t I t I t 1
a-ale0 Report No. T191-A
1.0 INTRODUCTION
Iralco are in the process of applying to the Environmental Protection Agency (EPA) for an Integrated Pollution Control (IPC) Licence for activities classified under Section 12.2 of the First Schedule of the Environmental Protection Agency Act, 1992, S.I. No. 07 of 1992, as:
’ The manufacture OY use of coating materials in processes with a capacity to make OY use at least IO tonnes per yeav of organic solvents and powder coatings with a capacity
to produce at least 50 tonnes per year’
Iralco are required to monitor their emissions to atmosphere as part of a baseline environmental investigation programme associated with acquisition of the (II%) Licence. A comprehensive atmospheric emissions monitoring programme was designed following a survey of the main point sources of atmospheric emissions on
the Iralco site undertaken by Bord na M6na Environmental Consultants in conjunction with personnel from the Iralco Environmental Department. The monitoring
programme was undertaken on 24 point sources located throughout the facility by Bord na Mona Environmental Consultants and Scientists between the 12th of September and the 26ti of November 2002 for the following parameters:
9 Volumetric flow 9 Particulate matter 9 Metals 9 Total Organic Carbon (TOC as C) 9 Acid Gases 9 Ammonia 9 Sodium hydroxide
This report details the samplin g and analytical methodologies employed and also includes a broad interpretation of the results obtained.
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Pralcu Rev& No. 2791-A
2.0 MONITORING PROGW AND METHODOLOGIES
Section 2.1 provides details of the sampling and analysis methodologies employed for the determination of the various parameters during the monitoring programme.
Section 2.2 provides brief details in a tabulated format of the monitoring programme, including point source identification and description; sample locations and parameters (refer to Table 2.1). All those categorised as main emissions were automatically inchrded in the monitoring programme.
For all point source emissions with abatement equipment in place (e.g. cyclones, wet scrubbers etc.), monitoring was performed downstream of the abatement equipment at the final emission to atmosphere outlet, with the exception of emission source A2-2. In the case of AZ-2 (Paint Plant Primer Booth Extraction Unit), sampling downstream of the abatement equipment was not possible due to physical sampling constraints.
2.1 METHODOLOGIES
2.1.1 Volumetric Flow and Temperatures
Volume flow was measured in accordance with the British Standard BS 3405 for average velocity in a duct. A standard L-type pitot tube and digital manometer or Gravimat isokinetic sampler was used to record velocity pressures. The measurements were taken at ten equidistant points along each axis (two where appropriate). Temperature measurements will also be recorded to coincide with the collection of stack gas samples using a k-type thermocouple. The results for temperature and volumetric flow are expressed in “C and Nm3/‘hr respectively.
2.1.2 Particulate Matter
Particulates were determined in accordance with the British Standard BS3405. Samples were collected isokinetically on pre-weighted quartz filters using the Gravimat SHC 500 isokinetic sampler. Each sample was collected over a minimum of 30 minutes, during a period of operation considered by Iralco operators to be representative of normal working conditions for the particular process. Following the sampling period, the weight gain was determined gravimetrically using a 5-point calibrated balance. The filters were then be dispatched to the Bord na Mona laboratory for metal analysis as detailed in Section 2.3 below. Results for total particulate matter are expressed in mg/Nm3 and as a mass emission in kg/hr.
Bard na M&a, Technical Services Pa,oe 5
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hiC0 Report No. T191-A
2.1.3 Metal Content
The concentration of a wide range of metals (Pb, Fe, Bo, As, Sn, Cd, Cu, Sb, Hg, Be, Cr, Co, Se, Ag, MO, Zn, Mn, Ni, Al and Ba) was determined by subsequent acid digestion of the filters used in the total particulate matter monitoring and analysis using Inductively Coupled Plasma Mass Spectroscopy (ICP-MS) in accordance with the ASTM standard methods. Results for individual metals detected and total metal content are expressed in mg/Nm3 and as a mass emission in kg/hr.
2.1.4 Total Organic Carbon (TOC as C)
Total Organic Carbon (TOC’s) quantified relative to methane, were determined using a Signal Total Organic Carbon analyser. The instrument employs flame ionisation detection and is calibrated against a reference methane standard prior to the commencement of the measurement programme. Monitoring was conducted over a minimum of 30 minutes, during a period of operation considered by Iralco operators to be representative of normal working conditions for the particular process. Results from the instrument averaged over the total sampling period were expressed as TOC in ppm (methane equivalent). The results were subsequently converted to mg/Nm3 expressed as TOC as C (relative to methane) also expressed in kg/In-.
Bord na Mdna, Technical Services Pa,ot? 6
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I 1 I I I I 1 D 1 I 3 1 I I D I I I I I 1
riwko Reuort No. T191-A
2.1.5 Acid Gases Q included Phosphoric (&P04), Sulphuric and Nitric Acids (HNO3) Monitoring
The sampling and analysis of the acid gases was conducted based on US EPA Method 26a. Samples were collected via a filter chamber containing a glass fibre filter, and through a series of four impingers using specialised SKC sampling pumps at a flow rate of approximately lml/min. A dry gas meter recorded the total volume sampled. The first two impingers contained either dilute sulphuric acid or deionised water to trap the anions; the third impinger was empty and the fourth contained silica gel. Each sample was collected over a minimum of 30 minutes, during a period of operation considered by Iralco operators to be representative of normal working conditions. Analysis of the impinger solutions was carried out using ion chromatography. The results are expressed in ms/Nm3 and kg/&-.
2.1.6 Ammonia Monitoring
Samples were collected via a series of impingers using specialised SKC sampling pumps at a flow rate of approximately ll/rnin. A dry gas meter recorded the total volume sampled. The first 2 impingers contained dilute sulphuric acid to trap the ammonia content, the third impinger was empty and the fourth contained silica gel. Sampling was carried out over a minimum of 30 minutes, during a period of operation considered by Iralco operators to be representative of normal working conditions. Analysis of the impingers was carried out using ion chromatography. The results are expressed in mg/‘Nm3 and kgihr.
2.1.7 Sodium Hydroxide Monitoring
Samples were collected via a sampling line through a cellulose ester mix (CE%f) filter followed by a deionised water impinger using specialised SKC sample pumps. Sampling was carried out over a minimum of 30 minutes, during a period of operation considered by Iralco operators to be representative of normal working conditions. Analysis of both the impinger solution and the filter (subsequent to acid digestion) for sodium content was carried out using Inductively Coupled Plasma 1Ma.s~ Spectroscopy (ICP-MS) in accordance with the ASTM standard methods. The results are expressed in mgNm3 and kg/l-n as sodium hydroxide.
Bard na M&a, Technical Services Page 7
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!
c
t
Iraico Report No. 7791 -A
2.2 MONITORING PROGRAMME
Plant Stack No. Stack Description Source of Emission Vo1ume Flow & Temp.
TOC Acids NH, /NaOH
AZ-1 Pre-treatment Process Degreasing extract unit (extract J d emissions fan) x X J x
A2-2 primer Process emissions Primer booth extraction unit 4 d J (exhaust fan) ”
J x x
A2-3 Primer Process emissions Primer booth flash off extraction J J unit (exhaust fan) X X X X
AZ-4 Primer Process emissions Primer natural vent d J X X X X I I I I
AZ-5 Ptimer Process emissions Primer oven vent I J IJI X X X X t
1
AZ-6 Top-coat Process emissions Top-coat booth extract unit J J J Paint Plant (exhaust fan)
J x x
AZ-7 Top-coat Process emissions Top-coat flash-off (exhaust fan) J J X X X X
A2-8 Clear-coat Process emissions Clear-coat booth extract unit J J J (exhaust fan)
J x x
A2-9 Clear-coat Process emissions Clear-coat flash-off extraction 4 J X X X X’ unit (exhaust fan)
AZ-10 Clear-coat Process emissions Clear-coat natural vent J J X X X X
AZ-1 1 Clear-coat Process emissions Clear-coat oven vent J J X X X X
A2-12 Process emissions Paint kitchen exhaust J J X X X X
Mechanical Cyclone exhaust from Audi
2 AZ-13 Cyclone emissions Forming Front Al cutting 4 J J J x x machine
IQ-14 Scrubber 1 6 Passat sanding pedestals (x2) J J J J x x VW Passat
.42-15 Scrubber 4 Bula Robot/4 Metabo Polishers J J J J x x
A2-16 Scrubber 2 emissions Emissions from semi-automatic 4 4 J Volvo P28 polishing machines
J x X
A2-17 Scrubber 3 emissions Emissions from other polishing J J J J x machines
X
Cyclone Exhaust (2) from Magna AZ-18 Cyclone Exhaust pebra saws + 2xTT Roofrail J J 4
Mechanical J x X
I millers
AZ-19 Cyclone Emissions Cyclone Exhaust from 1 sander & J J J 1 polisher J x x
1 Cyclone emissions from powder 1 J 1 p 1 J 1 Y 1 y ) ~ ) I Powder AZ-20 CyLE”m b,llfJJ‘“11D plant room Coating A2-2 1 Process Emissions Emissions from Dipping Bath 4 J X X J
treatment tanks X
1 Electorbrig Scrubber from dip charge tanks J J J htening A2-22 Scrubber exhaust emissions X X X
Pyrolyser A&23 Oven/process exhaust Oven emissions J 1 J J J x X
RI Sanding Area A2-24 Cyclone exhaust Cyclone exhaust from 6 sanding J
stations X J 4 X X
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Iralco Report No. Tl91 -.A
3.0 COMMITMENT TO QUALITY
3.1 LAB ACCREDITATION
Bord na Mona Technical Services (Technical Services) analytical laboratories is ILAB accredited by the National Accreditation Board (NAB) since 1997. It has always been the policy of the laboratories to achieve and maintain a high standard of quality consistent with client’s requirements in all aspects of the work carried out within the laboratory.
Bord na Mona ECS laboratories successfully transferred to the new standard of accreditation IS0 17025 on the 161h of November 2001.
3.2 Accredited to IS0 17025
This new standard contains all of the requirements that testing laboratories have to meet if they wish to demonstrate that they operate a quality system, are technically competent, and are able to generate technically valid results. IS0 17025 incorporates all those requirements of ISO 9001 and Is09002 that are relevant to the scope of testing services that are covered by the laboratory’s quality system. Thus a laboratory that complies with IS0 17025 will therefore also operate in accordance with IS0 9001 or IS0 9002.
3.3 Interlaboratory Proficiency Schemes
To ensure the accuracy of the analytical testing we participate in several external proficiency schemes. The ongoing competence of the laboratory and its staff is assessed by participation in various inter-laboratory proficiency testing schemes, such as Aquacheck and the EPA scheme organised for environmental laboratories throughout h-eland.
3.4 EPA Quality Control Register
Bord na Mona ECS Analytical Laboratories performance in the EPA intercalibration
scheme has insured its listing on the EPA’s register of Quality Controlled Laboratories. Both accredited and non-accredited test methods are assessed by these schemes.
Bard na M&a, Technical Services ?aEe 9
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3.5 Quality Control Audits
Bord na Mona ECS Analytical Laboratories consistently strive to improve the quality of the analytical work out in its laboratories. The laboratory has a full time Quality Control Manager who assists in the organisation and execution of the extensive progrannne of internal Quality Audits. These quality audits examine all aspects of the laboratory’s Quality System, with particular focus on auditing of test methods, and enable potential problems to be highlighted and immediate corrective action to be taken.
Bord na M&a, Techrlical Services Page 10
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3.6 Control Chain of Custody
As part of the Quality System in place in Bord na M6na, Environmental Limited, measures are taken to ensure controlled chain of custody. An outline of the chain of custody is given overleaf.
BORD NA MONA & BORD NA MdNA ENVIRONMENTAL LIMITED
I CONTROLLED CHAIN OF CUSTODY I
b 1 b 1
I SITE I 1 TRANSPORT [
Sampling and packa2tig of all samples were
carried out by Bord na M6na Technical Team:
C. Grimes, J. McCormack, K.
Gordon, P. O’Brien, J. Marsh and B. Tobin.
Transport Transport to Sample Receiving of samples at Bord na Document laboratory by Reception M6na Environmental Laboratory
Form Bord na M6na Form complex by: Technical Mary McFadden, Laboratory
Team. Manager (Secure laboratory complex
access to authorised personnel OdY>
LABORATORY
+ 4
Storage of all samples for 1 month period after report issue.
L
Supervised Disposal
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Repurt No. TIP]-A
4.0 RESULTS
Tables 4.1- 4.7 present the results of the monitoring survey carried out at the Iralco facility as follows:
Table 4.1
Table 4.2
Table 4.3
Table 4.4
Table 4.5
Table 4.6
Table 4.7
Temperature and Volumetric Flow Measurements
Particulate Matter Emissions
Total Metals Analysis Results
Total Organic Carbon (TOC) Emissions (as C)
Acids Analysis Results
Ammonia Analysis Results
Sodium Hydroxide Analysis Results
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Iralco Report No. T191-A I 1 I
I 8 I I 1
TABLE 4.1: TEMPERATURE & VOLUMETRIC FLOW MENTS
/ Volumcttic Flow
Rant Source of Emission I
Temp Nm31hr “C
extractlon unrt
Cyclone emissions
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Iralco Report No. Tl91 -A
c Part&late Mass
PliM Stack No. Stack Description Source of Emission Matter Emissions mg/Nm3 kg/b
A2-2 Primer Process emissions
Primer booth extraction unit (exhaust fan) 4.06 0.057
Paint Plant A2-6 Top-coat Process emissions Top-coat booth extract unit (exhaust fm) 3.17 0.152
122-S Clear-coat Process emissions Clear-coat booth extract unit (exhaust fan) 3.74 0.183
Mechanical A2-13 Cyclone emissions Cyclone exhaust from Audi Forming Front Al cutting 2 machine
CO.48 <O.OOl
VW Passat A2-14 Scrubber 1 6 Passat sanding pedestals (x2) CO.37 co.006 A215 Scxbber 4 3uh Robot/4 Metabo Polishers 0.37 0.0072
AZ!-16 Scrubber 2
Volvo P28 emissions Emissions from semi-automatic polishing machines cl?.40 <0.008
A2-17 Scrubber 3 emissions
Emissions from other polishing machines CO.48 c2.91 x 1o-3 I
Mechanical A2-18 Cyclone Exhaust Cyclone Exhaust (2) f?om Magna pebra saws + 2xTT ~0.48 <OX503 - I
Roofrail millers A2-19 Cyclone Emissions Cyclone Exhaust from 1 sander & 1 polisher CO.48 <0.002
Powder Coating A2-20 Cyclone emissions Cyclone emissions from powder plant room 228.3 0.811
Pyrolyser AZ23 Oven/process exhaust
Oven emissions co.47 c2.0 x I o4
Sanding Area A2-24 Cyclone exhaust Cyclone exhaust from 6 sanding stations co.37 <0.012
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,i’alco Report No. T191 -A
TABLE 4.3: TOTAL METAL ANALYSI[S RESULTS IVote I
Plant Total Mass Emissions
Stack No. Stack Description Source of Emission Metals mg/Nm3 kglhr
AZ2 Primer Process Primer booth extraction unit (exhaust emissions fad
-L15 co.06
Paint Plant AZ-6 Top-coat Process Top-coat booth extract unit (exhaust emissions f=d
(2.20 CO.09
X2-8 Clear-coat Process Clear-coat booth extract unit emissions (exhaust fan)
G.84 co.14
1 Mechanical 2 1 AX-13 1 CycIone emissions 1 Cyclone exhaust from Audi Forming Front Al mtin~ machine
c3.46 t co.01 I
VW Passat
Volvo P28
A2-14
A2-I.5
AL!-16
A2-17
Scrubber 1
Scrubber 4 Scrubber 2 emissions Scrubber 3 emissions
6 Passat sanding pedestals (x2) BuIa Roboti Metabo Polishers Emissions from semi-automatic
polishing machines Emissions from other polishing
machines
c2.69 co.05
0.17 co.04
c3.01 co.05
c3.46 co.02
Mechanical 1 A2-18
A2-19
Cyclone Exhaust
Cyclone Emissions
Cyclone Exhaust (2) from Magna pebra saws + 2x’IT Roof?ail miliers Cyclone Exhaust fiorn 1 sander & 1
nolisher
c3.47 <0.02’ *
Cl.42 co.01
Pyrolyser A2-23 Oven/process exhaust Oven emissions c3.41 co.002
Sanding Area A2-24 Cyclone exhaust Cyclone exhaust from 6 sanding stations ~2.68 <0.08
Note ’ Analysis of field blank quartz filters using Inductively Coupled Plasma Mass Spectroscopy (ICP-MS) yields
background levels of a variety of metals, resulting a high analytical limit of detection for such metals. Results obtained for all metals on sample filters were detected at levels less than the relevant analytical limit of
detection for individual metals and subsequently for total metal content.
Bord na M&a, Technical Services Page 15
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Renort No. 7791-A
TABLE 4.4: TOTAL ORGANIC CARBON Ei’vlISSPONS (AS C) Plant Stack No. Stack Description Source of Emission Total
Mass Emissions Organic Carbon mg/Nm3 as (C)
kg/k
Paint Plant AZ1 Pre-treatment Degreasing extract unit (extract Process emissions fan)
255 1.25
A2-2 Primer Process Primer booth extraction unit emissions (exhaust fan)
82 1.15
A2-3 Primer Process Primer booth ff ash off extraction emissions unit (exhaust fan) 7.9 0.03
A2-4 Primer Process emissions Primer natural vent 56 0.11
A2-5 Primer Process emissions Primer oven vent so 0.17
A2-6 Top-coat Process Top-coat booth extract unit emissions (exhaust fan) 260 12.4
AZ-7 Top-coat Process emissions Top-coat flash-off (exhaust fan) 3.4 0.01
.* A2-8 Clear-coat Process Clear-coat booth extract unit
emissions (exhaust fan) 65.5 2.6
A2-9 Clear-coat Process Clear-coat flash-off extraction emissions unit (exhaust fan) 53.1 0.18
A2-10 Clear-coat Process emissions Clear-coat natural vent 239 0.28
A2-I 1 Clear-coat Process emissions Clear-coat oven vent 82 0.11
A2-12 Process emissions Paint kitchen exhaust 97 0.49 Mechanical 2 A2-13 CycIone emissions Cyclone exhaust from Audi
Forming Front Al cutting 84 0.25 machine
VW Passat A2-14 4 Scrubber 1 6 Passat sanding pedestaIs (x2) 4.7 0.08
A2-15 Scrubber 4 Bula Robot/4 Metabo Polishers 11.7 0.23 Volvo P28 AZ-16 Scrubber 2 Emissions from semi-automatic
emissions polishing machines 15.7 0.28
A2-17 Scrubber 3 Emissions from other polishing emissions machines 3.3 0.02
Cyclone Exhaust (2) from Magna A2-18 Cyclone Exhaust pebra saws + 2xTT Roofrail 7.2 0.05
Mechanical 1 millers I
A2-19 Cyclone Emissions Cyclone Exhaust from 1 sander & 1 polisher 11.8 0.11
Powder Process Emissions Emissions from Dipping Bath 3.75
Coating A2-2 1 treatment tanks 0.023 Pyrolyser Oven/process Oven emissions Note 1 Note 1
A2-23 exhaust ‘Ote ’ TOC monitoring not undertaken as the point source emission outlet temperature (495°C) was in exceedence of
the temperature operating range of TOC sampling equipment.
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Irnlco Report No. Tl91-A
TABLE 4.5: ACID ANALYSIS RESULTS 1
Plllllt
Paint Plant
Powder Coating
Stsck No.
A2- 1
A2-2 I
Stack HF HF I-IN03 HN03 KS04 I-I$04 W04 H3P04 Source of Emission
Description mg/N m3 kglhr mg/N m3 kglhr mg/Nm3 kg/hi” mg/Nm3 kg/hr
Prc-treatment Process Degreasing extract unit (extract fan) 0.63 3.63 x 10” n/a n/a 9.44 0.054 n/a n/a
emissions Process Emissions from Dipping Bath treatment
Emissions tanks 0.31 1.94 x IO” n/a n/a n/a n/a 1.13 7.06 x 1O”3
Electrobrighte Scnlbbel Scrubber from dip charge tanks A2-22
exhaust emissions n/a n/a 1.09 0.014 10.22 0.13 co.39 c5.75 x 10”
ning
n/a = acid parameter is not applicable to the constituents of the process emission.
TABLE 4.6: AMMONIA ANALYSIS RESULTS
rlallt Stack No.
Stack Description
Sowce of Emission
Ammonia as
(NW
mg/Nm3
MilSS
Emissions kg/hr
Ammonia
, Electrobrighte
nine A2-22 Scrubber exhaust
Scrubber Corn dip charge tanks emissions
0.36 4.74 x 1o-3
TABLE 4.7: SODIUM HYDROXIDE ANALYSIS RJXSULTS Note’
Plant Stack No.
Stack Description
Source of Emission NaOH
mg/Nm3
NaolI Mass Emissions
kg/h1 I ,
Electrobrighte A2-22 Scrubber exhaust
Scrubber from dip charge 0.11 1.59 x 10”
ning tanks emissions ND’r ’ It is assumed that all elemental sodium detected in the sample is present in the form of sodium hydroxide.
Bord rrn Mhn, T~clrnicnl Services December 2003
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hzko Report No. T191-A
5.0 DISCUSSION
Tables 4.1 to 4.7 present the results of the recent air monitoring programme carried out at the Iralco facility, in Collinstown, Mullingar, Co. Westmeath. Where available, results obtained are compared to emission limit values listed in the BATNEEC Guidance Note for the Manufacture or Use of Coating Materials.
5.1 Particulate Matter Emissions
Particulate matter results for 13 point source emissions sampIed are presented in Table
4.2. For spray painting operations, the BATNEEC emission limit value for
particulates is 3 ms/m3. This limit is exceeded by emission points A2-2, A2-6 and A2-8 and A2-20.
The BATNEEC Guidance Note for the Manufacture or Use of Coating Materials does not specify an ELV for particulate matter for other processes. In this absence, the T A Luft, Technical Instructions on Air Quality 2001 may be referenced. Section 5.2.1 therein states that ‘the dust emissions contained in any waste gas may not exceed a mass flow of 0.2Okg/h or a mass concentrations of 20mg/m3. Even with a mass flow smaller than or equal to 0.2Okg/h, a mass concentration of 0.15g/m3 in the waste gas may not be exceeded’.
All non spraying operations do not exceed the 20mg/m3 BATNEEC guide value.
5.2 Total Metal Emissions
Total metal results (inorganic particle matter) from 22 point source emissions sampled are presented in Table 4.3. In the absence of limit values in the BATNEEC Guidance Notes for the Coating Industry, comparison of results obtained is made to the guide values stated in Section 5.2.2 of the T A Lufi 200 1 Technical Instructions.
TABLE 5.1: GUIDE VALUES FOR EMISSIONS TO AIR
Constituent Group or Parameter
Class Note 1 Mass Flow Threshold Emission Limit
for ELV Value mg/m3
T.A. L&t Class I >0.25 gill 0.05 Inorganic Particle Matter T.A. Luft Class II >2.5 gfh 0.5
T.A Luft Class III >5 g/h 1
‘Ote ’ T.A. Luft (German Technical Instructions on Air Quality Control - T.A. Luft 2001,
paragraph 5.2.1) guideline values for Inorganic Particle Matter are used, Classes I to III.
No metal contained within CIass I (e .g. Cadrniurn, Mercury) was detected in any sample analysed at the I&co facility. If substances of several classes are present, the mass
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concentration in the waste gas shall for coinciding Class II and IIT substances shall not exceed a total of lmg/m3. Analysis of field blank quartz filters using Inductively Coupled Plasma Mass Spectroscopy (ICP-MS) yields background levels of a variety of metals, resulting in a high analytical limit of detection for such metals.
Results obtained for all metals on sample filters were detected at levels less than the relevant analytical limit of detection for individual metals and subsequently for total metal content, However, due to the high analytical detection limits for the metal analysis, the results appear to exceed the T A Luft Class III guide value for total metals. However, as the metal content cannot exceed the particulate matter level (see Tables 4.2 and 4.3), there are only two emission points, namely A2-6 and A2-8, that may have exceeded the guide value of lmg/m3.
5.3 Total Organic Carbon (TOC) Emissions
r
TOC results (as C, relative to methane) for 21 point source emissions sampled during this assessment are presented in Table 4.4. Comparison of results obtained should be made to the ELV’s listed in Tables 5.1 and 5.4 of the BATNEEC guidance notes for Class 12.2 activities as represented below in Tables 5.2 and 5.3 respectively.
TABLE 5.2: BATNEEC EMISSION LIMIT VALUES FOR EMISSIONS TO AIR FOR ALL SOURCES
Emission SOlUTe
All
Sofvent Use or Consumption
Above *&&riold (tonnes/annum)
given in Tables 5.2 - 5.4
! I
I
Limit Values for Waste Gas Discharges mg/m3
Class A (total): 2 (for mass emissions > 1 Ogh of Class A CO~JOLIIYI~~)
Class B (total): 20 (for mass emissions > 1 OOg5 of Class B compounds)
Particulates (spray painting operations): 3
Other emissions: See tables 5.2 - 5.4
TABLE 5.3:BATNEEC EMISSION LIMIT VALUES FOR EMISSIONS TO AIR FROM OTHER
COATING PROCESSES
Emission Source Solvent Use or
Consumption Limit Values for Waste Gas Discharges u-g/m3
Other coating (e.g.
textiles, fabric, film &
paper)
lo-15t/a
>15 t/a
Coating and Drying
Total Organics (as C): 150
Coatiw
Total Orgzs C): 100
L?!Yiw Total Organics (as C): 50
Bord na M&a, Technical Services Page 19
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I I I I I I I 1 I I I I 1
1 I 1
Iralco utilise greater than 15 tonnes of solvents per annum. Consequently, the limit values for Total Organic Carbon (as C) for the coating process applies. In comparison with the results in Table 4.4 with the aforementioned limit values, emissions from M-1, AZ-6 and A2-IO during this monitoring event, exceed the 100 r&m’ for the coating process. However, for all other emission points monitored, the relevant emission limit value is not being exceeded.
In addition, attention should also be paid to the emission limit values for waste gases listed within the EU Council Directive 1999/13/EC of 11 March 1999 ‘on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations ’ which has been enacted into Irish law under S. I. No. 543 of 2002. Activities undertaken at Iralco are defined in Annex I of this Directive (Activity No. 8 - other coating, including metal, plastic, textile, fabric, film and paper coating), with an annual solvent consumption threshold in excess of those listed in Annex ILA (lower solvent threshold value of 5 tonnes/annum). The requirements within the Directive pertaining to atmospheric emissions of TOC’s for ‘existing installations’, therefore also apply to I&co. The relevant emission limit values for TOC’s(as C> in the waste gases listed in Annex IL4 or the requirements of the ‘reduction scheme’ listed in Annex III3 shall be complied with within specific time periods. Limit values of 50 mgNm3 applies to coating processes for installations with solvent consumption greater than 15 tonnes/annum. Existing installations must comply with these limits no later than 3 1 October 2007. However, existing installations which operate existing abatement equipment and complies with the ELV of 150 mg/m3 shall be exempt Tom the aforementioned ELV’s for a period of 12 years after the date referred to in Article 1.5, i.e. April 2013.
With the exception of emission point sources AZ-l, A2-2, A2-4, A2-5, A2-6, A2-8, A2- 9, A2-10, A2-11, A2-12 and A2-13 all other emission points monitored during this assessment are within the limit values of 50 mg/Nm3 for coating processes. No item of
abatement equipment is in place for emission point sources A2-1, M-6 and A2-10 and therefore the higher ELV of 150 mg/m3 does not apply.
5.4 Acid Emissions
Results for acid emissions from 3 point source emissions sampled are presented in Table 4.5. In the absence of comparison with relevant BATXEEC ELV’s for levels of acids obtained, attention may be paid to the ELV’s listed in T.A. Luft (German Technical Instructions on Air Quality Control - T.A. Luft 2001) guideline values for Vaporous or Gaseous Inorganic Substances, Classes I to IV as represented in Table 5.4.
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TABLE 5.4: T.A. LUFT EMISSION LIMIT VALUES FOR VAPOROUS OR GASEO’CTS INQRGkMC
SUBSTANCES EMWZBNS TO AIR I
Constituent Group or Parameter
TA Luft Class
TA Luft Class I
Mass Flow Threshold
>2.5 gih
Emission Limit
Value mglm3
0.5
Vaporous or Gaseous horganic
Substances
TA Luft Class II
TA Lufi Class III
TA Luft Class IV
>15 g/h
>0.15 kg/h
>1.8 kg/h
3.0 30.0 350.0
Levels of hydrofluoric acid (HP) obtained in all point source emissions monitored are below the T.A. Luft Class 1T concentration and mass emission limits of 3.0 mg!m3 and 15 g/h respectively. Levels of nitric and sulphuric acid were detected in AZ-22 ( Electrobrightening plant, scrubber exhaust) at concentrations of 1 .Q9 and 10.2 mgIm3 respectively. The level of phosphoric acid detected was less than the analytical limit of detection of 0.39 mdm3. 9.44 mg/m3 of sulphuric acid was detected in the emission fi-om A2-1. No ELV’s are available witbin BATNEEC, T.A. Luft or Danish EPA guidelines specifically for discharges of sulphuric, nitric or phosphoric acids to air. In this absence, a small fraction of the Occupational Exposure Limits (QELs) published by the National Authority for Occupational Safety and Health (NAOSH) and listed in the 2001 Code of Practice for the Safety, Health and Welfare at Work (Chemical Agents) Regulations 2001 may be used. The level commonly used is one fortieth of the Short Term Exposure Limit (STEL). These guide values are 0.25 ms/m3, 0.05 mg/m3 and 0.025 mg/m3 for nitric, phosphoric and sulphuric acid respectively. Emission point A2-22 exceeds the relevant guide value for nitric acid. The guide value for sulphuric acid is exceeded for emission points A2-1 and AZ-22. Emission point A2-21 exceeds the 0.05 mg/m3 guide value for phosphoric acid.
.
5.5 Ammonia and Sodium Hydroxide Emissions
Results for ammonia and sodium hydroxide emissions from A2-22, the scrubber exhaust in the Electrobrightenin g Plant are presented in Tables 4.6 and 4.7 respectively. Under the T A Luft Technical Instructions on Air Quality Control 2001, ammonia is classed as a Class III Inorganic substance and assigned a guide value of 30mg/m3 at a flow rate of O.lSkg/h. The level of ammonia detected at the outlet of emission point A2-22 during this monitoring event is considered low at 0.36 mg/m3 with a mass flow of ~0.005 kg&r and hence is significantly below the T A Luft guide value. No ELV’s are availabIe within BATNEEC, T.A. Luft or Danish EPA guidelines for discharges of sodium hydroxide to air. Guidance may be obtained from one fortieth of the OEL (0.0530mg/m3) as stated in the 2001 Code of Practice for sodium hydroxide. The concentration for emission point A2-22 exceeds this guide.
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However, the level of sodium hydroxide detected at the scrubber outlet during this monitoring event is considered low.
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