clara road, millstreet, co. cork. · 2017-05-30 · 3. solvent emissions directive ... laser...

ALPS Electric (Ireland) Limited.

IPPC Licence (Reg: P0835-01) Clara Road, Millstreet, Co. Cork.

SOLVENT MANAGEMENT PLAN 2016

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Solvent Management Plan 2016

Contents

1. INTRODUCTION ...................................................................................................................................1

2. PROCESS DESCRIPTION ....................................................................................................................3

3. SOLVENT EMISSIONS DIRECTIVE ..................................................................................................6

3.1 COMPLIANCE REQUIREMENTS .......................................................................................................6

3.2 COMPLIANCE ...................................................................................................................................7

3.3 QUALITY CONTROL .........................................................................................................................8

3.4 ALPS ELECTRIC (IRELAND) LTD. SOLVENT STORAGE AND DISTRIBUTION .......................8

3.5 DISPOSAL OF USED SOLVENT FROM SITE ....................................................................................9

4. LICENCE EMISSION MONITORING LOCATIONS .................................................................. 10

4.1 SUMMARY OF AIR EMISSIONS .................................................................................................... 10

4.2 AIR COMPLIANCE SUMMARY ...................................................................................................... 12

5. SOLVENT CONSUMPTION AND MANAGEMENT ................................................................. 13

5.1 SOLVENT CONSUMPTION ............................................................................................................ 13

6. QUANTIFICATION OF SOLVENT ................................................................................................. 18

7. SOLVENT MASS BALANCE ............................................................................................................ 19

8. CONCLUSION..................................................................................................................................... 20

Appendix 1 Glossy of Terminology

Appendix 2 Summary of all Solvents used at ALPS Electric (Ireland) Ltd. in 2016

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ALPS Electric (Ireland) Ltd. Solvent Management Plan 2016

Page | 1

1. Introduction

The Solvent Management Plan has been prepared by ALPS Electric (Ireland) Ltd.

to fulfill Condition 6.15 of the Integrated Pollution Prevention Control (IPPC)

Licence (Register No. P0835-01).

ALPS Electric (Ireland) Ltd. is located in Clara Road, Millstreet, Co. Cork. ALPS

Electric (Ireland) Ltd. is licenced for the principal activity of Surface Coatings

under Class 12.2.2 the Environmental Protection Agency Acts, 1992 to 2007. The

activity description in the IPPC Licence is as follows:

The manufacture or use of coating materials in processes with a capacity to make

or use at least 10 tonnes per year of organic solvents and powder coating

manufacture with a capacity to produce at least 50 tonnes per year, not included

in paragraph 12.2.1.

Condition 6.15 of the IPPC Licence is as follows:

The licensee shall prepare and report a Solvent Management Plan for the site for

each calendar year. The organic solvents to be included in the SMP shall be

determined by reference to the definition of an organic solvent in Council

Directive 1999/13/EC. The SMP shall be prepared in accordance with any

relevant guidelines in Annex Ill of the Directive or as issued by the Agency and

shall be submitted as part of the AER. The licensee shall keep records of the data

from which the reported information was derived and supporting documentation

including a description of the methodology used for data collection.

1.1 Purpose of the Report

The SMP has been prepared to verify compliance with the conditions of the

IPPC Licence by undertaking a mass balance of the annual solvent consumption

throughout the facility. The inputs amount of solvent to the site were weighed

against the outputs through emissions to air, water and waste. The resultant

difference between input and outputs is classified as fugitive emissions and is

evaluated to determine compliance with licenced limit values.

There are a number of pathways through which solvent can be lost as a result of

process within ALPS Electric (Ireland) Ltd. facility as outlined in Figure 1.

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Figure 1 Pathways of Solvent Loss

Solvent lost to waste

water treatment

Product

Chemical/

Physical Reaction

I2

Solvent A1-3,A2-1,A2-3

incinerated/adsorbed

Uncaptured Solvent

Air Emission

Solvent

Purchased

Solvent

Purchased

Solvent Recycled

I2

O5

O2

O7

O5

Collected Waste Solvent

Collected Waste Solvent

Solvent for reuse

elsewhere

Solvent for reuse

elsewhere

Chemical/ physical reaction physical reaction

Solvent Waste Gas Emission

Solvent

Purchased

Product

Residue

Solvent for Reuse

Elsewhere

Solvent Waste

Collected

Solvent lost to

wastewater

treatment

O8

O6

O3

O5

O1

O4

Solvent

Input

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2. Process Description

ALPS Electric (Ireland) Ltd. production process involves fabrication of plastic

parts and assembly of components onto printed wiring boards.

The main processes involved in the manufacture of the product are as follows:

Injection moulding of “non-cosmetic” plastic parts used in the assembly of

the products

Paint and lasering of decorative cosmetic parts.

Surface Mounting Process and wave soldering mount processes (Printed

wiring board stuffing)

Final assembly of units (assembling plastic parts to Printed wiring boards)

and including inspection and testing of finished units.

There are six key steps involved in the production of the wiring boards. A

description of the production process and how it relates to the Solvent Directive

is outlined in the following section.

Fabrication of plastic parts:

Fabrication of plastic parts:

1. Moulding Process

Plastic granules undergo injection moulding. The moulds are annealed, cooled

and cleaned.

2. Painting And Laser Tech Process

Moulds (plastic parts) requiring cosmetic coating are coated with a mixture of

paint, thinner and hardener using high volume low pressure (HVLP)

technology. Coated parts undergo a flash period of 15 minutes followed by

curing in an oven at 80oC.

Moulds are coated in two enclosed booths using automatic high volume low

pressure (HVLP) spray guns. Overspray is captured by a water curtain and

solvents are emitted without further abatement to emission point A1-3.

Solvent losses from mixing areas, flash off area and curing ovens are emitted

unabated through emission point reference A2-1. Solvent losses from manual

assembly process (flux and conformance coating) are directed unabated to

emission point A1-3 and A2-3. Emissions from these points vary on an annual

basis based on productivity however are approximately 3 kg/hr.

Laser etching of some parts is also undertaken. Annual solvent usage for this

coating activity varies on an annual basis based on productivity however is

estimated between 30-40 tonnes.

Licenced Activity: "Other Coating" Solvents Directive Annex IIA Activity 8.

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3. Raw Material Detrashing

Printed wiring boards and components are delivered to the site and

packaging is removed.

4. Surface Mount Technology (SMT) Process

Printed wiring boards are loaded onto a surface mount technology machine.

The boards are applied with solder paste, cleaned with solvent to remove dirt

and applied with glue (adhesive coating). Components are mounted

automatically onto the boards. The solder paste is cured and the boards are

inspected. Solvent used for adhesive coating in this area is approximately 1-2

tones per year.

Licenced Activity: "Adhesive Coating" Solvents Directive Annex IIA Activity

16. EPA Agreement for use >5 tonnes/year.

5. Manual Assembly Process

Larger components are manually placed onto the printed wiring boards from

the SMT process. Solder is applied by point spraying application. A solvent

based protective coating (conformance coating) is applied to the wiring

board followed by curing for certain products. The amount of solvent is used

in this process varies on an annual basis depending on productivity however

is approximately 0.5-1 tonnes per year.

6. Final Assembly

Moulds and wiring boards are assembled and parts are manually cleaned

using solvent. Solvent usage in final assembly varies on an annual basis

depending on productivity however is approximately 1.5 tonnes per annum.

Licenced Activity: "Other Coating" Solvents Directive Annex IIA Activity 8.

Licenced Activity: "Other Surface Cleaning" Solvents Directive Annex IIA

Activity 5. EPA agreement for use >2.

7. Cleaning of Pallets

Pallets from the manufacturing facility are cleaned within the chemical store

prior to reuse for transporting components within the processing areas.

Licenced Activity: Other Coating Solvents Directive Annex IIA Activity 8.

The amount of solvent utilized at the facility is influenced by customer

demand therefore input and output quantities may vary from year to year.

Table 2.1. provides indicative quantities of solvent used per annum for each

of the onsite processes.

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Table 2.1. Solvent Use and Estimated Quantities at Licence Emission

Points

Process Indicative

Solvent Use

Tonnes Per

Year

Emission

Point

Solvent Directive

Activity/Threshold

Coating of moulds:

- Spray booths

- Mixing, flash off, ovens

30-40 Tonnes A1-3

8. Other coating / >5

tonnes/year

Manual assembly:

- Conformance coating

- Flux coating

-SAM (Semi automaeted

manufacturin)

3

A1-3

,A2-3

8. Other coating / >5

tonnes/year

Surface Mount

Technology process

(adhesive coating)

1 A2-4 16. Adhesive coating /

>5 tonnes/year

Cleaning of Products 1.5 Fugitive 5. Other surface

cleaning / >2

tonnes/year

Cleaning of Pallets 3 Fugitive 8. Other coating / >5

tonnes/year

In order to achieve compliance with licenced emission limit ALPS Electric

(Ireland) Ltd. installed an abatement plant (A1-3). The abatement plant was

commissioned in April 2009 and replaced historical monitoring emission points

A2-6, and A2-7 (the Paint and Laser process stacks) and A2-2

(Solderwave/Concoat process stack). The abatement plant is based on a zeolite

concentrator followed by a regenerative thermal oxidiser. The exhaust air,

loaded with solvents from the process, is routed through a rotating activated

zeolite adsorption wheel. The Volatile Organic Carbons (VOC’s) are adsorbed in

the pores of the zeolite of the wheel in adsorption mode. The adsorption is

performed in one site while desorption is performed on the other site. The

outlet stream from the adsorption wheel is clean air and is discharged directly

to the atmosphere via a new stack (A1-3).

A small portion of the clean air (10%) is diverted to a heat exchange unit to be

heated by the clean air leaving the oxidation chamber. This warm air is then

directed back over a small isolated section of the spent zeolite in the desorption

section. The heated stream of gas is required to remove the VOC and allows

them to overcome the physical attraction forces of the zeolite adsorbent. By

using a smaller stream of air than the original VOC laden air stream the system

has effectively concentrated the exhaust gas. The resulting low-volume, high

concentration air is then directed to the oxidiser for oxidation of the VOC’s prior

to discharge to atmosphere.

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3. Solvent Emissions Directive

The European Council Directive (Limitation of Emissions of Volatile Organic

Compounds due to the Use of Organic Solvents in Certain Activities and

Installations) 1999/13/EEC has been implemented in Ireland by European Union

(Installations and Activities Using Organic Solvents) Regulations 2012 (S.I. No.

565 of 2012) and formerly through the Emissions of Volatile Organic

Compounds from Organic Solvents Regulations (SI. No. 543 of 2002) which are

now revoked by the 2012 Regulations.

The Regulations aim to prevent or reduce direct and indirect effects of

emissions of volatile organic compounds (VOC’s) into the environment and the

potential risks to human health by providing measures and procedures to be

implemented for specified activities and also to phase out the use of more

harmful solvents such as carcinogens, mutagens and those toxic to

reproduction.

The First Schedule of these Regulations requires that coating activity be subject

to compliance with the Regulations.

Under the Second Schedule of the Regulations the activity defined as “Other

Coating including metal, plastic, textile” (i.e. Activity number 8) detail the solvent

consumption thresholds under which ALPS Electric (Ireland) Ltd. must comply.

3.1 Compliance Requirements

An installation or activity operating above the solvent consumption threshold

will need to either:

Meet an emission limit value (Schedule 2) in waste gases (mg C/Nm3) and a

fugitive emission limit value (percentage of solvent use); or

Implement a solvent reduction scheme (Schedule 5) to reduce emissions

from the installation to equal to those that would be achieved by meeting

the total emission value.

Certain substances classified as carcinogenic, mutagenic or toxic (Risk Phrases

R45, R46, R49, R60, R61) must be replaced with less harmful substances, and

these substances along with halogenated volatile organic compounds with Risk

Phrase R40 must comply with separate emission limit values regardless of the

overall compliance method.

The Solvent Emission Directive states:

“For discharges of the VOCs with Risk Phrases R45, R46, R49, R60, R61, where the

mass flow of the sum of the compounds causing the labeling referred to in that

paragraph is greater than, or equal to, 10g/h, an emission limit value of 2

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mg/Nm3 shall be complied with. The emission limit refers to the mass sum of the

individual compounds.” And;

“For discharges of halogenated VOCs which are assigned the risk phrase R40,

where the mass flow of the sum of the compounds causing the labeling R40 is

greater than, or equal to, 100g/h, an emission limit value of 20 mg/Nm3 shall be

complied with. The emission limit value refers to the mass sum of the individual

compounds.”

To demonstrate compliance with the Regulations, ALPS Electric (Ireland) Ltd. will

use the Emission Limit Value Scheme.

Under the Second Schedule of the Regulations the activity defines as “Other

Coating including metal, plastic, textile” (i.e. Activity Number 8) detail the solvent

consumption and Emission Limit Value thresholds under ALPS Electric (Ireland)

Ltd. must comply.

Table 3.1: ALPS Electric (Ireland) Ltd. Emission Limit Values

Activity

Type

Activity (solvent

consumption in

tonnes/year)

Threshold

(solvent

consumption

threshold in

tonnes/year)

Emission limit values

in waste gases

(mg/C/Nm3

8 Other coating,

including metal,

plastic, textile(5), fabric,

film and paper coating

(>5)

5-15

> 15

100(1)(

1)

50/75

(2)(

3)(

4)

(1) Emission limit value applies to coating application and drying processes, operated

under contained conditions

(2) The first emission limit value applies to drying processes, the second to coating

application processes.

(3) For textile coating installations which use techniques which allow reuse of

recovered solvents, the emission limit applied to coating application and drying

processes taken together shall be 150.

(4) Coating activities which cannot be applied under contained conditions (such as

shipbuilding. aircraft painting) may be exempted from these values, in accordance with

Article 13(3).

(5) Rotary screen printing on textile is covered by activity

3.2 Compliance

The following sections outline the methodologies adopted for the

determination of solvent (including R-phrase solvents) and fugitive emission

levels from the ALPS Electric (Ireland) Ltd. facility and for the verification of

compliance.

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The solvent emission levels from the ALPS Electric (Ireland) Ltd. facility were

determined through a screening assessment of solvent (VOC) consumption

inventories and evaluation of VOC emission discharges.

For the purpose of this assessment, VOCs were defined as:

“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”

Only organic solvents used in process activities and in volumes exceeding 100

litres or named R phrases and deemed to satisfy the above definition for a VOC

(as defined in the Solvent Emission Directive) were included in the assessment.

Measurement of VOC emission at point source discharges was carried out to

determine compliance with the Regulations. All measurements were carried by

MCERTS accredited personnel.

3.3 Quality Control

ALPS Electric (Ireland) Ltd. utilize a wide variety of paints and thinners the

volumes of which are influenced by consumer demand. When a new paint is

ordered for a customer the Safety Data Sheet (SDS) sheet is reviewed by the

ALPS Electric (Ireland) Ltd. Health & Safety Engineer. The Risk Phrases for the

product are reviewed to assess the environmental and health hazards of a

substance.

Once deemed acceptable ALPS Electric (Ireland) Ltd. approve the product for

use within the site. Any product containing Risk Phrases R45, R46, R49, R60,

R61, or R40 and halogenated compounds will be issued for approval to the

Environmental Protection Agency prior to use onsite.

ALPS Electric (Ireland) Ltd. have an electronic quality control system known as

SAP (Systems, Applications, Products) MES (Manufacturing Execution System).

which enables the monitoring of inputs (paints, and thinners) containing

solvents onsite.

The SAP system allows ALPS Electric (Ireland) Ltd. to monitor the amount of

paint and solvent requested at the different process areas. Once an order has

been placed for the paint/solvent it will be logged on the MAPICS system and

all this information will be captured allowing a report on the amounts

consumed for process activities to be generated.

3.4 ALPS Electric (Ireland) Ltd. Solvent Storage & Distribution

Paints and thinners are stored within bunded storage rooms prior to dispatch to

processing areas within the facility.

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3.5 Disposal of Used Solvent from Site

Once used, solvents from waste paint, and paint sludge is removed offsite by a

licenced waste contractor. Some of the solvents are sent for disposal via

incineration, while some of the solvent is sent for recovery. A report detailing

the amounts of paint/thinners sent for disposal/recovery is received every

month by the Environmental Manager and is utilized to determine the amount

of waste solvent from the facility.

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4. Licence Emission Monitoring Locations

4.1 Summary of Air Emissions

The coating of moulds and printed circuit boards has been addressed within

the IPPC licence by the application of Emission Limit Values (ELV’s) for emission

points A1-3, A2-1 and A2-3 in accordance with activity No. 8 (Schedule 2 of S.I.

No. 565 of 2012) coating of moulds and printed circuit boards.

Air monitoring is undertaken in accordance with the IPPC licence requirements.

Monitoring was undertaken at the process vent stacks A1-3, A2-1, A2-3 and

A2-4 in 2016 by Odour Monitoring Ireland.

A description of the process area from which the air emission locations were

tested is provided in Table 4.1.

Table 4.1 Description of Process Area Emission Points

Monitoring Location Description

A1-3 Outlet from VOC Abatement system

A2-1 Paint and Lazer Process

A2-2 (Made redundant by A1-3) Concoat process & Wave solder 1&2

A2-3 Spot Dip (x3) and manual soldering

A2-4 SMT machine extract point

A2-6 (Made redundant by A1-3) PAL Area Extract 1

A2-7 (Made redundant by A1-3) PAL Area Extract 1

In order to achieve licenced emission limit values ALPS Electric (Ireland) Ltd.

installed an abatement plant to treat the exhaust air from the Paint and Laser

process stacks (A2-6 & A2-7) and the Solderwave/Concoat process stack (A2-2).

The abatement treatment plant was installed in April 2009 and a new emission

point A1-3 replaced previous emission points A2-2, A2-6, and A2-7.

The abatement plant comprised of a system based on a zeolite concentrator

followed by a regenerative thermal oxidiser. The exhausted air loaded with

solvents from the process is routed through a rotating activated zeolite

adsorption wheel. The VOCs are adsorbed in the pores of the zeolite in the area

of the wheel in the adsorption mode. The adsorption is performed in one site

while desorption is performed on the other site. The outlet stream from the

adsorption wheel is clean air and can be discharged directly to the atmosphere

via the new stack (A1-3).

Total Organic Carbon is monitored on a quarterly basis for emission points A3-

1, A2-1, A2-3, A2-4. The results of analysis for the 2016 reporting period are

outlined in Table 4.2

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Table 4.2 Total Organic Carbon Emissions from Process Vents during the 2016 Survey Period

Monitoring

Location

IPPC

Licence

Limit

Value

mg/m3

Measurement Period TOC conc. Normalised

Volumetric airflow

rate (Nm3/s)

Emission Limit

Value

Volumetric

airflow rate

(Nm3/hr)

Mass loading/

emission

Annual

Mass

Emission

Permitted

Mass

Emission

(mgC/Nm3)

(kg/hr)

Kg/Yr

Kg/Yr

A1-3 50

Quarter 1 4.180 19591

44,000

0.082 1494 19272

Quarter 2 18.070 18419 0.333

Quarter 3 22.510 21272 0.157

Quarter 4 8.44 19360 0.163

A2-1 50

Quarter 1 2.24 9678 16,619 0.022 1093 7279

Quarter 2 16.86 12069 0.203

Quarter 3 13.24 15235 0.202

Quarter 4 6.90 16050 0.111

A2-3 75

Quarter 1 16.5 2714 3,067 0.045 321 2015

Quarter 2 14.53 2586 0.038

Quarter 3 14.03 3016 0.042

Quarter 4 11.28 2920 0.033

A2-4 N/A

Quarter 1 11.73 2793

Not Licenced

0.033 228

Not

Licenced

Quarter 2 8.70 2504 0.022

Quarter 3 9.43 3165 0.030

Quarter 4 7.32 3665 0.027

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4.2 Air Compliance Summary

The overall combined annual mass emissions for TOC from all process sources

are significantly lower than annual permitted mass emissions. As a result

ALPS Electric (Ireland) Ltd. have demonstrated 100% compliance with

monitoring results were noted for the 2016 monitoring period.

Therefore as demonstrated above ALPS Electric (Ireland) Ltd. is in compliance

with Schedule two of the Regulations SI. No. 565 of 2012 (European Union

(Installations and Activities Using Organic Solvents) for the activity defined as

“Other Coating including metal, plastic, textile” (i.e. Activity number 8).

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5. Solvent Consumption and Management

The management and consumption of solvent onsite is outlined in the following

section of the report.

5.1 Solvent Consumption

The following tasks were considered as part of the scope of work in preparing

the SMP for:

Identification of all organic solvents used at the site and determination of

the amount of solvent used per annum.

Assessment to ensure that no carcinogenic, mutagenic or toxic (Risk Phrases

R45, R46, R49, R60, R61) solvent were used onsite

Identification and quantification of the potential loss pathways for the

various solvents used at the site,

Table 5.1 presents a summary of all organic solvents and materials which

contain organic solvents that are currently used at the site. The VOC content of

each material was determined by reference to the corresponding Safety Data

which are stored onsite.

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Condition 16.6 of the IPPC licence states that “solvent consumption in the

cleaning of product and adhesive coating shall not exceed 2 and 5 tonnes

respectively unless otherwise agreed by the agency.”

The amount of solvent used onsite for activities associated with cleaning of

product and adhesive coating was assessed with respect to Condition 6.16 of

the IPPC Licence is summarised in Table 5.2.

Table 5.2 Solvent Consumption for Cleaning of Product and Adhesive Coating

2016

S.I. No.543 of

2002) Activity

Category

Process Activity Solvent Consumed

in 2016 (Tonnes)

Threshold

Consumption

Emission Limit

Value

Activity 5 Cleaning of

Product

1.34

2

Activity 16 Adhesive Coating 0.3 5

As can be seen from Table 5.2 the solvent consumed in the cleaning of

product and adhesive coating are below the threshold limit value of 2

and 5 tonnes respectively and are compliant with Condition 6.16 of the

Licence.

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Table 5.3 Solvent Management Description and Relevance to ALPS Electric (Ireland) Ltd.

Solvent

Management

Reference

Description Relevance to process Where site Information can be

obtained

ALPS Electric (Ireland)

Ltd. Reference

I1 The quantity of organic solvents

(tonnes)/or their quantity in preparations

purchased which are used as input into

the process in the timeframe over which

the mass balance is being calculated.

Annual solvent (paint &

thinners) purchases for the

ALPS Electric (Ireland) Ltd.

facility.

Mapics quality control system will

log all paint and thinner uses with

in the plant.

Annual Solvent Input.

I2 The quantity of organic solvents or their

quantity in preparations recovered and

reused as solvent input into the process

(tonnes). (The recycled solvent is counted

every time it is used to carry out the

activity).

This does not take place at the

ALPS Electric (Ireland) Ltd.

facility. All solvent is used and

sent for recovery/disposal.

Not Applicable to operations. Recovered & Reused

C Consumption (C = I1 – O8) corresponds to

the quantity of organic solvent which iS

input into the process minus any that is

recovered and reused but not as input into

the process.

As no solvent is recycled

within the ALPS Electric

(Ireland) Ltd. facility

consumption is solely based

on the annual use of solvent.

Input or Usage

O1 Emissions in waste gases (tonnes)

The amount of solvent emitted

to air through licenced IPPC

emission points.

Obtain via monitoring of the waste

gases.

Complying with the ELV’s or

obtain via the solvent

management plan by difference if

complying with the reduction

scheme.

Air Emissions Licenced.

Monitoring of gases

from Pallet Cleaning

Store.

O2 Organic solvents lost in water (tonnes), if

appropriate taking into account waste

water treatment when calculating O5.

Solvent from the Paint and

Laser process is absorbed and

removed from the site in a

liquid sludge.

Laboratory analysis will determine

the percentage of solvent lost to

water.

O3 The quantity of organic solvents (tonnes) Paint residue in containers, Laboratory analysis will determine Lost to Product

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Page | 16

Solvent

Management

Reference


obtained


Ltd. Reference

which remain as contamination or residue

in products output from the process.

spray guns, and connection

tubes.

the percentage of solvent

remaining in used containers.

Preparation.

O4 Uncaptured emissions of organic solvents

to air (tonnes). This includes the general

ventilation of rooms, where air is released

to the outside environment via windows,

doors, vents and similar openings.

Solvents lost to air other than

though unlicensed emission

points. Solvent emissions from

areas which are not covered

by booth extraction systems,

e.g. some drying booths, gun

cleaning station, distillation

unit, paint mixing & storage

area, waste storage area

(containers, rags), spills, etc.

Obtain via the mass balance by

difference.

Air Fugitive Emission

O5 Organic solvents and/or organic

compounds lost due to chemical or

physical reactions

(tonnes) (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).

The abatement plant

comprised of a system is

based on a zeolite

concentrator followed by a

regenerative thermal oxidiser.

This has an 95% efficiency

rate.

-

Quarterly Air Monitoring Results

for the abatement plant (A1-3)

Abatement Plant

O6 Organic solvents contained in collected

waste (tonnes)

The quantity of solvent

generated at the site. Consists

of waste sent off-site for

disposal and the change in

inventory of the waste.

Records on weight of solvent waste

sent off-site for disposal.

If there is no record of disposal of

the waste by an authorised outlet,

no credit will be allowed for the

waste. Analysis of VOC content of

any solvent waste sent off-site is

required (this may need to be

Waste Collected.

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Page | 17

Solvent

Management

Reference


obtained


Ltd. Reference

repeated on a periodic basis).

Representative sampling methods

should be used.

O7 Organic solvents, or organic solvents

contained in preparations, which are sold

or are intended to be sold as a

commercially valuable product (tonnes).

Solvent in finished

products/semi finished

product, intermediates/rejects

sold for use elsewhere.

No solvent remains in the finished

product and is burned off through

the curing process and/or diverted

by water through curtain the site.

Finished Product

O8 Organic solvents contained in

preparations recovered for reuse but not

as input into

the process (tonnes), as long as not

counted under O7

It is important to distinguish between

waste sent for disposal and waste sent for

reuse, as solvent sent for reuse will reduce

the Consumption term.

Solvent sent offsite for

recovery or reuse in other

applications (including use as

fuel).

Solvent is sent off site to

Veolia who recover some of it

for reuse offsite.

Records on weight of solvent waste

sent off-site for recovery & reuse

elsewhere.

Sent offsite for Reuse.

O9 Organic solvents released in other ways

(tonnes)

Should not occur under

normal operating conditions.

This would include that not-

otherwise accounted for

proportions of VOC released

following, for instance an

accidental release of solvent

from a bund.

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Page | 18

6. Quantification of Solvent

The waste register was used to determine the amount of waste solvent that was

sent offsite in 2016. In order to confirm the percentage of solvent present within

the waste paint, flux and thinners samples were collected in October and

November 2010 and sent to for solvent analysis. The samples were analysed

using GC-MS Headspace for the identification of solvent composition. The

percentage solvent concentrations were estimated by utilising available

solvents, namely Butan-l-ol, Propan -2-ol, m-xylene and ethyl acetate.

Quantitative analysis of the solvent composition was compromised due to the

sensitivity of the GC-MS. It was noted from the GC-MS scans that each sample

type varied in composition. This caused difficulties for absolute quantization;

therefore the results are semi-quantitative in nature.

A summary of the results of analysis are outlined in Table 6.1

Table 6.1 Percent of Solvent Analysis in Emissions to Waste

Date of

Analysis

Percentage Solvent

Wipes Waste Flux and

Thinners

Waste

Paint and

Thinners

Paint Sludge

14/10/10 5.21 98 70 6

2.41 98 100 7

1.74 98 68 6

26/11/10 0.44 98 98 8

0.83 98 98 6

1.78 98 98 9

Average 2.07 98 88.67 6.94

The results of analysis were used to quantify the percentage of solvent within

the waste categories removed from the site.

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Page | 19

7. Solvent Mass Balance

A solvent mass balance has been completed for the facility which evaluates the

solvent throughout consumption facility, and respective outputs via abatement,

air, waste, and recovery with the remainder accounting for fugitive emissions

Table 7.1.

Table 7.1 Solvent Inputs ALPS Electric (Ireland) Ltd.2016

I1 INPUTS Amount Consumed in 2016 (Tonnes)

Paint & Laser 32.47

Wave solder process 1.28

Concoat

SMT 0.70

Final Assembly 1.34

Total Amount of Solvent Input

(Tonnes) 35.79

Condition 5.3 of the licence notes that the Total fugitive emissions to air of

volatile organic compounds shall not exceed 20% of solvent input per calendar

year. Table 7.2 presents the outputs of solvent through the facility and the

resultant fugitive emissions.

Table 7.2 Solvent Outputs and Resultant Fugitive Emissions 2016

Solvent Outputs

Total Outputs

(Tonnes)

Organic Solvent Emissions to Air O1 3.14

A1-3 0.95

A2-1 0.86

A2-3 0.29

A2-4 0.95

Total Inlet to Abatement Plant (A1-3) Annual Mass Emission 29.48

Organic solvents via Incineration O5 27.99

Solvent Emissions as Waste (Disposal) O6 2.66

Organic Solvents for Reuse as Fuel O8 0.04

Total VOC emissions 33.82

F=I1-O1-O5-O6-O7-O8 Fugitive Emission 1.97

Paint & Lazer (Cleaning of Pallets) 0.04

Total Fugitive Emissions 2.01

Percentage of Total Fugitive Emissions 5.62%

As can be seen in the Solvent Mass Balance the amount of fugitive emissions for

the facility is estimated at 2.01 tonnes which comprises 5.62% of the overall mass

balance and as a result demonstrates compliance with Condition 5.3. of the

licence.

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8. Conclusion

ALPS Electric (Ireland) Ltd. are compliant will all licenced air monitoring emission

requirements as set out in the Schedule B of the IPPC Licence as demonstrated in

Section 4 of the report.

Compliance with solvent consumption onsite is demonstrated in Table 8.1 and 8.2 for

each of the licenced conditions.

Table 8.1 Licence Compliance with IPPC licence Conditions

IPPC

Licence

Licence

Requirement

Process

Activity

Solvent

Consumed in

2016 (Tonnes)

Threshold

Consumption

Emission Limit

Value

6.16 Solvent

consumption in

the cleaning of

product and

adhesive coating

shall not exceed 2

and 5 tonnes

respectively

unless otherwise

agreed by the

agency.

Cleaning of

Product

1.34

2

Adhesive

Coating

0.3 5

Table 8.2 Licence Compliance with IPPC licence Conditions

IPPC

Licence

Licence

Requirement

Process

Activity

Percentage

Fugitive

Emissions

Threshold

Consumption

Emission Limit

Value

5.13 Total fugitive

emissions to air of

volatile organic

compounds shall

not exceed 20% of

solvent input per

calendar year.

Fugitive

Emissions

u

g

5.62% 20%

As can be seen from Table 8.1 the solvent consumed in the cleaning of product and

adhesive coating are below the threshold limit value of 2 and 5 tonnes respectively. The

percentage of fugitive solvent for 2016 was 5.6% which is substantially below the

consumption limit value of 20%. In conclusion the Solvent Management Plan for 2016

has demonstrated compliance the conditions of the IPPC Licence by providing

information on solvent consumption throughout the facility, demonstrating the

resultant solvent emissions via air and water, and compliance with the emission limit

values within the IPPC Licence.

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Appendix 1 Glossary of Terminology

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Glossary of Terminology

Activity Definition within the Schedule 1 of the of

Solvent Directive S.I. No. 565 of 2012

Coating Activity

Any activity in which a single or multiple application of a continuous

film of a coating is applied to:

(a) either of the following vehicles:

(i) new cars, defined as vehicles of category M1 in Directive

2007/46/EC of the European Parliament and of the Council of 5

September 2007 establishing a framework for the approval of

motor vehicles and their trailers, and of systems, components and

separate technical units intended for such vehicles3 and of

category N1 in so far as they are coated at the same installation

as M1 vehicles;

(ii) truck cabins, defined as the housing for the driver, and all

integrated housing for the technical equipment, of vehicles of

categories N2 and N3 in Directive 2007/46/EC;

(iii) vans and trucks, defined as vehicles of categories N1, N2 and N3 in

Directive 2007/46/EC, but not including truck cabins;

(iv) buses, defined as vehicles of categories M2 and M3 in Directive

2007/46/EC;

(v) trailers, defined in categories O1, O2, O3 and O4 in Directive

2007/46/EC;

(b) metallic and plastic surfaces including surfaces of airplanes, ships,

trains, etc.;

(c) wooden surfaces;

(d) textile, fabric, film and paper surfaces;

(e) leather.

Coating activities do not include the coating of substrate with metals

by electrophoretic and chemical spraying techniques. If the coating

activity includes a step in which the same article is printed by whatever

technique used, that printing step is considered part of the coating

activity. However, printing activities operated as a separate activity are

not included, but may be covered by these Regulations if the printing

activity falls within the scope thereof.

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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 the

equipment but to the cleaning of the surface products.

Adhesive Coating

Any activity in which an adhesive is applied to a surface, with the

exception of adhesive coating and laminating associated with

printing activities.

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Appendix 2 Summary of Solvents used in 2016

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Summary of all Solvents used at ALPS Electric (Ireland) Ltd. in 2016

Area Item Number Item Desc UOM Converted to

Kgs

Total purchased in

Tonnes Percentage

Solvent

Total in Tonnes

CONCOAT 917K0004 HUMISEAL 1R32A2 L 200 0.2 50 0.10

CONCOAT 917K0012 HUMISEAL THINNER 503 L 200 0.2 100 0.20

FA IC5JA MEGAFAC F-761 (MVZ401B00) KG 1344 1.344 100 1.34

PAL 4AB-00079A VARNISH T200-0001 ML 16 0.016 20 0.00

PAL 4AD-00024A

PAINT 94:369:E6161/ADM

CH/SOL ML 40 0.04 50 0.02

PAL 4DF-00025A THINNER T200 100VR1450 ML 15 0.015 55 0.01

PAL 917K0071A N-BUTYLACETATE FLUID L 1600 1.6 100 1.60

PAL 918K002B

PAINT 94:369 E1416 ADM V CH

MA ML 7750 7.75 58 4.50

PAL 918K003A HARDNER 90:CA:01 ML 660 0.66 37 0.24

PAL 918K0133A 01:439 JAXA THINNERS ML 50 0.05 70 0.04

PAL 918K031B HARDENER 516309 2K BMW ML 15 0.015 40 0.01

PAL 918K032B THINNER 517848 ML 50 0.05 100 0.05

PAL 918K065A HARDENER FOR PSA INKS H1 ML 20 0.02 25 0.01

PAL 918K066A TPV DILUANT SM120100 ML 21 0.021 99.9 0.02

PAL 918K076A

PAINT BLACK TC

94:368:E3098/A ML 260 0.26 58 0.15

PAL 918K078A CLEANING AGENT UR3 L 890 0.89 100 0.89

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Kgs

Total purchased in

Tonnes Percentage

Solvent

Total in Tonnes

PAL 918K087A THINNERS S&R 09:378 ML 4850 4.85 100 4.85

PAL 918K111A THINNER 510128 ML 30 0.03 100 0.03

PAL 918K115A THINNERS 512-829 ML 40 0.04 100 0.04

PAL 918K121A INK M3817 38 439 Y283 GREEN ML 12 0.012 10 0.00

PAL 918K122A

INK M381738486 443+10%910

BLUE ML 20 0.02 10 0.00

PAL 918K123B PAINT 516514 ML 6 0.006 100 0.01

PAL 918K125B PAINT BC 516691 ML 15 0.015 55 0.01

PAL 918K130A PAINT 35F:37M:E5083 NH827L ML 15 0.015 85 0.01

PAL 918K131A THINNER 01:571 RECRACK STD ML 35 0.035 100 0.04

PAL 918K132A PAINT 94:364:E4976/A NH1L ML 20 0.02 85 0.02

PAL 918K134A PRIMER 343-29 ML 100 0.1 5 0.01

PAL 918K135A

PAINT CR-349-44 10TN OYSTER

71 ML 10 0.01 0 0.00

PAL 918K136A

PAINT CR-349-44 10UA

VEN/BEIGE ML 50 0.05 0 0.00

PAL 918K145A PAINT H/M 2P-500TXL 5140870 ML 45 0.045 100 0.05

PAL 918K146A

PAINT S/ACE HG-300 TXL

514.873 ML 70.5 0.0705 100 0.07

PAL 918K147A

HARDENER STRON #73 TXL

514.871 ML 10 0.01 75 0.01

PAL 918K148A

HARDENER STRON #143TXL

514.874 ML 75 0.075 100 0.08

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Kgs

Total purchased in

Tonnes Percentage

Solvent

Total in Tonnes

PAL 918K154A THINNERS RUCO 100-VR-1271 ML 5 0.005 100 0.01

PAL 918K155A

HARDENER RUCO 100VR1433

100 ML 2 0.002 50 0.00

PAL 918K156B INK RED T200 2320-M10780 G 3960 3.96 60 2.38

PAL 918K157B INK BLUE T200 SD10552 ML 4 0.004 65 0.00

PAL 918K158A PAINT 94:360:E5491/A LP79 ML 85 0.085 100 0.09

PAL 918K159A

PAINT ALEXITCR 349-44 IVORY

WH ML 20 0.02 0 0.00

PAL 918K162A PAINT 90:1520/A GLOSS TC C3 ML 55 0.055 100 0.06

PAL 918K165B INK RED T200 SD10562 ML 7 0.007 60 0.00

PAL 918K166B T200 SERIES INKS ML 10 0.01 60 0.01

PAL 918K167A

INK TPL DARK GREY

M381738533 ML 65 0.065 15 0.01

PAL 918K168B

PAINT EBONY

94:D3124/E0223B ML 634 0.634 70 0.44

PAL 918K170B THINNER 01:D51/734/7 ML 4750 4.75 100 4.75

PAL 918K171A HARDENER 90:CA-77 ML 565 0.565 100 0.57

PAL 918K172A

INK 88PD 11-4301 WHITE

200072 ML 105 0.105 100 0.11

PAL 918K173A

INK 88PD 100 MEDIUM

(CLEAR) ML 45 0.045 100 0.05

PAL 918K174A

PAINT 94:D71/89/1:E5873/A T

OR ML 5 0.005 85 0.00

PAL 918K175B

PAINT BASECOAT 463-

07.9200.9 ML 1500 1.5 40 0.60

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Kgs

Total purchased in

Tonnes Percentage

Solvent

Total in Tonnes

PAL 918K176A THINNER 901.26 ML 2125 2.125 100 2.13

PAL 918K177A HARDENER 402 ML 384 0.384 100 0.38

PAL 918K178A

PAINT T/C 460.22 90LX PIANO

BL ML 4100 4.1 100 4.10

PAL 918K179A THINNER 902.76 ML 710 0.71 100 0.71


PAL 918K183A PAINT 94:369:E6031/A NH863L ML 350 0.35 95 0.33

PAL 918K185A

PAINT 402.41 L/C 90DX

SCHWARZ ML 768 0.768 50 0.38


PAL 918K187A THINNER :901.86 ML 685 0.685 100 0.69

PAL 918K189A THINNER 100VR1279 ML 5 0.005 100 0.01

PAL 919K009A INK TAMPO RED 88PD-1202140 ML 25 0.025 80 0.02

PAL 919K011A HARDENER 88PD TAMPO ML 10 0.01 100 0.01

PAL 919K012A THINNER PV-7 TAMPO ML 25 0.025 100 0.03

SMT 917K00103 SURCLEAN SCREEN CLEAN L 1360 1.36 50 0.68

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