environmental compliance in ireland’s engineering sector · 5.0 storage of hazardous materials...

Environmental Compliance in Ireland’s Engineering Sector


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“The established practice in Enterprise Ireland of conducting

environmental assessments of companies in receipt of grant-aid has

resulted in noticeable improvements in their environmental performance.

This is demonstrated by increased competitiveness through high levels of

compliance with regulation and best practice and of improved

sustainability. The majority of Irish engineering companies now operate

to the highest environmental standards and those regularly assessed by

Enterprise Ireland are more likely to be fully compliant.”

Tom Kelly, Divisional Manager,

Life Sciences, Engineering and Cleantech


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Environmental Compliance in Ireland’s

Engineering Sector Robert Geraghty, Mary Doolan, Tadhg Egan and Peter Prior

For correspondence contact Dr. Robert Geraghty, Senior Analyst, Environment & Green Technologies Department,

Enterprise Ireland, Eastpoint Business Park, Dublin 3

Tel: 01 727 2618: email: [email protected]

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1.1 Executive Summary_______________________________________________________ 8

1.2 Activities of Irish Engineering companies which may impact on the environment ______ 12

1.3 Assessing the environmental compliance in the Irish metal and plastic fabrication sectors 12

2.0 Wastewater Treatment _______________________________________________ 14

2.1 Industrial wastewater from metal and plastic fabrication _________________________ 14

2.2 Environmental legislation for metal and plastics fabrication _______________________ 15

2.3 The effluent discharge compliance record of Irish Engineering companies ____________ 16

3.0 Atmospheric Emissions _________________________________________ 18

3.1 Atmospheric emissions from metal fabrication _________________________________ 18

3.2 Atmospheric emissions from plastics fabrication ________________________________ 18

3.3 Legislation and Best Practice Guidelines ______________________________________ 20

3.4 Non-compliance of Irish engineering companies and best practice guidelines on atmospheric

emissions ______________________________________________________________ 21

4.o Waste Management __________________________________________________ 23

4.1 National Policy and Waste Management Planning _______________________________ 23

4.2 The Waste Management Act 1996 ___________________________________________ 24

4.3 Waste management in Irish industry _________________________________________ 24

4.4 Non-compliance of Irish engineering companies with regulations and best practice

guidelines on waste management ___________________________________________ 25

5.0 Storage of Hazardous Materials_______________________________________ 27

5.1 Non-compliance with regulation and best practice guidelines concerning the storage of

hazardous materials______________________________________________________ 27

6.0 Noise ________________________________________________________________ 28

6.1 Prevention and Control____________________________________________________ 28

6.2 Non-compliance with best practice guidelines concerning the noise pollution _________ 28

7.0 Overall Sectoral Performance _________________________________________ 29

7.1 Storage________________________________________________________________ 29

7.2 Effluent Discharges ______________________________________________________ 30

7.3 Atmospheric Emissions ___________________________________________________ 30

Appendix I ___________________________________________________________________ 32

Appendix II___________________________________________________________________ 34

Appendix III __________________________________________________________________ 39

Appendix IV __________________________________________________________________ 43

Appendix V ___________________________________________________________________ 48


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1.1 Executive Summary

Ireland’s engineering sector comprises over 600 companies. Most are small to medium

original equipment manufacturers (O.E.M.) and sub-component/assembly suppliers. They

generate sales of €2.7 billion, exports of €800 million and employ 16,000 [Enterprise Ireland data].

As part of the policy of promoting compliance with environmental legislation and good

practice, Enterprise Ireland conducts environmental assessments of all of its client companies

that are in receipt of grant support. For the purposes of this study, Enterprise Ireland has

reviewed the results of 409 assessments conducted over the past 15 years on 231

engineering companies, 14 of which are now licensed by the EPA under the IPPC Directive.

This study demonstrates that Ireland’s engineering sector operates to very high levels of

environmental regulatory compliance. The processing activities of the sector that are subject

to environmental regulation relate primarily to the treatment and discharge of industrial

effluents and to the management of waste, both of which are subject to strict licensing.

Typical non-hazardous wastewaters in metal and plastics fabrication include surface and

equipment cleaning/rinsing streams and cooling/heating liquids. In most cases, companies

discharge to sewer and all discharges, regardless of source or volume, must be licensed and

monitored and must not exceed emission limit values (ELVs). The study has shown that the

proportion of Irish engineering companies that complied fully with current legislation

improved from 75% (2002-2004) to 93% (2008-2010). Non-compliance took the form of

either not having the appropriate licence or not adequately monitoring discharges. The most

marked improvements took place in the machine and precision engineering sub-sectors both

of which were found to be 100% compliant in 2008-2010.

Improvements in the levels of compliance with waste management regulations were even

more impressive. Overall, waste management only accounted for 6.6% of all non-

compliances recorded since 1995. Companies either failed to properly dispose of waste (e.g.

open burning of packaging waste), stored waste on site for too long or failed to ensure that

their waste management contractor had the appropriate waste collection or storage permit.

Compliance by the sector improved from 89% (1995-1998) to 98% (2008-2010). The most

significant improvements were recorded by the machine and plastics engineering sub-sectors

where non-compliance was reduced from 25% and 22% (1995/98) to 0% and 5% (2008/10)

respectively.

There were also significant improvements in the levels of compliance with regulations and

with best practice guidelines concerning atmospheric emissions. Most industrial activities

generate atmospheric emissions such as VOCs, particulates, fumes and vapours. A small

number of companies in the sector (14) have specific conditions issued by the EPA in IPPC

licences. The other companies are not subject to specific conditions but are obliged, under

the general provisions of the Air Pollution Act 1987, to take measures to limit/ prevent


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pollution, with enforcement powers vested in the local authorities. During the period of this

study, the vast majority of the companies were compliant with best practice. Cases of non-

compliance involved companies not making adequate provisions for venting emissions (i.e.

stacks not being sufficiently raised above roof level) and/or inadequate provisions for

extraction/overspray collection in areas of the plant generating fumes, dusts and/or vapours.

Overall, atmospheric non-compliances accounted for 15% of all non-compliances since 1995.

During the period of the study, compliance with best practice guidelines improved from 80%

(1995-1998) to 96% (2008-2010). The plastics and precision engineering sub-sectors have

been fully compliant in this regard since 1999 and 2005 respectively. Compliance in the

metal fabrication and machine engineering sub-sectors has improved steadily from 76 % and

75% (1995-1998) to 94% and 92% respectively.

This study has also demonstrated a commitment by Ireland’s engineering sector to operate to

best practice guidelines relating to storage of hazardous materials such as fuels, solvents and

hydraulic fluids, despite the lack of any firm regulatory framework for non-licensed

companies. Such storage vessels should have adequate secondary containment (i.e.

bunding) to protect against pollution of surface and ground waters in the event of vessel

failure. Conditions to this effect may be included in an IPPC Licence or an Effluent Discharge

Licence for the site. In the absence of a licence it represents best practice to bund such

vessels. Storage was found to be the most significant area of environmental non-compliance

among Irish engineering companies. Over the period of the study, 57% of all non-

compliances recorded during 409 assessments related to inadequate bunding. In period

1999-2001, only 40% of Irish engineering companies complied with best practice relating to

bunding. Compliance levels, over the past 10 years, have improved to 66%, however, there

is still a lot to be done to render the engineering sector fully compliant. In most cases of non-

compliance, only one of a number of storage vessels on any given site were not bunded,

usually as a result of an oversight when new vessels are installed.

During the period of the study, only 4% of all of the non-compliances recorded related the

general condition of the manufacturing plant and the surrounding site and only 3% related to

excessive noise at boundaries. Furthermore, since 2002, all companies were found to be fully

compliant with best practice guidelines relating to noise and, with only one exception, to the

general site conditions of the plants that were assessed.

Companies that were assessed more than once were found to have improved environmental

performance. The evidence indicates that companies in the sector took positive actions to

improve their environmental performance and sustainability as a result of the intervention by

Enterprise Ireland.


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Introduction

Ireland’s vibrant engineering sector comprises over 600 companies, mostly SMEs, generating

sales of €2.7 billion and exports of €800m, predominantly to the EU. This highly diverse

sector, which employs 16,000, is dominated by original equipment manufacturers (O.E.M.)

and sub-component/assembly suppliers with a strong research and development ethos. The

dominant sub-sector is machine engineering where materials handling (conveyor/robotic

systems and hydraulic systems) and agricultural machinery (balers, spreaders, vertical

feeders and trailer hitches) account for exports of €150m and €100m respectively.

Engineering sub-sectors with significant exports also include metal product fabrication (i.e.

construction, environmental, industrial and automotive), precision engineering (medical, tool-

making) and plastics (i.e. tanks, medical tubing, packaging). Table 1 provides a breakdown

of the main activities covered by the Irish engineering sector.

Engineering Sub-sectors

Engineered Products

Metal Fabrication

• Construction products such as doors, window sets, curtain

walls, railings, gates, balconies, industrial doors, steel

frame housing, scaffolding and street furniture;

• Environmental equipment such as compactors and balers;

• Industrial equipment such as cleanroom equipment,

storage containers, catering equipment and process

equipment; and

• Automotive products/components for ambulances,

refrigerated vehicles and forklift cabs.

Machine Engineering

• Agricultural machinery such as spreaders, balers, vertical

feeders, feeder wagons, trailer hitches, slurry tankers and

post-drivers; and

• Materials handling systems such as quarry plant, forklifts,

hydraulics, trailers, dumpers and conveyors.

Plastics Engineering

• Medical tubing & packaging, filtration products, insulation

products, PVC doors & windows, extruded sheeting,

automotive parts, pipes, tanks, gutters, soffits, cladding

and trims.

Precision Engineering

• Medical devices, injection moulds, automotive parts, laser

cutting, CNC milling, tungsten tools, grinding wheels,

springs, turned parts and cable harnesses.

Table 1 : Engineering sub-sectors product breakdown


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Enterprise Ireland

Enterprise Ireland provides a wide range of grants and other non-financial supports to

Ireland’s indigenous manufacturing sectors. Financial supports include grants for everything

from R&D and expansion to training and overseas market development. Enterprise Ireland

also conducts environmental assessments of Irish-based companies (both indigenous and

foreign multi-national companies) that are in receipt of grant support. The environmental

assessments are designed to ensure that the grant recipients comply with current

environmental legislation and good environmental practice. Following the recommendations

that result from environmental assessments can improve the overall sustainability of a

company and help them to enhance their environmental credentials.

Through recommendations pursuant to its environmental assessments, as well as advice on

current environmental regulation and best practice, and the provision of grant-support for the

implementation of environmental management systems, Enterprise Ireland has played a

significant role in driving change in all manufacturing sectors that impact on the environment.

Enterprise Ireland also provides grant assistance to companies seeking to better manage their

environmental impacts by investing in systems for minimising waste and for managing air and

water emissions. Enterprise Ireland has enjoyed considerable success in improving levels of

regulatory compliance in the areas of wastewater treatment, emissions to the environment

and waste reduction. It has also encouraged continuous improvement and the adoption of

best practice guidelines relating to storage, noise, resource consumption and green-house gas

emissions. In doing so, Enterprise Ireland has caused Irish companies to react positively to

increased regulation, economic pressures to reduce waste and to the obligations of corporate

social responsibility. In order to measure this effect and determine the rate of change in

recent years, Enterprise Ireland has conducted an industry-wide study to measure existing

levels of environmental regulatory compliance and good practice.

This report deals specifically with Ireland’s indigenous engineering sector and involves 231

companies, as outlined in Table 1, that were assessed a total of 409 times between 1995 and

2010 (Appendix I provides a full listing of the participating companies). Of the 231

engineering companies included in this study 127 were assessed only once and 104 were

assessed more than once. 44 companies were assessed 3 or more times.


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1.2 Activities of Irish Engineering companies which may impact on the environment

1.2.1 Processes in metal fabrication and machine engineering

Of the overall Irish metals and plastics fabrication sector, the two sub-sectors which have the

greatest potential to impact on the environment are general metal fabrication and metal

fabrication in the context of machine engineering. The production processes which can have

the biggest environmental impact are forming and surface finishing as they tend to generate

industrial effluent, atmospheric emissions and wastes. Appendix II provides descriptions of

the various processes employed in metal fabrication such as forming, welding, surface

preparation and metal finishing.

1.2.2 Processes in plastics fabrication and machine engineering

Manufacturing of plastic products may or may not involve chemical reactions between

components. In non-reactive processes thermoplastic polymers are heated until molten,

shaped through a die or in a mould and cooled to obtain a solid product. In reactive

processes low-molecular-weight monomers or pre-polymers are polymerised in the mould in

the presence of suitable catalysts and additives. Reactive processes are employed with

thermosetting polymers and include Reaction Injection Moulding (RIM) of thermoplastic

polyamides by the fast anionic polymerization of lactams. Typical examples of polymeric

materials include:

• Thermoplastics Polyolefins such as polyethylenes (HDPE, LDPE) & polypropylenes,

styrenes (HIPS, ABS), vinyl (PVC), acrylics (PMMA), cellulosics, fluoroplastics (Teflon,

PVDF), polyesters (PET, PBT), polycarbonates, polyethers, polyamides (Nylon 6),

polyacetals, thermoplastic rubbers (SBS, SIS) and polyimides;

• Thermosets Polyurethanes, unsaturated polyesters, epoxydes and phenolics.

Appendix II provides descriptions of the various processes employed in plastics fabrication such

as reactive and non-reactive (moulding, extrusion) processes.

1.3 Assessing the environmental compliance in the Irish metal and plastic

fabrication sectors

Enterprise Ireland’s environmental assessments are conducted on-site by a specialist team.

The assessments focus on 6 main areas of compliance relating to:-

1) Industrial wastewater (see Section 2);

2) Atmospheric emissions and air quality (see Section 3);

3) The management of waste (see Section 4);

4) The storage and containment of hazardous materials (see Section 5);

5) Noise pollution (see Section 6); and

6) The general condition of the site and the working environment.


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A report is produced and a summary of the findings with relevant comments is sent to the

clients to indicate any areas where improvements are required. For the purposes of this study,

Enterprise Ireland has reviewed the results of 409 assessments conducted over the past 15

years on 231 engineering companies, 14 of which are now licensed by the EPA under the IPPC

Directive, with a view to:-

identifying the key areas where environmental compliance is an issue for Irish

engineering companies (atmospheric emissions, storage of hazardous materials,

management of waste, etc.);

determining whether compliance is based on regulation or on international best

practice guidelines and, in each case, who is the competent authority;

identifying the types of processes and activities that produce environmental impacts;

identifying and comparing the ways in which these environmental impacts can be

prevented and/or controlled;

comparing the performance of the different engineering sub-sectors (i.e. metal

fabrication, machine, precision and plastics engineering);

measuring changes in the levels of environmental compliance between 1995 and 2010

during which time Enterprise Ireland conducted 409 detailed assessments of 231

indigenous Irish engineering companies; and

determining the impact of Enterprise Ireland on the level of environmental compliance

by virtue of regular environmental reviews, by comparing companies that have been

assessed only once to those that have been assessed a number of times.


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2.0 Wastewater Treatment 2.1 Industrial wastewater from metal and plastic fabrication 2.1.1 Metal fabrication

Typical wastewater sources in metal fabrication include water-based cleaning and rinsing

streams; cooling waters; alternative cleaners; wastewaters from cutting, shot blasting,

deburring and mass finishing activities; and water-based metalworking fluid operations (see

Table 2).

Thermal treatments and hot work, including welding, may be followed by quenching in a liquid

media. The quenching bath is usually water or water-based and may contain chemical

additives such as organic solvents, phenols, oil and grease. Spent quenching baths may

include residuals of additives and their secondary products, suspended solids, and metallic

dross (e.g. oxides formed during solidification).

Wastewaters from wet scrubbers used in fume control may be highly alkaline or acidic in

nature and may contain metals and phenols. Thermal pollution from discharge of non-contact

cooling water can be avoided by using cooling towers or chillers. Metal machining fluids can

be petroleum-based, oil-water emulsions or synthetic emulsions.

Processes Air Emissions Process Wastewaters

Metal Shaping (metal cutting, grinding, forming)

VOCs from decomposing

lubricants, fumes and

cutting fluid mists

Waste machining fluids &

acids, alkali & solvent waste

Thermal Treatments (quenching and annealing)

Mists, VOC solvents and

particulates Contaminated quench fluids

Surface Preparation (welding, treating with abrasives, cleaning with solvents, emulsions, alkalis and acids)

Metal/metal oxide vapours,

dust, abrasive particles,

solvents, VOC, fumes and

acid/alkali vapours

Surfactants, emulsifiers,

detergents, terpenes, alkaline

or acid waste, and

cooling/quenching fluids

Surface Finishing (anodising, chemical conversion coating, electroplating, painting, polishing and etching)

Metal & acid fumes & mists,

ammonia, particulates and

solvents

Metal and acid or alkaline

waste (zinc, cyanide and

chromium)

Table 2 Engineering processes associated with metal fabrication and the resultant wastewater

and atmospheric emissions. Source : EHS Guidelines for Metal, Plastic and Rubber Products

Manufacturing, International Finance Corporation, World Bank Group, 2007

Metal plating wastes account for the largest volumes of metal-bearing and cyanide-bearing

wastes. Metal-bearing wastewaters are also generated in hot dip coating techniques (e.g.

galvanizing). Spent etching solutions can contain metals and acids. Painting processes


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generate solvent-bearing wastes and release solvents such as methyl-isobutyl-ketone,

toluene and xylenes. Anodising wastewaters can contain nickel acetate and non-nickel

sealers.

2.1.2 Plastics fabrication

Effluents from plastic fabrication processes may contain solvents, oils, water-soluble and

insoluble organic compounds released in the contact, processing and cleaning water and solid

particles with dimensions from <μm to several mms. Process wastewater used in the plastic

moulding/forming processes can be subdivided into either cooling (or heating) water for

plastics production; surface cleaning and wash water; and finishing operation water to remove

waste plastic material or to lubricate the product. The wide range of potential wastewater

contaminants from metal and plastics fabrication processes and the associated

prevention/treatment/removal/recycling strategies are described in Appendix III.

2.2 Environmental legislation for metal and plastics fabrication

2.2.1 Legislation

The Water Pollution Acts (1977 and 1990) and the Water Services Act (2007) are the primary

legislation relating to water management the purpose of which is to protect and improve the

current water quality status. Statutory responsibility for both water provision and water

management and protection rests with local authorities and the EPA. A large portion of water

regulation relates to the provision of safe drinking water. However, the legislation also

provides that all companies that generate industrial effluent (including cooling water and wash

water), regardless of volume, must be licensed to discharge to either a water course or to

sewer. Effluent Discharge Licences allow companies to discharge a controlled amount of trade

effluent to waters (Section 4) or to a public sewer (section 16), and are issued by the relevant

local authorities. When businesses apply to their relevant local authority for a licence they

will be required to provide details on the type and volume of discharge.

2.2.2 IPPC Licensed Companies

Large industrial activities require an Integrated Pollution Prevention Control (IPPC) licence

from the EPA (EPA Act 1992, Protection of the Environment Act 2003). This licence includes

provisions for wastewater discharges to water or sewer including discharge volumes,

temperature, pH and the concentration of pollutants. Legislation provides that engineering

companies must operate under an IPPC licence if they:-

(a) manufacture boilers, reservoirs and tanks and the manufacturing floor area exceeds

500 m2;

(b) engage in electroplating/metal cleaning in baths of over 30m3 in volume; or

(c) consume >10 tonnes per annum of organic solvents in surface coating operations.


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2.3 The effluent discharge compliance record of Irish Engineering companies

During the period of the study, the level of non-compliance with legislation concerning

industrial effluent by Ireland’s engineering sector increased from 13% (1995-1998) to 25%

(2002-2004) and fell to 7% non-compliance during 2008-2010. The increase in the level of

non-compliance between 1995 and 2004 can be explained by a group of new companies

unaware of their obligations to have an effluent discharge licence for any industrial effluent

regardless of source or quantity. This was followed by steep improvements in compliance as

companies responded to their raised awareness by:-

(1) securing the appropriate licence from the appropriate licensing authority;

(2) adhering strictly to obligations relating to monitoring and pre-treatment.

Non-compliance with wastewater regulation took the form either of (a) not having the

appropriate licence or (b) not adequately monitoring discharges (usually to sewer rather than

to water). This study demonstrates that, by a process of on-going assessments, Enterprise

Ireland assisted Irish engineering companies in receipt of grants to address their non-

compliance through:-

alerting them to be aware of their statutory obligations in relation to their industrial

effluents by notifying them of regulatory changes;

encouraging them to apply for the appropriate licence; and

encouraging them to invest in effluent pre-treatment/treatment/monitoring systems in

compliance with their licences.

Figure 1. Proportion of engineering companies (%) not complying with existing legislation

concerning the treatment and discharge of industrial effluent. Of a total of 231 companies and 409 assessments, 104 (45%) of companies were assessed more than once.

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The most marked improvements took place between 2005 and 2010 in the machine

engineering sector, where non-compliance was reduced from 17% to 0%, between 2002 and

2010 in plastics engineering, where non-compliance was reduced from 30% to 0%. Non-

compliance in the precision engineering between 2002 and 2010 fell from 33% to 9%. Metal

fabrication demonstrated no improvement between 1995 and 2010. On the contrary, non-

compliance actually increased from 15% to 16%. There was a notable spike in non-

compliances across several sectors, especially precision and plastics engineering, in the period

2002-2004. This is due to the fact that companies assessed for the first time during 2002-

2004 had more non-compliances than normal for those sectors.

Of the 104 companies that were assessed more than once, 15% were non-compliant at their

first assessment while only 7% remain non-compliant at their most recent assessment

although it should be noted that (a) the vast majority of the Irish engineering companies

discharge to sewer and (b) there was only one recorded case of an engineering company

exceeding its emission limit values.

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3.0 Atmospheric Emissions

3.1 Atmospheric emissions from metal fabrication

Metal fabrication processes can generate atmospheric emissions such as VOCs, fumes, mists,

metal oxide vapours, acid/alkali vapours, etc. (see Table 2). Air emissions from forming

processes include solvents and cooling/lubricant solutions, or vapours generated from

quenching (e.g. from oils and greases present on the surface of metals during plunge cooling)

and quenching bath emissions such as vapours/mists comprising water mixed with chemical

additives or synthetic oils.

Atmospheric emissions from welding processes relate directly to the material and the welding

method employed. They derive from the molten pool, the shielding gases, cored electrodes

reacting with the atmosphere and from burning of oils & greases present on the raw product.

Air emissions from surface cleaning relate to the evaporation of chemicals from degreasing,

cleaning, and rinsing. Particulate emissions may be generated by sand blasting and dry

surface grinding and these can include metallic particulates and oxides. Electrochemical

surface treatments produce air emissions, mists, and gas bubbles arising from heated fluids

which may contain metals and other substances present in the bath. During painting,

atmospheric emissions consist primarily of the organic solvents used as carriers for the paint.

Emissions also result from paint storage, mixing, application and drying.

Further details of potential atmospheric emissions and their sources from processes employed

in metal fabrication are contained in Appendix IV.

3.2 Atmospheric emissions from plastics fabrication

Particulate matter and VOCs can be found in atmospheric emissions from plastics

manufacturing processes. Handling of dry additives and granulation of polymers can release

particulates that can be prevented/controlled by filtering air exhaust from handling and

granulation areas and by capturing/controlling fugitive emissions through a primary cyclone

and a secondary bag-house or electrostatic precipitator.

Heating of thermoplastics during compounding/forming may result in the release of fine

aerosols. Furthermore, VOCs, including low-molecular weight additives and solvents, may be

released during compounding/forming operations, especially when heated. Shaping

operations release water vapour, low-boiling point additives and monomers trapped in the

polymer, especially at the hottest part in the processing line. Table 3 lists commonly

processed plastics and some of the constituents detected in fume when plastics are

processed, or heated, above their recommended upper process temperature. Unlike other


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thermoplastic processes, manufacturing of expandable polystyrene (EPS) products requires

that the raw materials be pre-conditioned prior to the final "tooled" moulding process. In the

conversion process, a small quantity of low-boiling point liquid, usually a pentane isomer

mixture (typically 3% - 8%), is used as a blowing agent. Potential emissions from the

processing of specific plastic types are listed in Table 3.

Commonly processed plastics

Constituents detected in fume during processing

Polyvinyl chloride (PVC) Hydrogen chloride, vinyl chloride monomer

Acrylonitrile-Butadiene-Styrene (ABS)

Styrene, phenol, butadiene

Polypropylene (PP) Aldehydes, butane, other alkanes, alkenes Acetals (POM) Formaldehyde

Low, Medium & High Density Polyethylene (LDPE, MDPE, HDPE)

Aldehydes, butane, other alkanes, alkenes

Polystyrene (PS) Styrene, aldehydes

Polyethylene terephthalate (PET)

Formaldehyde, methoxy benzene, benzaldehyde and VOCs

Table 3 Substances potentially released in plastics processing at high temperatures’.

Source : EHS Guidelines for Metal, Plastic and Rubber Products Manufacturing, International Finance Corporation, World Bank Group, 2007

Recommended pollution prevention and control systems for VOCs include:

Enclosed storage for all solvent fluids, cleaning fluids and low-boiling-point reagents;

Ventilation control systems at high processing temperature points along the

production line;

Local exhaust extraction systems and activated carbon adsorbers;

Recuperative/regenerative thermal oxidizers, regenerative catalytic oxidizers,

condensers or biofilters; and

Implementation of a Solvent Management Plan.

Further details of the potential emissions from plastics fabrication, their sources and

recommended measures for preventing and controlling such emissions can be found in

Appendix IV.


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3.3 Legislation and Best Practice Guidelines

3.3.1 The 1987 Air Pollution Act - Atmospheric Emission Licensing

Most industrial activities generate emissions to atmosphere, whether directly from the

process, through operation of support facilities such as boilers or through fugitive emissions.

However only a small proportion of such emissions are significant enough to warrant specific

licensing. Metal and plastic fabrication engineering processes that have the potential for

major emissions and may therefore be subject to licensing under Schedule 3 of the 1987 Air

Pollution Act include:-

The roasting & sintering of metal ores where plant capacity exceeds 1,000 tonnes per

annum;

The production of pig iron and crude steel;

The production of ferrous metals in foundries having melting installations with a

capacity of greater that 5 tonnes;

The production of compounds or alloys of magnesium or manganese;

The manufacture of glass or mineral fibre;

The manufacture of olefins, derivatives of olefins, monomers or polymers or other

organic intermediate products; and

Any chemical process in which any of the following basic inorganic chemicals are used

or generated – ammonia, bromine, carbon disulphide, chlorine, fluorine, hydrofluoric

acid, hydrogen chloride, hydrogen cyanide or hydrogen sulphide.

It should be noted that most of the processes, which are covered by the Air Pollution Act

(1987), are now subject to IPPC licensing under the Protection of the Environment Act 2003.

However, in situations where IPPC is not applicable, as is the case with 217 of the 231

engineering companies included in this study, a person operating any process or plant to

which the Air Pollution Act applies must have an atmospheric emissions licence. This is

obtained from the local authority in a manner similar to the procedure for obtaining a

planning permission or an effluent discharge licence (to waters) and involves similar

timescales. Any person may appeal a decision to An Bord Pleanala.

In practice, the number of licences issued to companies under the Air Pollution Act is very

small. The Act is now primarily used for establishing smokeless zones (Special Control

Areas), setting emission limit values for asbestos, combustion plant, controlling the sulphur

content of gas oil (0.05%), and the control of petroleum vapour emissions.

The Act itself obliges the company to use the best practicable means to limit/prevent an

emission and empowers the local authorities to serve a notice where complaints of air

pollution are received. However, for existing plant and other premises, this balance can vary

from sector to sector depending on the viability of the class of enterprise in question. As in


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the case of the Water Pollution Act, the licence is normally valid for at least three years and

subject to review where the nature of the emission or the ambient air quality has materially

changed or where there is significant modifications to an existing plant.

3.3.2 Emissions of Volatile Organic Solvents Regulation 2002 (Solvents Regulation)

“Emissions of Volatile Organic Compounds from Organic Solvents Regulations 2002” or the

Solvents Directive 1999/13/EC regulates the use of Volatile Organic Compounds (VOCs) with

a view to limiting the emissions of VOCs. This applies to industry activities using solvents in

volumes above specified solvent consumption thresholds per year and impact on the following

industrial engineering processes:-

Surface cleaning (2 categories);

Vehicle coating and refinishing;

Coil and other coating (metal, plastic, textile, fabric, film, paper);

Winding wire coating; and

Adhesive coating.

The Regulations are implemented through the Accredited Inspection Contractor (AIC) system

as follows:-

Activities with the capacity to use ≥ 10 tonnes/year of solvents require an IPPC

licence from the EPA.

Specified activities using < 10 tonnes/year and which are not an activity requiring

an IPPC licence (as defined in Schedule 1 of the Protection of the Environment Act

2003) may be required to operate under the Solvents Regulations.

Each activity category is assigned a solvent consumption threshold in tonnes/year above

which the Regulations apply. Further Solvents Regulation information relating to licensing,

fees, controls, emission limit values and the Solvents Reduction Scheme can be found in

Appendix V.

3.4 Non-compliance of Irish engineering companies and best practice guidelines on atmospheric emissions

During the period of the study, the overall level of non-compliance with legislation concerning

atmospheric emissions by Ireland’s engineering sector was reduced from 20% non-

compliance (1995-1998) to 4% non-compliance during 2008-2010 (see Figure 2).

The engineering sub-sector for which atmospheric emissions posed the least problems was

Plastics Fabrication where all of the companies assessed have been compliant since 1999.


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The Precision Engineering sub-sector showed a steady decline in non-compliances between

1995 and 2004 (14% to 11%) and has been fully compliant since 2005. The Metal

Fabrication and Machine Engineering sub-sectors, despite some fluctuations, each showed

steady declines in non-compliance between 1995 and 2010 from 23.5% and 25% to 6% and

8% respectively.

The main reasons why engineering companies failed to comply with legislation or with best

practice guidelines were:-

inadequate overspray collection, extraction or removal controls in spray-paint

shops;

inadequate fume extraction or removal controls from welding operations or

other fume generating processes;

inadequate controls in surface preparation (e.g. shot blasting) operations;

inadequate stack height;

non-compliance with solvent emission limits

Figure 2. Proportion of engineering companies (%) not complying with existing legislation and/or best practice guidelines concerning the atmospheric emissions. Of a total of 231 companies and 409 assessments, 104 (45%) of companies were assessed more than once.

The data indicate that plastics fabricators demonstrate higher overall levels of compliance

than metal fabricators and that atmospheric emissions from metal fabrication pose more

environmental issues and are less easily preventable that atmospheric emissions from plastics

fabrication.

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23

4.o Waste Management

Ireland has experienced dramatic changes in its waste management practices in the last

decade and now boasts an extremely sophisticated system of regulation. There are significant

financial and regulatory drivers in place to encourage companies to adopt waste minimisation

and recycling initiatives. Mandatory recycling initiatives are regularly rolled out and new

policies aim to restrict the use of disposal facilities such as landfill sites for the management

of commercial and industrial waste.

4.1 National Policy and Waste Management Planning

At national level, the Department of the Environment, Heritage and Local Government

(DoEHLG) is responsible for waste policy and legislation through the national laws and policy

statements. A significant proportion of national policy is governed by European Union (EU)

Directives which aims to move Irish waste management away from landfill into those options

that feature the upper echelons of the hierarchy (see Figure 3).

Figure 3. Hierarchy of Waste Management

The National Waste Prevention Task Force co-ordinates a range of national initiatives aimed at

waste prevention. The Waste Management Act 1996 is the main vehicle by which this policy

framework is enacted, through the provisions on waste collection, waste planning and

regulation. The Waste Management Act divides the responsibility for the regulation of waste

between the EPA and the local authorities.

_________________________________________________________________

http://www.environ.ie/en/


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24 _________________________________________________________________

4.2 The Waste Management Act 1996

The Act forbids the handling, transportation, recovery or disposal of waste when it is done in a

manner which causes environmental pollution. It also forbids the use of an unauthorised

waste collector or waste management facility. There is a duty to inform a local authority if

there is any loss, spillage or accident involving non-hazardous waste that may cause

environmental pollution to arise. Where hazardous waste is involved, both the local authority

and the EPA must be informed. In general, the penalties for the contravention of the Waste

Management Act are €1900 or prison sentences of up to 12 months. However, more serious

offences can be subject to fines up to €12.7 million and imprisonment of up to 10 years.

Further details of the legislation and regulations governing waste management are provided in

Appendix V.

4.3 Waste management in Irish industry

4.3.1 Metal Fabrication and Related Businesses

Metal fabrication and related operations such as wastewater treatment and fume reduction

may generate solid or liquid wastes. These include metal-bearing sludges (due to oxide

scales formed during thermal treatments), scrap metal, metal-bearing cutting fluids and

sludges and solvent-still bottom wastes. Scrap metal consists mainly of metal removed from

the intermediate piece (e.g. steel) and may be combined with small amounts of metalworking

fluids (e.g. cooling or lubricant liquids) used prior to and during the metal shaping operation

that generates the scrap. This type of scrap is typically reintroduced as a feedstock. Welding

slags, dusts and powders may contain various metal oxides depending on the base metals

and their coatings.

Surface preparation activities result in the generation of solid wastes (e.g. sludges, still-

bottoms, cleaning tank residues, machining fluid residues). Anodizing, chemical conversion

coating, electroplating and painting may generate a number of spent solutions and

wastewaters whose treatment may result in the production of sludges, base metals, metal

oxides and several types of reactive compounds. Polishing, hot deep coating, etching and

other metal finishing techniques generate the same wastes as anodizing, but with the addition

of polishing sludges, hot dip tank dross and etching sludges.

Pollution prevention and control measures include:

Separating metal dust or scrap by type to promote recovery and recycling;


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25 _________________________________________________________________

Reducing and treating slags from welding, forging, machining, and mechanical

finishing, which may contain metal ions; and

disposal of sludge from surface finishing processes (e.g. galvanizing, painting, hot

dip).

4.3.2 Plastics Engineering

Plastics manufacturing is not normally associated with significant quantities of solid waste as

scrap materials from shaping/finishing operations are usually recycled. Thermoplastic

polymers tend to be reground and mixed with virgin materials.

4.4 Non-compliance of Irish engineering companies with regulations and best practice guidelines on waste management

During the period of the study, the level of non-compliance with legislation concerning the

management of waste by Ireland’s engineering sector improved consistently from 1995 to

2010 (10.5% non-compliance in 1995-1998 to 2% non-compliance in 2008-2010; see Figure

4). The most significant improvements were recorded by the machine engineering sub-sector

where non-compliance was reduced from 25% in 1995-1998 to 0% in 2008-2010. Plastics

fabrication recorded the next most significant improvement from 22% (1999-2001) to 5%

(2008-2010). Non-compliance by the metal fabricators improved steadily from 10% (1999-

2001) to 0% (2008-2010) while, apart from a few cases in 2002-2004, the precision

engineering sector has always been compliant. This is partly due to the fact that processing

waste from plastic fabrication can be reground and reused.

Not making adequate provisions for the disposal of either non-hazardous (e.g. packaging) or

hazardous waste (e.g. dross, phosphating solutions and packaging material) accounted for the

majority of regulatory non-compliances with regard to waste. Here inadequate provisions

included open burning, land-filling and tipping instead of segregation, reuse and recycling.

Other reasons why engineering companies failed to comply with waste regulation include

storing waste for too long on-site and not ensuring that waste management contractors had

the appropriate waste collection/storage permit.


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26

Figure 4. Proportion of engineering companies (%) not complying with existing legislation and/or best practice guidelines concerning waste management. Of a total of 231 companies and 409 assessments, 104 (45%) of companies were assessed more than once.

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27

5.0 Storage of Hazardous Materials

Introduction

The overall objective of hazardous materials management is to avoid or, when avoidance is

not feasible, minimise uncontrolled releases of hazardous materials or accidents (including

explosion and fire) during their production, handling, storage and use. Facilities that store or

handle hazardous materials at, or above, threshold quantities, require special treatment to

prevent accidents such as fire, explosions, leaks or spills and to prepare and respond to

emergencies. Oil water separators and grease traps should be installed and maintained as

appropriate at refuelling facilities, workshops, parking areas, fuel storage and containment

areas.

Details on preventative and control measures for hazardous waste spill prevention (e.g.

overfill protection & secondary containment) and explosion prevention can be found in

Appendix V.

5.1 Non-compliance with regulation and best practice guidelines concerning the storage of hazardous materials

During the period of the study, the level of non-compliance with legislation concerning the

storage of hazardous materials by Ireland’s engineering sector improved consistently between

1995-1998 and 2008-2010 for metal fabrication (59% to 29% non-compliance) and for

machine engineering (61% to 33% non-compliance).

Figure 5. Proportion of engineering companies (%) not complying with existing

regulatory/best practice guidelines concerning the storage of hazardous materials. Of a total of 231 companies and 409 assessments, 104 (45%) of companies were assessed more than once.

_________________________________________________________________


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28 _________________________________________________________________

The most marked improvements in compliance levels were for the plastics engineering and

precision engineering sub-sectors over that period with reductions in non-compliance from

76% to 38% in plastics fabrication and 62% to 41% in precision engineering. However,

despite these significant improvements, storage of hazardous materials, especially liquid

hazards such as fuel oils, lubricating oils, hydraulic fluids, solvents, acids, etc. remains the

most significant area of environmental non-compliance in Ireland’s engineering sector and is

responsible for 57% of all non-compliances during the past 15 years.

Inadequate provisions for secondary containment (i.e. bunds) on storage vessels for

hazardous liquids such as fuels and solvents accounted for >90% of all storage non-

compliances. Failure to maintain bunds also contributed to overall non-compliance in these

companies. In most cases, non-compliance resulted from only one storage tank not being

bunded. Other reasons include failure to provide adequate facilities to safely store flammable

liquids such as solvents and paints and, to a considerably lesser extent, inadequate integrity

testing of storage containers.

6.0 Noise This section addresses impacts of noise beyond the property boundary of the facilities. Worker

exposure to noise is a matter for Occupational Health and Safety.

6.1 Prevention and Control

Details of measures for preventing and mitigating noise can be found in Appendix V.

6.2 Non-compliance with best practice guidelines concerning the noise pollution

In general, specific noise limits are only imposed on companies in IPPC licences issued by the

EPA. Apart from one metal fabrication company which, in 2000, was found not to comply with

best practice, all of the engineering companies included in this study comply with best

practice guidelines relating to the control and prevention of noise pollution.


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29

7.0 Overall Sectoral Performance

Overall the Irish engineering sector has performed very well with marked improvements in

compliance with regulatory and best practice guidelines relating to atmospheric and

wastewater emissions, waste management, noise and the general condition of the site (see

Figure 6)

Figure 6. Proportion of engineering companies (%) not complying with existing regulatory/best practice guidelines concerning the storage of hazardous materials. Of a total of 231 companies that were assessed 409 times, 45% were assessed more than once.

7.1 Storage

Non-compliance with best practice guidelines concerning the storage of hazardous materials

(primarily fuels, lubricants and solvents) accounted for 57% of all non-compliances recorded

since 1995. Despite significant improvements during the period of the study, non-compliance

with best practice guidelines on the storage of hazardous liquids remains a problem with 34%

of engineering companies still having issues during the period 2008-2010. In most cases,

companies were found to be non-compliant because they failed to bund one or more storage

vessels (usually just one) with the resultant risk of ground pollution in the event of a major

leak or catastrophic failure. It is worth pointing out, however, that only companies operating

under an Effluent Discharge Licence are required by law, as part of the groundwater pollution

prevention provisions of their licence, to bund their storage vessels. Engineering companies

that don’t have an Effluent Discharge Licence have no specific legal condition to comply with

but are required to bund their hazardous liquid storage vessels under best practice guidelines.

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30 _________________________________________________________________

7.2 Effluent Discharges

The next most significant area of non-compliance experienced by the Irish engineering sector

during the period of this study concerns industrial effluent and accounted for 17% of all non-

compliances recorded since 1995. The law states that all industrial effluent discharges to

waters or local authority sewer systems must be made in accordance with the requirements of

a relevant local authority discharge licence (or the conditions of an IPPC/waste licence in

cases where the EPA licenses the activity). In fact, most of the engineering companies

included in this study discharge only modest levels of industrial effluent to local authority

sewers. In return, the local authority charge them an annual fee to treat the discharge.

Most compliance issues arise from the company either not having the appropriate licence or

not adequately monitoring the discharge. Licences are subject to specific operational

conditions and, as a general rule, once they have the appropriate licence, most engineering

companies adhere to the terms of their licences.

Very few Irish engineering companies included in this study are licensed to operate on-site

wastewater treatment facilities and to discharge treated effluent to water. Only 14 of the 231

companies in this study are of a sufficient scale that they operate under an IPPC licence from

the EPA.

7.3 Atmospheric Emissions

The next most significant area of non-compliance experienced by the Irish engineering sector

during the period of this study concerns atmospheric emissions and accounted for 15% of all

non-compliances recorded since 1995.

Most industrial activities, including metal and plastic fabrication, generate emissions to

atmosphere (see Section 3) but only a small proportion of such emissions are significant

enough to warrant specific licensing. Certain large scale metal and plastic fabrication

engineering processes have the potential for major emissions and may therefore be subject to

licensing under the 1987 Air Pollution Act, however, none of the Irish engineering companies

are considered to fall into this category.

In fact, most of the processes covered by the Air Pollution Act, 1987 are now subject to IPPC

licensing and only 14 of the 231 companies in this study come under EPA control. The Act

itself obliges the company to use the best practicable means or “best available technology not

entailing excessive costs” to limit/prevent an emission. “Best practicable means” has

different meanings for new plant and for existing plant in terms of the balance between

technology, the environment and costs.

Regardless of the requirement for a licence, all companies are obliged to extract any

dangerous gases, vapours, fumes or dusts from the workplace for health and safety reasons.


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31 _________________________________________________________________

These extractions should be vented to atmosphere through a stack of sufficient height to

adequately disperse the emissions to prevent local air pollution, under the general provisions

of the Act. Failure to comply properly with these provisions was the cause of the non-

compliances recorded.

Total Compliance

The sub-sector which demonstrated the highest level of overall compliance (i.e. fully

compliant with atmospheric and wastewater emissions, waste, storage, noise and site) was

the plastics engineering (57%) followed by machine engineering (56%), metal fabrication

(49%) and precision engineering (46%). It was found that only 32% of engineering

companies assessed for the first time were likely to be fully compliant, whereas 59% of

companies assessed more than once were likely to be fully compliant at the last assessment.

Area of compliance

% of non-compliances

Reasons for non-compliance

Storage 57% Inadequate secondary containment Inadequate integrity testing Flammable liquid provisions

Effluent Treatment

17%

No effluent discharge licence Inadequate discharge monitoring Inadequate treatment systems Exceeding emission limit values

Atmospheric Emissions

15%

Inadequate extraction/ventilation Inadequate stack height Inadequate overspray collection

Waste Management

6.6%

Inadequate disposal open burning, land-filling and tipping. Inadequate management of hazardous waste

Site 4.1% Poor condition of factory site

Noise 3.1% Excessive noise at boundary

Table 4. Breakdown of the main areas where EI’s engineering clients were non-

compliant with either legislation or best practice


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32 _________________________________________________________________

Appendix I

Participating Companies

(IPPC-licensed companies in bold)

AJ Precision Ltd. Burnside Eurocyl Ltd. Flanco Engineering Ltd. Abbey Farm Machinery Burnside Hydracyl Ltd. Flexi-Fabrications Ltd. Abbey Rollers Ltd. BW Design Workshop Ltd Flexitech Ltd. Accutool Ltd. Byrne-Mech Ltd. Flow Technology Ltd. Ace Compaction Ltd. C & C Springs Ltd. Foamalite Ltd. Aclare Plastics Ltd. C & F Tooling Ltd. Formtech Tooling & Design Ltd. AED Ltd C & G Engineering Ltd. Freefoam Plastics Ltd. Agri & Industrial Rubber CL Precision Ltd. Frentech Engineering Ltd. Athlone Extrusions Ltd. Cantwell Electrical Eng Ltd. Fuchsia Homes Ltd. Aircold Ltd. Caragh Tool & Die Ltd G & G Engineering Ltd. Aisle Master Ltd. Carbery Plastics Ltd. G & M Steel Fabricators Ltd. Allbrite Engineering Ltd. Carson Industries Ltd. G & S Stainless Steel Ltd. Allied Turned Parts Ltd. Cashels Engineering Ltd. Garmoore Ltd. Alpha Precision Ltd. Castit Ltd. Gem Plastics Ltd. Ancofer Electrical Ltd. Clare-Pak Ltd. Glenfield Eng Co. Ltd. APA Systems Ltd. Clonmore Manuf. Ltd. Global Stainless Ltd. Aqua Design Ltd. Combilift Ltd. Global Steel Manuf Ltd. Architectural Aluminium Compressed Air Centre Gradal Engineering Ltd. Archway Products Ltd. Concrete & Quarry Eng Manuf

Services Ltd. Harte Designs Ltd.

Arrowcrest Ltd. Connabride Plastics Ltd. HDS Energy Ltd. ATA Tools Group Ltd. Conor Engineering Ltd. Heatonsgrove Ltd. Atto Abrasives Ltd. Consort Case (Ire) Ltd. Hennessey Environmental Services Ltd. Aughey Plant Intl Ltd. Cork Plastics Ltd. Highway Safety Developments Ltd. Auto Conversions Ltd. Cross Agri Engineering Ltd Hiltone Engineering Ltd. Automatic Plastics Ltd. Daniel Whelan Engineering Works Hi-Spec Engineering Ltd. Automation & Tooling Specialists Ltd.

Dawnlough Ltd. Holfeld Plastics Ltd.

AWP Engineering Ltd. Delmec Engineering Ltd. Hydro International Ltd. BA Engineering Ltd. Dennison Trailers Ltd. Inishowen Engineering Manufacturing

Ltd. Baileboro Foundry Ltd. Design Partners Consultancy Ltd. Inmo-Tech Ltd. Ballinadee Engineering Ltd. Dortek Ltd. Innovative Products Ltd. Ballytherm Ltd. Douglas Engineering Ltd. Instant Upright Ltd. BCD Engineering Ltd. Dromone Engineering Ltd. Insulated Chimneys Ltd. Bellurgan Precision Engineering Ltd.

Duggan Profiles Ltd. IO Systems Ltd.

Belmont Plant & Equipment Dunreidy Engineering Ltd. Iralco Ltd. Benson Engineering Ltd. Eirtech Support Services Ltd. Irish Custom Extruders Bolger Engineering Ltd. ELC Laser Group Ltd. Irish Dairy Services Ltd. Bonnar Engineering Ltd. Electrical & Pump Services Ltd. Iron Images Ltd. Brennan Fencing Ltd. Enplast Ltd. Jetwash Ltd. BS Manufacturing Ltd. Fenlon Engineering Ltd. JFC Technologies Ltd. Burnside Autocyl Ltd. Flair International Ltd. Jimmy Mullins Engineering Ltd


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33 _________________________________________________________________

Participating Companies

(IPPC-licensed companies in bold)

JN Cummins Engineering Ltd. Murray Design & Engineering Ltd. Sky Clad Ltd. John Byrne Conveyors & Packaging Ltd.

NDT Services Ltd Slieve Foy Tool and Die

John F Dunne Engineering Noone Engineering Ltd. Sligo Tool & Die Ltd. K Plastic Products Ltd. Now-A-Tow Ltd. Smallwares Ltd. Kells Stainless Ltd. Nypro Ltd. Smithstown Light Engineering Ltd. Kelly Precision Ltd. O'Donovan Engineering Co. Ltd SMT Centre Ltd. Kel-Tech Engineering Ltd. ODS Steel Manufacturing Ltd. Solids Technology Ltd. Kent Stainless Ltd. Oglesby & Butler Ltd. Solution Equipment Ltd. Kerry Die Products Ltd. OMC Engineering Ltd. Somerby Ltd. Kilkenny Cooling Systems Ltd PMG Tooling Services SPMT Ltd. Killalla Precision Components Ltd. PB Machine Tech Ltd. Stamina Tools Ltd. Killarney Plastics Ltd. PlateTek Engineering Ltd. Sturdy Products Ltd. Killarney Precision Engineering Ltd Prenco Manufacturing Ltd. Suretank Ltd. Kingspan Building Products Ltd. Pressco Jig & Tool Co Ltd. T Butler Engineering Ltd. Kingspan Insulation Ltd. Prism Engineering Ltd. Takumi Precision Engineering Ltd. Lampost Construction Co. Ltd. Procut Engineering Processes Ltd. Taltech Engineering Ltd. Larkin Engineering Ltd. Protech Performance Plastics Ltd. Tanco Engineering Co. Ltd Laserplant (Ire) Ltd. Pro-Tek Medical Ltd. Techniform Ltd. Liscarroll Engineering Ltd. Provac Ltd. Tegan Innovations Ltd. LSM Engineering Ltd. Puretech Ltd. Thermo Door Ltd. MJ Quinn Ltd. Quality Plastics Ltd. Thermoframe Ltd. Mac Fab Systems Ltd. Quinn Packaging Ltd. Tim Crowley Ltd. Machine Engineering Ltd. Quinn Therm Ltd. Tobin Engineering Ltd. Major Equipment Ltd. Redwood Hydraulics Ltd. Tocana Ltd. Mallow Road Engineering Ltd. Richard Keenan Ltd. Tool & Plastic Industries Ltd. Malone Farm Mach Ltd. Roche Manufacturing Ltd. Torc Precision Engineering Ltd. McAree Engineering Works Ltd. ROM Plastics Ltd. Triace Ltd. McDonald International Ltd Rossmore Engineering Ltd. Tritech Precision Ltd. McHale Engineering Ltd. Roto Spiral Ltd. TSS Manufacturing Ltd. Meath Metal Products Ltd. Sanbra Fyffe Ltd. Turbo Fixings Ire Ltd. Mergon International Ltd Sandford Ventilation Ltd. Ulando Ltd. MI Flues Ltd. Sanritsu Mobilon Ltd. Valley Forge Ltd. Michael Tighe Engineering. Ltd Scafftex Manufacturing Ltd. Value Tech Ltd. Modular Automation Ireland Ltd. Schiedel Chimney Systems Ireland

Ltd. Vistamed Ltd.

Monread Truck Bodies Ltd. Schivo Precision Ltd. Waterford Castings Ltd. Mould & Tool Specialists Ltd. Seamless Aluminium Ltd. Wright Window Systems Murphy Stainless Steel Specialists Ltd.

Securi-Cabin Ltd. Xtratherm Ltd.


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34 _________________________________________________________________

Appendix II

Processes Employed in Metal and Plastics Fabrication

Forming and finishing techniques employed in Metal Fabrication

Metal fabrication operations addressed in this report fall into 2 groups - forming (including

thermal treatments) and finishing (including surface treatments, metal cleaning and coating).

Heat treating with controlled heating and cooling cycles (e.g. quenching, tempering) modifies

the physical properties of the metal product. The metal may be hot-worked, cold-worked, or

both, to produce specific shapes. During cold deformation, an intermediate heat treatment

(e.g. annealing) may be applied to eliminate hardening and maintain the malleability of the

metallic material. Following heat treatment, the surface is cleaned of rust, scales and

scrapes. Fabricating processes usually employ cutting fluids (e.g. ethylene glycol),

degreasing and cleaning solvents, acids, alkalis and heavy metals. Oils are typically used

when forming and cutting the metal.

Welding

There are more than 20 types of welding including furnace and oxyacetylene flame, plasma

torch, laser and electron beam, however, manual metal arc welding (using a flux-coated

electrode) and gas metal arc welding (using a wire electrode gas-shielded from the external

atmosphere) are the most widely used and constitute ~70% of all welding.

Surface Preparation

Cleaning of metal surfaces prior to finishing treatments (e.g. coating, painting, chemical

deposition) may involve simple abrasive blasting using high pressurized water and abrasive

powders (e.g. alumina, silica), air blast, and/or abrasive paper (with or without water as a

lubricant and cooler). Alkaline cleaning solutions consist of (1) builders (e.g. alkali hydroxides

and carbonates), (2) organic or inorganic additives and (3) surfactants. Alkaline cleaning is

often assisted by mechanical action, ultrasonics or by electrolysis and can be used to remove

organics.

Acid cleaning is used for near-final preparation of metal surfaces before electroplating,

painting and other finishing processes. Acid pickling is commonly used to remove the scale

from semi-finished mill products. Most carbon steel is pickled with H2SO4 or HCl while

stainless steel is pickled with HCl or HF. Multi-stage chemical cleaning processes employ

organic solvents to degrease the surface of the metal. Emulsion cleaning, for example, uses

kerosene, mineral oils, and glycols dispersed in an aqueous medium.


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35 _________________________________________________________________

Metal Finishing

Anodizing is an electrolytic process which confers metal surfaces with an insoluble

oxide coating. The most common aluminium anodizing process employs H2SO4.

Metal parts are then rinsed and sealed using chromic acid, nickel acetate, nickel-cobalt

acetate and hot water.

Chemical Conversion Coating includes chroming, phosphating, metal colouring and

passivating. Chromate conversion coating usually employs hazardous hexavalent

chromium and other compounds which react with the metal surface to form a layer

containing a complex mixture of chromium, other constituents, and base metals.

Phosphate coatings are formed by immersing steel, iron or zinc-plated steel in a

diluted solution of phosphate salts, phosphoric acid and other reagents.

Electroplating is the production of a surface coating of one metal upon another

through electro-deposition. The most commonly electroplated metals and alloys

include brass (copper-zinc), cadmium, chromium, copper, gold, nickel, silver, tin, and

zinc. During electroplating, metal ions in aqueous solution are chemically reduced onto

the metal surface. The metal ions in the solution are usually replenished by the

dissolution of metal from solid metal anodes or by direct replenishment with metal

salts or oxides. Sodium or potassium cyanide is used as a complexing agent for

cadmium and precious metals electroplating.

Painting involves the application of predominantly organic coatings to a work piece

for protective and/or decorative purposes. Paint is applied in various forms, including

dry powder, solvent-diluted formulations and water-borne formulations. Various

methods of application (spray painting, electro-deposition) are used.

Other Metal Finishing Techniques Polishing removes or smooths out surface

defects that can adversely affect appearance or function. Subsequent cleaning and

washing can produce wastewaters containing metals. Hot dip coating (e.g.

galvanising) involves immersing a metal part into a molten bath of another metal (in

this case zinc) to provide a protective film. Water is used for rinsing following pre-

cleaning and for quenching after coating. Wastewaters generated by these operations

often contain metals.


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36 _________________________________________________________________

Processes Employed in Plastics Fabrication

Manufacturing of plastic products may or may not involve chemical reactions between

components. In non-reactive processes thermoplastic polymers are heated until molten,

shaped through a die or in a mould and cooled to obtain a solid product. In reactive processes

low-molecular-weight monomers or pre-polymers are polymerised in the mould in the

presence of suitable catalysts and additives. Reactive processes are employed with

thermosetting polymers and include Reaction Injection Moulding (RIM) of thermoplastic

polyamides by the fast anionic polymerization of lactams.

Typical examples of polymeric materials include:

Thermoplastics Polyolefins such as polyethylenes (HDPE, LDPE) & polypropylenes,

styrenes (HIPS, ABS), vinyl (PVC), acrylics (PMMA), cellulosics, fluoroplastics (Teflon,

PVDF), polyesters (PET, PBT), polycarbonates, polyethers, polyamides (Nylon 6),

polyacetals, thermoplastic rubbers (SBS, SIS) and polyimides;

Thermosets Polyurethanes, unsaturated polyesters, epoxydes and phenolics.

Non-reactive plastic processes

Non-reactive plastic processes are the most common procedures in polymer manufacturing.

The polymer, obtained through separate polymerization reactions, is supplied in pellet or

powder form. Additives are mixed with the plastic materials in a compounding/mixing step to

yield a final product with the desired characteristics. Plastic additives and their functions

include:

Lubricants to assist in moulding and extruding;

Antioxidants to inhibit oxidation;

Antistats to impart electrical conductivity and prevent electrostatic charge

accumulation;

Blowing agents (foaming agents) to produce a cellular structure;

Colourants to impart colour to the resin;

Nucleating agents and clarifiers to speed-up the solidification during cooling of the

molten polymer and increase the transparency;

Flame retardants;

Heat stabilizers to maintain the chemical and physical properties;

Impact modifiers to prevent brittleness and cracking;

Plasticisers to increase flexibility and workability;

Ultraviolet stabilizers (UV light absorbers) to absorb or screen out ultraviolet

radiation thus preventing degradation.

The manufacture of thermoplastic products usually involves: (1) imparting characteristics to

plastic resin with chemical additives; (2) converting pellets, granules, powders, sheets, fluids


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37 _________________________________________________________________

or pre-forms into either intermediate or final shapes or parts via moulding; and (3) applying

finishing treatments. Granulators are used to recover uncontaminated rejected parts and

scrap material into chips or pellets suitable for mixing with virgin feed in the extruder. To

form solid plastics products, a variety of moulding processes are used, as follows:

Injection moulding: Plastic granules or pellets are heated and homogenized by an

Archimedean screw, rotating in a heated cylinder, which pumps the molten polymer

towards the end of the screw. A hydraulic ram then injects this material into a cold

mould where the plastic solidifies.

Extrusion: Plastic pellets or granules are fluidized, homogenized, and formed

continuously as the extrusion machine feeds them through a die. Extruding is often

combined with post-extruding processes such as blowing, thermoforming, or

punching.

Blow moulding: Here an extruded plastic tube is trapped within a hollow mould and

compressed air is injected to cause the still-molten plastic to form to the mould. The

solid product is then ejected from the mould. Films are formed by extruding a tube,

which is then inflated to form a thin vertical film bubble, and cooled and rolled for

subsequent processing.

Thermoforming: Heat and pressure (or vacuum) are applied to plastic sheets placed

over moulds to confer on it the shape of the mould.

Rotational moulding: Finely ground plastic powders are heated in a rotating mould

to obtain a melt with low viscosity. When the inner surface of the revolving mould is

evenly coated with the molten resin, the mould is cooled and a scrap-free hollow

product is obtained.

Compression and transfer moulding: Plastic powder or a preformed plastic part is

plugged into a mould cavity and compressed with pressure and heat until it takes the

shape of the cavity. Transfer moulding is similar, except that the plastic is liquefied in

one chamber and then injected into a closed mould cavity by a hydraulically operated

plunger.

Calendering: Plastic parts are squeezed between two rolls to form a thin, continuous

film.

Reactive Plastic Manufacturing Processes

To produce a thermoset plastic material, liquid resins undergo catalysis followed by curing to

produce a finished part. Once cured, the part cannot be changed or reformed, except for

finishing treatments. Resins include urethane, epoxy, polyester, acrylic, phenolic and amino

resins. Fillers and additives are added to the resin-catalyst mixture prior to moulding to

increase product strength and performance and to reduce cost. Most thermoset plastic

products contain large amounts of fillers (up to 70%) such as mineral fibres, clay, glass

fibres, wood fibres and carbon black. Several other ingredients such as curing agents,

accelerators, reactive diluents, and pigments are also used. Various moulding options can be


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38 _________________________________________________________________

employed including vacuum, press, and rotational moulding, hand-lamination, casting and

encapsulation, spray-up lamination, resin transfer moulding, filament winding, injection

moulding and reaction injection moulding.

Foamed Plastics

There are three types of foamed plastic, i.e. blown, syntactic, and structural, and all can be

produced using injection, extrusion, and compression moulding to create foam products in

many of the same shapes as solid plastics products. Blown foam is an expanded matrix,

similar to a natural sponge. Syntactic foam is the encapsulation of hollow organic or inorganic

microspheres in the plastic matrix, and structural foam is a foamed core surrounded by a solid

outer skin. Structural foam plastic is made by injecting moulding liquid resins that contain

chemical blowing agents. Welding, adhesive bonding, machining, and surface decoration are

used to finish the product.


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39 _________________________________________________________________

Appendix III

Potential wastewater emissions and their sources in metal

and plastics fabrication

Potential wastewater emissions and their sources in metal fabrication

Typical wastewater sources in metal fabrication include water-based cleaning and rinsing

streams, cooling waters, alternative cleaners, wastewaters from cutting, shot blasting,

deburring and mass finishing activities, and water-based metalworking fluid operations.

Thermal treatments and hot work, including welding, may be followed by quenching in a liquid

media. Quenching baths are usually water or water-based and may contain chemical

additives such as organic solvents, phenols, oil and grease. Spent quenching baths may

include residuals of additives and their secondary products, suspended solids, and metallic

dross (e.g. oxides formed during solidification). Wastewaters from wet scrubbers used in

fume control may be highly alkaline or acidic in nature and may contain metals and phenols.

Thermal pollution from discharge of non-contact cooling water can be avoided by using

cooling towers or chillers. Metal machining fluids can be petroleum-based, oil-water

emulsions or synthetic emulsions.

Hot dip coating techniques such as galvanizing require water for rinsing following pre-cleaning

and for quenching after coating. This can result in a solid oxide dross waste and metal-

bearing wastewaters. Etching solutions comprise strong acids or bases and spent etching

solutions can contain metals and acids. Metal plating and related wastes account for the

largest volumes of metal-bearing wastes (e.g. cadmium, chromium, copper, lead, and nickel)

and cyanide-bearing wastes. Painting processes generate solvent-bearing wastes and release

solvents such as methyl-isobutyl-ketone, toluene and xylenes. Wastewaters from anodizing

can contain nickel acetate and non-nickel sealers. Other potential pollutants include

complexers and metals, which may be combined with other metal finishing wastewaters and

treated onsite by conventional hydroxide precipitation. Wastewaters containing hexavalent

chromium (e.g. from chemical conversion coating) should be pre-treated to reduce it to its

trivalent state. The conventional treatment process generates a sludge that is usually sent

off-site for metals reclamation/disposal.

Methods for Wastewater Management & Pollution Prevention in Metal

Fabrication

Effluents can be differentiated into separate streams including (a) wastewaters potentially

impacted by oils and solvents; (b) surface treatment / finishing wastewaters; and (c) metal

containing wastewaters.


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40 _________________________________________________________________

Oil-based effluents:

Separate oil-based effluents from wastewater;

Employ standardised oil types;

Extend the life of cooling liquids using centrifuges, disk or belt skimmers and biocides.

Prevent solvent-contamination of cutting oils;

Recycle oil quench baths by removing metals;

Recover metal-working fluids using drip pans; and

Reduce grease accumulation in cold forming by automatic oiling.

Solvent and water-based effluents:

Prevent spills and fugitive emissions of solvents (see Section on Storage).

Employ less hazardous degreasing agents (e.g. petroleum solvents & vegetable

cleaning agents) and counter-current solvent cleaning (i.e. clean with dirty prior to

fresh solvent); clean metals with aqueous non-VOC-containing alkali.

Recycle spent degreasing solvents on site, reuse batch stills and waste solvents; cold

clean with recycled mineral spirits prior to final vapour degreasing;

Recover acids in wastewaters through evaporation;

Reduce rinse contamination via drag-out using surfactants and other wetting agents;

Use mechanical cleaning techniques instead of chemicals where possible (e.g. a

vibrating abrasion apparatus for brass rather than acid pickling; mechanical scraping

instead of acid solution to remove oxides of titanium; and rotating brush machines

with pumice to clean copper sheets);

Reduce dissolved metal ion concentrations by reverse osmosis/ precipitation; use non-

chromate solutions for alkaline etch cleaning of wrought aluminium; use sulphuric

acid/hydrogen peroxide dip instead of cyanide and chromic acid dip for copper-bright

dipping process);

Replace acid/alkaline pickling solutions with alternative cleaning agents;

Use flow restrictors / control meters to activate rinse;

Treat/recycle process wastewaters using ion exchange, reverse osmosis, electrolysis

and electrodialysis with ion exchange.

Surface treatment/finishing wastewaters:

Substitute strong complexing agents like EDTA and toxic surfactants like NPE and

PFOS with less hazardous alternatives;

Regenerate anodizing and alkaline silking baths by recuperation of metallic (e.g.

aluminium) salts through use of hydrolysis of sodium aluminate;

Minimise wastewater in painting by correct sequencing (light to dark) and appropriate

spraying techniques (e.g. electrostatic finishing instead of conventional air spray);

Avoid and substitute the use of chlorinated solvents with non-toxic or less toxic

solvents as cleaning agents;


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41 _________________________________________________________________

Substitute chromic acid and tri-sodium phosphate with less toxic and non fuming

cleaners (e.g. sulphuric acid and hydrogen peroxide), and cyanide cleaners with

ammonia;

Employ less toxic bath components (e.g. zinc in place of cadmium in alkaline/saline

solutions; nitric or hydrochloric acids in place of cyanide in certain plating baths; zinc

chloride in place of zinc cyanide);

Install drain boards, drip guards, drip bars and dedicated dragout tanks after process

baths.

Metals in wastewater:

Reduce consumption of hazardous raw materials by minimising water use;

Separate wastewaters with recoverable metals from other wastewaters and recover

metals using electrolytic cells or hydroxide precipitation;

Continuously regenerate metal pickling baths by electrolysis and metal recovery;

Recover metals from bright dipping solutions using ion exchange (Cu) or by

segregating phosphates from treatment of aluminium-based alloys;

Solutions containing cyanide salts (e.g. for hardening processes) should be replaced

with solutions using a fluidized bath of nitrogen and corundum;

Substitute hexavalent chromium in plating or employ closed loops and covered vats to

minimize emissions.

Potential wastewater emissions and their sources in plastics fabrication

Potential wastewater emissions plastics fabrication include solvents, oils, water-soluble and

insoluble organic compounds released in the contact, processing and cleaning water, and solid

particles (<1μm - <10mm). Process wastewaters from plastics moulding/ forming include

Cooling/heating water (high temperature, can contain toxics such as phthalates)

Surface cleaning & wash water (high BOD/COD, suspended solids and organic carbon,

oil & grease, zinc)

Finishing water to remove waste plastic and/or lubricate the product (suspended solids

and phthalates)

Methods for Wastewater Management & Pollution Prevention in Plastics

Fabrication

Recommended pollution prevention options for contact, cleaning, and finishing wastewaters

include:

Good housekeeping practices;

Activated carbon to remove soluble organics, including phthalates;

Biodegradable plasticizers where possible;

Remove suspended solids, oils and grease from cleaning and finishing water using

sedimentation/settling units; and


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42 _________________________________________________________________

Minimise cooling water consumption.

Treatment of Process Wastewaters from metal and plastic fabrication

The treatment of process wastewater from metal/plastic fabrication operations may require

the use of unit operations specific to individual manufacturing processes given the myriad of

raw materials, chemicals and processes employed. Techniques for treating process

wastewater in this sector include source segregation and pre-treatment of concentrated

wastewater streams. Typical wastewater treatment steps include: grease traps, skimmers,

dissolved air floatation or oil-water separators for separation of oils and floatable solids;

filtration for separation of filterable solids; flow and load equalization; sedimentation for

suspended solids reduction using clarifiers; biological treatment, typically aerobic treatment,

for reduction of soluble organic matter (BOD); biological nutrient removal for reduction in

nitrogen and phosphorus; chlorination of effluent when disinfection is required; dewatering

and disposal of residuals in designated hazardous waste landfills.

Additional engineering controls may be required for

(i) containing and treating volatile organics;

(ii) recovering metals using membrane filtration or other physical/chemical

treatments;

(iii) removal of recalcitrant organics using activated carbon or advanced chemical

oxidation;

(iv) removal of residual colour using adsorption or chemical oxidation;

(v) reducing effluent toxicity by reverse osmosis, ion exchange, activated carbon, etc.;

(vi) containing and neutralizing of nuisance odours; and

(vii) routing of contaminated streams (e.g. stormwater from exposed solid waste areas

such as metal cuttings) to the treatment system.


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Appendix IV

Potential atmospheric emissions and their sources in metal and plastics fabrication

Potential atmospheric emissions and their sources in metal fabrication

Typical atmospheric emissions in metal fabrication include VOCs, fumes, mists, metal oxide

vapours, acid/alkali vapours, etc. (see Section 3). Air emissions from forming processes

include solvents and cooling/lubricant solutions, or vapours generated from quenching (e.g.

from oils and greases present on the surface of metals during plunge cooling) and quenching

bath emissions such as vapours/mists comprising water mixed with chemical additives or

synthetic oils. Typical atmospheric emissions from welding processes derive from the molten

pool, the shielding gases, cored electrodes reacting with the atmosphere and from burning of

oils & greases present on the raw product. Air emissions from surface cleaning relate to the

evaporation of chemicals from degreasing, cleaning, and rinsing. Particulate emissions may

be generated by sand blasting and dry surface grinding and these can include metallic

particulates and oxides. Electrochemical surface treatments produce air emissions, mists, and

gas bubbles arising from heated fluids which may contain metals and other substances

present in the bath. During painting, atmospheric emissions consist primarily of the organic

solvents used as carriers for the paint. Emissions also result from paint storage, mixing,

application and drying.

Methods for Atmospheric Emission Management & Pollution Prevention in Metal

Fabrication

Volatile Organic Compounds emissions management strategies include:

Refrigerator condensing coils above the degreaser vapour zone;

Air flow over the top of the degreaser (typically <40m/minute);

Rotation of parts before removal from the vapour degreaser;

In order to reduce emissions during welding and coating, metal surfaces should be

carefully cleaned; and

Coatings should be removed from the base metal before welding preferably using

mechanical cleaning instead of solvents.

Dust emissions management strategies include:

In-line aspirators (with filters or scrubbers) or electrostatic precipitators;

Wetting metal surface to prevent or minimize dust production.

Management strategies for acid/metal content in mist and fume emissions include:


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44 _________________________________________________________________

Reduce air emissions of electroplated metals using fume suppressants as

additives to electroplating baths;

Eliminate acids using in-line aspirators with filters;

Abate metals or metal oxides using filtration;

Control of welding fumes by removing coatings from base metals.

Point Sources in metal fabrication

Point sources are discrete, stationary, identifiable sources of emissions that release pollutants

to the atmosphere. They are characterized by the release of air pollutants typically

associated with the combustion of fossil fuels, such as nitrogen oxides (NOx), sulphur dioxide

(SO2), carbon monoxide (CO) and particulate matter (PM), as well as VOCs and metals/metal

oxides. Emissions from point sources should be avoided and controlled according to good

international industry practice (GIIP) through the combined application of process

modifications and emissions controls.

Stack Height

The stack height for all point sources of emissions, whether significant or not, should be

designed according to GIIP to ensure reasonable diffusion and to avoid excessive ground level

concentrations due to downwash, wakes and eddy effects. For companies with multiple

sources of emissions, stack heights should be established with due consideration to emissions

from all other sources, both point and fugitive.

Potential atmospheric emissions and their sources in plastics fabrication

VOCs and Particulates

Typical atmospheric emissions from plastics manufacturing processes include particulate

matter and VOCs. Particulates derive from the handling of dry additives and granulation.

Fine aerosols can derive from heating of thermoplastics during compounding/forming and

VOCs can derive from compounding/forming operations, especially when heated. Water

vapour, low-boiling point additives and monomers trapped in the polymer can be released

during high temperature shaping operations.

Polymeric Dust

Granulators can produce high concentrations of combustible/explosive fine dusts especially

when foamed rigid plastics are being treated or whenever coarse and fine granules are being

mechanically sieved. Fine powders may accumulate on vertical walls and horizontal surfaces

beyond the reach of conventional housekeeping. Hazards from polymeric dust only arise if

the materials are rigid (e.g. if its glass transition temperature is above room temperature)

and/or when dealing with foamed materials due to their lower resistance to fragmentation.


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45 _________________________________________________________________

Pentane

Raw expandable polystyrene (EPS) beads typically contain highly flammable pentane which is

released during storage and transportation and from finished products immediately after

manufacture.

Air quality and dermal exposure risks

Fine, respirable dusts may be generated during the machining and finishing of cured parts.

Room temperature compounding for non-reactive processes may also generate dust

emissions. VOC emissions arise from low-boiling-point ingredients and thermal decomposition

of the most labile compounds and worsen with increasing temperature. Thermoplastic

polymers are generally considered safe, however, resin formulations in reactive processes for

thermoset products contain potentially hazardous materials. Isocyanates, present in

polyurethanes, can represent both respiratory and dermal hazards. Phenol and formaldehyde

present in phenolic and amino resins represent an exposure hazard as do urea- and

melamine-formaldehyde resins. Heat decomposition of polyurethane products occurs in as

welding, heat removal of electrical insulating varnishes and hot wire cutting of foams. A

number of solvents may be present in the reactive processing of thermosets. These may be

introduced into the workplace as part of the resin or curing agent, during the manufacturing

process, or as part of the cleanup process.

Methods for Atmospheric Emission Management & Pollution Prevention in

Plastics Fabrication

Measures to prevention and control particulates include:

filtering air exhaust from handling and granulation areas and by capturing/controlling

fugitive emissions through a primary cyclone and a secondary bag-house or

electrostatic precipitator.

Measures to prevention and control VOCs include:

Enclosed storage for all solvent fluids, cleaning fluids and low-boiling-point reagents;

Ventilation control systems at high processing temperature points along the

production line;

Local exhaust extraction systems and activated carbon adsorbers;

Recuperative/regenerative thermal oxidizers, regenerative catalytic oxidizers,

condensers or biofilters; and

Implementation of a Solvent Management Plan.

Measures to prevent and control polymeric dust include:

Minimization of surfaces onto which polymer dust can settle or stick (e.g. due to

electrostatic forces);

Minimization of dust formation by proper maintenance of cutter knives and settings;


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46 _________________________________________________________________

Elimination of all sources of ignition by grounding metal parts to reduce sparks formed

due to static electricity and eliminating metal pieces entering the granulator by using a

magnetic separator.

Measures to prevent and control pentane include the following:

A work permit system should be established in areas where EPS is stored;

Prohibit smoking anywhere EPS bead is manufactured, used or stored;

Mix pentane vapour with steam during pre-expansion to reduce flammability and vent

the pentane/steam vapour;

Ground conveying and convey product at slow speeds to minimize static electricity;

Store expandable beads and pre-forms in a well-ventilated area. Maturing silos should

be grounded and ventilated as explosive mixtures may be generated in the head

spaces;

Use appropriate switches, lighting, motors, ventilation fans and portable electrical

devices;

As hot-wire cutting may cause fires, electricity supply to the wire should be

disconnected in the event that the conveyor stops;

Identify/monitor where pentane ‘hot spots’ are likely to occur using a gas monitor;

Deploy a fire extinguishing system in EPS handling areas.

Measures to prevent and control occupational exposure include the following:

Isolation (e.g. isolated storage, separate process areas, enclosures, closed systems)

and local exhaust ventilation should be adopted. Controls should be implemented in

compounding and mixing areas, heated curing areas including autoclaves, finishing

and repair areas, and controlling off-gases from exotherms;

Adequate ventilation control systems and exhaust extraction with activated carbon

adsorbers should be installed to prevent operator exposure to toxics, dusts and fibres.

Adequate ventilation should not be <6 air changes per hour;

Adequate ventilation should be used to maintain the concentration of the isocyanates

below 25% of the concentration that may cause harmful effects;

The residence time and processing temperature should be set to minimize plastics

overheating and prevent fume generation; The ‘burning out’ of nozzles, blocked dies,

injectors, material transfer valves, screen filter breaker plates should be conducted

under extraction or by other methods which prevent fume exposure;

Should have clear emergency procedures, including evacuation, for processing of heat-

sensitive materials (e.g. acetals and PVC). Potential release of formaldehyde or

hydrogen chloride may result from the rapid polymer degradation;

Temperatures should be monitored and controlled in all sections of the production line.

Proportional-Differential-Integral controllers or PC controlled heating systems will

minimize the cycling thermal fluctuations responsible for fume release.


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47 _________________________________________________________________

Gloves, protective clothing, eye protection, and other relevant PPE should be worn,

especially when working with resins, curing agents and solvents;

Respirators should be used where airborne solvent and dust levels are potentially high

(e.g. during resin mixing, and finishing / repair activities), where large surface areas

and significant hand work are involved and whenever polyurethane-based materials

are produced or handled at temperatures that might degrade the polymer;

Operators should be provided with Material Safety Data Sheet (MSDS) from the

supplier / distributor for the particular formulation used.


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48 _________________________________________________________________

Appendix V

Legislation and Best Practice Guidelines for Preventing &

Controlling Pollution

Introduction

Engineering companies have a duty of care to prevent water pollution arising from their

activities. All industrial (trade) effluent discharges to waters or local authority sewer systems

must be made in accordance with the requirements of a relevant local authority discharge

licence (or the conditions of an IPPC/waste licence in cases where the EPA licences the

activity). Such licences are subject to specific operational conditions. Business must

implement systems and facilities to reduce water wastage and prevent water pollution. It is

an offence to allow entry of polluting matters into waters. All polluting matter arising from

any emergency situations, accidents or spillages must be contained on site so as to minimise

any pollution risk to ground or surface waters. Any washings or drainage from plant activities

must be dealt with in such a way as to prevent any possible contamination of the water

nearby. The regulatory authorities must be notified immediately in the event of an accidental

discharge. A complete set of records should be maintained detailing any water monitoring

undertaken. All relevant information on discharges must be supplied to the relevant

regulatory authority on request.

Legislation & Best Practice Guidelines for Wastewater Management

The Water Pollution Acts (1977 and 1990) and the Water Services Act (2007) are the primary

legislation relating to water management the purpose of which is to protect and improve the

current water quality status. Statutory responsibility for both water provision and water

management and protection rests with local authorities and the EPA. A large portion of water

regulation relates to the provision of safe drinking water. However, the legislation also

provides that all companies that generate industrial effluent (including cooling water and wash

water), regardless of volume, must be licensed to discharge to either a water course or to

sewer. Effluent Discharge Licences allow companies to discharge a controlled amount of trade

effluent to a public sewer (Section 4) or waters (section 16), and are issued by the relevant

local authorities. When businesses apply to their relevant local authority for a licence they

will be required to provide details on the type and volume of discharge.

Environmental Management Guidelines for Small Businesses

Companies do not require a licence if they only discharge domestic-type wastewater, i.e.

sewage to municipal sewers. In general, companies do not require a licence for discharges of

uncontaminated storm water (rainwater) since this discharge is non-polluting. However, a

local authority may decide that storm water from paved areas where there is a risk of

pollution should be licensed. Either way, the company is obliged to ensure they have the


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49 _________________________________________________________________

correct licence for any discharges. The company must provide detailed information on the

type and amount of discharge and ensure that wastewater is treated correctly. Local

authority charges are calculated on a ‘water in/water out’ principle and cover the full cost of

supply, collection and treatment of water and wastewater, including any capital costs.

IPPC Licensing

Large industrial activities require an Integrated Pollution Prevention Control (IPPC) licence

from the EPA (EPA Act 1992, Protection of the Environment Act 2003). This licence includes

provisions for wastewater discharges to water or sewer including discharge volumes,

temperature, pH and the concentration of pollutants. Legislation provides that engineering

companies must operate under an IPPC license if they:-

manufacture boilers, reservoirs and tanks and the manufacturing floor area exceeds 500 m2;

engage in electroplating/metal cleaning in baths of over 30m3 in volume; or

consume >10 tonnes per annum of organic solvents in surface coating operations.

Cost Implications

The application fee to the local authority for an effluent discharge licence is relatively

inexpensive, however, the applicant must provide a detailed architect’s drawing of the site

and, in order to comply with the licence, the company will probably need to invest in

monitoring equipment (flow recorders, samplers). Depending on the processes involved, the

company may also be required to install a system for physical or chemical pre-treatment of

effluent in order to adjust pH and to, for example, reduce the metal content of the effluent

(e.g. precipitation/flocculation).

The process that is most often responsible for generating industrial effluent in engineering

companies is washing the product between welding and painting. By using wipes rather than

water to clean surfaces and by employing powder painting, engineering companies can avoid

the necessity for an effluent discharge licence. Certain engineering processes such as plating,

degreasing, soldering, cleaning with organic solvents, etc. can generate hazardous waste

which cannot be discharged or land-filled and must, therefore, be removed/processed by

licensed waste management contractors.

Emissions and Effluent Guidelines

Table 5 (see below) provides emission and effluent guidelines for metal and plastic

manufacturing. Process emissions and effluent discharge values are indicative of good

international industry practice in countries with recognized regulatory frameworks. They are

achievable under normal operating conditions in appropriately designed and operated facilities

through the application of pollution prevention and control techniques. These levels should be

achieved, without dilution, for at least 95% of the annual operating hours. Deviation from


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50 _________________________________________________________________

these levels in consideration of specific, local project conditions should be justified in the

environmental assessment.

Effluent guidelines are applicable for direct discharges of treated effluents to surface waters

for general use. Site-specific discharge levels may be established based on the availability

and conditions in use of publicly operated sewage collection and treatment systems or, if

discharged directly to surface waters, on the receiving water use classification. Emissions

guidelines are applicable to process emissions.

Effluent Discharge Units Guidelines

pH S.U. 6-9 COD mg/litre 250 Suspended Solids mg/litre 50 Oils & Greases mg/litre 10 Aluminium mg/litre 3 Arsenic mg/litre 0.1 Cadmium mg/litre 0.1 Chromium (total) mg/litre 0.5 Chromium (hexavalent) mg/litre 0.1 Copper mg/litre 0.5 Iron mg/litre 3.0 Lead mg/litre 0.2 Mercury mg/litre 0.01 Nickel mg/litre 0.5 Silver mg/litre 0.2 Tin mg/litre 2.0 Zinc mg/litre 2.0 Cyanides (total) mg/litre 1.0 Cyanides (free) mg/litre 0.2 Ammonia mg/litre 10 Ammonia (electroplating) mg/litre 20 Fluorides mg/litre 20 Phenols mg/litre 0.5 Total Nitrogen mg/litre 15 Total Phosphorus mg/litre 5.0 Sulfide mg/litre 1.0 Volatile Organic Halogens mg/litre 0.1 Temperaturea oC <3

Table 5 Effluent discharge guidelines for Metal & Plastic Fabrication a Recorded at the edge of a mixing zone taking into account ambient water quality,

receiving water use, potential receptors and assimilative capacity. Source : EHS Guidelines for Metal, Plastic and Rubber Products Manufacturing, International

Finance Corporation, World Bank Group, 2007

Legislation & Best Practice Guidelines for Managing Atmospheric Emissions

The 1987 Air Pollution Act - Atmospheric Emission Licensing

Most industrial activities generate emissions to atmosphere, however, only a small proportion

of such emissions are significant enough to warrant specific licensing. Metal and plastic

fabrication engineering processes that have the potential for major emissions and may

therefore be subject to licensing under Schedule 3 of the 1987 Air Pollution Act include:-


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51 _________________________________________________________________

Roasting & sintering at a capacity of more that 1,000 tonnes per annum;

The production of pig iron and crude steel;

Foundries melting installations with a capacity of greater that 5 tonnes;

The production of compounds or alloys of magnesium or manganese;

The manufacture of glass or mineral fibre;

The manufacture of olefins, derivatives of olefins, monomers or polymers or other

organic intermediate products;

Any chemical process in which any of the following basic inorganic chemicals are used

of evolved – ammonia, bromine, carbon disulphide, chlorine, fluorine, hydrofluoric

acid, hydrogen chloride, hydrogen cyanide or hydrogen sulphide.

It should be noted that most of the processes, which are covered by the Air Pollution Act

(1987) are now subject to IPPC licensing under the Protection of the Environment Act 2003.

The Act itself obliges the company to use the best practicable means to limit/prevent an

emission and empowers the local authorities to serve a notice where complaints of air

pollution are received. The licence is normally valid for at least three years and subject to

review where the nature of the emission or the ambient air quality has materially changed or

where there is significant modifications to an existing plant.

Emissions of Volatile Organic Solvents Regulation 2002 (Solvents Directive)

The Solvents Directive 1999/13/EC regulates the use of Volatile Organic Compounds (VOCs)

to limit VOCs emissions. This applies to industry activities using solvents above specified

thresholds per year and impact on surface cleaning; vehicle coating and refinishing; coil and

other coating (metal, plastic, textile, fabric, film, paper); winding wire coating; and adhesive

coating. The Regulations are implemented through the Accredited Inspection Contractor

(AIC) system as follows:-

Activities with the capacity to use ≥ 10 tonnes/year of solvents require an IPPC

licence from the EPA.

Specified activities using < 10 tonnes/year and which are not an activity requiring

an IPPC licence (as defined in Schedule 1 of the Protection of the Environment Act

2003) may be required to operate under the Solvents Regulations.

Each activity category is assigned a solvent consumption threshold in tonnes/year above

which the Regulations apply.

Compliance with Solvents Regulation (2002)

An installation can comply with the air emissions requirements by one of two routes:-

a) compliance with a reduction scheme (in Schedule 3 of the Regulations); or


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52 _________________________________________________________________

b) meeting the emission limit values (ELVs) in waste gases and the fugitive emission values or

total emission limit values (in Schedule 2 of the Regulations), and other relevant special

provisions in Schedule 2. Certain VOC containing substances or preparations classified as

carcinogenic, mutagenic or toxic (Risk Phrases R45, R46, R49, R60, R61) must be replaced

where possible with less harmful substances or preparations. These substances along with

halogenated VOCs with Risk Phrase R40 must comply with separate ELVs regardless of the

overall compliance method.

Tracking and recording of solvent purchase, use and emissions data will be necessary for the

annual AIC inspection. Emission monitoring may be a requirement. These requirements will

be determined by the sector and compliance method chosen. Where greater than an average

of 10 kg/h of Total Organic Carbon is emitted from the final discharge point (post abatement

equipment) continuous monitoring is required.

Solvent Management Plans are to be prepared to verify compliance, identify future reduction

options and provide information to the public on solvent consumption, emission and

compliance with the Directive.

Solvents Reduction Scheme

The purpose of the Reduction Scheme is to allow the operator achieve emission reductions

equivalent to those achieved if the ELVs were applied. The operator may use a reduction

scheme appropriate for their installation, such as the substitution with coatings containing

reduced levels of solvents in the total input, or increased efficiency in the use of solvents.

The operator first calculates the current annual reference emission based on the total mass of

solids consumed in a year multiplied by an appropriate factor, which is activity related. The

target emission is then calculated from the annual reference emission and a percentage

derived from the fugitive emission limit for that activity. Compliance is achieved if the actual

solvent emission, determined from the solvent management plan, is less than or equal to the

target emission.

Solvent Emission Limit Values

Schedule 2 of the Regulations is a list of the specified activities with thresholds and related

emission limit values that must be met. There are 20 categories of activities and each

category is assigned a solvent consumption threshold (above which the Regulations apply), a

combination of emission limit value and fugitive emission value and/or a total emission limit

value. Local authorities may exempt certain installations from compliance with some

emission limit values in specified circumstances provided the operator demonstrates that Best

Available Techniques (BAT) are being employed and that there is no significant risk to human

health or the environment.


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53 _________________________________________________________________

The Accredited Inspection Contractor (AIC) System

Metal & plastics fabrication activities that come under the AIC must do the following:-

Register with the competent authority and operate in accordance with an annual

certificate of compliance issued by the competent authority. In the case of non-

IPPC licenced activities, the competent authority is the Local Authority.

Organise for an AIC to annually review their operations to determine the state of

compliance with the Regulations and produce an annual AIC report. The

Certificate of Compliance (as per Schedule 5 of the Regulations) will be issued on

the basis of this report stating that the installation is in compliance with the

Regulations.

Meet requirements regarding air emissions relevant to the sector.

Fees / Turnaround Time / Duration of Certificate

To register with the Local Authority the registration details listed in Schedule 4 of the

Regulations, an AIC report and €50 fee must be submitted. The certificate of compliance will

be issued within 14 days of receipt of the report from the AIC, provided the Local Authority is

satisfied that the report demonstrates compliance. If not satisfied, the competent authority

will refuse to issue a certificate. The certificate of compliance is valid for no longer than 1

year.

Legislation & Best Practice Guidelines for Waste Management

The Waste Management Acts 1996 - 2010

The Act forbids the handling, transportation, recovery or disposal of waste when it is done in a

manner which causes environmental pollution. It follows that the use of an unauthorised

waste collector or waste management facility is an offence.

There is a duty to inform a local authority if there is any loss, spillage or accident involving

non-hazardous waste that may cause environmental pollution to arise. Where hazardous

waste is involved, both the local authority and the EPA must be informed. In general, the

penalties for the contravention of the Waste Management Act are €1900 or prison sentences

of up to 12 months. However, more serious offences can be subject to fines up to €12.7

million and imprisonment of up to 10 years.

Inappropriate waste management activities can also be dealt with under other legislation such

as the Local Government (Water Pollution) Acts 1977 and 1990 (see Section 2.0). and the Air


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54 _________________________________________________________________

Pollution Act 1997 (See Section 3.0). Burning waste may simultaneously contravene the Air

Pollution Act and the Waste Management Act.

What is “Waste”?

Waste is something which a holder discards, intends to discard or is required to discard and

includes scrap materials, waste paper or plastic and so on. In order to be a waste under

national law, the material must be identifiable from the list set out in the First Schedule to the

Waste Management Act or in the European Waste Catalogue (EWC). The term “discard” also

refers to recoverable/recyclable materials.

What is “Hazardous Waste”?

For a waste to be a hazardous, it must exhibit certain hazardous properties (such as

flammability or toxicity), which are listed in the Second Schedule to the Waste Management

Act.

Hazardous Waste Storage and Record Keeping

The storage of significant quantities of hazardous waste is controlled either by the EPA or by a

local authority under the Protection of the Environment Act 2003 (IPPC Directive). For

smaller companies that are not subject to IPPC licensing the temporary storage of hazardous

waste must be authorised by a local authority where the storage period is <6 months and the

quantities being stored exceed 25,000 litres or 40 m3. The Waste Management (Hazardous

Waste) Regulations 1998 require producers to keep specified records of any hazardous waste

arising from the premises. These records, which must be kept for 3 years, set out the

quantity, nature and origin of waste produced; any treatment carried out; and the quantity,

nature, destination, frequency of collection and mode of transport of any hazardous waste

transferred to another person.

Non-Hazardous Waste Storage and Record Keeping

The temporary storage of non-hazardous waste at the premises where it is produced is

generally exempt from needing any form of authorisation under the Waste Management Act.

There is no general statutory requirement on smaller companies in Ireland to keep records of

waste quantities, where they have been moved to and by whom. However, it is prudent for

every company to retain this information. It is also desirable that written contracts are

obtained from providers of waste management services, including those handling recyclable

materials.

Waste Oils

The Waste Management (Hazardous Waste) Regulations 1998 make the disposal of waste oils

to waters or drainage systems an offence. It is also prohibited to mix them with other


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wastes. Companies that produce more than 500 litres of waste oils per annum must keep

information on the quantity, quality, origin and location of waste oils. When waste oils are to

pass to another person, details of the date of transfer and the identity of the transferee must

be maintained for at least two years.

Fluorescent Tubes

In general, spent fluorescent tubes are defined as hazardous waste. Hence they must be

subject to the storage and record keeping requirements set out above. In addition, they

should also be segregated from other non-hazardous waste and consigned for specialist

processing.

Moving Hazardous Waste within Ireland

All carriers of hazardous waste must operate under waste collection permits. In addition, the

movement of hazardous waste within Ireland is controlled by the Waste Management

(Movement of Hazardous Waste) Regulations 1998. This tracking process employs

consignment notes or “C1 forms” allowing any hazardous waste movement to be traced back

to the point of origin. Exemptions to C1 include authorised movements of hazardous wastes,

when such materials are to be exported from Ireland to other countries; the transfer of waste

oil; and waste collected from either bring centres or segregated collection services provided to

members of the public.

Moving Waste from Ireland to Another EU State

Transporting wastes from Ireland to other countries is complicated and is usually undertaken

by specialist firms. The legal requirements are set out in the Waste Management (Shipments

of Waste) Regulations 2007. The local authority, rather than the EPA, is the body with

responsibility for such activities.

International Movements of Non-Hazardous Waste to Recovery Facilities

While the provisions described above embrace transactions of hazardous waste to recovery

facilities, non-hazardous waste passing internationally to recovery is also subject to this

legislation. The affected wastes are those which are on Regulation 259/93’s “Green List”.

Legislation & Best Practice Guidelines for Noise Management

Prevention and Control

Noise prevention and mitigation measures should be applied where predicted or measured

noise impacts exceed the applicable noise level guideline at the most sensitive point of

reception outside the site boundary (e.g. residences, hotels, schools, hospitals/ nursing

homes and parks). The preferred method for controlling noise from stationary sources is to

implement noise control measures at source. Methods for prevention and control of sources


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of noise emissions depend on the source and proximity of receptors. Noise reduction options

that should be considered include:

Installing silencers for fans, mufflers on engine exhausts and compressor components,

acoustic enclosures for equipment casing radiating noise;

Improving the acoustic performance with sound insulation;

Installing acoustic barriers without gaps and with a continuous minimum surface

density of 10 kg/m2 in order to minimize the transmission of sound through the

barrier;

Installing vibration isolation for mechanical equipment;

Limiting the hours of operation for specific pieces of equipment or operations;

Re-locating noise sources to less sensitive areas;

Use natural topography as a noise buffer during facility design.

Record and respond to complaints.

Noise Level Guidelines

Noise impacts should not exceed 70 decibels or result in a maximum increase in background

levels of 3 dB at the nearest receptor location off-site. Highly intrusive noises, such as noise

from aircraft flyovers and passing trains, should not be included when establishing

background noise levels.

Monitoring

Noise monitoring may be carried out for the purposes of establishing the existing ambient

noise levels in the area of the proposed or existing facility, or for verifying operational phase

noise levels. Monitors should be located approximately 1.5m above the ground and no closer

than 3 meters to any reflecting surface (e.g. wall). In general, the noise level limit is

represented by the background or ambient noise levels that would be present in the absence

of the facility or noise source(s) under investigation.

Funded by the Irish Government under the National Development Plan, 2007-2013

Transforming Ireland

www.envirocentre.ie

www.enterprise-ireland.com

© Enterprise Ireland October ’11 – (000)

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