Pollution Prevention and Control Act 1999

Environmental Permitting (England and Wales)

Regulations 2007

Environmental Permit for the Operation of an Installation

Maier UK Limited

Chasewater Heath Industrial Estate

Attwood Road

Burntwood

Staffordshire

WS7 8GJ

VOC Coating Process

Environmental Health

District Council House

Frog Lane

Lichfield

Staffordshire WS13 6ZE

Tel: 01543 308725

Fax: 01543 308728

Operator: Maier UK Limited

Chasewater Heath Industrial Estate

Attwood Road

Burntwood

Staffordshire

WS7 8GJ

Installation: VOC Coating Process

Applicant: Maier UK Limited

Chasewater Heath Industrial Estate

Attwood Road

Burntwood

Staffordshire

WS7 8GJ

Contents Page no.

Environmental Permit 1

Definitions 4

Installation Description 5

Conditions:

Emission Limits 6

Emission Monitoring and other provisions 6

Solvent Emissions Directive 8

Control Techniques 11

Site Plans

Explanatory Notes Appendix 1

Appeals……………………………………………………………. Appendix 2

SED Mass Balance Calculation Definitions………………….…Appendix 3

ENVIRONMENTAL PERMIT OF INSTALLATION UNDER:

POLLUTION PREVENTION AND CONTROL ACT 1999

ENVIRONMENTAL PERMITTING (ENGLAND AND WALES) REGULATIONS 2007

ENVIRONMENTAL PERMIT Ref. No: PPC62/C/00

Maier UK Limited, whose registered office is at Chasewater Heath Industrial Estate, Attwood Road, Burntwood, Staffordshire, WS7 8GJ (company registration number 3758650), is hereby permitted to carry on an installation as defined in Chapter 6 Section 6.4 Part B(a)(iv) and Section 7 Part B of Schedule 1 of the Environmental Permitting (England and Wales) Regulations 2007 (as amended), in accordance with the conditions set out in this environmental permit.

The installation hereby permitted is located at Chasewater Heath Industrial Estate, Attwood Road, Burntwood, Staffordshire, WS7 8GJ. The site location is shown on Plan 1 and Plan 2. The site layout and installation boundary are shown on Plan 3. These plans are appended to and form part of this environmental permit.

This environmental permit shall not be taken to permit the operation of any other installation, including any other installation falling within the definition in Chapter 6, Section 6.4 and Section 7 of Schedule 1 of the Environmental Permitting (England and Wales) Regulations 2007 (as amended).
DEFINITIONS

1.  "day" means any period of 24 consecutive hours commencing at midnight.

2.  "hr" means hour.

3.  "m" means metre.

4.  "mm" means millimetre.

5.  "m²" means square metre.

6.  "m³" means cubic metre.

7.  “m/s” and “ms-1 ” both mean metres per second

8.  "g" means gram.

9.  "kg" means kilogram.

10.  "mg" means milligram.

11.  “mg/m3 ” and “mgm-3 ” both mean milligram per cubic metre.

12.  "l" means litre.

13.  “g/l” and “gl-1 ” both mean grams per litre

14.  "K" means Kelvin (273K º 0 °C).

15.  " °C" means degrees Celsius (centigrade).

16.  "kPa" means kiloPascal (101.3 kPa º 1 atmosphere pressure).

17.  "abnormal emission” means an obvious or excessive emission typically causing an observable pollutant plume or haze. The final arbiter of whether an emission is abnormal will be the Local Authority inspector.

18.  "coating material" includes paint, varnish, lacquer, dye, any metal oxide coating, any adhesive coating, any elastomer coating and any metal or plastic coating.

19.  "duct" includes enclosed structures through which prescribed substances for air may be conveyed.

20.  "organic solvent" means any organic liquid which, at 101.3 kPa and 293K (20 °C), is used or acts as a dissolver or dispersion medium, viscosity adjuster, or for cleaning operations.

21.  “plant” means machinery, equipment and any other devices used in the operation of the prescribed process. For crushing and screening processes, plant includes crushers, screens, excavators, front end loaders, back actors, loading shovels, and dump trucks plus any other equipment which feeds the crushers and screens and moves pre- and post-processed materials.

22.  "process vent" includes open termination of ducts.

23.  "stack" includes structures and openings of any kind through or from which prescribed substances for air may be emitted.

24.  "volatile organic compound (VOC)" shall mean any organic compound 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. For the purpose of the Solvents Emissions Directive, the fraction of creosote which exceeds this value of vapour pressure at 293.15 K shall be considered as a VOC.

25.  “SED or Solvent Emissions Directive’’ is the ‘COUNCIL DIRECTIVE 1999/13/EC of 11 March 1999 on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations’.


INSTALLATION DESCRIPTION

The process involves the use of volatile organic compounds in the coating of plastic components for the automotive industry.

Injection moulded components are spray coated using a High Pressure Low Volume (HVLP) system on an automated production line comprising a sequence of booths for applying primer, basecoat and clearcoat layers. These booths are all water wash systems located in enclosed pressurised areas within the factory and exhaust to atmosphere. Sprayed components enter a flash off area and curing oven following each coating, the exhaust from these 3 flash off areas and 3 ovens being served by an incinerator which is itself exhausted to atmosphere.

Some components have a dedicated coating line which exhausts to atmosphere via two roof mounted stacks.

CONDITIONS

Emission Limits

  1. All releases to air, other than condensed water vapour, shall be free from droplets and persistent visible emissions.
  1. There shall be no offensive odour beyond the site boundary, as shown on Plan 3.
  1. The reference conditions for emission limits are 273.15K, 101.3kPa, without correction for water vapour content, unless stated otherwise.
  1. The emission limits and provisions shown in Table 1 below shall be complied with.

Table 1

Substance / Source / Emission limit / provision / Type of monitoring / Monitoring frequency
Particulate matter / Plant extraction system stacks / 50 mg /Nm3 as 30 minute mean for contained sources / See conditions 15 to 20 inclusive. / Annual
  1. As a SED installation, the operator has opted for the reduction scheme compliance route. Therefore this permit contains no VOC emission limits. The operator shall comply with the reduction scheme conditions and other SED requirements contained in the ‘Solvent Emission Directive’ section of this permit.

Emission Monitoring and other provisions

  1. The operator shall keep a logbook containing records of inspections, tests and monitoring, including all non-continuous monitoring, inspections and visual assessments. The logbook shall be kept on site and made available for the regulator to examine. Records shall be kept by the operator for at least two years.
  1. The operator shall notify the regulator at least 7 days before any periodic monitoring exercise to determine compliance with emission limit values. The operator shall state the provisional time and date of monitoring, pollutants to be tested and the methods to be used.
  1. The results of non-continuous emission testing should be forwarded to the regulator within 8 weeks of the completion of the sampling.
  1. Adverse results from any monitoring activity (both continuous and non-continuous) shall be investigated by the operator as soon as the monitoring data has been obtained/received. The operator shall:

• identify the cause and take corrective action;

• record as much detail as possible regarding the cause and extent of the problem, and the action taken by the operator to rectify the situation;

• re-test to demonstrate compliance as soon as possible; and

• notify the regulator.

10. In the case of abnormal emissions, malfunction or breakdown leading to abnormal emissions the operator must:

• investigate immediately and undertake corrective action;

• adjust the process or activity to minimise those emissions; and

• promptly record the events and actions taken.

  1. The regulator must be informed without delay if there is an emission that is likely to have an effect on the local community.
  1. All appropriate precautions must be taken to minimise emissions during start-up and shutdown.
  1. The introduction of dilution air to achieve emission concentration limits must not be permitted.
  1. Dilution air may be added for waste gas cooling or improved dispersion where justified, but this must not be considered when determining the mass concentration of the pollutant in the waste gases.
  1. Calibration and compliance monitoring shall meet the following requirements as appropriate. No result shall exceed the emission concentration limits specified, except where either:

(a) data is obtained over at least 5 sampling hours in increments of 30-minutes or less; or

(b) at least 20 results are obtained where sampling time increments of more than

30-minute are involved; AND in the case of (a) or (b)

(c) no daily mean of all 30-minute mean emission concentrations shall exceed the specified emission concentration limits during normal operation (excluding start-up and shut-down); and

(d) no 30-minute mean emission concentration shall exceed twice the specified emission concentration limits during normal operation (excluding start-up and shut-down).

  1. Calibration and compliance monitoring for all substances shall be carried out using the following method, or a method which can be demonstrated to be equivalent to that stated: Non-continuous emissions monitoring of particulate matter shall be carried out according to the main procedural provisions of BS ISO 9096:2003, with averages taken over operating periods excluding start-up and shutdown.
  1. Where non-continuous quantitative monitoring is required, the frequency may be varied. Where there is consistent compliance with emission limits, regulators may consider reducing the frequency. When determining “consistent compliance” factors to consider include:

(a) the variability of monitoring results, for example, results which range from 15 – 45 mg/Nm3, against an emission limit of 50 mg/Nm3 might not qualify for a reduction in monitoring; and

(b) the margin between the results and the emission limit, for example, results which range from 45 - 50 mg/Nm3 when the limit is 50 mg/Nm3 might not qualify for a reduction in monitoring.

  1. Consistent compliance shall be demonstrated using the results from at least:

• three or more monitoring exercises within two years; or

• two or more monitoring exercises in one year supported by continuous monitoring.

  1. Regulators, when considering reducing non-continuous monitoring frequencies shall take any significant process changes, which might have affected the monitored emission, into account.
  1. The frequency of non-continuous quantitative monitoring shall be increased, for example, as part of the commissioning of new or substantially changed activities, or where emission levels are near to or approach the emission concentration limits.
  1. Care is needed in the design and location of sampling systems in order to obtain

representative samples. The operator shall ensure that adequate facilities for sampling are provided on vents or ducts. Sampling points on new plant shall be designed to comply with the British or equivalent standards.

Solvents Emission Directive

  1. The reduction scheme shall be complied with. Solvent Management Plans (SMP) shall be completed to determine compliance with the reduction scheme. The SMP shall be submitted to the regulator within a month of the due date. The SMP provides definitions and calculations to demonstrate compliance with the VOC requirements of the reduction scheme (see Appendix 3). These definitions must be used in all calculations relating to the SMP.
  1. Solvent Management Plans shall be completed annually AND three monthly from the date of this Environmental Permit.
  1. The operator has chosen to use the SED Reduction Scheme to achieve emission reductions to a “Target Emission” equivalent to those, which would have been achieved if the concentration emission limits, had been applied. The operator shall forward an emission reduction plan (as part of the SMP), which includes in particular:

• decreases in the average solvent content of the total input; and/or

• increased efficiency in the use of solids to achieve a reduction of the total emissions from the installation.

  1. The Target Emission for an installation shall be calculated as follows;

(a) The Total Mass of Solids in the quantity of coating consumed in a year is determined.

– solids are all materials in coatings that become solid as a result of curing, polymerisation, or the evaporation of the water or solvent

– all ingredients other than water and organic solvents should be assumed to form part of the solid coating

(b) Table 2 Target Emission Values must then be used to determine the Target Emission.

Table 2: Target Emission Values

  1. Compliance with the Reduction Scheme is achieved if the annual actual solvent emission determined from the Solvent Management Plan is less than or equal to the Target Emission. The annual actual solvent Emission for an installation shall be calculated as follows:

Annual actual solvent emission = I1-O8-O7-O6 (see Appendix 3)

  1. The flexibility inherent in this compliance route shall not be taken to encourage:

• the replacement of a low or no organic solvent coating system with a conventional high organic solvent coating system; or

• the introduction of such a conventional high organic solvent coating system into a activity; or

• the introduction of such a conventional high organic solvent coating system onto a product where it was not in use before; or

• the introduction of high solids formulations which have no beneficial effect on the product but increase the solids used, except where a reduction in the overall VOC emissions can be demonstrated.

The regulators shall be given prior notification of any proposal to introduce such systems, which shall include reasons why lower organic solvent systems are not considered technically appropriate or practicable.

  1. A determination of the organic solvent consumption, the total mass of organic solvent inputs minus any solvents sent for reuse/recovery off-site, shall be made and submitted to the regulator annually (as part of the Solvent Management Plan) in the form of a mass balance in order to determine the annual actual consumption of organic solvent (C):

Where: C= I1- O8

I1 Total quantity of organic solvents, or their quantity in preparations purchased which are used as input into the process/activity.

A calculation of the purchased organic solvent Input ( I1) to the activity, is carried out by recording:

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

(ii) The mass of organic solvent contained in coatings, diluents and cleaners in the purchased stock (PS) during the accounting period; minus