i analog devices

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I ANALOG DEVICES

Environmental Licensing Programme, Environmental Protection Agency, PO Box 3000, Johnstown Castle Estate, Co. W exford.

IPPCL Reg. No. PO224-02

Ref: Clerical amendment for Technical Amendment C

Date: 24* April 201 3

To Whom It May Concern,

The Agency recently issued Analog Devices with a new T&hnicalhendment (Technical Amendment C) in February 2013. This Technical Amendment however was not written in line with the most recent revision of Schedule:l of the Analog Devices IPPC Licence CpO224-02) which has previously been amendcd under Technical Amendment A in 2007. On speaking with John McEntagart in the Ofice of Climate, Licencing and Resource Use, he requested that a clerical amendment be sought on the Technical Amendment C to correct these errors. _-

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A summary of the inaccuracies in the Technical Amendment C have been compiled and included in this letter for reference. Errors have been highlighted in Red and relevant changes due to the most recent BAT Guidance have beenhighlighted in 13 I LE.

Both Technical Amendment A and Technical Amendment C have also been included as additional attachments for reference.

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I would appreciate if someone could revert to me as a matter of uxgency as this issue needs to be resolved. Should you require any futher information, please don’t hesitate to contact me.

Yours Sincerely,

Fiona O’Mahony Snr EHS Engineer Analog Devices, Raheen, Limerick, Direct Line +353 61 495867 Fax: +353 61 301258 E-mail: [email protected]

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ANALOG DEVICES, RAHEEN BUSINESS PARK, LIMERICK, IRELAND. TEL. +353-61-229011 & 495495 a FAX: +353-67-308448 .-

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APPENDIX A

SUMMARY OF INACCURACIES IN TECHNICAL AME

Page 3 of Technical Amendment C - Schedule 1 (i)

EF- 12F4 EF-16F 1

- These emission points are no longer in use:

F4 Roof 1417824 F1 Roof 432000

Volume to be emitted

SC09-B3

Point Ref in any one Number

6"FAB 1555200 64800 Scrubber Deck


~

EF- 19F4 SC-05F4 I F4Roof I 44870

1 F4Roof I 276480

Emission limit values (m3/m3)

Maximum rate per hour (m3)


I1500 Changed to 4000

59076 18000 11 520 1870

Minimum Total discharge Fluorides (as

above ground 11.5 0.4 11.5 0.4

height HF)

The SC-09B3 emission point was added Volume to be emitted

Point Ref Number

This ernissic

Emission Point Ref Number

SC04-F2 SC04-F2

volume to

Locations

F2 Roof F2 Roof


height (as HF) above ground (m) + 8.3 1 0.4

%--+?-

Total Bromides (as HBr) at mass flows >50g/hr 5 5 5 5

Total Acids (as HCL)

5 5 20 10


height above

Maximum in any one day (m3)

276000 Changed to 96000

Total

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of Technical Amendment C - Schedule 1 (i)

TA Luft inorganic dust particles Class I1

0.01

These emissi

Point Ref Number

TA Lufi inorganic dust particles Class 111 (excluding antimony and lead) 0.5 0.5 5 SC-05F4


I oints are no loneer in use: Volume to be emitted .



1 and lead)

1417824


Emission Locations Maximum Maximum Point Ref in any one rate per Number day (m3) hour (m3)

276480 44870

Minimum discharge height above


EF-15Fl EF-13F4

Minimum discharge height above ground (m)

ground (m) F1 Roof 216000 9000 8.3 F4 Roof 393984 16416 12

59076 I1520

Emission Limit Value 15 mg/in3 80 n1gh13 150 m g h 3 dccrcascd 10 75mg/ni3

Parameter T A L u l i Organics Class I TA L u l i Organics Class I I Total Organic Carbon (as C)


Mass Flow Threshold 0. I k d h r O. jhg/hr O.jI+/hr

2 0 20 20

Emission Point Ref Number



Minimum discharge height above ground (m)

TA Lufi inorganic dust particles Class I1

Total I’articulates

20

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Page 5 of Technical Amendment C - Schedule 1 (iii)

Emission point reference numbers are incorrect: 0

0 SC-09B3 has been added The following have been removed EF-12F4, EF-16F1, EF-19F4, SC-05F4

Emission point reference numbers are incorrect: .-

0

0 SC-09B3 has been added The following have been removed SC-05F4, EF-12F4, EF-19F4

Antimony and General dust removed and Total Particulates added.

Page 6 of Technical Amendment C - Schedule 1 (iii)

Emission point reference numbers are incorrect: The following have been removed EF-lSF1, EFI3-F4, EF18-F4 (Should list EF-03B3, EF-04B3, EF-38B3 and EF-39B3 even though this is incorrectly referenced in our current licence)

Table amended to reference Class I, Class II and Total Organic Carbon instead of TA Luft Organics Class I, Class I1 and Class 111.

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Headquarters P.O. Box 3000

Johnstown Castle Estate County Wexford

Ireland

AMENDMENT A. To

INTEGRATED POLLUTION PREVENTION & CONTROL LICENCE

Licence Register Number: Licensee:

Location of Installation:

PO224-02 Analog Devices B.V.

Raheen Industrial Estate,

Raheen,

County Limerick.

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Reason for the Amendment of Conditions The Environmental Protection Agency is satisfied, on the basis of the information available, that subject to compliance with the conditions of licence Reg. No. PO224-02 granted on the 02/01/2001, as well as any amendments noted herein, any emissions fkom the activity will comply with and not contravene any of the requirements of Section 83(5) of the Environmental Protection Agency Acts, 1992 and 2003.

Amendment of Conditions In pursuance of the powers conferred on it by Section 96(l)(b) and (c) of the Environmental Protection Agency Acts, 1992 and 2003, the Agency amends Licence Reg. No. PO224-02, granted to Analog Devices B.V., Raheen Industrial Estate, Raheen, County Limerick.

Henceforth, the Licence shall be read in conjunction with the amendments set out below. This technical amendment is limited to the following:- Glossary of Terms, Conditions and Schedule of the Licence.

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Amendments

Glossary of Terms

BAT Best Available Techniques.

To be inserted into the Glossary of the existing licence. 1

Incident The following shall constitute an incident for the purposes of this licence:

(i) an emergency; (ii) any emission which does not comply with the requirements of th~s

(iii) any trigger level specified in this licence which is attained or exceeded;

(iv) any indication that environmental pollution has, or may have, taken

licence;

and,

place.

1 To be inserted into the Glossary of the existing licence.

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Conditions of Licence

I O . 1 The licensee shall cany out at intervals as required by the Agency an audit of the energy efficiency of the site. The audit shall:-

(i)

(ii)

identify all opportunities for energy use reduction and efficiency,

be carried out in accordance with the guidance published by the Agency; “Guidance Note on Energy Efficiency Auditing” and

a summery of audit findings shall be subnlltted as part of the Annual Environmental Report.

(iii)

The recommendations of the audit will be incorporated into the Schedule of Environmental Objectives and Targets under Condition 2.2.

The licensee shall identify opportunities for reduction in the quantity of water used on site including recycling and reuse initiatives, wherever possible. Reductions in water usage shall be incorporated into the Schedule of Environmental Objectives and Targets under Condition 2.2.

The licensee shall undertake an assessment of the efficiency of use of raw materials in all processes, having particular regard to the reduction in waste generated. The assessment should take account of best international practice for this type of activity. Whcre improvements are identified, these shall be incorporated into the Schedule of Environmental Objectives and Targets under Condition 2.2.

10.2

10.3

Delete Condition 10.1 and 10.2 of the existing licence and replace with tlie above condifions.

13.1 Accident Prevention and Emergency Response

13.1.1 The licensee shall, no later than 3 1 ” December 2007, ensure that a documented Accident Prevention Policy is in place, which will address the hazards on-site, particularly in relation to the prevention of accidents with a possible impact on the environment. This procedure shall be reviewed annually and updated as necessary.

13.1.2 The licensee shall, no later than 3 1’’ December 2007, ensure that a documented Emergency Response Procedure is in place, which shall address any emergency situation which may originate on-site. This Procedure shall include provision for minimising the effects of any emergency on the environment. This procedure shall be reviewed ailnually arid updated as necessary.

13.2 Incidents

13.2.1 In the event of an incident the licensee shall immediately:-

(i) carry out an investigation to idcntify the nature, source and cause of the incident and any emission arising therefrom;

(ii) isolate the source of any such emission;

(iii) evaluate the environmental pollution, if any, caused by the incident;

(iv) identify and execute measures to mitiimise the emissions/nial fiinction and the effects thereof;

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( v )

(vi)

identify the date, time arid place of the incident; notify the Agency and other relevant authorities.

13.2.2 The licensee shall provide a proposal to the Agency for its agreement within one month of the incident occurring or as otherwise agreed by the Agency to:-

(i)

(ii)

identify and put i n place measures to avoid reoccurrence of the incident; and identify and put in place any other appropriate remedial action.

Delete Conditio11 13. I of the misting licence and replace wit11 the above conditions.

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Schedules to Licence

Sclzedrrle 1 (i) Emissions to Atinospliere

Scrubber Deck 0.2 5

17 0.4 5 5

11.5 0.4 5 10

11.5 5 (at mass 5

64,800 18 0.2 5

64,800 18 0.2 5

1,555,200 64,800 18.3 0.2 5

6 FAB 1,555,200 64,800 17 SC-02B3 Scrubber Deck

SC-03B3 6 FAB 360,000 15,000 Scrubber Deck

SC-04F2 F2 Roof 96,000 4,000

SC-06G3 Effluent Plant 37,050 1,545 flows > 5glhr)

G3G4

SC-0783 6 F A B 1,555,200 Scrubber Deck

SC-08B3 6 FAB 1,555,200 Scrubber Deck

p- -

SC-09B3 6 FAB Scrubber Deck

Note 1:

Note 2:

Where inorganic dust particles of several classes are emitted simultaneously, in addition to the above individual limits, the sum of the concentrations of Classes II and 111 shall not exceed the Class 111 limits. Antimony may be emitted from this emission point up to a concentration limit of 0.2 m@m3

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EF-0463 6 FA6 Scrubber Deck 221,lW 9,216 17

EF-3883 6" FA8 Scrubber Deck 221,184 9,216 18

, EF-3983 6" FAB Scrubber De& 221,184 9,216 18

TA Luft Organics Class I

TA Luft Organics Class II

TA Luft Organics Class 111

15 mgfm'

80 mg/m3

150 mglm'

Note 1: Where organic substances of several classes are emitted simultaneously, in addition to the above individual limits, the sum of the concentrations of Classes I, II and 111 shall not exceed the Class 111 limits.

Schedule I($ EJnissiom to Atmosphere: Abatement/l"reatmeirt control

SC-0183: 6-inch Fab Scrubber No. 1 SC-02B3: &inch Fab Scrubber No. 2 Emission Point Reference No's.: SC-03B3: &inch Fab Pumped Scrubber SC-07B3: 6-inch Fab Scrubber No. 3 SC-08B3: 6-inch Fab ScrubberNo. 4 SCO4F2: Aqua Regia Scrubber SC-09B3: &inch Fab Scrubber

Monitoring:

p! Pump function

Liquid level

Liquid circulation through the scrubber

Condition of packing (packed tower scrubbers only)

Continuous

Continuous

Continuous for SC-0183, SC-0263. SC-0383. SC- 0783, SC-0883, SC-09B3

Daily for SC-04F2

Daily inspection

Daily inspection

pH probe & controller

Pump failure alarm

Level detectors

Visual inspection

Visual inspection

Visual inspection

Eouimnent:

I 1 pH probe and controller 1 Spare probes held on site I pH I Circulation pump I Liquid circulation I RunlStandby pumps on all systems

Liquid level 1 Level detectors I None

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Emission Point Reference No.:

Liquid circulation

SC-06G3 : Effluent Plant Scrubber

None I None

Monitoring :

NOx

CO

Equipment:

Biannually Flue gas analyser

Biannually Flue gas analyser

Schedule 1 (iii) Mottitoring of Emissions to Atmosphere

Emission Point Reference No’s.: BOL-1G3, BOL-2G3, BOL-3G3, BOL-11G3

. Emission Point Reference No’s.: SC-0183, SC-02B3, SC-03B3, SCO4F2, SC-0783, SC48B3, SC-

0983.

Total Fluoride (as HF)

Total Bromides (as HBr)

Total Acids (as HCI)

Quarterly

Quarterly

(Emission points where allowed under Schedule l(i))

Quarterly

To be agreed in writing with the Agency

To be agreed in writing with the Agency

I To be agreed in writing with the Agency

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-. .. . .

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Class II

TA Luft Inorganic Dust Particles Class 111

Emission Point Reference No’s.:

Bi-annually

SC-0163: 6-inch Fab Scrubber No. 1 SC-0283: 6-inch Fab Scrubber No. 2 SC-0363: 6-inch Fab Pumped Scrubber SC-0763, 6-inch Fab Scrubber No. 3 SC-0863: 6-inch Fab Scrubber No. 4 SC-0963: 6-inch Fab Scrubber

Antimony Bi-annually

General Dusts Bi-annually

Iso-kinetic GravimetridlCP



TA Luft Organics Class I TA Luft Organics Class II TA Luft Organics Class 111

Emission Point Reference No.: SC-06G3 : Effluent Plant Scrubber

Quarterly Adsorption, GC-FID Quarterly Adsorption, GC-FID Quarterly Adsorption, GC-FID

Annually To be agreed in writing with the Agency

Total Fluoride (as HF)

*A *- Emission Point Reference No’s.: EF-18F4, EF-03B3, EF-0483

Delete Scliedules I o ) , 169 and I(iii, of the existing licence mid reppkrce w i t h the above Sck edii les.

This Amendment shall be cited as Amendment A to IPPC licence Reg. No. PO224-02.

Sealed by the seal of the Agency on this the 12th day of March, 2007

was affixed hereto:

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1

I * ' I

Licence Register Number:

Licensee:

Location of Installation:

Headquarters P.O. Box 3000

Johnstown Castle Estate County Wexford

Ireland

PO224-02

Analog Devices B.V.

Raheen Industrial Estate,

Raheen, County Limerick I

TECHNICAL AMENDMENT C To

INTEGRATED POLLUTION PREVENTION & CONTROL LICENCE

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I

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Environmental Protection Aaencv Licence Rep. No. PO224-02

y . * .I.

i i

Emission Point Reference No.: SC-06G3 : Efnucnt Plant Scrubber ~

i

Emission Point Reference No's.: EF-I5FI. EF-13F4, EF-18F4, EF-0383. EF-0463

This technical amendment shall be cited as Amendment C to the licence.

Sealed by the Seal of the Agency on this the 2lst day of February 2013.

PRESENT when the seal of the Agency wns nfiixed hereto

/as/ % Patrick Byrne, Authdiised Person

Technical Amendment P0224-02/C .Page 6

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