Licence Register No. P0100

EXECUTIVE SUMMARY IPPC licence Update

Elan Corporation plc continues to operate its site at Monksland Industrial Estate, Athlone, (the Athlone site to be

referred to hereafter as Elan) under conditions applied in its Integrated Pollution Prevention & Control (IPPC) licence,

Register Number P0100-02. The following with regarding Elan's IPPC licence is noteworthy for 2010:

A site audit, by the EPA, took place on 08/12/2010, a report for which was issued on 17/01/2011. The audit

resulted in a number of minor observations (all of which were subsequently followed up on via correspondence to

the EPA). There were no non-compliant findings arising from the audit.

Overall Compliance with IPPC Licence & GHG Permit The following provides a summary of Elans Environmental performance through out 2010.

Elan achieved 99.5% compliance with wastewater emissions limits.

Elan achieved 99% compliance with air emissions limits (via non continuous monitoring).

Elan achieved 100% with all other emissions limits of IPPC licence i.e. wastewater emissions limits via continuous

monitoring, air emissions limits via continuous monitoring, noise emissions etc.

Elan achieved 100% compliance with GHG Permits conditions.

Emissions Trading & Energy Management

Elans original Greenhouse Gas Emissions Permit (Permit No. GHG011-01), under the Emissions Trading (ET)

Directive 2003/87/EC, was issued in March 2004. This original GHG Permit has undergone two revisions pursuant to

the European Communities (Greenhouse Gas Emissions trading) Regulations 2004 to 2005, S.I. No. 437 of 2004 and

S.I. No. 706 of 2005; the latest revision, Permit No. GHG011-03, being issued in correspondence dated 07/10/08.

Elans CO2 emissions for 2010 were 7,028 tonnes, versus an allocation of 13,450 tonnes, a reduction of 13% on 2009s

CO2 emissions.

Elans energy management programme in 2010 resulted in a reduction in energy usage of 14% in 2010 versus the 2009

energy usage. The reduction of energy consumption has significant environmental benefits and assists Elan in

achieving its CO2 emission targets under the Emissions Trading Directive.

Elans Operational Excellence Programme

In 2009, Elan established an Operational Excellence (OE) programme to assist Elan, Athlone in achieving its

competitiveness and continuous improvement objectives. OE is employment of lean thinking in the provisions of site

activities including development, scale-up and manufacturing activities. It involves the philosophy of leadership,

teamwork and problem solving resulting in continuous improvement throughout the organisation by focusing on the

needs of the customer, empowering employees, and optimising existing activities in the process. A cross-functional

team was set up to complete six-sigma training. The Environmental Department have engaged in this programme with

the benefit of improving on the sites environmental performance and enhancing the many elements of the

Environmental Management System.

In 2010 two projects with focus on environmental performance: (CTO Operation and Chloride Reduction in wastewater)

were completed by use of OE tools, these projects have resulted in improved performance in both areas.

Environmental Projects in the Local Community

In 2010 Elan continued its involvement as a resource to local education facilities. In the environmental discipline, Elan

facilitated visits of the facility for Environmental, Heath & Safety students of the Sligo Institute of Technology (AIT) to

present the environmental focussed activities of the site in order to demonstrate the implementation of environmental

control measures and environmental management systems typical to the Pharma-Chem sector. The involvement in this

scheme has shown to be both positive and mutually beneficial to Elan and the local community. Elan continues to

respond to requests of this nature to support environmental education programmes.

Elan also supports the Lough Ree Fish Hatchery (located in Coosan, Athlone) which continues, under the supervision

of the Shannon Regional Fisheries Board, since 2003 to provide a suitable breeding ground for trout, thus enhancing

the survival rate of the young trout in a controlled pollution-free environment.

Elan supports and encourages all employees to endeavor recycling activities both on and away from the Elan site.

While major schemes are in operation on the Elan site to support recycling, in order to encourage such activity for

employees while away from site, it was arranged that the entry fee to the Athlone Recycling Centre would be paid by

Elan for its employee. In 2010, this recycling centre received almost 670 visits from Elan employees.

Waste Management & Recycling

The quantity of waste generated in 2010 was 933

tonnes which was an increase on the 2009 figure of

874 tonnes. In total, 65% of all waste generated at

the Elan facility was recovered or recycled.

725 tonnes of non-hazardous waste was produced

in 2010; a significant increase from the 2009

quantity of 336 tonnes owning to an increase in

construction activity on the site in 2010.

The quantity of non-hazardous waste recycled

(which would otherwise have gone to landfill)

during 2010 was 548 tonnes, or 76 % of the total

quantity of non-hazardous waste. This is a

significant increase on the non-hazardous recycle

rate achieved in previous years (61% in 2009, 57%

in 2008, and 51% in 2007).

The quantity of hazardous waste decreased to 208

tonnes in 2010 (538 tonnes in 2009) of which 29%

was recovered off site and 68% treated via

incineration employing waste to energy technology.

TABLE OF CONTENTS 1.0 Introduction ....................................................................................................... 1

1.1 Facility Details .......................................................................................................................................... 11.2 Company Description ............................................................................................................................... 11.3 Organisational Structure ........................................................................................................................... 31.4 Environmental Policy ............................................................................................................................... 4

2.0 Summary Data .................................................................................................... 52.1 Emissions to Sewer ................................................................................................................................... 52.2 Surface Water Discharges......................................................................................................................... 72.3 Emissions to Atmosphere Summary ......................................................................................................... 82.4 Summary of Emissions for CTO By-Passes/Shutdowns .......................................................................... 92.5 Waste Management Summary Information ......................................................................................... 112.6 Resource Consumption ........................................................................................................................... 152.7 Environmental Non-compliances & Complaints .................................................................................... 16

3.0 Environmental Management Programme (EMP) ........................................... 183.1 EMP- Report for 2010 ............................................................................................................................ 183.2 EMP -Proposal for 2011 ......................................................................................................................... 233.3 Pollution Emissions Register .................................................................................................................. 27

4.0 IPPC Report Summaries.................................................................................. 304.1 Groundwater Monitoring 2010 ............................................................................................................ 304.2 Groundwater Monitoring Results-2010 .................................................................................................. 324.3 Surface Water and Groundwater Protection Measures ........................................................................... 384.4 Toxicity Studies ...................................................................................................................................... 394.5 Noise Report ........................................................................................................................................... 394.6 List I and List II Substances ................................................................................................................... 39

5.0 Appendix I: Summary of Waste Analysis 2010 ................................................. 406.0 Appendix II: Notes in relation to Table 2.5.2 ..................................................... 417.0 Appendix III: Transporters of Waste from the Elan site in 2010 ...................... 428.0 Appendix IV: Energy Consumption Figures Electricity