Environmental Protection Unit

Variation Ref:AON.EPU.15440.JDPermit Ref: 70(334)B

Environmental Protection Unit

Pollution Control

SCHEDULE 1 TO VARIATION NOTICE

REFERENCE:

REFERENCE: 70(334)B

Pollution Prevention and Control Act 1999

Environmental Permitting (England and Wales)

Regulations 2010

Company Name:
Paintbox Birmingham Limited
Installation Address: / Registered Office Address:
36-44 Melchett Road,
Kings Norton,
Birmingham,
B30 3HS / 36-44 Melchett Road,
Kings Norton,
Birmingham,
B30 3HS

Contact Details:Birmingham City Council, Environmental Protection

Pollution Control Team, 581 Tyburn Road

Erdington, Birmingham, B24 9RX

Tel: 0121 303 9938Fax: 0121 303 9901

Part I

Introductory Note and Process Description

Introductory Note

Process Description

Part II

Permit Conditions

Section 1

General Conditions

Section 2

Upgrading

Section 3

Emission Limits And Controls

Section 4

Emissions Monitoring

Section 5

Abnormal Emissions

Section 6

Solvent Management

Section 7

Materials Handling And Storage

Section 8

Operating Conditions

Section 9

Management, Training and Maintenance

Part III

Explanatory Note and Appendices

Explanatory Note

Appendix 1

Installation Location

Appendix 2

Installation Layout

Part I

Introductory Note

Permit Holder: /

Paintbox Birmingham Limited

Installation Address: / 36-44 Melchett Road,
Kings Norton,
Birmingham,
B30 3HS
Registered Address of Company: / 36-44 Melchett Road,
Kings Norton,
Birmingham,
B30 3HS
Provenance / Date
Application for Permit Received / 15/09/2008
Application Duly Made / 30/01/2009
Permit Ref 70(334)B Issued / 29/05/2009
Variation AON.EPU.15440.JD Issued / 06/11/2012

Paintbox Birmingham Limited is hereby permitted by Birmingham City Council to carry on a Solvent Activity as prescribed in Schedule 1, Part 2, Chapter 6, Section 7 Part B of The Environmental Permitting (England and Wales) Regulations 2010 as described below namelyother coating activities, including metal, plastic, textile (except rotary screen printing on textile), fabric, film and paper coatingin accordance with the conditions detailed in this Permit.

Date……………..…Signed………………………………………….

Jane Dunsford

Environmental Protection Officer

Contact Details:Birmingham City Council, Environmental Protection Unit,

581 Tyburn Road, Birmingham, B24 9RX

Tel: 0121 303 9938Fax: 0121 303 9901

Process Description

The process involves the preparation and painting of plastic and metal components.

The process begins with the preparation of the surface of the substrate prior to painting.

Firstly abrasion of the parts takes place in the DA booth prior to painting. Abrasion is either by light mechanical abrasion of the surface by hand using abrasive pads or by means of power tools and abrasive pads. Excess dust is then removed from the parts using compressed air lines. The dust created from the DA abrasion process is captured via a bank of extract filters within the booth wall. The filtered air is then vented into the plant. The filters containing the captured dust are replaced based on the operational loading of the production process.

The abraded parts are then moved to the pre-clean area where they are cleaned using solvent wipes and any build up of static is removed using deionising air streams.

The parts are then moved to a spray booth on a conveyor system where the parts receive a coat of primer. The conveyor system is installed between the different areas of the process to move the components automatically from one area to another. Each section of the plant is adjoined to the adjacent section so that the product remains inside the plant as it moves from one area to another. The paint is applied manually using conventional spray guns.Dry filters are present in the floors of the spray booths which capture a proportion of particulates from the solid contents of the paint and lacquer systems. The extracted air is emitted to atmosphere via emission stacks, there are 15 emission stacks in total located as indicated on the plan in Appendix 2. The booths are maintained at negative pressure by means of invertor motor control and pressure monitoring systems, if the booth pressure becomes positive the booth automatically shuts down. The booths are heated by direct gas fired burners.

The parts are then flashed off at low temperature for a specified time to remove the solvent from the paint between spray coats. The flash offs are heated by direct gas fired burners.

The parts then receive a base coat (matt coloured layer), this is then flashed off again to remove the solvent from the paint between spray coats.

A coat of clear gloss lacquer is then applied.

The parts are then moved by a conveyor system to a bake oven where they are baked at high temperature to cure and cross link the paint polymers. The bake ovens are heated by direct gas fired burners.

The parts are then cooled, inspected and polished by hand if required.

There are some variations to this process, the variations being the omission of one or more of the operations described above, or in some cases the addition of one or more layers of paint.

Part II

Permit Conditions

1.0 / General Conditions
1.1 / The requirements of the conditions attached to this permit shall come into effect on the date indicated in the individual condition or if no date is indicated shall take effect forthwith.
1.2 / In relation to any aspect of the activity, and without prejudice to any other condition of this Permit, the activity shall be operated so as to meet the requirements of the Clean Air Act 1993 and Part III of the Environmental Protection Act 1990 and any regulations made thereunder.
1.3 / At all times during which this permit is in force a copy of the permit shall be kept posted at the installation in such a position as to be conveniently read by persons having duties which are or may be affected by the conditions set out in the permit.
1.4 / Permitted activities shall only be carried on within the boundary as indicated by shading on the Installation Location reproduced in Appendix 1 of this Permit.
1.5 / Permitted activities shall only be carried on using the plant and equipment as detailed in the Process Description and on the Installation Layout reproduced in Appendix 2 of this Permit.
1.6 / The best available techniques shall be used to prevent or, where that is not practicable, reduce emissions from the installation in relation to any aspect of the operation of the installation which is not regulated by any other condition of this permit.
1.7 / The operator shall notify the Regulator at least 28 days in advance of any modification to the activity, including ancillary operations within the boundary, or any change in the manner of operation, other than routine maintenance or the fitting of standard replacement parts. Written approval shall be obtained prior to any such change or modification.
2.0 / Upgrading
2.1 / Within 3 months of the date of this permit, emissions of volatile organic compoundsfrom Stack 2 as indicated in Appendix 2 shall be continuously quantitatively monitored and recorded. The continuous emissions monitors shall be fitted with audible and visual alarms set to trigger when the level of volatile organic compound emissions reaches 75% of the emission limit detailed in condition 3.4.
3.0 / Emissions Limits and Controls
3.1 / All emissions to the external air, other than steam or condensed water vapour, shall be free from droplets and from persistent mist and persistent fume.
3.2 / All emissions shall be free from offensive odour outside the site boundary as perceived by the Regulator.
3.3 / Emissions from combustion processes shall not exceed the equivalent of Ringelmann Shade 1, as described in BS 2742:1969.
3.4 / The following emissions limits apply to the stacks in Appendix 2:
Substance / Emission limits / Type of monitoring / Monitoring frequency / Stack Numbers
VOC expressed as total mass of organic carbon / 50mg/Nm3 / Manual extractive testing / Annually / 4
5
7
10
11
13
14
VOC expressed as total mass of organic carbon / 75mg/Nm3 / Manual extractive testing / Annually / 1
2
3
6
8
9
12
15
VOC expressed as total mass of organic carbon / 75mg/Nm3 / Continuous
Quantitative / Continuous / 2
Particulate Matter / 50mg/Nm3 / Manual extractive testing / Annually / 1 -15
3.5 / Reference conditions for the emission limits in condition 3.4 are 273.15K, 101.3kPa, without correction for vapour content.
3.6 / The introduction of dilution air to achieve emission concentration limits is not permitted.
3.7 / Fugitive emissions of solvents shall not exceed 20% of the total solvent input.
4.0 / Emissions Monitoring
4.1 / Sufficient facilities for sampling shall be provided on vents or ducts.
4.2 / Emissions monitoring of particulate matter and VOC’s from stacks 1-15 shall be carried out as specified in condition 3.4.
4.3 / Monitoring and sample provision shall be carried out in accordance with methods described in M1 “Sampling requirements for monitoring stack emissions to air from industrial installations”[1] and M2 “Monitoring of stack emissions to air”[2], or by another method agreed in writing by the Regulator.
4.4 / For periodic measurements at least three readings shall be obtained during each measurement exercise.
4.5 / For continuous monitoring of VOCs, emission limit values shall be considered to be complied with if:

No daily mean of the 30 minute mean emission concentrations exceed the emission limit value, and
No 30 minute mean emission concentration exceedstwice the emission limit.

4.6 / All continuous monitoring readings shall be on display to appropriately trained operating staff.
4.7 / Continuous monitoring instruments shall be fitted with audible and visual alarms situated appropriately to warn the operator of arrestment plant failure or malfunction. The activation of alarms shall be automatically recorded.
4.8 / All continuous monitors shall be operated, maintained and calibrated in accordance with the manufacturers’ instructions and these records shall be made available for inspection.
4.9 / All continuous emissions monitors shall be designed to have no greater than 5% downtime. A manual or automotive procedure shall be in place to detect instrument malfunction and to monitor instrument availability.
4.10 / The Regulator shall be advised at least 7 days in advance of any non-continuous monitoring, together with the provisional time and date of monitoring, pollutants to be tested and the methods to be used. These methods shall be approved by the Regulator.
4.11 / The results of non-continuous monitoring shall be forwarded to the regulator within 8 weeks of the completion of the sampling.
4.12 / Where any emission measurement exceeds the emission concentration limits specified in condition 3.4 the operator shall conduct an investigation as soon as the results are 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 to rectify the situation
Re-test to demonstrate compliance as soon as possible; and
Notify the regulator

5.0 / Abnormal Emissions
5.1 / All spillages shall be cleared immediately.
5.2 / In the event of any abnormal emissions, malfunction or breakdown leading to abnormal emissions the operator shall:

Investigate immediately and take corrective action
Adjust the process or activity to minimise those emissions, and
Promptly record the events and actions taken

5.3 / The regulator shall be informed without delay if there is an incident or emission that is likely to have an effect on the local community or
in the event of the failure of key arrestment plant.
5.4 / Any activity shall be suspended in cases of non-compliance where emissions cause immediate danger to human health, taking into account the quantities and toxicities of substances released, the location of the installation and the sensitivity of receptors.
6.0 / Solvent Management
6.1 / 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. The determination of solvent consumption shall be in the form of a mass balance calculation to determine the annual actual consumption of organic solvent. The determination of Solvent Consumption shall be carried out in accordance with Process Guidance Note 6/23 (11). The information submitted shall include a detailed list of the types of all coatings, diluents and cleaning materials used. The inventory (Solvent Management Plan) shall be forwarded to the regulator by the end of April each year and shall cover the period from 1 April to 31 March.
6.2 / A programme to monitor and record the consumption of organic solvents against product produced shall be used to minimise the amount of excess organic solvent used. The regulator shall be provided with a copy of the programme on an annual basis.
6.3 / Cleaning operations involving organic solvents shall be periodically reviewed at least every two years to identify opportunities for reducing VOC emissions. The Regulator shall be provided with a report of the conclusions of the review.
6.4 / Designated risk phrase materials[3]shall not be used in the process.
6.5 / The operator shall submit details for approval to Birmingham City Council’s Environmental Protection Unit any proposal in relation to any of the following activities:

Replacement of low or no VOC solvent degreasing systems with conventional high VOC content degreasing systems;
Introduction of conventional high VOC content degreasing systems into the process;
Introduction of conventional high VOC content degreasing systems onto products where it was not previously used;
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.

7.0 / Materials Handling and Storage
7.1 / Drums of organic solvent containing material shall be stored in closed storage containers, in a secure and well ventilated storage area. The storage area shall be in an impervious bunded area which is resistant to the liquids in storage and which is capable of holding 110% of the capacity of the largest organic solvent storage vessel contained within.
7.2 / Empty drums and containers contaminated with organic solvent shall be labelled as to the nature of their contents and shall be stored tightly lidded.
7.3 / Empty drums or drums containing solvent contaminated waste shall be stored in a secure and well ventilated area.
7.4 / All reasonably practicable efforts shall be made to minimise the amount of residual organic solvent bearing material left in drums and other containers after use. All organic solvent contaminated waste shall be stored in closed containers.
7.5 / Used wipes and other items contaminated with organic solvent shall be placed in a suitably labelled metal bin fitted with a self-closing lid.
7.6 / All potentially odorous waste materials shall be stored in suitable closed containers or bulk storage vessels.
7.7 / All vessels or containers containing organic solvents shall be lidded or enclosed when not in use and the period that the vessel or container is open for use shall be kept to a minimum.
7.8 / Emissions from the emptying of mixing vessels and transfer of materials shall be adequately contained, preferably by the use of closed transfer systems. This may be achieved by the use of closed mobile containers, containers with close-fitting lids, or, preferably, closed containers with pipeline delivery.
7.9 / Application of cleaning solvents shall be:
• from a contained device or automatic system when applied directly on to machine rollers;and
• dispensed by piston type dispenser or similar contained device, when used on wipes.
7.10 / When organic solvent is used on wipes:
• pre-impregnated wipes should be held within an enclosed container prior to use.
• where practicable no organic solvent cleaning fluids or significantly less volatile organic solvents cleaning fluids should be used (with or without the addition of mechanical, chemical or thermal enhancements).
7.11 / Dusty wastes shall be stored in closed containers and handled in a manner that avoids emissions.
8.0 / Operating Conditions
8.1 / All appropriate precautions shall be taken to minimise emissions during start-up and shutdown.
8.2 / Where practicable, fixed equipment shall be cleaned in-situ, and such equipment shall,where practicable, be kept enclosed whilst cleaning is carried out.
8.3 / Where equipment is cleaned off-line (such as screens, plates, drums, rollers and coating trays) cleaning shall be carried out using enclosed cleaning systems, wherever possible. Enclosed cleaning systems shall be sealed to prevent emissions whilst in operation, except during purging at the end of the cleaning cycle. If this is not practicable emissions shall be contained and vented to abatement plant where necessary.
8.4 / Residual coating materials contained in parts of the application equipment shall be removed prior to cleaning.
8.5 / Dry sweeping of dusty materials shall not be permitted.
8.6 / Dusty wastes shall be stored in closed containers.
8.7 / Suitable organic solvent containment and spillage equipment shall be readily available in all organic solvent handling areas.
9.0 / Management, Training and Maintenance
9.1 / The operator shall maintain a statement of training requirements for each operational post and shall keep a record of the training received by each person whose actions may have an environmental impact.
9.2 / Appropriate staff shall receive formal training and instruction in their duties relating to control of the activity and emissions to air. Particular emphasis shall be given to training for start-up, shutdown and abnormal conditions.
9.3 / Plant and equipment shall be operated and maintained in accordance with the manufacturer’s recommendations.
9.4 / A written maintenance programme shall be kept in relation to pollution control equipment, and this shall be available to the Regulator upon request.
9.5 / Stacks and ductwork shall be cleaned as part of the routine maintenance programme.
9.6 / Details of plant and equipment inspections, servicing and maintenance shall be recorded.
9.7 / The process operator shall provide a list of key abatement plant and shall have a written plan for dealing with its failure.
9.8 / Chimneys, flues and ductwork shall be adequately insulated to minimise the cooling of gases and prevent liquid condensation.
9.9 / Stacks or vents shall not be fitted with any restriction at the final opening such as a plate, cap or cowl.
9.10 / An adequate supply of spares and consumables shall be held on site, or should be available at short notice from guaranteed suppliers, so that plant breakdowns can be rectified rapidly.
9.11 / A high standard of housekeeping shall be maintained.
9.12 / The process operator shall ensure that adequate management systems are devised and maintained to ensure compliance with this Permit. These systems may involve the adoption of recognised published standards such as ISO 14001 or EMAS, or alternatively may comprise a system devised in-house.
9.13 / All records and documentation referred to in this Permit shall be recorded in an easily retrievable format. These records shall be retained by the operator for a minimum of two years and shall be made available to the Regulator for inspection upon request. A summary of these documents is as follows:

Results of all non-continuous monitoring and continuous monitoring
Quantity of solvent use
Solvent Management Plan
Maintenance programme and maintenance records
Details of any malfunction/breakdown incorporating the cause, effect and any corrective action taken
Management systems
Training Records
Cleaning Review
List of key abatement plant

Part III

Environmental Protection Unit