ChF AUTOMOTIVE LTD T/A IRALCOO COLLINSTOWN, TELEPHONE +353 44 . ' . e ' * : Ms Grainne Oglesby, Office of Environmental Sustainability, PO Box 3000 L, Environmental Protection Agency (EPA) . I. Johnstdwn Castle Estate *-CO Wexford 19.07.2017 RE: C&F Automotive Ltd T/A Iralco Industrial Emissions Activities Licence Application ref PO690-03 Dear Ms Oglesby, I refer to the letter dated 03.07.2016 from Ms Jennifer Cope regarding further information requests. To address the contents of this letter, please find below our responses addressing each separate item raised; I. EPA reqiiest; Pleuse idcntih the eniission points to uir thut are ussociuted with: 0 Activity 3 - Couting Activitv (u) (i) uncl Activip I I - Siwjuce Cleuning C&F response: The emission points to air associated with Activitv 3 ~ Coating Activity (u)(i)urc us f0llo1.t:~; A2-1, A2-2, A2-3, A2-4, A2-5, A2-6, A2-7, A2-8, A2-9, A2-10, A2-11, A2-12, A2-25 and A2-3 1 The emission points to air associated with Activity I I - Sitrfiicc Clccining ure us, jdlmx; There are none. This activity is minimal by virtue of solvent (IPA) being used to clean down parts during inspection on occasion. The expected solvent usage here is less than OStonnes per year and thus part 2 does not apply. DIRECTORS J.FLAHERM P.PRENDERGAST REGISTERED OFFICE: BARBAVILLA, COLLl NSTOWN, CO.WESTMEATH REGISTERED IN DUBLIN IRELAND NO 460316 VAT REG NO. lE96898706 IBAN IE87 BOFl9016 8595 3834 96 BIC BOFllEZD For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 04-08-2017:03:04:07
Transcript
C h F AUTOMOTIVE LTD T / A IRALCOO
COLLINSTOWN,
TELEPHONE +353 44
. '.e ' *: Ms Grainne Oglesby,
Office of Environmental Sustainability,
PO Box 3000 L, Environmental Protection Agency (EPA)
The emission points to air associated with Activity I I - Sitrfiicc Clccining ure us, j d l m x ;
There are none. This activity is minimal by virtue of solvent (IPA) being used to clean down parts during inspection on occasion. The expected solvent usage here is less than OStonnes per year and thus part 2 does not apply.
2. EPA 1-eyziest; Please confirtn the upplicuhle activities, carried out ut the instullrtion refirred to in Chapter 5, Annex VII Part 2, of the Indiistrial Eniission.s Dil-ectiiv (20 I 0/75/E U).
C&F Response:
The applicable activity under Chapter 5 , Annex VI1 Part 2 of the Directive (20 10/75/EU) is activity 6 ~ Vehicle Coating (< 15) and vehicle refinishing. We are specifically vehicle refinishing.
A revised non technical summary is also attached.
Hence, please find enclosed one signed original and one hard copy of the application together with two copies of all documentation on PDF format on CD-Roin disks.
Yours Sincerely,
Niall Nally Senior Environmental Officer, CgLF Automotive Ltd Cc Mr Andrew Elder, Operations Manager, C&F Automotive Ltd, Collinstown, CO Westmeath
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ATTACHMENT A NON TECHNICAL SUMMARY
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Attachment A Industrial Emissions Licence Application
C&F Automotive Ltd T/A Iralco is located in a rural setting surrounded by agricultural land. The site is located approximately 1.5 kin south of Collinstown Village and occupies approximately 1 1 hectares in total (although about half of this site is allocated to farmland and mature woodland) see Map A.l attached. The facility, which was established in 1964, manufactures decorative and functional trim for the automotive industry.
The land immediately north, south, east and west is agricultural fields (improved grassland type). In addition the nearest dwelling and associated goat farm is immediately west of the main offices and another dwelling is also located approximately 250m south-east from the main factory building. There are two separate bungalow type dwellings within the site curtilage but these are used on occasion as temporary living spaces for employees. There is some ribbon development dwellings further along the Country road north of the site in the direction of Collinstown village.
In summary there are three houses within a 650111 radius of the C&F site (see Map B2.1 included in Attachment B2 in the original application). This excludes two houses within the site boundary used on occasion by employees. In terms of land topography, the site is relatively low lying when compared to the main road to the site.
The site operates as a production facility specialising in decorative and functional trim products for the automotive sector. The final products include; aluminium and stainless steel exterior trim, sometimes with rubber attachments as supplied by customers. All exterior trim is surface coated either by anodizing, powder coating or wet painting. All products are exported with the majority to customers in the EU.
The hours of all operations are based on a three cycle 8 hours shift per cycle Monday to Friday inclusive. Hence the facility runs for 24hours for five days per week. The facility is routinely closed on Saturdays, Sundays and Bank Holidays with essential maintenance and/or cleaning work on Saturdays. During periods of increased business, the facility can also run for a full day on Saturdays which effectively means six normal working days per week.
Photo 1 below illustrates the existing site and immediate area (viewing from roadside entrance).
Page 1 o f 6 C&F Automotive Ltd T/A IralcoO.
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Attachment A Industrial Emissions Licence Application
t
Photo 2 below illustrates the existing site and immediate area (viewing from roadside east of the factory). Note the factory building in the background.
C&F Automotive Ltd T/A IralcoO. Page 2 of 6
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Attachment A Industrial Emissions Licence Application
The existing facility uses both aluminium and stainless steel raw materials in its product manufacture. The metal is accepted in sheet rolls typically less than ltonne weight and between lmm and 2mm thickness. The rolls are then subject to mechanical activities i.e. forming, cutting, shaping, bending, milling, cropping and sanding down. The metal surface is also surface treated by polishing (combination of robotic and manual by general operatives). The resultant parts are then either finished by anodising or coating (powder/paint). There is also a new process of solvent based dip coating for anodized parts.
There is a proposal in 2018 to install a sinall de-plating line at the facility for reworking of dip-coated parts and for deplating of sealed anodised aluminium parts. The deplating line will be located at the existing anodising section and will form an extension of the anodising line within the same existing building. All wastes and emissions associated with this small extension will be similar in nature to existing emissions and also will be accommodated by existing treatment infrastructure.
The majority of production activities are carried out inside the main factory building. Further detailed production activities information is included in Attachment D of the application.
The company has been in operation since 1964 at this location. As a result of their continued business success and in line with market sector demand for new innovative and robust products, C&F Automotive Ltd proposes to implement a new process within the present installation and as such will anticipate an increase in both their solvent usage and manufacturing output. The new process will be a designated solvent based dip coating line inside the existing installation building. This will result in the facility requiring an Industrial Emissions License under the following additional activity (as per First Schedule of the EPA Act 1992 to 201 3);
Schedule I , Class 12.2.2, Descr?ptioii; The niutiufircture 01” use of coating materials in processes with a capacity to mukc or use ut leust I O toiities per. yeur of ot.gariic solvents, and powder coating mantijacttire with a capacity to prod~ice at least 50 tome5 per year, not iiicltided in paragraph 12.2. I .
The company has full planning permissions for all structures, development and activities on- site and no environmental impact assessment was required for these planning permissions. This is confirmed in a letter from Westmeath County Council dated lst July 2015 and is included in Attachment B6 of this application.
The annual quantities of solvents and other substances used and stored on-site do not come under the EC (Control of Major Accident Hazards Involving Dangerous Substances) Regulations 2006.
C&F Automotive Ltd T/A IralcoO. Page 3 of 6
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Attachment A Industrial Emissions Licelice Application
The sources of emissions from the site summarised as follows:
Air emissions;
C
0
0
There are currently twenty six active individual point source emissions from the facility and two stacks that are presently inactive. There is a proposal to bring on- line one additional stack to service the new oven at the dip coating room, an existing stack will be converted to solvent extraction from the dip coating room which will use solvent based materials and also a new stack for a proposed small de-plating line. Therefore there will be thirty stacks overall (two of which will be inactive until further notice). All active stacks are used during normal working hours (some being used for 24hours to coincide with production). The emissions from the stacks are mostly volatile organic compounds, some total particulates and also two of stacks whereby small amounts of treated acid and/or alkali fumes are extracted. All significant stacks have treatment of the exhaust gasses by use of various methods e.g. cyclones, wet scrubbers and air filtration. The flow rates from the stacks are set for optimum extraction. All stacks are presently monitored quarterly for; volatile organics, flow rates, acid fumes (where applicable), ammonia (where applicable) and sodium hydroxides (where applicable) and annually for particulates. The emissions are all within present licence limits in 2015 but with some breaches on occasion for organics in 2016 and 2017. The future two new stacks are expected to be within limits due to their servicing of small areas. There are also minor emissions from five boiler stacks on-site (LPG) powered boilers at the facility which are used to heat the main factory building, ovens at the paint plant, anodizing line and the R&D office heating. The impact to air from these small units is minimal. Fugitive emissions from the facility occur at I ) where solvent (iso propyl alcohol [IPA]) is being used as a coolant in some of the milling and sawing machines inside the main factory building 2) fugitive emissions froin mixing thinners with paint and also cleaning out the internal paint delivery transfer lines at the Paint Plant weekly using a recycled solvent thinner supplied by a contractor, 3) IPA used to clean parts on occasion using wiping cloths and 4) transferring from containers, dispensing of solvent on the various product lines and general transferring to waste storage containers. The impact from fugitive emissions are minimal due to the fact that all present activities are in compliance with the licence requirements in terms of solvent usage.
0 Emissions to ground;
0 The emissions to ground from the facility comprises of a percolation area associated with an interceptor unit treating general car park storm water run-off
C&F Automotive Ltd T/A IralcoO. Page 4 of 6
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Attachment A Industrial Emissions Licence Application
and small yard areas associated with some warehouse buildings located in the northern portion of the site. There is a sampling point downstream of the interceptor unit prior to soak-away ref SWI and this is monitored weekly for parameters. The discharge point is not subject to licence emission limit values at present and is considered insignificant.
External Noise emissions;
o External noise from the operational stacks especially the cyclones and scrubber units facing east and south directions. A new air conditioning unit to service the new solvent based dip coating room is a new source of noise but is insignificant. These are outside point source noise emissions.
o External vehicular noise from deliveries of raw materials to the site and unloading using fork lift trucks. Similarly, noise from fork lift truck handling of finished product (pallets of packaged parts) and waste materials including skips to vehicles for export from the site.
o Metals forming, pressing, sanding and polishing noises are experienced at the factory but not experienced at nuisance levels beyond site boundaries due to these being internal operations inside buildings.
Baseline noise surveys were undertaken at the factory site in order to detennine the environmental impacts associated with typical operations.
Noise monitoring was conducted over a typical working day, evening and night at and around the facility with all usual activities including the use of the air extraction stack systems. The noise monitoring showed that existing noise emissions are not resulting in nuisance conditions from the facility.
Surface water catchment run-off from the back yard area and associated roof spaces is treated by a hydrocarbon interceptor and then discharged to a land drain at emission point SW2. Various physical and chemical parameters are tested weekly. Water test results shows that the treated discharge at SW2 is in routine compliance with the present licence limits apart from occasional total nitrogen and to a lesser extent total ammonia due to occasional seasonal changes.
The energy type used at the facility is electricity and LPG gas. Electricity is used to power the equipment and plant used during product manufacturing, lighting and administratiordoffice equipment. Two bulk LPG gas supply tanks on-site service the ovens at the paint-powder coating plant, various boilers and also for space heaters in the factory building. Energy consumption saving initiates have been undertaken within the facility in order to reduce electricity and gas usage. This includes, identifying equipment that can be
C&F Automotive Ltd T/A IralcoO. Page 5 of 6
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Attachment A Industrial Emissions Licence Application
turned off when not in use, air leaks repairs to reduce compressor energy use and also space heating reductions.
All fluorescent tubes used on a 24hr basis have now been replaced by LED counterparts and this has reduced electricity demand in 20 16 to 201 7. In summary, taking LPG and electricity into account, the energy consumption has been reduced by 8% at the facility compared to 20 15 usages. This has greatly reduced the company carbon footprint.
All wastes generated at the facility are sent off-site for disposal or recovery in accordance with the requirements of the Waste Management Act, as amended. The majority of waste sent off-site is termed hazardous waste (i.e. spent acids, acid rinses, alkalis, solvents and metal salt filtercakes) and also hazardous contaminated packaging (plastic, paper and metals). Waste management is controlled at the site by means of temporary storage in a large bunded waste stores at the rear of the site prior to weekly collection by fully authorized waste management companies. There is no waste acceptance, treatment or disposal occurring on- site.
As part of this application, management at the facility is committed to reduce the potential environmental liabilities as follows:
On-going environmental training for employees to prevent and minimize environmental pollution incidents e.g. spills, waste management, energy consumption management. Internal and external bunding for liquids storage
Further measures to control and minimize air emissions from the facility. Waste reduction processes.
The company holds a certified quality, environmental and energy management systems awards (i.e. ISO/TS 16949:2009, I S 0 I4001 :2O04, IS050001 :2011) and enforces these standards.
It is anticipated that the issuing of this new licence from the Agency will result in increased environmental controls for the company and C&F Automotive Ltd is committed to complying with these conditions whilst remaining as a successful product manufacturer in Collinstown, CO Westmeath.
C&F Automotive Ltd T/A IralcoO. Page 6 of 6
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$*q Map A. 1 General Site Location map for C&F Automotive Ltd T/A lralco' "$4 _ '
