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ATTACHMENT NO C& Paper Industries (SAPPI) as Mill Manager of the Usutu Pulp Company in Swaziland and...

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ATTACHMENT N O C MANAGEMENT OF THE INSTALLATION 1. Site Management & Control 2. Environmental Management System (EMS) 3. Hours of Operation 4. Fit and Proper Person Additional Documents Included SmartPly Europe Ltd. Environmental Policy Environmental Management Programme 2014
Transcript
Page 1: ATTACHMENT NO C& Paper Industries (SAPPI) as Mill Manager of the Usutu Pulp Company in Swaziland and with Courtaulds Fibers as Factory Systems Manager at their viscose rayon plant

ATTACHMENT NO C

MANAGEMENT OF THE INSTALLATION

1. Site Management & Control

2. Environmental Management System (EMS)

3. Hours of Operation

4. Fit and Proper Person

Additional Documents Included

SmartPly Europe Ltd. Environmental Policy

Environmental Management Programme 2014

Page 2: ATTACHMENT NO C& Paper Industries (SAPPI) as Mill Manager of the Usutu Pulp Company in Swaziland and with Courtaulds Fibers as Factory Systems Manager at their viscose rayon plant

SmartPly Europe Ltd. P0001-03 Attachment C

1. Site Management & Control

SmartPly Europe Ltd is a wholly owned subsidiary of Coillte Teoranta, a state owned company operating in forestry, land based businesses and added-value processing operations. SmartPly, along with Medite Europe Ltd, are part of the Coillte Panel Products (CPP) division of Coillte. The organisation structure for CPP is shown in Figure 1.

Figure 1: Organisational structure of Coillte Panel Products

Environmental management is incorporated into all functions of SmartPly’s operations and is ultimately driven by the Chief Operations Officer. The organisational structure for SmartPly Europe Ltd. is shown in Figure 2.

Neil Foot Acting Managing Director, CPP

Pat Trihy Director

Finance & Procurement, CPP

Denis Buckley Director

Finance & Procurement, CPP

John Browne Procurement Manager,

CPP

AN Other Chief Operations

Officer, CPP

Pat Beardmore Operations Director,

Medite

Jim McCann Operations Director,

SmartPly

Mark Hearne HR Manager, CPP

Lindy Duff Logistics Manager, CPP

David Murray Innovation Manager,

CPP

Andrew Macdonald Director

Sales & Marketing, CPP

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Page 3: ATTACHMENT NO C& Paper Industries (SAPPI) as Mill Manager of the Usutu Pulp Company in Swaziland and with Courtaulds Fibers as Factory Systems Manager at their viscose rayon plant

SmartPly Europe Ltd. P0001-03 Attachment C

Figure 2: Organisational structure at SmartPly Europe Ltd.

Jim McCann Operations Director,

SmartPly

Michael Nichol Technical Manager

Colm Clancy Process Engineer

Ronnie Roux Process Improvement

Technician

Conor Bohan R&D Assistant

Anne Lucey Quality &

Environmental Manager

Paul McGovern Quality Leadman

Lyndsey Broxton O'Leary Laboratory Technician

Cormac Ryan Laboratory Technician

Liam Robinson Maintenance

Manager

James Phelan Logyard Manager

JB O'Sullivan Logyard Quality

Operator

2 Logyard Operators

Deirdre Foskin Stores Manager

Liam Phelan Stores Operator

Frank Kavanagh Mechanical Leadman

13 Mechnical Technicians

Edna MacDonald Maintenance Planner

Derek Dardis Electrical Engineer

John Ross Electrical Maintenance

Manager

Brian Maher Process Autormation

Technician

8 Electrical Technicians

Seamus Ryan Projects Manager

Muiris O'Suilleabhain Project Enigineer

Paul Doherty Production Manager

4 Shfit Coordinators

16 Shift A Operators

16 Shift B Operators

16 Shift C Operators

16 Shift D Operators 8 Area Leaders

5 Utility Crew

2 Coating Line Operators

Ann Marie Gahan Operations

Administrator

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Page 4: ATTACHMENT NO C& Paper Industries (SAPPI) as Mill Manager of the Usutu Pulp Company in Swaziland and with Courtaulds Fibers as Factory Systems Manager at their viscose rayon plant

SmartPly Europe Ltd. P0001-03 Attachment C

The Operations Director is responsible for all plant operations at SmartPly including the function of environmental performance and compliance. The Quality & Environmental Manager is responsible for managing the environmental management system and environmental licence requirements. Environmental management and monitoring is supported by the Laboratory Technician. Managers and Area Leaders in each department are responsible for ensuring that specific environmental obligations are fulfilled within their own work area. This includes obligations for the operation and control of abatement and treatment systems on-site. Daily production meetings are held and environmental issues are discussed and raised as required. All personnel receive environmental induction training on commencement of employment at SmartPly and specific or refresher training as the need arises. SmartPly’s environmental policy statement is included as part of this Attachment.

SmartPly assesses environmental performance on an on-going basis and aims to continuously improve through the implementation of the annual environmental management programme. A copy of the EMP for 2014 forms part of this attachment. Coillte Panel Products and SmartPly also set key performance indicators for environmental compliance which are reviewed on a monthly and quarterly basis.

2. Environmental Management System

SmartPly operates a documented system for the management of environmental, safety, quality and operational systems on site. The quality management system is certified to IS0 9001:2008 and the safety system successfully completed a certification audit to ISO 18001 in October 2014. The environmental management system is not currently certified to any established standard but is based on the same principles and controls as the quality and safety management systems.

3. Hours of Operation

SmartPly’s normal hours of operation will remain unchanged following the plant upgrade. The current hours of operation are:

Production: 24 hours/day, 7 days/week

Office hours: Mon – Thurs 08:00 – 16:30, Fri 08:00 – 15:30

Weighbridge: Mon – Thurs 06:45 – 21:00, Fri 06:45 – 20:00, Sat 07:00 – 13:00, Sun Closed.

3.1 Proposed Hours of Construction/Development Works and Timeframes

Construction and installation works will take place Monday - Friday between 07:00 – 20:00 and Saturdays 07:00 – 18:00 with the majority of work being carried out during normal office hours. In the event of project delays, construction and installation works may be carried out on a 24hr basis. In the event of such an occurrence, every effort will be made to ensure that these works will not impact off-site. Table 1 shows the timeframe for the plant upgrade and installation of equipment.

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Page 5: ATTACHMENT NO C& Paper Industries (SAPPI) as Mill Manager of the Usutu Pulp Company in Swaziland and with Courtaulds Fibers as Factory Systems Manager at their viscose rayon plant

SmartPly Europe Ltd. P0001-03 Attachment C

Table 1: Timeframe for SmartPly plant upgrade key milestones

Project Milestone Date Commence site enabling works Nov-14 Place order with supplier for main process equipment Sep-14

Start Building works Nov-14 Technical specifications for third

party equipment from supplier

Building construction equipment ready

Jul-15 Delivery of supplier plant equipment to site Start main equipment installation Aug-15 Complete equipment installation Jan-16 First Board Mar-16 Project Closure Jul-16

4. Fit and Proper Person

SmartPly Europe Ltd. and the Directors of SmartPly have not at any time been convicted under the Environmental Protection Agency Act 1992, as amended, the Waste Management Act 1996, as amended, the Local Government (Water Pollution) Acts 1997 and 1990, the Air Pollution Act 1987 and the Air Pollution Act 1987 (Environmental Specifications for Petrol and Diesel Fuels) (Amendment) Regulations 2004.

The Operations Director, Jim McCann, is a Chartered Chemical Engineer with twenty seven years’ experience managing large scale production operations and large scale projects in synthetic fibres, wood pulp and panel board sectors in the USA, Africa and Europe. The Operations Director is responsible for manufacturing operations and technical innovation at the SmartPly plant in Waterford. Prior to joining SmartPly, Jim held senior management positions with South African Pulp & Paper Industries (SAPPI) as Mill Manager of the Usutu Pulp Company in Swaziland and with Courtaulds Fibers as Factory Systems Manager at their viscose rayon plant in Mobile, Alabama, USA. Prior to this he worked for 9 years as a chemical engineer in wood pulp, inorganic fertiliser and inorganic chemical manufacture.

The Quality & Environmental Manager, Anne Lucey, has a Degree in Environmental Science and a Diploma in Quality Assurance. Anne has nine years’ experience working in IPPC licenced environments. She is responsible for implementing the EMS, environmental licence conditions and EMP annually. The Laboratory Technician, Lyndsey Broxton O’Leary, is qualified to degree level in Environmental Science. She is responsible for monitoring and supporting the implementation of the EMS and environmental licence conditions. They have a wide range of experience within IPPC

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Page 6: ATTACHMENT NO C& Paper Industries (SAPPI) as Mill Manager of the Usutu Pulp Company in Swaziland and with Courtaulds Fibers as Factory Systems Manager at their viscose rayon plant

SmartPly Europe Ltd. P0001-03 Attachment C

licenced industries and both have been working at the SmartPly installation for over 7 and 4 years respectively.

SmartPly is a wholly owned subsidiary of the state company Coillte Teoranta, who currently guarantees all the liabilities of SmartPly under Section 17(1) of the Companies (Amendment) Act, 1986. In the event of a site closure financial requirements would be underwritten by Coillte’s own internal resources. Attachment K contains further information regarding environmental liabilities and CRAMP.

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Page 7: ATTACHMENT NO C& Paper Industries (SAPPI) as Mill Manager of the Usutu Pulp Company in Swaziland and with Courtaulds Fibers as Factory Systems Manager at their viscose rayon plant

SmartPly Europe Ltd Environmental Policy

SmartPly Europe Ltd, a wholly owned subsidiary of Coillte, manufactures Oriented Strand Board, an environmentally sustainable timber-based product, which is used for structural and non-structural building applications. SmartPly Europe is committed to a healthy environment by taking a leadership role in our community to be good neighbours. We believe sound business practices and efforts to enhance the environment are compatible.

The Environmental Policy Principles at SmartPly Europe are as follows: Commitment: Senior Management and the Board of Directors are accountable for environmental issues and prepare environmental plans that allocate adequate financial and human resources to ensure that these issues are dealt with in a manner that reflects their high priority. Notwithstanding the foregoing, all employees must take account of the consequences of their actions and their obligation to integrate the Environmental Policy Principles in all activities, in conjunction with all other relevant policies. Competence: Ensure workforce competence and responsibility at all levels through selection, retention, education, training and awareness in all aspects of the environment, health and safety. Risk Assessment: Identify, assess, prioritise and document the hazards and risks associated with all our activities. Prevention and Control: Prevent, minimise or control priority risks, personal injury & illness, property and environmental damage, through planning, design, investment, management and workplace procedures. Where accidents and incidents do occur, take prompt corrective action, investigate root causes and take remedial action. Actively seek to prevent recurrences and disseminate experiences learned. Prepare and periodically test emergency response plans. Performance: Set appropriate goals, objectives, targets and performance indicators for all our operations. To strive as a minimum to achieve, and where possible surpass, Integrated Pollution Prevention and Control License condition requirements and all applicable Environmental legislation and regulations. Apply international best practice and utilise Best Available Technology (BAT) to achieve environmental targets and goals. Sustainable Development and Sustainable Products: Commitment to sustainable forestry practices through maintaining FSC Certification. Manufacture a range of timber panels, which deliver value for money in all applications safely, which incorporate environmental benefits. Active promotion of recycling and waste minimisation on-site. Continual Improvement: Foster creativity and innovation in the management and performance of our business, and our approach to solving the challenges facing our enterprise. Support research and development into environmental, health & safety issues, and promote the implementation of international best practices and technologies where appropriate and where feasible. Evaluation: Monitor, review and confirm the effectiveness of management and workplace performance against objectives, targets and applicable legal requirements, and report findings of such evaluation measures to all relevant personnel. Communications: Promote and maintain open and constructive dialogue and good working relationships with employees, local communities, regulatory agencies, business organisations and other affected and interested parties, to increase knowledge and enhance mutual understanding in matters of common concern. Make available to interested parties relevant information on the company’s environmental performance and respond to any community concerns that may arise. Operational Activities: Endeavour to operate in a manner which minimises adverse impact on employees, local community and environment utilising energy and other resources responsibly and efficiently. Incorporation of environmental costs into financial plans and the purchase/use of products is reviewed from an environmental and health and safety point of view, prior to purchase.

Page 8: ATTACHMENT NO C& Paper Industries (SAPPI) as Mill Manager of the Usutu Pulp Company in Swaziland and with Courtaulds Fibers as Factory Systems Manager at their viscose rayon plant

I

SmartPly Europe Ltd lE Licence RegNo. : POOOJ-03

2.2 Environmental Management Programme 2014 Proposal

The following is SmartPly Europe's Environmental Management Programme proposal for 2014. The EMP proposal outlines the programme's objectives and targets, required actions, responsibilities, resources needed and proposed completion dates.

Objective: Target:

Project:

Reduce fugitive emissions Achieve 100% compliance with baghouse particulate monitoring and eliminate potential for fugitive emissions from all other sources

Install high efficiency dust filter at emission point reference A2-7

Aim I Reasons The aim of the project is to improve the efficiency of dust removal from for production processes, reduce the potential for fugitive emissions and Undertaking achieve I 00% compliance with monitored emissions from baghouse filters.

Actions - Install and commission high efficiency dust filter at emission point reference A2-7.

Responsibility Operations Director /Projects Manager

Resources Financial: As per approved capital expenditure budget. Required Completion Q2 2014 Date

Objective: Reduce noise emissions Target: Achieve zero noise related complaints

Project: On-site noise mitigation

Aim I Reasons The aim of the project is to mitigate noise emissions from the plant for Undertaking

Actions - Assess plant in order to identify areas which may be contributing to noise emission impacts off-site e.g. wall vents and fans.

- In conjunction with the maintenance department, ensure any malfunctioning or imbalanced equipment is repaired or replaced.

- Improve notices for noise compliance on plant doors and notice boards.

Responsibility - Lyndsey Broxton O'Leary - Laboratory Technician

Resources Financial: To be detennined where required Required Completion Q4 2014 Date

10 of 14

Page 9: ATTACHMENT NO C& Paper Industries (SAPPI) as Mill Manager of the Usutu Pulp Company in Swaziland and with Courtaulds Fibers as Factory Systems Manager at their viscose rayon plant

SmartP/y Europe Ltd lE Licence RegNo.: POOOJ-03

Objective: Target:

Project:

Resource Use and Energy Efficiency Reduce energy consumption and consumable usage per m3 of product produced

Install heat recovery system on the exhaust coming from the compressors.

Aim I Reasons There are three air compressors on site. The aim of the project is to recover for heat generated from the compressors and use it to heat the office block and Undertaking water.

Actions - Install a heat recovery system/ buffer tank. - Add piping from the buffer tank to the office heating system.

Responsibility Liam Robinson - Maintenance Manager

Resources Required

Completion Date

Objective: Target:

Project:

Brian Maher - Process Automation Technician.

Financial: As per approved capital expenditure budget.

Q4 2014

Environmental Management Systems EMS which complies with all relevant regulations, requirements and guidelines

Improve the process of treating WESP circuit water.

Aim I Reasons The aim of the project is to improve the pressing of Nijhuis sludge and so for improve the process of treating the circuit water from the WESP's. Undertaking

Actions - Upgrade capacity of dewatering press so that the process of treating the WESP circuit is more efficient.

Responsibility - Michael Nichol - Technical Manager - Colm Clancy - Process Engineer - Ronnie Roux - Electrician

Resources Financial: Pending capital expenditure plan Required

Completion Q4 2014 Date

11 ofl4

Page 10: ATTACHMENT NO C& Paper Industries (SAPPI) as Mill Manager of the Usutu Pulp Company in Swaziland and with Courtaulds Fibers as Factory Systems Manager at their viscose rayon plant

SmartPly Europe Ltd lE Licence RegNo.: POOOJ-03

Objective: Target:

Project:

Environmental Management Systems EMS which complies with all relevant regulations, requirements and guidelines

De-sludge Emergency Holding Tanks

Aim I Reasons Condition 3 of the IPPC Licence. for Undertaking

Actions

Responsibility

Resources Required

Completion Date

Objective: Target:

Project:

The aim of the project is to de-sludge the Emergency Holding Tanks (EHTs) to ensure adequate capacity is available for fire water retention on site

- Complete de-sludging proposal and submit to the Agency for approval. - De-sludge EHT I utilising approved contractor

- Anne Lucey - Quality & Environmental Mgr - Sharon Mal one - Environmental Technician

Financial: To be determined

Q4 2014

Environmental Management Systems EMS which complies with all relevant regulations, requirements and guidelines

Improve filtration of WESP scrubber water

Aim I Reasons Condition 5 of the IPPC Licence. for The aim of the project is to improve the filtration of the scrubber water in Undertaking the WESPs which wiii help to improve compliance with air emission

parameters.

Actions - Install filter on cleaning pwnp system in WESP I

Responsibility - Michael Nichol - Technical Manager - Colm Clancy - Process Engineer - Ronnie Roux - Electrician

Resources Financial: €50,000 Required Completion Q3 2014 Date

12 of 14

Page 11: ATTACHMENT NO C& Paper Industries (SAPPI) as Mill Manager of the Usutu Pulp Company in Swaziland and with Courtaulds Fibers as Factory Systems Manager at their viscose rayon plant

SmartP/y Europe Ltd. lE Licence RegNo.: POOOJ-03

Objective: Target:

Project:

Resource Use and Energy Efficiency Reduce energy consumption and consumable usage per m3 of product produced

Trial production of OSB utilising resin derived from soya bean.

Aim I Reasons To trial resin of soya bean origin as an alternative to petrochemical based for resin binders. Undertaking

Actions - Trial soya bean derived resin and assess suitability as a viable alternative to existing resins.

Responsibility Michael Nichol - Technical Manager

Resources Financial: As per approved innovation budget. Required

Completion Q4 2014 Date

13 of 14

Page 12: ATTACHMENT NO C& Paper Industries (SAPPI) as Mill Manager of the Usutu Pulp Company in Swaziland and with Courtaulds Fibers as Factory Systems Manager at their viscose rayon plant

ATTACHMENT NO D

INFRASTRUCTURE & OPERATION

1. Current Process Description

2. Future Process Description

3. Development & operational history of the site

Additional Documents Included:

Drawing 1 - Present day process layout

Drawing 2 - Proposed process layout

Page 13: ATTACHMENT NO C& Paper Industries (SAPPI) as Mill Manager of the Usutu Pulp Company in Swaziland and with Courtaulds Fibers as Factory Systems Manager at their viscose rayon plant

SmartPly Europe Ltd. P0001-03 Attachment D

1. Current Process Description

The SmartPly Europe facility, co-located with the EU-funded Belview Port in County Kilkenny, produces commodity (OSB2), and construction grade (OSB3) oriented strand board products. The origins of the product in North America in the 1970’s coincided with the protection of large old growth “peeler” logs used for plywood; OSB being produced instead from renewable plantation grown softwood species. Oriented strand board or OSB is a composite wood-based panel product composed of thin wafers of pine and spruce pulp-grade wood pressed under heat and pressure with wax and synthetic resins. The resulting product is an environmentally sustainable and cost effective substitute for softwood plywood. The Belview facility currently utilises a single multi-opening press with fourteen flights and a nameplate capacity of 350,000 m3.

Figure 1: SmartPly Europe process overview

1. The logs are brought to site via a number of hauliers contracted by Coillte. Once the lorries have

been weighed and inspected to ensure the timber meets quality requirements, they are unloaded in the log-yard.

2. The logs are stacked and sorted into particular bays according to their species. When logs are

required in the plant, loaders remove them from their bays and place them in the log in-feed conveyor. From here they are slowly fed into the plant.

3. Once inside the plant the logs pass along a conveyor belt system to the debarkers where all of

the bark is removed. The debarkers are a drum type design. The removed bark is dropped into a waste conveyor system and is used to feed the biomass furnace or goes for stockpiling externally. Excess bark is sold off-site for horticultural usage.

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Page 14: ATTACHMENT NO C& Paper Industries (SAPPI) as Mill Manager of the Usutu Pulp Company in Swaziland and with Courtaulds Fibers as Factory Systems Manager at their viscose rayon plant

SmartPly Europe Ltd. P0001-03 Attachment D

4. From there, the debarked logs pass along to the waferisers where they are shredded or waferised to the required flake size. These flakes or strands are then stored in the four wet bins.

5. Next, the strands are dried in one of the four large dryers. The current process uses four direct

fired rotary drum dryers. The strands are pneumatically conveyed through the dryers while exposed to a stream of hot air that is generated from the biomass burners. The burners are fuelled with fine wood and dust particles which are collected from different stages of the process via the baghouse filters. The biomass is generated from the dry flake screening process, board cutting and trimming area and from dust collected from sanding board for T&G and other products.

All of the emissions from the dryers and the biomass furnace are passed through the air

pollution control system, called WESPs (Wet Electrostatic Precipitators), where they are treated before venting to atmosphere. Each WESP is a two-stage treatment system; the first stage is a wet scrubber whilst the second stage is an electro-static precipitator. The exhaust gases contain ash, carbon monoxide and nitrogen oxides from the combustion of wood. In the dryer chamber, small quantities of wood fines result from the abrasion of wafers moving through the dryers. In addition, water vapour and organic compounds naturally occurring in the wood are driven from the wafers due to the heat in the dryers.

6. After exiting the dryers, the wafers are transferred pneumatically along with the dryer exhaust

to the primary cyclones which separate the wafers from the dryer exhaust gases. The exhaust gases along with the entrained fines exit the primary cyclones and then pass through the WESPs where fines, condensable organics and VOCs are removed. The cleaned exhaust gas then exits to atmosphere via the main stack A2-1. A portion of the scrubber water used in the WESPs is drawn off, treated with a flocculent and passed through a dissolved air floatation unit to remove the collected material. The material is then dewatered and the solids are used as fuel in the biomass furnace. The treated scrubber water is then returned to the WESPS.

7. The dried flake strands are then screened to remove all sub-sized strands and all dry fines

material. This rejected material is sent to the hammer-mill where it is pulverised to a fine dust for use as fuel in the dryer burners. The required dry strands then pass to the blenders where a mixture of wax and resin is applied which allows the strands to fuse together when heated under pressure in the press. The wax and resin are applied via spinner heads which rotate at very high speeds and distribute the resin and wax inside the rotating drum over the tumbling flake surface to ensure even bonding in the press.

8. The strands are then conveyed to four former bins on the forming line; top surface, two for the

core, and the bottom surface. Discs in the surface formers orient wafers in the major axis, while vanes in the core formers position the strands 90 degrees to the major axis for the core of the board, in order to yield a three layer construction. The loose mat of strands is conveyed on a caul screen from the forming line to the press. Cross-cut saws cut the mats to the required press size length by cutting out a crosswise section of the mat. The material from the crosswise section is then extracted via a baghouse filter with the flake being collected and processed in the hammer-mill for fuel as before.

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SmartPly Europe Ltd. P0001-03 Attachment D

9. Each caul screen with its own cut mat is then accelerated away to the loader and into the batch processing press. The loose mats are pressed between thermal oil heated steel platens after being loaded into the press. The intense heat and pressure applied allows the resin to cure and set so that the flakes are bound together resulting in the board being produced. Like the dryers, all emissions from the press are passed to the WESPs for treatment before venting to atmosphere. Emissions from the press consist of VOCs and water vapour which are emitted from the wafers and from the resins.

10. The product exiting the press is separated from the caul at the board caul separator. The empty

cauls return for refill to the forming station and the board is routed to the sawline. The pressed boards are trimmed to final product size with a portion routed to the sander and tongue and groove machine for further processing. Each board is grade stamped. Boards are stacked and bundled together with a band-strapping machine. The edges and surfaces of the boards may be spray coated with a water resistant edge seal and UV curable putty. Finished square edge product is spray stencilled with the Company logo and stored in the warehouse where it cools naturally until dispatched.

11. Finished Product is transported and shipped to customers in Ireland, United Kingdom, Europe

and America.

Drawing 1 showing the key process activities arrangement in the current plant is included at the end of this attachment.

2. Future Process Description

The manufacturing process for OSB in the future upgraded plant will utilise the same method but will be carried out with more efficient and up-to-date equipment in key process areas. The upgrade equipment is summarised and compared to the existing equipment in the following table:

Table 1: Existing & Updated Equipment Changes

Plant Equipment Existing Equipment New Equipment Log yard Existing log yard & equipment retained None Debarkers Two existing debarkers retained None Waferisers Two disc flakers retained None Geka Biomass Furnace - Thermal oil heater for press & hot gases to dryers

Existing Geka Biomass Furnace retained

Tie-ins to new press and upgrade of booster pumps

Wet flake bins Four wet bins retained None

Dryers Four rotating drum dryers retained (two single pass & two triple pass) None

Dryer heat system Four biomass burners retained None

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SmartPly Europe Ltd. P0001-03 Attachment D

Plant Equipment Existing Equipment New Equipment

WESPs Two existing WESPs retained Tie-ins for air emissions from new press and associated areas

Screens for flake screening Existing four screens retained None

Dry bins Three existing dry bins retained None

Blenders Three existing blenders retained: Top surface, core and bottom surface Tie in for flake reclaim to blenders

Blender outfeed conveyors

Three rake conveyors from blenders to existing forming line

New blender outfeed conveyors to transport flake from existing blenders to new forming line location

Forming line Existing forming line has limited control of flake distribution

New forming line required for continuous press compatibility

Press Existing multi-daylight batch press has limited panel control & inflexibility of dimensions

New continuous press & associated emissions extraction and scrubbing system

Board cooling Existing panels tend to warp when packaged hot. Dimensional tolerance can vary when panels cool after cutting

New board cooler included to cool panels prior to cutting and strapping

Master panel storage Current saw line causes downtime on existing press

New master panel storage included to decouple saw line from press

Saw line Current saw line designed for limited finished panel dimensions

New saw line included for wide panels (2.8m) and precision cutting of full size range of product mix. Dust extraction included

T&G & Coating line Existing line equipment retained Existing lines retained but layout modified to make way for installation of new press hall

Building Existing building size 28,800m2 – limited space for expansion

Building extension of 8,960m2 to house new continuous press

Drawing 2 shows the proposed key process activities for the plant and is included at the end of this attachment.

3. Development and operational history of the site

SmartPly Europe Ltd is a wholly owned subsidiary of Coillte. Formerly, the company was known as Louisiana Pacific Coillte Ireland Limited when under the control of both Coillte and Louisiana Pacific. The facility was first licensed on the 8th of June 1995 as Licence Reg. No. 1 following the plant’s initial development at its current site in Belview.

D-5

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SmartPly Europe Ltd. P0001-03 Attachment D

In 2003 SmartPly Europe Limited was granted planning permission for the vertical extension of the main stack A2-1 from 42m to 90m above ground level. This increase in height was undertaken in order to resolve the issue of plume grounding and odour nuisance at residences in the vicinity of the installation. The IPPC Licence was revised as a result and the new licence, P0001-02 was issued on the 2nd of September 2005. Minor adjustments to Licence P0001-02 were agreed with the Agency as noted in Table 2 below.

Table 2: Minor adjustments made to P0001-02

Condition No.

Existing Condition

Proposed Wording

OEE Agreement Reference Description

C.4 WESP sludge analysis Removal

As from EPA Audit 1st May 2008 & SmartPly letter dated

27/06/08 in relation to Schedule C.4 Monitoring.

Removal of WESP sludge from list of analyses as the WESP &

Nijhuis sludge are the same material except the Nijhuis

sludge is dewatered.

C.6.2 Ambient

formaldehyde monitoring

Monitoring frequency

reduced to bi-annual

Agency Ref P0001-02 /ap03pmd.doc. Issued on

26/11/2008

Monitoring of ambient formaldehyde reduced to bi-

annual

On the 16th of May 2011, a Technical Amendment was issued to resolve incidents of volumetric flow non-compliances which were occurring in the main stack. The non-compliances were occurring due to natural drafts being drawn from the base of the stack following the stack extension in 2005. Emission limit values for volumetric flow in relation to a number of baghouse filters were also re-adjusted. At the request of the Agency, SmartPly submitted an application for review of Licence P0001-02 in January 2012. The review related to the EC Environmental Objectives (Surface Waters) Regulations 2009. Licence P0001-03 was subsequently issued on 7th March 2013. This licence was amended on the 19th December 2013 under Section 82A (11) of the Environmental Protection Agency Act 1992, as amended. The amendment brought the licence into accord with the Industrial Emissions Directive. A Technical Amendment to Licence P0001-03 was issued on 24th March 2014. The amendment increased the volumetric flow from A2-1, adjusted the volumetric flows from a number of baghouses and also relocated the licenced position of one baghouse (A2-7).

D-6

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Existing process

equipment

Smart Ply

È

Smartply Europe

Ph +353 51 851233

Fax +353 51 851130

Waterford, Ireland

Drawing 1

Page 19: ATTACHMENT NO C& Paper Industries (SAPPI) as Mill Manager of the Usutu Pulp Company in Swaziland and with Courtaulds Fibers as Factory Systems Manager at their viscose rayon plant

Proposed process

equipment

Existing process

equipment

Smart Ply

È

Smartply Europe

Ph +353 51 851233

Fax +353 51 851130

Waterford, Ireland

Drawing 2


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