Operator: Rawlins Crushing and Plant Hire Ltd

Pollution Prevention and Control Act 1999

Environmental Permitting (England and Wales)

Regulations 2007

Environmental Permit for the Operation of an Installation

Autosmart International Limited

Lynn Lane

Shenstone

Staffordshire

WS14 0DH

Manufacture of Coating Materials

Environmental Health

District Council House

Frog Lane

Lichfield

Staffordshire WS13 6ZE

Tel:01543 308725

Fax:01543 308728

Operator:Autosmart International Limited

Lynn Lane

Shenstone

Staffordshire

WS14 0DH

Installation:Manufacture of Coating Materials

Applicant:Autosmart International Limited

Lynn Lane

Shenstone

Staffordshire

WS14 0DH

ContentsPage no.

Environmental Permit...... 1

Definitions...... 4

Installation Description...... 5

Conditions:

Emission Limits...... 10

Emission Monitoring and other provisions...... 13

Control Techniques...... 15

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: PPC87/A/08

Autosmart International Limited, whose registered office is at Lynn Lane, Shenstone, Staffordshire, WS14 0DH (company registration number 1395515), is hereby permitted to carry on an installation as defined in Chapter 6, Section 6.4 Part B(a)(i) and Section 7 Part B(a) 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 Lynn Lane, Shenstone, Staffordshire, WS14 0DH. The site location and installation boundary is shown on Plan 1. The site layout is shown on Plan 2. 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 7 of Schedule 1 of the Environmental Permitting (England and Wales) Regulations 2007.

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  0 °C).
15. " °C" means degrees Celsius (centigrade).
16. "kPa" means kiloPascal (101.3 kPa  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 installation can be divided into 2 areas where significantly different processes occur.

The first, which will be referred to as the ‘Gantry’ is that which blends detergents and then allows the final product to be filled into (usually plastic) containers in a range of sizes from 250ml to 1000litres.

The second, which will be referred to as the ‘Aerosol plant’, is that which blends mostly solvent based products and which are then filled into pressurised metal aerosol containers of 150ml or 400ml in size.

The Gantry area

The gantry is responsible for manufacturing the vast majority, in volume terms, of finished product. There are 16 vessels, of sizes from 500litres to 13,000litres, all but one of which are positioned next to a raised platform (which forms the ‘gantry’ structure). At least 10 filling machines positioned at floor level next to the gantry provides the means of filling the blended product.

Each vessel has at least one mixing device, and is served by one or more extraction systems. The vessels are tailored towards the production of groups of formulations, for example they may be reserved solely for use with solvent based products, or may have a type of mixer suited to emulsion forming.

There are well over 100 different formulations that have to be manufactured on the gantry, and therefore a batch process is employed. The requirement for batches is determined by a stock control system, and such batches are then planned for production on the gantry in a vessel suitable for the formulation, and usually within a 2 week window.

There are around 230 different materials used on the site as a whole. The majority are liquid and are used mainly from 205l barrels, either by adding full drums directly to the processing vessels or by weighing portions on scales. Some of the liquids used often and/or in great volume are stored in bulk tanks, and pumped into vessels through a metering system. Most solid materials tend to be used from 25kg bags.

Waste product from spillages, washdowns and flush through are collected via a drain running alongside the gantry, which empties into a small sump and then gets pumped into a storage tank for collection.

Empty drums are sealed and stored outside until such time as they are collected, either by the original supplier or an approved waste contractor. Other packaging gets compressed and collected in an appropriate waste stream (e.g. cardboard, metal), again for collection by an approved contractor, following our duty of care under Section 34 of the EPA 1990.

The use of extraction systems to capture emissions within this area has two main objectives. Firstly it needs to remove any noxious substances from the vicinity of the operator (for example, harmful concentrations of vapours), as part of our requirements under the CoSHH regulations. Secondly, it has to provide a means of controlling the formation of explosive atmospheres, in order to allow compliance with Dangerous Substances and Explosive Atmospheres (DSEAR) regulations

The Aerosol plant area

The aerosol plant is a contained unit that manufactures its own blends in a dedicated blending room, and then goes on to fill these into aerosols via a single automatic filling line.

Again, a batch system is operated due to the variety of formulations made, along the same planning principles as the gantry. But batch sizes tend to be smaller. The propellant used for all the aerosols is a butane blend. Due to the potential hazards involved, the whole area is controlled as per BAMA (British Aerosol Manufacturers Association) guidance – which draws from applicable regulations (CoSHH, DSEAR etc). This involves 3 extraction systems providing localised and general extraction, covering almost the entire area at all times while the plant is in operation.

Raw materials used here are almost all liquid and weighed from 205l barrels, empty ones of which are treated as per the gantry.

Activities in either areas under the scope of SED

The manufacture of some of the blends manufactured on the Gantry or in the Aerosol plant are activities that can be classified as ‘Manufacture of coating preparations, varnishes, inks and adhesives’, as defined in SED Annex I. For simplicity, and the purposes of this report, such blends will be classed as ‘Coatings’.

Each formulation was reviewed and a decision made as to whether it fell under the definition of a Coating. The table below then shows a comparison of Coating manufacture against all other products in the two facilities for the year 2007

This demonstrates that, in volume terms, 6.6% of product manufactured on site is an activity that falls under the definition in SED.

However, in practice there is little or no distinction actually made when undertaking the activity of manufacturing a coating, against any other formulation made. Thus, to attempt to reconcile VOC usage and losses solely for ‘coatings’ would not be a practical exercise.

In addition to this, the overall aim of the PPC and SED legislation was interpreted as to control pollution with the focus on emissions, and in particular those originating from VOC’s (and particulate matter). Taking this on board, a much higher percentage of activities we undertake involve the use of VOC’s, than those which fall under the definition of a coating.

The table below shows a comparison of activities involving VOC, against those that do not, for the year 2007…

Note: All activities that can be defined as coating manufacture also involve the use of VOC’s.

The decision was therefore made to include all activities that involved the use of VOC’s or which could potentially be a release of particulate matter, within the 2 facilities for the purpose of producing the figures required to demonstrate compliance.

The following two flowcharts demonstrate the gantry and aerosol processes, and identify emission sources.Flowchart: Gantry manufacturing process

Identified emission sources

Key

Flowchart: Aerosol Plant manufacturing process

Identified emission sources

Key

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 1.

1. The reference conditions for emission limitsare 273.15K, 101.3kPa, without correction for water vapour content, unless stated otherwise.

1. The non-VOC emission limits and provisions shown in Table 1 below shall be complied with.

Table 1

1. The operators chosen VOC compliance option is total emission limit values. The VOC total emission limit values and provisions shown in Table 2 (SED Box 6 of Process Guidance Note 6/44(04)) shall be complied with.

1. The annual manual extractive testing referred to in table 2 is subject to an agreement made with the regulator made during the application stage. The agreement is: Annual manual extractive testing is not required subject to; the use of the mass balance ratios calculated in section B2.2,3 of the application, and that the process has not changed in any way that could change these mass balance ratios. The regulator will periodically review the agreement.

1. A Solvent Management Plan (SMP) shall be submitted to the regulator annually to determine compliance with the total emission and the organic solvent input. The SMP provides definitions and calculations to demonstrate compliance with the VOC requirements of the total emission limit values (see Appendix 3). These definitions must be used in all calculations relating to the SMP.

1. The annual SMP shall be calculated on a calendar year basis and submitted within one calendar month of the lapse of each calendar year (e.g. end of January).

Table 2

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 (note: it can be incorporated into the SMP) in the form of a mass balance in order to determine the annual actual consumption of organic solvent (C):

Where: C= I1- O8

I1Total 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 process/activity, is carried out by recording:

(i) The mass of organic solvent contained in raw materials and preparations in the initial stock (IS) at the start of the accounting period; plus

(ii) The mass of organic solvent contained in raw materials and preparations in the purchased stock (PS) during the accounting period.

(iii) Minus the mass of organic solvent contained in raw materials and preparations in the final stock (FS) at the end of the accounting period.

Total Organic Solvent Input (I1) = IS + PS – FS

1. Designated risk phrase materials must be either replaced, controlled or limited as set out in Table 3 (SED Box 7 of Process Guidance Note 6/44(04)).

Table 3

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 provide a list of key arrestment plant and shall have a written procedure for dealing with its failure, in order to minimise any adverse effects.

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.

1. 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. The introduction of dilution air to achieve emission concentration limits is 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. Where the Total Emission Limit Value option is adopted: no result should exceed the emission limits specified, except where either:

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

(b) at least twenty results are obtained where sampling increments of more than 30-minutes are involved

1. Stationary source emissions monitoring of mass concentration of total gaseous organic carbon in flue gases from organic solvent shall be carried out according to the main procedural provisions of continuous flame ionisation detector method EN 13526.

1. 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/m3might 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/m3when the limit is 50 mg/m3might not qualify for a reduction in monitoring.