SR Technics - Environmental Protection Agency · Sean Lawlor Environment Manager Environmental...

SR Technics

IPPC Licence Application No: Subject:

Office of Licensing and Guidance Environmental Protection Agency PO Box 3000 Johnstown Castle Estate Co. Wexford

766

Re: Response to Request for Information

Date: 12.06.2006

SR Technics Ireland Limited Facilities Services Facilities Building MD I98

Ref: ENVLic0206.epa

Telephone: 00353-1 -81 2-691 8 Telefax: 00353-1 -81 2-6847 E-Mail: [email protected]

Dear Sir/Madam,

In response to your request for information regarding IPPC Licence Application No.766 (EPA Letter dated 09.05.2006) please find attached answers to questions posed and a revised non-technical summary. Also included are two CD’s in searchable PDF format.

I trust the above is to your satisfaction, but if you require further information, please contact

me.

Yours sincerely,

c-. U e G - - L. Sean Lawlor

Environment Manager

Environmental Protection Agency

SR Technics Ireland Limited Dublin Airport, Ireland

Tel: + 353 1 81 2 6000, Fax +353 1 886 8492 Directors: Dr. Hans Ulrich Beyeler, Chairman (Swiss), Paddy Finnegan, Frank Keoghan, Alex Kugler (Swiss), Tom

McDermott, Noel Murray, Declan OShea, Peter Quigley, Richard Steiblin (French) www.srtechnics.com

Registered in Ireland 268659

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mailto:[email protected]

http://www.srtechnics.com

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Non technical Summary_rev3.doc Page 2 – (1) of 60

IPPC Licence Application

- Revised Non Technical Summary

IPPC Register No. 766

Issue No 3 45078448

9th June 2006

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Revised Non technical Summary_rev3.doc

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Page 2 – (2) of 60

CONTENTS

Section Page No

1. INTRODUCTION............................................................................................... Page 2 (4)

2. FACILITY OPERATIONS ................................................................................. Page 2 (4)

3. RAW MATERIALS............................................................................................ Page 2 (6)

4. EMISSIONS TO ATMOSPHERE...................................................................... Page 2 (7)

4.1. Point Source Emissions .................................................................................... Page 2 (7) 4.2. Fugitive Emissions ............................................................................................ Page 2 (8) 4.3. Control & Abatement Technology ..................................................................... Page 2 (9) 4.4. Assessment of the Solvent Emissions Directive (1999/13/EC) ...................... Page 2 (10) 4.5. Assessment of Impact of Atmospheric Emissions .......................................... Page 2 (11)

5. EMISSIONS TO SURFACE WATER.............................................................. Page 2 (14)

6. EMISSIONS TO SEWER ................................................................................ Page 2 (14)

6.1. Sources of Emissions To Sewer ..................................................................... Page 2 (14) 6.2. Emissions of Cadmium to Sewer .................................................................... Page 2 (16) 6.3. Arrangements for Discharges to Sewer .......................................................... Page 2 (16) 6.4. Abatement of Emissions to Sewer .................................................................. Page 2 (16) 6.5. Assessment of Impact of Emissions to Sewer/Waters.................................... Page 2 (17)

7. EMISSIONS TO GROUND ............................................................................. Page 2 (17)

8. SITE CONDITION ........................................................................................... Page 2 (18)

8.1. ENVIRONMENTAL SETTING......................................................................... Page 2 (18) 8.2. Historical Incidents .......................................................................................... Page 2 (18) 8.3. Current Groundwater Monitoring..................................................................... Page 2 (19) 8.4. Trichloroethylene (TCE) And TCE Breakdown Product Monitoring................ Page 2 (19) 8.5. Ongoing Groundwater Monitoring For Chlorinated Solvents .............................Page 220)

9. NOISE EMISSIONS ........................................................................................ Page 2 (21)

10. WASTE MANAGEMENT ................................................................................ Page 2 (22)

11. SAMPLING AND MONITORING.................................................................... Page 2 (22)

12. ENERGY EFFICIENCY................................................................................... Page 2 (25)

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CONTENTS

Section Page No

13. CONTAINMENT OF ACCIDENTAL SPILLAGES.......................................... Page 2 (26)

14. EMERGENCY RESPONSE ............................................................................ Page 2 (27)

15. APPLICATION OF BEST AVAILABLE TECHNIQUES AT SR TECHNICS . Page 2 (28)

16. ENVIRONMENTAL MANAGEMENT.............................................................. Page 2 (31)

17. DECOMMISSIONING ..................................................................................... Page 2 (31)

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1. INTRODUCTION

SR Technics Ireland (SR Technics) is an aircraft and airport motive equipment

maintenance facility situated at Dublin Airport. A Site Map is presented in Section B.2

(drawing reference IPPCboundary).

Dublin Airport was first developed as an airfield in 1917. Prior to this development the

lands were used for agriculture purposes. In 1937 construction of a Civil Airport to service

Dublin commenced with the original terminal brought into service in 1941.

Hangar development commenced in 1941 with the construction of Hangar 1.

Development continued with the construction of Hangars 2, 4 and 5 through the fifties

and sixties. The Garage was constructed in 1972. Hangar 6 was constructed in 1990 and

Hangar 3 in 1992.

The Auxiliary Power Unit test cell was recently developed and upgraded to cater for

larger type units.

The site is bounded by the airport to the west, north and south and by the main N1

motorway to Belfast on the east.

1,274 people are employed at the SR Technics Dublin Airport site. The facility operates

Monday to Friday over two shifts: 8.a.m to 4.p.m and 7.a.m to 11.p.m. The facility is

manned by airport police at each entry point with restricted access only.

SR Technics was granted an Integrated Pollution Control Licence (Register Number 480)

0n 31st August, 1999.

This application for an Integrated Pollution Prevention and Control (IPPC) licence,

Register number 766, has been prepared in response to a letter from the EPA dated 19th

September, 2005 and in response to an EPA request for further information in a letter

dated 10th February 2006. SR Technics published a notice of intent to submit an

application in the Irish Independent on 7th

December 2005.

2. FACILITY OPERATIONS

SR Technics carries out operations briefly summarised as follows:

1. Operations support, part of the Facilities Services Department, is responsible for

aircraft docking, scaffolding, hangar equipment maintenance and hangar

cleaning;

2. Aircraft maintenance: - both small and very large maintenance checks are carried

out in 6 hangars on the site. All aspects of maintenance is carried out, including

engine maintenance, airframe repair and electrical checks. A range of aircraft

size can be accommodated and the hangars are appropriately sized and

equipped.

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3. Aircraft washing: - this is carried out, as required, on aircraft when docked in the

hangars. Power washing is utilised along with specialised organic detergents.

Washings that arise are diverted to sewer.

4. Workshops: - there are a number of workshops on the site that compliments the

main aircraft maintenance operation. All have specialised functions. The

workshops include:

a. Landing Gear workshop;

b. APU Service Centre workshops;

c. Safety Equipment Workshop;

d. Avionic Workshop;

e. Components Cleaning Workshop;

f. Airframe Components Workshop;

g. Engine Workshop (limited engine servicing);

h. Aircraft Maintenance Overhaul Support Shop (AMOSS) – this is a

general task workshop to support the aircraft maintenance operation;

i. Hydraulic components workshop;

j. Pneumatic components workshop;

k. Carpentry Workshop;

l. Mechanical/Electrical workshop;

5. Plating Shop: - a sub-section of the Landing Gear workshop, the plating shop

facilitates the plating of cadmium, nickel and chromium onto landing gear parts

using a process known as electrolysis. The process involves component cleaning

(mainly grit blasting), plating in baths of plating solution, rinsing and heat

treatment. The cadmium plating process is fitted with an abatement system that

ensures that no cadmium containing wastewater is diverted to sewer from the

plating shop.

6. Auxiliary Power Unit (APU) Service Centre: - APU’s are small engines that are

installed in aircraft to run essential parts of the aircraft, such as electrical items,

but that play no part in the movement of the plane itself. Approximately 100 of

these units per annum are stripped down, cleaned, inspected, maintained, rebuilt

and tested. Testing involves many advanced techniques.

7. Sheet metal fabrication: here, fabrication and repair of aircraft structural metal

parts is carried. Welding, cutting and heat treatment of metal is carried out here;

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8. Painting: - Large Airframe painting is carried out in Hangar 3. However, since

September 11th, 2001, there has only been limited, aircraft painting (in 2002).

Currently, most painting is carried out on specific aircraft parts and on Dublin

Airport motive equipment (e.g., luggage cars). Painting of parts is carried out in a

number of enclosed spray painting booths dedicated for this task. Parts are

cleaned, primed and painted. Hangar 3 is equipped with extraction to facilitate

airframe painting. SR Technics has made considerable progress towards

reducing the organic solvent consumption during painting operations, notably the

move to using high solids content (and therefore low organic solvent content)

paints on all exterior surface painting operations.

9. Materials Services Department: - this department analyses, plans, sources,

receives, controls, stores and issues aeronautical and commercial materials to

the maintenance departments and also to external customers;

10. Ground Support Equipment Maintenance: - located in the Garage Building, this

division provides maintenance and repair services for powered vehicles and

towed units operated by Dublin Airport and SR Technics. Work here comprises

all operations commonly associated with vehicle garages, including washing and

component spray painting. Outside the garage, there is also a vehicle re-fuelling

station, providing petrol and diesel to SR Technics and Dublin Airport powered

vehicles.

11. Line Maintenance Division: - located primarily on the ramp at Dublin Airport, this

division provides aircraft turnaround and aircraft maintenance support to

contracted customers. This operation also includes aircraft de-icing, towing and

pushback services.

3. RAW MATERIALS

In summary, there are a number of groups of potentially polluting compounds (relative to

soil and groundwater) that may be categorised as follows:

� Paints: - containing organic solvents and, in some cases, trace quantities of

chromic pigments;

� Thinners;

� Paint strippers: - containing organic solvents with only very small quantities

containing dichloromethane;

� Fuel oils: - mainly kerosene, petrol and diesel;

� Lubricating and hydraulic oils;

� Plating solutions: - largely acid type solutions containing copper, cadmium and

nickel ions and associated metals;

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� Degreasing solutions: - non-halogenated organic solvent based; these have

replaced trichloroethylene (TCE).

� Other cleaning solutions: - inorganic acids and bases;

� Silver solutions: - noting that these are contained in specialised close loop

systems;

� Fibreglass repair chemicals (e.g., epoxy resins);

� Sealants.

The material services department maintains strict control over material purchase and issue.

A ‘Just-In-Time’ protocol is used to ensure the minimum of storage needs and consumption

of raw materials.

Mostly small quantities of a large number of raw materials are used. Some materials used

are contract specific and may be used only once for that contract.

Other raw materials used, that are not generally potentially polluting, include:

� Sheet metal;

� Welding gases;

� Wood;

� Fibreglass;

� Plastics;

� Composite materials;

� Electrical equipment;

� Component parts.

4. EMISSIONS TO ATMOSPHERE

4.1. Point Source Emissions

A summary list of main emissions points to atmosphere is provided in Table A.1.

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Table A.1 – Details of Main Emission Points.

Point Emission Source Diameter mm Height

Above GL m

A1 H3 - EXTRACT SYSTEM 2500 20.00

A2 H3 - EXTRACT SYSTEM 2500 20.00

A9 H1 PLATING SHOP CHROME SCRUBBER 450 9.55

A18 H1 PLATING SHOP DEGREASER 180 7.09

A31 H1 APU CLEANING SHOP DEGREASER 150 4.73

A35 H3 WET PAINT SPRAY BOOTH 640 8.76



A42 H5 MAIN PAINT SPRAY BOOTH 900 5.54

A44 GA PAINT SHOP 800x800 5.00

A45 GA PAINT SHOP 800x800 5.00

A46 H6 PAINT SPRAY BOOTH 600x500 26.60

There are many minor emissions to atmosphere, broadly categorised as follows:

� Workshop emissions from, e.g., test areas, carpentry, garages;

� Boilers;

� Space heating;

� Other plating shop emissions.

The minor emissions are considered to have emissions to atmosphere of pollutants

significantly less than that of the main emissions.

4.2. Fugitive Emissions

Fugitive emissions are largely generated in the following operations on the site:

� Aircraft maintenance;

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� Aircraft and component painting; and to a lesser extent

� Degreasing.

The requirements of the Solvent Directive regarding fugitive emissions for the above

activities are emission limit values for fugitive emissions expressed as a percentage of

solvent input.

An exemption from the Activity 8 emission limit values for aircraft painting is noted in the

next section to this non-technical summary This exemption includes both point source

emission limit values and fugitive emission limit values. Notwithstanding this exemption,

details pertaining to BAT for aircraft painting have been presented with the aim to reduce

overall VOC emissions and therefore the mass emissions of VOC’s as fugitive emissions

from aircraft painting.

Regarding other activities on site, an estimate of fugitive emissions of 60% of solvent

input (i.e., the amount of solvent used) has been made based on 2004 data. The relevant

activities include component painting, degreasing and general aircraft maintenance.

It is important to note that the above estimate of fugitive emissions has been presented

on a site-wide basis, rather than on an activity basis. Further, more detailed, work is

required to more accurately determine fugitive emissions. For example, it is likely that

fugitive emissions in individual component spray paint booths, as a percentage of solvent

consumed in the booths, is substantially less than 60% given the enclosed area and

extraction presented. A similar situation is anticipated for solvent degreasing. The largest

contributor to fugitive emissions is likely to be general aircraft maintenance.

Once a more detailed fugitive emissions estimate is completed, then a programme of

specific action to reduce the percentage of fugitive emissions can be developed and

implemented.

4.3. Control & Abatement Technology

The following abatement technology is applied at SR Technics:

� Water curtains: - These are used in spray paint booths to remove paint dust from

sanding operations and also to remove paint from cleaning and painting. They

operate by pumping water in a loop. The water comes in contact with air that is

extracted from the paint booths and which then absorbs the pollutants;

� Dust Collectors: - These unit operations used filters inside a metal box to remove

dust from the air that is extracted from the process served by the filter. The filter

then empties to a holding pot underneath. The clean air is discharged to

atmosphere. These units are used for a variety of operations where dust may be

generated, for example, sanding, wood cutting, etc

� One of the main emissions, that from the chrome plating operation, has a water

scrubber attached to the extraction system. Water is pumped through the

scrubber where it contacts air that may have small quantities of chrome

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containing dust or fumes. The chrome dust or fume is then absorbed by the

water. This water is then periodically removed and disposed of separately.

The above abatement unit operations are on a preventative maintenance

programme.

4.4. Assessment of the Solvent Emissions Directive (1999/13/EC)

An assessment was carried out as to the applicability of the provisions contained in the

Solvents Directive relating to emissions from aircraft painting. The Directive,

implemented in Ireland through S.I. No.543 of 2002, Emissions of Volatile Organic

Compounds from Organic Solvents Regulations 2002, allows companies with coating

activities to comply with the Solvents Regulations by complying either with emission limit

values (on waste gas emissions and fugitive emissions) or electing to apply what is

known as a ‘Reduction Scheme’. The Reduction Scheme effectively allows a company to

set targets relating to overall reduction of organic solvent emissions to air over time and

in a specific manner.

There is an exemption to the above requirements applied to certain coating activities,

which includes aircraft painting. At SR Technics, aircraft painting is carried out in Hangar

3. The key exemption provisions are:

1. Exemption from the emission limit values and therefore the consideration of a

Reduction Scheme;

2. Exemption from the Reduction Scheme if it can be demonstrated to the

satisfaction of the EPA that Best Available Techniques (BAT) is being used and

that the Reduction Scheme is not technically and economically feasible.

The Reduction Scheme cannot technically or economically be applied for aircraft painting

at SR Technics. There are two main reasons:

1. Inconsistency in solids deposition on an airframe (i.e., painting), given the various

client specific requirements.

2. The need to include all VOC containing materials in the Reduction Scheme

calculation. Unlike vehicle refinishing, there is a significant variation in the ‘recipe’

for airframe painting. For example, there are times when only high solids painting

is required with minimal surface preparation and in this case a Reduction

Scheme calculation will produce low values or VOC emissions emitted relative to

solids used. However, in many cases, and perhaps for contracts for an extended

period of time, there is the need only to apply relatively small amounts of high

solids paint but the need for significant surface preparation (containing high VOC

content but no solids content), resulting in Reduction Scheme indices far greater

than the target values. The flexibility to have either situation is important for the

viability of the aircraft painting business at SR Technics.

A BAT assessment specific to aircraft painting was then prepared as required. One

aspect of BAT is abatement. The conclusion from that assessment is abatement is

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technically and economically unfeasible in order to meet emission limit values due to the

very large air flows to be treated, coupled with low organic solvent emissions.

SR Technics has extensively implemented BAT in its aircraft painting operation. The main

application file lists in detail the BAT implemented. Among the more important BAT

measures introduced to aircraft painting at SR Technics include:

� A move completely to high solids, and therefore low organic solvent, containing

paint;

� Using equipment that minimizes paint application and over-spray;

� Improved procedures for painting;

� Enclosed spraying equipment cleaning;

� Careful raw material purchasing control.

4.5. Assessment of Impact of Atmospheric Emissions

URS Ireland completed a conservative dispersion modelling assessment of the main

emissions from the SR Technics Plant (listed above in Table A.1), comprising an original

dispersion model report in December 2005, followed by additional dispersion modelling

detailed in a second (addendum) report in April 2006. Both dispersion modelling reports

are included in Attachment No. I.1 to the main IPPC application. The addendum report

was in turn followed by a clarification letter dated 26th May 2006 clarifying the derivation

of suitable criteria against which to compare predicted ground level concentrations of

volatile organic compounds.

The modelling excluded emission point A9. This exclusion was made considering that the

emissions monitoring indicated that the relevant parameter, inorganic matter containing

chrome, has not been detected in the discharge for the past two years.

Both particulate and organic solvent emissions, the latter expressed as Total Organic

Carbon (TOC), were modelled.

Emission points to atmosphere were modelled based on maximum emission gas flow

rates, resulting in conservative emission mass flow rates of carbon. The relevant input

concentration data is summarised as follows:

1. Hangar 1 operations include short duration repair work and deep cleaning. There

are two vapour degreasers labelled A 18 (Electroplating Shop) and A 31 (APU

Cleaning Shop). VOC emissions from A18 and A31 have been modelled at the

relevant BAT Emission Limit Values1 of 75mgC/m

3.

1 BAT Guidance Note on Best Available Techniques for Solvent Use in Coating, Cleaning and

Degreasing (Draft, December 2004)

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2. Hangar 3 contains the potentially most significant emissions to atmosphere, A1

and A2, where painting and related activities are carried out. Emissions from A1

and A2 have been modelled at a VOC concentration of 300mgC/m3 based on

limit values issued by the EPA to other licensed facilities, namely Shannon

Aerospace Ltd. and Lufthansa Technik Painting Shannon Limited. Particulates

emissions from A1 and A2 have been modelled at 20mg/m3 based also on limit

values issued by the EPA to Shannon Aerospace Ltd. and Lufthansa Technik

Painting Shannon Limited.

Hangar 3 also contains a paint shop which consists of two spray gun machines

which are vented to atmosphere via emission points A35, A36 and A37. VOC

emissions from A35, A36 and A37 have been modelled at the relevant BAT

Emission Limit Values of 100 mgC/m3 for VOCs. Particulate emissions from A35,

A36 and A37 were modelled at 20mg/m3.

3. Hangar 5 operations include aircraft strip-down, various structural repairs and

painting. Emissions from self-contained paint spray facility in this hangar are

emitted through A42. Emission point A42 has been modelled at the relevant BAT

Emission Limit Value of 100 mgC/m3 for VOCs and at an Emission Limit Value of

20mg/m3 for particulates.

4. Hangar 6 operations include aircraft strip-down, various structural repairs and

painting. Emissions from the paint shop in Hangar 6 are emitted through A46.

A46 has been modelled at the relevant BAT Emission Limit Values of 100

mgC/m3 for VOCs and at an Emission Limit Value of 20mg/m

3 for particulates.

Emissions from the Paint and Body Shop in the Garage are emitted through A44 and

A45. A44 and A45 have been modelled at the relevant BAT Emission Limit Values of 100

mgC/m3 for VOCs and 20mg/m

3 for particulates.

The model allowed for surrounding buildings and utilised three years of Meteorological

data. The model input also utilised expected maximum flow rates from the emission

points.

The key model output is detailed in the second (addendum) report dated April 2006 and

key data from that report is repeated in the external consultants (URS) letter dated 26

May 2006. The main emissions modelled were split into a number of areas as follows:

Area Stacks Included

Main aircraft painting area A1 and A2

Degreasing area A18 and A31

Smaller paint shop areas A35, A36, A37, A42, A46

Garage paint shops A44 and A45

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For each of the above group of stacks, the output, expressed as maximum predicted

ground level concentration at certain distances from the emission sources, was then

compared with relevant guideline limits (further detail below). Material Safety Data Sheets

(MSDS’s) for the base / thinner / hardener products used in the different areas, serviced

by the four stack groups, provide the percentage, by weight, of the various organic

substances contained in the products. This information was multiplied by the total annual

usage figures for these products, to get the total estimated usage for each of the organic

substances per annum and then apportioned out to each group of stacks knowing what

products are used in each case. This facilitated the comparison of the predicted ground

level concentrations to identified substance OEL derived guideline values, with reference

to the relative quantities of each substance in the waste gas.

The model was considered very conservative as it was assumed that all main emissions

occurred at the above concentrations all of the time. In reality, this is not the case with

emissions occurring over certain times per day and at measured concentrations on

average significantly less than the above.

The resultant relative ground level concentrations were compared to the Occupational

Exposure Limit (OEL) derived guideline value (i.e. the OEL/10) for each substance.

Where available, the UK Environment Agency Limits (EALs) were also included for

comparison. Short term EALs are taken from Appendix D of UK Environment Agency

IPPC Guidance Note H1.

The results in show that, in all cases, the predicted ground level concentration of the

various organics are lower than the respective OEL/10 for each of the organics. It is also

noted that the predicted ground level contributions are also below the Short Term EAL

criteria. The EAL values, used as air quality assessment criteria in the UK, are also

derived from Occupational Exposure Limits however a different factor is used to derive

the criteria.

It is also noted that the OEL/40 criteria are all significantly lower than the EAL criteria.

Should the OEL/40 criteria be employed rather than the OEL/10 then exceedences would

be noted for formic acid and benzyl alcohol from A1/A2. All the other stack groups would

be within the OEL/40 values. Assuming continuous maximum emissions from A35, A36,

A37, A42 and A46 the more stringent guideline value, i.e. the OEL/40 value, may be

exceeded for a limited area in the vicinity of the site, however given the conservative

assumptions employed in the modelling assessment, it is considered that in practice off-

site concentrations are likely to be below the guideline value. It is understood that there

are no sensitive receptors (e.g. schools, residential areas) in the vicinity of the site, hence

the use of the OEL/40 value may be considered overly conservative given that no

persons will be continually exposed to any releases (e.g. residents) and there are no

reported highly sensitive receptors (school children, elderly or sick people).

For particulate emissions, the predicted maximum ground level concentration from the

relevant emission points were above the relevant guideline limit for all three years met

data. However, the model was considered ultra-conservative in respect of emissions of

particulate matter (dust). The key reasons being:

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1. The actual measured particulate concentration is an order of magnitude lower

than the input concentration to the model for the majority of the emission points;

2. Particulate emissions will occur only some of the time, largely during surface

preparation for later painting, whereas the dispersion model assumed discharge

of particulate from all emission points modelled for particulate, all of the time;

3. A tight guideline value was assumed, i.e., a total inhaleable dust limit value,

against which the model output for particulate matter was compared. In reality,

much of the particulate matter expected from the emissions from SR Technics

will be larger, non-inhaleable particulate matter.

4. Finally, a 100th

percentile maximum concentration value was calculated. This

means the absolute worst concentration which is predicted to occur in any one

year. This is highly dependent on a number of factors occurring together, e.g, full

discharge at the maximum input concentrations and, at the same time, the worst

weather conditions relating to dispersion (i.e., poor dispersion). Such an event is

highly improbable at SR Technics given the nature of operations at the site.

Therefore, it was concluded overall that the main emissions from SR Technics do not

have a significant impact on the surrounding air quality at the concentrations modelled.

5. EMISSIONS TO SURFACE WATER

Uncontaminated storm water is discharged from the SR Technics site to the nearby

Sluice River (via tributary streams) from three surface discharge points, SW1, SW2 and

SW3. Each of these emission points is associated with an area of the SR Technics site.

The emissions to surface water are monitored according to Schedule 5 of the IPC

licence, register number 480 for organic matter and pH.

The main potential area for contamination is in the vicinity of the Garage operation and

vehicle fuelling area. The fuelling area and part of the Garage forecourt discharge to

sewer (SW3) through an oil interceptor.

SR Technics, in the main application file for the IPPC licence, has requested that weekly

visual inspections of storm water be carried out instead of daily inspections. This arises

from a contradiction in the current IPC licence.

6. EMISSIONS TO SEWER

6.1. Sources of Emissions To Sewer

Emissions to sewer from the site includes:

� sanitary waste water;

� final rinse water from chrome and nickel plating lines;

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� rinse water from fluorescent penetrate testing;

� x-ray film processing, wheel and brake cleaning;

� aircraft wash wastewater from all Hangars and the Garage wash bay plus the

fuelling area.

There are 3 emission points namely SE1, SE2 and SE3 as shown on Drawing Reference

‘IPPCSewer’ in Section E.3 of this IPPC Application.

SE1 contains emissions from

� Hangar 1

� APU shop

� Wheel and Brake shop

� Undercarriage shop, Plating shop

� Composite shop

� Non-destructive Testing operations

SE2 contains emissions from Hangar 2, 3, 4 and 5

� Cleaning shop

� Hydraulic shop

� Pneumatic shop

� Avionic shop

� Stores operation

SE3 contains emissions from

� Garage

� Vehicle Fuelling Area

� Hangar 6

� Full details of emissions from each process are contained in Section D, Process

Description, of the main IPPC application. The main pollutants in the emissions to

sewer will be:

� Organic matter from sanitary wastewater;

� Suspended solids, both inorganic and organic;

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� Trace concentrations of heavy metals, largely nickel, chrome, cadmium and

copper;

� Detergents used to wash aircraft;

� Trace concentrations of solvents from painting operations and general aircraft

maintenance;

� Trace concentrations of jet fuels and oils.

Currently, wastewater is monitored according to Schedule 2 of the IPC licence, register

number 480.

6.2. Emissions of Cadmium to Sewer

The EPA requested SR Technics to assess the occurrence and frequency of emissions of

cadmium to sewer. Cadmium is released to sewer at all three emission points SE1, SE2

and SE3 mainly from aircraft washing operations and this cannot be avoided. An

assessment of the actual concentrations of cadmium in the discharges to sewer indicates

only occasional excursions above the emission limit value of 0.5 mg/l set for SE1.

Nonetheless, SR Technics continues to progress the opportunity to reduce the quantity of

cadmium getting into the aircraft washings as part of its Environmental Management

Programme.

6.3. Arrangements for Discharges to Sewer

The effluent from SE1, SE2 and SE3 is discharged to the sewer system vested by the

Dublin Airport Authority. This sewer system in turn discharges ultimately to the Greater

Dublin Area drainage system and on to the Ringsend Wastewater Treatment Plant.

Following receipt of the sewer report for year 2000 the Agency requested a report

outlining the feasibility of separating the trade effluent from the sanitary effluent to ensure

that sampling and monitoring at each discharge point to sewer consisted of trade effluent

only. Following a detailed site survey of the sewer system it became clear that the task

would be enormous given the mix of trade and sanitary effluent streams in so much of the

system and all discharging at the selected emission points.

There was further correspondence on the above matter between SR Technics and the

EPA in 2001 and in 2002, but with no firm conclusion on the EPA assessment of

information provided.

6.4. Abatement of Emissions to Sewer

The following unit operations are provided as abatement of emissions to sewer:

� 3-chamber oil interceptors are placed at specific locations in the facility drainage

system. These are designed to remove oil from wastewater but will also remove

suspended solids;

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� In the Plating shop, there are two technologies used to remove cadmium from the

wastewater generated in the cadmium plating process. An electrolysis unit does

most of the work, followed by ion exchange to take out trace cadmium from rinse

waters. The net effect is effectively zero discharge of effluent from the cadmium

plating operation;

� A small filtration system is used to remove silver metal from effluent generated

from a film processing unit located in the Non-destructive testing area;

� There are grease traps fitted into main food areas on the site (canteen, break,

room).

Maintenance of the above unit operations is provided through the sites Preventative

Maintenance Programme.

6.5. Assessment of Impact of Emissions to Sewer/Waters

The impact of emissions to sewer is considered insignificant. There are no discharges of

materials to sewer that will cause significant difficulty to receiving sewer maintenance

operations or sewer integrity. Pollutants in the sewer discharges are not likely to cause

any significant operational difficulty to the receiving wastewater treatment plant at

Ringsend by virtue both of the properties of the pollutants and the dilution ultimately

experienced in the Greater Dublin Area drainage system.

SR Technics did examine the impact of cadmium discharges on foot of the EPA request

to assess cadmium discharges generally. Cadmium is not being received at the Ringsend

plant in concentrations great enough to cause harm to the microbial population carrying

out the bulk of wastewater treatment at Ringsend. Further, it was conservatively assumed

that all of the cadmium in the SR Technics effluent is precipitated out in the waste

activated sludge at Ringsend, and also conservatively assumed that all of this cadmium

will be present in the Biofert product from waste sludge treatment at Ringsend. In that

case, on average less than 4% of the Biofert cadmium mass content would derive from

SR Technics. Furthermore, cadmium concentration is not a limiting factor for the land

application of Biofert.

7. EMISSIONS TO GROUND

There are no intended emissions to ground from the SR Technics facility. The company is

monitoring site groundwater on an annual basis in accordance with IPC licence

requirements (refer to Section 8 for more detail).

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8. SITE CONDITION

8.1. ENVIRONMENTAL SETTING

The topographic elevation of the site is approximately 65 metres above Ordnance Datum.

The topography of the surrounding area slopes down gently to the north and northeast.

The made ground at the site consists of a concrete slab with an average thickness of 0.2-

0.3 metres underlain by fill material to an average depth of four metres below ground.

Underlying the fill material are glacial till deposits with an average thickness of ten to

eleven metres. The glacial till deposits were underlain by a limestone formation identified

by the Geological Survey of Ireland (GSI) as Carboniferous Limestone. Signs of

weathering were observed within the top metre of the encountered limestone formation.

Surface water drainage from the site is reported to be north and northwest towards the

Forrest Little (Cuckoo) Stream and Wad Stream, via storm water drains. Both streams

join approximately three kilometres west of the site and are shown to flow into the Irish

Sea at Portmarnock Bridge. At this point the stream is know as the Sluice River.

Data from the Irish Environmental Protection Agency indicated that the surface water

quality in the area is poor. Dublin Airport Authority regularly monitors the water quality of

the Forrest Little Stream for key inorganic parameters. No surface water is abstracted

from the above streams on a regular basis. The fill material overlaying the glacial till has

been shown to be partially saturated

Previous investigations reported a general

north/northeastward groundwater flow direction within the fill material.

The low permeability and the considerable thickness of the glacial till can be anticipated

to greatly retard any vertical downward movement of water from the shallow soils to the

limestone aquifer. However, preferential pathways of higher permeability may exist due

to sand and gravel lenses within the glacial till unit.

Most of the surface area at the site is sealed by road surfacing, concrete slabs or

buildings. Local groundwater recharge can therefore generally be expected to be minor.

8.2. Historical Incidents

There were a number of incidents on the site which were all reported to the Agency. Most

incidents related to fuelling of aircraft outside the hangars but emergency procedures in

place prevented contamination of sewer and surface water drains.

There were two incidents which had the potential to cause pollution since the IPC

process started:

1. A fuel spill from a parked aircraft on 30th March 1998 when approximately 4

tonnes of fuel spilled onto the ramp area and entered the surface water drainage

system.

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2. A leak from a cleaning tank, containing an Ardrox solution 188, went undetected

and an estimated 200 litres of solution entered the sewer system. A pH probe

was fitted in the bund in the cleaning shop and prevents the sump pump from

operating if the pH goes outside limits.

8.3. Current Groundwater Monitoring

Shallow groundwater monitoring is carried out as required by the site’s current IPC

Licence. The related requirements are contained in Condition 10.3 and Schedule 5(ii) of

the licence.

The location of the shallow groundwater monitoring wells on site are presented in

Drawing Reference ‘IPPCBoreholes’ in Section I.5 of this IPPC Application.

Based on data collected by URS during 2004 and 2005 (up to September 2005) observed

environmental quality of shallow groundwater was generally good with contaminant

concentrations remaining below or close to individual method detection limits.

8.4. Trichloroethylene (TCE) And TCE Breakdown Product Monitoring

Groundwater monitoring carried out by URS in January 2003 revealed the presence of

TCE in the limestone bedrock aquifer at monitoring well GW003D. Additional wells were

installed subsequently, and a quantitative risk assessment was carried out. This work

was aimed at quantifying the risk posed by TCE and related breakdown products for

identified receptors at the site and off site. This latter work was split into two phases: Part

A: Site Investigation and Part B: Quantitative Risk Assessment.

The main findings from this work were as follows:

� The observed levels of TCE, and breakdown products 1,1-dichloroethene (1,1-DCE)

and cis-1,2-DCE, in the bedrock aquifer at GW003D exceeded the respective Dutch

Intervention Values and EQS guideline values.

� It is thought that the source of the TCE impact is located at the site, most likely in the

vicinity of GW003D/GW004. TCE was used as a degreaser in workshops in this area.

Potential spillages/leakages could have entered the fill material in the past and

migrated northward towards the well locations following the general groundwater

gradient.

� At the time of reporting on the investigation work, it was considered that the presence

of 1,1 DCE and cis-1,2-DCE in soil and groundwater underlined that TCE is

biodegrading at the site. Further it was considered that the absence of these

compounds in groundwater samples collected downstream of GW003D indicated that

the TCE impact was relatively localised. However, the hazardous nature of these

compounds warranted a more detailed assessment, taking into account the exposure

risk to potential receptors at the site and off site.

� Due to the observed increasing trend in TCE concentrations in the bedrock aquifer at

GW003D, ongoing regular groundwater monitoring was recommended.

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In order to assess the aforementioned exposure risk to potential receptors at the site and

off site, a quantitative risk assessment was prepared on the basis of a conceptual model

delineating sources, potential pathways and potential receptors for observed

contaminants (Part B of the 2003 study).

The model results indicated that, at the time of the study, the observed contaminant

concentrations in soil and groundwater at the site did not pose a risk to the identified

receptors at the site (site users) or to off-site (controlled waters).

With regard to the parameter set used in the modelling exercise it should be noted that a

range of parameters had to be estimated based on the geology at the site or literature

values. The spatial extent of the source zones were conservatively estimated. The

assessment of model sensitivity, by increasing modelled source areas and hydraulic

conductivity of the bedrock aquifer, underlined the absence of any significant risk for

identified receptors from soil and groundwater contamination observed at the site.

The risk assessment work again concluded that the observed increasing trend in

contaminant concentrations in the bedrock aquifer should be addressed in the interim by

ongoing regular groundwater monitoring. Remedial action was not considered

necessary.

8.5. Ongoing Groundwater Monitoring For Chlorinated Solvents

Groundwater monitoring specific to the observed TCE issue was carried out by URS in

January 2003, March 2003, September 2003, January 2004, September 2004, February

2005 and September 2005.

The latest monitoring carried out, in September 2005, confirmed the presence of TCE

and other chlorinated solvents in groundwater collected from the limestone aquifer at

GW003D, as documented in previous reports. Compared to the previous monitoring

round in February 2005, observed levels of TCE increased from 3.22 mg/l to 3.84 mg/l.

This concentration of TCE is the highest observed at GW003D since URS commenced

monitoring in 2003. Concentrations of TCE breakdown products have all decreased from

peaks observed in February 2005, to similar levels observed during monitoring in

September 2004.

Chlorinated solvents were furthermore detected in groundwater samples collected in

September 2005 at the shallow monitoring well GW004. The TCE concentration observed

at GW004 in September 2005 was the lowest observed since monitoring commenced in

2003.

With regard to observed chlorinated solvents in shallow groundwater at GW004, these

are known degradation products of 1,1,1-TCA and TCE. The presence of these

breakdown products in shallow groundwater indicates that reductive dehalogenation of

1,1,1-TCA and TCE is occurring in the low permeability glacial till deposits close to the

suspected historic source zone of solvent impact upgradient of GW004.

The presence of degradation products in groundwater collected from the limestone

aquifer at GW003D furthermore indicates that natural biodegradation of observed TCE

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levels is occurring at the site. The reported low hydraulic gradient, low permeabilities of

the individual geological units and limited direct groundwater recharge at the site are

likely to yield low net groundwater flow rates across the site. While this would tend to

decrease the dilution potential for any contaminant impact on groundwater it may also

increase the potential for abiotic decay and biodegradation, due to increased residence

times. It is noted that concentration trends of one of the degradation products appears to

lag behind temporal fluctuations in TCE concentrations.

The observed increase in TCE levels in groundwater collected from the limestone aquifer

over recent monitoring rounds may be associated with retarded vertical migration of

historic residual pockets of shallow TCE impact. At the same time, declining trends of

TCE in shallow groundwater impact may indicate the overall depletion and degradation of

the historic source zone of solvent impact.

In view of the increasing levels of TCE at GW003D, the limited nature of TCE impact in

the bedrock aquifer should be confirmed by including additional deep monitoring wells

down-gradient of GW003D in the next regular groundwater monitoring round. GW006

should also remain in the next groundwater monitoring round to assess shallow

groundwater quality down-gradient of GW004.

9. NOISE EMISSIONS

There are a number of noise sources on the site that SR Technics are required to monitor

annually as per Schedule 4 of the licence. Table A.2 is a summary of the noise sources.

SR Technics also carries out noise monitoring at boundary locations, both at day and at

night in 6 locations around the boundary and at one sensitive receptor, a residential home

located approximately ¼ of a mile north east of SR Technics.

Noise monitoring results has shown that SR Technics is generally compliant with noise

monitoring emission limit values. Significant expenditure was invested in reduction of

noise from some sources, especially the APU test cell.

It is important to note that SR Technics operations occur within the main airport area and

therefore there is substantially more noise impact from the airport activities (aircraft

operation) than would be expected at SR Technics.

Table A.2. Noise Emission Sources

Reference Location

NS1 Exhaust - Hangar 3 (East side)

NS2 Extract - Hangar 5

NS3 south APU South side (at full load)

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Reference Location

NS1 Exhaust - Hangar 3 (East side)

NS3 north APU North side (at full load)

NS4 Air Intake - Hangar 5

NS5 Compressor Louver - Hangar 5

NS6 Exhaust - Hangar 3 (West side)

10. WASTE MANAGEMENT

Solid and liquid waste, both hazardous and non-hazardous, is generated from the various

operations summarised in Section 2 of this document. Section H of the main IPPC

application details the quantities and types of wastes generated and provides details of

disposal and recovery of waste generated.

In summary, the types of waste produced at SR Technics include:

Hazardous wastes:

� Acid and base solutions;

� Spent adhesives and

resins;

� Spent paints

� Chrome waste;

� Contaminated sump

water;

� Plating solution solutions;

� Contaminated solid

packaging;

� Degreaser wastes;

� Sludge from aircraft

stripping;

� Fluorescent tubes;

� Batteries;

� Mineral and lubricating

oils,

� Waste cleaning solvents;

� Waste fluxes;

� Waste coolants;

� Plating tank sludges;

� Magnetic particle

contaminated oil;

� Water contaminated with

oil.

Non-hazardous waste:

� Crushed metal cans; � Non-hazardous sediment

from drains;

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� Canteen waste;

� Scrap metal;

� Timber;

� Soft drink bottles;

� Paper & cardboard;

� Electrical & electronic

waste

SR Technics has implemented a programme of waste segregation on site in order to

maximise the recovery of waste rather than disposal. Each department on site has a

number of clearly marked bins for waste disposal.

11. SAMPLING AND MONITORING

Monitoring of emissions to the environment will be conducted to ensure all

control/treatment systems continue to operate to specification and in compliance with

emission limit values and the requirements of the IPPC licence.

The table below contains a list of all current monitoring points, the parameter measured

at each point, the method of measurement and the frequency of measurement

Table A.3 Monitoring Points

Monitoring

Points

Parameter Monitoring Method Frequency

Emissions to Atmosphere

Flow Pitot Tube Quarterly

Class B

Compounds

Adsorption Quarterly

Class III Inorganic

Dust Particles

Isokinetic Quarterly

A1, A2

Total Organics (as

C)


Flow Pitot Tube Annually A9

Class III Inorganic

Dust Particles

Isokinetic Annually

Flow Pitot Tube Quarterly A18, A31

Class B

Compounds


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Monitoring

Points


Total Organics (as

C)


Flow Quarterly Pitot Tube

Particulates Quarterly Isokinetic

A35, A36,

A37, A42,

A44, A45,

A46 Total Organics (as

C) Quarterly

Adsorption

Emissions to Sewer

SE1, SE2, SE3

Flow

Continuous (30 min)

sampling via automatic

sampler

Continuous

SE1, SE2, SE3

Temperature

Continuous (30 min)

sampling via automatic

sampler

Continuous

SE1, SE2, SE3 pH Composite 24Hr sample Continuous

SE1, SE2, SE3 BOD Composite 24Hr sample Monthly

SE1, SE2, SE3 COD Composite 24Hr sample Monthly

SE1, SE2, SE3 Suspended Solids Composite 24Hr sample Monthly

SE1 Sulphates Composite 24Hr sample Monthly

SE1, SE2, SE3 Detergents

(as MBAS) Composite 24Hr sample Monthly

SE1, SE2, SE3 Oils, Fats, Grease Composite 24Hr sample Monthly

SE1 Chromium (as Cr) Composite 24Hr sample Monthly

SE1 Copper (as Cu) Composite 24Hr sample Monthly

SE1 Nickel (as Ni) Composite 24Hr sample Monthly

SE1 Silver (as Ag) Composite 24Hr sample Monthly

SE1 Tin (as Sn) Composite 24Hr sample Monthly

SE1 Cyanide (as Cn) Composite 24Hr sample Monthly

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Monitoring

Points


SE1, SE2, SE3 Cadmium (as Cd) Composite 24Hr sample Monthly

Emissions to Surface Water

Visual Inspection Grab sample Weekly1

pH Grab sample Weekly

SE1, SE2, SE3

COD Grab sample Monthly

Groundwater Monitoring

Arsenic Standard technique in

accordance with BS6068-

6.11:1993

Biannually

Cadmium Standard technique in


6.11:1993

Biannually

Chromium Standard technique in


6.11:1993

Biannually

Copper Standard technique in


6.11:1993

Biannually

Lead Standard technique in


6.11:1993

Biannually

Mercury Standard technique in


6.11:1993

Biannually

Nickel Standard technique in


6.11:1993

Biannually

Silver Standard technique in


6.11:1993

Biannually

Zinc Standard technique in


6.11:1993

Biannually

GW012, GW013,

GW014, GW016,

GW008, GW011

Mineral Oil Standard technique in


6.11:1993

Biannually

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Monitoring

Points


Diesel Range

Organics

Standard technique in


6.11:1993

Biannually

Volatile Organic

Carbons



6.11:1993

Biannually

GW004, GW003D Volatile Organic

Carbons



6.11:1993

Biannually

Noise Monitoring

Noise Sources:

NS1, NS2, NS3

(south), NS3

(north), NS4,

NS5, NS6

Sound Pressure

Limit – dB(A)

In accordance with ISO

1996:1982: Acoustics –

description and measurement of

Environmental Noise and EPA

Environmental Noise Survey

Guidance Document

Annually

Boundary Locations:

B1, B2, B3, B4, B5. B6

LAeq, LA10, LA90






Guidance Document

Annually

Noise Sensitive Location:

S1 LAeq, LA10, LA90






Guidance Document

Annually

12. ENERGY EFFICIENCY

The total energy consumed on the entire site in 2004 was 37,392 MWh’s consisting of

electricity (33.8%), gas (35.5%), high temperature hot water from the Dublin Airport

Authority (DAA) central boiler house (29.4%) and heating oil (1.3%).

Electrical energy is used for lighting, general services, motive power, process heating

including heat treatment ovens and electroplating, plus heavy plant including frequency

converters, air compressors and hydraulic rigs.

Gas is used for space heating in hangars 3, 4, 5, 6 and the Garage building. The paint

spraying and drying process in hangar 3 is operated by gas. Water heating in hangar 6

and the Garage plus a high pressure hot wash plant, for aircraft washing in hangar 6, also

uses gas.

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High temperature hot water, from a central DAA boiler house, is used to space heat

hangars 1 and 2 plus workshops, logistic centre and offices. The primary energy source

for this boiler is gas.

Heating oil is used to space heat the APU test cell, a boiler for heating the cleaning shop

vats, a paint spray booth in hangar 5 and a high pressure hot wash plant for aircraft

washing in hangar 3.

There is no energy generated on site.

A full energy audit was carried out in 1999 and a detailed Energy Management Master

Plan was drawn up. This master plan outlined clear objectives for the 2000 – 2005

periods and set an aggressive reduction target of 12.5% in total energy consumption.

Yearly targets were set based on review of previous year and success towards overall 5

year target.

In 2001 an electrical monitoring and recording system (Energy Focus) was installed.

In all new developments energy efficiencies measures are taken into consideration. The

preventative maintenance programme includes repairs to leaking taps, repairs to air lines,

repairs to insulation and lagging etc. General awareness of energy efficiencies are

promoted throughout the organisation with newsletters, notice boards, e-mails and a

focus TV system.

The cumulative effect of the energy master plan, managed as part of the Environmental

Management Programme, is an overall energy usage reduction of 17.7% (45,423 to

41,805 mWh’s) between 2000 and 2004 which was ahead of initial target.

13. CONTAINMENT OF ACCIDENTAL SPILLAGES

The drainage system, consisting of the trade effluent and foul sewage system discharging

to the Greater Dublin Area sewer network and the surface water system discharging, via

the Sluice River, to Dublin Bay , is protected in the following manner:

� Installation of 3-chamber interceptors at strategic locations;

� Installation of pump sumps in areas where trade effluent is generated that can

only discharge, via pumping, to the sewer system when the pumps and level

control is active. In an emergency, such as a spillage, these pump sumps can be

isolated.

� Installation of a large emergency holding tank in Hangar 6, designed to hold a

large spill of potentially polluting material, e.g., aviation fuel or contaminated

firewater.

The storage and containment of all materials at SR Technics conform to existing IPC

licence requirements and best practice. Bund capacities incorporate the required 110%

of the volume of the largest tank or 25% of the volume of the total tankage within the

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bund, whatever is the greater. In addition a 3-year rolling bund and drain programme

ensures that any deficiencies in available secondary containment are rectified in a timely

manner.

14. EMERGENCY RESPONSE

SR Technics does not carry out an activity scheduled identified in the Major Accidents

Directive 96/082/EEC as amended (the Seveso Directive).

SR Technics has in place an Emergency Reaction Plan covering a wide variety of potential

safety and health risks, including:

� Ire/explosion;

� Gas leak;

� Chemical spill;

� Major damage;

� Bomb warning;

� Multiple persons injury;

� Traffic accident;

� Anthrax.

One of the important contributions to the emergency measures at SR Technics is the

Airport Fire Services which can be on site in less than 5 minutes in the event of an

emergency situation requiring their services.

SR Technics also maintains a separate Environmental Management Emergency

Reaction Plan. This document contains emergency contact details for the EPA, Fingal

County Council and the Eastern Regional Fisheries Board. The plan also documents

detailed actions and procedures in the event of:

� A fire in any area of the site (and therefore control of firewater run-off);

� A significant spillage of potentially polluting material;

The plan also contains:

� Details of persons responsible and to contact with full contact details;

� A list of first aiders and contact details;

� Template forms, e.g., the Environmental incident Investigation Report.

� Details on classification of spills and other emergency events.

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15. APPLICATION OF BEST AVAILABLE TECHNIQUES AT SR TECHNICS

A number of Best Available Technique (BAT) measures have been implemented at SR

Technics and the company continues to look for further BAT opportunities. Notable BAT

measure include:

� The implementation of an Environmental Management System which includes:

o A schedule of significant environmental aspects which assesses all

operations with a view to reviewing cleaner production methods and the

reduction and minimisation of waste.

o A schedule of Objectives and Targets drawn up and implemented as part

of the Environmental Management Programme. The schedule

incorporates all environmental concerns, e.g., emissions to air, waste,

water management, energy management, etc.

A report on the progress of this programme is prepared and submitted as part of

the Annual Environment Report (AER). A planned programme of further

improvements is drawn up for the following year and also included in the AER for

approval.

� Training is extensively carried out on site and includes:

o Foundation course in Environment Management

o Environmental Management training for the environment committee

o Environment Auditing

o Maintaining an pollution control licence

o Spill control

o Waste Management and Minimisation

SR Technics has an in-house training school where technical and staff

development training is carried out. All courses have an environment module

included as does induction training for all new entrants

� Emissions to Air: refer to Section 4.4 above.

� Emissions to Sewer:

o Cadmium abatement system that now results in the cessation of

cadmium contaminated rinse water to sewer;

o A silver recovery unit was installed on the film processing unit in the Non

Destructive Test section to eliminate silver discharges to sewer (SE2).

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o Use of interceptors to reduce significantly the risk of unplanned

emissions to sewer and surface water.

o Revised washing procedures to reduce the quantity of pollutants

discharged to sewer, notably heavy metals;

o Implementation of an Environmental Reaction Plan in the event of a

significant spill or similar.

� Non-hazardous waste management:

o Creation of a non-hazardous waste segregation/ storage compound;

o Increased waste diversion from landfill

o Reuse of waste packaging material from customers

o Reduction from two compactors going to landfill to one compactor

� Hazardous Waste Management:

o Waste segregation units upgraded and extended to other areas

o Diversion of targeted waste streams away from landfill (i.e. aerosol cans,

oil contaminated waste)

o Introduction of the Halon 1301 Recycler (HAL). To ensure safe removal

of Halon 1301 from aircraft fire extinguishers during service

o Introduction of non-flow drag out tanks in the plating shop to replace the

free flowing rinse water system. The drag-out tanks incorporate plate out

& ion exchange filters to remove metals from solutions

o Introduction of a mobile vacuum waste oil unit to remove the waste oil

from the oil drip trays in the garage

o Creation of chemical database

o Reuse of waste Aviation Fuel as a fuel substitute

o Analysis of structural sealant (PR1436) usage showed a large amount of

waste. Sealant now provided in smaller tubes.

� Water Management:

o Implementation of a water management plan

o Installing chiller units on the degreasing tanks to form a closed loop and

eliminate free flow of fresh water to drain

o Fitting automatic valves to hydraulic rigs to switch off water when the rig

is switched off

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o Installing food operated or detector on wash hand basins

o Planned maintenance programme of inspections and leak repairs

Water usage has decreased from 44,000 cubic meters in 2001 to 26,000 cubic

meters in 2004 a reduction of 41%.

� Energy Management: Refer to Section 12 above

� Process Improvements:

o Triklone N (TCE) was phased out and replaced by an alternative product

o Degreasers in plating and APU shops fitted with a range of opening

options to reduce emissions

o Defined and implemented the Tech Washings procedure to give improved

process and monitoring results

o Upgrade/Replace Wax Tank to a more efficient unit in the Plating Shop,

Hangar 1

o Introduction of pre-impregnated sealant wipes (Diestone DLS) to reduce

fugitive emissions

o Improved techniques to reduce aircraft painting overspray by shielding

spray area from drafts

o Improved techniques to capture stripper waste more quickly through

better preparation

� Noise Management:

o Installation of double acoustic air intake louver in Test Cell

o Installation of new Test Cell door with higher acoustic rating

o Sealing all openings in compressor room and closing outside for

emergency exit only

o Repairs to louvers at compressor cooling tower.

� Groundwater Protection:

o Upgraded bunding across the site with a 3-year rolling bund and drain

programme.

o Implementation of a groundwater monitoring programme.

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16. ENVIRONMENTAL MANAGEMENT

Specific elements of environmental management at SR Technics include:

� An Environmental Policy (IPPC Application Attachment number C.1a) has been

created for the facility and it is this policy that acts as a foundation for the EMS.

The Environmental Policy is communicated to the workforce via environmental

notice boards.

� The organisational chart (IPPC Application Attachment number C.1b) shows the

overall organisational structure along with the full environment management

team. Environmental responsibilities are defined in the individual job

descriptions.

� The Environmental Committee: - The Environmental Management System (EMS)

is structured as a decentralised body within the organisation. As part of the EMS

an Environmental Committee has been established which is comprised of key

management, specialists and representatives from each section in the

Organisation. The Committee is headed by the Facilities Maintenance Manager

and is supported by the Environment Officer. The Committee meets on the last

Tuesday of each month with minutes taken and distributed to the attendees and

copied to key managers in areas of potentially high environmental impact.

� SR Technics’s quality system is registered under BS EN 9001:2000, EASA 145

and FAR 145. The Safety and Quality policy is given in the Maintenance

Organisation Exposition (MOE).

� SR Technics also operates a Safety Management System (SMS). This is tasked

with identifying any adverse trends in relation to safety related events or potential

events and with addressing identified deficiencies in the interests of safety.

� Environmental Performance Review: - The overall performance of the facility is

determined based on the monitoring of results, preventive maintenance checks,

waste figures and the progression of the EMP. An Environment and Safety Audit

Checksheet is completed monthly in each area to identify areas of improvement.

� The environmental performance is further analysed by unannounced audits,

visits, sampling and analyses from the Environmental Protection Agency (EPA)

and also from Fingal County Council. The EMS is also supported by the

ISO9001-2000 Internal audit schedule.

17. DECOMMISSIONING

In the unlikely event of cessation of activities on site, SR Technics will complete a

planned programme of decommissioning and incorporating any EPA requirements in this

regard.

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SR Technics expects that the financial provisions for any decommissioning not related to

soil and groundwater will be considered as a normal trading cost.

Regarding known groundwater contamination by the chlorinated solvent TCE and its

breakdown products, it is currently recommended to continue monitoring. Given that SR

Technics is a large multi-national organisation, it is expected that sufficient funds and

resources will be set aside in a manner agreed with the Agency for any future monitoring

that may be required at the time of cessation of activities. Regarding any potentially

unknown soil and groundwater contamination, no such significant contamination has

been detected and this follows two due diligence excercises. However, in the event that

cessation of activities occurs, then SR Technics may consider additional soil and/or

groundwater investigation as part of a closure audit.

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