Solvent Management Plan 2016 for Dulux Paints Ireland Limited Final 31st March 2017

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Document Control

Status Draft Final

Date 29/03/2017 31/03/17

Version # 1 2

Written

Approved

This report has been prepared by Environet Consulting Ireland Ltd, with all appropriate care and diligence within

the terms of the Contract with the client. This Contract incorporates our Terms and Conditions and takes account

of the resources devoted to it by agreement with the client.

We disclaim any responsibility to the client and others in respect of any matters outside the scope of works.

This report is confidential to the client and we accept no responsibility to third parties to whom this report, or any part thereof, is made known. Such parties rely on the report at their own risk.

Dungarvan Business Centre

Fairlane

Shandon

Dungarvan

Co. Waterford

Ireland

Tel: 058-51155

Fax: 058-51231

Email: info@environet.ie

www.environet.ie

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iii

TABLE OF CONTENTS:

1 INTRODUCTION ............................................................................................... 5

1.1 Activity Details ............................................................................................. 5

1.2 Report Preparation ...................................................................................... 5

1.3 Site Description ........................................................................................... 5

1.4 Licence Requirements & Solvent Management ......................................... 6

2 PROCESS DESCRIPTION ................................................................................ 7

2.1 Materials ....................................................................................................... 7

2.2 Emission Sources ........................................................................................ 8

3 SOLVENT EMISSIONS DIRECTIVE ................................................................. 9

3.1 Compliance ................................................................................................ 10

4 SOLVENT MASS BALANCE .......................................................................... 12

4.1 Equation Used ........................................................................................... 12

4.2 Solvent Input (I1) ........................................................................................ 13

4.3 Solvent Input (I2) ........................................................................................ 15

4.4 Licensed Emissions to Atmosphere (O1) ................................................ 15

4.5 Emissions to Waters (O2) ......................................................................... 16

4.6 Solvent in Residue from the Process (O3) ............................................... 16

4.7 Uncaptured Emission of Organic Solvent to Air (O4) ............................. 16

4.8 Organic Solvents Lost Due to Chemical or Physical Reaction (O5) ...... 16

4.9 Organic Solvent in Waste (O6) .................................................................. 16

4.10 Organic Solvent in Product (O7) ............................................................... 17

4.11 Solvent sent for Recovery (O8) ................................................................. 17

4.12 Fugitive Emission Calculation .................................................................. 17

4.13 Compliance with Legislation ..................................................................... 19

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5 METHOD LIMITATIONS ................................................................................. 21

6 SOLVENT REDUCTION PLAN ....................................................................... 22

6.1 Introduction ................................................................................................ 22

6.2 Solvent Reduction Measures .................................................................... 22

6.2.1 Employee Training & Solvent Awareness ............................................ 22

6.2.2 Good Housekeeping .............................................................................. 22

6.2.3 Solvent Substitution .............................................................................. 23

6.2.4 Maintenance ........................................................................................... 23

7 CONCLUSION ................................................................................................ 24

Appendix A – Site Location

Appendix B – Site Layout Plan

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1 Introduction

1.1 Activity Details

Name: Dulux Paints Ireland Limited

Address: Shandon Works, Commons Road, Cork

IPC Licence Number: P0218-01

Activities Licensed: The manufacture of paints, varnishes, resins, inks,

dyes, pigments or elastomers where the production

capacity exceeds 1,000 litres per week

1.2 Report Preparation

This report was prepared on behalf of the operator by Environet Solutions.

Environet Solutions

Dungarvan Business Centre

Dungarvan

Co. Waterford

1.3 Site Description

Dulux Paints Ireland Ltd. (Dulux) is the largest paint manufacturer in Ireland. The

company employs 67 people and normally operates eight hours per day, five days

per week. The company manufactures a range of decorative paints, coatings for

trade and industrial use and a range of wood care products such as stains and

varnishes. William and Stanley Harrington began manufacturing paint and

varnishes on the site in 1885. For many years, the company operated under the

name HGW (Harrington, Goodlass and Wall) Ltd. until 1988 when the site was

fully acquired by ICI (Imperial Chemical Industries), of which Dulux Paints was a

subsidiary. In January 2008, ICI Paints was acquired by AkzoNobel and the

combined businesses mean that AkzoNobel is now the largest paint manufacturer

in the world.

The site is situated approximately 3 km north of the centre of Cork City. A site

location map is included in Appendix A.

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1.4 Licence Requirements & Solvent Management

The IPC Licence in place for the site was issued on 28th August 1997. This licence

was amended by way of Technical Amendment on 21st February 2013 in order to

ensure full compliance with S.I. No. 543 of 2002 (Emissions of Volatile Organic

Compounds from Organic Solvents Regulations, 2002).

These regulations have since been superseded by S.I. No. 565 of 2012 European

Union (Installations and Activities Using Organic Solvents) Regulations 2012.

The Technical Amendment appended the follow conditions to the IPC licence:

5.6 Solvent Management Plan (SMP)

The licensee shall prepare a Solvent Management Plan for the installation

for each calendar year. The organic solvents to be included in the SMP

shall be determined by reference to the definition of an organic solvent in

Council Directive 1999/13/EC. The SMP shall be prepared in accordance

with any relevant guidelines in Schedule 6 of the Solvents Regulations (S.I.

No. 543 of 2002) or as issued by the Agency and shall be submitted as part

of the AER. The licensee shall keep records of the data from which the

reported information was derived and supporting documentation including a

description of the methodology used for data collection.

5.7 Fugitive Emissions of Volatile Organic Compounds

5.7.1 For calendar years where solvent input is between 100 and

1000 tonnes per year, the fugitive emissions limit value from the

activity is 5% of the solvent input.

5.7.2 For calendar years where solvent input is greater than 1000

tonnes per year, the fugitive emissions limit value from the activity is

3% of the solvent input.

Assessment of compliance with these fugitive emission limit values shall be

reported annually as part of the AER.

This Solvent Management Plan is produced in order to comply with Conditions 5.6

& 5.7 of the Technical Amendment.

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2 Facility Details

2.1 Process Description

Paint manufacture on site in general terms can be described as a blending

operation. Pigment, resin and solvent or water are mixed and treated in a mill to

achieve pigment dispersion. Additives including anti skinning agents, anti-foam

and biocides are used to condition and preserve the paint. Ancillary activities on-

site include laboratories, warehousing, tank farm and workshops.

2.2 Materials

The raw materials used in the paint manufacturing process include solids

(powders), solvents, and resins. Solids provide the coating with colour, opacity,

and a degree of durability. Binders are components which form a continuous

phase, hold the solids in the dry film, and cause it to adhere to the surface to be

coated. The majority of binders are composed of resins and drying oils which are

to a great extent responsible for the protective and general mechanical properties

of the film. For viscosity adjustment, solvents are required. Materials that can be

used as solvents include aliphatic and aromatic hydrocarbons, alcohols, esters,

ketones, and esters and ether-esters of ethylene, propylene glycol and water. A

full inventory of organic solvents used by Dulux in 2016 is provided in Table 2.

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2.3 Emission Sources

The primary factors affecting emissions from paint manufacture are the types of

solvents used, and mixing temperature. Emission losses in paint and varnish

manufacture can arise from several steps in the process.

Major emission sources are:

Fugitive losses during mixing of preparations in the manufacturing

process;

Losses during product filling;

Losses during cleaning activities;

Diurnal losses from bulk storage tanks due to atmospheric temperature

and pressure variations;

Losses that occur during tank filling when vapour is displaced by liquid;

Losses from raw materials product clinging to the vessels and equipment.

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3 Solvent Emissions Directive

The European Council Directive (Limitation of Emissions of Volatile Organic

Compounds due to the Use of Organic Solvents in Certain Activities and

Installations) 1999/13/EEC was implemented in Ireland by the Emissions of

Volatile Organic Compounds from Organic Solvents Regulations (S.I. No. 543 of

2002). These regulations have since been superseded by S.I. No. 565 of 2012

European Union (Installations and Activities Using Organic Solvents) Regulations

2012.

The Regulations aim to prevent or reduce direct and indirect effects of emissions

of volatile organic compounds (VOC’s) into the environment and the potential risks

to human health by providing measures and procedures to be implemented for

specified activities and also to phase out the use of more harmful solvents such as

carcinogens, mutagens and those toxic to reproduction.

3.1 Scope of the Assessment

Organic compounds are chemicals containing one or more carbon atoms. The

Industrial Emissions Directive (2010/75/EU) defines organic compounds as; any

compound containing at least the element carbon and one or more of hydrogen,

halogens, oxygen, sulphur, phosphorus, silicon or nitrogen, with the exception of

carbon oxides and inorganic carbonates and bicarbonates’.

An organic compound can be further defined as any compound containing at least

the element carbon and one or more of hydrogen, halogens (e.g.; chlorine, fluorine

or bromine), oxygen, sulphur, phosphorus, silicon, or nitrogen, with the exception

of carbon oxides and inorganic carbonates and bicarbonates. Methane, ethane,

CO, CO2, organometallic compounds and organic acids are generally excluded

from this definition. For hydrocarbon solvents, a vapour pressure of 0.01 kPa at

293,15 ºK grossly corresponds to a boiling point or initial boiling point in the range

215-220ºC.

According to the Directive, Volatile Organic Compounds (VOCs) are functionally

defined as ‘any organic compound as well as the fraction of creosote, having at

293,15 K a vapour pressure of 0,01 kPa or more, or having a corresponding

volatility under the particular conditions of use’. This Industrial Emissions Directive

definition of VOCs is the basis for determining the materials to be included in the

Solvent Mass Balance (Section 4).

The Directive further defines organic solvents as ‘any volatile organic compound

which is used for any of the following:

(a) alone or in combination with other agents, and without undergoing a

chemical change, to dissolve raw materials, products or waste materials;

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(b) as a cleaning agent to dissolve contaminants;

(c) as a dissolver;

(d) as a dispersion medium;

(e) as a viscosity adjuster;

(f) as a surface tension adjuster;

(g) as a plasticiser;

(h) as a preservative’

3.2 Compliance

An installation or activity operating above the solvent consumption threshold will

need to:

Meet an emission limit value (Schedule 2) in waste gases (mg C/Nm3) and

a fugitive emission limit value (percentage of solvent use);

Certain substances classified as carcinogenic, mutagenic or toxic that carry the

Hazard Statements H340, H350, H350i, H360D or H360F or halogenated volatile

organic compounds which are assigned or need to carry the hazard statements

H341 or H351 must be replaced where possible with less harmful substances, and

must comply with separate emission limit values regardless of the overall

compliance method.

Dulux has confirmed that it does not use any solvents with Hazard Statements

H340, H350, H350i, H360D, H360F, H341 or H351.

Under the Second Schedule of the Regulations (S.I. 565/2012) the activity is

defined as:

“Manufacture of coating mixture, varnishes, inks and adhesives”

i.e. Activity number 17 detail the solvent consumption thresholds for Dulux.

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Activity (solvent consumption threshold in tonnes/year)

Threshold (solvent consumption threshold in tonnes/year)

Emission Limit Values in Waste Gases (mgC/Nm3)

Fugitive Emission Limit Values (% of solvent input)

Total Emission Limit Values

Special Provisions

Manufacture of coating mixture, varnishes, inks and adhesives

(> 100)

100-1000

> 1000

150

150

5

3

5% of solvent input

3% of solvent input

The fugitive emission limit does not include solvent sold as part of a coatings mixture in a sealed container.

Table 1: Compliance Requirements

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4 Solvent Mass Balance

4.1 Equation Used

The various solvent inputs and outputs are highlighted below:

Where:

Inputs of organic solvents (I):

I1: The quantity of organic solvents or their quantity in preparations purchased

which are used as input into the process in the time frame over which the mass

balance is being calculated.

I2: The quantity of organic solvents or their quantity in preparations recovered and

reused as solvent input into the process. (The recycled solvent is counted every

time it is used to carry out the activity.)

Outputs of organic solvents (O)

O1: Emissions in waste gases.

O2: Organic solvents lost in water, if appropriate taking into account wastewater

treatment when calculating O5.

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O3: The quantity of organic solvents which remains as contamination or residue in

products output from the process.

O4: Uncaptured emissions of organic solvents to air. This includes the general

ventilation of rooms, where air is released to the outside environment via windows,

doors, vents and similar openings.

O5: Organic solvents and/or organic compounds lost due to chemical or physical

reactions (including for example those which are destroyed, e.g. by incineration or

other waste gas or waste water treatments, or captured, e.g. by adsorption, as

long as they are not counted under O6, O7 or O8).

O6: Organic solvents contained in collected waste.

O7: Organic solvents, or organic solvents contained in preparations, which are

sold or are intended to be sold as a commercially valuable product.

O8: Organic solvents contained in preparations recovered for reuse but not as

input into the process, as long as not counted under O7.

In order to calculate fugitive emissions (F) the following equation is used:

F = I1 - O1 - O5 - O6 - O7 - O8

4.2 Solvent Input (I1)

Dulux uses a stock inventory system for quality control purposes. Under this

system it is possible to accurately calculate the solvent input to the process using

the procurement database and end-of-year stocktake data. Please see Table 2:

Solvent Input below.

VOC Material Solvent Content %

Annual Usage (tonnes)

2A951 190KG 480 40 INTERMEDIATE 48.00% 17,235.45

2A953 185KG 190-172 INTERMEDIATE 33.00% 1,282.05

2F355 190KG 200609 INTERMEDIATE 29.00% 382.51

3S010 BULK 102-0537 ALKYD RESIN SOLUTION 24.80% 33,768.30

3S070 190 KG ANDECAL 07 35.00% 14,976.30

3T117 BULK 101600 48.00% 42,221.60

3X475 170KG WORLEEKYD 9121 45.60% 620.16

3X532 185KG X101-394 PEG ALKYD (PPG) 25.00% 8,463.09

3X644 BULK X102-556 ALKYD OLIGOMER TANK 2.50% 2,649.36

4WA13 1000KG ULTRALUBE XP-11090755 0.45% 0.50

5XD74 200KG H647P LIMA YELLOW OXIDE 23.05% 233.40

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VOC Material Solvent Content %

Annual Usage (tonnes)

5XD75 200KG H6317 LIMA BLACK TINTER 33.56% 950.06

5XD76 200KG H6455 LIMA RED OXIDE 23.01% 156.63

5XD77 200KG H6444 LIMA YELLOW 10G TINTER 33.02% 93.78

5XE59 200KG H6488 LIMA BURGUNDY TINTER 17.39% 79.68

5XH28 200KG H6650 LIMA TINTER JET BLACK 38.84% 1,083.64

5XH34 200KG H665A LIMA TINTER ORG RED 42.93% 652.62

7G010 205KG ETHYLDIGLYCOL 100.00% 1,533.70

7K008 190KG CYCLOHEXANON 100.00% 1,625.00

7L050 157KG EXXSOL D60 100.00% 5,942.70

7L057 BULK SHELLSOL D40/ SPIRDANE D40 100.00% 128,194.60

7L250 205l EXXSOL D120 100.00% 1,087.56

7R003 174KG XYLENE 100.00% 26,653.65

8D024 200KG DURHAM MANGANESE 10% 22.00% 136.87

8D033 1000KG BORCHI OXY-COAT 99.00% 2,563.06

8D194 160KG AN DRAGON LIGAND SOL 66.25% 965.99

8D194 800KG IBC AN DRAGON LIGAND SOLN 65.25% 468.89

8D271 200KG ZIRCONIUM 18% 44.00% 42.65

8D477 1000Kg STRONTIUM 18 58.00% 4,081.69

8D478 1000KG DURHAM CALCUIM 10/C9 46.00% 2,973.67

3X658 190KG X101-561 DRUMS 42.00% 7,092.12

5XA09 180KG ACOTINT SB1 BLUE 25.00% 133.75

5XA13 180KG ACOTINT COLORPASTE SR1 9.10% 34.18

5XA14 190KG ACOTINT SR2 16.90% 99.98

5XA19 500KG ACOTINT SW1 WHITE 9.80% 89.63

5XA21 200KG SEZ ACOTINT MM PASTA SY2 17.29% 118.56

5XD13 180KG ACOTINT SV3 VIOLET 14.30% 36.88

5XD18 200KG LIMA TINTER ORGANIC BLUE 34.80% 413.03

5XG53 200KG LIMA DEC VIOLET TINTER 33.70% 135.27

5XH30 200KG ACOTINT SZ4 DRUM 18.66% 426.80

5XH71 200KG H6303 LIMA ORGANIC YELLOW 30.75% 190.43

5XM76 200KG ACOTINT SY6 YELLOW OXIDE 12.10% 35.85

7A003 167KG N - BUTANOL 100.00% 130.00

8V007 190KG EXKIN 2 /METHYL ETHYL KETOX 100.00% 7,856.81

TOTAL 317,912.46

Table 2: Solvent Input

Therefore, I1 = 317,912 kg

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4.3 Solvent Input (I2)

As solvent is not reused in the process I2 = 0 kg.

4.4 Licensed Emissions to Atmosphere (O1)

Dulux has one main emission to atmosphere (V35) with the following emission

limit values specified under Schedule 1(i) Emissions to Atmosphere of the IPC

Licence.

Maximum flow in any one day: 283,200 m3

Maximum flow rate per hour: 11,800 m3

TA Luft Organics Class I: 20 mg/m3

TA Luft Organics Class II: 100 mg/m3

Total Organic Carbon (as C): 150 mg/m3

Based on quarterly emissions monitoring and the production records for the

emission point in question it has been calculated that the emission of solvent from

emission point V35 was 25.71 kg in 2016.

The VOC emission concentration from release point V35 is calculated using an

averaged value of quarterly monitoring data supplied by an ISO 17025 accredited

external contractor.

The captured mass emission (E) is calculated using the following equation:

E = ECVOC x Q x h x 10‐6

Where:

E = captured mass emission (kg/year)

ECVOC = emission concentration expressed as VOC (mg (VOC)/Nm3)

Q = volume flow (m3/h)

h = operational hours per annum

In 2016, the following values were used to calculate captured mass emissions to

atmosphere:

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ECVOC = 2.55 mg (VOC)/Nm3

Q = 10,987 m3/h

h = 918 hours

Therefore, O1 = 25.71 kg.

Dulux are required under the Solvent Directive regulations to comply with the

Emission Limit Values in Waste Gases 150 mgC/Nm3. Quarterly air emission

monitoring conducted in 2016 measured an average emission of 2.3 mgC/Nm3.

Therefore Dulux is compliant with Emission Limit Values in Waste Gases.

4.5 Emissions to Waters (O2)

There are no process effluent emissions from Dulux and surface water emissions

monitoring has shown no evidence of solvent contamination.

Therefore, O2 = 0 kg.

4.6 Solvent in Residue from the Process (O3)

There is no specific residue from the process on products. Any solvent in the

product is planned to be present in the paint and is accounted for in O7 below.

4.7 Uncaptured Emission of Organic Solvent to Air (O4)

These form all of the fugitive emissions from the plant and have been calculated

by way of mass balance calculation below.

4.8 Organic Solvents Lost Due to Chemical or Physical

Reaction (O5)

Within paint manufacturing, only the physical processes of weighing, mixing,

grinding, tinting, thinning, and packaging take place, and no chemical reactions

are involved. These processes are carried out in large mixing tanks at

approximately room temperature. Therefore due to the nature of paint manufacture

it is not expected that any solvent will be lost in the manufacturing process by way

of chemical reaction.

4.9 Organic Solvent in Waste (O6)

It is expected that a small quantity of residue will be present in drums crushed at

the site. Assuming that each barrel has 0.25% solvent residue it has been

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estimated that the amount of solvent in solid waste for the year of < 25 kg. Since

solvent lost in this way is <0.01% of total solvent input, this figure has been

estimated for the purpose of the mass balance calculation.

Therefore, O6 = 25 kg

4.10 Organic Solvent in Product (O7)

In order to assess this aspect of the mass balance Dulux has carried out extensive

sampling and analysis of its paint products. Much of this information is

commercially sensitive but is available for inspection by the EPA.

In summary, the outcome of the exercise was that for 2016 the total amount of

solvent in all products produced was 293,224.22 kg

Therefore, O7 = 293,224 kg

4.11 Solvent sent for Recovery (O8)

As the solvent sent for recovery has significant commercial value Dulux has a very

reliable figures for this element of the mass balance. Drums of wash solvent are

sent to the UK for reuse on a regular basis. In 2016 Dulux sent a total of 20,400 ltr

wash white spirit to the UK for reuse. In calculating the solvent mass, the following

assumptions were made:

That the solvent content of the wash is 100%;

The specific gravity (SG) of wash white spirit = 0.7715.

20,400 ltr x 0.7715 (SG) = 15,735.6 kg

Therefore, O8 = 15,739 kg

4.12 Fugitive Emission Calculation

Schedule 6 of S.I. No. 565 of 2012 European Union (Installations and Activities

Using Organic Solvents) Regulations 2012 outlines the mass balance equations

for determining the Fugitive and Total mass emissions for the facility.

In order to calculate fugitive emissions (F) the following equation is used:

F = I1 - O1 - O5 - O6 - O7 - O8

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Input/Output Mass (kg)

I1 317,912.46

O1 25.71

O5 -

O6 25.00

O7 293,224.22

O8 15,735.60

Table 3: Summary of Mass Balance Inputs and Outputs

F = I1 - O1 - O5 - O6 - O7 - O8

Therefore, F = 8,901.93 kg

The fugitive emission limit value is expressed as a proportion of the input, which

shall be calculated according to the following equation:

I = I1 + I2

The fugitive emissions value (F) expressed as a proportion of Input

Fugitive Emissions (as % of solvent input) = F/(I1 + I2) x 100%

Therefore, F = 2.80%

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4.13 Compliance with Legislation

Under the Second Schedule of the Regulations the activity defined as

“Manufacture of coating mixture, varnishes, inks and adhesives” (i.e. Activity

number 17) detail the solvent consumption thresholds for Dulux.

Activity

(solvent

consumption

threshold in

tonnes/year)

Threshold

(solvent

consumption

threshold in

tonnes/year)

Emission

Limit

Values in

Waste

Gases

(mgC/Nm3)

Fugitive

Emission

Limit

Values

(% of

solvent

input)

Total

Emission

Limit Values

Special

Provisions

Manufacture of

coating mixture,

varnishes, inks

and adhesives

(> 100)

100-1000

> 1000

150

150

5

3

5% of solvent

input

3% of solvent

input

The fugitive

emission limit

does not

include

solvent sold

as part of a

coatings

mixture in a

sealed

container.

Table 3: Compliance Requirements for the Paint Manufacturing Industry

For assessing compliance with a total emission limit value expressed in solvent

emissions per unit product or otherwise stated in Schedules 2 and 3, the solvent

management plan shall be drawn up annually to determine emissions (E). The

emissions shall be calculated according to the following equation:

E = F + O1

Solvent Input = 317,912.46 kg in 2016. The legislation requires that fugitive

emissions are no greater than 5% of solvent input where solvent consumption is

between 100 t and 1000 t per annum.

Therefore, max Fugitive Emissions Allowed = 15,896 kg per annum.

Calculated Fugitive Emissions = 8,901.93 kg per annum or 2.80% of solvent

input.

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Therefore we can conclude that Dulux is compliant with its Fugitive

Emission Limit Value.

Total emissions (fugitive plus licensed) must also be less than 5% of solvent

input. Total emissions = 8,901.93 + 25.71 kg per annum or 8,927.64 kg.

Total Emissions = 8,927.64 kg per annum or 2.81 % of solvent input.

Therefore we can conclude that Dulux is compliant with its Total Emission

Limit Value.

4.14 Comparison with Previous Years

The results of the mass balance calculation to determine annual Fugitive

Emissions and Total Emissions of VOCs from the facility are in line with results

from previous years. Table 4 summaries calculated VOC emissions from the

facility since 2013.

Year Fugitive Emission (as

percentage of solvent input)

Total Emission (as percentage

of solvent input)

2013 2.9 % 3.2 %

2014 3.7 % 3.8 %

2015 1.5 % 1.5 %

2016 2.8 % 2.8 %

Table 3: Summary Mass Balance Assessment Data 2013-2016

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5 Method Limitations

The mass balance approach to emissions estimation considers a facility as a sort

of black box where the total quantity of solvent in the raw materials consumed as

opposed to the amounts of solvent leaving the facility as product and by-product,

is compared and analysed.

Calculating emissions using mass balance initially appears to be a straightforward

approach to emission estimation. However, few European paint and ink

manufacturing facilities consistently track material usage and waste generation

with the overall accuracy needed for application of this method, and inaccuracies

associated with individual material tracking or other activities inherent in each

material handling stage often accumulate into large deviations of total facility

emissions.

The BAT Reference document Surface Treatment using Organic Solvents August

2007, acknowledges the difficulty with this method. If the difference is calculated

between two almost equal numbers such as ‘solvent input’ and ‘solvent contained

in product’, then the outcome, which should represent the fugitive emissions, is a

relatively small number. The inaccuracy in the resulting small number, however, is

equal to the sum of the inaccuracies in the two original, large numbers. Thus, all

the inaccuracies in the two original numbers are included in the fugitive emissions.

Because fugitive emissions of VOCs from this activity is typically below two

percent of gross consumption, an error of only ± 5 percent in any of the large

inputs or outputs of the operation can significantly skew estimations. Potential

sources of error in the mass balance include the following:

The delivery of bulk raw materials to a facility is often tracked by volume

and not by weight. Since density varies with temperature, the actual mass

per unit volume of materials delivered in the summer may be less than that

received in the winter months;

The raw materials received by a facility may be used in hundreds of

different finished products. In order to complete the mass balance, it is

crucial that the exact quantity and characterisation of each material shipped

off-site that contains organic solvents is known. This involves precise

analysis of the solvent concentration in each product, waste, or recycling

stream.

Batch production of paint often requires the manual addition of raw

materials at the quality control stage. Sometimes these additions are not

accurately measured or recorded.

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6 Solvent Reduction Plan

6.1 Introduction

The application, and release, of volatile organic compounds can, due to their

properties, cause harm to human health and/or contribute to local or

transboundary formation of photochemical oxidants in the boundary layers of the

troposphere, leading to environmental degradation.

The purpose of this section is to identify measures integrated into the production

process for minimising VOC emissions from point and diffuse sources specifically

for manufacturing solvent-based paints and coatings, and to assess these under

the aspects of efficiency and costs.

6.2 Solvent Reduction Measures

6.2.1 Employee Training & Solvent Awareness

Theoretical and practical training in the handling, use and clean-up of solvents and

related equipment is essential for any solvent reduction plan to succeed.

Environmental, economic and health implications are also emphasised.

Written documentation at Dulux for all operations involving the handling or use of

solvents include:

Process manuals to detail the quantities of solvent required, provide health

and safety data and identify the relevant operating procedures;

Operating procedures to explain how to use particular equipment/plant in

conjunction with solvents or coatings.

6.2.2 Good Housekeeping

Dulux implements procedures to:

Always re-lid partly emptied drums or cans of solvent and, where practical,

seal with adhesive tape to prevent vapour losses.

Keep solvent containers away from sources of heat and draughts to

minimise evaporation.

Encapsulate vessels, reservoirs and machinery as much as possible, using

well-fitting sealed lids and covers.

Where vessels and reservoirs do not have proper covers, use anti-static

plastic covers (attached by elastic bands, tyre inner tubes, or nylon hook

and loop fasteners etc.) or Clingfilm. Such covers have the added

advantage of keeping dust and debris out of the mix.

Remove containers of residue solvent from working areas to safe storage

areas on a regular basis to avoid accidental spillage.

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When mixing solvents and coatings pour the least volatile material first and

the most volatile last, thereby reducing losses.

Train operators to adopt a ‘clean as you go’ philosophy. This will prevent

the build-up of stubborn materials and therefore reduce the need for

excessive cleaning at the end of the batch or shift.

Use drop pipes that pass to the bottom of the container to avoid top-filling of

mixing vessels and machine reservoirs. This prevents splashing and

excessive disturbance of the fluid surface, and therefore reduces losses.

Where the filler pipe has to be withdrawn, do this slowly, switching off any

pump first and emptying any remaining solvent that may be contained in the

pipe into the container.

Fit mixing vessels and reservoirs with automatically closing inlet valves to

avoid overfill.

6.2.3 Solvent Substitution

Dulux will engage with suppliers, trade associations and other companies to

identify new products, equipment and processes that either eliminate solvent

consumption, e.g. compliant coatings, or reduce usage.

As a Sustainability driven company, AkzoNobel are continually working towards

the goal of formulating paint that is completely VOC free.

6.2.4 Maintenance

Dulux will further develop their preventive maintenance programme to:

Visually check for leaking flanges, valves, welds, tanks, bunds, etc.

Pressure-test pipelines, tanks, etc.;

Check the tightness of nuts and bolts;

Check for wear and tear on machinery, valves, bunds etc.;

Recalibrate metering systems.

This programme is in place and continuously ongoing. Pressure testing was

completed for 2016 and a certificate is available. Dulux aims to reduce solvent

losses, improve efficiency and product quality, and help to keep the workplace

generally tidy and pleasant.

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7 Conclusion

Dulux has confirmed that it does not use any solvents with Risk Phrases R40,

R45, R46, R49, R60 or R61.

Quarterly air emission monitoring conducted in 2016 measured an average

emission of 2.4 mgC/Nm3, which is significantly below the ELV of 150

mgC/Nm3. Therefore, Dulux is compliant with Emission Limit Values in Waste

Gases.

With regard to both fugitive and total emissions Dulux is compliant with S.I.

No. 565 of 2012 European Union (Installations and Activities Using Organic

Solvents) Regulations 2012.

Mass Balance Calculated Fugitive Emissions = 8,901.93 kg per annum or

2.80% of solvent input. Therefore, we can conclude that Dulux is compliant

with its fugitive emission limit value.

Total emissions (fugitive plus licensed) must also be less than 5% of solvent

input. Total emissions = 8,901.93 + 25.71 kg per annum or 8,927.64 kg.

Total Emissions = 8,927.64 kg per annum or 2.81% of solvent input.

Therefore, we can conclude that Dulux is compliant with its Total Emission

Limit Value.

Fugitive and Total Emissions as a percentage of solvent input are in line with

results from previous annual assessments.

Dulux management and operatives have shown good awareness in relation to

the potential for fugitive emissions of solvent from their activity. Environet is

confident that there is commitment at all levels of the organisation to further

reduce fugitive solvent emissions from the facility.

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Appendix A – Site Location

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Project Solvent Management PlanClient DuluxDrawing Name Site Location ‘Discovery Series’ MapVersion 1Date 23-05-2014

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Appendix B – Site Layout Plan

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