annual environmental report 2008 · 2014. 12. 16. · annual environmental report january –...

Annual Environmental Report

January – December 2008

IPC License Reg. No. P0106-01 of 29

Annual Environmental Report 2008

Pauwels Trafo Irl Ltd.

IPC License Register No. P0106-01




Contents 1.0 Introduction 1.1 IPC License Details 2.0 Site Description 2.1 Local Environmental Conditions 2.2 Main Units, Main Products 2.3 Organisation Chart for Environmental Management 2.4 Environmental Policy 2.5 Economic Contribution and Employment 3.0 Summary Information 3.1 Self Monitoring Data

3.1.1 Emissions to Sewer 3.1.2 Emissions to Surface Water 3.1.3 Emissions to Atmosphere 3.1.4 Waste Management 3.1.5 Noise

3.2 Agency Monitoring and Enforcement 3.3 Energy and Water Consumption 3.4 Environmental Incidents and Complaints

3.4.1 Environmental Incidents 3.4.2 Environmental Complaints

4.0 Management of the Activity 4.1 Environmental Objectives and Targets 4.2 Environmental Management Program Report 2008/2009 4.3 Environmental Management Program Proposal 2009/2010 4.4 European Pollutant Release and Transfer Release 5.0 License-Specific Reports 5.1 Bunding 6.0 Further Reporting 6.1 New Products/New Processes




Table 1 Summary Table for Emissions to Sewer (SE-1) Table 2 Summary of Non-compliances for Emissions to Sewer Table 3 Surface Water Discharges (SW) Average Emissions – Comparison of 2007

and 2008 Table 4 Summary of Non-compliances for Emissions to Surface Water Table 5 Summary Table for Emissions to Atmosphere – Comparison of 2007 and 2008 Table 6 National Waste Database Report Table 7 Energy and Water Consumption 2001 to 2008 Table 8 Environmental Incidents – Historical Data – Comparison of 2007 and 2008 Table 9 List of Environmental Incidents 2008 Table 10 Environmental Complaints – Historical Data – Comparison of 2007 and 2008 Appendix 1 Quality, Environmental Health & Safety Policy (QEH&S Policy) Appendix 2 AER Summary Report – P0106_2008(1) Appendix 3 Bund Integrity Results




1.0 Introduction

1.1 IPC License Details Pauwels Trafo Irl Ltd. (Dublin Rd, Cavan) were granted an IPC License by the Environmental Protection Agency in May 1997, (Reg. No. 106) under Class 12.2 of the First Schedule to the EPA Act, 1992: The use of coating materials with the capacity to use at least 10 tonnes of organic solvents per year. Condition 2.9.2 of the License requires the company to submit to the Agency an Annual Environmental Report within 18 months of date of grant of license and each year thereafter. This document presents the ninth report. During 2007 PTI made an application to the Agency for Integrated Pollution prevention and Control License (IPPCL, Registration number P0106-02), The review of this application continued during 2008.Under the direction of a representative from the Agency (Namely Stuart Huskisson) we have been informed we now come under Class 3.9 (Boiler making and the manufacture of reservoirs, tanks and other sheet metal containers where the production area exceeds 500 square metres). The manufacture of tanks is not a new operation within the company, however due to the decommissioning of the ‘Wet’ paint process, Pauwels Trafo Irl Ltd. have fallen out of the original class 12.2, since we no longer use a solvent based system. On the 10th day of December 2008 a draft license was issued to PTI (P0106-02) for review. The parameters of this license was accepted by PTI on 15th January 2009. Integrated Pollution Prevention and Control License (P0106-02) is now in effect in PTI from this date.




2.0 Site Description

2.1 Local Environmental Conditions Pauwels Trafo Irl Ltd is located approx. 2 miles east of Cavan town. The company does not come under the Seveso Regulations, since the quantities of dangerous substances stored at the site do not exceed the prescribed limits in the relevant regulations.

2.2 Main Units, Main Products

Pauwels Trafo Irl Ltd. is a wholly owned subsidiary of Crompton Greaves– an industrial conglomerate based in India. Pauwels Trafo Ireland operates a manufacturing facility to produce single phase and three phase distribution transformers and accessories to customer specifications.

The production of a transformer involves 3 main stages:

� Production of active part � Production of tank and tank painting � Final Assembly

The facility operates 7 days per week. There are a number of shift patterns in operation depending on the process, mainly 8hr shifts, 5 days per week, with a large number working days only. Overtime hours are worked depending on customer demand. The most environmentally significant issue associated with the operation is the painting of the tank, which involves Zinc Phosphating, Electro-coating and finally Powder coating.

2.3 Organisational Chart for Environmental Management

Managing DirectorJames McMahon

QEH&S Manager (Quality, Environmental, Health & Safety Manager)

Angus Fee

Quality EngineerSarah Connolly




2.0 Site Description contd/

2.4 Environmental Policy In 1999 the company developed a Quality and Environmental Manual. During 2000 the company became registered to BS EN ISO14001: 1996 and has achieved continued compliance. In 2005 the company was accredited to the updated Environmental standard BS EN ISO 14001:2004.

During 2008 the company structure was reviewed, Health & Safety was amalgamated with the Quality & Environmental department. The purpose of this was to attain accreditation to the Health & Safety standard and thus integrated all three ‘ISO’ standards. In December 2008 Pauwels Trafo Ireland was indeed accredited with the Health & Safety standard (OHSAS 18001:2007) – thus we now have an integrated Quality, Environmental, Health & Safety policy. The policy is displayed at various locations in the factory. It is also available to the public - a copy is attached in Appendix 1.

2.5 Economic Contribution and Employment

The company employs approx 400 personnel. The facility operates 7 days per week. There are a number of shift patterns in operation depending on the process, mainly 8hr shifts, 5 days per week, with a large number working days only. Overtime hours are worked depending on customer demand.




3.0 Summary Information

3.1 Self-Monitoring Data Below is a summary of emissions data for 2008. The main emissions from Pauwels Trafo are from emissions to:

� Sewer, � Surface water and � Atmosphere.

Noise monitoring has also been part of the IPC License requirement however it has been recognized by the Agency that Pauwels are not a major contributor to noise levels and the monitoring requirement has been waivered.

3.1.1 Emissions to Sewer

A summary of the Emissions to Sewer is presented in Table 1 below. Weekly monitoring of Emissions to Sewer is required and quarterly reports were submitted to the Agency as required.

There were a number of non-compliances in the Emissions to Sewer mainly with concentrations of Suspended solids and Total Heavy Metals above IPC License limits. Causes:

� Due to ‘spill’ from E-coat bath, some residue travelled into Final Discharge pipework. The spill occurred on 24th December 2007, all emissions were closed-off for the Christmas holidays hence all material was contained within our facility, there were no emissions to sewer.

Preventative Action:

� We employed the services of an External company to ‘wash-out’ the Final discharge and Balance tank, this was completed on 31st March 2008. We were still experiencing sporadic non-compliances, the external contractor informed us this may happen due to this cleaning process. The ‘E-coat’ materials that had coagulated in the tanks and pipework, and had been broken up using a power washer thus not all residues from the cleaning process were removed in its entirety. A decision by Management during quarter #3 to install a new Final Discharge tank appears to have eliminated the problem – we have not experienced any non-compliance since September 2008.




TABLE 1: Summary Table for Emissions to Sewer (SE-1)

PARAMETER Mass Emissions (kg) 2007

Mass Emissions (kg) 2008

Licensed Mass Emissions (kg)

Volume (m³) 8174.84 6207.502 26280

Sulphate 254.14 176.03 5256

Total Phosphorus 15.14 4.70 131.4

Manganese 0.60 0.486193 78.84

Nickel 0.60 0.29 13.14

Zinc 1.39 1.29 32.85

Total Heavy Metals 5.77 5.37 45.99

OFG 31.78 21.89 657

S Solids 254.50 208.21 1314

(Method of Calculation: Volume Emission Limit Value = Limit m3/day x 365days Mass Emission Limit value = Daily limit kg/m3 x Annual volume emission limit value Total Mass Emission Value = Sum of (Conc kg/m3 of weekly sample x Volume discharged weekly m3)

The summary of non-compliances for 2008 is below. All were notified to the Agency at the time of occurrence. The actual mass emissions for 2008 are much lower than the Mass Emission limit. TABLE 2: Summary of Non-compliances for Emissions to Sewer

Non-compliance No. of Non-compliances

Cause Corrective Action/Preventative Action

Suspended Solids 10 Due to a ‘spill’ from E-coat bath, some residue travelled into Final Discharge pipework

Installation of a new Final Discharge tank.

Total Heavy Metals 2 As above As above




Trend Analysis

0.0

20.0

40.0

60.0

80.0

100.0

% C

ompl

ianc

e

1

% Compliance Emissions to Sewer SE-1 (2007 v's 2008)

2007 2008

0

10000

20000

30000

2008

Comparison of Volume Discharged per Annum v's IPCL Limit (m3)(Based on Daily discharge volume 72m3)

EPA Limit 2007 2008




0

1000

2000

3000

4000

5000

6000

Sulphate

Annual Mass Emission (kgs) Sulphate Emissions to Sewer SE-1

EPA Limit

2007

2008

0

20

40

60

80

100

120

140

Total Phosphorus

Annual Mass Emissions (kgs) Total Phosphorus Emission to Sewer SE-1

EPA Limit

2007

2008




0

10

20

30

40

50

60

70

80

Manganese

Annual Mass Emission (kgs) Manganese Emissions to Sewer SE-1

EPA Limit

2007

2008

0

2

4

6

8

10

12

14

Nickel

Annual Mass Emission (kgs) Nickel Emissions to Sewer SE-1

EPA Limit

2007

2008




0

5

10

15

20

25

30

35

Zinc

Annual Mass Emissions (kgs) Zinc Emissions to Sewer SE-1

EPA Limit

2007

2008

0

10

20

30

40

50

Total Heavy Metals

Annual Mass Emissions (kgs) Total Heavy Metals Emissions to Sewer SE-1

EPA Limit

2007

2008




0

100

200

300

400

500

600

700

OFG

Annual Mass Emissions (kgs) Oils, Fats & Greases Emissions to Sewer SE-1

EPA Limit

2007

2008

0

200

400

600

800

1000

1200

1400

S Solids

Annual Mass Emissions (kgs) Suspended Solids Emissions to Sewer SE-1

EPA Limit

2007

2008




3.1.2 Emissions to Surface Water There are 10 Surface water emission points. SW-1 and SW-2 require a daily visual inspection and monthly analysis for pH, COD and Oils, Fats, Greases. The other 8 require a weekly visual and quarterly analysis for COD and Oils, Fats, Greases. Limits for COD and Oils, Fats & Greases were set in April 1999, after a proposal by Pauwels was accepted by the Agency. The company, as part of its commitment to ensuring no contamination of surface water, also analyse upriver and downriver samples. This is not an IPCL requirement. TABLE 3: Surface Water Discharges (SW) Average Emissions –

Comparison of 2007 and 2008

COD

(Action Limit 110ppm) Oils, Fats, Greases

(Action Limit 15ppm) 2007 2008 2007 2008 SW-1 16.46 13.92 0.70 1.00 SW-2 28.0 79.0 0.20 1.00 SWCP-1 13.00 9.25 0.20 1.00 SWCP-2 26.00 18.14 0.60 1.00 SWCP-3 No flow No flow No flow No flow SWCP-4 No flow No flow No flow No flow SWCP-5 36.00 13.40 0.20 1.00 SWR-1 23.00 39.43 0.60 1.00 SWG-1 No Flow No Flow No flow No flow SWG-2 39.00 29.00 0.20 1.00 Upriver 24.23 21.83 0.70 1.00 Down River 20.54 18.92 0.75 1.00

TABLE 4: Summary of Non-compliances for Emissions to Surface Water

Non-compliance No. of Non-compliances

Cause Corrective Action/Preventative Action

COD (16th Jan ’08) 1 Unknown

Unknown. PTI were informed by External laboratory on 22nd January 2008 that COD analysis was out-of-specification. The internal analysis performed for that day (16th January 2008) was visually ‘Clear, odourless and there was no presence of oil’. A second sample was taken immediately and forwarded for analysis, the results obtained was 22mg/L – the Action limit is 110mg/L. All further samples were within specification during 2008.




3.1.3 Emissions to Atmosphere The emission points and monitoring specified are as follows: Reference Point Reference Name Monitoring Requirement

A4a Old Shot- Blast Annual A4b New Shot-Blast Annual A15 Final Assembly Stray Booth Annual A26 E-Coat Cure Oven Annual A27 Powder Coat Cure Oven Annual A28 Burn-Off Oven Annual A29 New Drying Oven Not required under IPCL P0106-01

There was full compliance in 2008. The mass emission rates are outlined in Table 4 below. The method for arriving at the figures is explained as follows:

Annual Mass emission (kg) = Average kg/hr x operational hours

TABLE 5: Summary Table for Emissions to Atmosphere – Comparison of 2007 and 2008

Emission Point Parameter Mass Emissions

(kgs) 2007 Mass Emissions

(kgs) 2008 IPCL Limits (kgs) 2008

A4A Old Shotblast Particulates 32.22 3.90 219

A4B New Shotblast Particulates 29.96 3.90 219

A15 Final Ass'y Total Organics as C Not monitored No longer in

service 26,280

A26 E-coat oven Total Organics as C 11.851 5.71 26,280

A27 Powder oven Total Organics as C 8.433 5.298 26,280

A28 Burn-off oven Total Organics as C 0.164 0.251 1261.44

Hydrogen Chloride 0.4212 0.654 1261.44

Total Heavy Metals 0.004 0.007 1261.44 A29 New Drying Oven CO 4,263 1,354 Not specified

NO as NO2 17.60 87.98

Not specified

SO2 4.06 10.83

Not specified

O2 18.2% 16.4%

Not specified

CO2 1.60% 3.3%

Not specified




Trend Analysis

0

5000

10000

15000

20000

25000

30000

kgs

A26 A27 A15 A28

Annual Mass Emissions (kgs) to AtmosphereTotal Organic Carbon

AER limit

2007

2008

0

5

10

15

20

25

30

35

kgs

A28

Annual Mass Emissions (kgs) to Atmosphere Total Heavy Metals

AER limit

2007

2008




0

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100

150

200

250

kgs

A4A A4B

Annual Mass Emissions (kgs) to AtmosphereParticulates

AER limit

2007

2008

0

200

400

600

800

1000

1200

1400

1600

1800

2000

kgs

A28

Annual Mass Emissions (kgs) to Atmosphere Hydrogen Chloride

AER limit

2007

2008




3.1.4 Waste Management The data below represents the waste disposed/recovered from our site during 2008. Appendix 2 details summary information of Waste arising from PTI.

TABLE 6: National Waste Database Data Report

Industrial Sector NACE Code 2561 Reporting Period January – December 2008 Number of Employees (for reporting period) 400 Total tonnage of Waste Produced 1, 664.35 Ton Hazardous 125.96 Ton Non-Hazardous 1, 538.39 Ton Total tonnage of Waste Recovered 1, 427.90 Ton Hazardous 65.87 Ton Non-Hazardous 1, 362.03 Ton

3.1.5 Noise

The IPC License (P0106-01) requires and annual noise survey at three locations, however in 1999 we received notification from the Agency that the Noise survey requirement would be removed from our License (reference M106/AP/12 – 30th April 1999 Excerpt from the letter states: ‘I am to advise you that under Condition 10.4 of IPC License, that the requirement for an annual noise survey of the site operations has been removed. However, the Agency reserves the right to require noise monitoring on site at any time in the future’. Nevertheless the Agency reserves the right to require monitoring at any time in the future. There were no noise complaints in 2008.




3.2 Agency Monitoring and Enforcement

3.2.1 Introduction This section deals with Agency Monitoring and inspections v’s Licence requirements Sewer Emissions: Two Sewer samples were tested by the Agency during 2008, there were no significant differences between the results obtained with our External Testing Company and that of the Agency. Air Emissions: Air emission monitoring was not performed by the Agency during 2008. Site Visits: Mr.Kieran Fahy visited PTI 22nd August 2008 to perform a site inspection. One non-compliance and two observations were reported, all issues were addressed. 3.3 Energy and Water Consumption Energy usage is considered fewer than three sources at Pauwels:

� Heating oil, � Propane gas and � Electricity.

Municipal water is used for domestic and industrial purposes (cooling water for machines and for chemical baths in the new paint line). Resource consumption is monitored continuously as part of our environmental management system. In previous years the company examined resource usage in a number of different ways however, there has been a management decision that turnover should be the constant used for comparison purposes. For the purposes of IPC License reporting (as per AER guidance note) the usage/kg raw material usage is reported to the Agency.




TABLE 7: Energy and Water Consumption 2003 to 2008

Year Water m³ ..

Electricity KWhr# Gas m³~ Diesel (Litres) ^^

Trafo Oil (Litres) ^^

2004 7762 4571782 321532 14609 2527672 2005 6027 4873827 323429 10116 2770871 2006 3888 5142081 339354 10717 3574721 2007 7699 5545636 372504 20636 3177339 2008 9672 5728251 371883 14609 3394801

.. Based on water readings from County council. # Electricity usage is based on bills received from ESB. ~ Gas figures from meters installed as part of Resource reduction project.

^^ Calculations based on quantities purchased Trend Analysis

Resource usage per Raw material (T)

0

100

200

300

400

500

600

700

800

2001 2002 2003 2004 2005 2006 2007 2008

Wat er

Elec t r ic it y

Gas

Hea t Oil

Tra fo Oil




3.4 Environmental Incidents and Complaints

3.4.1 Environmental Incidents

TABLE 8: Historical Data 2007 2008 Total No. Incidents/Spills

7 2

Incident Reports – notified to authorities

0 0

Spill Reports/Incidents – dealt with In-house

7 2

TABLE 9: List of Environmental Incidents 2008 DATE REF No Incident Details Corrective / Preventative Action Reported To Status

19th Mar ‘08 Spill No. 018 Transformer Leaking - Broken Bushing Spill was contained, transformer was

placed onto a spill tray, removed to the Repair area and repaired.

In-house only CLOSED

25th Apr ‘08 Spill No. 019 Oil leak from cut-off valve – valve not properly closed

Spill was contained within the vicinity. The Power washer was removed and supply pipework isolated.

In-house only CLOSED




3.4.2 Environmental Complaints

There were no environmental complaints received in 2008.

Table 10: Historical Data

2007 2008 0 0




4.0 Management of the Activity

4.1 Environmental Objectives and Targets

During 1999 and 2000 a lot of work was carried out in preparation for ISO14001 Environmental Management System. A general review was carried out at the end of 1998 and from this an Aspects register was formulated. After identifying the most significant environmental aspects the company decided on Objectives and Targets. This register is updated annually and new Objectives and Targets set accordingly at the Annual Review. The Annual Review will take place during April 2009 (as our year runs from April to March). The Aspects Register will be forwarded after our Annual Management Review Meeting.

4.2 Environmental Management Program Report 2008/2009

In 2004 the company reviewed its approach to the system of running projects. It was decided that projects would be set up annually and then dealt with through separate Project Review Meetings. Each project was assigned an individual number and a leader was appointed. A standard Project review sheet was formulated and all leaders were expected to use this for the duration of the project. Environmental Objectives and Targets became part of this ‘Project system’ – i.e. part of the overall business plan and management approach. The following is a list of the ‘projects’ worked on and a summary of the progress achieved.

1 Integrated Pollution Prevention & Control License Application 2 Review S.I. No. 798 of 2007 Waste Management (packaging) regulations

2007 3 Installation of a new Final Discharge tank 4 Accreditation to OHSAS 18001 5 Quality, Environmental & Safety Electronic Management System 6 REACH review & compliance 7 Bunding testing matrix 8 Energy Audit 9 Alternative to Diesel at Leak Test System 10 Others – waste minimisation




4.2 Environmental Management Program Report 2008/2009 continued:

1. Integrated Pollution Prevention & Control License Application History: This project began in April 2007 with a visit from Stuart Huskisson (Agency representative), he presented guidelines in order to make an application to the Agency for a new IPPC license. During Mr. Huskisson’s visit we were informed we now come under Class 3.9 (Boilermaking and the manufacture of reservoirs, tanks and other sheet metal containers where the production area exceeds 500 square metres). The manufacture of tanks is not a new operation within the company, however due to the decommissioning of the ‘Wet’ paint process, Pauwels Trafo Irl Ltd. have fallen out of the original class 12.2, since we no longer use a solvent based system. Update: A draft IPPC license was issued by the Agency in December 2008. This was reviewed and accepted by Pauwels Trafo Irl in January 2009. There are a number of requirements stipulated in IPPCL P0106-02. All requirements will be addressed as separate projects during 2009.

2. Compliance with S.I. No. 798 of 2007 Waste Management (packaging) regulations 2007

PTI employed the services of an External Consultancy Company to review the legislation. They have recently reported how PTI must comply with these requirements. We are currently reviewing the quantity of packaging (pallets) placed onto the Irish Market (Jan – Dec 2008), this will be completed during April 2009.Hence this project will continue during 2009.

3. Installation of a new Final Discharge tank PTI experienced numerous out-of-specification results for Suspended solids during 2008. Management decided to install a new Steel tank to eliminate this problem. A 46, 500Litre stainless Steel tank was installed during November – This project is now closed.

4. Accreditation to OHSAS 18001 In order to promote continuous improvement within the facility, PTI decided to implement the Health & Safety Standard (OHSAS 18001) during 2008. We felt this accreditation would not only tighten our Safety standards within the workplace but also give us a competitive edge. PTI were already certified to the Quality & Environmental Management Systems (ISO 9001 & ISO 14001). PTI are the only company within the Crompton greaves group accredited to all three standards – This project is now closed.

5. Quality, Environmental & Safety Electronic Management System A number of various packages were reviewed during 2008. We visited many organisations and reviewed the packages in-use within their facilities. PTI have decided to implement an Electronic Integrated Management System namely Q-Pulse. Implementation will begin during March 2009 – this project will continue during the coming year.





6. REACH review & compliance Representatives from PTI attended an information session regarding REACH legislation. PTI were advised that we are considered a down-stream user therefore we do not need to register with the European Chemicals Agency (ECHA). Our suppliers are keeping us informed of their progress, they have pre-registered as required. It is our intention to review all materials used in PTI to evaluate both our and the suppliers compliance during 2009 - this project will continue during the coming year.

7. Bunding testing matrix According to our IPC license (P0106-01) ‘Condition 9.3.1 of our license the company is required to test all bunds at least once every three years’; this was historically performed on the following bunds

• Oil Storage bund • Final discharge bund

During a visit of our former inspector (Ms. Anne Pearson) she stated all bunded pallets must also be tested. Ms.Pearson advised the use of the IPPC guidance note on ‘Storage and Transfer of Material for Scheduled Activities’ on how this could be achieved. PTI have agreed the information that will form basis of our system: -Number of bunds – individual numbering system -Location -Liquids stored on each -Date tested -Findings including problems encountered

8. Energy Audit During the IPPCL application process, PTI were advised by the Environmental Consultancy Company (aiding us with our application) not to perform an Energy Audit until the new license was issued. This is a new requirement under Condition 7: Resource use and Energy Efficiency, this audit will be performed within one year of the date of grant of this licence - this project will be addressed under the IPPCL requirements.





9. Alternative to Diesel at Leak Test System History: The company had issues with Suspended Solids in 2005 and determined that the presence of diesel was causing globules of fat which were lining our pipework and coming out as suspended solids. By removing diesel this issue would be solved and Oils, Fats, Greases would be removed from the system. After initial discussions it was decided to try out a dilute solution of a corrosion inhibitor sprayed into the tank under pressure. The solution did pass through the pinhole leaks however it was difficult for the operator to see and identify the leak. A search was then carried out to find a suitable dye which could be used. Fluorescein dye was recommended however H&S had some reservations about using this. It was also suggested that a dye requiring the use of a UV lamp for detection could be tried. However our H&S department did not let this go ahead as the strength of the lamp required would be harmful to the health of employees. This was all explained to the Agency inspector during her visits in 2006, a status report was also discussed during her visit in February 2007. Update: As explained previously our proposal was rejected by the H&S department. Other tank manufactures were contacted regarding their procedure for performing leak testing, one company used fluorescent dye however the remaining uses Diesel. With the implementation of the following controls:

1. Installation of a new Final Discharge tank 2. Increase in the Time-period from leak testing to painting, minimum four

hours. Management decided to continue using Diesel – this project is now considered closed.

10. Other Information In addition to the specific projects identified above the company continuously monitors its waste from production areas and sets new targets every year. These are reported monthly and reviewed at monthly QEH&S meetings by the Management review board. This has become a procedural part of our Environmental Management System.




4.3 Environmental Management Program Proposal 2009 - 2010 As part of the ISO14001 Environmental Management System, company’s management carries out an Annual Review. One of the items on the agenda is a review of the Aspects Register and the Objectives and Targets. Due to company changes the internal Annual Management Report now runs from April to March. It will be compiled by the QEH&S Department and the Annual Management Review meeting will take place at end April. The Aspects register will be presented at this meeting. However as the Agency requires calendar year reporting, the following Environmental projects have already been decided:

1 Implementation of the requirements as stipulated in IPPCL P0106-02 including

Energy Audit 2 Quality, Environmental & Safety Electronic Management System 3 REACH review & compliance 4 Bunding testing matrix

4.4 European Pollutant Release and Transfer Register This legislation (i.e. S.I. No. 123 of 2007) concerning the establishment of a European Pollutant Release and Transfer Register came into place during 2007. This requires all license holders to accumulate data based on annual emissions and waste transfers and report through a standardized web-facilitated report system as part of the Annual Environmental Report. Electronic information was previously forward and a hardcopy is attached to this report – reference Appendix 3.




5.0 License-Specific Reports

5.1 Bunding As required under our IPC license (P0106-01) ‘Condition 9.3.1 of our license the company is required to test all bunds at least once every three years’; this was performed during 2008 on the following bunds

• Oil Storage bund • Final discharge bund

This test was performed during July and August 2008, however the contractor did not forward the completed reports until January 2009. A copy of the findings were forwarded to the Agency on 6th February 2009. Note: A copy of the Certificates is available in Appendix 4




6.0 Further Reporting

6.1 New Products/New Processes As part of the Environmental Management System at Pauwels we have implemented procedures to control the introduction of new products/new processes. These procedures ensure approval from H&S, Environment and Quality departments prior to the implementation of the change. During 2008 the following new products/processes were implemented:

� Waste Disposal Companies – -Rilta Limited t/a Sita Environmental (Waste License W0192-01) -Leinster Environmentals (Waste Permit No: WP 2008/09) -Cyclone Shredding (Waste Permit No: CPD487/4A)

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