Annual Environmental Report 2009 an G E R R Valspar Industries (Ireland) Ltd

March 2010

Annual Environmental Report 2009 AN G E R R Valspar Industries (Ireland) Ltd. Ballinamore

Co. Leitrim O’ E IPPC Licence Register No. P0209-01 E ON L L A M M M

2B Richview Office Park, St. Catherine’s House, 4 McDonagh Terrace, Clonskeagh, Catherine Street, Woodquay Dublin 14. Waterford. Galway.

Tel: +353 1 2602655 Tel: +353 51 876855 Tel: +353 91 531069 Fax :+353 1 2602660 Fax :+353 51 876828 Fax :+353 91 531084 e‐mail: [email protected] e‐mail: [email protected] e‐mail: [email protected]

Annual Environmental Report 2009 March2010 Valspar Industries (Ireland) Ltd. IPPC Licence Reg. No. P0209-01

Annual Environmental Report 2009

Valspar Industries (Ireland) Ltd IPPCL Registration No. P0209-01 Willowfield Road Ballinamore Co. Leitrim

Table of Contents

Page No.

1.0 Introduction ...... 1 1.1 Environmental Highlights ...... 1

2.0 Company Profile and Background ...... 2 2.1 Brief Description of Processes ...... 2

3.0 Environmental Management ...... 3 3.1 Environmental Management Organisation ...... 3 3.2 Environmental Management System Description ...... 3 3.2.1 Environmental Policy ...... 4 3.2.2 Planning ...... 6 3.2.3 Implementation and Operation ...... 6 3.2.4 Checking and Corrective Action ...... 6 3.2.5 Management and Review ...... 7 3.3 Environmental Training and Education ...... 7

4.0 Emissions Data ...... 8 4.1 Emissions to Atmosphere ...... 8 4.2 Emissions to Sewer ...... 8 4.2.1 Monitoring of Emissions to Sewer ...... 8 4.2.2 Flows ...... 8 4.3 Pollutant Release and Transfer Register (PRTR) ...... 9

5.0 Surface Water Monitoring Summary ...... 11

6.0 Noise Assessment Programme ...... 12

7.0 Waste Management Summary ...... 12 7.1 Non-Hazardous Waste ...... 12 7.2 Hazardous Waste ...... 14 7.3 Waste Paint Analysis...... 17

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8.0 Resource Consumption ...... 18 8.1 Electricity Usage ...... 18 8.2 Diesel Usage ...... 19 8.3 Water Usage ...... 19

9.0 Environmental Incidents and Complaints ...... 21 9.1 Environmental Incidents ...... 21 9.2 Complaints ...... 21

10.0 Review of Objectives and Targets ...... 22 10.1 Introduction ...... 22 10.2 Environmental Management Programme ...... 22 10.3 Review of On-going Objectives and Targets Jan-Dec 2009 ...... 23 10.4 Review of Specific Objectives and Targets Jan-Dec 2009 ...... 25

11.0 Additional and Ongoing Objectives and Targets for 2010 ...... 27

12.0 Reports ...... 28

13.0 Monitoring Programme 2009 ...... 28 13.1 Surface Water ...... 28

List of Tables ______

Table 1 Results of Surface Water Monitoring from Samples taken in 2009 Table 2 Waste Management Summary 2007-2009 Table 3 Non-Hazardous Waste collected by CWD Ltd. in 2009 Table 4 Waste generated per tonne of finished product Table 5 Waste Generated On Site (Jan-Dec 2009) Table 6 Electricity Usage 2009 Table 7 Total Electricity Consumption 2007-2009 Table 8 Total electricity usage per tonne of finished product 2008-2009 Table 9 Diesel Consumption 2006-2009 Table 10 Diesel consumption per tonne of finished product Table 11 Water Usage 2009 Table 12 Water Consumption 2007-2009 Table 13 Water consumption per tonne of finished product Table 14 Review of On-going Objectives and Targets Jan-Dec 2009 Table 15 Review of Specific Objectives and Targets Jan-Dec 2009 Table 16 Schedule of Specific Environmental Objectives and Targets for 2010

List of Figures ______

Figure 1 Core Elements of the EMS

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List of Appendices ______

Appendix A PRTR Electronic Submission Appendix B Monthly Audit Reports Appendix C Waste Paint Analysis Report from TMS Appendix D Surface Water Monitoring Results

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1.0 Introduction

This report comprises the Annual Environmental Report for Valspar Industries (Ireland) Limited, Ballinamore, Co. Leitrim, and has been compiled in accordance with Section 2.9.2 of IPPC Licence, Register number P0209-01 and in accordance with the EPA Guidance Notes on the preparation of AERs. The report generally covers the period of 1st January 2009 to 31st December 2009.

The Annual Environmental Report is viewed by the Management of Valspar Industries (Ireland) Ltd. as an important part of company communication on environmental matters, both internally and publicly.

The AER also fulfils the following objectives:

• Provides a summary assessment of performance of the reported year against the previous year’s environmental objectives and targets.

• Brings together all reports required under the Conditions of the IPPC Licence.

• Allows an evaluation of those reports, results and programmes prepared to monitor, track and improve environmental performance.

• Provides a structured format for the development of an environmental strategy incorporating the resetting of environmental goals and targets in subsequent years.

• Provides environmental information and performance data on the facility at Ballinamore in clear, non technical language, providing a means of communicating environmental information to site neighbours and the public.

Valspar Industries (Ireland) Ltd. has maintained good environmental performance in 2009, taking 2008 as a base year. In previous years, the facility has improved performance dramatically (elimination of process waste water, reduction in formaldehyde, elimination of crystalline silica); however, due to the stream lining of the process and products substitution in 2001, it has been difficult to maintain constant improvement over the subsequent years. The company has however maintained the status quo.

1.1 Environmental Highlights

To summarise, in 2009 the following were maintained and/or improved upon from 2008:

• 100% compliance with Emission Limit Values was achieved on all environmental analysis. • The overall generated waste per unit output has decreased from 0.0200 tonnes in 2007 to 0.0179 tonnes in 2008 and 0.0164 tonnes of waste per tonne of paint produced in 2009. • The rate of land-filled waste production per tonne of finished product has been reduced from 0.0095 tonnes in 2007 to 0.0067 tonnes in 2008 and 0.0066 tonnes of waste per tonne of paint produced. Hence a negligible improvement has been achieved.

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• The company’s electricity supplier is Airtricity, who generate and supply ‘green’ energy from renewable wind resources. • A negligible improvement of the usage of electricity per tonne of finished product has been achieved. • Diesel consumption per tonne of finished product has reduced by more than 83% since 2006. • Water consumption per tonne of finished product has decreased by approximately 31%. • Maintenance of a waste register ensured accurate knowledge of the destination of all waste generated.

2.0 Company Profile and Background

Valspar Industries (Ireland) Ltd. operate a coating manufacturing facility in Ballinamore, Co. Leitrim. The coating manufacturing activity operates under an IPPC licence (Reg. No. P0209-01) issued by the EPA in 1997. The products are water-soluble acrylic emulsion coatings with minimum solvent of approximately 3.5% by volume. The coatings are comparable to water based emulsion paints used for interior household purposes.

The site was an advance factory at the eastern side of Ballinamore and was built in 1980 by the I.D.A. and up until the arrival of Lilly Industries (Ireland) Ltd. in 1996 had been occupied on an infrequent and short term basis by local industries, the last of which was Ballinamore Textiles. The facility was taken over by Valspar Corporation in 2001 and was closed temporarily at the beginning of 2002 for 2 months, but has been in continuous operation since then.

The overall site is laid out as follows:

• Administration, Laboratory and Canteen • Production Building • Flammable Storage Room (fireproofed) • Flammable Goods Staging Area (fireproofed) • Boiler and Air Compressor Room (outside) • Electricity Switch Room (outside) • Tanker Loading Area • Loading Dock for Raw Material Receipt • Weighbridge

At present, the company has a total of six employees.

There are two main products manufactured on site; TPA Doorskin Primer (DP) and Pigmented Anti-Metal Mark (PAMM). In 2009 approximately 2,197.4 tonnes of finished product was manufactured at Valspar Industries (Ireland) Ltd. in comparison to 3,160 tonnes in 2008, 4,058 tonnes in 2007 and 4,510 tonnes in 2006. This slight fluctuation in production is based on demand from Valspar’s customer base.

2.1 Brief Description of Processes

Since the previous AER, there have been no changes to the basic production process. The manufacturing operations can be divided into the following categories:

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Manufacturing Processes

The manufacturing process involves mixing and blending the raw materials in enclosed containers. The primary raw materials are water, acrylic latex emulsion, which is a resin material that helps to form a film or coating, solids such as titanium dioxide which is a white pigment, and clay, together with small quantities of other ingredients such as cross-linking resins which act as binders, defoamers and alcohol which acts as a co- solvent.

Dispatch

The finished products are dispatched from the site in bulk tankers or IBCs (intermediate bulk containers).

Auxiliary

The main auxiliary processes are heating of the premises and storage of finished product and raw materials. There are no wastewater treatment facilities etc.

3.0 Environmental Management

3.1 Environmental Management Organisation

Mr. Gerry Donohoe took over as Site Manager from Peter Egan in September 2008 and directs all matters of an environmental nature. Ms. Noreen White is the Environmental Representative of the site. Much of the monitoring and report preparation is out-sourced to independent consultants. In-house monitoring in the form of surface water monitoring and operation of the dust collector system as well as implementation of procedures is carried out by in-house personnel with responsibilities in these areas.

3.2 Environmental Management System Description

Valspar Industries (Ireland) Ltd. introduced an Environmental Management System (EMS) based on ISO 14001 which is intended to;

a) Achieve a reduction in the likelihood of potential environmental risks and liability through regulatory compliance.

b) Ensure that the conditions of Valspar Industries (Ireland) Ltd. Integrated Pollution Prevention Control licence are met fully.

c) Ensure that the Valspar Industries (Ireland) Ltd. Environmental Objectives and Targets (EOT) are achieved through an action programme.

d) Identify areas for environmental improvement, and the person responsible for these.

e) Periodically audit activities for regulatory compliance.

Figure 1 illustrates the core elements of the EMS.

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ENVIRONMENTAL POLICY

CONTINUAL IMPROVEMENT Planning PLAN Environmental Aspects Management Review ACT Legal & other Requirements Objectives & Targets Environmental Management Programme

Checking & Corrective Action CHECK Monitoring & Measurement Non-Conformance Corrective Action Preventative Action Implementation & Operation Records DO EMS Audit Structure & Responsibility Training and Awareness Communication EMS Documentation Documentation Control Operational Control Emergency Response

Figure 1 The Core Elements of the EMS

The company has maintained the monitoring and reporting requirements under the terms of the IPPCL and as set out in Figure 1. The presence of an environmental representative on site ensured that items of the EMS as set out in Figure 1 were fully implemented and maintained in 2009 and that the necessary resources were assigned to each task.

The full complement of Environmental Procedures was implemented in 2004 and this continued in subsequent years and in 2009. Tasks such as internal auditing are carried out by the Environmental Representative. The environmental management system at the facility is an administrative and reporting structure, which establishes objectives for continuous, structured and quantifiable improvement in the company's environmental performance and essentially ensures lines of communication, information flows and the allocation of responsibilities.

3.2.1 Environmental Policy

It is the policy of Valspar Industries (Ireland) Ltd. to conduct business responsibly and in a manner designed to put first the health and safety of employees, customers, the public and the environment. The company recognises that its business activities have an environmental dimension and therefore places a high priority on the management of its environmental affairs. The company recognises the legitimate interest that others have in its environmental performance. As a member of the community the company is conscious of the effects of its operations on the environment – land, water, air, and

Malone O'Regan 4 Annual Environmental Report 2009 March2010 Valspar Industries (Ireland) Ltd. IPPC Licence Reg. No. P0209-01 noise. The company will continue to comply with the spirit as well as the letter of national and local laws.

Valspar Industries (Ireland) Ltd. communicates openly about its environmental policies, practices and performance and ensures the awareness of all its employees on environmental issues. Valspar Industries (Ireland) Ltd. gives and will continue to give full co-operation to all statutory bodies engaged in environmental protection. The company will ensure that it is fully aware of the environmental issues of its operations and will strive to continuously improve its environmental performance. Valspar Industries (Ireland) Ltd. is committed to providing a safe and healthy workplace for our employees and operating our facilities in a manner that is harmonious with the local community.

In achieving this policy the company adheres to the following:

(i) Inclusion of health, safety and environmental impact among the criteria by which products, processes, equipment and facilities are designed, developed and evaluated.

(ii) Implementation programmes and provision of competent personnel with responsibility for environmental compliance, industrial hygiene, occupational health, safety, fire prevention and protection and emergency response.

(iii) Periodical evaluation of environmental protection, health and safety programmes for regulatory compliance and progress towards goals and objectives. Where deficiencies are identified, appropriate corrective actions are implemented. Everyone at Valspar Industries (Ireland) Ltd. has the responsibility to be fully aware of and observe all legal requirements pertaining to health, safety and environmental protection, as well as company policies, objectives and targets.

(iv) Performance and recording of process environmental safety audits or hazards review of processes, and evaluation of effects on employees, community and the environment. Where hazards are identified, appropriate corrective strategies are developed.

Environmental protection is ensured through the following:

(1) Before any changes are initiated at the site a full environmental impact assessment is carried out. This environmental assessment will be repeated by Valspar Industries (Ireland) Ltd. staff and outside consultants, as required during the further purchase or disposal of Valspar Industries (Ireland) Ltd. property.

(2) Adherence to all environmental protection standards and regulations, objectives and targets which may be applicable.

(3) Encouragement of waste minimisation in the area of air emissions, wastewater, solid wastes and noise control, where practical.

(4) In the handling of waste, methods such as reuse and recycling shall be given preference when disposal options are chosen.

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(5) Every effort to use environmentally safe and sustainable energy sources and improve energy efficiency and conservation will be made.

3.2.2 Planning

The identification of significant environmental aspects of the site was carried out during the initial IPPC licence application process. Since the granting of the licence, the company has not introduced any major process changes. Most of the significant changes have been in the formulation of products where there has been a progressive reduction of solvents such as formaldehyde and elimination in some cases e.g. triethylamine. Besides process changes, the information generated through the monitoring of existing aspects is fed into the planning of the EMS and setting of objectives and targets.

Valspar Industries (Ireland) Ltd. use external consultants to advise and update them on new and emerging environmental legislation. Any critical new legislation will be controlled via measures such as the setting of a new objective or the development of a new procedure, which will then be implemented within the EMS. The company, through regular review of existing objectives and targets, monitoring data, legal requirements and evaluation of new effects can then plan the setting of new objectives and targets. On-going objectives and targets have been set for the facility while specific objectives and targets are set annually as required. These are detailed in Section 10.0 of this report. Regulation (EC) No. 166/2006 of the European Parliament and of the Council concerning the establishment of a European Pollutant Release and Transfer Register (the ‘E-PRTR Regulation’) is in force. It replaced the AER emissions reporting system and took effect from the 2007 reporting year. Valspar Industries (Ireland) Ltd. is controlled by Activity No. 50.1- General Activity listed in the EPA PRTR return form for the facility. The form has been completed electronically as required and is attached in Appendix A. 3.2.3 Implementation and Operation

As stated above, Valspar Industries (Ireland) Ltd. has implemented a large number of procedures in relation to its IPPCL. The objective is to maintain the implementation and operation of these procedures.

3.2.4 Checking and Corrective Action

Valspar Industries (Ireland) Ltd. have implemented procedures in order to ensure that the EMS is operating correctly and efficiently. Monthly checking and corrective action forms were fully implemented in 2005 and they have been maintained during the subsequent years. Through the following procedures, the company will address the issue of checking and corrective action:

• Monitoring and Measurement • Maintenance of Records • Internal Auditing and • Implementation of Corrective Action Procedures

Monthly internal audit reports are attached in Appendix B.

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3.2.5 Management and Review

As part of the EMS, senior management carry out an annual review of the EMS. The annual review addresses all of the following issues:

• Environmental performance, completion of objectives and targets. • Status of EMP. • New legal requirements. • Complaints. • Notifiable Incidents. • Non-conformances and corrective actions. • Overall IPPCL compliance. • New significant aspects. • Identification and setting of new objectives and targets.

The AER is formulated as a result of the annual review.

3.3 Environmental Training and Education

In 2009 in house training of all staff in relation to safety and environmental matters and the EMS was carried out. The following training was provided to all relevant employees during 2009: safety statement and safety management procedure, company EHS policy, risk assessment and identification of hazards, fire prevention, incident investigation, control of hazardous procedures, chemicals handling, handling of flammable goods, spillage awareness, surface water inspection, EHS Emergency response procedures, use of MSDS sheets, evacuation procedures and fork truck safety. If new methods or equipment are employed due to updates in the EMS, appropriate training will be performed in 2010 as well as the annual ongoing training.

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4.0 Emissions Data

4.1 Emissions to Atmosphere

Schedule 1 (iii) of the IPPC Licence (P0209-01) requires that emissions to atmosphere are monitored on a quarterly basis. Due to 100 % compliance at all times the EPA reduced the frequency of monitoring from quarterly to bi-annually in 2000. Due to upgrade of the exhaust system in October 2005, it was agreed with the EPA that neither monitoring nor reporting of emissions is required.

The HEPA filter system is however being monitored on regular basis to ensure that the system is efficient.

4.2 Emissions to Sewer

The primary sources of waste water are: • utilities • sanitary

Utilities

This water consists of mop-wash which is water used only in the washing of the production area. Very little is used on a weekly basis and after consultation with Leitrim County Council and analysis of the content of the water by external contractors, permission was granted by LCC to dispose of this water to effluent as detailed in previous AERs.

Sanitary

Sanitary waste-water includes the toilets and wash/ shower rooms. This volume of waste-water is relatively small and would be similar to that produced in a domestic house-hold due to the small number of employees working currently at the plant (six in total). Wastewater from the site discharges into the Local Authority system.

4.2.1 Monitoring of Emissions to Sewer

Given that the wastewater from the site is mainly domestic in nature, a request to discontinue quarterly monitoring at PEMP1 was sent to the EPA and Leitrim County Council in 2002. Leitrim County Council had no objections to the discontinuation of monitoring of the emission point PEMP1, given that emissions did not occur. As a result, no monitoring of emissions to sewer was carried out since receipt of permission to cease monitoring in 2003.

4.2.2 Flows

The volume of emissions to sewer must not exceed 5.0 m3 in any one day and a maximum rate per hour of 1.0 m3. Continuous flow monitoring is not done at the facility. However given that domestic effluent from the six staff is the main constituent it can be stated that the company does comply with the allowable volume of emissions to sewer.

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4.3 Pollutant Release and Transfer Register (PRTR)

The primary purpose of the PRTR is to control the method in which pollutants and large quantities of waste are tracked. Under the PRTR system substances requiring tracking are listed in Annex II of Regulation (EC) No. 166/2006, transposed into Irish legislation in the form of European Communities (European Pollutant Release and Transfer Register) Regulations 2007 (S.I. No. 123 of 2007).Hazardous waste over 2 tons/ year and non-hazardous waste over 2,000 tons/ year are also required to be tracked under the regulations.

The pollutants for inclusion in the E-PRTR are listed in Annex II of Regulation (EC) No. 166/2006 concerning the establishment of a European Pollutant Release and Transfer Register and amending Council Directives 91/689/EEC and 96/61/EC. This has been transposed into Irish legislation in the form of European Communities (European Pollutant Release and Transfer Register) Regulations 2007 (S.I. No. 123 of 2007).

The compounds tracked previously were Dipropylene Glycol Mono Methyl Ether (DPGMME), Propylene Glycol N-Butyl Ether (PGNBE – also known as butoxypropanol) and Dipropylene Glycol N-Butyl Ether as required by the EPA, as both organic solvents1 fall into non-methane VOCs category . Volumes used of these compounds in 2009 can be found in the final product with no accidental or fugitive losses to be reported.

Santiciser 160 has been replaced by Platinom M (dimethyl phthalate) during 2009 to conform to the REACH regulations. A total of 2.647 tonnes of platinum M were used during 2009.

Tracking System

Raw Materials

The compounds enter the site in liquid form. Exact volumes are recorded during stock control. In 2009, a total of 34.797 tonnes of DPGMME, 3.877 tonnes of PGNBE and 0.213 tonnes of DPNB were used. In 2008, a total of 51.585 tonnes of DPGMME, 6.174 tonnes of PGNBE and 0.277 tonnes of DPNB were used. In 2007, a total of 65.05 tonnes of DPGMME and 8.9 tonnes of PGNBE and 0.098 tonnes of DPNB were used. This represents a decrease since 2007 of 30.25 tonnes of DPGMME and 5.023 tonnes of PGNBE while DPNB usage decreased by 0.064 tonnes compared to 2008.

Storage

The compounds are delivered in 200 kg drums which are stored in a fireproof storage room. The volume of the chemicals required for the making of a batch of paint is transferred to a separate fireproof room known as the flammable room where it is directly piped to the point of usage. Full anti-static measures are taken when the chemicals are being dispensed.

Processing

All chemicals are contained in enclosed drums, in bunded rooms and are transferred to Process via transfer piping. The percentage of solvent in the products varies between

1 Solvent quantities are estimated during stock control. Final product specification indicates approx. 3% solvent content, which is used to estimate fugitive emissions.

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1.5 and 4% in the main products and between 1 and 4 % in the MDF Primer which accounts for 12% of production.

Output

Potential emissions to the environment are in two forms:

(1) Air Emissions (2) Waste Paint

Air emission monitoring was carried out by external contractors ASEP in July 2009 at the facility. This was carried out at the HEPA filter. Samples showed low levels of organic compounds in use in the formulation with butoxyethanol (0.56 mg/m3),butoxypropanol (0.30 mg/m3), acetone (0.90 mg/m3) and cyclopentanone (0.11 mg/m3) being the main components.

Waste paint residue analysis has shown that the level of DPGMME and PGNBE found in samples analysed annually was below Method Detection Limit of <0.2 mg/kg as indicated on the report prepared by TMS (see Appendix C). Dimethyl phthalate was below the lab limit of detection of <78.13 mg/kg (see TMS lab report in Appendix C)

No waste water is generated in the manufacturing process and hence no loss occurred via water emissions. The only waste water which results from the manufacturing process is cleaning mop wash which is unlikely to carry detectable levels of solvent.

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5.0 Surface Water Monitoring Summary

Surface water from the roofs of the facility, from the warehouse and from associated paved areas flows into the storm drains on site. This water discharges from the site by gravity to Leitrim County Council’s storm drain on Willowfield road adjacent to the site. Continuous monitoring for pH and conductivity takes place on a daily basis at each of the surface water collection points on the site. Data is available for all surface water on site and leaving the factory site and was in full compliance in 2009.

A maintenance and calibration program is also in place for all surface water monitoring equipment to ensure all monitoring results collected are accurate. Standard operating procedures govern that all sump pumps in any relevant manhole location are electrically isolated in the OFF position during the loading or unloading of any product or raw material. All sump pumps are isolated at the close of operations each day, so that in case of a fire or spillage no contamination from material or water used to fight a fire will leave the site. Pumps are automatically isolated when the fire alarm is triggered. Emphasis has been and will continue to be aimed towards prevention of any contamination of surface water.

To date Valspar Industries (Ireland) Ltd. has never had a spill of any kind at the facility and thus no contamination of surface water has occurred. In July 2000 Valspar Industries (Ireland) Ltd. received confirmation from the EPA and Leitrim County Council to reduce lab analysed water monitoring frequency on surface water from monthly to quarterly. Water samples are submitted to an external lab for pH and COD on a quarterly basis. In January 2003, the EPA revised the reporting requirement for surface water to an annual reporting event; however monitoring is to continue on a quarterly basis. Continuous and quarterly surface water monitoring reports are attached in Appendix D. It is noted that only three samples were collected and analysed during 2009 due to change of personnel. Corrective action has taken place and surface water monitoring will be carried out quarterly during 2010.

Surface water monitoring results are presented in Table 1 below. Surface water samples are taken from the surface water monitoring point at the weighbridge (Weigh) and at the loading bay (Load).

Table 1 Results of Surface Water Monitoring from Samples taken in 2009 APR SEP NOV PARAMETER Weigh Load Weigh Load Weigh Load

pH 8.77 8.89 7.57 7.70 7.81 8.23

COD (mg/l) 47 40 42 44 43 38

As shown in Table 1, all results indicate that surface water at the facility is of neutral pH. The results show that the surface water is unlikely to affect the ‘Q4 – Good quality’ status of the receiving waters2.

2 EPA ENVision Online Map Viewer, EPA, 2007

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6.0 Noise Assessment Programme

The EPA agreed to the cessation of environmental noise monitoring due to the absence of noise complaints and lack of significant noise sources at the facility. Two occupational noise surveys were conducted in 2007 and the recommendations were implemented on site. Hearing protection is provided where necessary.

7.0 Waste Management Summary

Waste generated on site in 2009 can be summarised and compared to volumes generated in 2008 and 2007 as follows:

Table 2 Waste Management Summary 2007- 2009 2009 2008 2007 1.548 tonnes hazardous – 1.27 tonnes hazardous – 1.76 tonnes hazardous – recovered/ recycled (empty recovered/ recycled recovered/ recycled steel drums) Approximately 0.8 tonnes Approximately 0.5 tonnes 0.84 tonnes of paper – of paper/ cardboard – of paper – recycled. recycled. recycled. 18.05 tonnes of wood 28.83 tonnes of wood 39.9 tonnes of wood pallets – recycled. pallets – recycled, pallets – recycled. 1.548 tonnes of steel - 0.984 tonnes of steel - - recycled recycled 1.02 tonnes of recyclable 3.936 tonnes of plastic - material (steel, rubble, - recycled plastic,…) - recycled 14.52 tonnes to landfill 21.14 tonnes to landfill 38.7 tonnes to landfill 21.41 tonnes recycled in 35.52 tonnes recycled in 42.5 tonnes recycled in total total total Total: 35.93 tonnes of Total: 56.66 tonnes of Total: 81.2 tonnes; 52% of waste produced; 59.6 % of waste produced; 62.7% of which was recycled/ which was recycled/ which was recycled/ recovered recovered recovered

These quantities are described further below and categorised in further detail in Table 5.

The amount of waste sent off-site in 2009 was 35.93 tonnes, a decrease from the 2008 figure of 56.66 tonnes. However, the primary decrease in waste generation is due to a significant reduction in final product output as since 1st of June 2009 production has been reduced to three days per week. Final product generated on site decreased by 30.5% compared to the 2008 figure. The overall percentage of waste being sent off site for recovery/ recycling amounts to 59.6% of the total waste produced on site, which is a decrease from the 62.7% figure in 2008.

7.1 Non-Hazardous Waste

The following table shows non-hazardous waste volumes collected by CWD Ltd., Killygarry Industrial Park, Cavan (Waste Collection Permit No. CW009) on a monthly basis in 2009.

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Table 3 Non-Hazardous Waste collected by CWD Ltd. in 2009 Month Total Tonnage Month Total Tonnage January 1.74 July 0.2 February 2.6 August 0 March 0 September 0 April 0 October 6.5 May 5.1 November 0 June 0 December 0.2 Total Tonnage: 16.34

Details of the destination and carrier of all waste are shown in Table 4. In total, 16.34 tonnes of non-recoverable waste collected at Valspar Industries by CWD Ltd. was disposed of to the Corranure Landfill, Lismagratty and Corranure Townlands, Cootehill Road, Cavan (Licence Reg. No. W0077-03). Paper and cardboard waste from the site was collected by C.W.D. Ltd. and sent for recycling at Oxigen Environmental Ltd., details shown below on Table 4. The total estimated paper and cardboard recycled in 2009 amounted to approximately 0.8 tonnes. One skip with 1.02 tonnes of recyclable material (mixed steel, rubble …) was collected onsite for segregation and recycling by CWD in 2009.

Used pallets were sent for recycling to Pallet Supplies Ltd. The total quantity of wood pallets recycled in 2009 was 18.05 tonnes which is a decrease of 37% from the 2008 figure of 28.83 tonnes.

The Packaging Regulations (2003) require segregation of waste on the premises prior to collection. Valspar segregates wood, plastic, steel and paper and cardboard waste in compliance with the regulatory requirements. Therefore, the total amount of waste disposed of to landfill in 2009 was 14.52 tonnes. This is a decrease of 31% from the 2008 figure of 21.14 tonnes.

However, the primary decrease in waste sent off site for disposal and recycling is due to a significant reduction in production. For data normalisation waste generated per tonne of final product during 2007 -2009 is shown in Table 4 below.

Table 4 Waste generated per tonne of finished product Year 2007 2008 2009 Total waste generated (tonnes) 81.20 56.66 35.93 Total landfill waste (tonnes) 38.70 21.14 14.52 Total recycled waste(tonnes) 42.50 35.52 21.41 Total finished product (tonnes) 4,058 3,160 2,197 Total waste (tonnes) per tonne of 0.0200 0.0179 0.0164 finished product Total landfill waste (tonnes) per 0.0095 0.0067 0.0066 tonne of finished product Total recycled waste (tonnes) per 0.0105 0.0112 0.0097 tonne of finished product

The overall generated waste per unit output has decreased from 0.0200 tonnes in 2007 to 0.0179 tonnes in 2008 and 0.0164 tonnes of waste per tonne of paint produced in 2009.

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The rate of land-filled waste production per tonne of finished product has changed from 0.0095 tonnes in 2007 to 0.0067 tonnes in 2008 and 0.0066 tonnes of waste per tonne of paint produced in 2009. Hence a negligible improvement has been achieved. The rate of recycled waste per tonne of finished product has however decreased in 2009.

7.2 Hazardous Waste

In 2009, 1.548 tonnes of waste classified as hazardous was sent off site (EWC 15 01 11*- empty steel drums). In November 2007, Valspar replaced all fluorescent tube light fittings and therefore eliminated this source of hazardous waste. Waste oil does not arise as it is continuously recycled in the machines. All chemicals are fully used in the production process except where they occur in waste paint which on analysis, by TMS environmental, is not deemed hazardous and is suitable for landfill.

Table 5 below shows a summary of waste (hazardous and non-hazardous) generated on site which was collected for recovery/ disposal during 2009.

Malone O'Regan 14 Annual Environmental Report 2009 March 2010 Valspar Industries (Ireland) Ltd. IPPC Licence Reg. No. P0209-01

Table 5 Waste Generated On Site (Jan-Dec 2009) Waste EWC Quantity Waste Contractor Carrier Ultimate Destination Material Code (tonnes) Pallet Supplies Ltd Mountain Lodge Pallet Supplies Ltd Pallets are re-used or Cootehill Mountain Lodge recycled. Wood Pallets 15 01 03 18.05 Co. Cavan Cootehill Permit Register Reference Permit Register Reference No. Co. Cavan No. WP/06/29 issued by WP/06/29 issued by Cavan Cavan County Council. County Council. Recovered for re-use by Cavan Waste Disposal Ltd. Cavan Waste Disposal Ltd. Oxigen Environmental Ltd., Kilgarry Industrial Park, Paper and Kilgarry Industrial Park, Merrywell Industrial Park, 20 01 01 0.8 Co. Cavan cardboard Co. Cavan Ballymount road Lower Waste Licence Register: Clondalkin Dublin 22. No. W0207-01 issued by the EPA Waste Reg. No.: W0208-01 All drums are washed and crushed by: Rilta Environmental Ltd. Johnston Haulage Co. Ltd Rilta Environmental Ltd. Block 402, Blackchurch Waste Register No: Greenogue Business Park Rathcoole W0192-03

Empty Steel Rathcoole Co. Dublin 15 01 11* 1.548 Drums Dublin Permit Register Reference Sent for recycling to:

Waste Licence Register: No. CW090 issued by Mayo A1 Metal Recycling No. W0192-03 issued by the EPA Co. Council Acragar, Mountmellick, Co. Laois Permit Register Reference No. WMP007b

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Waste EWC Quantity Waste Contractor Carrier Ultimate Destination Material Code (tonnes) Disposal: Cavan Waste Disposal Ltd. Cavan Waste Disposal Ltd. Corranure Landfill, Mixed Kilgarry Industrial Park, Kilgarry Industrial Park, Lismagratty and Corranure Municipal 20 03 01 14.52 Co. Cavan Co. Cavan Townlands, Cootehill Road, Waste Waste Licence Register: Cavan (Licence Reg. No. No. W0207-01 issued by the EPA W0077-04). Segregation and recycling: Cavan Waste Disposal Ltd. Cavan Waste Disposal Ltd. Cavan Waste Disposal Ltd. Mixed Kilgarry Industrial Park, Kilgarry Industrial Park, Kilgarry Industrial Park, Municipal 20 03 01 1.02 Co. Cavan Co. Cavan Co. Cavan Waste Permit Register Reference Permit Register Reference

No. W0207-01 issued by the EPA No. W0207-01 issued by the EPA TOTAL 35.93

* Hazardous waste

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7.3 Waste Paint Analysis

Waste paint is analysed in accordance with the requirements of Schedule 3(ii), and on annual (as opposed to biannual) basis, as agreed with the EPA in 2003. Waste paint was sent to TMS Environment Ltd. for analysis in November 2009 and the results are presented in Appendix C. The waste paint is classified as non-hazardous under the current legal definition of hazardous waste in Ireland.

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8.0 Resource Consumption

The following section summarises electricity, diesel and water usage in 2008.

8.1 Electricity Usage

In January 2005, electricity supply was changed from the ESB to Airtricity, who generate and supply electricity from renewable energy resources, principally from wind. Table 6 below shows the electricity usage for 2009, as taken from Airtricity usage invoices.

Table 6 Electricity Usage 2009 AIRTRICITY (UNITS - KILOWATT HOURS) INVOICES DAY NIGHT 06/02/2009 14,880 4,200 09/03/2009 8,040 1,440 08/04/2009 7,200 1,440 08/05/2009 4,048 1,232 08/06/2009 5,520 1,320 08/07/2009 4,680 1,200 10/08/2009 6,600 1,320 08/09/2009 4,200 1,200 08/10/2009 5,640 1,200 10/11/2009 7,080 2,160 08/12/2009 6,480 1,560 74,368 18,272 TOTAL 92,640

Table 7 below compares the electricity consumption during 2009 with the previous years. Table 8 below shows the electricity usage per tonne of finished product.

Table 7 Total electricity consumption 2007-2009 Year Consumption (kWh) 2007 102,360 2008 133,776 2009 92,640 Percentage Reduction (%) 30.75* Note:*Calculation based on 2009 consumption divided by 2008 consumption

Table 8 Total electricity usage per tonne of finished product 2008-2009 Year 2008 2009 Consumption (kWh) 133,776 92,640 Quantity of finished product (tonnes) 3,160 2,197 Usage (kWh) per tonne of finished product 42.33 42.17

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Electricity consumption has been reduced by approximately 30% in one year. However, a negligible improvement of the usage of electricity per tonne of finished product has been achieved.

8.2 Diesel Usage

Invoices, from Parkes Fuels, are used to estimate diesel consumed by Valspar Industries (Ireland) Limited. Consumption has greatly reduced since the purchase of electrical forklifts in November 2006. Table 9 below shows the approximate diesel consumed since 2006. A delivery of 1,000 litres in December 2006 lasted until October 2008 and there was then one delivery during 2008; there was also only one delivery in 2009 of 400 litres. Overall diesel consumption has reduced by more than 88% since 2006.

Table 9 Diesel Consumption 2006-2009 Year Consumption (L) 2006 3500 2007/08 1500 2009 400 Percentage Reduction (%) 88.57* Note:*Calculation: 2009 (400 L) consumption divided by 2006 consumption.

Table 10 below outlines the overall diesel consumption per tonne of finished product for data normalisation. 2009 values have been compared to 2006, as consumption for 2007 and 2008 is a combined figure.

Table 10 Diesel consumption per tonne of finished product Year 2006 2009 Diesel Consumption (L) 3,500 400 Quantity of finished product (tonnes) 4,510 2,197 Usage (L) per tonne of finished product 0.78 0.13

Overall diesel consumption per tonne of finished product has reduced by more than 83% since 2006.

8.3 Water Usage

Table 11 below shows the approximate water consumption during the period November 2008 to October 2009, which is taken from Leitrim Co. Council water charge invoices.

Table 11 Water Usage 2009 (November 2008- October 2009) Period Periodic Consumption (m3) November 2008 to March 2009 361 March 2009 to October 2009 372 Total Water Usage 2009 733

The approximate water consumption during 2009 was 733 m3. Table 12 below compares the water consumption 2009 with previous years.

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Table 12 Water Consumption 2007-2009 Year Water Consumption (m3) 2007 887 2008 1,524 2009 733 Percentage Reduction (%) 17.36* Note:*Calculation: 2009 consumption divided by 2007 consumption.

As explained in the AER 2008, water consumption increased in 2008 due to the washing and cleaning down of equipment used in production during a relatively quite period. Therefore, 2009 efficiency and reduction has also been compared to 2007 values.

The water consumption 2009 decreased by 17.36% from 2007 and by 51.9% from 2008. Nevertheless, for data normalisation water usage per tonne of final product during 2007 -2009 is shown in Table 13 below.

Table 13 Water consumption per tonne of finished product Year 2007 2008 2009 Water Consumption (m3) 887 1,524 733 Quantity of finished product 4,058 3,160 2,197 (tonnes) Water Consumption (m3) per tonne 0.22 0.48 0.33 of finished product

The rate of usage per unit output in 2009 was 0.33m3 per tonne of product which is an increase in efficiency when compared to 2008 value (0.48 m3 per tonne of product) but a decrease in water efficiency of 33% when compared to 0.22 m3 per tonne in 2007. This is likely due to lower production during 2009 affecting the efficient use of water.

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9.0 Environmental Incidents and Complaints

9.1 Environmental Incidents There were no environmental incidents during 2009.

9.2 Complaints There were no complaints filed in 2009.

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10.0 Review of Objectives and Targets

10.1 Introduction

Condition 2.2 of the IPPCL requires that a schedule of Environmental Objectives and Targets be submitted to the EPA. The purpose of this requirement is to set out clear environmental goals within Valspar Industries (Ireland) Ltd. to facilitate:

- Compliance with the site IPPCL and regulatory requirements. - Continual improvement in environmental performance at the site.

A schedule of Environmental Objectives and Targets was initially submitted to the Agency in March 1998. These objectives and targets were updated in 2000 and included as part of the AER 2000. As the aim is to improve environmental performance over time, objectives and targets are revised and up-dated every year, in light of licence reviews, managerial requirements, introduction of new products and processes with the subsequent identification of new environmental considerations.

10.2 Environmental Management Programme

The Environmental Management Programme (EMP) is a rolling programme from year to year with some revisions annually. Specific short term objectives are also added each year. The ongoing projects include the following:

1. Surface Water Monitoring 2. Noise Minimisation 3. Fugitive Emissions, Identification and Reduction 4. Energy Monitoring, Targeting and Reduction 5. Employee Education/ Training 6. External Housekeeping 7. Environmental Audits 8. Maintenance and Calibration 9. Waste Characterisation and Minimisation 10. Recycling of Waste 11. Raw Material Substitution

The majority of these projects have been discussed in the preceding section, however, they are summarised below in Table 14.

The specific objectives and targets for 2009 are reviewed in Table 15. Additional specific short term environmental objectives and targets for 2010 are summarised below in section 11.

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10.3 Review of On-going Objectives and Targets Jan-Dec 2009

Table 14 Review of On-going Objectives and Targets Jan-Dec 2010 Objective/ Environmental Objectives On-going Environmental Outcome of Ongoing Objective Target Resp. and Targets 2010 for On- Targets 2009 Objectives and Targets 2009 Date going Programme 100% compliance achieved. However only three samples Maintain 100% compliance. Surface water compliance G. were collected due to change Maintain 100% compliance. On-going Carry out quarterly surface monitoring. Donohoe of personnel. This has been water monitoring. corrected and quarterly monitoring will be carried out. No new noise sources Maintain existing level of introduced. No complaints minimal noise emissions. Maintain existing level of received. Noise assessments Maintain recommendations of G. - Carry out internal noise minimal noise emissions. On-going and hearing tests carried out noise assessment Donohoe assessments. successfully in 2007 and - Maintain recommendations recommendations continued of noise assessment to be maintained in 2009. Maintain suppression Emissions monitoring carried systems. out in July 2009 by ASEP Workplace emissions Maintain suppression systems. found that emissions remain monitoring. Fugitive Emissions G. Monitor and inspect system On-going at a low level but that HEPA To monitor HEPA filter Identification and Reduction. Donohoe visually. filter may be becoming less performance and to replace if efficient and allowing necessary, as per increased breakthrough recommendations given by ASEP. M+T Programme is being Maintain M+T Programme. To Implement energy efficiency G. Maintain M+T Programme. On-going maintained and energy is continue measuring energy projects. Donohoe being measured. usage and to minimise use. Maintain records to be kept by G. Records are being kept. On- Carry out housekeeping External Housekeeping On-going Environmental Representative Donohoe going – Ongoing.

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Objective/ Environmental Objectives On-going Environmental Outcome of Ongoing Objective Target Resp. and Targets 2010 for On- Targets 2009 Objectives and Targets 2009 Date going Programme Inspection audits were carried Monthly inspection audits will Carry out environmental To carry out inspection audits G. On-going out on a monthly basis – continue to be carried out – auditing on a monthly basis Donohoe Ongoing. Ongoing. Staff training records will be maintained and refresher Staff received environmental Staff training records will be courses provided where training in 2009 on the EMS maintained and refresher appropriate. New staff G. and EMP as well as corporate courses provided where Carry out employee training On-going members will undergo the full Donohoe standards, local health and appropriate. New staff training schedule. Corporate safety standards and quality members will undergo the full standards to be introduced in control. training schedule. 2008. Maintenance and calibration Maintain records which are to were carried out as per EMS Maintain monitoring and G. On-going – Continue to be kept by Environmental On-going procedures. abatement equipment Donohoe maintain records. Representative. Environmental Representative maintained all records. Waste Management Waste Register to be G. Maintain waste register On-going Waste Register maintained. Implementation maintained. Donohoe accurately. Crosslinker is not used since Review solvent content on an 2007. Platinom M (dimethyl on-going basis when new Review on an on-going basis G. phthalate) was used during Raw Material Substitution. products are introduced and On-going when new products are Donohoe 2009 in order to replace minimise content where introduced. possible. Santiciser 160, which was not REACH compliant. G. Maintain level of spillages at Spillage Prevention Maintain level of spillages at 0. On-going. No spillages occurred in 2009. Donohoe 0. Target met for no Maintain zero environmental G. Maintain level of incidents at Maintain incident level at 0. On-going. environmental incidents incidents Donohoe 0. occurring on site in 2009.

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10.4 Review of Specific Objectives and Targets Jan-Dec 2009

Table 15 Review of Specific Objectives and Targets Jan-Dec 2009 Objective/ Person Outcome of Environmental Objectives and Objective Environmental Targets for 2009 Target Responding Targets for 2009 Date

Implement corporative Implement fully corporative standards Dec 2009 G. Donohoe Ongoing. To fully implement during 2010. standards relating to HSE Fire training was conducted with all staff. PAT testing on electrical equipment and Implement fire Review corporate fire prevention thermal imaging on all heavy duty electrical Dec 2009 G. Donohoe prevention requirements and ensure compliance. equipment (motors, circuit breakers, etc.) was completed. Quarterly fire drills were carried out. Review and update recycling programme. Implement recycling Investigate ways to divert waste product Dec 2009 G. Donohoe Ongoing – No changes from previous year. programme away form landfill. Jan 2009 Implement Corporate Achieve green score month on month G. Donohoe Ongoing. To continue during 2010. Scoreboard Feb 2009 Improve Water Upgrade Conductivity and PH Meters at Completed. System was upgraded on G. Donohoe Monitoring weighbridge and Loading Dock. February 2009.

Implement ECOS. Close off all monthly items. Dec 2009 G. Donohoe All items were closed off on time.

Ensure quality of Audit of laboratory and monitoring external laboratory and Sep 2009 G. Donohoe Not done. To be carried out during 2010. contractors monitoring contractors

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Objective/ Person Outcome of Environmental Objectives and Objective Environmental Targets for 2009 Target Responding Targets for 2009 Date All washwater is collected and reused. No Reduce the amount of water used for Reduce water usage Dec 2009 G. Donohoe waste water is generated from the production washing down of equipment onsite process.

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11.0 Additional and Ongoing Objectives and Targets for 2010

While previous objectives and targets listed in Table 14 are classed as on-going and part of overall rolling programme at the site, the following specific schedule of objectives and targets (Table 16) has been formulated for completion in 2010.

Table 16 Schedule of Specific Environmental Objectives and Targets for 2010 Completion No Objectives Targets Responsibility Date Implement fully Implement Corporative December 1 corporative standards G. Donohoe Standards 2010 relating to HSE. Redo risk assessment Carry out Risk December 2 on all major plant and G. Donohoe Assessment review 2010 machinery. Review and update Carry out Chemical Risk December 3 chemical risk G. Donohoe Assessment 2010 assessment. Implement Corporate Achieve green score December 4 G. Donohoe Scorecard month on month. 2010 Implement Preventative Review and ensure its December 5 Maintenance G. Donohoe implementation 2010 programme Complete Corporate No more than 10 December 6 G. Donohoe HSE Audit corrective actions 2010 Ensure quality of Audit of laboratory and September 7 external laboratory and G. Donohoe monitoring contractors 2010 monitoring contractors Inspection of onsite bunded areas by a suitable qualified person Complete integrity and in accordance with December 8 testing of onsite bunded G. Donohoe EPA guidance notes on 2010 areas storage and transfer of materials for scheduled activities. Follow recommendations given Safe managing of in survey report carried December 9 asbestos containing out by Harrington G. Donohoe 2010 materials Asbestos removal during September 2009.

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12.0 Reports

A number of reports were completed in the period from January – December 2009. Appendices A, B, C and D contain the following:

• PRTR Summary Report • Monthly Inspection Reports • Waste Paint Analysis • Surface Water analysis and inspection checklist

13.0 Monitoring Programme 2008

Details of the environmental monitoring programme proposed for the facility for 2009 are presented below:

13.1 Surface Water

Continuous monitoring of pH and conductivity will continue at the weighbridge and loading bay monitoring locations.

Quarterly monitoring will continue for the following parameters: • pH • COD Reporting will be on an annual basis.

AER Returns Worksheet Version 1.1.10 REFERENCE YEAR 2009

1. FACILITY IDENTIFICATION Parent Company Name Valspar Industries (Ireland) Limited Facility Name Valspar Industries (Ireland) Limited PRTR Identification Number P0209 Licence Number P0209-01

Waste or IPPC Classes of Activity No. class_name 12.2.2 #######################################################

Address 1 Willowfield Road Address 2 Ballinamore Address 3 Co. Leitrim. Address 4

Country Ireland Coordinates of Location -7.79409 54.0514 River Basin District GBNIIENW NACE Code 2030 Manufacture of paints, varnishes and similar coatings, printing ink and Main Economic Activity mastics AER Returns Contact Name Gerry Donohoe AER Returns Contact Email Address [email protected] AER Returns Contact Position Environmental Officer AER Returns Contact Telephone Number 071-9645077 / 087-2359326 AER Returns Contact Mobile Phone Number AER Returns Contact Fax Number 071-9645078 Production Volume 0.0 Production Volume Units Number of Installations 0 Number of Operating Hours in Year 0 Number of Employees 0 User Feedback/Comments Web Address

2. PRTR CLASS ACTIVITIES Activity Number Activity Name 50.1 General

3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002) Is it applicable? No Have you been granted an exemption ? No If applicable which activity class applies (as per Schedule 2 of the regulations) ? Is the reduction scheme compliance route being used ? 4.1 RELEASES TO AIR | PRTR# : P0209 | Facility Name : Valspar Industries (Ireland) Limited | Filename : P0209_2009.xls | Return Year : 2009 | 29/03/2010 09:37 8 8 16 16 24 24 6 6 6 6 6 6 28 SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS RELEASES TO AIR POLLUTANT METHOD QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year 0.0 0.0 0.0 0.0 * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION B : REMAINING PRTR POLLUTANTS RELEASES TO AIR POLLUTANT METHOD QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year 0.0 0.0 0.0 0.0 * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION C : REMAINING POLLUTANT EMISSIONS (As required in your Licence) RELEASES TO AIR POLLUTANT METHOD QUANTITY Method Used Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year 0.0 0.0 0.0 0.0 * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

Additional Data Requested from Landfill operators

For the purposes of the National Inventory on Greenhouse Gases, landfill operators are requested to provide summary data on landfill gas (Methane) flared or utilised on their facilities to accompany the figures for total methane generated. Operators should only report their Net methane (CH4) emission to the environment under T(total) KG/yr for Section A: Sector specific PRTR pollutants above. Please complete the table below:

Landfill: Valspar Industries (Ireland) Limited

Please enter summary data on the quantities of methane flared and / or utilised Method Used Facility Total Capacity m3 additional_pollutant_no T (Total) kg/Year M/C/E Method Code Designation or Description per hour Total estimated methane generation (as per site model) 0.0 N/A Methane flared 0.0 0.0 (Total Flaring Capacity) Methane utilised in engine/s 0.0 0.0 (Total Utilising Capacity) Net methane emission (as reported in Section A above) 0.0 N/A 4.2 RELEASES TO WATERS | PRTR# : P0209 | Facility Name : Valspar Industries (Ireland) Limited | Filename : P0209_2009.xls | Return Year : 2009 | 29/03/2010 09:40 8 81616 24 24 6 6 6666 SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS Data on ambient monitoring of storm/surface water or groundwater, conducted as part of your licence requirements, should NOT be submitted under AER / PRTR Reporting as this only concerns Releases from your facility RELEASES TO WATERS POLLUTANT QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year 0.0 0.0 0.0 0.0 * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION B : REMAINING PRTR POLLUTANTS RELEASES TO WATERS POLLUTANT QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year 0.0 0.0 0.0 0.0 * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION C : REMAINING POLLUTANT EMISSIONS (as required in your Licence) RELEASES TO WATERS POLLUTANT QUANTITY Method Used Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year 0.0 0.0 0.0 0.0 * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button 4.3 RELEASES TO WASTEWATER OR SEWER | PRTR# : P0209 | Facility Name : Valspar Industries (Ireland) Limited | Filename : P0209_2009.xls | Return Year : 200929/03/2010 | 09:41 8 8 16 16 6 6 6 6 SECTION A : PRTR POLLUTANTS OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER POLLUTANT METHOD QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year 0.0 0.0 0.0 0.0 * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence) OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER POLLUTANT METHOD QUANTITY Method Used Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year 0.0 0.0 0.0 0.0 * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button 4.4 RELEASES TO LAND | PRTR# : P0209 | Facility Name : Valspar Industries (Ireland) Limited | Filename : P0209_2009.xls | Return Year : 2009 | 29/03/2010 09:43 8 8 16 16 6 6 6 6 SECTION A : PRTR POLLUTANTS RELEASES TO LAND POLLUTANT METHOD QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year 0.0 0.0 0.0 * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence) RELEASES TO LAND POLLUTANT METHOD QUANTITY Method Used Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year 0.0 0.0 0.0 * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button 5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE | PRTR# : P0209 | Facility Name : Valspar Industries (Ireland) Limited | Filename : P0209_2009.xls | Return Year : 2009 | 29/03/2010 09:44 5 9 8

Haz Waste : Name and Licence/Permit No of Next Destination Haz Waste : Address of Next Quantity Facility Non Haz Waste : Destination Facility Name and License / Permit No. and Actual Address of Final Destination (Tonnes per Name and Licence/Permit No of Non Haz Waste : Address of Address of Final Recoverer / Disposer i.e. Final Recovery / Disposal Site Year) Method Used Recover/Disposer Recover/Disposer (HAZARDOUS WASTE ONLY) (HAZARDOUS WASTE ONLY) Waste European Waste Treatment Location of

Quantity T/Year Transfer Destination Code Hazardous Description of Waste Operation M/C/E Method Used Treatment Name and Licence / Permit No. of Recoverer / Disposer / Broker Address of Recoverer / Disposer / Broker Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY) Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY) Mountain Lodge,Mountain Lodge,Cootehill Co. Pallets Supplies Cavan,Cootehill Co. Within the Country 15 01 03 No 18.05 Wood pallets R3 E Volume Calculation Offsite in Ireland Ltd.,WP/06/29 Cavan,Ireland Ballymount Road Lower,Merriwell Industrial Oxigen Environmental Park,Dublin,Clondalkin Within the Country 20 01 01 No 0.8 Cardboard and paper R3 E Volume Calculation Offsite in Ireland Ltd,W0208-01 Dublin 22,Ireland Grant's Drive Greenogue A1 Metal Recycling Business Park,Block Ltd.,WMP007b,Acragar,Acra 402,Rathcoole gar,Mountmellick Co. Acragar,Acragar,Mountmellic Rilta Environmental Dublin,Rathcoole Laois,Mountmellick Co. k Co. Laois,Mountmellick Within the Country 15 01 11 Yes 1.548 Steel drums R4 C Volume Calculation Offsite in Ireland Ltd.,W0193-03 Dublin,Ireland Laois,Ireland Co. Laois,Ireland Cootehill Road,Cootehill Road,Lismagratty and Curranure Townlands Cavan,Cavan Co. Within the Country 20 03 01 No 14.52 mixed municipal waste D1 M Weighed Offsite in Ireland Corranure Landfill,W0077-04 Cavan,Ireland Kilgarry Industrial Park,Kilgarry Industrial Cavan Waste Disposal Park,Cavan Co. Within the Country 20 03 01 No 1.02 Mixed municipal waste (recyclable) R4 M Weighed Offsite in Ireland Ltd.,W0207-01 Cavan,Cavan,Ireland * Select a row by double-clicking the Description of Waste then click the delete button APPENDIX B

APPENDIX C

APPENDIX D