Plastic Omnium permit...Thermoplastic resin based products are stored in metal trolleys prior to the...

Permit P / 1 / 6.4 (A) (2) (a) 24th September 2007 Page 1

Pollution Prevention and Control Act 1999 Pollution Prevention and Control (England and Wales) Regulations 2000 (as amended) Solvent Emissions (England and Wales) Regulations 2004

Permit Permit number P / 1 / 6.4 (A) (2) (a) North West Leicestershire District Council (“the Regulator”) in exercise of its powers under Regulation 10 of the Pollution Prevention and Control (England and Wales Regulations (SI 2000 No 1973), hereby authorises Plastic Omnium Automotive Limited (“the Operator”). Of / whose Registered Office (or principal place of business) is: Plastic Omnium Automotive Limited Halesfield 7 Telford Shropshire TF7 4RQ Company registration number 03275572 to operate an installation at: Plastic Omnium Automotive Limited Westminster Industrial Estate Huntingdon Way Measham Swadlincote Derbyshire DE12 7DS To the extent authorised by and subject to the conditions of this Permit. Signed

Dated this day 24th September 2007

G. E. Crossley Environmental Services Manager

North West Leicestershire District Council, Council Offices, Coalville, Leicestershire, LE67 3FJ

Tel. 01530 – 454545 Fax. 01530 – 454506 The Address for all correspondence in relation to this Permit.

Status log Detail Date Comment Application Received 30th October 2003 Not Duly Made Date Duly Made 12th November 2003 Duly Made Schedule 4 Notice Served 18th February 2004 Request for further information Schedule 4 Notice Response 30th July 2004 Response for further information First draft issued 3rd February 2006 For consultation purposes Permit issued 24th September 2007



Detailed contents list Page

Description of the installation 3 1 Surface Preparation element 3

2 Paint Mixing activity 4

3 Coating Application activity 5

4 Zeolite Wheels 6

5 VOC abatement element 7

6 Water treatment element 8

7 Raw materials storage element 8

8 Waste storage element 9

9 Finishing element 9

List of Plant or equipment used within the installation 10

Plant concerned with preventing emissions to the environment 13

Process description flow chart 14

Glossary of Terms / Definitions 15

Permit Conditions 17 1 Authorised Plant 17

2 Emissions 17

Emissions Limits and Controls – Air 17

Atmospheric Dispersion of Contained Emissions 18

Emission limits and Controls – Surface Water and Sewer 19

Emission limits and Controls - Groundwater 21

3 Monitoring, sampling and measurement of emissions 22

Monitoring, sampling and measurement of emissions – Surface Water and Sewer

24

Monitoring, sampling and measurement of emissions – Groundwater

25

Air Quality 25

4 Process Controls 26

5 Noise Emissions 28

6 Waste Minimisation 30

7 Energy Efficiency 32

8 Prevention of Accidents 33

9 General Conditions 34

10 Decommissioning the Installation 35

11 Solvent Emissions Directive 36

Appendix 1 – Solvent Inventory Calculation 38

Appendix 2 – Part A2 Installation plan P/1/6.4(A)(2)(a) – 1 39

Appendix 3 – Emission Points – Paint Plan P/1/6.4(A)(2)(a) – 2 40

Appendix 4 – Foul and storm water drainage P/1/6.4(A)(2)(a) – 3 41

Explanatory Notes 42



Description of the Installation This installation is for the painting of plastic components produced mainly for automobiles that are required to match the metallic parts of the vehicle body. The following activities are carried out on site;

1. Surface Preparation element

2. Paint mixing activity.

3. Coating application activity.

4. Zeolite Wheels element.

5. VOC abatement element.

6. Water treatment element.

7. Raw materials storage element.

8. Waste storage element.

9. Finishing element

The following text divides the processes as described above into activities, both those scheduled under the above regulations and those non-scheduled elements required to be permitted because of their polluting potential and direct association and technical connection with the scheduled activities. 1 Surface Preparation element Thermoplastic resin based products are stored in metal trolleys prior to the painting process. If required, specific areas of the product are protected with masking tape. The product is taken to the surface preparation area and placed onto a jig fixture, which is installed on a conveyor system. Exposed areas of the product are manually cleaned, using a Tak-cloth. The product is then blown with ionised air. This negates any static charge in the product to stop the attraction to the product surface of airborne dust. The product undergoes a final inspection and clean using an ultra-violet lamp and Tak-cloth. All used Tak-cloths are stored in sealed containers. The component is then ‘flamed’ to ensure adhesion of the paint. This is achieved by bringing a gas-powered flame close to the surface to be painted. The surface molecular structure of the plastic is changed to allow better adhesion of the paint coating. The surface preparation element is a non scheduled element technically connected and directly associated with the coating activity and is included in the permit by virtue of potential for odour generation in accordance with the requirements of the Pollution Prevention and Control (England and Wales) Regulations 2000 (as amended).



2 Paint Mixing Activity The paints used in the coating process are specified by the customer and are required to match exactly the specification for the product. Plastic Omnium coat parts of motor vehicles that are delivered to the customer’s vehicle manufacturing line for assembly. It is therefore essential that the specification of the paint; its tint, tone and colour are exact. All paint is mixed within a designated area with the paint being diluted on site to the required specification. The mixed paint is then automatically pumped to the application area and the final mix of resin and hardener takes place there, as per the normal application of twin-pack paint. Paint is mixed using 25L containers and the mixing process is fully contained within the paint mixing room. Equipment Cleaning The spray guns are cleaned in the enclosed paint mixing room. This involves the use of an automatic peddle dispensing machine. The spray guns are manually cleaned in a stream of gunwash solvent. This is pumped from a drum of solvent held under the machine. The solvent then drains back into the drum and is re-circulated. When the gunwash in the drum becomes too contaminated with paint to be used further, the drum is sealed and a fresh solvent drum is put on the machine. The spent gunwash is returned to an authorised disposal agent for reclamation. Mixing of paint is an element within the coating process that is directly associated and technically connected with the activities scheduled in Section 6.4 (A) (2) of the Pollution Prevention and Control (England and Wales) Regulations 2000 (as amended) and as such it is regulated as a polluting activity.



3 Coating Application activity The plastic products are conveyed to the spray booths on the jig fixtures. Robots using electrostatic bell application apply paint mechanically. There is the option of manual application using high-volume low-pressure (HVLP) spraying equipment, in the event of plant failure. The coating application is carried out in four stages: Stage one of the spraying process is the primer application. This takes place in spray booth 1, (the primer booth). Prior to spraying, the primer is manually mixed with thinners and put in lidded pressure pots. It is then mixed automatically with hardener at the point of spray using robotic electrostatic bell application. Primer aids the adhesion of the basecoat. After spraying, the primer is allowed to flash off and dry. Stage two occurs in spray booths 3 & 4, (the base coat booths). Base coats are prepared and applied in a similar manner to primers. There are two base coats applied using robotic electrostatic bell application. Both sub-stages are allowed to flash off and dry. Stage three occurs in spray booths 5 & 6, (the clear coat booths). The clear coat is automatically mixed with hardener in a totally enclosed mixing unit immediately prior to being fed to the robot. There are two clear coats applied using robotic electrostatic bell application. Both sub-stages are allowed to flash off and dry. The final stage is drying. Air is heated and blown over the product to promote the evaporation of solvents from the paint, thus ensuring a high quality finish. The product is then allowed to cool. Spray booth operation There are six spray booths in total, with a flash off zone after each of the three paint applications. Mechanical spraying is conducted in five booths (spray booth 2 only used if manual spraying is required), with the option of manual spraying in all booths in the event of plant failure. All incoming air is passed through fabric panel air filters that are fitted into the booth ceilings; all outgoing (extracted) air passes through the water curtain of the wet back booths. This ensures that no dust enters the spray booths, and that no particulate exits the spray booths. All water from the wet back booths is subject to treatment prior to discharge to foul sewer (Refer to 6. Water Treatment element). Air flows over the product being sprayed on the conveyor line at a minimum speed of 0.5 m/s. In all spray booths, the air is extracted and recirculated through grills in the booth floor and then ducted directly to the Zeolite wheel.



4 Zeolite Wheels Solvent laden air is ducted from spray booths 1, 2, 3, 4, 5 and 6 and the flash off zones to the Zeolite wheels. Here, the solvent is adsorbed then desorbed and a portion of the resulting air stream passes out of Stack A. The remaining desorbed air feeds through the incinerator. Summary technical data (Zeolite Wheel x 2 - primer and basecoat) Manufacturer: Munters Zeol (MUNTERS CORPORATION) Model: Zeolite Rotor Model number: RS-D2900 Brief description: Zeolite Wheel Rotor Concentrator Flow rate: 80800 Nm3 / hr Temperature: 18°C Inlet pressure: 75 mm W.C. VOC: 1000 mg / Nm3 (xylene) Outlet concentration:



5 VOC abatement element The thermal incinerator is responsible for the combustion of emissions from spray booths 1, 2, 3, 4, 5 and 6 (the primer (1, 2), base coat (3, 4) and clear coat (5, 6) booths), the flash off zones and the oven. Solvent laden air from the oven is ducted directly to the incinerator and does not pass through the Zeolite wheels. The exhausted air provides heat for the oven whilst a proportion of it is discharged to atmosphere via a 16.6 metre high stack. Summary technical data Manufacturer; GEC Alsthom Air Industrie Systemes Model: Incinerator PB Reference number: PB219.7/8/43/G Brief description: Single combustion chamber. Single tubular

exchanger concentric to the chamber. Flow rate: 21790 kg/h Entry air temperature: 80°C Exit air temperature: 430°C Combustion temperature: 720 - 750°C Exchange power: 2178 kW Exchanger surface: 292 m2

50 mg / Nm3 of total carbon 100 mg / Nm3 of carbon monoxide

Maximum emissions:

100 mg / Nm3 of nitrogen oxides The VOC abatement element is a non scheduled element technically connected and directly associated with the coating activity and is included in the permit by virtue of potential for discharge of pollutants and odour generation in accordance with the requirements of the Pollution Prevention and Control (England and Wales) Regulations 2000 (as amended).



6 Water Treatment element Water from the wet back spray booths is automatically pumped to the water treatment plant. The water treatment plant is essentially a flocculation tank that removes suspended solids and some dissolved materials as part of the flocculation process. There is no deliberate discharge of List I or List II substances from the installation. By-products of the water purification system are precipitated as hydrated metal oxides, and the resultant sludge is collected by a licensed waste contractor and buried off-site in a licensed landfill. Some of these substances remain in the trade effluent discharged to sewer (due to their solubility product), but these are present in very low parts per million (ppm), or parts per billion (ppb) quantities, and are unlikely to discharge to groundwater due to the checks on system integrity. All water emissions are sampled for the requested substances. The volume and concentrations of discharged water are monitored. Water treatment is an element within the coating process that is directly associated and technically connected with the activities scheduled in Section 6.4 (A) (2) of the Pollution Prevention and Control (England and Wales) Regulations 2000 (as amended) and as such it is regulated as a polluting activity. 7 Raw Material Storage element Raw materials for the installation are stored in varying locations around the site, as marked on plan P/1/6.4(A)(2)(a) – 1 Part A2 Installation in Appendix 2. The major raw materials concerned with the installation are listed in Table 1 along with the activities or elements those materials are concerned within the installation. Raw material storage is an element within the coating process that is directly associated and technically connected with the activities scheduled in Section 6.4 (A) (2) of the Pollution Prevention and Control (England and Wales) Regulations 2000 (as amended) and as such it is regulated as a polluting activity. Materials Used Table 1 (below) lists the total quantities of raw materials (in tonnes – except where noted otherwise) brought into the installation and subjected to processing. The figures listed are for the year 2006.



Table 1 – Quantities of Raw Materials

Raw Material Usage (tonnes / annum) Activity Primer coat conductive primer 21.55 2,3 Primer / clearcoat hardener 53.82 2,3 Basecoat material 159.5 2,3 Clearcoat Resin material 118 2,3 Solvent thinners 76.8 2 Flushing solvent 183.6 2,3 Flocculation / biocide chemicals 43.46 6 Water m3 15069m3 6 Substrate 3598.57 1 Tak-Cloth - number 102,000 1 8 Waste storage element All waste materials associated with activities and elements noted above are stored in appropriate sealed drums or containers, skips or are contained and stored in the specified waste storage areas marked on plan P/1/6.4(A)(2)(a) – 1 Part A2 Installation in Appendix 2. All liquid wastes containing VOC’s are stored in the waste storage area marked on plan P/1/6.4(A)(2)(a) – 1 Part A2 Installation in Appendix 2, with a bunded area capable of containing 110% of the volume of the largest container present. Solid wastes from the installation are stored in dedicated covered containers and are stored within the dedicated waste storage area. Such materials are removed outside the installation buildings only when transported to the dedicated waste storage area awaiting transfer for final disposal by an approved waste carrier. Waste storage is an element within the coating activity that is directly associated and technically connected with the activities scheduled in Section 6.4 (A) (2) of the Pollution Prevention and Control (England and Wales) Regulations 2000 (as amended) and as such it is regulated as a polluting activity. 9. Finishing Element After cooling, the product is unloaded from the inspection area, any masking tape protecting the product removed and polished where appropriate. Any defects are first identified and sanded with a very fine grade of sandpaper. A small quantity of polish is then applied to the product before buffing with an air driven, hand held polishing tool. Finishing is an element within the coating activity that is directly associated and technically connected with the activities scheduled in Section 6.4 (A) (2) of the Pollution Prevention and Control (England and Wales) Regulations 2000 (as amended) and as such it is regulated as a polluting activity by virtue of the potential for waste generated.



List of plant or equipment used within the Installation The following Table 2 contains a list of all plant or equipment used within the installation along with the identified emission points to atmosphere. Emergency bypass exhausts are identified in brackets: Table 2 – List of plant equipment concerned with the installation Plant or Equipment used

Activity Machine reference numbers

Abatement Emission Points

DENCO DESICCANT AIR DRYER

2 AIR DRYER NONE N/A

AIR REPLACEMENT PLANT 1

1,2 ARP1 NONE N/A


1,3,4,5 ARP2 INCINERATOR B


1 ARP3

NONE N/A

EXHAUST RECIRC FAN PRIMER BOOTH

3,4,5 EX – PB INCINERATOR B

EXHAUST FAN MAIN BOOTH F11 (BYPASS)

3,4,5 EX – PB BCB INCINERATOR B (G)

EXHAUST RECIRC FAN BASECOAT BOOTH

3,4,5 EX - BCB INCINERATOR B

EXHAUST FAN 1 CLEARCOAT F10 BOOTH (BYPASS)

3,4,5 EX - CCB INCINERATOR B (F)

EXHAUST FAN 2 CLEARCOAT F12 (BYPASS)

3,4,5 EX - CCB INCINERATOR B

EXHAUST FAN UV ROOM

1 EX – UV ROOM NONE C

FLAMER EXHAUST FAN/UV BOOTH

1 FL - EXHAUST NONE C

HUMIDIFER ARP2 3,4,5 HUMIDIFER INCINERATOR B

EXHAUST FANS PAINT KITCHEN (MIX-ROOM)

2 PAINT KITCHEN FANS (MIX-ROOM)

NONE D

OVEN 3,5 OVEN INCINERATOR B

PRIMER BOOTH (2 BOOTHS)

3,4,5,6 PB INCINERATOR B (G)

Continued overleaf



Plant or Equipment used

Activity Machine reference numbers

Abatement Emission Points

BASECOAT BOOTH (2 BOOTHS)

3,4,5,6 BCB INCINERATOR B (G)

CLEARCOAT BOOTH (2 BOOTHS)

3,4,5,6 CCG INCINERATOR B (F)

AH/IPROS BURNERS (ARP 1&2)

2,3,4,5 BURNERS INCINERATOR B

OVEN RECIRC FANS 3,5 OVEN RECIRC

INCINERATOR B

PROCESS WATER RESERVOIRS

6 PWR NONE FUGITIVE

PAINT REMOVAL SCRAPER (3 OFF)

6 SCRAPER NONE N/A

SUBMERSIBLE BOOTH WATER SUPPLY PUMPS

6 SUB-PUMPS NONE N/A

VOC – EXHAUST FAN INCINERATOR EXHAUST F21 (BYPASS)

3,4,5 VOC - EX INCINERATOR B

VOC ABATEMENT PLANT

5 VOC - SYS INCINERATOR B

FLAMING ABB ROBOT CELL A ID1

1 FLA ID1 NONE C

FLAMING ABB ROBOT CELL B ID2

1 FLB ID2 NONE C

ABB ROBOT ID3 3,4,5,6 PRIMER ROBOT ID3

INCINERATOR B (G)

ABB ROBOT ID4 3,4,5,6 PRIMER ROBOT ID4

INCINERATOR B (G)

ABB ROBOT ID5 3,4,5,6 BASECOAT ROBOT ID5

INCINERATOR B (G)

ABB ROBOT ID6 3,4,5,6 BASECOAT ROBOT ID6

INCINERATOR B (G)

ABB ROBOT ID7 3,4,5,6 CLEARCOAT ROBOT ID7

INCINERATOR B (F)


INCINERATOR B (F)


INCINERATOR B (F)


INCINERATOR B (F)

ABB ROBOT ID33 3,4,5,6 NEW BASE ROBOT ID33

INCINERATOR B (G)

ABB ROBOT ID33 3,4,5,6 NEW BASE ROBOT ID34

INCINERATOR B (G)



PAINT PLANT CONVEYOR SYSTEM

1,3

CONV

NONE

N/A

SPOT-REPAIR BOOTH 2,3,9 SRB NONE D SPRAYER BREATHING EQUIPMENT

2,3 P/P B.A.P. NONE N/A

PROCESS/CONVEYOR CONTROL PANELS

3 PANELS NONE N/A

PAINT/SOLVENT STORES

7 STORES NONE FUGITIVE

SCADA SYSTEM 3 SCARDA SYSTEM

NONE N/A

SOLVENT DECANTING/WASTE SYSTEM

2,3 WASTE SOLVENTS

NONE FUGITIVE

WASTE COMPOUND 8 WASTE COMPOUND

NONE FUGITIVE



Plant concerned with preventing emissions to the environment Many of the emissions from the process plant identified in Table 2 above, are ducted to abatement equipment installed for the purpose of removing pollutants prior to release to the environment. Table 3 (below) identifies the emission points that are abated and discharge direct to the environment. Equipment and emission points that emit direct to the environment are classified as unabated emission sources. These external emission points are shown on Plan P/1/6.4(A)(2)(a) - 2 in Appendix 3. Table 3 – Abatement plant and Emissions to environment Plant or Equipment used

Abatement Type

Machine reference numbers

Emission Points

Pollutants

ZEOLITE WHEEL DISCHARGE STACK (PARTIALLY)

DISPERSION A VOC, NCO, TPM

INCINERATOR/OVEN DISCHARGE STACK

INCINERATION B VOC, CO, CO2, NCO, TPM, NOX, SOX, SMOKE

UV BOOTH/FLAMING ROBOT DISCHARGE STACK

DISPERSION C NONE

PAINT STORES/MIXING ROOM DISCHARGE STACK

DISPERSION D VOC, NCO, TPM

EMERGENCY BY-PASS EXHAUST – CLEARCOAT

DISPERSION (F) VOC, NCO, TPM

EMERGENCY BY-PASS EXHAUST – PRIMER & BASECOAT

DISPERSION (G) VOC, NCO, TPM

WATER TREATMENT PLANT

FLOCCULATION (H) pH, TSS, OIL, DIS, COD

Legend: TPM Total Particulate Matter VOC Volatile Organic Compound NCO Isocyanate CO Carbon Monoxide CO2 Carbon Dioxide Smoke see condition 2.3 pH Acidity TSS Total Suspended Solids SOx Sulphur Oxide Oil Physically separable/ dispersed/emulsified or soluble oils Dis Maximum rates of discharge COD Chemical Oxygen Demand Brackets indicate that the emission point is only used in the event of an emergency by-pass of the abatement plant.



Delivery and storage of raw materials (paint related products and

thinners).

Masking and surface cleaning of thermoplastic

moulding.

Primer application (mixed with hardener)

using robotic electrostatic bell

application.

Process Description Foreseeable emissions to air, land and water

Del

iver

y &

Sto

rage

Prep

arat

ion

Coa

ting

Fini

shin

g

Components ionised to

remove static charge

Component surface “flamed”by robot to make surface receptive

Vehicle movement &

manual handling of containers

Flash off

Paint mixing and spray gun cleaning

Basecoat application using robotic

electrostatic bell application

Flash off

Clearcoat application (mixed with hardener)

using robotic electrostatic bell

application.

Zeolite wheel

Incinerator

De-masking

Polishing

Paint, solvent and other treatment chemicals to ground, drains or air in the event of spillage.Fugitive/odourous emissions during storage.

Scrap work due to defects.Combustion gases (COx) from “flaming” robot. CO content may increase slightly during start up, when burner is “cold”.Waste wipes.

Fugitive/odourous and unabated emissions of VOC during paint mixing and gun cleaning.Point source emissions of VOC and particulate matter from zeolite wheel and incinerator –value increases slightly during start up & shutdown as burner efficiency reduces.Reject parts.Discharge of treated waste water to foul sewer.Waste sludge from water treatment process.Possible spillage of water treatment chemicals to surface water drain.Packaging waste.Combustion gases from oven and incinerator (NOx and COx).Waste gun washings (recycled).Unabated VOC emissions (bypass stacks – due to malfunction of abatement & paint mixing/stores areas during normal operation).

Reject parts.Fugitive particulate matter and VOC emissions.Packaging and other solid wastes from demasking.Waste filters from spot-repair process.

Drying oven

Flash off

Spot-Repair



Glossary of Terms / Definitions: Activity One or more stationary technical units falling within the defined

sections of the Schedule 1 of the Pollution Prevention and Control (England and Wales) Regulations 2000 (as amended).

Electrostatic Bell An application method where paint particles are moving parallel to

each other. An electrostatic charge aids particle adhesion. ELV Emission Limit Values, those values stipulated in the SED or in

guidance for emission of particular pollutants to atmosphere. EPA Environmental Protection Act, the former pollution control regime, now

redundant for this plant and site due to the implementation of PPC. Halogenated Shall mean an organic solvent which contains at least Organic solvent one atom of bromine, chlorine, fluorine or iodine. per molecule. Installation One or more activities within a defined area comprising the process. LEV Local Exhaust Ventilation, normally associated with small uncontained

plant or equipment. Organic solvent Means any VOC which is used alone or in combination with other

agents, and without undergoing a chemical change, to dissolve raw materials, products or waste materials, or is used as a cleaning agent to dissolve contaminants, or as a dissolver, or as a dispersion medium, or as a viscosity adjuster, or as a surface tension adjuster, or a plasticiser, or as a preservative.

Organic compound Means any compound containing the element carbon in combination

hydrogen, halogens, oxygen, sulphur, phosphorus, silicon or nitrogen, with the exception of carbon oxides and inorganic carbonates and bicarbonates.

PPC Pollution Prevention and Control, the new pollution control regime

replacing that under EPA. Regulator Means North West Leicestershire District Council Environmental

Services Section. When contacting the regulator it is not sufficient to contact any other part of the council other than the Environmental Services Section at the address specified in the additional notes or at the telephone numbers provided. Regulating Authority shall be construed accordingly, that being the authority for whom the regulator works.



R-Phrase Means the same as in Directive 67/548/EEC as follows: R Phrase Definition

R40 Limited evidence ofcarcinogenic effects

R45 May cause cancerR46 May cause heritable genetic

damageR49 May cause cancer by

inhalationR60 May impair fertilityR61 May cause harm to the

unborn

Designated risk phrase material means the designation or label given

to a coating or preparation (as a whole). The fact that a preparation or coating contains r-phase chemicals does not in itself always make a material r-phrase.

SED Solvent Emissions Directive or ‘COUNCIL DIRECTIVE 1999/13/EC of

11 March 1999 on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations’.

STU Stationary Technical Unit shall have the same meaning as in the

Pollution Prevention and Control Regulations, but in summary shall mean, one machine used for the purpose of printing on flexible packaging or one machine used in connection with that activity, e.g. an incinerator. There must be at least 1 STU per activity, but it is possible to have multiple STU’s still comprising only one activity.

Volatile Organic Shall mean any organic compound having at 293,15 K a Compound (VOC) vapour pressure of 0.01 kPa or more, or having a corresponding

volatility under the particular conditions of use.



Permit Conditions

1. Authorised Plant

1.1 The only plant and equipment authorised for use in this installation is that listed in Table 2. No other plant or equipment shall be utilised without the written consent of the regulator.

1.2 Plant or equipment concerned with the prevention of emissions to atmosphere shall

consist of that mentioned in Table 2 (above). No other abatement plant shall be used except where a formal application, in writing, has been submitted to, and approved by, the regulator.

1.3 No application of coatings shall take place outside of the spray booths designated in

Table 2 above without the written consent of the regulator.

2. Emission Limits and Controls - Air

2.1 There shall be no visible emissions, other than steam or water vapour from the

installation. 2.2 Emissions from the installation, other than steam or condensed water vapour, shall

be free from persistent mist and free from persistent fume. 2.3 Emissions from combustion processes, (specifically plant with emission reference

points denoted by the word ‘smoke’ in Table 3 above) shall not exceed the equivalent of Ringleman shade 1 as described in British Standard B.S.2742:1969 at any time.

2.4 Emissions from final point of discharge to atmosphere serving the emission points

listed in Table 3 shall not exceed the following concentrations of the substances and chemicals listed:

Table 4 – Permitted Concentrations in Emissions to Air Pollutant Emission Limit Total Particulate Matter (TPM) 50 mg / m-3Volatile Organic Compounds (VOC) 50 mg / m-3Carbon Monoxide (CO) 100 mg / m-3Oxides of Nitrogen (NOx) 100 mg / m-3Oxides of Sulphur (SOx) 0.2% wt/wt sulphur in fuel (before 1/01/2008)

0.1% wt/wt sulphur in fuel (from 1/01/2008) Isocyanates (NCO) 0.1 mg / m-3

It shall be a requirement for emission points listed in Table 3 to meet the particular pollutant emission concentrations listed for that emission point only. Not all emitted substances or chemicals apply to all emission points.



2.5 The concentrations of the substances listed in condition (2.4) shall be expressed at

reference conditions, 273K, 101.3kPa, without correction for water vapour content and the results of the monitoring shall be expressed in milligrams per cubic metre (mg / m-3).

2.6 There shall be no offensive odour emitted from the installation detected beyond the

site boundary as perceived by an officer of the regulating authority. 2.7 No piece of plant or equipment mentioned in condition 1.1 above (or any replacement

used for the same purpose), shall be operated with an extraction point direct to atmosphere unless specifically noted within this document or specifically agreed in writing with the regulator.

2.8 The introduction of dilution air to emission stacks shall not be permitted.

In the event that emissions from a stack can be demonstrated to be compliant with condition 2.4 above, air may be added to render harmless a visible or odorous emission. The introduction of dilution air shall only be permitted where stated within this permit.

2.9 All emissions from the installation shall be ducted to suitable abatement plant

capable of meeting the same standard as is indicated in condition 2.4 or shall be accounted for in Table 2 and be noted to specifically comply with those emission limits without abatement plant.

2.10 Any bypass of the abatement plant shall be deemed an emergency and steps shall

be taken to contain the unabated emissions. If the unabated emissions cannot be contained, steps shall be taken to stop the process and the regulator shall be notified immediately.

Atmospheric Dispersion of Contained Emissions

2.11 The final efflux velocity of all emissions from the final point of discharge to

atmosphere serving the emission points listed in Table 3 shall not be less than 15 ms-1.

2.12 Chimneys and vents listed in Table 3 from which it is necessary to achieve dispersion

of the residual pollutants shall discharge vertically upwards and shall not be fitted with any restrictive plates, caps or cowls at the final opening.

2.13 Within a period not to exceed 15 months from the date of issue of this permit and to

be agreed in writing with the regulator, emission points listed in Table 3, shall be altered to new heights calculated in accordance with the procedural document D1 entitled, "The Determination of Discharge Stack Heights for Polluting Emissions", published by HMIP or another standard to be agreed with the regulator. The height, as calculated, shall be agreed with the regulator prior to works being carried out.

Notwithstanding the above, emissions consisting solely of particulate matter shall not

require a calculation to be carried out, and, in accordance with the requirements of D1, the effective discharge height is reduced to ground level.



This condition shall remain suspended for all emission points other than the

following:

Table 5 – Determination of Discharge Stack Heights

Exhaust Emission Point

Extend Height Efflux Cone

Zeolite Wheel discharge By 3 metres No

Oven/Incinerator discharge By 2.4 metres Yes – reducing from 0.9 metres to 0.65 metres Paint Stores/Mixing Room

discharge No Yes – reducing from 1 metres to 0.65 metres

The other emission points shall only be required to be dealt with as necessary to achieve compliance with this condition where requested in writing by the regulator.

2.14 Any final points of discharge to atmosphere shall be maintained at the minimum

height as calculated in condition 2.13 for the lifetime of the plant. Where guidance, plant or equipment, or the nature of emissions changes; the calculations required in conditions 2.13 shall be repeated and the heights modified accordingly.

Emission Limits and Controls – Surface Water and Sewer

2.15 The discharge from the effluent treatment plant shall comprise solely of water from

the paint plant pit. The effluent shall not contain any of the substances of properties listed in Table 6 below in amounts or proportions other than those that comply with the limits stated, and shall not contain any substances or properties not listed except with the prior written consent of the regulator:

Table 6 – Discharge consent criteria Pollutant Limit pH (pH) To fall within the range 6 – 10 Total Suspended Solids (TSS) 1500 mg l-1Cooling Waters None to be detected Temperature (oC) Not to exceed 43 oC Physically separable, dispersed, emulsified or soluble oils (Oil)

None to be detected

Maximum rates of discharge (Dis) No more than 2.5 litres per second No more than 10 m3 per 24 hrs

Chemical Oxygen Demand (COD) No more that 2000 mg l-1 (expressed as O)

Records of weekly volume discharge kept available for inspection at all times.

Compliance sampling shall be undertaken at least once per quarter and a summary of the results made available to the regulator within 4 weeks of completion of the sampling.



2.16 The discharge into the effluent treatment plant shall be sampled for the presence and concentration of the following chemicals:

• Xylene • N-butyl-acetate • Acetone • Total organic carbon The sampling shall take place at the same frequency as that required by condition 2.15 above and the results shall be used to help compile the data for condition 11.3.

2.17 Run-off from identified raw material storage areas shall be channelled/transported to

a suitable effluent treatment plant, e.g. an interceptor, where necessary to prevent or minimize discharge of pollutants to surface waters and sewers. Areas to which this condition applies shall be specified in writing by the regulator.

2.18 All effluent treatment plant, e.g. interceptors, for the site shall be:

• impermeable; • visually inspected monthly and; • have an annual maintenance inspection.

Prior to this inspection all contents shall be removed. 2.19 No process effluent shall be channelled or transported from the site unless first

directed to a suitable effluent treatment plant or otherwise agreed in writing by the regulator.

This condition shall not apply where road-going tankers collecting effluent from storage tanks and transporting the effluent to a suitably licensed point of final disposal.

2.20 Delivery connections to bulk liquid storage tanks shall be located within the bunded

area noted in condition 2.24, and shall be locked when not in use. 2.21 The flocculent storage tank shall be fitted with high-level alarms or volume indicators

to warn of over-filling. Where practicable, the filling systems shall be interlocked to the alarm system to prevent overfilling.

2.22 The operator shall supply a plan of the site indicating the location of the fixed storage

tanks, their contents, and maximum capacity together with the location of any associated fixed above or below ground pipework.

The plan shall be submitted by 1st February 2008 and updated (and resubmitted) as may be necessary where changes occur or new plant is installed.

2.23 Each storage tank shall be clearly labelled with:

• A reference number consistent with the above plan • The tank maximum volume • The tank contents • Any relevant hazard warnings



2.24 Every storage tank shall be surrounded by a bunded area impervious to the material

being stored in the tank. The bunded area shall be capable of storing 110% of the capacity of the largest tank within the bund.

The integrity of storage tanks and bunds shall be inspected, recorded and documented, particularly where corrosive substances are involved. Such inspections shall take place at least every three months or as indicated on the operator’s maintenance schedule prepared for condition 9.1 below.

These inspections should be included in the maintenance schedule required by condition 9.1 and copies stored with the logbook required to be kept in accordance with condition 9.5.

2.25 There shall be no effluent emissions to sewer or surface water drainage without the

prior consent of the regulator and the prior consent of Severn Trent or Environment Agency as may be necessary. The operator shall make a written application to the regulator as soon as is practicable and in no case with less than 72 hours notice prior to any intention to discharge waste effluent to sewer or surface water drainage.

Emission Limits and Controls – Groundwater

2.26 The effluent transport system (including any subsurface plant, equipment, tanks,

drains, sewers, sumps, or storage vessels) shall be inspected and surveyed at least once every five years for the following:

• Establish a record of all subsurface drains, sewers, plant, equipment, sumps

or storage vessels to include the routing of all pipework.

• Produce an inspection and maintenance record for all subsurface drains, sewers, plant, equipment, sumps of storage vessels, which involves as necessary, pressure or leak tests, materials thickness checks or camera surveys.

Where an inspection determines that subsurface infrastructure is leaking,

arrangements shall be made to repair, isolate or otherwise contain the leak in accordance with a defined action plan, and the regulator shall be notified immediately.

2.27 There shall be no defects in the concrete hard standing within the area of the

installation as designated on Plan P/1/6.4(A)(2)(a) – 1 Part A2 Installation in Appendix 2. Moreover, as far as is practicable, joints between concrete pads shall be effectively sealed so as to provide an impervious surface.

Where a defect is noted in accordance with the requirements of condition 3.14, action

shall be taken to rectify the defect within 6 weeks of identification. For the purpose of this condition, a ‘defect’ is any break in the concrete hard standing that will allow liquid spillages to drain away into the sub-soil. For the purpose of this condition ‘rectified’ shall mean repair of the defect such that liquid spillages can no longer enter the sub-soil.



3. Monitoring, sampling and measurement of emissions

3.1 The process shall be observed, from a position providing an unimpeded view of the

emissions points for the prescribed process, for visible emissions at least once per day, or more often as may be prescribed in writing by the enforcing authority. In the event of visible emissions being observed, immediate action shall be taken to determine the cause of the emission, and action shall be taken to abate the emission.

If excessive visible emissions are noted, immediate action shall be taken to determine the cause of the emission and to resolve the malfunction responsible for the emission.

Contingency arrangements shall be instigated to prevent or reduce to a minimum any further visible emissions caused by the malfunction. The regulator shall be notified of any such occurrence as soon as practicable.

The results of the observations shall be recorded in the logbook required to be kept by condition 9.5, along with details of remedial action taken.

3.2 A daily assessment shall be made for odour emissions from the prescribed process

while the process is operating. The assessment shall be made at a point on the process boundary where such an emission is most likely to be detected, taking into account the wind direction, source of odour, nearest neighbour, etc. The assessment must be made by a responsible person who has been instructed to carry out these duties. A record of all olfactory assessments shall be entered into the logbook required to be kept in accordance with condition 9.5. The records shall include a subjective assessment of the nature and severity of any odour detected.

If odour emissions are detected, immediate action shall be taken to determine the cause of the emission and to resolve the malfunction responsible for the emission. Contingency arrangements shall be instigated to prevent or reduce to a minimum any further odour emissions caused by the malfunction. The regulating authority shall be notified of any such occurrence as soon as practicable.

3.3 Emissions from the final point of discharge to atmosphere serving the emission

points listed in Table 3 shall be sampled for concentrations of the substances listed within that table on an annual basis. The only exceptions to this being the UV Booth/Flaming Robot discharge stack (location C), the two emergency by-pass discharge stacks (locations F and G) and the water treatment plant (location H). Where an emission limit (prescribed by condition 2.4) for a particular pollutant is listed for an emission point, there shall be a requirement to sample and provide emission monitoring results for that pollutant.

All sampling shall be carried out in accordance with recognised standards as agreed

with the regulator prior to monitoring taking place. In all cases this shall be to the MCERTS, or equivalent, standards for both procedures and personnel. The proposed test methods for measuring compliance with emission concentration limits shall be forwarded to the regulator at least 21 days prior to commencement of sampling, and testing shall not be commenced until the regulator approves the proposed test method in writing.



The regulating authority must be advised at least 7 days in advance of any periodic monitoring exercise giving the date, time and place of sampling and the pollutants to be tested.

Results shall be expressed in accordance with the requirements of condition 2.4 and

the results of monitoring to be supplied to the regulating authority within 56 days of completion of the monitoring. Monitoring reports shall be submitted in both paper copy and electronic format.

3.4 The incinerator shall be continuously monitored for temperature and shall operate

within a temperature range to be agreed in writing with the regulator. The incinerator is to be fitted with an audible and visual alarm to be triggered in the event that the device ceases to operate within the agreed temperature range.

Any sounding of an alarm is to be recorded in the logbook required to be kept in

accordance with condition 9.5. 3.5 Within two-years of the issue of this permit, the emissions from the stack serving the

incinerator shall be continuously monitored for Carbon Monoxide emissions, and shall be continuously recorded with an averaging period of 15 minutes. The continuous monitoring equipment shall be connected to a visual and audible alarm that should be set to trigger at a reference level to be agreed in writing with the regulator within 3 months of installation.

Emission events that lead to the triggering of an alarm shall be recorded in the

logbook required to be kept in accordance with condition 9.5 along with details of the investigation into what caused the event.

3.6 The emissions from the stack serving the incinerator shall be continuously monitored

for Volatile Organic Compounds (VOC), and shall be continuously recorded with an averaging period of 15 minutes. The continuous monitoring equipment shall be connected to a visual and audible alarm that should be set to trigger at a reference level to be agreed in writing with the regulator within 3 months of installation.

Emission events that lead to the triggering of an alarm shall be recorded in the

logbook required to be kept in accordance with condition 9.5 along with details of the investigation into what caused the event.

Continuous monitoring of VOC shall not be required where conditions 3.4 and 3.5 are

complied with, and where the sampling and results for routine monitoring required by condition 3.3 are submitted annually.

3.7 All continuous monitors shall be calibrated every 12 months (or more frequently if

necessary) in accordance with manufacturers’ instructions. 3.8 All continuous monitors noted in conditions 3.4 to 3.6 shall be replaced with a

suitable MCERTS accredited device by 1st April 2009, or sooner where the existing device is found to be defective.



3.9 No result from continuous monitoring equipment referred to in conditions 3.5 and 3.6

shall exceed the emission concentration limits specified in condition 2.4, except where: • data is obtained over at least 5 sampling hours in increments of 15 minutes or

less; or

• at least 20 results are obtained where sampling time increments of more than 15 minutes are involved;

and in such circumstances:

• no more than 5% of all 15-minute mean emission concentrations should exceed the specified emission concentration limits (during normal operating hours (excluding start-up and shut-down);

• no 15-minute mean emission concentration should exceed twice the emission

concentration limits specified in condition 2.4; and where continuous monitoring is undertaken, compliance with this condition shall be demonstrated on a daily basis.

3.10 A summary of the continuous monitoring results shall be supplied to the regulating

authority every 6 months. Such a summary shall be in some from of electronic format and shall clearly highlight any results that breach the limits stipulated in condition 2.4 or any part of this condition.

Monitoring, Sampling and Measurement of Emissions – Surface Water and Sewer

3.11 The Environment Agency have not requested any specific surface water monitoring

as a result of Regulation 13 of the Regulations. 3.12 Effluents from the final point of discharge to sewer listed in Table 3 shall be sampled

for concentrations of the substances listed within that table on a quarterly basis. Where an emission limit (prescribed by conditions 2.15) for a particular pollutant is listed for an emission point, there shall be a requirement to sample and provide emission monitoring results for that pollutant in accordance with the standard as stated within Table 6.

Effluents discharged shall be sampled according to a standard as agreed in writing

with the regulator prior to sampling taking place. All results to be submitted within 4 weeks of completion of the sampling.



Monitoring, Sampling and Measurement of Emissions – Ground Water

3.13 The Environment Agency have not requested any specific ground water monitoring

as a result of Regulation 13 of the Regulations. 3.14 The concrete hard-standing covering the installation designated in plan

P/1/6.4(A)(2)(a) - 1 shall be inspected on an annual basis. Defects in the concrete hard standing shall be identified and results shall be included in the log book required to be kept by condition 9.5. ‘Defects’ shall have the meaning prescribed in condition 2.27. Particular attention shall be given to areas surrounding storage tanks, within bunded areas, waste storage areas, and raw material storage areas. All defects shall be dealt with as required by condition 2.24 (above) within 6 weeks of the inspection.

3.15 The storage areas for waste and for raw materials identified in accordance with

condition 4.3 hereinafter referred to as storage areas, shall be assessed for the following:

• maximum storage capacity • maximum storage period • suitability to store the specified material

The storage areas shall be inspected once per month to check that capacity, period

of storage or the materials stored conform to those specified for that particular repository. The results of the monthly inspection shall be included in the log book required to be kept by condition 9.5.

Air Quality

3.16 The operator shall prepare a list of all emission points, and related pollutant emissions to atmosphere based on Table 3 (above). The operator shall provide details of the emissions of those pollutants to atmosphere as a result of any sampling that may be carried out (see conditions 3.3 and 3.4) or data gathered (see condition 2.10).

Where sampling is carried out, no correction for atmospheric pressure or water

vapour shall be made. The operator shall also submit for each point of emission to atmosphere details of

stack height, volume flow rate and stack diameter, as well as the height, width and length of the building to which the stack (or stacks) are attached.

The results shall be tabulated and submitted in Microsoft Excel format and shall be

sent to the following email address (or another to be specified by the regulator): [email protected]



4. Process Controls

4.1 The raw materials used in the prescribed process and all waste materials produced from the prescribed process shall be handled with care to prevent or reduce to an absolute minimum any emissions to air.

4.2 Spillages of liquids and finely divided materials shall be cleaned up immediately.

Liquid spillages shall be contained and cleaned up by the use of a suitable absorbent material. Spillages of finely divided or powdery materials shall be removed by means of vacuum cleaning using an industrial grade vacuum cleaner or by wet cleaning methods, dry sweeping methods shall not be permitted. Sweeping and vehicular movement of powdery materials using uncovered containers is prohibited unless the material is thoroughly damped to prevent wind entrainment.

4.3 All raw materials delivered to the installation, and waste materials generated by the

installation, shall be placed in areas of site designated for storage. These storage and waste areas are specifically designated in plan P/1/6.4(A)(2)(a) - 1 in Appendix 2.

No raw material or waste shall be stored anywhere other than in the areas so designated.

All designated areas shall be capable of containing the raw material or waste contained therein, and prevent overflow into surrounding areas. Where damage accrues to containment for these areas, this damage shall be repaired as soon as is practicable and in any case no longer than 6 weeks from the date of detection of the damage after the inspection (see below).

The operator shall inspect the designated areas on a monthly basis to ensure that materials or wastes are adequately contained. The results of the inspections along with any repair work (where necessary) shall be recorded in the log book required to be kept by condition 9.5.

4.4 Any accumulation of waste or raw materials found outside the areas designated by

condition 4.3 above shall be considered a spillage and shall be dealt with in accordance with the requirements of condition 4.2 above.

4.5 Drums and containers containing liquid VOC materials, whether full, partly full or

empty, shall be stored in a bunded, secure, well-ventilated storage area away from other products. All drums and containers whether full, partly full or empty, shall be kept tightly closed to prevent any fugitive emissions to air.

4.6 Application of cleaning solvents should either be:

• From a contained device or automatic system when applied directly on to machine rollers, or

• Dispensed by piston type dispenser or similar contained device, when used on

wipes. The use of pre-impregnated wipes will be held within an closed container prior to use.



4.7 Solvent Wipes and other items contaminated with solvent shall be placed in a

suitably labelled metal bin fitted with a self-closing lid. Bins shall be emptied at least daily. Special bins that allow air to circulate beneath and around them to aid cooling should be used for materials that may undergo spontaneous combustion only after prior agreement with the enforcing authority.

All bins shall be emptied at least on a daily basis and the contents shall be placed in

a sealed drum and dealt with in accordance with condition 4.5. 4.8 Cleaning solvents shall be contained in self-closing containers. Organic solvent free

cleaning fluids or significantly less volatile organic solvent cleaning fluids shall be used (with or without the addition of mechanical, chemical or thermal enhancements) in preference to traditional solvent based cleaners.

4.9 Solvent Storage Containers (including paint) whether empty or full shall only be

stored in a bunded area. The bunding shall be impervious to the materials in use and be capable of storing 110% of the capacity of the largest container within the bund.

4.10 The coupling of solvent storage containers (including paint) to transfer pipework or

mixing systems shall only be undertaken by nominated persons trained to do so, and shall only be carried out in a bunded area.

4.11 The pipework associated with transfer of solvent, paint or other volatile materials

shall be checked for integrity and shall be fitted with an isolation valve on both sides of the coupling to minimise losses from either the IBC or the pipework. The connections shall be kept securely locked at all times when a connection is not being made and shall be under the direct control of the named personnel only.

4.12 The waste storage area shall be bunded and impervious to the liquid material being

stored in the area. The bunded area shall be capable of storing 110% of the capacity of the largest tank/container within the bund.

4.13 The integrity of storage tanks and bunds shall be inspected and documented on a

monthly basis, particularly where corrosive substances are involved. These inspections should be included in the maintenance schedule required by

condition 9.1 and copies stored with the logbook required to be kept in accordance with condition 9.5.



5. Noise Emissions

5.1 The operator shall:

• Carry out a survey of the installation and identify any plant or equipment likely to give to noise. The survey shall specifically identify plant or equipment capable of being discerned at the installation boundary.

• Annually review the noise survey of the installation such that any changes to the

plant or equipment noted in Table 2 (above) are identified and the survey updated appropriately.

• Construct a noise management plan based on the survey which shall include the

following:

1) A statement of policy with regard to dealing with noise 2) A documented complaint procedure for the investigation, analysis,

determination, and solution to noise problems

3) Details of routine maintenance undertaken in particular to deal with noise issues

• Construct a register of complaints regarding noise emissions from the installation.

The operator shall provide the above information by 1st April 2008 and thereafter shall update the information as noted above or at the formal written request of the regulator. All documentation required to be produced by this condition, shall be retained in the log book required to be kept in accordance with condition 9.5.

5.2 It shall be an absolute requirement that any new plant or equipment brought into the

installation, or any plant or equipment that undergoes modification, shall be demonstrated to comply with the requirements of BAT.

The operator shall demonstrate that sound power levels for substantially changed

plant or equipment shall be lower or comparable to that for existing. For new plant or equipment the emitted noise levels shall be demonstrated to be as low as possible when compared to other manufacturers’ plant or equipment of the same type.



5.3 No new plant or equipment shall be permitted within the installation except where: (i) The plant or equipment can be demonstrated to have a minimal environmental

impact. For the purpose of this condition ‘minimal’ shall be taken to mean that, the plant or equipment, if monitored under requirements of BS 4142:1997, has a rating level of –10dB (when compared to the background level), or is otherwise inaudible.

OR

(ii) Where plant or equipment cannot be demonstrated to meet the standard above,

a full noise survey shall be carried out and the results modelled to show the specific impact of the new plant or equipment on the environment. The modelling exercise shall take account of any relevant noise abatement measures. The results of the modelling shall be submitted to the regulator and shall demonstrate BAT.

The modelled plant or equipment shall be permitted within the installation only

where written consent of the regulator has been obtained. 5.4 In the event of the regulator receiving a complaint of noise associated with any

element or activity within the installation boundary, the operator shall:

(i) Be required to investigate the source of the complaint. (ii) Carry out such monitoring, surveys or modelling of the source of the complaint to

demonstrate, to the satisfaction of the regulator, either:

(a) that the complaint is unfounded, or (b) the complaint has substance

Where (ii)(b) above is found to be the case, the operator shall arrange to carry out

such works or change procedures or processes in such a way, that a re-assessment carried out in (ii) above comes to the conclusion in (ii)(a).

All time scales in relation to any aspect of this condition are to be set by the regulator

in the event of a complaint being received. Typically, 5.4(i) shall take no longer than 48 hours from the date of notification, whilst 5.4(ii) may take considerably longer dependent on the work required to be undertaken.



6. Waste Minimisation

6.1 The operator shall:

• Maintain an inventory covering the principal types of raw materials used (as listed in Table 1). The inventory shall be submitted to the regulator annually.

• Review alternatives for the principal types of raw materials used with regard to

their environmental impact. Notably this shall include, solvents, paints, cleaning products and water use. Such reviews shall be submitted to the regulator every four years.

• Maintain records to demonstrate that quality and/or environmental control

procedures are used to minimise any potential adverse environmental impact of the use or storage of raw materials.

• Undertake to complete any long-term studies needed into the less polluting

options and make any material substitutions identified within the review period. Such studies will be identified as and when required by the regulator and requested in writing.

All information required by this condition shall be submitted to the regulator annually,

or where such information is requested every four years from the date of issue of the permit as may be required for long term studies. All such information shall be retained by the operator and kept with the log book as required to be kept in accordance with condition 9.5.

6.2 The operator shall demonstrate that a systematic approach to the reduction of waste

at source is being used. The operator shall carry out a waste minimisation audit within 18 months of issue of

the permit and thereafter at the written request of the regulator. The methodology used and an action plan for optimising the use of raw materials shall be submitted to the regulator within 2 months of completion of the audit.

Specific improvements resulting from the recommendations of audits shall be carried

out within a timescale approved by the regulator.



6.3 The operator shall, within 4 weeks of submitting the information required by condition

6.1, also calculate the following indicators of waste minimisation performance expressed as a ratio:

(i) tonnes of VOC consumed v tonnes of good product (ii) tonnes of paint consumed v tonnes of good product (iii) tonnes of wastes produced v tonnes of good product (iv) volume of ‘clean’ water consumed v tonnes good product

All such information shall be retained by the operator and kept with the log book

required to be kept in accordance with condition 9.5. Where any of the above parameters are not specifically monitored, arrangements

shall be made to undertake monitoring of the use of the material within 8 weeks of issue of this permit.

6.4 The operator shall carry out a regular water efficiency audit. The operator shall

provide a baseline audit by 1st November 2009. The operator shall arrange to measure the monthly volume of mains water used in

the installation. All measurements should be recorded and the records held on site. 6.5 The operator shall:

• record the quantity, nature, origin and where relevant, the destination, frequency of collection, mode of transport and treatment method of any waste which is disposed of or recovered.

• ensure that waste storage areas are clearly marked and signed, and that

containers are clearly labelled.

• ensure that appropriate storage facilities are provided for substances that are flammable, sensitive to heat or light etc, and that incompatible waste types are kept separate.

• ensure that containers are stored with lids, caps and valves secured and in place

(this also applies to emptied containers).

• ensure that procedures are in place to deal with damaged or leaking containers.

• segregate waste wherever practicable.

• identify the disposal route for all waste, which shall be as close to the point of production as possible.

• ensure that dust from abatement plant shall be collected in robust bags that can

be disposed of directly, or in fully enclosed skips to avoid the release of fugitive dusts during transfer.

• store dusty wastes in closed containers and handle in a manner that avoids

emissions.



7. Energy Efficiency

7.1 The operator shall produce an annual report on the energy consumption of the

installation. The report shall monitor energy usage for the installation and identify target areas for reduction and shall be updated annually. ("Sankey" diagrams and energy balances would be useful as aids).

7.2 The operator shall ensure that all plant listed in Table 2 is operated and maintained

to optimise the use and minimise the loss of energy. 7.3 The operator shall within 4 weeks of submitting the information required by condition

7.1, also calculate the following indicators of energy efficiency performance expressed as a ratio:

(i) Gas consumed v good tonnes produced. (ii) Electricity v good tonnes produced.

All such information shall be retained by the operator and kept with the log book

required to be kept in accordance with condition 9.5. Where any of the above parameters are not specifically monitored, arrangements

shall be made to undertake monitoring of the use of the energy source within 8 weeks of issue of this permit.

7.4 In respect of energy efficiency, the operator shall meet the requirements of either:

(i) Climate Change Agreement (CCA), or (ii) Direct Participation Agreement (DPA); in addition to the requirements of conditions 7.1 to 7.3 (above).

Where neither (i) nor (ii) above are complied with the operator shall notify the

regulator immediately.



8. Prevention of Accidents

8.1 The operator shall produce an accident management plan that identifies the hazards,

assesses the risks and identifies the measures required to reduce the risk of potential events or failures that might lead to an environmental impact.

The plan shall identify:

• the actions to be taken to minimise these potential occurrences; and • the actions to deal with such occurrences so as to limit their consequences

In the case of abnormal emissions arising from an accident, such as a spillage for

example, the operator shall:

• investigate immediately and undertake remedial action as soon as practicable • promptly record the events and actions taken • ensure the regulator is made aware, as soon as practicable

In the event of an accident occurring, the operator shall follow the prescribed

instructions within the accident management plan. In an emergency situation it shall be sufficient to demonstrate that any divergence from the plan was necessary either:

• in the interests of health and safety • as a result of instructions from a suitably qualified member of the emergency

services (fire, ambulance, police) • as a result of instructions from a duly authorised officer of the Health and Safety

Executive • as a result of instructions from the regulator

The accident management plan shall be reviewed annually and be submitted to the

regulator upon written request. A copy of the accident management plan shall be kept with the logbook required to be kept by condition 9.5.



9. General Conditions

9.1 Effective operational and maintenance systems shall be employed on all aspects of

the installation where failure could impact on the environment. In particular there shall be:

• documented operational control procedures • a documented preventative maintenance schedule, covering all plant where

failure could lead to impact on the environment, including major 'non productive' items such as tanks, pipe-work, retaining walls, bunds, ducts and filters. This shall be reviewed and updated annually

• a documented cleaning schedule covering all aspects of good housekeeping • documented procedures for monitoring of emissions to include duration,

frequency, type and appropriate reference standard where applicable Operation and maintenance procedures shall be updated from time to time as may

be necessary to account for changes in working practice or plant and machinery, chemical or procedures used. If the procedures change, a copy of the new procedures shall be kept available for inspection and submitted to the regulating authority upon request.

In terms of emergency maintenance, spares and consumables, in particular, those

subject to continual wear shall be held on site or shall be available at short notice so that plant breakdowns can be rectified rapidly.

9.2 Relevant staff at all levels shall receive the necessary formal training and instruction

in their duties relating to control of the process and emissions to the environment. Such training shall include the following:

• awareness of the regulatory implications of the permit • awareness of all potential environmental impacts under normal and abnormal

circumstances • awareness of the procedures for dealing with a breach of the permit conditions • prevention of accidental emissions and action to be taken when accidental

emissions occur • awareness of all operating procedures

Records shall be kept which detail all relevant training provided to staff. The records

shall be made available for inspection by an authorised officer from the regulating authority. Records of training shall be retained for two years.

The operator shall appoint a suitably competent person to liase with the regulator and

members of the public in the event of complaint. The designated person shall be notified to the regulator within 14 days of issue of the permit and, where that person changes, within 14 days of any change. The requirement to have a competent person liasing with the regulator does not reduce the requirement to adequately train staff in terms of environmental awareness.



9.3 If there is any intention to change any aspect of the installation from the description

of the process at the beginning of this permit, or any other aspect which may affect the substances or concentration of substances being emitted to the environment, the regulator shall be notified of the proposed changes at least 4 weeks before the changes take place.

9.4 Any malfunction which results in emissions to the environment which are likely to

cause an adverse effect on the local community shall be reported to the regulator immediately, and a record shall be made of the incident within the logbook required by condition 9.5.

9.5 A logbook shall be established and maintained which records all information required

to be kept by conditions of this permit, this includes details of procedures, results of sampling, record of all visual and olfactory observations, maintenance records and any other information required to be recorded and kept by conditions of this permit.

The information shall be recorded in a form to be agreed with the regulator but can

include both electronic and hard copies, and shall be retained for at least two years. This information shall be made available for inspection by an authorised officer of the regulating authority on request. Where information is updated or modified, copies of the modified information shall replace those held within the logbook.

10. Decommissioning the Installation 10.1 A site decommissioning plan shall be submitted to the regulator within 4 months of

issue of this permit. The plan shall be prepared and updated as may be necessary due to changes in plant, equipment or materials used within the installation. In any event the plan shall be reviewed and resubmitted every 3 years from the date of the first submission.

The plan shall include:

• A complete methodology to be adopted in the decommissioning of the installation, to include:

1) Removal of key plant or machinery likely to be contaminated

2) Removal of contamination associated with the plant and machinery

3) Minimising any contamination from the installation buildings during demolition

4) Removal of contaminated subsurface infrastructure as may be necessary

• An assessment of the impact of decommissioning on the nearest sensitive

receptors.

• The preparation of a ground contamination report to include the testing of soil within the decommissioned installation to demonstrate contamination levels are no greater than those submitted in the operators application site reports.



11. Solvent Emissions Directive Requirements

11.1 The total emissions of VOCs, which are not destroyed by the use of abatement

equipment listed in Table 2, shall not exceed 20% of the solvent inputs, as determined from the Solvent Management Plan and calculated in accordance with condition 11.2 below. For the avoidance of doubt fugitive emissions of solvent include those discharged to sewer as well as emissions to air.

This condition shall not become enforceable until 1st November 2007 11.2 The operator shall construct an inventory of solvent use within the installation. The

inventory shall be carried out by recording: (i) The mass of solvent contained in inks, coatings, diluents and cleaners in the

initial stock (IS) at the start of the accounting period, plus (ii) The mass of solvent contained in inks, coatings, diluents and cleaners in the

purchased stock (PS) during the accounting period (iii) Minus the mass of solvent contained in inks, coatings, diluents and cleaners in

the final stock (FS) at the end of the accounting period Then Total Solvent Input (I1) = IS + PS – FS The inventory shall specifically and separately identify any VOCs carrying any of the

R-Phrases as prescribed within the Solvent Emissions (England & Wales) Regulations 2004.

Further, having calculated total solvent Input (I1), the operator shall then calculate

solvent consumption by subtracting from the Input figures any solvent that is sent out for recovery.

Hence: C (consumption) = I1 – O8 The inventory and consumption data shall be submitted to the regulating authority on

1st April and 1st September for the preceding 6 months solvent use, every year. (see Appendix 1).



11.3 Based on the data compiled for condition 11.2, and the descriptions in Appendix 1,

the operator shall calculate the percentage of fugitive emissions applicable to the installation.

To demonstrate compliance with fugitive emission values as required in condition

11.1 above, the operator shall determine the fugitive emissions (F) from the activity using the following:

F = I1 - O1 – O5 - O6 - O7 - O8 Or F=O2 + O3 + O4 + O9

Definitions of the outputs (“Os” are shown in Appendix 1. Each can be determined by direct measurement of the quantities or, an equivalent calculation can be made by other means, for instance by using the capture efficiency of the process.

The Fugitive Emission value as a percentage of the Solvent Input (I) is determined by

Fugitive Emission Value = 100 x F/I Where the Solvent Input (I)= I1+ I2

Fugitive emission values must be determined for the activity, and must be repeated when any equipment or process modification is carried out. (see Appendix 1).

There shall be no requirement to submit this information prior to 1st November 2007.

11.4 At no time shall the operator introduce any substance or preparation into the

installation that is labelled with the risk phrase of R45, R46, R49, R60 or R61, without the prior written consent of the regulator. Substances or preparations already in use shall be replaced with non-designated substances in accordance with a scheme to be submitted to the regulator within 3 months of issue of this permit.

11.5 The operator has currently selected the emission limit route for demonstrating

compliance with the requirements of the solvent emissions directive. Should the operator wish to change the compliance alternative to the reduction scheme route, an application in writing must be submitted to the regulator by 21st October 2007 along with an appropriate calculation demonstrating compliance with the required Target Emission.

11.6 Within six months of the issue of this permit, the operator shall submit to the regulator

information that demonstrates that when manual spraying is carried out the transfer paint efficiency is at least 65% when used on flat panels.

(For information prEN 13966-1 October 2000 is a draft European Standard for the

determination of the efficiency for liquid coating materials. Part 1 concerns flat panels and will be sufficient for evaluating transfer efficiency for this condition).



Appendix 1: Solvent Inventory Calculation



APPENDIX 2: Part A2 Installation plan



APPENDIX 3: Emissions Points – Paint Plan



APPENDIX 4: Foul and Storm water drainage system



Explanatory Notes

These notes do not form part of the Permit 1. You should note that section 12(10) of the Act provides that, relation to any aspect of

the process not regulated by specific conditions within the permit the best available techniques shall be used such that:

All the appropriate preventative measures are taken against pollution, in particular through application of the best available techniques; and,

No significant pollution is caused.

2. Section 3(1) of the Regulations defines “BAT” as follows:

a. ‘available techniques’ means those techniques which have been developed on a scale which allows implementation in the relevant industrial sector, under economically and technically viable conditions, taking into consideration cost and advantages, whether or not the techniques are used or produced inside the United Kingdom, as long as they are reasonably accessible to the operator;

b. ‘best’ means , in relation to techniques, the most effective way of achieving a

general high level of protection of the environment as a whole; c. ‘techniques’ includes both technology used and the way in which the

installation is designed, managed, operated and decommissioned. 3. The ready availability of essential spares and a written maintenance programme i

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