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Eli Lilly S.A, Irish Branch

Dunderrow, Kinsale, Co Cork

Ms. Noeleen Keavey

Administration Officer

Office of Climate, Licensing and Resource Use

EPA, Wexford

Date: 12-10-2015

Re: Eli Lilly Licence Review (P0009-04)

In response to the Agency’s request, dated Aug 26th

2015, for further information in support

of the above referenced license review application we hereby furnish the following

information to address the queries raised;

1. Planning permissions and related EIS status since last license review (2005):

Below is the listing of planning permissions approved for the site by Cork Co.

Council since the last license review. The grant date for each application together with

its EIS status is also listed in the table. As can be seen from the listing only two

applications related to a significant expansion of production facilities at the site and

both of these were subject to EIA. The EIS for the IE43 development has already been

submitted with the license review application and an electronic PDF copy of the IE42

EIS is being submitted with this response.

The remaining applications, with the exception of the CHP plant, were for ancillary

facilities such as office, warehouse and cafeteria extensions that are not subject to

EIA.

The construction of the CHP plant has been deemed to be exempt from planning as

outlined in the enclosed letter from the local authority.

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Planning

Ref

Date

Granted

Description of Development

EIS Required

Yes/No

N/A Exempt

Ref: D/207/15

Construction of CHP Plant No

146065 08/01/2015 Demolition of existing idled IE3 Production building

and ancillary plant and equipment. No

145747

07/11/2014

The development will consist of the following: (1) A

new IE15C warehouse building of 276m2 gross floor

area, overall height not exceeding 7.1m above

existing ground level (2) All associated site

development works. The proposed development is

covered by the existing Integrated Pollution Control

Licence (Licence Register P0009-03). The proposed

development is located in an Establishment to which

the Major Accidents Directive applies.

No

116594

20/03/2012

The construction of a Pharmaceutical Biotech

manufacturing facility (IE43), including administration,

plant and storage accommodation with a total floor

area of 22,680 square metres, over three floors with

intermediate service platforms and ground to eave

heights from 30.150 metres high for the main

manufacturing area to 11.300 metres high for

ancillary areas. The proposed works shall include the

construction of two separate electrical utility building;

230 square metres floor area and 148 square metres

floor area, each 4.7 metres high, together with

extensions to internal site service roads, a new staff

car park, external plant concrete mounting pads and

hard standings, and extension of an existing pipe

bridge structure, partical diversion of an existing

stream within the site, an entrance and the formation

of landscaped berms together with new tree planting

to provide enhanced visual screening.

Yes

115033

11/08/2011

Extension of 32 square metres gross floor area,

with rooftop plant area, overall height not

exceeding 7.5 metres above existing ground level to

the existing IE1 Warehouse Building and all

associated site works

No

105899

21/10/2010

Extension of 113sqm gross floor area, overall height

not exceeding 3.7m above existing ground level &

internal modifications to the existing IE7

Environmental Control Building, removal of existing

single storey portacabin office of 60sqm gross floor

area from the western side of the existing IE7

Environmental Control Building, extension of 24sqm

gross floor area overall height not exceeding 4.7m

above existing ground level & internal modifications

No

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Planning

Ref

Date

Granted

Description of Development

EIS Required

Yes/No

to the existing IE2 laboratory/production building, &

associated site works

084373

18/04/2008

Modifications to kitchen extension to reception and

cafeteria building (IE 05) at existing manufacturing

facility permitted under Reg. No. 07/10056 to

include partial demolition and alterations of existing

single storey kitchen and demolition of temporary

construction activities cafeteria seating area and

construction of single storey extensions on a phased

basis to existing kitchen and cafeteria seating area

with associated internal alterations, construction of

new entrance canopy and external louvered

screening and associated site works

No

0710056

30/10/2007

Construction of single storey kitchen extension to

northern side of existing reception and cafeteria

building(IE5) with associated internal alterations,

construction of entrance and plant platform above

to eastern side, construction of two storey office

extension to north and east of existing single storey

warehouse building(IE1), construction of single

storey forklift store on eastern side of warehouse

building and associated site works

No

079929

23/10/2007

Construction of 3 storey pharmaceutical biotech

manufacturing facility (IE42) to include integral

administration, laboratory, storage facilities and

utilities with additional piped services carried on

pipe bridges linking adjacent IE30 facility, continued

use of temporary construction access road, soft

landscaping and remodelling of existing surrounding

topography to include raising existing ground levels

Yes

0610855

20/12/2006

Construction of extension to existing IE 03

Production building Annex for production of active

pharmaceutical ingredients to include production

and ancillary administration areas.

No

068394

01/11/2006

Construction of extension to existing facility for the

production of pharmaceutical ingredients including

production and ancillary administration areas and

the continued use of existing construction entrance

No

064530

05/05/2006 Construction of Forklift Charging Room (IEO1),

Wash Room (IE07), Raw Materials Charging Room

and Materials Store (IE30)

No

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2. Please refer to the letter below from the local authority declaring the CHP plant as

an exempted development.

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3. Description of the CHP Plant:

Combined heat and power (CHP), also known as cogeneration, involves the

simultaneous production of heat and electric power from the same source of fuel,

which in this case is natural gas. The engine consists of a gas-fuelled

reciprocating engine, a generator / alternator, and a heat recovery system.

The engine, fuelled by natural gas, drives the alternator to supply the site

medium voltage network displacing external utility power requirements.

Waste heat from the engine exhaust, recovered in the boiler as steam, feeds the

site steam network, whereas waste heat recovered from the engine jacket, as hot

water, supplies building hot water systems in IE30, IE42 & IE43.

CHP has advantages in terms of being more energy efficient from an overall

primary fuel input aspect when electricity generation from primary fuel input is

considered. The nominal thermal input of natural gas to the unit is 9738 kW,

generating 4401 kW of electrical output and recovering thermal energy of up to

1771 kW of hot water from engine jacket water and 2166kW of steam from the

waste heat recovery boiler on the exhaust.

The CHP plant will supply electrical and heating loads to production buildings

IE30, IE42 and IE43 thus reducing utility energy usage.

The CHP plant puts to use the by-product heat that is normally discharged to the

atmosphere resulting in a higher thermal efficiency. This leads to reduced energy

costs and as a result, CHP engines have a lower rate of carbon dioxide (CO2)

emissions per Mega Watt (MW) of useful energy produced.

The CHP plant will be installed in a new circa 200m² single story building, IE19, to

the south west of IE42. As the exhaust stack from the unit will be less than 20

metres in height it is therefore exempt from planning as outlined in the above

correspondence from the Local Authority.

Predicted emissions from the stack have been modelled together with other

existing and planned combustion sources on site and the results of this modeling

is outlined in Attachment I of the application.

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TABLE E.1(ii) MAIN EMISSIONS TO ATMOSPHERE (1 Page for each emission point)

Emission Point:

Emission Point Ref. No:

A2-6

Source of Emission:

Proposed CHP Engine

Location:

Adjacent to IE30

Grid Ref. (12 digit, 6E,6N):

E 159969, N 0 52638

Vent Details

Diameter:

Height above Ground(m):

0.7 20 m (modelled at 12 m)

Date of commencement:

Planned commencement Nov ’15

Characteristics of Emission:

(i) Volume to be emitted:

Average/day Nm3/d Maximum/day 438,528 Nm3/d

Maximum rate/hour 18,272 Nm3/h Min efflux velocity 13.2 m.sec-1

(ii) Other factors

Temperature 177oC (max) oC(min) 120oC (avg)

For Combustion Sources: Volume terms expressed as : wet. √ dry. 5% O2

(iii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up

/shutdown to be included):

Periods of Emission

(avg)

60 min/hr 24 hr/day 350 day/yr

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TABLE E.1(iii): MAIN EMISSIONS TO ATMOSPHERE - Chemical characteristics of the emission (1 table per emission point)

Emission Point Reference Number: A2-6 Proposed CHP Engine

Parameter Prior to treatment(1) Brief As discharged(1)

mg/Nm3 kg/h description mg/Nm3 kg/h. kg/year

Avg Max Avg Max of treatment Avg Max Avg Max Avg Max

NOx 500# 9.1 80,031*

* Depends on hours of operation

# The NOx discharge concentration of 500 mg/Nm3 is based on vendor design specification for the engine. This value is

referenced to the following conditions; 0oC, 101.3kPa, 5% O2.

It should be noted that the above discharge concentration value is equivalent to 190 mg/Nm3 referenced to 0oC, 101.3kPa, 15%

O2 as outlined in the 2015 EU Directive on the limitation of emissions of certain pollutants into the air from medium combustion

plants.

TABLE F.1(i): ABATEMENT / TREATMENT CONTROL

Emission point reference number: A2-6 Proposed CHP Engine

As the CHP plant is not a treatment/abatement system this table is not considered applicable.

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4 An updated drawing, Attachment B.2, outlining both the existing site boundary

and the proposed site boundary extension is included with this submission as

requested.

5 The Chemicals Act (Control of Major Accident Hazards involving Dangerous

Substances) Regulations (S.I 209 of 2015) applies to site activities.

However ranking under the new regulations has not yet taken place as the

necessary forms to complete the process are not yet available. Forms are due for

submission by 31st May 2016.

It is expected however that the site will remain as a top tier Seveso site due to

the quantities of materials stored on site that are considered toxic and/or a

danger to the environment.

We trust that the above responses are to the satisfaction of the Agency. If further

information is required on any aspect of the application please contact the

undersigned.

Yours faithfully,

______________________________

Charlie McGuinness

Environmental Compliance Representative

Tel: 021-4702665

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