for inspection purposes only. consent of copyright owner ... · esp014 calibration of the...

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Smart/J/y Europe Limited Application for a Revised IPPC Licence Attachment C.1 - Site Management and Control

CONTENTS

Section Page No

1.

2.

3.

4.

5.

6.

7.

6.

INTRODUCTION TO MANAGEMENT SYSTEMS.. ....................................................... 2

MANAGEMENT ORGANISATIONAL STRUCTURE INCLUDING ENVIRONMENTAL MANAGEMENT RESPONSIBILITY LEVELS ............................... 2

MANAGEMENT OF TREATMENT AND ABATEMENT SYSTEMS .............................. 6

CALIBRATION AND MAINTENANCE SYSTEMS ........................................................ 6

WASTE CONTROL SYSTEMS ..................................................................................... 6

GENERAL OUTLINE OF QUALITY CONTROL SYSTEM ............................................ 7

ENVIRONMENTAL MANAGEMENT PROGRAMME .................................................... 9

ONGOING ASSESSMENT OF ENVIRONMENTAL PERFORMANCE.. ..................... IO

APPENDICES

C.l .I IS0 9001 : 2000 Certificate of Accreditation

C.l.2 Smartply Organisational Structures

Cl .3 Environmental Management Programme

Cl .4 Environmental Policy

C.1.5 Quality Policy

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Smartfly Europe Limited Application for a Revised IPPC Licence Attachment Cl - Site Management and Control

1. INTRODUCTION TO MANAGEMENT SYSTEMS

SmartPly Europe Limited has a structured management approach to the operation of the business in terms of product quality, process control, environment, safety and training.

Safety and quality management systems are audited on an ongoing basis by a combination of internal audit teams and National Standards Authority of Ireland (NSAI) external audits. The quality management system is certified to IS0 9001:2000 by NSAI as presented in Appendix C.1 .I.

2. MANAGEMENT ORGANISATIONAL STRUCTURE INCLUDING ENVIRONMENTAL MANAGEMENT RESPONSIBILITY LEVELS

The Lead Team management structure at SmartPly Europe Limited is illustrated in Figure C.l.1 below. SmartPly Europe Limited operates a relatively flat management structure with a strong emphasis on team working. The management structure of each department is separately presented in Appendix C.1.2.

Ultimate responsibility for environmental management rests with the Managing Director. Environmental objectives and targets are set for each of the functional areas that report directly to the Managing Director.

Each functional area can initiate actions to ensure compliance with environmental policies and procedures, identify and record environmental issues, initiate, recommend or provide solutions and ensure compliance with IPC licence conditions. Line Managers within functional areas are responsible and accountable for environmental tasks and duties within their own work area.

The Compliance Manager is dedicated to environmental and health and safety programmes. The Compliance Manager has responsibility for the day-to-day operation of the site environmental management system, together with implementation of a number of specific compliance related programmes under the EMP. The Compliance Manager is supported by an Environmental Technician responsible for monitoring, measurement, waste management and IPC licensing issues.

Regular management/technical meetings are held where environmental matters are discussed and reported as the need arises.

The post of Compliance Manager Environmental Specialist requires an honours degree in science or engineering and 6 years experience, at least 3 of which are at management level or an MSc in environmental science or engineering and 5 years experience, at least 3 of which are at management level. The current Compliance Manager holds a BSc in Environmental Science, a diploma in pollution assessment and control and is in the latter stages of a master’s degree in Integrated Environmental Management. He also has 10 years relevant experience. The post of Environmental Technician requires a diploma in Environmental Science and preference for 1 year experience. The current Environmental

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SmartPly Europe Liinited Application for a Revised IPPC Licence Attachment C.l - Site Management and Control

Technician has a diploma in pollution assessment and control, a degree in quality and has 2 years relevant experience.

All staff receives an environmental induction, and depending on requirements, external and internal training courses are given as needs arise.

The procedures for the management of treatment and abatement systems are laid out in the environment, health and safety management system, as supplemented by the relevant standard operating procedures.

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URS SmartPIy Europe Limited Application for a Revised IPPC Licence Attachment C-1 - Site Management and Control

3. MANAGEMENT OF TREATMENT AND ABATEMENT SYSTEMS

The responsibility for the operation and control of treatment and abatement systems on site is that of the Greenend Process Manger, reporting directly to the Operations Director. Compliance with standards is assessed by the Compliance Manager. The Compliance Manager is supported in this role by the Environmental Technician.

4. CALIBRATION AND MAINTENANCE SYSTEMS

SmartPly Europe Limited has established standard procedures for the calibration and maintenance of environmental abatement and treatment equipment. These procedures are detailed below in Table C.1 .I :

Table C.l.1 Calibration and maintenance procedures

CODE TITLE

ESPOOG Controlling storm water and waste water

ESP012 Dealing with Environmental Complaints

ESP014 Calibration of the Conductivity Meter

ESPOIS Environmental checks of effluent abatement system and surface water runoff

ESPOIG Maintaining the Sewage Treatment Plant

ESP022 Procedure to be followed upon observing a leak from the drain system

ESP038 Baghouse inspection and lock out procedure

5. WASTE CONTROL SYSTEMS

Smartfly Europe Limited operates a strict waste management and control system, which is defined by documented site-specific standard operating procedures, which are reviewed and updated regularly to reflect up-to-date operations on-site.

Waste production control is carried out by the measurement of yield in accordance with good manufacturing practice requirements and waste is minimised where possible. Wastes are contained in suitable containers and evaluated for reprocessing or recovery.

Relevant standard operating procedures for waste management are summarised below:

l ESPOI 1 Waste Collection and Disposal/Recovery Off Site

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uR!s SmartPly Europe Limited Application for a Revised IPPC Licence Attachment C.l - Site Management and Control

This procedure sets out the process for arranging for the collection of hazardous and non-hazardous waste from the site. These wastes include refuse, sewage sludge, oil, metal, ash, paper and packaging. It outlines the responsibilities of the personnel assigned to coordinate waste collections. Approved, i.e. licensed, waste disposal contractors used by SmartPIy Europe Limited are listed here. The process for preparation of appropriate documentation for transportation is outlined. In addition the requirement for acceptance/disposal confirmation of the waste is detailed.

l ESP028 Waste Recycling

This procedure details the process for collection of recyclable waste from the SmartPly Europe Limited site. These waste include batteries, oil filters, fluorescent tubes, paper, cardboard, blender waste, tin cans, metals, waste oil, oily rags and glass. The duties of the waste co-ordinator are outlined. Waste recycling points on the facility are listed and the approved licensed waste recovery contractors are identified.

In addition to the procedures described above, there are procedures for waste management of specific waste types from production and maintenance.

It is noted that there is an environmental project underway to minimise the volume of hazardous and non-hazardous waste requiring disposal. Disposal volumes, disposal types and the waste arising from the various processes are reviewed on an annual basis. Similarly, non-hazardous waste generation in terms of both types and volumes is reviewed annually. Waste minimisation programmes for hazardous and non-hazardous wastes are developed based on the results of these studies reviews, and these programmes are also reviewed on an annual basis.

SmartPly Europe Limited intend to reduce to a minimum the amount of waste sent to landfill with the emphasis on reduce, reuse and recycle. SmartPly Europe Limited is continuously investigating possible outlets for waste streams to get away from the dependence on landfill. It is noted that SmartPly Europe Limited in 2003 identified a UK company, Glacier ARM, who can recycle and reprocess wood ash for use in the manufacture of cement.

GENERAL OUTLINE OF QUALITY CONTROL SYSTEM

SmartPly Europe Limited is committed to establishing and maintaining a quality management system, which meets the requirements of all applicable international guidelines and standards for the manufacture of wood products. The company promotes continuous quality improvement in all of its products, processes and operations. Smartfly Europe Limited has implemented a quality management system, which is certified to IS0 9001:2000 by NSAI, who carry out regular quality audits.

The quality system is built around three key principles:

l Resource management;

l Product realisation; and

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SmartPly Europe Limited Application for a Revised IPPC Licence Attachment Cl - Site Management and Control

l Measurement, analysis and improvement.

The quality system ensures that Smartfly Europe Limited:

l Provides appropriate facilities, materials, equipment and trained personnel;

l Provides sufficient resources to monitor and update the quality system and

l Understands fully customer requirements and meets or exceeds those requirements.

The quality system is documented through the quality manual, standard operating procedures, and work instructions and specifications. The management at SmartPly Europe Limited reviews the complete quality system at an annual review meeting and objectives for the following year are set at this meeting. In addition, quality objectives are regularly monitored at management technical meetings with a view to continual improvement.

SmartPly Europe Limited strives for a “Right First Time” objective and believes that each individual employee has a vitally important contribution to make in the quality performance of the company. All employees are directly responsible and accountable for the quality of their own work and are invited to actively participate in the identification and solving of all incidents that may have a bearing of product quality.

The Quality Manager is responsible for maintaining an appropriate quality system and ensuring compliance to quality guidelines and standards. The management of the quality system incorporates areas such as document control, quality audits, change control, customer complaints and non-conforming products. The Compliance Manager is also responsible for providing adequate training facilities, coordination of training activities and documentation of training programmes.

The QA Engineer and Technician, who assist the Quality Manager, are responsible for the inspection; testing and keeping of associated documentation related to raw materials, finished products and packaging materials, In addition, the QA Engineer and QA Technicians are responsible for the provision and update of material specifications and test procedures, maintenance and calibration of inspection and test equipment and the control of associated documentation. The QA Engineer and QA Technician are also responsible for the safe and secure warehousing of all materials, their correct issue, packaging and shipment.

The Maintenance Manager is responsible for the provision and installation of necessary equipment for production and services, the repair, servicing and calibration of equipment used for production and services and the implementation of an effective schedules maintenance programme.

The Quality Manager and Support Services reports to the Managing Director of Smartply Europe Limited The Managing Director is ultimately responsible for ensuring that adequate resources are available to meet the quality policy, and periodically reviews the quality system to ensure its continuing suitability and effectiveness.

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SmartPly Europe Limited Application for a Revised IPPC Licence Attachment Cl- Site Management and Control

The Process Manager have the primary responsibility for manufacture of quality products. The Process Manager is responsible for ensuring compliance with Production SOP’s and must ensure that any deviation to a process is fully and adequately investigated, documented and communicated through the correct channels.

SmartPly Europe Limited has prepared a quality policy, which is presented in this attachment as Appendix C. 1.5.

7. ENVIRONMENTAL MANAGEMENT PROGRAMME

SmartPly Europe Limited has established an environmental management programme (EMP) for Implementing and achieving its objectives and targets. The EMP specifies the objectives to be achieved, the persons responsible and the means and timeframe by which they are to be achieved. It is the aim of SmartPly Europe Limited to minimise its impact on the local and global environment in 2004/2005. The 2004/2005 environmental management plan forms part of a five-year plan to significantly reduce all sources of local nuisance, thereby reducing complaints from local residents. The 200412005 EMP will place particular focus on the following environmental issues:

l Plume Grounding from SmartPly Europe Limited - Target: To yield maximum reduction in ground level concentrations downstream of the plume. This project involves the extension of the existing 42 metre stack to a height of 90 metres. This extension of this stack is currently under construction and should be complete by the end of Q4 2004.

l Fugitive Dust Emissions from SmartPly Europe Limited - Target: To reduce the dust nuisance from the site. This project includes the removal of the existing bark out feed chute and replacement of this unit with an improved device towards improved entrapment of fugitive emissions. This is planned for completion by Q4 2004. There is also a programme underway to reduce nuisance dust emissions caused by a surplus storage of fines outside the building during the summer months. Projects for this programme include 1. research into methods for controlling biomass fuel production, with a view to controlling fuel production on a seasonal basis and 2. Investing in a separate wood fines blending in order to enhance the fines content of the board thereby further reducing fines production. In addition to these programmes of dust emissions reduction a programme to raise immediate alarm to a baghouse failure has been proposed. This involves integration of the baghouse alarms into SmartPly Europe Limited Human machine Interface (HMI) system so visual and audible alarms will be sounded in the press control in the event of a baghouse failure. This allows for a rapid response which could result in prevention of dust emissions limits reaching greater levels.

l Atmospheric Emissions from SmartPly Europe Limited - Target: To improve atmospheric emissions by increasing the removal efficiency of pollutants from the

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SmartPly Europe Limited Application for a Revised IPPC Licence Attachment C.9 - Site Management and Control

8.

WESP’s. This project involves upgrading the existing WESP’s to incorporate the very latest technologies and is due for completion by Q4 2004.

l Energy Usage on Smart/J/y Europe Limited site. - Target: To replace non- renewable energy with renewable energy as much as possible. This programme will involve projects such as 1. installing a wood fuelled gasifier on site for the purposes of displacing LPG consumption 2. Assessing the feasibility of co- operating a small-scale wood pellet manufacturing machine with a local renewable energy generator for the purpose of converting surplus wood fines to a readily usable renewable energy. 3. A proposed new office building will include renewable energy heating system to replace the propane system currently installed for office heating.

l Community Relations. - To reduce environmental complaints received at the facility. A review of all complaints will be completed each year and communicated to the board of directors. Data is gathered continuously and reported to the managing director each month.

Appendix C.1.3 to this Attachment provides further information on the EMP, including the status of various projects as at January 2004. In addition, the Environmental Policy Statement is included as Appendix C.1.4.

ONGOING ASSESSMENT OF ENVIRONMENTAL PERFORMANCE

SmartPly Europe Limited provides for ongoing assessment of its environmental performance through the environmental projects as described above and though the Annual Environmental Report produced for the EPA. As described in Section 6 above, SmartPly Europe Limited operates a series of environmental projects aimed at reducing potential environmental impacts. Further information on environmental projects is included as Appendix C.1.3.

An environmental and safety corrective action system is in place and provides a mechanism by which continuous improvement is achieved. Corrective actions are tracked on a continuous basis and the records are maintained. The Compliance Manager is responsible for the maintenance of the safety and health corrective action follow up and close out and the maintenance of the environmental corrective action system.

Specific environmental performance indicators are assessed as follows:

Reduced waste to landfill by reducing waste from processes and increasing the level of recycling: Waste quantities are declared in the AER annually and a waste comparison report is prepared by SmartPly Europe Limited both of these reports are used to design waste minimisation programmes, which would include process modifications where applicable, and which may result in improved yields, reduced wastes or the use of alternative less hazardous materials. In addition, recycling options are continuously being pursued for waste streams that could be potentially recycled but currently are sent to landfill.

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SmartPly Europe Limited Application for a Revised IPPC Licence Attachment C.l - Site Management and Control

Improvements in treatment/abatement systems resulting in reduced emissions: There are environmental projects underway that target reducing emissions to air (Project 1 and 3). See Section 6 of this Attachment and Appendix C.1.3 for further information on these projects.

Use of alternative energies: Energy usage is evaluated annually for the AER. A programme for the replacement of non-renewable energy with renewable energy for certain processes on the SmartPly Europe Limited site is detailed in Project 4. See Section 6 of this Attachment and Appendix C.1.3 for further information on these projects

Reduction in fugitive emissions: As part of the environmental project 1, plans have been made to reduce fugitive emissions from dust at SmartPly Europe Limited. A description of project is given in Section 6 of this Attachment.

Prevention of accidents and the preparation of contingency plans in the event of accident: SmartPly Europe Limited has adopted and implemented procedures to identify foreseeable emergencies through the systematic analysis of its on site operations. Potential accidents and emergency situations are identified using methodologies outlined in SmartPly Europe Limited ‘s standard operating procedures.

An emergency plan has been developed to provide an organised response should any emergencies (e.g. fire accidental releases, explosions) occur. Procedures are also in place that test and review the emergency plan. Emergency preparedness drills and exercises are carried out on a routine basis as detailed in Attachment J - Accident Prevention and Emergency Response of this IPPC Licence review application.

Employee training: Training of personnel is considered a key function in the successful operation of the plant. All staff members receive an environmental induction, and other training is given as appropriate. Each individual manager is responsible for identifying the training requirements of personnel within their departments and for ensuring that departmental personnel receive the necessary environmental, health and safety training to ensure conformance with the companies’ environmental and health and safety policies. It is the individual managers’ responsibility to determine the level of ekperience, competence and training necessary to ensure the capability of personnel; especially those carrying out specialised environmental, health and safety management functions. Training records are kept by the Human Resources Manager.

Complaints recording and investigation. Smartfly Europe Limited’s Work Procedure ESPO72 Dealing with Environmental Complaints is in place to detail how environmental complaints made to SmartPly Europe Limited are handled by Smart~Iy Europe Limited. The procedure details how SmartPly Europe Limited should record complaints, how the complaint should be investigated and how to respond to the complainant. A summary of complaints and actions arising from the complaints is included in SmartPly Europe Limited’s Annual Environmental Report 2003.

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Appendix C.1 .I

IS0 9001:2000 Certificate

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SmartHy Europe Limited Application for a Revised IPPC Licence Attachment C.l - Site Management and Control

Appendix Cl .2

Organisational Structure

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Appendix C.l.3

Environmental Management Programme

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SmaripZy Europe IPC Licence No. I

Smartplv Europe Environmental Management Plan

Targets and Obiectives for 2004/2005

Introduction

Smartply Europe is in the business of providing environmentally sustainable, high quality

timber products for the construction industry. It is the aim of Smartply Europe to minimise its

impact on the local and global environment in 2004/2005. The 2004/2005 environmental

management plan forms part of a five-year plan to significantly reduce all sources of local

nuisance, thereby reducing complaints fkom local residents. The 2004/2005 EMP will place

particular focus on the following environmental issues.

l Fugitive dust emissions

l Plume grounding

l Atmospheric emissions abatement improvement

l Energy efficiency

l Community relations

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Smartply Europe IPC Licence No. 1

Fwitive dust emissions

In recent years outside storage of fine materials has become an increasingly necessary

aspect to the business. While to date every effort has been made to reduce nuisance

fugitive dust emissions, through construction of dust storage bays, water dousing, dust

binding trials and installation of dust leak detection on baghouses, we are still experiencing

dust related complaints in relation to the facility fi-om our near neighbours.

The environmental management team within Smartply Europe have identified the

following areas as significant in terms for potential fugitive dust emissions; outside storage

of fines, conveyance of bark to outside bark storage, baghouse leaks.

Towards reducing dust nuisance fi-om the site we propose the following projects in

2004f2OQ5

Upgrading: of the bark out feed conveyor

This project will consist of removal of the existing bark out feed chute and replacement of

this unit with an improved device towards improved entrapment of fugitive emissions.

Timeframe

44 2004

Proiect responsibilitv:

Log yard co-ordinator

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Reduction in fines production

The Smartply Europe facility stores clean untreated wood fines outside the building on a

seasonal basis. One of the primary reasons for the requirement to store fines outside the

building is the fact that our facility was designed with a fixed ability to produce biomass

fuel. However, demand for consumption of this biomass fuel varies according to the

season. During winter months outside storage is virtually non-existent, whereas during

summer months a significant surplus arises. This surplus can give rise to nuisance fugitive

dust emissions. It is the intention of Smartply Europe to eliminate this source of fugitive

emissions.

The complex nature of fuel production within the plant and the cost of operational

downtime has prevented investment in fuel control programmes to date. It is now proposed

to conduct research into methods of controlling biomass fuel production, with a view to

controlling fuel production on a seasonal basis. Reduction in the production in biomass

fines at source will make a significant impact on overall fugitive emissions reduction. It is

proposed to visit other facilities with similar production facilities and learn how biomass

fuel production can be controlled seasonally. A separate wood tines blending system will

also be financially appraised in 2004. Fines blending will enhance our ability to increase

the fines content of our board thereby further reducing fines production.

Fines feed screw diversion uroiect

While the above work will be carried out over a longer time period, in 2004 it is proposed

to carry out a very significant modification to our fines screening process that will allow

the facility to decrease the volumes of fines generated. This process modification will

allow far greater control over the generation of dryer fuel and is therefore anticipated to

reduce the amounts of surplus generated in summer months. It is proposed to modify one

of the four screeners during 42 of 2004, and if successful the modifications will be carried

out on all four of the screeners. It is anticipated that should this project be successful that it

will result in a very substantial reduction in outside storage of wood fines.

Timeframe

Due to the highly complex nature of our operation and the interactions of fuel generation

within all areas of the operation, the project to establish greater control of dust emissions

Annual Environmental Report 2003 25

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will take place over a 5-year period. In 2004 specific focus will be on completion of a cost

benefit analysis on fines blending and the modification of the fines feed screw diversion. If

the fines feed screw diversion project is successfkl it may negate the need to install a fines

blending system.

ResDonsibilitv

Jim McCann Operations Director

John Clancy Process manager

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Intewation of the baghouse alarm svstem into the factorv’s Human Machine Interface

/HMI) svstem.

Throughout the past 2 years considerable work has taken place on installing a HMI system

within the plant. This has yielded far greater operational control over the production

process, which in turn has improved efficiency and problem solving within the operation. 3

years ago LPCI installed stand alone baghouse monitoring systems on all of the baghouses.

These systems function to detect dust emissions beyond our licence limits and light a

beacon in the area where a leak occurs. This detection system has improved our response

times in relation to baghouse failures. In order to further improve our response times it is

now proposed to integrate the baghouse alarms into our HMl system so visual and audible

alarms will be sounded in the press control room in the event of a baghouse failure.

Timeframe

It is proposed to complete the integration of all 5 baghouses by the end of 2004

Responsibilitv

John Ross Electrical maintenance manager

Paul Doherty Process manager

John CIancy Process manager

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Smartply Europe IPC Licence No, 1

Plume grounding

Plume grounding has been a significant problem since operations began at the Belview

facility. Very significant investments have been made to date towards finding a resolution

to the problem. We are now confident that we have a solution that will yield the maximum

possible (79%) reduction in ground level concentrations downstream of the plume. As the

Agency has already agreed this solution involves the extension of the existing 42 metre

stack to a height of 9Ometres. During 2003 planning permission was sought and granted

for the construction of a 90 metre stack on our site. Following granting of planning

permission Smartply Europe placed a tender notice in the Official Journal of the European

Union in compliance with EU tendering protocol. Smartply Europe has appointed a project

manager and a tender has been awarded to the mechanical engineering company.

Arrangements are now been made to finalise pricing and timeframe details.

Timeframe

This project is the most costly and complex undertaking in the operational history of the

Belview facility. As such, extreme care is being taken to ensure that the project is

completed within budget and to the highest possible quality and safety standards with

minimum disruption to production,

All design work is now complete and trial pits for civil works have commenced. It is

anticipated that steel work will be purchased by the end of Q2 and construction will

commence in 43. Chronic steel shortages on world markets has caused significant

scheduling problems.

Responsibility

David Tobin, Compliance manager, project co-ordination

Malone O’Regan; Project management and planning

NCL Scott; Design

MEC ltd., Mechanical engineering and fabrication

Civil works (TBA)

Electrical installation (TBA)


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Atmosnheric emissions abatement improvement

During initial plant construction the EPA mandated that WESPs were to be installed on

site as this was at the time understood to be Best Available Technology (BAT). While the

WESP is efficient at removal of atmospheric pollutants from an air-stream and transfer to a

water medium, one of the limitations of WESP technology at that time was the ability of

the WESP to remove pollutants from the water stream. This has reduced the potential

efficiency of many WBSPs installed throughout Europe. Smartply Europe has been at the

forefront of attempts to resolve this design problem common to all Senna generation

WESPs.

Smartply proposes to upgrade its existing WESPs to incorporate the very latest advances in

WESP technology. It is proposed to install an advanced water treatment plant connected to

the WESPs, it is expected that this unit will significantly improve all emissions from the

WESPs including; odour, HCHO, MDI, Particulates and CVOCs. In addition it is expected

that the unit will improve safety, reliability and extend operation lifetime.

Timeframe

The WESP upgrade will commence operations Q2 2004 and be fully integrated into the

operations group within Smartply Europe by 43.

Responsibility

David Tobin, Compliance manager

Paul Collins, Environmental technician

John Clancy, Process manager


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Energv Efficiencv/Renewable energy

Smartply Europe is already one of the largest users of renewable biomass energy in Ireland. As

such, we have a very strong interest in renewable energy we also recognise the need for a

reduction in the causal factors of anthropogenic global warming.

In the past number of years we have significantly reduced fossil fuel consumption though

improved control measures. We have also completed a detailed cost benefit analysis on the

feasibility of installing a biomass fuelled combined heat and power plant. Unfortunately

however conventional biomass fuelled CHP is not an economically viable option due to our

very high temperature heat demand.

We now propose to investigate the feasibility of installing a wood fuelled gasifier on site for the

purposes of displacing LPG consumption. LPG is currently used for ignition purposes within

the dryers, office heating, and fuel for forklifts.

We also intend to assess the feasibility of co-operating a small-scale wood pellet manufacturing

machine with a local renewable energy generator. If this venture is economically viable it will

be used to convert surplus wood fines to a readily usable renewable energy.

Wood fired office heating

It is proposed to renovate and extend the existing offices at the Smartply Europe site over the

next 2 years. Any new office building will include a renewable energy heating system to

replace the propane system currently installed utilised for office heating.

Timeframe

l Biomass gasification is not yet a fully commercially proven technology therefore it is

expected that this project will be completed over a 5- year timeframe if it is deemed to be

viable and safe for our operation.

l The viability of wood pellet manufacture will be assessed in 2004.

l The plans for the new offices will be completed in 2004, with construction, pending

planning, being completed at the start of Q3,2005.

ResDonsibilitv

David Tobin, Compliance manager


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Smartply Europe

Communitv relations

IPC Licence No. 1

It is proposed at the end of each year to conduct a review of any complaints received at the facility. This review will consist of the assessment of the cause and nature of all complaints with a view to reducing such complaints in future years. The results of this review will be communicated to the board of directors.

Timeframe: Data will be gathered continuously and reported to the managing director each month. A review of the data will be conducted annually and trends reported internally.

Responsibilitv: David Tobin, Compliance manager and Tim Rabbitte Environmental technician.

Annual Environmentd Report 2003

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Smart/J/y Europe Limited Application for a Revised IPPC Licence Attachment C.1 - Site Management and Control

Appendix Cl.4

Environmental Policy

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SmartPly Europe Environmental Policy SmartPly Europe Ltd., a wholly owned subsidiary of Coillte, manufacture Oriented Strand Board, an environmentally sustainable timber-based product, which is used for structural and non-structural building applications.

SmartPly Europe is committed to a healthy environment by taking a leadership role in our community to be good neighbours. We believe sound business practices and efforts to enhance the environment are compatible.

The Environmental Policy Principles at SngartPly Europe are as,follows:

Commitment: Senior Management and the Board of Directors are accountable for environmental issues and prepare environmental plans that allocate adequate financial and human resources to ensure that these issues are dealt with in a manner that reflects their high priority. Notwithstanding the foregoing, all employees must take account of the consequences of their actions and their obligation to integrate the Environmental Policy Principles in all activities, in conjunction with all other relevant policies.

Competence: Ensure workforce competence and responsibility at all levels through selection, retention, education, training and awareness in all aspects of the environment, health and safety.

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Risk Assessment: Identify, assess, prioritise and document the hazards and risks associated with all our activities.

Prevention and Control: Prevent, minimise or control priority risks, personal injury & illness, property and environmental damage, through planning, design, investment, management and workplace procedures. Where accidents and incidents do occur, take prompt corrective action, investigate root causes and take remedial action. Actively seek to prevent recurrences and disseminate experiences learned. Prepare and periodically test emergency response plans.

Performance: Set appropriate goals, objectives, targets and performance indicators for all our operations. To strive as a minimum to achieve, and where possible surpass, Integrated Pollution Control Licence conditions requirements and all applicable Environmental legislation and regulations. Apply international best practice and utilise Best Available Technology (BAT) to achieve environmental targets and goals.

Sustainable Development and SustainabIe Products: Commitment to sustainable forestry practices through maintaining FSC Certification. Manufacture a range of timber panels, which deliver value for money in all applications safely, which incorporate environmental benefits. And active promotion of recycling and waste minimisation on-site.

Continual Improvement: Foster creativity and innovation in the management and performance of our business, and our approach to solving the challenges facing our enterprise. Support research and development into environmental, health & safety issues, and promote the implementation of international best practices and technologies where appropriate and where feasible.

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Evaluation: Monitor, review and confirm the effectiveness of management and workplace performance against objectives, targets and applicable legal requirements, and report findings of such evaluation measures to all relevant personnel.

Communications: Promote and maintain open and constructive dialogue and good working relationships with employees, local communities, regulatory agencies, business organisations and other affected and interested parties, to increase knowledge and enhance mutual understanding in matters of common concern. Make available to interested parties relevant information on the company’s environmental performance and respond to any community concerns that may arise.

Operational Activities: Endeavour to operate in a manner which minimises adverse impact on employees, local community and environment utilising energy and other resources responsibly and efficiently. Incorporation of environmental costs into financial plans and the purchase/use of products is reviewed from an environmental and health and safety point of view, prior to purchase.

Signed: Louis E. Hess Managing Director

Date:

March 2003 Smart/J&Europe Environmental Policy

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SmartPly Europe Limited Application for a Revised IPPC Licence Attachment C.1 - Site Management and Control

Appendix Cl .5

Quality Policy

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To define and document the policy of the company and to demonstrate management’s commiEment to provide the resources and training necessary to satisfy its customers and applicable regulatory requirements. To achieve process stability and reliability, control every process to the desired target and to improve process capability. To continuously review and improve the quality system and objectives. To ensure that the quality policy is communicated throughout the organisation.

Appendices Quality Policy

QUALITY POLICY

To be a European leader in quality, value and service for OSB products.

Quality Management Process

9 To Focus on our customers. 9 To Establish mission, vision, and indicators of performance. +3 To understand, standardise, stabilise, and maintain processes. 9 To plan, do, check, act for continual improvement and innovation.

Operational Policy

9 Achieve process stability and reliability. + Control every process to the desired target. +3 Improve process capability.

Customer Satisfaction

Continual Improvement

Innovation Process Emphasis Management Leadership

Empowerment

Statistical Methods

Employee Development Partnerships Assessment

Principles

Anticipate, understand, and excel at meeting customer requirements. Continuously improve the current level of performance of process, products and service. Search for and implement creative processes, and products. Focus on our process as a means to improve results. Create and maintain a shared vision, constancy of purpose, and supportive environment that include appropriate recognition and reinforcement. Create a culture where people have knowledge, skills, authority and desire to decide, act, and take responsibility for results of their actions and for their contribution to the success of the company. Understand the concept of variation and apply appropriate statistical methods for continual improvement and innovation. Encourage and support life long learning and personal growth Build long-term partnerships with customers and suppliers. Assess performance and benchmark against Europe’s best.

Lou Hess Managing Director

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