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Swords Laboratories

P0014-04

Annual Environmental Report for 2012

BMS Swords Laboratories P0014-04

AER 2012

Annual Environmental Report

1 Introduction

This report is the Annual Environmental Report for 2012 for Swords Laboratories,

Watery Lane, Swords, Co. Dublin as required by IPPC Licence P0014-04. It has been

prepared following the format laid down in the EPA’s Guidance Note for ‘Annual

Environmental Report’. All changes to the ‘AER for 2011’ are highlighted in bold.

Swords Laboratories is part of the Bristol-Myers Squibb Company and specialises in

the manufacture of bulk pharmaceutical intermediates and products including

oncology, cardiovascular and anti-viral drugs.

Activities on site include: manufacturing, manufacturing technology, quality control

and environmental laboratories, warehousing, maintenance workshops, wastewater

treatment, tank farms, administration facilities, a Thermal Oxidiser and a Solvent

Recovery plant. Approximately 340 people are employed full time at Swords

Laboratories.

The General Manager and the Environmental, Health and Safety Director, have

established a site Environmental Health and Safety Policy (page 4). The policy is

posted at a number of locations around the site. The EHS Ireland organisational chart

is attached (page 5). Swords Laboratories was re-accredited to ISO 14001:2004 in

November 2010 by SGS Ireland (page 6).


AER 2012


AER 2012

EHS Ireland Chart 2012

EHS Director

Safety Manager

Safety and Loss Prevention Coordinator

Safety Engineer

Safety Engineer

Occupational Health & Safety Coordinator

Safety Officer

Process Safety Manager EHS Chemical Regulatory Lead Environmental Manager

Environmental Coordinator Swords

2 x Environmental TechniciansCruiserath

Environmental Coordinator Cruiserath

2 x Environmental Technicians Swords

QEHS Manager


AER 2012

ISO 14001 cert


AER 2012

2 Summary Information The summary information presented here covers the reporting period January to December

2012.

2.1 Self – Monitoring Data

2.1.1 Emissions to Sewer

The aqueous wastewaters generated from the manufacture of bulk pharmaceutical

intermediates and products are treated in the on-site wastewater treatment plant (WWTP)

before discharge to the sewer. Full monitoring results may be found in Appendix A and

summary emissions to sewer found in the PRTR worksheets in Appendix E.

Summary Information for Emissions to Sewer 2012

Parameter No. of

Samples

Taken

Mass

emission

2012

Mass

Emission

2011

Licensed

Mass

Emission

Flow (m³) Continuous 129,932 112,183 182,500

pH Continuous Range: 6 - 9

Range: 6 - 8 6-10

Temperature Daily 23C (max) 25C (max) 42C (max)

BOD (kg) 23 3,716 476 54,750

COD (kg) 71 22, 015 16,068 365,000

Suspended Solids (kg) 353 4,771 6,881 73,000

Sulphates (kg) 20 19,591 18,663 136,875

Zinc (kg) 19 < 2.99 3.479 219

Fats, oils, grease (kg) 18 571 618 21,900

Ortho-phosphate (as P)

(kg) 78 1,248 1,992 21,900

Fluoride (as F) (kg) 20 43.9 55.7 n/a

Chromium (as Cr) (kg) 19 < 0.34 < 0.281 109.5

Copper (as Cu) (kg) 19 < 0.85 < 0.519 109.5

Lead (as Pb) (kg) 19 < 0.07 < 0.062 36.5

Nickel (as Ni) (kg) 19 < 0.29 < 0.224 109.5


AER 2012

Quarterly sampling of the Final Effluent for Toxicity testing commenced in September 2007.

The 2012 test results are below:

Sample Date & Type:

24-hr composite 07-Mar-12 06-Jun-12 05-Sep-12 05-Dec-12

Toxicity Freshwater Algae 48h EC50

to Daphnia Magna < 1 TU < 1 TU < 1 TU < 1 TU

Toxicity: Activated Sludge (ISO

8192)

< 2 TU < 2 TU < 2 TU < 2 TU

Details of non-compliances with regard to emissions to sewer can be seen in the table below.

All non-compliances were notified to the Agency and Fingal County Council in accordance with

Condition 12.2 of the licence.

Summary of Emissions to Sewer Non- Compliances 2012

Date of Occurrence

Rank Non-Compliance Corrective & Preventative Actions

20.Jan.12 2

Final Effluent licence limit exceedences due to discharge of volume greater than daily treatable volume of an aqueous waste stream from the solvent recovery plant

BOD mg/l COD mg/l

19-Jan-12 353

20-Jan-12 209 4,750

21-Jan-12 2,600

Installed valve on the line from the relevant tank to the WWTP

Automated the pump on the relevant tank to ensure that bottom valve closes when the pump shuts down.

14.Mar.12 1

Final Effluent licence limit exceedences following over dosing of caustic to WWTP. Following pH correction, treatment effectiveness was reduced.

BOD mg/l SS mg/l pH

14-Mar-12 > 10

16-Mar-12 288 664

Automation and interlocks installed to ensure that pH in carrousel is used to operate caustic dosing pumps;

Alarms relayed to security and maintenance for immediate response outside daytime working hours.

2.1.2 Emissions to Atmosphere

The total number of samples taken from the Thermal Oxidiser is calculated as 16,704; this is

the sum of the half-hourly CEM samples collected over the year. A summary of TO downtime


AER 2012

is attached in Appendix B and was reported quarterly during the year. Summary details of

emissions to air can be found in the PRTR worksheets in Appendix E.

Summary Information for Emissions to Atmosphere from Thermal Oxidiser 2011

Parameter No. of

Samples

Taken

Mass

Emissions

(kg) 2012

Mass

Emissions

(kg) 2011

Licensed

Mass

Emissions

(kg)

Hydrogen Chloride Continuous 172.09 120.20 5,256

Total Organic Carbon Continuous 0.00 0.01 3,504

SOx Continuous 0.00 1.31 n/a

NOx Continuous 573.04 853.80 n/a

CO Continuous 0.96 1.85 n/a

Particulates 4 109.34 242.25 5,256

Hydrogen Fluoride 4 < 6.89 < 7.75 700.8

Hydrogen Bromide 4 < 6.89 < 7.75 n/a

Dioxins (TEQ) 1 1.85 x 10-4 < 7.59 x 10-7 1.752 x 10 -3

n/a – not applicable

There were two non-compliances for HCl emissions from the TO during 2012, these were

notified to the Agency at the time & are outlined below. Incidents notified to the Agency

relating to the Thermal Oxidiser are also outlined below.

With regard to Condition 4.1.1 of the IPPC licence:

No 24 hour mean value exceeded the emission limit value;

> 99.98 % of all 30-minute mean values taken continuously over 2012 did not exceed

1.2 times the emission limit value;

Except for the HCl results detailed below, there were no other exceedences of 2 x the

ELV for any parameter.

The Continuous Environmental Monitoring System (CEMS) printouts for two periods of 30-

minute ELV exceedences are attached in Appendix B – the daily average was compliant.


AER 2012

Summary of Emissions to Air Non- Compliances & Incidents 2012

Date of Occurrence

Rank Non-Compliance Corrective & Preventative Actions

23-Aug-12 1 Two exceedences of A2-1 HCl ELV: 96.32 & 60.35

mg/m3

The investigation with the Analyser vendor is continuing. HCl spikes have been observed in a number of trials immediately on dosing Urea to the DeNOx chamber. For that reason, the DeNOx chamber will not be used until the source of the issue can be identified & corrected.

Date Incident Incident

Rank Authorities contacted

Corrective & Preventative Actions

30-Jan-12 Failure of CEMS on Thermal Oxidiser 1 EPA CEMS data connected to site data historian so data logging could be stopped. 28-Apr-12 Failure of CEMS on Thermal Oxidiser 1 EPA

6-Jun-12 Failure of CEMS on Thermal Oxidiser. 1 EPA Auto-archive function on the analyser PC deactivated.

17-Jul-12 Failure of CEMS on Thermal Oxidiser 1 EPA Full disk cleanup completed Jan-13; Additional checks implemented by site Automation group; Improved service contract with vendor (ABB) under review.

3-Dec-12 Failure of CEMS on Thermal Oxidiser 1 EPA

Monitoring of emissions to air was carried out on the P3 stack in December 2012 as it was

completing processing activities after the TO shutdown on 20th December. The results are

attached in Appendix B.

2.1.3 Emissions to Water

Surface water from processing areas on site is directed to the WWTP to minimise the potential

for accidental contamination of the nearby Ward River. Areas of the site having little risk of

contamination (e.g. roof drainage from non-manufacturing buildings, paved areas / roads, etc.)

pass through the site surface water drains to the surface water tank. Following the detection

of solvent in river samples during March 2011 the Surface Water tank has been diverted and

treated in the WWTP and is not discharged to the Ward River. Therefore, there are no

monitoring results for SW tank discharges to the river for 2012.


AER 2012

Surface water also leaves the site via six surface water outfalls from areas with no potential for

contamination (car parks, etc.). The surface water outfalls are monitored weekly and results

are attached in Appendix C. Following a notified incident in October 2011 the surface water

outfall at the WWTP was blanked out, and in June 2012, a valve was installed on the surface

water outfall adjacent to the WWTP.

2.1.4 Ambient Monitoring

2.1.4.1 Groundwater

18 groundwater monitoring boreholes are monitored quarterly on site – 5 bedrock wells & 13

shallow wells. Monitoring was carried out in February, April, August & November 2012

and results are attached in Appendix D.

The levels of accumulated rainwater in the underground storage tank vaults are

checked monthly and solvent analysis carried out on any samples with an elevated COD result.

Any accumulated water in the vaults is pumped to the WWTP or into a waste solvent tank,

depending on the level of contamination. The results of samples collected in 2012 are reported

in Appendix D.

Update on CLIARP:

Following the unsuccessful pilot scale treatability trial in late 2011, a revised

remediation programme was compiled. A wider site investigation highlighted further

potential source areas. This involved delineating the extent of the impact to soil and

groundwater quality from the source areas and undertaking a detailed risk

assessment to establish corrective action requirements. This was completed in June

2012. A pilot trial of the proposed techniques (Multi-phase Extraction & In situ

Chemical Oxidation) was carried out and completed by November 2012. The design

for full scale remediation was completed by December 2012 and includes a two stage

approach; stage 1 involves free product recovery. Depending on its success (i.e.

reaching Risk Based Target Values), stage 2, the polishing step, may or may not be

required. Stage 1 is due to start on the 31st March 2013.


AER 2012

2.1.4.2 River Water

The Ward River runs alongside the eastern boundary of the site. It is monitored upstream and

downstream of the plant on a weekly basis for a suite of typical River water quality

parameters, and twice monthly for solvents. All results of the monitoring are attached in

Appendix D.

2.1.5 Environmental Incidents and Complaints 2012 The following is a summary of the Environmental incidents notified to the Agency as required

by Condition 4.1 and complaints received 2012. Details of incidents notified relating to

Emissions to Sewer & Air are outlined in Sections 2.1.1 and 2.1.2 respectively.




20-Jan-12

Spill into collection tank of IPA waste during waste transfer to tankfarm.

1 EPA

Set-up of area modified to reduce hose changes;

Buffer tank system put in place to collect wastes;

Signage installed at area,

Transfer procedure updated and training completed with operators.

14-Feb-12 Leak of Syltherm from overhead line into bunded area.

1 EPA

Length of failed pipework replaced;

Survey completed to identify any other lengths of pipework on distribution system at risk of corrosion.

28-Feb-12 Discharge of solvent to process drain during cleaning.

1 EPA

Procedure updated to include pressure test of system prior to cleaning;

New pump & connections installed to increase flexibility.

22-May-12

Loss of F-gas from HVAC chiller detected during routine leak check.

1 EPA PM introduced to run unit regularly to prevent leaks; Leak check job plans updated.

22-Jun-12

Loss of F-gas from process chiller detected during routine leak check.

1 EPA Replaced failed o-ring; Gas taken out of unit while not in use.


AER 2012




27-Sept-12

Leak of Glycol from distribution system on P3 roof. Drain had been mis-routed to foul sewer.

2 EPA, FCC

Gasket replaced & bolts tightened; Lock nuts & spring washers installed on similar equipment across the site. Drainage for the area was routed to process drain.

7-Nov-12 Small leak from loaded road tank on site into area spillage tank.

1 EPA

Pitting identified on tank was repaired & tank recertified; Sacrificial anodes to be used in tanks storing site waste for over 1 week.

21-Nov-12

Discharge of solvent to process drain during plant cleaning operation.

1 EPA, FCC Line breaking procedure & permit updated & training rolled out.

Summary of Notification of Non-Compliances 2012

Date Reference NONC

27-Apr-12 P0014-04/nc18 Two events of exceedence of emission limit values on emissions to sewer.

25-Jan-13 P0014-04/nc19 Late notification of two incidents; Storage of waste on site over six months; Bund integrity testing not completed on schedule in all cases.

2.1.5.1 Summary of Complaints

There were a total of 2 off-site complaints received in 2012, both related to noise. Details of

complaints received are outlined below:

Date Details Corrective Actions

24-Mar-12 Noise complaint – related to fire alarm testing on a Saturday

Fire alarm testing rescheduled to Monday to Friday only, advance notice provided to neighbours.

9-Oct-12 Noise complaint received - related to a noisy pump.

Pump was taken out of operation and overhauled.

3 Waste Management

Full details of waste shipped off-site in 2012 can be found in the PRTR workbooks, Appendix

E.


AER 2012

4 Agency Monitoring and Enforcement

4.1.1 Aqueous Emissions Sampling

Agency staff took samples of the final effluent discharge to sewer during 2012. Split samples

were taken by Swords Laboratories and results are compared below. All sample results were

compliant with emission limit values.

Agency Final Effluent Sampling 2012

Date 22-Feb-12 22-Mar-12 08-Nov-12

Site EPA

(Comp) Site

EPA

(Grab) Site

EPA

(Comp)

BOD (mg/l) 50 <300 15 16 <2 < 2

COD (mg/l) 540 455 150 193 30 37

SS (mg/l) 66 32 68 16 0 < 10

pH 7.49 7.6 7.85 7.8 8.09 8.3

Sulphates (mg/l) 171 170.6 279.47 247.1 140 133

Ortho Phosphate (mg/l) 37 29.177 2.45 2.713 0.04 0.020

Zinc (mg/l) 0.0123 nm 0.0151 0.0033 nm nm

Chromium (mg/l) 0.0025 nm < 0.002 0.0028 nm nm

Copper (mg/l) 0.00528 nm 0.00676 0.0026 nm nm

Lead (mg/l) < 0.0005 nm 0.0167 < 0.0005 nm nm

Nickel (mg/l) 0.00242 nm 0.00308 0.0017 nm nm

Fats / Oil / Grease (mg/l) nm nm 6.6 nm nm nm

1,3,5-Trimethylbenzene (µg/l)

nm nm < 1 0.5 nd nd

Acetone (mg/l) nd nd 0.093 < 3 nd nd

Bromodichloromethane (µg/l)

< 500 0.8 < 1 0.5 nd nd

c-1,2-Dichloroethene (µg/l)

nd nd < 1 1 nd nd

Chloroform (µg/l) nd nd 1 1.6 nd nd

DCM (µg/l) 1,500 < 0.5 36 28.4 nd nd

Methanol (mg/l) nd nd < 1 7 nd nd

Tetrahydrofuran (mg/l) 86 118 0.015 < 4 nm nm

No other solvents were detected above the Method Detection limit.

nd: not detected nm: not measured


AER 2012

4.1.2 Atmospheric Emissions Sampling 4.1.2.1 Thermal Oxidiser Monitoring Catalyst Environmental visited the site on behalf of the EPA on the 24th – 26th January 2012 to complete Thermal Oxidiser stack monitoring for the compounds listed below. All monitoring results were compliant.

Compound Result Emission Limit

Value

Total Particulate Matter 3.8 mg/m3 30 mg/m3

HCl 2.0 mg/m3 30 mg/m3

HF < 0.10 mg/m3 4 mg/m3

Total VOCs as Carbon 0.27 mg/m3 20 mg/m3

Dioxins & Furans (NATO-I TEQ) Average of 3 runs:

0.0029 ng/m3 0.1 ng/m3

4.1.3 Agency Site Audits On 21st March, Patrick Kenny & Mary Gurrie carried out a site inspection. The site was

found to be non-compliant with one licence condition, and three observations were

raised. Follow up action was outlined in our response of 23rd May.

On 24th September, Patrick Kenny & Maeve O’Reilly carried out a site inspection. The

site was found to be compliant with all licence conditions and four observations were

raised. Follow up action was outlined in our response of 4th December.

On 30th November, Patrick Kenny & David Matthews carried out a site audit. The site

was found to be non-compliant with three licence conditions and six observations

were raised. Follow up action was outlined in our response of 14th February 2013.

See table in Section 2.1.5 for details of notifications of non-compliance issued by the

EPA in 2012.


AER 2012

4.2 Energy and Water Consumption

2012 2011 2010

Electricity (GWhr) 30.44 28.44 27.76

Natural Gas (m³) 3,230,859 3,154,636 3,170,342

City Water supply (m3) 231,188 238,286 214,111

Energy & Water consumption 2009‐2012

0

50

100

150

200

250

300

350

400

2009 2010 2011 2012

25

26

27

28

29

30

31

32

MWhr

Water (000's m3) Gas ('0,000's m3) Electricity (GWhr)

5 Management of the Activity

5.1 Schedule of Objective & Targets

5.1.1 The following Environmental Management Programme was proposed for

2012.

The following outlines the current status of the Environmental Management Programme (EMP)

put in place to achieve the site’s Objectives and Targets. This version of the EMP is an update

to the AER document submitted to the Agency in March 2012, updates are highlighted in bold.


AER 2012

Licence Objectives Licensee Targets 2012 Status 2012 Process Modification to improve yields, eliminate / reduce wastes or use alternative less hazardous materials.

Continue process improvements programme. 1. Cycle time efficiency for Product U was assessed in 2011 and improvements made resulting in reduction of waste stream volumes and energy usage. These improvements were sustained in 2012.

2. Replacement of HOBt was investigated for two processes, but cancelled when the substitute material was found to be not useable.

3. Laboratory work commenced for Intermediate F to demonstrate if product lost to mother liquor can be recovered.

4. Significant manufacturing cycle time reductions achieved for Intermediates F and H and Product K, resulting in energy savings.

Improvement in treatment / abatement systems to reduce emissions.

1. EPA non compliance notifications: Reduce by 50% the number of non-compliances issued by the EPA (nmt 1) using 2011 as base year.

2. TO HCl IPPC licence exceedences: Maintain the number of reportable HCl exceedences (>60mg/m3) from the TO at zero.

3. Reduce the no. of HCl exceedences > 30mg/m3 by 75% (nmt 2) using 2011 as baseline (only actual HCl exceedences).

4. Maintain 2010 number of WWTP licence exceedences (nmt 6).

5. Reduce total number of complaints by 40% of 2011 number (nmt 3).

6. Reduce the no. of incidents notifiable to the EPA by 36% using 2011 as base year (nmt 4 rank ≥ 2 and nmt 10 rank 1).

1. 4 non-compliances were received in 2012, all issued following inspections.

2. 2 reportable HCl exceedences occurred in 2012 – believed to be related to caused by Urea dosing in the TO for abatement purposes.

3. 4 half-hour ELV exceedences were recorded in 2012 – partly related to a contaminated filter line in the CEMS and partly related to solvent recovery activities.

4. 7 WWTP limit exceedences were recorded 2012 related to two incidents.

5. 2 complaints received 2012. 6. 16 incidents were notified to the EPA 2012, 2

Rank 2, the remainder Rank 1.

Use of alternative treatment / abatement systems.

Install backup to Thermal Oxidiser. Cryogenic condenser plant installed & commissioning works commenced 2012.


AER 2012

Licence Objectives Licensee Targets 2012 Status 2012

Recovery, reuse, recycling of waste material both on-site and off-site.

1. Investigate solvent recovery possibilities and look at solvent pre-treatment possibilities.

2. Investigate an alternative route for aqueous phosphate waste stream (external / internal, pre treatment).

3. Investigate alternative solution for liquid sludge. 4. Increase drum recycling / recovery by 10%. 5. Investigate implementing central waste compound with

a view to increasing recycling and improving waste segregation.

1. Investigations will continue in 2013. In addition, Cruiserath completed modifications on their incinerator guns to increase burn rates by up to 50%.

2. No alternative route identified for aqueous phosphate waste currently consigned to Veolia Sotrenor.

3. A trial was undertaken using a mobile tanker as a sludge dewatering unit. Some further review is required before implementation as a back-up for Cruiserath.

4. A drum rinsing trial was completed in Veolia Fermoy to render drums non hazardous. The results of the trial were reviewed and approved by BMS for ongoing use.

5. This project was not progressed in 2012

Reduction of VOC emissions to air

1. Continue Fugitive Emissions and process emissions monitoring programmes.

2. Achieve TO downtime of ≤ 1% during 2012. 3. Investigate linking frequently used bulk tanks to the

TO. 4. Investigate possibility of determining vessel emissions

during TO downtime and compare with theoretical data. 5. Investigate implementation of recommendations from

Solvent Management Plan report.

1. 8 processes were desktop surveyed in 2012 with monitoring planned on 5 during 2013 if scheduled. 1 monitoring round was completed for P3 in December 2012 during TO shutdown.

2. TO downtime was 0.87 % in 2012. 3. This project has been added to site projects

list for completion in 2014. 4. Not feasible to complete due to safety &

access issues. 5. Two of the remaining recommendations from

the Solvent Management Plan report were implemented.

Savings in energy and material usage.

1. Reduce gas and electricity use by 15% of 2009 use by 2015.

2. Reduce GHG emissions by 15% of 2009 emissions by 2015.

3. Reduce total water use by 10% of 2009 volume by 2015.

1. A reduction of 4% of 2009 use has been achieved to date.

2. A reduction of 2.5% of 2009 GHG emissions has been achieved to date.

3. A reduction of 5% of 2009 water use has been achieved to date.


AER 2012

Licence Objectives Licensee Targets 2012 Status 2012

Contaminated Land Investigation, Assessment & Remediation Plan (CLIARP)

Implement Groundwater Remediation Plan for Areas 1 – 5 in accordance with EPA requirements: Undertake delineation & risk assessment for areas 1-5; Undertake treatability trial; Submit remediation plan proposal; Commence remedial action following detailed design.

Delineation and risk assessment complete. Treatability trial completed. Full scale remediation proposal submitted to the Agency and full scale remediation due to commence on the 31st March 2013.

Reduction in Noise Emissions

1. Continue annual noise survey programme & investigate any issues.

2. Implement noise management programme 3. Reduce total number of complaints by 40% of 2011

number (nmt 3).

1. The 2012 noise survey was completed with no issues identified.

2. A noise management programme was implemented.

3. The number of complaints was reduced by 60% of 2011 number – two were received 2012.


AER 2012

The following is the Environmental Management Programme proposed for 2013

Objective Target Due date

Collaborate to deliver the scheduled Groundwater Remediation & Drainage upgrades within budget / schedule.

Implementation of full scale Stage 1 GW remediation by Q1 2013

Q1 2013

Reduce IPPC non conformances No more than 28 non compliances in the year Q4 2013

Reduce IPPC non conformances by implementing agreed improvements to improve effectiveness of treatment and abatement systems

Reduce # CEMs failures on air abatement systems in Swords by 25% by Q4.

Q1 and Q4

Ensure compliant, reliable and accurate detection of HCl air emissions

Q3 2013

Reduce number of TO bypasses by 10% based on 2012 Q1 2013

Reduce reportable F-gas releases by 50% Q4 2013


AER 2012

Objective Target Due date

Reduce IPPC non conformances by implementing agreed improvements to increase and improve the recovery, reuse and recycling of waste

Achieve 20% drum recycling rate of empty drums leaving site and divert from incineration

Q4 2013

Carry out sludge dewatering trial in Cruiserath. Review option of carrying sludge dewatering in Swords (assess the odour)

Q4 2013

Develop and implement a solvent recovery strategy that will optimise usage of Solvent recovery across both sites,

Q4 2012

Ensure Sustainable Operations Natural Gas - 35,100,000 kWh (1% reduction) Electrical - 28,300,000 kWh (7% reduction) Water - 223,200 m3 (3% reduction)

Q4 2013

Process modifications resulting in improved yields, elimination or reduction of waste or use of alternative less hazardous materials

Yield optimisation for Product J. Q4 2013

Product K - recovery of Intermediate F from mother liquors.

Q4 2013


AER 2012

6 Pollutant Release and Transfer Register: 6.1 Report for 2012 & Proposal for 2013

The printed copy of PRTR Workbooks 2012 can be found in Appendix E.

For 2013 it is proposed to monitor the same substances as 2012 and report on

those solvents that represent over 90 % of the total emissions.

7 Licence – Specific Reports

7.1 Noise The annual noise survey was carried out in September 2012 & the report is

attached in Appendix F. As suggested by the Agency during their inspection, off-

site daytime monitoring was also carried out in the adjacent park & at the entrance

to Fingal County Council.

7.2 Bund, Sump and Drain Inspection and Testing

Integrity testing of underground tanks is carried out every three years as part of

the tank integrity-testing programme. Eleven tanks were due for testing during

2012 and all were tested & certified.

CCTV surveying of all Process, Foul and Surface Water drains is carried out on an

ongoing basis, with each system surveyed every three years as required. During

2012, all process drains were CCTV surveyed and pressure testing is

ongoing to determine integrity. It is planned to commence pressure

testing of Surface Water drains in 2014 and Foul drains in 2015.

Bund integrity testing is carried out on a phased routine on a three yearly

basis, see table below for details of 2012. In addition, 10 bunds were

constructed / modified during project works in 2012 and they were also

integrity tested.

Tests required 2012 Repairs

required Status of repairs – Mar-13

Bunds 37 5 3 completed & bunds certified.

Works ongoing on 2 bunds

Sumps 23 4 Completed & sumps certified


AER 2012

7.3 Residuals Management Plan & ELRA Statement

The revised risk matrix can be found below – only one medium risk hazard has

been identified, the remaining are low-level risks remain which are under ongoing

monitoring & management. No new hazards were added in the 2012 review.

Risk Matrix – Current Risk Status March-13 –

Risks in red have increased since 2011 review

Occ

urr

en

ce

V. High 5 2, 6, 24 14 13 34

High 4

Medium 3 4, 38

5, 9, 15, 21, 25, 39, 40 33

Low 2

3, 8, 18, 22, 35, 37, 42 16, 32

V. Low 1

1, 7, 17, 23, 26, 29, 45 30

Trivial 1

Minor 2

Moderate 3

Major 4

Massive 5

Severity

High risks identified during the 2012 review were:

# 13: Leak from underground process drains – based on the findings of

the drainage integrity testing completed during 2012 and

# 34: Potential for unknown additional Groundwater contamination

sources exist – based on the findings of the extended delineation & risk

assessment works during 2012.

Bristol-Myers Squibb Co., our parent and an unlimited liability company, will act as

guarantor for any future environmental liabilities of Swords Laboratories. BMS

maintains a Global remediation fund for ongoing remediation required at sites

during their operation. In addition, BMS manages ARO’s (Asset Retirement

Obligations) - reserves designed to accumulate over their lifespan, so that

adequate funds are available at the time the asset replacement is required. These

are currently in place for the Swords site tankfarms and WWTP and have a current


AER 2012

estimated value of $400,000. These combined measures, in conjunction with the

programme proposed for a known closure, will fund remediation of Environmental

Liabilities.

The Residual Management Plan has been reviewed and as a result it is

proposed to increase the stated CLIARP costs from €25,000 proposed, to

€1,290,000 the current budgeted cost for Stage 1 groundwater

remediation programme. The total estimated cost of the residuals

management plan is therefore €1,893,850

7.4 Solvent Management Plan

A Solvent Management Plan was compiled by the Clean Technology Centre and can

be found in Appendix G.

Appendix A

Emissions to Sewer

P0014-04 AER 2012


DateFlow

(m3)BOD(mg/l)

COD(mg/l)

SS(mg/l)

Temp.(°C)

pHSulphates

(mg/l)

Ortho Phosphateas P (mg/l)

Fluoride(mg/l)

Zinc(mg/l)

Cadmium (mg/l)

Chromium(mg/l)

Copper(mg/l)

Lead(mg/l)

Nickel(mg/l)

Total heavy metals (mg/l)

Fats / Oil / Grease(mg/l)

Limit 600 200 1500 400 42 6 - 10 750 100 n/a 1 n/a 0.5 0.5 0.1 0.5 n/a 100

01-Jan-12 66 702-Jan-12 63 703-Jan-12 253 0 17 7 10.0004-Jan-12 432 2 16 705-Jan-12 480 0 17 7 7.4006-Jan-12 391 2 15 707-Jan-12 290 2 16 708-Jan-12 338 10 16 709-Jan-12 325 4 19 610-Jan-12 251 4 16 6 26.0011-Jan-12 236 34 16 612-Jan-12 342 32 18 7 30.0013-Jan-12 395 38 11 714-Jan-12 460 38 18 715-Jan-12 398 6 17 716-Jan-12 357 48 15 7 48.0017-Jan-12 264 78 17 718-Jan-12 439 11 770 54 17 7 105.65 54.63 0.18 0.00868 0.00025 0.002 0.002 0.0005 0.002 0.01543 4.8019-Jan-12 446 353 820 110 17 720-Jan-12 516 209 4750 76 17 721-Jan-12 314 2600 74 17 722-Jan-12 412 1375 64 16 723-Jan-12 390 56 230 52 18 7 12.0024-Jan-12 399 210 25 18 725-Jan-12 365 200 80 18 7 17.0026-Jan-12 431 180 100 17 727-Jan-12 408 137 114 16 828-Jan-12 396 138 110 14 729-Jan-12 504 139 116 16 730 J 12 527 180 54 15 730-Jan-12 527 180 54 15 731-Jan-12 463 360 72 15 7 22.0001-Feb-12 581 270 148 16 702-Feb-12 517 280 164 16 7 21.0003-Feb-12 544 104 15 704-Feb-12 505 38 17 705-Feb-12 462 44 15 806-Feb-12 477 98 12 807-Feb-12 490 54 14 808-Feb-12 462 12 280 90 15 8 178.61 23.22 0.270 0.033 0.00025 0.00252 0.003480 0.0005 0.002 0.04175 13.809-Feb-12 381 104 15 710-Feb-12 327 94 15 7 22.0011-Feb-12 277 84 18 712-Feb-12 282 62 18 713-Feb-12 243 74 14 714-Feb-12 299 70 16 715-Feb-12 408 80 15 716-Feb-12 438 76 19 717-Feb-12 338 30 17 718-Feb-12 301 18 18 719-Feb-12 366 20 15 720-Feb-12 267 72 18 721-Feb-12 423 66 18 722-Feb-12 378 50 540 66 16 7 171.04 37.00 2.45 0.0123 0.00025 0.0025 0.00528 0.0005 0.00242 0.0232523-Feb-12 187 96 18 7 27.1024-Feb-12 278 50 15 725-Feb-12 418 38 17 726-Feb-12 361 78 18 727-Feb-12 345 56 20 728-Feb-12 335 360 38 17 729-Feb-12 368 240 42 18 8 18.80

AER 2012


DateFlow

(m3)BOD(mg/l)

COD(mg/l)

SS(mg/l)

Temp.(°C)

pHSulphates

(mg/l)


Fluoride(mg/l)

Zinc(mg/l)

Cadmium (mg/l)

Chromium(mg/l)

Copper(mg/l)

Lead(mg/l)

Nickel(mg/l)



Limit 600 200 1500 400 42 6 - 10 750 100 n/a 1 n/a 0.5 0.5 0.1 0.5 n/a 100

01-Mar-12 420 210 46 15 702-Mar-12 501 120 40 17 7 21.1003-Mar-12 447 112 54 20 704-Mar-12 384 104 24 19 705-Mar-12 346 112 26 16 706-Mar-12 327 111 26 15 707-Mar-12 311 2 98 26 19 7 123.72 17.11 0.19 0.0085 0.00027 0.002 0.00336 0.00056 0.002 0.01669 14.208-Mar-12 374 24 17 709-Mar-12 378 32 18 7 18.8010-Mar-12 381 30 17 7 17.1011-Mar-12 344 64 17 712-Mar-12 366 2 21 713-Mar-12 493 0 17 8 19.7014-Mar-12 199 420 116 15 915-Mar-12 0 NS NS NS NS16-Mar-12 173 288 1410 664 17 9 128.36 6.20 0.53 0.2390 0.00025 0.0159 0.04410 0.00058 0.00535 0.30518 13.017-Mar-12 341 108 730 262 17 9 181.42 35.21 0.75 0.005 0.00025 0.002 0.01960 0.0005 0.002 0.02935 8.018-Mar-12 314 166 780 170 18 9 167.01 10.60 0.54 0.005 0.00025 0.002 0.00422 0.0005 0.002 0.01397 6.019-Mar-12 237 196 700 132 19 9 176.09 8.46 0.53 0.005 0.00025 0.002 0.00507 0.0005 0.002 0.01482 11.020-Mar-12 327 128 580 226 20 8 139.42 9.37 0.42 0.0562 0.00025 0.00204 0.00924 0.0005 0.002 0.07023 12.021-Mar-12 295 360 124 17 822-Mar-12 224 15 150 68 18 8 249.47 2.45 0.16 0.0151 0.00025 0.002 0.00676 0.00167 0.00308 0.02886 6.623-Mar-12 115 150 4 17 824-Mar-12 238 148 136 17 825-Mar-12 403 112 192 18 726-Mar-12 420 240 38 17 727-Mar-12 387 80 30 17 7 2.2028-Mar-12 415 52 17 729-Mar-12 426 44 20 730 M 12 463 36 20 7 1 330-Mar-12 463 36 20 7 1.331-Mar-12 436 0 8 701-Apr-12 395 8 8 702-Apr-12 502 0 8 703-Apr-12 497 78 16 7 1.304-Apr-12 497 2 60 144 16 7 311.84 0.25 0.1 0.00684 0.00025 0.00373 0.002 0.0005 0.002 0.01532 6.605-Apr-12 428 144 18 706-Apr-12 456 48 17 707-Apr-12 400 54 18 708-Apr-12 400 36 18 709-Apr-12 413 42 18 710-Apr-12 348 34 12 711-Apr-12 434 92 11 712-Apr-12 436 48 16 713-Apr-12 432 94 16 714-Apr-12 336 28 18 715-Apr-12 213 126 13 716-Apr-12 421 182 17 717-Apr-12 432 74 16 718-Apr-12 484 80 18 719-Apr-12 497 186 18 820-Apr-12 407 166 13 7 1.321-Apr-12 377 90 15 722-Apr-12 304 72 17 7 1.323-Apr-12 310 2 17 724-Apr-12 358 66 16 725-Apr-12 482 54 16 7 1.326-Apr-12 463 52 15 727-Apr-12 444 18 18 7 1.328-Apr-12 361 12 16 729-Apr-12 369 4 16 730-Apr-12 374 22 16 7 < 1.3

Note: On 15-Mar-12, due to pH exceedence overnight Final Effluent discharge was stopped for that day and therefore no samples were analysed.

AER 2012


DateFlow

(m3)BOD(mg/l)

COD(mg/l)

SS(mg/l)

Temp.(°C)

pHSulphates

(mg/l)


Fluoride(mg/l)

Zinc(mg/l)

Cadmium (mg/l)

Chromium(mg/l)

Copper(mg/l)

Lead(mg/l)

Nickel(mg/l)



Limit 600 200 1500 400 42 6 - 10 750 100 n/a 1 n/a 0.5 0.5 0.1 0.5 n/a 100

01-May-12 398 22 16 702-May-12 417 8 18 7 < 1.303-May-12 466 50 16 704-May-12 411 32 17 705-May-12 419 60 21 706-May-12 462 78 14 707-May-12 498 10 17 708-May-12 433 26 16 709-May-12 323 4 42 24 20 7 124.75 0.16 0.1 0.01200 0.00025 0.00222 0.00664 0.0005 0.00302 0.02463 2.210-May-12 382 2 17 7 1.4011-May-12 313 12 15 712-May-12 278 2 15 713-May-12 239 4 17 714-May-12 254 6 15 7 7.3015-May-12 277 12 15 716-May-12 329 0 14 7 7.8017-May-12 280 24 19 718-May-12 391 2 16 719-May-12 506 36 18 720-May-12 562 42 19 721-May-12 410 58 18 8 9.2022-May-12 374 40 17 723-May-12 368 30 19 7 10.0024-May-12 304 0 17 725-May-12 288 0 19 726-May-12 321 40 18 727-May-12 334 6 20 728-May-12 322 0 20 7 12.0029-May-12 254 0 19 730 M 12 255 44 19 7 13 0030-May-12 255 44 19 7 13.0031-May-12 246 22 19 801-Jun-12 299 36 19 702-Jun-12 297 0 19 703-Jun-12 274 68 17 704-Jun-12 186 58 20 705-Jun-12 228 60 15 806-Jun-12 308 2 80 60 15 8 109.12 16.79 0.32 0.0248 0.00059 0.002 0.011 0.0005 0.002 0.04089 1.807-Jun-12 330 42 17 708-Jun-12 173 92 18 7 18.4009-Jun-12 255 30 16 710-Jun-12 337 50 17 711-Jun-12 362 4 17 712-Jun-12 235 54 18 8 14.6013-Jun-12 305 34 16 814-Jun-12 401 64 19 8 15.0015-Jun-12 378 66 17 816-Jun-12 202 70 18 8 16.0017-Jun-12 233 50 18 818-Jun-12 306 68 18 8 13.0019-Jun-12 396 116 17 820-Jun-12 326 110 18 7 15.0021-Jun-12 303 116 18 722-Jun-12 266 132 17 723-Jun-12 335 14 19 724-Jun-12 288 10 19 725-Jun-12 377 138 18 7 12.0026-Jun-12 405 132 18 727-Jun-12 354 144 19 7 10.0028-Jun-12 286 12 18 729-Jun-12 194 30 18 730-Jun-12 271 20 19 7

AER 2012


DateFlow

(m3)BOD(mg/l)

COD(mg/l)

SS(mg/l)

Temp.(°C)

pHSulphates

(mg/l)


Fluoride(mg/l)

Zinc(mg/l)

Cadmium (mg/l)

Chromium(mg/l)

Copper(mg/l)

Lead(mg/l)

Nickel(mg/l)



Limit 600 200 1500 400 42 6 - 10 750 100 n/a 1 n/a 0.5 0.5 0.1 0.5 n/a 100

01-Jul-12 454 36 17 702-Jul-12 315 84 18 7 9.1003-Jul-12 389 10 19 704-Jul-12 349 2 65 38 19 7 142.00 16.00 0.16 0.0186 0.00025 0.00241 0.002 0.0005 0.002 0.02576 3.405-Jul-12 375 34 18 706-Jul-12 406 74 18 707-Jul-12 480 18 20 708-Jul-12 399 6 20 709-Jul-12 408 10 17 710-Jul-12 490 24 16 7 23.0011-Jul-12 532 6 19 712-Jul-12 492 75 14 16 7 16.3013-Jul-12 505 34 18 714-Jul-12 439 66 17 715-Jul-12 501 38 17 716-Jul-12 530 66 18 7 20.7017-Jul-12 514 16 18 718-Jul-12 548 16 23 7 16.3019-Jul-12 542 6 17 720-Jul-12 505 26 18 721-Jul-12 519 16 17 722-Jul-12 530 20 20 723-Jul-12 540 58 23 824-Jul-12 584 96 20 825-Jul-12 563 34 19 826-Jul-12 339 28 19 727-Jul-12 291 18 21 728-Jul-12 383 2 19 729-Jul-12 431 6 18 730 J l 12 384 48 17 8 1 5030-Jul-12 384 48 17 8 1.5031-Jul-12 359 94 19 701-Aug-12 404 2 47 60 20 7 189.00 2.70 0.50 0.0186 0.00025 0.00452 0.00335 0.0005 0.00313 0.03035 1.402-Aug-12 369 42 18 703-Aug-12 289 32 18 704-Aug-12 339 14 18 705-Aug-12 344 20 19 806-Aug-12 447 30 19 707-Aug-12 354 4 19 7 3.8008-Aug-12 315 30 18 709-Aug-12 271 18 18 7 4.8010-Aug-12 263 10 20 711-Aug-12 276 0 21 712-Aug-12 341 2 20 813-Aug-12 290 14 20 8 9.1014-Aug-12 254 38 20 715-Aug-12 343 8 20 7 8.5016-Aug-12 262 0 19 717-Aug-12 256 0 20 718-Aug-12 228 4 20 719-Aug-12 294 44 20 720-Aug-12 399 10 20 7 14.0021-Aug-12 356 10 19 722-Aug-12 332 28 20 7 18.0023-Aug-12 345 10 19 724-Aug-12 398 4 19 725-Aug-12 259 20 21 726-Aug-12 114 16 19 727-Aug-12 269 8 17 7 20.0028-Aug-12 255 36 19 729-Aug-12 241 0 19 7 16.0030-Aug-12 219 0 19 731-Aug-12 245 36 18 7

AER 2012


DateFlow

(m3)BOD(mg/l)

COD(mg/l)

SS(mg/l)

Temp.(°C)

pHSulphates

(mg/l)


Fluoride(mg/l)

Zinc(mg/l)

Cadmium (mg/l)

Chromium(mg/l)

Copper(mg/l)

Lead(mg/l)

Nickel(mg/l)



Limit 600 200 1500 400 42 6 - 10 750 100 n/a 1 n/a 0.5 0.5 0.1 0.5 n/a 100

01-Sep-12 190 4 20 702-Sep-12 117 46 19 703-Sep-12 163 0 20 7 6.4004-Sep-12 194 46 19 705-Sep-12 211 3 72 16 21 7 21.00 0.64 0.1 0.0705 0.00025 0.002 0.0158 0.0005 0.002 0.09105 3.4006-Sep-12 203 20 18 707-Sep-12 214 20 19 708-Sep-12 229 20 21 709-Sep-12 225 28 18 710-Sep-12 210 2 19 711-Sep-12 252 36 14 8 1.2012-Sep-12 272 36 18 813-Sep-12 279 32 20 7 0.7614-Sep-12 354 0 18 715-Sep-12 364 2 19 716-Sep-12 343 16 17 717-Sep-12 273 28 18 718-Sep-12 327 28 17 7 0.1419-Sep-12 404 0 16 720-Sep-12 459 2 21 7 0.0621-Sep-12 399 2 16 722-Sep-12 293 6 18 723-Sep-12 300 0 15 724-Sep-12 375 0 20 725-Sep-12 415 0 20 7 0.0626-Sep-12 432 0 19 727-Sep-12 324 0 19 8 0.0928-Sep-12 329 39 0 18 729-Sep-12 347 36 0 17 730 S 12 325 36 8 18 730-Sep-12 325 36 8 18 701-Oct-12 409 38 0 18 702-Oct-12 369 35 0 17 703-Oct-12 307 3 35 0 17 7 197.00 0.16 0.1 0.0194 0.00025 0.002 0.0172 0.0005 0.002 0.04135 1.8004-Oct-12 338 32 0 16 705-Oct-12 351 0 15 706-Oct-12 328 0 18 707-Oct-12 364 0 18 808-Oct-12 438 0 18 709-Oct-12 316 0 15 710-Oct-12 306 0 17 711-Oct-12 316 0 18 712-Oct-12 343 0 14 713-Oct-12 143 0 17 714-Oct-12 216 0 15 715-Oct-12 242 0 18 716-Oct-12 154 0 16 717-Oct-12 303 4 19 818-Oct-12 343 8 17 819-Oct-12 368 0 17 820-Oct-12 317 0 18 721-Oct-12 289 0 13 722-Oct-12 329 0 17 723-Oct-12 299 0 18 824-Oct-12 333 0 20 825-Oct-12 353 0 18 726-Oct-12 357 0 20 727-Oct-12 357 0 14 828-Oct-12 434 0 12 829-Oct-12 504 0 17 830-Oct-12 515 0 16 831-Oct-12 527 0 12 8

AER 2012


DateFlow

(m3)BOD(mg/l)

COD(mg/l)

SS(mg/l)

Temp.(°C)

pHSulphates

(mg/l)


Fluoride(mg/l)

Zinc(mg/l)

Cadmium (mg/l)

Chromium(mg/l)

Copper(mg/l)

Lead(mg/l)

Nickel(mg/l)



Limit 600 200 1500 400 42 6 - 10 750 100 n/a 1 n/a 0.5 0.5 0.1 0.5 n/a 100

01-Nov-12 454 0 14 702-Nov-12 338 0 14 703-Nov-12 275 0 13 704-Nov-12 312 2 15 705-Nov-12 190 0 17 806-Nov-12 197 24 19 807-Nov-12 259 2 27 0 17 8 149.00 0.02 0.32 0.0184 0.00025 0.0025 0.00293 0.0005 0.002 0.02658 0.808-Nov-12 387 2 30 0 15 8 140.00 0.04 0.4409-Nov-12 330 0 14 810-Nov-12 265 0 15 811-Nov-12 274 0 14 812-Nov-12 311 0 18 813-Nov-12 390 0 17 814-Nov-12 366 2 16 815-Nov-12 301 0 15 816-Nov-12 403 6 17 817-Nov-12 301 56 11 818-Nov-12 331 0 12 819-Nov-12 316 0 18 820-Nov-12 234 0 18 821-Nov-12 245 16 0 14 822-Nov-12 246 44 0 18 823-Nov-12 260 44 0 17 824-Nov-12 274 41 0 18 825-Nov-12 371 38 2 14 826-Nov-12 449 39 0 13 827-Nov-12 448 41 0 14 828-Nov-12 572 35 0 10 729-Nov-12 371 0 11 730 N 12 278 0 14 730-Nov-12 278 0 14 701-Dec-12 496 0 14 802-Dec-12 475 32 13 803-Dec-12 519 27 0 14 804-Dec-12 463 30 0 16 805-Dec-12 455 2 39 0 10 8 89.00 0.16 0.36 0.0210 0.00025 0.002 0.00272 0.0005 0.002 0.02847 1.506-Dec-12 551 43 0 15 807-Dec-12 453 88 4 11 808-Dec-12 373 84 0 18 809-Dec-12 407 32 0 13 810-Dec-12 447 0 14 811-Dec-12 404 16 11 812-Dec-12 403 0 12 813-Dec-12 414 18 12 814-Dec-12 482 12 14 815-Dec-12 494 8 18 816-Dec-12 464 0 13 817-Dec-12 420 20 15 818-Dec-12 419 0 16 819-Dec-12 346 0 14 820-Dec-12 499 0 17 821-Dec-12 504 0 15 822-Dec-12 484 823-Dec-12 301 824-Dec-12 236 825-Dec-12 248 826-Dec-12 253 827-Dec-12 272 828-Dec-12 227 829-Dec-12 187 830-Dec-12 201 831-Dec-12 246 8

AER 2012


AER 2012

Date of sample

Project No Acetone

(µg/l)

Carbon Disulphide

(µg/l)

Dichloro methane

(µg/l)

Tetrahydrofuran (µg/l)

Methyl tert butyl

ether (µg/l)

Chloroform (µg/l)

Methanol (µg/l)

Isopropanol (µg/l)

Triethylamine (µg/l)

N-Methyl pyrollidinone

(µg/l)

18-Jan-12 Jan Effluent 7 1 08-Feb-12 Feb Effluent 3 730

22-Feb-12 Feb Effluent (EPA) 1,500 86,000

01-Mar-12 Mar Effluent 1 05-Mar-12 Mar Effluent 1 07-Mar-12 Mar Effluent 2 16-Mar-12 Mar Effluent 28,000 2,000 790 226,000 5,600 310 17-Mar-12 Mar Effluent 18,000 870 510 88,400 18-Mar-12 Mar Effluent 38,000 2,000 1,000 145,000 19-Mar-12 Mar Effluent 29,000 3,200 920 243,000 900 20-Mar-12 Mar Effluent 29,000 910 1,100 97,300 1,200

22-Mar-12 Mar Effluent (EPA Grab) 93 2 36 15 1

7,300 04-Apr-12 Apr Effluent 130 12 21 2 09-May-12 May Effluent 1 04-Jul-12 July Effluent 1 01-Aug-12 Aug Effluent 2 05-Sep-12 Sept Effluent 1 03-Oct-12 Oct Effluent 18 2 07-Nov-12 Nov Effluent 2 1

08-Nov-12 Nov Effluent (EPA) 1

03-Dec-12 Dec Effluent 11 1 04-Dec-12 Dec Effluent 1 1 05-Dec-12 Dec Effluent 23 1 06-Dec-12 Dec Effluent 16 1 07-Dec-12 Dec Effluent 12 1 08-Dec-12 Dec Effluent 15 1 1 09-Dec-12 Dec Effluent 17 1 1

No other solvent in the VOC or Alcohols suite were detected above the Method Detection Limit.


AER 2012

The site Final Effluent solvent concentration trigger level is 1 mg/l and the investigations into results in excess of that are outlined below:

February 2012: trigger level exceeded Dichloromethane and Tetrahydrofuran - a source of the elevated THF & DCM in the Final Effluent could not be confirmed

March 2012: trigger level exceeded for Acetone, Dichloromethane, Tetrahydrofuran, Methanol, Isopropanol and Triethylamine – it is believed that the cause of the elevated solvent concentrations was the incident in the WWTP on 14th March and that treatment effectiveness was reduced as a result.

Periodic meetings continue on site to discuss upcoming processing, identify streams that require further testing / alternative disposal & to re-iterate issues caused in WWTP by solvent over-loading.


Waste Sludge From the On-site Waste Water Treatment Plant 2012

Aluminium Cadmium Chromium Copper Iron Lead Manganese Nickel Zinc

07-Mar-12 24,200 <5.10 <40.8 41.7 1600 13.7 99.8 <40.8 303 6.56 42,700 45,000 2,825 4.518 95.482 69.906-Jun-12 36,900 671 <53.6 79.9 4440 21.3 223 <53.6 698 6.85 30,840 28,000 2,300 3.164 96.836 58.7605-Sep-12 45,100 <5.57 <44.6 93.9 4820 20.7 257 <44.6 507 7.62 38,860 32,000 2,075 4.046 95.954 52.6705-Dec-12 53,600 <7.5 <60.0 105 4810 21.3 364 <60.0 651 6.88 32,780 31,000 2,038 3.236 96.764 59.66

MTBE Acetone DCM Toluene

06-Jun-12 <1 <13 <1 <2.5 <13 70.005-Sep-12 <28 <140 <43 <57 <140 470

no other solvents were detected above MDL

pH SS (mg/l) COD (mg/l) BOD (mg/l)Date

Loss on Ignition %

Water content %

Dry matter %

Metals

(mg/kg) dry

Carbon Disulfide

2-Butanone

VOC (ug/kg)Date

AER 2012

Appendix B

Emissions to Air

P0014-04 AER 2012


AER 2012

Thermal Oxidiser Downtime summary 2012

All TO bypasses 2012 were determined to be non-significant.

Date & Time (duration)

Cause & characteristics Estimated emission quantity

Assessment of

significance

Corrective & preventative actions taken

4th Jan 10:53 - 11:26

Low water level in quench tower due to loss of pressure in the city water mains but not sufficient to trigger the low pressure alarm

n/a non-significant

Minimum quench level alarm on the operator’s pager has been implemented as preventive action

30th Jan 14:15-14:45

The TO shutdown due to an accidental switch over from Deaerator pump A to new pump C for a test run.

n/a non-significant

SCADA screen will be updated to highlight that pump B is NOT part of duty/standby and loss of run signal from either pump A or C will immediate shutdown the TO.

1st Feb 14:40-15:00

To repair a leak in the boiler house, the supply of Deaerator water had to be stopped. This eventually led to a shortfall in water to the TO Deaerator and a subsequent shutdown.

n/a non-significant

None possible - it’s not possible to have an alternative water supply to the deaerator as it needs DI water.

11th Feb 21:50 to 12th Feb 01:40

A faulty temperature probe on the PSB stack was indicating that the PSB was off when it was actually on, this shut down the TO as it’s interlocked to the PSB operation.

n/a non-significant

Temperature probe on PSB to be routinely changed out. Feedback from the PSB temperature probe to the PLC to identify failures will be investigated.

12th Feb 05:15 to 06:20 n/a non-

significant

12th Feb 08.20 - 09.10 n/a non-

significant

12th Feb 09.35 - 12.45 n/a non-

significant

12th Feb 14.30 - 15.15 n/a non-

significant

14th Feb 11:00 - 12.43 Planned shutdown n/a non-

significant None required

29th Mar 11:00 - 17:20

The combustor shut down on a high pressure interlock during operation of the soot blowers.

n/a non-significant

Investigate possibility of additional response speed during operation of soot blowers

24th April 7.12 - 25th April 7.42 Planned shutdown n/a Non-

significant None required

21st June 15:25 - 18:15

Loss of instrument air to the Plume Suppression Burner system. The air loss was caused by the accidental closure of a manual valve on the air manifold by personnel working in the area.

n/a Non-significant

The valve handle was removed. It is planned to review & modify any other air valves for critical equipment in the area.

26th June

16.10 - 18.15

False activation of an Inergen System Detector caused by dust in the TO control room from A/C unit servicing.

n/a Non-significant

A/C unit service work order will be updated to include disablement of the Inergen System & covering the detector in the room during & for 1 hour after those works.


AER 2012

Date & Time (duration)

Cause & characteristics Estimated emission quantity

Assessment of

significance

Corrective & preventative actions taken

5th Aug 18.35 - 20.30 Low level switch in steam

drum

n/a Non-significant Damaged level switch

connection head was replaced. 13th Aug 03.40 - 05.40 n/a Non-

significant

10th Aug 23.50 – 11th Aug

01.50 Failed airline n/a Non-

significant Failed length of airline was replaced.

28th Aug 10:23 – 14:09 Planned shutdown n/a Non-

significant Manufacturing activities were planned around the shutdown.

10th Sep 16:28 - 17:45; 18:19 - 19:13

Inergen system activation n/a Non-significant

Dust entered the detector & activated the system

21st Sept 14:55 - 15.55 Inergen system activation n/a Non-

significant Faulty interface did not remain disabled during routine testing

15th Oct 11.50 to 12.15

Planned works to switchover to standby quench pump. n/a Non-

significant

CAPAs under investigation – will be implemented before any similar planned activities.

12th Nov 11.27 - 11.50

During PLC shutdown to connect the Cryogenic Condenser to the vent header PLC.

n/a Non-significant

Prompt to be added to vent header PLC to ensure that WWTP is taken off-line during any planned PLC shutdowns.

24th Nov 05:00 - 13:30

Air line to natural gas valve on PSB burst and led to a complete shutdown of the Thermal Oxidiser.

n/a Non-significant Airline was replaced.

28th Nov 00.35 to 03.25

Failed temperature probe on combustor. n/a Non-

significant Temperature probe replaced.

19th Dec 09.25 Christmas shutdown n/a Non-

significant

None required. Stack monitoring completed for P3 activities that continued.

BMS Swords Laboratories P0014‐04

HCl

23‐Aug‐12 00:30 1.01

01:00 0.73

01:30 1.88

02:00 1.98

02:30 2.34

03:00 2.67

03:30 2.02

04:00 1.46

04:30 1.42

05:00 1.05

05:30 1.66

06:00 1.76

06:30 1.91

07:00 1.90

07:30 1.51

08:00 0.79

08:30 1.99

09:00 0.81

09:30 0.70

10:00 0.52

10:30 1.29

11:00 1.80

11:30 1.63

12:00 2.31

12:30 2.49

13:00 2.00

13:30 1.49

14:00 0.99

14:30 0.99

15:00 1.43

15:30 1.92

16:00 2.92

16:30 8.29

17:00 15.55

17:30 96.32

18:00 60.35

18:30 20.45

19:00 11.41

19:30 9.65

20:00 5.50

20:30 7.63

21:00 6.46

21:30 7.24

22:00 6.22

22:30 4.10

23:00 2.87

23:30 2.22

24:00:00 1.97

Average: 6.62

CEMs data for periods of 30‐minute ELV exceedence

AER 2012

SWORDS LABORATORIES P0014‐04

Sample Flow rate Sample Parameter Emission ELV

Time (ml/min) Vol m³ (kg/hr) (kg/hr)

(mins)

CC tube

20‐Dec‐12 11:50 P3 Stack Vent A2‐7 30159.6

0.00479 DCM 0.037 0.1

Ethyl Acetate 0.013 3.0Other VOC's 0.002 3.0

SG tube

20‐Dec‐12 13:15 P3 Stack Vent A2‐7 30 165.5 0.00496 Methanol 0.002 3.0

TA Luft Class III

limit (sum of

Class III, II & I

parameters)

0.05 3.0

HCl, SO2 and Particulates monitoring were not completed at the time.

Date Vent Process & Step

Saxagliptin API ‐ Drying &

Cleaning

Saxagliptin API ‐ Drying &

Cleaning

AER 2012

Appendix C

Emissions to Surface Water

P0014-04 AER 2012


Storm water outfall monitoring

Date Location pH COD BOD Visual Inspection(mg/l) (mg/l)

04-Jan-12 SW2 West of Gate 7.84 Clear, colourless, odourless, no suspended solids, sediment present.SW3 East of Gate 8.03 Clear, slight yellow tinge, odourless, no suspended solids.SW4 New Admin 7.88 Clear, colourless, odourless, no suspended solids.* SW5 P4/P7 7.29 Clear, colourless, odourless, no suspended solids, sediment present.SW6 MT Lab 7.84 Clear, colourless, odourless, no suspended solids.* SW7 WWTP NS Being pumped out to WWTP.

12-Jan-12 SW2 West of Gate 7.83 Clear, colourless, odourless, no suspended solids.SW3 East of Gate 7.90 Clear, slight yellow tinge, odourless, no suspended solids.SW4 New Admin 7.93 Clear, colourless, odourless, no suspended solids.* SW5 P4/P7 7.52 Slightly, colourless, odourless, suspended solids, sediment present.SW6 MT Lab 8.03 Clear, colourless, odourless, no suspended solids.* SW7 WWTP NS Being pumped out to WWTP.

18-Jan-12 SW2 West of Gate 7.71 11 <2 Clear, colourless, odourless, no suspended solids, sediment present (muck and grit).

SW3 East of Gate 7.73 68 5 Slightly cloudy, yellow tinge, very mild stagnant odour, no suspended solids.SW4 New Admin 7.85 18 <2 Clear, colourless, odourless, no suspended solids.

* SW5 P4/P7 6.84 89 64 Slightly cloudy, yellow tinge, mild stagnant odour, suspended solids (vegetation), sediment present.

SW6 MT Lab 7.67 7 <2 Clear, colourless, odourless, no suspended solids.* SW7 WWTP NS NS NS Being pumped out to WWTP.

25-Jan-12 SW2 West of Gate 8.07 Clear, colourless, odourless, no suspended solids, sediment present .SW3 East of Gate 7.87 Slightly cloudy, yellow tinge, odourless, no suspended solids.SW4 New Admin 8.04 Clear, colourless, odourless, no suspended solids.

* SW5 P4/P7 7.37 Slightly cloudy, colourless, mild stagnant odour, no suspended solids, (vegetation) sediment present.

SW6 MT Lab 7.85 Clear, colourless, odourless, no suspended solids.* SW7 WWTP NS Being pumped out to WWTP.

31-Jan-12 SW2 West of Gate 7.85 Clear, colourless, odourless, no suspended solids, sediment present .SW3 East of Gate 8.41 Slightly cloudy, yellow tinge, odourless, no suspended solids.SW4 New Admin 7.96 Clear, colourless, odourless, no suspended solids.

* SW5 P4/P7 6.57 Slightly cloudy, greyish colour due to mucky sediment at base of sampling point, SW5 P4/P7 6.57

odourless, no suspended solids.SW6 MT Lab 7.76 Clear, colourless, odourless, no suspended solids, some sediment.* SW7 WWTP NS Being pumped out to WWTP.

08-Feb-12 SW2 West of Gate 7.91 13 <2 Clear, colourless, odourless, no suspended solids, sediment present .SW3 East of Gate 8.04 67 3 Slightly cloudy, yellow tinge, odourless, no suspended solids.SW4 New Admin 7.94 19 <2 Clear, colourless, odourless, no suspended solids.

* SW5 P4/P7 6.91 79 101 Slightly cloudy, stagnant odour, greyish colour due to mucky sediment at base of sampling point, odourless, no suspended solids

SW6 MT Lab 7.90 13 <2 Clear, colourless, odourless, no suspended solids.* SW7 WWTP NS NS NS Being pumped out to WWTP.

14-Feb-12 SW2 West of Gate 7.85 Clear, colourless, odourless, no suspended solids.

SW3 East of Gate 8.17 Slightly cloudy, slight yellow tinge, slight stagnant odour, no suspended solids.

SW4 New Admin 7.93 Clear, colourless, odourless, no suspended solids.

* SW5 P4/P7 6.84 Slightly cloudy, slight stagnant odour, mucky sediment had settled and liquid colourless, no suspended solids.

SW6 MT Lab 7.87 Clear, colourless, odourless, very few suspended solids.* SW7 WWTP NS DRY.

22-Feb-12 SW2 West of Gate 8.01 Clear, colourless, odourless, no suspended solids.SW3 East of Gate 8.15 Slightly cloudy, slight yellow tinge, odourless, no suspended solids.SW4 New Admin 7.93 Clear, colourless, odourless, no suspended solids.* SW5 P4/P7 7.53 Clear, colourless, odourless, some suspended solids, some sediment.SW6 MT Lab 7.90 Clear, colourless, odourless, no suspended solids.* SW7 WWTP NS DRY.

28-Feb-12 SW2 West of Gate 7.93 Clear, colourless, odourless, no suspended solids.

SW3 East of Gate 8.05 Slightly cloudy, slight yellow tinge, slight stagnant odour, no suspended solids.

SW4 New Admin 7.92 Clear, colourless, odourless, no suspended solids.* SW5 P4/P7 7.14 Clear, colourless, odourless, no suspended solids.SW6 MT Lab 7.98 Clear, colourless, odourless, no suspended solids.* SW7 WWTP NS DRY.

AER 2012



07-Mar-12 SW2 West of Gate 8.10 8 <2 Clear, colourless, odourless, no suspended solids, some sediment.SW3 East of Gate 8.15 81 2 Slightly cloudy, slight yellow tinge, odourless, no suspended solids.SW4 New Admin 8.06 19 <2 Clear, colourless, odourless, no suspended solids.* SW5 P4/P7 7.32 28 4 Clear, colourless, odourless, some floating vegetation.SW6 MT Lab 8.06 1 <2 Clear, colourless, odourless, no suspended solids.* SW7 WWTP NS NS NS DRY.

14-Mar-12 SW2 West of Gate 7.96 12 Clear, colourless, odourless, sheen visible at sampling point with brownish film.

SW3 East of Gate 7.89 Slightly cloudy, slight yellow tinge, odourless, no suspended solids.SW4 New Admin 7.87 Clear, colourless, odourless, no suspended solids.

* SW5 P4/P7 7.16 Very slightly cloudy, colourless, odourless, sediment/muck present with vegetation.

SW6 MT Lab 7.69 Clear, colourless, odourless, no suspended solids.* SW7 WWTP NS DRY.

21-Mar-12 SW2 West of Gate 7.86 Clear, colourless, odourless, no suspended solids.SW3 East of Gate 7.81 Clear, colourless, odourless, no suspended solids.SW4 New Admin 7.76 Clear, colourless, odourless, no suspended solids.* SW5 P4/P7 7.28 Slightly cloudy, colourless, odourless, mucky/slightly grey/black.SW6 MT Lab 7.74 Clear, colourless, odourless, no suspended solids.* SW7 WWTP NS DRY.

28-Mar-12 SW2 West of Gate 7.81 Clear, colourless, odourless, no suspended solids.SW3 East of Gate 7.79 Clear, colourless, odourless, no suspended solids.SW4 New Admin 7.85 Clear, colourless, odourless, no suspended solids.* SW5 P4/P7 NS DRY.SW6 MT Lab 7.74 Clear, colourless, odourless, no suspended solids.* SW7 WWTP NS DRY.

04-Apr-12 SW2 West of Gate 7.94 UR <2 Clear, colourless, odourless, no suspended solids.SW3 East of Gate 7.78 14 3 Clear, colourless, odourless, no suspended solids.SW4 New Admin 7.71 34 3 Clear, colourless, odourless, no suspended solids.* SW5 P4/P7 NS NS NS DRY.SW6 MT Lab 7.67 UR <2 Clear, colourless, odourless, some sediment present.

Cloudy yellow stale odour (some loose sand from sand bag used to block outfall)* SW7 WWTP 7.35 490 228 Cloudy, yellow, stale odour (some loose sand from sand bag used to block outfall).

This is being pumped out to WWTP.

12-Apr-12 SW2 West of Gate 7.97 Clear, colourless, odourless, no suspended solids.SW3 East of Gate 7.75 Clear, colourless, very slight stagnant odour, no suspended solids.SW4 New Admin 7.85 Clear, colourless, odourless, no suspended solids.* SW5 P4/P7 NS DRY.SW6 MT Lab 7.85 Clear, colourless, odourless, very small amount sediment present.* SW7 WWTP NS DRY.

18-Apr-12 SW2 West of Gate 7.78 Slightly cloudy, colourless, odourless, sediment present.SW3 East of Gate 7.75 Clear, colourless, odourless, no suspended solids.SW4 New Admin 7.92 Clear, colourless, odourless, no suspended solids.* SW5 P4/P7 7.52 Clear, colourless, odourless, some vegetation floating in sample.SW6 MT Lab 7.87 Clear, colourless, odourless, no suspended solids.* SW7 WWTP 7.29 Cloudy, colourless, odourless, sediment present.

25-Apr-12 SW2 West of Gate 8.03 Cloudy, grey/brown, odourless, some suspended solids.SW3 East of Gate 8.18 Clear, colourless, odourless, no suspended solids.SW4 New Admin 7.83 Clear, colourless, odourless, no suspended solids.* SW5 P4/P7 7.14 Clear, colourless, odourless, no suspended solids.SW6 MT Lab 7.56 Cloudy, colourless, odourless, no suspended solids.* SW7 WWTP NS DRY.

AER 2012



03-May-12 SW2 West of Gate 7.81 Cloudy, grey/brown, odourless, some suspended solids.SW3 East of Gate 8.48 Clear, colourless, odourless, no suspended solids.SW4 New Admin 7.84 Clear, colourless, odourless, no suspended solids.* SW5 P4/P7 7.60 Brown / grey in colour, cloudy, odourless, sediment & suspended solids present.SW6 MT Lab 7.78 Clear, colourless, odourless, no suspended solids.* SW7 WWTP NS DRY.

09-May-12 SW2 West of Gate 8.02 2 3 Clear, colourless, odourless, sediment present.SW3 East of Gate 8.63 25 3 Clear, colourless, odourless, no sediment or suspended solids present.SW4 New Admin 7.92 UR <2 Clear, colourless, odourless, no sediment or suspended solids present.

* SW5 P4/P7 7.51 57 83 Slightly cloudy, colourless, odourless, brown/grey sediment/silt present. Sheen visible at sample point, but difficult to see into sample location.

SW6 MT Lab 7.77 1 <2 Clear, colourless, odourless, no sediment or suspended solids present.* SW7 WWTP NS NS NS DRY.

16-May-12 SW2 West of Gate 8.01 Clear, colourless, odourless, suspended solids and sediment present.SW3 East of Gate 8.31 Clear, colourless, odourless, no suspended solids.SW4 New Admin 7.91 Clear, colourless, odourless, no suspended solids.* SW5 P4/P7 7.40 Clear, colourless, odourless, suspended solids and sediment present.SW6 MT Lab 7.90 Clear, colourless, odourless, no suspended solids.* SW7 WWTP NS DRY.

23-May-12 SW2 West of GateSW3 East of GateSW4 New Admin* SW5 P4/P7SW6 MT Lab* SW7 WWTP

30-May-12 SW2 West of Gate 7.90 Slightly cloudy, colourless, odourless, sediment & suspended solids present.

SW3 East of Gate 7.92 Clear, colourless, odourless, suspended solids present (some vegetation).SW4 New Admin 7.62 155 Clear, yellowish, odourless, no sediment or suspended solids.

* SW5 P4/P7 7.84 750 Cloudy, colourless, slight solvent like odour, slight sheen visible, sediment present.

SW6 MT Lab 7.81 Clear, colourless, odourless, no suspended solids present .* SW7 WWTP NS DRY

Samples were not collected from Surface Water outfalls in error, as per correspondence to the Agency at the time.

* SW7 WWTP NS DRY.

06-Jun-12 SW2 West of Gate 7.82 6 4 Slightly cloudy, brownish colour when shaken due to sediment, odourless, suspended solids present.

SW3 East of Gate 8.22 27 6 Very slightly cloudy, colourless, odourless, no suspended solids, some vegetation present.

SW4 New Admin 7.88 15 <2 Clear, colourless, odourless, no suspended solids.* SW5 P4/P7 6.97 95 31 Slightly cloudy, colourless, odourless, sediment present.SW6 MT Lab 7.72 3 <2 Clear, colourless, odourless, no suspended solids.

* SW7 WWTP 10.06 550 171 Cloudy, brown/yellow colour, strong stale/stagnant odour, suspended solids & sediment present.

13-Jun-12 SW2 West of Gate 8.04 Clear, colourless, odourless, some sediment.

SW3 East of Gate 8.90 Slightly cloudy, colourless, very slight stagnant odour, some sediment, no suspended solids.

SW4 New Admin 7.99 Clear, colourless, odourless, no suspended solids.

* SW5 P4/P7 7.36 Cloudy, colourless, slight stagnant odour, grey mucky sediment, suspended solids.

SW6 MT Lab 7.79 Clear, colourless, odourless, no suspended solids.* SW7 WWTP NS DRY.

20-Jun-12 SW2 West of Gate 8.12 Clear, colourless, odourless, sediment, no suspended solids.SW3 East of Gate 8.85 Very slightly cloudy, colourless, odourless, no suspended solids.SW4 New Admin 7.97 Clear, colourless, odourless, no suspended solids.* SW5 P4/P7 NS DRY.SW6 MT Lab 7.92 Clear, colourless, odourless, no suspended solids.* SW7 WWTP NS DRY.

26-Jun-12 SW2 West of Gate 7.91 Clear, colourless, odourless, sediment & suspended solids present.

SW3 East of Gate 8.41 Clear, colourless, very slight stagnant odour, no suspended solids, no sediment.

SW4 New Admin 7.92 Clear, colourless, odourless, no suspended solids, no sediment.* SW5 P4/P7 7.48 Clear, colourless, odourless, no suspended solids, no sediment.SW6 MT Lab 7.71 Clear, colourless, odourless, no suspended solids, no sediment.* SW7 WWTP 7.60 Cloudy, grey/brown, stagnant odour, sediment & suspended solids present.

AER 2012



04-Jul-12 SW2 West of Gate 7.85 7 <2 Clear, colourless, odourless, sediment & suspended solids present.SW3 East of Gate 8.06 30 3 Clear, colourless, very slight stagnant odour, sediment, vegetation present.SW4 New Admin 7.97 11 <2 Clear, colourless, odourless, no suspended solids.* SW5 P4/P7 7.14 20 10 Clear, colourless, odourless, no suspended solids, vegetation present.SW6 MT Lab 7.68 2 <2 Clear, colourless, odourless, no suspended solids, no sediment.* SW7 WWTP 6.80 270 560 Cloudy, grey/brown, stagnant odour, sediment & suspended solids present.

10-Jul-12 SW2 West of Gate 8.03 Clear, colourless, odourless, no sediment or suspended solids present.SW3 East of Gate 8.67 Clear, colourless, very slight stagnant odour, no sediment or suspended solids.SW4 New Admin 7.91 Clear, colourless, odourless, no suspended solids/sediment.* SW5 P4/P7 7.31 Clear, colourless, odourless, no suspended solids, sediment present.SW6 MT Lab 7.72 Clear, colourless, odourless, no suspended solids, no sediment.* SW7 WWTP 6.36 Cloudy, grey/brown, stagnant odour, sediment & suspended solids present.

18-Jul-12 SW2 West of Gate 7.94 Clear, colourless, odourless, some sediment, no suspended solids present.SW3 East of Gate 8.41 Clear, colourless, odourless, no sediment or suspended solids present.SW4 New Admin 7.89 Clear, colourless, odourless, no sediment or suspended solids present.

* SW5 P4/P7 6.62 Clear, colourless, odourless, very small amount of sediment, no suspended solids present.

SW6 MT Lab 7.77 Cloudy, colourless, odourless, no suspended solids, some sediment.

* SW7 WWTP 6.40 550 Cloudy, brownish , stagnant odour, suspended solids and sediment present (mucky).

25-Jul-12 SW2 West of Gate 7.85 Clear, colourless, odourless, some sediment, no suspended solids present.SW3 East of Gate 8.08 Clear, colourless, odourless, some sediment, no suspended solids present.SW4 New Admin 7.89 Clear, colourless, odourless, no sediment, or suspended solids present.* SW5 P4/P7 8.13 Clear, colourless, odourless, some sediment, no suspended solids present.SW6 MT Lab 7.68 Clear, colourless, odourless, some sediment, no suspended solids present.* SW7 WWTP 7.43 56 Cloudy, colourless, odourless, sediment & suspended solids present.

01-Aug-12 SW2 West of Gate 8.06 11 <2 Clear, colourless, odourless, some sediment, no suspended solids present.

SW3 East of Gate 8.22 35 5 Clear, slight yellow tinge, odourless, some sediment, no suspended solids present.

SW4 New Admin 7.94 20 <2 Clear, colourless, odourless, no sediment, no suspended solids present.

* SW5 P4/P7 6.81 74 32 Slightly cloudy, colourless, slight sweet odour, some sediment & suspended solids.

SW6 MT L b 7 81 UR 2 Cl l l d l di t d d lid tSW6 MT Lab 7.81 UR <2 Clear, colourless, odourless, no sediment, no suspended solids present.

* SW7 WWTP 7.52 30 4 Slightly cloudy, slight yellow tinge, odourless, some sediment , no suspended solids.

08-Aug-12 SW2 West of Gate 8.02 Clear, colourless, odourless, some sediment & suspended solids present.SW3 East of Gate 8.11 Clear, slight yellow tinge, odourless, no sediment, no suspended solids present.SW4 New Admin 7.77 Clear, colourless, odourless, no sediment, no suspended solids present.* SW5 P4/P7 7.17 Cloudy, colourless, slight stagnant odour, some sediment no suspended solids.SW6 MT Lab 7.81 Clear, colourless, odourless, no sediment, no suspended solids present.

* SW7 WWTP 7.26 24 Slightly cloudy, colourless, slight stagnant odour, some sediment ,no suspended solids.

15-Aug-12 SW2 West of Gate 7.57 Clear, colourless, odourless, some sediment & suspended solids present.

SW3 East of Gate 7.95 Clear, slight yellow tinge, odourless, some sediment, no suspended solids present.

SW4 New Admin 7.60 Clear, colourless, odourless, no sediment, no suspended solids present.* SW5 P4/P7 7.23 Clear, colourless, odourless, no sediment, no suspended solids present.SW6 MT Lab 7.58 Clear, colourless, odourless, no sediment, no suspended solids present.

* SW7 WWTP 6.94 86 Slightly cloudy, colourless, slight stagnant odour, some sediment ,no suspended solids.

22-Aug-12 SW2 West of Gate n/a No sample obtained due to low level.SW3 East of Gate 8.03 Clear, slight yellow tinge, odourless, no sediment, no suspended solids present.SW4 New Admin 7.55 Clear, colourless, odourless, no sediment, no suspended solids present.* SW5 P4/P7 7.61 Clear, colourless, odourless, no sediment, no suspended solids present.SW6 MT Lab 7.79 Clear, colourless, odourless, no sediment, no suspended solids present.

* SW7 WWTP 6.56 158 Cloudy, colourless, stagnant odour, large amount of mucky sediment, suspended solids also present.

29-Aug-12 SW2 West of Gate n/a No sample obtained due to low level.SW3 East of Gate 8.44 Clear, colourless, odourless, no sediment, no suspended solids present.SW4 New Admin 7.94 Clear, colourless, odourless, no sediment, no suspended solids present.

* SW5 P4/P7 7.47 Clear, colourless, slight stagnant odour, no sediment, no suspended solids present.

SW6 MT Lab 7.81 Clear, colourless, odourless, no sediment, no suspended solids present.

* SW7 WWTP 6.78 103 Cloudy, colourless, stagnant odour, large amount of mucky sediment, suspended solids also present.

AER 2012



05-Sep-12 SW2 West of Gate NS NS NS No sample obtained due to low level.SW3 East of Gate 7.88 22 4 Clear, colourless, odourless, no sediment, no suspended solids present.SW4 New Admin 7.44 UR <2 Clear, colourless, odourless, no sediment, no suspended solids present.* SW5 P4/P7 6.84 32 34 Cloudy, grey, odourless, mucky sediment and suspended solids present.SW6 MT Lab 8.10 UR <2 Clear, colourless, odourless, no sediment, no suspended solids present.

* SW7 WWTP 7.02 840 315 Cloudy, yellowish, stagnant odour, large amount of mucky sediment, suspended solids also present.

12-Sep-12 SW2 West of Gate NS No sample obtained due to low level.SW3 East of Gate 8.07 Clear, colourless, odourless, no sediment, no suspended solids present.SW4 New Admin 7.90 Clear, colourless, odourless, no sediment, no suspended solids present.

* SW5 P4/P7 7.26 71 Cloudy, colourless, slightly stagnant odour, sediment and suspended solids present, (sediment black in colour).


* SW7 WWTP 7.31 114 Cloudy, colourless, stagnant odour, sediment & suspended solids present, sediment brownish in colour.

18-Sep-12 SW2 West of Gate NS No sample obtained due to low level.SW3 East of Gate 7.72 Clear, colourless, odourless, no sediment, no suspended solids present.SW4 New Admin 7.43 Clear, colourless, odourless, no sediment, no suspended solids present.* SW5 P4/P7 7.58 Cloudy, greyish, diesel like odour, suspended solids and sediment present.SW6 MT Lab 8.15 Clear, colourless, odourless, no sediment, no suspended solids present.* SW7 WWTP 6.74 113 Cloudy, greyish, stagnant odour, suspended solids and sediment present.

27-Sep-12 SW2 West of Gate 7.96 Clear, colourless, odourless, no sediment, no suspended solids present.

SW3 East of Gate 8.55 Very slight yellow colour, clear, odourless, no sediment, no suspended solids present.

SW4 New Admin 7.96 Clear, colourless, odourless, no sediment, no suspended solids present.* SW5 P4/P7 7.39 Clear, colourless, stagnant odour, sediment & suspended solids present.SW6 MT Lab 7.96 Clear, colourless, odourless, no sediment, no suspended solids present.

* SW7 WWTP 6.56 110 Cloudy, greyish, stagnant odour, suspended solids and sediment present (muck/silt settled in bottom of bottle).

03-Oct-12 SW2 West of Gate NS NS NS No sample obtained due to low level.

SW3 East of Gate 8.44 44 4 Clear, slight yellowish colour, odourless, very light sediment and suspended solids present.

SW4 N Ad i 7 97 16 2 Cl l l d l di t d d lid tSW4 New Admin 7.97 16 <2 Clear, colourless, odourless, no sediment, no suspended solids present.* SW5 P4/P7 8.37 14 3 Clear, colourless, odourless, no sediment, no suspended solids present.SW6 MT Lab 8.17 28 Clear, colourless, odourless, no sediment, no suspended solids present.

* SW7 WWTP 6.72 160 132 Slight cloudy, yellowish colour, stagnant odour, suspended solids and sediment present (muck and silt in bottom of bottle).

09-Oct-12 SW2 West of Gate NS No sample obtained due to low level.SW3 East of Gate 8.55 Clear, colourless, odourless, no sediment, no suspended solids present.SW4 New Admin 7.86 Clear, colourless, odourless, no sediment, no suspended solids present.

* SW5 P4/P7 7.44 Cloudy, charcoal colour, odourless, sediment present, suspended solids present.


* SW7 WWTP 6.91 147 Cloudy, charcoal colour, stagnant odour, sediment present, suspended solids present.

17-Oct-12 SW2 West of Gate 7.74 Clear, colourless, odourless, no sediment, no suspended solids present.

SW3 East of Gate 8.17 Clear, slight yellowish tinge, odourless, slight sediment, no suspended solids present.

SW4 New Admin 8.00 Clear, colourless, odourless, no sediment, no suspended solids present.* SW5 P4/P7 7.68 Clear, colourless, odourless, no sediment, no suspended solids present.SW6 MT Lab 7.67 Clear, colourless, odourless, no sediment, no suspended solids present.

* SW7 WWTP 7.24 42 Slight cloudy, colourless, slight stagnant odour, slight sediment, no suspended solids present.

24-Oct-12 SW2 West of Gate NS No sample obtained due to low level.

SW3 East of Gate 8.98 Clear, colourless, very slight stagnant odour, no sediment, no suspended solids present.

SW4 New Admin 8.55 Clear, colourless, odourless, no sediment, no suspended solids present.* SW5 P4/P7 8.04 Clear, colourless, odourless, sediment present, no suspended solids present.SW6 MT Lab 8.24 Clear, colourless, odourless, no sediment, no suspended solids present.

* SW7 WWTP 7.70 65 Clear, colourless, stagnant odour, sediment present, no suspended solids present.

31-Oct-12 SW2 West of Gate NS No sample obtained due to low level.SW3 East of Gate 8.27 Clear, slight yellowish tinge, odourless, no suspended solids / sediment.SW4 New Admin 7.99 Clear, slight yellowish tinge, odourless, no suspended solids / sediment.* SW5 P4/P7 NS No sample obtained as works are ongoing as part of integrity testing.SW6 MT Lab 7.78 Clear, slight yellowish tinge, odourless, no suspended solids / sediment.* SW7 WWTP 7.21 59 Slight cloudy, colourless, slight stagnant, odour, no suspended solids / sediment.

AER 2012



07-Nov-12 SW2 West of Gate NS No sample obtained due to low level.SW3 East of Gate 8.27 36 7 Clear, colourless, odourless, no suspended solids / sediment.SW4 New Admin 8.17 8 <2 Clear, colourless, odourless, no suspended solids / sediment.* SW5 P4/P7 NS No sample obtained due to low level.SW6 MT Lab 7.96 20 3 Clear, colourless, odourless, no suspended solids / sediment.* SW7 WWTP 6.96 110 132 Cloudy, slight yellowish colour, stagnant odour.

13-Nov-12 SW2 West of Gate NS No sample obtained due to low level.SW3 East of Gate 7.97 Clear, slight yellow colour, odourless, no suspended solids / sediment.SW4 New Admin 8.03 Clear, slight yellow colour, odourless, no suspended solids / sediment.* SW5 P4/P7 8.98 Clear, slight yellow colour, odourless, no suspended solids / sediment.SW6 MT Lab 8.16 Clear, slight yellow colour, odourless, no suspended solids / sediment.* SW7 WWTP 7.06 100 Suspended solids & sediment visible, slight stagnant odour.

22-Nov-12 SW2 West of Gate NS No sample obtained due to low level.SW3 East of Gate 8.22 Clear, slight yellowish tinge, odourless, no sediment or suspended solids.SW4 New Admin 8.13 17 Clear, colourless, odourless, no sediment or suspended solids.* SW5 P4/P7 NS No sample (as mechanical equipment being used in area).SW6 MT Lab 8.00 36 14 Clear, colourless, odourless, no sediment or suspended solids.

* SW7 WWTP 7.39 33 Slight cloudy, colourless, slight stagnant odour, sediment and suspended solids visible.

28-Nov-12 SW2 West of Gate NS No sample obtained due to low level.SW3 East of Gate 8.65 Slight cloudy, slight yellowish colour, no sediment or suspended solids.SW4 New Admin 8.08 Clear, colourless, odourless, no sediment or suspended solids.* SW5 P4/P7 8.46 190 Clear, colourless, odourless, no sediment or suspended solids.SW6 MT Lab 7.88 Clear, colourless, odourless, no sediment or suspended solids.* SW7 WWTP 6.93 70 Cloudy, greyish colour, stagnant odour, sediment and suspended solids visible.

05-Dec-12 SW2 West of Gate NS No sample obtained due to low level.SW3 East of Gate 8.32 50 <2 Slightly cloudy, slight brownish colour, no sediment or suspended solids.SW4 New Admin 8.01 10 <2 Clear, colourless, odourless, no sediment or suspended solids.* SW5 P4/P7 7.75 150 31 Cloudy, colourless, odourless, no sediment or suspended solids.SW6 MT Lab 7.99 2 <2 Clear, colourless, odourless, no sediment or suspended solids.

* SW7 WWTP 7.08 103 32 Cloudy, brownish/yellowish colour, stagnant odour, sediment and suspended solids.

12-Dec-12 SW2 West of Gate NS No sample obtained due to low level.

SW3 East of Gate 7.80 Slight cloudy, slight brownish colour, odourless, sediment and suspended solids visible.

SW4 New Admin 7.94 Clear, colourless, odourless, no sediment or suspended solids.* SW5 P4/P7 8.15 Cloudy, colourless, odourless, no sediment or suspended solids.SW6 MT Lab 7.94 Clear, colourless, odourless, no sediment or suspended solids.

* SW7 WWTP 7.09 Cloudy, brownish/yellowish colour, stagnant odour, sediment and suspended solids visible.

17-Dec-12 SW2 West of Gate 8.05 Clear, colourless, odourless, no sediment or suspended solids.SW3 East of Gate 7.66 Clear, yellowish/brownish odourless, no sediment or suspended solids.SW4 New Admin 7.78 Clear, colourless, odourless, no sediment or suspended solids.* SW5 P4/P7 7.72 Slight cloudy, colourless, odourless.SW6 MT Lab 7.84 Clear, colourless, odourless, no sediment or suspended solids.* SW7 WWTP 7.30 Cloudy, greyish, stagnant odour, sediment and suspended solids visible.

Note: UR: Under rangeNS: Not sampled* SW5 P4/P7 is permanently diverted to process drain.* SW7 WWTP was blocked using sandbags in Oct/Nov 2011. A valve was installed in June 2012 and since then collected liquid has been pumped to the WWTP.

AER 2012

Appendix D

Ambient Monitoring

P0014-04 AER 2012


Ward River monitoring

January 04-Jan-12 11-Jan-12 18-Jan-12 25-Jan-12 30-Jan-12

Upstream pH 8.16 8.16 8.24 8.37 8.08

Conductivity (uS/cm) 725 847 877 787 720

COD (mg/L) 15 4 UR 15 27

BOD (mg/L) <2

Tetrahydrofuran (ug/l) <2

Bis (2-Ethylhexyl) Phthalate (ug/l) 24

Downstream pH 8.16 8.22 8.24 8.38 8.12


COD (mg/L) 12 4 UR 12 17

BOD (mg/L) <2

Tetrahydrofuran (ug/l) 2

Bis (2-Ethylhexyl) Phthalate (ug/l) <1

February 08-Feb-12 14-Feb-12 22-Feb-12 28-Feb-12

Upstream pH 8.27 8.09 8.34 8.21

Conductivity (uS/cm) 828 833 873 813

COD (mg/L) 23 4 4 17

BOD (mg/L) <2

Tetrahydrofuran (ug/l) <2 2

Downstream pH 8.31 8.16 8.33 8.17


COD (mg/L) 20 UR 9 UR

BOD (mg/L) <2

Tetrahydrofuran (ug/l) 3 4

March 07-Mar-12 14-Mar-12 21-Mar-12 28-Mar-12

Upstream pH 8.57 8.36 8.28 8.15


COD (mg/L) 8 UR 16 6

BOD (mg/L) <2

Tetrahydrofuran (ug/l) <2 <2

Downstream pH 8.48 8.28 8.25 8.18



BOD (mg/L) <2

Tetrahydrofuran (ug/l) 5 3

P0014-04


April 04-Apr-12 11-Apr-12 18-Apr-12 25-Apr-12

Upstream pH 8.23 8.34 8.14 8.24


COD (mg/L) 10 28 4 14

BOD (mg/L) <2


Acetone (ug/l) 65

Downstream pH 8.25 8.32 8.23 8.28



BOD (mg/L) <2


Acetone (ug/l) 32

May 03-May-12 09-May-12 16-May-12 30-May-12 23-May-12

Upstream pH 8.03 8.31 8.41 8.44


COD (mg/L) 16 11 2 12

BOD (mg/L) <2


Downstream pH 8.04 8.15 8.43 8.37


COD (mg/L) 14 16 UR 8

BOD (mg/L) <2


June 06-Jun-12 13-Jun-12 20-Jun-12 26-Jun-12

Upstream pH 8.36 8.26 8.35 8.23


COD (mg/L) 14 20 9 1

BOD (mg/L) <2


Downstream pH 8.37 8.30 8.34 8.15


COD (mg/L) 13 18 12 4

BOD (mg/L) <2


River samples were not

collected in error, as per

correspondence to the Agency at

the time.

P0014-04


July 04-Jul-12 10-Jul-12 18-Jul-12 25-Jul-12

Upstream pH 8.30 8.26 8.19 8.22


COD (mg/L) 17 9 21 19

BOD (mg/L) <2

Downstream pH 8.29 8.25 8.24 8.24


COD (mg/L) 8 11 9 22

BOD (mg/L) <2

August 01-Aug-12 08-Aug-12 15-Aug-12 22-Aug-12 29-Aug-12

Upstream pH 8.23 8.31 8.01 8.2 8.34


COD (mg/L) 8 14 6 12 21

BOD (mg/L) <2

Chloroform (ug/l) 2

Downstream pH 8.31 8.30 8.03 8.05 8.32

Conductivity (uS/cm) 737 816 736 736 7.23

COD (mg/L) 7 9 12 10 22

BOD (mg/L) <2

Chloroform (ug/l) 0.9

September 05-Sep-12 12-Sep-12 18-Sep-12 27-Sep-12

Upstream pH 7.92 8.20 8.10 7.82


COD (mg/L) UR 23 8 23

BOD (mg/L) <2

Chloroform (ug/l) 0.8

Downstream pH 7.95 8.18 8.03 7.79


COD (mg/L) UR 23 7 27

BOD (mg/L) <2

Chloroform (ug/l) <0.8

P0014-04


October 03-Oct-12 10-Oct-12 17-Oct-12 23-Oct-12 31-Oct-12

Upstream pH 8.25 7.99 7.94 7.49 8.34


COD (mg/L) 12 5 37 5 15

BOD (mg/L) <2

Downstream pH 8.22 8.01 8.02 7.4 8.31


COD (mg/L) 8 3 39 9 16

BOD (mg/L) <2

November 07-Nov-12 14-Nov-12 22-Nov-12 28-Nov-12

Upstream pH 8.20 8.22 8.26 8.22


COD (mg/L) 13 8 20 UR

BOD (mg/L) <2

Methylene chloride (ug/l) 63

Downstream pH 8.20 8.22 8.25 8.21


COD (mg/L) 9 11 4 15

BOD (mg/L) <2

Methylene chloride (ug/l) 6

December 05-Dec-12 12-Dec-12 17-Dec-12

Upstream pH 8.27 8.09 8.36

Conductivity (uS/cm) 841 835 835

COD (mg/L) 13 6 11

BOD (mg/L) <2

Downstream pH 8.25 8.11 8.39

Conductivity (uS/cm) 836 836 833

COD (mg/L) UR 10 9

BOD (mg/L) <2

None of the other analytes in the Volatile Organics, Semi-volatile organics or solvents used in processes were detected above the Method Detection limit.

P0014-04

Groundwater Monitoring Report - 2012

Swords Laboratories, Swords, Co. Dublin

Prepared for

Swords Laboratories Watery Lane Swords Co. Dublin

Prepared by

Geosyntec Consultants Ltd 30-32 Botanic Road Dublin 9

Project Number: GCU0152008

March 2013

00152-008 IPPC Groundwater Report 2012 (final).docx ii 07.03.2013

Project Title: Groundwater Monitoring Report - 2012

Project No: GCU0152008

Report Ref: GCU0152008/Final Report

Status: Final

Client Contact: Muirín Gowen

Client Details: Swords Laboratories Watery Lane Swords Co. Dublin

Issued By: Geosyntec Consultants Ltd.

30-32 Botanic Road

Glasnevin

Dublin 9

Document Production / Approval Record

Name Signature Date Position

Prepared by Graham Webb

7 March 2013

Project Manager

Approved by Jim Wragg

7 March 2013

Project Director

00152-008 IPPC Groundwater Report 2012 (final).docx iii 07.03.2013

LIMITATION

Geosyntec Consultants Ltd. has prepared this Report for the sole use of Swords Laboratories in accordance with the Agreement under which our services were performed. No other warranty, express or implied, is made as to the professional advice included in this Report or any other services provided by us. This Report may not be relied upon by any other party without the prior and express written agreement of Geosyntec Consultants Ltd.

Unless otherwise stated in this Report, the assessments made assume that the site and facilities will continue to be used for their current purpose without significant change. The conclusions and recommendations contained in this Report are based upon information provided by others and upon the assumption that all relevant information has been provided by those parties from whom it has been requested. Information obtained from third parties has not been independently verified by Geosyntec Consultants Ltd, unless otherwise stated in the Report.

COPYRIGHT

© This Report is the copyright of Geosyntec Consultants Ltd. Any unauthorised reproduction or usage by any person other than the addressee is strictly prohibited.

00152-008 IPPC Groundwater Report 2012 (final).docx iv 07.03.2013

TABLE OF CONTENTS

1 INTRODUCTION ........................................................................................................... 1 1.1 GENERAL INTRODUCTION .............................................................................. 1 1.2 BACKGROUND INFORMATION ....................................................................... 1

1.2.1 Site Setting ................................................................................................ 1 1.2.2 Site History ............................................................................................... 1 1.2.3 Geology .................................................................................................... 2 1.2.4 Hydrogeology ........................................................................................... 2 1.2.5 Hydrology ................................................................................................. 3 1.2.6 Potential Pollutant Linkages ..................................................................... 3 1.2.7 Monitoring Well Numbering Scheme ...................................................... 4

1.3 PROJECT OBJECTIVE ......................................................................................... 4 1.4 SCOPE OF WORKS .............................................................................................. 4

2 RESULTS ........................................................................................................................ 5 2.1 FIELD-MEASURED PARAMETERS .................................................................. 5 2.2 LABORATORY RESULTS .................................................................................. 6

2.2.1 Major Ions including Nitrogen Species & COD ....................................... 6 2.2.2 Metabolic Gases ....................................................................................... 7 2.2.3 Volatile Organic Compounds ................................................................... 8 2.2.4 Semi-Volatile Organic Compounds .......................................................... 9

3 SUMMARY, CONCLUSIONS AND RECOMMENDATIONS .................................... 9

LIST OF TABLES

Table 1: Well Renumbering System

Table 2: Inorganic Parameters in Groundwater

Table 3: Volatile Organics in Groundwater

LIST OF FIGURES

Figure 1: Site Layout

Figure 2: Shallow Groundwater Contour Plan

LIST OF APPENDICES

Appendix A: Time-Series Plots of COPC Concentrations in Groundwater

Appendix B: Borehole Logs

Appendix C: Laboratory Reports (on CD)

00152-008 IPPC Groundwater Report 2012 (final).docx 1 07.03.2013

1 INTRODUCTION

1.1 GENERAL INTRODUCTION

Geosyntec Consultants Ltd (Geosyntec) was retained by Swords Laboratories to undertake the site’s groundwater monitoring programme during 2012 and to produce this groundwater monitoring report. The work was completed in accordance with Geosyntec’s proposal reference 111203 dated December 2011.

The requirements of the groundwater monitoring programme are specified in Schedule C.6 of the site’s Integrated Pollution Prevention & Control (IPPC) Licence number P0014-04. This requires the monitoring of groundwater from a network of 18 on-site groundwater monitoring wells on a quarterly basis.

This report summarises the results and findings from all four monitoring rounds completed during 2012.

The 2012 monitoring programme was led by Graham Webb, who has approximately 20 years’ experience in contaminated land and groundwater assessment and remediation. The site work was completed by Patrick Breheny, a hydrogeologist based in Geosyntec’s Dublin office. The groundwater samples were analysed by Chemex Environmental in Cambridge, UK.

1.2 BACKGROUND INFORMATION

1.2.1 Site Setting

The site is located in a semi-urban setting approximately 300 metres north of Swords town centre (Figure 1). The facility is mainly occupied by production plant and associated buildings and infrastructure. Ground surfaces are generally covered by concrete or asphalt. There are a number of small landscaped areas adjacent to the administrative buildings in the northern part of the site and in some other peripheral areas of the facility. The site layout and current groundwater monitoring well network is illustrated by Figure 2.

Surrounding land use includes residential, commercial and recreational properties. The site is bounded by the Ward River to the east, with an area of public parkland beyond. To the north and northwest it is bounded by Watery Lane and commercial properties beyond. To the west and southwest is generally residential land. South of the site, and immediately adjacent to it there is a neighbouring industrial facility, the former Arch Chemicals facility that is now owned and operated by Lonza.

Ground elevations across the site range from approximately 11.6 m (north-eastern corner) to 17.7 m (south-western perimeter) above Ordnance Datum (AOD) with a moderate east and northeast topographic gradient towards the Ward River.

1.2.2 Site History

The facility commenced operations producing pharmaceutical products in 1964. An Integrated Pollution Control (IPC) licence was first issued to Swords Laboratories by the Environmental Protection Agency (the Agency) in December 1995. The current Integrated Pollution and Prevention Control (IPPC) licence (register number P0014-04) was issued in September 2007.


1.2.3 Geology

The site is underlain by Lower Carboniferous bedrock, specifically the Malahide Limestone Formation, which in the Swords area is fine-grained, thinly to coarsely-bedded and cherty. Observations from cores recovered during recent investigations and of outcrops of this formation within the bed of the Ward River show this unit to be thinly to medium-bedded (~100-300mm) with jointing and/or fracturing.

Borehole records for the current and past investigations at the site indicate a weathered zone of limestone at the interface with the overlying Quaternary deposits at some borehole locations. This has been observed as angular gravel and cobbles grading to thinly-bedded more competent bedrock. There was also evidence of some clay matrix within the gravel/cobble band and clayey infilling of wider bedding plane features from the unconsolidated soil and rock cores recovered during this investigation. The competent bedrock has closely-to-widely spaced fractures, occasional thin marly bands and locally, fault zones with breccia in a clayey and silty matrix. Rock cores and exposures in the Ward River bed indicate a shallow 10-20o bedrock dip in a northerly direction.

Depth to bedrock across the site has been observed to vary between approximately 1.9 m and 5.5 m, with a typical depth to bedrock of 3 – 4 metres.

Glacial till has been observed overlying the limestone bedrock across the majority of the site. This has been described as ranging from silty clay to sandy gravel. Whilst the silty clay descriptions predominate for the majority of the site area, sandy and gravelly zones have been observed and appear to be particularly prevalent in the area to the north of the P5 production building.

The glacial till is typically overlain by a variable thickness of Made Ground, which is frequently composed of reworked glacial till. In the vicinity of the P2 tank farm and Solvent Recovery Unit tank farm, Made Ground has been encountered in the majority of the boreholes installed in this area. It typically comprises concrete or asphalt pavement underlain by layers of clayey and gravelly fill material. Where the fill material extends below 2m depth it was observed to be predominantly granular. The base of this coarse granular fill was observed to extend to depths of up to 4.8m and locally directly overlaid the bedrock.

1.2.4 Hydrogeology

Groundwater is typically encountered in both in the shallow Made Ground/overburden and in the underlying bedrock at depths ranging from about 0.2m to 2 m below ground level (bgl).

The inferred lateral groundwater flow direction based on measured groundwater elevations is generally north-easterly in the overburden, tending more easterly close to the Ward River (eastern site boundary).

The bedrock aquifer beneath the site is classified by the Geological Survey of Ireland (GSI) as ‘Locally Important - moderately productive only in local zones’. On a regional scale, the groundwater is assumed to flow generally in an east-north-easterly direction towards the Broad Meadow Estuary.


The weathered limestone is thought to be a significant horizon for groundwater flow where this is developed. As would be expected the granular fill and granular glacial till strata appear to be reasonably conductive to groundwater flow whereas the cohesive fill and cohesive drift deposits are indicated to have permeability one or two orders of magnitude less than the granular drift and weathered limestone respectively. Hydraulic conductivity values for the un-weathered bedrock indicate that below the weathered horizon the bedrock groundwater flux is likely to be relatively modest.

The low to moderate permeability and thickness glacial till are likely to retard both lateral contaminant migration within the shallow soils, and also retard downward movement to the limestone bedrock. However, preferential pathways may exist locally via natural gravel lenses and man-made gravel backfill material which extend close to, or possibly directly overlie the bedrock. There are also in-ground structures such as tank farm vaults/shallow groundwater containment barriers, which affect shallow groundwater flow in some sections of the site. The weathered bedrock horizon may also act as a sink for shallow groundwater discharge from the site.

1.2.5 Hydrology

The Ward River lies approximately 5-10 m from the eastern site boundary and flows towards the north. The elevation of the river bed varies from 11.0 mAOD near the southern end of the site and 8.1 mAOD at the northern end. As such, the river bed is approximately three metres below the elevation of the site at its eastern boundary. Shallow groundwater has been observed seeping into the Ward River from the upper bedrock surface at around four locations adjacent to the site. As described above, there is also expected to be an element of base flow from the bedrock to the river.

The Ward River has a relatively low flow and is not tidal in the vicinity of the site. Previous reports estimated an average flow rate of approximately 40,000m3/day (0.5m3/s) in the vicinity of the site. The confluence of the Ward River with the Broad Meadow River is approximately 1.5 km to the north/northeast of the site (at Balheary). From there, the combined river flows east into Broad Meadow Estuary and the Irish Sea.

1.2.6 Potential Pollutant Linkages

Past investigations and monitoring events have identified groundwater impact by a number of organic compounds at the site, including tetrahydrofuran (THF), methyl-tert-butyl ether (MTBE), dichloromethane (DCM), BTEX compounds (benzene, toluene, ethyl benzene and xylenes) and a suite of ketones and alcohols. Prior to 2011, the primary area of potential concern in relation to the observed groundwater impact was in the vicinity of the P2 tank farm.

Investigations completed by Geosyntec (at the time as Ford Consulting Group) during 20111 and 20122 found additional potential source areas of groundwater impact in the vicinity of the P5 production building and the former location of solvent recovery

1 Ford Consulting Group, March 2011; Subsurface Assessment - Installation and Sampling of Additional Monitoring Wells, Swords Laboratories, Watery Lane, Swords, Co. Dublin 2 Ford Consulting Group, August 2012; Delineation Investigations and Revised Risk Assessment, Swords Laboratories, Watery Lane, Swords, Co. Dublin


operations (in both cases linked to historical site operations) where remedial action was found to be necessary.

The primary Compounds of Potential Concern (COPCs) in these two areas are DCM, MTBE and tert butyl alcohol (TBA – a natural breakdown product of MTBE). The primary receptor potentially at risk of impact from COPCs in these two areas is considered to be the Ward River although the remedial criteria developed for the site have also considered impacts to deep groundwater quality in the wider area. Remedial action is scheduled to commence in both these areas during March 2013. A monitoring-based strategy has been recommended for the P2 tank farm area. A further potential source area identified at the site relates to previous losses from an effluent sump adjacent to the P4 production building. The primary compounds of potential concern in this area are THF and TBA. A hydraulic containment system has been installed and operated in this area since July 2012.

2-Chloropyridine is also present in groundwater in some areas of the site; however 2-chloropyridine has never been used at the site and it is thought to be migrating onto the site from an adjacent facility operated by Lonza. As such, it is not considered a COPC from the site’s perspective.

1.2.7 Monitoring Well Numbering Scheme

The locations of the 18 groundwater monitoring wells included in the 2012 monitoring round are shown in Figure 1. A new well numbering system was adopted at the site during 2012. The primary aim of this change was to give a unique identification number for each well location and to indicate the depth of each individual well at that location by a suffix:

• “S” for shallow wells (generally 4 – 6m deep, installed within the drift/weathered bedrock),

• “I” for intermediate depth wells (generally 9 – 12m deep, installed within the shallow bedrock),

• “D” for wells greater than 15m deep installed within the bedrock

Table 1 shows both the old numbering system (i.e. the numbering system quoted in the IPPC licence) and the new numbering system for the 18 IPPC wells.

1.3 PROJECT OBJECTIVE

The objectives of the 2012 groundwater monitoring programme were to satisfy the requirements of the site’s IPPC licence with regard to groundwater monitoring and to prepare a groundwater monitoring report for inclusion in the site’s Annual Environmental Report.

1.4 SCOPE OF WORKS

The scope of works undertaken to fulfil the project objectives can be summarised as follows:


• The inspection, purging and sampling of the 18 wells included in the IPPC groundwater monitoring network (refer Table 1). Prior to purging, water level measurements were taken in all wells; during purging wellhead parameters including pH and electrical conductivity were measured. The wells were purged and samples collected using sampling tubing dedicated to each well, a battery-powered peristaltic pump and a flow-through cell. Samples collected for metals/metalloids were filtered at the time of collection and preserved with dilute nitric acid;

• The collected samples were packed in cool boxes and were sent by overnight courier to the subcontracted laboratory accompanied by chain-of-custody documentation. In all cases, the samples were received at the laboratory within the recommended holding times and temperatures;

• Contract laboratory analysis of groundwater samples by Chemex Environmental, Cambridge, UK for a volatile organic compound (VOC) suite and a semi-volatile organic compound (SVOC) suite (in both cases including analysis for specific organic compounds used in site processes), an alcohols suite, major anions and cations, total nitrogen, and a dissolved trace metal and metalloid suite. Ammoniacal nitrogen and Chemical Oxygen Demand (COD) analyses were completed on-site by the EHS department laboratory;

• Preparation of this report on the main findings of the 2012 groundwater monitoring round.

The samples were collected on the following dates:

• Q1: 14th- 16th February 2012

• Q2: 2nd – 4th April 2012 (completed early in the quarter to coincide with other sampling taking place on site)

• Q3: 8th – 9th August 2012

• Q4: 13th – 15th November 2012

2 RESULTS

2.1 FIELD-MEASURED PARAMETERS

Measured water elevations in the monitoring wells were generally consistent with past monitoring events, with the inferred lateral groundwater flow direction being generally north-easterly in the overburden, tending more easterly close to the Ward River (eastern site boundary).

Measurements of wellhead parameters are summarised in the following:

• pH readings were mostly in the range 7 – 8 and were generally consistent over the four monitoring events. pH readings in monitoring well AGW20-S (formerly GW13) were higher, ranging between 9.2 and 10.9 over the four monitoring events. The source of the high pH in this well is not clear. The pH readings, including those from AGW20-S, were broadly consistent with measurements taken prior to 2012 by BMS.


• Electrical conductivity (EC) readings were higher than the Agency’s draft IGV of 1000 μS/cm in a number of wells over the monitoring period, with a maximum of 6,200μS/cm recorded in AGW14-S in Q2. EC readings in this well were in the approximate range 3,800-4900 μS/cm in Q1, Q3 and Q4. EC readings in 7 – 8 of the 18 wells exceeded the IGV in Q1, Q2 and Q3; the results from each well were quite variable between monitoring events, and the locations where the exceedences were recorded changed from quarter to quarter. In Q4, 14 of the 18 EC readings exceeded the IGV; this included up-gradient wells, where EC readings of 1,100-1,300 μS/cm were recorded.

• Redox potential readings and dissolved oxygen readings were generally low, indicating reduced groundwater conditions across much of the site. Redox potential was generally negative, with readings as low as -230 mV recorded (AGW20-I, Q3). Redox readings in the P2 tank farm area were typically in the range -140 mV to -150mV. Low redox potential was also recorded in down-gradient wells in the northern area of the site (AGW09-S and AGW28-S). Slightly positive redox readings were recorded in up-gradient well AGW01-S and well AGW03-S, located north-west (across-gradient) of the production areas. Reducing groundwater chemistry and elevated electrical conductivity values, such as those seen in the wells located in the vicinity of the P2 tanks farm (AGW14-S for example), are likely to be related. Reduced groundwater chemistries in this area are believed to reflect on-going microbial degradation of organic compounds present in the groundwater in this area and the associated use of electron acceptors (dissolved oxygen, nitrate, sulphate etc). Iron and manganese present in the aquifer matrix are also reduced by these processes to form soluble salts and this frequently leads to significant rises in the electrical conductivity of the groundwater.

• Dissolved oxygen readings were generally in the range 0.4 – 2 mg/l and were relatively consistent across the four monitoring events, with most readings below 1 mg/l indicating relatively anaerobic conditions in groundwater at the site. Again this is consistent with the degradation of organic compounds in groundwater at the site. Dissolved oxygen is the most energetically efficient electron acceptor and is used preferentially by microbes in degrading hydrocarbons such as the BTEX detected in the vicinity of the P2 tank farm.

2.2 LABORATORY RESULTS

The laboratory results are summarised in Table 2 (inorganic parameters and metabolic gases) and Table 3 (VOCs and SVOCs). Discussion of the results is provided in the following sections.

2.2.1 Major Ions including Nitrogen Species & COD

The groundwater samples were analysed for chloride, fluoride and sulphate as well as nitrate, nitrite and kjeldahl nitrogen.


Chloride concentrations were elevated in most of the wells in and around the P2 tank farm area, with concentrations generally above the Groundwater Threshold Value3 (GTV) of 187.5 mg/l. The highest concentrations were generally observed in AGW14-S (results ranged from 831 – 1600 mg/l over the four monitoring events in this well). The presence of elevated chloride concentrations in groundwater at the site tend to correlate closely to areas where DCM has been detected. Previous investigations have demonstrated substantial microbial degradation of DCM in the site groundwater to liberate chloride.

Fluoride concentrations in all of the groundwater samples collected during the four monitoring rounds were below the IGV of 1 mg/l.

Similarly, sulphate concentrations in all of the groundwater samples collected during the four monitoring rounds were below both the IGV of 200 mg/l and the GTV of 187.5 mg/l.

With regard to nitrogen species, total nitrogen concentrations in most wells over the monitoring period were <10mg/l, with generally low or non-detect nitrate, nitrite and kjeldahl nitrogen. Where higher total nitrogen concentrations were reported, these were generally as a result of elevated kjeldahl nitrogen being present. Kjeldahl nitrogen concentrations were generally highest (ranging from about 20 - 50 mg/l over the monitoring period) in wells AGW12-S, AGW14-S and AGW15-S in the P2 tank farm area. Kjeldahl nitrogen is the sum of organic nitrogen, ammonia and ammonium in the sample. The presence of these reduced species in the P2 tank farm area groundwater is consistent with the processes of microbially mediated organic compound degradation described above where nitrate is progressively reduced to nitrite and ammoniacal nitrogen by acting as an electron acceptor.

COD results are included here as they follow a similar pattern to the major ions results. Elevated COD (generally in the range 30 - 80 mg/l over the monitoring period) was reported in wells AGW11-S, AGW12-S, AGW14-S, AGW15-S and AGW16-S, all located in the P2 tank farm area. Elevated COD in this area again reflects the reduced nature of the groundwater resulting from microbially mediated organic compound degradation.

There was marked variation in concentrations of inorganic parameters between monitoring events; however, no clear seasonal effect or other temporal trend was evident in the reported results.

2.2.2 Metabolic Gases

The groundwater samples were analysed for methane, ethane, ethene and carbon dioxide. These parameters were included in the monitoring programme to assess whether the processes of in-situ biodegradation of organic compounds in groundwater were active in key parts of the site.

Elevated methane and carbon dioxide was observed AGW11-S, AGW12-S, AGW14-S, AGW15-S and AGW16-S, all located in the P2 tank farm area indicating that in-situ biodegradation processes were active in this area of the site. Methane concentrations were typically in the range 10 – 20 mg/l in these wells, with carbon

3 SI No. 9, 2010; European Communities Environmental Objectives (Groundwater) Regulations.


dioxide concentrations in the typical range 200 – 300 mg/l. Ethane and ethene were not detected in most samples; however they were detected at trace concentrations in a very small number of samples.

2.2.3 Volatile Organic Compounds

Consistent with previous years, elevated concentrations of a number of VOCs were reported in groundwater samples collected from the P2 tank farm area. The compounds detected at highest concentration in the P2 tank farm area during 2012 were THF, m&p-xylene and ethylbenzene, with lower (<1 mg/l) concentrations of benzene, toluene, o-xylene and MTBE also being present in some wells in this area of the site. Graphs showing concentrations over time for these compounds are included in Appendix A.

Generally concentrations of these compounds in the P2 tank farm area appear to be stable or declining; however some exceptions were noted during 2012, as follows:

• Concentrations of m&p-xylene in AGW16-S (formerly GW05) have been fluctuating over the past two years in the range 5 – 10 mg/l, with relatively high concentrations recorded in Q2 2011, Q2 2012 and Q3 2012. Ethyl benzene has been fluctuating over the same period in this well between about 1 – 2 mg/l, with a result of 2.7 mg/l recorded for Q3 2012. The reasons for the observed concentration fluctuations are unclear. A possible explanation for this relates to temporal changes in the shallow groundwater flow direction in this area (noted during earlier investigations in this area) that may reflect preferential recharge following prolonged periods of rainfall. The increases seen in AGW16-S may have been related to construction work in the area immediately up-gradient of this well, which may have mobilized residual soil contamination in the area.

• In Q4 2012, the reported concentrations of both ethylbenzene and m&p-xylene in well AGW16-S were below the detection limit. The reasons for this rapid decline are also not clear; however, the decreases may be linked to the completion of ground works on the up-gradient construction project mentioned above. Alternatively they may be related to interference from the pilot scale product recovery trials being undertaken in the vicinity of the P5 building to the north that preceded this monitoring event.

• In recent years, THF has been detected in the mg/l range in wells AGW11-S, AGW12-S and AGW15-S. A relatively high THF result of 17 mg/l was reported for well AGW15-S in Q1 2012; however THF concentrations in this well have declined at an approximately linear rate since then; the latest result (Q4 2012) was about 3 mg/l.

Reported VOC concentrations in monitoring wells located in areas remote from the P2 tank farm were generally below detection, although trace concentrations (typically <20 μg/l) of diethyl ether and MTBE were detected in a number of wells located in northern areas of the site, and generally down-gradient of the site’s production buildings, including AGW07-S, AGW09-S and AGW28-S.

As outlined earlier, 2-chloropyridine is a compound used on the adjacent Lonza site that has been observed in groundwater on the Swords site in recent years. This compound is not used on the Swords site, nor has it been used on the site in the past.


During 2012, 2-chloropyridine was detected consistently (i.e. in at least three of the four sampling events) only in wells AGW20-S and AGW20-I. The highest reported concentration was 1 mg/l in AGW20-I in Q4 2012.

2.2.4 Semi-Volatile Organic Compounds

Consistent with monitoring results from past years, SVOCs were generally not detected in groundwater during the 2012 monitoring programme. The only wells where standard suite SVOCs were detected during 2012 were AGW15-S and AGW16-S, both located in the P2 tank farm area. The compounds detected are summarised in the following:

• In AGW15-S, acenaphthalene (Q3 & Q4) and naphthalene (Q2, Q3 & Q4) were detected at trace concentration (<10μg/l in all cases)

• In AGW16-S, 2,4-dimethylphenol was detected at 36 μg/l and phenol was detected at 11 μg/l (Q2 only in both cases)

A scan for tentatively identified compounds (TICs) was completed on all samples and from this analysis an additional compound, 3-trifluoromethylbenzenamine, was detected consistently in four wells within the P2 tank farm area. This compound was detected at highest concentration in AGW12-S (up to 1.1 mg/l in Q2) and at lower concentrations (<0.2 mg/l) in adjacent wells AGW11-S, AGW14-S and AGW16-S. This compound is thought to be related to a past process at the facility. The results indicate the presence of a relatively localised area of shallow soil contamination by this compound centered around AGW12-S. This compound was not detected in wells down-gradient of the P2 tank farm area during the delineation investigations completed by Geosyntec during 2011/2012.

3 SUMMARY, CONCLUSIONS AND RECOMMENDATIONS

The results of the 2012 groundwater monitoring programme were generally consistent with the results from recent years’ monitoring programmes, confirming the presence of groundwater impact by a number of organic compounds in the P2 tank farm area. The compounds present in shallow groundwater in this area of the site include THF, MTBE, DCM and BTEX compounds. Generally concentrations of COPCs in the P2 tank farm area appear to be stable or declining, although there have been marked fluctuation in concentrations of some compounds in some wells over the past 12 months (refer to time-series graphs in Appendix A). Possible reasons for this relate to temporal changes in the shallow groundwater flow direction in this area (noted during earlier investigations in this area) that may reflect preferential recharge following prolonged periods of rainfall. Other variables may include the effect of recent remedial trials (product recovery beneath the P5 Building) and possibly mobilisation of residual soil contamination during recent construction works near the P2 Tank Farm area.

Groundwater is in a reduced state across much of the site, with low redox potential and low dissolved oxygen concentrations. In the P2 tank farm area, there is evidence that in-situ biodegradation of COPCs is occurring, with relatively elevated


concentrations of dissolved iron, manganese, ammonia, methane and carbon dioxide present in groundwater.

A risk assessment completed by URS in 2010 found that compounds present in groundwater in the P2 tank farm area posed a potential risk to water quality in the Ward River, and this led to a remedial options assessment and a remedial treatability study being completed for this area of the site during late 2010/2011.

Subsequent to this, Geosyntec (formerly Ford Consulting Group) completed additional site-wide investigations during 2011 and 2012 which included collection of groundwater quality data from new monitoring wells in the area between the P2 tank farm area and the Ward River, as well as in other areas of the site. Data from these wells was used to refine the Conceptual Site Model and to update the risk assessment for the P2 tank farm. It was found from these studies that concentrations of COPCs were attenuating rapidly down-gradient of the P2 tank farm, to the extent that remedial action in the P2 tank farm area was not deemed to be necessary. The studies also identified three other areas of the site where remedial action was found to be necessary and which are the subject of a corrective action plan.

With the benefit of the refined CSM developed as part of the 2011/2012 site assessments, and given the greatly increased number of groundwater monitoring wells at the site, Geosyntec reviewed the current IPPC groundwater monitoring network during late 2012 and submitted a proposal to Swords to improve its design4. Key programme objectives that were considered in the proposed revision to the groundwater monitoring programme were as follows:

• Monitoring groundwater quality down-gradient of potential source areas where the need for corrective action has been identified. Wells were selected primarily to monitor the progress of the corrective action programmes in these areas. This monitoring work will seek to assess if COPCs in the overburden continue to be attenuated and also to assist in demonstrating improvements in groundwater quality in the shallow bedrock related to the corrective action programme.

• Monitoring groundwater quality down-gradient of other potential source areas (e.g. production buildings, tank farms, storage areas). Wells were selected primarily to confirm that substances used in site processes are not impacting groundwater quality in these areas.

The proposal included recommendations to refine the analytical schedule, specifically to limit the monitoring of SVOCs to wells in the vicinity of the P2 tank farm and to remove total nitrogen and indicators of natural attenuation from the monitoring programme.

The proposal to change the groundwater monitoring network and adjust the analytical schedule was accepted by the Agency in early March 2013, with some conditions. The Agency’s conditions included adding four specific “deep” wells in the monitoring network.

4 Geosyntec letter to Swords Laboratories dated 12 December 2012, reference GCU0152008

TABLES

TABLE 1 - WELL RENUMBERING SYSTEM

00152-008 August 2012

Current Name Proposed Name Proposed Name Current NameGW01 AGW01-S AGW01-S GW01GW02 AGW03-S AGW01-I GW10GW03 AGW07-S AGW03-S GW02GW04 AGW09-S AGW06-S GW15GW05 AGW16-S AGW06-I GW16GW06 AGW28-S AGW07-S GW03

GW07A AGW11-S AGW09-S GW04GW07B AGW12-S AGW10-S GW09GW07C AGW14-S AGW10-I GW14GW07D AGW15-S AGW11-S GW07AGW09 AGW10-S AGW12-S GW07BGW10 AGW01-I AGW14-S GW07CGW11 AGW18-I AGW15-S GW07DGW12 AGW20-I AGW16-S GW05GW13 AGW20-S AGW18-I GW11GW14 AGW10-I AGW20-S GW13GW15 AGW06-S AGW20-I GW12GW16 AGW06-I AGW28-S GW06

TABLE 2 - INORGANIC PARAMETERS IN GROUNDWATER

00152-008 Oct 2012

Q4 2012

pH Ammonia mg/l COD mg/l Chloride mg/lConductivity

uS/cmFluoride mg/l Nitrate (as N) mg/l

Nitrite (as N) mg/l

Kjeldahl Nitrogen (as N)

mg/l

Total Nitrogen mg/l

EPA IGV 6.5 - 9.5 0.15 nc 30 1000 1 nc nc

GW Threshold Values

187.5Conversion

factor=0.2258Conversion

factor=0.3043

MDL 0.05 0.02 1.5 5 5Former Well ID New Well ID

1 AGW01-S 7.04 0.01 3 27 1223 0.05 7.67 - 7.32 AGW03-S 7.56 0.01 6 286 1192 0.13 - - 8.43 AGW07-S 7.63 0.03 10 110 878 0.26 - - -4 AGW09-S 7.3 0.29 0 90.7 1089 0.48 - - 30.05 AGW16-S 7.11 11.30 41 0 1714 - - - -6 AGW28-S 7.82 0.61 17 41 922 0.29 - - 8.4

7A AGW11-S 7.1 14.30 41 224 1316 0.30 - - 14.07B AGW12-S 7.04 46.00 53 347 1642 0.25 - - 26.07C AGW14-S 6.88 45.50 56 1014 3834 - - - 29.07D AGW15-S 7.09 33.90 30 568 1768 0.23 - - 22.09 AGW10-S 7.4 0.04 9 56 1083 0.08 - - 5.6

10 AGW01-I 7.57 0.07 1 42 1348 0.28 - - -11 AGW18-I 8.06 0.16 5 9 674 0.31 0.3 - 35.012 AGW20-I 7.8 5.14 26 145 1380 0.08 - - 10.013 AGW20-S 10.04 2.04 23 95 1241 - - - 11.014 AGW10-I 7.9 0.01 20 103 1293 0.07 3.78 - 8.415 AGW06-S 7.89 0.01 26 427 2299 0.36 - - 7.816 AGW06-I 7.45 0.09 8 39.4 916 0.26 - - 9.5

KEY

467 = above IGV/GTV

nr = not recorded

TABLE 2 - INORGANIC PARAMETERS IN GROUNDWATER

00152-008 Oct 2012

Q4 2012

EPA IGV

GW Threshold Values

MDLFormer Well ID New Well ID

1 AGW01-S2 AGW03-S3 AGW07-S4 AGW09-S5 AGW16-S6 AGW28-S

7A AGW11-S7B AGW12-S7C AGW14-S7D AGW15-S9 AGW10-S

10 AGW01-I11 AGW18-I12 AGW20-I13 AGW20-S14 AGW10-I15 AGW06-S16 AGW06-I

KEY

467 = above IGV/GTV

nr = not recorded

Methane mg/l Ethene mg/l Ethane mg/l CO2 mg/l Sulphate mg/l Iron ug/lManganese

ug/l

LNAPL / DNAPL Yes/No

Dissolved Oxygen (mg/L)

ORP (mV)

nc nc nc nc 200 200 50

187.5 18.75

1.3 15 2

- - - 193.0 138.0 - 8 no 0.58 53.90.002 - - 116.0 39.2 - 581 no nr 2170.056 - - 163.0 57.0 532 1100 no nr 2400.111 - - 122.0 71.6 2910 1020 no 0.78 -121.77.800 - - 160.0 299.0 11500 2270 no 0.32 -144.24.100 - - 108.0 39.1 3880 546 no 0.66 -177.7

11.300 0.040 0.080 217.0 118.0 9400 1080 no 0.42 -10415.600 - - 278.0 509.0 36600 3220 no 0.34 -142.218.200 - - 316.0 329.0 45200 3360 no 0.39 -145.620.500 - - 221.0 98.6 6130 1320 no 0.86 -122.70.281 - - 143.0 87.4 1120 738 no 0.88 -76.90.007 - - 178.0 77.5 - 29 no 2 35.30.553 - - 31.0 56.3 - 243 no 0.39 -66.11.120 - - 89.6 211.0 74 188 no 0.78 -106

27.900 - - 22.8 285.0 - 29 no 0.45 -178.60.011 - - 106.0 92.6 - 20 no 1.39 15.80.152 - - 138.0 125.0 - 4 no 0.43 -47.50.082 - - 134.0 30.7 155 235 no 0.65 -64.5

TABLE 3 - ORGANIC PARAMETERS IN GROUNDWATER

00152-008 Oct 2012

New Well Reference AGW01-S AGW01-S AGW01-S AGW01-S AGW01-S AGW01-S AGW01-S AGW01-S AGW01-S AGW01-S AGW01-S AGW01-S AGW01-S AGW01-S AGW01-S AGW01-S

Former Well Reference GW 1 GW 1 GW 1 GW 1 GW 1 GW 1 GW 1 GW 1 GW 1 GW 1 GW 1 GW 1 GW 1 GW 1 GW 1 GW 1

LOD (μg/L) IGV (μg/L) GTV (μg/L) Q1 2009 Q2 2009 Q3 2009 Q4 2009 Q1 2010 Q2 2010 Q3 2010 Q4 2010 Q1 2011 Q2 2011 Q3 2011 Q4 2011 Q1 2012 Q2 2012 Q3 2012 Q4 2012

Scaling Factor 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

1,2-Dichloroethane 1 3 2.251,2-Dichloropropane 11-Chlorobutane 14-Methyl-2-pentanone MIBK 5Acetone 10 17Benzene 1 1 0.75Bromoform 1 24.66Bromomethane 1Carbon disulfide 1Chloroform 1 12Diethyl ether 2Ethyl benzene 1 10m&p-Xylene 2 10Methylene chloride 2o-Xylene 1 10Tert-methyl-butyl ether 1Tetrahydrofuran 10Toluene 1 10Trichloroethene 1 7.5Vinyl chloride 1 0.375

Non-purgeable organics & non-target compounds2-Chloropyridine 50Cyclohexane 10Acetonitrile 500TEA 500i-propanol 250Ethyl-Acetate 250Methanol 1000n-butanol 250Pyridine 1000Triethylsilane 5DMF 1000

NOTE: FOR PURGEABLE ORGANICS, BLANK CELL = NOT DETECTED ABOVE LOD * SCALING FACTOR


00152-008 Oct 2012

New Well Reference

Former Well Reference

LOD (μg/L) IGV (μg/L) GTV (μg/L)

Scaling Factor

1,2-Dichloroethane 1 3 2.251,2-Dichloropropane 11-Chlorobutane 14-Methyl-2-pentanone MIBK 5Acetone 10Benzene 1 1 0.75Bromoform 1Bromomethane 1Carbon disulfide 1Chloroform 1 12Diethyl ether 2Ethyl benzene 1 10m&p-Xylene 2 10Methylene chloride 2o-Xylene 1 10Tert-methyl-butyl ether 1Tetrahydrofuran 10Toluene 1 10Trichloroethene 1 7.5Vinyl chloride 1 0.375



AGW03-S AGW03-S AGW03-S AGW03-S AGW03-S AGW03-S AGW03-S AGW03-S AGW03-S AGW03-S AGW03-S AGW03-S AGW03-S AGW03-S AGW03-S AGW03-S

GW 2 GW 2 GW 2 GW 2 GW2 GW2 GW2 GW2 GW2 GW 2 GW 2 GW 2 GW2 GW 2 GW 2 GW 2

Q1 2009 Q2 2009 Q3 2009 Q4 2009 Q1 2010 Q2 2010 Q3 2010 Q4 2010 Q1 2011 Q2 2011 Q3 2011 Q4 2011 Q1 2012 Q2 2012 Q3 2012 Q4 2012

1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

18 11 11

3

2 1 1 1 1 4 34


00152-008 Oct 2012

New Well Reference



Scaling Factor




AGW-07-S AGW-07-S AGW-07-S AGW-07-S AGW07-S AGW07-S AGW07-S AGW07-S AGW07-S AGW07-S AGW07-S AGW07-S AGW07-S AGW07-S AGW07-S AGW07-S

GW 3 GW 3 GW 3 GW 3 GW3 GW 3 GW 3 GW 3 GW 3 GW3 GW 3 GW 3 GW 3 GW3 GW 3 GW 3


1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

69

1

3 4 5 4 8 6 6 6 5 9 18 14 6 5 8 2

7

3 3 5 6 7 7 6 6 5 5 9 10 6 4 6 4

82

1000


00152-008 Oct 2012

New Well Reference



Scaling Factor







1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

6 10 6 5 6 4 4 6 3 4 4 4 3 3 2 6

35 40 23 18 22 17 16 21 12 15 14 13 12 20 1338 10

1300


00152-008 Oct 2012

New Well Reference



Scaling Factor





GW 5 GW 5 GW 5 GW 5 GW5 GW5 GW5 GW5 GW5 GW 5 GW 5 GW5 GW5 GW 5 GW 5 GW5


166.7 82.5 82.5 50.0 50.0 62.5 62.5 62.5 50.0 50.0 50.0 50.0 100.0 100.0 100.0 1.0

1400710

120 68 89 120 93 180 180 170 130 170 210 430 0490

990 600 1000 1300 1500 1100 1700 1600 1200 990 1800 1800 2700 07700 7600 3800 5200 7600 8000 5700 7100 9300 6500 5000 8500 10000 17000 0

130490 250 450 380 320 160 980 590 190 380 830 650 0 0

3 91 76 72 66 110 9941 550 390 460 290 6

11000 9100 370 510 110 110 88 590 51

2600 41000

12000

16002600 2000

14.2 2300


00152-008 Oct 2012

New Well Reference



Scaling Factor





GW 6 GW 6 GW 6 GW 6 GW6 GW6 GW6 GW6 GW6 GW 6 GW 6 GW 6N GW 6N GW 6N GW 6N GW 6N


1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 5.0 1.0 1.0

41010

14 114

7 6 6 10

4 12

11 7 8 9 21

25

450


00152-008 Oct 2012

New Well Reference



Scaling Factor





GW 7A GW 7A GW 7A GW 7A GW7A GW7A GW7A GW7A GW 7A GW 7A GW 7A GW 7A GW 7A GW 7A GW 7A GW 7A


333.3 250.0 25.0 100.0 100.0 100.0 100.0 100.0 50.0 50.0 50.0 50.0 25.0 2.5 5.0 5.0

7902700 9400 700

23 4

11110 160 340 11

6000 140 2 700 10

42 120 130 50 28 37 31 502700 5400 6600 14000 6000 5000 6000 5900 3200 8900 2500 770 530 250

31000 34000 6100 5900 2900 1600 5

120000 10000

16100 5900920

300 500


00152-008 Oct 2012

New Well Reference



Scaling Factor





GW 7B GW 7B GW 7B GW 7B GW7B GW7B GW7B GW7B GW7B GW 7B GW 7B GW 7B GW7B GW 7B GW 7B GW 7B


20.0 100.0 20.0 25.0 50.0 662.5 62.5 62.5 25.0 25.0 25.0 25.0 100.0 25.0 25.0 25.0

250

440460 290 290 120 35 50 52 89 96 91 48

77 1800 240 33 52 1000 990 300 120 74 71 120 130 120 110340 10000 1900 260 370 240 5600 6100 2500 1400 1100 720 910 1100 1200 540

3402833 690 38 610 570 160 110 97 77 110 160 90 70

2400 6400 3600 3000 4800 9600 9100 8400 4400 4900 4200 3100 5500 6600 2900 290710 94 120 28

42000 50270 390 440

5203209000

200000

7.5 8100


00152-008 Oct 2012

New Well Reference



Scaling Factor





GW 7C GW 7C GW 7C GW 7C GW7C GW7C GW7C GW7C GW7C GW 7C GW 7C GW 7C GW7C GW 7C GW 7C GW 7C


50.0 25.0 25.0 5.0 20.0 50.0 50.0 50.0 12.5 16.7 5.0 5.0 20.0 20.0 6.3 6.3

73

21 27 18 18 14 52 49 38 19

10 4 32 36 6 0200 260 110 120 100 120 34 17 130 140 18 0

87 93 470 27 78 110 350 100 56 77 68 290 310 160 1403500 3300 4100 630 2400 3300 6700 3800 1600 1200 400 240 2400 2600 620 160140 150 8 20

4000 160

500580

2900 1500

5001170

1902.8


00152-008 Oct 2012

New Well Reference



Scaling Factor





GW 7D GW 7D GW 7D GW 7D GW7D GW7D GW7D GW7D GW 7D GW 7D GW 7D GW 7D GW 7D GW 7D GW 7D GW 7D


100.0 62.5 10.0 25.0 12.5 50.0 50.0 50.0 125.0 100.0 100.0 100.0 200.0 50.0 50.0 50.0

1100 8200 1000140

110 41 250 170 320 93 86 0640 320 78 27 170 1200 640 1200 200 250 0

96 96 290 2500 100150 240 200 350 60

100 83 62 55 26 77 62 527300 5900 1600 1500 1200 1500 6600 2700 5700 8500 8200 4700 17000 12000 8000 32009300 6000 50 50 66 50 50 50 20000 16000 50 50 23000 50

1800 7100 3100 230

1900 1000 1000 2600 20400 500 500 500 1900 500

3300400 1000

2400

89700 8900

2.2


00152-008 Oct 2012

New Well Reference



Scaling Factor







1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

10 19

3

144 19 4 3 3 2

12

2500 11000 1700 1000 170 100 120 69 56 110


00152-008 Oct 2012

New Well Reference



Scaling Factor




AGW01-I AGW01-I AGW01-I AGW01-I AGW01-I AGW01-I AGW01-I AGW01-I AGW01-I AGW01-I AGW01-I AGW01-I AGW01-I AGW01-I AGW01-I AGW01-I



1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

1

3200 550 72 79 100


00152-008 Oct 2012

New Well Reference



Scaling Factor







1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

8

2

280 91

1500


00152-008 Oct 2012

New Well Reference



Scaling Factor





GW 12 GW 12 GW 12 GW 12 GW12 GW12 GW12 GW12 GW12 GW12 GW12 GW12 GW12 GW12 GW12 GW12


50.0 10.0 10.0 2.5 25.0 50.0 50.0 10.0 25.0 25.0 25.0 1.0 1.0 1.0 1.0 1.0

323 9

1500 140 33 1700 4700 2100 27 84 15 4341 20 11 3 19 16 14 13

12 10 2 13 915 4 13 17 4

4300 150 52 19 45 1 6 8 4

31400 1500 950 530 2600 6200 2700 1200 3800 940 330 37 200 200 38 16

11 2 2150

6000 2700 2000 250 490 700 630 1000

1300

800 900

700


00152-008 Oct 2012

New Well Reference



Scaling Factor





GW13 GW13 GW13 GW13 GW13 GW13 GW13 GW13 GW13 GW 13 GW 13 GW 13 GW13 GW 13 GW 13 GW 13


125.0 25.0 1.0 1.0 1.0 1.0 1.0 5.0 25.0 25.0 5.0 1.0 12.5 2.5 1.0 5.0

3

2500 42 29 80 4700 2100 27 2300 210 73 4202 19 11 3 8 3 10

2 29 10 2 6 2 144 54 15 4 9 4 23

17000 6 6 39 16 270 52 19 4 61 12015 5 1 3 1 6

5600 4500 180 97 120 570 3800 940 330 37 5 346 70 11 2 13 5 12

47 72 380 1000 250 250 65 2905 40

900 2000


00152-008 Oct 2012

New Well Reference



Scaling Factor







1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

23 140 170

10.9

2 3 3 4 8 3

4 3 2 41

240 3500 1300 380 400 150 120 52 260 77 50


00152-008 Oct 2012

New Well Reference



Scaling Factor







1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 no sample 1.0 1.0

12

110

2

8 3 2 1 1 1 1 2 2 1 20

48 94


00152-008 Oct 2012

New Well Reference



Scaling Factor





GW16 GW16 GW16 GW16 GW16 GW16 GW16 GW16 GW16 GW16 GW16 GW16 GW16 GW16 GW16 GW16


1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

2

47

1 2 3 2 3 2 3

760 300 190

FIGURES

WAREHOUSEWAREHOUSE

P7P7

BUILDINGBUILDINGP4P4

PUMPHOUSEPUMPHOUSE

FIRESTATIONFIRESTATION

S.W. TANKS.W. TANK

BOILER HOUSEBOILER HOUSE

P1 \ P2 \ P5.TANK FARM.P1 \ P2 \ P5.TANK FARM.

SOLVENTRECOVERYCONTROLROOM.

SOLVENTRECOVERYCONTROLROOM.

P8TANK FARM

P8TANK FARM

DRUMSTORAGEDRUMSTORAGE

P3CHILLERSP3CHILLERS

MAINPRODUCTIONBUILDINGP2 / P5STORAGE

MAINPRODUCTIONBUILDINGP2 / P5STORAGE

P3 PLANTP3 PLANT

(P6.)(P6.)

WAREHOUSE QUALITY CONTROL

& ENGINEERING BUILIDING

WAREHOUSE QUALITY CONTROL

& ENGINEERING BUILIDING

P9.P9.

P8.P8.

P8 \ P

9 D

RU

M S

TO

RA

GE

P8 \ P

9 D

RU

M S

TO

RA

GE

BALANCINGTANK No.1.BALANCINGTANK No.1.

LAB.LAB.

OLDADMINISTRATION

BUILDING

OLDADMINISTRATION

BUILDING

CHEMICAL DEVELOPMENT

LABORATORY.(C.D.L.)

CHEMICAL DEVELOPMENT

LABORATORY.(C.D.L.)

BALANCINGTANK No.1.BALANCINGTANK No.1.

THERMALOXIDISERTHERMALOXIDISER

FIRE WATERRETENTION TANK.

FIRE WATERRETENTION TANK.

RAW MATERIALSDRUM STORAGE

RAW MATERIALSDRUM STORAGE

MANUFACTURINGSUPPORT CENTREMANUFACTURINGSUPPORT CENTRE

CAR PARKCAR PARK

CAR PARKCAR PARK

CAR PARKCAR PARK

AGW09-SAGW09-S AGW18-IAGW18-I

AGW28SAGW28S

AGW07SAGW07S

AGW03SAGW03S

AGW01IAGW01I

AGW01SAGW01S

AGW06IAGW06I

AGW06SAGW06S

AGW11SAGW11S

AGW12SAGW12S

AGW14SAGW14S

AGW10SAGW10S AGW10IAGW10I

AGW20IAGW20I

AGW20SAGW20S

AGW16SAGW16S

AGW15SAGW15S

AGW02SAGW02S

AGW02IAGW02I

AGW03IAGW03I

AGW05IAGW05I

AGW04IAGW04I

AGW30SAGW30S

AGW38SAGW38S

AGW38IAGW38IAGW38DAGW38D

AGW37IAGW37IAGW37DAGW37D

AGW36DAGW36DAGW36IAGW36IAGW36SAGW36S

AGW27SAGW27S

AGW35DAGW35D

AGW26IAGW26I

AGW25DAGW25D

AGW24DAGW24DAGW24SAGW24SAGW24IAGW24I

AGW23SAGW23S

AGW22DAGW22D


AGW20DAGW20D

AGW34SAGW34S


AGW17P13AGW17P13

RW6RW6

RW5RW5

RW4RW4

RW3RW3

RW2RW2

RW1RW1AGW13P13AGW13P13

AGW29IAGW29I

AGW33SAGW33S

AGW39SAGW39S

AGW40SAGW40SAGW40IAGW40I

AGW41SAGW41S

GCSGCS

GCNGCN

INSCINSC

AGW05SAGW05S

AGW04SAGW04S

AGW29SAGW29S

AGW08IAGW08IAGW08SAGW08S


AGW25SAGW25SAGW25IAGW25I


AGW21IAGW21I

AGW21SAGW21S

AGW19SAGW19S

Figure 9

00152-010

JDWW

PTD/RV

1:1,000

June 201200152-010/BM

Bristol Myers Squibb

Swords Laboratories, Swords

0m 50mApproximate Scale

Key

Groundwater Monitoring Well

IPPC Groundwater Monitoring Well Figure

Delph, UK November-2012

1

Swords Laboratories

IPPC Groundwater Monitoring Network

Bristol-MyersSquibb

GCU00152-008

APPENDIX A

Time-Series Plots of COPCs in Groundwater

TEMPORAL TRENDS IN SELECTED VOCS IN GROUNDWATER: 2009 - 2012

Geosyntec Consultants GCU0152008

0

100

200

300

400

500

600

700

800

900

1000

Q12009

Q22009

Q32009

Q42009

Q12010

Q22010

Q32010

Q42010

Q12011

Q22011

Q32011

Q42011

Q12012

Q22012

Q32012

Q42012

ug/l

Benzene concentration in Groundwater 2009 - 2012

AGW12-S

AGW14-S

AGW16-S

AGW20-S

AGW20-I



0

500

1000

1500

2000

2500

3000

Q12009

Q22009

Q32009

Q42009

Q12010

Q22010

Q32010

Q42010

Q12011

Q22011

Q32011

Q42011

Q12012

Q22012

Q32012

Q42012

ug/l

Ethylbenzene concentration in Groundwater 2009 - 2012

AGW12-S

AGW14-S

AGW15-S

AGW16-S

AGW20-S

AGW20-I



0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

18,000

Q12009

Q22009

Q32009

Q42009

Q12010

Q22010

Q32010

Q42010

Q12011

Q22011

Q32011

Q42011

Q12012

Q22012

Q32012

Q42012

ug/l

m & p-Xylene in Groundwater 2009 - 2012

AGW11-S

AGW12-S

AGW14-S

AGW15-S

AGW16-S

AGW20-S

AGW20-I



0

200

400

600

800

1,000

1,200

Q12009

Q22009

Q32009

Q42009

Q12010

Q22010

Q32010

Q42010

Q12011

Q22011

Q32011

Q42011

Q12012

Q22012

Q32012

Q42012

ug/l

o-Xylene concentration in Groundwater 2009 - 2012

AGW12-S

AGW15-S

AGW16-S

AGW20-S

AGW20-I



0

1000

2000

3000

4000

5000

6000


ug/l

MTBE concentration in Groundwater 2009 - 2012

AGW03-S

AGW06-S

AGW06-I

AGW07-S

AGW09-S

AGW11-S

AGW12-S

AGW14-S

AGW15-S

AGW16-S

AGW20-S

AGW20-I

AGW28-S



0

2000

4000

6000

8000

10000

12000

14000

16000

18000

Q12009

Q22009

Q32009

Q42009

Q12010

Q22010

Q32010

Q42010

Q12011

Q22011

Q32011

Q42011

Q12012

Q22012

Q32012

Q42012

ug/l

THF concentration in Groundwater 2009 - 2012

AGW10-S

AGW10-I

AGW11-S

AGW12-S

AGW14-S

AGW15-S

AGW16-S

AGW20-S

AGW20-I



0

5000

10000

15000

20000

25000

30000

35000

Q12009

Q22009

Q32009

Q42009

Q12010

Q22010

Q32010

Q42010

Q12011

Q22011

Q32011

Q42011

Q12012

Q22012

Q32012

Q42012

ugl

Toluene concentration in Groundwater 2009 - 2012

AGW10-I

AGW11-S

AGW12-S

AGW14-S

AGW15-S

AGW16-S

AGW20-S

BMS Swords Laboratories AER 2012

P0014‐04

Underground storage tank vault monitoring Monitoring of vaults is undertaken monthly with solvent analysis carried out on any samples with a COD > 1,000 mg/l. Samples highlighted in red below were not sent for external solvent analysis inadvertently. The lab checklist has been updated to ensure that this is completed as required in future.

Vault

1 Vault

3 Vault

4 Vault

8 Vault

10 Vault

11 Vault

26 Vault 33/37

Vault 36

COD mg/l

COD mg/l

COD mg/l

COD mg/l

COD mg/l

COD mg/l

COD mg/l

COD mg/l

COD mg/l

23-Jan-12 11,200 02-Mar-12 3,900 19-Jun-12 2,750 50 06-Jul-12 800 750 03-Sep-12 150 300 03-Oct-12 60 1,700 400 300 100 150 05-Nov-12 77 129 129 64 550 142 26-Nov-12 500 700 05-Dec-12 200 200 500

Vaults 26, 33/37 & 36, P2 Tankfarm & Vaults 1 - 12, P8 Tankfarm were empty in February, April, May & August 2012. Liquid accumulated in the vaults is pumped to the WWTP.

Appendix E

PRTR Worksheets

P0014-04 AER 2012

Sheet : Facility ID Activities AER Returns Workbook 28/3/2013 10:38

| PRTR# : P0014 | Facility Name : Swords Laboratories | Filename : P0014_2012 Final.xls | Return Year : 2012 | 2527 28/03/2013 11:54

Guidance to completing the PRTR workbook

Version 1.1.15REFERENCE YEAR 2012

1. FACILITY IDENTIFICATIONParent Company Name Swords Laboratories

Facility Name Swords LaboratoriesPRTR Identification Number P0014

Licence Number P0014-04

Waste or IPPC Classes of ActivityNo. class_name

5.6

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

11.1 #######################################################

5.16The use of a chemical or biological process for the production of basic pharmaceutical products.

Address 1 Watery LaneAddress 2 SwordsAddress 3 County DublinAddress 4

DublinCountry Ireland

Coordinates of Location -6.22089 53.4618River Basin District IEEA

NACE Code 2110Main Economic Activity Manufacture of basic pharmaceutical products

AER Returns Contact Name Muirin GowenAER Returns Contact Email Address [email protected]

AER Returns Contact Position Environmental coordinatorAER Returns Contact Telephone Number 018139395

AER Returns Contact Mobile Phone NumberAER Returns Contact Fax Number 018139153

Production Volume 142359.0Production Volume Units kg

Number of Installations 0Number of Operating Hours in Year 0

Number of Employees 340User Feedback/Comments

AER Returns Workbook

| PRTR# : P0014 | Facility Name : Swords Laboratories | Filename : 2011 vs 2012 emissions.xlsx | Return Year : 2012 | Page 1 of 1

User Feedback/CommentsWeb Address

2. PRTR CLASS ACTIVITIESActivity Number Activity Name50.1 General

4(e)Installations using a chemical or biological process for the productionon an industrial scale of basic pharmaceutical products

50.1 General3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002)

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

If applicable which activity class applies (as perSchedule 2 of the regulations) ? Manufacturing of pharmaceutical products.

Is the reduction scheme compliance route beingused ? No

4. WASTE IMPORTED/ACCEPTED ONTO SITE Guidance on waste imported/accepted onto site

Do you import/accept waste onto your site for on-site treatment (either recovery or disposal

activities) ? NoThis question is only applicable if you are an IPPC or Quarry site

| PRTR# : P0014 | Facility Name : Swords Laboratories | Filename : 2011 vs 2012 emissions.xlsx | Return Year : 2012 | Page 1 of 1

Sheet : Releases to Air AER Returns Workbook 28/3/2013 10:39

4.1 RELEASES TO AIR Link to previous years emissions data | PRTR# : P0014 | Facility Name : Swords Laboratories | Filename : P0014_2012 Final.xls | Return Year : 2012 | 28/03/2013 11:548 14 22 25 33 40 6 12 6 10 6 12 37

SECTION A : SECTOR SPECIFIC PRTR POLLUTANTSPlease enter all quantities in this section in KGs

QUANTITYA2-1 A2-2 A2-3 A2-4 A2-6 A2-7 A2-8

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 Emission Point 2 Emission Point 3 Emission Point 4 Emission Point 5 Emission Point 6 Emission Point 7T (Total) KG/Year

A (Accidental) KG/Year

F (Fugitive) KG/Year

03 Carbon dioxide (CO2) C ETS 6611017.0 0.0 0.0 0.0 0.0 0.0 0.0 6611017.0 0.0 0.004 Hydro-fluorocarbons (HFCs) E ESTIMATE 0.0 0.0 0.0 0.0 0.0 0.0 0.0 129.8 0.0 129.880 Chlorine and inorganic compounds (as HCl) M EN 1911-1 to 3:2003 172.09 0.0 0.0 0.0 0.0 0.0 0.0 172.09 0.0 0.008 Nitrogen oxides (NOx/NO2) M EN 14792:2005 573.04 0.0 0.0 0.0 0.0 0.0 0.0 573.04 0.0 0.0

07 Non-methane volatile organic compounds (NMVOC) C OTHSum of calculated individual compounds. 0.0 74.14 187.8 18.98 34.07 73.47 43.29 2211.78 0.0 1780.03

47 PCDD + PCDF (dioxins + furans)(as Teq) M EN 1948-1 to3:2003 0.0001848 0.0 0.0 0.0 0.0 0.0 0.0 0.0001848 0.0 0.011 Sulphur oxides (SOx/SO2) M EN 14791:2005 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION B : REMAINING PRTR POLLUTANTSPlease enter all quantities in this section in KGs

QUANTITYA2-1 A2-3 A2-4 A2-6 A2-7

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 Emission Point 2 Emission Point 3 Emission Point 4 Emission Point 5 T (Total) KG/YearA (Accidental) KG/Year


02 Carbon monoxide (CO) M EN 15058:2004 0.96 0.0 0.0 0.0 0.0 0.96 0.0 0.0

35 Dichloromethane (DCM) C OTHUSEPA software TANKS 4.0.9d 0.0 124.12 18.98 28.22 8.94 490.2 0.0 309.94

84 Fluorine and inorganic compounds (as HF) M OTH Based on USEPA 26A 6.89 0.0 0.0 0.0 0.0 6.89 0.0 0.0

73 Toluene C OTHUSEPA software TANKS 4.0.9d 0.0 0.0 0.0 0.0 0.0 4.87 0.0 4.87


SECTION C : REMAINING POLLUTANT EMISSIONS (As required in your Licence)Please enter all quantities in this section in KGs

QUANTITYA2-1 A2-2 A2-3 A2-4 A2-6 A2-7 A2-8

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 Emission Point 2 Emission Point 3 Emission Point 4 Emission Point 5 Emission Point 6 Emission Point 7T (Total) KG/Year

A (Accidental) KG/Year


247 Acetone C OTHUSEPA software TANKS 4.0.9d 0.0 0.0 63.68 0.0 0.0 8.06 26.24 879.93 0.0 781.95

248 Ethanol C OTHUSEPA software TANKS 4.0.9d 0.0 0.0 0.0 0.0 0.0 21.55 0.0 34.65 0.0 13.1

214 Hydrogen bromide M OTH Based on US EPA 26A 6.89 0.0 0.0 0.0 0.0 0.0 0.0 6.89 0.0 0.0

246 Isopropyl Alcohol (IPA) C OTHUSEPA software TANKS 4.0.9d 0.0 48.6 0.0 0.0 3.08 4.17 0.0 96.75 0.0 40.9

323 Methanol C OTHUSEPA software TANKS 4.0.9d 0.0 0.0 0.0 0.0 2.77 6.86 15.15 261.78 0.0 237.0

330 Organic solvents C OTHSum of calculated individual compounds. 0.0 74.14 187.8 18.98 34.07 73.47 43.29 2211.78 0.0 1780.03

RELEASES TO AIRMETHOD

POLLUTANT METHODMethod Used

Method Used

RELEASES TO AIRPOLLUTANT METHOD

Method Used

POLLUTANT

RELEASES TO AIR

| PRTR# : P0014 | Facility Name : Swords Laboratories | Filename : P0014_2012 v3.xls | Return Year : 2012 | Page 1 of 1

330 Organic solvents C OTH compounds. 0.0 74.14 187.8 18.98 34.07 73.47 43.29 2211.78 0.0 1780.03244 Total Particulates M ALT Based on BS 13284 109.34 0.0 0.0 0.0 0.0 0.0 0.0 109.34 0.0 0.0237 Volatile organic compounds (as TOC) M OTH FID 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0



Sheet : Releases to Waters AER Returns Workbook 28/3/2013 10:39

4.2 RELEASES TO WATERS Link to previous years emissions data | PRTR# : P0014 | Facility Name : Swords Laboratories | Filename : P0014_2012 Final.xls | Return Year : 2012 | 28/03/2013 11:548 8 16 16 24 24 6 6 6 6 6 6

SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS Data on ambient monitoring of storm/surface water or groundwater, conducted as part of your licence requirements, should NOT be submitted under AER / PRTR Reporting as this only concerns Releases from your facility

Please enter all quantities in this section in KGsQUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year0.0 0.0 0.0 0.0


SECTION B : REMAINING PRTR POLLUTANTSPlease enter all quantities in this section in KGs

QUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year0.0 0.0 0.0 0.0


SECTION C : REMAINING POLLUTANT EMISSIONS (as required in your Licence)Please enter all quantities in this section in KGs

QUANTITY

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year0.0 0.0 0.0 0.0


RELEASES TO WATERS

Method Used

RELEASES TO WATERS

RELEASES TO WATERS

Method Used

POLLUTANTMethod Used

POLLUTANT

POLLUTANT


Sheet : Releases to Wastewater or Sewer AER Returns Workbook 28/3/2013 10:39

4.3 RELEASES TO WASTEWATER OR SEWER Link to previous years emissions data | PRTR# : P0014 | Facility Name : Swords Laboratories | Filename : P0014_2012 Final.xls | Return Y 28/03/2013 11:548 17 25 35 6 6 6 6

SECTION A : PRTR POLLUTANTSPlease enter all quantities in this section in KGs

QUANTITYSE-1

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year

18 Cadmium and compounds (as Cd) M OTH

Derived from US EPA Methods SW 846-6020 and 1631B 0.04 0.04 0.0 0.0

19 Chromium and compounds (as Cr) M OTH


20 Copper and compounds (as Cu) M OTH


35 Dichloromethane (DCM) M OTHDerived from US EPA methods 624 & 8260B 32.87 32.87 0.0 0.0

83 Fluorides (as total F) M OTH IC - based on APHA 4110B 43.9 43.9 0.0 0.0

23 Lead and compounds (as Pb) M OTH


22 Nickel and compounds (as Ni) M OTH


07 Non-methane volatile organic compounds (NMVOC) M OTHSum of individually analysed organic solvents 3131.77 3131.77 0.0 0.0

76 Total organic carbon (TOC) (as total C or COD/3) C OTH COD/3 7338.0 7338.0 0.0 0.0

24 Zinc and compounds (as Zn) M OTH



SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence)Please enter all quantities in this section in KGs

QUANTITYSE-1

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year

376 Acetone M OTHDerived from US EPA methods 624 & 8260B 250.0 250.0 0.0 0.0

OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER

OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER

Method Used

Method Used

POLLUTANT METHOD

POLLUTANT METHOD

Link to previous years emissions data Page 1 of 1

376 Acetone M OTH methods 624 & 8260B 250.0 250.0 0.0 0.0303 BOD M ALT BS EN 1899-1: 1998 3716.0 3716.0 0.0 0.0306 COD M OTH HACH test 22015.0 22015.0 0.0 0.0

314 Fats, Oils and Greases M ALTHexane extraction and gravimetry 571.0 571.0 0.0 0.0

375 Isopropyl Alcohol (IPA) M OTHDerived from US EPA methods 624 & 8260B 26.92 26.92 0.0 0.0

323 Methanol M OTHDerived from US EPA methods 624 & 8260B 1677.29 1677.29 0.0 0.0

330 Organic solvents C OTHSum of individually analysed organic solvents 3131.77 3131.77 0.0 0.0

387 Ortho-phosphate (as P) M OTHBased on APHA 4110B & APHA 4500 1248.0 1248.0 0.0 0.0

343 Sulphate M ALT IC - based on APHA 4110B 19591.0 19591.0 0.0 0.0240 Suspended Solids M OTH BS EN 872:2005 5381.0 5381.0 0.0 0.0

347 Total heavy metals C OTHSum of individually analysed metals. 4.57 4.57 0.0 0.0


Link to previous years emissions data Page 1 of 1

Sheet : Releases to Land AER Returns Workbook 28/3/2013 10:40

4.4 RELEASES TO LAND Link to previous years emissions data | PRTR# : P0014 | Facility Name : Swords Laboratories | Filename : P0014_2012 Final.xls | Return Year : 2012 | 28/03/2013 11:548 8 16 16 6 6 6 6

SECTION A : PRTR POLLUTANTSPlease enter all quantities in this section in KGs

QUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year0.0 0.0 0.0


SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence)Please enter all quantities in this section in KGs

QUANTITY

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year0.0 0.0 0.0



RELEASES TO LAND

RELEASES TO LAND


| PRTR# : P0014 | Facility Name : Swords Laboratories | Filename : P0014_2012 v3.xls | Return Year : 2012 | Page 1 of 1| PRTR# : P0014 | Facility Name : Swords Laboratories | Filename : P0014_2012 v3.xls | Return Year : 2012 | Page 1 of 1

Sheet : Treatment Transfers of Waste AER Returns Workbook 28/3/2013 10:50

5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE | PRTR# : P0014 | Facility Name : Swords Laboratories | Filename : P0014_2012 Final.xls | Return Year : 2012 | 28/03/2013 11:545 79 Please enter all quantities on this sheet in Tonnes 0

Quantity (Tonnes per

Year)

Haz Waste : Name and Licence/Permit No of Next

Destination Facility Non Haz Waste: Name and Licence/Permit No of

Recover/Disposer

Haz Waste : Address of Next Destination Facility

Non Haz Waste: Address of Recover/Disposer

Name and License / Permit No. and Address of Final Recoverer /

Disposer (HAZARDOUS WASTE ONLY)

Actual Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)

Transfer DestinationEuropean Waste

Code Hazardous Quantity T/Year Description of Waste

Waste Treatment Operation M/C/E Method Used

Location of Treatment Name and Licence / Permit No. of Recoverer / Disposer / Broker Address of Recoverer / Disposer / Broker Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY) Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)

Within the Country 15 01 01 No 1.653 paper and cardboard packaging R3 M Weighed Offsite in Ireland Greenstar Limited,W0183-01

Millennium Park,.,Ballycoolin,County Dublin,Ireland

Within the Country 15 01 02 No 2.5 plastic packaging D1 M Weighed Offsite in IrelandGreenstar Knockharley Meath Landfill,W0146-02

Knockharley,.,Navan,County Meath,Ireland

Within the Country 15 01 06 No 6.192 mixed packaging R3 M Weighed Offsite in Ireland Greenstar Limited,W0183-01


Within the Country 15 01 07 No 3.593 glass packaging R5 M Weighed Offsite in IrelandGlassco Recycling,WFP-KE-08-357-01

Osberstown Business Park Carragh Road,Unit 4,Naas,County Kildare,Ireland

Within the Country 16 02 14 No 0.55discarded equipment other than those mentioned in 16 02 09 to 16 02 13 R13 M Weighed Offsite in Ireland

KMK Metals / WEEE Recycle,W0113-03

Cappincur Industrial Estate Daingean Road,.,Tullamore,County Offaly,Ireland

Within the Country 16 02 16 No 2.067

components removed from discarded equipment other than those mentioned in 16 02 15 R13 M Weighed Offsite in Ireland



Within the Country 17 05 04 No 0.62soil and stones other than those mentioned in 17 05 03 R5 M Weighed Offsite in Ireland Greenstar Limited,W0183-01


Within the Country 17 05 04 No 212.11soil and stones other than those mentioned in 17 05 03 D1 M Weighed Offsite in Ireland Greenstar Limited,W0183-01


Within the Country 17 05 04 No 36.2soil and stones other than those mentioned in 17 05 03 R5 M Weighed Offsite in Ireland Greenstar Limited,W0183-01


mixed construction and demolition wastes other than those mentioned in 17 09 01 17

Millennium Park Ballycoolin County

Method Used

Within the Country 17 09 04 No 239.53other than those mentioned in 17 09 01, 17 09 02 and 17 09 03 R5 M Weighed Offsite in Ireland Greenstar Limited,W0183-01

Park,.,Ballycoolin,County Dublin,Ireland

Within the Country 19 12 07 No 4.918 wood other than that mentioned in 19 12 06 R3 M Weighed Offsite in Ireland Greenstar Limited,W0183-01


Within the Country 19 12 09 No 101.67 minerals (for example sand, stones) R5 M Weighed Offsite in Ireland Greenstar Limited,W0183-01


Within the Country 19 12 09 No 17.02 minerals (for example sand, stones) D1 M Weighed Offsite in Ireland Greenstar Limited,W0183-01


Within the Country 19 12 12 No 34.667

other wastes (including mixtures of materials) from mechanical treatment of wastes other than those mentioned in 19 12 11 D1 M Weighed Offsite in Ireland Greenstar Limited,W0183-01


Within the Country 20 01 01 No 6.72 paper and cardboard R3 BrunnenWeighed Offsite in IrelandRehab Enterprises Limited,WFP-DS-10-0008-03

Broomhill Road,Unit 77,Tallaght,Dublin 24,Ireland

Within the Country 20 01 08 No 0.287 biodegradable kitchen and canteen waste R3 M Weighed Offsite in Ireland Greenstar Limited,W0183-01


Within the Country 20 01 08 No 16.578 biodegradable kitchen and canteen waste R3 M Weighed Offsite in IrelandGreenstar Materials Recovery Limited,W0188-01

Road 3A Greenogue Industrial Estate,Site 14B Phase 3,Rathcoole,County Dublin,Ireland

Within the Country 20 01 25 No 0.4984 edible oil and fat R3 M Weighed Offsite in IrelandFrylite Group,WFP-DS-10-0009

Ballymount Drive,Unit S2/S3 Ballymount Industrial Estate,.,Dublin 12,Ireland

Within the Country 20 01 38 No 2.37 wood other than that mentioned in 20 01 37 R3 M Weighed Offsite in IrelandBailey waste recycling,WFP-FG-08-002-01

Rosemount Business Park Ballycoolin Road,.,Blanchardstown,Dublin 11,Ireland




Year)



Recover/Disposer










Method Used

Within the Country 20 01 38 No 63.675 wood other than that mentioned in 20 01 37 R3 M Weighed Offsite in Ireland Greenstar Limited,W0183-01


Within the Country 20 01 40 No 36.25 metals R4 M Weighed Offsite in Ireland Greenstar Limited,W0183-01


Within the Country 20 03 01 No 28.463 mixed municipal waste D1 M Weighed Offsite in Ireland Greenstar Limited,W0183-01


Within the Country 20 03 07 No 85.41 bulky waste D1 M Weighed Offsite in Ireland Greenstar Limited,W0183-01


Within the Country 07 05 12 No 581.34sludges from on-site effluent treatment other than those mentioned in 07 05 11 R3 M Weighed Offsite in Ireland BMS Cruiserath,P0552-02

Cruiserath Road,.,Mulhuddart,Dublin 15,Ireland

Within the Country 07 05 12 No 1494.87sludges from on-site effluent treatment other than those mentioned in 07 05 11 D8 C Weighed Offsite in Ireland Dublin City Council,D0034-01 .,.,Ringsend,Dublin 4,Ireland

Within the Country 07 05 03 Yes 296.14organic halogenated solvents, washing liquids and mother liquors R2 C Volume Calculation Onsite of generatio

Swords Laboratories,P0014-04

Watery Lane,.,Swords,County Dublin,Ireland

Swords Laboratories,P0014-04,Watery Lane,.,Swords,County Dublin,Ireland


Within the Country 07 05 04 Yes 776.08other organic solvents, washing liquids and mother liquors R2 C Volume Calculation Onsite of generatio





Within the Country 07 05 04 Yes 1.736other organic solvents, washing liquids and mother liquors D8 C Volume Calculation Onsite of generatio





Within the Country 07 05 03 Yes 3190 92organic halogenated solvents, washing liquids and mother liquors D10 M Weighed Offsite in Ireland BMS Cruiserath P0552 02

Cruiserath Road,.,Mulhuddart,Dublin 15 Ireland

BMS Cruiserath,P0552-02,Cruiserath Road,.,Mulhuddart,Dublin 15 Ireland

Cruiserath Road,.,Mulhuddart,Dublin 15 IrelandWithin the Country 07 05 03 Yes 3190.92 liquids and mother liquors D10 M Weighed Offsite in Ireland BMS Cruiserath,P0552-02 15,Ireland 15,Ireland 15,Ireland

Within the Country 06 01 06 Yes 6.88 other acids D13 M Weighed Offsite in Ireland

Veolia Environmental Services Technical Solutions,W0050-02

Corrin, ,Fermoy,County Cork,Ireland

Veolia Environmental Services Technical Solutions,W0050-02,Corrin, ,Fermoy,County Cork,Ireland


Within the Country 06 01 06 Yes 0.004 other acids R13 M Weighed Offsite in Ireland





To Other Countries 06 01 06 Yes 15.03 other acids D10 M Weighed Abroad

Veolia Environmental Services Ellesmere Port,BS51931E/GM3001

Bridges Road,.,Ellesmere Port South Wirral,CH 65 4EQ,United Kingdom

Veolia Environmental Services Ellesmere Port,BS51931E/GM3001,Bridges Road, ,Ellesmere Port,South Wirral CH65 4EQ,United Kingdom

Bridges Road, ,Ellesmere Port,South Wirral CH65 4EQ,United Kingdom

To Other Countries 06 02 05 Yes 1.46 other bases D10 M Weighed Abroad





To Other Countries 07 05 01 Yes 37.31 aqueous washing liquids and mother liquors D10 M Weighed Abroad





Within the Country 07 05 01 Yes 11.99 aqueous washing liquids and mother liquors D15 M Weighed Offsite in Ireland








Year)



Recover/Disposer










Method Used

Within the Country 07 05 04 Yes 1.84other organic solvents, washing liquids and mother liquors R2 M Weighed Offsite in Ireland





To Other Countries 07 05 04 Yes 11.86other organic solvents, washing liquids and mother liquors D10 M Weighed Abroad





To Other Countries 07 05 13 Yes 26.86solid wastes containing dangerous substances D10 M Weighed Abroad

Sava BmbH & Co,KG 10HFO03002

Osterweute,1,Brunsbuttel,25521,Sweden

Sava BmbH & Co,KG 10HFO03002,Osterweute,1,Brunsbuttel,25521,Sweden


To Other Countries 07 05 13 Yes 112.23solid wastes containing dangerous substances D10 M Weighed Abroad





Within the Country 13 02 08 Yes 0.45 other engine, gear and lubricating oils R9 M Weighed Offsite in IrelandEnva Ireland Ltd. T/A Enva,W0184-01

Clonminam Industrial Estate,.,Portlaoise,County Laois,Ireland

Enva Ireland Ltd. T/A Enva,W0184-01,Clonminam Industrial Estate,.,Portlaoise,County Laois,Ireland

Clonminam Industrial Estate,.,Portlaoise,County Laois,Ireland

To Other Countries 14 06 01 Yes 1.43 chlorofluorocarbons, HCFC, HFC D10 M Weighed AbroadRSL Ireland Limited,COR-DS-10-0002-01

Robinhood Industrial Estate,48,Clondalkin,Dublin 22,Ireland

HRP Refrigerants Limited,3/91/24,Gellihirion Industrial Estate,.,Pontypridd Mid Glamorgan,CF37 5SX,United Kingdom

Gellihirion Upper Boat Midway Park,.,Pontypridd,Mid Glamorgan,United Kingdom

Veolia Environmental

Within the Country 15 01 10 Yes 0.39packaging containing residues of or contaminated by dangerous substances D15 M Weighed Offsite in Ireland





Within the Country 15 01 10 Yes 5.94packaging containing residues of or contaminated by dangerous substances R13 M Weighed Offsite in Ireland





Within the Country 15 01 10 Yes 26.14packaging containing residues of or contaminated by dangerous substances R4 M Weighed Offsite in Ireland





To Other Countries 15 01 10 Yes 24.5packaging containing residues of or contaminated by dangerous substances D10 M Weighed Abroad





To Other Countries 15 02 02 Yes 0.89

absorbents, filter materials (including oil filters not otherwise specified), wiping cloths, protective clothing contaminated by dangerous substances D10 M Weighed Abroad





Within the Country 16 02 13 Yes 1.86

discarded equipment containing hazardous components (16) other than those mentioned in 16 02 09 to 16 02 12 R4 M Weighed Offsite in Ireland



KMK Metals / WEEE Recycle,W0113-03,Cappincur Industrial Estate Daingean Road,.,Tullamore,County Offaly,Ireland





Year)



Recover/Disposer










Method Used

To Other Countries 16 05 04 Yes 0.009gases in pressure containers (including halons) containing dangerous substances D10 M Weighed Abroad



Remondis NL,56.8851.1.3-G 7/97,Brunnenstr,138,Lunen,44536,Germany

Brunnenstr,138,Lunen,44536,Germany

Within the Country 16 05 07 Yes 0.041discarded inorganic chemicals consisting of or containing dangerous substances D13 M Weighed Offsite in Ireland





Within the Country 16 05 07 Yes 0.039discarded inorganic chemicals consisting of or containing dangerous substances R13 M Weighed Offsite in Ireland





Within the Country 16 05 07 Yes 0.003discarded inorganic chemicals consisting of or containing dangerous substances R2 M Weighed Offsite in Ireland





To Other Countries 16 05 07 Yes 0.063discarded inorganic chemicals consisting of or containing dangerous substances D10 M Weighed Abroad





To Other Countries 16 05 07 Yes 0.09discarded inorganic chemicals consisting of or containing dangerous substances D10 M Weighed Abroad





Within the Country 16 05 07 Yes 0 06discarded inorganic chemicals consisting of or containing dangerous substances D10 M Weighed Offsite in Ireland

Veolia Environmental Services Technical Solutions W0050 02

Corrin, ,Fermoy,County Cork Ireland

Veolia Environmental Services Technical Solutions,W0050-02,Corrin, Fermoy County Cork Ireland

Corrin, ,Fermoy,County Cork IrelandWithin the Country 16 05 07 Yes 0.06 or containing dangerous substances D10 M Weighed Offsite in Ireland Solutions,W0050-02 Cork,Ireland ,Fermoy,County Cork,Ireland Cork,Ireland

Within the Country 16 05 08 Yes 0.172discarded organic chemicals consisting of or containing dangerous substances D10 M Weighed Offsite in Ireland





To Other Countries 16 05 08 Yes 0.004discarded organic chemicals consisting of or containing dangerous substances D10 M Weighed Abroad





To Other Countries 16 05 08 Yes 2.13discarded organic chemicals consisting of or containing dangerous substances D10 M Weighed Abroad





Within the Country 16 05 08 Yes 0.039discarded organic chemicals consisting of or containing dangerous substances R13 M Weighed Offsite in Ireland





Within the Country 16 05 08 Yes 0.035discarded organic chemicals consisting of or containing dangerous substances R2 M Weighed Offsite in Ireland





Within the Country 16 06 01 Yes 0.46 lead batteries R4 M Weighed Offsite in IrelandKMK Metals / WEEE Recycle,W0113-03







Year)



Recover/Disposer










Method Used


mixtures of, or separate fractions of concrete, bricks, tiles and ceramics containing dangerous substances D15 M Weighed Offsite in Ireland






wastes whose collection and disposal is subject to special requirements in order to prevent infection D9 M Weighed Offsite in Ireland SRCL,W0055-02

Beech road Western Industrial Estate,430,Naas Road,Dublin 12,Ireland

SRCL,W0055-02,Beech Road Western Industrial Estate,430,Naas Road,Dublin 12,Ireland

Beech Road Western Industrial Estate,430,Naas Road,Dublin 12,Ireland

Within the Country 20 01 21 Yes 0.15fluorescent tubes and other mercury-containing waste R4 M Weighed Offsite in Ireland





To Other Countries 07 05 01 Yes 115.64 aqueous washing liquids and mother liquors D10 M Weighed Abroad





To Other Countries 07 05 01 Yes 1300.67 aqueous washing liquids and mother liquors R1 M Weighed Abroad



Veolia Sotrenor France,DCVC-EIM-FT 2005-195,Route d'Harnes, ,COURRIÈRES ,62710,France

Route d'Harnes, ,COURRIÈRES ,62710,France

Within the Country 07 05 03 Yes 887.75organic halogenated solvents, washing liquids and mother liquors R2 M Weighed Offsite in Ireland





Veolia Environmental Services Ellesmere

To Other Countries 07 05 03 Yes 360.18organic halogenated solvents, washing liquids and mother liquors R2 M Weighed Abroad



Services Ellesmere Port,BS51931E/GM3001,Bridges Road, ,Ellesmere Port,South Wirral CH65 4EQ,United Kingdom


To Other Countries 07 05 03 Yes 207.26organic halogenated solvents, washing liquids and mother liquors D10 M Weighed Abroad

Veolia Environmental Services,W0054-02

Allied Industrial Estate,Unit 1A,Kylemore Road,Dublin 10,Ireland



Within the Country 07 05 03 Yes 359.66organic halogenated solvents, washing liquids and mother liquors D15 M Weighed Offsite in Ireland





To Other Countries 16 08 07 Yes 3.16spent catalysts contaminated with dangerous substances R8 M Weighed Abroad

BASF Italia Srl - Divisione Ca,RU 10374

Via di Salone,245,Rome,131,Italy

BASF Italia Srl - Divisione Ca,RU 10374,Via di Salone,245,Rome,131,Italy

Via di Salone,245,Rome,131,Italy

Within the Country 15 01 01 No 16.68 paper and cardboard packaging R3 M Weighed Offsite in IrelandBailey waste recycling,WFP-FG-08-002-01

Rosemount Business Park Ballycoolin Road,.,Blanchardstown,Dublin 11,Ireland


Appendix F

Noise

P0014-04 AER 2012

_____________________________________

Technical Report Prepared For

Veolia Environmental Services Swords Laboratories

Watery Lane Swords

Co. Dublin

_____________________________________ Technical Report Prepared By

Jennifer Harmon BSc AMIOA

_____________________________________

Our Reference

JH/12/6355NR01A

____________________________________ Date Of Issue

15 October 2012

_____________________________________

BRISTOL-MYERS SQUIBB SWORDS LABORATORIES

IPPC LICENCE NOISE SURVEY 2012

JH/12/6355NR01A AWN Consulting Limited _____________________________________________________________________________________________________

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EXECUTIVE SUMMARY AWN Consulting has been commissioned to measure environmental noise levels in order to establish the noise climate in the vicinity of the Bristol-Myers Squibb (BMS) – Swords Laboratories facility in accordance with the appropriate Integrated Pollution Prevention and Control (IPPC) Licence. This document reviews the survey data and presents it in a form suitable for submittal to the Environmental Protection Agency (EPA) as part of Abbott’s Annual Environmental Report (AER). Environmental noise surveys have been carried out at the three specified noise sensitive locations located to the north, east and west of the facility as set out in the facilities licence conditions. Noise levels were measured during the daytime period at Locations 2 and 3 and during the day evening and night-time periods at Location 1 over the course of an attended noise survey. During daytime periods, the key sources of noise were noted to be from road traffic noise, bird song and plant noise emissions at low levels at the measurements locations. Measured noise levels were in the range of 50 to 62dB LAeq, 15mins. The higher value was attributed to passing road traffic at Location 2. The steady background noise level in terms of the LA90 parameter recorded during the daytime period was in the range of 45 to 53dB LA90. During the evening period at Location 1, noise levels were in the range of 46 to 47dB LAeq, 15mins with background noise levels measuring 43 to 44dB LA90. The dominant noise sources during this period were noted to be road traffic and plant noise emissions at low level. During the night-time survey period, the key sources of noise at Location 1 were noted to be from road traffic along Watery Lane and plant noise emissions at low levels. Measured noise levels were in the range of 44 to 47dB LAeq, 15mins. The steady background noise level in terms of the LA90 parameter recorded during the night-time period was in the range of 42 to 43dB LA90. No tones were recorded at the monitoring locations which would attract a penalty as assessed in accordance with ISO 1996-2 (2007). No impulsive noise characteristics were noted during the survey periods at any of the noise sensitive locations. The survey data has been analysed and it may be concluded that this facility is in compliance with the relevant conditions of its IPPC Licence. Estimated specific noise levels from the facility are summarised in the table below and compared against the relevant licence limits.

Location Period Estimated Specific Plant Noise, dB

Criteria, dB LAeq,15mins

Within Criteria?

Location 1 Daytime 46 55 Yes

Night-time 43 45 Yes

Location 2 Daytime ~47 55 Yes

Location 3 Daytime 51 55 Yes

Report Prepared By: Report Checked By:

JENNIFER HARMON LOUIS SMITH Senior Acoustic Consultant Acoustic Consultant


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CONTENTS Page

Executive Summary 2

1.0 Introduction 4

2.0 Survey Details 5

2.1 Measurement Locations 5

2.2 Survey Periods 6

2.3 Weather Conditions 7

2.4 Personnel and Instrumentation 7

2.5 Procedure 7

3.0 Survey Results 8

3.1 Location 1 10

3.2 Location 2 10

3.3 Location 3 10

4.0 Discussion 11

4.1 Daytime Noise Levels 11

4.2 Night-time Noise Levels 11

4.3 Comparison Against Previous Surveys 12

4.4 Estimate of Specific Plant Noise Levels 12

5.0 Conclusion 14

Figure 1 – Site Context and Noise Measurement Locations 5

Figure 2 – Monitoring Location 1 6



Appendix A – Glossary of Acoustic Terminology 15

Appendix B – Calibration Certificates for Monitoring Equipment 16

Appendix C – One-Third Octave Band Centre Frequency Data 19


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1.0 INTRODUCTION

BMS operate a facility at Swords Laboratories, Watery Lane, Swords, Co. Dublin. The facility is licenced by the Environmental Protection Agency (EPA) under an Integrated Pollution Prevention and Control (IPPC) Licence (Licence number P0014-04). The facility operates 24 hours a day, 7 days a week. A number of external plant items operate at the facility which make up the main noise emissions from the plant.

The criteria for assessment in relation to noise are outlined in Schedule 4 of the IPPC License1. These criteria are summarised as follows:

B.4 Noise Emissions

Daytime dB(A) LAeq

(15 minutes) Night-time dB(A) LAeq

(15 minutes)

55Note 1

45 Note 1,

Note 1: There shall be no clearly audible tonal component or impulsive component in the noise emission from the activity at any noise sensitive location.

Daytime is defined in the licence document as 08:00 to 22:00hrs and night-time 22:00 to 08:00hrs. This report prepared by AWN Consulting presents the results of the 2012 annual noise survey and compares the range of measured noise levels against the criteria outlined above. Please refer to the Glossary of Terms in Appendix A for a definition of the various acoustic terminology used in this report.

1 EPA Licence Register Number P0014-04


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2.0 SURVEY DETAILS An attended annual noise survey was conducted at the specified noise monitoring locations as part of the IPPC conditions. The survey was conducted generally in accordance with the Guidance Note for Noise: License Applications, Surveys and Assessments in Relation to Scheduled Activities (NG4). Survey details are set out below.

2.1 Measurement Locations Noise measurements were conducted at three positions Locations 1, 2 and 3, as previously agreed by the EPA. These locations are described overleaf and shown on Figure 1 below.

Figure 1 Site Context and Noise Monitoring Locations (Source Google Earth) The monitoring locations are described overleaf.


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Location 1 Located within the southwest corner of the facility at shared boundary of the residential property off Watery Lane and Swords Laboratories.

Figure 2 Monitoring Location 1 (Source - Google Street View). Monitoring Location to rear of

property within BMS facility. Location 2 Located to the north of the facility, outside Fingal County Council

Offices, off Watery Lane.

Figure 3 Monitoring Location 2 Location 3 Located within Swords Town Park to the east of the site.

Figure 4 Monitoring Location 3

2.2 Survey Periods Measurements were conducted over the course of the following survey periods: • Daytime: 10:16 to 14:11hrs on 19 September 2012, • Evening 22:00 to 23:00hrs, and; • Night-time: 23:00 on 19 September to 00:37hrs 20 September 2012.

During all of the survey periods noted above, BMS have confirmed that the facility was in normal full operation.


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2.3 Weather Conditions

The weather during daytime survey periods was dry and calm, temperatures were in the range 14 to 16 degrees Celsius, wind speeds were in the range 0.1 to 1.5 m/s. The weather during night-time survey periods was dry and very calm, temperatures were typically 10 degrees Celsius, wind speeds were <1 m/s.

2.4 Personnel and Instrumentation Jennifer Harmon (AWN) conducted the noise level measurements during all survey periods. The measurements were performed using the following equipment:

Manufacturer Equipment Model Serial Number Microphone Calibration date

Brüel & Kjaer 2260 1823777 ½” Type 4189 S/N 2199217 August 2011

Table 1 Noise Monitoring Equipment Details The microphone was protected using a proprietary Brüel and Kjaer windshield. Before and after the survey the measurement apparatus was check calibrated using a Brüel & Kjær Type 4231 Sound Level Calibrator Serial Number: 2263026. The calibration certificates for the equipment is included in Appendix B. Wind speed was monitored using a hand held kestrel anemometer.

2.5 Procedure Measurements were conducted on a cyclical basis between the three monitoring locations during the daytime periods. Night-time monitoring was conducted at Location 1 only as the other two locations are not noise sensitive during this period. Sample periods were 15 minutes during both the daytime and night-time surveys in accordance with the licence conditions. The results were saved to the instrument memory for later analysis. Survey personnel noted all primary noise sources contributing to noise build-up. Survey results are summarised in Tables 2 and 3 overleaf.

JH/12/6355NR01A AWN Consulting Limited _______________________________________________________________________________________________________________________________________________________________

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3.0 SURVEY RESULTS

The survey results for each monitoring location are summarised in Tables 2 and 3 below. Please refer to the Glossary of Terms in Appendix A for a definition of the various parameters discussed below. Appendix C presents the measured 1/3rd octave band analysis for each survey period.

Location Period Time

Measured Noise Levels dB re. 2x10-5 Pa) Weather Conditions

Comments LAeq LAFmax LA10 LAF90

Win

d

Spe

ed

Win

d D

irect

ion

% C

loud

C

over

Tem

p ˚C

Location 1

Day

12:00 –12:15 53 74 55 46 0.5 SW ~40 ~16

• Road traffic noise main source. • Activities within contractors compound intermittent

(manual tools) • Plant noise from BMS audible at very low level.

12:46 –13:01 52 69 55 45 0.4 SW ~50 ~16 • As above. • Maximum (LAmax) noise levels from contractors

compound

13:56 –14:11 52 71 55 46 0.7 SW ~50 ~16 • As above. Road traffic dominates.

Evening

22:00 –22:15 47 64 50 43

0.6 W/SW ~50 ~11

• Road traffic and plant noise emissions main noise sources. Aircraft overhead (~3) Calm conditions prevail

22:15 –22:30 47 59 50 43

22:30 –22:45 46 61 49 44

Night

23:07 –23:22 47 58 50 43

0.5 W ~40 ~10

• Road traffic reducing, plant noise audible at low level

23:22 -23:37 46 59 48 43

• Plant noise main background noise source. Intermittent traffic along Watery lane contributing to LAeq levels

23:37 –23:52 45 59 47 43

23:52 –00:07 45 56 48 43

00:07 –00:22 44 56 45 43

00:22 –00:37 44 56 45 42

Table 2 Results of Noise Monitoring Survey at Location 1

JH/12/6355NR01A AWN Consulting Limited ________________________________________________________________________________________________________________________________________________________________

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Location Period Time

Measured Noise Levels dB re. 2x10-5 Pa) Weather Conditions

Comments LAeq LAFmax LA10 LAF90

Win

d

Spe

ed

Win

d D

irect

ion

% C

loud

C

over

Tem

p ˚C

Location 2 Day

11:01 62 75 65 51

0.4 SW ~50 ~15

• Road traffic along Watery lane dominates noise levels.

• Vehicles entering and existing offices and adjacent compound.

• BMS audible at very low levels in background.

12:24 61 84 65 53 • As above.

13:34 64 90 67 53

• As above. Machinery within maintenance depot (FCC) source of higher noise levels. (Forklifts, tractors etc. Car horn sounding source of maximum noise levels.

• BMS facility not audible.

Location 3 Day

10:16 53 65 54 51 0.4

SW ~50 ~15

• Plant noise emissions from BMS main background noise source.

• Distant road traffic noise and occasional leaf rustle, pedestrians in park.

• Aircraft x 1

11:25 50 60 51 49 0.6 • As above (no aircraft)

13:12 50 69 50 49 0.7

Table 3 Results of Noise Monitoring Survey at Locations 2 and 3


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3.1 Location 1

During the daytime survey period noise levels were dominated by road traffic passing along Watery Lane to the front of the house and plant noise emissions from BMS to a lesser extent. Occasional activities within the contractors compound were also audible during the survey periods. Ambient noise levels measured during the daytime survey period were in the range of 52 to 53dB LAeq,15mins. Background noise levels were in the range of 45 to 46dB LA90. During the late evening period, road traffic along Watery Lane in addition plant noise emissions were noted to be the main sources of noise at this position. Other sources included overhead aircraft. Ambient noise levels were in the range 46 to 47dB LAeq

and background noise levels were in the range 43 to 44dB LA90. During the night-time period, plant noise emissions from the BMS facility and intermittent road traffic were the main sources noted. Calm wind conditions prevailed during the survey periods. Ambient noise levels were in the range of 44 to 47dB LAeq, with higher levels being recorded at the start of the monitoring period when road traffic was more noticeable. As traffic volumes reduced, ambient noise levels also reduced. This is also reflected in the reduction in the LA10 parameter which reduced from 50 to 45dB over the course of the night-time survey. Night-time background noise levels measured at this location were in the range of 42 to 43dB LA90. This parameter is considered to represent more closely the contribution of plant noise to the overall noise levels. No tones were detected in the 1/3rd octave spectra at this location. No impulsive characteristics were associated with measured noise levels.

3.2 Location 2

During the daytime survey period noise levels were dominated by road traffic passing along Watery Lane, vehicles entering and exiting the Fingal County Council (FCC) offices and occasional activity from the maintenance compound as part of the FCC site. Plant noise emissions from the BMS facility were just audible during lulls in traffic. Ambient noise levels were in the range of 61 to 64dB LAeq,15mins The background noise levels recorded were in the range of 51 to 53dB LA90.

No tones were detected in the 1/3rd octave spectra at this location. No impulsive characteristics were associated with measured noise levels.

3.3 Location 3

During the daytime survey period noise levels were dominated by plant noise emissions from the BMS facility. Other sources included distant road traffic, leaf rustle and pedestrians within the park. Ambient noise levels were in the range of 50 to 53dB LAeq,15mins The background noise levels recorded were in the range of 49 to 51dB LA90.

No tones were detected in the 1/3rd octave spectra at this location. No impulsive characteristics were associated with measured noise levels.


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4.0 DISCUSSION

4.1 Daytime Noise Levels

Noise levels at the three monitoring locations were influenced by a combination of steady plant noise emissions and intermittent sources such as road traffic. Ambient noise levels at monitoring Location 2 were dominated predominately by road traffic.

For instances where a facility’s noise emission levels are artificially high or controlled by extraneous noise sources, the NG4 guidance states the following:

For some noise surveys, the LAF90,T index may be used to give a good indication of the actual noise output from the site, where the noise emissions on site are relatively steady and extraneous noises may unduly influence the measured LAeq,T.

In this instance, road traffic at Location 2 dominated the LAeq measurement and hence a more accurate approximation of the relatively constant facility process noise can be determined by considering the LA90 quantity. Table 4 below summarises both the measured LAeq and LA90 parameters at each location and compares against the daytime noise criterion of 55dB LAeq,30min.

Location Noise Emission

Level (dB, LAeq,15min)

2

Noise Emission Level

(dB, LA90,15min)

Daytime Criterion (dB, LAeq, 15min)

Compliant?

Location 1 52 – 53 45 – 46

55

Yes

Location 2 61 – 64 51 – 53 Yes*

Location 3 50 – 53 49 – 51 Yes Table 4 Review of Measured LAeq,15min and LA90,15min Levels Note * Traffic noise dominated the LAeq parameter at this location, the LA90 parameter is however below

the daytime criterion. In summary, all measured daytime noise levels are in accordance with the daytime EPA criterion. Facility daytime noise emissions would therefore be compliant with EPA licensing requirements.

4.2 Night-time Noise Levels

Night-time noise levels were monitored at one location representative of the closest noise sensitive location. Noise levels at this location were influenced by plant noise and road traffic. The results of both the LAeq and LA90 parameters are presented in Table 5 and compared against the night-time noise criterion of 45dB LAeq,15min.

Location Noise Emission

Level (dB, LAeq,15min)

1


(dB, LA90,15min)

Night-time Criterion (dB, LAeq, 15min)

Compliant?

Locaton1 44 - 47 42 - 43 45 Yes* Table 5 Review of Measured LAeq,15min and LA90,15min Levels Note * Traffic noise contributed to the LAeq parameter at this location, particularly at the start of the

monitoring period. The steady background noise level, represented by the LA90 parameter is however below the night-time criterion.

2 It should be noted for this assessment no tonal or impulsive noise emissions were identified in relation to

noise emissions form the facility. Therefore, in this instance LAeq is equal to LAr T.


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In summary, the measured night-time noise levels are in accordance with the night-time EPA criterion. Facility night-time noise emissions would therefore be compliant with EPA licensing requirements.

4.3 Comparison Against Previous Survey

The range of noise levels measured at over the course of the annual noise survey during 2011 are compared against those recorded during the most recent 2012 survey. The values for 2012 are an average of the daytime and night-time survey periods.

Location Year

Daytime Night-time Noise Emission

Level (dB, LAeq,T)


(dB, LA90)


(dB, LAeqT)


(dB, LA90)

Location1 2011 53 48 49 46

2012 52 46 46 43

Location 2 2011 69 55

2012 62 52

Location 3 2011 56 55

2012 51 50 Table 6 Comparison of 2012 Survey Results Against 2011 Survey Results

Noise levels recorded during the 2011 survey were noted to be higher than those

recorded during 2012. This was noted to be predominately due to the influence of higher wind speeds and rustling foliage during the 2011 survey. During the 2012 survey calm conditions prevailed and background noise levels were dominated more by steady plant noise.

4.4 Estimate of Specific Plant Noise Levels

A requirement of the EPA NG4 documents is that specific noise levels at noise sensitive locations be measured and/or estimated as part of the annual noise monitoring report. The following methodology has been adopted in order to complete this aspect of the assessment:

Description of Site Noise Noise Parameter that Best Represents Specific

Noise from Site Category Subjective Impression

A Site noise dominant, no other significant noise sources noted.

LAeq,T

B Intermittent noise from other sources (e.g. traffic, birds, wind), with underlying site noise audible.

LA90,T if frequent interfering noise and site noise is audible in lulls. or LA50,T if site noise is clearly audible (steady of variable), with occasional interference from other sources.

C Plant barely audible (i.e. not immediately noticeable, unless actively listening)

<LA90,T (i.e. specific plant noise is up to 5dB lower than measured LA90,T)

D Plant not audible Not Detected, ND <<LA90,T (more than 5dB lower than LA90,T)

Table 7 Methodology for Determination of Site Specific Noise

The estimated specific noise level at each monitoring location is presented in Table 8 below based on the methodology set out above.


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Location Period Site Noise Category

Noise Parameter that Best

Represents Specific Noise

from Site

Estimated Specific Plant

Noise, dB

Within Criteria?

Location 1 Daytime B LA90 46 Yes

Night-time B LA90 43 Yes

Location 2 Daytime C <LA90 ~47 Yes

Location 3 Daytime A LAeq 51 Yes

Table 8 Estimation of Specific Noise Levels at Monitoring Locations The results of the assessment has demonstrated that specific noise levels associated with plant noise emissions from the BMS facility are well below the emission limit values set out within the relevant sections of its IPPC licence.


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5.0 CONCLUSION

Noise levels have been measured at the locations stipulated in the relevant IPPC Licence. Audible noise sources include traffic on surrounding roads and steady plant noise emissions from the BMS facility. Taking account of the various sources contributing to noise levels at the monitoring locations, the specific noise levels associated with the BMS facility were found to be within the daytime noise criterion of 55dB LAeq, 15mins.

Night-time noise monitoring was conducted at one location representing the closest noise sensitive property to the facility. The specific noise associated with the BMS facility was found to be 43dB(A). In this instance, the facility is considered to be within the night-time noise criterion of 45dB LAeq,15mins. In addition, review of one-third octave band data confirms that there is no tonal component to measured noise levels. No impulsive noise sources were observed during the survey periods. It may therefore be concluded that this facility is in compliance with Schedule 4 of the IPPC Licence in respect of noise.


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APPENDIX A

GLOSSARY OF ACOUSTIC TERMINOLOGY

ambient noise The totally encompassing sound in a given situation at a given time,

usually composed of sound from many sources, near and far.

background noise The steady existing noise level present without contribution from any intermittent sources. The A-weighted sound pressure level of the residual noise at the assessment position that is exceeded for 90 per cent of a given time interval, T (LA90,T).

criterion noise level The long-term mean value of the noise level that must not be

exceeded. This is generally stipulated in the IPPC/Waste licence and it may be applied to a noise source, a boundary of the activity or to an NSL in the vicinity of the site.

dB Decibel. The scale in which sound pressure level is expressed. It is defined as 20 times the logarithm of the ratio between the RMS pressure of the sound field and the reference pressure of 20 micro pascals (20 µPa).

free-field These are conditions in which the radiation from sound sources is unaffected by the presence of any reflecting boundaries or the source itself. In practice, it is a field in which the effects of the boundaries are negligible over the frequency range of interest. In environmental noise, true free-field measurement conditions are seldom achieved and generally the microphone will be positioned at a height between 1.2 and 1.5 metres above ground level. To minimise the influence of reflections, measurements are generally made at least 3.5 metres from any reflecting surface other than the ground.

LAeq This is the equivalent continuous sound level. It is a type of average

and is used to describe a fluctuating noise in terms of a single noise level over the sample period (T).The closer the LAeq value is to either the LAF10 or LAF90 value indicates the relative impact of the intermittent sources and their contribution. The relative spread between the values determines the impact of intermittent sources, such as traffic, on the background.

LAFmax The maximum rms A-weighted sound pressure level occurring within

a specified time period. Measured using the “Fast” time weighting.

LAF10 Refers to those A-weighted noise levels in the top 10 percentile of the sampling interval; it is the level which is exceeded for 10% of the measurement period. It is used to determine the intermittent high noise level features of locally generated noise and usually gives an indicator of the level of road traffic. This parameter was measured using the “Fast” time weighting.

LAF90 Refers to those A-weighted noise levels in the lower 90 percentile of

the sampling interval; it is the level which is exceeded for 90% of the measurement period. It will therefore exclude the intermittent


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features of traffic and is used to describe a background level. This parameter was measured using the “Fast” time weighting.

1/3 octave band analysis

Frequency analysis of sound such that the frequency spectrum is subdivided into bands of one–third of an octave each.

A-weighting The “A” suffix denotes the fact that the sound levels have been “A-

weighted” in order to account for the non-linear nature of human hearing. All sound levels in this report are expressed in terms of decibels (dB) relative to 2x10-5 Pa.


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APPENDIX B

CALIBRATION CERTIFICATES OF MONITORING EQUIPMENT


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APPENDIX C

ONE-THIRD OCTAVE BAND CENTRE FREQUENCY DATA (TABULAR)

Loc. Period Time (hrs)

Measured Noise Level, (dB Leq) at 1/3 Octave Frequency Band (Hz)

L Aeq

(dB

)

50

63

80

100

125

160

200

250

315

400

500

630

800

1k

1.25

k

1.6k

2k

2.5k

3.15

k

4k

5k

6.3k

8k

10k

Loc 1

Day

12:00 58 56 54 53 45 43 44 42 42 42 42 42 44 45 42 41 40 42 38 38 37 35 33 29 53

12:46 59 55 52 50 45 44 45 43 42 41 42 42 43 44 42 41 39 41 36 39 37 33 32 27 52

13:56 58 55 52 49 45 44 43 43 42 41 42 42 44 45 43 40 39 39 35 33 32 29 26 -- 52

Night

22:00 53 51 52 47 41 41 40 40 38 38 37 37 38 40 38 36 34 33 30 28 27 22 -- -- 47

22:33 55 54 49 46 41 40 40 39 38 38 38 38 39 40 38 37 34 32 30 28 26 22 -- -- 47

22:52 51 49 48 46 41 40 40 39 39 38 37 37 37 37 36 36 34 33 32 30 29 26 23 20 46

23:07 52 49 48 47 42 41 41 41 41 39 38 38 38 40 38 36 34 32 30 27 26 22 -- -- 47

23:22 51 48 47 46 41 40 39 39 38 37 37 37 37 38 36 35 33 31 29 27 25 21 -- -- 46

23:37 51 48 47 45 39 39 39 39 37 37 36 36 37 38 36 35 33 30 29 26 25 21 -- -- 45

23:52 52 55 47 45 40 39 39 39 37 37 36 36 36 37 36 34 32 30 28 26 25 20 -- -- 45

00:07 51 48 47 45 39 40 39 39 37 37 36 36 35 36 35 33 32 30 28 26 25 20 -- -- 44

00:22 51 48 47 44 39 40 39 39 37 38 36 35 35 35 34 33 32 30 28 26 25 22 -- -- 44

Loc 2 Day

11:01 67 63 63 58 56 55 54 53 52 51 51 51 53 54 53 50 48 46 45 46 46 37 35 36 62

12:24 67 65 58 59 56 55 54 54 52 51 51 52 53 54 52 51 48 47 43 41 39 36 35 30 61

13:34 66 68 67 65 59 57 57 56 55 55 54 54 55 56 54 53 52 50 48 45 43 40 37 34 64

Loc 3 Day

10:16 60 58 56 55 54 53 51 47 49 46 47 46 44 42 41 40 39 35 32 30 28 26 24 -- 53

11:25 60 58 56 57 55 51 47 42 42 41 40 42 41 41 40 38 36 35 33 31 29 26 24 -- 50

13:12 59 57 55 56 53 50 48 43 41 40 39 40 41 41 40 37 35 35 32 29 27 25 -- -- 50

Note: ’--‘ Denotes measurement value is below the dynamic range of sound level meter, i.e.<20dB


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Measurement Location 1: One Third Octave Band Results (Graphical)

Figure C1 Daytime: 12:00 – 12:15hrs Figure C2 Daytime: 12:46 – 13:01hrs Figure C3 Daytime: 13:56 – 14:11hrs

Figure C4 Average Evening: 22:00 – 23:00hrs Figure C5 Average Night: 23:00– 00:00hrs Figure C5 Average Night: 0:00– 01:37hrs


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JH/11/5794NR01 AWN Consulting Limited _____________________________________________________________________________________________________________________

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Appendix G

Solvent Management Plan

P0014-04 AER 2012


1 2012 Solvent Management Plan, Swords Laboratories. AER 2012

Solvent Management Plan 2012

for Swords Laboratories

Clean Technology Centre 53 Melbourne Road Bishopstown Cork



Table of Contents

1 Introduction

2 Description of the Solvent Management Plan

3 Results and Comments

4 Recommendations

Appendix 1 Overall Solvent Management Plan Results

Appendix 2 Terminology Used and its Relation to the Solvents Directive



1 INTRODUCTION

The Clean Technology Centre has carried out a solvent mass balance at Swords

Laboratories for the period January 2012 to December 2012. The overall results of the

solvent management plan are given in Appendix 1.

Ten solvents are included in the solvent mass balance, namely acetone, acetonitrile, ethanol,

ethyl acetate, isopropanol (IPA), methanol, methylene chloride (DCM), methyl isobutyl ketone

(MIBK) and toluene. The usage of N-methyl-2-pyrrolidone (NMPO) has increased and is thus

included in the 2012 SMP. The solvents listed are stored in bulk and constitute the majority of

solvents at the site in terms of usage.

Five additional solvents are also used in the facility namely heptanes, butanol,

tetrahydrofuran (THF), isopropylacetate and cyclohexane are also used in the facility.

Combined these solvents account for only 4% of the total solvent throughput and are

therefore not assessed further in this solvent management plan. These solvents are totaled

together and referenced as ‘Other NMVOCs”.

It is intended to report this category of ‘Other NMVOCs’ in 2013 and to report in detail those

solvents that represent 90-95% of the total solvent usage.

2 DESCRIPTION OF THE SOLVENT MANAGEMENT PLAN

A list of the terminology used in the Solvent Management Plan is given in Appendix 2. The

following paragraphs describe the main terms used in the solvent management plan, and the

sources of information for such terms.

Fresh Solvent Input

The input stream for the solvent mass balance consists of the sum of the individual goods

receipts for each solvent and the virgin solvent change of inventory (COI) as recorded in the

in-house solvent mass balance spreadsheet.

Recovered & Reused Solvent

The volumes of solvent recovered on-site are recorded and summarized in in-house

spreadsheets. The difference between the inventory of the recovered solvent tanks at the

start and end, together with the total recovered amount, gives solvent recovered and reused

at the site.

Total Solvent Input or Usage

This figure is based on the sum of fresh solvent purchased and used, and solvent recovered

and used.

Licensed Emissions to Air

Licensed emissions to air consist of the thermal oxidiser (TO) Vent 130 and 7 different vents

(via scrubbers) when the TO is off-line.



Thermal Oxidiser (TO)

Emissions from the thermal oxidiser vent during operation have been calculated using the

total kg of carbon emitted from the TO for the year, obtained through regular monitoring. This

has been attributed to the various solvents in use in proportion to the throughput of each

solvent at the site.

Licensed Emissions when TO is Off-line

When the thermal oxidiser is off-line, process emissions are vented through a number of

licensed vents. The operation of processes, particularly those involving DCM is minimized,

during periods when the TO is not operational. Emissions from these vents when the TO is

down have been calculated based on TO downtime memos submitted by all plant managers.

These memos detail the processes and unit operations that were being performed during

such downtime and solvent volumes involved. Using this detailed information and engineering

estimates of emissions associated with such processes, the quantity of emissions emitted

during the TO downtime have been calculated.

Additionally licensed emissions are generated from solvent storage tanks and building

ventilation which are connected to the TO, when the TO is off-line. The emissions are based

on the total hours of TO downtime for the year.

Fugitive Emissions to Air

Fugitive emission sources at Swords Laboratories are from the tank farm (apart from a

number of tanks which are connected to the TO), building vents not connected to the TO,

waste water treatment plant emissions through the biofilter when the TO is offline, and any

components external to production buildings.

Tank Farm Emissions to Air

The number and type of solvent storage tanks in the P8, P2 and Solvent Recovery tank farms

has changed substantially in recent years. Solvent storage tanks consist of tanks containing

fresh solvent, tanks containing recovered solvent, and tanks containing waste for either

disposal or on-site/off-site recovery. The majority of these tanks are underground storage

tanks.

Up to 2007 there were 33 storage tanks at the site containing solvent or solvent-related

waste. All of these tanks vented to atmosphere apart from TK8 [fresh DCM], and TK11 and

TK12 which were connected to the TO.

In mid 2008 seven of these underground tanks were removed and replaced with five vertical

above ground tanks (TK15, TK16, TK17, TK18, TK19). These above ground tanks, which are

painted white to minimise breathing losses, are all connected to the TO. In 2009 an additional

number of the original underground tanks were removed and replaced with new tanks, which

are connected to the TO.

In early 2010 the waste DCM storage tank (TK41), which had been painted white in previous

years to minimise emissions, was connected to the TO.



Fugitive emissions were estimated using the USEPA software TANKS 4.0.9d. These

emissions were scaled up based on tank throughputs and composition, which was obtained

through waste analysis by Swords Laboratories.

For those tanks which are connected to the TO, an estimate of emissions to atmosphere was

made for when the TO was off-line based on the total hours of TO downtime for the year.

Building Vents Not Connected to the TO

These are fugitive emissions associated with general building ventilation systems that are not

connected to the TO. An estimate of such emissions was made using flow data for individual

vents, information on whether such vents are connected to the TO or not, and relevant

occupational solvent monitoring from recent years within the production buildings, where

available. The emissions from this source are minimal in comparison to the other fugitive

emission sources

WWTP Biofilter Emissions

Emissions to air from the wastewater treatment plant were directed to the TO throughout the

year. During the TO downtime these emissions are vented directly through the biofilter. These

emissions were calculated using estimates of solvent stripped to air within the waste water

treatment plant and the monitored solvent removal efficiency of the biofilter.

Components External to Production Buildings

For this mass balance no estimate has been made regarding process components such as

flanges, pump seals, valve stems, etc. Previous monitoring at the site (within buildings and at

the tank farm), as well as extensive monitoring in the Irish Pharmachem industry has shown

such emissions to be negligible. Emissions from such components within production buildings

will be captured by building ventilation. Hence it is deemed that the only components of future

relevance would be those on process lines external to production buildings. This would

include lines between the tank farm and production buildings, as well as lines to and from the

solvent recovery plant, components within the solvent recovery plant itself, and to a lesser

extent, lines to the waste water treatment plant (dilute stream).



Summary of Air Emissions

Summary information on licensed and fugitive air emissions is as follows:

Licensed Emissions Fugitive Emissions

Emitted during TO downtime (kg)

Building Ventilation not connected to TO

(kg)

Storage Tanks not connected to TO (kg)

WWTP biofilter during TO downtime (kg)

TOTAL

(kg)

Acetone 99.69 32.3 746 1.81 780

DCM 198.69 85.5 205 1.15 292 Methanol 25.7 236 0.02 236

Ethyl Acetate 35.7 126.7 0.51 127 Acetonitrile 14.44 92.4 0.005 92

IPA 58.07 38.6 0.03 39 MIBK 0.001 20.3 0.5 0.02 21

Ethanol 21.63 13 13 Toluene 0.008 4.9 0.0002 5 NMPO 1.9 0.1 0.1

Other NMVOCs 0.221 153 153

Total 456 138 1,617 3.5 1,758



Solvent discharged to Sewer

Monitoring of effluent from the WWTP for specific solvents is carried out on a monthly basis.

Total daily flows from the WWTP are recorded by a flowmeter. The total mass of solvent sent

to sewer is calculated using these measured parameters.

Consumed

The consumed term consists of solvent biodegraded in the waste water treatment plant and

solvent treated by the site’s thermal oxidiser.

Solvent Biodegraded in the WWTP

Monitoring of the influent and effluent from the WWTP for specific solvents is carried out on a

monthly basis. Total daily flows from the WWTP are recorded by a flow meter.

Drummed waste solvent is added to the WWTP over periods of low production to feed the

WWTP. Additionally solvent spillages from some areas on site drain to the WWTP. The

balance tanks have an average residence time in 2012 of approximately 3.3 days. Analysis of

influent to the waste water treatment plant is carried out on a monthly basis. Those additions,

which occurred outside the 3 days of a sampling period, would not have been captured in the

analysis and are included as an extra load.

For 2012 drummed solvent additions composed of approximately 1100 litres methanol, 1000

litres IPA distillate, and 100 litres acetone waste. Any spillages that drained to the WWTP

were included as extra loads.

The difference between the solvent load in tonnes per year in the influent and the effluent

from the WWTP gives the amount of solvent that is either biodegraded or is stripped to air

from the WWTP. Under normal operation a certain amount of solvent in the influent will be

stripped through agitation in the balance tanks or aeration within the carousel. This stripped

solvent is collected and vented to the biofilter/TO. The fraction of solvent that is stripped and

the fraction that is biodegraded in the WWTP were determined through the utilisation of a

USEPA software programme, WATER8.

Solvent Treated by the TO

Solvent treated by the TO is made up of process emissions, building vents connected to the

TO, emissions from the solvent recovery plant when operational, emissions from the WWTP

and vent emissions from a large number of tanks connected to the unit. Estimates for process

emissions treated by the TO consist of:

- Estimates of process emissions associated with distillations at the site. Estimates

were calculated based on distillation hours per batch, batches per year, equipment in

use, and engineering estimates of associated emissions. Engineering estimates or

modeled emissions rather than actual measured emissions were used.

- Solvent from building vents treated by the TO was estimated based on which vents

were connected, fan ratings, occupational solvent monitoring within the production

buildings, where available, and the associated process durations.



- Solvent from the WWTP treated by the TO was estimated using the quantity of

solvent stripped to air in the WWTP (see above) and subtracting the quantity of

solvent emissions that passed directly through the biofilter during TO downtime.

- Solvent from solvent recovery plant operation treated by the TO was estimated based

on the volumes recovered, typical batch size and duration, and engineering estimates

of associated emissions. It was assumed that the solvent recovery plant was not

operational during any of the TO shut downs.

- Solvent emissions from the solvent storage tanks treated by the TO was estimated

based on emissions estimates for these tanks minus the emissions to air during TO

downtime. The tanks that are connected to the TO are TK08, TK 11 and TK12 in the

P8 Tank Farm, TK15, TK16, TK17, TK18, TK19 and TK41 in the Solvent Recovery

Tank Farm and TK20, TK21, TK22, TK23 in the P2 Tank Farm.

For the SMB in 2004 and 2005, monitoring of the feed stream to the TO was carried out for a

number of months. This was used as one method to estimate the solvent treated by the TO.

However, due to persistent problems experienced with this sampling, this practice has been

discontinued. In 2011 it was determined that the monitoring of the feed stream is currently not

feasible due to wide variation in production processes onsite.

Waste Offsite

Waste off-site consists of solvent waste sent for disposal and a certain amount for recovery.

The waste contractor provides summary data on the unit weight of each load with analysis

per load undertaken by Swords Laboratories. Where the contents of a bulk tank are shipped

in two separate tankers the bulk tank is analysed with the analysis applied to both tankers.

The quantity of packaged waste is also recorded with solvent composition analysed on a

regular basis.

Accumulation

Accumulation of solvent is the difference in the quantities of solvent between the start and

end of the period of the solvent mass balance in waste tanks and drums, and in the recovered

solvent tanks. The inclusion of this term differentiates between waste generated and that

which has actually been shipped, and also differentiates between solvent recovered and

actually reused.



3 MASS BALANCE RESULTS AND OBSERVATIONS

RESULTS – UNACCOUNTED SOLVENT

The quantity of unaccounted solvent in the mass balance is calculated using the following

equation:

Unaccounted = Input fresh solvent – Output - Accumulation

The table gives a breakdown of unaccounted solvent for 2011 and for 2012, expressed as a

percentage of usage or throughput, for each solvent in use.

Solvent

% Unaccounted2012

% Unaccounted 2011

Proportion of total solvent

usage, 2012 (%)

Acetone -4.5% 8.1 % 28%

DCM 12.5% -9.6% 26.7%

Methanol 11.7% 2.9 % 16.4%

Ethyl acetate 6.2% 26.9 % 8.5%

Acetonitrile -5.4% -34.2 % 2.7%

IPA 12.9% 12.4 % 8.2%

MIBK -75.25% 45.9 % 0.1%

Ethanol

(SD3A alcohol) 10.2% -0.08 % 2.2%

Toluene -23.4% 26.1 % 0.9%

NMPO 13.25% - 2.3%

Other NMVOCs 16%

(Five solvents)

5.2%

(Three solvents only) 4.2%

The overall unaccounted value for total bulk solvent usage onsite in 2012 is estimated to be

6.3% of total solvent usage, increased from a value of 3.2% in 2011. It must be noted that the

2012 unaccounted values includes the tracking of two additional solvents.

The positive unaccounted figures show that there is more solvent in the input than in the

output streams, and the negative vice versa. The negative unaccounted figures for MIBK and

Toluene could be viewed as relatively high. The reason behind these high net negative

unaccounted figures is mainly because either solvent treated by the TO is over-estimated

estimated or the relevant composition of the waste is over-estimated. Additional comments

are given under Observations below.

RESULTS – FUGITIVE EMISSIONS

For corporate reporting purposes fugitive emissions consists of emissions of solvent to air

other than through the main waste gas stacks. Fugitive emissions results for the site are

summarised in the following table expressed as a percentage of total usage or throughput.



Solvent

Fugitive emissions to air

(tonnes)

Fugitive emissions to air

(% of throughput or usage)

Acetone 0.78 0.05 %

Acetonitrile 0.09 0.06 %

MIBK 0.021 0.4%

Ethyl acetate 0.127 0.03%

Methanol 0.24 0.03%

DCM 0.29 0.02%

Ethanol 0.013 0.01 %

IPA 0.039 0.009%

Toluene 0.005 0.01%

NMPO 0.0001 0.0001%

Other NMVOCs 0.15 0.07%

Total 1.76 0.05%

of Total Throughput or Usage

OBSERVATIONS

Emissions to air

Total emissions to air in 2012 reduced slightly from 2011 levels. Comparison between

emissions in 2011 and 2012 is best undertaken by expressing the total emissions in terms of

overall solvent usage or throughput, as shown in the following table.

Solvent

Emissions to air, % of total solvent throughput

2012

Emissions to air, % of total solvent throughput

2011

Acetone 0.06% 0.08 %

Acetonitrile 0.07% 0.08%

MIBK 0.4% 0.06 %

Ethyl acetate 0.04% 0.03 %

Methanol 0.03% 0.03 %

DCM 0.04% 0.03 %

IPA 0.02% 0.01 %

Toluene 0.01% 0.01 %

Ethanol 0.03% 0.01 %

NMPO 0.002% -

Other NMVOCs 0.04% -

The following points in relation to air emissions should be noted:

- The licensed emissions have increased marginally for all solvents due to a slight

increase in the process emissions during TO downtimes.



- The reduction in fugitive emissions is attributed to a reduction in the fugitive

emissions from the tank farm. This is attributed to the increased use of solvent

storage tanks connected to the TO and the reduced throughput of some solvents.

- The continuous improvement in the storage tank farm has significantly reduced the

fugitive emissions produced in previous years. These improvements include the

replacement of tanks, painting of tank shells and connection of vents to the TO. The

proposed connection of the acetone storage tanks to the TO in 2014 will further

reduce fugitive emissions.

Unaccounted solvent

The overall unaccounted value for total bulk solvent usage onsite in 2012 is estimated to be

6.3% of total solvent usage, increased from a value of almost 3.21% in 2011. The 2012 value

includes the inclusion of two additional solvents.

The percentage unaccounted solvent in the SMP is poor for some of the solvents – namely

NMPO, toluene and MIBK. In total, these solvents only account for 3.3% of the total solvent

usage onsite. Therefore a high-unaccounted value for these solvents would not be critical in

the overall accuracy of the SMP. Possible reasons for these unaccounted values are given

below:

o NMPO: The unaccounted value at 13% is encouraging considering that this is the first year

that the solvent is tracked in detail. The unaccounted value is due to the under-

estimation of the waste solvent consumed in the TO or sent off-site for treatment.

o Toluene The unaccounted value for toluene at -23% is high, but represents a slight

improvement on the 2011 unaccounted value. Toluene accounts for only 0.9% of the

total solvent usage onsite, therefore a high-unaccounted value for this solvent is not

critical in the overall accuracy of the SMP

o MIBK: The usage of MIBK has greatly reduced from 58 tonnes in 2011 to 5 tonnes in 2012,

with no solvent purchased in 2012. The infrequent use of this solvent and its low

content in the waste, results in this solvent being difficult to track. MIBK accounts for

only 0.1% of the total solvent usage onsite, therefore a high-unaccounted value for

this solvent is not critical in the overall accuracy of the SMP

TO Downtime Memo System

The memo system for TO downtimes provides a more exact picture as to what is actually

occurring within a production building during the shutdown period and hence should lead to a

more accurate emissions estimation.



The memo template, which was adopted in 2004 has resulted in a more organized

identification system of those processes which are of concern in the estimation of emissions

during TO downtimes.

In 2007 the memo downtime format was revised to incorporate a column detailing the exact

time span that the operation was actually in progress during the TO shutdown. In order to

ensure the accuracy of emissions during the TO downtime it is essential that the plant

managers detail the actual time of the downtime applicable to the process steps.

In 2008 the TO downtime memos were further improved to detail the quantity of solvent

involved in the process step.

In 2010 and 2011, to further improve the estimation process, plant managers and operators

were contacted to provide further details for those downtime periods where large solvent

emissions were estimated, based on the information provided.

In 2012 the memo template was further improved to allow staff to indicate the volume of

solvent in the vessel at the end of the process, to determine the maximum level of solvent

involved, whether reflux conditions were in place, and specific information on drying steps,

which can be a significant source of emissions.

In summary, the continuous revision of the TO memo helps to provide more accurate detail in

determining the process emissions during the TO downtime.

Monitoring in Water Treatment Plant Influent and Effluent

The monitoring for certain solvents, particularly those included in the SMB, in the influent and

effluent to/from the waste water treatment plant has been ongoing since 1995. This

monitoring allows for more accurate fugitive emissions from the WWTP and final emissions to

sewer to be determined.



4 SOLVENT MASS BALANCE RECOMMENDATIONS

Recommendations have been divided into those that would reduce emissions from the site

and those that would improve the accuracy of the solvent mass balance.

The following would help reduce the level of emissions from the site:

Connection of storage tanks with large turnovers to the TO

A large number of solvent storage tanks are now either connected to the TO or

painted white to minimise fugitive emissions from the tank. These tanks, which in the

main contain mixed waste and virgin and recovered volatile solvents such as DCM,

contribute the largest quantity of breathing and working losses.

There are a limited number of virgin and recovered solvent tanks with large turnovers

that may be painted or connected to the TO in future years, where feasible, to

minimise fugitive emissions to air e.g. TK05 and TK06.

Budgets allowing, in 2014 the facility plans to connect the acetone storage tanks

TK06 and TK40, to the TO, to significantly reduce fugitive acetone emissions.

The following measures would improve the accuracy of the solvent mass balance:

Continued use of the revised TO downtime memo system incorporating solvent at

start and end of process and time element for longer shutdowns.

Distillations Estimates

TO feed measurement

Solvent waste tanks composition analysis

Distillations Estimates

There are many assumptions inherent in the method used to calculate solvent treated by the

TO. Such assumptions include saturated air, estimates for air flow rates and the identification

of the vessels used. CTC believe that the volume treated by the TO may be over-estimated

for a number of solvents. The facility will continue to consider alternative methods.

TO Feed Measurement

The most accurate method to determine the quantity of solvent being treated or consumed by

the thermal oxidiser is to sample and monitor the feed stream. A number of sampling

campaigns have been undertaken in previous years with a limited number of campaigns

undertaken in 2006. However this sampling and monitoring program was discontinued due to

problems with the monitoring and analysis equipment.

In 2011 it was determined that the monitoring of the feed stream is currently not feasible due

to wide variation in production processes onsite.

Waste Solvent Tank Analysis

In the Pharmachem sector the solvent waste stream sent offsite for treatment is often the

largest output stream in the input-output assessment of the Solvent Management Plan.

Therefore in order to accurately estimate the solvent waste it is important to ensure that the



analysis of the waste tankers is as accurate as possible. Each individual tank shipment is

sampled to ensure an adequate representation of the waste.



Appendix 1 Overall Solvent Mass Plan Results

FRESH SOLVENT

CONSUM. OUTPUT ACCUM UNACCOUNTED

tonnes Purchased

(P) COI

P + COI

Recovered & Reused

INPUT or

USAGE

in WWTP

by TO

Total Consum

Air - Licensed

Air - Fugitive

To Sewer

recov off-site

waste generated

Accum on-site Unacc % Unacc

Acetone 726.88 15.3 742 719 1,461 17 91 108 0.1 0.78 0.25 120 619 -40.2 -66 -4.49%

Acetonitrile 146.75 -3.4 143 0 143 0.1 2 2 0.014 0.09 0 29 120 0.50 -8 -5.44%

Ethyl Acetate 437.49 4.0 441 0 441 7.87 4 12 0.04 0.13 0 74 327 1.15 27 6.22%

IPA 419.13 7.1 426 0 426 11.0 0 11 0.06 0.039 0.03 105 252 2.6 55 12.85%

Methanol 877.66 -23.7 854 0 854 11 3 15 0.025 0.24 1.68 134 598 5.29 100 11.70%

MC 1248.6 -20.2 1228 165.41 1,394 10.72 225 236.13 0.2 0.29 0.03 408 588 -177.9 174 12.48%

MIBK 0 4.9 4.92 0.00 5 0.19 0.04 0.23 0 0.02 0 0 8 0.03 -3.71 -75.33%

Toluene 48.43 -3.2 45 0.00 45 0.00 0.11 0.11 0 0.005 0 3 52 0.13 -10.59 -23.41%

Ethanol 135.08 -22.6 112 0.00 112 4 0 4.05 0.02 0.01 0 0 95 1.69 11.47 10.20%

NMPO 132.8 -14.3 119 0.00 119 3 0 2.87 0.002 0.0001 0.08 22 76.65 0.97 15.70 13.25%

Other NMVOCs 212 3 215 0 215 0 0 0 0 0.15 1 70 109 0.15 35 16%

Total 4,385.15 -52.92 4,332 884.01 5,216 64.98 327 391.65 0.46 1.76 3.06 965.11 2,844.92 -206 331 6.34%



Appendix 2: Terminology Used and its Relation to the Solvents Directive

Shorthand used in Solvent

Management Plan Description

Purchased + COI Annual virgin solvent purchases plus the change in inventory (COI) of virgin solvent (tanks and drums) between the start and end of the year.

Recovered & Reused Solvent recovered and reused on-site. Consists of actual recovered amounts and the change in inventory of recovered solvent.

Input or Usage Throughput or usage of solvent in the production and pilot plants (corresponds to Gross Usage in current PER terminology)

Air - Licensed Solvent lost to air through licensed emission points (TO and scrubbers). To Sewer The quantity of solvent discharged to sewer from the outflow of the waste water treatment plant.

Lost to Product The quantity of any solvent present as a contaminant in the finished product. (Assumed zero). Air - Fugitive Solvent lost to air other than through licensed emission points. Includes tanks not connected to the TO,

building vents not connected to the TO, the waste water treatment plant when the TO is off-line/not connected, and any components external to production buildings.

Consumed in WWTP & Consumed by TO

Solvent treated by the site’s thermal oxidiser and biodegraded in the site’s waste water treatment plant.

Waste generated The quantity of solvent waste generated. Consists of solvent sent off-site for disposal and change in relevant waste tank inventories.

- Not relevant to the site. Any solvent present in products will be as a contaminant only. Recovered off-site Solvent sent off-site for recovery and reuse in other applications (including use as a fuel).

- Not relevant to the site. Unaccounted The difference between fresh solvent input and solvent output and accumulation. Illustrates the accuracy of

the solvent mass balance. Accumulation Change in the quantity of solvent in the plant – namely the recovery plant tanks. Used in the unaccounted

calculation.

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