print & display limited, aer 2008 · 2014. 12. 16. · industrial unit on the cookstown...

Print & Display Limited,

Cookstown Industrial Estate,

Tallaght,

Dublin 24.

IPC Licence Registration No: 116

Annual Environmental Report 2010

Contents

Page

1 INTRODUCTION

1

2 GENERAL OVERVIEW OF THE ACTIVITY 2

2.1 Company Profile 2

2.2 Location and Environmental Conditions 2

2.3 Printing Processes 3

2.4 Raw Materials and Principal Emissions 4

2.5 Overview of Recent Environmental Developments 5

3 DATA 7

3.1 Emissions to Atmosphere 7

3.2 Emissions to Sewer 9

3.3 Surface Water Runoff 11

3.4 Noise 12

3.5 Waste Management 13

3.6 Energy and Water Usage 14

3.7 Environmental Incidents and Complaints 15

3.8 Pollution Emission Register 15

4 ENVIRONMENTAL MANAGEMENT 17

4.1 Site Management 17

4.2 Environmental Management System 17

4.3 Human Resources, Training and Education 17

4.4 Environmental Objectives and Targets 18

4.5 Environmental Management Programme 18

LIST OF ATTACHMENTS

Attachment I Annual Waste Arising – 2010 Attachment II Print & Display Ltd. Organisation Chart Attachment III Environmental Objectives and Targets Review, March 2011

Attachment IV Implementation of Environmental Management Programme 2010/2011

Attachment V Proposed Environmental Management Programme 2011/2012

Page deliberately blank.


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Print & Display Ltd. Page 1 of 18

1. INTRODUCTION:

Print & Display Ltd. is licensed under the Environmental Protection Act, 1992 to operate a screen

printing business at Cookstown Industrial Estate, Tallaght, Dublin 20. The licensed activity is

situated within the Cookstown Industrial Estate, approximately two kilometres to the southeast of

Newlands Cross.

The Print & Display Ltd. facility is a Class 12.2 activity, under the First Schedule of the EPA, Act

1992. The Integrated Pollution Control (IPC) licence register number for the activity is 116.

Condition 2.9.2 of the Print & Display Ltd. facility’s IPC Licence requires the Company to produce

an Annual Environmental Report (AER) and to submit it to the Environmental Protection Agency

(EPA).

This report constitutes the AER for the licensed period 1 January to 31 December 2010. The format

of this report is in general compliance with the EPA’s 2000 Guidance Note for AERs.


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2. GENERAL OVERVIEW OF THE ACTIVITY:

2.1 Company Profile:

Print & Display Limited operate a screen printing business which manufactures printed material for use

in advertising, e.g. posters, point of sale displays etc. The existing plant was established in 1988 in an

industrial unit on the Cookstown Industrial Estate. Approximately 45 people are employed at the plant

and most of the output is for the home market, however, a small proportion is for the export market.

2.2 Location and Environmental Conditions:

The Print & Display facility is subject to IPC licensing due to the fact that the company currently uses

‘coating materials in processes with a capacity to use at least 10 tonnes per year of organic solvent’.

Located within the industrial estate, the printing plant is situated a considerable distance from any

residential areas and the plant causes no known significant environmental impact.

The printing plant consists of a ground floor production area (1,880 m2) and first floor offices, canteen

and training area. Process effluents are discharged to the local authority sewer and prior to being

licensed under the IPC regime the Print & Display Ltd. plant was regulated by Dublin County

Council under a licence to discharge trade effluent.

Print & Display Ltd. was granted an IPC licence on 22 January 1997. Waste disposal, noise control,

atmospheric emissions and discharges of effluent and surface water run-off are all regulated by the

Company’s IPC licence.

There are no discharges made to ground and surface run-off is discharged to the local authority system.

All waste is disposed off-site and no on-site waste disposal or recovery is undertaken. The plant

discharges atmospheric emissions directly to air, however, the impact of these emissions is not

significant.


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2.3 Printing Processes:

The Print & Display screen printing plant utilises manufacturing processes which have been designed to

apply ink to a variety of substrates including: paper, board and vinyl etc. These finished printed

materials are used in advertising e.g. point of sale displays, billboards etc. There are a number of

distinct processing stages involved in the production of the printed material. These steps can be

regarded as unit operations, as follows:

Design/Artwork

Graphic/Film Production

Preparation Process

Printing Process

Finishing and Dispatch

In screen printing, the screen with the required image (stencil) is loaded into the printing machine. All

of the P&D printing lines are either fully automatic or semi automatic. The material to be printed is

loaded into the feeder. The feeder then presents the material to the printing machine. In the printing

unit, ink is forced through the image area of the screen mesh and onto the material (substrate) by the

action of rubber squeegees. The substrate with the wet ink image then passes to the drying stage where

drying is achieved by either hot air or by UV light, depending on the ink system in use.

The final stage of printing involves stacking the dried prints on a pallet. After the screen has been used

in the printing machine, excess ink is removed and returned to the ink container. The used screen is

then returned to the Preparation Department for washing prior to being reused. Screen washing is

carried out in an automatic screen washing machine (Screen Washer).

Print and Display operate one of the most advanced screen printing plants in Ireland having installed a

five-colour and a four-colour automatic printing line along with a series of specialist digital machines.

In the state-of-the-art five-colour and a four-colour lines, the material to be printed is generally loaded

into the machine only once and passes through a series of printing units and driers. This once through

process has major advantages over conventional systems, where the material to be printed is loaded into

the machine repeatedly for the application of one ink colour at a time.

Print and Display also operate digital printing machines which produce printed materials directly from

digital format. There is thus no screen preparation involved and no chemicals used in graphic

production with the new digital printing process. Raw material usage is therefore reduced and there

will be reductions in hazardous and packaging waste arising from the Preparation and Graphics

Departments.


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2.4 Raw Materials and Principal Emissions: A wide range of raw materials are used in the various different stages of processing. The Graphics

Department previously used photographic fixer, developer and film, however, this activity has

effectively ceased for a number of years. The screen preparation process involves the use of screen

washing solutions, photoemulsion and screenfiller. Inks, display board and miscellaneous substrates

constitute the predominant raw materials which are used during printing. Other materials used in the

printing process include: paper, self-adhesive vinyl, plastics, and varnishes.

The Finishing and Dispatch Departments utilise a range of raw materials which include printed goods,

packaging materials, adhesive tapes, etc. The principal environmental emissions from the plant arise

from the use of screen washing chemicals and solvent based inks. These emissions are mainly organic

solvents which are evolved and discharged directly to atmosphere, via licensed emission points.

Process effluent from the Print & Display Ltd. facility arises primarily from the screen washing area.

This effluent is discharged to the foul sewer via an interceptor trap on the north-western side of the

Print & Display Ltd. site (Licensed Emission Point SE1).

There are no waste treatment facilities at the plant and no atmospheric abatement plant or effluent

treatment systems are warranted. On this basis, the plant is relatively simple to manage and Print &

Display Ltd. operates and maintains an Environmental Management System in line with the

requirements of the IPC licence.

There is currently one licensed atmospheric emission point which is active at the facility and one

licensed effluent discharge point. Details of the overall emissions are provided in Section 3 of this

report.


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2.5 Overview of Environmental Developments:

During 1999 and 2000, a major development plan was implemented at the Print & Display facility in

response to the company’s commitment to reduce atmospheric emissions. Prior to 1999, the

principal emission from the Print & Display plant was the organic solvent which arose from the

drying of solvent based inks. One of the projects in the 1997/1998 Environmental Management

Programme involved the identification of means to reduce the atmospheric emissions arising from

solvent based inks. After evaluating a series of options, it was determined that raw material

substitution provided the optimum means of reducing atmospheric emissions.

Due to the incompatibility of solvent free inks with certain substrates which are used in the printing

process, raw material substitution could not proceed without major plant modifications. After

extensive research, it was determined that the only viable option was to replace and/or upgrade the

entire printing plant to make it compatible with UV ink usage. In conjunction with this a number of

ancillary projects arose directly as a result of the raw material substitution programme.

During 1999 and 2000 the printing plant was effectively decommissioned and a new printing plant

was installed. A phased decommissioning/commissioning process ensured that production was

maintained while converting the printing plant to predominantly UV ink usage.

A huge commitment of resources was required in order to successfully implement the raw material

substitution programme and the successful implementation of this project has radically improved the

environmental performance of the facility. More recently a complete review of the screen-wash

operation in the plant was undertaken. The primary objective was to eliminate hazardous materials

and after extensive work, a series of trials was undertaken with replacement raw materials introduced

in 2003. This ensured that screens were cleaned with a less hazardous raw material and the

emissions arising from the process were reduced.

During 2003 a new digital printing line (Press Jet) was planned and commissioning work proceeded

during 2004. Although the new line uses solvent based ink, it has major environmental benefits, over

conventional screen printing, as follows:

There is no screen preparation involved and no chemicals or film used in graphic

production with the new digital printing process. Raw material usage is therefore

reduced and there are also reductions in hazardous and packaging waste arising from

the Preparation and Graphics Departments.

There is less printed waste associated with the new digital printing process.

Overall, therefore, the Printing Department’s hazardous and non-hazardous waste generation have

been reduced by the new digital printing processes.

In 2005 further investment was made at the plant and a new printing machine was commissioned -

the NUR Tempo™ machine. This machine employs the latest digital printing technology using

printing inks that are cured by the application of UV light immediately after printing. One of the big

advantages of this technology is that the process uses less ink than other digital printing methods.


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As the NUR Tempo™ machine utilizes UV-curable inks, there is no ink evaporation and no VOCs

(volatile organic compounds) are emitted thus creating a more user and environment friendly

atmosphere.

During 2007 a new digital (HP Scitex TJ38300 printing machine was commissioned to replace an

existing digital machine (Pressjet) which was installed in 2003. The HP Scitex can print on a new of

substrates and while it uses a solvent based ink it is highly efficient in the manner in which ink is

utilised and its digital process minimises waste.

Originally P&D used a dedicated screen washing machine which always needed to be supplemented

by intensive manual cleaning. The original machine and the manual washing process utilised solvent

and detergents and they both gave rise to atmospheric emissions of VOC and to a contaminated

effluent discharge. In addition, the original washing process was labour intensive, gave rise to noise

and airborne emissions and used large volumes of water.

In order to address some of the persistent difficulties associated with screen cleaning, P&D invested

in the Enviromatic Screen Washing System in 2006. The Enviromatic system resulted in a screen

cleaning system that is much more environmentally friendly. It dramatically reduced the volume of

solvents used by Print & Display as the machine utilizes a solvent-based cleaning system in an

enclosed unit, with the solvent being recycled and re-used. The system is fully automated, so it also

has the benefit of eliminating human involvement in the process. This has reduced the facility’s

running costs and also eliminated any occupational hygiene issues associated with the original

system. Discharges to air and effluent discharges have been significantly reduced by the new

cleaning system.

During 2010 a formal application was made to the Agency under Condition 1.2 of the IPPC licence

to install and operate a new printing machine. The new ‘HP Scitex XP27JO’ machine is a flatbed

press and uses printing inks that are cured by the application of UV light immediately after printing.

The use of UV-curable inks in the HP Scitex XP27JO machine has several advantages over the

solvent-based inks used in other equipment. UV-curable inks bond to a wider range of substrates and

do not require any coating. Greater colour consistency is achieved since the ink cures immediately

and there is no dot gain variation and no temperature dependency. The UV-curable ink also has a

VOC (volatile organic compound) content of less than 95 g/l and thus creates a more user and

environment friendly atmosphere. The machine utilizes up to 3 litres of ink per hour and under worst

case conditions the total use of VOC in the machine will be 0.29 kg/h.

Consultations were made with the Agency during 2010 regarding the new machine and emission

testing programme has confirmed that the emissions from the machine do not pose any technical or

compliance issues for Print & Display Ltd.


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3. DATA:

All of the data presented in this section of the report is based upon independent monitoring

undertaken on behalf of print & Display Limited, unless otherwise stated. The Agency and South

Dublin County Council also monitor emissions from the facility and there is generally a high degree

of consistency between the various monitoring data.

3.1 Emissions to Atmosphere:

The principal environmental emissions from the printing plant arise from the use of inks and screen

washing chemicals. These emissions are mainly in the form of organic solvents which are evolved and

discharged directly to atmosphere.

Table 3.1.1 Licensed Atmospheric Emission Points:

Emission Point

Source of Emission

A 1 Composite Printing Emission

A2 Side-Wall Printing Machine

(not operational.)

A3 Screen-Washer

The ‘Side-Wall Printing Machine’ emission point (A2) has been decommissioned for a number of years

and the use of solvent based cleaning solutions in the screen-wash bay has been phassed out. This has

effectively made emission point A3 redundant.

Details of the Print & Display atmospheric process emissions for 2010 are presented in Table 3.1.2

below. The data is based on the monitoring programmes undertaken on behalf of the company by

Moloney & Associates, Acoustic & Environmental Consultants. During each monitoring programme

samples were taken from the operational emission points.

The sampling and analytical methods generally involved collecting representative samples on to

adsorbent tubes using personal sampling pumps and analysing the samples by gas chromatography

with a flame ionisation detector (GC/FID). A direct reading FID has also been used in conjunction

with the adsorbent tube sampling technique


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A summary of the compliance history for 2010 is presented below. The data is based on the

monitoring programmes which were undertaken on behalf of the company.

Table 3.1.2 2010 Atmospheric Emissions – VOC Compliance History:

Emission Point 2010

% Compliance

A1 100

A3 100

As can be seen from Table 3.1.2 there was a 100% level of compliance with the atmospheric

emission limit values at A1 and A3 during 2010. This maintains the 100% compliance standard

since 2006.

A summary of the annual atmospheric emission details is presented in Table 3.1.3. The data includes

a breakdown of the results for individual licensed emission points, as well as a total emission for all

licensed emission points.

Table 3.1.3 2010 Atmospheric Process Emissions:

Emission Point 2010 Mass Emission

(kg VOC per annum)

A1 1173

A3 55

Total Emission 1228

The A1 data in Table 3.1.3 is based on the mean emission monitoring results and a mean run time of

3672 hours per annum.


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3.2 Emissions to Sewer:

Process effluent from the Print & Display Ltd. facility arises primarily from the screen washing area.

This effluent is discharged to the foul sewer via an interceptor trap on the north-western side of the

Print & Display Ltd. site (Emission Point SE1).

It is important to note that the majority of the trade effluent is generated in the screen wash area of

the plant. While a dedicated screen cleaning machine has been traditionally used in this area to

reclaim the screens, cleaning agents were also applied by brush where persistent staining arose. This

latter activity, known as spot-cleaning, had the potential to give rise to short term spikes in the

concentration of certain contaminants.

In 2006 a new screen cleaning system (Environmatic) was commissioned in consultation with the

EPA and South Dublin County Council. The new system was designed to minimise the release of

effluent discharge and to reduce air emissions. The other major benefit of the new system is that it

almost entirely eliminates the need for spot-cleaning and thus spikes in the discharge are eliminated.

For the purpose of comparing the annual mass emissions, the total process effluent generated at the

facility (based upon meter readings and the annual water consumption) was assumed to be an average

of 8.61 m3 per day. This mean daily discharge was used to compute the annual discharge for 2010,

based on 255 working days per annum in the screen wash area.

Details of the process effluent emissions for the period 2008 to 2010 are presented in Table 3.2.1

below. This data was computed using the self-monitoring quarterly compliance monitoring results for

these years. Analysis of quarterly grab samples was undertaken by Independent Laboratory Limited

and based on the mean concentrations and daily discharge rate, the annual mass emission was

computed.

Table 3.2.1 Waste Water Emissions 2008 to 2010:

Parameter 2008 Mass

Emission

(kg per annum)

2009 Mass

Emission

(kg per annum)

2010 Mass

Emission

(kg per annum)

Licensed Mass

Emission

(kg per annum)

BOD 2,226 1,213 3,008 109,500

COD 7,717 2,897 8,143 219,000

Suspended

Solids

1157 475 188 8,760

Sulphate 131 390 136 13,140

MBAS 137 57 18 2,190

Silver 0.02 < 0.154 < 0.170 10.95

As can be seen from the above data, compared with the licensed mass emission, the overall discharge

is relatively insignificant.


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Overall the impact of the plant’s effluent is not considered to be significant. This is because the

effluent from the plant is treated (along with all of the industrial estate effluent, and Dublin’s

municipal waste water) in the city’s effluent treatment plant at Ringsend, Dublin 4.

During 2010, there was one reported non-compliance with the effluent limit values, based upon all of

the sampling and analysis undertaken by Independent Laboratory, the EPA and South Dublin County

Council. A summary of the compliance history has been prepared, and this data is presented in Table

3.2.2 below.

Table 3.2.2 Summary of Effluent compliance for 2010:

Emission Point 2010

% Compliance

BOD 100

COD 100

Suspended Solids 100

Sulphate 100

MBAS 100

pH 83

On the 24th

of May 2010 a grab sample was collected by South Dublin County Council and the

reported result for pH was 4.4. The limit value for pH is 6 – 10 and the Agency was formally

notified of the incident and an investigation was undertaken. Consultations were held with the

suppliers of screen cleaning chemicals and no explanation for a low pH was identified. There was no

unusual activity on site and no effluent discharge arose outside of the normal screen washing process.

On site pH tests were taken and Independent Laboratory Ltd have also undertaken routine tests since

May 2010. In addition, South Dublin County Council has also undertaken tests for pH since the

reported incident. All test results since the reported pH non-compliance have been fully compliant.


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3.3 Surface Water Runoff:

Storm water arising on the Print & Display Ltd. facility is discharged into the County Council surface

water drainage system. The combined storm water discharge exits the Print & Display Ltd. site via a

manhole which is located at the north-eastern corner of the facility.

In accordance with the licence requirements, grab samples of surface water are analysed for pH and

COD on a biannual basis. Two sampling points (SW1 and SW2) were designated for monitoring but

difficulties with a roof drainage system prevented samples being collected from one of the points.

During 2010, the roof drainage issue was resolved and sampling of both SW1 and SW2 was

undertaken. In addition, the surface water sampling and reporting procedure was updated.

During 2010 a total of three grab samples of surface water were analysed for pH and COD. A

summary of the mean monitoring results for these surface water emissions (SW1 and SW2) are

presented in Table 3.3.1 below.

Table 3.3.1 2010 Mean Surface Water Monitoring Results:

Parameter Mean Concentration

2010

COD (mg/l) 353

pH (pH units) 7.1

In addition to the pH and COD analysis, grab samples of surface runoff are taken periodically for

visual inspection. The surface water monitoring programme has not detected any significant level of

spillage or contamination from the plant. In addition, the visual monitoring programme has not

necessitated any further assessment or monitoring.


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3.4 Noise:

The Print & Display Ltd. facility is located within a busy industrial estate and is far removed from

any noise sensitive location. The plant does not cause any significant impact on the noise

environment and for this reason there is no requirement to undertake environmental noise monitoring

at the plant.

It has been noted that recent changes at the plant have reduced the overall ambient noise level. In

particular the new printing machines are apparently quieter than the older machines they replaced. In

addition, the elimination of power hosing in the screen-wash area has had a noticeable improvement

on the ambient noise level inside the factory.


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3.5 Waste Management:

All waste management operations are regulated at the site in accordance with the terms and

conditions of the Company’s IPC licence. There are a number of distinct waste streams generated

throughout the plant, including:

Miscellaneous non-segregated waste

Waste sludge

Waste solvent

Waste cardboard

Waste timber.

In recent years major improvements in the on-site management of waste have occurred. The

handling and segregation of waste have been improved with modifications to the on-site bailing and

compacting systems and with on the job training.

Waste cardboard and waste timber has now been entirely diverted from landfill and both of these

streams are recycled. This data and details of the annual waste sent for off site disposal in 2010 are

presented in Table 3.5.2 (Attachment I of this report).

The types of hazardous waste generated on site includes: spent solvent/sludge which arises

intermittently from the screen wash machine and sludge from the interceptor trap. The use of

photographic chemicals has now been discontinued and there will be no hazardous waste arising

from the Graphics Department for the foreseeable future.

A summary of the total annual tonnage of hazardous and non-hazardous waste for the period 2005 to

2010 is presented in Table 3.5.1 below.

Table 3.5.1 Summary of Annual Waste Arising (2005 – 2010):

2005

(tonne)

2006

(tonne)

2007

(tonne)

2008

(tonne)

2009

(tonne)

2010

(tonne)

Hazardous Waste 1.4 3.8 2.4 3.6 8.2 6.6

Non-Hazardous Waste 357.5 367.0 380.6 445.2 394.5 387.81

There have been a number of significant changes at the plant in recent years and variations in

production output arise from time to time. For these reasons, caution is necessary when drawing

conclusions from the above data and it may not be possible to directly compare data from one year

with that of another. However, it is noteworthy that the greatest increase in waste production in

recent years has arisen in cardboard and timber waste which are recycled. The production of all other

waste streams has generally declined over the past number of years.

A review of suitability of the Company’s waste contactors is periodically undertaken and, when

necessary, consultations are held with the Agency regarding the approval of new contractors.


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3.6 Energy and Water Usage:

Details of electricity consumption, boiler fuel consumption and water consumption for the years 2007

to 2010 are presented in Table 3.6.1 below:

Table 3.6.1. Utilities Summary Report:

Utility 2007

Consumption

2008

Consumption

2009

Consumption

2010

Consumption

Electricity (kWh) 1,165,285 1,246,043 1,255,275 1,200,051

Space heating –

natural gas (kWh)

1,429,357 1,436,089 1,326,755 1,461,473

Water (m3) 6223 5585 4865 4576

As with waste management data, direct comparisons cannot always be made between one year and

another. However, it is noteworthy that there has been a slight increase in gas consumption between

2009 and 2010 (for space heating) and a slight decrease in electricity and water consumption over the

same period.

3.7 Environmental Incidents and Complaints:

The only environmental incident which has ever arisen at the plant, related to the discharge of

effluent and atmospheric emissions which do not fully comply with all of the licence limits. There

was one minor incident which arose during 2010 and this related to a reduced pH reading in one the

effluent samples. This was addressed earlier in Section 3.2 and the pH issue has now been

demonstrated to be fully compliant.

Print & Display Ltd. have a documented procedure for recording environmentally related complaints

as part of their Environmental Management System. There were no such complaints received since

the company was granted its IPC licence up to the end of December 2010.


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3.8 Pollution Emission Register:

Detailed PER assessment work was undertaken during the initial years of the company’s IPC licence.

The main emissions arising from the activity are the organic solvents which are discharged directly to

atmosphere. These organic solvents are used in the manufacture of ink and they are evolved during

the ink drying stage of the printing process. In addition, screen wash solutions are predominantly

solvent based and these are emitted to atmosphere during the screen cleaning process.

A wide range of solvents are used in the manufacturing of the Print & Display raw materials (inks

and screen washing chemicals). For this reason it is necessary to focus upon the total VOC

emissions, as opposed to the individual solvent emissions or the emission of specific compounds.

Some GC/MS work has been undertaken on samples collected at the plant, however, a huge range of

organic solvents was detected and these solvents were difficult to quantify individually. In addition,

data furnished from the raw material suppliers in the form of MSDSs do not accurately identify the

full range of solvents present in some of the raw materials.

Sampling of effluent suggests that there are negligible losses of solvent to sewer and the solvent

losses to product are not known but are thought to be insignificant. While the bulk of the VOC is

discharged from the licensed emission points, the remainder is evolved as fugitive emissions. It was

previously agreed with the Agency that the facility would not be subject to a detailed PER

assessment. However, the principal VOCs have been tracked by simple mass balancing and a

summary of the data is presented below. For comparison purposes, the VOC consumption data for

the period 1999 to 2009 is presented.

Table 3.8.1 Summary of solvent consumption 1999 - 2010

Year Total Solvent Consumption (kg)

1999 56,712

2000 28,625

2001 37,795

2002 27,411

2003 26,450

2004 16,780

2005 18,821

2006 14,686

2007 10,814

2008 17,148

2009 21,704

2010 20,074

There has been a marked decrease in the total solvent consumption over the period 1997 to 2007.

This is a direct result of the success of the ‘raw material substitution programme’ at the plant. This

has involved a phased decommissioning of the original printing machines and the commissioning of

a new screen washing machine at the plant. Increases in solvent consumption during 2009 (over the

2007 and 2008 data) have mainly arisen due to the increased activity levels of the ‘Turbo Jet’ and the

‘Press Jet’ machines, although there has been a minor reduction in solvent usage during 2010.


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Details of the PER data for 2010 are presented below.

Table 3.8.2 2010 PER Data:

Pollutant Usage

(kg solvent

per

year

Air

Emission

(kg TOC

per

annum –

Fugitive

and point

source)

MOM Effluent

Emission

(kg VOC

per

annum)

MOM Waste

(kg VOC

per annum)

MOM

Total

Organic

Carbon

20,074 13,474 M & C 0 C 6,600 M


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4. ENVIRONMENTAL MANAGEMENT

4.1 Site Management:

A copy of the current Print & Display Organisation Chart is included in Attachment II of this report.

The Managing Director is ultimately responsible for site management and control. Specific

responsibilities are delegated through the Plant Manager (Environmental Manager).

The Plant Manager assumes the role of Environmental Manager and as such is responsible for

environmental and safety management including all monitoring and reporting functions. Day to day

environmental management activities are carried out in conjunction with an Environmental

Management Committee.

4.2 Environmental Management System:

Print & Display Ltd. does not have a formalised Environmental Management System which meets

the criteria specified by ISO 14001. However, Print & Display Ltd. does operate and maintain an

Environmental Management System in line with the requirements of the IPC licence.

4.3 Human Resources, Training and Education:

Under Condition 2.7 of the Company’s IPC licence Print & Display Ltd. are required to establish and

maintain procedures for identifying training needs, and for providing appropriate training, for all

personnel whose work can have a significant effect upon the environment.

Print & Display Ltd. is also required to provide appropriate training for personnel who perform

certain tasks which have significant environmental implications. In response to this requirement,

Print & Display Ltd. have undertaken a series of training initiatives in the past including: in-house

Environmental Training Workshops and the participation in external workshops and seminars. More

recently an evaluation of training needs was undertaken and this has been used to develop an

Environmental Training Programme during 2010 and 2011.

Budgetary constraints limited the formal training undertaken during 2010, however, on-the-job

training was undertaken by the development of checklists of duties and tasks and this will be

followed up on during 2011 with a workshop. During July 2010 an Environmental Training

Workshop was presented to key personnel at the plant.


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4.4 Environmental Objectives and Targets:

Condition 2.2.1 of the Print & Display IPC licence requires a schedule of Environmental Objectives

and Targets to be drawn up. The Environmental Objectives and Targets form the basis of an

Environmental Management Programme at the facility. Considerable resources have been devoted to

environmental management over the years and major progress has been achieved in implementing the

firm’s Environmental Objectives and Targets.

A lot of the original targets had a time-frame of more than three years and many of the 2010/2011

Environmental Objectives and Targets are a natural extension of the original ones.

A review of the Environmental Objectives and Targets was undertaken during March 2011 and this has been

documented in Attachment III.

4.5 Environmental Management Programme

An Environmental Management Programme (EMP) proposal was developed for the Print & Display

Ltd. facility under Condition 2.3.1 of the IPC licence. Details of the implementation of the EMP are

presented on a project by project basis in a report presented in Attachment IV.

A total of eight projects were proposed in the EMP for 2010/2011 and significant progress has been

made with all projects being implemented. Some issues have arisen and additional projects have

been identified and targeted to form part of the EMP for 2011 and 2012. These are addressed in the

Environmental Management Programme (EMP) proposal which is presented in Attachment V.

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Attachment I

Annual Waste Arising -

2010

___________

_______________

Table 3.5.2 Annual Waste Arisings - 2010

Waste Material EWC Code Hazardous

(yes or no)

Quantity (Tonnes)

per annum

Method of

Disposal/Recovery

Location of

Disposal/Recovery

Name of waste

Disposal/Recovery

Contractor

Miscellaneous

office and plant

waste (not

segregated)

08 03 99 No 109.64 Landfill (D1) Ballycoolin, Fingal,

Co. Dublin.

Veolia Environmental

Services/Greenstar

Limited

Cardboard 20 01 01 No 196.34 Recycling (R13) Ballycoolin, Fingal,

Co. Dublin.


Services/Greenstar

Limited

Waste timber

packaging

15 01 03 No 81.829 Recycling (R13) Ballycoolin, Fingal,

Co. Dublin.


Services/Greenstar

Limited

Waste solvents 20 01 13* yes 6.6 Incineration (D10) Cookstown

Industrial Estate,

Dublin 24.

Guardian Silver Lining

_________________

_____________

Attachment II

Print & Display Ltd.

Organisation Chart

___________

__________________

Print & Display Ltd. - Organizational Chart

Managing Director

Ronan Conway

Finance Director

Carolyn Egan

Sales Director

Eamonn McKay

Operations Director

(Environmental Manager)

Jason Clarke

Finishing Manager

Dave Nevins

Print Manager - Screen

Kevin Quinn

Print Supervisor

Craig Jones

Print Supervisor

Tony Moore

__________________

_____________

Attachment III

Environmental

Objectives and Targets

Review, March 2011

___________

__________________


80, Cookstown Industrial Estate, Tallaght,

Co. Dublin


Environmental Objectives and Targets

Review March 2011

Contents

Page

1. INTRODUCTION 1

2. REVIEW OF THE OBJECTIVES & TARGETS 2

3. PROPOSED OBJECTIVES & TARGETS 3

4. CONCLUSION 4

APPENDIX 1

TABLE 1: Summary of objectives and targets review.

Environmental Objectives and Targets Review March 2011 Page 1 of 5

1. INTRODUCTION:

Print & Display Ltd. are licensed under the Environmental Protection Act 1992 to carry on a

screen printing operation with a capacity to use at least 10 tonnes per annum of organic

solvents.

Condition 2.2.1 of the Company’s Integrated Pollution Control (IPC) Licence requires the

licensee to prepare a schedule of objectives and targets. Condition 2.2.1 also requires the

objectives and targets to be reviewed and amendments to be notified to the Agency, as part of

the AER.

This submission presents a review of the company’s objectives and targets and sets out the

proposed amendments for 2011/2012.


2. REVIEW OF THE OBJECTIVES AND TARGETS:

A series of principal objectives and targets were initially established in 1999. These

objectives and targets related to the following issues:

The implementation of a raw material substitution programme.

The evaluation of alternative raw materials for the screen wash area.

The assessment of the ventilation needs of the printing plant.

Consulting with the Agency in connection with the licensing implications of all the

plant’s development plans.

The development of appropriate monitoring systems for the printing plant.

Investigating means of minimizing waste.

Upgrading the plant’s environmental documentation system.

Reviewing the environmental training and awareness needs of the facility.

Considerable progress has been made with regard to all of theses targets and objectives and a

review was undertaken in March 2011. Some targets have progressed further than others and

some have long term implications.

The implementation of the raw material programme was hugely successful and over the past

number of years the printing plant was effectively decommissioned and a new printing plant

was installed. This has ensured that most of the printing machines now operate on UV inks

and the raw material substitution programme has totally eliminated the need for any

abatement plant.

The development of new printing systems had a secondary set of impacts and most noticeably

caused intermittent problems with effluent quality. As a result of this, a work programme

was developed to resolve certain effluent quality issues and an entire new screen washing

process was successfully installed in 2006.

Once the facility’s atmospheric and effluent emissions have been successfully reduced and

controlled, secondary areas of attention have been targeted for environmental improvement.

In particular, in-house training and the development of systems to ensure full compliance

became the focus. In addition, the licensee has been obliged to review the enforcement

category for the facility in consultation with the EPA using the approved guidance and

published methodology. Along with this work a periodic review of all waste disposal

contracts has been undertaken but new developments have given rise to project work such as

the evaluation and approval of new contractors.


During 2010 Print & Display Ltd. fulfilled all of its obligations arising as a result of the

Environmental Liability Risk Assessment (ELRA) requirements published by the Agency.

Significant resources were devoted to undertaking the necessary assessment work and

consulting with the relevant authorities. The project work undertaken included the

development of a Closure Plan for the facility and the consideration of financial provision for

environmental liabilities. A review of the Risk Assessment, Closure Plan and Financial

Provision will be undertaken on an annual basis, the findings of which will be communicated

to the EPA as part of the Annual Environmental Report.

From time to time the Environmental Documentation System needs to be updated and this

work has featured in the EMP. In addition, a periodic review of the Enforcement Category is

also undertaken in line with EPA guidance.

New targets and objectives have been set for 2011/2012 and these include an evaluation of

on-site bunds and an evaluation of potential obligations arising from the use of fluorinated

greenhouse gases and ozone depleting substances. In addition, some of the 2010/2011 targets

and objectives have been carried over.


3. PROPOSED OBJECTIVES AND TARGETS:

A series of objectives and targets has been developed for 2011/2012. Some of these are a

natural continuation of the earlier targets and some have arisen out of new developments and

legislative requirements. The objectives and targets are set out in tabular form in Appendix I.


4. CONCLUSION:

A summary of the proposed 2011/2012 objectives and targets is set out in tabular form in

Appendix I. The licensee undertakes to review these objectives and targets for the 2011 AER

although some are likely to have a lifespan of a few years.

APPENDIX I

Table 1:

Summary of

objectives and targets review.

TABLE 1: Summary of objectives and targets review.

OBJECTIVES

PRIMARY GOALS

PRIMARY DEADLINES

3.1 The licensee will review all waste

disposal operations.

A review of all waste contracts was completed and new arrangements and

recycling outlets were identified and the necessary approvals were sought

through the Agency. Waste contractors have also been subject to a

questionnaire and/or to an audit or inspection where appropriate.

Major improvements in waste segregation and

disposal have been implemented. A number of

new issues and contracts have arisen over the past

number of years and new waste management

objectives were also established. (Refer to

objective 3.6 and 3.14). Approval has been sought

for new contractors in 2011 and consultations have

been undertaken with the Agency and with Dublin

City Council regarding waste licences and Waste

Disposal permits of certain contractors.

3.2 The licensee will evaluate all

waste labelling and storage

arrangements.

An evaluation of the current storage and labelling arrangements for waste

will be undertaken with a view to reducing hazards and preventing

pollution. Any necessary improvements will be made to ensure that 100%

of all waste storage vessels are properly labelled and appropriate for the

waste material.

This project was undertaken during 2009 and

additional labelling and storage arrangements have

been put in place. It is intended that it shall be

periodically reviewed and if necessary revisited

during 2011.

TABLE 1: Summary of objectives and targets review (continued).

OBJECTIVES

PRIMARY GOALS

PRIMARY DEADLINES

3.3 The licensee will evaluate the

current surface water monitoring

programme and make any

necessary improvements.

The company is required to monitor surface water in accordance with

Condition 9.1 of the IPC licence. The sampling and reporting procedure is

in need of updating. The sampling and the reporting procedures will be

reviewed and updated to ensure full compliance with the licence

requirements.

The project was completed during 2010 and will

be the subject o a review during 2011.

3.4 The licensee will examine the

screen-wash floor to determine

the extent of any necessary

improvements. Any necessary

upgrade to the floor will be

completed at the soonest

possible plant shut-down.

A review of screen-wash area floor to determine the extent of any

necessary improvements will be undertaken. The aim will be to ensure that

the grouting is repaired to prevent seepage of cleaning agents from this

area.

A decision to modernise the entire screen washing

system was taken and the resulted in an

Environmatic Screen washing system being

installed during 2006. The screen wash bay is no

longer used and the potential for seepage does not

exist anymore.

3.5 The licensee will evaluate all

effluent generating processes

and develop appropriate

monitoring systems for the

screen wash area.

The effluent ELVs are expected to be revised in accordance with Dublin

County Council consent. It is envisaged that recent improvements will

ensure full compliance; however, this will require detailed effluent

monitoring work. Where necessary additional measures will be adopted to

ensure consistent compliance with all licence limits.

The Environmatic Screen washing system has

resulted in consistently good effluent quality.

During 2009 a potential issue arose due to a build

up of sludge in the interceptor trap. Arrangements

were subsequently made in consultation with The

Agency for appropriate removal and off-site

disposal. In May 2010 an effluent sample was

reported to have a pH of 4.4 (limit 6 – 10). This

matter has been investigated and no apparent cause

has yet been identified. Ongoing pH sampling is

being undertaken at the facility and all the data

since May 2010 has been fully compliant.


OBJECTIVES

PRIMARY GOALS

PRIMARY DEADLINES

3.6 The licensee undertakes to investigate

means of minimising waste.

A series of measures will be adopted to ensure that waste is avoided at

source and that unavoidable waste is recycled or reused where possible.

Waste minimisation practices were identified by closely collating and

benchmarking waste output for individual print runs. Improvements

were subsequently phased into the activity over a period of years and

P&D set itself a target to reduce the tonnage of landfilled waste by 5%.

A series of waste minimisation measures were

adopted and during 2007 a detailed waste

packaging audit was undertaken. This concluded

that the facility was in compliance of its packaging

waste obligations. P&D does not believe that there

are further improvements to be made although a

review of waste management options will be

undertaken in consultation with waste contractors.

Where practicable further improvements will be

developed by December 2011.

3.7 The licensee will upgrade the plant’s

environmental documentation

system.

The existing environmental documentation system will be reviewed and

appropriate improvements to the documentation system will be made.

It is envisaged that key parts of the EMS will require ongoing

documentation changes and updates. During 2010 a register of all

standard operating procedures (SOPs) will be prepared and any

necessary updates will be made.

A register of all SOPs was prepared and any

necessary updates were made

during 2010. A further evaluation and review of

the documentation system will be made by

December 2011 in line with issues and

developments arising from other projects.

3.8 The licensee will review the

environmental training and

awareness needs of key personnel.

A review of key staff’s environmental awareness and training will be

completed. A programme will be developed to ensure that all relevant

personnel are provided with appropriate training.

A training review has been completed and a

training needs assessment has been completed for

key staff. A new training programme will be

implemented by September 2011 and where new

issues arise, updates to the training programme

will be made.


OBJECTIVES

PRIMARY GOALS

PRIMARY DEADLINES

3.9 The licensee will review the site

drainage system and any

necessary improvements will be

made.

The existing drainage system will be examined and improvements to the

system will be made, where necessary. Questions have been raised about

where certain drains discharge to and whether any run-off emanates from

the adjacent sites. One of the main objectives will be to determine precisely

where all drains discharge. An up to date site drainage plan will be

compiled and circulated to all relevant personnel.

Issues regarding the discharge of surface water

from other sites have arisen. Relatively small

volumes of surface water arise on the P&D site,

but the combined surface water of the industrial

estate passes though the P&D drain. This project

was implemented in 2009 and some modifications

in the surface water monitoring procedure were

called for during 2010 (see Objective 3.16).

3.10 The licensee will review the

potential for recycling screen

wash solvent on-site.

The Environmatic Screen washing system has resulted in consistently good

effluent quality and it has reduced the emissions to atmosphere. An

evaluation of ways to reduce raw material usage will be evaluated and in

particular the benefits of solvent recovery will be assessed. Consultations

will be held with equipment suppliers and with the EPA and the

environmental benefits of available systems will be assessed. In the event

that a viable system can be sourced, prior notification will be given to the

Agency and all safety and environmental issues will be investigated.

This project was originally commenced in April

2007 and was fully completed by the purchase and

commissioning of the new Environmatic Screen

wash system.

3.11 An energy conservation

programme and awareness

strategy will be developed for

the company.

A log of energy consumption will be made on a monthly basis. Good

housekeeping practices and energy conservation initiatives will be

introduced.

Ongoing energy consumption data will be

maintained during 2011. Staff awareness and

training initiatives will be introduced where

necessary.

3.12 The licensee shall establish

formal procedures to ensure that

the requirements of the IPC

licence are being complied with.

An internal review off all IPC licence conditions and schedules will be

undertaken. A series of checklists and questionnaires will then be

developed to facilitate P&D personnel to undertake internal audits.

An audit of the facility was undertaken during

2010 and checklists were developed to remind staff

of their periodic environmental obligations. These

checklists will form the part of on-the-job training

during 2011. Internal audits will also proceed on

an annual basis as part of the preparation work for

the AER. The next audit will be completed by

January 2012.


OBJECTIVES

PRIMARY GOALS

PRIMARY DEADLINES

3.13 The licensee shall review of the

enforcement category for the

facility in consultation with the

EPA.

A review of the EPA’s guidance will be made. All pertinent data will be

compiled and consultations will be held where necessary. An electronic

submission will be made to the Agency based upon the 2009 AER data.

.

The project originally resulted in a submission to

the EPA in 2009. Notification that new guidance

has been issued was received by P&D in July 2010

(RBME guidance). A new assessment based upon

the updated RBME was completed in August 2010.

Based upon the 2010/2011 AER, a new submission

will be made to the Agency by July 2011.

3.14 A review of all waste disposal

contracts will be made.

During 2010 the acquisition of Veolia Environmental Services by

Greenstar Limited has proceeded. In addition, P&D has evaluated the

suitability of certain waste contractors and this may result in new outlets

being used for waste disposal. These developments require a formal

notification to the Agency and/or an update of internal documentation

systems.

The project has commenced and during April 2011

consultations were made with the EPA regarding

the approval of new waste contactors. Contractual

arrangements will not be entered into until the

contactors have been approved. It is likely that this

will proceed during 2011 with a final review and

update of any documentation to be completed by

November 2011.

3.15 A review of all statutory

obligations and relevant guidance

documentation pertaining to

Environmental Liability Risk

Assessment (ELRA) will be made. All

necessary submissions will be

furnished to the Agency.

The company’s obligations arising as a result of all relevant

Environmental Liability Risk Assessment (ELRA) Guidance and policy

documents will be reviewed with reference to any new statutory

obligations. Where necessary a documented response will be made.

Major resources have already been devoted to

undertaking the necessary assessment work and

consulting with the relevant authorities. In

addition, the company has developed a Closure

Plan for the facility, an ELRA report and has also

documented the consideration of financial

provision for environmental liabilities. A review

of the Risk Assessment, Closure Plan and

Financial Provision was undertaken during

November 2010. This assessment will be

reevaluated and reviewed in line with new

developments by the end of December 2011.


OBJECTIVES

PRIMARY GOALS

PRIMARY DEADLINES

3.16 A review of the surface water

monitoring procedure will be made and

any necessary modifications will be

made.

Two sampling points were designated but difficulties with a roof drainage

system prevented samples being collected from one of the points. In

addition, the sampling and reporting practices have been complicated by

the fact that surface water enters the site from other facilities on the

industrial estate. A new procedure will be put in place and implemented to

ensure that the sampling and reporting is in line with all requirements and

where necessary consultation swill be held with Dublin County Council

and the EPA.

The new procedure will be put in place and

completed before the end of November 2011.

3.17 A review of the bunding

arrangements at the facility will be

undertaken.

The company’s obligations in relation to bunding are specified in the IPC

licence, however, guidelines have evolved and an evaluation of all bunds

will be undertaken to determine their suitability. A documented bund

management record will be prepared.

Guidance will be reviewed and a documented bund

management record will be prepared.

and completed during July 2011.

3.18 A review of the legislation and

guidance on the use of fluorinated

greenhouse gases and ozone

depleting substances will be made.

Potential obligations may have arisen in relation to potential obligations

arising from the use of fluorinated greenhouse gases and ozone

depleting substances. A review of the legislation and guidance will be

made along with potential sources such as chillers and air conditioning

units which are used on site.

The relevant legislation and guidance will be

reviewed and a documented management

procedure will be formulated

and completed by the end of August 2011.

__________________

_____________

Attachment IV

Implementation of

Environmental

Management Programme

2010/2011

___________

__________________



Co. Dublin


Implementation of

Environmental Management Programme 2010/2011

Contents

Page

1. INTRODUCTION 1

2. IMPLEMENTATION OF EMP PROJECTS 2

3. CONCLUSION 10

Implementation of Environmental Management Programme 2010/2011 Page 1 of 10

1. INTRODUCTION:

Print & Display Ltd. are licensed under the Environmental Protection Agency Act 1992 to

carry on a screen-printing operation with a capacity to use at least 10 tonnes per annum of

organic solvents. The location of the licensed activity is 80, Cookstown Industrial Estate,

Tallaght, Co. Dublin and the licence register number is 116.


licensee ‘...to establish and maintain an Environmental Management Programme, including

a time schedule for achieving objectives and targets’.

This report sets out the details of the implementation of the Environmental Management

Programme (EMP) for 2009 and 2010, on a project by project basis.


2. IMPLEMENTATION OF EMP PROJECTS:

Project Number 1:

An Environmental Audit will be undertaken at the facility to

determine the level of compliance with the IPC licence.

Relationship to the

company's objectives

and targets:

This project will help to ensure that the requirements of the IPC

licence are being complied with in accordance with Objective

3.12.

Rationale for

undertaking project:

A systematic audit will enable the licensee to determine the

degree of compliance with the IPC licence requirements. Where

problem areas are identified appropriate remedial action will be

undertaken. This project will help to ensure that pollution is not

caused by the plant and it will also help to reduce the plant’s

environmental liabilities.

Target to be achieved

by project:

The project will help to achieve compliance with the IPC licence

requirements and it will help to prevent environmental pollution.

It will also help in the compilation of the AER.

Outline of Project:

An internal Environmental Audit of the Print & Display facility

will be undertaken annually. The Audit methodology will be

primarily based upon a site specific checklist which was designed

to determine the level of Print & Display’s environmental

compliance with the IPC licence requirements. The Audit will

also be helpful in focussing upon potentially non-complaint

issues.

Current Status: This project has been fully implemented.

Summary Report: An audit checklist was developed and this has been modified and

updated to facilitate the audit process. An internal audit was

undertaken at the facility and this was closed off during March

2011. The audit process is to be repeated on an annual basis.


Project Number 2:

Consultations will be held with waste contractors regarding

their environmental licences and/or permits. Where

considered appropriate or necessary an audit of their

facilities will be undertaken.

Relationship to the


and targets:



3.14.

Rationale for


All waste is disposed off site using approved contractors and

approved facilities. Commercial pressures will require

competitive tendering to be considered and new contracts may be

considered. Even if our contactors are not changed, it is

considered good practice to ensure that the existing agents and

contractors are fully authorised and that appropriate controls and

documentation are in place. During 2010 the acquisition of

Veolia Environmental Services by Greenstar Limited has resulted

in new outlets being used for waste disposal. These developments

will require a formal notification to the Agency and/or an update

of internal documentation systems.

The project will review all wastes handled by P & D and will also

facilitate a review of the provisions of Condition 7 of the licence.


by project:

During 2010 Veolia Environmental Services was acquired by

Greenstar and this may result in different disposal outlets being

used. An assessment of the licensing implications of this will be

undertaken and a submission will be made to the Agency, where

required.

Outline of Project:

All waste streams will be examined in line with Condition 7 and

consultations will be held with all waste contactors regarding

their environmental licences and/or permits. Copies of these will

be sourced and reviewed and where considered appropriate or

necessary an audit of certain contractors or their facilities will be

undertaken.

Current Status: This project was successfully implemented, but ongoing issues

may arise.

Summary Report: Consultations were held with all waste contactors during 2010

with and an evaluation of the suitability of two new contactors

was undertaken and completed in March 2011. In addition,

consultations were also held with the EPA regarding the approval

of these new waste contractors. Given the changes in the waste

sector and the need to keep a watching brief on waste

management, some follow-up work is likely.


Project Number 3:

The facility’s environmental documentation system will be

reviewed and upgraded during 2010.

Relationship to the


and targets:



3.7.

Rationale for


Condition 2.5 of the IPC licence specifically requires the

Company to provide and maintain an Environmental

Documentation System. Compliance with this condition will

ensure that appropriate controls and records are in place.


by project:

The project will achieve compliance with Condition 2.5 and it

will help to prevent environmental pollution. It will also re-

familiarise all relevant staff of the environmental management

system.

Outline of Project:

The documentation system is a fundamental part of the

environmental control system and developments in key parts of

the plant may require some new documentation changes from

time to time. During 2010 a register of all standard operating

procedures (SOPs) will be developed and this will be used for

staff training, as required.

Current Status: This project was successfully been implemented during 2010.

Summary Report: All documentation was reviewed and updated during November

2010 and a register of all standard operating procedures (SOPs)

was developed. New developments have and EPA Guidance has

arisen and this will require an update of the Emergency Response

Procedure during 2011.


Project Number 4:

An environmental training programme will be developed for

key personnel at the plant.

Relationship to the


and targets:



3.8.

Rationale for


Condition 2.7 of the IPC licence specifically requires the licensee

to address training and awareness. Improved awareness will

generally help to promote better environmental practices. In

addition, new functions and responsibilities may be undertaken

by key personnel and some may require additional training.


by project:


will also help to ensure that miscellaneous conditions are

complied with. It will also help to prevent environmental

pollution. All personnel whose work has the potential to impact

upon the environment will undergo a training programme.

Approximately 5 personnel will be provided with training during

2010 and 2011.

Outline of Project:

The project will initially involve developing the key areas to be

highlighted in response to the training needs of key employees.

Training seminars or workshops will then be presented in-house

and/or on the job training will be provided.

Current Status: This project was successfully implemented.

Summary Report: During 2010 and 2011 a review of the training requirements was

made. On the job training was provided and a training workshop

was undertaken on the 28 July 2010. A training needs evaluation

was subsequently carried out and a workshop is planned for 4

employees during 2011 with SOP training to be provided for an

additional two employees.


Project Number 5:

A programme will be implemented to closely monitor energy

usage with a view to introducing improved practices

throughout the facility.

Relationship to the


and targets:



3.11

Rationale for


An efficient energy conservation programme will reduce the

overall emissions attributable to the facility and it will also be in

line with good environmental practice. There should hopefully

be additional cost savings to be made.


by project:

The target to be achieved is to have an up-to-date energy

conservation programme fully operational and subject to an

internal review by March 2010. This will ensure that all

personnel are aware of the environmental issues associated with

energy conservation and that the company’s programme is up to

date and functioning well.

Outline of Project:

A review of all energy consumption will be made and recorded

on a monthly basis. A series of energy conservation measures

will be adopted throughout the plant. These will be based upon

simple housekeeping measures such as switching off lights and

equipment when not in use and minimising energy wastage etc.

Where necessary, awareness and training will be improved


Current Status: The project was successfully implemented.

Summary Report: Energy consumption was reviewed and recorded on a monthly

basis. There has been a slight increase in gas consumption

between 2009 and 2010 (for space heating) and a slight decrease

in electricity consumption over the same period.


Project Number 6:

A review of the enforcement category for the facility will be

made and a submission will be lodged with the EPA.

Relationship to the


and targets:

This project will help to ensure that the facility is requirements of

the IPC licence are being complied with in accordance with

Objective 3.13.

Rationale for


New methodologies have been established to determine the

enforcement category of licences. This enables licensed facilities

to assess their enforcement category with a view to improving

environmental performance and it also facilitates the Agency in

assigning the appropriate attention and resources in the

fulfillment of their policing role.


by project:

The target to be achieved is to have a complete review of the

enforcement category and to make a full electronic submission to

the Agency by the end of September 2010.

Outline of Project:

A review of the EPA’s new (2010) guidance will be made. All

pertinent data will be compiled and consultations will be held

where necessary. An electronic submission will be made to the

Agency based upon the 2009 AER data and consultations held

with Agency personnel.

Current Status: The project was successfully completed.

Summary Report: The relevant guidance documents were reviewed and all

necessary consultations were held to collate and process the

required data. The project was successfully completed and a

submission was made to the EPA during August 2010.


Project Number 7:

A review of the statutory obligations and relevant guidance

documentation pertaining to Environmental Liability Risk

Assessment (ELRA) will be made. If necessary or appropriate

a submission will be lodged with the EPA based upon the

review findings.

Relationship to the


and targets:



Objective 3.15.

Rationale for


The company’s obligations arising as a result of relevant

Environmental Liability Risk Assessment (ELRA) Guidance and

policy documents require a periodic risk assessment and review.

This work will be undertaken with reference to new statutory

obligations and EPA guidance and in the light of a review of the

enforcement category of the IPC licence. This will enable P&D

to evaluate their enforcement category/Risk Assessment and

Financial Provision.


by project:


relevant legislation/guidance and the Risk Assessment, Closure

Plan and Financial Provisions by November 2010.

Outline of Project:

A review of the EPA’s guidance will be made. All pertinent data

will be compiled and consultations will be held where necessary.

A review of the Risk Assessment, Closure Plan and Financial

Provisions will be undertaken. In the event of amendments

arising, all necessary consultations will be held with Agency

personnel and appropriate submissions will be made.

Designation of

Responsibility:

The Environmental Manager will assume overall responsibility

for this project, with assistance being provided by the company

directors and Environmental Consultants, as required.


Summary Report: All relevant guidance documents were reviewed and all necessary

consultations were held to acquire and process the required data.

The Environmental Liability Risk Assessment, Closure Plan and

Financial Provision report was reviewed and updated during

November 2010.


Project Number 8:

A review of the surface water monitoring procedure will be

made and any necessary modifications will be made.

Relationship to the


and targets:



Objective 3.16.

Rationale for


The company is required to monitor surface water in accordance

with Condition 9.1 of the IPC licence. Two sampling points were

designated but difficulties with a roof drainage system prevent

samples being collected from one of the points. In addition, the

sampling and reporting procedure is in need of updating.


by project:

The target to be achieved is to review and update the surface

water monitoring procedure in accordance with Condition 9.1 of

the IPC licence (and the agency’s requirements) before the end of

August 2010.

Outline of Project:

A review of the surface water monitoring procedure will be

made. Consultations will be held with Agency personnel where

necessary and a modified system will be implemented. On-the-

job training will be provided on the new procedure where

required.


Summary Report: Problems with the roof drainage were resolved and surface water

sampling recommenced on a weekly basis on 20 August 2010.


3. CONCLUSION:

A total of eight projects were proposed for the 2010/2011 EMP. All of these have been

successfully implemented. Some of the project work will need to be repeated during 2011 as

a result of new issues and developments.

A draft EMP proposal will be submitted to the EPA for 2011/2012.

_______________________

_________

Attachment V

Proposed Environmental

Management

Programme – 2011/2012

___________

__________________



Co. Dublin


Proposed Environmental Management Programme 2011/2012

Contents

Page

1. INTRODUCTION 1

2. SCOPE OF THE EMP 2

3. PROPOSED EMP PROJECTS 3

4. CONCLUSION 12

Proposed Environmental Management Programme 2011 - 2012 Page 1 of 12

1. INTRODUCTION:

Print & Display Ltd. are licensed under the Environmental Protection Agency Act 1992 to

carry on a screen-printing operation with a capacity to use at least 10 tonnes per annum of

organic solvents. The location of the licensed activity is 80, Cookstown Industrial Estate,

Tallaght, Co. Dublin and the licence register number is 116.


licensee ‘...to establish and maintain an Environmental Management Programme, including

a time schedule for achieving objectives and targets’.

This report sets out the details of the proposed Environmental Management Programme

(EMP) for 2011 and 2012, on a project by project basis.


2. SCOPE OF THE EMP:

The primary factors which have determined the scope of the EMP are the licensee’s proposed

objectives and targets and the general provisions of the Integrated Pollution Control licence.

Condition 2.3 of the licence specifies the issues which should be addressed ‘as a minimum’ in

the EMP.

Reference has also been made to the Agency's guidance - Guidance Note for Annual

Environmental Report - in determining the scope and layout of the EMP.


3. PROPOSED EMP PROJECTS:

The following projects are proposed for 2011 and 2012.

Project Number 1:

An Environmental Audit will be undertaken at the facility to

determine the level of compliance with the IPC licence.

Relationship to the


and targets:



3.12.

Rationale for


A systematic audit will enable the licensee to determine the

degree of compliance with the IPC licence requirements. Where

problem areas are identified appropriate remedial action will be

undertaken. This project will help to ensure that pollution is not

caused by the plant and it will also help to reduce the plant’s

environmental liabilities.


by project:

The project will help to achieve compliance with the IPC licence

requirements and it will help to prevent environmental pollution.

It will also help in the compilation of the AER.

Outline of Project:

An internal Environmental Audit of the Print & Display facility

will be undertaken annually. The Audit methodology will be

primarily based upon a site specific checklist which was designed

to determine the level of Print & Display’s environmental

compliance with the IPC licence requirements. The Audit will

also be helpful in focussing upon potentially non-complaint

issues.

Designation of

Responsibility:

The Environmental Manager will assume responsibility for this

project.

Project Schedule: An internal audit will be undertaken in consultation with our

Environmental Consultants during January 2012.


Project Number 2:

Consultations will be held with waste contractors regarding

their environmental licences and/or permits. Where

considered appropriate or necessary an audit of their

facilities will be undertaken.

Relationship to the


and targets:



3.14.

Rationale for


All waste is disposed off site using approved contractors and

approved facilities. Commercial pressures require competitive

tendering to be considered and new contracts are actively being

considered. It is considered good practice to ensure that the

existing agents and contractors are fully authorised and that

appropriate controls and documentation are in place. These

developments will require a formal notification to the Agency

and/or an update of internal documentation systems.

The project will review all wastes handled by P & D and will also

facilitate a review of the provisions of Condition 7 of the licence.


by project:

During 2011 the approval of new waste contactors has been

sought and this may result in new operational practices and

different disposal outlets being used. An assessment of the

licensing implications of this will be undertaken and a

consultations will be held with the Agency and/or Dublin City

Council, where required by the end of November.

Outline of Project:

All waste streams will be examined in line with Condition 7 and

consultations will be held with all waste contactors regarding

their environmental licences and/or permits. Copies of these will

be sourced and reviewed and where considered appropriate or

necessary an audit of certain contractors or their facilities will be

undertaken.

Designation of

Responsibility:


project, however, external assistance may be provided by

Environmental Consultants.

Project Schedule: The project has already commenced and will proceed during

2011, when it is likely that new contractual arrangements will be

entered into. The time line for these can not be determined but no

waste disposal contracts will proceed without the prior approval

of the EPA.


Project Number 3:

The facility’s environmental documentation system will be

reviewed and upgraded during 2011.

Relationship to the


and targets:



3.7.

Rationale for


Condition 2.5 of the IPC licence specifically requires the

Company to provide and maintain an Environmental

Documentation System. Compliance with this condition will

ensure that appropriate controls and records are in place.


by project:


will help to prevent environmental pollution. It will also re-

familiarise all relevant staff of the environmental management

system.

Outline of Project:

The documentation system is a fundamental part of the

environmental control system and developments in key parts of

the plant may require some new documentation changes from

time to time. On the 31 of December 2010 new guidance was

issued by the EPA regarding the Notification of Incidents. This

will require a review and updating of our Emergency Response

Procedure (ERP). In addition, developments in waste

management will require certain documentation to be updated.

Designation of

Responsibility:




Project Schedule: The ERP will be reviewed and updated before the end of July.

The waste management documentation system will be reviewed

and updated as the need arises, with a final review undertaken by

the end of December 2011.


Project Number 4:

An environmental training programme will be developed for

key personnel at the plant.

Relationship to the


and targets:



3.8.

Rationale for


Condition 2.7 of the IPC licence specifically requires the licensee

to address training and awareness. Improved awareness will

generally help to promote better environmental practices. In

addition, new functions and responsibilities may be undertaken

by key personnel and some may require additional training.


by project:


will also help to ensure that miscellaneous conditions are

complied with. It will also help to prevent environmental

pollution. All personnel whose work has the potential to impact

upon the environment will undergo a training programme.

Approximately 7 personnel will be provided with training during

2011.

Outline of Project:

The project will initially involve developing the key areas to be

highlighted in response to the training needs of key employees.

Training seminars or workshops will then be presented in-house

and/or on the job training will be provided.

Designation of

Responsibility:




Project Schedule: The project is essentially required on an ongoing basis. A review

of the training requirements has undertaken and Emergency

Response Procedure (ERP) and Environmental Awareness

training is to be provide to 5 employees. Training on SOPs and

Environmental Awareness will be provided to two additional

employees before the end of September 2011.


Project Number 5:

A programme will be implemented to closely monitor energy

usage with a view to introducing improved practices


Relationship to the


and targets:



3.11

Rationale for


An efficient energy conservation programme will reduce the

overall emissions attributable to the facility and it will also be in

line with good environmental practice. There should hopefully

be additional cost savings to be made.


by project:

The target to be achieved is to have an up-to-date energy

conservation programme fully operational and subject to an

annual review by July 2011. This will ensure that all personnel

are aware of the environmental issues associated with energy

conservation and that the company’s programme is up to date and

functioning well.

Outline of Project:

A review of all energy consumption will be made and recorded

on a monthly basis. A series of energy conservation measures

will be adopted throughout the plant. These will be based upon

simple housekeeping measures such as switching off lights and

equipment when not in use and minimising energy wastage etc.

Where necessary, awareness and training will be improved


Designation of

Responsibility:


project, however, external assistance may be provided by energy

consultants.

Project Schedule: This project will be ongoing during 2011 and will be completed

by the end of January 2012.


Project Number 6:

A review of the enforcement category for the facility will be

made and a submission will be lodged with the EPA.

Relationship to the


and targets:



Objective 3.13.

Rationale for


New methodologies have been established to determine the

enforcement category of licences. This enables licensed facilities

to assess their enforcement category with a view to improving

environmental performance and it also facilitates the Agency in

assigning the appropriate attention and resources in the

fulfillment of their policing role.


by project:


enforcement category and to make a full electronic submission to

the Agency by the end of July 2011.

Outline of Project:



An electronic submission will be made to the Agency based upon

the 2010 AER data and consultations held with Agency

personnel.

Designation of

Responsibility:




Project Schedule: The project will be completed by the end of July 2011.


Project Number 7:

A review of the statutory obligations and relevant guidance

documentation pertaining to Environmental Liability Risk

Assessment (ELRA) will be made. If necessary or appropriate

a submission will be lodged with the EPA based upon the

review findings.

Relationship to the


and targets:



Objective 3.15.

Rationale for


The company’s obligations arising as a result of relevant

Environmental Liability Risk Assessment (ELRA) Guidance and

policy documents require a periodic risk assessment and review.

This work will be undertaken with reference to new statutory

obligations and EPA guidance and in the light of a review of the

enforcement category of the IPC licence. This will enable P&D

to evaluate their enforcement category/Risk Assessment and

Financial Provision.


by project:


relevant legislation/guidance and the Risk Assessment, Closure

Plan and Financial Provisions by December 2011.

Outline of Project:



A review of the Risk Assessment, Closure Plan and Financial

Provisions will be undertaken. In the event of any significant

amendments arising, all necessary consultations will be held with

Agency personnel and appropriate submissions will be made.

Designation of

Responsibility:


for this project, with assistance being provided by his fellow

directors and their Environmental Consultants, as required.

Project Schedule: The project will be completed by the end of December 2011.


Project Number 8:

A review of the bunding facilities will be made and any

necessary modifications will be made.

Relationship to the


and targets:



3.17.

Rationale for


The company’s obligations in relation to bunding are specified in

the Condition 9 of the IPC licence. However, guidelines have

evolved and an evaluation of all bunds will be undertaken to

determine their suitability. A documented bund management

record will be prepared.


by project:

The target to be achieved is to review the bunding facilities in

line with Condition 9 of the IPC licence (and the Agency’s

requirements) before the end of July 2011.

Outline of Project:

A review of the bunding facilities and the relevant guidance will

be made. Consultations will be held with Agency personnel

where necessary and a questionnaire will be completed and a

submission will be made before the end of April 2011.

Designation of

Responsibility:


for this project, with assistance being provided by his

Environmental Consultant, as required.

Project Schedule: A questionnaire will be completed and a submission will be made

before the end of April. The review of the bunding facilities and

the relevant guidance will be made by the end of July 2011.


Project Number 9:

A review of the legislation and guidance on the use of fluorinated

greenhouse gases and ozone depleting substances will be made

and where necessary controls and documentation systems will be

developed.

Relationship to the


and targets:



3.18.

Rationale for


The company’s obligations in relation to F-gas and ODS are

specified in the relevant EC regulations (No. 842 of 2006 and

1005 of 2009). In addition, guidance has been published by the

Agency.


by project:

The target to be achieved is to review the equipment on site to

identify whether any pertinent refrigerants are used or contained.

An inventory of pertinent equipment and appropriate

management practices will be developed, before the end of

August 2011.

Outline of Project:

An assessment of any on-site air conditioning and/or chilling

equipment will be made. Consultations will be held with

suppliers and/or relevant contractors and an estimate of likely

volumes of HCF refrigerant will be made. The relevant

legislation and guidance will be reviewed and a documented

management procedure will be formulated.

Designation of

Responsibility:


for this project, with assistance being provided by his

Environmental Consultant and Maintenance Manager, as

required.

Project Schedule: This project will commence in May and will be completed by the

end of August 2011.


4. CONCLUSION:

This submission sets out the EMP projects proposed for 2011 and 2012. A total of nine

projects have been proposed and work has already commenced on some of these. Some of

the projects have a time-frame over more than one year and some give rise to obligations on

an annual basis in line with issues which arise in the licensing system.

Page deliberately blank.

Sheet : Facility ID Activities AER Returns Workbook 21/4/2011 17:40

| PRTR# : P0116 | Facility Name : Print & Display Ltd. | Filename : P0116_2010.xls |

Return Year : 2010 | 3556 20/09/2011 11:06

Guidance to completing the PRTR workbook

Version 1.1.12

REFERENCE YEAR 2010

1. FACILITY IDENTIFICATION

Parent Company Name Print & Display Ltd.

Facility Name Print & Display Ltd.

PRTR Identification Number P0116

Licence Number P0116-01

Waste or IPPC Classes of Activity

No. class_name

12.2.2 #####################################################

Address 1 80 Cookstown Industrial Estate

Address 2 Tallaght

Address 3 Dublin 24

Address 4

Country Ireland

Coordinates of Location -6.37295 53.2960

River Basin District IEEA

NACE Code 2030

Main Economic Activity

Manufacture of paints, varnishes and similar coatings, printing ink

and mastics

AER Returns Contact Name Jason Clarke

AER Returns Contact Email Address [email protected]

AER Returns Contact Position Environmental Manager

AER Returns Contact Telephone Number 01- 4131400

AER Returns Contact Mobile Phone Number

AER Returns Contact Fax Number 01- 4513624

Production Volume 4,628,116

Production Volume Units m2 of printed board per annum

Number of Installations 1

Number of Operating Hours in Year 5400

Number of Employees 45

User Feedback/Comments

Web Address www.printanddisplay.ie

2. PRTR CLASS ACTIVITIES

Activity Number Activity Name

50.1 General

3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002)

Is it applicable? no

Have you been granted an exemption ? no

If applicable which activity class applies (as per

Schedule 2 of the regulations) ?

Is the reduction scheme compliance route being

used ?

AER Returns Workbook

| PRTR# : P0116 | Facility Name : Print Display Ltd. | Filename : P0116_2010.xls | Return Year : 2010 | Page 1 of 1

http://www.epa.ie/downloads/advice/aerprtr/completinguploadingtheprtrworkbook/

Sheet : Releases to Air AER Returns Workbook 21/4/2011 17:42

4.1 RELEASES TO AIR Link to previous years emissions data | PRTR# : P0116 | Facility Name : Print & Display Ltd. | Filename : P0116_2010.xls | Return Year : 2010 | 20/09/2011 11:06

8 8 16 16 24 24 6 6 6 6 6 7 16

SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS

Please enter all quantities in this section in KGs

QUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year

0.0 0.0 0.0 0.0

* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION B : REMAINING PRTR POLLUTANTS


QUANTITY


03 Carbon dioxide (CO2) E OTH

Estimate based on

emission factors 300480.0 300480.0 0.0 0.0


SECTION C : REMAINING POLLUTANT EMISSIONS (As required in your Licence)


QUANTITY

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 Emission Point 2 T (Total) KG/Year

A (Accidental)

KG/Year

F (Fugitive)

KG/Year

237 Volatile organic compounds (as TOC) M OTH

Stack sampling using

adsorbent tubes and direct

reading FID 1173.0 55.0 13474.0 0.0 12246.0


Additional Data Requested from Landfill operators

Landfill: Print & Display Ltd.Please enter summary data on the

quantities of methane flared and / or

utilised

additional_pollutant_no T (Total) kg/Year M/C/E Method Code

Designation or

Description

Facility Total Capacity

m3 per hour

Total estimated methane generation (as per

site model) 0.0 N/A

Methane flared 0.0 0.0 (Total Flaring Capacity)

Methane utilised in engine/s 0.0 0.0 (Total Utilising Capacity)

Net methane emission (as reported in Section

A above) 0.0 N/A

METHOD

POLLUTANT METHOD

Method Used

For the purposes of the National Inventory on Greenhouse Gases, landfill operators are requested to provide summary data on landfill gas (Methane)

flared or utilised on their facilities to accompany the figures for total methane generated. Operators should only report their Net methane (CH4) emission

to the environment under T(total) KG/yr for Section A: Sector specific PRTR pollutants above. Please complete the table below:

Method Used

Method Used

POLLUTANT

RELEASES TO AIR

POLLUTANT METHOD

Method Used

RELEASES TO AIR

RELEASES TO AIR


Sheet : Releases to Wastewater or Sewer AER Returns Workbook 21/4/2011 17:42

4.3 RELEASES TO WASTEWATER OR SEWER Link to previous years emissions data | PRTR# : P0116 | Facility Name : Print & Display Ltd. | Filename : P0116_2010.xls | Return Year : 2010 | 20/09/2011 11:06

8 8 16 21 6 6 6 6 21

SECTION A : PRTR POLLUTANTS


QUANTITY


0.0 0.0 0.0 0.0


SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence)


QUANTITY

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year

303 BOD M OTH

Standards Methods for the

Examination of Water and

Wastewater (APHA,

AWWA & WEF 1995) 3008.0 3008.0 0.0 0.0

306 COD M OTH



Wastewater (APHA,

AWWA & WEF 1995) 8143.0 8143.0 0.0 0.0

240 Suspended Solids M OTH



Wastewater (APHA,

AWWA & WEF 1995) 188.0 188.0 0.0 0.0

343 Sulphate M OTH



Wastewater (APHA,

AWWA & WEF 1995) 136.0 136.0 0.0 0.0

308 Detergents (as MBAS) M OTH



Wastewater (APHA,

AWWA & WEF 1995) 18.0 18.0 0.0 0.0

354 Silver M OTH



Wastewater (APHA,

AWWA & WEF 1995) 0.17 0.17 0.0 0.0


OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER

OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER

Method Used

Method Used

POLLUTANT METHOD

POLLUTANT METHOD

Link to previous years emissions data Page 1 of 1

Sheet : Treatment Transfers of Waste AER Returns Workbook 21/4/2011 17:43

5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE | PRTR# : P0116 | Facility Name : Print & Display Ltd. | Filename : P0116_2010.xls | Return Year : 2010 | 20/09/2011 11:06

5 8 Please enter all quantities on this sheet in Tonnes 7

Quantity

(Tonnes per

Year)

Haz Waste : Name and

Licence/Permit No of Next

Destination Facility Non

Haz Waste: Name and

Licence/Permit No of

Recover/Disposer

Haz Waste : Address of Next

Destination Facility

Non Haz Waste: Address of

Recover/Disposer

Name and License / Permit No. and

Address of Final Recoverer /

Disposer (HAZARDOUS WASTE

ONLY)

Actual Address of Final Destination

i.e. Final Recovery / Disposal Site

(HAZARDOUS WASTE ONLY)

Transfer Destination

European Waste

Code Hazardous Quantity T/Year Description of Waste

Waste

Treatment

Operation M/C/E Method Used

Location of

Treatment Name and Licence / Permit No. of Recoverer / Disposer / Broker Address of Recoverer / Disposer / Broker Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY) Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)

Within the Country 08 03 99 No 109.64 wastes not otherwise specified D1 M Weighed Offsite in Ireland

Greenstar Limited,W0183-

01

Millenium

Park,Ballycoolin,Fingal,Co.

Dublin,Ireland

Within the Country 20 01 01 No 196.34 paper and cardboard R13 M Weighed Offsite in Ireland


01

Millenium


Dublin,Ireland

Within the Country 15 01 03 No 81.829 wooden packaging R13 M Weighed Offsite in Ireland


01

Millenium


Dublin,Ireland

To Other Countries 20 01 13 Yes 6.6 solvents D10 M Weighed Abroad

Guardian Silver

Lining,W0122-01

61 Cookstown Industrial

Estate,Belgard

Road,Tallaght,Dublin

24,Ireland

ATM,03 7623,Vlasweg

12,Afvalstoffen Terminal

Moerdijk BV,Moerdjik,4782

PW,Netherlands

Vlasweg 12,Afvalstoffen

Terminal Moerdijk

BV,Moerdjik,4782

PW,Netherlands

* Select a row by double-clicking the Description of Waste then click the delete button

Link to previous years waste data

Link to previous years waste summary data & percentage change

Method Used


print & display limited, aer 2008 · 2014. 12. 16. · industrial unit on the cookstown...

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