annual environmental report 2012 · 4.2 noise monitoring report summary 2012 ... the principal...

Annual Environmental

Report 2012

Company: Baxter Healthcare SA Address: Moneen Road, Castlebar, Co. Mayo Licence Register No: PO636-02

Declaration

All the data and information presented in this report has been checked and certified as

being accurate. The quality of the information is assured to meet licence requirements.

Caitriona Gannon Michelle Bourke

1.0 INTRODUCTION ............................................................................................................................. 1

1.1 FACILITY DETAILS .......................................................................................................................... 1 1.2 BRIEF DESCRIPTION OF THE ACTIVITIES AT THE SITE .................................................................... 1 1.3 ENVIRONMENTAL OPERATING STRUCTURE IN USE AT THE SITE ................................................... 3 1.4 COMPANY ENVIRONMENTAL POLICY ............................................................................................. 6 1.5 ORGANISATIONAL STRUCTURE ....................................................................................................... 7

2.0 SUMMARY INFORMATION ........................................................................................................ 8

2.1 SELF-MONITORING DATA ............................................................................................................... 8 2.1.1 Emissions to Sewer ................................................................................................................. 8 2.1.2 Emissions to Surface Water .................................................................................................... 9 2.1.3 Emissions to Atmosphere ...................................................................................................... 11

2.2 SUMMARY OF WASTE ARISING ..................................................................................................... 12 2.3 ENERGY AND WATER RESOURCE CONSUMPTION SUMMARY ...................................................... 12 2.4 SUMMARY OF NOTIFICATIONS OF NON-COMPLIANCES ................................................................ 13 2.5 SUMMARY OF ENVIRONMENTAL INCIDENTS ................................................................................ 14

2.5.1 Comments on Table 9 Environmental incidents .......................................................................... 17 2.6 SUMMARY OF ENVIRONMENTAL COMPLAINTS ............................................................................ 18

3.0 MANAGEMENT OF THE ACTIVITY ....................................................................................... 19

3.1 INTRODUCTION .............................................................................................................................. 19 3.2 REPORT ON PROGRESS OF ENVIRONMENTAL MANAGEMENT SYSTEM FOR 2012 ........................ 20 3.3 ENVIRONMENTAL MANAGEMENT PROGRAMME 2013 ................................................................. 28 3.4 WASTE MANAGEMENT.................................................................................................................. 35 3.5 POLLUTANT RELEASE AND TRANSFER REGISTER – REPORT FOR 2012 & PROPOSAL FOR 2013 .. 41

4.0 LICENCE-SPECIFIC REPORTS ................................................................................................ 42

4.1 ANNUAL CO2 EMISSIONS ............................................................................................................. 42 4.2 NOISE MONITORING REPORT SUMMARY 2012 ............................................................................. 43 4.3 GROUNDWATER MONITORING REPORT SUMMARY ...................................................................... 44 4.4 REPORT ON ANNUAL SOLVENT USAGE ........................................................................................ 46 4.5 RESPIROMETRY TESTING ............................................................................................................. 47 4.6 TOXICITY TESTING ....................................................................................................................... 48 4.7 API ABSENCE TESTING ................................................................................................................. 48 4.8 PROCESS RAW MATERIALS USAGE EFFICIENCY .......................................................................... 49 4.9 ENVIRONMENTAL LIABILITY STATEMENT .................................................................................... 49

APPENDICES

APPENDIX A Summary of Waste Arising

APPENDIX B Baxter‟s AER /PRTR Returns

APPENDIX C Waste Contractors

APPENDIX D Baxter Products

APPENDIX E Energy Projects 2012, Energy Efficiency Audit Summary Report & Energy Business Plan 2013

APPENDIX F Bund Integrity Reports

APPENDIX G Pipe & Sump Integrity Reports

1

1.0 INTRODUCTION

1.1 Facility Details

This Annual Environmental Report (AER) has been compiled for the Baxter Healthcare SA facility

located at Moneen Road, Castlebar, Co. Mayo. This facility was established in July 1972. Baxter‟s

Irish Manufacturing headquarters in Ireland and it currently operates under IPPC Licence Register

No. PO636-02. Today there are over 1,000 people employed between the Baxter facility in Castlebar

and the Baxter facility located in Swinford, Co. Mayo. The direct payroll and economic contribution

generated through Baxter Healthcare operations is significant in the Castlebar catchment and Region.

National Grid Reference

Easting 5 1 5 8 7 3 Northing 7 9 0 0 3 8

Licence details

Company Name Baxter Healthcare SA

Location Moneen Road, Castlebar, Co. Mayo

Register Number P0636-02 (Technical amendment A dated 24th November 2010)

Commencement Date 20th August 2007

Principal class of activity The use of chemical or biological process for the production of

basic pharmaceutical products

1.2 Brief Description of the Activities at the Site

Products Manufactured at the Site

Baxter Healthcare is a global medical products and services company. Through Baxter‟s subsidiaries,

the company provides critical therapies for people with life-threatening conditions. Baxter‟s products

include biopharmaceuticals, vaccines, bio-surgery products, transfusion therapies, medication

delivery and renal therapy.

The products that are currently manufactured in Baxter Castlebar can be described as follows:

Medication Delivery (MD) – these are intravenous solution products in small bag sizes

ranging from 50ml and 150ml, these products are used most frequently for drug

administration in intravenous format to patients.

Renal Therapy – these are a range of dialysis solution products for patients who suffer from

kidney failure. The principal category is peritoneal dialysis solutions that enable dialysis to

take place in the patient‟s home.

See appendix D for information on Baxter‟s products.

2

Processes Used at the Site

The dialysis product processes operated at Baxter Castlebar are all similar:

The Primary containers for both medication delivery and renal products (Bags which range in

size from 50ml to 5 Litre) comprise of materials that are classed as PVC and Non-PVC. The

films used to manufacture the Non PVC Bags on site are supplied by a Baxter Healthcare

sister plant in Switzerland, while all PVC bags are received pre formed from a sister plant in

Belgium. PVC tubing for some of the renal product is extruded on site.

Dialysis solutions are prepared using sterilised water in large tanks. The ingredients are

added manually. The mixed solution is then filled into bags. The bags are enclosed in

pouches, and piping attached. The assembled product is sterilised in steam chambers. The

sterilised product is packed into cardboard boxes and despatched on wooden pallets.

The current processes are:

Twinbag Process - involves the manufacturing of Dialysis Solution, which is filled

into plastic bags, sterilised and packed.

Mainline Process - involves the manufacturing of Dialysis Solution, which is filled

into plastic bags, sterilised and packed.

Miniline Process - involves the production of a range Sterile Premixed Drugs in

intravenous (IV) Solutions.

Physioneal Process - this process is the same as the Twinbag process, except that the

product is pH compatible with the human body, and is packed in a gas barrier pouch.

Physioneal Clearflex – A renal dialysis solution filled into a Non PVC two chamber

container utilising an in-line Form Seal process.

Normal operating hours are Monday to Friday, 3 shifts, Saturday and Sunday, 2 shifts. Baxter‟s site

is provided with 24-hour security 7-days a week.

3

1.3 Environmental Operating Structure in Use at the Site

Baxter Corporation has a strong commitment to Environmental Excellence and promotes a

"State of the Art" Environmental Programme. Baxter Ireland incorporated these Programmes

into its Strategic Business Plan in early 1992. The Irish Manufacturing Operations (IMO)

Environmental, Health and Safety Policy (EHS) Statement and the IMO‟s EHS

Organisational Structure are included at the end of this section.

The facility has established and maintains a documented quality system, which ensures that

the product conforms to specific requirements. This system includes the preparation and

implementation of documented quality system procedures and instructions in accordance with

the Quality Manuals, and in compliance with the applicable regulatory requirements. The

facility also operates both an environmental and a health and safety management system, both

systems are accredited to the ISO 14001 and OSHAS 18001 standards and are certified by

ERMCVS.

The facility holds a Green House Gas Permit Number, IE-GHG-133-05, Installation No. IE-

97, Activity Code E1.1. The facility holds a Police Certificate for Keeping Explosives for

Private Use Serial No. 188943, Form C 49, the explosive chemicals are 500g Ammonium

nitrate, 500g Potassium Nitrate, 225ml of Nitrobenzene, 150g Sodium Nitrite, 500g Potassium

Dichromate, 100g Potassium Chromate and 1kg Magnesium Nitrate hexahydrate . This

certificate is reviewed and re-issued on an annual basis. In addition to external requirements,

the plant also operates to Baxter Corporate requirements.

The Baxter Irish Manufacturing Operations EHS Management Programme is designed to

protect the health and safety of all our employees, the public and the environment. The

programme is an integral part of the Irish Manufacturing Operations business and its goals are

included in our business plan. The Senior Management Group define the EHS policies,

working alongside the Senior Management Team and with individual employees, implements

these policies.

The Environmental, Health & Safety Management System Procedure lays out the format to

document, achieve and maintain an Environmental, Health and Safety Management System

(EHSM) that conforms to the operation‟s environmental, health and safety policy and meets

in full the requirements of the Environmental Management Standard – ISO 14001, OHSAS

18001 Safety Management System Standard and Integrated Pollution Control Licence.

On the basis of the results from Corporate and Division/Internal Audits, EHS reviews and

Risk Assessment outcomes, we have established EHS objectives and targets. The objectives

and targets are in line with Baxter Corporate and Baxter Irish Manufacturing Operations

policy statements and are reviewed on a regular basis with the EHS Dept alongside the Senior

Management Team.

The principal EHS goals are reviewed at the EHS Management System Annual Management

Review. The goals and targets are incorporated into the Business Plans for the Operation.

Responsibility is given to individuals to oversee the implementation of the goals. Progress

made towards achieving these goals/targets is reviewed on a regular basis at the EHS

Meetings and at the Quarterly EHS Review meetings with Senior Management. It is the

responsibility of Senior Management to communicate to their reportees any

issues/recommendations from this review. EHS key performance indicators are included in

4

all employees Performance Management Objectives (PMOs) specified in the company‟s

annual appraisal system.

The organisation has identified and evaluated its EHS aspects. The organisation has

identified and evaluated its EHS Risks and Hazards as per National Requirements. Risk

Assessment Master Plan shows the scope/severity/frequency of risks and their plans for

completion of risk assessments on site.

All new projects and processes are reviewed to determine whether they are acceptable

from an environmental point of view, and the means needed for preventing, or if that is

not possible, minimising environmental impact, through application of the best available

techniques. This is addressed through procedure Procedure IR36-11-02-015 on Risk

Assessment Management Plan.

Waste is minimised by a comprehensive waste management programme of recovery,

recycling and reuse, end-of-pipe or final disposal is only used where there is no other

practicable option. All Waste on site is managed through the EHS Department. The EHS

Department is responsible for sourcing all waste contractors used, obtaining all required

documentation and are responsible for tracking and maintaining all paperwork pertaining to

the waste types taken off site. As a corporate requirement, the EHS Manager carries out

Regulated Waste Management Site audits on all hazardous waste contractors on a frequency

set by Corporate procedures.

Baxter Castlebar has a very successful and long-standing Energy Reduction Quality Working

Team, which are very much, results driven. Designed to focus on energy use and through the

application of technology, skill and company wide commitment, to achieve real savings in

energy costs, improve competitiveness and as a consequent reduction in environmental

impact.

As per Schedules 1 – 4 of the IPPC licence various environmental monitoring is carried out at

Baxter to include; air, effluent, surface water, groundwater, waste analysis and noise

monitoring. Ambient monitoring of air quality, ground water and noise shows that the impact

of Baxter‟s operations is minimal. An external accredited laboratory carries out all the

wastewater analysis on a daily, weekly and monthly basis where applicable.

Baxter have developed and implemented a comprehensive emergency response plan, this plan

establishes the responsibilities and procedures for anticipated emergency situations, the

training requirements for responsible parties and an inventory of emergency response

equipment. It clearly defines roles and responsibilities of all employees in an emergency

situation. In addition to the emergency response plan, there is a fully trained emergency

response team available on every shift to deal with any emergencies that may occur.

24-hour security is provided on the site to continuously monitor all activities on site both

internal and external.

All employees receive updates at Departmental meetings pertaining to the current EHS issues

and programme. They are made aware of their individual responsibilities in relation to waste

minimisation and assistance with recycling programmes and their compliance with EHS

Procedures and Regulations. Procedures relating to the EHS Aspects are updated through

Baxter standard operating procedures within the QA system

5

EHS quarterly reviews for senior managers are held at the end of each quarter to review

progress on EHS goals, targets and various EHS projects. This review also provides an update

on the current status of all monitoring and inspections carried out. Also Corporate EHS

newsletters, Division EHS, Baxtra Articles, weekly communication meetings, site specific

publications on our environmental, health & safety programme creates awareness of our EHS

programme amongst employees.

A training plan has been compiled which lists the training requirements for individual

personnel. Training records are maintained by the HR Department recording the training

sessions attended. New employees receive EHS orientation presentation (which identifies the

hazards within the plant) and tour of recycling areas, fire evacuation routes within the plant.

They also are instructed on the EHS policies and procedures we have in place and on EHS

issues in general pertaining to our operations.

6

1.4 Company Environmental Policy

ENVIRONMENTAL, HEALTH & SAFETY POLICY STATEMENT Baxter‟s Irish Manufacturing Operation comprising the Castlebar and Swinford plants is committed to

Environmental, Health & Safety (EH & S) leadership and meeting all Regulatory, Division and Corporate

Requirements.

The Irish Manufacturing Operation is focused on being the leading supplier of the products we

manufacture achieving this through continuously improving quality, value, and the services we provide to

our customers and through respect for the environment.

To accomplish this, we are integrating Environmental, Health & Safety principles into all our business activities.

1. Leadership: The Irish Manufacturing Operation is committed to leadership and Continuous improvements in

respect of EH & S. We will maintain a state-of-the-art EHS programme in terms of OSHAS 18001 and the ISO-

14001 International Standard.

2. Legal Compliance: We will commit to complying with all Irish and European Union laws and regulations.

We will also commit to adhering to Corporate requirements. Baxter Healthcare Corporation has in the past and

will continue in the future to demonstrate continuous improvements in EH&S performance beyond statutory

obligations as far as is economically achievable.

3. Waste Minimisation: Baxter‟s Irish Manufacturing Operation will commit to aggressively pursuing

opportunities to minimise waste and the prevention of pollution. Specifically we will commit to reducing

hazardous and non hazardous waste against our annual targets. We will commit to maintaining an aggressive

waste cardboard, paper, plastic, batteries, fluorescent bulbs, pallets, metals, drums, electronic waste and oil

recycling programmes.

4. Energy Conservation: Through increasing energy efficiency in line with current targets, we will meet our

commitment to the Baxter corporate energy programme.

5. Accident Prevention: Through our proactive intervention programme we will commit to minimising the

number of accidental incidents at both operating facilities. We will commit to reduction in lost workday

accidents, lost workdays and recordable accidents in line with our corporate targets and also provide effective

injury management for all employees.

6. Workplace Environment: Through active ergonomics, noise reduction and air quality programmes, we will

commit to enhancing the workplace environment for all of our employees.

7. Risk Analysis/Control: We will maintain an Emergency Response Plan and risk analysis programmes to

minimise risk to personnel, the environment and company.

8. EHS Co-ordinators and Managers: The EH&S Manager has overall responsibility for EH&S protection and

the EH&S programme. In addition, each employee and particularly every manager are responsible for

compliance with this Policy.

9. Training and Audits: The Irish Manufacturing Operation will provide co-ordinated, effective EH&S

training, awareness and audit programmes to educate the staff and contractors on the company‟s EH&S policy

and procedures. We will assist our contractors, suppliers and customers to develop a similarly concerned

approach to protection of their personnel and the environment.

10. Communication: We will maintain communication links with Baxter Corporate Headquarters and Division

personnel, shareholders, authorities, community groups and neighbours as relevant in relation to EH&S affairs.

11. Public Availability: Our EHS Policy Statement is made available to the public through the EHS Department

in the Castlebar plant and the General Office Area in the Swinford plant. In addition a copy of our EH&S policy

has been made available to all employees, and is displayed in reception, on the EH&S notice boards and will be

periodically reviewed

- 7 -

1.5 Organisational Structure

Figure 1: Company Organisational Chart for Environmental Management at Irish Manufacturing Operations

Alan Weiler

PLANT MANAGER

IMO

Gerry Prendergast

Engineering Director

Caitriona Gannon

EHS Manager.

Michelle Bourke

EHS Coordinator.

- 8 -

2.0 SUMMARY INFORMATION

2.1 Self-Monitoring Data

2.1.1 Emissions to Sewer

Emissions to sewer were discharged from the plant in accordance with condition 4/5

and Schedule B/C of the IPPC Licence.

Baxter has one emission points to process waste (PW). The PW discharge point is

monitored for the parameters shown in Table 1. The summary table shows that for the

mass emissions for the year 2012 were in compliance with the Licensed Mass

Emissions for all parameters.

The current monitoring programme for the emissions to sewer consists of online pH,

Temperature and flow measurements and 24hour flow proportional composite samples

taken for analysis in accordance with the IPPC licence conditions

TABLE 1 SUMMARY OF MASS EMISSIONS 2011 & 2012

Parameter Mass

Emissions

for 2011

(Kg/year)

Mass

Emissions

for 2012

(Kg/year)

Licensed Mass

Emission

(kg/year)

Volume (m³) 437,035 454,987 547,500

BOD 180,802 175,005 547,500

COD 269,988 272,557 1,368,750

Suspended Solids 14,258 11,300 80,300

Ammonia (as N) 18.32 9.74 803

Total Phosphorous (as P) 52 131 1,606

Sulphate (as SO4) 13,471 26,341 54,750

Detergents (as MBAS) 301 307 4,015

Fats, Oils & Grease 2314 3961 32,120

Chloride 230,215 255,451 365,000

Comment:

Overall it can be seen that loading to sewer of each of the physical/chemical parameters

were well below the licensed mass limits for 2012.

- 9 -

2.1.2 Emissions to Surface Water

Table 2 below presents a summary of the emissions to surface water for 2012.

Week Beg.

Surface West Surface

West Surface East

Surface East

COD (mg/l) pH COD (mg/l) pH Warning limit-100mg/l Action limit 150mg/l 6 - 9.5

Warning limit-100mg/l Action limit 150mg/l 6 - 9.5

31/12/2011 77 8.55 35 8.1

07/01/2012 110 7.69 35 7.94

14/01/2012 42 8.53 34 8.3

21/01/2012 38 9.1 38 8.13

28/01/2012 75 7.66 35 8.15

04/02/2012 42 7.89 33 8.15

11/02/2012 45 8.97 38 8.19

18/02/2012 100 7.85 43 8.46

25/02/2012 70 8.04 37 8.03

03/03/2012 58 8.67 37 7.96

10/03/2012 47 8.52 40 8.27

17/03/2012 47 8.65 35 8.12

24/03/2012 132 8.57 45 8.05

31/03/2012 68 9.41 8.11 47

07/04/2012 37 8.59 8.31 37

14/04/2012 50 7.98 32 7.93

21/04/2012 127 8.48 35 8.12

28/04/2012 60 9.22 47 8.01

05/05/2012 40 7.99 40 8.16

12/05/2012 43 8.61 38 8.11

19/05/2012 55 8.93 45 8.02

26/05/2012 45 8.62 44 8.2

02/06/2012 35 8.49 37 7.95

09/06/2012 38 8.6 36 8.29

16/06/2012 37 8.05 41 8.09

23/06/2012 35 8.18 42 8.33

30/06/2012 42 8.93 41 8.15

07/07/2012 45 9.25 46 7.93

14/07/2012 60.0 8.93 63.0 8.09

21/07/2012 58 8.97 56 8.05

28/07/2012 * * * *

04/08/2012 * * 53 8.02

11/08/2012 119 7.85 45 8.02

18/08/2012 62 7.33 50 7.9

25/08/2012 50 8.43 46 8.04

01/09/2012 56 7.82 42 7.9

07/09/2012 45 8.96 42 8.26

14/09/2012 40.0 8.34 36.0 8.15

- 10 -

Week Beg.

Surface West Surface

West Surface East

Surface East

COD (mg/l) pH COD (mg/l) pH Warning limit-100mg/l Action limit 150mg/l 6 - 9.5

Warning limit-100mg/l Action limit 150mg/l 6 - 9.5

21/09/2012 45.0 8.47 44.0 8.20

29/09/2012 25 7.88 35 7.96

06/10/2012 37 8.6 37 8.23

13/10/2012 37 7.98 40 7.89

20/10/2012 40 9.03 32 8.18

27/10/2012 35 7.79 35 7.85

03/11/2012 35 7.89 20 8.11

10/11/2012 45 8.37 43 8.17

17/11/2012 35 8.31 36 8.01

24/11/2012 40 8.43 48 8.31

01/12/2012 42 7.85 44 7.85

08/12/2012 35 7.9 45 8.15

15/12/2012 37 8.48 37 8.22

22/12/2012 * * * *

29/12/2012 60 8.81 25 8.52

*Implies that there was no surface water sample available

In 2012 surface water discharges were monitored in accordance with Schedule C2.3 and Condition

5.

Comment: There were no incidents recorded (i.e. no action limits reached). Visual inspections

were carried out and recorded on site log book.

- 11 -

2.1.3 Emissions to Atmosphere

Baxter operates a number of boilers that generate steam. The boilers are numbered as; boiler 2(A1-1),

3(A1-2), 4(A1-3) and 6(A1-5). Boiler 5 is a domestic boiler located on site for heating a small office

complex called the Annex which is not in use and the oil supply was removed in 2012. Boiler 3 was

decommissioned in December 2008 and replaced with Boiler 7.

Under Condition 6.10.2, Boiler 3 (Boiler 7) was replaced with a natural gas burning boiler in

November 2009. Boiler 4 & Boiler 6 were both converted to natural gas in December 2009. Due to

the age of Boiler 2 it was unsuitable for conversion to gas and was converted to diesel instead.

Boiler #3 (Boiler# 7) is a new boiler and as such is very efficient and reliable. As part of Condition

6.10.3 Boilers 3, 4, & 6 are now to be used as the primary boilers on-site and for boiler #2 to be a

back-up boiler.

Baxter Healthcare installed boiler economizer on our Steam boiler 6 (A1-5) in August 2012 as

approved by the EPA prior to installation. The principal change in emissions is that the efflux

temperature reduced upon installation of an economiser.

The IPPC licence limits the emissions of sulphur dioxide (SO2), nitrogen dioxide (NO2) and carbon

monoxide (CO) from the boilers. Ambient air quality was monitored in the vicinity of the facility as

part of the EIS prepared in 2002. The recorded level of all pollutants monitored was within air quality

standards.

Table 3 is a summary of the mass emissions to atmosphere from boilers 2, 3, 4 and 6. These emissions

are based on stack flow rate and stack concentration measurements conducted by Site Rite in April &

November 2012.

Table 3 shows that all the boilers are operating within the approved limits for 2012.

TABLE 3 SUMMARY OF EMISSIONS TO ATMOSPHERE

IPPC Licence

Emission

Point

Reference

Parameter

Mass

Emissions

for 2012

(Kg/year

Licensed

Mass

Emission

(kg/year)

Boiler points:

A1-5 (boiler 6)

A1-3 (boiler 4)

A1-1 (boiler 2)

A1-2 (boiler 7)

Oxides of

sulphur (as SO2) 1,049 1,006,507

Nitrogen oxides

(as NO2) 9,404 436,108

Carbon

Monoxide (CO) 40 69,414

There has been no non-compliance of Mass air emissions to the atmosphere at the Baxter plant for the

calendar year 2012.

Baxter Healthcare installed a CHP plant in late 2009. The CHP Plant comprises of two natural gas

fired Jenbacher Cogeneration Units capable of generating a combined total of 3 Mw of electrical

energy. Table 4 below represents the results of the monitoring completed on the 3rd April and on the

8th November 2012.

- 12 -

TABLE 4 SUMMARY OF RESULTS FROM MONITORING THE COMBINED HEAT AND POWER PLANT (CHP)

Engine

Number Oxygen %

Nox as

(NO2)

mg/Nm3

Carbon

Monoxide

mg/Nm3

Sulphur

dioxide

mg/Nm3

Apr Nov Apr Nov Apr Nov Apr Nov

CHP 416 9.5 9.6 520.5 343 761.4 731.8 200.2 169

CHP 612 10.6 10.9 498.2 309.1 254.4 242.3 101.8 78.5

2.2 Summary of Waste Arising

Details of the individual waste sent off site for treatment including disposal and recycling by

appropriate licensed waste management contractors and total quantities of waste produced including

hazardous and non-hazardous waste for the calendar year 2012 are presented in Appendix A.

2.3 Energy and Water Resource Consumption Summary

Table‟s 5 and 6 indicate the energy and & Table 7 indicates the water use on the Baxter site for 2012.

TABLE 5 SUMMARY TABLE OF ENERGY CONSUMPTION FOR 2011 VS. 2012

Energy Source Energy Consumed 2011(MW) Energy Consumed 2012(MW)

Medium Fuel Oil 0 0 Diesel 118 743

Propane 18 (cylinders) 17 (cylinders) Natural Gas 102,093 111,182

Electricity 5,870 7,452

TABLE 6 SUMMARY TABLE OF ENERGY CONSUMPTION IN 2012

2012 Consumption of different energy streams Energy Stream Annual

Quantity

Units

Electricity consumed onsite 28,803,998 kWh

Electricity Imported 7,451,507 kWh

Electricity Generated Onsite (CHP sites only) 21,352,491 kWh

Electricity exported offsite (CHP sites only) 0 kWh

Natural Gas Total 111,181,604

kWh (Gross Calorific value

(CV))

Natural Gas for CHP 49,398,028 kWh (Gross CV)

Gasoil 68,000 Litre

TABLE 7 SUMMARY TABLE OF WATER CONSUMPTION FOR 2011VS 2012

Resource Amount Consumed 2011

(Litres)

Amount Consumed 2012

(Litres)

Water 564,876,000 612,780,187

- 13 -

2.4 Summary of Notifications of Non-Compliances

Date of

Notification Non-Compliance

23/02/2012

Condition 3.6, 3.9, 8.4 and 8.5- road tankers containing cleaning agents stored in

an non designated, unbunded area, an absence of adequate local containment.

Tankers did not contain any high level alarms

23/02/2012 Condition 5.10 – Effluent monitoring not being carried out over the Christmas

shutdown period

23/02/2012

Condition 1.4 and 8.3 – Waste management and classification – the movement of

2 consigments of solution A as non hazardous. It was previously classified as

hazardous and the subsequent reclassification had not been carries out to the

satisfaction of the Agency

23/02/2012 Condition 5.10 and 11.10- Submission of reports – Delays in submitting the

quarterly reports

16/04/2012 Condition 11.1 – issues the flow meter in October 2011 not being reported by

phone of by Fax using the notification form but by including the quarterly report.

12/06/2012

Condition 3.6.2,3.6.5,8.5 and 8.9- road tankers containing cleaning agents &

sugar solution stored in an non designated, unbunded area, an absence of adequate

local containment. Tankers did not contain any high level alarms

12/06/2012 Condition 5.1 – Exceedance of ELVs for flow at the PW emission point (3

exceedances)

28/06/2012

Condition 3.6 & 6.11 - 15 bunds were visually inspected, however a liquid

retention test (LRT) was not completed, reasons for not completing a LRT were

not satisfactory, two bunds were neither visually or LRT tested.

23/07/2012 Condition 5.1 – Chloride, Sulphate & flow exceedances at PW emission point (12

chloride, 2 Sulphate and 5 Flow)

28/08/2012 Condition 5.1- Chloride and Sulphate exceedances at PW emission point (6

Chloride & 1 Sulphate)

10/10/2012 Condition 5.1- Chloride & Flow exceedances at PW emission point(3 chloride

and 9 flow)

11/12/2012

Condition 3.6.2, 8.5 & 3.9- Bunding and material- road tankers containing sugar

solution stored in an non designated, unbunded area, an absence of adequate local

containment. Tankers did not contain any high level alarms

11/12/2012 Condition 5.1- Chloride & Flow exceedances at PW emission point(4 chloride

and 3 flow)

11/12/2012 Condition 11.1 - Non-notification of incidents for exceedance of ELV‟s for

Temperature and pH at PW emission point

*Detailed Corrective and Preventative Actions plans were submitted to the EPA for the above Non-

compliances.

- 14 -

Table 8 Comparison of number of Notification of Non-Compliance 2011 vs. 2012

Parameter No of Non-Compliances

in 2011

No of Non-Compliances in

2012

Volume (m³) 9 23

pH 1 0

Temperature 0 0

BOD 1 1

BOD Loading 0 1

COD 1 0

Suspended Solids 0 0

Ammonia (as N) 0 0

Total Phosphorous (as P) 0 0

Sulphate (as SO4) 0 7

Detergents (as MBAS) 0 0

Fats, Oils & Grease 0 0

Chloride 0 30

Chloride Loadings 0 19

Audit Finding 7 14

NOx 0 0

SOx 0 0

Total 19 95

2.5 Summary of Environmental Incidents

Table 9 shows the environmental incidents during 2012. The details given below show the

occasions on which one of the following occurred:

A release to atmosphere from a potential emission point.

An emission that did not adhere to the limits of the licence.

The malfunction of monitoring and control equipment leading to a breach of the

licence.

An incident that had the potential to contaminate surface or ground water, or posed an

environmental threat to either air or land.

- 15 -

TABLE 9

Date Incident/Parameter Result ELV

3/01/2012 Flow 1767m3 1500m3

4/01/2012 Flow 1791m3 1500m3

06/03/2012 Chloride Loading 1063kg/day 1000kg/day

01/05/2012 EPA Spilt Sample -Chloride 930mg/l 750mg/l

05/05/2012 Flow 1630 m3 1500m3

06/05/2012 Flow 1752 m3 1500m3

14/05/2012 Flow 1546 m3 1500m3

17/05/2012 Flow 1511 m3 1500m3

05/06/2012 Flow 1584 m3 1500m3

12/06/2012 Chloride 842.4mg/l 750mg/l

19/06/2012 Chloride 855mg/l 750mg/l

20/06/2012 Flow meter malfunction n/a n/a

21/06/2012 Sulphate 112.4mg/l 100mg/l

21/06/2012 Chloride 1035mg/l 750mg/l

22/06/2012 Chloride loading 1044kg/day 1000kg/day

23/06/2012 Chloride 849.6mg/l 750mg/l




01/07/2012 Chloride 1019.7mg/l 750mg/l

02/07/2012 Chloride 1266.3mg/l 750mg/l


04/07/2012 Sulphate 116.8mg/l. 100mg/l

05/07/2012 Chloride loading 1028kg/day. 1000kg/day

10/07/2012 Chloride 2246.4mg/l 750mg/l

10/07/2012 Flow 1521 m3 1500m3

11/07/2012 Flow 1533 m3 1500m3



14/07/2012 Flow 1554 m3 1500m3


17/07/2012 Chloride 1043.1mg/l 750mg/l

18/07/2012 Chloride 853.2mg/l 750mg/l

19/07/2012 Flow 1559 m3 1500m3

19/07/2012 Chloride 781.2mg/l 750mg/l



22/07/2012 Chloride 761.4mg/l 750mg/l

29/07/2012 Chloride 1332mg/l 750mg/l

11/08/2012 Chloride 779.4mg/l 750mg/l

11/08/2012 Sulphate 134.7mg/l 100mg/l

- 16 -

Date Incident/Parameter Result ELV

12/08/2012 Sulphate 108.5mg/l 100mg/l

13/08/2012 Chloride 907.2mg/l 750mg/l

16/08/2012 Chloride 799.2mg/l 750mg/l

18/08/2012 Chloride 772.2mg/l 750mg/l



21/08/2012 Chloride 754.2 750mg/l

24/08/2012 Sulphate 113.1mg/l 100mg/l

25/08/2012 Chloride 2142mg/l 750mg/l

26/08/2012 Chloride 1207.8mg/l 750mg/l

27/08/2012 Chloride 1078.2mg/l 750mg/l


03/09/2012 Sulphate 109.3mg/l 100mg/l

05/09/2012 Sulphate 112.9mg/l 100mg/l

05/09/2012 Flow 1538 m3 1500m3

08/09/2012 Flow 1587 m3 1500m3

13/09/2012 Flow 1808 m3 1500m3


14/09/2012 Flow 1581 m3 1500m3

14/09/2012 Chloride loading 1058.6kg/day 1000kg/day

21/09/2012 Flow 1583 m3 1500m3

21/09/2012 Chloride loading 1025.8kg/day 1000kg/day

27/09/2012 Flow 1506 m3 1500m3

27/09/2012 Chloride 1724.4mg/l 750mg/l


30/09/2012 Chloride 831.6mg/l 750mg/l

03/10/2012 Flow 1525 m3 1500m3

4/10/2012 Flow 1594 m3 1500m3

05/10/2012 Flow 1530 m3 1500m3


7/10/2012 Chloride 826.5 mg/l 750mg/l


12/10/2012 Flow 1567 m3 1500m3

13/10/2012 Flow 1615 m3 1500m3

18/10/2012 Flow 1513 m3 1500m3

25/10/2012 Chloride 1137.6mg/l 750mg/l


7/12/2012 Chloride 1738.8mg/l 750mg/l


20/12/2012 BOD 1598mg/l 1000mg/l

20/12/2012 BOD loading 1826.5kg/day 1500kg/day

- 17 -

2.5.1 Comments on Table 9 Environmental incidents

Baxter confirms that the environmental incidents referred to in Table 9 were classed as Category one

incidents i.e. Breach of Emission Limit Values with no environmental pollution.

Baxter Healthcare in June 2012 was requested by the Agency to conduct daily monitoring of the

wastewater parameters. Baxter Healthcare was originally monitoring chloride and sulphate three

times per week.

Chloride

The investigations led Baxter to the conclusion that fixed daily amounts of chloride discharges from

our raw water treatment processes cause us to be close to our chloride emission limit. This is to say

that the regeneration cycles of the water softeners and the organic scavengers in our water treatment

area causes a discharge of salt that are close to the emission limit values.

To mitigate this Baxter has since the 20th August 2012 reduced by half the organic scavengers in our

raw water treatment process.

Sulphate

Root-cause investigations identified increase sulphate was due to cleaning of organic scavenger and

raw water tanks.

Volume

Root-cause investigations identified the following contributing factors:

Safety valve failure on line feeding hot water system into the plant leading to increase water

discharged to drain.

Change of Reverse Osmosis membrane

Increased flushing of water to drain

Cooling Towers (West and East) control set up leading to excessive discharges of water.

CAPA

Baxter Healthcare has completed corrective and preventative actions for the identified root causes and

has applied for a technical amendment with increased licence limits for volume, chloride & sulphate.

Baxter Healthcare is in the process of increasing the Wastewater treatment (WWTP) infrastructure at

the Knockthomas Site. A User Requirement Specification (URS) has been developed, to include the

increase limit in the above parameters.

Baxter Healthcare is seeking capital for the investment in the WWTP infrastructure. A project plan is

in place to have the project completed by Q1 2014. Contracts between the Mayo County Council are

Baxter Healthcare is in draft for the management of the WWTP.

- 18 -

2.6 Summary of Environmental Complaints

Table 10 gives a summary of the complaints received in 2011 vs. 2012. There was one complaints

received during 2012.

TABLE 10 SUMMARY OF COMPLAINTS RECEIVED IN 2011 VS 2012

Complaint Categories Complaints Received

2011

Complaints Received

2012

Odour 0 0

Noise 0 0

Water 0 0

Procedural 0 0

Miscellaneous 1 1

Total 1 1

Summary of the miscellaneous complaint

Baxter received a complaint from Veolia Water Ireland (VWI), after a discharge on the 19th

December 2012. A BOD load of 32,750PE was measured at the Veolia composite inlet

sample. This compliant and the BOD exceedance associated was reported to the EPA in a

timely manner.

- 19 -

3.0 MANAGEMENT OF THE ACTIVITY

3.1 Introduction

As part of the well-established environmental health and safety management system Baxter has set

a list of environmental objectives and targets in line with the Schedule of Objectives & Targets

outlined in their IPC licence and corporate goals and targets. Senior management define the EHS

policies and the EHS Manager, through the environmental management programme implements

these policies, goals and targets.

Baxter‟s EHS management programme is designed to protect the health and safety of all our

employees, the public and the environment. The programme is an integral part of Baxter‟s business

goals and is included in the business plan. Baxter has outlined a clear environmental target for each

of the objectives in each case taking into account realistic time-scales for completion. Goals for

each target were set with both long term and short-term goals in mind and to achieve year on year

improvement until the ultimate goal is reached.

Further goals and targets are set at EHS quarterly reviews and EHS meetings. Progress towards

achieving these goals and targets are reviewed at the EHS quarterly reviews.

Each year, subject to the Company‟s EHS management standards, each Baxter facility and

regional/business unit worldwide must prepare an EHS performance report on program status and

progress under relevant targets, objectives and other measures of performance. Each unit must

complete the annual EHS information verification process in Baxter‟s EHS Information

Management System (Insite). Information from Insite is included in the company wide report to the

Company and the public, including the annual Baxter Sustainability Report.

Monthly EHS reports detailing waste management, energy management, water consumption, and

greenhouse gas emissions are prepared after the end of each calendar month and sent to Regional

EHS Manager monthly. These reports generate an Eco-Efficiency Performance Report, which

provides graphical analysis of all environmental parameters year to date.

- 20 -

3.2 Report on Progress of Environmental Management System for 2012

As part of the requirements of the IPC Licence (Condition 2.2), Baxter maintain Environmental

Management System (EMS) for the site. The EMS ensures that the requirements of the

Environmental, Health and Safety Policy are met.

The key aim of the system is to ensure that Baxter continually improves environmental

performance by setting targets. Targets should be quantifiable wherever it is practical to ensure

that real attainment is recorded against the targets.

The EMS maintains an Environmental Management Program which is prepared, reviewed and

updated annually to account for improvements resulting from the phased introduction of the

objectives and targets. Table‟s 11 – 20 detail the progress made on the EMS for 2012.

The EMS references the most significant environment aspects and associated impacts onsite.

Baxter maintains environmental documentation/communication system procedures to inform the

public on environmental performance of the facility as required by the IPPC licence.

- 21 -

TABLE 11 PROGRESS REPORT ON TOTAL WASTE

Baxter aim to reduce Total Waste by 3% per unit of production and

conduct RWMS Audits

Target/Objective Baxter aim to reduce Total waste by 3% reduction in Total Waste

Generated per production unit based on end of 2011 figures.

Track API Waste separately in Divisional EHS Report.

Methods Baxter EHS Team will use best available techniques for storage,

transportation and disposal of non-hazardous waste. Regular meetings

scheduled to look at reduction type projects and compliance with waste

stream disposal.

Corrugate conversion lost team has been set up.

Re- Launch Waste Management Quality Working Team(QWT) to focus

on reduction on non-hazardous recycling rate.

Generate weight per bin per area for plastic weight in conjunction with

facilities engineering.

Continue to use FIFO policy in the labs.

Good Housekeeping practice drive – Office area‟s to have central bins,

better waste segregation and reduce amount of waste generated.

Hazardous waste training for all employees that enter the hazardous waste

shed

Responsible Person EHS Dept

Time Frame December 2012

Priority High

Monitoring Method Included as a component of quarterly environmental reviews.

Achievement vs. Target

Detailed procedures are in place for the handling of all waste streams. All

employees received refresher training in the Waste Recycling/Waste

Management plans and practices. There are effective Waste Management

Systems are in place.

Good Housekeeping practice drive was rolled out – much improved

segregation on-site.

Cost of disposal of Chemical & API waste is charged to the department

generating the waste to improve awareness and accountability of waste

generation.

All EHS waste audits was carried out as required, Dangerous goods safety

advisor carried out a site audit with no major findings.

Baxter waste increased from 17.23 to 22.78 grams per production unit for

total generated without API which was to the increase disposal of

Cleaning solutions at ENVA.

Micro Lab initiated a project to reduce the amount of bio-hazardous waste

by:

1. Removing all non contaminated glass (now goes into glass

recycling bin)

2. Removing all non contaminated agar plates (now goes into

general waste)

- 22 -

TABLE 12 PROGRESS REPORT ON ENERGY REDUCTION

Reason

Condition 7.2 of IPPC Licence, also Corporate Goal

Target/Objective Baxter aim to reduce the amount of energy used by 3% per production unit

based on end of 2011 figures.

Methods Means of achievement detailed in engineering procedure goals.

Implement Lean Energy Programme

Energy conservation on the Baxter site is an on going process, which

will be monitored and reported, on a quarterly basis and achieved by

Dec 2012.

Responsible Person Energy Manager


Priority High


Achievement vs.

Target

22% decrease in energy use per production unit. Decrease primarily

due to energy reduction projects implemented and increase in

production output. The KWh/LEQ (Litre equivalent) figure

decreased from 0.81 KWh/LEQ in 2011 to 0.66 in 2012. See

appendix E, for details on Energy Projects completed in 2012.

TABLE 13 PROGRESS REPORT ON WATER USE

Reason

Condition 7.3 of IPPC Licence, also Corporate Goal

Target/Objective Baxter aim to reduce water consumption by 3% per production unit

Methods Means of achievement detailed in engineering procedure goals.

Also included as a component of quarterly environmental reviews.

Responsible Person Engineering & Facility Engineering Mgr


Priority High


Achievement vs.

Target

Overall in 2012 a decrease of 8.2% in water usage per unit of production.

Decrease primarily due to water reduction measured taken and increase in

production output.

TABLE 14 PROGRESS REPORT ON GREEN HOUSE GAS EMISSIONS

Reason

Green House Gas Emission

Target/Objective Baxter aim to reduce GHG emissions by 3% per production unit.

Methods Means of achievement detailed in engineering procedure goals under

energy projects.

Responsible Person Engineering & Facility Engineering Mgr


Priority Medium


Achievement vs.

Target

There was no reduction on GHG emissions. Baxter were allocated

20,623 tonnes of CO2 and Baxter emitted 20,862 tonnes of CO2

- 23 -

TABLE 15 PROGRESS REPORT ON PACKAGING

Reason

Packaging Compliance Regulations.

Target/Objective Maintain reporting requirements for Essential Packaging Regulations

Methods Maintain procedures set up by the Packaging Quality working Team

(QWT) to ensure adherence to the requirements of the Packaging

Programme.

Responsible Person Product Development Manager, EHS Co-ordinator

Time Frame Dec 2012

Priority Medium


Achievement vs.

Target

All new and changed packaging have been updated on the

compliance database

TABLE 16 PROGRESS REPORT ON EMISSIONS TO AIR

Reason

Legislative requirements and IPPC requirement

Target/Objective Ensure compliance with ODS regulations and phase out use of Ozone

Depleting substances R22 on site by 2014

Biannual emission monitoring for boilers & CHP

Methods Document R22 containing equipment phase out. Ensure compliance

with Regulation EC 1005-2009 & Regulation (EC) No 842/2006–

ensure all vendors have F-gas certification and C&G 2079

certification. Commission external consultant to complete boiler &

CHP monitoring biannually.

Responsible Person Maintenance Manager & EHS

Time Frame Dec 2014

Priority Medium

Monitoring Method Review annually

Achievement vs.

Target

Baxter is on target regarding the regulations. Baxter has until 2014 to

phase out R22. All Boiler & CHP emission monitoring was

completed in 2012 as per IPPC Licence requirements.

TABLE 17 PROGRESS REPORT ON UNDERGROUND DRAINS

Reason

IPPC requirement Condition 2.2.2.2 (ii) & Condition 6.11

Target/Objective Maintain underground drains in good repair

Methods Complete CCTV survey of process and foul pipelines

Carry out remediation works to process water and foul pipelines.

Inspect at least every three years

Responsible Person Facilities Engineering Manager

Time Frame Dec 2012

Priority Medium

Monitoring Method Reviewed annually

Achievement vs.

Target

See Appendix G for details of inspections completed in 2012

- 24 -

TABLE 18 PROGRESS REPORT ENVIRONMENTAL EMERGENCY

Reason

Corporate EHS Requirements & legislative requirement

Target/Objective Ensure the site is fully prepared in the event of an environmental emergency

Methods Maintain Emergency Management Team

Update Site Emergency Response Plan to include specific

requirements on dealing with environmental spills and incident

reporting.

Carry out specific training with Emergency Response Team (ERT) on

dealing with chemical spills

Conduct fire drills to test site systems

Install emergency drain covers at strategic locations on site

Introduce new MSDS database resulting in easy access to hazard

information

Responsible Person EHS Dept ,


Priority Medium


Achievement vs.

Target

ERT trained per the training plan

Drain covers installed

New sharepoint site initiated to store all MSDS

TABLE 19 PROGRESS REPORT EPA COMPLIANCE

Reason

Corporate EHS Requirements & legislative requirement

Target/Objective Meet all requirements of IPPC licence & Greenhouse Gas Permit

Methods Comply with all conditions, reporting and monitoring requirements of

the IPPC licence

Responsible Person EHS Manager


Priority High


Achievement vs.

Target

Baxter Healthcare received a number of non compliances in 2012 from EPA

in the form of EPA inspection report. There were 7 non compliances

addressed to the satisfaction of the EPA.

On 19 December 2012 the Environmental Protection Agency prosecuted

Baxter Healthcare SA at Castlebar District Court. The Agency Agreed to

withdraw a number of charges and Baxter Healthcare SA pleaded guilty to

the following:

• Causing or permitting alterations to the activity, which did, or were likely

to, result in a material change or increase in the nature or quantity of

emissions, the raw materials used and wastes generated;

• Failing to notify the Agency as soon as practicable after the occurrence of

an emission to sewer on two separate dates which did not comply with the

requirements of its licence;

• Failing to ensure that all waste was stored in designated areas, protected as

may be appropriate, against spillage and leachate run-off and did fail to

clearly label and appropriately segregate all waste.

The court accepted the plea of Baxter Healthcare SA, convicted and fined

the company of the agreed counts and awarded agreed costs to the Agency.

- 25 -

TABLE 20 PROGRESS REPORT ENVIRONMENTAL INCIDENTS OR NOV

Reason

Corporate EHS Requirements

Target/Objective 10% reduction in environmental incidents or notices of violations

Methods Continue to work with BOD QWT

Install the necessary infrastructure or outcome from engineering

studies being completed

Reduce the amount of tank heels/dumps

Responsible Person EHS Manager/Production/Engineering


Priority High


Achievement vs.

Target

Baxter Healthcare has increased the amount of environmental incidents 19

to 95. These figures are taken from Table 8 comparison of Notification of

non compliances 2011 vs 2012.

TABLE 21 PROGRESS REPORT REGULATED WASTE MANAGEMENT SITES (RWMS)

Reason

Corporate requirement

Target/Objective Complete RWMS Audits based on Corporate Target dates

Methods EHS to carry out audits as per dated defined in the corporate audit

schedule for Regulated Waste Management site audits (RWMS).



Priority Medium


Achievement vs.

Target

RWMS audit were completed as per corporate schedule. The dates for

audits are also included in the EHS waste compliance package details.

TABLE 22 PROGRESS REPORT RAW MATERIALS

Reason

IPPC Requirement – Condition 7.4

Target/Objective Undertake an assessment of the efficiency of use of raw materials in all

processes on an annual basis

Methods Monitor inventories purchased and having regard to the reduction in

waste generated and through department conversion loss reporting



Priority Medium


Achievement vs.

Target

This project has commenced and is due to be completed Mid 2013

- 26 -

TABLE 23 PROGRESS REPORT SUFACE WATER EMISSIONS

Reason

IPPC Requirement – Condition 2.2.2.2

Target/Objective COD levels in surface water discharges

Methods Review warning and action levels for surface water COD

External lab to notify EHS Department when COD is over 100mg/l

Review emergency response plan implemented in the event of the

action levels being reached.

Responsible Person EHS Department


Priority Medium


Achievement vs.

Target

Action warning and action limits and emergency response plan were

reviewed

TABLE 24 PROGRESS REPORT TRAINING

Reason

IPPC Requirement – Condition 2.2.2.6

Target/Objective Maintain training & awareness

Methods Develop training matrix alongside HR

HR to log training on Isotrain

HR to maintain training records

Responsible Person EHS Department/HR


Priority High


Achievement vs.

Target

Training completed as per matrix and all training logged by HR.

TABLE 25 PROGRESS REPORT BUND

Reason

IPPC Requirement – Condition 3.6

Target/Objective Programme

Methods The integrity and water tightness of all bunding structures and their

resistance to prevention by water or it her materials stored therein

must be tested and demonstrated. The results must be reported to the

Agency. This must be repeated every three years.

Responsible Person Facility Engineering


Priority High


Achievement vs.

Target

All bund were inspected and tested – See appendix F

All bund were numbered and marked on a site drawing

The above were submitted to the Agency

- 27 -

TABLE 26 PROGRESS REPORT NOISE

Reason

IPPC Requirement – Condition 6.15 & Schedule B4

Target/Objective Complete Annual Noise Survey

Methods Commission external consultant to complete and report to the EPA

once results have been obtained. Initiate corrective action if results

are out of compliance.



Priority Medium


Achievement vs.

Target

Monitoring completed in March 2012 and report was forwarded to the EPA

TABLE 27 PROGRESS REPORT GROUNDWATER

Reason

IPPC Requirement –Condition C6(ii)

Target/Objective Complete Biannual Groundwater monitoring

Methods Commission external consultant to complete and report to the EPA

once results have been obtained. Initiate corrective action if results

are out of compliance.



Priority Medium


Achievement vs.

Target

Monitoring was completed in both April and November 2012 and reports

forwarded to the EPA

- 28 -

3.3 Environmental Management Programme 2013

Introduction

Baxter Healthcare has prepared this EMP Proposal for 2013 based on corporate EHS goals and

targets and on remaining actions from the 2012 EMP see Table 28 below. Some of the objectives

and targets set out in the EMP may have a time frame that extends longer than a year, as a result

some of the projects will be ongoing in 2013, with further developments planned.

- 29 -

TABLE 28 ENVIRONMENTAL MANAGEMENT PROGRAMME 2013

Reason

Objective and

Targets

Means of achievement

Priority

Person

Responsible

Time

Frame

Waste

Due to Corporate

EHS goals and

Regulatory

continuous

improvement

requirements.

IPPC 2.2.2.2

Baxter aim to reduce

Total waste

(Hazardous, Non-

hazardous & Biohaz)

by 3% Generated per

production unit based

on end of 2012 Leq

figures.

Track API waste

separately in

Divisional EHS

Report

Hold Monthly mtg

with Plant Mgr,

Engineering Mgrs &

EHS

Review alongside each functional manager to ensure

reduction in no of bins generated. Shared key

outcomes and review possible improvements alongside

main producer.

Continue to review option for sending API waste for

recovery vs. Incineration vs biodegradable in

conjunction with EPA approval. (ENVA with approval

from EPA).

Re-Train all employees on waste management

procedures when new bins are relabelled. Review

status alongside Each production area.

Good House Keeping Drive – Continue to develop

better waste segregation practices around the plant.

Improve on bin facilities; promote reduction and

recycling of waste. Review as part of Gemba Walks.

Continue to use FIFO policy in labs. Review lab smalls

test procedure. Track quantities of lab smalls and

establish if reduction initiatives can be implemented.

Continue to work with all suppliers to ensure minimum

scrap waste is generated through purchasing process.

In the case of poor segregated bins ensure bins are not

collected by janitorial

Hazardous waste training for all employees that enter

the hazardous waste shed

High

Medium

Low

Medium

High

Medium

Medium

Medium

EHS &

M.Grogan

EHS

All Mgrs &

EHS

All Mgrs &

EHS

Chemistry

Lab Mgr

Purchasing

Fac Eng. Mgr

EHS

Apr-13

May-13

Feb-13

Ongoing

Jun-13

Sept-13

Ongoing

Oct-13

- 30 -


Reason

Objective and

Targets


Priority

Person

Responsible

Time

Frame

Energy

Corporate EHS Goal

IPPC 2.2.2.2 & 7.2

Baxter aim to reduce

the amount of energy

used by 3% per unit

of production based

on end of 2012 Leq

figures.

Means of achievement detailed in engineering procedure

goals.

Implement Lean Energy Programme

Progress monitored as part of quarterly environmental

reviews to be approved by Director Engineering

High E. Systems

Manager Dec-13

Water

Corporate EHS Goal

IPPC 2.2.2.2 & 7.3

Reduce water

consumption per unit

of production by 3%.


goals.

Progress monitored as part of quarterly environmental

reviews to be approved by Director Engineering

High

E. Systems

Manager

Dec-13

Greenhous

e Gas

Emissions

Corporate EHS Goal

Comply with GHG

Permit.


goals under energy projects.

Medium

Facilities

Manager

Dec-13

Emissions

to Air

Legislative

Requirement

IPPC C1:2

Ensure compliance

with ODS

regulations and phase

out use

of Ozone Depleting

Substances R22 on

R22 on site by 2014.

Biannual emission

monitoring in boilers

and CHP

Document R22 containing equipment phase out plan.

Ensure compliance with Regulation EC 1005-2009 –

ensure all vendors have F-gas certification and C & G

2079 certification.

Commission external consultant to complete Air & CHP

monitoring

Medium

EHS

department

Maintenance

Jul-13

- 31 -


Reason

Objective and

Targets


Priority

Person

Responsible

Time

Frame

Underground

drains

IPPC 2.2.2.2 (ii) Maintain

underground drains

in good repair

Complete CCTV survey of process water and foul

pipelines. Carry out remediation works to process

water and foul pipelines. Inspected at least every 3

years. Maintain underground drains in good repair

and keep drawings current.

Medium Facility

Manager Dec 13

Environmental

Emergency

Legislative

Requirement

Ensure the site is

fully prepared in

the event of an

environmental

emergency

Maintain Emergency Management Team. Refer to

annual training plan. Hold ERT meetings on a qtr

basis.

Site Emergency Response Plan includes specific

requirements on dealing with environmental spills

and incident reporting.

Specific training included for ERT team on dealing

with chemical spills

Complete gap analysis alongside Regional EHS of

other items that should be considered

Medium EHS Dec 13

Packaging

Compliance

Corporate EHS goals

and targets.

Maintain reporting

requirements for

Essential Packaging

Regulations

Maintain procedures set up by the Packaging Quality

working Team (QWT) to ensure adherence to the

requirements of the Packaging Programme.

Update the Beles 8 system based on product

development change requests IR40-08-01-078.

Medium

Product

Development

Manager

EHS Specialist

Dec 13

EPA Compliance

Legislative

Requirement

Meet all

requirements of IPPC

Licence

Comply with all conditions, reporting and monitoring

requirements of the IPPC licence

Develop/Re-Train relevant personnel on new

guidelines for IPPC licence reporting

• Inspection guidelines

• Handling/reporting complaints

• IPPC Management Responsibility

Improve channel of communications with the EPA.

Seek formal meetings to discuss sections of Licence

High

EHS Manager

Dec 13

- 32 -

TABLE 28 ENVIRONMENTAL MANAGEMENT PROGRAMME 2013 CONT’D

Reason

Objective and

Targets


Priority

Person

Responsible

Time

Frame

Training IPPC 2.2.2.6 Maintain training &

awareness

Revise the core training spec IR40-03-02-057 to

ensure all aspects of EHS are included

Develop training Matrix alongside HR

HR to log training on Isotrain

HR to maintain training records. Await feedback

from Regional EHS on 2013 Training Matrix.

Low

EHS

Department

HR

Mar 13

Bund

IPPC 3.6 Programme

The integrity and water tightness of all the bunding

structures and their resistance to prevention by

water or other materials stored therein must be

tested and demonstrated. The results must be

reported to the Agency. This must be repeated

every three years.

High Facility Eng.

Manager Feb 13

Noise

IPPC C6.15 & B4 Annual Noise

Survey

Commission external consultant to complete and

report to EPA once results obtained. Initiate

Corrective action if results are out of compliance

Medium EHS

Department Mar 13

Groundwater

IPPC C6(ii) Biannual Ground

water

Commission external consultant to complete.

Initiate Corrective action if results are out of

compliance

Medium EHS

Department Dec 13

Wastewater

List 1 &11 Identify & Phase out

Continue to work with laboratories to

identify/reduce/phase out List I

substances where applicable

High EHS Dec 13

Wastewater

IPPC

Emergency

Response

procedures for

maintenance

intervention

Review Operational controls and Emergency

Response procedures for maintenance intervention

Improve process effluent controls

in the case of the sump area

High Facilities Eng

Manager Mar 13

Effluent

Monitoring IPPC requirement

Reduce monitoring

days

Seek approval from the EPA to reduce the daily

monitoring to agreed frequency High EHS Apr 13

- 33 -


Reason

Objective and

Targets


Priority

Person

Responsible

Time

Frame

RWMS

Corporate

compliance

Complete RWMS

Audits based on

Corporate Target

Dates

EHS to carry out audits as per dates defined in the

corporate audit schedule for Regulated Waste

Management Site Audits (RWMS).

To be completed in 2013

• Atlas Oil

Medium

EHS Manager Apr 13

Environmental

incidents or

NOV

Corporate EHS

goals and targets.

Mitigate number of

exceedances

Continue to work with the BOD QWT

Install the necessary infrastructure or outcome

from engineering studies being completed

Reduce the amount of tank heels/dumps

High

EHS Manager

Production

Engineering

Q1 2014

Raw Materials IPPC requirement

C7.4

Undertake an

assessment of the

efficiency of use of

raw materials in all

processes on an

annual basis

Monitor inventories purchased and compared to

previous year for inclusion in Annual Env Report.

Medium Logistics

Manager Mar 13

Surface water

emission IPPC 2.2.2.2 (i)

COD levels in

surface water

discharges.

Review warning and action levels set for surface

water COD

External Lab to notify EHS Department when

COD is over 100mg/l

Ensure procedure followed

Medium

EHS

Department

Ongoing

- 34 -


Reason

Objective and

Targets


Priority

Person

Responsible

Time

Frame

Emissions to Air New Corp

Requirement

To log all data on

insite pertaining to

ODS etc

Facilities are required to report the following data

into the Baxter EHS Information Management

System (Insite EHS) on a monthly basis (all

environmental data categories are defined in the

Reference and Training Guide section 8.0):

• Emissions of listed air contaminants, including:

o toxic air pollutants,

o volatile organic compounds (VOCs), and

o refrigerants with ozone depleting and/or global

warming potential, including ammonia

Medium Maintenance

Manager Monthly

Bunding of Haz

waste tankers IPPC

Provide bunding for

road tankers

Submit to EPA outcome of integrity test. Await

response on report submitted on 15/2/2013 High Fac Eng Mgr Mar13

Fugitive

Emissions IPPC C6.9

Identify Fugitive

emissions

Discuss with Corporate Regional EHS and confirmed

that we do not have Fugitive emissions Medium EHS Mar 13

- 35 -

3.4 Waste Management

Baxter has established and operates a comprehensive, documented waste management

system throughout the plant. Procedure Specs detail the management, and control of

Hazardous and Non-Hazardous waste on-site. The waste streams are classified in

accordance with National/European legislation. There is a segregation programme in place,

which operates throughout the whole plant. Production personnel are responsible for

primary segregation of all waste, and it is the responsibility of janitorial personnel to ensure

that all segregated waste is transferred and stored correctly in the waste storage area until

collection.

Permit details of the waste contractors used are located in Appendix C.

Details of waste records for hazardous and non-hazardous waste stream for Baxter

Healthcare site can be found in table 29. There have been no rejected consignments from

the Baxter site.

- 36 -

TABLE 29 INFORMATION ON EACH WASTE STREAM

European

Waste

Catalogue

Code

Hazardous

(Yes/No) Description of Waste

Quantity

(t/year)

Disposal/

Recovery

Code

Location of

Disposal/

Recovery

Name of Waste Disposal

Recovery Contractor

Licence / Permit Reference for

Treatment Facility

20 01 01 No Cardboard/Paper 272.2 R5 Castlebar, Co.

Mayo Repulping: Feoil Freight WCP-MO-09-0075-01

15 01 02 No PVC scrap Polyethylene

scrap 820.2 R5

Clogher,

Westport,

Mayo

Bourke waste ltd WFP-MO-08-0004-01-01

WCP-MO-09-0633-01

15 01 02 No Non PVC scrap 7.1 R5 Castlebar, Co.

Mayo Reuse: Feoil Freight WCP-MO-09-0075-01

15 01 03 No Wooden pallets 10.2 R11 Castlebar, Co.

Mayo Reuse: Feoil Freight WCP-MO-09-0075-01

20 03 01 No General waste 338.3 D1

Aghalustia

Townland, Ballaghaderreen,

Co Roscommon

McGrath Industrial Waste Ballaghaderreen Landfill

Licence 59-2

20 03 01 No Kitchen waste 26.4 D1

Aghalustia Townland,

Ballaghaderreen, Co Roscommon

McGrath Industrial Waste

Ballaghaderreen Landfill Licence 59-2

20 01 08 No Kitchen recycling waste 7.8 R3

Shepherds drive,

Carnbane Industrial

Estate, Newry, Co

Down


Re-GEN Waste Ltd WML22/25

20 01 08 No Biodegradable waste 15.0 R3 Headford Road,

Galway,

McGrath Industrial waste

Carrowbrowne Landfill Site W0013-01

17 09 04 No Construction and

Delimitation 4

D1

Aghalustia

Townland,

Ballaghaderreen,

Co Roscommon


Ballaghaderreen Landfill Licence 59-2

20 01 02 No Glass 11.5 D10 Turlough Castlebar

Co. Mayo. McGrath‟s Industrial Waste WFP-MO-10-0015-01-01

20 01 40 No Metal 14.9 R4 Oranmore, Co.

Galway Galway Metal Co Ltd

WFP-09-G-0006-05

20 01 21 Yes Lamps 0.394 R4 Netherlands and

Kildare

Separation, Irish Lamp

Recycling/ Claushuis Metaalmaatschappij BV

WFP-KE-08-0348-01

- 37 -

European

Waste

Catalogue

Code

Hazardous


Quantity

(t/year)

Disposal/

Recovery

Code

Location of

Disposal/

Recovery


Recovery Contractor


Treatment Facility

07 05 01 Yes

Active Pharmaceutical

Ingredients (Aqueous solution)

212.34 D10 Borsigstrasse 2

22113 Hamburg

Abfall-Verwertungs-

Gesellschaft mbH IB/2234/AVG/GENB-2

07 05 01 Yes


Ingredients (Aqueous solution)

66.442 D10

Dijle 17 a 2800

MECHELEN

Neatherland

Indaver NV MLAV1/98 00000485

07 05 13 Yes


Ingredients (Contaminated solids)

& mixed packaged waste


22113 Hamburg Abfall-Verwertungs-


07 05 13 Yes


Ingredients (Contaminated solids)

& mixed packaged waste

0.367 D10

Dijle 17 a 2800

MECHELEN

Neatherland


18 01 03 Yes

Clinical Waste (sharps, wipes,

cloths, gloves used in micro.gmo material, autoclaved material)

10.819 D9

Unit 1A, Allied Ind est, Kylemore

road, Ballyfermot, Dublin 10

Ecosafe Systems Ltd, Waste Mgt Permit: CW059

Licence 54-2

16 02 13 Yes WEEE (waste

electrical electronic equipment)

2.247 R12 (R4)

Cappincur Industrial Estate, Daingean Road, Tullamore, Co. Offaly

KMK Metals recycling Licence: 113-3

06 01 06 Yes

Other Acids (ammonium

Thiocyanate/Flocon 40)


22113 Hamburg

Abfall-Verwertungs-


- 38 -

European

Waste

Catalogue

Code

Hazardous


Quantity

(t/year)

Disposal/

Recovery

Code

Location of

Disposal/

Recovery


Recovery Contractor


Treatment Facility

14 06 02* Yes

Other halogenated solvents and solvent mixtures (Mercury

Thiocyanate)


22113 Hamburg

Abfall-Verwertungs-


14 06 02* Yes

Other halogenated solvents and solvent

mixtures (Ensolv/Betadine)

1.463 D10 Dijle 17 a 2800 MECHELEN

Neatherland


14 06 03* Yes Other solvents and

solvent mixtures (Cyclohexanone/DEHP)


22113 Hamburg

Abfall-Verwertungs-


15 02 02* Yes Absorbents, filter

materials (HCL/Oil/Magnaflux)


22113 Hamburg

Abfall-Verwertungs-


15 02 02* Yes Absorbents, filter

materials (HCL/Oil/Magnaflux)

1.059 D10 Dijle 17 a 2800

MECHELEN

Neatherland


16 05 06* Yes

Laboratory chemicals, consisting of or containing dangerous substances,

0.227 D10 Dijle 17 a 2800

MECHELEN

Neatherland


16 05 06* Yes

Laboratory chemicals, consisting of or

containing dangerous substances,

0.006 D15

Tolka Quay

Road

Dublin Port Indaver Ireland Ltd W0036-2

16 05 06* Yes

Laboratory chemicals, consisting of or

containing dangerous substances,


22113 Hamburg

Abfall-Verwertungs-


20 01 14* Yes Acids- Oxonia cleaning

solution 214.7 D9

Smithstown

Industrial est.

Shannon, Co. Clare

Enva Ireland W0041-01

20 01 29* Yes Acids- Oxonia cleaning

solution 708.9 D9

Smithstown Industrial est.

Shannon, Co. Clare


16 10 01* Yes Aqueous liquid wastes containing dangerous

substances -Solution A 616.9 D9

Smithstown

Industrial est. Shannon, Co. Clare


- 39 -

European

Waste Catalogue

Code

Hazardous (Yes/No)

Description of Waste

Quantity (t/year)

Disposal/ Recovery

Code

Location of

Disposal/

Recovery


Recovery Contractor


Treatment Facility

16 10 02 No Aqueous liquid wastes containing dangerous

substances -Solution A 41.3 D9

Smithstown Industrial est.

Shannon, Co. Clare


16 05 09 No Discarded chemicals

Extraneal/Sugar Solution

673.9 D9 Smithstown

Industrial est.

Shannon, Co. Clare


20 01 25 No Edible oil and fat 0.29 R1 Orchard Road Ind, Est, Strabane, Co.

Tyrone, BT82 9FR

Frylite LTD WML 26/26

06 01 01* Yes sulphuric acid and sulphurous acid

0.233 D10 Dijle 17 a 2800 MECHELEN

Neatherland


06 01 02* Yes Hydrochloric Acid 2.737 D10 Borsigstrasse 2

22113 Hamburg

Abfall-Verwertungs-


06 02 04* Yes Potassium/Sodium

Hydroxide 0.028 D10

Borsigstrasse 2

22113 Hamburg

Abfall-Verwertungs-


06 02 05* Yes Sodium Hypochlorite 0.360 D10 Borsigstrasse 2

22113 Hamburg

Abfall-Verwertungs-


08 03 17* Yes waste printing toner

containing dangerous substances

1.4 R3

Unit 3, Shannon

Development Ent

Ctn, Syngfield,

Birr. Ireland

Source Imaging Supplies Ltd WFP-10-OY-0181-01

15 01 10* Yes Oxonia Drums 0.031 D10 Borsigstrasse 2

22113 Hamburg

Abfall-Verwertungs-


16 03 03* Yes

off-specification batches and unused products Inorganic wastes containing

dangerous substances


22113 Hamburg

Abfall-Verwertungs-


16 03 05* Yes

off-specification batches and unused

products organic wastes containing


10.636 D10

Dijle 17 a 2800

MECHELEN

Neatherland


- 40 -

European

Waste Catalogue

Code

Hazardous (Yes/No)

Description of Waste

Quantity (t/year)

Disposal/ Recovery

Code

Location of

Disposal/

Recovery


Recovery Contractor


Treatment Facility

16 09 03* Yes Oxidising

substances Oxonia Active


22113 Hamburg

Abfall-Verwertungs-


20 01 27* Yes

Paint, inks, adhesives and

resins containing dangerous substances

0.254 D10

Dijle 17 a 2800

MECHELEN

Neatherland


20 01 33* Yes Batteries 0.156 R12(R4)

Cappincur Industrial Estate, Daingean Road, Tullamore, Co. Offaly

KMK Metals recycling Licence: 113-3

16 05 08* Yes

Discarded organic chemicals consisting

of or containing dangerous substances

1.539 D10 Dijle 17 a 2800 MECHELEN Neatherland


16 05 04* Yes

Gases in pressure containers (including halons) containing


0.058 D10 Dijle 17 a 2800 MECHELEN Neatherland


18 02 06 No

Chemicals order than those

mentioned in 18 02 05* (finshed product

discard)

2335 R12 Cushinsheeaune. Westport, Co.Mayo

P&D Horan Ltd WFP-MO-09-0007-01

- 41 -

3.5 Pollutant Release and Transfer Register – Report for 2012 & Proposal for 2013

As per Condition 6.16 of the IPPC licence‚ the licensee shall prepare and report a PRTR for the

site.

The PRTR report for 2012 will be submitted to the Agency, electronically through the Agency‟s

web based system and also through the AER. See Appendix B.

PRTR Proposal for 2013

It is proposed to track and report the same pollutants in 2013 for the PRTR as were reported for the

year 2012.

- 42 -

4.0 LICENCE-SPECIFIC REPORTS

The following licence specific report summaries are included in this section:

Annual CO2 emissions

Noise monitoring report

Groundwater monitoring summary

Review of Residuals Management Plan

Report on annual solvent usage

Respirometry Testing

Toxicity Testing

API Absence Test

4.1 Annual CO2 Emissions

The facility holds a Green House Gas Permit Number, IE-GHG-133-05, Installation No.

IE-97, Activity Code E1.1.The annual CO2 emissions are calculated using the mass

balance approach, by adding the tonnes of CO2 emitted due to Medium Fuel Oil (MFO),

Natural Gas (Nat Gas), Light Fuel oil (LFO) and Liquid Petroleum Gas (LPG). The CO2

allocation to Baxter for 2012 was 20,623 tonnes of CO2. The verified annual installation

emissions report was submitted to the Agency in March 2012, this confirmed a total of

20,862 tonnes of cO2 emitted in 2012. Table 30 below summarises the total CO2

emissions from the Baxter plant for 2012.

TABLE 30 DETAILED SUMMARY OF 2012 CO2 EMISSIONS FROM THE BAXTER PLANT

Fuel type Activity data Units Weighted

Net Calorific Value

Units Weighted

Emission factor

Units Oxidation

factor Total CO2 as

tonnes )

Nat Gas 9598208.5 NM3 0.000037 Tj/NM3 57.0 tCO2/TJ 1 20634.6

LFO (Diesel)

0.06604412 KTonnes 43.31 TJ/KTonnes 73.3 tCO2/TJ 1 209.7

LPG (cooker)


LPG (bottle)


Total emissions (sum of fossil fuel emissions & fossil fraction of mixed fuels)

Tonnes of CO2 20,862

Subject to Condition 1.4 of the GHG Permit carbon dioxide from Schedule 1 activities

shall only be emitted to the atmosphere from the emission points as listed in Tables 31

and 32 below:

- 43 -

TABLE 31 CARBON DIOXIDE EMISSION POINTS

Emission Point

Reference

Emission Point

Description

Thermal Input

Capacity

Capacity Units

A1-1 No. 2 Boiler Stack 7.2 Mw




CHP CHP 1 & 2 2.8 Mw

Carbon dioxide from Schedule 1 activities may also be emitted to atmosphere from

the minor emission points listed in Table 32 below.

TABLE 32 CARBON DIOXIDE MINOR EMISSION POINTS

Emission Point

Reference

Emission Point

Description

Thermal Input

Capacity

Capacity Units


SBG-1 Exhaust Standby Generator 1 0.024 Mw

SBG-2 Exhaust Standby Generator 2 0.192 Mw

PU-1 Exhaust of Firewater Pump Engine 0.083 Mw

CK-1 LPG Cooker 0.1 Mw

A3-7 Exhaust of Atomic Absorption Unit < 0.1 Mw



Exhaust of Atomic Absorption Unit

4.2 Noise Monitoring Report Summary 2012

The Noise Monitoring survey was carried out on the 22nd & 23rd March 2012 as per

Condition 6.15. The survey methodology followed the Environmental Protection Agency

(EPA) “Environmental Noise Survey Guidance Document” (2003), EPA “Guidance Note

for Noise in Relation to Scheduled Activities” (2006), and ISO 1996 “Description and

measurement of environmental noise”. The plant was in normal production throughout

the survey.

The results of the noise monitoring indicated that their was no environmental noise issues

at the noise sensitive receptors associated with operations at the Baxter Healthcare

Facility. Daytime and nighttime noise limits were complied with at all noise sensitive

locations with regard to Baxter noise emissions. Frequency analysis data indicated that

operations at Baxter Healthcare do not give rise to a tonal noise impact at the nearest

residential properties.

Noise levels at the house locations in 2012 were similar to the results for the 2011 survey,

and there is no evidence of a systematic change in emissions

- 44 -

4.3 Groundwater Monitoring Report Summary

Bi-annual groundwater monitoring was carried out in April and November 2012. It is

noted that the groundwater is not used as a potable supply. However, in the absence of

any relevant Irish groundwater quality standards the analytical results are discussed with

reference to background levels, using the EPA Interim Guideline Values (EPA IGV‟s)

and the Drinking water MAC‟s.

Findings and Conclusions as submitted to the EPA.

Field measurements (i.e. temperature, pH and electrical conductivity) are within the

expected range for these parameters.

The concentrations of sodium and chloride showed no significant change since previous

sampling rounds, except for chloride in MW2 and remain below the Drinking Water

Standards values.

Ammonium concentration in MW4 exceeded the limit of 0.3mg/l for drinking water and

also the EPA IGV of 0.15mg/l in September and October 1.02mg/l & 1.13mg/l

respectively. The desktop assessment completed in August 2010 concluded that an off-

site source (hydraulically up-gradient of MW4) to the west and north-west of the Baxter

facility was contributing to the elevated ammonia concentrations.

An elevated COD level was detected in MW 2-4 in October, with a value of 13mg/l.

However this concentration does not indicate significant contamination.

Slight increase in DRO concentrations of 0.02mg/l were detected in MW3. As none of

the petroleum indicator parameters were detected it is likely the hydrocarbons detected

are of a natural origin or related to another source.

The concentrations of the hydrocarbon indicator parameters have shown no change since

the 2006 monitoring round, as concentrations of all parameters were below the laboratory

detection limits.

Supplementary Investigative Analysis

To further investigate the trend of the increasing ammonia concentration in MW4,

additional analysis for nitrate, nitrite, total coliforms and faecal coliforms was carried out

in November 2012 by Envest Environmental Ltd.

A nitrate concentration of 0.8mg/l was detected in the groundwater sample collected from

MW4. This is very low and well below the EPA IGV for nitrate of 25mg/l. A low nitrate

value is normally accompanied by an elevated ammonia concentration as the reduced

nitrate is transformed to ammonium with the loss of the oxygen molecule.

A nitrite concentration of <0.02mg/l was detected in the groundwater sample colleted

from MW4. If significant pollution was present, then a measurable nitrite concentration

would be detected and this would be accompanied by elevated ammonia, chloride,

sodium or potassium. The sodium concentration in MW4 was 12.1mg/l (significantly

- 45 -

below the EPA IGV of 150mg/l) and the chloride concentration was detected as 13.6mg/l

(significantly below the EPA IGV of 30mg/l).

Total and faecal coliforms were determined as being 0 (zero) CFU/100ml and <1

CFU/100ml respectively in the groundwater sample analysed from MW4.

A groundwater level survey was undertaken at the site in conjunction with this biannual

monitoring event. The wells were surveyed relative to an arbitrary site datum so that a

contour map could be prepared to confirm the flow direction at the site.

MW1 MW2 MW3 MW4

Groundwater Level

The groundwater flow direction was confirmed to be in a south easterly direction and this

is illustrated in Figure 2 below:

Therefore from the consultants review of the long-term monitoring of groundwater at the

site and interpretation of the most recent site data, it is their opinion that groundwater

coming onto the site in the vicinity of MW4 has slightly elevated concentrations of

ammonia and therefore they consider the source of elevated ammonia in MW4 to be

hydraulically upgradient i.e. an off-site source.

- 46 -

4.4 Report on Annual Solvent Usage

Table 33 below represents the volume of solvents purchased in 2012.

Table 33 Volume of solvents purchased in 2012

Solvent Name Volume Purchased in

2012

Cyclohexanon 1170 kgs

DEHP (Di-ethylhexylphthalate) 200 kgs

IPA (Propan-2-ol) – Sterile 70/30

IPA sprays

7,200 litres

IPA (Propan-2-ol) – non-sterile 70/30

IPA sprays

1,536 litres

Pago (Solvent W15 blue) 860 litres

Ensolv 546 kgs

Acetonitrile 600 litres

Acetic Acid 12 litres

Acetic Anhydride 22.5 litres

Ethanol 12 litres

Methanol 258 litres

Formaldehyde 5 litres

Chloroform 20 litres

- 47 -

4.5 Respirometry Testing

As per EPA requirements, Baxter Healthcare carried out respirometry testing in

December 2012. A sample of process effluent, together with activated sludge from

Castlebar Municipal Waste water Treatment Plant, was collected and tested to investigate

the inhibitory effect (if any) of Baxter‟s process effluent on the respiration rate of the

activated sludge micro-organisms. The test data demonstrated that process effluent from

the Baxter facility exhibited no inhibitory effect on activated sludge from Castlebar

Municipal Waste Water Treatment Plant. Testing SE1 This result indicates that the Baxter Healthcare SA trade effluent sample was inherently

biodegradable and treatable by the microbes in the activated sludge in the Baxter annex plant

at Castlebar WWTP.

As per the EPA request a sample of Solution A (Alconox and Multichlor) and Oxonia

cleaning agents (at the Baxter Healthcare working strength) was individually tested on the

sludge from the Castlebar WWTP.

A grab sample of trade effluent at location PW (Process Waste) was taken on the 10th

December 2012.

Based on the results of this test in Table 34, we can consider the possible impact of a

direct discharge of Solution or Oxonia cleaning agents to the Castlebar Municipal WWTP

(by-passing the Baxter annex WWTP)

Table 34 Respirometry Testing of Cleaning Agents

Respirometry Testing of Cleaning Agents

Cleaning Agent I.T. %v/v Working

strength

I.T. Kg of cleaning

discharged directly

Oxonia 0.02 to 0.03 8 to 12

Solution A

Multichlor

Alconox

1

480

424

All test data was sent to the EPA and is available on file in the EHS Department.

- 48 -

4.6 Toxicity Testing

As per EPA requirements, Baxter Healthcare carried out Toxicity testing in January 2012.

The toxicity testing was carried out on:

1) The waste cleaning solutions stream Oxonia and solution A (Alconox &

Multichlor) prior to mixing.

2) A mixed effluent sample from emission point Process Waste (PW)

The test methods used were:

Method 6.1 based on ISO 6431:1996/Cor.1:1998: „water quality – determination

of inhibition of the mobility of Daphnia magna Straus (Cladocera, Crustacea)-

Acute toxicity test‟.

Method 6.2 based on ISO 11348-3:2007:‟Water quality-determination of

inhibitory effect of water samples on the light emission of Vibrio Fischeri

(Luminescent bacteria test)- Part 3:Method using freeze-dried bacteria‟

Table 35 Toxicity Testing of Emissions to Sewer (Process Waste (PW)) and cleaning agents

Toxicity Testing

Sample Name Test Parameter Concentration

%vol./vol.

Toxic Units

Baxter Process

20.01.2012

48h EC50 to Daphnia

magna

>100 <1

30 min EC50 to Vibrio

fischeri

38.3 2.6

Solution A

48h EC50 to Daphnia

magna

5.7 17.5


fischeri

2.3 43.5

Oxonia

48h EC50 to Daphnia

magna

0.053 1887


fischeri

0.063 1587

* 30 min EC50 to Vibrio

fischeri

0.060 1667

*30 min EC50 to Vibrio fischeri (pH adjusted, 7.4)

All test data was sent to the EPA and is available on file in the EHS Department.

4.7 API Absence testing

As per Condition 3.2 Pharmaceutical actives are to be tested annually. The sample was

collected on a 24 hour flow proportional sampler and taken at 8.00am on the 4th

December. The sample was sent to an external laboratory for testing. Table 36 below

provides the results of the analysis which confirms that Baxter Healthcare Effluent does

not contain API‟s.T

Table 36 API Absence Testing of Emissions to Sewer – Process Waste (PW)

API Absence Test Baxter Process 4/12/12

Bupivacaine HCL [18010-40-7] mg/l <1.00

Ciprofloxacin [85721-33-1] mg/l <2.00

Gentamicin [1405-41-0] mg/l <2.00

Metronidazole [443-48-17] mg/l <1.00

- 49 -

4.8 Process Raw Materials Usage Efficiency

As per IPPC licence condition 7.4, an assessment of the efficiency of use of raw materials

was carried out in 2012. This assessment focused on the key areas of water, energy and

raw material conservation. See progress report for Waste, Energy & water in Table 11 to

13 for further details.

4.9 Environmental Liability Statement

As per Condition 12.3 “The licensee shall as part of the AER provide an annual

statement as to the measures taken or adopted at the site in relation to the prevention of

environmental damage, and the financial provisions in place in relation to the

underwriting of costs for remedial actions following anticipated events or

accidents/incidents, as may be associated with the carrying on of the activity”.

In the event of a permanent closure or partial closure of the site a reserve financial

provision consisting of a charge on the profit & loss to cover the anticipated closure costs

will cover the cost of closure or down sizing, by agreement with the Agency. The items

allowed for and included in any such closure provision would include the cost of draining

of plant and equipment, removal of waste substances, securing the site, and provision for

a return to an acceptable status.

Baxter Healthcare SA confirms that at the time of permanent closure or partial closure of

the Baxter licensed facility (Register 636-02) financial provisions will be made available

in accordance with the site‟s de-commissioning management plan.

- 50 -

APPENDIX A

SUMMARY OF WASTE ARISING

- 51 -

SUMMARY OF WASTE ARISING

Waste 2007 2008 2009 2010 2011 2012

Total quantity of waste produced in calendar year(Tonnes)

1429.33 1674.82 1669.53 1706.77 2642.91 4102.33

total quantity of waste disposed of on-site

0 0 0 0 0 0

total quantity of waste disposed of off-site

294.06 336.94 505 358.01 1506.733 2950.443

total quantity of waste recovered on-site

0 0 0 0 0 0

total quantity of waste recovered off-site

1023.67 1337.88 1165.53 1348.76 1136.181 1151.887

2007 2008 2009 2010 2011 2012

Quantity of non-hazardous waste produced in calendar year

1308.5 1461.47 1544.79 1522.23 1643.51 1859.24

quantity of non-hazardous waste disposed of on-site

- - - - - -

quantity of non-hazardous waste disposed of off-site

- - - - - 1855.043

quantity of non-hazardous waste recovered on-site

- - - - - -

quantity of non-hazardous waste recovered off-site

- - - - - 4.197

2007 2008 2009 2010 2011 2012

Quantity of hazardous waste produced in calendar year (Tonnes)

120.82 213.35 125 184.538 1008.5 2243.09

quantity of hazardous waste disposed of on-site

0 0 0 0 0 0

quantity of hazardous waste disposed of off-site

120.82 213.35 125 184.538 1008.5 1095.4

quantity of hazardous waste recovered on-site

0 0 0 0 0 0

quantity of hazardous waste recovered off-site

- - - - - 1147.69

- 52 -

APPENDIX B

BAXTERS AER/PRTR RETURNS

- 53 -

- 54 -

- 55 -

- 56 -

- 57 -

- 58 -

- 59 -

APPENDIX C

Waste Contractors

- 60 -

WASTE CONTRACTORS USED IN 2012

Waste Contractor Waste Licence No. Collection Permit No.

AVG IB/2234/AVG/GENB-2 N/A

EcoSafe 054-2 WCP-DC-09-1203-01

Feoil Freight WFP-MO-11-0019-01 WCP-MO-09-0075-01

Galway Metal WFP-09-G-0006-05 WCP-LK-08-589-01

Irish Lamps WFP-KE-08-0348-01 WCP-DC-08-1115-01

Iggy Madden Transport N/A WCP-MO-08-0590-02

KMK Metals 113-3 WCP-OY-08-0607-01

Bourke Waste Ltd WFP-MO-08-0004-01-

01

WCP-MO-09-0633-01

Cunningham Transport N/A WCP-MO-09-0638-01

JP Ryan N/A WCP-CK-09-0696-01

McGrath Industrial WFP-MO-10-0015-01-

01

WCP-MO-09-0002-02

Trevor Ratcliff N/A WCP-DC-08-1130-01

Indaver - Ireland W0036-02 N/A

Indaver - NV MLAV1/98 00000485 N/A

ENVA Ireland W0041-01 WCP-DC-08-1116-01

P & D Horan’s WFP-MO-09-0007-01 WCP-MO-09-0297-001

Frylite LN/11/63 WCP-DC-10-1297

Source Imaging WFP-10-OY-0181-01 N/A

Guinan Haulage N/A WCP-OY-09-626-02

Ravenhill Couriers Ltd N/A WCP-OY-09-620-01

- 61 -

APPENDIX D

Baxter Products

- 62 -

- 63 -

- 64 -

APPENDIX E

Energy Efficiency Audit Report

Summary

&

Energy Projects 2012

- 65 -

Energy Audit Report Summary

- 66 -

- 67 -

Energy Program Business Plan 2013

- 68 -

Energy Projects 2012

Year Completed

Project Description Cost (K€) Annualized Savings(K€)

Simple Payback

Savings (K€) in year

completed

Annual KWh

savings (Gas)

Annual KWh

savings (Electricity)

2012 Insulate Condensate return lines

38 19 2.00 15 551,229

2012 Boiler 6 Economizer 182 48 3.79 12 1,600,000

2012 Raw water Booster Pump Upgrade

66 20 3.30 7 181,818

2012 High efficiency lighting 12 3.8 3.16 0 34,545

Total 2012 298 90.8 3.28 34 2,151,229 216,364

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APPENDIX F

Bund Integrity Testing Reports

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APPENDIX G

Pipe and Sump Integrity Testing

Reports

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Internal Pipe Integrity Testing Report

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Sump Integrity Testing Report

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External Pipe Integrity Testing Report

annual environmental report 2012 · 4.2 noise monitoring report summary 2012 ... the principal...

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