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Corden Pharmachem - Annual environmental report 2008

Annual Environmental Report 2008

Corden Pharma Ltd

t/a Corden PharmaChem

Wallingstown,

Little Island,

Co. Cork

IPPC Licence Registration No: P0134-03

March 2009


Corden PharmaChem AER 2008 Page 2 of 104

Compiled by:

Peter Keegan

EHS Officer

Approved and Authorised by

Sean Kenrick

EHS Manager

Corden PharmaChem.,

Wallingstown,

Little Island,

Co. Cork



TABLE OF CONTENTS

1. INTRODUCTION......................................................................................................................6

1.1 Site Location.............................................................................................................................................. 6

1.2 Site Activities ............................................................................................................................................. 6

1.3 Company Overview .................................................................................................................................. 7

1.4 Environmental Policy ............................................................................................................................... 8

1.5 Company Organisation Chart ................................................................................................................. 8

2. SELF-MONITORING DATA...................................................................................................9

2.1 EMISSIONS TO SEWER .......................................................................................................................... 9

2.1.1 Summary & PRTR Table......................................................................................................................... 9

2.1.2 Summary of Notification Reports.......................................................................................................... 16

2.1.3 Office of Environmental Enforcement Wastewater Sampling............................................................ 17

2.1.4 EPA Certified Laboratory proficiency scheme .................................................................................... 18

2.2 EMISSIONS TO SURFACE WATER ....................................................................................................... 19

2.2.1 Summary of surface water emissions & PRTR Table ......................................................................... 19

2.2.2 Surface Water Exceedance of Warning Level...................................................................................... 22

2.3 EMISSIONS TO ATMOSPHERE......................................................................................................... 23

2.3.1 Process Emissions Summary.................................................................................................................. 23

2.3.2 Boiler Emissions Summary .................................................................................................................... 25

2.3.3 Dust Emissions Summary....................................................................................................................... 26

2.3.4 PRTR Table – Emissions to Air............................................................................................................. 27

2.4 WASTE MANAGEMENT ....................................................................................................................... 30

3. ENERGY AND WATER CONSUMPTION .........................................................................36

3.1 ENERGY & WATER CONSUMPTION..................................................................................................... 36

4. ENVIRONMENTAL INCIDENTS AND COMPLAINTS ............. .....................................37

4.1 INCIDENTS 2008 ................................................................................................................................. 37

4.1.1 Incident 01-08 Over pressurisation of Waste Drum......................................................................... 37

4.1.2 Incident 02-08 Waste Treatment Incident ......................................................................................... 38

4.1.3 Incident 03-08 PB2 Reaction Vessel Incident – Update.................................................................... 39

4.2 THERMAL OXIDISER BYPASSES......................................................................................................... 40



4.3 COMPLAINTS ...................................................................................................................................... 42

5. MANAGEMENT OF THE ACTIVITY ......................... .......................................................44

5.1 ENVIRONMENTAL MANAGEMENT SYSTEM ........................................................................................ 44

3.2 HUMAN RESOURCES, TRAINING AND EDUCATION: ........................................................................... 44

5.3 SCHEDULE OF ENVIRONMENTAL OBJECTIVES AND TARGETS .......................................................... 44

5.4 ENVIRONMENTAL MANAGEMENT PROGRAMME................................................................................ 45

6. LICENCE SPECIFIC REPORTS..........................................................................................46

6.1 NOISE ................................................................................................................................................. 46

6.2 GROUNDWATER MONITORING ........................................................................................................... 48

6.3 BUND TESTING ................................................................................................................................... 50

6.4 TOXICITY TESTING OF EFFLUENTS ................................................................................................... 51

APPENDICES ..................................................................................................................................52

APPENDIX I .................................................................................................................................................. 53

Site Plan of the Corden PharmaChem Facility................................................................................................... 53

APPENDIX II ................................................................................................................................................ 54

Corden PharmaChem Organisation Chart......................................................................................................... 54

APPENDIX III............................................................................................................................................... 55

Environmental Policy Statement ......................................................................................................................... 55

APPENDIX IV ............................................................................................................................................... 57

Compliance Summary Tables .............................................................................................................................. 57

APPENDIX V................................................................................................................................................. 63

Dioxin Monitoring Report 2008 ........................................................................................................................... 63

APPENDIX VI ............................................................................................................................................... 64

Dust Monitoring for 2008 ..................................................................................................................................... 64

APPENDIX VII.............................................................................................................................................. 64

PRTR Waste Tables for 2008 ...............................................................................................................................64

APPENDIX VIII ............................................................................................................................................ 75

Utilities Reports 2008 ............................................................................................................................................ 75



APPENDIX IX ............................................................................................................................................... 78

Review of 2008 Environmental Management Programme................................................................................ 79

APPENDIX X................................................................................................................................................. 87

Proposal for 2009 Schedule of Objectives and Targets...................................................................................... 88

APPENDIX XI ............................................................................................................................................... 89

Environmental Management Projects Proposal 2009........................................................................................ 90

APPENDIX XII.............................................................................................................................................. 95

External Acoustic Survey - November 2008........................................................................................................ 95

APPENDIX XIII ............................................................................................................................................ 96

Groundwater Monitoring Reports....................................................................................................................... 96

APPENDIX XIV............................................................................................................................................. 97

Bund Testing Reports ........................................................................................................................................... 97

APPENDIX XV ............................................................................................................................................ 104

Wastewater Toxicity Reports 2008 .................................................................................................................... 104

CORDEN PHARMACHEM

Section 1: Introduction


1. INTRODUCTION

Name of company: Corden Pharma Ltd t/a Corden PharmaChem.

Location of site: Wallingstown, Little Island, Co. Cork

IPPC License Register Number (issued in Feb 2008): P0134-03

1.1 Site Location

Corden PharmaChem is located at Wallingstown, Little Island, Co. Cork. The facility is situated on a 20-

acre site, within the Little Island IDA Industrial Estate, approximately 5 miles east of Cork City.

Little Island forms the northern shore of Lough Mahon and is relatively low lying. The Corden

PharmaChem facility is located roughly in the centre of Little Island, 400 metres to the north of the northern

shore of Lough Mahon. The plant is bounded to the north, west and south by industrial complexes. The plant

is bounded to the east by a road and a golf club. Considerable environmental monitoring is currently

undertaken throughout Little Island, due to the industry sector of many of the larger industrial sites.

1.2 Site Activities

Corden PharmaChem is licensed under Class 5.16 of the First Schedule of the EPA, Acts 1992 & 2003, to

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

Corden PharmaChem is a multi-product cGMP manufacturing facility, which produces bulk active

pharmaceutical ingredients for clients worldwide. The company also operates a research and development

facility, which is actively involved in product development.

Corden PharmaChem holds ISO 14001 certification and is operated to Irish Medicines board (IMB) and US

Food & Drug Administration (FDA) cGMP manufacturing standards

Corden PharmaChem is also an ISO 9002 accredited company. In addition, Corden PharmaChem is licensed

to process controlled substances and is accredited by the National Drugs Advisory Board.



1.3 Company Overview

Corden PharmaChem was established as Irish Pher in 1974 as a fine chemical production company. In 1992,

the company was purchased by Ecosol AG and it was subsequently renamed Irotec Laboratories Limited.

In 1999, Irotec laboratories Ltd. was acquired by the Cambrex Corporation, and renamed Cambrex

Profarmaco Cambrex Cork Ltd. In mid 2004 the company changed its name to Cambrex Cork Ltd.

Cambrex Corporation is a leading global supplier of products and services to the Life Sciences Industries and

a producer of speciality chemicals through its subsidiaries in the US and Europe.

In 2006 ICIG (International Chemical Investors Group) acquired Cambrex Cork and our sister company in

Landen, Belgium. In January 2007 the company officially changed its name from Cambrex Cork to Corden

PharmaChem

ICIG, based in Frankfurt, Germany is the holding company for a number of subsidiaries in the fine and

specialty chemicals industry, owning eight businesses, with sales of over €300 million. ICIG operates eleven

manufacturing sites in Germany, France, the United States and Poland with over 1800 employees. ICIG

companies include WeylChem, PPC, ENKA, Rütgers Organics, Rütgers Carbotech, CarboTech Engineering

and Nease Corporation.

The Corden PharmaChem product list includes a wide range of bulk active materials, which are used in the

formulation of final dosage forms at secondary pharmaceutical facilities in Europe and the USA. The

therapeutic uses of Corden’s products include: anti-rheumatic, anti-inflammatory, analgesic, anti-coagulant,

anti-fungal, anti-cancer, anti-depressant, anti-psychotic, vasodilator, beta blocker, and stimulant uses.

A plan of the existing Corden PharmaChem facility is presented in Appendix I of this report. The existing

facility consists primarily of two Production Buildings (PB1 and PB2), an administration and laboratory

building, a canteen/social building and miscellaneous site infrastructure, utilities and facilities.

The EHS Manager is responsible for environmental and safety management systems including all EHS

monitoring and reporting functions. Engineering are responsible for the day to day running of the

Wastewater Treatment plant, Air pollution abatement technology (Thermal Oxidiser, Scrubbers, Boilers etc).

A copy of Corden’s Organisation Chart is included in Appendix II of this report. The EHS section is a

dedicated unit with a current staff of 2 full-time employees with further back up from the Engineering

department. The EHS department includes the EHS Manager and Environmental Officer The Engineering

Department consists of 3 full time Engineers, 1 Utilities Officer and 2 EHS Operators.



Condition 11.7 of the Corden PharmaChem IPPC Licence requires the company to produce an Annual

Environmental Report (AER) and to submit it to the Environmental Protection Agency (EPA). This report

constitutes the AER for the period January 2008 to December 2008.

The format of this report is in compliance with the EPA’s Guidance Note for the AER (February 1997).

1.4 Environmental Policy In 1996, Corden PharmaChem first published its Environmental Policy Statement. This Environmental

Policy Statement has evolved over the past number of years and the current version, issued in January 2006,

is presented in Appendix III of this report.

1.5 Company Organisation Chart

The current version of Corden PharmaChem’s organisation chart is included in Appendix II

CORDEN PHARMACHEM

Section 2: Compliance Summary


2. SELF-MONITORING DATA 2.1 Emissions to Sewer

2.1.1 Summary & PRTR Table

Treated effluent from the Corden PharmaChem facility was discharged from the Wastewater Treatment Plant

(WWTP) via overhead pipe to the Cork County Council industrial sewer on the East side of the Corden

PharmaChem site., and ultimately to Carrigrennan Waste Water Treatment plant

For Summary of non compliances refer to Appendix IV.

Parameter Licensed Mass Emission (Kg per annum)

2007 Mass Emission (Kg per annum

2008 Mass Emission (Kg per annum

Volume (m3/year) 93,075 23,913 21,398

Temperature Max. 25 ºC 24.1°C

(average 16.01)

23.4°C

(Average16.3°C)

pH 6 - 9 Max 8.7

Min: 6.04

Max: 8.9

Min: 6.4

Toxicity

10 TU

<2 TU (respirometry)

55.5 TU (T Battagliai)

<2 TU (respirometry)

31.2 TU (T Battagliai)

BOD 73,000/73,200 2,315 2,344

COD 365,000/366,000 29,550 13,284

Suspended Solids 10,950 1,982 3,021

Total Nitrogen - 832 405

Ammonia (as N) - 170 272

Total Phosphorus (as P)

- 34.3 107

Sulphates (as SO4) - 14,937 12,546

Cyanide - 0..55 3.4

Fats, Oils & Grease - 60.3 89.7

TABLE 2.1.1 EMISSIONS TO SEWER/WASTE WATER SUMMARY

CORDEN PHARMACHEM



PRTR TABLE - RELEASES TO WASTEWATER OR SEWER #VALUE!

28/04/2009 10:49

SECTION A : PRTR POLLUTANTS OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-W ATER TREATMENT OR SEWER

POLLUTANT METHOD QUANTITY Method Used SE1

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

06 Ammonia (NH3) M ALT

4500-NH3-D Ammonia selective electrode method 270.0 270.0 0.0 0.0

17 Arsenic and compounds (as

As) M EN14385 0.071 0.071 0.0 0.0

20 Copper and compounds (as

Cu) M EN14385 0.166 0.166 0.0 0.0 82 Cyanides (as total CN) M ALT HACH Method 8027 3.4 3.4 0.0 0.0 23 Lead and compounds (as Pb) M EN14385 0.024 0.024 0.0 0.0 22 Nickel and compounds (as Ni) M EN14385 0.189 0.189 0.0 0.0

07 Non-methane volatile organic

compounds (NMVOC) M USEPA 8260B 20.1 20.1 0.0 0.0

12 Total nitrogen M ALT HACH Method 10022 - digestion/colorimetry 405.0 405.0 0.0 0.0

76 Total organic carbon (TOC)

(as total C or COD/3) C PER COD/3 4430.0 4430.0 0.0 0.0

13 Total phosphorus M ALT HACH Method 8190 digestion/colorimetry 107.0 107.0 0.0 0.0

24 Zinc and compounds (as Zn) M EN14385 1.61 1.61 0.0 0.0

CORDEN PHARMACHEM



OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-W ATER TREATMENT OR SEWER

POLLUTANT METHOD QUANTITY Method Used SE1

Pollutant No. Name M/C/E

Method Code

Designation or Description

Emission Point 1

T (Total) KG/Year



238 Ammonia (as N) M ALT

4500-NH3-D Ammonia selective electrode method 270.0 270.0 0.0 0.0

303 BOD M ALT 5120B - standard method - 5 day test 2340.0 0.0 0.0 0.0

305 Calcium M EN14385 608.0 608.0 0.0 0.0 306 COD M EN14385 13300.0 13300.0 0.0 0.0

314 Fats, Oils and Greases M ALT 5520 C - Gravimetric Method 89.7 89.7 0.0 0.0

357 Iron M EN14385 19.8 19.8 0.0 0.0 362 Kjeldahl Nitrogen M ALT HACH Method 424.0 424.0 0.0 0.0 320 Magnesium M EN14385 165.0 165.0 0.0 0.0 321 Manganese (as Mn) M EN14385 1.42 1.42 0.0 0.0

323 Methanol M USEPA 8260B 12.3 12.3 0.0 0.0

327 Nitrate (as N) M ALT

HACH method - 8039 - cadmium reduction method 226.0 226.0 0.0 0.0

370 Selenium M EN14385 0.095 0.095 0.0 0.0

343 Sulphate M ALT HACH method - 8051 - turbidity/colorimitry 12500.0 12500.0 0.0 0.0

240 Suspended Solids M ALT Standard method 2540D - gravimetry 3020.0 3020.0 0.0 0.0

358 Tin M EN14385 1.23 1.23 0.0 0.0 347 Total heavy metals M EN14385 2.18 2.18 0.0 0.0

351 Total Organic Carbon (as C) M USEPA 8260B 4430.0 4430.0 0.0 0.0

CORDEN PHARMACHEM



237 Volatile organic compounds

(as TOC) M USEPA 8260B 20.1 20.1 0.0 0.0

CORDEN PHARMACHEM



Parameter

% Change 2005-2006

Volume (m3/year) -10.5%

Temperature n/a

pH n/a

Toxicity n/a

BOD +1.3%

COD -55%

Suspended Solids +52%

Total Nitrogen -51%

Ammonia (as N) +60%

Total Phosphorus (as P) +212%

Sulphates (as SO4) -16%

TABLE 2.1.2 % CHANGE IN EMISSIONS TO SEWER 2007-2008.

CORDEN PHARMACHEM



WWTP Parameters

0

10000

20000

30000

40000

2006 2007 2008

Year

Kgs

BODTSSNitrogenSulphatesVolumeCOD

TABLE 2.1.3 EMISSIONS TO SEWER / WASTEWATER SUMMARY.

100% Compliances.

Effluent is sampled and analysed in accordance with the terms of the Corden PharmaChem

IPPC licence, P0134-03. During 2008, 100% compliance was achieved for the following

licenced parameters:

• Temperature;

• pH

• Nitrates

• Total P

• BOD

• Total Heavy Metals

• Cyanide;

• Volume

• OFGS

• COD

• Total Nitrogen

• VOCs

Effluent is sampled and analysed in accordance with the terms of the IPPC licence and during

2008, there were 4 non-compliances.

CORDEN PHARMACHEM



Details of these non-compliances have been notified to the Agency in accordance with

condition 11.1 of our IPPC licence. Refer to Notification reports and Biannual reports.

Compliance performance 2003-2008.

0

5

10

15

20

25

30

35

2002 2004 2005 2006 2007 2008

Breaches

A review of the overall WWTP non-compliances has been undertaken and a monthly

summary is provided in Table 2.1.4. A tabulated record of each of the WWTP non-

compliance records is presented in Appendix IV.

Month

Janu

ary

Feb

ruar

y

Mar

ch

Apr

il

May

June

July

Aug

ust

Sep

tem

ber

Oct

ober

Nov

embe

r

Dec

embe

r

Tot

al

pH 0 0 0 0 0 0 0 0 0 0 0 0 0

BOD 0 0 0 0 0 0 0 0 0 0 0 0 0

COD 0 0 0 0 0 0 0 0 0 0 0 0 0

Suspended Solids 1 0 0 1 0 0 0 0 0 0 0 0 2

Total Nitrogen 0 0 0 0 0 0 0 0 0 0 0 0 0

Ammonia (as N) 0 0 0 0 1 0 0 0 0 0 0 0 1

Total Phosphorous 0 0 0 0 0 0 0 0 0 0 0 0 0

Sulphates 0 0 0 1 0 0 0 0 0 0 0 0 1

Cyanide 0 0 0 0 0 0 0 0 0 0 0 0 0

Fats, oil & greases 0 0 0 0 0 0 0 0 0 0 0 0 0

TOTAL 1 0 0 2 1 0 0 0 0 0 0 0 4

Table 2.1.4 Monthly Waste Water Emissions Non-Compliance History

CORDEN PHARMACHEM



2.1.2 Summary of Notification Reports

FE-01-08 – Suspended Solids

Total Suspended Solids reading of 863 mg/l Vs IPPC licence of 200mg/l Suspended Solids

was detected on 22 January 2008. The total volume wastewater discharged for 22 January

was 82 m3; giving an emission load of 70kg/Day. The reason for these high levels was mainly

due to high volumes entering WWTP and solids in the system. As well as diversion in which

the outfall was diverted to holding tanks, flow rates throughout the system were also reduced

to help reduce the emissions loadings. Diversion and sludge removal helped reduce outfall

flowrates as the plant re-established normal operating conditions. Regular monitoring of

suspended solids was carried out until they come back into compliance

FE-02-08 – Sulphates

Analysis of the composite sample from 09 April indicated sulphate levels of 808 mg/l Vs

IPPC limit of 500mg/l. The total sulphate mass emissions loadings were 49 Kgs/day. Further

sulphate analysis on the 14th, 15th, 16, and 17th April indicated levels of 1070, 1010, 1040 and

1040 mg/l respectively. All other parameters were within IPPC licence compliance. Sulphates

are a monthly test, but frequency of testing was increased until compliance was achieved.

Flow rates were reduced in an attempt to reduce mass loading emissions. A factor giving rise

to increased sulphate levels was the bypassing of the sulphuric acid valve on 09th April.

Approximately 500 litres bypassed directly into the equalisation basin, thereby increasing

sulphate levels. The valve was subsequently fixed and normal service has resumed.

FE-03-08 – Suspended Solids

Analysis of the composite sample on 12 April indicated a Total Suspended Solids reading of

428 mg/l Vs IPPC licence of 200mg/l Suspended Solids. Suspended solids analysis on 13th,

14th and 15th April also indicated levels of 325, 351 and 328 mg/l respectively. The reason for

these high levels was mainly due to high volumes of solids in the system and settleability

problems. Flow rates throughout the system were reduced to help reduce the emissions

loadings and emptying and cleaning out of clarifiers was carried out to help remove solids

from the system

FE-04-08 - Ammonia

CORDEN PHARMACHEM



Analyses of the final effluent composite samples from 07, 08, 09 May 2008 indicated

ammonia readings of 156, 80.5 and 110mg/l respectively. Our licence limit is 50mg/L NH3 (as

N).

Since the PB2 incident which occurred on 28th April 2008, production has been stopped and

as a result the usual waste/feed for the wastewater biological system was not available. As a

result the biological system was not operating as effectively as usual. Ammonia levels in the

raw influent were lower than ammonia levels in the final effluent, which shows that there was

an upset to the plant because of production shutdown. There was a source of waste onsite,

which was fed in at a slow rate as it is a strong waste. The main bulk of the waste streams

however were not available due to this shutdown.

2.1.3 Office of Environmental Enforcement Wastewater Sampling. The EPA’s Office of Environmental Enforcement made 1 unscheduled visit to Corden

PharmaChem to sample waste water streams. Analysis was conducted in EPA laboratories in

Iniscarra (wastewater screen) & Kilkenny (VOC screen). The wastewater results reported to

Corden PharmaChem indicate a close correlation with our own QC laboratory wastewater

sample results.

Test Parameter

IPPC Limits

EPA Result

11/11/08

Corden Pharma-

Chem Result

11/11/08

Flow (m3/day) 255m3/day 85 85

pH 6.0 – 9.0 7.79 @ 20°C 7.497 @ 20°C

BOD (mg/l) 1000mg/l or

200kg/day 4.1 130

COD (mg/l) 5000 mg/l or

1000kg/day 138 181

Suspended Solids

(mg/l)

200mg/l or

30kg/day <2 7

Total

Nitrogen (mg/l)

50mg/l <1 2.3

CORDEN PHARMACHEM



Test Parameter

IPPC Limits

EPA Result

11/11/08

Corden Pharma-

Chem Result

11/11/08

Flow (m3/day) 255m3/day 85 85

Ammonia

(as N) (mg/l)

50mg/l

0.053

0.031

Total Phosphorus

(as P) (mg/l)

10mg/l <0.2 0.03

Sulphates

(as SO4) (mg/l)

500mg/l

190

90

Cyanide

(as HCN) (mg/l)

0.2mg/l <0.010 ND

Table 2.1.3 OEE laboratory results compared to Corden PharmaChem QC laboratory results

2.1.4 EPA Certified Laboratory proficiency scheme

Corden PharmaChem have been accepted into the EPA Certified Laboratory proficiency

scheme for 2006-2009. This program allows facilities to check the validity, consistency and

adequacy of the methods they employ to perform various wastewater test. This scheme will

allow Corden PharmaChem to satisfy itself that our laboratory procedures, systems and

analysis are to a consistently high standard, and where not, to take the necessary action so a

high standard of consistency can be reached.

The categories of testing we have applied to join are:

Category 1 – pH, Sulphates;

Category 2 - BOD/COD, suspended solids;

Category 4 – Ammonia (as mg/l NH4), nitrate (mg/l (NO3), phosphorous (mg/l P).

The Register for 2008 has yet to be drafted but for 2007, Corden PharmaChem were on the

register for COD, Phosphates, Sulphates and Suspended Solids. We are currently working

towards the 2009 register.

CORDEN PHARMACHEM



2.2 Emissions to Surface Water

2.2.1 Summary of surface water emissions & PRTR Table

Storm water arising on the Corden PharmaChem facility is discharged into a surface water

drainage system. The combined storm water discharge exits the Corden PharmaChem site at

the southeast corner of the facility. The combined discharge is then conveyed to Lough

Mahon via the Cork County Council surface water drain.

Dedicated Process Area Surface Water Drainage System (PASD) holding tanks are provided

to collect all of the surface water from potentially contaminated areas. Samples of surface

water are taken from the holding tanks and are tested for COD and pH. The surface water

from the PASD holding tanks is discharged to the surface water drain only in the event that it

meets prescribed criteria (COD <100mg/l, pH 6-9). In the event of contamination arising, the

PASD surface water is discharged to the WWTP. This ensures that no contaminated surface

water is discharged from the site.

In accordance with Schedule C 2.3 of the IPPC License, Corden PharmaChem has monitored

surface water discharges and the monitoring data is presented in Table 2.2.1.

Parameter

2007

2008

Total Flow m3/yr 14,667 3,948

Temperature (average ˚C) 17 16

pH (average) 7.1 7.4

BOD ((kg) 337 146

COD ((kg) 543 30

Table 2.2.1 Emissions to Surface Water Summary

CORDEN PHARMACHEM



PRTR TABLE - 4.2 RELEASES TO WATERS

SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS

RELEASES TO WATERS POLLUTANT QUANTITY

Method Used SW1

No. Annex II Name M/C/E Method Code


Emission Point 1

T (Total) KG/Year



76 Total organic carbon (TOC) (as total C

or COD/3) C PER COD/3 44.0 44.0 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 POLLUTANTS

RELEASES TO WATERS

POLLUTANT QUANTITY Method Used

No. Annex II Name M/C/E Method Code


Emission Point 1

T (Total) KG/Year



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

CORDEN PHARMACHEM



SECTION C : REMAINING POLLUTANT EMISSIONS (as requi red in your Licence)

RELEASES TO WATERS POLLUTANT QUANTITY

Method Used SW1

Pollutant No. Name M/C/E Method Code


Emission Point 1

T (Total) KG/Year



303 BOD M 5120B Standard Method: 5

day test 360.0 360.0 0.0 0.0

306 COD M

5220D or Hach

method 8000

Examination of water and wastewater

digest/colorimetry 130.0 130.0 0.0 0.0 351 Total Organic Carbon (as C) M continuous Protoc 300 220.0 220.0 0.0 0.0

CORDEN PHARMACHEM



2.2.2 Surface Water Exceedance of Warning Level

SW-01-08

Analysis carried out on the 24-hour composite Surface Water sample from February 07th, indicated a COD

value of 160mg/l from a surface water discharge flow of 20m3. Visually, the sample was colourless and

clear. There was surface water discharge on 06 February 2008 from 18:44 to 20:42 during which there was

an average flow of 8.4m3/hr during which the ph was 6.8.

In late January it was noticed that part of the equipment of the TOC analyser wasn’t in usual condition.

During this time, all surface water discharges were diverted to onsite containment, so there were no surface

water emissions from site. During week 5, February 01st, the service contractors were onsite to service the

analyser and repair the fault. Upon the approval from service contractors the TOC analyser was put back

online and normal surface water management mode resumed.

However on 07 February it was noted by site Instrumentation Engineer that the analyser failed its daily

calibration. It is also the composite sample from this day which exceeded the warning level set by Corden

PharmaChem. The surface water flow was then diverted and remained so until further investigations into the

current status of the analyser is known. The surface water flow automatically diverts to onsite containment

when TOC levels are >33mg/l. Following extensive maintenance and cleaning of the TOC unit, normal mode

resumed.

SW-02-08

Analysis carried out on the 24-hour composite Surface Water sample from February 09th, indicated a COD

value of 120mg/l from a surface water discharge flow of 20m3. Visually, the sample was colourless and

clear,

This was as a result of cleaning and testing of the TOC analyser and surface water chambers on

Friday 08th. Testing and cleaning of the system was carried out on Friday 08th from approx 10:00 to

15:00 with sporadic flows of emissions to surface water during this period. This was in response to

the surface water exceedance on 07th February. While TOC levels were below 33mg/l during these

times, it is possible that there was some stagnant contamination in the sampling chamber at the time

resulting in an exceedance of the warning level. The chambers and sample container have since

been cleaned and cleared of any visible contamination.

CORDEN PHARMACHEM



2.3 Emissions to Atmosphere

2.3.1 Process Emissions Summary

Aa summary report of scrubber process emissions emitted via a thermal oxidiser from stack A12/1 to

atmosphere is presented in Table 2.3.1. Results are based on grab sample analysis

2.3.1.1 Emissions from A2/1

Parameter Licensed Mass Emission (Kg per annum)1

2007 Mass Emission (Kg per annum)2

2008 Mass Emission (Kg per annum)3

VOC – Class I (Tubes) 876 0 0

VOC – Class II (Tubes) 4,380 110 7.21

VOC – Class III (Tubes) 6,570 360 82.3

Dioxins 4.38 x 10-6 6.56 * 10-8 7.78 * 10 -08

Hydrogen Chloride 438 64 48 Nitrogen Oxides (as NO2)

4,380 46.5 42

Carbon Monoxide 2,190 47 7 Sulphur Dioxide (SOx) 13,140 27.4 7

Hydrogen Bromide 219 12 6

Hydrogen Cyanide 87.6 7.47 23 Hydrogen Sulphide 219 0 0 Ammonia 2,190 0.45 0.3

Table 2.3.1.1 Licensed Emissions from A2/1 to Atmosphere Summary

Thermal Oxidiser Non-Compliances

There were No thermal Oxidiser compliances during 2008, however a tabulated record is nonetheless

presented in Appendix IV.

1 based on 8760 hrs of operation 2 based on 7920 hrs of operation 3 based on 5803 hrs of operation

CORDEN PHARMACHEM



2.3.1.2 Emissions from A2/5


2007 Mass Emission (Kg per annum)


VOC – Class I (Tubes) 1,314 0 0

VOC – Class II (Tubes) 6,570 2,120 729

VOC – Class III (Tubes) 9,855 5,300 5000

Table 2.3.1.2 Licensed Emissions from A2/5 to Atmosphere Summary

2.3.1.3Emissions from A2/6




VOC – Class I (Tubes) 8,760 0 0 VOC – Class II (Tubes) 43,800 5,100 1,510

VOC – Class III (Tubes) 65,700 31,000 10,900

Table 2.31.3 Licensed Emissions from A2/6 to Atmosphere Summary

The figures for 2008 were calculated based on the Thermal Oxidiser (TO) in operation for 5803 hours. These

calculations assume that the average concentration is emitted for the full operating time of the TO. If fugitive

emissions are taken into account, up to 20kgs may have been emitted during bypass time of 389 hours, All

bypass incidents were not of environmental significance as confirmed in notification/TO reports and by

External consultants’ air modelling reports.

As can be seen from the tables above the annual mass emissions are much lower than the permitted mass

emission limits. In addition, the emissions from A2/1meet the Emission Limit Values for all parameters as

specified in Schedule B of the IPPC license. As can be seen from the table above there is mainly a large

reduction in all air emissions in 2008 when compared to 2007 – due to improved monitoring and response

times and also due to reduced hours of operation especially regards the thermal oxidiser.

The air abatement system onsite consists of:

• Waste gas collection system, both general plant and specific to processes/machines and vessels

CORDEN PHARMACHEM



• Acidic & Basic aqueous gas scrubbers,

• Catalytic bed thermal oxidiser,

• Stack monitoring system and other necessary instrumentation to abate the waste gas streams from

their production facilities in PB1 and PB2.

A range of instrumentation continuously monitors the operation of the thermal oxidiser, including: LEL

meters, airflow meters, temperature probes and a continuous HCl and TOC monitor. In addition, routine

monthly and quarterly sampling is undertaken by sorbent & adsorbent tube sampling techniques by Corden

PharmaChem personnel. Dioxin Monitoring is carried out by A.S.E.P., an accredited Laboratory based in

Queens University of Belfast.

Additional measures such as operator/supervisor retraining, maintenance and supervision have contributed to

substantially reducing control system and operator error bypasses.

2.3.2 Boiler Emissions Summary

Two Boilers X3021 & X3003, are fuelled by natural gas to generate steam for the site. The boilers are

operated on a demand cycle with one on full duty, supplying steam to the site and another on standby. The

emissions are discharged via stacks A1/1 & A1/2 respectively and are classified as minor emission points.

Samples are drawn from the exhaust flues each month and analysed for boiler emissions (Nitrogen Oxides as

NO2, Carbon Monoxide (CO) and Oxides of Sulphur as SO2. A summary of the results is presented in Table

2.3.4

The average monitoring results from each boiler were used in computing the data in Table 2.3.4 based on the

maximum theoretical exhaust rate for the boilers and the actual operating time for each boiler during the

year.

The calculations assume that each boiler discharged emissions for its full operating time. Only one boiler is

operational at a given time. Boiler X3003 ran for approx. 1464 hrs and boiler X3021 ran for approx 5520 hrs

during 2008 both with an average flowrate of 1600Nm3/Hr.

CORDEN PHARMACHEM



2007 Mass Emission (Kg/year)

2008 Mass Emission (Kg/year)

Boiler ID Nitrogen Oxides

(as NO2)

Nitrogen Oxides

(as NO2)

Nitrogen Oxides

(as NO2)

Nitrogen Oxides

(as NO2)

Carbon Monoxide

Sulphur Dioxide

Average of X3021 & X3003

1044 1040 216 53 427 195

Table 2.3.2 Boiler Emissions

2.3.3 Dust Emissions Summary

In accordance with Schedule B, a summary report of dust emissions for 2007 and 2008 to atmosphere are

presented in Table 2.3.5.

Location Licensed Mass Emission (kg/yr)

2007 Mass Emission (kg/yr)

2008 Mass Emission (kg/yr)

A2/1 (Formerly A1/2)

Total Dust n/a 0.5 0.58kg (0.07mg/m3)

Total Dust 54.3 3.9 A2/2 (formerlyA1/3) Active Dust 8.147 Not Detectable

Not in operation

Total Dust 54.3 3.9 A2/3 (formerly A1/4) Active Dust 8.147 Not Detectable

Not in operation

Total Dust 89.9 5.2 A2/4 (formerly A1/5) Active Dust 13.48 Not Detectable

Not in operation

Total Dust 412 4.2 4.3 A2/5 (formerly A2/10) Active Dust 61.7 Not Detectable Not Detectable

A2/6 (formerly A2/17)

Total Dust n/a <1 Not in operation

Active Dust n/a Not Detectable

Table 2.3.3. Summary of Dust Emissions

Refer to Appendix VI for further dust reports of 2008. All analysis were within IPC/IPPC licence limits.

A2/5 monitoring was conducted by Corden Pharmachem personnel, while A2/1 was monitored by ASEP.

CORDEN PHARMACHEM



2.3.4 PRTR Table – Emissions to Air

4.1 RELEASES TO AIR SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS

RELEASES TO AIR POLLUTANT METHOD QUANTITY

Method Used A2/1 A2/5 A2/6 Boilers:

A1/1;A1/2

No. Annex II Name M/C/E

Method Code


Emission Point 1

Emission Point 2

Emission

Point 3 Emission Point 4

T (Total) KG/Year



06 Ammonia (NH3) M ALT NIOSH 6016: Ion Chromatography 0.258 0.0 0.0 0.0 0.258 0.0 0.0

03 Carbon dioxide (CO2) C PER 56.832 tCO2/TJ 0.0 0.0 0.0 1.01 1.01 0.0 0.0

80 Chlorine and inorganic compounds (as HCl) M ALT

1911 to 3 1998: NIOSH 7903 48.2 0.0 0.0 0.0 48.2 0.0 0.0

08 Nitrogen oxides (NOx/NO2) M ALT

Use of MADUR GA 40T plus portable flue gas analyser using electorchemical and IR gas sensors (non dispersive) 0.0 0.0 0.0 53.4 53.4 0.0 0.0

85 Hydrogen cyanide (HCN) M ALT NIOSH 6010:Spectrophotometry 22.6 0.0 0.0 0.0 22.6 0.0 0.0

07 Non-methane volatile organic

compounds (NMVOC) M ALT MDHS 72 - analysis by thermal desorption GCMS 102.0 5720.0

12400.0 0.0 18222.0 0.0 0.0

47 PCDD + PCDF (dioxins +

furans)(as Teq) M EN 1948 USEPA Methods 8290 1613 for analysis 0.0 0.0 0.0 0.0 0.0 0.0 0.0

11 Sulphur oxides (SOx/SO2) M

ISO 1948:19

98 7.43 0.0 0.0 195.0 202.43 0.0 0.0

CORDEN PHARMACHEM



SECTION B : REMAINING PRTR POLLUTANTS

RELEASES TO AIR POLLUTANT METHOD QUANTITY

Method Used A2/1 A2/5 A2/6 Boilers

A1/1;A1/2

No. Annex II Name M/C/E

Method Code Designation or Description

Emission Point 1

Emission Point 2

Emission

Point 3 Emission Point 4

T (Total) KG/Year



02 Carbon monoxide (CO) M ALT

Use of MADUR GA 40T plus portable flue gas analyser using electorchemical and IR gas sensors (non dispersive) 7.8 0.0 0.0 427.0 434.8 0.0 0.0

73 Toluene M NRB MDHS 72 7.1 676.0 1290.0 0.0 1973.1 0.0 0.0

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

the delete button

CORDEN PHARMACHEM



SECTION C : REMAINING POLLUTANT EMISSIONS (As requi red in your Licence) RELEASES TO AIR

POLLUTANT METHOD QUANTITY

Method Used A2/1 A2/5 A2/6

Pollutant No. Name M/C/E

Method Code Designation or Description

Emission Point 1

Emission Point 2

Emission

Point 3 T (Total) KG/Year



206 Benzene & toluene & xylene

(combined) M ALT MDHS 72 7.1 676.0 1290.0 0.0 0.0 0.0 210 Dust M ALT Gravimetric 0.58 0.0 0.0 0.58 0.0 0.0

214 Hydrogen bromide M ALT NIOSH 7903 - Ion chromatography 7.09 0.0 0.0 7.09 0.0 0.0

230 TA Luft organic substances

class 1 M ALT MDHS 72 0.0 0.0 0.0 0.0 0.0 0.0


class 2 M ALT MDHS 72 7.21 729.0 1510.0 2246.21 0.0 0.0


class 3 M ALT MDHS 72 82.3 5000.0 10900.

0 15982.3 0.0 0.0 244 Total Particulates M ALT Gravimetric 0.58 0.0 0.0 0.58 0.0 0.0

237 Volatile organic compounds (as

TOC) M ALT MDHS 72 89.5 5730.0 12400.

0 18239.5 0.0 20.0 323 Methanol M ALT MDHS 72 0.0 11.6 0.0 11.6 0.0 0.0

351 Total Organic Carbon (as C) M ALT MDHS 72 89.5 5730.0 12400.

0 0.0 0.0 0.0

352 Total Organic Carbon (as

Toluene) M ALT MDHS 72 7.21 676.0 1290.0 1973.21 0.0 0.0

CORDEN PHARMACHEM



2.4 Waste Management

In accordance with Condition 11.7 & 11.8 of the IPPC License a copy of the waste management record has

been submitted as part of the AER and the PRTR.

During 2008, approximately a total of 1515 tonnes of hazardous waste was generated onsite. The majority of

this was waste solvent, which arose from processes in PB1. Other hazardous waste streams generated on site

included, solid hazardous waste, waste oils, spent fluorescent tubes, batteries and empty gas cylinders.

A total of 221 tonnes of non-hazardous waste was generated on-site in 2008. The majority of this waste

consisted of solid miscellaneous waste (canteen and office waste) and commercial and industrial waste.

However, glass, scrap metal, paper and cardboard were recovered & recycled by approved agents. The Non-

Hazardous waste sent for disposal also consisted of dried sludge from the wastewater treatment plant.

The waste tables for 2008 in appendix VII . A summary of the total annual tonnage of hazardous and non-

hazardous waste for 2007 and 2008 is presented in Table 2.4.1 below:

Waste for 2007 (tonnes)

Non-Hazardous

Waste Hazardous Waste Total

Recovered 228 1182 1410

Disposed 49 1254 1303

Total 277 2436 2713

Waste for 2008 (tonnes)

Non-Hazardous

Waste Hazardous Waste Total

Recovered 194 1006 1200

Disposed 27 509 536

Total 221 1515 1736

Table 2.4.1: Waste Management Report

The total waste figures produced in 2008 show a slight decrease of 36% on the 2007 total (mainly due to

production shutdown during the year). The overall total of waste generated, both hazardous and non

hazardous was 1736 metric tonnes.

CORDEN PHARMACHEM



The multi-product and batch nature of production somewhat minimises the possibility of making direct

comparisons from one year to another, however the recovery of hazardous waste is always the preferred

option.

During 2008, the segregation of hazardous liquid wastes on site continued to be addressed. Great emphasis

was placed on segregating solvent waste streams with high calorific value, from streams of lower calorific

value arising from the production processes.

Work on material and waste reduction is continually assessed during the year . Due to the multi product

nature of the facility, cGMP rules regarding solvent recovery, etc we were not able to fully investigate

techniques such as on site solvent recovery.

Aspects of waste management are targeted in our EMP from year to year if feasible. The following

represents the total quantity of waste (HAZ) generated per metric tonne of product sold for 2008 and

previous years.

29

21.9 20.1 20.7

29.7

05

1015202530

2002 2005 2006 2007 2008

Metric tonnes Waste Vs MT Product

MT Waste /MT Product

CORDEN PHARMACHEM



Waste Disposal Carriers/Hauliers

The names of the carriers of the waste from the site and their permit details (including issuing authority) are

provided in Table 2.4.2.

Carriers Name Waste Collection

Permit No. Issuing Authority

Ipodec Ireland Ltd CK WMC 10/01 Cork County Council

Tank Trans Ltd CK WMC 67/01 Cork County Council

JP Ryan & Sons Ltd CK WMC 34/01 Cork County Council

Murphy Transport Ltd CK WMC 19/01 Cork County Council

Molloy & Sherry Transport Ltd CK WMC 122/02 Cork County Council

Cleanaway4 (Cara) CK WMC 53/01 Cork County Council

S (Transport) Cork Ltd CK WMC 70/01 Cork County Council

Irish Lamp Recycling Co Ltd CK WMC 57/01 Cork County Council

Returnbatt Ltd CK WMC 80/01 Cork County Council

Johnson Haulage Co Ltd CK WMC 50/01 Cork County Council

Cork Metal Company CK WMC 26/01 Cork County Council

Atlas Environmental Ireland Ltd. CK WMC 16/01 Cork County Council

South Coast transport Ltd CK WMC 07/01 Cork County Council

Bailey Waste Recycling Ltd. CP D59/1 Dublin City Council

Indaver Ireland CP D53/1 Dublin City Council

Gandon Enterprises Ltd t/a Rehab

Recycling Ltd WCP/LK/119/03b Limerick County Council

Collins Waste Disposal CK(S) WMC 18/02 Cork County Council

AVR-safeway

Table 2.4.2: Names of the carrier of the waste and their permit details (including issuing authority)

4 This haulier was only used for a small number of waste IBC collections in the year. This haulier is licensed under the Cara Permit No.

CORDEN PHARMACHEM



Waste Disposal Contractors

Details of the ultimate disposal/recovery destination facility for the waste from the site (including its permit

details and issuing authority) are provided below in Table 2.4.3:

Carriers Name Waste Collection Permit No. Issuing Authority

Ipodec Ireland Ltd CK WMC 10/01 Cork County Council

Tank Trans Ltd CK WMC 67/01 Cork County Council

JP Ryan & Sons Ltd CK WMC 34/01 Cork County Council

Murphy Transport Ltd CK WMC 19/01 Cork County Council

Molloy & Sherry Transport Ltd CK WMC 122/02 Cork County Council

Cleanaway5 (Cara) CK WMC 53/01 Cork County Council

S (Transport) Cork Ltd CK WMC 70/01 Cork County Council

Irish Lamp Recycling Co Ltd CK WMC 57/01 Cork County Council

Returnbatt Ltd CK WMC 80/01 Cork County Council

Johnson Haulage Co Ltd CK WMC 50/01 Cork County Council

Cork Metal Company CK WMC 26/01 Cork County Council

Atlas Environmental Ireland Ltd. CK WMC 16/01 Cork County Council

South Coast transport Ltd CK WMC 07/01 Cork County Council

Bailey Waste Recycling Ltd. CP D59/1 Dublin City Council

Indaver Ireland CP D53/1 Dublin City Council

Rehab Recycling Ltd

(Gandon Enterprises Ltd) WCP/LK/119/03b Limerick County Council

Collins Waste Disposal CK(S) WMC 18/02 Cork County Council

AVR-safeway

5 This haulier was only used for a small number of waste IBC collections in the year. This haulier is licensed under the Cara Permit No.

CORDEN PHARMACHEM



Disposal and/or Recovery Destination

Facility Name Waste Permit No. Issuing Authority

Rossmore Landfill Site, Co Cork Waste licence No. 22-1 Irish EPA

Innovatherm, Germany

56.8851.1.3/8.1-G

Umweltschutz Ruhr GmbH

Betram, Sturnshof 20, Bottrop,

Germany G62.352/00/0811 B2 Staatliches Umweltamt Herten

Gruba gesellschaft fur, Germany

(formerly Buchen Umweltservice

GmbH, Germany: name change in

Sep/Oct 2003)

529/1772/Efb ZER-QMS GmbH

Cleanaway Ltd, UK

AG8233

UK Environment Agency

Kommunekemi A/S, Denmark

131/070-0002

Miljoministeriet Miljostyrelsen

Sava, Germany

A 51 G 00 508

GOES

Shanks Chemical Services, Scotland IPC/001/1994 Scottish EPA

Soltec (Irl) Ltd., Co Westmeath Waste licence No. 115-1 Irish EPA

SRM, UK (Lancashire) Env Licence AG9248 UK Environment Agency

SRM, UK (Sunderland)

Transfer Station (TW 306

SL)

Solvent Recovery Plant

(AG8594/AT2616)

UK Environment Agency

& Her Majesty’s Inspectorate of

Pollution (UK)

SRM, UK (Rye Harbour)

AG 8039/AH3881

Her Majesty’s Inspectorate of

Pollution (UK)

AVR Chemie

(now closed 09/2005)

NV Afvalverwerking Rijnmond (AVR) Lic.: 340618/20176136

Prof. Gerbrandijweg 10 Rob Sasse

NL-3197KK Rotterdam-Botlek +31-181 273 3479

340618/11.2005 VROM

Shannon Environmental Services, Co. Waste licence No. 41-1 Irish EPA

CORDEN PHARMACHEM



Clare

SITA Environmental Ltd Waste licence No. 83-1 Irish EPA

Dow Halterman

Middlesbrough

BT9828

Environment Agency

Kinsale Road Landfill Waste licence No. 12-2 Irish EPA

Cara Waste, Minane Bridge (Sludge) Irish EPA

TRV, Holland (no longer used) Liquid Hazardous VROM

McGill Env. systems (Sludge) Irish EPA

AVG - Hamburg Hazardous Solvent &

packaged waste Council of Hamburg

REMAT Hazardous

LGM 640455

Provincie Noord Brabant,

Holland

Remondis

Remondis Production GmbH Lic.: 21/Fo/Tho-G61/93

Brunnenstr. 138 Michaela Koch

DE-44536 Lunen +49-2306 106342

NH Sludge Germany

NV Afvalwerking Rijnmond Holland

AVR Environmental Solutions Youghal NH Sludge W0211-01 EPA

Table 2.4.3: Details of the ultimate disposal/recovery destination facility for the waste (including its permit

details and issuing authority)

CORDEN PHARMACHEM

Section 3: Resource Consumption


3. ENERGY AND WATER CONSUMPTION

3.1 Energy & Water consumption.

Details of electricity consumption, boiler fuel consumption and water consumption for 2007 and 2008 are

presented in Table 3.1 below. Refer to appendix VII for a more detailed Electric usage report

Parameter 2007

2008

Electricity consumption (MWh)

4988 3452

Natural Gas consumption (MWh)

6642 5477

Water consumption (m3)

68,377 33,357

Finished product manufactured (tonne)

117.64 51

Table 3.1 Resource Consumption Summary

Corden PharmaChem are still implementing the action items arising from an energy audit carried out in

2003. We have carried out site energy audits to identify losses in the following systems, electrical, gas and

steam distribution, compressed air, nitrogen and hot water systems. An energy Management team has been

set up in 2007/2008 to help enforce energy awareness and to implement energy savings initiatives.

We have also reviewed processes and major pieces of plant such as pumps, fans and motors. We have

replaced defective or inefficient steam traps, installed an additional metering system that monitors power

consumption and utilities consumption.

Projects identified in our 2009 EMP proposal (Appendix XI) address the objective of conserving resources

such as water and energy, other projects include smaller projects such as switching to more energy efficient

lighting

CORDEN PHARMACHEM

Section 4: Environmental Incidents


4. ENVIRONMENTAL INCIDENTS AND COMPLAINTS

4.1 Incidents 2008

Incidents which affected the normal operation of site activities in 2008 are summarised as follows. None of

these had any impact on the environment.

4.1.1 Incident 01-08 Over pressurisation of Waste Drum

An incident occurred on 02nd March at approximately, which involved the over-pressurisation of a 200 litre

drum, containing tetrahydrofuran and magnesium and the subsequent release of its contents causing solvent

spillage, damage to drum store roof and racking and that other drums appeared to have fallen to ground.

This incident occurred in a drum-store onsite. There were no injuries and all liquid spilled was contained

locally. Physical damage to the drum-store was minimal.

The emergency services were called and remained on site for a number of hours during the clean-up in an

observational & supporting role. As the Fire Brigade confirmed their satisfaction with the on-site operations,

they left the site at shortly afterwards. One of the first tasks completed was the venting and removal of

potentially pressurized drums from the drum store, as well as ensuring that all waste drums onsite were in a

safe mode.

Investigation

The material in question is THF/Mg taken from K2009 reactor, prior to beginning a Tramadol Grignard

reaction. Water in Grignard reaction vessel is well known to inhibit initiation of the reaction and could lead

to reactor contents having to be disposed of if the reaction does not initiate. This is hazardous in itself but if

addition continued then accumulation of added materials would result and sudden initiation (possible in

Grignard type reactions) could result in an uncontrollable incident in vessel. All Corden precautions are to

avoid any possibility of this scenario. Thus if initial raw material, Mg and THF , fail the water content in-

process analysis before any reactants are added to vessel, it is removed and fresh material added. This occurs

approximately 1-2 times a year or once every 40 batches.

Hydrogen Evolution Trials

From hydrogen evolution trials carried out by R&D, the presence of rust seems to catalyse the generation of

gas (H2) and prolong gas evolution period.

CORDEN PHARMACHEM



Conclusions

The factual conclusions of this investigation are as presented below

1. Failed drum attained pressure of 2.5Bar, or higher, before rupture.

2. Increased water content in drummed material could not be classed as only cause of incident, as material

with far higher water content did not experience the same volume of gas evolution and pressure build up.

3. Presence of rust accelerates rate of generation of gas (H2) and prolongs gas evolution period

substantially. This is actual cause of incident.

4.1.2 Incident 02-08 Waste Treatment Incident

In the course of treating the cyanide-containing wastewater from a CMP Batch in V6033 (waste

treatment tank) on 07th March 2008, an incident occurred which resulted in the shearing of the

polypropylene vent pipes on V6033 and in addition, the agitator motor was found on the catwalk

adjacent to the vessel and the contents leaked through the bottom outlet valve (BOV) into the

bund.

Due to the leaking BOV, all of the batch in V6033 drained to the bund in the aftermath of the

incident. It was recovered and stored in an adjacent vessel along with the bund water.

Incident Description

V6033 contained 2800 L of wastewater at 37 ºC, when the operator added 50 L of 35 % H2O2. The addition

elicited a relatively typical temperature rise (37 to 44 ºC) and level gauge response (to foaming). At 9 am the

operator added a further 50L of 35 % H2O2, and 15 minutes later the incident occurred.

Fuel/Ignition Source

From analysis and calculations carried out it is concluded that a vapour phase explosion occurred

due to presence of acetone in the headspace.

Sparking or overheating due to a failed agitator bearing provided the ignition source.

CORDEN PHARMACHEM



4.1.3 Incident 03-08 PB2 Reaction Vessel Incident – Update

An incident occurred in PB2 building on 28th April at approximately 01:30, which unfortunately resulted in

the fatality of an employee, and injury to one other. This was reported to EPA by phone at approximately

03:00 and by notification report dated 09 May 2008. This incident involved the over-pressurisation of a

process reaction vessel in PB2. The emergency services were called at the time and remained on site for a

number of hours.

As a result of this incident, production was put on hold and each process step would only restart once a full

safety review/Hazops review and subsequent action items were completed. Start up of production was

therefore on a gradual basis. Production ultimately restarted in PB1 in Mid August.

PB2 production plant has since partially reopened, ground floor areas such as Mill room, dryers etc are now

operational. However the reactor and centrifuges area remain closed pending final repair and commissioning.

There were no significant emissions or release to the environment as a result of this incident.

The Health and Safety Investigation into this incident is still ongoing. Over 100 hazops and safety reviews

have since been completed since the above incident, as of 20 Janurary 2008 and Corden Pharmachem

Management and Staff are still conducting safety reviews of remaining processes.

In an effort to optimise production from PB1, Corden Pharmachem has moved to a 4 shift cycle since

October 2008.

CORDEN PHARMACHEM



4.2 Thermal Oxidiser Bypasses

Thermal oxidiser (TO) bypasses gave rise to the most frequently reported incidents during 2008. The

oxidiser control system is designed in such a way that an automatic and failsafe shutdown occurs when

certain operational limits are exceeded. There were IPPC licence breaches during these bypasses, are during

normal operation of the TO.

4.2.1 Causes of bypass

The vast majority of bypasses during 2008 were caused by low bed temperatures (84 or 64% of bypasses).

When the bed temperatures fall below 260ºC, the TO goes into bypass and will not be available to restart

until temperatures are >320ºC. High LEL caused 23 (17%) bypasses, Mechanical faults caused 14 bypasses.

LEL bypasses are caused by high solvent levels and are detected by a lower explosive limit (LEL) analyser.

LEL bypasses can cause the thermal oxidiser to go into safety shutdown. During a shutdown all process

emissions are discharged to a by-pass vent. The main events giving rise to bypasses in 2008 are summarised

as follows;

• Low bed temperatures.

• High LEL

• Mechanical fault (control valves sticking).

• Planned Maintenance

• Loss of steam

4.2.2 Bypass time

Total by-pass time for January–December 2008 was 389.4 hours (23,364 minutes). Weekend bypass duration

during plant shutdown for Q1 and Q2 alone was 22714 and for Q3 and Q4 alone was 3141minutes. During

Q1 and Q2, 51% of the bypass time occurred during weekend shutdowns. Of the annual bypass duration,

17,459 minutes or 75% of bypass time was caused by Low Bed Temperatures and 761 minutes or 3% of

bypass time was planned. Mechanical faults caused 2,930, minutes or 13% of the bypass time. High LEL

accounted for 363 minutes or 1.6% of the total bypass time for 2008

4.2.3 Mass emissions.

The mass VOC emissions during bypasses for 2008 were ~20Kgs Vs 33Kgs for 2007 Vs 36Kgs for 2006.

This represents a reduction of mass emissions of 65% in VOC mass emissions,. This reduction in VOC

CORDEN PHARMACHEM



emissions is due to the fact that most bypasses were mechanical or caused by low bed temperatures during

time of low/No emissions and also due to the production and TO shutdown during the year.

4.2.4 2008 performance

Overall the thermal oxidiser was online for approximately 95% of the time in 2008 including weekends. This

compared to the highest recorded online time of 99.1% for 2005 is a small decrease. However as already

stated the reason for this is due to increased low bed temperature bypasses, which Engineering and the

suppliers, KEU have worked on to help alleviate the issue during the shutdown in July 2007 as is well

documented with the agency

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

2004 2005 2006 2007 2008

Bypass time (mins)

277

37.4 35.7 33 19.58

0

50

100

150

200

250

300

Jan 2003- Jul2004

2005 2006 2007 2008

VOC massemissions(kgs)

CORDEN PHARMACHEM



4.2.5 HCl Compliance

100% compliance with HCl limits during 2008 was achieved.

Month Number of HCl 30 minute mean load breaches (i.e. >20mg/m3)

Percentage HCl 30 minute mean compliance

Number of HCl 24 hr mean load breaches (i.e. daily average >10mg/m3)

Percentage HCl 24 hr mean compliance

Jan ‘08 0 100% 0 100% Feb ‘08 0 100% 0 100% March ‘08 0 100% 0 100% April ‘08 0 100% 0 100% May ‘08 0 100% 0 100% June ‘08 0 100% 0 100% July ‘08 0 100% 0 100% August ‘08 0 100% 0 100% September ‘08 0 100% 0 100% October ‘08 0 100% 0 100% November ‘08 0 100% 0 100% December ‘08 0 100% 0 100%

Table 4.2 HCL Compliance as per continuous Analyser

4.3 Complaints

In accordance with Condition 11.4 and schedule D of the IPPC licence, a summary report of the number and

nature of complaints received is included in the AER. Corden PharmaChem have a documented procedure

for recording environmentally related complaints as part of their Environmental Management System.

1 complaint was received during 2008 Vs 7 in 2006, from a neighbouring Farmer. This is summarised in

Table 4.2.1 below. Summary of incident is below:

Summary of Odour Complaint

On 22nd August 2008 an odour complaint was received from a neighbouring farmer, Mr Delaney. There was

an easterly wind at the time and the complainant reported getting odours from the wastewater treatment

plant.

CORDEN PHARMACHEM



Corden carried out an investigation and survey around site and noted that there had been an odour around the

WWTP, mainly due to the recommencement of production and the aeration of old sludge in the sludge tank. .

There were low flows through the wastewater treatment plant due to production being shut down for a

number of weeks and as a result levels of waste and fresh sludge decreased.

It was therefore concluded that the odour had arisen due to the anaerobic activity in the sludge at the bottom

of the sludge tank as it was being emptied (age of sludge greatest at bottom of tank). Levels were lower than

usual due to production shutdown, with no fresh waste/sludge being supplied.

Odour surveys were carried out as per usual and the degree of aeration of the old sludge was controlled so to

avoid the dispersion of further odours.

Category of Complaint

Number of Complaints 2008

Odour 1 Noise 0 Water 0

Procedural 0 Miscellaneous 0

Total

1

Table 4.2.1 Complaints Summary

CORDEN PHARMACHEM

Section 5: Management of the Activity


5. MANAGEMENT OF THE ACTIVITY

5.1 Environmental Management System

In accordance with Condition 2.2 Corden PharmaChem have established and continue to

maintain an Environmental Management System (EMS).

ISO14001 accreditation was achieved in Corden PharmaChemin March 2003.

A very successful surveillance audit was undertaken by NSAI in October 2007 on the Corden

ISO 14001 Environmental Management System, within which the IPC non compliances and

subsequent corrective action plans were noted. It was noted that the EMS and general

environmental performance was of a high standard and continually improving. A

recertification audit is due in 2009.

3.2 Human Resources, Training and Education:

Under Condition 2.2.2.6 of the Company’s IPPC licence, Corden PharmaChem are required

to establish and maintain procedures for identifying training needs, and for providing

appropriate training, for all personnel whose work can have a significant effect upon the

environment. Corden PharmaChem are also required to provide appropriate training for

personnel who perform certain tasks, which have significant environmental implications.

During 2007/2008, in-house environmental training/environmental awareness training

sessions were conducted and as required.

5.3 Schedule of Environmental Objectives and Targets

Condition 2.2.2.2 of Corden’s IPC licence requires a schedule of Environmental Objectives

and Targets to be drawn up. The Licence also requires that time frames be included for the

achievement of set targets.

A review of the 2008 Environmental Objectives and Targets/EMP are presented in Appendix

IX of this report. Due to production shutdown during the year some projects were

deferred/cancelled.

The Environmental Objectives and Targets proposed for 2009 are presented in Appendix X.

CORDEN PHARMACHEM

Section 5: Management of the Activity


5.4 Environmental Management Programme

Condition 2.2.2.3 of the IPPC licence requires an Environmental Management Programme

(EMP) to be maintained. The License requires that the EMP shall include designation of

responsibility for targets, the means by which they may be achieved, the time within which

they may be achieved.

Details of the EMP Review of 2008 are presented on a project basis in Appendix IX.

The EMP proposal for 2009 is included in Appendix XI of this report.

CORDEN PHARMACHEM

Section 6: Licence – Specific Reports


6. LICENCE SPECIFIC REPORTS

6.1 Noise

In accordance with Condition 6.12 of the IPPC licence an annual environmental noise survey

was undertaken at the Corden PharmaChem site. The 2008 survey was undertaken in

November.

The full report on the results and methodology of the 2008 noise survey is presented in

Appendix XII of this report.

Table 6.1.1 outlines a summary of the specific source measurements from the Corden

PharmaChem site. These results are within the limits specified in Schedule 4(i) of original

IPC licence P0134-02

dB (A) @ reference distance

Ref Description

Max. Ref Dist (m)

SPL Limit

SPL 2006

SPL 2007

SPL 2008

NS1 Pump House 5 68 63 62 63

NS2 Glycol Pumps 3 76 76 75 76

NS3 Liquid Ring Pumps 3 75 73 73 74

NS4 Air Handler (high level) 10 60 62 61 60

NS5 Boiler House 5 62 N/A N/A N/A

NS6 Treatment Plant Comp 5 63 65 63 63

NS7 Generator 5 90 N/A9 N/A N/A

NS8 Scrubber Pumps 3 72 73 73 72

Table 6.2.1 Comparison between Schedule 4(i) of IPC license and observed sound pressure

levels (SPL)

NS1, NS2, NS3, NS4, NS5, NS6, and NS8 are within the limits specified by the schedule.

Source NS7/NS5 was not operating during the survey period. The ambient noise levels in

daytime and night time, and predicted impact at our nearest sensitive neighbour have not

changed in 2008 .

CORDEN PHARMACHEM



Table 6.2.2 outlines the noise levels at noise sensitive locations identified from the Corden

PharmaChem site:

Ambient Noise Daytime,

30 min LAeq

Ambient Noise Night time,

15 min LAeq Ref Description

2006 2007 2008 2006 2007 2008

B1 North Boundary 61 56 54 58 55 53

B2 West Boundary 60 59 64 58 58 58

B3 East Boundary 56 58 55 51 54 50

B4 South Boundary 55 59 51 56 54 49

B5 West Boundary 61 60 61 62 61 61

B6 East Boundary 56 58 56 55 52 53

S1

Sensitive Area 1:

Local farm yard/golf course

55 58 57 53 46 45

S2

Sensitive Area 2:

Private residence – on public road

61 62 64 54 49 51

S3

Sensitive Area 3:

Private residence– Estate off public road

58 61 63 47 46 44

Table 6.2.2 Noise Sensitive Locations Result

Daytime ambient noise

According to Schedule B4 and Condition 4.5 of the IPPC license, the maximum daytime

noise levels measured at NSLs is specified as 55 dB(A) (Leq, T). In 2008, this limit was

exceeded at sensitive areas S1, S2 and S3. This was due to neighbouring facilities and road

traffic

Night-time ambient noise

According to Schedule B4 and Condition 4.5 of the IPPC license, the maximum night time

levels off site is specified as 45 dB(A) (Leq, T). In 2008, this limit was exceeded at S2.

CORDEN PHARMACHEM



As reported previously, there are other larger plants and road traffic in the area, which

contribute more to the overall noise measured at sensitive receivers in particular, than does

Corden PharmaChem. These sensitive receivers are located adjacent to a main road and

several industrial sites which are situated much closer to the receiver than Corden. S1

sensitive receiver is unoccupied farmland.

6.2 Groundwater Monitoring

In accordance schedule C6 of the IPPC license, groundwater monitoring points have been

sampled and analysed for 2008. This Schedule requires biannual monitoring of pH,

temperature, conductivity, level, major anions, major cations, nitrate, total ammonia,

volatile/semi-volatile organics and heavy metals. A report of this monitoring is submitted

biannually and a summary report submitted as part of this AER.

The groundwater sampling was conducted by O’Callaghan Moran and analysis was

conducted by Alcontrol and the full reports are presented in Appendix XIII. The groundwater

monitoring results for 2008 are improved in quality, especially for MTBE. The results are

summarised below:

• All wells except MW-7 with levels of 13.3mg/l in March 2008 were found to

contain less than the Dutch list indicative level of MTBE (9.2 mg/L).

• MTBE was present in levels over EPA IBV of 0.03mg/l in wells, MW-1, 3, 4, 7, 8,

in both March and November 2008 and MW 10 exceeded this level in March only.

However the MTBE concentration is falling from the levels found in 2003/2004 and

is now usually undetected in 3 wells. There have been no incidents or identifiable

on-site sources of MTBE leakage to groundwater at the facility since the previous

round of monitoring was undertaken. The source(s) of MTBE are not considered to

be associated with on-going releases of these parameters to the ground or

groundwater beneath the site.

• Sewage odours detected in wells MW -5 and 6 and Ammonia levels were above

EPA IGV level of 0.14mg/l in all wells on both sample dates. Ammonia

concentrations continue to be elevated and have generally decreased slightly since

the previous monitoring period. There has been an increase in the concentration in

CORDEN PHARMACHEM



MW-6 since March 2007. It is likely that elevated ammonia levels in the groundwater

originate from upgradient off-site source areas possibly associated with leaking sewers.

• Corden PharmaChem believe this lends credence to our view that treated effluent

and sewage is leaking from a damaged Cork County Council sewer line, as

previously notified to the Agency. For this reason Corden PharmaChem have

relocated final outfall line disharge line (end 2007/beginning 2008)from old IDA

sewer on west of plant to east side of plant , the flaxfort road sewer

• No other organic compound occurred above EPA IGV levels

• The odours and the high levels of total coliforms detected indicate possible

contamination of the groundwater associated with potential leakage from the former

IDA/County Council foul sewer along the FMC/Corden PharmaChem boundary.

The most likely source of contamination in the groundwater beneath the site is

leakage from the former IDA/Council process sewer system up hydraulic gradient of

the facility.

• Monitoring in accordance with IPPC licence conditions will continue to be used to

assess groundwater quality. The presence of upgradient sources of contamination

inhibits an accurate evaluation at this time.

• Based on the results there still appears to be an ongoing source of pollution up

gradient of Cordens site, emphasizing the need for repair on the council sewer

CORDEN PHARMACHEM



6.3 Bund Testing

Due to changes in personnel at the contract engineers and due to the incident ot Cordens site

in April 2008, bund testing was delayed. A schedule of testing has been drawn up and all

bunds due for testing will be done this year. The Bunds tested this year so far are B5, B7,

B10, B11, B12, all of which passed. Refer to Appendix XIV for Bund certificates and

procedure for bund testing, which was compiled in accordance with EPA guidance document

on the ‘Storage and Transfer of Materials for Scheduled Activities’ (2004).

The schedule below outlines which bunds are due to be tested during 2009 - include B1, B2,

B3, B4, B8A, and B6A. B1 – B4 cannot be tested until shutdown later in 2009.

Bund 20

03

2004

2005

2006

2007

2008

2009

B1 PB1 Tankfarm * * *



B3A PB1 Tankfarm * *


B5 TO Scrubber Bund * *

B6A Diesel Tank * *

B7 Refrigerant tank bund * * *

B8A PB2 Tank farm (neutralisation tank area) * *

B10 PB2 solvent tank farm * * *

B11 PB1 ambient cooling tank bund * * *

B12 Dump tank PB1 * *

B13 Pump bund strong waste tanks * *

B14 Floor collection bund warehouse * *

B15 PB1 Neutralisation Bund * *

Table 6.4.1 Bund Testing Timetable

CORDEN PHARMACHEM



6.4 Toxicity Testing of Effluents In accordance with schedule C.3.2 of the licence, requires that respiromety of the final

effluent is tested on an annual basis. In 2008 a Respirometry inhibition test on activated

sludge in March were <2 T.U. for 180 min EC50. The Corden PharmaChem trade effluent

sample exhibited a low level of inhibition to Carrigrenan activated sludge with an EC50 value

“greater than 50 % concentration v/v” and an Inhibition Threshold of 30 to 40 % v/v. This

means that the Corden effluent would need to be less than 30 % of the domestic flow in the

sewer to minimise the risk of acute inhibition/toxicity to the activated sludge in the treatment

plant.

At this level our wastewater does not inhibit the activated sludge mixture from the

Carrigrennan plant. In terms of flow, our 80-90 m3 per day would only be expected to have a

minimal impact on the operation of the plant. Corden PharmaChem are licensed to discharge

a maximum of 255 cubic meters of trade effluent per day to the local authority sewer. The

total Dry Weather Flow (DWF) into the Carrigrenan treatment plant is estimated at around

50,000 cubic meters per day and this flow is in the region of 43 % domestic and 57 %

industrial. Based on the company discharging at their maximum discharge allowance of 255

cubic meters per day and a domestic DWF of 21,500 cubic meters per day the Corden trade

effluent would only represent around 1.2 % of the domestic DWF in the sewer. This is

significantly lower than the inhibition threshold of greater than 50 % v/v.

Test reports are contained in Appendix XV.

Corden PharmaChem AER Appendices Page 52 of 104

APPENDICES


Appendix I

Site Plan of the Corden PharmaChem Facility


Appendix II

Corden PharmaChem Organisation Chart

08-04-02 1

Personnel - Organisation

Managing Director

Finance, Admin & IT

Cust. Support& Logistics

Quality Operations R&D EHS

HR & Admin

IT

QC

RA

Production

Engineering

Customer Support

IRL & UKSales

6 8 20 57 9 2

Chemistry

AnalyticalServices

QAFinance Materials

Process Innovation


Appendix III

Environmental Policy Statement

ENVIRONMENTAL POLICY

We at Corden PharmaChem, recognise that our operations have an impact on the surrounding

environment and are committed to a cleaner, healthier environment. We therefore

acknowledge our duty in ensuring that all activities are conducted in an environmentally

responsible manner. Through this we are committed to the integration of sound environmental

programs and practices into our daily business activities at all workplaces so as to meet the

needs of customers, consumers, the company and the public.

With this policy we are committed to:

� Operating our business to meet or exceed the applicable environmental legislation

such as National and EU Legislation and the relevant Codes of Practice and

Guidelines.

� Identifying and reducing risk to minimise environmental impact arising from our

operations and products.

� Providing a framework for setting and reviewing measurable environmental

objectives and targets and to commit to the policy of continuous improvement aimed

at prevention of pollution and improving environmental performance.

� Maintaining an Environmental Management System of which consideration of

environmental concerns and energy efficiency are integral parts of all development

and planning stages.

� Optimising energy efficiency and conservation practices on all the company’s

operations.

� Promoting waste minimisation and to dispose of all waste in a responsible manner,

according to relevant statutory requirements.


� Ensuring that all Corden PharmaChem employees and persons working on behalf of

the company are aware of this policy and the requirements of Corden’s EMS

� Promoting environmental awareness among Corden PharmaChem employees and to

ensure all managers and employees understand their responsibilities and

accountabilities to deliver against the company’s environmental policy.

� Consulting with relevant regulatory agencies, environmental organisations and

interested parties on environmental matters. We recognise the importance of the

neighbourhood in which we operate and will consult with the local community as

necessary to ensure their views are considered.

____________________________

Patrick Burke Date Managing Director


Appendix IV

Incidents and Non-Compliances 2008 Compliance Summary Tables


WASTEWATER LICENCE NON COMPLIANCES 2008 Corden PharmaChem have had 4 final effluent licence breaches in 2008.

Monthly Monitoring

Period Parameter

Emission Point Ref

No.

No of exceedances

(i.e.>ELV) Vs No of samples

Maximum exceedance vs.

Emissions Limit Value

Cause Corrective Action

January 2008

Final Effluent: Total Suspended Solids

SE1 1 of 7

863 mg/l Vs 200 mg/l

High volumes entering WWTP and high levels of solids in the system

• As well as diversion in which the outfall was diverted to holding tanks, flow rates throughout the system were also reduced to help reduce the emissions loadings.

• Diversion and sludge removal helped reduce outfall flowrates as the plant re-established normal operating conditions.

• Increased monitoring of suspended solids

February 2008 Final Effluent: All Parameters

SE1 0 of 136

NA NA

NA

March 2008 Final Effluent: All Parameters

SE1 0 of 136

NA NA

NA

April 2008 Final Effluent: Total Suspended Solids

SE1 8 of 14

1015 mg/l Vs 200 mg/l

Due to high volumes of solids in the system and settleability problems

• Flow rates throughout the system were reduced to help reduce the emissions loadings

• Emptying and cleaning out of clarifiers carried out to help remove solids from the system

• Increased monitoring of suspended


solids April 2008 Final

Effluent: Total Sulphates

SE1 12 of 13 1340 mg/l Vs 500mg/l

A factor giving rise to increased sulphate levels was the bypassing of the sulphuric acid valve on 09th April. Approximately 500litres bypassed directly into the equalisation basin, thereby increasing sulphate levels. These high levels also continued into May and is counted as 1 Incident Breach

• The valve was subsequently fixed and normal service has resumed.

• Flow rates reduced • Increased monitoring of sulphates

May 2008 Final Effluent: Ammonia

SE1 9 of 24 110 mg/l Vs 50mg/l

Since the PB2 incident which occurred on 28th April 2008, production has been stopped until mid August 2008 and as a result the usual waste/feed for the wastewater biological system is not available. As a result the biological system was not operating as effectively as usual. Ammonia levels in the raw influent were lower than ammonia levels in the final effluent, which shows that there was an upset to the plant because of production shutdown. There was a source of waste onsite, which was fed in at a slow rate as it is a strong waste. The main bulk of the waste streams however were not available due to production shutdown.

• Sourced different waste from around site to improve biological properties of system.

• Increased monitoring of Ammonia

June – December 2008

Final Effluent: All Parameters

SE1 0 of ~ 900

NA NA

NA


SURFACE WATER NON COMPLIANCES

Corden PharamChem had 2 surface/storm water warning level exceedances in 2008 period

Monthly Monitoring

Period Parameter

Emission Point Ref

No.

No of exceedances vs. No. of samples

Maximum exceedance vs. Warning Level


January 2008

pH, Temp, BOD, COD, TOC

SW1 0 NA NA NA

February 2008

COD SW1 2 of 3 160 Vs 100mg/l COD

Testing of TOC analysers and cleaning of surface water chamber.

• Following extensive maintenance and cleaning of the TOC unit, it was planned to resume normal mode and closely monitor the situation to ensure compliance with IPPC licence.

• Surface water flow diverted to onsite containment

March – December 2008

pH, Temp, BOD, COD, TOC

SW1 0 NA NA NA


Thermal Oxidiser emissions summary Corden had 0 TOC mass emission licence breaches in 2008

Monthly Monitoring Period

Parameter Emission Point Ref No.

No of exceedances vs. No. of samples

Maximum exceedance vs. Emissions Limit Value


January - December

TOC mass emission

A2/1 0 of 1488 No exceedance No exceedance

No exceedance

February TOC mass emission

A2/1 0 of 1344 No exceedance No exceedance No exceedance

March TOC mass emission


April TOC mass emission

A2/1 0 of 1440 No exceedance No exceedance. No exceedance

May TOC mass emission

A2/1 0 of 0 (TO Shutdown)

No exceedance No exceedance. No exceedance

June TOC mass emission


No exceedance No exceedance No exceedance

July TOC mass emission


No exceedance No exceedance No exceedance

August TOC mass emission


September TOC mass emission


October TOC mass emission


November TOC mass emission


December TOC mass emission



HCL Compliances

Corden had 0 HCl licence breaches in 2008

Monthly Monitoring Period

Parameter Emission Point Ref No.

No of exceedances vs. No. of samples (1/2 hour value s >20mg/m3)

Maximum exceedance vs. Emissions Limit Value


January – December

2008

Hydrogen Chloride

A2/1 0 of ~ 12000 No exceedance No exceedance No exceedance


Appendix V

Dioxin Monitoring Report 2008

Not included, as Full AER Report in PDF would exceed 20mb capacity (already submitted to

EPA and in Paper version of AER - details in summary section of AER)


Appendix VI

Dust Monitoring for 2008



Appendix VII

PRTR Waste Tables for 2008


Transfer Destination

European 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 (HAZARDOU

S WASTE ONLY)

To Other Countries 07 05 01 Yes 190.0 LRDA Salts D8 M Weighed Abroad

AVR Safeway/W0050-2

Corrin, Fermoy, Co. Cork

ATM Afvalstoffen terminal Moerdijk BV Vlasweg 12, Seaport M152, 4782 PW Moerdijk, Netherlands 930809.002/4

To Other Countries 07 05 01 Yes 20.1 LRDA Salts D10 M Weighed Abroad

AVR Safeway/W0050-2


Sava GmbH, Osterweute 1 26541 Brunsbuttel, Germany

A 51 G 00 508

To Other Countries 07 05 01 Yes 71.5 Cyanide waste D10 M Weighed Abroad

AVR Safeway/W0050-2



A 51 G 00 508

Within the Country 07 05 01 Yes 163.0 Aqueous solvent R13 M Weighed

Offsite in Ireland

AVR Safeway/W0050-2


AVR Safeway, Corrin, Fermoy, Co. Cork W0050-2



European Waste Code

Hazardous

Quantity

T/Year



M/C/E

Method Used


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)

To Other Countries 07 05 01 Yes 45.1 Aqueous solvent D10 M Weighed Abroad

AVR Safeway/W0050-2



A 51 G 00 508


AVR Safeway/W0050-2


Pyros Environmental, Charleston Rd, Southhampton, UK ZP3632SR

Within the Country 07 05 04 Yes 405.0 Mixed Solvent R2 M Weighed

Offsite in Ireland

AVR Safeway/W0050-2


Soltec Ireland Ltd, Mullingar Co. Westmeath 115-1


AVR Safeway/W0050-2



Within the Country 07 05 04 Yes 360.0 Mixed Solvent R13 M Weighed

Offsite in Ireland

AVR Safeway/W0050-2





European Waste Code

Hazardous

Quantity

T/Year



M/C/E

Method Used






Within the Country 07 05 04 Yes 22.1 Mixed Solvent D13 M Weighed

Offsite in Ireland

AVR Safeway/W0050-2



Within the Country 07 05 04 Yes 25.0 Mixed Solvent D15 M Weighed

Offsite in Ireland

AVR Safeway/W0050-2



To Other Countries 07 05 04 Yes 21.5 Mixed Solvent R1 M Weighed Abroad

AVR Safeway/W0050-2


SRM Morecambe, Lancashire, UK

AG9248/BL7302ID

To Other Countries 07 05 04 Yes 4.23

Waste Packed solvents D10 M Weighed Abroad

AVR Safeway/W0050-2



A 51 G 00 508

Within the Country 07 05 04 Yes 0.394

Waste Packed solvents R13 M Weighed

Offsite in Ireland

AVR Safeway/W0050-2



Within the Country 07 05 04 Yes 19.7 Waste THF R13 M Weighed

Offsite in Ireland

AVR Safeway/W0050-2


AVR Safeway, Corrin, Fermoy, Cork W0050-2



European Waste Code

Hazardous

Quantity

T/Year



M/C/E

Method Used







Paked sodium salts D10 M Weighed Abroad

AVR Safeway/W0050-2



A 51 G 00 508


Packed waste - ethylene dichloride,

methylene chloride,

fluororobenzene, diethyl carbomyl

chloride D10 M Weighed Abroad

AVR Safeway/W0050-2



A 51 G 00 508

To Other Countries 07 07 04 Yes 3.43 Sodium salts D10 M Weighed Abroad

AVR Safeway/W0050-2



A 51 G 00 508


Low Ph, Ethyl Acetate / HCL /

IPA R2 M Weighed Abroad

AVR Safeway/W0050-2


BIP Organics LTD, Middlewich, Cheshire, UK BS5223IH



European Waste Code

Hazardous

Quantity

T/Year



M/C/E

Method Used







contaminated solids wastes D10 M Weighed Abroad

AVR Safeway/W0050-2




contaminated solids wastes R3 M Weighed Abroad

AVR Safeway/W0050-2


ATM Afvalstoffen terminal Moerdijk BV Vlasweg 12, Seaport M152, 4782 PW Moerdijk, Netherlands 930809.002/4


contaminated solids wastes D10 M Weighed Abroad

AVR Safeway/W0050-2



A 51 G 00 508

Within the Country 15 01 02 No 5.54

Waste Empty plastic containers

washed D10 M Weighed Offsite in Ireland

AVR Safeway/W0050-2





European Waste Code

Hazardous

Quantity

T/Year



M/C/E

Method Used







contaminated wastes packaging D10 M Weighed Abroad

AVR Safeway/W0050-2



A 51 G 00 508

Within the Country 15 01 10 Yes 4.52 waste metal drums R4 M Weighed

Offsite in Ireland

AVR Safeway/W0050-2



Within the Country 15 01 10 Yes 0.993

Waste contaminated

drums D10 M Weighed Offsite in Ireland

AVR Safeway/W0050-2




absorbents, filters, waste PPE, wipes,

gloves, spill kits D10 M Weighed Abroad

AVR Safeway/W0050-2



A 51 G 00 508


Inorganic wastes - LAB D10 M Weighed Abroad

AVR Safeway/W0050-2



A 51 G 00 508



European Waste Code

Hazardous

Quantity

T/Year



M/C/E

Method Used







discarded organic waste from labs D10 M Weighed Abroad

AVR Safeway/W0050-2



A 51 G 00 508

Within the Country 16 06 01 Yes 0.002 Wet batteries R4 M Weighed

Offsite in Ireland

AVR Safeway/W0050-2


WEEE Recycle, Cappincur IE, Tullamore, Offaly W0113-03

Within the Country 16 06 02 Yes 0.172 Waste dry batteries R4 M Weighed

Offsite in Ireland

AVR Safeway/W0050-2


WEEE Recycle, Cappincur IE, Tullamore, Offaly W0113-03

To Other Countries 20 01 14 Yes 1.56 Waste acids D10 M Weighed Abroad

AVR Safeway/W0050-2



A 51 G 00 508



European Waste Code

Hazardous

Quantity

T/Year



M/C/E

Method Used






To Other Countries 20 01 15 Yes 0.056 Solid KOH, NaOH D10 M Weighed Abroad

AVR Safeway/W0050-2



A 51 G 00 508

To Other Countries 20 01 21 Yes 0.15 Fluorescent tubes R4 M Weighed Abroad

AVR Safeway/W0050-2


Indaver Relight NV, 2030 Antwerpen, belgium

46003/233/11/1

To Other Countries 20 01 27 Yes 2.08 Waste Resin D10 M Weighed Abroad

AVR Safeway/W0050-2



A 51 G 00 508


Electronic Equipment R4 M Weighed

Offsite in Ireland

AVR Safeway/W0050-2


techrec Ltd, Nabgor rd, Dublin 12 WP 98099


commercial and industrial waste R13 E

Volume Calculation

Offsite in Ireland

AVR Safeway/W0050-2


greenstar MRF, glyntown cork

W 136-2/CK WMC/42/01 & CK WMC/323/05



European Waste Code

Hazardous

Quantity

T/Year



M/C/E

Method Used







paper and cardboard R13 E

Volume Calculation

Offsite in Ireland

AVR Safeway/W0050-2



W 136-2/CK WMC/42/01 & CK WMC/323/05

Within the Country 15 01 06 No 1.32 mixed packaging R13 E

Volume Calculation

Offsite in Ireland

AVR Safeway/W0050-2



W 136-2/CK WMC/42/01 & CK WMC/323/05


demolition waste, concrete etc R13 E

Volume Calculation

Offsite in Ireland

AVR Safeway/W0050-2



W 136-2/CK WMC/42/01 & CK WMC/323/05

Within the Country 20 01 38 No 0.578 wood R13 E

Volume Calculation

Offsite in Ireland

AVR Safeway/W0050-2



W 136-2/CK WMC/42/01 & CK WMC/323/05


commercial and industrial waste D15 E

Volume Calculation

Offsite in Ireland

AVR Safeway/W0050-2



W 136-2/CK WMC/42/01 & CK WMC/323/05


paper and cardboard D15 E

Volume Calculation

Offsite in Ireland

AVR Safeway/W0050-2



W 136-2/CK WMC/42/01 & CK WMC/323/05



European Waste Code

Hazardous

Quantity

T/Year



M/C/E

Method Used






Within the Country 15 01 06 No 0.83 mixed packaging D15 E

Volume Calculation

Offsite in Ireland

AVR Safeway/W0050-2



W 136-2/CK WMC/42/01 & CK WMC/323/05


demolition waste, concrete etc D15 E

Volume Calculation

Offsite in Ireland

AVR Safeway/W0050-2



W 136-2/CK WMC/42/01 & CK WMC/323/05

Within the Country 20 01 38 No 1.27 wood D15 E

Volume Calculation

Onsite in Ireland

AVR Safeway/W0050-2



W 136-2/CK WMC/42/01 & CK WMC/323/05


Sludge from wastewater

treatment plant R1 M Weighed Onsite in Ireland

AVR Safeway/W0050-2


AVR Environmental solutions, Youghal Co. Cork W0211-01


Appendix VIII

Utilities Reports 2008

&

Utilities reports for previous years for comparison


Electricity Bill

Breakdown

Date Cost € Consumption

kWh Jan-06 38095.6 446536 Feb-06 36967.4 433452 Mar-06 40009.46 470571 Apr-06 38048.57 446667 May-06 39246.61 462097 Jun-06 36073.96 420570 Jul-06 26782.4 305036 Aug-06 36834.31 431443 Sep-06 35842.36 418736 Oct-06 37107.04 434027 Nov-06 55537.53 428341 Dec-06 45587.65 347905 Jan-07 54635.15 439382 Feb-07 48967.62 392787 Mar-07 43080.13 435902 Apr-07 41019.57 412883 May-07 44755.14 453044 Jun-07 43169.44 438330 Jul-07 28921.17 283933 Aug-07 44064.99 446881 Sep-07 43382.48 439277 Oct-07 44475.06 449368 Nov-07 49174.47 447803 Dec-07 39181.69 349690 Jan-08 50175.18 455059 Feb-08 45651.08 407773 Mar-08 43868.44 390245 Apr-08 52963.59 402200 May-08 27651.37 195420 Jun-08 16778.04 111284 Jul-08 19677.18 124955 Aug-08 31994.57 218669 Sep-08 38458.88 282951 Oct-08 43005.5 276175 Nov-08 42583.45 293390 Dec-08 42583.45 293390


Gas Bill Breakdown

06-08

Date Cost Consumption

kWh Jan-06 29430.6 807010 Feb-06 28606.93 774250 Mar-06 31273.48 852952 Apr-06 17623.66 648143 May-06 22234.25 588171 Jun-06 14173.35 471850 Jul-06 12621.64 272764 Aug-06 15557.36 456131 Sep-06 14062.8 476894 Oct-06 16840.57 586412 Nov-06 26239.39 775190 Dec-06 25553.3 614538 Jan-07 30690.01 853890 Feb-07 25757.08 705810 Mar-07 15820.75 780750 Apr-07 11788.45 592842 May-07 14040.82 588750 Jun-07 12929.53 516741 Jul-07 9602.89 194820 Aug-07 12709.04 396120 Sep-07 13688.95 406778 Oct-07 16428.26 469979 Nov-07 21593.05 611188 Dec-07 20118.93 621891 Jan-08 28913.21 857483 Feb-08 25032.71 764446 Mar-08 24660.44 726322 Apr-08 26075.16 707682 May-08 12287.64 234519 Jun-08 5988.72 8806 Jul-08 8733.8 113293 Aug-08 11953.49 243216 Sep-08 15203.63 297569 Oct-08 17433.18 423473 Nov-08 21062.56 587486 Dec-08 17597.88 513076


Appendix IX

Review of 2008

Environmental Objectives and Targets & Environmental Management


Review of 2008 Environmental Management Programme

Project 01/2008 Waste Management/Responsible Resource Management

Relationship to objectives and targets:

This project is in line with Corden’s 2008 objective number 1 &10. It is also linked to aspect 2.3, 2.8 and 7.1 of the 2008 Aspects impact register.

Reason for undertaking project:

To reduce resource consumption/waste and emissions to atmosphere

Target:

Reduce consumption of Ethyl Acetate and IPA

Project Summary:

Reengineer final step of tramadol HCL to reduce solvent consumption:

Designation of Responsibility:

R&D

Time Frame: 1. Completion of lab trials by plant shutdown in July

2. Implemented thereafter

Status: This project was cancelled


Project 02/2008 Responsible resource management


This project is in line with Corden’s 2008 objective number 3.

It is also linked to aspect 7.4 of the 2008 Aspects impact register.


Reduce energy consumption.

Reduce water consumption by 5%

Target: To run different energy saving campaigns during 2008

Project Summary:

Reduce overall energy usage by increasing awareness and implementing energy savings initiatives/projects

Interlock valve will be fitted to PB1 vacuum pump, when all the vacuum pumps are off the water valve will close. Estimated cost of project is €867; estimated savings is €6000/annum. Payback of 1.4 months.

Investigate Weekend energy consumption:


Engineering Manager

Time Frame: December 2008

Completed Items: Set up of Energy Management Team.

During 2008 will run campaigns such as:

1. switch it off

2. Water savings and reduce water consumption by 5%

Status Interlock to be fitted to PB1 vacuum pump in 2009


Project 03/2008 Reduction of emissions to water/sewer


This project is in line with Corden’s 2008 objective number 2

It is also linked to aspect 2.3 and 4.1 of the 2008 Aspects impact register.


Reduction volumes of emissions to sewer

Target: To reduce amount of waste to be treated and therefore volume emitted to sewer

Project Summary:

Diverting of water used to cool HCl cylinders to PASD drain this will save of the cost of treating this water in the WWTP. Preventing rainwater from entering the WWTP during heavy periods of rain by putting in a further drain. Again this will save by not having to treat this water and also help with capacity issues in the WWTP.


Utilities Officer

Time Frame: Q3 2008

Completed Items: Ongoing

Status Completed in 2008

Project 04/2008 Emissions to Atmosphere


This project is in line with Corden’s 2008 objective number 6 &7 and It is also linked to aspect 2.3 of the 2008 Aspects impact register.


Reduction of emissions to atmosphere

Target: Reduce spillages/fugitive emissions

Project Summary: Reduce TOC emissions during bypass times when planned maintenance is taking place


EHS/Instrumentation

Time Frame: Q, 2008


Status Maintenance work carried out during production shutdown,

No real benefit




This project is in line with Corden’s 2008 objective number 7 and It is also linked to aspect 2.6 of the 2008 Aspects impact register.


Reduction of active dust and particulates to local atmosphere and reduction of exposure to personnel. Improving the handling of drug substances is consistent with, and necessary for, reaching the company’s goals of high Quality, Safety, and Environmental and Operational standards.

Target: Improve interior air quality

Project Summary:

Upgrade of sieving and milling activities. Powder handling system will be fully contained and inerted Improving the handling of drug substances is consistent with, and necessary for, reaching the company’s goals of high Quality, Safety, and Environmental and Operational standards.


Engineering/Operations

Time Frame: Q4, 2008


Status Deferred to 2009




This project is in line with Corden’s 2008 objective number 3, 6 & 7 and It is also linked to aspect 2.3, 2.6 and 7.4 of the 2008 Aspects impact register.


To improve monitoring of critical parameters on vessels during production; to improve recording and reliability of recording and to provide reliable trending

Target: Improve process monitoring which could lead to reduction in emissions to atmosphere e.g. too high pressures could can lead to high emissions and therefore bypass at TO. Improved process monitoring should reduce the frequency of this occurrence

Project Summary:

New Operation Monitoring System; installation of pressure and temperature indicators:

In PB1, currently we have 7 Foxboro Pneumatic Control Chart recorders Model 122-FP, which are at least 25-year-old technology.

It is proposed to replace these pneumatic recorders with a “Multi Channel Process System” (MCPS) data acquisition application, which will allow the reactor sump temperatures and pressures to be displayed on a PC screen in the PB1 supervisor’s office. Historical trending data can be accessed from a server and can then be printed off, selecting any desired timeframe





Status Completed


Project 07/2008 Emissions to surface water/Groundwater protection


This project is in line with Corden’s 2008 objective number 8 and linked to aspects 3.1 and 4.1 of the 2008 environmental aspects and impacts register


To reduce fugitive emissions and possible surface water/groundwater contamination

Target: Reduce potential emissions

Project Summary:

Upgrade overhead floor drain (from PB2 directly to waste treatment) to Glass Reinforced Plastic






Project 08/2008 Responsible Resource Management


This project is in line with Corden’s 2008 objective number 3 and is linked to aspect 7.4 of the 2008 impacts and aspects register.


• Reduce steam and hence gas required to heat the domestic hot water system

• The installation of solar panels would help raise the environment profile of the site.

Target:

Project Summary:

Upgrade of hotwater generation system

Investigate possible installation of solar panels to supplement the domestic hot water system and install a system to heat water as required rather than the current storage and distribute system.





Status Project cancelled


Project 09/2008 Emissions to Atmosphere/Sewer




To reduce emissions to WWTP by ensuring it is safely and adequately treated in neutralisation tank

Target: To reduce emissions to WWTP

Project Summary:

Upgrade neutralisation tanks:

This tank needs to be upgraded in order to allow safe treatment of cyanide waste





Status Deferred to 2009 – major capital project

Project 10/2008 Resource Management




The current insulation is 30 years old. New insulation would reduce the heat loss of the condensate and hence reduce heat load in the boiler to evaporate the water

Target: To reduce energy consumption

Project Summary:

Upgrade of PB1 steam and condensate supply and return











Improving the air quality of the work area is consistent with, and necessary for, reaching the company’s goals of high Quality, Safety, and Environmental and Operational standards.

Target: To improve air quality of PB1 general area

Project Summary:

Upgrade PB1 local Exhaust ventilation –

Increase number of local extract point (no. of Niedermann arms etc)

Install a clean/wash room so to reduce personnel exposure during cleaning of equipment





Status Complete


Appendix X

Environmental Objectives and Targets

Proposal for 2009


Proposal for 2009 Schedule of Objectives and Targets No. Objective Target for 2009

1

Hazardous Waste Management and

process modifications giving improved

yields

Reduce hazardous waste volumes

2 Reduction of Wastewater mass

emissions. Achieve effluent reduction

3 Responsible resource management Reduce electricity and gas use by for

2009

4 Responsible resource management Investigate potential water savings

projects

5 Responsible resource management Reduce Nitrogen losses

6 Reduction of emissions to air Reduce number of Thermal Oxidiser

bypasses and mass emissions.

7 Reduction of emissions to air

Reduce emission of HCL to atmosphere

as well as other emissions such as dust

etc

8 Reduction of emissions to water Reduce contamination of surface water.

9 Protection of groundwater &

stormwater

Ensure integrity of underground drains

and pipes.

10 Reduction of fugitive process emissions

to air

Reduce fugitive emissions from

processes & plant


Appendix XI

Environmental Management Programme (EMP)

Proposal for 2009


Environmental Management Projects Proposal 2009

Project 01/2009 Responsible resource management


This project is in line with Corden’s 2009 objective number 3 & 4.

It is also linked to aspect 7.4 of the 2009 Aspects impact register.


Reduce energy consumption.

Reduce water consumption by 5%

Target: To investigate potential water saving initiatives

Project Summary:

Reduce overall energy usage by increasing awareness and implementing energy savings initiatives/projects

Interlock valve will be fitted to PB1 vacuum pump, when all the vacuum pumps are off the water valve will close. Estimated cost of project is €867; estimated savings is €6000/annum. Payback of 1.4 months.


Engineering Manager

Time Frame: Mid 2009 for installation of interlock on vacuum pump

Completed Items: Set up of Energy Management Team.

During 2008 will run campaigns such as:

3. switch it off

4. Water savings and reduce water consumption by 5%






Reduction of active dust and particulates to local atmosphere and reduction of exposure to personnel. Improving the handling of drug substances is consistent with, and necessary for, reaching the company’s goals of high Quality, Safety, and Environmental and Operational standards.

Target: Improve interior air quality

Project Summary:

Upgrade of sieving and milling activities. Powder handling system will be fully contained and inerted Install flap vavles on equipment for loading of materials to reactors Improving the handling of drug substances is consistent with, and necessary for, reaching the company’s goals of high Quality, Safety, and Environmental and Operational standards.






Project 03/2009 Emissions to surface water/Groundwater protection


This project is in line with Corden’s 2009 objective number 8 and linked to aspects 3.1 and 4.1 of the 2008 environmental aspects and impacts register


To reduce fugitive emissions and possible surface water/groundwater contamination

Target: Reduce contamination and ensure intregrity of pipework

Project Summary:

Upgrade overhead floor drain (from PB2 directly to waste treatment) to Glass Reinforced Plastic





Project 04/2009 Emissions to Atmosphere/Sewer




To reduce cyanide emissions to WWTP by ensuring it is safely and adequately treated in neutralisation tank

Target: To reduce emissions to WWTP

Project Summary:

Upgrade neutralisation tanks:

These tanks need to be upgraded in order to allow safe treatment of waste




Completed Items: Ongoing – Major capital project


Project 05/2009 Resource Management




The current insulation is 30 years old. New insulation would reduce the heat loss of the condensate and hence reduce heat load in the boiler to evaporate the water

Target: To reduce energy consumption

Project Summary:

Upgrade of PB1 steam and condensate supply and return



Time Frame: 2010







Improving the air quality of the work area is consistent with, and necessary for, reaching the company’s goals of high Quality, Safety, and Environmental and Operational standards.

Target: To improve air quality of PB1 general area

Project Summary:

to carry out thorough clean and inspection of ducts during 2009, so to ensure build up is not occurring in pipework






Appendix XII

External Acoustic Survey - November 2008




Appendix XIII

Groundwater Monitoring Reports

March & November 2008




Appendix XIV

Bund Testing Reports


Bund Testing Certificate

Test details

Client: Corden PharmaChem

Bund Location: B5 – T.O. Scrubber bund

Survey Dates: 25– 27 February 2009 Personnel Involved:

Colin Barry – Utilities Operator Fergal Condon – Utilities Operator

Daily log

Date Comments Water level(mm)

Evaporation Personnel

25/02/09 Relaxation Period

90 0 Colin Barry,

Fergal Condon

26/02/09 Standby vessel 10 L

87 0 Colin Barry,

Fergal Condon


87 0 Colin Barry,

Fergal Condon

Comments This bund was tested in accordance to B.S. 8007:1987 – Design of concrete structures for retaining aqueous liquids: section nine, inspection and test of the structure and in conjunction with EPA guidance note on Storage and Transfer of Materials for Scheduled Activities. Test Conducted by: Signed: ________________________________ Utilities Operator ________________________________ Utilities Operator

Conformance to B.S. 8007: Section 9

Passed

Reviewed By: Signed ______________________________


Head of Engineering Approved by: Signed ______________________________ EHS Manager


Test details


Bund Location: B7 –PB1 refrigerant Bund



Daily log




230 0 Colin Barry, Fergal Condon


230 0 Colin Barry,

Fergal Condon


230 0 Colin Barry,

Fergal Condon


230 0 Colin Barry,

Fergal Condon



Passed


Reviewed By: Signed ______________________________ Head of Engineering Approved by: Signed ______________________________ EHS Manager



Test details


Bund Location: B10 – PB2 Solvent Tank Farm

Survey Dates: 10 – 13 March 2009 Personnel Involved:


Daily log



10/03/09 Standby vessel 195mls

453 0 Colin Barry,

Fergal Condon


453 0 Colin Barry,

Fergal Condon


453 0 Colin Barry,

Fergal Condon


453 0 Colin Barry,

Fergal Condon



Passed

Reviewed by: Signed ______________________________ Head of Engineering Approved by: Signed ______________________________ EHS Manager



Test details


Bund Location: B11 –PB1 Ambient Cooling Tank Bund

Survey Dates: 03– 06 March 2009 Personnel Involved:


Daily log


Evaporation/ Rainfall

Personnel

03/03/09 Relaxation

990 0 Colin Barry,

Fergal Condon


1000 10 Colin Barry,

Fergal Condon


1000 0 Colin Barry,

Fergal Condon


1000 0 Colin Barry,

Fergal Condon



Passed

Reviewed By: Signed ______________________________ Head of Engineering Approved by: Signed ______________________________ EHS Manager



Test details


Bund Location: B12 –PB1 Dump Tank



Daily log




410 0 Colin Barry,

Fergal Condon


410 0 Colin Barry,

Fergal Condon


410 0 Colin Barry,

Fergal Condon



Passed

Reviewed by: Signed ______________________________ Head of Engineering Approved by: Signed ______________________________

EHS Manager


Appendix XV

Wastewater Toxicity Reports 2008

March 2008

