Print & Display Limited, AER 2008 · 2.1 Company Profile: Print & Display Limited operate a screen...

Print & Display Limited,

Cookstown Industrial Estate,

Tallaght,

Dublin 24.

IPC Licence Registration No: 116

Annual Environmental Report 2009

Contents

Page

1 INTRODUCTION

1

2 GENERAL OVERVIEW OF THE ACTIVITY 22.1 Company Profile 22.2 Location and Environmental Conditions 22.3 Printing Processes 32.4 Raw Materials and Principal Emissions 42.5 Overview of Recent Environmental Developments 5 3 DATA 73.1 Emissions to Atmosphere 73.2 Emissions to Sewer 93.3 Surface Water Runoff 113.4 Noise 123.5 Waste Management 133.6 Energy and Water Usage 143.7 Environmental Incidents and Complaints 153.8 Pollution Emission Register 16 4 ENVIRONMENTAL MANAGEMENT 184.1 Site Management 184.2 Environmental Management System 184.3 Human Resources, Training and Education 184.4 Environmental Objectives and Targets 194.5 Environmental Management Programme 19

LIST OF ATTACHMENTS

Attachment I Annual Waste Arising - 2009 Attachment II Print & Display Ltd. Organisation Chart Attachment III Environmental Objectives and Targets Review, July 2010 Attachment IV Implementation of Environmental Management Programme 2009/2010 Attachment V Proposed Environmental Management Programme 2010/2011

Page deliberately blank.

Annual Environmental Report 2009 ________________________________________________________________________________________________

_____________________________________________________________________________________________ Print & Display Ltd. Page 1 of 19

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 2009 to 31 December 2009. The format of this report is in general compliance with the EPA’s 2000 Guidance Note for AERs.



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 Cookstown plant and most of the plant 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.



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 and these lines 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.



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 are currently three licensed atmospheric emission points at the facility and one licensed effluent discharge point. Details of the overall emissions are provided in Section 3 of this report.



2.5 Overview of Recent 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. 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.



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. Details of the Print & Display atmospheric process emissions for 2009 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



A summary of the compliance history for 2009 is presented below. The data is based on the monitoring programmes which were undertaken on behalf of the company. Table 3.1.2 2009 Atmospheric Emissions – VOC Compliance History:

Emission Point 2009 % 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 2008. 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 2009 Atmospheric Process Emissions: Emission Point 2009 Mass Emission

(kg VOC per annum)

A1 578

A3 36

Total Emission 614

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. The estimated operational time for A3 was 3825 hours per annum.



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. During 2009 the overall volume of water used at the plant dropped to approximately 87% of the 2008 figure (4865 m3 as opposed to 5585 m3). 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 have been maintained at a steady rate of 9.57 m3 per day. This mean daily discharge was used to compute the annual discharge for 2009, based on 255 working days per annum in the screen wash area. Details of the process effluent emissions for the period 2007 to 2009 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 2007 to 2009:

Parameter 2007 Mass Emission

(kg per annum)

2008 Mass Emission

(kg per annum)

2009 Mass Emission

(kg per annum)

Licensed Mass Emission

(kg per annum) BOD 2,166 2,226 1,213 109,500 COD 6,537 7,717 2,897 219,000

Suspended Solids

362 1157 475 8,760

Sulphate 264 131 390 13,140 MBAS 187 137 57 2,190 Silver 0.02 0.02 < 0.154 10.95

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



During 2009 there were no reported non-compliances 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 2009:

Emission Point 2009 % Compliance

BOD 100

COD 100 Suspended Solids 100

Sulphate 100 MBAS 100

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 effluent treatment plant at Ringsend, Dublin 4.



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 (SE2) 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. During 2009 two grab samples of surface water were analysed for pH and COD per annum. A summary of the mean monitoring results for these surface water emissions are presented in Table 3.3.1 below. Table 3.3.1 2008 Mean Surface Water Monitoring Results:

Parameter Mean Concentration 2008

COD (mg/l) 231

pH (pH units) 7.0

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 to date at the plant. In addition, the visual monitoring programme has not necessitated any further assessment or monitoring. On occasions, during heavy rainfall run-off from the adjacent site was observed to enter the P& D yard. The adjacent site previously contained a large volume of un-bunded chemical drums and there was an obvious concern that some contamination could emanate from the site and enter the P&D surface water system. This issue was brought to the attention of the company that was operating on the site and the south Dublin County Council was also notified. It is understood that suitable remedial work has now been completed to prevent any surface water runoff emanating from the site. To date, it would seem that this remedial work has been successful, however, a watching brief is being maintained as the former occupants of the site have appeared to have ceased operations there.



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.



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 2009 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 2003 to 2009 is presented in Table 3.5.1 below. Table 3.5.1 Summary of Annual Waste Arising (2003 – 2009): 2004

(tonne) 2005

(tonne) 2006

(tonne) 2007

(tonne) 2008

(tonne) 2009

(tonne) Hazardous Waste 6.28 1.4 3.8 2.4 3.6 8.2

Non-Hazardous Waste 403.5 357.5 367.0 380.6 445.2 394.5

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.



3.6 Energy and Water Usage: Details of electricity consumption, boiler fuel consumption and water consumption for the years 2007 to 2009 are presented in Table 3.6.1 below: Table 3.6.1. Utilities Summary Report:

Utility 2007

Consumption

2008

Consumption

2009

Consumption

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

Space heating – natural gas

(kWh)

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

Water (m3) 6223 5585 4865

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 electricity consumption between 2008 and 2009 and a slight decrease in gas consumption (for space heating) over the same period. There has been a noticeable reduction in water consumption between 2007 and 2009.



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 were no such incidents during 2009. 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 2009.



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 - 2009:

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

There has been a marked and consistent 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 screen wash machines.



Details of the PER data for 2009 are presented below. Table 3.8.2 2009 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

21,704 15,642 M & C 0 C 6,062 M



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 2009. Budgetary constraints limited the formal training undertaken during 2009, however, however, Environmental Liability Risk Assessment (ELRA), Residuals Management Plans Closure Remediation and Aftercare Plans (CRAMP) and Financial Provision (FP) assessments were undertaken at the plant and this required some on-site training in May 2009. In addition, on-the-job training was facilitated during 2009 by the development of checklists of duties and tasks.



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 formed the basis of an extensive Environmental Management Programme at the facility. Considerable resources were devoted to environmental management during this time, and major progress was 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 2009/2010 Environmental Objectives and Targets are a natural extension of the original ones. A review of the Environmental Objectives and Targets was undertaken during July 2010 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 seven projects were proposed in the EMP for 2009/2010 and significant progress has been made with all projects being implemented. Some subsequent issues have arisen and additional projects have been identified and targeted to form part of the EMP for 2010 and 2011. These are addressed in the Environmental Management Programme (EMP) proposal which is presented in Attachment V.

__________________ _____________

Attachment I Annual Waste Arising -

2009 ___________ _______________

Table 3.5.2 Annual Waste Arisings - 2009

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 114.1 Landfill (D1) Balleally landfill site.

Veolia Environmental Services

Cardboard 20 01 01 No 210.2 Recycling (R13) Exported to miscellaneous paper mills


Waste timber packaging

15 01 03 No 70.0 Recycling (R13) Transferred to Panda waste for processing in Finsa facility Co. Clare.


Floor cleaning waste (aqueous liquid waste containing ink)

08 03 08 No 0.2 Physico-chemical treatment (D9)

Germany/Holland and England

Guardian Silver Lining

Waste solvents 20 01 13* yes 6.1 Incineration (D10) Germany/Holland and England

Guardian Silver Lining

Waste from interceptor tank

08 03 14* yes 2.1 Physico-chemical treatment (D9)

Enva Ireland Ltd Portlaoise, Co. Laois

Enva Ireland Ltd

_________________ _____________

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, July 2010

___________ __________________

Print & Display Ltd. 80, Cookstown Industrial Estate, Tallaght,

Co. Dublin


Environmental Objectives and Targets Review July 2010

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.

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 2009/2010.

Environmental Objectives and Targets – 2008/2009 Page 1 of 5

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 July 2010. 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 for 2008 and 2009. In addition, the licensee was obliged to review the enforcement category for the facility in consultation with the EPA using the approved guidance and published methodology. A review of all waste disposal contracts was also be undertaken during 2009 but new developments have arisen here due to the acquisition of Veolia Environmental Services by Greenstar Limited.


During 2009 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. During 2010 a review of the surface water monitoring procedure will be made. This will involve consultations with Agency personnel where necessary and a modified monitoring procedure will be implemented. This may also give rise to a need for on-the-job training.


3. PROPOSED OBJECTIVES AND TARGETS: A series of objectives and targets has been developed for 2010/2011. Some of these are a natural continuation of the earlier targets and they are set out in tabular form in Appendix I.


4. CONCLUSION: A summary of the proposed 2010/2011 objectives and targets is set out in tabular form in Appendix I. The licensee undertakes to review these objectives and targets for the 2010 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 off 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).

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 underway during 2009 and additional labelling and storage arrangements have

been put in place. It is intended that it shall be reviewed during the end and if necessary revisited

during 2010.

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. 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. The sampling and the reporting procedures will be reviewed and updated to ensure full compliance with the licence

requirements.

The project will be completed by the end of August 2010.

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.

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

OBJECTIVES

PRIMARY GOALS

PRIMARY DEADLINES

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. 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 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 Greenstar Limited. Where practicable further improvements will be

developed by December 2010. 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 will be prepared and any necessary updates will be made by the end of November 2010.


OBJECTIVES

PRIMARY GOALS

PRIMARY DEADLINES

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 will be completed by December 2010 and any new training requirements will be

implemented by February 2011, as required.

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 2010 and 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 was also developed to remind staff of their periodic environmental obligations. Internal audits will proceed on an annual basis as

part of the preparation work for the AER. The next audit will be completed by January 2011.


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 and the 2009 AER will be completed by August 2010.

3.14 A review of all waste disposal contracts will be made.

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 has commenced and will be completed by October 2010.

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 will be undertaken by the end of November 2010.

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 practice and procedures were not consistent. A new procedure will be put in place and implemented to ensure that the sampling and reporting procedures are in line with the

documented requirements.

The new procedure will be put in place and implemented by the end of August 2010.

__________________ _____________

Attachment IV

Implementation of Environmental Management Programme 2009/2010

___________ __________________

Print & Display Ltd.

80, Cookstown Industrial Estate, Tallaght, Co. Dublin


Implementation of Environmental Management Programme 2009/2010

Contents

Page

1. INTRODUCTION 1 2. IMPLEMENTATION OF EMP PROJECTS 2 3. CONCLUSION 9

Implementation of Environmental Management Programme 2009/2010 Page 1 of 9

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. Approximately 45 people are employed by the licensee and the printing plant has been in operation since 1988. Print & Display Ltd. operate a screen-printing business which manufactures printed material for use in advertising, for example, Point of Sale Displays, posters, etc. The licensee operates a Quality Management System which complies with the international standard ISO 9002/EN29002. In addition, an Environmental Management System (EMS) has been developed and implemented at the facility in line with EPA/ Integrated Pollution Control licence requirements. Condition 2.3.1 of the Company’s Integrated Pollution Control (IPC) Licence requires the 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.

Designation of Responsibility:

The Environmental Manager will assume responsibility for this project, however, external assistance may be provided by

Environmental Consultants. Current Status: This project has been fully implemented.

Summary Report: An internal audit was undertaken at the facility and this was closed off during June 2010. An internal checklist was

developed and this has been modified and updated to facilitate the audit process. 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

company's objectives and targets:


3.14.


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. The project will review all wastes handled by P & D. It will also facilitate a review of the provisions of Condition 7 of the licence.


A review of the disposal of all waste streams will be made in the light of the detailed provisions of Condition 7 of the licence.

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:


Environmental Consultants. Current Status: This project was successfully been implemented during 2009 but

recent developments have arisen at Veolia Environmental Services during its integration with Greenstar.

Summary Report: Consultations were held with all waste contactors during 2009. In addition, consultations were also held with the EPA regarding the approval of a new waste contractor (Enva Ireland ). In June

2010 notification was received of the acquisition of Veolia Environmental Services by Greenstar and some changes to the

waste recycling and final disposal outlets are evolving. Clarification of these changes has been sought and the necessary

notification will be made to the Agency.


Project Number 3:

The facility’s environmental documentation system will be

reviewed and upgraded during 2009. Relationship to the



3.7. Rationale for

undertaking project:

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.


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. During 2008 and 2009 the entire documentation system will be reviewed

and revised. Particular attention will be paid to those areas where staff have been given new roles and responsibilities and in

addition regard will be had to any relevant changes in the ISO 9001 documentation system and to issues arising from any EPA and internal audits. A new documentation ‘sign-off’ procedure

will be developed. Designation of Responsibility:

The Environmental Manager will assume responsibility for this project, however, external assistance may be provided by the

Environmental Management Committee. Current Status: This project was successfully been implemented during 2009.

Summary Report: All documentation was reviewed and updated during December

2009. Since then however, new developments have arisen and this has required an update of the Emergency Response

Procedure, Surface Monitoring Procedure and certain Waste Management documentation.


Project Number 4:

An environmental training programme will be developed for

key personnel at the plant. Relationship to the



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.


The project will achieve compliance with Condition 2.7 and it 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 4 personnel will be provided with training during 2009.

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. Designation of Responsibility:


Environmental Consultants. Current Status: This project was successfully been implemented.

Summary Report: During 2009 a review of the training requirements was made. In

May 2009 on the job training was provided on Environmental Liability Risk Assessment (ELRA), Residuals Management Plans

Closure Remediation and Aftercare Plans and Financial Provision assessments. Some on the job informal training was

also provided in preparation for an internal audit and an Emergency Response training workshop was undertaken in July

2010.


Project Number 5:

A programme will be implemented to closely monitor energy

usage with a view to introducing improved practices throughout the facility.


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. Target to be achieved

by project:

The target to be achieved is to have an up-to-date energy conservation programme fully operational and subject to an

internal management review by March 2009. 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 by the use of posters and notices throughout the facility.


The Environmental Manager will assume responsibility for this project, however, external assistance may be provided by energy

consultants. 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 electricity

consumption between 2008 and 2009 and a slight decrease in gas consumption (for space heating) 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.


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.

Target to be achieved

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 august 2009. 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. An electronic submission will be made to the Agency based upon

the 2008 AER data and consultations held with Agency personnel.


The Environmental Manager will assume overall responsibility for this project.

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 2009.


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





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:

The target to be achieved is to have a complete review of the relevant legislation/guidance and the Risk Assessment, Closure

Plan and Financial Provisions by December 2009. 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.


The Environmental Manager will assume overall responsibility for this project, with assistance being provided by his

Environmental Consultants, as required. Current Status: The project was successfully completed during 2009.

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 submitted to the Agency during May 2010.


5. CONCLUSION: A total of seven projects were set proposed for the 2009/2010 EMP. All of these have been successfully implemented. A draft EMP proposal will be submitted to the EPA for 2010/2011.

________________________________

Attachment V

Proposed Environmental Management Programme – 2010/2011

___________ __________________

Print & Display Ltd.

80, Cookstown Industrial Estate, Tallaght, Co. Dublin


Proposed Environmental Management Programme 2010/2011

Contents

Page

1. INTRODUCTION 1 2. GENERAL OVERVIEW OF THE ACTIVITY 2 3. SCOPE OF THE EMP 3 4. PROPOSED EMP PROJECTS 4 5. CONCLUSION 12

Proposed Environmental Management Programme 2009 - 2010 Page 1 of 12

1. INTRODUCTION: Print & Display Ltd. is 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. Condition 2.3.1 of the Company’s Integrated Pollution Control (IPC) Licence requires the licensee ‘...to establish and maintain an Environmental Management Programme, including a time schedule for achieving objectives and targets’. Many of the projects have a time frame of more than one year and this submission sets out the proposed Environmental Management Programme (EMP) for 2010 and 2011.


2. GENERAL OVERVIEW OF THE ACTIVITY: Approximately 45 people are employed by the licensee and the printing plant has been in operation since 1988. Print & Display Ltd. operate a screen-printing business which manufactures printed material for use in advertising, for example, Point of Sale Displays, posters, etc. The licensee operates a Quality Management System which complies with the international standard ISO 9002/EN29002. In addition, an Environmental Management System (EMS) has been developed and implemented at the facility in line with EPA/ Integrated Pollution Control licence requirements.


3. 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.


4. PROPOSED EMP PROJECTS: The following projects are proposed for 2010 and 2011. Project Number 1:

An Environmental Audit will be undertaken at the facility to

determine the level of compliance with the IPC licence.


and targets:


3.12.


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.


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.


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 2011.


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



3.14.


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. Target to be achieved

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. Designation of Responsibility:


Environmental Consultants. Project Schedule: The project commenced in July 2010 and will be completed by

October 2010.


Project Number 3:

The facility’s environmental documentation system will be

reviewed and upgraded during 2010. Relationship to the



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.


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. Designation of Responsibility:

The Environmental Manager will assume responsibility for this project, however, external assistance may be provided by the

Environmental Management Committee. Project Schedule: Elements of the documentation system need to be reviewed and

updated intermittently. A register of all standard operating procedures (SOPs) will be prepared and any necessary updates

will be made. The SOP register will be finalised by the end of November 2010.


Project Number 4:

An environmental training programme will be developed for

key personnel at the plant. Relationship to the



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.


The project will achieve compliance with Condition 2.7 and it 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. Designation of Responsibility:


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

of the training requirements and budget will be implemented by December 2010 with any necessary training organised and

implemented before the end of February 2011.


Project Number 5:

A programme will be implemented to closely monitor energy

usage with a view to introducing improved practices throughout the facility.


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. Target to be achieved

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 throughout the facility.


The Environmental Manager will assume responsibility for this project, however, external assistance may be provided by energy

consultants. Project Schedule: This project needs to be implemented on an ongoing basis. The

project commenced in 2006 and will be ongoing during 2010 and 2011.


Project Number 6:

A review of the enforcement category for the facility will be

made and a submission will be lodged with the EPA.


and targets:




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.


The Environmental Manager will assume overall responsibility for this project.

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





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:

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


The Environmental Manager will assume overall 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 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





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.


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.


The Environmental Manager will assume overall responsibility for this project, with assistance being provided by his

Environmental Consultant, as required. Project Schedule: The project will be completed by the end of August 2010.

5. CONCLUSION:

This submission sets out the EMP projects proposed for 2010 and 2011. A total of eight 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.


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