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ALPS Electric Ireland

Ltd.

2011 Annual Environmental

Report for ALPS Electric

Ireland Ltd. Clara Road,

Millstreet, Co Cork. IPPC

Licence (Reg: P0835-01)

March 2012

Annual Environmental Report 2011

ALPS ELECTRIC (IRELAND) LTD.

ANNUAL ENVIRONMENTAL REPORT

March 2012

Contents

1. Introduction ........................................................................................................ 1 1.1 Licence Details .........................................................................................1 1.2 Summary Data Table ...............................................................................1 1.3 Company Profile.......................................................................................2 1.4 Economic Contribution............................................................................2 1.5 Company Environmental Policy..............................................................3 1.6 Process Description ..................................................................................4 1.6.1 Fabrication of plastic parts: .......................................................................4 1. Moulding Process ........................................................................................4 2. Painting and Laser Tech Process...............................................................4 3. Raw Material Detrashing............................................................................4 4. Surface Mount Technology (SMT) Process...............................................5 5. Manual Assembly Process..........................................................................5 6. Final Assembly Process ...............................................................................5 1.7 Environmental Management System .....................................................5

2. Discharges, Wastes & Resource Summary Data.............................................. 6 2.1 Discharges to Air .......................................................................................7 2.1.2 Compliance Summary............................................................................11 2.2 Discharges to Water ...........................................................................12 2.2.1 Monitoring of Storm Water Emissions....................................................12 2.3 Waste Management ............................................................................14 2.3.1 Hazardous Waste.....................................................................................14 2.3.2 Non- Hazardous Waste ............................................................................15 2.4 Noise Monitoring ..................................................................................20 2.5 Resource Consumption........................................................................21 2.5.1 Summary of Water Consumption for 2010 and 2011...........................22 2.5.2 Summary of Electrical Consumption for 2010 and 2011 .....................23 2.6 Monitoring and Enforcement ................................................................28 2.7 Reported Incidents Summary................................................................32 2.8 Complaints Summary .............................................................................32

3. Environmental Management Programme – Summary Update .................... 33 3.1 EMP Report 2011.....................................................................................33 3.1.2 Bunding and containment....................................................................33 3.1.3 Decommissioning and Residuals Management Plan.........................34 3.1.4 Environmental Liabilities Risk Assessment.............................................34 3.1.5 Efficiency in the Use of Raw Materials ...............................................35

Annual Environmental Report 2011

Attachments

Attachment A Company Organisation Structure

Attachment B Site Location

Attachment C Process Flow Diagram

Attachment D Paint and Lazer Process

Attachment E Status Update Environmental Management Plan 2010

Attachment F Proposed Environmental Management Plan 2011

Annual Environmental Report 2011 March 2012

Page 1 of 35

1. Introduction

This document is the third Annual Environmental Report (AER) covering

environmental performance at Alps Electric (Ireland) Ltd. located on Clara

Road, Millstreet, Co. Cork.

This report covers the period from January 1st to December 31st 2011 and has

been prepared in accordance with the EPA ‘Guidance note for: Annual

Environmental Report’ (October 2001) and other relevant guidance as

provided by the EPA on the Agency website (www.epa.ie).

Since the IPPC Licence was issued by the Agency in June 2008, Alps Electric

(Ireland) Ltd. have issued detailed regular reports to the Agency in order to

demonstrate routine compliance with the terms of the licence (Reg: P0835-01).

Alps Electric (Ireland) Ltd. operate an Environmental Management

Programme, which sets out targets on a range of environmental projects

including energy efficiency and reduction in water consumption, together with

environmental training and awareness, to deliver ongoing improvements in

environmental performance at the plant. Progress in achieving targets set

within the EMP, together with the revisions to the Programme for 2012 are

included in Attachments E and F of this AER.

The next AER will cover the calendar year 2012 and will be issued in the first

quarter of 2013.

1.1 Licence Details

Licensee: ALPS Electric (Ireland) Limited

Location of Activity: Clara Road, Millstreet, County Cork.

IPC Licence Register No.: P0835-01

Date of Issue 11th June 2008

Principal Class of Activity 12.2.2: Surface Coatings

1.2 Summary Data Table

Current IPPC Licence annual reporting requires the submission of an EPA

Pollution Release Transfer Register (PRTR) Form which documents the emissions

and IPPC management information in the form of a spreadsheet, which is

transmitted to the Agency electronically. The spreadsheet has been submitted

electronically to the EPA.


Page 2 of 35

1.3 Company Profile

Alps Electric (Ireland) Ltd. is a Japanese company producing parts for the

automotive industry. The following components are manufactured at the

facility: electronic components, car electronics, communications and

broadcasting- related equipment.

Alps Electric (Ireland) Ltd. was established in Millstreet Town, Co Cork in March

1988 to manufacture computer peripherals (keyboards, mouse products). In

1996 Alps Electric (Ireland) Ltd. commenced manufacturing car electronics at

its facility in Millstreet and now specifically produce parts for the automotive

industry and employ all the disciplines demanded by this sector.

A copy of Alps Electric (Ireland) Ltd.’s Company Organisational Structure is

appended as Attachment A of the Report. The location of Alps Electric

(Ireland) Ltd. IPPC Licence boundary is illustrated in Figure 1 of Attachment B.

1.4 Economic Contribution

Alps Electric (Ireland) Ltd. are a significant employer in Millstreet, employing

over 450 personnel. Indirectly, taking a 1:3 multiplier, there is an estimated 1,350

people involved in the supply of services and materials to the plant.

The annual economic contribution to the local economy is estimated to

exceed €20 million both directly in salaries, and materials and services

purchased.


Page 3 of 35

1.5 Company Environmental Policy

ENVIRONMENTAL POLICY STATEMENT

ALPS Electric (Ireland) Limited as a major participant in the Electronics industry and as

a member of the global community, is committed to protecting our Environment by

safeguarding precious resources through the use of technologically advanced

business practices and the efforts of its employees. The manufacturing processes

within ALPS Electric (Ireland) Ltd., will be controlled so as to minimise waste & emissions

from the plant and recycling of product, where possible, will be carried out. Alps

Electric (Ireland) Ltd., will actively encourage its suppliers to make a meaningful

contribution in order to promote a cleaner Environment.

To sustain and protect the Environment, Alps Electric (Ireland) Ltd., will

strive to:

o Implement continual improvement, prevention of pollution, re-use and

recycling in all its operations in order to cause the minimum impact on

the Environment.

o Conduct all activities in an Environmentally responsible manner in

compliance with European ,National legislative and regulatory

regularions, Alps Electric (Ireland) Ltd. Corporate Requirements and our

Integrated Pollution Prevention Control Licence P0835-01.

o Conduct activities according to corporate Alps Electric (Ireland) Ltd.

Environmental principles, Alps Electric (Ireland) Ltd. Environmental action

plans, goals and Management philosophy.

o Communicate and implement Environmental policy objectives, and

targets to available management programmes of Alps Electric (Ireland)

Ltd. at all levels within the organisation.

o Make information on Alps Electric (Ireland) Ltd. Environmental policy,

objectives and targets available to

staff, other interested parties and the public on request.

o Conduct regular Environmental Audits of the Environmental Management

System and manufacturing operations to ensure compliance with this

policy, our Environmental objectives and targets and the requirements of

the Environmental Management System Standard ISO 14001.

o Implement an energy usage monitoring system to reduce energy costs,

through management of fuel cost, equipment efficiency, plant

efficiency, awareness and training.

This Environmental Policy Statement has full commitment and support of site

Management team.

--------------------------------- Managing Director

--------------------------------- ISO 140001 Management Representative


Page 4 of 35

1.6 Process Description

The production process involves fabrication of plastic parts and assembly of

components onto printed wiring boards.

The main processes involved in the manufacture of the product have been as

follows:

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

of the products;

� Paint and lasering of decorative cosmetic parts;

� Surface Mounting Process and wave soldering mount processes (Printed

wiring board stuffing);

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

and including inspection and testing of finished units.

A Process Flow diagram is appended as Attachment C of the report.

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

follows:

1.6.1 Fabrication of plastic parts:

1. Moulding Process

Plastic granules undergo injection moulding. The moulds are annealed,

cooled and cleaned.

2. Painting and Laser Tech Process

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

mixture of paint, thinner, and hardener using high volume low pressure

(HVLP) technology. Coated parts undergo a flash period of 15 minutes

followed by curing in an oven at 80oC.

Moulds are coated in two enclosed booths using automatic high volume

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

and solvents are emitted without further abatement to emission point A1-

3. Solvents losses from mixing areas, flash off area and curing ovens are

emitted unabated through emission point reference A2-1. Solvent losses

from manual assembly process (flux and conformance coating) are

directed unabated to emission point A1-3 and A2-3. Emissions are

approximately 3 kg/hr.

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

this coating activity is estimated at 50 tonnes.

A flow diagram of the paint and laser process is appended as Attachment

D of the report.

3. Raw Material Detrashing

Printed wiring boards and components are delivered to the site and

packaging is removed.


Page 5 of 35

4. Surface Mount Technology (SMT) Process

Printed wiring boards are loaded onto a surface mount technology

machine. The boards are applied with solder paste, cleaned with solvent

to remove dirt and applied with glue (adhesive coating). Components are

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

boards are inspected. Solvent used for cleaning in this area is

approximately 2.4 tonnes per year.

5. Manual Assembly Process

Larger components from the SMT process are both manually placed onto

the printed wiring boards in conjunction with Semi Automated Assembly

(SAM). Solder is applied with either a wave solder or by point spraying

application. A solvent flux is sprayed over the area to be soldered. A

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

wiring board followed by curing. Approximately 17 tonnes of solvent per

year is used in this process.

6. Final Assembly Process

Moulds and wiring boards are assembled and parts are manually cleaned

using solvent. Solvent usage in final assembly is 1.5 tonnes per annum.

1.7 Environmental Management System

Alps Electric (Ireland) Ltd. have implemented an Environmental Management

System (EMS) and are certified to ISO 14001. The EMS has been in place since

1987 and documents the overall management system that includes

organisational structure, planning activities, responsibilities, practices,

procedures, processes and resources for developing, implementing, achieving,

reviewing and maintaining the Environmental Policy.

Since 1994, Alps Electric (Ireland) Ltd. environmental preservation plans have

expanded to include a global management structure, and a corporate turn

towards “green” products. Lowering the impact our business activities have on

the environment is a necessary step in “perfecting the art of electronics”.

The company has identified an environmental aspects register which identifies

potential environmental emissions associated with the site and the actions Alps

Electric (Ireland) Ltd. will implement to manage and prevent an environmental

incident. The objectives and targets of the EMS ensure conformance with the

IPPC Licence which are set a defined time period for achievement. These

include environmental training and awareness, and monitoring. Emergency

procedures associated with the operation of the site are also prepared as part

of the EMS.


Page 6 of 35

2. Discharges, Wastes & Resource Summary Data

This section of the Annual Environmental Report (AER) summarises all

environmental and resource monitoring information for the calendar year 2011.

Information on emissions and discharges to air and water are summarised as

annual mass emissions and are based on the average measured concentration

for the relevant parameter multiplied by the volumetric flow data for the year

from the relevant emission point.

Information on waste arisings is presented in accordance with the AER

electronic report spreadsheet as issued by the EPA.

Summary totalised and relative data on resource (power and fuel) and water

usage at the plant during 2011 are presented in comparison with previous years

data to allow comparison.

Summary information on all emissions and discharges, waste arisings and

resource use have been compiled on an electronic spreadsheet which has

been submitted to the Agency by e-mail to [email protected].


Page 7 of 35

2.1 Discharges to Air

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

Odour Monitoring Ireland were commissioned by Alps Electric (Ireland) Ltd. to

perform emission testing of the process vent stacks A2-1 A2-2, A2-3, A2-4 A2-6

and A2-7. A summary of compliance with mass emission limit values is outlined

below.

The actual mass emissions are based upon average sampling results and

permitted flow values for each source expressed as hourly mass emissions

(kg/hr). The annual mass emission is calculated on the basis of annual hours of

operation for each source.

Permitted mass emissions are based on the IPPC licence emission limit value for

each source. This is multiplied by the permitted hourly flow limit and taking a

24/365 operational period.

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

tested is provided in Table 2.1.1.

Table 2.1.1 Description of Process Area Emission Points

Monitoring

Location

Description

A1-3 Outlet from VOC Abatement system

A2-1 Paint and Lazer Process

A2-2 Concoat process and Wave solder 1&2

A2-3 Spot Dip (x3) and manual soldering

A2-4 SMT machine extract point

A2-6 PAL Area Extract 1

A2-7 PAL Area Extract 1

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

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

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

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

followed by a regenerative thermal oxidiser.

The exhausted air loaded with solvents from the process is routed through a

rotating activated zeolite adsorption wheel. The VOCs are adsorbed in the

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

adsorption is performed in one site while desorption is performed on the other

site. The outlet stream from the adsorption wheel is clean air and can be

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

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

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

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

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


Page 8 of 35

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

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

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

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

to discharge to atmosphere.

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

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

Total Organic Carbon is monitored on a quarterly basis for emission points A3-1,

A2-1, A2-3, A2-4. The results of analysis for the 2011 reporting period are outlined

in Table 2.1.2.


Page 9 of 35

Table 2.1.2 Total Organic Carbon Emissions from Process Vents during the 2011 Survey Period

IPPC

Licence

Limit

Value

mg/m3

TOC conc. Emission Limit

Value Volumetric

airflow rate

(Nm3/hr)

Mass

loading/

emission

Annual

Mass

Emission

Permitted

Mass

Emission

(mgC/Nm3) (kg/hr) Kg/Yr Kg/Yr

Monitoring

Location

Measurement

Period

NormalisedVolumetric

airflow rate (Nm3/s)

Quarter 1 4.14 8.43 0.13 19272

Quarter 2 7.47 8.39 0.23

Quarter 3 4.10 8.35 0.12

A1-3 50

Quarter 4 2.29 7.61

44,000

0.06

956

Quarter 1 6.74 4.57 0.11 7279

Quarter 2 6.16 4.33 0.1

Quarter 3 6.00 4.11 0.09

A2-1 50

Quarter 4 9.60 3.57

16,619

0.12

743

Quarter 1 36.75 0.78 0.1 2015

Quarter 2 38.03 0.85 0.12

Quarter 3 27.20 0.85 0.08

A2-3 75

Quarter 4 31.00 0.78

3,067

0.09

690

Quarter 1 4.78 1.42 0.24 0

Quarter 2 5.45 1.23 0.24

Quarter 3 5.33 1.22 0.23

A2-4

Quarter 4 6.08 1.17

0.03

1310


Page 10 of 35

Figure 2.1.1 provides an illustration of the Total Organic Carbon (TOC)

emissions from process vents during the 2011 survey period.

0

5000

10000

15000

20000

25000

A1-3 A2-1 A2-3

Monitoring Emission Points

Kg/Yr

Actual Mass Emission

Permitted Mass Emission

Limit Value

Figure 2.1.1 Annual Mass Emissions for Total Organic Carbon

As can be seen from Figure 2.1.1 Total Organic Carbon (TOC) emissions from

process vents during the 2011 survey period were well below IPPC licence

limit values.

It is also noted that the actual annualised mass emissions for all process

sources are significantly lower than the permitted annual discharges in

accordance with the IPPC Licence P0835-01.

Carbon monoxide, and oxides of nitrogen are monitored for emission point

A1-3 (Outlet from VOC Abatement system) on a biannual basis. The results of

analysis for the 2011 monitoring period are outlined in Tables 2.1.3 and 2.1.4.

Table 2.1.3 Flue Gas Analysis of Carbon Monoxide from A1-3

IPPC

Licence

Limit

Value

mg/m3

Carbon Monoxide

(mg/Nm3)


Kg/Yr

Total Mass Emission

Limit Value kg/Yr

100 Average 21.3 4457.9

38544


Page 11 of 35

Table 2.1.4 Flue Gas Analysis of Oxides of Nitrogen from A1-3

IPPC

Licence

Limit Value

mg/m3

Oxides of

nitrogen as

NO2 (mg/Nm3)


Kg/Yr

Total Mass Emission

Limit Value kg/Yr

200 Average 6.74 1406.6 77088

Figure 2.1.2 provides an illustration of the annual mass emissions for carbon

monoxide, and oxides of nitrogen from process vent A1-3 during the 2011

survey period.

0.0

5000.0

10000.0

15000.0

20000.0

25000.0

30000.0

35000.0

40000.0

Carbon Monoxide Nitrogen Oxides

Monitoring Parametera

Kg/Yr


Permitted Mass Emission Limit Value

Figure 2.1.2 Annual Mass Emissions for Carbon Monoxide and Oxides of

Nitrogen from A1-3

As can be seen from Figure 2.1.2 annual mass emissions for carbon monoxide,

and oxides of nitrogen from process vent A1-3 during the 2011 survey period

were below permitted IPPC licence limit values.

2.1.2 Compliance Summary

The overall combined annual mass emissions for TOC, carbon monoxide, and

oxides of nitrogen from all process sources are significantly lower than annual

permitted mass emissions. As a result Alps Electric (Ireland) Ltd. have

demonstrated 100% compliance with monitoring results are noted for the 2011

monitoring period.


Page 12 of 35

2.2 Discharges to Water

There is no process effluent generated and therefore no emissions to water.

2.2.1 Monitoring of Storm Water Emissions

Storm water, which arises from rainfall from roof and hardstanding area and

the air handling units, is discharged at 2 points which merge at a monitoring

reference SW1 (E126798 N089581) located off-site. The storm water discharges

to the Finnow River.

Monitoring point SW1 is visually inspected and monitored for pH, on a weekly

basis and Chemical Oxygen Demand (COD) on a monthly basis.

A second water monitoring point M1 is located to the west of the site (E126805,

N089578) and monitors water runoff from the paint and lazer process and

cooling machine. Monitoring point M1 is monitored for pH on a weekly basis,

Chemical Oxygen Demand (COD) on a monthly basis, and is visually

inspected on a daily basis. Organic compounds are monitored on a biannual

basis.

All visual inspections for both SW1 and M1 for the 2011 reporting period

indicate the water was good, clear, and colourless.

PH results for monitoring point SW1 ranged between 6.29- 7.98 for the 2011

reporting period, and between 6.45 -8.76 for monitoring point M1.

COD results for both SW1, and M1 for the 2011 reporting period are outlined in

Table 2.2.1.

Table 2.2.1 COD and Organic Compounds Results for SW1 and M1 for 2011

Month Parameter SW1 M1

January COD (mg/L) 16.9 2.3

February COD (mg/L) <5.0 <5.0

March COD (mg/L) 9.4 7.5

April COD (mg/L) <5.0 <5.0

May COD (mg/L) 7.7 <5.0

May Organic Compounds (µg/L) <0.01

June COD (mg/L) 6.3 7.7

July COD (mg/L) <5.0 <5.0

August COD (mg/L) <5.0 <5.0

September

COD (mg/L)

14 10

October COD (mg/L)

November COD (mg/L) 12 4

December COD (mg/L) 3 <2

December Organic Compounds (µg/L)

US EPA 624 Volatile Screen <1

December

Organic Compounds (µg/L)

US EPA 625 Semi-Volatile

Screen <0.01


Page 13 of 35

M1 was analysed for organic compounds in May, and December. The results

showed that concentrations for the parameter analysed in May were

<0.01µg/L. In December water from M1 was analysed for both volatile

compounds (US EPA 624), and semi-volatile compounds ((US EPA 625) the

results of which were <1 and <0.01µg/L respectively.

There are no licenced emission limit values for the water parameters.


Page 14 of 35

2.3 Waste Management

Management of solid non-hazardous and hazardous wastes are recorded in

accordance with Condition 8 of the IPPC Licence.

2.3.1 Hazardous Waste

Hazardous waste generated on-site is waste solvent and materials

contaminated with waste solvent, which is forwarded to Germany for

incineration. A significant portion of the solvent used at the installation each

year is transferred to waste.

All documentation is retained on-site in accordance with legislative

requirements and the IS0 14001certified Environmental Management System. A

summary of hazardous wastes which arose for the 2011 monitoring period are

outlined in Figure 2.3.1. Hazardous material taken offsite for the 2010 monitoring

period is provided for comparative purposes.

Empty unused drums

Fluorescent Tubes

WASTE Empty drums

Waste Oil

Waste Flux,Thinners, and Water w,

Paint, Hardeners,Sludge etc.(X10)

Waste Wipes

Waste Grease

0

5

10

15

20

25

30

35

40

45

Weight (Tonnes)

Waste Type

2010 (Tonnes)

2011 (Tonnes)

Figure 2.3.1 Summary of Hazardous Wastes which Arose for in 2010 and 2011

There was a 17% increase noted in the quantities on hazardous waste removed

off site in 2011 (70.079 Tonnes) when compared with those in 2010

(59.854Tonnes). This increase in 2011 corresponds with the increase in

production at the facility.


Page 15 of 35

2.3.2 Non- Hazardous Waste

All non-hazardous waste generated on-site during 2011 was sent for

recovery/disposed which is managed using authorised contractors.

All documentation is retained on-site in accordance with legislative

requirements and the IS0 14001certified Environmental Management System. A

summary of non-hazardous wastes which arose for the 2011 monitoring period

are outlined in Figure 2.3.2. The waste arisings for 2010 are also shown for

comparative purposes.

0

0.02

0.04

0.06

0.08

0.1

0.12

Cardboard packaging

Plastic

Plastic packaging

Wooden packaging

C&I dry mix

Electronic waste

Mixed packaging

We

igh

t (T

on

ne

s)

2010 2011

Figure 2.3.2 Summary of Non- Hazardous Wastes which Arose for in 2010 and

2011

Non hazardous waste increased in 2011 increased by 48% which is reflective of

the increase in production hours at the facility. As can be seen from figure 2.3.2

there was a significant increase in the amount of plastic (48%), cardboard

(28%) and plastic packaging (20%) removed from the facility in 2011.

Full details of hazardous and non-hazardous waste arisings for the 2011

reporting period including European Waste Catalogue references, name of

waste disposal /recovery contractor and disposal/recovery codes are outlined

in Table 2.3.1.


Page 16 of 35

Table 2.3.1 Summary Information on Waste Arisings for the 2011 Reporting Period

European

Waste

Code

Hazardous Quantity

(Tonnes

per Year)

Description of Waste

Waste

Treatment

Operation

Location of

Treatment

Name and

Licence/Permit No of

Next Destination

Facility

Address of Next

Destination Facility

15 01 01 No 88.02 paper and cardboard

packaging

R3 Offsite in

Ireland

Greenstar Recycling

(Munster)

Ltd.,W0136-02

Sarsfield Court Industrial

Estate ,Glanmire ,Co.

Cork,.,Ireland

15 01 02 No 39.791 plastic packaging R3 Offsite in

Ireland

Greenstar Recycling

(Munster)

Ltd.,W0136-02



Cork,.,Ireland

15 01 03 No 20.38 wooden packaging R3 Offsite in

Ireland

Greenstar Recycling

(Munster)

Ltd.,W0136-02



Cork,.,Ireland

20 01 35 Yes 4.497 discarded electrical and

electronic

R5 Offsite in

Ireland

Greenstar Recycling

(Munster)

Ltd.,W0136-02



Cork,.,Ireland

15 01 06 No 1.03 mixed packaging R3 Offsite in

Ireland

Greenstar Recycling

(Munster)

Ltd.,W0136-02



Cork,.,Ireland

20 01 39 No 108.32 plastics R3 Offsite in

Ireland

Greenstar Recycling

(Munster)

Ltd.,W0136-02



Cork,.,Ireland

20 03 07 No 72.162 bulky waste D1 Offsite in

Ireland

Greenstar Recycling

(Munster)

Ltd.,W0136-02



Cork,.,Ireland

15 01 10 Yes 3.116 packaging containing

residues of or

contaminated by

D10 Offsite in

Ireland

Veolia

Environmental

Services Technical

Corrin ,Fermoy ,Co. Cork ,

,Ireland


Page 17 of 35

European

Waste

Code

Hazardous Quantity

(Tonnes

per Year)


Waste

Treatment

Operation

Location of

Treatment

Name and


Next Destination

Facility

Address of Next


dangerous substances Solutions Ltd.

,W0050-02.


residues of or

contaminated by

dangerous substances

R4 Abroad ATM Moerdijk B.V.

,Licence No:

1538449

Vlasweg 12 ,4782 PW

,Moerdijk,.,

Netherlands


residues of or

contaminated by


R4 Offsite in

Ireland

Veolia

Environmental

Services Technical

Solutions Ltd.

,W0050-02.


,Ireland


residues of or

contaminated by


D10 Abroad Veolia Ellesmere Port

,BS5193IE

,Bridges Road Ellesmere

Port ,South Wirral

Cheshire , CH65

4EQ;,United Kingdom


residues of or

contaminated by


Abroad Sava,A51G00508 SAVA GmbH & Co. KG

,Ostertweute 1

,Brunsbuttel,25541,German

y

07 05 04 Yes 5.437 other organic solvents,

washing liquids and

mother liquors

R2 Abroad Recyfuel,DPA

D3200/61080/RGPED

/2008/AP-PU

Zoning Industriel d’Ehein

,4480 Engis (Liege)

Belgium

07 05 04 Yes 2.021 other organic solvents,

washing liquids and

mother liquors

R2 Offsite in

Ireland

Veolia

Environmental

Services Technical

Solutions Ltd.


,Ireland


Page 18 of 35

European

Waste

Code

Hazardous Quantity

(Tonnes

per Year)


Waste

Treatment

Operation

Location of

Treatment

Name and


Next Destination

Facility

Address of Next


,W0050-02.

19 02 09 Yes 0.227 solid combustible wastes

containing dangerous

substances

D10 Abroad Sava,A51G00508 GmbH & Co. KG

,Ostertweute 1


y

20 01 21 Yes 0.07 fluorescent tubes and

other mercury-containing

waste

R4 Offsite in

Ireland

KMK Metals,W0113-

04

Cappincur Industrial Estate

, Daingean Road ,

Tullamore ,.,Ireland

13 02 08 Yes 0.158 other engine, gear and

lubricating oils

R1 Offsite in

Ireland

Veolia

Environmental

Services Technical

Solutions Ltd.

,W0050-02.


,Ireland


residues of or

contaminated by


D10 Abroad Veolia Ellesmere Port

,BS5193IE

VEOLIA ES (UK) Ltd.

,Bridges Road Ellesmere

Port ,South Wirral

Cheshire , CH65

4EQ;,United Kingdom

15 02 02 Yes 7.342 absorbents, filter materials

(including oil filters not

otherwise specified),

wiping cloths, protective

clothing contaminated

by dangerous substances

R1 Abroad Recyfuel,DPA

D3200/61080/RGPED

/2008/AP-PU

Zoning Industriel d’Ehein

,4480 Engis (Liege)

,Belgique,.,Belgium


Page 19 of 35

European

Waste

Code

Hazardous Quantity

(Tonnes

per Year)


Waste

Treatment

Operation

Location of

Treatment

Name and


Next Destination

Facility

Address of Next









,Licence No:

1538449

Vlasweg 12 ,4782 PW

,Moerdijk,.,Netherlands







D10 Abroad Sava,A51G00508 SAVA GmbH & Co. KG

,Ostertweute 1


y

20 01 27 Yes 43.948 paint, inks, adhesives and

resins containing



,Licence No:

1538449

Vlasweg 12 ,4782 PW

,Moerdijk,.,Netherlands

20 01 27 Yes 0.584 paint, inks, adhesives and

resins containing


R2 Offsite in

Ireland

Veolia

Environmental

Services Technical

Solutions Ltd.

,W0050-02.


,Ireland


Page 20 of 35

2.4 Noise Monitoring

An annual noise monitoring survey was undertaken by OES in 2011 in

accordance with Condition 6 of the IPPC Licence.

A total of six (AN1-AN6) noise monitoring locations were surveyed as part of

the assessment. One additional location, namely: AN6, which is located within

the residential area north of the facility, was added during the noise survey.

Results for the 30 minute readings recorded on the August July 2011 are

summarised in Table 2.4.1.

Table 2.4.1 Daytime Noise Measurement (17th August 2011)

Location Grid Ref. Time LAeq LA10 LA90 EPA

Emission

Limit

Value

AN1 12679E,

89670N 14:29-15:30 48.0 51.1 36.5

AN2 126798E,

89581N 16:45-17:30 56.4 53.6 50.6

AN3 126915E,

89528N 18:30-19:00 52.4 54.1 51.1

AN4 126965E,

89572N 15:38-16:08 51.8 52.0 42.5

AN5 126892E,

89711N 15:03-15:33 52.9 50.1 39.8

AN6 126851E,

89763N 17:27-17:57 49.0 49.0 36.3

55 dB(A)

Nighttime noise measurements were also undertaken to monitor noise

emissions from the monitoring locations the results of which are outlined in

Table 2.4.2.

Table 2.4.2 Nighttime Noise Measurement (17th /18th August 2011)

Location Grid Ref. Time LAeq LA10 LA90 EPA

Emission

Limit Value

AN1 12679E,

89670N 22:00-22:30 48.7 51.2 33.0

AN2 126798E,

89581N 22:34-23.04 51.5 50.9 48.8

AN3 126915E,

89528N 23:08-23:38 49.7 50.0 48.8

AN4 126965E,

89572N 23:42-00:12 50.5 49.5 43.6

AN5 126892E,

89711N 00:17-00:47 50.3 44.7 40.9

AN6 126851E,

89763N 00:55-01:25 41.1 45.1 29.4

45 dB(A)

Based on the results above the following conclusions were drawn:


Page 21 of 35

• Noise levels measured at the agreed monitoring points (AN-1 to AN-6) are

attributable to both the operation of the ALPS facility and to external

(transient) sources, which are not associated with ALPS. Predominant

among these other sources are vehicular movements associated with

other commercial enterprises operating within the industrial estate, which

are a significant contribution to overall noise levels in the area.

• Based on observations made during the survey, and taking account of the

influence of off-site transient noise sources, it is considered appropriate to

determine compliance with the noise requirements of the ALPS IPPC

License based on the LA90 parameter (This parameter gives a more

representative indication of the actual plant noise as the contribution of

traffic and other extraneous noises, which may unduly influence the LAEQ

parameter are not included).

• All measurements within the residential area (AN6) were within both the

daytime and night-time limits of 55dB LAeq and 45dB LAeq (30minutes)

respectively. Therefore, the site activities and plant operation at ALPS

Electric (Ireland) Ltd. are not resulting in a negative impact on the nearby

residential area.

• The daytime limit of 55dB LAeq was not exceeded at locations AN1, AN3,

AN4 and AN5 for the monitoring events.

• The daytime limit of 55dB LAeq was exceeded at location AN2 for the

monitoring events. The primary factor driving noise levels in this area was

deemed to be the vehicle traffic moving to and from the loading dock

zone, together with vehicles with their engines left running while waiting to

load or offload. A review of the LA90 shows that the noise level

attributable to the ALPS facility at this location was 50.6 dBA, which is well

within the limit value and marginally below the level measured in Year

2010.

• Using the LA90 parameter, all daytime measurement locations were found

to comply with the IPPC Limit of 55dBA.

• Extraneous traffic noise contributes to night-time noise levels at all of the

perimeter measurement points. Again, although the LAEQ parameter

shows higher than licensed noise levels, the LA90 descriptor shows that

resultant noise levels at the perimeter (with the exception of AN-2 and

AN3) are quite low and well within the relevant limit.

• The night-time noise levels at of AN2 and AN3 exceed the IPPC Limit of

45dBA. The LA90 values at AN2 and AN3 indicate that the likely source of

noise is from equipment running at the ALPS facility.

The report recommended that a review of equipment contributing to the

noise levels detectable at AN2 and AN3 is carried out to identify options to

limit noise emissions at source. The review should include noise sources

contributing to the tonal component of the noise levels.

2.5 Resource Consumption


Page 22 of 35

Gas oil is used in the standby generator and the space heating boiler.

Electricity consumption is mainly related to machine operations and ovens

along with utilities.

Energy consumption (electricity and fuel oil) at the site over the 2011 reporting

period is summarised on Tables 2.5.1. Data for the same period last year is

provided for comparison purposes.

2.5.1 Summary of Water Consumption for 2010 and 2011

A summary of water consumption for 2011 is outlined in Table 2.5.1 and Figure

2.5.1. Water consumption for the 2010 monitoring period is provided for

comparison purposes.

Table 2.5.1 Summary of Water Consumption between 2010 and 2011

Water Consumption (M3)

2010 2011

Jan 423 475

Feb 436 452

Mar 457 481

Apr 438 428

May 439 490

Jun 391 453

Jul 192 274

Aug 361 355

Sep 417 425

Oct 461 401

Nov 494 357

Dec 392 344

0

100

200

300

400

500

600

January

February

March

April

May

June Ju

ly

August

September

October

November

December

Month

M3

2011 2010

Figure 2.5.1 Summary of Water Consumption between 2010 and 2011


Page 23 of 35

Alps Electric (Ireland) Ltd. have made significant efforts to reduce the amount

of water consumed onsite as part of their processing operations which is

reflected in the above results.

As can be seen from Figure 2.5.1 there no significant change in water use for

the 2011 reporting period.

2.5.2 Summary of Electrical Consumption for 2010 and 2011

A summary of electrical consumption for 2011 is outlined in Table 2.5.2 and

Figure 2.5.2. Electrical consumption for the 2010 monitoring period is provided

for comparison purposes.

Table 2.5.2 Summary of Electricity Consumption between 2010 and 2011

Electricity Consumption kWh

2010 2011

Jan 460080 570517

Feb 483620 522011

Mar 530586 576319

Apr 486755 502875

May 466572 491044

Jun 469417 444460

Jul 373048 312432

Aug 428184 436154

Sep 492150 479435

Oct 492217 487391

Nov 547707 467892

Dec 521083 385781

0

100000

200000

300000

400000

500000

600000

700000

January

February

March

April

May

June Ju

ly

August

September

October

November

December

Month

kWh

2011 2012

Figure 2.5.2 Summary of Electrical Consumption between 2010 and 2011


Page 24 of 35

Electricity consumption is mainly related to machine operations and ovens

along with utilities. There was no significant change in water use for the 2011

reporting period which increase by 1% compared with 2010.

Energy costs contribute significantly to overall operating costs. As a result,

energy efficiency is a high priority both in terms of cost and environmental

benefits through the reduction of green house gases. Alps Electric (Ireland) Ltd.

aims to continuously reduce energy consumption by implementing goals

which are measured and tracked on at weekly basis.

Alps Electric (Ireland) Ltd. has implemented an employee energy awareness

campaign in 1997, which has significantly increased over the past few years.

The objective of the programme is to educate and engage employees in

energy management.

2.5.3 Summary of Oil Consumption for 2010 and 2011

A summary of oil consumption for 2011 is outlined in Table 2.5.3 and Figure 2.5.3.

Oil consumption for the 2010 monitoring period is provided for comparison

purposes.

Table 2.5.3 Summary of Oil Consumption between 2010 and 2011

Oil Consumption

2010 2011

Jan 1667 1667

Feb 1667 1667

Mar 1750 1833

Apr 938 1770

May 893 1858

Jun 938 1858

Jul 536 973

Aug 714 1593

Sep 982 1947

Oct 893 833

Nov 1719 917

Dec 1250 625


Page 25 of 35

0

500

1000

1500

2000

2500

January

February

March

April

May

June Ju

ly

August

September

October

November

December

Month

litres

2011 2010

Figure 2.5.3 Summary of Oil between 2010 and 2011

Analysis of the data indicates that total consumption of oil increased by 10%

between the 2011 (15,321 litres) when compared with the 2010 (13,947litres)

period. The increase is a result of the increase in production in 2011.

2.5.4 Summary of LPG Consumption for 2010 and 2011

A summary of LPG consumption for 2011 is outlined in Table 2.5.4 and Figure

2.5.4. LPG consumption for the 2010 monitoring period is provided for

comparison purposes.

Table 2.5.4 Summary of LPG Consumption between 2010 and 2011

LPG Oil Consumption Heating

2010 2011

Jan 6339 6946

Feb 6339 6946

Mar 6656 7641

Apr 6705 6383

May 6386 6702

Jun 6705 6702

Jul 3831 3510

Aug 5109 5744

Sep 7024 7021

Oct 6703 1085

Nov 7127 1194

Dec 6091 814


Page 26 of 35

0

1000

2000

3000

4000

5000

6000

7000

8000

9000

January

February

March

April

May

June Ju

ly

August

September

October

November

December

Month

litres

2011 2010

Figure 2.5.4 Summary of LPG between 2010 and 2011

Analysis of the data indicates that total consumption of LPG decreased

by 20% between the 2011 (84,004 litres) and 2010 (75,015 litres) period.

Gas oil is used in the standby generator and the space heating boiler.

Alps Electric (Ireland) Ltd. has improved the energy monitoring system

which has resulted in better tracking and awareness and consumption.

2.5.4 Summary of Calor Gas Consumption for 2010 and 2011

A summary of Calor Gas consumption for 2011 is outlined in Table 2.5.5 and

Figure 2.5.5. Calor Gas consumption for the 2010 monitoring period is provided

for comparison purposes.

Table 2.5.5 Summary of Calor Consumption between 2010 and 2011

Calor Gas Consumption Canteen

2011 2010

Jan 314 276

Feb 314 276

Mar 345 290

Apr 111 129

May 117 123

Jun 117 129

Jul 61 74

Aug 100 98

Sep 123 135

Oct 54 123

Nov 60 236

Dec 41 172


Page 27 of 35

0

50

100

150

200

250

300

350

400

January

February

March

April

May

June Ju

ly

August

September

October

November

December

Month

litres

2011 2010

Figure 2.5.5 Summary of Calor Gas between 2010 and 2011

Calor Gas is used for the canteen area for food processing. There was a

14%decrease in the amount of calor gas used onsite in 2011.

Annual Environmental Report March 2011

Page 28 of 35

2.6 Monitoring and Enforcement

EPA Inspections

A single unannounced Agency inspection (non-monitoring) was undertaken

on 6th July 2011. The site inspection commenced at 10.00 a.m. and the

following personnel were in attendance:

Representing Alps Electric (Ireland) Ltd.

Ms. Maria Walsh Quality Systems Engineer

Mr. John Foley Quality Assurance Manager

Representing the Environmental Protection Agency:

Maria Lenihan Inspector

During the inspection, the Agency Inspector did not raise any non-

compliance with the IPPC licence. The inspector commended the licensees

approach in addressing an odour complaint in October 2010 and

commitment to carrying out weekly odour monitoring surveys since February

2011.

During the inspection special attention was paid to the diesel tank and bund,

chemical store, paint and laser sludge room, surface water monitoring points

and fire water retention tank.

During the site inspection 5 observations were noted. These observations,

although not non-compliances, were addressed by Alps Electric (Ireland) Ltd.

as outlined in Table 2.6.1.


Page 29 of 35

Table 2.6.1 Summary of Site Inspection Observations non compliances and current status of corrective actions implemented by Alps

Electric (Ireland) Ltd.

Ref. Observations Corrective Action Action Status

1 On review of the diesel bund integrity

test report the following was noted:

• The water level was to the oil filter

level of the diesel tank only due to a

possibility of waster damage to the

insulation that had been put in place

around the filter. The report states

that “the vast majority of bund

failures occur at the

vertical/horizontal joint so the

hydrostatic test will address this

statistically high leak area. The risk of

leakage at a higher level in the bund

was addressed by detailed

inspection of the external wall on 3

accessible sides”. One of the walls

was therefore inaccessible for visual

inspection and there was No sign off

by a suitably qualified person

regarding this visual inspection.

• The height of the water in the bund

was 1,360m at the beginning of the

test and the height of the water was

1,355m at the end of the test. The

detail for pass/fail criteria was not

specified in the report.

• The report states that “the diesel tank

Diesel Bund Integrity Testing

1. Submit a proposal to the

Agency within one month of

receipt of this report to verify

the integrity of the diesel

tank bund on-site.

2. Ensure the pass/fail criteria

for integrity testing of bunds

on-site is specified in all

future bund integrity reports.

A re-test of the diesel tank bund took place on the 16th

of August and Tuesday the 23rd of August by

Chemstore. The bund passed the test and the results

of the test were submitted to the Agency on the 7th of

September 2011.


Page 30 of 35


surface is now showing

2

It was noted that integrity testing of the

storm water drainage system had not

been undertaken as it runs under the

building.

It was noted that repairs necessary for

the storm water drainage system have

not been completed to date due to

associated costs and locations.

Integrity Testing & Repair of

Storm Water Drainage

System

Submit a proposal within one

month of receipt of this

report to address the

integrity of the stormwater

drainage system from S10

onwards and for the repair

of the identified failed

sotrmwater pipework S1-S2,

S3-S4, S4-S7, S7-S8, S8-S9, and

S9-S10.

A camera survey of the storm lines S9-S14 was

completed by Kerry Drain Services on the 29th of July

2011. The survey indicated that the section is in good

condition and does not require repair.

A section which was previously obstructing the

camera was cut from between S9-S10 thus allowing

access to S10, S11, and S14.

S12 and S13 were not accessible at these are sealed

off underneath the Quality Laboratory floor. Due to

this inaccessibility the pressure test cannot be

completed.

Repairs to storm drains S1-S2, and S9-S10 have been

completed. It is planned to complete the remaining

repairs as follows at a cost of €11,500:

A3-S4 December 2011

S4-S7 March 2012

S7-S8 July 2012

S8-S9 July 2012

3 On review of the storm water monitoring

results for the site it was noted that the

pH buffer 10 is being utilised as an

Analytical Quality Control (AQC) for pH

monitoring onsite.

AQC for PH Monitoring

Put in place a representative

AQC for pH monitoring with

an acceptable tolerance

range. When sufficient AQC

data is gathered carry out a

A representative AQC for pH monitoring with an

acceptable tolerance range will be implemented. A

pH buffer of 7 will be used. This information will be

included in a quality control chart for analysis. It is

planned to commence from 11th July 2011 onwards.


Page 31 of 35


statistical analysis of this

date for the generation of a

quality control chart that

can be utilised going

forward.

4 The licencing officer raised concern that

sludge removed by the pulse jet system

is taken offsite as hazardous waste

sludge among the waste sludge

generated from the paint process area.

Concern was raised regarding the use of

the EWC code for both sludge and dust.

The EWC code used for waste hazardous

sludge from this facility is 20 01 27 and is

not appropriate EWC Code.

Disposal of Dust from the

Pulse Jet System

Submit a proposal to the

Agency within one month of

receipt of this report for the

designation of appropriate

EWC codes for the waste

sludge and dust generated

from the paint process on-

site for Agency review and

approval.

Following consultation with our hazardous waste

disposal contractors, Veolia, we have confirmed that

the hazardous waste sludge will be classified under

EWC Code 08 01 13 pending approval from the EPA.

This was later approved with the Agency via email

dated 10th of August 2011.

5 The night-time LA90 was exceeded at the

boundary locations AN2 and AN3.

Contributors to noise in these areas

included the abatement plant and

compressor on-site. It was noted that no

noise complaints were received in 2010

and 2011 and that annual noise

monitoring for 2011 is due to be

completed on-site shortly.

Noise Monitoring Report

2010

On completion of the noise

monitoring survey for 2011,

the licensee shall take

necessary measure to

address any noise

monitoring location that

does not comply with the

noise emission limits

specified in the licence.

Noise monitoring took place on the 17th and 18th of

August by OES Consulting Ltd. A copy of the report

was issued to the Agency under separate cover.

As recommended in the report a review of the

equipment contributing to the noise levels at AN2 and

AN3 was undertaken to identify options to limit noise

levels. In addition the tonal components of the noise

levels were reviewed.


Page 32 of 35

Monitoring Inspections

No EPA monitoring inspections were undertaken for the 2010 monitoring

period.

2.7 Reported Incidents Summary

There were no environmental incidents for the 2011 reporting period.

2.8 Complaints Summary

Alps Electric (Ireland) Ltd. has established and maintains an IS0 14001:2004

accredited Environmental Management System (EMS). This has been in place

since 1997. This is used to manage environmental performance, and

implement procedures to monitor, investigate and log any complaints of an

environmental nature.

There were no complaints for the 2011 reporting period.


Page 33 of 35

3. Environmental Management Programme – Summary Update

Section 3 of the AER contains summary information on the Alps Electric

(Ireland) Ltd. Environmental Management Programme (EMP), together with a

review of performance in meeting specified targets throughout 2011.

A summary of the progress achieved in relation to the objectives and targets

for 2011 EMP is presented in Attachment E of the Annual Environmental

Report.

It is noted that both the EMP and Schedule of Objectives and Targets fall

under the site Environmental Management System and accordingly, are

included within a structured system of management review and periodic

auditing by internal auditors.

3.1 EMP Report 2012

Much of the effort undertaken in relation to environmental management at

the site is focused on compliance with the conditions of the IPPC licence.

Significant progress has been made in this area, and Alps Electric (Ireland)

Ltd. have a high level compliance with the Licence. The following sections

contain a summary of progress during 2011 and the revised plant objectives

and targets and EMP for 2012 is included as Attachment F.

3.1.1 Solvent Management Plan (SMP)

In accordance with Condition 6.15 of the IPPC licence Alps Electric (Ireland)

Ltd. has prepared a Solvent Management Plan (SMP) for the 2011 reporting

period. The SMP has been prepared as per the definition of an organic

solvent (Council Directive 1999/13/EC), and in accordance with any relevant

guidelines in Annex Ill of the Directive. Alps Electric (Ireland) Ltd. retain records

and supporting documentation including the methodology used for data

collection as part of the SMP plan.

Solvent consumption for cleaning product, and adhesive coating has not

exceeded 2 and 5 tonnes per annum respectively in accordance with

Condition 6.16 of the IPPC licence.

3.1.2 Bunding and containment

In accordance with Condition 3.5 of the IPPC Licence all tanks and

containers and their resistance to penetration by water or other materials

carried or stored therein shall be tested at least once every three years.

Bund testing was undertaken in 2010 and all of the bunds onsite passes

inspection. The next bund integrity inspection will be undertaken in 2013.

Kerry Drain Services undertook pressure testing of storm water lines around the

facility. The report was later amended to include storm water lines that were


Page 34 of 35

not surveyed during the first inspection. A programme of works is in place to

address repairs identified as part of the survey.

Following an Agency inspection in 2011it was noted that integrity testing of

the storm water drainage system which runs under the production facility had

not been undertaken. A camera survey of the storm lines S9-S14 was

completed by Kerry Drain Services on the 29th of July 2011. The survey

indicated that the section is in good condition and does not require repair.

Repairs to storm drains S1-S2, and S9-S10 have been completed. It is planned

to complete the remaining repairs as follows:

A3-S4 December 2011

S4-S7 March 2012

S7-S8 July 2012

S8-S9 July 2012

3.1.3 Decommissioning and Residuals Management Plan

Condition 10.2 of the IPPC Licence requires the preparation and submission to

the Agency of a Decommissioning and Residual Management Plan (RMP).

The plan was prepared by external independent consultants OES in 2009.

The RMP is updated on an annual basis as part of subsequent AER’s. This

update will takes account of any changes in the plant layout, processes,

materials and chemicals stored which may affect the RMP through

contribution to additional disposal or cleaning costs in accordance with

Condition 10.2.2.

The overall cost will be updated to reflect inflation over the interval and will

be revised on the basis of the most recent WPI* at that time. In accordance

with Agency guidance a detailed review of the Decommissioning and

Residuals Management Plan is scheduled for 2012.

WPI = Appropriate Wholesale Price Index (Capital goods Building and Construction (i.e.

Materials and wages) Index as published by the Central Statistics Office for the year since last

closure cost calculation.

3.1.4 Environmental Liabilities Risk Assessment

Under Condition 12.2.2 of the IPPC Alps Electric (Ireland) Ltd. were required to

carry out an Environmental Liabilities Risk Assessment (ELRA). OES were

commissioned by Alps Electric (Ireland) Ltd. to carry out an ELRA of facility.

The assessment consisted of a site inspection, interviews and documentation

review. The report on this assessment was submitted to the Agency 2009. The

Environmental Liabilities Risk Assessment (ELRA) was reviewed and update in

2012.

The ELRA is intended to form the basis for determination of an appropriate

level of environmental insurance cover and is to be reviewed annually. The

IPPC licence Condition 12.2.2 requires Alps Electric (Ireland) Ltd. to review the

ELRA as necessary to reflect any significant change on site, and in any case,

every three years following initial agreement.


Page 35 of 35

The ELRA indicates that the Alps Electric (Ireland) Ltd. facility is well defined in

terms of historic and current environmental impacts. The site is also subject to

an on-going monitoring programme for emissions to air and noise, and water.

The current environmental management programme on the site has reduced

the risk of the development of new significant environmental liabilities to a low

level.

In overall terms, Alps Electric (Ireland) Ltd. have insurance policies in place to

deal with the eventualities evaluated in this assessment, and at levels far in

excess of the financial implications of any single or combined liability.

3.1.5 Efficiency in the Use of Raw Materials

Alps Electric (Ireland) Ltd. continually strives to improve the efficiency of its

processes in order to reduce the raw materials consumed and the waste

produced.

Efficiencies throughout the plant are tracked using the “Operational

Equipment Efficiency” system. This system details process information such as

quantities built, time worked, downtime issues, equipment issues, reject items

etc.

This information is inputted into a tracking system which generates a weekly

report. The data is reviewed and actions are taken for continuous

improvement.

Attachment A

Attachment A

Company O

rganisation Structure

Company O

rganisation Structure

Human Resources Manager Breda Flaherty

Organisation Structure of Alps Electric Ireland Ltd.

Finance Manager Roland Neher

Business Planning Manager

Yoshiriro MurakamiMIS

Mgr Patrick Tuohy

Customer Service Group (CSG)

Mgr Patrick Tuohy

Logistics and WHMgr George O’Callaghan

Operations ManagerSr Manager Alan Perry

Quality Control Section 1

Mgr Thomas O’Leary

EngineeringMgr James Sugrue

Engineering Manufacturing & Facilities

Mgr Peter Creagh

Moulding and PaintingMgr Anthony Barry

Final AssyMgr Alan Perry

SMT/ Manual Production Mgr Kieran O’Sullivan

Managing DirectorBrendan O’Shaughnessy

Supply Chain Management Sr Mgr

Patrick Tuohy

Residential DirectorYoshiriro Murakami

EngineeringSr Manager James Sugrue

Quality Assurance Sr Manager John Foley

NPIMgr Patrick Tuohy

# Change

O= Promotion

&= Holds two or more positions

Attachment B

Attachment B

Site Location

Site Location

Note Ref

Scale.

Issue no. CheckedDate Approved

Client

Date Scanned

Title

Project No.

Figure No.

environmental health and safety engineering project management © Copyright of OES Consulting, 2nd Floor, FBD House, Fels Place, Tralee Co. Kerry.

Tel: 353 (0)667128321 Fax: 353 (0)66 7180061 Email: [email protected]

By

Rev.

NTS 1141_01

Figure 1

Site Location

01

ALPS ELECTRIC IRELAND LTD.

ALPS Electric Ireland

Ltd. Site Boundary

N

Production Floor

Car Park

WorkshopCar Park

Car Park

Canteen

Car Park

Car ParkSite Boundary

Attachment C

Attachment C

Process Flow Diagram

Process Flow Diagram

Alps Electric Ireland Ltd. Process Flow Diagram

3) Detrashing of

Components

4) Surface

Mount Process

5) Manual

Assembly/Semi-

Automated

Assembly (SAM)

6) Final

Assembly

2) Painting and

Lazer Etch

Process

1) Moulding

Process

Printing

Required

YES

NO

OVERALL PROCESS FLOWThe overall production process at Alps Electric involves the simultaneous fabrication

of structural plastic parts and assembly of components onto printed circuit boards.

These are then brought together to form the final product. The plastic parts may

require painting and laser etching for cosmetic purposes. The fabrication of plastic

parts involves a moulding process, step 1, and, if required, a painting and laser

etching process, step 2. Assembly of printed circuit boards incorporates detrashing

of delivered components, surface mount process and manual assembly, steps 3, 4

and E respectively.

Attachment D

Attachment D

Paint and

Paint and Lazer

LazerProcess

Process

Alps Electric Ireland Ltd.

Painting and Laser etch Process

INPUTS PROCESS Emissions

Moulded Parts

from Step 2

Step 2

2.1 Loading of

Parts

2.2 Mixing of Paint

and Thinners

2.3 Ionised Air

2.5 Application

of Paint

2.4 Addition of

Hardner

2.6 Flash off Period

2.7 Curing Oven

2.8 Repeat for

each colour

required

Solvent

emissions

waste drums

Solvent emission

paint particles

heat output

solvent emission

Paints, thinners

Energy/

Compressed air

Mixed paint,

Hardener

Energy Mixed

paint

Energy

Energy

heat output

solvent emission

Alps Electric Ireland Ltd.

Painting and Laser etch Process

INPUTS PROCESS Emissions

Energy

2.9 Move to

laser Machine

2.10 Laser

etching of

painted parts

2.11 Unload &

Transfer of Parts

Fume from

etched paint

Attachment E

Attachment E

Status Update Environmental M

anagement

Status Update Environmental M

anagement

Plan 2011

Plan 2011

1

4.0 Management Programmes, Objectives & Targets

5.0 The following table consists of Management Programmes set for 2011.

Management Programmes Tasks Responsible Completion

Date

Comments

MP 66. Compliance with

legal requirements

• Completion and submission of AER

(Annual Environmental Report) for 2010.

• Review and update if necessary the

Decommissioning Management Plan.

• Review and updated if necessary the ELRA

(Environmental Liabilities Risk

Assessment).

John Foley 31/03/2011 Complete.

AER submitted to the EPA

electronically on 30/03/11.

MP 52 Control of emissions

to atmosphere.

Ensure that all emission levels are in compliance

with IPPC limits.

James Sugrue 30/12/2011 Quarter 3 monitoring took place

on 28/09/11. All emission limits

within compliance levels..

MP 60 Control of resource

usage & energy efficiency

(oil, gas, LPG)

Monitor, control and reduce where possible the use

of energy, water, oil, gas, LPG.

Peter Creagh 16/12/2011 Ongoing monitoring taking place.

MP56 Control of

Hazardous Waste

Ensure that all hazardous waste in stored correctly

and removed off site by a licensed contractor.

Peter Creagh 30/12/2011 Planned visit of Veolia to take

place.

MP 58 Control of Noise

emissions.

External Environmental Noise monitoring to take

place.

John Foley 31/08/2011 Noise survey completed on

17/08/11. Exceedance at locations

AN2 & AN3 additional analysis

of equipment to take place.

MP62 Monitoring &

Reduction of water

consumption

ALIR to reduce water usage thereby reduce costs.

Planned 3.5% reduction for 2011.

Peter Creagh 23/12/2011 Ongoing monitoring taking place.

MP61 Control of Supplier

Activities

ALIR to ensure that all suppliers are compliant to

relevant legal requirements.

George O Callaghan 01/09/2011 As detailed on the Purchase

Order.

MP 54 Solvent Reduction

Plan

Investigate the possibility of reducing the amount of

solvent in use within the plant

James Sugrue 30/06/2011 Complete. The elimination of the

wave solder machine reduced the

consumption of solvent by 25%.

MP 59 Control of Non-

Hazardous Waste

Reduction in the amount of plastic parts being

scrapped and sent for re-cycling.

Thomas O Leary 23/12/2011 See overall presentation on

reduction of scrap.

2

Management Programmes Tasks Responsible Completion

Date

Comments

MP63 Safe Place of work

for all personnel.

Occupational exposure monitoring to be completed

where necessary.

Joanne O Sullivan 16/12/2011

28/02/12

Occupational monitoring for PAL

Laser area and SAM area to be

completed early 2012

MP 57 Odour Prevention ALIR to ensure that zero odour is being emitted

from the plant.

Thomas O Leary 31/05/2011 Ongoing odour sniff test taking

place.

MP64 Product Design

Activities

Ensure that all environmental considerations are

taken into account in conjunction with Auto Japan

when new products are being implemented.

James Sugrue 16/12/2011 Planned introduction of Y555 all

environmental concerns

addressed at ALPS Japan.

MP32 Safe system of work

for all employees

Ensure that all requirements of the EPD (Explosive

Protection Document) are completed.

James Sugrue 30/06/2011 All recommendations

implemented with the exception

of the 3k mixing process as this is

no longer in use.

MP65 Visual Impact Visual impact to be taken into consideration for any

modifications to current building or for any new

proposed building projects.

James Sugrue 16/12/2011 N/A

MP53 Control of

Contractors while working

on site

All contractors to be informed of the

environmental/Health & Safety requirements while

working on site.

All Managers

31/05/2011

Feb 2012

Contractors list to be updated and

new information to be submitted

to all contractors. Safety Code of

Practice for contractors to be

updated.

All information submitted

awaiting replies and training to be

completed.

MP67 Maintain

Registration to ISO14001

EMS

Re-certification audit due on 19/20/21 April 2011 Marie Walsh 30/04/2011 Complete. Continued registration.

MP70 Control of Aqueous

Discharge

Zero hazardous discharge from the plant. Alan Perry 30/12/2011 Complete

MP72 Site preparation in

the event of an emergency.

Completion of fire water retention tank James Sugrue 29/07/2011

30/04/12

Door ways to be completed

during summer shutdown.

MP69 Compliance with air

emission monitoring

requirements.

No exceedance in air emissions from the plant. James Sugrue

31/03/2011

No air emission exceedance to

date for 2011.

3

The following table consists of the objectives and targets set for 2011.

Objectives Targets

Management

Programmes

Tasks Responsible Date Status

OBJ 66: Product

Design.

ALIR in conjunction with

Auto Japan to ensure that

any new products

introduced or any

modification to existing

products are

environmentally friendly

where possible.

MP64 Product

Design Activities

Review of ECN’s for any new

products or modification to

current products that may have

an environmental impact.

Patrick Tuohy 22/12/10 Closed

OBJ 69: Completion

and submission of

AER (Annual

Environmental

Report) for 2010.

All associated requirements

of the IPPC Licence P0835-

01 to be completed.

MP 66 Compliance

with legal

requirements

Compile 2010 licence

information and submit to

EPA.

Marie Walsh &

OES Consulting.

31/03/11 Closed

OBJ 70: Compliance

with air monitoring

requirements.

All monitoring requirements

to be completed.

MP69 Compliance

with legal

requirements on air

monitoring

Quarterly monitoring of the

following vents: A1-2,,A2-

3,A2-4. Continuous monitoring

of FID for A1-3.

Marie Walsh &

Odour

Monitoring.

23/12/2011 No exceedance to

date on any

emission points.

OBJ 68: Maintain

certification to

ISO14001 EMS

Zero major non-

conformances during ISO

14001 surveillance audit or

internal audits by 22-Dec-

2011

MP 67 Continue

compliance to

ISO14001 EMS

certification.

Continuous review of EMS. Marie Walsh 22/12/11 Continued

certification

achieved.

OBJ 71: Control of

aqueous discharge

from the plant. Zero

environmental

contamination from

any discharge from

the plant.

ALIR to ensure that no

environmental

contamination of surface

water, groundwater, subsoil

etc shall take place.

MP 70 Control of

Aqueous Discharge.

Continuous analysis of water

samples for Ph, visual

appearance and COD.

Marie Walsh &

Southern

Scientific.

22/12/11 No contamination

detected.

4

Objectives Targets

Management

Programmes


OBJ 54 & OBJ 70:

Control of

emissions to

atmosphere for

2011 period.

All monitoring

reports to be

reviewed to ensure

compliance.

Continuous

monitoring of

abatement plant for

Total Organic

Carbon (as C).

Discussion with

EPA to take place to

amend current

licence re emissions

from new chemical

shed.

MP 52 Control of

emissions to

atmosphere.

(a) Ensure that all

emission Limit Values

are within the

allowable limits.

(b) Amendment of IPPC

licence to incorporate

emissions from the

new chemical shed

into A1-3.

Marie

Walsh/James

Sugrue/Odour

Monitoring

Ireland.

22/12/10 All emission levels

compliance. Following

discussions with EPA

No amendment

required to IPPC

licence. Emissions

from chemical shed to

be incorporated into

solvent mgt plan.

OBJ 61:

Management of

non hazardous

waste to final

disposal.

No environmental

contamination due to

non hazardous waste

Removal of non

hazardous waste by

licensed contractor

at all times.

MP59 Control of

non Hazardous

Waste.

Correct storage and segregation

of non hazardous waste at all

times.

Use of licensed contractors.

George O

Callaghan

30/12/11 Complete

OBJ 60: Control of

external Noise emissions.

Environmental noise

survey to take place.

MP 58 Control of

Noise Emissions.

Noise monitoring to take place

as per EPA recommendations.

Marie Walsh 30/12/2011 Survey took place on

17th

August

2011.Locations AN2 &

AN3 exceeded

allowable levels.

OBJ 59: Zero

Odour Pollution

Zero complaints re

odour pollution

MP:57 Odour

Prevention

Odour sniff test to take place to

confirm if there is an odour

being emitted from the plant.

Marie Walsh 30/06/2011 No complaints to date

for 2011.

5

Objectives Targets

Management

Programmes


OBJ 36:

Control/reduce the

risk of incidents

from

explosive/flammable

atmosphere.

Recommendations

from EPD to be

implemented.

MP 32 Safe place

of work for all

ALIR personnel

(Explosive

Atmosphere).

All recommendations to be

implemented.

James Sugrue March

2011

Complete

OBJ:55 Control of

Contractors.

All contractors to

remain compliant to

environmental and

health/safety

requirements while

working on site.

MP:53 Control of

contractors while

working on site

All current contractors to

receive re-training on the

environmental, health and

safety requirements while

working on site.

Peter

Creagh/Marie

Walsh/Joanne O

Sullivan

30/06/2011

Feb 2012

A complete review

of all contractors

have taken place all

now re-catergoised.

New documentation

submitted to all

contractors.

OBJ 62: Control of

energy usage

Increase average

production value per

KW from €11.29 to

€11.70.

MP 60 Control of

resource usage (oil,

gas, , LPG) and

energy efficiency.

Continuous emphasis on

reduction of resources.

Peter Creagh 16/12/10 Complete

OBJ 67: Control of

Visual Impact

Visual impact to be

considered for any

planned

modifications to the

premises.

MP:65 Visual

impact

All planning requirements to

be considered in the event of

any proposed modifications to

the building.

James Sugrue 30/12/2011 N/A. No

modifications to

plant took place.

OBJ 64: Reduction

in water usage.

Monitoring and

reduction of water

consumption

MP62 Monitoring

and reduction of

water consumption.

Reduce water usage where

possible (eg sanitation)

Peter Creagh 30/12/2011 Water usage

reduced due to

reduction in

headcount.

OBJ 65:

Occupational

Exposure

Monitoring

Ensure that

occupational

exposure monitoring

is completed in

relevant areas.

MP63 Occupational

Exposure

monitoring of all

relevant personnel

Ensure safe place of work for

all employees.


31/03/12

Rescheduled to be

completed early

2012.

6

Objectives Targets

Management

Programmes


OBJ 56: Solvent

usage reduction

programme.

(a)To reduced the

amount of solvent

used within the

washing processes.

MP54 Solvent

Reduction Plan.

Completion of an accurate

solvent management plan for

2010 and reduce if possible the

amount of solvents in use for

cleaning.

Anthony

Barry/Alan

Perry/Thomas O

Leary.

22/12/11 Complete.

Updated

Solvent Mgt

Plan submitted

to EPA.

OBJ 73: Site

preparation in the

event of an

emergency.

Remaining exit

points to be sealed

up to 25mm during

summer shutdown.

MP 72 Prevention

of Environmental

Pollution resulting

from as emergency

situation.

Modification to exits in

order to seal the areas and

prevent fire water

escaping.

James

Sugrue/Peter

Creagh

30/09/2011

30/04/12

Rescheduled to

early 2012.

OBJ:63 ALIR to

ensure that all

suppliers in use are

compliant to

relevant

regulations eg

ROHS, REACH.

ALIR to use confirm

suppliers

conformance to legal

requirements.

MP61 Supply Side

Activities

All new suppliers to submit

written confirmation of

compliance or approved green

procurement document.

George O

Callaghan

30/12/2011 No new suppliers in

use.

OBJ:58 Investigate

the possibility of

disposal of sludge

waste to landfill as

opposed to

hazardous waste

disposal.

Reduction in the

quantity of

hazardous waste

going for disposal.

MP:56 Control of

Hazardous Waste

Analysis of paint sludge to take

place to confirm solvent

content when paint is dry. If

acceptable investigate

possibility to send to landfill

Marie Walsh 30/06/2011 Currently not

possible to send to

landfill due to

excess cost. Sludge

will continue to be

sent to Veolia for

hazardous water

disposal.

Attachment F

Attachment F

Proposed Environmental M

anagement Plan

Proposed Environmental M

anagement Plan 2012

2012

ALPS ELECTRIC (IRELAND) LTD

AGENDA FOR ISO 14001 ENVIRONMENTAL MANAGEMENT REVIEW

1 of 4

4.0 Management Programmes, Objectives & Targets

The following table consists of Management Programmes, Objective and Targets set for 2012.

Management Programmes Objectives Tasks/Target Responsible Completion Date

MP 76. Compliance with

legal requirements

OBJ 77 Ensure that ALIR

remains compliance with all

the requirements of the IPPC

license.

• Completion and

submission of AER

(Annual

Environmental

Report) for 2011.

• Review and update if

necessary the

Decommissioning

Management Plan.

• Review and update if

necessary the ELRA

(Environmental

Liabilities Risk

Assessment).

John Foley/ Marie

Walsh

31/03/2013

MP 77 Control of emissions

to atmosphere.

OBJ 78 Ensure that all emission

levels are in compliance with

IPPC limits.

Quarterly monitoring of stacks

A1-3, A2-1, A2-3, A2-4

Monthly analysis of RTO

abatement download

information.

James Sugrue/Marie

Walsh

31/12/12

MP 84 Control of electrical

energy usage.

OBJ 85 Monitor, control and

reduce where possible the use of

energy within the plant.

Sustain current rate of €11.68

per KWA.

• Investigate

updating/changing

current compressors.

• Investigate the

implementation of

standby and

hibernation rules for

PC’ & laptops.

Peter Creagh 28/12/12



2 of 4

MP 80 Control of Hazardous

and contaminated Waste

OBJ 81 Ensure that all hazardous

waste in stored correctly and

removed off site by a licensed

contractor.

• Review of all

hazardous waste

categories to ensure

that they are correct

for the specific waste

type.

• Review new online

system introduced by

Veolia to ensure it

retains all relevant

information.

Peter Creagh/Marie

Walsh

28/12/12

MP 82 Control of Noise

emissions.

OBJ Compliance with IPPCL

requirements for noise. • External

Environmental Noise

monitoring to take

place.

• Investigate the cause

of exceedance at

AN2 & AN3

locations.

• Noise considerations

to be taken into

account when

replacing/investing in

any equipment.

James Sugrue/Marie

Walsh

28/12/12

MP 88 Monitoring &

Reduction of water

consumption

OBJ 90

ALIR to reduce water usage

where possible.

• Implement the

metering of chillers.

• Implement new water

control system ie

monthly checking

and dosing of water

systems.

Peter Creagh

30/06/12

MP Control of Supplier

Activities

ALIR to ensure that all suppliers

are compliant to relevant legal

requirements.

Review of all current MSDS

on file to ensure they are the

most up to date revision.

Patrick Tuohy / Marie

Walsh

30/06/12



3 of 4

MP 74 Solvent Reduction

Plan

OBJ 88 Investigate the possibility

of reducing the amount of solvent

in use within the plant

• Investigate the

possibility of

implementing PVD

Testing in order to

reduce solvent usage.

• Remove spot dip and

replace with robotic

soldering.

• Investigate

eliminating PVA

concoat.

James Sugrue/Peter

Creagh

Dec 2015

MP 81 Control of Non-

Hazardous Waste

OBJ 82 Reduction in the amount

of plastic parts being scrapped and

sent for re-cycling.

Maintain emphasis of scrap

reduction.

Thomas O Leary 28/12/12

MP 63 Safe Place of work

for all personnel.

OBJ 65 Occupational exposure

monitoring to be completed where

necessary.

PAL, SAM areas to be

completed.


MP Odour Prevention ALIR to ensure that zero odour is

being emitted from the plant.

Ensure correct control

methods are maintained at all

times when handling/using

hazardous chemicals.

Alan Perry 18/12/12

MP 85 Product Design

Activities

OBJ 86 Ensure that all

environmental considerations are

taken into account in conjunction

with Auto Japan when new

products are being implemented.

Continue to create

environmentally friendly parts

as per customer requirements

and legal requirements.

James Sugrue/Patrick

Tuohy

MP 86 Visual Impact OBJ 87 Visual impact to be taken

into consideration for any

modifications to current building

or for any new proposed building

projects.

In the event of any

modifications to the plant

ALIR to comply with any

planning requirements.

James Sugrue 28/12/12

MP 89 Control of

Contractors while working

on site

OBJ 80 All contractors to be

informed of the

environmental/Health & Safety

requirements while working on

site.

Ensure all contractors comply

with ALIR rules while

working on site.

Peter Creagh/Marie

Walsh/Joanne O

Sullivan

30/04/12

MP 67 Maintain Registration OBJ 91 Maintain compliance Ensure that zero major non- Marie Walsh 28/12/12



4 of 4

to ISO14001 EMS with ISO14001 requirements. conformances are raised

during internal and external

audits.

MP83 Control of Aqueous

Discharge

OBJ 84 Zero hazardous discharge

from the plant.

Maintain good work practices

and environmental training

within the plant.

Alan Perry 28/12/12

MP72 Site preparation in the

event of an emergency.

OBJ 73 Completion of fire water

retention tank.

Ensure that all door levels are

raised.

James Sugrue 30/06/12

MP 87 Env Health & Safey

control of ozone depletion

substances.

OBJ 89 Control and use of

substances that deplete the ozone

layer and control of certain

fluorinated greenhouse gases (F

gas)

• Eliminate the use of

equipment that

contains R22 gas.

• Maintain an F Gas

Register

Peter Creagh 28/12/12

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