c&f automotive ltd. · 2017-04-26 · smp 2015 c&f automotive ltd solvent management plan...
TRANSCRIPT
C&F AUTOMOTIVE LTD T/A IRALCO®
COLLINSTOWN, CO. WESTMEATH, REP. OF IRELAND
TELEPHONE +353 44 96 66600 FAX +353 44 96 66690
Document No: SMP016-C&F
Description:
Solvent Management Plan Report 2016
Revision No
Document purpose Originated Author Date
01 Compliance report C&F Niall Nally
Senior Environmental Officer
24/02/2017
SOLVENT MANAGEMENT PLAN REPORT 2016
FOR
C&F AUTOMOTIVE LTD. IEL licence no: P0690-02
FACILITY AT
COLLINSTOWN, MULLINGAR, CO WESTMEATH
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 26-04-2017:03:15:05
SMP 2015 C&F Automotive LTD
Solvent Management Plan 2016
Licence No: P0690-02
SMP015-C&F Page 2 of 15 Version 1
Report Content
1.0 Introduction ………………………………………………………. 3
2.0 Basis and Methodology ………………………………………………………. 6
3.0 Mass Balance and Article Findings …………………………………………. 8
3.1 Inputs and Losses ………………………………………………….. 8
3.2 Annex VII of the Directive …………………………………………..9
3.3 VOCs with Designated Risk Phrases ………………………………. 10
3.4 Halogenated VOCs …………………………………………………11
4.0 Conclusions ……………………………………… 14
Tables:
Table 1: Mass Balance Terminology ………………………………………………………… 7
Table 2: Summary of Mass Balance ……………………………………………………… 8
Table 3: Summary of Itemised Solvent Consumption …………………………………… 9
Table 4: Summary of Solvent Consumption …………………………………………… 10
Table 5: Balance of IPA Consumption……………………………………………………… 11
Table 6: Halogenated VOC with R phrase of R40……………………………………………. 13
Appendices:
Appendix I: Definitions in the Directive
Appendix II: Calculation of Solvent Input
Appendix III: Calculation of Solvent
Output
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 26-04-2017:03:15:05
SMP 2015 C&F Automotive LTD
Solvent Management Plan 2016
Licence No: P0690-02
SMP015-C&F Page 3 of 15 Version 1
1.1 Introduction
This Solvent Management Plan (SMP) is in response to Condition 5.4 of the
licence which states; ‘The total fugitive emissions to air of volatile organic compounds
shall not exceed 25% of total solvent input’.
In addition, Condition 6.17 states ‘The licensee shall maintain a solvent management
plan for the site. The substances to be included in the SMP shall be determined by
reference to the definition of a solvent in the Council Directive 2010/75/EU, and
shall be assessed by the Agency each year. The SMP shall be prepared in
accordance with any relevant guidelines in Annex III of the Directive or as issued
by the Agency and shall be submitted as part of the AER (Annual Environmental
Report).
The Solvent Management Plan was established in accordance with the Directive
2010/75/EU of the European Parliament and of the council of 24 November 2010
on Industrial Emissions.
The aim of the directive is to limit and control emission of volatile organic
compounds to atmosphere. This directive is incorporated into the IEL through
Conditions 5 & 6.
Schedule 1 of S.I. 565 of 2012 outlines two activities that come under the remit of
the directive, namely:
Vehicle Refinishing: Any industrial or commercial coating activity and
associated degreasing activities performing:
(a) the original coating of road vehicles as defined in Directive
2007/46/EC or part of them with refinishing-type materials, where this is
carried out away from the original manufacturing line;
(b) the coating of trailers (including semi-trailers) (category O in Directive
2007/46/EC).
Surface Cleaning: Any activity except dry cleaning using organic solvents
to remove contamination from the surface of material including
degreasing. A cleaning activity consisting of more than one step before or
after any other activity shall be considered as one surface cleaning
activity. This activity does not refer to the cleaning of equipment but the
cleaning of surface products.
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 26-04-2017:03:15:05
SMP 2015 C&F Automotive LTD
Solvent Management Plan 2016
Licence No: P0690-02
SMP015-C&F Page 4 of 15 Version 1
The IE licence stipulates under Condition 5.4 that the company shall not exceed a
25% threshold for fugitive emissions from site reflecting the requirements of S.I.
565 of 2012, Schedule 2.
In terms of risk substances at the facility, the following conditions apply;
Condition 5.5.1 ‘Substances or preparations which, because of their content of
VOCs classified as carcinogens, mutagens or toxic to reproduction under
Regulation (EC) No 1272/2008, are assigned or need to carry the hazard
statements H340, H350, H350i, H360D, H360F, (or the risk phrases R45, R46,
R49, R60 and R61) shall not be used in coating operations at the installation,
without the prior written agreement of the Agency.’
Condition 5.5.2 ‘Substances or preparations which contain halogenated VOCs
which are assigned the hazard statement H351 or Risk Phrase R40 where the usage
rate is such that the mass emission to atmosphere of the sum of the R40 compounds
would exceed 100g/h, shall not be used in coating operations at the installation,
without the prior written agreement of the Agency.’
Condition 5.5.3 ‘The licensee shall assess all new VOC containing substances and
preparations employed at the site, prior to use, for compliance with Conditions
5.5.1 and 5.5.2. All such assessments shall be reported annually as part of the AER.
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 26-04-2017:03:15:05
SMP 2015 C&F Automotive LTD
Solvent Management Plan 2016
Licence No: P0690-02
SMP015-C&F Page 5 of 15 Version 1
To assess the site for compliance with these criteria:
Raw Material SDS’s were assessed for inclusion of the hazard statements
H340, H350, H350i, H360D, H360F and/or risk phrases R45, R46, R49, R60
and R61. The only raw materials in use on site with a risk rating outlined
above include:
None used on site
Raw Material SDS’s were assessed for inclusion of H351 and/or R40. The
only raw materials in use on site with a risk rating outlined above include:
BASF Thinner R40 and H351. Constituents were
naphthalene (3 to 5%).
Fuller Primer Anthrazite R40 and H351. Constituents were
naphthalene (0.1 to 0.25%) and formaldehyde (0.1-<0.2%) make-up
of product.
Clearcoat stargloss R40 and H351. Constituents were
naphthalene (0.5 to 1%) and formaldehyde (0.1-<0.2%) make-up of
product.
Standard thinners R40 and H351. Constituents were
tetrahydrofuran (0.5 to 1%) make-up of product.
For the purpose of this plan, the EPA’s Best Practice Guidelines for Surface
Cleaning using Solvents was also used as a reference document for this SMP in
the absence of any specific guidelines for the Part II Activities Licensed.
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 26-04-2017:03:15:05
SMP 2015 C&F Automotive LTD
Solvent Management Plan 2016
Licence No: P0690-02
SMP015-C&F Page 6 of 15 Version 1
2.0 Basis and Methodology
The basis for an SMP is a mass balance, accounting for all inputs and outputs of
organic solvents, as defined in the Solvents Directive. A mass balance identifies
where solvent goes into a process, where it is consumed and where it comes out.
The mass balance approach used in this exercise is that outlined in European
Union (Installation and Activities using Organic Solvents) Regulations 2012,
S.I. 565 of 2012. Reference was also made to guidelines issued by the Agency for
Surface cleaning using solvents.
The following methodology was carried out to determine the quantity of solvents
used on site throughout the calendar year 2015 at the facility:
1. All substances containing VOCs were collated in spreadsheets,
2. MSDS were assessed to determine the concentration of VOC in each
substance,
3. Purchasing details were assessed for each substance,
4. Substances containing VOCs sent off site as hazardous waste were totaled,
5. Emissions to atmosphere were evaluated for the year,
6. A mass balance was carried out for each activity.
Figure 1: Pictorial Display of an SMP Balance
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 26-04-2017:03:15:05
SMP 2015 C&F Automotive LTD
Solvent Management Plan 2016
Licence No: P0690-02
SMP015-C&F Page 7 of 15 Version 1
Table 1: Mass Balance Terminology
Table 1: Mass Balance Terminology and Relevance to C&F Automotive
Inputs of Organic Solvent (I)
I1
The quantity of organic solvents, in a pure
state or in preparations purchased, which are
used as input into the process in the time
frame over which the mass balance is being
calculated.
For the purpose of this plan the mass balance will
be based on purchases during 2016.
I2
The quantity of organic solvents, in a pure
state or in preparations recovered and
reused, as solvent input into the process
Solvents are not reused or recovered on site.
Solvent waste is removed off site for
disposal/recovery and is therefore included in
waste records.
Outputs of Organic Solvent (O)
O1
Emissions in waste gases
Air emissions monitoring were carried out on all
emission points on a quarterly basis for flow and
TOC. This information will be used to estimate total
emissions to air during the year of 2016.
O2
Organic Solvents lost in water, if appropriate
taking into account wastewater treatment
when calculating O5
There are negligible VOCs that could be lost
through this route.
O3
The quantity of organic solvents which
remains as contamination or residue in
products output from the process.
Treated materials are dried in ovens on site at
elevated temperatures which would liberate any
volatile solvent from the products and thus lost as
emissions to air.
O4
Uncaptured emissions of organic solvents to
air. This includes the general ventilation of
rooms, where air is released to the outside
environment via windows, doors, vents and
similar openings.
This information will be estimated based on mass
balance. This is required to be carried out for
compliance with the Solvents Directive and
condition 5.4 of the IEL.
O5
Organic solvents lost due to chemical or
physical reactions including for example
those which are destroyed, e.g. by
incineration or other waste gas or waste
water treatments, or captured e.g. by
adsorption, as long as they are not counted
under O6, O7 or O8.
There was no data available outlining the pre and
post concentrations for organic compounds at the
treatment systems. It is therefore not known the
concentrations of solvent lost through the treatment
process.
O6
Organic solvents contained in collected
waste on-site, i.e. spent paint gun wash
consisting of thinners.
Spent thinners (paint gun wash) collected in
200litre metal drums on-site for off-site disposal
and/or recovery. Waste packaging and solvent
used rags and contain minimal waste solvent
product on disposal. These are weighed on receipt
by the waste management company. Paint sludge
in 200litre drums.
O7
Organic solvents or organic solvents
contained in preparations, which are sold or
are intended to be sold as a commercially
valuable product.
Not Applicable
O8
Organic solvents contained in preparations
recovered for reuse, but not as input into the
process, as long as not counted under O7.
Not Applicable
O9 Organic solvents released in other ways. Not Applicable
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 26-04-2017:03:15:05
SMP 2015 C&F Automotive LTD
Solvent Management Plan 2016
Licence No: P0690-02
SMP015-C&F Page 8 of 15 Version 1
3.1 Mass Balance and Article Compliance
3.2 Inputs and Losses
Table 2: Summary of Mass Balance
Reference Component Total Solvent Content
Kg / Year (TOC as C)
I1 Inputs 15,336
I2 Internal Recycle 0
I Total Input 15,336
O1 Organic Solvent in Waste Gases (Average 2016) 9,347
O2 Organic Solvent Lost in Water 0
O3 Organic Solvent retained on Product <1Note 1
O4 Fugitive Organic Solvent Emissions 2,494Not 2
O5 Wastewater Treatment or Reacted 0Note 3
O6 Collected Waste Solvent (TOC as C for 2016) 3,494Note 4
O7 Solvents Sold Off 0
O8 Recovered Solvent but not Reused 0
O9 Solvents Released in Other ways 0
O Total Output 12,841
U Organic Solvent Over Accounted For 0
Note 1 Products are dried in ovens which would liberate all solvents used.
Note 2 Fugitive Emissions (F) has been calculated from Input – measured outputs, i.e.
F = I1-O1-O5-O6-O7-O8 = 15,336 – 9,347-0-3,494-0-0= 2,494.20 or 16%
Note 3 The license does not require pre and post analysis; therefore there is no detail available on
solvent losses at the treatment systems.
Note 4
Waste disposed of has been converted to an average carbon equivalent based on the
ratios applied in solvent input calculations.
Note 5
The mass balance for this site was estimated for the following reasons:
There is a certain degree of uncertainty from air emissions monitoring as these are only spot
checks carried out four times per year as opposed to continuous analysers. The 4 results
were averaged for all stacks and multiplied by the operating house for an annual emission
value.
The concentrations and flow rates can vary between monitoring sessions, so this does lead
to a degree of inaccuracy when bringing 30 minute samples period up to annual 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 26-04-2017:03:15:05
SMP 2015 C&F Automotive LTD
Solvent Management Plan 2016
Licence No: P0690-02
SMP015-C&F Page 9 of 15 Version 1
3.3 Annex VII of the Directive
3.3.1 Vehicle Coating (<15) and Vehicle Refinishing
The first scope of activities determined on site was listed under “Vehicle
Refinishing” in Schedule I of the directive:
The original coating of road vehicles as defined in Directive 2007/46/EC, or
part of them, with refinishing type materials, where this is carried out away
from the original manufacturing line.
Table 3 outlines the substances containing VOCs used at C&F Automotive in
this activity.
Table 3: Summary of Itemised Solvent Consumption for coatings
Substance Total
TOC
as C
Consumption
Threshold
Solvent
Consumption
Emission
Limit Value
Fugitive
Emissions
Values
Tonnes / 2016
Tonnes /
Year
mgC/Nm3
% of
Solvent
Input
Standard Thinners 4.467
> 0.5
50
25
Thinner SV13-033 2.060
Brilliant Schwartz 1.074
Primer Antracite 0.828
Clear coat star gloss 1.278
Total Input 9.707
Notes:
1: Compliance with Article 17 should be demonstrated on 15 minute averaging periods.
Solvent consumption in this activity has a threshold of >0.5 tonnes per year as
indicated in Column 3 of Annex VII Part 2 of the Directive. Solvent consumed
in 2016, referenced as carbon, for this activity was determined above the
consumption threshold i.e. 9.707 tonnes and therefore does come under the remit
of the Directive and its associated Regulation S.I. 565 of 2012. The actual
fugitive % for 2016 data is [fugitive emissions 2,494 TOC divided by solvent
input as TOC 15,335.5 = 16%.
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 26-04-2017:03:15:05
SMP 2015 C&F Automotive LTD
Solvent Management Plan 2016
Licence No: P0690-02
SMP015-C&F Page 10 of 15 Version 1
3.3.2 Surface Cleaning
The second scope listed was “Surface Cleaning”, defined as following under the
Directive:
Any activity except dry cleaning using organic solvents to remove
contamination from the surface of material including degreasing. A cleaning
activity consisting of more than one step before or after any other activity shall
be considered as one surface cleaning activity. This activity does not refer to the
cleaning of equipment but the cleaning of surface products.
Table 4 outlines the substances containing VOCs used at C&F Automotive in this
activity.
Table 4: Summary of Solvent Consumption
Substance Total
VOC
Input
Threshold
Solvent
Consumption
Solvent
Consumption
Emission
Limit
Value
Tonnes / 2015 Tonnes /
Year
Tonnes /
Year mgC/Nm3
IPA Consumption
5% of Total IPA Input (9,120kg) to facility
0.456
>11
1 – 51
>51
202
202
Notes:
1: Using compounds specified in Article 5(6) and 5(8)
2: Limit refers to mass of compounds in mg/m3 and not to total carbon
This activity has a threshold of 1 tonne per year which was not exceeded at this
site during 2015. An assessment using compounds specified in Article 5(6) and
(8) was also carried out:
Isopropyl Alcohol is characterised with risk phrases R11 R36 R67, and
therefore does not come under the Risk Phrase specific terms of the Directive.
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 26-04-2017:03:15:05
SMP 2015 C&F Automotive LTD
Solvent Management Plan 2016
Licence No: P0690-02
SMP015-C&F Page 11 of 15 Version 1
3.3.3 Balance of IPA for 2016
The remaining IPA input on site is used for the purposes of machine coolant.
This activity is not covered under the remit of the regulations or the directive.
Table 5: Balance of IPA Consumption
Substance Total
VOC
Input
Threshold
Solvent
Consumption
Solvent
Consumption
Emission
Limit
Value
Tonnes / 2014 Tonnes /
Year
Tonnes /
Year mgC/Nm3
IPA Input Used as Coolant
95% of Total IPA Input to facility
8.664
None applied
N/a
N/a
Notes:
3.4 VOCs with designated Risk Phrases
The Directive deals specifically with risk phrases applied to substances
potentially used on site.
Condition 5.5.1 ‘Substances or preparations which, because of their content of
VOCs classified as carcinogens, mutagens or toxic to reproduction under
Regulation (EC) No 1272/2008, are assigned or need to carry the hazard
statements H340, H350, H350i, H360D, H360F, (or the risk phrases R45, R46,
R49, R60 and R61) shall not be used in coating operations at the installation,
without the prior written agreement of the Agency.’
A full review of solvents used on site in 2016 and their respective Material
Safety Data Sheets was carried out.
The were no solvents with the risk phrases mentioned above.
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 26-04-2017:03:15:05
SMP 2015 C&F Automotive LTD
Solvent Management Plan 2016
Licence No: P0690-02
SMP015-C&F Page 12 of 15 Version 1
3.5 Halogenated VOCs
The Solvent Regulations outlines specific requirements for halogenated organic
compounds with a risk phrase of R40.
Condition 5.5.2 ‘Substances or preparations which contain halogenated VOCs
which are assigned the hazard statement H351 or Risk Phrase R40 where the
usage rate is such that the mass emission to atmosphere of the sum of the R40
compounds would exceed 100g/h, shall not be used in coating operations at the
installation, without the prior written agreement of the Agency.’
The compounds used at C&F Automotive were assessed for composition as
classification with R40. The following compound and quantity was used on site
in 2016:
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 26-04-2017:03:15:05
SMP 2015 C&F Automotive LTD
Solvent Management Plan 2016
Licence No: P0690-02
SMP015-C&F Page 13 of 15 Version 1
Table 6: Halogenated VOCs with Risk Phrases of 40
Substance Volume
of
Product
kg
R40
Constituent
Average
VOC
Content
%
2016
Usage
Kg/yr
Estimated
Sum of
Daily
Usage
Directive
Threshold
Primer
Naphthalene
0.175
6.426
Anthracite 3,672
Formaldehyde 0.150 5.508
79.160 100
Thinner
2,605
Naphthalene
4
104.2
g/hour g/hour
Clearcoat
star gloss
3,240
Naphthalene
Formaldehyde
0.750
0.150
24.30
4.860
Standard
thinners
6,200
Tetrahydrofuran
0.50
13.025
The estimated daily usage is based on 2000 hours of operation per year (attained from air
emissions operating times in 2016).
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 26-04-2017:03:15:05
SMP 2015 C&F Automotive LTD
Solvent Management Plan 2016
Licence No: P0690-02
SMP015-C&F Page 14 of 15 Version 1
4.1 Conclusions
Two activities as per Schedule I of the Regulations (SI 565 of 2012) were
carried out at C&F Automotive, namely Surface cleaning and Vehicle
Coating (or parts thereof);
There were a total of 8 raw materials used on site that contributed solvent
into process activities;
The total input of solvent into the process in 2016 was 15,335.5 Kgs
(Referenced as Carbon);
The estimated air emissions of solvent was 9,347 Kgs (Referenced as
Carbon),
The calculated fugitive emissions from site were 2,494.1 kg, which is
approximately 16%. The licence limit for fugitive emissions for the site is
25%.
Most of the remaining solvent was disposed of as waste solvent 3,494.4 kg
(Referenced as Carbon);
Three raw materials; BASF thinner, Primer Anthracite, Clearcoat star
gloss and standard thinners contains Naphthalene and/or Formaldehyde,
tetrahydrofuran which have a Risk Phrase of R40. The sum of the volumes
of raw materials used were within the threshold outlined by condition 5.5.2
of the license insofar as the limit of 100g/hour was not exceeded.
Under the activity “surface cleaning”, the only product used was IPA. The
solvent content used in 2016 was well within the thresholds outlined in
Schedule 2 of SI 565 of 2012.
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 26-04-2017:03:15:05
SMP 2015 C&F Automotive LTD
Solvent Management Plan 2016
Licence No: P0690-02
SMP015-C&F Page 15 of 15 Version 1
Appendix I Definitions of the Directive
Organic Compound Organic Compound shall mean any compound containing at
least the element carbon and one or more of hydrogen,
halogens, oxygen, sulphur, phosphorous, silicon or nitrogen,
with the exception of carbon oxides and inorganic carbonates
and bi-carbonates.
Volatile
Organic
Compounds
VOC shall mean any organic compound having at 293.15 K a
vapour pressure of 0.01 kPa or more, or having a corresponding
volatility under the particular conditions of use. For the purpose
of this Directive, the fraction of creosote which exceeds this
value of vapour pressure at 293.15 K shall be considered as a
VOC.
Organic Solvent An organic solvent is a VOC which is used alone or in
combination with other agents, and without undergoing a
chemical change, to dissolve raw materials, products or waste
materials or is used as a cleaning agent to dissolve
contaminants, or as a dissolver, or as a dispersion medium or as
a viscosity adjuster, or as a surface tension adjuster, or as a
plasticizer, or as a preservative.
For in
spec
tion p
urpo
ses o
nly.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 26-04-2017:03:15:05
Appendix II - Solvent Input Calculations.
Substance Constituents CAS No. Molecul
ar Formula
Mean Compositi
on %
Molar Mass
Carbon Molar Mass
No. of atoms
No of Carbon atoms
Molar Mass of
Carbon in substance
Solvent Input 2016
kg
Solvent (TOC as C Input) kg 2016
Primer anthracite Xylene 1330-20-7 C8H10 7.500% 106 12 18 8 96 275.40 249.42
Butan-1-ol 71-36-3 C4H10O 6.000% 74 12 15 4 48 220.32 142.91
Epoxy resin 25036-25-3
C18H22O3 10.500% 286 12 43 18 216 385.56 291.19
Solvent naptha (Petroleum) heavy aromatic
64742-94-5 C9 1.375% - 12 - 9 108 50.49 41.31
Solvent naptha (Petroleum) light aromatic
64742-95-6 C9 1.375% - 12 - 9 108 50.49 41.31
Ethyl benzene 100-41-4 C8H10 1.500% 106 12 18 8 96 55.08 49.88
Napthalene 91-20-3 C10H8 0.175% 128 12 18 10 120 6.43 6.02
Naptha (petroleum) hydrosulferized heavy
64742-82-1 C6H14 0.125% 86 12 20 6 72 4.59 3.84
Formaldehyde 50-00-0 CH2O 0.150% 30 12 4 1 12 5.51 2.20
Total 1,053.86 828.10
Brillintschwarz N-butyl acetate 123-86-4 C6H12O2 22.500% 116 12 20 6 72 611.78 379.72
Xylene 1330-20-7 C8H10 16.250% 106 12 18 8 96 441.84 400.15
Butan-1-ol 71-36-3 C4H10O 6.000% 74 12 15 4 48 163.14 105.82
2-methoxy-1-methylethyl acetate 108-65-6
C6H12O3 3.000% 132 12 21 6 72 81.57 44.49
[3-(2,3-epoxypropoxy) propyl] trimethoxysilane, Naphtha (petroleum), hydrotreated light 2530-83-8
C9H20O5Si 3.750% 230 12 35 9 108 101.96 47.88
Ethyl benzene 100-41-4 C8H10 1.500% 106 12 18 8 96 40.79 36.94
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 26-04-2017:03:15:05
2-(2-butoxyethoxy) ethanol 112-34-5
C8H18O3 3.000% 162 12 29 8 96 81.57 48.34
Butyl glycollate 7397-62-8 C6H12O3 0.750% 132 12 21 6 72 20.39 11.12
Total 1,543.03 1,074.47
Isopropyl alcohol Isopropyl alcohol 67-63-0 C3H8O 100.000% 60 12 12 3 36 9,120.00 5472.00
Total 9,120.00 5,472.00
Thinner sv13-0333 Ethyl benzene 100-41-4 C8H10 3.500% 106 12 18 8 96 91.18 82.57
Xylene 1330-20-7 C8H10 22.500% 106 12 18 8 96 586.13 530.83
Mesitylene 108-67-8 C9H12 2.000% 120 12 21 9 108 52.10 46.89
1,2,4-trimethylbenzene 95-63-6 C9H12 8.500% 120 12 21 9 108 221.43 199.28
Butan-1-ol 71-36-3 C4H10O 11.000% 74 12 15 4 48 286.55 185.87
N-butyl acetate 123-86-4 C6H12O2 8.000% 116 12 20 6 72 208.40 129.35
Solvent naphta (heavy)
64742-94-5 C9 27.000% 12 9 108 703.35 575.47
Solvent naphta (light)
64742-95-6 C9 8.500% 12 9 108 221.43 181.17
Napthalene 91-20-3 C10H8 4.000% 128 12 18 10 120 104.20 86.83
N-propylbenzene 103-65-1 C9H12 2.000% 120 12 21 9 108 52.10 42.63
Total 2,526.85 2,060.89
Clearcoat stargloss 5910 Xylene 1330-20-7 C8H10 1.500% 106 12 18 8 96 48.60 44.02
N-propylbenzene 103-65-1 C9H12 1.500% 120 12 21 9 108 48.60 43.74
Mesitylene 108-67-8 C9H12 2.250% 120 12 21 9 108 72.90 65.61
1,2,4-trimethylbenzene 95-63-6 C9H12 8.500% 120 12 21 9 108 275.40 247.86
Napthalene 91-20-3 C10H8 0.750% 128 12 18 10 120 24.30 22.78
Butan-1-ol 71-36-3 C4H10O 8.500% 74 12 15 4 48 275.40 178.64
Butyl diglycol 112-43-5 C8H18O3 2.250% 258 12 29 8 96 72.90 27.13
Formaldehyde 50-00-0 CH2O 0.150% 30 12 4 1 12 4.86 1.94
N-butylacetate 123-86-4 C6H12O2 4.000% 116 12 20 6 72 129.60 80.44
Hydroxyphenyl-alkylbenzotriazole
127519-17-9
C27H39N3O3 0.400% 495 12 72 27 324 12.96 8.48
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 26-04-2017:03:15:05
Methyl 1,2,2,6,6 pentamethyl-4-piperidyl sebacate
82919-37-7
C21H39N04 0.150% 363 12 65 21 252 4.86 3.37
Isopropylbenzene 98-82-8 C9H12 1.500% 120 12 21 9 108 48.60 43.74
Bis-(1,2,2,6,6-pentamethyl-4-piperidinyl)-sebacate
41556-26-7
C30H56N2O4 0.400% 536 12 92 30 360 12.96 8.70
O-xylene 95-47-6 C8H10 1.500% 106 12 18 8 96 48.60 44.02
Solvent naptha (Petroleum) heavy aromatic
64742-94-5 C9 6.000% - 12 - 9 108 194.40 159.05
Solvent naptha (Petroleum) light aromatic
64742-95-6 C9 11.250% - 12 - 9 108 364.50 298.23
Total 1,639.44 1,277.75
Standard Thinner Acetone 67-64-1 C3H6O 15.000% 58 12 10 3 36 930.00 577.24
Ethyl acetate 141-78-6 C4H802 2.500% 88 12 14 4 48 155.00 84.55
Toluene 108-88-3 C7H8 15.000% 92 12 15 7 84 930.00 849.13
MIBK 108-10-1 C6H12O 2.000% 100 12 19 6 72 124.00 89.28
Propan-2-ol 67-63-0 C3H8O 7.500% 50 12 12 3 36 465.00 334.80
Tetrahydrofuran 109-99-9 C4H8O 0.500% 72 12 13 4 48 31.00 20.67
Xylene 1330-20-7 C8H10 7.500% 106 12 18 8 96 465.00 421.13
Heptane 142-82-5 C7H16 15.000% 100 12 23 7 84 930.00 781.20
Butan-1-ol 71-36-3 C4H10O 2.000% 74 12 15 4 48 124.00 80.43
N-butylacetate 123-86-4 C6H12O2 2.500% 116 12 20 6 72 155.00 96.21
Cyclohexane 100-82-7 C6H12 7.500% 84 12 18 6 72 465.00 398.57
Ethanol 64-17-5 C2H5OH 7.000% 46 12 9 2 24 434.00 226.43
Ethyl benzene 100-41-4 C8H10 5.000% 106 12 18 8 96 310.00 280.75
Methyl Acetate 79-20-9 C3H6O2 6.000% 74 12 11 3 36 372.00 180.97
Methanol 67-56-1 C1H3OH 2.000% 32 12 6 1 12 124.00 46.50
Total 6,014.00 4,467.87
Boiling additive
2-(2-butoxyethoxy) ethyl acetate 124-17-4
C10H20O4 99.770% 204 12 34 10 120 119.72 70.43
Dualion M8V2 N-propanol 23519-77-9 C3H8O 20.000% 60 12 12 3 36 140.00 84.00
259.72 154.43
Overall Total 22,156.91 15,335.5
0
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 26-04-2017:03:15:05
Appendix III - Solvent Output Calculations
TOC as C
result 2016
Average
mass flows
kg
Operating
hours
Mass flow
per annum
kg
Emission
point Parameter Unit Q1 Q2 Q3 Q4
A2-1 TOC (as C) mg/m3 7 4 16 3
Vol flow Nm3/hr 3,846 3,537 3,651 3,771
Mass flow per hr kg/hr 0.028 0.015 0.058 0.011 0.028 2,880 80.5
A2-2 TOC (as C) mg/m3 36 2 9 9
Vol flow Nm3/hr 17,114 15,667 14,938 26,555
Mass flow per hr kg/hr 0.624 0.032 0.133 0.236 0.257 1,920 492.6
A2-3 TOC (as C) mg/m3 10 4 5 5
Vol flow Nm3/hr 2,824 6,059 5,457 3,076
Mass flow per hr kg/hr 0.028 0.025 0.029 0.016 0.024 1,920 46.6
A2-4 TOC (as C) mg/m3 29 95 98 34
Vol flow Nm3/hr 1,597 1,032 1,075 608
Mass flow per hr kg/hr 0.046 0.098 0.105 0.021 0.068 1,920 129.6
A2-5 TOC (as C) mg/m3 40 13 36 86
Vol flow Nm3/hr 1,353 1,280 1,299 1,116
Mass flow per hr kg/hr 0.054 0.016 0.046 0.096 0.053 1,920 102.2
A2-6 TOC (as C) mg/m3 22 3 53 55
Vol flow Nm3/hr 23,189 35,590 36,558 35,110
Mass flow per hr kg/hr 0.518 0.123 1.935 1.937 1.128 1,920 2,166.1
A2-7 TOC (as C) mg/m3 20 4 11 18
Vol flow Nm3/hr 4,014 4,019 4,034 5,599
Mass flow per hr kg/hr 0.079 0.014 0.045 0.103 0.061 1,920 116.2
A2-8 TOC (as C) mg/m3 30 2 2 43
Vol flow Nm3/hr 17,916 29,738 30,791 30,201
Mass flow per hr kg/hr 0.530 0.063 0.069 1.291 0.488 1,920 937.2
A2-9 TOC (as C) mg/m3 45 33 35 21
Vol flow Nm3/hr 2,988 6,754 6,415 5,707
Mass flow per hr kg/hr 0.135 0.220 0.224 0.120 0.175 1,920 335.7
A2-10 TOC (as C) mg/m3 50 16 134 135
Vol flow Nm3/hr 1,300 921 870 575
Mass flow per hr kg/hr 0.065 0.015 0.117 0.077 0.068 1,920 131.4
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 26-04-2017:03:15:05
A2-11 TOC (as C) mg/m3 41 5 11 134
Vol flow Nm3/hr 1,407 500 573 1,159
Mass flow per hr kg/hr 0.057 0.003 0.006 0.155 0.055 1,920 106.2
A2-12 TOC (as C) mg/m3 45 27 34 33
Vol flow Nm3/hr 1,862 1,660 1,692 1,993
Mass flow per hr kg/hr 0.084 0.044 0.057 0.065 0.063 1,920 120.4
A2-14 TOC (as C) mg/m3 4 9 12 10
Vol flow Nm3/hr 16,396 16,827 14,617 14,028
Mass flow per hr kg/hr 0.060 0.153 0.174 0.142 0.132 5,760 761.1
A2-15 TOC (as C) mg/m3 16 12 9 10
Vol flow Nm3/hr 14,710 14,809 17,878 17,976
Mass flow per hr kg/hr 0.235 0.183 0.156 0.185 0.190 5,760 1,091.7
A2-16 TOC (as C) mg/m3 16 11
Vol flow Nm3/hr 21,476 21,592
Mass flow per hr kg/hr 0.339 0.239 0.000 0.193 5,760 1,110.4
A2-17 TOC (as C) mg/m3 10 6 10 12
Vol flow Nm3/hr 9,630 10,798 8,021 8,589
Mass flow per hr kg/hr 0.098 0.070 0.083 0.099 0.088 5,760 504.0
A2-18 TOC (as C) mg/m3 0 0 14 14
Vol flow Nm3/hr 0 0 4,916 4,811
Mass flow per hr kg/hr 0.000 0.000 0.069 0.066 0.034 3,840 129.5
A2-19 TOC (as C) mg/m3 13 11 18 17
Vol flow Nm3/hr 11,073 11,093 11,153 9,754
Mass flow per hr kg/hr 0.146 0.124 0.198 0.169 0.159 3,840 611.8
A2-21 TOC (as C) mg/m3 14.000 2.000 5.920 9
Vol flow Nm3/hr 2101.000 2518.000 3422.000 3492
Mass flow per hr kg/hr 0.029 0.005 0.020 0.031 0.021 2,400 51.2
A2-23 TOC (as C) mg/m3 43 415 52 17
Vol flow Nm3/hr 551 588 658 679
Mass flow per hr kg/hr 0.023 0.244 0.034 0.012 0.078 2,160 169.3
A2-25 TOC (as C) mg/m3 21.000 19.000 9.000 18.960
Vol flow Nm3/hr 2005.000 2336.000 2052.000 2336.000
Mass flow per hr kg/hr 0.042 0.044 0.018 0.044 0.037 3,840 143.3
A2-13 TOC (as C) mg/m3 5
Vol flow Nm3/hr 4,149
Mass flow per hr kg/hr 0.021 0.021 480 10.0
Total Mass Flow per annum (O1) 9,347.0
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 26-04-2017:03:15:05
Waste table of solvent related items (O6)
EWC code Quantity (kg) % carbon TOC as C lost Waste description
14 06 03 5914 56% 3312 Waste Solvent
08 01 13 2870 2.5% 71.8 Sludges from Paint
15 01 10 1495 3% 25.1 Containers used for
solvents/VOcs
15 02 02 3427 2.5% 85.7 Waste Rags & absorbents
Total VOC as Carbon in Waste 3,494 kg
Note: sludges is estimated using 2.5% which is a conservative %
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 26-04-2017:03:15:05