APPENDIX 2.Assessment of Emissions to Athmosphere from the Iralco Facility.

Iralco Air Modelling 2005

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:52

Iralco

Integrated Pollution Control Licence Appkation

ATTACHMENTNO. 12(A)

DETAILSOFALLPOINTEMISSIONSTO ATMOSPHERE

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:52

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

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:52

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

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:52

I I D I

I I I D I I I I I I I I I

A4 Potential Emissions

None

.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:52

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:52

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:52

In

TTACHMENT No. 12(B)

Fucnm EMISSIONS TO ATMOSPHERE

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:52

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

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:52

Iralco I

Pollutioaz coxktr 1 lliamx Application

ATTACHMENT No. i 2(C)

ASSESSMENT OF ATMOSPH~NC EMISSIONS

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:53

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

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:53

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

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:53

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

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:53

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.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:53

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

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:53

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

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:53

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

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:54

!

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

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:54

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

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:54

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

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:54

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

Bard na M&a, Technical Services Page I I

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:54

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

Bard na M&a, Technical Services Fape I2

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:54

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

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:54

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

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:54

,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

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:55

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.

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:55

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

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:55

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

Bard FZR M&R, Tech&al Services Pa,0 18

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:55

.lraico Report No. Tl91-A

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

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:55

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.

I Bard na M&a, Technical Services Paze 20

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:55

Irako Report No. T191-A

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.

Bord na Mha, Technical Services Page 21

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:55

Report No. 3391-A

However, the level of sodium hydroxide detected at the scrubber outlet during this monitoring event is considered low.

Bard na M&m, Technical Services Paze 22

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 25-07-2013:16:11:55