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Solvent Management Plan 2017 for Dulux Paints Ireland Limited Final 6th April 2018
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Document Control
Status Draft Final
Date 31/03/2018 06/04/2018
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: [email protected]
www.environet.ie
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iii
TABLE OF CONTENTS:
1 INTRODUCTION ............................................................................................... 1
1.1 Activity Details ............................................................................................. 1
1.2 Report Preparation ...................................................................................... 1
1.3 Assumptions ................................................................................................ 1
1.4 Methodology ................................................................................................ 2
1.5 Site Description ........................................................................................... 2
1.6 Licence Requirements & Solvent Management ......................................... 2
2 FACILITY DETAILS .......................................................................................... 4
2.1 Process Description .................................................................................... 4
2.2 Materials ....................................................................................................... 4
2.3 Emission Sources ........................................................................................ 5
3 SOLVENT EMISSIONS LEGISLATION ............................................................ 6
3.1 Scope of the SMP Assessment ................................................................... 6
3.2 Compliance .................................................................................................. 7
4 SOLVENT MASS BALANCE ............................................................................ 9
4.1 Equation Used ............................................................................................. 9
4.2 Solvent Input (I1) ........................................................................................ 10
4.3 Solvent Input (I2) ........................................................................................ 12
4.4 Licensed Emissions to Atmosphere (O1) ................................................ 12
4.5 Emissions to Waters (O2) ......................................................................... 13
4.6 Solvent in Residue from the Process (O3) ............................................... 13
4.7 Uncaptured Emission of Organic Solvent to Air (O4) ............................. 14
4.8 Organic Solvents Lost Due to Chemical or Physical Reaction (O5) ...... 14
4.9 Organic Solvent in Waste (O6) .................................................................. 14
4.10 Organic Solvent in Product (O7) ............................................................... 14
4.11 Solvent sent for Recovery (O8) ................................................................. 14
4.12 Fugitive Emission Calculation .................................................................. 15
4.13 Compliance with Legislation ..................................................................... 16
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4.14 Comparison with Previous Years ............................................................. 17
5 METHOD LIMITATIONS ................................................................................. 18
6 CONCLUSION ................................................................................................ 19
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 Assumptions
The following assumptions have been made in order to facilitate the production of
this report:
• It is assumed that all relevant information and material has been provided to
Environet by the client;
• Emissions of organic solvent through licenced (main or minor) emission
points are not considered fugitive emissions, as defined in Article 57(3) of
the Industrial Emissions Directive (2010/75/EU).
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1.4 Methodology
The assessment of the fugitive organic solvent emissions from the Pfizer Grange
Castle facility was carried out having regard to the methodology specified in the
following legislation and best practice guidance documents:
• Industrial Emissions Directive, 2010/75/EU;
• European Union (Installations and Activities Using Organic Solvents)
Regulations, S.I. No. 565 of 2012;
• Air Advice Note No. 1: Good Practice for Solvent Mass Balance and
Fugitive Emission Assessments for EPA Licensed Sites, EPA (2017);
• Guidance on VOC Substitution and Reduction for Activities Covered by the
VOC Solvents Emissions Directive (Directive 1999/13/EC), European
Commission - DG Environment (March 2009).
1.5 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.
1.6 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.
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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 2017 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 Legislation
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 SMP Assessment
The following definitions provided in the Industrial Emissions Directive
(2010/75/EU) were used to compile a list of all organic solvent containing products
at the installation.
Organic Compounds
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’.
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.
Volatile Organic Compounds
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).
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Organic Solvents
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;
(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.)
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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.
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 (kg)
2A951 190KG 480 40 INTERMEDIATE 48.00% 34,119.84
2A953 185KG 190-172 INTERMEDIATE 33.00% 563.31
2F355 190KG 200609 INTERMEDIATE 29.00% 432.39
3S007 BULK 102-0548 ALKYD RESIN SOLUTION 35.00% 0.04
3S010 BULK X102-537 TANK 24.80% 35,297.92
3S070 190 KG ANDECAL 07 35.00% 20,705.15
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VOC Material Solvent Content %
Annual Usage (kg)
3T117 BULK 101600 48.00% 44,008.96
3X532 185KG X101-394 PEG ALKYD (PPG) 25.00% 9,813.25
3X644 BULK X102-556 ALKYD OLIGOMER TANK 2.50% 2,695.17
3X658 190KG X101-561 DRUMS 42.00% 7,113.72
4WA13 1000KG ULTRALUBE XP-11090755 0.45% 13.00
5XA09 180KG ACOTINT SB1 BLUE 25.00% 225.57
5XA11 190 KG SEZ ACOTINT MM PASTA SG1 19.13% 68.87
5XA13 180KG ACOTINT COLORPASTE SR1 9.10% 47.38
5XA14 190KG ACOTINT SR2 16.90% 249.21
5XA18 180KG ACOTINT SV2 MAGENTA 22.75% 7.96
5XA19 500KG ACOTINT SW1 WHITE 9.80% 50.86
5XA20 307KG SEZ ACOTINT MM PASTA SY1 10.46% 12.72
5XA21 200KG SEZ ACOTINT MM PASTA SY2 17.29% 308.22
5XA22 200KG SEZ ACOTINT MM PASTA SY3 8.79% 31.96
5XD13 180KG ACOTINT SV3 VIOLET 14.30% 152.26
5XD18 200KG LIMA TINTER ORGANIC BLUE 34.80% 107.02
5XD74 200KG H647P LIMA YELLOW OXIDE 23.05% 134.19
5XD75 200KG H6317 LIMA BLACK TINTER 33.56% 253.01
5XD76 200KG H6455 LIMA RED OXIDE 23.01% 77.08
5XD77 200KG H6444 LIMA YELLOW 10G TINTER 33.02% 47.55
5XE59 200KG H6488LIMA BURGUNDY TINTER 17.39% 34.40
5XF13 200KG H634X LIMA ALKD N6 ORANGE 32.39% 2.75
5XG53 200KG LIMA DEC VIOLET TINTER 33.70% 88.09
5XH28 200KG H6650 LIMA TINTER JET BLACK 38.84% 178.66
5XH30 200KG ACOTINT SZ4 DRUM 18.66% 1,162.43
5XH34 200KG H665A LIMA TINTER ORG RED 42.93% 290.18
5XH71 200KG H6303 LIMA ORGANIC YELLOW 30.75% 137.98
5XM76 200KG ACOTINT SY6 YELLOW OXIDE 12.10% 241.06
7G010 205KG ETHYLDIGLYCOL 100.00% 2,292.41
7G026 190KG SOLVENON DPM 100.00% 203.77
7K008 190KG CYCLOHEXANON 100.00% 917.00
7L050 157KG EXXSOL D60 100.00% 7,317.42
7L057 BULK SHELLSOL D40/ SPIRDANE D40 100.00% 146,477.38
7L250 205l EXXSOL D120 100.00% 1,438.80
7R003 174KG XYLENE 100.00% 14,698.96
7R005 190KG CAROMAX 18/MACSOL100 100.00% 380.00
8D024 200KG DURHAM MANGANESE 10% 22.00% 87.13
8D033 1000KG BORCHI OXY-COAT 99.00% 3,437.58
8D051 950KG DUR NUODEX COBALT NEO 10 46.00% 144.52
8D194 160KG AN DRAGON LIGAND SOL 66.25% 1,794.98
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VOC Material Solvent Content %
Annual Usage (kg)
8D194 800KG IBC AN Dragon Ligand Soln 66.25% 52.72
8D271 200KG ZIRCONIUM 18% 44.00% 160.95
8D477 1000Kg STRONTIUM 18 58.00% 5,049.25
8D478 1000KG DURHAM CALCUIM 10/C9 46.00% 7,587.64
8E147 200KG EMPIMIN OT75 / AEROSOL OT75 13.00% 82.74
8G002 1000KG MONOPROPYLENE GLYCOL 100.00% 51,302.04
8S063 25KG SEZ BYK-344 52.50% 81.75
8V007 190KG EXKIN 2 /METHYL ETHYL KETOX 100.00% 7,619.60
TOTAL 409,798.78
Table 2: Solvent Input
Therefore, I1 = 409,798.78 kg
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 230.32 kg in 2017.
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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 2017, the following values were used to calculate captured mass emissions to
atmosphere:
ECVOC = 24.1 mg (VOC)/Nm3
Q = 11,627 m3/h
h = 822 hours
Therefore, O1 = 230.32 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 2017 measured an average emission of 21.8 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.
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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
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 2017 the total amount of
solvent in all products produced was 363,140.60 kg.
Therefore, O7 = 363,140.60 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 2017, Dulux also sent obsolete
solvent based raw materials for reuse. An inventory of these items is given in
Table 3 below.
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Material Volume (Litres)
Specific Gravity
Solvent Concentration
Solvent Content (kg)
White Spirit 44,000 0.7715 95% 32,248.70
Worleekyd 9121 1600 0.9010 51% 735.22
101-507 Resin 1600 0.9440 40% 604.16
Total
33,588.08
Table 3: Solvent Input
Therefore, O8 = 33,588.08 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
Input/Output Mass (kg)
I1 409,798.78
O1 230.32
O5 -
O6 25.00
O7 363,140.60
O8 33,588.08
Table 4: Summary of Mass Balance Inputs and Outputs
F = I1 - O1 - O5 - O6 - O7 - O8
Therefore, F = 12,814.78 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
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The fugitive emissions value (F) expressed as a proportion of Input
Fugitive Emissions (as % of solvent input) = F/(I1 + I2) x 100%
Therefore, F = 3.13%
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 5: 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 = 409,798.78 kg in 2017. 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.
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Therefore, max Fugitive Emissions Allowed = 20,489.94 kg per annum.
Calculated Fugitive Emissions = 12,814.78 kg per annum or 3.13% 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 = 12,814.78 + 230.32 kg per annum or 13,045.10 kg.
Total Emissions = 13,045.10 kg per annum or 3.18 % 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 %
2017 3.1 % 3.2 %
Table 6: Summary Mass Balance Assessment Data 2013-2017
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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 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 2017 measured an average
emission concentration of 21.8 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 = 12,814.78 kg per annum or
3.13 % 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 = 12,814.78 + 230.32 kg per annum or 13,045.10 kg.
• Total Emissions = 3.18% 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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