annual environmental report for 2008 · 2014. 12. 16. · and 2008 and table 2.1.3 summarises the...

Pfizer Cork, Ltd Inchera,

Little Island, Co. Cork

Annual Environmental Report for 2008

March 2009

This Annual Environmental Report, March 2008, has been prepared using the guidelines from the Environmental Protection Agency’s publication “Integrated Pollution Control Licensing, Guidance note for Annual Environmental Report”, published in October 2000. As specified in the guidance document all summary information is presented for the previous calendar year (2008). A submission of summary information in electronic format has also been made to the EPA, as requested, to comply with PRTR reporting requirements. This information is also reproduced in this report.

Contents Page no 1.0 Introduction 1.1 Facility Details 1 1.2 Site Description 1 1.3 Environmental, Health and Safety Policy 3 1.4 Company Organisation 4 2.0 Summary information 2.1 Emissions to sewer summary 7 2.2 Emissions to atmosphere summary 11 2.3 Waste management report 12 2.4 Noise monitoring summary information 20

2.5 Groundwater monitoring summary information 21 2.6 Stormwater monitoring summary information 29 2.7 Energy consumption 30 2.8 Water consumption 32 2.9 Environmental incidents and complaints 33 2.10 EPA monitoring 34 2.11 EPA Audits 38 2.12 Underground pipeline testing and bund testing 39

3.0 Environmental Objectives and Targets 40 4.0 Environmental Management Programme Report 42 5.0 PRTR 45

6.0 Proposals for AER period January to December 2008 6.1 Objectives and targets proposal 46

6.2 EMP Proposal 47 6.3 Pollutant Release and Transfer Register proposal 48 6.4 Noise monitoring programme proposal 50

Appendix: 51 Appendix 1 PRTR and waste reporting for 2008 Appendix 2 Environmental Management Programme proposal for 2009 Appendix 3 Underground line repairs and testing 2008 Appendix 4 Bund testing 2008 Appendix 5 Programme for the identification and reduction in fugitive emissions Appendix 6 Investigate the feasibility of installing silt traps and/or oil separators on

stormwater discharges

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1.0 Introduction: 1.1 Facility details: Licence Register No. P0103-02 Name: Pfizer Cork Ltd Location: Inchera, Little Island, Co. Cork. 1.2 Site description: Pfizer Cork Ltd. is located on a 25 acre site at Inchera in the Little Island Industrial Estate. The plant essentially consists of administrative offices, production facilities, quality control/warehouse complex, laboratories, utilities, maintenance workshop and storage areas. The solvent storage area and the utilities (steam, air, water, etc.) are separated from the main building and housed. Additionally there are storage tanks for water, sprinkler supply and fuel oil, together with various tanks associated with the waste water treatment plant, the carbon adsorber and the stormwater retention pond. The plant has approximately 160 employees and specialises in the manufacture of active pharmaceutical ingredients and in particular products for the treatment of cancer, CNS products and smoking cessation aids. These products are manufactured by chemical synthesis for use in formulation plants for the preparation of ampoules, tablets and other such dosage forms. Pfizer Cork Ltd became certified to ISO 14001 in December 1999 and is also a participator in the Responsible Care Programme. Through the structured management system of ISO 14001 continual improvement in environmental protection is achieved. The setting of Objectives and Targets and the use of an Environmental Management Programme are seen as critical tools to help achieve overall site improvements. In April 2003 Pharmacia Corporation were acquired by Pfizer Corporation and in January 2004 the name “Pharmacia Cork Ltd” was changed to “Pfizer Cork Ltd”. During 2004 the old Warehouse building was renovated for use as a Laboratory block and the new purified water project commenced. In June 2005 Pfizer Cork Ltd. and Pfizer Ireland Pharmaceuticals (Little Island) were merged, in terms of management structure but remained as separate legal entities. In February 2007 Pfizer announced it’s decision to sell/close the Pfizer Cork Ltd. site and as a consequence in December 2007 the leadership structures for Pfizer Cork Ltd. and Pfizer Ireland Pharmaceuticals (Little Island) were separated. The site received it’s new IPPC Licence in January 2008: P0103-02.

2

As no buyer has been found for the site, to date, the site is scheduled to close by the end of 2009, with a phased reduction in staff numbers throughout the year,

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1.3 Environmental, Health and Safety Policy Pfizer Cork Ltd. are involved in the manufacture of active pharmaceutical ingredients in Little Island. These products make an important contribution to the healthcare industry. In keeping with the Corporate Environmental, Health and Safety Policy, we are committed to conducting our operations in a manner that protects the environment, our employees, the public and the local community .We will continue to strive for continual improvement in these areas. Pfizer Cork Ltd. implements and maintains programmes to:

Minimise the risk of major and minor accidents and incidents occurring, through a risk assessment approach.

Monitor and evaluate, on a routine basis, the site environment, health and safety protection programmes to assure high standards are being maintained.

Design, construct, operate, maintain and manage its operations to high standards. Pfizer Cork Ltd are committed to conserving natural resources and preventing pollution by reducing wastes at their sources, reusing and recycling material and disposing of waste safely. We will aim for innovative and environmentally sound technologies throughout our business activities. The company complies with all relevant environmental, health and safety legislation and Corporate Guidelines and where possible exceeds legislative requirements. We foster openness and dialogue with employees and the public about our safety and environmental performance, responding, in particular, to any concerns they have about the potential hazards and impacts of our operations, products, emissions and waste. Internally we encourage employee involvement in the planning, implementation and evaluation of safety and environmental projects and initiatives. Pfizer Cork Ltd carries out appropriate training for all employees to ensure that they can carry out their duties in a manner, which does not compromise plant safety or environmental protection. We encourage similar safety and environmental standards to our own from all third parties involved with our business - suppliers, contractors and vendors. We are committed to operating an Environment and Safety Management System and a Major Accident Prevention Plan. This provides Pfizer Cork Ltd with the framework for implementing this policy and setting and reviewing safety and environmental goals, objectives and targets. The Company’s Environmental, Health and Safety Policy is publicly available, communicated to all employees, made available to stakeholders and the public and regularly reviewed to reflect legislative and company changes.

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1.4 Company Organisation Environmental aspects are integrated into the company at the top management level. New processes and changes to existing processes are scrutinised to ensure compliance with the company’s environmental, health and safety policy. The following charts 1.4.1 and 1.4.2 show the site leadership structure and the EHS Department structure.

5

Chart 1.4.1 Site Leadership structure

Site Leader

HR Leader

Supply Chain Leader

Quality Operations Leader

EHS Leader

Engineering Leader

Technical Services/RFT Leader

Operations Leader

Business Finance Leader

Site administration Support

6

Chart 1.4.2 EHS Team Organisation

EHS Team LeaderGER BARRY

Environmental Team Leader NOELLE HIGGINS

Environmental Analyst ALEX JOYCE

Environmental WWTP Operator CONOR CUMMINS

Process Safety Engineer SINEAD KEOHANE

EHS Administrator MARTINA DOBBYN

Occupational Nurse MARGARET MORRISSEY

Industrial Hygienist MARION LYONS

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2.0 Summary Information 2.1 Emissions to sewer summary Table 2.1.1 summarises the emissions to sewer during the calendar years 2006, 2007 and 2008. Table 2.1.2 and 2.1.3 summarises the toxicity testing carried out on the effluent and table 2.1.4 gives a summary of the analysis for organic solvents.

There were no non compliances with the IPPC Licence, for discharges to sewer during 2008.

Table 2.1.1 Summary information Parameter Unit Licensed

emission Note 1

2006 2007 2008

Volume m3 273,750 69,306 84,375 69,460

Temperature 0C 32 oC (max) Note 2 Note 2 Max: 24 pH 6.5-8.5 6.5-8.0 6.5-8.0 6.5-8.0 BOD kg 54,750 757 1,673 865 COD kg 273,750 8,028 12,774 9,503 Suspended Solids kg 136,875 3,933 6,485 3,127 Ammonia (as N) kg 2,737 Note 2 Note 2 33.2 Total Nitrogen (as N) kg 32,850 Note 2 Note 2 391 Sulphates kg 273,750 Note 2 Note 2 13,625 Phenols kg 547.5 <3.99 <0.64 <0.35 Anionic detergents (as MBAS) kg 1,368 Note 2 Note 2 3.47 Oils, fats and greases kg 5,475 Note 2 Note 2 451.4 Total heavy metals kg 273.7

Zinc kg 4.33 <2.93 <3.965 Hg kg <0.07 <0.08 <0.695 Cd kg <5.54 <0.2321 <0.695 Pb kg <0.35 0.380 <2.085 Cr kg <0.38 <0.6331 <0.695 As kg <0.42 0.253 <1.395 Cu kg 0.69 <0.759 <0.695 Ni kg <1.73 <0.6331 <0.695 Fe kg 15.93 31.64 <9.865

Total Phosphorus (as P) kg 13,687 269 132 320 % Compliance 100 100 100 Number of samples 348 352 288 Note 1: The licensed emission limit (kg) was calculated from the maximum concentration

limit and the maximum allowable flow rate. Note 2: prior to the issuance of the new IPPC Licence (P0103-02) in January 2008 these

parameters were not required to be tested for.

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Summary results of toxicity testing of effluent Effluent samples were tested in March and August 2008 by Enterprise Ireland Ltd. and Enterprise Environmental Table 2.1.2 summarises the results of testing of sludge on Vibrio fischeri for 2006, 2007 and 2008 and Table 2.1.3 summarises the effects of the final effluent on the respirometry of activated sludge from the Carrigrennan waste water treatment plant, over the same time period. Table 2.1.2 Method 6.2 based on BS EN ISO 11348-3:1999:”Water quality determination of the inhibitory effect of water samples on the light emissions of Vibrio fischeri (Luminescent bacteria test) – Part 3: method using freeze-dried bacteria Date Test parameter Test result No. of

Toxic units

June-06 5 min. EC50 to Vibrio fischeri >45% vol./vol. <2.2 June-06 15 min. EC50 to Vibrio fischeri >45% vol./vol. <2.2 Nov-06 5 min. EC50 to Vibrio fischeri >45% vol./vol. <2.2 Nov-06 15 min. EC50 to Vibrio fischeri >45% vol./vol. <2.2 June-07 5 min. EC50 to Vibrio fischeri >45% vol./vol. <2.2 June-07 15 min. EC50 to Vibrio fischeri >45% vol./vol. <2.2 Nov-07 5 min. EC50 to Vibrio fischeri >45% vol./vol. <2.2 Nov-07 15 min. EC50 to Vibrio fischeri >45% vol./vol. <2.2 Mar 2008 5 min. EC50 to Vibrio fischeri >45% vol./vol. <2.2 Mar 2008 15 min. EC50 to Vibrio fischeri >45% vol./vol. <2.2 Aug 2008 5 min. EC50 to Vibrio fischeri >45% vol./vol. <2.2 Aug 2008 15 min. EC50 to Vibrio fischeri >45% vol./vol. <2.2

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Table 2.1.3 Respirometry test, Method B of ISO 8192 Date Test parameter Test result

June-06 EC50 toxicity value (180 min) Greater than 50% concentration v/v

June-06 Toxic Unit value (180 min) Less than 2 TU Nov-06 EC50 toxicity value (180 min) Greater than 50%

concentration v/v Nov-06 Toxic Unit value (180 min) Less than 2 TU June-07 EC50 toxicity value (180 min) Greater than 50%

concentration v/v June-07 Toxic Unit value (180 min) Less than 2 TU Nov-07 EC50 toxicity value (180 min) Greater than 50%

concentration v/v Nov-07 Toxic Unit value (180 min) Less than 2 TU Mar 2008 EC50 toxicity value (180 min) Greater than 50%

concentration v/v Mar 2008 Toxic Unit value (180 min) Less than 2 TU Aug 2008 EC50 toxicity value (180 min) Greater than 50%

concentration v/v Aug 2008 Toxic Unit value (180 min) Less than 2 TU

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Table 2.1.4 Summary Results of Volatile and Semi/volatile Organic compounds Grab samples of effluent were taken in March, May, August and October 2008 and analysed for volatile and semi-volatile organics by Chemex Environmental International Ltd. A full range of volatile and semi-volatile organics were tested for. Only those that were detected are shown below. mg/L

Parameter detected Limit 11 Mar 2008

08 May 2008

12 Aug 2008

17 Oct 2008

Chloroform

0.002 0.002 ND ND

Tetrahydrofuran 0.002 ND ND 0.042

Acetone 0.001 ND 0.001 0.002

Methyl tert butyl ether 0.007 0.0006 0.003

ND

Bromodichloroethane

ND 0.001 ND ND

Dibromochloroethane ND 0.0005 0.0005

ND

Diethyl ether ND ND 0.003 0.0009

Bromoform ND ND 0.0007

ND

Dichloromethane ND ND ND 0.0008

Total 1 0.012

0.0041

0.0082

0.0457

ND = Not detected

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2.2 Emissions to Atmosphere Summary Table 2.2.1 below summarises the emissions to atmosphere during the calendar years 2006, 2007 and 2008. The table summarises the losses from licensed emission points (ref: P0103-02). Appendix 5 summarises losses of materials from fugitive sources. There were no non-compliances with the IPPC Licence for emissions to atmosphere during 2008. Table 2.2.1 Summary Information Parameter Units Licensed

emission2006 2007 2008

Particulates kg 80 <67 <67 <67 TA Luft Organics Class I

kg 1954 0.8 <1.16 18.4 note1

TA Luft Organics Class II

kg 9774 <50 <50 <50

TA Luft Organics Class III

kg 14661 96 39 34

TA Luft Inorganics Class II

kg 488.7 <1.0

<0.6 <0.4

TA Luft Inorganics Class III

kg 2932.2 <11.8

<4.34 <2.67

TA Luft Inorganics Class IV

kg 48870 <5.0

<3.5 <0.350

1,2 Dichloroethane kg 488.7 0.5 0.36 0.01

Chlorides (as HCl) kg 977.4 <8.280

<9.53 <7.781

Iodides (as HI) kg 488.7 <0.07 <0.12 <0.149

Amines (total) kg 977.4 <127.3

<27.8 <3.968

Sulphur oxides (as SO2)

kg 29,322 <1.454

<1.088

<0.875

Ammonia (as NH3) kg 4914 <10.626

<4.239 <1.643

Nitrogen oxides (as NOx)

kg 15,330 Not measured

Not measured

2,452

% Compliance 100 100 100 Number of samples 130 130 140 Note 1: DCM was reclassified as a TA Luft Organic Class 1 material in January

2008when the Licence was revised to P0103-02

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2.3 Waste Management Report Table 2.3.1 Annual waste arisings for 2008 (for National Waste Database) European Waste Catalogue Code

Hazardous (Yes/No)

Description of Waste Quantity (t/year)

Method of Disposal Recovery

Location of Disposal/ Recovery Name of Waste Disposal Recovery Contractor

07 05 03 Yes Waste chlorinated waste solvents from process

812.24

R6 (c) Akzo Nobel Base Chemicals bv, Welplaatweg 12, NL-3197 KK Rotterdam-Botlek

Veolia

07 05 03 Yes Waste chlorinated waste solvents from process

892.00

D10 (c) Sava, GmbH, Osterweute 1, 25541 Brunsbuttel, Germany

Veolia

07 05 04 Yes Waste non-chlorinated waste solvents from process

300.88

R13 AVR Safeway, Fermoy, Co. Cork Veolia

07 05 04 Yes Waste non-chlorinated waste solvents from process

102.48

R12-R1/R5

G.V.S GmbH & Co. KG Essener Str. 64, 68219 Mannheim, Germany

Veolia

16 05 07 Yes Laboratory waste 8.429

D10 c) Sava, GmbH, Osterweute 1, 25541 Brunsbuttel, Germany

Veolia

07 05 13 Yes Waste contaminated packaging, solids, air filters

43.1 D10 (c) Sava, Sonderabfallverbrennungsanlagen GmbH, Koogstr. 97, 25541 Brunsbuttel, Germany

Veolia

07 05 03 Yes Waste Silica wet with solvents 60.427 D10 (c) Sava, Sonderabfallverbrennungsanlagen GmbH, Koogstr. 97, 25541 Brunsbuttel, Germany

Veolia

07 05 04 Yes Waste Amberlite wet with methanol 0.32 D10 c) Sava, Sonderabfallverbrennungsanlagen GmbH, Koogstr. 97, 25541 Brunsbuttel, Germany

Veolia

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European Waste Catalogue Code

Hazardous (Yes/No)




07 05 04 Yes Waste solvents and chemicals packaged


Veolia

20 01 21 Yes Waste Fluorescent Tubes 0.1 R4 (b) Irish Lamp Recovery Ltd, Co Kildare

Irish Lamp Recovery Ltd, Co Kildare

20 01 33 Yes Waste Batteries 0.03 R4 (b) Irish Lamp Recovery Ltd, Co Kildare


18 01 03 Yes Medical waste 0.003 D8 (b)KTK Landfill SRCL

15 01 10 No Empty clean IBC 1.555 D10 (c) Sava, Sonderabfallverbrennungsanlagen GmbH, Koogstr. 97, 25541 Brunsbuttel, Germany

Veolia

07 05 13 Yes Waste ion exchange resin and waste alumina


Veolia

07 05 13 Yes Sodium chloride 0.162 D10 (c) Sava, Sonderabfallverbrennungsanlagen GmbH, Koogstr. 97, 25541 Brunsbuttel, Germany

Veolia

07 05 01 No Waste biomass 4.961 D10 c) Sava, Sonderabfallverbrennungsanlagen GmbH, Koogstr. 97, 25541 Brunsbuttel, Germany

Veolia

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Hazardous (Yes/No)




07 05 04 Yes Waste methanol 29.47

R2 (a)

07 05 04 Yes Waste isopropanol 22.16

R2 (a)

07 05 04 Yes Waste pyridine 68.39

R2 (a)

07 05 03 Yes Waste dichloromethane 39.38

R2 (a)

07 05 13 Yes Waste API 2.084 D10 (c) Sava, Sonderabfallverbrennungsanlagen GmbH, Koogstr. 97, 25541 Brunsbuttel, Germany

Veolia

07 05 13 Yes Waste oil contaminated with API 2.555 D10 (c) Sava, Sonderabfallverbrennungsanlagen GmbH, Koogstr. 97, 25541 Brunsbuttel, Germany

Veolia

07 05 12 No Sludge from WWTP 171.68

R13/R1 (b)AVR Environmental Solutions Limited, Foxhole, Youghal, Co. Cork and then (c) Betram, Kronprinzen str 24, 45128, Essen, Germany (blending) and then Innovatherm GmbH, Lunen, Germany

Veolia

15 01 06 No Office/Warehouse waste 59.01 D1 (b) Youghal Landfill, Co.Cork Veolia

20 01 08 No Canteen waste 27

D1 (b) Youghal Landfill, Co.Cork Veolia

15 01 03 No Wooden pallets 21.92

R3 (b) Veolia Veolia

20 01 01 No Paper 44.66

R3 (b) Shred-it Shred-it

15


Hazardous (Yes/No)




15 01 04 No Crushed drums 31.48 R4 (b) Cork Metal, Cork Cork Metal 20 01 02 No Glass 2.915

R5 (b) Rehab Recycling Partnership, Cork Rehab Recycling

Partnership 20 01 02 No Glass (pyrex) 0.22 D1 (b) Tullagower Quarries

Tullagower, Kilrush Co. Clare

Veolia

20 01 01 No Cardboard 7.72

R3 (b) Veolia, Cork Veolia

20 01 40 No Scrap metal 2.24

R4 (b) Cork Metal, Cork Cork Metal

07 05 13 Yes Toner cartridges 0.489 D10 (c) Sava, Sonderabfallverbrennungsanlagen GmbH, Koogstr. 97, 25541 Brunsbuttel, Germany

Veolia

16 02 13 Yes WEEE 0.592 R4 (b) KMK Metals Recycling Ltd., Tullamore, Co. Offaly

KMK Metals

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As agreed with the EPA the records showing each consignment of waste can be viewed at the site in the Waste Management Records. Table 2.3.2 is a Register of Disposal Sites used in 2008 and Table 2.3.3 is a Register of Transporters of waste. Table 2.3.2 Register of Recovery/Disposal Sites

Disposal/Recovery Sites Used in 2008

Waste stream Licence Reference

Permitting Authority

Akzo Nobel Base Chemicals bv, Welplaatweg 12, NL-3197 KK Rotterdam-Botlek

Recovery of chlorine from DCM streams

2001144652 20075068

Minifterie van volkshuisvesting ruimtelijke ordening en milieubeheer

Sava, Sonderabfallverbrennungsanlagen GmbH, Koogstr. 97, 25541 Brunsbuttel, Germany

Non-chlorinated waste lab waste, lab equipment, contaminated PPE, glassware, solids for incineration and silica wet with DCM and others for incineration

A51/V00605 A51/G00508

Goes Gesellschaft furdie organisation der entsorgung von sonderabfallen mbH

G.V.S GmbH & Co. KG Essener Str. 64, 68219 Mannheim, Germany

Non-chlorinated waste

72b3-8823.12/9.211

German authority

AVR Safeway, Fermoy Blending of solvent waste

W0050-01 EPA


Fluorescent tubes – recovery of mercury and recovery of batteries

WP 02/2000A Kildare Co. Co.

Bettram, Essen, Germany Blending of sludge

G62.352/0010811 B2

German Authority

Innovatherm, Lunen, Germany Incineration of sludge

56.8851.1.318.1

German Authority

AVR-Environmental Solutions Limited Foxhole, Youghal, County Cork

Drying of sludge and consolidation for thermal treatment

W0211-01

EPA

Youghal Landfill Landfillable W0068-01 EPA

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Disposal/Recovery Sites Used in 2008

Waste stream Licence Reference

Permitting Authority

Youghal Mudlands, Youghal, Co Cork

material

Veolia Environmental Services Forge Hill Kinsale Road Cork

Segregation of recyclables from non-recyclabes

W0173-1 EPA

Glyntown Enterprises Ltd. Unit 3, Silverbullet Warehousing, Sarsfield Court, Glanmire, Co. Cork Bailey Waste Paper Co. Ltd., Rosemount Business Park, Ballycoolin Road, Dublin 15 (through Shred-it)

Recycling of paper

11/01 WPT01

Cork Co. Co. Fingal Co. Co.

Cork Metal, Cork Metal drums and scrap metal for recovery

08/01 Cork Co. Co.

Rehab Recycling Partnership, Monahan Road, Cork

Glass and drink can recycling

635 Cork City Council

KMK Metals Recycling Ltd., Tullamore, Co. Offaly

Waste electrical and electronic equipment, batteries

WRP 033 South Dublin County Council

SRCL Ltd 430 Beech Road, Western Industrial Estate, Naas Road, Dublin 12

Sharps from medical room

W54-2 EPA

Tullagower Quarries Tullagower, Kilrush Co. Clare

Pyrex glass 015/05/WPT/CL

Clare County Council

KTK Landfill, Kilcullen Co. Kildare

Medical waste, following sterilisation

W0081-03 EPA

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Table 2.3.3 Register of Transporters of Waste Transporter of Waste Waste stream Waste Collection

Licence no. South Coast Transport

Mixed solvents CK WMC 07/01 revision 2

J P Ryan


Johnston Haulage

Solid Waste CK WMC 50/01 revision 1

Murphy Transport Ltd.


Irish Lamp Recycling

Fluorescent tubes and batteries

CKWMC 57/01

Veolia Canteen, sludge and general waste for disposal, cardboard, pallets, plastic for recovery, scrap metal,

CK MWC 10/01

Cork Metal Co. Dublin Hill, Cork

Scrap metal and metal drums for recovery

CKMWC 26/01 revision 1

Shred-it (National Document Management Group Ltd) 53, Park West Industrial Park Dublin 12

Recycling of paper CK WMC 108/02

Rehab Recycling Partnership, Cork

Glass and can recycling CK WMC 146/03 revision 1

KMK Metals Recycling Ltd., Tullamore, Co. Offaly

WEEE, batteries CK WMC 84/01

SRCL Ltd 430 Beech Road, Western Industrial Estate, Naas Road, Dublin 12

Sharps from medical room

CK WMC 08/01

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2.3.4 Annual waste statistics Table 2.3.4 below summarises the waste statistics for the calendar years 2006, 2007 and 2008. Table 2.3.4 Waste Statistics (tonnes)

2006 2007 2008 Total quantity of waste produced in calendar year (Tonnes)

4,190.55

4,026.00

2,797.97

total quantity of waste disposed of on-site

0 0 0

total quantity of waste disposed of off-site

2,175.70

1,869.24 1,607.50

total quantity of waste recovered on-site

205.26

153.33 159.43

total quantity of waste recovered off-site

1,809.59

2,003.43 1,031.05

Quantity of non-hazardous waste produced in calendar year (tonnes)

983.61

805.65 374.00

quantity of non-hazardous waste disposed of on-site

0

0 0

quantity of non-hazardous waste disposed of off-site

456.909 495.302 258.399

quantity of non-hazardous waste recovered on-site

0 0 0

quantity of non-hazardous waste recovered off-site

526.69 310.34 115.59

Quantity of hazardous waste produced in calendar year (tonnes)

3,206.95 3,220.36 2,423.97

quantity of hazardous waste disposed of on-site

0 0 0

quantity of hazardous waste disposed of off-site

1,718.79 1,373.939 1,349.097

quantity of hazardous waste recovered on-site

205.26 153.3292 159.428

quantity of hazardous waste recovered off-site

1,282.90 1,693.087 915.445

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2.4 Noise monitoring summary information The noise survey was carried out by AWN Consulting Ltd during April 2008, at the boundary and at a noise sensitive location, during day-time and night-time conditions.

Table 2.4.1 Summary of noise monitoring results LAeq dB(A) Day-time Night-time %

Compliance Location Dec 2006 June

2007 April 2008 Dec 2006 June

2007 April 2008

S1: North Esk

63

59

58

49

46

49

100

B1: west boundary of the site

59 61 57

53 60 54

-

B2: north boundary of the site

59 62 60

57 67 60

-

B3: east boundary of the site

58 58 56

58 60 56

-

B4: south boundary of the site

65 64 64

65 60 64

-

From analysis of the noise levels recorded during the survey it may be concluded that the site complies with the daytime and night-time noise criterion as specified in the IPPC licence, at the designated noise sensitive location.

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2.5 Groundwater monitoring summary information Groundwater samples were taken from boreholes no. 2, 3, 4 and 5. These were analysed as required by the IPPC Licence by Alcontrol Geochem (sampled by URS) in March and August 2008. The results are outlined in the following tables (Table 2.5.1 and table 2.5.2). Tables 2.5.1 and 2.5.2 summarise the groundwater monitoring results from these boreholes during 2008. Table 2.5.3 shows all of the results for Borehole 5 and graph 2.5.3 displays this graphically. Table 2.5.4 shows the results of samples from borehole 2, from September 2005 and Graph 2.5.4 displays this graphically.

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Table 2.5.1 Summary of groundwater monitoring results for March 2008. Parameter

Borehole #2

Borehole #3

Borehole #4

Borehole #5

pH 7.33 7.10 8.13 7.78 COD mg/L <20 <20 140 74 Conductivity µS/cm 984 831 4,767 535 Volatile Organic Compounds None detected except: Chloroform µg/L 1,2 Dichloroethane µg/L

246 <1.0

1.1 <1.0

<1.0 3.1

1,070 <8.0

Semi-Volatile Organic Compounds: None detected

ND

ND

ND

ND

ND = none detected

23

Table 2.5.2 Summary of groundwater monitoring results for August 2008 Parameter

Borehole #2

Borehole #3

Borehole #4

Borehole #5

pH 6.94 6.07 7.30 6.50 COD mg/L <20 <20 140 74 Conductivity µS/cm 776 624 4,580 590 Volatile Organic Compounds None detected except: Chloroform µg/L

795

<1.0

<1.0

2,110

Semi-Volatile Organic Compounds None detected

ND

ND

ND

ND

ND = none detected

24

Table 2.5.3 Results from monitoring of borehole 5 for Chloroform

Month, year Chloroform µg/L Jan-02 110 Feb-02 8200 Mar-02 11000 Mar-02 917 Apr-02 <1 Apr-02 11,000 Apr-02 6,800 May-02 4,500 Jun-02 19,200 Jul-02 23,600

Nov-02 <1 *Dec-02 62,000 *Dec-02 1,646 *Dec-02 51,500 Feb-03 99,000 May-03 36,709 Aug-03 28,318 Nov-03 12,956 Mar-04 20,677 May-04 15,317 Sep-04 15,516 Nov-04 18,020 Mar-05 25,230 Jun-05 18,070 Sep-05 11,397 Dec-05 11,165 Mar-06 8,436 Jun-06 6,711 Aug-06 9,722 Sep-06 577 Dec-06 2,862 Mar-07 1,975 Jun-07 656 Sep-07 2,314

Dec 2007 1,550 March 2008 1,070

October 2008 2,110

* This sample was split between three laboratories.

25

Chloroform results from Borehole 5 (ug/L)DIV 400ug/L, IGV 12 ug/L

0 0 0 0 0 4551108200110008,900

4,500

19,20023,600

56,750

99,000

36,70928,318

12,95620,677

15,00018,02025,230

18,07011,168

6,7119,722577 1,324

1,070

2,110656

15,3172,314

1,550

8,436

11,397

2,862

1,975

0

20,000

40,000

60,000

80,000

100,000

120,000

May

-99

Sep

-99

Jun-

00

Dec

-00

Jun-

01

Dec

-01

Jan-

02

Feb-

02

Mar

-02

Apr

-02

May

-02

Jun-

02

Jul-0

2

Dec

-02

Feb-

03

May

-03

Aug

-03

Nov

-03

Mar

-04

May

-04

Sep

-04

Nov

-04

Mar

-05

Jun-

05

Sep

-05

Dec

-05

Mar

-06

Jun-

06

Aug

-06

Sep

-06

Dec

-06

Mar

-07

Jun-

07

Jul-0

7

Sep

-07

Dec

-07

Mar

-08

Aug

-08

In overall terms a declining trend in chloroform concentrations in groundwater continued to be seen during 2008, from borehole 5.

Graph 2.5.3 Results from borehole 5 (chloroform)

26

Table 2.5.4 Results from monitoring of borehole 2 for Chloroform

Date Chloroform µg/L Laboratory used 28 Sep 2005 27,663 Alcontrol Geochem 25 Oct 2005 4,295 Alcontrol Geochem 08 Nov 2005 3,065 Alcontrol Geochem 12 Dec 2005 29,385 Alcontrol Geochem

20-Mar-06 20,665 Alcontrol Geochem 01-Jun-06 7,973 Alcontrol Geochem 01-Aug-06 11,296 Alcontrol Geochem 25-Sep-06 6,424 Alcontrol Geochem 07-Dec-06 2,156 Alcontrol Geochem

Mar-07 1,173 Alcontrol Geochem Jun-07 467 Alcontrol Geochem Sep-07 195 Alcontrol Geochem Dec -07 180 Alcontrol Geochem Mar-08 246 Alcontrol Geochem Aug-08 795 Alcontrol Geochem

27

Chloroform in Borehole 2 (ug/L)DIV = 400ug/L

0

27,663

4,2953,065

29,385

20,665

7,973

11,296

6,424

2,1561,173

246 795195 1803044670

5000

10000

15000

20000

25000

30000

35000

Mar

/200

5

Apr/2

005

May

/200

5

Jun/

2005

Jul/2

005

Aug/

2005

Sep/

2005

Oct

/200

5

Nov

/200

5

Dec

/200

5

Jan/

2006

Feb/

2006

Mar

/200

6

Apr/2

006

May

/200

6

Jun/

2006

Jul/2

006

Aug/

2006

Sep/

2006

Oct

/200

6

Nov

/200

6

Dec

/200

6

Jan/

2007

Feb/

2007

Mar

/200

7

Apr/2

007

May

/200

7

Jun/

2007

Jul/2

007

Aug/

2007

Sep/

2007

Oct

/200

7

Nov

/200

7

Dec

/200

7

Jan/

2008

Feb/

2008

Mar

/200

8

Apr/2

008

May

/200

8

Jun/

2008

Jul/2

008

Aug/

2008

28

The 2008 monitoring of boreholes 2 and 5, confirmed the presence of chloroform in these boreholes, above the guideline values. The August 2008 chloroform results for these wells were increases compared to the March 2008 concentrations, however they are considered to be seasonal or climatic fluctuations within the overall long-term declining trends evident in these wells, possibly related to the extremely heavy rainfall experienced between June and August 2008.

29

Stormwater monitoring summary information Table 2.6.1 summarises the stormwater monitoring carried out in 2008 Table 2.6.1 Summary of stormwater monitoring 2008

pH (continuous) TOC (continuous) ppm

Month

Range % >9 or <5

Max % >200

Action taken

Jan 6.23 - 7.56 0 34.81 0 No action required Feb 6.43 - 7.56 0 105.81 0 No action required Mar 6.51 - 7.89 0 291.65 0.18 Stormwater diverted to the

stormwater retention pond Apr 6.43 - 7.89 0 896.52 0.92 Stormwater diverted to the

stormwater retention pond May 6.36 - 8.52 0 336.31 0.58 Stormwater diverted to the

stormwater retention pond Jun 5.86 - 8.37 0 429.23 1.42 Stormwater diverted to the

stormwater retention pond Jul 5.97 - 7.94 0 331.79 0.96 Stormwater diverted to the

stormwater retention pond Aug 6.41 - 8.85 0 1250.8 0.11 Stormwater diverted to the

stormwater retention pond Sep 9.05 - 10.22 0.04 2195.8 1.02 Stormwater diverted to the

stormwater retention pond Oct 6.29 - 9.35 0.14 1181.5 0.54 Stormwater diverted to the

stormwater retention pond Nov 5.8- 9.1 0.06

600 0.65

Stormwater diverted to the stormwater retention pond

Dec 6.15 - 8.15 0 1130.5 1.73

Stormwater diverted to the stormwater retention pond

30

2.7 Energy consumption Electricity and natural gas are used on-site. Natural gas is used in the boilers.

The following graphs and tables (2.7.1) outline the electricity usage during the calendar years 2006, 2007 and 2008. Table 2.7.1 Electricity usage

Year Electricity (MWhrs) Electricity (Megawatts per

tonne of product) 2006 16,499 233.8 2007 18,737 335.5 2008 18,647 262.3

Graph 2.7.1 Electricity usage (KWHrs per tonne of product for 2006, 2007 and

2008)

0

50000

100000

150000

200000

250000

300000

350000

2006 2007 2008

Electricity usage (KWhrs) per tonne of product produced for 2006, 2007 and 2008

Note: the Kiloplant production building came on-line in 2007

31

The following table and graph (2.7.2) outlines the usage of natural gas on-site during the calendar years 2006, 2007 and 2008 Table 2.7.2 Natural gas usage

Year Natural gas (MWhrs) Natural gas per tonne of product

2006 16,537 234 MWhrs/tonne product 2007 17,116 306 MWhrs/tonne product 2008 17,609 247 MWhrs/tonne product

Graph 2.7.2

0

50

100

150

200

250

300

350

2006 2007 2008

Natural gas usage MWhrs per tonne of product produced for 2006, 2007 and 2008

Note: the Kiloplant production building came on-line in 2007

32

2.8 Water consumption Water is used throughout the site and is purified on-site for use in production. Tables and graphs (2.8.1) below outline the usage of water over the calendar years 2006, 2007 and 2008. Table 2.8.1 Usage of water (m3)

Year Water (m3) Water (m3 x 1000) per tonne of product

2006 187,319 2.65 2007 173,301 3.10 2008 119,366 1.67

Graph 2.8.1 Usage of water per tonne of product

0.00

0.50

1.00

1.50

2.00

2.50

3.00

3.50

2006 2007 2008

Water usage (m3 x 1000) per tonne of product produced for 2006, 2007 and 2008

Notes: the Kiloplant production building came on-line in 2007

A no. of leaks were repaired in end of 2007 leading to significant reduction in water usage in 2008.

33

2.9 Environmental incidents and complaints There was 1 environmental incident during 2008 and no complaints Table 2.9.1 Incident Date Incident Cause Corrective Action 13 Apr 2008 There was a high TOC reading recorded on

the stormwater on the evening of the 13th. On inspection of the pond on Monday morning (14th) the inlet valve was observed to have diverted. However when the analyst went to sample the pond on the 17th, she found that the liquid was leaving the pond via the outlet valve.

Bottom valve on pond not seated fully.

Valve repaired.

34

2.10 EPA monitoring The following samples were taken by the EPA during 2008: Table 2.10.1 EPA Sampling on 11 Feb 2008

Note 1 : monthly result Note 2: annual result Note 3: quarterly result

Final effluent from the waste water treatment plant Parameter Units Licence Limit EPA result Pfizer result pH 6.5- 8.5 7.88 6.82-6.99 COD mg/l 1000 45 59 BOD mg/l 200 6.6 8 note 1 Suspended solids mg/l 500 15 21 Ammonia mg/l 10 0.146 0.01 Total Phosphorus mg/l 50 <2.0 0.95 note 1 Total Nitrogen mg/L 120 <1.0 0.3 note 1 Sulphate mg/L 1000 <5.0 7 note 1 Phenols mg/L 2.0 <0.01 <0.005 note 2 Anionic detergents mg/L 5 0.10 <0.05 note 2 Total heavy metals mg/L 1 Iron mg/L 0.101 0.142 note 2

Manganese mg/L 0.018 Cadmium mg/L <0.0001 <0.01 note 2 Chromium mg/L 0.024 <0.01 note 2 Copper mg/L <0.005 <0.01 note 2 Nickel mg/L 0.077 <0.01 note 2 Lead mg/L <0.001 <0.03 note 2 Zinc mg/l 0.013 0.057 note 2 Aluminium mg/L <0.050

Fats oils and greases mg/L No FOG apparent

<1.0 note 2

VOC screen (by GCMS) Chloroform 1,4 dioxane Tetrahydrofuran Acetone Methyl tert butyl ether

mg/L mg/L mg/L mg/L mg/L mg/L

1

0.0013

0.002 note 3

1.3295 note 3 0.002 note 3 0.001 note 3 0.007 note 3

35

Table 2.10.2 Euro Environmental Services sampling on behalf of EPA on 15 April 2008

Table 2.10.3 Euro Environmental Services sampling on behalf of EPA on 15 April 2008

Note 1: Annual result

Air emissions monitoring from vent A201 Parameter Units Emission

Limit Value

Euro Environmental results on behalf of EPA

Pfizer result

Oxides of sulphur (SO2) mg/m3 300 <LOD 1.7 note 1 TA Luft Organics class 1 mg/m3 20 1.1 2.556 note 1 TA Luft Organics class 11 mg/m3 100 2.4 0.747 note 1 TA Luft Organics class 111 mg/m3 150 133.8 0.09 note 1 Ammonia mg/m3 50 <LOD 0.5 note 1 Chloride (HCl) mg/m3 10 8.63 3.4 note 1

Air emissions monitoring from vent A17 Parameter Units Emission

Limit Value

Euro Environmental results on behalf of EPA

Pfizer result

Nitrogen oxides as NO2 mg/m3 350 164.3 49 note 1 Oxides of sulphur (SO2) mg/m3 320 <LOD 0 note 1

36

Table 2.10.4 EPA Sampling on 11 Nov 2008

Note 1: continuous pH and TOC Note 2 visual inspection on 12th Nov

Stormwater Parameter Units EPA result Pfizer result pH pH units 7.58 5.8 – 9.1 note 1 Conductivity µS/cm 474 Not tested COD mg/L 21 Not tested Total organic carbon (as NPOC)

mg/L C

3.89 21 – 96 note 1

Appearance Pale grey/straw colour. Slight

turbidity. Moderate amount of fine

floating and settled solids. No surface

film.

Clear solution, small particulates.

Odourless. note 2

37

Table 2.10.5 EPA Sampling on 11 Nov 2008

Note 1: sample from 10th Nov Note 2: monthly sample Note 3: annual sample

From comparing the above data from Agency monitoring and monitoring carried out by the site there is no significant difference in analysis results for the majority of samples.

Final effluent from the waste water treatment plant Parameter Units Licence Limit EPA result Pfizer result pH 6.5 – 8.5 7.52 6.77 – 7.2 COD mg/l 1000 83 117 note 1 Suspended solids mg/l 500 63 55 note 1 Ammonia mg/l 10 0.043 0.12 note 1 Total Phosphorus mg/l 50 3.07 2.74 note 2

Total Nitrogen mg/L 120 <1.00 9.5 note 1

Phenols mg/L 2.0 <0.01 <0.005 note 3

Sulphate mg/L 1000 98.4 36 note 2 Anionic detergents mg/L 5 0.05

<0.050 note 3

Oils fats and greases mg/L 20 No fats, oils of grease visible on the sample

12 note 3

Total Heavy metals mg/L 1.0 0.038 Iron mg/L 0.246 0.142 note 3 Manganese mg/L 0.022 Cadmium mg/L <0.0001 <0.01 note 3 Chromium mg/L 0.006 <0.01 note 3 Copper mg/L 0.006 <0.01 note 3 Nickel mg/L <0.005 <0.01 note 3 Lead mg/L <0.001 <0.03 note 3 Zinc mg/l 0.026 0.057 note 3 VOC screen (by GCMS) Acetone Diethyl ether Dichloromethane Tetrahydrofuran

mg/L mg/L mg/L mg/L mg/L

1 0.0013

0.002 0.0009 0.0008 0.042

38

2.11 EPA Audits There were no official inspections in 2008.

39

2.12 Underground line testing and bund testing Underground chemical and foul sewer lines testing and repairs which were completed are shown in Appendix 3.

40

3.0 Objectives and Targets Table 3.1 Objectives and Targets for 2008 OBJECTIVES TARGETS (EMP Projects) COMMENTS 1 Erection of installation

notice board at the entrance to the site.

Put in place the installation notice board at the entrance to the site by the end of April 2008.

Complete

2 Residuals Management Plan to be completed by June 2008

Residuals Management Plan to be completed by June 2008

Complete

3 Environmental Liabilities Risk Assessment to be completed by Dec 2008

Complete the ELRA by December 2008, for submission to the EPA, for agreement

ELRA was completed by December and submitted to the EPA in January 2009

4 Assess background levels of detergents in final effluent

Determine the background levels of detergents in final effluent and from this agree an emission limit value with the Water Services Authority

Detergent levels in final effluent monitored over 3 months (programme agreed with Cork County Council. No detergents detected. Limit of 5mg/L suggested by Cork County Council and has been agreed by EPA.

5 Investigate the feasibitity of adding a poly dosing system to the 2nd stage clarifier

Investigate the feasibitity of adding a poly dosing system to the 2nd stage clarifier

Poly dosing system has been installed on 2nd stage clarifier

6 Put in place a programme for the identification and reduction in fugitive emissions

Prepare a report on the fugitive losses of key VOCs and chlorinated materials from the site during 2008

Complete. See appendix 5

7 Carry out an audit of the energy efficiency of the site

Audit of the energy efficiency of the site to be completed by December 2008

Energy monitoring is continuing throughout 2008, using the site’s BMS.

8 Upgrading and installation of steams traps site-wide

Installation of steam traps where none exist and upgrade of those which are inefficient

Complete

9 Establish water conservation programme

Investigate opportunities for reduction in the quantity of water used.

Assessment of use of water on-site has begun through a Green Belt (Right First Time) project. A water leak was repaired leading to a significant

41

reduction in water use in 2008 (173,301 in 2007 to 118,484 in 2008)

10 Recycle reject water from PUW process

Recycle reject water from PUW process

It has been decided not to persue this project due to the future of the site

11 Carry out an assessment of the efficiency of use of raw materials (having regard to the reduction in waste generated)

Carry out an assessment of the efficiency of use of raw materials (having regard to the reduction in waste generated)

No work will completed on this project due to the site closure.

12 Introduce improved waste recycling programme

Introduce improved waste recycling programme

Removed “open” skips from the site and replace with dedicated, labelled wheelie bins. Provided a daily collection service for cardboard, plastics (drinking cups and plastic bottles, cans and cardboard). Removed cardboard and plastic coffee/tea cups from the canteen/coffee docks.

13 Carry out integrity testing of bunds

All bunds on-site to be hydraulically tested Completed. See appendix 4

14 Investigate the feasibility of installing silt traps and/or oil separators on stormwater discharges

Carry out study of the feasibility of installing silt traps and/or oil separators on the stormwater discharges from the site.

Complete. See Appendix 6

42

4.0 Environmental Management Programme Report for 2008 Table 4.1 EMP Report 2008 Project number

Project Target Achievement to date Difficulties encountered Corrective actions implemented

1.1 Erection of installation notice board at the entrance to the site.

Put in place the installation notice board at the entrance to the site by the end of April 2008.

Complete None

1.2 Residuals Management Plan to be completed by June 2008

Residuals Management Plan to be completed by June 2008

Complete None

1.3 Environmental Liabilities Risk Assessment to be completed by Dec 2008

Complete the ELRA by December 2008, for submission to the EPA, for agreement

ELRA was completed by December and submitted to the EPA in January 2009

None

1.4 Assess background levels of detergents in final effluent

Determine the background levels of detergents in final effluent and from this agree an emission limit value with the Water Services Authority

Detergent levels in final effluent monitored over 3 months (programme agreed with Cork County Council. No detergents detected. Limit of 5mg/L suggested by Cork County Council and has been agreed by EPA.

None

1.5 Investigate the feasibitity of adding a poly dosing system to the 2nd stage clarifier

Investigate the feasibitity of adding a poly dosing system to the 2nd stage clarifier

Poly dosing system has been installed on 2nd stage clarifier

None

2.1 Put in place a programme for the identification and reduction in fugitive emissions

Prepare a report on the fugitive losses of key VOCs and chlorinated materials from the site during 2008

Complete. See appendix 5

None

3.1 Carry out an audit of the Audit of the energy efficiency of the Energy monitoring is None

43

Project number


energy efficiency of the site

site to be completed by December 2008

continuing throughout 2008, using the site’s BMS.

3.2 Upgrading and installation of steams traps site-wide

Installation of steam traps where none exist and upgrade of those which are inefficient

Complete None

4.1 Establish water conservation programme

Investigate opportunities for reduction in the quantity of water used.

Assessment of use of water on-site has begun through a Green Belt (Right First Time) project. A significant leak was repaired leading to a significant reduction in water use in 2008 (173,301 in 2007 to 118,484 in 2008)

None

4.2 Recycle reject water from PUW process

Recycle reject water from PUW process

It has been decided not to persue this project due to the future of the site

Due to the site closure at the end of 2009 this project will not be completed.

5.1 Carry out an assessment of the efficiency of use of raw materials (having regard to the reduction in waste generated)

Carry out an assessment of the efficiency of use of raw materials (having regard to the reduction in waste generated)

No work will completed on this project due to the site closure.

Due to the site closure at the end of 2009 this project will not be completed.

5.2 Introduce improved waste recycling programme

Introduce improved waste recycling programme

Removed “open” skips from the site and replace with dedicated, labelled wheelie bins. Provided a daily collection service for

None

44

Project number


cardboard, plastics (drinking cups and plastic bottles, cans and cardboard). Removed cardboard and plastic coffee/tea cups from the canteen/coffee docks.

6.1 Carry out integrity testing of bunds

All bunds on-site to be hydraulically tested

Completed. See appendix 4

Complete

6.2 Investigate the feasibility of installing silt traps and/or oil separators on stormwater discharges

Carry out study of the feasibility of installing silt traps and/or oil separators on the stormwater discharges from the site.

Complete. See Appendix 6

Complete

45

5.0 Pollutant Release and Transfer Register (PRTR) Appendix 1 shows the AER/PRTR emissions data was reported though the EPA’s AER/PRTR Emissions Data Reporting Workbook and uploaded to the EPA’s web site.

46

6.0 Proposals for AER Period 2009 6.1 Proposal for Objectives and Targets No. Title Licence

Condition 1.1 Put in place a site closure strategy 1.2 Plan for the closure of the site abatement equipment: WWTP

and carbon adsorber

1.3 Prior to closure ensure that all appropriate chemicals/solvents/API/wastes are removed from site and treated/incinerated in an appropriate manner

1.4 Compile and submit data on PRTR for 2009

6.14

1.5 Review Residuals Management Plan and agree an implementation strategy with the EPA

10.2

2.1 Continue to monitor losses of solvents from fugitive sources 6.8 3.1 Assess energy usage in the WWTP with a view to reducing

energy usage from the blowers 7.2

4.1 Continue to monitor groundwater quality on-site C.6 4.2 Agree groundwater monitoring programme for post site

closure, with the EPA

47

6.2 Proposals for Environmental Management Programme (EMP) The Environmental Management Programme Proposal for the coming year is detailed in the Appendix.

The projects for this year’s Environmental Management Programme are: 1.1 Put in place a site closure strategy 1.2 Plan for the closure of the site abatement equipment: WWTP and carbon adsorber 1.3 Prior to closure ensure that all appropriate chemicals/solvents/API/wastes are

removed from site and treated/incinerated in an appropriate manner 1.4 Compile and submit data on PRTR for 2009 1.5 Review Residuals Management Plan and agree an implementation strategy with the

EPA 2.1 Continue to monitor losses of solvents from fugitive sources 3.1 Assess energy usage in the WWTP with a view to reducing energy usage from the

blowers 4.1 Continue to monitor groundwater quality on-site 4.2 Agree groundwater monitoring programme for post site closure, with the EPA

48

6.3 Proposal for Pollutant Release and Transfer Register (PRTR)

Summary This proposal will outline the materials to be reported in the Pollutant Release and Transfer Register (PRTR) covering the period January to December 2009. Introduction Under the E- Pollutant Release and Transfer Register Regulation (EC) no. 166/2006, which was brought under Irish law through S.I no. 123 of 2007, operators of activities shall annually report emissions to it’s competent authority. Under condition 6.14 of the IPPC licence “the licensee shall prepare and report a PRTR for the site. The substances and/or waste to be included in the PRTR shall be agreed by the Agency each year by reference to EC Regulation No.166/2006 concerning the establishment of the European Pollutant Release and Transfer Register and amending Council Directives 91/689/EEC and 96/61/EC. The PRTR shall be prepared in accordance with any relevant guidelines issued by the Agency and shall be submitted electronically in specified format and as part of the AER.” The PRTR, for January 2008 to December 2009 will be submitted to the Agency, electronically through the Agency’s web based system and also through the AER. The following substances, listed in PRTR are used/emitted from the site and the quantities of these materials emitted to air, water and sewer, as appropriate, will be reported. PRTR no. Pollutant 7 Non-methane volatile organic compounds (NMVOC) 8 Nitrogen oxides 11 Sulphur oxides 12 Total nitrogen 13 Total phosphorus 14 Hydrochlorofluorocarbons (HCFCs) 35. Dichloromethane 76 Total organic carbon (TOC) (as total C or COD/3) 80 Chlorine and inorganic compounds (as HCl) Note: Chloroform and 1,2 dichloroethane, which were reported in previous years, will not be used on-site in 2009. Data Determination The data for the PRTR will be obtained using the following methods: ° Measured ° Calculated ° Estimated

49

Where possible, direct measurement will be used to determine emissions. But where this is not possible calculation and estimation techniques may also be required.

50

6.4 Proposal for noise monitoring For the coming year we propose to measure noise levels at noise sensitive locations. Readings will be taken during day-time and night-time conditions. We also propose to take measurements at the boundary fence.

We will retain the services of an outside consultant to carry out this work.

51

Appendix Appendix 1 PRTR and waste reporting for 2008 Appendix 2 Environmental Management Programme proposal for 2009 Appendix 3 Underground line repairs and testing Appendix 4 Bund testing Appendix 5 Programme for the identification and reduction in fugitive emissions Appendix 6 Investigate the feasibility of installing silt traps and/or oil separators on

stormwater discharges

Appendix 1 PRTR and waste reporting for 2008 The AER/PRTR emissions data was reported though the EPA’s AER/PRTR Emissions Data Reporting Workbook and uploaded to the EPA’s web site.

The data is reproduced in the following pages.

AER Returns Worksheet

Version 1.1.03 REFERENCE YEAR 2008

1. FACILITY IDENTIFICATION

Parent Company Name Pfizer Cork Limited Facility Name Pfizer Cork Limited

PRTR Identification Number P0103 Licence Number P0103-02

Waste or IPPC Classes of Activity

No. class_name

5.16.0The use of a chemical or biological process for the production of basic pharmaceutical products.

5.6.0

The manufacture of pesticides, pharmaceuticals or veterinary products and their intermediates, not included in paragraphs 5.12 to 5.17.

Address 1 Little Island Address 2 County Cork Address 3 Address 4

Country Ireland Coordinates of Location 17350719

River Basin District NACE Code 212

Main Economic Activity Manufacture of pharmaceutical preparations AER Returns Contact Name Noelle Higgins (P0103)

AER Returns Contact Email Address [email protected] AER Returns Contact Position Environmental Team Leader

AER Returns Contact Telephone Number 0214510266 AER Returns Contact Mobile Phone Number

AER Returns Contact Fax Number 021 4510291 Production Volume 0.0

Production Volume Units Number of Installations 1

Number of Operating Hours in Year 0Number of Employees 0

User Feedback/Comments Web Address

2. PRTR CLASS ACTIVITIES Activity Number Activity Name

4e

Installations using a chemical or biological process for the production on an industrial scale of basic pharmaceutical products

5a Installations for the recovery or disposal of hazardous waste

3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002)

Is it applicable? No Have you been granted an exemption ?

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# : P0103 | Facility Name : Pfizer Cork Limited | Filename : Fugitive emissions data .xls | Return Year : 2008 |

8 15 23 23 31 33 6 SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS

RELEASES TO AIR

Method Used A201 A17

No. Annex II Name M/C/EMethod Code

Designation or Description

Emission Point 1

Emission Point 2

T (Total) KG/Year

A (Accidental) KG/Year

F (Fugitive) KG/Year

35 Dichloromethane (DCM) C OTH

USEPA Tanks and Water9 18.0 0.0 1386.0 0.0 1368.0

34 1,2-dichloroethane (EDC) C OTH


58 Trichloromethane C OTH


07

Non-methane volatile organic compounds (NMVOC) C OTH

Mass balance 36.0 0.0 5702.0 0.0 5666.0

80 Chlorine and inorganic compounds (as HCl) M

BSEN 1911 7.7 0.0 7.7 0.0 0.0

14 Hydrochlorofluorocarbons (HCFCs) M OTH

Mass balance 0.0 0.0 83.0 0.0 83.0

08 Nitrogen oxides (NOx/NO2) M ALT 0.0 2452.0 2452.0 0.0 0.0

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



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 A201

Pollutant No. Name M/C/E

Method Code


Emission Point 1

T (Total) KG/Year



230 TA Luft organic substances class 1 M PER 18.4 18.4 0.0 0.0



4.3 RELEASES TO WASTEWATER OR SEWER | PRTR# : P0103 | Facility Name : Pfizer Cork Limited |Year : 2008 |

8 14 22 27 6SECTION A : PRTR POLLUTANTS OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR

SEWER

POLLUTANT METHOD

Method Used S1

No. Annex II Name M/C/E Method Code


Emission Point 1

T (Total) KG/Year



34 1,2-dichloroethane (EDC) M GCMS 0.03 0.03 0.0 0.0

06 Ammonia (NH3) M Std Method 33.2 33.2 0.0 0.0

35 Dichloromethane (DCM) M GCMS 0.008 0.008 0.0 0.0

12 Total nitrogen M Std Method 391.0 391.0 0.0 0.0

13 Total phosphorus M Std Method 320.0 320.0 0.0 0.0

76 Total organic carbon (TOC) (as total C or COD/3) M

Std Method 3167.0 3167.0 0.0 0.0

58 Trichloromethane M GCMS 0.048 0.048 0.0 0.0


SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence) OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR

SEWER

POLLUTANT METHOD

Method Used S1

Pollutant No. Name M/C/E Method Code Designation or Description

Emission Point 1

T (Total) KG/Year



303 BOD M PER I.S. EN 1899-1 865.0 865.0 0.0 0.0308 Detergents (as MBAS) M PER PHA 20th Ed.1998 3.47 3.47 0.0 0.0

314 Fats, Oils and Greases M PER Partition- Gravimetric Method APHA 451.4 451.4 0.0 0.0

343 Sulphate M PER Aquakem reference manual 13625.0 13625.0 0.0 0.0

240 Suspended Solids M PER Standard methods 3127.0 3127.0 0.0 0.0 0.0 0.0 0.0 0.0


5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE

| PRTR# : P0103 | Facility Name : Pfizer Cork Limited | Filename : Fugitive emissions data .xls | Return Year : 2008 | 24/03/2009 15:45

5 38

Method Used

Transfer Destination

European Waste Code Hazardous

Quantity T/Year

Description of Waste

Waste Treatment Operation M/C/E

Method Used

Location of

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)

To Other Countries 07 05 03 Yes 812.24

Waste chlorinated solvents from process R6 M Weighed Abroad

Akzo Nobel Base Chemicals bv,

Welplaatweg 12, NL-3197 KK Rotterdam-Botlek

Akzo Nobel Base Chemicals bv, Welplaatweg 12, NL-3197 KK Rotterdam-Botlek

200114465220075000


Waste chlorinated solvents from process R6 M Weighed Abroad

Sava, GmbH,

Osterweute 1, 25541 Brunsbuttel, Germany

Sava, GmbH, Osterweute 1, 25541 Brunsbuttel, Germany

AV1/V00605 AV1/G00508


Waste non-chlorinated solvents from process R13 M Weighed Abroad

AVR Safeway

Fermoy, Co. Cork

Geocycle (Scoribel) Rue de Courrière 49 Z.I.B. de Feluy BE-7181 Seneffe Belgium 38.152/BPP


Waste non-chlorinated solvents from process R12 M Weighed Abroad

G.V.S GmbH & Co.

KG Essener Str. 64, 68219 Mannheim, Germany

G.V.S GmbH & Co. KG Essener Str. 64, 68219 Mannheim, Germany 72b3-8823.12/9211


Laboratory waste D10 M Weighed Abroad

Sava, GmbH,



AV1/V00605 AV1/G00508

Within the Country 07 05 13 Yes 43.1

Waste contaminated packaging, solids and air filters D10 M Weighed Abroad

Sava, GmbH,



AV1/V00605 AV1/G00508

Method Used



Quantity T/Year



Method Used

Location of

Treatment

Name and Licence /

Permit No. of


Broker


Broker







Waste silica wet with solvents D10 M Weighed Abroad

Sava, GmbH,



AV1/V00605 AV1/G00508


Waste amberlite wet with methanol D10 M Weighed Abroad

Sava, GmbH,



AV1/V00605 AV1/G00508


Waste solvents and chemicals packaged D10 M Weighed Abroad

Sava, GmbH,



AV1/V00605 AV1/G00508


Waste fluorescent tubes R4 M Weighed

Offsite in Ireland

Irish Lamp Recovery Ltd, Co Kildare Co Kildare

Irish Lamp Recovery Ltd, Co Kildare 02/2000A


Waste batteries R4 M Weighed

Offsite in Ireland

Irish Lamp Recovery Ltd, Co Kildare Co Kildare

Irish Lamp Recovery Ltd, Co Kildare 02/2000A


Medical waste D8 M Weighed Abroad SRCL Ltd.

430 Beech Road, Western Industriasl Estate, Naas road, Dublin 12

KTK Landfill, Kilcullen Co. Kildare W0081-03

To Other Countries 15 01 10 Yes 1.555 IBC D10 M Weighed Abroad

Sava, GmbH,



AV1/V00605 AV1/G00508


waste ion exchange resin and waste alumina D10 M Weighed Abroad

Sava, GmbH,



AV1/V00605 AV1/G00508

Method Used



Quantity T/Year



Method Used

Location of

Treatment

Name and Licence /

Permit No. of


Broker


Broker







waste sodium chloride D10 M Weighed Abroad

Sava, GmbH,



AV1/V00605 AV1/G00508


waste biomass D10 M Weighed Abroad

Sava, GmbH,



AV1/V00605 AV1/G00508


Waste methanol R2 M Weighed

Onsite in Ireland on-site on-site on-site P0103-02

Within the Country 07 05 04 Yes 22.16 Waste IPA R2 M Weighed



Waste pyridine R2 M Weighed



Waste dichloromethane R2 M Weighed


To Other Countries 07 05 13 Yes 2.084 Waste API D10 M Weighed Abroad

Sava, GmbH,



AV1/V00605 AV1/G00508


Waste oil contaminated with API D10 M Weighed Abroad

Sava, GmbH,



AV1/V00605 AV1/G00508

To Other Countries 07 05 12 No 171.68

Sludge from the WWTP R13 M Weighed Abroad

Innovatherm GmbH

Lunen, Germany

Within the Country 15 01 06 No 59.01

Office/warehouse waste D1 M Weighed

Offsite in Ireland

Veolia Environmental Services

Forge Hill, Kinsale Road, Cork


Canteen waste D1 M Weighed

Offsite in Ireland



Method Used



Quantity T/Year



Method Used

Location of

Treatment

Name and Licence /

Permit No. of


Broker


Broker







wooden pallets R3 M Weighed

Offsite in Ireland



Within the Country 20 01 01 No 44.66 waste paper R3 M Weighed

Offsite in Ireland Shred-it

53, Park West Industrial Park, Dublin 12


crushed metal drums R4 M Weighed

Offsite in Ireland Cork Metal Dublin Hill, Cork


waste glass (pyrex) D1 M Weighed

Offsite in Ireland



Within the Country 20 01 02 No 2.915 waste glass R5 M Weighed

Offsite in Ireland

Rehab Recycling Partnership

Monaghan Road, Cork


waste cardboard R3 M Weighed

Offsite in Ireland



Within the Country 20 01 40 No 2.24 scrap metal R4 M Weighed

Offsite in Ireland Cork Metal Dublin Hill, Cork


waste toner cartridges D10 M Weighed Abroad

Sava, GmbH,



AV1/V00605 AV1/G00508

Within the Country 16 02 13 Yes 0.592 WEEE R4 M Weighed

Offsite in Ireland

KMK Metals Recycling Ltd.,

Tullamore, Co. Offaly

KMK Metals Recycling Ltd.,Tullamore, Co. Offaly WRP 033

Pfizer, Cork, Ltd Inchera,

Little Island, Co. Cork

Objectives and Targets

and

Environmental Management Programme

Proposal for January – December 2009 March 2009

Appendix 2

This proposal for an Environmental Management Programme is for the time period January 2009 to December 2009.

Objectives and Targets Proposal for 2009 OBJECTIVES TARGETS (EMP Projects) 1 Compliance 1.1 Put in place a site closure strategy

1.2 Plan for the closure of the site abatement equipment: WWTP and carbon adsorber


1.4 Compile and submit data on PRTR for 2009 1.5 Review Residuals Management Plan and agree an

implementation strategy with the EPA 2 Reduction in fugitive emissions 2.1 Continue to monitor losses of solvents from fugitive

sources 3 Energy conservation 3.1 Assess energy usage in the WWTP with a view to

reducing energy usage from the blowers 4 Groundwater protection 4.1 Continue to monitor groundwater quality on-site

4.2 Agree groundwater monitoring programme for post site closure, with the EPA

EMP Proposal No. Title Licence

Condition Page no.

1.1 Put in place a site closure strategy 1 1.2 Plan for the closure of the site abatement equipment: WWTP

and carbon adsorber 2


3

1.4 Compile and submit data on PRTR for 2009

6.14 4

1.5 Review Residuals Management Plan and agree an implementation strategy with the EPA

10.2 5

2.1 Continue to monitor losses of solvents from fugitive sources 6.8 6 3.1 Assess energy usage in the WWTP with a view to reducing

energy usage from the blowers 7.2 7

4.1 Continue to monitor groundwater quality on-site C.6 8 4.2 Agree groundwater monitoring programme for post site

closure, with the EPA 9

1

Project no 1.1: Put in place a site closure strategy Relationship to objectives and targets: This project is in line with Pfizer Cork Ltd.’s 2009 Objective

no.1: Compliance Reason for undertaking project: The site will be closed at the end of 2009. Target: Agree Closure Plan with all interested parties (Corporate, EPA)

by November 2009. Project summary: The closure plan will include the strategy for the handling of

the IPPC Licence once the scheduled activities have ceased on-site.

The plan will list the sampling/monitoring which will be required to be carried out post site closure and any other activities as agreed with the EPA.

Designation of responsibility: The Environmental Team Leader is responsible for the

completion of this project. Time frame: Closure plan will be complete by November 2009.

2

Project no 1.2: Plan for the closure of the site abatement equipment: WWTP and carbon adsorber

Relationship to objectives This project is in line with Pfizer Cork Ltd.’s 2009 and targets: Objective no.1: Compliance Reason for undertaking project: The site is scheduled to be shutdown by end of 2009. The

waste water treatment plant and the carbon adsorber will need to be decommissioned prior to full site closure.

Target: Agree closure plan by October 2009 Project summary: Waste water treatment plant and the carbon adsorber to be fully

decommissioned by December 2009. Plan for closure of these systems is to be developed by October

2009. Decommissioning will include cleaning of all tanks/lines and

removal of activated sludge.

Designation of responsibility: The Environmental Team Leader is responsible for this project. Time frame: Waste water treatment plant and the carbon adsorber to be fully

decommissioned by December 2009.

3

Project no 1.3 Prior to closure ensure that all appropriate

chemicals/solvents/API/wastes are removed from site and treated/incinerated in an appropriate manner

Relationship to objectives This project is in line with Pfizer Cork Ltd.’s 2009 and targets: Objective no.1: Compliance Reason for undertaking project: All production activity and associated laboratory and technical

support will finish on-site in December 2009. All appropriate chemicals/solvents/APIs/wastes will need to be removed from site prior to site shutdown.

Target: All appropriate chemicals/solvents/APIs/wastes to be

substantially removed from site by December 2009. Any chemicals remaining will be clearly identified with a reason as to why they are still on site and a plan as to what will happen to these materials.

Project summary: All materials will be classified, packaged and labelled

appropriately for transportation and sent off-site for appropriate disposal/recovery.

Where appropriate, materials will be sent for recovery/recycling but where this is not possible materials will be sent for incineration/disposal. Any sites being used will be permitted/licensed as appropriate.

Designation of responsibility: Environmental Team Leader is responsible for this project. Time frame: This project will be completed by December 2009

4

Project no 1.4 Compile and submit data on PRTR for 2009 Relationship to objectives This project is in line with Pfizer Cork Ltd.’s 2009 and targets: Objective no 1:Compliance Reason for undertaking project: Condition no 6.14 of the IPPC Licence requires that the

Licensee shall prepare and report a PRTR for the site. The PRTR shall be submitted electronically in specified format and as part of the AER.

Target: Complete sampling and analysis during 2009 to ensure that

PRTR can be submitted electronically and as part of the AER by March 2010.

Project summary: The following materials will be reported in the PRTR for the

year 2009: Mon-methane VOCs Nitrogen oxides Sulphur oxides Total nitrogen Total phosphorus Hydrochlorofluorocarbons (HCFCs)

Dichloromethane Total organic carbon (TOC) (as total C or COD/3)

Chlorine and inorganic compounds (as HCl)

Designation of responsibility: Environmental Team Leader is responsible for this project. Time frame: Sampling/analysis will be complete by December 2009. PRTR

to be submitted electronically and as part of the AER by March 2010

5

Project no 1.5 Review Residuals Management Plan and agree an implementation plan with the EPA

Relationship to objectives This project is in line with Pfizer Cork Ltd.’s 2009 and targets: Objective no 1:Compliance Reason for undertaking project: The site will close by December 2009. The site’s first RMP

was submitted to the EPA in June 2008. This Plan will be reviewed in light of the site’s closure and any amendments will be agreed with the EPA.

Target: Review RMP and agree any changes with the EPA Project summary: RMP to be reviewed any amendments discussed and agreed

with the Agency prior to site shutdown in December 2009

Designation of responsibility: Environmental Team Leader is responsible for this project. Time frame: RMP review with the EPA to be complete by November 2009.

6

Project no 2.1: Continue to monitor losses of solvents from fugitive sources Relationship to objectives This project is in line with Pfizer Cork Ltd.’s and targets: 2009 EMP objective number 2: reduction in fugitive emissions Reason for undertaking project: The IPPC Licence section 6.8 requires that the site prepares a

programme for the identification and reduction in fugitive emissions.

Target: Prepare a report on the fugitive losses of key VOCs and

chlorinated materials from the site during 2009. Project summary: A number of materials used on-site (VOCs and chlorinated

materials) are tracked every year to determine the loss of these to various media. One portion of this includes an assessment of the loss from fugitive sources.

The fugitive emissions quantification study is comprised of fugitive emissions arising from ♦ Building Ventilation Emissions ♦ Solvent Tank farm emissions ♦ WWTP emissions Sampling is used (where appropriate) and software models (Water9 and Tanks) are used to estimate losses from WWTP and solvent storage tanks.

Designation of responsibility: The Environmental Team Leader is responsible for

implementation of this project. Time frame Sampling of influent to the WWTP will be carried out in 2009, at

an appropriate time to capture processes which emit the material of interest.

A report on the fugitive losses will be included in the AER submitted by March 2010.

7

Project no 3.1: Assess energy usage in the WWTP with a view to reducing energy usage from the blowers

Relationship to objectives This project is in line with Pfizer Cork Ltd.’s and targets: 2009 EMP objective number 3: energy conservation Reason for undertaking project: The IPPC Licence section 7.2 requires that the opportunities for

energy use reduction be included in the EMP. Reduced COD loads to the WWTP, due to a reduction in production activity has resulted in a significant decreased in feed to the 2nd stage aeration system. Low F:M ratios in the 2nd stage has led to an underfed system which is more prone to shocks. This system is fed from one blower which is 45 KW.

Target: Assessment of feasibility of removing 2nd stage aeration system

to be completed by May 2009. Project summary: Assess the risks involved in removing the 2nd stage aeration

system. Removal of this aeration basin will allow one blower to be switched off, reducing the energy usage by approx 300,000 Kwhrs.

The assessment will also chart all activities in the WWTP, evaluate historical data (F:M) and highlight any engineering work required to make this change.

Designation of responsibility: The site Engineering Lead is responsible for this project. Time frame Project to be completed by June 2009.

8

Project no 4.1: Continue to monitor groundwater quality on-site Relationship to objectives This project is in line with Pfizer Cork Ltd.’s and targets: 2009 EMP objective number 4: Groundwater protection Reason for undertaking project: IPPC Licence Section C.6 requires biannual monitoring of

groundwater from boreholes 2, 3, 4 and 5. Target: Sample BH2, BH3, BH4, BH5 biannually during 2009 and

include a summary of these results in the AER to be submitted by March 2010

Project summary: URS will collect samples from BH2, BH3, BH4, BH5 in the

first and 2nd halves of the year for analysis for the parameters required in the IPPC Licence: pH COD Conductivity Volatile/semivolatile organics (including chloroform)


implementation of this project. Time frame: To be completed by December 2009

9

Project no 4.2: Agree groundwater monitoring programme for post site closure, with the EPA

Relationship to objectives This project is in line with Pfizer Cork Ltd.’s and targets: 2009 EMP objective number 4: groundwater protection Reason for undertaking project: The site will be closed by December 2009. A strategy needs to

be agreed with the EPA regarding the on-going groundwater monitoring required on the site, post site closure.

Target: Agree groundwater monitoring strategy for post closure as

regards what is required and who will be responsible for carrying out this work..

Project summary: Review current groundwater quality and historical data with

the EPA in order to agree the strategy for monitoring post site closure.


implementation of this project. Time frame Project to be completed by December 2009

1

Appendix 3 Underground line repairs and testing Foul sewer testing No From To Description 2004 2006 2007/2008

F73 F14 F14B from OP6 failed

not repaired. Line continuously surcharging back from pump sump

lined and re-tested - passed

F74 F14B F14A from OP6 failed

not repaired. Line continuously surcharging back from pump sump


F75 F14A foul sump pump from OP6 passed No longer in use

F76 F14B F14C south of OP 6 passed No longer in use

F77 F14C F14D west of tech services car park passed

failed - not relined as line reduces from 225mm to 150 mm at a4C, backdrop at 14D


F78 F14D AJ door of Tech services passed passed F87 FS01 FS02 Tech services building passed passed F88 FS02 FS03 Tech services building passed passed F89 FS03 FS28 Tech services building passed passed F90 FS28 Foul 04 south of tech services building passed passed

F11 Foul 11 Foul 12 east of tech services building failed

not repaired. Line continuously surcharging and collapsed from MH12 and MH13


F12 Foul 12 Foul 13 east of tech services building failed

not repaired. Line continuously surcharging and collapsed from MH12 and MH13


2

No From To Description 2004 2006 2007/2008

No From To Description 2004 2006 2007/2008

F13 Foul 13 Foul 04 south of tech services building failed

not repaired. Line continuously surcharging


F14 Foul 04 Foul 05 under old engineering stores passed passed F15 Foul 05 pump sump south of old engineering stores passed passed F30 F4B F4A Warehouse passed passed F31 F4A F4 Warehouse passed passed F47 F4 F3 Warehouse failed relined passed F25 F4 F5 north of Warehouse passed passed F24 F5 F7 north west of Warehouse passed passed F34 F5 F6 portacabin redundant passed F23 F7 F8 west of OP6 utilitites passed passed F22 F8 F16 west of OP6 utilitites passed passed F26 F7 F9 west of OP6 utilitites passed passed F21 F16 F15A west of OP6 utilitites passed passed F20 F15A F15 west of OP6 utilitites passed passed F29 F16 F12 west of OP6 utilitites failed redundant F27 F10 F12 north west of OP6 utilties passed passed

F28 F12 F13 north west of OP6 utilties passed

failed - not relined as line continually surcharging


F69 F5 F5A north of Warehouse unable to test relined passed F68 Foul D Co. Council south of canteen failed relined passed F37 BGE F3A BGE F3B south of engineering stores passed passed F35 BGE F3B BGE F3C south of engineering stores passed passed F36 BGE F3C BGE F3 north of admin offices failed relined passed F38 BGE F3D BGE F3 north of admin offices failed relined passed F39 BGE F30 BGE F4 north of admin offices passed passed F40 BGE F4 BGE F5 north of admin offices passed passed

3

No From To Description 2004 2006 2007/2008 F41 BGE F5 BGE F5A north of admin offices failed relined passed F42 BGE F5A BGE F6 north of admin offices failed relined passed

F43 BGE F6 BGE F8 west of admin offices failed

there is an uncharted manhole in the corridor between the canteen and admin offices. This is the cause of the leak.

lined and re-tested and passed (F6A manhole recorded)

F44 BGE F8 BGE F9 south of admin offices failed not relined lined and re-tested and passed

F45 F3A F3 west of Warehouse passed passed F46 MH2 MH1 west of Warehouse passed passed F50 MH6A MH6 west of Warehouse passed lined passed F51 MH6B MH6 west of Warehouse passed passed F53 MH6 MH5 west of Warehouse passed passed F55 MH22A MH2 west of Warehouse passed passed F56 MH2C MH2 west of Warehouse passed passed F57 MH2B MH2 west of Warehouse passed lined passed F58 MH3 MH2 west of Warehouse passed passed F59 MH3E MH3 west of Warehouse passed lined passed F60 MH3C MH3 west of Warehouse passed lined passed F61 MH2D MH2 west of Warehouse passed passed F62 MH3B MH3 west of Warehouse passed passed F63 MH6D MH6 west of Warehouse passed lined passed F64 MH3A MH3 west of Warehouse passed passed F65 MH3F MH3 west of Warehouse passed passed F66 MH5A MH5 west of Warehouse passed lined passed

F67 BGE F8 septic tank south of admin offices failed not relined lined and re-tested and passed

F70 septic tank BGE F10 south of admin offices unable to test passed

4

No From To Description 2004 2006 2007/2008 F86 Foul 19 Foul 18 south of P4 passed passed F85 Foul 18 Foul 17 south of P4 failed passed F84 Foul 17 Foul 16 south west of P4 failed passed F10 Foul 16 Foul 15 west of P4 failed relined passed F81 Foul 15 Foul 15A P4 redundant passed F82 Foul 15A Foul 14 P4 redundant passed F9 Foul 16 Foul 16A south of P5 failed relined passed F8 Foul 20C Foul 20B south of P5 passed passed F7 Foul 20B Foul 20A south of P5 failed passed F5 Foul 20A Foul 20 south west of P5 failed relined passed F4 Foul 20 Foul 21 west of EHS drum pad failed relined passed F1 Foul 21 Foul D west of EHS drum pad failed relined passed F2 Foul D septic tank south of Security passed passed F3 septic tank Foul C south of Security passed passed F16 Foul C Foul B north of Security passed passed F17 Foul B Foul A north of Security passed passed F6 Foul 20 septic tank west of P5 failed passed F33 septic tank Foul 22 west of P5 passed passed F19 Foul 22 Foul 23 north of P5 failed relined passed F18 Foul 23 Foul 24 north of P5 passed passed F32 Foul 24 Foul 25 south east of QC lab building passed passed F79 Foul 25 Foul 26 QC Lab passed passed F80 Foul 26 Foul 27 QC Lab passed passed

F83 Stair block Foul 22A

beside stair block extension for QC lab building passed passed

F48 F3 F2 north west of Warehouse failed relined passed F49 F2 F1A north west of Warehouse failed relined passed F71 F1 F1A north west of Warehouse failed relined passed

F72 septic tank ccc MH north west of Warehouse unable to test passed

5

Underground chemical line testing

No From To Description Drawing no 2004 2006 2007 2008 2009

P1 Chem 38 A Chem 38 line from tanker area beside south side TF 04212-003 passed Passed

P7 Chem 38 B Chem 38 A line from tanker area beside south side TF 04212-003 passed Passed

P8 EHS drum pad Chem 39 line from EHS drum pad 04212-003 passed Passed P3 Chem 39 Chem 38 west of EHS drum pad 04212-003 passed Passed P2 Chem 38 Chem 42 west of EHS drum pad 04212-003 passed Passed P9 A Chem 42 Chem 42B south of P5 04212-003 failed Passed P9 B Chem 42B Chem 42C south of P5 04212-003 failed Passed P9 C Chem 42C Chem 42D south of P5 04212-003 failed Passed P5 Chem 42D Chem 42E south of P5 04212-003 failed Passed P6 Chem 42E Chem 42F south of P5 04212-003 passed Passed P49 Chem 42E inside P5 inside P5 04212-003 passed Passed P46 Chem 37 inside P5 inside P5 04212-003 passed Passed P4 Chem 42 Chem 33 south west of P5 04212-003 passed Passed P40 Chem 33 Chem 33A west of P5 04212-003 passed Passed

P47 Chem 33A Chem 36 north of P5 04212-003 unable to test Constant flow

No longer in use

P48 Chem 36 Chem 37 north of P5 04212-003 unable to test Constant flow

No longer in use

P39 Chem 33A unnumbered manhole west of QC lab 04212-003 passed Passed

P41 Chem 33B Chem 32 west of QC lab 04212-003 passed Passed P35 Chem 31 Chem 30 west of QC lab 04212-003 passed Passed P79 Cem 33 C Chem 33D QC building (south) 04212-003 passed Passed P78 Chem 33B Chem 33C south of QC 04212-003 passed Passed P72 within QC Chem 41 QC building 04212-003 passed Passed P71 Chem 41 Chem 33C QC building 04212-003 passed Passed

6


P42 Chem 40 Chem 31 north of QC 04212-003 passed Passed P43 Chem 30 Chem 29 north of QC 04212-003 passed Passed P38 Chem 29 Chem 28 south of OP6 04212-003 passed Passed P37 Chem 28 Chem 27 west of WWTP 04212-003 passed Passed P23 Chem 11 Chem 27 west of WWTP 04212-003 passed Passed P22 Chem 27B Chem 27 west of WWTP 04212-003 passed Passed P30 Chem 26 Chem 27 west of WWTP 04212-003 passed Redundant P18 Chem 28A Chem 28 north of env lab 04212-003 passed Passed P25 Chem 28B Chem 28A north of env lab 04212-003 passed Passed P17 Chem 25 Chem 28A north of tech services building 04212-003 passed Passed P16 CW 24 Chem 25 west of tech services building 04212-003 passed Passed P15 CW 20 CW 24 west of tech services building 04212-003 passed Passed P12 CW 19 CW 20 east of P4 04212-003 failed Passed P11 CW 18 CW 19 east of P4 04212-003 failed Passed P76 CW 21 CW 20 P4 04212-003 passed Passed P73 CW 23 CW 22 P4 04212-003 passed Passed P67 Floor drain CW 22 P4 04212-003 passed Passed P66 Floor drain CW 22 P4 04212-003 passed Passed P65 CW 22 CW 19 P4 04212-003 passed Passed P68 CW 12A CW 12 P4 04212-003 passed Passed P69 CW 12B CW 12 P4 04212-003 failed Passed P10 CW 12 CW 18 south of P4 04212-003 passed Passed P13 CW 18C CW 18 south of P4 and P2 04212-003 passed Passed P14 CW 18A CW 18 north of south side TF 04212-003 passed Passed P80 CW 18B CW 18A north of south side TF 04212-003 passed Passed P55 CW 1A CW 1B OP4 milling/drying and corridor 04212-003 failed Passed P54 CW 1A CW 1 OP4 milling/drying and corridor 04212-003 passed Passed P59 CW 1 CW 2 OP4 milling/drying and corridor 04212-003 passed Passed P61 CW 2 CW 2A OP4 milling/drying and corridor 04212-003 passed Passed P62 OP3 CW 1 P3 04212-003 failed Passed P64 OP3 Chem 4 P3 04212-003 passed Passed

7


P33 DI Water room Chem 4 DI water OP4 04212-003 passed Passed P32 Chem 4 Chem 4A south of DI water OP4 04212-003 passed Passed P63 CW 2A Chem 4A Tech services building 04212-003 passed Passed P34 CW 4B CW 47 east of P3 04212-003 passed Passed P21 Chem 4A Chem 5A south of tech services 04212-003 passed Passed P20 Chem 5A Chem 5B south of tech services 04212-003 passed Passed P29 Chem 5B Chem 27 south east of tech services building 04212-003 passed Passed P31 Chem 4A Chem 5C south of tech services 04212-003 passed Passed P28 Chem 5C Chem AJ3 south of tech services 04212-003 unable to test Passed P27 Chem AJ3 Chem AJ2 south of tech services 04212-003 unable to test Passed P19 Chem AJ2 Chem AJ1 south east of tech services building 04212-003 failed Passed (repaired) P36 Chem 27A Chem 27 west of WWTP 04212-003 passed Passed P74 CW 22 CW 23 P4 04212-003 passed Passed

P45

battery charging room in Warehouse

pumping station Warehouse 04212-003 passed Passed

P44 Warehouse sampling rooms

pumping station Warehouse 04212-003 passed Passed

P81 DR 40 Sluice CW 24 DR 40 room 0412-003 Passed P82 Chem 32 Chem 31 West of QC Lab. 0412-003 Passed P83 DR 20 Sluice CW 24 DR 20 room 0412-003 Passed

1

Appendix 4 Bund testing

Bund Number

Bund Description Bund Location 2008 2009

B1 H2SO4 Storage North-East of Tank Farm Passed B2 HCl Tank North-East of Tank Farm Passed B3 Caustic Liquor Tank North-East of Tank Farm Passed B4 Y-20 Scrubber, FA-73 West of P2 Passed B5 DA5 Scrubber, FA-412 East of P4 Passed B6 ML-206 (Methanol) Tank Farm Passed B7 C/T-102 (Sodium Hydroxide) Tank Farm Passed B8 ML-101, ML-102, ML-103, ML-103, ML-

105, ML-106, ML-107, ML-108 Tank Farm

Passed B9 ML-109, ML-110, TT-202, ML-201, ML-

301, ML-302, ML-303, ML-203 Tank Farm

Passed B10 D2-N, D3-11 (Solvent Recovery) Tank Farm Passed B11 TT-101, TT-102N, TT-103N, WT-101N,

ST-101, ST-102N, ST-103N Tank Farm

Passed B12 ST-108A, ST-108, ST-106, ST-105, ST-

205, ST-201, ST-202 Tank Farm

Passed B13 ST-204, ST-203, ML-204, ML-205, FA-77,

CT-201, D4 Tank Farm

Passed B14 CT-301, ML-111, ML-304, ML-306, ML-

112, ML-305, ST-301N Tank Farm

Passed B15 ML-113, FA-76 Tank Farm Passed B16 Drum Storage Area West of P5 Passed B17 Pump for B19 North-West of SYN-1 Failed –

no longer in use B18 F-1683, Pumps and Valves for B21 North-West of SYN-1 Passed B19 Portable tank of HCl North-West of SYN-1 Passed B20 Pumps and Valves North-West of SYN-1 Passed B21 D-1265, D-1205, D-1675, D-1682, D-1225,

D-1295 North-West of SYN-1

Passed B22 Pumps and Valves, Storage space North-West of SYN-1 Passed B23 Storage space North-West of SYN-1 Passed

2

Bund Number


B24 Drum pumping station North of SYN-1 Passed B25 D-1428, D-1422, D-1421 North of SYN-1 Passed B26 Pumps for B27 West of Utilities Building

(Northern Side) Passed B27 D-8230, D-8250, D8210 West of Utilities Building

(Northern Side) Passed B28 Pumps for B27 West of Utilities Building

(Northern Side) Passed B29 3 x 25litre drums (Boiquase 17801,

Biosperese 535 EMD, Drewgard 886) North-West of Utilities Building

(Northern Side) Passed B30 2 Diesel tanks South-East of Utilities Building

(Northern Side) Passed B31 Drum Storage Pad North-East of Utilities Building

(Northern Side) Passed B32 D-6400 North East Tank Farm Passed B33 D-6100, D-6110, D6130 North East Tank Farm Passed B34 D-6300, D6330 North East Tank Farm Passed B35 Pumps and Valves North East Tank Farm Passed B36 D-7530, C-7520, C-7510 Carbon Absorber Passed B37 D-7506 North-West of Carbon Absorber

Passed B38 Caustic Soda, Sulphuric Acid West of Sludge Tanks Passed B39 Methanol Storage Tank North of Utilities Building

(Southern Side) Passed B40 Pumps and Valves North of Utilities Building

(Southern Side) Passed B41 Diesel Tank (old) West of Utilities Building

(Southern Side) Passed B42 Diesel Tank (new) West of Utilities Building

(Southern Side) Passed B43 Underfloor sump P6 (indoors) Passed B44 Underfloor sump SYN-1 (indoors North-West of

building) Passed B45 EHS waste Drum Pad Tank Farm Passed

3

Bund Number


B46 Pumps and Valves, Metal Recycling Skip Tank Farm Passed B47 Tanker Parking Bay North-West of Utilities Building

(Northern Side) Passed B48 Nitrogen + Plant water North of Kilo Plant Passed B49 MTBE, ETAC & IPA unloading North of Kilo Plant Passed B50 THF unloading North of Kilo Plant Passed B51 ETAC tank, MTBE tank, D-2160 tank North of Kilo Plant Passed B52 FA-52, FA-57, FA-26, FA-20, FA-21, FA-

23 South of P5

Passed B53 DA-2 (Process Gas Scrubber), FA-49 South of P5 Passed B54 DA-6 Scrubber, DA-8 Scrubber South of P5 Passed B55 FA-715, IBC-70 West of P4 Passed B56 Oil and waste oil West of utilities building

(southern side) Passed Passed B57 Oil and waste oil West of utilities building

(southern side) Passed B58 Cabinet bund (phosphorus oxychloride) South of OP5 Passed B59 Flammable storage bunds West of Warehouse Passed B60 Flammable storage bunds West of Warehouse Passed B61 Flammable storage bunds West of Warehouse Passed B62 Water reactive material West of Warehouse Passed B63 Flammable stores West of Warehouse Passed B64 Flammable stores West of Warehouse Passed B65 Underfloor sump Kiloplant underfloof sump Passed B66 Sump at tanker uloading area NE Tank

Farm Beside NE Tank Farm

Passed B67 Acid/caustic bund for DI water room External to south side DI water

room Passed

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Appendix 5 Programme for the identification and reduction in fugitive emissions EMP No 2.1 Background: The IPPC Licence (P0103-02) which was received in January 2008 contained Condition:

The licensee shall prepare a programme to the satisfaction of the Agency, for the identification and reduction of fugitive emissions. This programme shall be included in the Environmental Management Programme.

Method used: The following solvents were reviewed, as these were the largest volume solvents used on-site: Acetone n butanol 1,4 Dioxane Ethanol Hexane Isopropyl Alcohol Methanol THF The following chlorinated materials were also tracked: Chloroform 1,2 Dichloroethane Dichloromethane Estimates of losses were made from the following fugitive sources:

Process components Solvent storage tanks WWTP emissions

Process components losses: Estimated of losses of solvents from process components were made using a Pfizer standard of 1kg of solvent lost per 1,000kg of solvent used. Solvent storage tanks Losses from solvent storage tanks was estimated using Tanks software and entering the no. of times the tanks were filled during the year. WWTP losses Losses from the WWTP were estimated by using the measured concentration of solvents in the influent and modelling the outcome using Water9. The total of the 3 sources of fugitive losses was added to give the total loss for the site.

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Results

Fugitive losses kg Material Net use kg Process

components

Solvent storage tanks

WWTP emissions

Total Fugitive losses

kg

Fugitive losses as % of total use

Acetone 40,559 41 63 0 104 0.26n butanol 146,346 146 1 108 255 0.171,4 Dioxane 8,067 8 0 73 81 1.00Ethanol 49,829 50 22 1260 1332 2.67Hexane 10,806 11 31 0 42 0.39Isopropyl Alcohol

93,247 93 8 263 364 0.39

Methanol 153,277 153 32 2874 3059 2.00THF 41,234 41 78 339 458 1.11Dichloromethane 519,604 174.1 434.9 759 1368 0.261,2 Dichloroethane

9,568 0 0.5 18.7 19.2 0.20

Chloroform 8,877 0 1 20.8 21.8 0.25Total 1,081,414 688.1 671.4 5715.5 7075 0.65 Discussion: Losses of the main 8 solvents used on-site, as well as the 3 chlorinated materials used on-site in 2008 was completed for 2008. 0.65% of the total net use was estimated to have been lost during 2008 from fugitive sources. Ethanol and methanol losses were seen to be at or above 2% and this was mainly from the WWTP. Due to the planned closure of the site at the end of 2009 and the phased shutdown of production processes chloroform, 1,2 dichloroethane and 1,4 dioxane will not be used on-site in 2008. Dichloromethane will continue in use in 2008 but at significantly lower volumes, than previous years.

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Appendix 6: Investigate the feasibility of installing silt traps and/or oil separators on stormwater discharges

EMP No. 6.2 Background: The IPPC Licence (P0103-02) which was received in January 2008 contained Condition 3.8:

The licensee shall investigate the feasibility of installing silt traps and/or oil separators on storm water discharges from the installation. Any separator installed on foot of the investigation shall be a Class I full retention separator and the silt traps and separator shall be in accordance with I.S. EN 858-2:2003 (separator systems for light liquids). A report on this study shall be included in the AER to be submitted by 31st March 2009 and any recommendations arising shall be incorporated into the Schedule of Environmental Objectives and Targets with a timeframe to be agreed by the Agency.

Risk Assessment A risk assessment approach was used in the review of the stormwater discharges points to assess their potential to cause stormwater contamination. The risk assessment took into account the area which was drained and the activities carried out in that area, any monitoring/control systems already in place and the ultimate location of discharge. There are 4 locations of stormwater discharge from the site, as shown in drawing FSK 2024: SW1: The storm drains from the majority of the site (including all areas where chemicals/processing

materials are stored and used) are gravity drained to one location, monitored for TOC and pH and then leave the site at SW1 (to the north at Upper Loughmahon). In the event of any contamination being detected the flow is diverted to the retention pond on-site. Any silt or heavy particles in the stormwater from this area will be collected in the monitoring sump, which is cleaned regularly.

SW3: Stormdrains from the north west of the site drain directly to the Harbour at SW3. This area collects

stormwater runoff from a roadway and a contractors’ compound. As a consequence of the scheduled closure of the site at the end of 2009, there is now only occasional use of this area and therefore a low risk of contamination from moving traffic entering the stormwater system.

SW4: The car park to the west of Security drains to the County Council stormwater sewer to the west of

the site at SW4. The County Council stormwater sewer services the Little Island area. The risk of a spill of diesel/petrol as a consequence of an accident in this area is considerably lower than the risk of a spill on the main roadway, as cars are limited to 15km/hr. Also the risk of causing significant contamination to this large stormwater sewer, from spilled diesel/petrol from the car park area is deemed to be low (given the volumes of stormwater generated in this car park area and the volumes of stormwater carried in the sewer).

SW5: The roadway to the east of Security drains to the County Council stormwater sewer at SW5, at the

south west corner of the site. Again, the risk of causing significant contamination to this large stormwater sewer, from spilled diesel/petrol from this roadway is deemed to be low.

Conclusion It is therefore concluded that silt traps and/or oil separators are not required to be installed on any of the 4 stormwater discharge points from the site. This assessment is based on the current on-site risks, taking into account the reduction in activity on-site, particularly in the area drained to SW3.

annual environmental report for 2008 · 2014. 12. 16. · and 2008 and table 2.1.3 summarises the...

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