Attachment N" E.l.A(a) - Details of Emissions to Atmosphere

Emissions to atmosphere fi-om point sources occur from a number of areas at SR Technics, largely:

Emissions fi-om painting activities; Emissions from plating activities; Emissions from component cleaning activities (including organic solvent degreasing); Boilers; General aircraft maintenance; Component testing; Engineering workshops; Airport automobile maintenance (Garage).

A list of emissions to air is presented in Table Att.E. I

Request for change of monitoring frequency: It is requested to change the frequency of monitoring of emission point A9 (chrome Scrubber) fi-om quarterly to biannually. This request is based on premise that in the previous three years monitoring results the levels of Class I11 Inorganic Dust Particles has been less than 0.04mgll (ELV of 5mgll).

\ Receiver 1 5 DEC 28%

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Table Att.E.l- List of Emission Points to Atmos~here

I A7 I H3 CLEANING SHOP SOLVENT CLEANER I MINOR I 300 8.00

A3 A4 A5 A6

H3 CLEANING SHOP PAINT STRIPPER H3 CLEANING SHOP ALKALINE CLEANER H3 CLEANING SHOP ALKALINE CLEANER H3 CLEANING SHOP ALKALINE CLEANER

A8 A9 A1 0 A1 I A1 2 A1 3 A1 4 A1 5

MINOR MINOR MINOR MINOR

H3 CLEANING SHOP ALKALINE CLEANER H I PLATING SHOP CHROME SCRUBBER H I PLATING SHOP CAUSTIC CHROME STRIP H I PLATING SHOP NOT IN USE

A1 6 A1 7 A1 8

H I PLATING SHOP ROOF FAN H I PLATING SHOP NOT IN USE H I PLATING SHOP ZINC PHOSPHATE H I PLATING SHOP CADMIUM PLATING

A1 9 A20 A2 1 A22

300 300 300 300

MINOR MAIN

MINOR

H I PLATING SHOP ROOF FAN NOT IN USE H I PLATING SHOP NOT IN USE H I PLATING SHOP DEGREASER

A23 A24 A25

8.00 8.00 13.00 8.00

MINOR

MINOR MINOR

H I PLATING SHOP NICKLE PLATING H I PLATING SHOP DE-WAX TANK H I PLATING SHOP WAX TANK H I PLATING SHOP MISCELLANEOUS BENCH

A26A A26B

300 450 300

MAIN

H I PLATING SHOP VAPOUR BLAST NOT IN USE H I PLATING SHOP NOT IN USE H I PLATING SHOP SULPHURIC ACID EXTRACT

8.00 9.55 4.10

300 300

MINOR MINOR MINOR MINOR

H I PLATING SHOP HCLlCHROMlC PASSlVATlON H I PLASMA FLAME SPRAY

4.80 6.20

180

MINOR

MINOR

7.09 450 300 300

MINOR MINOR

5.20 5.20 5.20

300 5.50 300

300x300 5.20 10.50

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A2 7 A28

A29

H1 PLATING SHOP NOT IN USE H I PLATING SHOP NOT IN USE H1 MACHINE SHOP WET SPRAY SYSTEM NOT IN USE H1 MACHINE SHOP WET SPRAY SYSTEM NOT IN

MINOR

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I I H I WHEEL & BRAKE NDT WET RINSE BOOTH FOR I I I I I A50 A51

I A56 I H6 KARCHER WATER HEATER I MINOR I 350 3.70

A52 A53 A54 A55

FLUORESENT PENETRANT H I WHEEL & BRAKE CLEANING SHOP

I A63 I H6 AHU C BOILER No.1 NOT IN USE

H5 HYDRAULICS SHOP H I WHEEL & BRAKE NDT POWDER BOOTH H I COMBINED DISCHARGE FROM A50, A51 ,A53 APU TEST CELL

A57 A58 A59 A60 A6 1 A62

MINOR MINOR

I A75 I H3 SPACE HEATER 1 MINOR I I2000x2000 I 8.70

MINOR MINOR MINOR MINOR

H6 RENDAMAX BOILER No.2 H6 RENDAMAX BOILER No.1 H6 AHU A BOILER No.1 NOT IN USE H6 AHU A BOILER No.2 NOT IN USE H6 AHU B BOILER No.1 NOT IN USE H6 AHU B BOILER No.2 NOT IN USE

A64 A65 A66 A67 A68 A69 A70 A7 1 A72 A73 A74

450x300 450x300

9.50 9.50

300 300

MINOR MINOR

H6 AHU C BOILER No.2 NOT IN USE H6 AHU D BOILER No.1 NOT IN USE H6 AHU D BOILER No.2 NOT IN USE GA GARAGE BOILER H3 KARCHER WATER HEATER H5 BURNTWOOD HEATER H3 CLEANING SHOP WATER HEATER H3 SPACE HEATER H3 SPACE HEATER H3 SPACE HEATER H3 SPACE HEATER

450x300 5000x5000

500 500

MINOR MINOR MINOR MINOR MINOR MINOR MINOR MINOR

2.20 9.50 9.50 12.20

26.10 26.10

400 150 200 350

2000x2000 2000x2000 2000x2000 2000x2000

7.00 5.50 6.00 9.00 8.70 8.70 8.70 8.70

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A77 A78 A79 A80 A8 1 A82

H6 DUST BOOTH H6 DUST BOOTH

A83 A84

GA DOMESTIC HOT WATER BOILER H4 SPACE HEATING H4 SPACE HEATING APU TEST CELL BOILER

A85 A86 A87 A88 A89

MINOR MINOR

GA FACILITIES WELDING EXTRACT GA BATTERY CHARGING SHOP EXTRACT

A90 A9 1

MINOR MINOR MINOR MINOR

H5 AMOSS WELDING EXTRACT H I APU PAINT BOOTH H3 SHEETMETAL SHOP CUTTINGIGRINDING H5 HOT AIR FURNACE GA VEHICLE FUME EXTRACT SYSTEM

600 600

MINOR MINOR

H2 SANDING BOOTH COMPOSITE SHOP H3 KEW PRESSURE WASHER

3.80 3.80

1 50 400 400

MINOR MINOR MINOR MINOR MINOR

1 50 300

MINOR MINOR

300 2.00 2.40

400 600 400 400

7.00 15.50 15.50 2.40

6.40 5.00 4.75 8.00

150 4.3

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SR Technics has designated the emissions to atmosphere as 'main' emissions, others as 'minor' emissions and finally there are a number of 'potential' emissions.

Due consideration for the EPA IPPC Application Guidance note was made in determining what emissions should be considered 'main' or 'minor'. From this exercise, the following is noted:

1. SR Technics have declared three new emission points, A44, A45 and A46. Refer to.the listing above for details on these emission points. Whilst actual available monitoring data for VOC's indicates generally low VOC emissions from these emission points, the possibility to emit higher concentrations is possible and so the emission points were considered 'main' emissions;

2. Whilst maintained as a 'main' emission, monitoring on emission point A9 (chrome plate scrubber discharge) has indicated, particularly in the last two years, discharge of chrome containing particulate matter below detection of limit. Given the very low emissions of pollutants from this emission point, this emission point was excluded from the dispersion model;

3. 'Potential' emission points also include those emission points that are no longer in use. Whilst there are no plans to re-commission these emission points for the function as detailed in Table E. 1 (v), this cannot be discounted in the case of each such emission point. If emission point(s) is (are) re- commissioned, the Agency will be notified accordingly with a change in status of designation.

Main emissions are mainly related to painting and degreasing activities. Details on main Tables E. 1 .(ii) & (iii)

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Attachment N % . l . ~ ( b ) - Assessment of Solvents Directive (1999/13/EC)

Council Directive 199911 3lEC on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations (the Solvent Directive) requires an installation to comply with either the emission limit values in waste gases and the fugitive emission values or the total emission limit values, or alternatively the requirements of a reduction scheme. The relevant values are an emission limit value of 50mg c/iVm3 in waste gas emissions and a fugitive emission value (percentage of solvent input) of 20%. These emission limit values have also been referenced in the Irish EPA Draft BAT Note on Solvent use in Coating, Cleaning and Degreasing (specifically In the case of the reduction scheme the Directive sets target ratios of solvents emittedlsolids used in the process, the aerospace sector target being set at 3.5 by 2005 and 2.33 for 2007.

In 2003, in a submission to the EPA, a sector group representing three companies in the Irish Aerospace maintenance business, which includes SR Technics, presented detail on a exemption possibility fiom the above emission limit values for aircraft painting activities. The exemption is detailed as follows:

Note 4 of Activity 8 of Annex IIA states; coating activities which cannot be applied under contained conditions (such as shipbuilding, aircraft painting) may be exemptedfiom these values in accordance with Article 5 (3) (b). In this case, the 'values' are the aforementioned emission limit values. Article 5(3)(b) of the Directive states that Activities which cannot be operated under contained conditions may be exempted from the controls of Annex IIA, when this possibility is explicitly mentioned in that Annex. The reduction scheme of Annex IIB is than to be used, unless it is demonstrated to the satisfaction of the competent authority that this option is not technically and economically feasible. In this case, the operator must demonstrate to the satisfaction of the competent authority that the best available technique is being used.

In Ireland the Regulations giving effect to the Solvents Directive, (S.I. No.543 of 2002 Emissions of Volatile Organic Compounds from Organic Solvents Regulations 2002), the Solvents Regulations, fully reflects the Solvents Directive in regards to the above exemption provisions.

Therefore an exemption fiom the regulations can be given provided it is demonstrated that the reduction programme is not technically or economically feasible and BAT is being used. SR Technics considers that this exemption provision applies to aircraft carried out in Hangar 3 (emission points A1 and A2) at the Dublin Airport site.

Demonstration of the applicability of this exemption is detailed below.

The Reduction Scheme Applied to SR Technics.

The Reduction Scheme, legally defined in Schedule 3 of the Solvents Regulations, was considered in some detail by SR Technics and the attached SMP presents some detailed calculations. The calculations show that SR Technics, through the switch to

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high solids paints, has already achieved and gone beyond the 2005 Reduction Scheme target of 3.7 kg VOC emitted per kg Paint Solids Used (in 2002 a value of 2.71 was calculated). However, the Reduction Scheme as a tool to manage solvent usage in the aircraft painting business on an on-going basis is not viable due for two key reasons:

Inconsistency in solids deposition on an airframe (i.e., painting), given the various client specific requirements. The need to include all VOC containing materials in the Reduction Scheme calculation. Unlike vehicle refinishing, there is a significant variation in the 'recipe' for airframe painting. For example, there are times when only high solids painting is required with minimal surface preparation and in this case a Reduction Scheme calculation will produce low values or VOC emissions emitted relative to solids used. However, in many cases, and perhaps for contracts for an extended period of time, there is the need only to apply relatively small amounts of high solids paint but the need for significant surface preparation (containing high VOC content but no solids content), resulting in Reduction Scheme indices far greater than the target values. The flexibility to have either situation is important for the viability of the aircraft painting business at SR Technics.

SR Technics notes that the same issues are identical across the sector in Europe which includes both Shannon Aerospace and Lufthansa Aircraft Painting Shannon. Both of these companies have recently received their IPPC licences and the EPA Inspectors report for each has concluded that the reduction scheme is not feasible.

Assessment of Best Available Techniques (BAT)

Abatement

BAT for the installation was assessed against the draft BREF Reference Document on Best Available Techniques on Surface Treatment using Organic Solvents and the E P A draft BAT Guidance Note on Best Available Techniques for Solvent Use in Coating, Cleaning and Degreasing. The BREF document acknowledges that waste gas cleaning is not applied to this sector due to factors such as substantial volume flows and the discontinuous operation.

The above acknowledgement can be referenced with specific sector research:

1. SR Technics carried out extensive work on the design of a suitable system. It was determined that thermal oxidation was not technically feasible given the required pre-concentrator size required (required in order to bring the air flow and solvent load to the thermal oxidizer into the range technically feasible for thermal oxidation);

2. Shannon Aerospace carried out a feasibility study on VOC abatement in the paint hanger however the cost of upgrading ( S 2 . l million) and activated carbon disposal (approximately €84,000 per month) together with the physical size of the hangers, volume of airflow and short periods of painting made this option uneconomic. It is noted that similar hangar design, operation and air flow rates as applied at Shannon Aerospace (and indeed

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Lufthansa Aircraft Painting) are also applied at SR Technics and therefore the abatement conclusions reached at Shannon Aerospace regarding carbon abatement equally apply to SR Technics.

BA T Incorporated into SR Technics Operations

Table E. 1 .A. I provides specific examples of extensive BAT measures employed in aircraft painting at SR Technics. Most of the BAT detailed in Table E. 1 .A. 1 is detailed in the attached Solvent Management Plan (SMP).

SR Technics has incorporated the painting programme into its Environmental Management Programme, thus facilitating senior management commitment to reduction in VOC emissions and the development of targets that are reported to the Agency

Table E.l.A.1: - BAT Assessment - Painting Operations

annually. SR Technics operates a Just-in-time (JIT) raw materials

BAT Measure

management system that results in lower VOC product

BREF Reference Csectionl

consumption Progressive introduction of lower VOC products used in all stages of airframe painting. SR Technics has so far been successful in almost complete introduction of high solids (and so low VOC) paints for exterior airframe painting. Whilst these products are more difficult to work with, SR Technics has

I implemented new practices and procedures necessary to achieve a similar quality of finish to that experienced with the high VOC

2 1.1 (para. 12)

2 1.1 (para. 24)

21.12 (para. 129)

chemically stripped with organic solvent based strippers. Where possible, and economically feasible, sanding and other mechanical means of paint stripping occurs. Over 70% of aircraft are mechanically stripped rather than chemically

Cessation of the use of dichloromethane containing paint strippers for large scale paint stripping. Such strippers are used only for small areas of an airframe surface that cannot otherwise be treated. The minimisation of areas of the airframe that must be

21.1 (para. 34)

4.3

stripped are SR Technics. Use of high pressure was systems to reduce water consumption 12.1 (para. 32) during ai&ake washing. Use of a highly specialised pneumatic gun for sealant

I Cleaning of spray guns in enclosed units to reduce solvent 1 20.9 I

20.7 application. This minimises sealant usage. Application of paint with High Volume, Low Pressure (HVLP) 20.7

quantities required. The off-site recovery of spent cleaning solvents. 2 1.1 (para. 47)

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In the attached SMP, please note the following administrative notes:

BAT Measure

Contracting of specialist airframe painting crews which not only ensures quality but will also result in minimisation of consumption of paint and other airframe preparation products containing organic solvents.

The move towards interior painting using water based products rather than organic solvents based paint products. Approximately 20% of interior work is carried out using water based products. SR Technics hopes to progress increase in usage of such products through the recent purchase of a DMG Aerodry which substitutes drying booths with application of diffused compressed air over the components being painted with water based paints. SR Technics is actively looking into low VOC airframe cleaners and gun cleaners (e.g., Tetrosyl panel wipe, PPG Aerospace panel cleaner, Aerodex WB 9000 gun-cleaner). The use of continuous water curtain abatement and filters in component spray paint booths.

1. FLS Aerospace to be replaced by SR Technics throughout. 2. Replacement of references to the SED with corresponding references to the

Solvents Regulations in Section 4 of the attached SMP, noting that the same exemptions

BREF Reference (section)

2 1.1 (para. 24)

2 1.12 (para. 129) & 2 1.1 (para. 29)

2 1.1 (para. 35)

20.7.4.1

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Attachment N q . 1 . B - Fugitive Emissions

This attachment addresses the following specific requirement:

"In relation to activities listed in the Schedule of Council Directive 1999/13/EC on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations; - speclh the relevant category of activity in the Schedule - speczh how the requirements in relation to fugitive emissions will be met. "

There are three Scheduled Activities under the above regulations (the Solvents Regulations) that apply to activities at SR Technics. These are:

Activity 4: Surface Cleaning (specific Risk Phrase compounds as per Articles 8 & 10 of the Solvents Regulations); Activity 5: Other Surface Cleaning; Activity 8: Other Coating (but noting the exemption relating to aircraft painting as detailed in Note 4 to Activity 8, Schedule 2) and as discussed in Attachment E. 1. A.)

Fugitive emissions are largely generated in the following operations on the site:

Aircraft maintenance; Aircraft and component painting; and to a lesser extent Degreasing.

The requirements of the Solvent Directive regarding fugitive emissions for the above activities are emission limit values for fugitive emissions expressed as a percentage of solvent input. The emission limit values are:

Activity 4: 15% for specific risk-phrase solvent consumption of 1 to 5 tonneslannum or 10% for solvent consumption >5 tonneslannurn; Activity 5: 20% for solvent consumption of 2 to 10 tonneslannum or 15% for solvent consumption > 10 tonnes per annum; Activity 8: 25% for solvent consumption of 5 to 15 tonneslannum or 20% for solvent consumption > 15 tonnes per m u m .

An exemption fi-om the Activity 8 emission limit values for aircraft painting is noted in Section E. 1 .A.(b) and this includes both point source emission limit values and fugitive emission limit values. Notwithstanding this exemption, details pertaining to BAT for aircraft painting have been presented with the aim to reduce overall VOC emissions and therefore the mass emissions of VOC's as fugitive emissions from aircraft painting.

Regarding other activities, including component painting, degreasing and general aircraft maintenance, the Annual Environmental Report (AER) for 2004 provides information to initially provide an estimate of fugitive emissions. In 2004, no aircraft painting was undertaken. The emissions monitoring data for 2004 indicated

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e a total mass emission of 1,630.51 kg of total organic carbon (TOC orLC' fraction of VOC) to air fkom point source monitoring of main emissions. The Pollution Emission Register mass balance on TOC indicated a total of 10,710 kg TOC used in 2004, of which, by mass balance, an estimate of 8,032 kg were emitted to atmosphere as a combination of point source and fugitive emissions. This means that an estimate of [(8,032 - 1,630.5 1)/10,710] x 100 = 60 % of emissions from solvent using Solvent Directive activities, excluding aircraft painting, were fugitive emissions in 2004.

It is important to note that the above estimate of fugitive emissions has been presented and on a site-wide basis, rather than on an activity basis. Further, more detailed, work is required to more accurately determine fugitive emissions. For example, it is likely that fugitive emissions in individual component spray paint booths, as a percentage of solvent consumed in the booths, is substantially less than 60% given the enclosed area and extraction presented. A similar situation is anticipated for solvent degreasing. The largest contributor to fugitive emissions is

a likely to be general aircraft maintenance.

Once a more detailed fugitive emissions estimate is completed, then a programme of specific action to reduce the percentage of fugitive emissions can be developed and implemented.

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ACCURACY OF EASTINGS/NORTHINGS 3-15M

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DRPlWN P S T ~ N L E Y T I T L E SR TECHNLCS

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