Environment Protection/Health & Safety File Record Sheet.HAZOP Procedure - 3 11 .OO 1, Basis of Process Safety Report - 3 11.002 Basis of Safety & Environmental Protection - 60 1.030

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Page 1 of 1 SAFETY & ENVIRONMENTAL ATTACHMENT I SOP

601.032 Effective Date: TITLE: FILERJKORDSHEET. Revision No: 0 Date: 14/06/02

Prev Rev No: Dated:

Environment Protection/Health & Safety File

Record Sheet.

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EPA Export 25-07-2013:15:30:44

REVISION LOG

SOP TITLE: MANAGEMENT OF PROCESS SAFETY 1 SOP NUMBER/CODE: 601.032

REVISION NO. REQUESTED BY: REASON FOR REVISION EFFECTIVE DATE

0 DH To create new SOP

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SOP TITLE:

MANAGEMENT OF PROCESS SAFETY

I acknowledge receipt of the above SOP.

I have destroyed (returned in the case of Master BMI’s and CPs) the superceded revision of the SOP.

Signed: Department:

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SAFETY & ENVIRONMENTAL PROCEDURE

TITLE: PRELIMINARYHAZARDASSESSMENT

Page 1 of 4

SOP 601.031 Effective Date:

Revision No: 0 Date: 13.06.02 Prev Rev No: Dated:

1.0 PURPOSE

To describe the process used to complete a Preliminary Hazard Assessment on new or existing processes or equipment so as to assess their Major Accident Potential and the controls necessary to eliminate those hazards or mitigate their consequences if realised.

Note:- This SOP forms part of a suite of SOP’s relating to the management of process safety which is governed by SOP 601.032. Other Operational SOP’s which form part of this suite of SOPS include: Chemical Reaction Hazards - 940.001, Equipment Proposal Report - 2 11 .Ol 1 Preliminary Hazard Assessment - 601.03 1, Equipment Evaluation & Selection - 301.003 HAZOP Procedure - 3 11 .OO 1, Basis of Process Safety Report - 3 11.002 Basis of Safety & Environmental Protection - 60 1.030.

2.0 PROCEDURE”

2.1 Preliminary Hazard Assessment (PHA) is a technique used to identify the major hazard potential of a process or item of equipment.

Unlike HAZOP which focuses on the minute detail of a process, PHA takes a broader view of the process or item of equipment in order to: > Identify the Major Hazard Potential k The events which would cause the Hazard to be realised > The consequences of the Hazard being realised.

The PHA does not give an accurate assessment of the frequency of any incident nor does it specify the measures used to control the Hazard. The technique has particular importance in identifying the worst accident which might occur such as the greatest fire, explosion, toxic gas release, or incident with a major public safety /enviromnental~mpact.

2.2

2.3

Written By :

Derrnot Hanrahan,, Safety & Env Offker.

Date:

Approved By:

Approved By:

John O’Donoghue, Safety & Env Mgr.

Approved By:

Approved By:

Frances Martin, BPC Manf. Mgr.

Approved By:

Approved By:

Peter Holly, Tech. Services Leader

Mary Shire, Bernie Harten, Werner Kunz, NPD Mgr. Nitrates Manf. Mgr. Pharma Manf. Mgr.

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‘,


TITLE: PRELIMINARY HAZARD ASSESSMENT

Page 2 of 4



2.4

2.5

0 2.6

2.7

2.8

2.9

For a PHA study it is not necessary to determine exact frequencies of events however it is essential that events with Major accident potential are identified so that they may be effectively analysed so that the necessary controls can be put in place.

Site major hazards generally fall into the following categories: 9 Explosions and Fires. 9 Toxic Gas Releases. 9 Environmental Impact.

The Safety and Environment Officer and PHA Leader has responsibility for scheduling and documentation of all PHA requiring completion as identified by Change Control.

The Preliminary Hazard Assessment meetings will be attended as necessary by: 9 NPD Chemist with responsibility for the Process 9 Tech. Services Engineer with responsibility for the Process introduction. 9 Technical Representative from the customer department. 9 Any other persons deemed necessary to assist in the completion of the PI-IA.

In order to ensure the efficient completion of the study the NPD Chemist must ensure that details relating to the following are available at the meeting : 9 The Process Description 9 MSDS Data for the chemicals used in the process 9 Thermochemical data for the process 9 Compatibility data 9 Data on gas generation where appropriate.

This data will in general form the bulk of the Chemical Reaction Hazard Report which is prepared by the NPD Chemist.

In order to ensure the efficient completion of the study the Technical Services Engineer must ensure that details relating to the following are available at the meeting : 9 Vent sizing in the reactors being used for the process 9 Materials of construction for the vessels being used. 9 Pressure / vacuum ratings for the equipment being used 9 Condensing efficiencies of overhead systems 9 Any other engineering data relevant to the process.

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TITLE: PFWLWINARYHAZARDASSESSMENT

Page 3 of 4



2.10 The Technical representative from the Customer department must be capable of bring to the meeting a knowledge of the: > Specified production buildings > Production Equipment > Manufacturing Processes g Process Chemistry > Utilities

* 2.11 The study commences with the NPD Chemist responsible for the process describing the process as it will be run on the plant.

2.12 Using Keywords as outlined in Attachment I below the PHA Group must analyse the process by considering the > Hazards which exist > Initiating event which causes the hazard to become an Accident > Consequences of the Accident. A table as outlined in Attachment II is completed by the PHA Leader.

2.13 The Hazards Identified are then-subjectively scored based on the severity of their consequences if realised. (See Attachment III) Note: When considering the hazards it is assumed that controls to prevent occurrence are not in place. Ranking are scaled as follows.

Table 1

2.14 Once the Severity Ranking (R ) is agreed the Acceptable Frequency ( L) may be obtained from Table 1 above. The Target Risk may then be obtained by adding the severity ranking to the power of the acceptable frequency. The Target Risk is only acceptable when its value is equal or less that zero.

2.15 If an identified Hazard has previously resulted in an accident the frequency is higher (i.e.) 10e3 increases to 10e2.

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TITLE: PRELIMINARYHAZARDASSESSMENT

i .i Page 4 of 4



0

3.0

e

4.0

2.16 The criteria on which priorities for further study such as Consequence Modeling or Quantified Risk Assessment is decided is based on Attachment IV below, where:

. A - Priority study required. .

. B - Further study probably required.

. C - Further study may be unnecessary.

2.17All Action items arising from the PHA must be followed up and closed out by the Safety and Environment Officer Systems and the person responsible for the completion of that action items must sign off on their completion.

2.1 SAll outstanding items must be completed before process commencement or equipment operation.

2.19The PHA Leader, the Safety and Environment Manager, the Facilities Manager and the Manager of the Customer Department must sign off the PHA sign off sheet in order to acknowledge that all items have been carried out as agreed. (See Attachment V).

DOCUMENTATION Attachment I Preliminary Consequence Analysis Keywords. Attachment II PHA Record Sheet. Attachment III Preliminary Hazard Analysis - Severity Rankings Attachment IV Prioritisation For Risk. Attachment V Example of: PHA Sign Off Sheet.

Q/S&E/SOP’s/Forms/601.O3 l_Att. V PI-IA Sign Off Sheet.doc

REYISION

This SOP is reviewed annually according to SOP 100.007. Any necessary changes will be documented in a new revision of this SOP.

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SAFETY & ENVIRONMENTAL ATTACHMENT I

TITLE: PRELIMINARY CONSEQUENCE ANALYSIS KEYWORDS

Page 1 of 1



i0. Keywords

. Flammables:

l Ignition l Fire l Explosion/Detonation

!. Chemicals:

l Toxicity l Corrosion a Compatibility l Exothermic/Thermal Decomposition/RunaT

Potential. l Radiation H&ards

3. Environmental Damage:

l Gaseous Emissions. l Liquid Effluents.

4. Thermodynamic Hazards:

l High pressure 0 Low pressure l High temperature l Low te’mperature

No.

5.

6. Release of Material:

l Rupture l Discharge l Fugitive Emissions l Periodic Emissions l Handling

7. Loss of Services:

8.

Keywords

Mode of Operation:

m Start-up l Shutdown l Maintenance l Abnormal l Emergency

l Electricity l Water l Other services

External Threats:

l Accidental impact l Weather l Corrosion - erosion l Potential Domino Effects

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SAFETY & ENVIRONMENTAL ATTACHMENT II

TITLE: PHA RECORD SHEET (EXAMPLE)


Revision No: 0 Prev Rev No:

Page 1 of 1

Date: 13.06.02 Dated:

No. Keyword

01 Flammables

02

03

Flammables

Flammables

Latent Hazard Initiating event Consequences if realised

Hydrogen - tire/explosion with hydrogenation reaction.

Exothermic reaction,

Hydrogen gas leak - ignition occurs.

Fire/explosion occurs with possible major damage to plant area.

MethanoLNickel - flammable.

Hydrogen - MCP storage Line rupture/fracture on area - fire. exit line from MCPs.

Crystalliser/Still - distillation of methanol - flammable.

Vacuum pump failure - Flammable mixture - ingress of air. tire/explosion in vessel.

i

Major leak of hydrogen - gas cloud build up - ignition - blast effects or major fire.

- S -

4

-

1

-

I

-

F

lOA

105

Target Risk

0

F- -

B

B

-

4.

Comment

Target Risk = S+L = 4 + (-4) = 0

Consequences of Hydrogenator vessel failure to be evaluated.

Target Risk = S+L = 3 + (-3) = 0

Blast effects to be evaluated - e.g. impact on people/adjacent buildings.

Target Risk = S+L = 3 + (-2) = 1

Note: Previous incidents occurred on site 3 frequency is higher, F = 10”

ACtiOll

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SAFETY & ENVIRONMENTAL ATTACHMENT III

TITLE: PRELIMINARY HAZARD ANALYSIS - SEVERITY RANKINGS

Page 1 of 1



A. Catastrophic Consequences: Severitv 5 Catastrophic damage and severe clean-up costs. On-site: Loss of normal occupancy > 3 months. Off-site: Loss of normal occupancy > 1 month. Severe national pressure to shutdown. Three or more fatalities of plant personnel. Fatality of member of the public or at least five injuries. Damage to historic building. Severe environmental damage involving permanent or long term damage to a significant area. Acceptable frequency 0.00001 per year (I O-‘/y.

B. Severe Consequences: Severitv 4 Severe damage and major clean-up. Major effect on business with loss of occupancy up to 3 months. Possible damage to public property. Single fatality or injuries to more than five plant personnel. One in ten chance of a public fatality. Short-term environmental damage over a significant area. Severe media reaction. Acceptablefrequency 0.0001 per year (I@“/$$

Maior Consequences: Severitv 3 Major damage and minor clean-up. Minor effect on business but no loss of building occupancy. Injuries to less than five plant personnel with one in ten chance of fatality. Some hospitalisation of public. Short term environmental damage to water, land, flora, or fauna. Considerable media reaction. Acceptablefiequency 0.001 times per year (1 O-3/y.

D. Appreciable Consequences: Severitv 2 Appreciable damage to plant. No effect on business. Reportable near miss incident under EC Directive - Seveso II. Injury to plant personnel. Minor annoyance to public. Acceptablefiequency 0.01 times per year (1 F’/y).

E. Minor Consequences: Severitv 1 Near-miss incident with significant quality released. Minor damage to plant. No effect on business. Possible injury to plant personnel. No effect on public, possible smell. Acceptable fi-equency 0.1 times per year (I ff ‘ly).

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SAFETY & ENVIRONMENTAL ATTACHMENT IV

TITLE: PRIORITISATION FOR RISK

Page 1 of 1



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SAFETY & ENVIRONMENTAL ATTACHMENT V

TITLE: EXAMPLEOF: PHA SIGN OFF SHEET

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Page 1 of 1



SIFA PRELIMINARY HAZARD ASSESSMENT SIGN- OFF SHEET

TITLE

Acknowledgement that the PHA Items have been carried out as agreed ,*

TITLE Preliminary Hazard Assessment Leader Safety & Environment Manager BPC Manager Facilities Mgr

NAME SIGNATURE

Note:- All outstanding items must be completed prior to the commencement of the above process or items of equipment.

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REVISION LOG

SOP TITLE: PRELIMINARY &UAFtD ASSESSMENT SOP NUMBER/CODE: 601.031

REVISION NO. REQUESTED BY: REASON FOR REVISION EFFECTIVE DATE

0 DH To create new SOP

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SOP TITLE:

PRELIMINARYHAZARDASSESSMENT


For All Conies .

I have destroyed (returned in the case of Master EMI’s and CPs) the superceded revision of the SOP.

Signed: Department: ,*

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.,:

SAFETY & ENVIRONMENTAL PROCEDURE Page 1 of 2

SOP :ITLE: EQUIPMENT ISOLATION 620.002 Effective Date:

Revision No: 0 Date: 24 08 99 - Prev Rev No: _ Dated:

1.0 PURPOSE:

To outline the procedures necessary for effective isolation of equipment.

!.O PROCEDURE

2.1 Isolation is achieved by switching off / disconnecting the motive force (electricity compressed air, hydraulic fluid, etc.)

2.2 Each craftsperson has his own lock, to which there is only one key.

2.3 At the point of isolation, a padlock is to be fitted by each craftsperson performing work.

2.4 Most isolators have facility for locking by 3 padlocks. Otherwise, a “multiclasp” must be used to enable multiple padlocks to be fitted.

** 2.5 A tag indicating the name of craftsperson working on the equipment must also be attached.

Where more than one trade is involved additional tags must be attached.

2.6 Removal of tags I padlocks may only be authorised by the person who originally attached them. Any other person removing safety isolation devices without authorisation, will be subject to disciplinary action, up to and including dismissal.

Written & Approved By: Approved By: Approved By : Read By :

Kieran Hill John O’Donoghue Pat Gallagher Brendan Lynch, Safety Systems Engineer’ Safety & Environment Mgr. Engineering Mgr. Maintenance Supervisor.

Date: Date: Date: Date:

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II I

REXISION LOG

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SOP TITLE:

EQUIPMENT ISOLATION


11 Covzes Except QAiIhxter Copyc . .

I have destroyed treturned in the case of Master BMI’s and CPs) the superceded revision of the SOP.

Signed: Department:

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‘: :a; ,._,. .:i

>’ r TRAINING Ft~com SOP TITLE SOP NO.

EOUIPMENT ISOLATION 620 002 A

REV. NO.

0

The trainees must sign below to show agreement with the following statement

THE SOP DESCRIBED ABOVE HAS BEEN EXPLAINED TO ME, AND 1 FULLY UNDERSTAND ALL THAT IS REQUIRED OF ME TO COMPLY WITH ITS REQUIREMENTS.

Name of Trainer: (Block Capitals)

Signature of Trainer: Date:

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EPA Export 25-07-2013:15:30:48

Attachment J.1 Accident Prevention and Emergency Response Schwarz Pharma Ltd. Revised IPCL Application

Appendix J.l.2

- Firewater Retention Study/Proposal

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, .

Schwarz Phakna Ltd. Shannon Industrial Estate

Shannon, Co. Clare IPC Licence Reg. No 20

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Proposal for the Upgrade to Emergency Containment System

Rev. Issue Date Revision Description Prepared Checked Approved Client by by by Approval

01 18.02.2005 Draft POUJS

02 28.03.2005 Issue Draft POL/JS KOC POL

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Schwarz Pharnia Ltd.

Proposal for the Upgrade to Emergency Containment System

March 2005

Contents

I .O Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..*.............*.................... 1

2.0 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..~......................... 1

3.0 Proposed Emergency Retention System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 3. I Emergency Retention Tank ..~,.....,.~.~..~~....~~....~..~.~....~~~~,..~.~~~~...,,....~~,~,~.,.,,, 2 3.2 PenstockslShutoff Valves ~.~~..........I...~.~.,~........~~....~.~~~~,......~~~.~.........~.~~..,.. 3 3.3 Pump Sumps .,.~.....~,.~......,.......~~.,.........,..,,....~.........~.,.~..~.~,.~~.,..~.~..~~,~.,~.,.,,, 3 3.4 Diversion Pipeline . . . ..~..~.~...~...........~........................~....~....~.,...~~.~~.~....~..~.~.~~ 4

4.0 Propo:ed Programme . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..*....................... 6

Attachments

Attachment A Drawings

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_“.

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Schwarz Parma Ltd Proposed Emergency Containment Upgrade

March 2005

I .O Introduction

Schwarz Pharma Ltd. commissioned OES Consulting to carry out a review of the installation fire fighting water runoff containment arrangements in late 2004.

Arising from this review, a proposal relating to the upgrade of the site emergency containment arrangements was submitted to the Agency. Agency approval for this upgrade was received in January 2004.

This document comprises a detailed proposal for the collection, conveyance and storage of potentially contaminated firewater runoff in the event of a major fire at the Schwarz Pharma plant.

The document contains a number of revisions to the proposal submitted to the Agency in late 2004 and this is due to an extension of the scope of work to incorporate site Master Plan development.

2.0 Background

The review of firewater runoff containment undertaken by OES Consulting Q4 2004 identified a requirement for the upgrade of existing facilities at the Schwarz Pharma site to a level capable of providing retention of runoff in an emergency (i.e. fire, significant spillage) up to an estimated 1 ,320m3.

The volume was based on an estimated volume from firefighting effort of 756m3 together with an estimated worst-case surface water volume of 564m3. The surfa& water volume was based on a 24-hour storm condition over the relevant catchment within the site.

The report submitted to the Agency in November 2004 envisaged the installation of a containment culvert drain along the south western perimeter of the site, together with a series of pump sumps at strategic locations within the site.

This arrangement was proposed in general terms only and dealt with the existing site layout only.

A comprehensive programme of survey work has been undertaken since completion of the November 2004 report in order to finalise the design and confirm a number of details including underground pipeline routes, manhole and sump invert levels etc.

In addition, elements of the site Masterplan, and in particular the upgrade to the Nitration Plant roadway in early 2005, have facilitated a more comprehensive solution to the provision of emergency containment at the site. The original proposal has been revised to focus all emergency retention efforts at a single storage location and move away from a compartmentalized approach for primary storage. Accordingly, it is proposed to provide all of the required storage at the location of the existing Equalization Tank. This updated proposal does not include for the achievement of any additional containment through construction of a culvert.

OESREP~l026~02~O~Rev01 Page 1 of 6

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March 2005

3.0 Proposed Emergency Retention System

A detailed description of the proposed emergency retention system, incorporating tanks, pipework and pumping arrangement is described below. The elements of the system are as follows:

1. 1 No. Aboveground storage tank 2. Provision of 2 No. penstocklshut off valves to on surface water discharges. 3. Provision of emergency pumping at 3 No. pump sumps, complete with

submersible pump sets operating on a duty/ standby cycle. 4. Dedicated emergency pipeline to connect the pump sumps to the emergency

storage tank. 5. Provision for drain down of storage tank to allow for discharge to WWTP or off

site disposal as appropriate. 6. Provision of power supply, cabling and connection to plant fire alarm system.

In addition to the above, a number of associated elements are proposed which will address surface water discharges from the site and relocate waste storage to a new purpose-built and bunded storage tank.

The proposal has been developed based on guidance and standards including:

0

0

0

CIRIA Report 164 - Design of Containment Systems for Prevention of Water Poliution from Industrial Accidents C/R/A Report 163 - Construction of Bunds for Oil Storage Tanks CIRIA Special Report 124 - Barriers and liners for containment HSE HSG 176 - The Storage of Flammables in Tanks HSE Contract research Report - Effects of secondary containment on source term modeling (WS Atkins Consultants Ltd.) HSE EH 70- The Control of Firewater run-off from CIMAH sites HSE Specialist Inspector Report (SIR) No 39 - Guidance on the bunding of bulk chemical storage vessels. UK Environment Agency Pollution Prevention Guidelines PPG 18 - Managing Fire Water and Major Spillage’s and PPG 27 - Pollution incident Response Planning German Environment Agency System of Classification of Substances Hazardous to Waters (WGK)

3.1 Emergency Retention Tank

It is proposed to upgrade the storage capacity at the existing ET Tank location through installation of a new tank. In order to provide a single location for storage and subsequent handling of potentially contaminated material.

The tank will comprise a “Permastore” type, glass lined steel storage tank with a nominal capacity of 1,395m3, complete with inspection ladder, inspection manway, inlet and outlet connections.

The tank will be situated at the location of the current ET tank, which will be demolished. The tank will be completed and tested to BS8007.

Provision will be made for emptying tank of rainwater to preserve containment capacity. In addition, the tank will be fitted with a high-level alarm.

;, _

Page 2 of 6

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March 2005

A low level outlet will be provided to allow for gravity drain down of tank to existing drainage system (to WWTP) or tanker depending on composition and volume of material contained in an emergency.

It is noted that the design of the new Nitration Plant roadway/drainage culvert provides an additional minimum 200m3 of surface water storage will be provided in the new Nitration Plant roadway/drainage culvert.

3.2 PenstockslShutoff Valves

Surface water from the site will discharge to the Western Perimeter drain at two points from the Southern Perimeter Drain and Northern Perimeter Drain.

There will be no other discharges to surface water from the site.

Two shut off valves will be provided at western end of southern and northern perimeter drains. Both discharges to surface water will be made on the basis of continuous TOC measurement.

High TOC and/or fire alarm will activate the automatic shutoff valves, preventing uncontrolled discharge to surface water from this site.

On activation of shut off valves, liquid will back up within the drainage system to pump sumps (Section 3.3). From there, liquid may be pumped to the emergency containment tank.

Provision is currently being made on Nitration Plant Roadway upgrade for shutoff valve at downstream end of the new Northern Perimeter Drain.

3.3 Pump Sumps

It is proposed to install 3 No pump sumps at the following locations.

1. On existing Southern Perimeter Drain (prior to discharge to west catchment drain)

This pump sump and associated shut off will allow diversion of potentially contaminated material from the southern drainage catchments of the plant (BPCIChemical Warehouse/Maintenance/Offices/ Administration/Car Park)

2. On upgraded Northern Perimeter Drain (prior to discharge to west catchment drain)(Currently being taken account of as part of Nitration Plant roadway upgrade.

This pump sump and associated shut off will allow diversion of potentially contaminated material form the northern drainage catchments of the plant (Nitration Plant, Future Developed Areas to the north and north east under Schwarz Pharma Site Masterplan)

3. On existing surface water drain adjacent to S39 (upgrade of manhole to allow installation of pumps)

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March 2005

This pump sump will allow diversion of potentially contaminated material form the central drainage catchments of the plant (Pharma Plantliltilitiesl WWTP Compound)

Each of the above sumps will be provided with pumping as wet well duty/assist cycle submersible pumps with a capacity of min. 500m3/hr. In addition, the existing firewater pumping arrangement from the Solvent Sump/ET will be upgraded to allow diversion to a new above ground diversion pipeline (Section 3.4).

The existing pipeline will be removed on completion and commissioning of new system to ensure that there is no interruption of emergency containment.

Pump operation will be controlled by level indicators. Pumps sets will have their own electrical panel and will be provided with emergency supply.

3.4 Diversion Pipeline

Each emergency pump set will be connected to a single dedicated pipeline that will run generally overground from each of the 3 No. pump sumps (a number of short underground sections are proposed to facilitate roadway crossing).

The surface pipeline will be 250mm 0 pipeline to API% hydrant standard, seamless welded steel pipe shotblasted and coated complete with all flanged connections and bends. Pipeline will be mounted on low level supports pipe rack between the sumps and the, storage tank.

Underground sections to be sleeved ductile iron with flanged connections.

All pipe and support racks will be suitably coated for corrosion protection and labeled (contents and direction of flow).

The riser from each pump set will be fitted with a T-piece incorporating a gate valve to allow for routine testing of each pump.

The diversion pipeline running form the Southern Catchment Drain and ET will be fitted with a low level valved and lockable connection to the ET to allow drain under gravity to ET and hence introduction to WWTP in the event that treatment is appropriate.

3.5 Additional Elements of Containment Proposal

Two additional elements of the containment proposal relate to the diversion of surface water from the area of the waste water treatment plant and the relocation of the Nitration Plant liquid waste holding area (currently in the equalization tank) to a new dedicate storage tank at Nitration plant.

These elements are described below.

3.51 Surface Water Diversion

There is an existing surface water discharge point in the area of the WWTP (S41), which is currently shut off.

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Currently, surface water from this area is diverted from a manhole (S39) and pumped to the WWTP along with surface water from the Nitration Plant catchment (at S44).

This arrangement is in place pending the installation of a TOC analyzer on the surface water discharge at the northern end of the site (at Nitration). Installation of a TOC analyzer will allow continuous monitoring of surface water discharges in the same way as currently implemented at the southern end of the site (S07). *

At this time, surface water from the S39 area will be permanently diverted to the Northern drainage system where it will combine with surface water runoff form the northern parts of the site and discharge to the western perimeter drain.

As part of the proposed emergency containment upgrade, a permanent above ground pipeline will be installed from the upgraded pump sump at S39 to the Northern Perimeter Drain, to allow continuous drainage of surface water from the Pharma and WWTP catchments to this discharge point.

In the event of an emergency, diversion to the Northern Perimeter Drain will stop and runoff will be diverted to the emergency containment tank.

3.5.1 Relocation of Nitration Plant Waste Storage

Since 2002, a liquid waste stream from the Nitration process has been diverted away from the WWTP to storage at a chamber within the existing equalization tank.

The liquid waste stream is a form of crude Isosorbide-5-Mononitrate (5ISM) solution, the bulk of which is water (Ca. 71%). The solution does however contain appreciable quantities of sodium acetate (20%), which together with smaller quantities of sodium nitrate and Isosorbide, represents a significant COD and dissolved solids loading on the treatment plant.

This stream is discharged from the nitration plant to a dedicated 80m3 chamber at the equalization tank for collection prior to being tankered off site as required.

It is proposed to install a dedicated 25m3 stainless steel storage tank for this waste in the area to the immediate west of the Nitration Plant (north of existing Nitration Plant tankfarm).

This tank will be bunded to minimum 110% of the tank capacity with incorporation of a pump over facility for surface water removal.

The tank design will be in accordance with relevant industry standards and codes. The bund will be reinforced concrete and will be designed in accordance with BS 8007 together with relevant HAS/UK HSE and CIRIA Guidelines on bund construction (safety and environmental factors).

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Schwatz Parma Ltd Proposed Emergency Containment Upgrade

March 2005

4.0 Proposed Programme

The programme for installation of the emergency retention system described above is outlined below in terms of timescale after Agency approval as follows:

Event Task

Agency Approval

+ 6 weeks

+ 7 weeks + 10 weeks + 14 weeks

Preparation of tender documentation for review by Client Issue of Tender Documentation Receipt of completed Tender Evaluation, recommendation & Contract Award

Contract Award

+ 2 weeks +I4 weeks

Commencement of site work Project completion

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Attachment A Drawings -

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Documents

Environment Protection/Health & Safety File Record Sheet.HAZOP Procedure - 3 11 .OO 1, Basis of Process Safety Report - 3 11.002 Basis of Safety & Environmental Protection - 60 1.030