ANNUAL ENVIRONMENTAL REPORT

Transcription

1 ANNUAL ENVIRONMENTAL REPORT RELIANCE GENEMEDIX PLC IPPC LICENCE REF: P SRAGH BUSINESS PARK, TULLAMORE, CO. OFFALY JANUARY December 2008

2 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT TABLE OF CONTENTS 1.0 INTRODUCTION MANAGEMENT OF THE ACTIVITY Schedule of Environmental Objectives and Targets Environmental Management Programme Report Environmental Management Programme Proposal for Pollution Emission Register Report Pollution Emission Register Proposal for Boiler Emissions Summary Emissions to Sewer Summary Surface Water Monitoring Waste Management Report Resource Consumption Summary Noise Monitoring Report Tank and Pipeline Testing and Inspection Report Bund Testing Energy Efficiency Audit Report Summary Toxicity Test Results Complaints Summary Reported Incidents Summary 18

3 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT LIST OF TABLES Table Schedule of Environmental Objectives and Targets Table Results of particulate matter monitoring Table Results of flue gas monitoring Table Summary of waste water discharge to sewer data for 2008 Table Average daily chemical constituents of waste water discharged to sewer in 2008 Table Summary of surface water discharge monitoring data for 2008 Table Summary of non hazardous waste statistics at GeneMedix plc Table Summary of hazardous waste statistics at GeneMedix plc Table Waste analysis of mixed solvent waste Table Resource consumption summary Table Summary of Noise Monitoring Results- Boundary locations Table Summary of Noise Monitoring Results- Sensitive locations LIST OF APPENDICES Appendix 1 Appendix 2 Appendix 3 Appendix 4 AER Summary Data Boiler Emissions Monitoring Report Noise Monitoring Report Underground tank Assessment Report

4 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT 1.0 INTRODUCTION GeneMedix plc has a state-of-the-art mammalian cell-manufacturing facility for the production of Erythropoietin. This biochemical product is indicated for the treatment of anaemia associated with chronic renal failure among other conditions. Erythropoietin is produced following the culture of a mammalian cell line in a 10L bioreactor. The cells are cultured for a period of 30 days, during this period the EPO product is excreted by the cells into the supernatant, this supernatant is collected continuously and stored as harvest at 4 C. The EPO product is then extracted from the harvest using a series of filtration and column chromatography procedures. Each step in the purification process will enrich the product removing impurities until the final product that meets the stringent purity requirements of a biopharmaceutical. Organisational Chart of the Environmental Management Structure at GeneMedix plc is presented below. Vinay Ranade CEO Conor O Dea General Manager Derek Claffey Engineering Manager. (IPPC Licence manager) Kevin Callaghan QA Manager Denis Looby Production Manager Denis Bracken Facilities Engineer

5 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT GeneMedix plc facility is operated under an Integrated Pollution Prevention Control (IPPC) Licence No. P granted in September 2002 by the Environmental Protection Agency (EPA). The facility commenced activities in February In February 2007 GeneMedix plc were acquired by Reliance Life Sciences which resulted in a new headquarters being established at the facility in Tullamore. Total workforce in Tullamore now stands at 50. On the 19 th December 2007 a licence was granted by the Irish Medicines Board to GeneMedix plc for the commercial manufacture of EPO which resulted in some full scale lots being manufactured from March 2008 on. The reporting period for this Annual Environmental Report is 1 st January 2008 to 31 st of December MANAGEMENT OF THE ACTIVITY 2.1 Schedule of Environmental Objectives and Targets A list of objectives and targets and their current status is included below in table below. The environmental objectives and targets are regulated by the company environmental management system Table Schedule of Environmental Objectives and Targets No Objective and Target Title Date of commencement Proposed completion date EMP Ref No. 2 Waste Management October 2003 Ongoing EMP 2 5 Training for all staff at facility January 2004 Ongoing EMP 5 6 Audit of Energy Efficiency at December 2006 April 2009 EMP 6 the Site

6 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT 2.2 Environmental Management Programme Report 2008 The following tables summarise the progress of all the Environmental Management Programmes (EMPs), which are being worked on by Environmental Team members on an ongoing basis. EMP No 2 Title Waste Management Date of October 2003 commencement Proposed December 2008 completion date Stages complete Stage 1 to 5. Comments The quantities of waste materials, hazardous and non hazardous are continuously monitored. There was an increase in waste generated on site for 2007 when compared to 2006, refer to Waste Management section 2.9 below. This was due to progress in the development of the lead product, EPO and move towards commercial manufacture. Management are committed to continuously monitor waste management at the facility in terms of waste production, minimisation and handling practices. Recycling is now being promoted as much as possible with the intention of reducing the volumes of waste going to landfill. During the 2008 approx 22% of all waste collected by AES was recycled. We will continue to promote recycling and increase the volume of recycling as much as possible. As part of the AER we will continue to monitor and document all waste removed from the facility. This project will remain open indefinitely at stage 5.

7 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT EMP No 5 Title Training for all staff at the facility Date of January 2004 and is on-going commencement Proposed March 2008 completion date Stages complete Stage 1, 2, 3, 4 Comments All scheduled training is carried out as per the company training matrix and on-going use of standard operating procedures (SOPs). The training matrix is specific to the IPPC license with key personnel assigned roles and responsibilities regarding the maintenance of the license. The standard operating procedures (SOPs) expand on the requirements of the IPPC license and ensure a day to day maintenance of the environmental criteria necessary for license compliance. The company will update the training requirements of all staff in light of recent company restructuring and expansion i.e. new parent ownership and significant increase in employee numbers. In addition, it is proposed to delegate the management of the IPPC licence from the general manager to the engineering function, i.e. Derek Claffey Engineering manager for the site. Training is ongoing for all staff during induction. Also, all staff directly involved in the management of the IPC licence are trained on their various functions and procedures. This EMP will be kept open indefinitely to ensure that training continues to be carried out on an ongoing basis.

8 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT EMP No 6 Title Audit of Energy Efficiency at the Site Date of Initial proposed date; December 2006 commencement Proposed March 2009 completion date Stages complete N/A Comments A summary of progress to date is as follows; March 2007, initial meeting between ENVIROCO Management Ltd and GeneMedix staff in relation to data gathering, initial positive developments and duties designations etc. September 2007 a company change was made to Airtricity as the electricity provider in line with environmental initiatives at the facility. Mid September 2007, meeting between ENVIROCO Management Ltd and GeneMedix staff in relation to update on progress and agreement for ENVIROCO Management Ltd to work out the electricity consumption costs for period. December 2007 finalised consumption data for A decision was reached which highlighted that it would be more advantageous to perform a more detailed energy audit when the company has entered commercial production. The nature of the company s validation activities made it difficult to generate a true baseline for energy consumption as production activities were sporadic throughout the year. September 2008, recommenced review of energy consumption and collection of data for Enviroco so that report can be compiled. This is being completed at the moment and is hoped to be ready by end of April Environmental Management Programme Proposal for 2009 All environmental management programmes will be followed as identified in the GeneMedix plc EMP Project Schedule attached to this AER. It is noted that EMP reference numbers 1, 3 and 4 are completed. EMP reference number 2 is also complete, but will be kept open to ensure continued monitoring and promotion of waste management. EMP 6 is an addition to the original program and arose from EMP1.

9 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT 2.4 Pollution Emission Register Report 2008 As agreed with the Agency, it is proposed to track Total Organic Carbon (TOC) from the GeneMedix plc facility. In summary, there is TOC content in the nutrient broth media that is used as a raw material in the manufacturing process. The actual TOC content is unknown at present and is currently being determined by analysis from suppliers. Some of this TOC is used up during manufacturing and some enters the waste water to sewer. The quantities of TOC in the waste water can only be determined by analysis. TOC analysis of the waste water is carried out monthly and the results are used for the purpose of completing the PER (see Appendix 1 AER Summary Data attached). 2.5 Pollution Emission Register Proposal for 2009 There has been no deviations from the manufacturing operations or material/substance change of use at the facility since the formulation of the PER proposal in July Therefore it is not expected or proposed to include any additional substances or materials in the PER for Boiler Emissions Summary Odour monitoring ltd monitored the concentration of emissions to atmosphere from a series of emission points (boilers) at the GeneMedix facility on the 12 th December The monitoring was carried out to determine the emission concentrations in comparison with the TA Luft 2002 emission guidelines. Total particulate measurements were carried out using extractive sampling under isokinetic conditions as outlined in British Standard EN :2002.The boiler emissions monitoring report is included in Appendix 2 of this AER. The following tables summarise the results of the monitoring.

10 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT Table Results of Particulate Matter monitoring Emission Point Emission Value mg/nm 3 Emission Guideline* mg/nm 3 Boiler 1 plant steam generator Boiler 2 Office Heater Boiler 3 BLR Boiler 4 BLR *As stated in TA Luft 2002 Section Furnaces with a firing thermal capacity of 5MW or more. Table Results of Flue Gas monitoring Emission Point Parameter Emission Value mg/nm 3 Boiler 1 Plant steam generator Boiler 2 Office Heater Boiler 3 BLR Boiler 4 BLR *As stated in TA Luft 2002 Section Furnaces. Emission Guideline* mg/m 3 CO NO SO CO NO SO CO NO SO CO NO SO Conclusions: The volumetric airflow rate of each boiler emission point 1-4 is reported in accordance with IPPC licence Concentrations of Carbon Monoxide (CO), Nitrogen Oxides (as NO 2 ) and Sulphur Dioxide (SO 2 ) and total particulates were reported in accordance with IPPC licence The exhaust gas emissions are in the typical concentration range for such compounds in the exhaust flue gas form boilers operating on gas oil/light fuel oil. All recorded values are within the recommended guideline limit values contained in Ta Luft 2002.

11 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT 2.7 Emissions to Sewer Summary The revised and agreed discharge volumes permitted to sewer from GeneMedix plc are as follows (EPA ref: M638/ap02bk.doc): Maximum volume emitted in any one day: 50 m 3 The actual emission limit values for the parameters of the discharge to sewer (temperature, ph, BOD etc.) have not changed and remain as stated in the IPPC licence ref: P Table below compared the parameter license limits with the actual concentrations measured in the waste water being discharged to sewer from January to December 2008 (12 months data). Table Summary data of waste water discharge to sewer for Parameter Units Max licensed emission Total parameter loadings for 12 months measured in discharge to sewer Volume* m 3 /yr 18, Suspended solids kg/yr 2, BOD kg/yr 2, COD kg/yr 5, Total dissolved kg/yr None given None given solids Total Nitrogen kg/yr Phosphates kg/yr * = volume figure as agreed on 8 th January 2004 from the EPA ref: M638/ap02bk.doc As can be seen from table above, the total environmental loadings to sewer as a result of the waste water discharge is minimal and well below the licensable limits of the facility license. Table below compared the parameter license daily limits with the average daily concentrations measured in the waste water being discharged to sewer from January to December 2008 (12 months data). Table Average daily chemical constituents of waste water discharged to sewer in 2008

12 March 2009 Reliance GENEMEDIX PLC 2008 ANNUAL ENVIRONMENTAL REPORT Waste Water BOD COD N P SS 1000L Av day kg/day kg/day kg/day kg/day kg/day Limit 50m Jan Feb March April May June July August September October November December From Table above, it can be seen that the average daily environmental loadings to sewer as a result of the waste water discharge is minimal and in most cases, well below the licensable limits of the facility license. There were some peaks showing in months April, September and December and these were due mainly to increased activity within the production areas during this time. 2.8 Surface Water Monitoring Condition of the facility licence requires that the licensee shall monitor surface water discharges in accordance with Schedule 4(i) Surface Water Discharge Monitoring of this licence. A report on the results of this monitoring shall be submitted to the Agency annually as part of the AER. Table below summarises the analysis data for 2008 for the surface water being discharged from the site. Table Summary of surface water discharge monitoring data for 2008 Parameter Units Mar 08 Oct 08 BOD mg/l 16 2 COD mg/l Temperature º C Conductivity ms/cm ph Units

13 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT There are no maximum emission limit values set by the EPA for surface water discharges from the site. As can be seen from the results above the actual parameter levels for the discharge vary from BOD between 2 and 16 mg/l, COD between 43.2 and 83.4 mg/l etc. All emissions to surface water from the facility are not considered significant. GeneMedix plc will continue to monitor the surface water discharge from the site as scheduled in 4 (i) of the IPPC License no. P Waste Management Report Table below summarises all non hazardous waste generated at the GeneMedix plc facility in Table Summary of non hazardous waste statistics at GeneMedix plc No Waste Type Waste description EWC Code Quantity (kg) 1 Cardboard Cardboard packaging associated with raw materials purchase 2 Paper Paper packaging associated with raw materials purchase and other internal paper wastes Glass Waste glass bottles (uncontaminated) 4 Solid waste from facility Sterilised solid waste originating from the autoclave (petri dishes operations containing sterilised nutrient media) 5 General waste Mixed office based waste, canteen waste and similar general waste Table Summary of non hazardous waste statistics at GeneMedix plc 6 Timber Wood pallets End of life PC s etc Discarded electrical and electronic equipment (Non-hazardous i.e. old computers) Total 25,550 kg The final recovery/disposal location of all non hazardous wastes from the facility is the waste licensed site operated by A.E.S Ireland Ltd, Cappincur, Tullamore, Co Offaly. Waste license No: W , Conroy recycling WP-04/2002 and WEEE recycle waste permit W Table below summarises all hazardous waste generated at the GeneMedix plc facility for 2008 (12months period).

14 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT Table Summary of hazardous waste statistics at GeneMedix plc No Waste Type Waste description EWC Code Quantity (litres/kg) 1 Mixed solvents Aqueous wastes originating from * 120L facility operations which contain a small amount of solvents in the aqueous phase. 2 Monitors Discarded electrical and electronic * 90Kg equipment (hazardous components i.e. computer monitors.) 3 Oil bund water Contaminated water from oil tank bund * 5000L A qualitative and quantitative waste analysis report is carried out per consignment of aqueous/solvent waste sent for recovery in order to identify the exact solvent content. This waste analysis is summarised below in table Table Waste analysis of mixed solvent waste Date Jan 08 Drum 1 Jan 08 Drum 2 Volumes Water (%) Methanol (%) Ethanol (%) IPA* (%) 60L % 0.02% 0.72% 60L % 1.3% 2.0% IPA*: Iso Propyl Alcohol All aqueous waste contaminated with solvents are collected by Shannon Environmental Services Ltd and recovered at their site in Smithstown Industrial Estate, Shannon, Co Clare for recovery (now owned by ENVA Ireland). Waste license No: W Similarly, all WEEE materials (computers and monitors) were collected and transported to KMK Metals

15 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT Recycling Ltd, Cappincur Industrial Estate, Daingean Road, Tullamore (Waste Licence No: W ). All bund water was collected by Enva Ireland ltd Portlaoise, waste permit WO In addition to the above solvent wastes, there were a small number of various out of date chemicals and compounds disposed of during These were all collected and disposed of by Enva Ireland ltd, Smithstown industrial estate, Shannon, Co Clare- waste licence no. W All of these items were documented in C1 number B Resource Consumption Summary The following table summarises the resources that are consumed at the GeneMedix plc facility. Table Resource consumption summary for Consumption, units Resource type Resource use Fuel oil Facility heating 95,000 litres 93,000 litres 92,000 litres Electricity Facility power 1,048 MWh 1,399 MWh 1,143 MWh Municipal water Product manufacture and site use 3,700,000 litres 4,740,000 litres 4,200,000 litres As can be seen from above, the Facility had a slight decrease in the use of fuel oil and electricity at the facility. The figures will vary slightly from year to year due to the sporadic nature of production carried out and also due in part to weather conditions outside, which determines the amount of heating/cooling required for the facility Noise Monitoring Report A noise monitoring survey was carried out at the GeneMedix facility in response to condition 8.1 of the IPPC license No. P The noise monitoring survey was carried out on 3 rd December 2008 from 9am to 5pm during normal site operations. All boundary and noise sensitive locations were measured. A copy of the Noise Monitoring Report is attached in

16 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT Appendix 3 of this AER. A summary of the noise monitoring results are presented in tables and below. Table Summary of Noise Monitoring Results Boundary locations Monitoring Point Location L Aeq GM NB 001 Rear yard of the plant 55 GM NB 002 Side car park of the plant 52 GM NB 003 Front boundary of the plant adjacent to 55 Industrial Park Road GM NB 007 Rear yard of the plant 53 GM NB 008 Side car park of the plant 54 GM NB 009 Front boundary of the plant adjacent to Industrial Park Road 55 Table Summary of Noise Monitoring Results Sensitive locations Monitoring Point Location L Aeq GM NS 004 Outside the Grovelands Childcare 51 Facility GM NS 005 Rear of the Moorehill House Hotel, 57 adjacent to newly built townhouse GM NS 006 Within the Moylena Housing Estate 46 In summary, noise sources from the plant audible at the site boundaries have been identified as; Vehicles entering/leaving the site Personnel entering/leaving building Pumps and fans operating to the rear of the plant Activities at the GeneMedix plc plant predominately occur within the plant building, with primary outdoor noise sources been the operation of pumps and fans located to the rear of the plant. The statistical analysis of the noise at boundary monitoring stations shows primary noise at the boundaries of the facility are attributable to road traffic and, to a lesser extent, the operation of pumps and fans on site. None of the boundary monitoring locations monitored recorded values which exceeded the EPA guideline limit of 55 db(a). Noise station NS005 located at the rear of the Moorhill House received a noise pressure of 57 db(a) slightly exceeding the EPA guideline limit by 2 db(a).. This was primarily due to passing traffic on the nearby N80 road and operations from the GeneMedix facility were not audible from this location. The remaining noise sensitive locations were well below the EPA guideline limit.

17 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT 1/3 Octave analysis identified 2 tonal components of note to the rear of the GeneMedix plc facility 630 Hz 2000 Hz These frequencies all showed identifiable peaks on the eastern boundary of the site to the rear of the facility. Frequency ratings of 2000 Hz having been associated with the operation of the pneumatic waste water discharge against the rear wall of the GeneMedix plc Facility. 630 Hz has been associated with the running of a diesel generator at the Moorhill townhouse development. None of the three NSL s, monitored show tonal aspects associated with the 2 boundary tones at 630&200Hz. This was to be expected as activity from the GeneMedix plc facility was not audible at these noise sensitive locations. Tonal noise arising from the waste water treatment pump to the rear of the GeneMedix plc facility may cause annoyance in the future. Further monitoring of this boundary will help identify any sources of nuisance noise before it becomes problematic. A comparison of noise levels recorded in December 2008 to levels recorded in August 2007 and December 2005 showed a reduction at most stations to 2005 levels. Therefore, noise monitoring at the GeneMedix plc plant do not indicate any notable increases at noise sensitive locations Tank and Pipeline Testing and Inspection Report All issues regarding the tank and pipeline testing were addressed in a letter to the Agency dated 14 th April Following this letter, testing was carried out on the underground effluent tank. The tank was emptied by a licensed contractor and inspected with photographs being taken. This was carried out by GeneMedix personnel and the report is included in Appendix 4. Due to ongoing production, the CCTV inspection of the internal drains was not completed during It is planned to carry this out at later date as was highlighted in a letter to the EPA dated 20 th February Bund Testing All bunds were tested in 2007 and included in last years AER. They will be due for testing again in Energy Efficiency Audit Report Summary In relation to the completion and submission of an energy audit from the site a letter to the Agency was submitted, dated 4 th April This letter

18 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT addressed the reasons for the deferral of the audit until later this year (2008). This Energy audit is in progress and planned to be submitted soon after the AER Toxicity Test Results There is no new or additional information to comment on in this section Complaints Summary There were no environmental complaints received at the facility during the period of January to December Reported Incidents Summary There were no incidents occurred during the reporting period 2008.

19 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT APPENDIX 1 AER Summary Data

20 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT PRTR# : P0638 Facility Name : GeneMedix plc Filename : P0638_2008.xls Return Year : /03 REFERENCE YEAR FACILITY IDENTIFICATION Parent Company Name GeneMedix plc Facility Name GeneMedix plc PRTR Identification Number P0638 Licence Number P AER Returns Worksheet Version Waste or IPPC Classes of Activity No. class_name The manufacture of pesticides, pharmaceutical or veterinary products and their intermediates. Address 1 IDA Business And Technology Park Address 2 Tullamore Address 3 County Offaly Address 4 Country Ireland Coordinates of Location River Basin District NACE Code 212 Main Economic Activity Manufacture of pharmaceutical preparations AER Returns Contact Name Derek Claffey AER Returns Contact Address d.claffey@genemedix.com AER Returns Contact Position Engineering manager AER Returns Contact Telephone Number AER Returns Contact Mobile Phone Number AER Returns Contact Fax Number Production Volume 0.0 Production Volume Units Number of Installations 0 Number of Operating Hours in Year 0 Number of Employees 50 User Feedback/Comments Web Address 2. PRTR CLASS ACTIVITIES Activity Number Activity Name 3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002) Is it applicable? No Have you been granted an exemption? Yes If applicable which activity class applies (as per Schedule 2 of the regulations)? Is the reduction scheme compliance route being used?

21 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT

22 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT 4.2 RELEASES TO WATERS PRTR# : P0638 Facility Name : GeneMedix plc Filename : P0638_2008.xls Return Year : /03/ : SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS Data on ambient monitoring of storm/surface water or groundwater, conducted as part of your licence requirements, should NOT be submitted under AER / PRTR Reporting as this on RELEASES TO WATERS POLLUTANT QUANTITY Method Used 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 * 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 Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION C : REMAINING POLLUTANT EMISSIONS (as required in your Licence) RELEASES TO WATERS POLLUTANT QUANTITY Method Used Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

23 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT 4.3 RELEASES TO WASTEWATER OR SEWER PRTR# : P0638 Facility Name : GeneMedix plc Filename : P0638_2008.xls Return Year : /03/ : SECTION A : PRTR POLLUTANTS OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER POLLUTANT METHOD QUANTITY Method Used 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 * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence) OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER POLLUTANT METHOD QUANTITY Method Used Sewer discharge point Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year information gathered as part of sampling carried out 240 Suspended Solids M PER on discharge to sewer BOD M PER information gathered as part of sampling carried out on discharge to sewer COD M PER information gathered as part of sampling carried out on discharge to sewer Nitrate (as N) M PER information gathered as part of sampling carried out on discharge to sewer Total Organic Carbon (as C) M PER information gathered as part of sampling carried out on discharge to sewer * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

24 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT 4.4 RELEASES TO LAND PRTR# : P0638 Facility Name : GeneMedix plc Filename : P0638_2008.xls Return Year : /03/ : SECTION A : PRTR POLLUTANTS RELEASES TO LAND POLLUTANT METHOD QUANTITY Method Used No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence) RELEASES TO LAND POLLUTANT METHOD Method Used QUANTITY Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

25 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT

26 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT APPENDIX 2 Boiler Emissions Monitoring Report

27 ODOUR & Environmental Engineering Consultants Unit 32 De Granville Court, Dublin Rd, Trim, Co. Meath Tel: Mobile: www odourireland com STACK EMISSION TESTING AT GENEMEDIX PLC. SRAGH, INDUSTRIAL ESTATE, TULLAMORE, CO. OFFALY. Performed by Odour Monitoring Ireland on behalf of enviroco management ltd. Prepared by: Attention: Licence No IPPC Date: 09 th Feb 2009 Report Number: 2009.A107 (2) Dr. Brian Sheridan Mr. Niall Nally Version: Document Version 2 Reviewers: Mr. Niall Nally

28 Report Number 2009A107(2) ENVIROCO Management Ltd Section TABLE OF CONTENTS Page number TABLE OF CONTENTS DOCUMENT AMENDMENT RECORD i ii 1. Introduction 1 2. Materials and Methods Volumetric flow rate measurement In stack analysis Particulate sampling and analysis Total Particulate matter sampling methodology Job preparation Filter selection and preparation Sampling location Suitability of sampling location Leak checks Sampling Duration of sampling Cumulative sampling Repeat Velocity and temperature readings Weighing of the sample 4 3. Results-Emission testing Volumetric flow rate Flue gas concentrations Total particulates emissions 5 4. Discussion of results 9 5. Conclusion 9 6. Appendix I-Sampling and analysis details 10 i

29 Report Number 2009A107(2) ENVIROCO Management Ltd Document Amendment Record CLIENT: ENVIROCO MANAGEMENT LTD. TITLE: Stack emission testing at GeneMedix PLC, Sragh Industrial Estate, Tullamore, Co. Offaly. Project Number: 2009A107(2) DOCUMENT REFERENCE: STACK EMISSION TESTING AT GENEMEDIX PLC, SRAGH INDUSTRIAL ESTATE, TULLAMORE, CO. OFFALY. 2009A107(1) Document for review B.A.S JWC B.A.S 04/02/ A107(2) Minor amendments NN BAS B.A.S 09/02/2009 Revision Purpose/Description Originated Checked Authorised Date ii

30 Report Number 2009A107(2) ENVIROCO Management Ltd 1. Introduction Odour Monitoring Ireland was commissioned by Enviroco Management Ltd. to perform stack emission testing from four boilers exhaust points located in GeneMedix PLC Sragh Industrial Estate, Tullamore, Co. Offaly. The parameters monitored are identified in Table 1.1. Table 1.1. Monitored parameters and techniques for GeneMedix PLC Sragh Industrial Estate, Tullamore, Co. Offaly. Sample location Parameter Analytical method Stack locations 1 to 4 Volumetric Flow Rate Pilot tube method EN :2002 Stack locations 1 to 4 Oxygen (O 2 ) Flue gas analyser Stack locations 1 to 4 Oxides of nitrogen (NO X as NO 2 ) Flue gas analyser Stack locations 1 to 4 Carbon monoxide (CO) Flue gas analyser Stack locations 1 to 4 Sulphur dioxide (SO 2 ) Flue gas analyser Stack locations 1 to 4 Temperature 0 PT100 type C thermocouple Isokinetic sampling Stack locations 1 to 4 Total Particulate Matter train This report presents details of this monitoring programme. The environmental monitoring was carried out by Dr. John Casey and Dr. Brian Sheridan, Odour Monitoring Ireland at GeneMedix PLC Sragh Industrial Estate, Tullamore, Co. Offaly on the 12 th December Methodology, Results, Discussion and Conclusions are presented herein. 1

31 Report Number 2009A107(2) ENVIROCO Management Ltd 2. Materials and Methods This section provides brief details of the methodologies employed to perform emission testing of each stack source. 2.1 Volumetric flow rate measurement The volumetric airflow rate was determined from stack velocity measurements calculated using a pitot tube connected to a digital manometer in accordance with EN :2002, where possible. A PT 100 type thermocouple was used for measuring temperature. Airflow rate and temperature profiles were performed at pre-calculated intervals across the stack in order to determine the average velocity profile across the stack diameter. 2.2 In stack analysis Flue gas analysis was performed using a Testo 350 MXL/454 flue gas analyser. Concentrations of Carbon monoxide, Oxygen, Oxides of nitrogen, Sulphur dioxide and temperature were measured within the analyser box and all data was logged electronically in 1-minute intervals. Data was downloaded from the control handheld using the Com soft software and average concentrations calculated are presented within. All results presented are at K, kpa on a dry gas basis. 2.3 Particulate sampling and analysis Samples of the gas stream were extracted through a probe and filter holder arrangement containing a pre-conditioned and pre-weighed quartz fibre filter using a TCR automated isokinetic sampling train. Sampling was performed in accordance with BS EN :2002, where possible. Emissions were measured over a minimum of 30 -minute period. Upon completion of sampling, the filters were placed in their original container and sealed. All sampled were labelled and logged onto a laboratory submission sheet. All filters were sent to a UKAS accredited laboratory for gravimetric analysis. Filter head wash was also packaged into a sealed container for gravimetric analysis. Results are presented in mg Nm -3 at standard temperature of K and standard pressure of kpa without correction for moisture content Total Particulate matter sampling methodology Job preparation A pre-site survey must first be taken to obtain the following information. Client details (name and address), description of stack to include name and location), sample platform/access, Hazards, Power supply and location, additional PPE required. The Iso stack TCR Tecora automatic isokinetic particulates measurement equipment is fully inspected prior to use and its calibration stats observed. This includes: Pitot tube-all pitot tubes are checked for damage/burrs, paying particular attention to the inlet holes. All dirt and blockages are removed. Micro manometer-digital differential pressure metres that are used are capable of measuring in the range of 0 Pa to 2250 Pa with a sensitivity of ±1 Pa. The instrument is checked for physical damage, battery life test and calibration status observed. 2

32 Report Number 2009A107(2) ENVIROCO Management Ltd Nozzles-All nozzles used have been constructed in accordance with EN and ISO 9096:2003. Each nozzle is physical checked for damage and removed if necessary. The nozzle calibration status is observed. Flow metre-the flow metre is checked for blockages and obvious physical damage. Its calibration status is also observed. Rope kit-all lifting tackle are physical checked for cuts and contamination. Laboratory-The gravimetric testing house selected is UKAS accredited for the particular test method Filter selection and preparation Stack conditions can vary for temperature, moisture, acidity, low and heavy particulate loading. Following the pre-site survey, the stack condition should be known and the appropriate filter can be selected and prepared as described below. Filter mediums-glass wool, quartz wool, Low ash PVC membranes and a range of thimbles can be used depending on stack characteristics. Quartz filters were used in this instance as glass fibre filters can react to SO 3 and lead to inaccurate measurement. Filters are prepared by drying in an oven at C for a period of 1 hour and placed in a dessicator to cool. The filters are weighed accurately on a 4-figure balance and then placed in clean filter holder before transport to site. Spare filters are also prepared Sampling location Suitability of sampling location Before sampling can commence, a preliminary velocity and temperature survey must be undertaken along the two sampling lines at nine equally concentric spaced areas in the stack. This is performed in accordance with EN :2002, where possible. The procedures as set out in Section 2.1 of the standard were followed. The stack diameter is measured using a steel rod. The angle of gas flow must be less than 15 0 with regard to duct axis. There should be no local negative flow. The minimum velocity should be larger than 5 Pa for Pitot tube measurement. Sampling is undertaken from either four or eight sampling points on each plane. Sampling points shall be located either more than 3% of the sampling line length or more than 5 cm whichever is the greater value from the inner wall. If the ratio of the highest to the lowest dynamic pressure exceeds 9:1 of the ratio of the highest to lowest gas velocity exceeds 3:1, another sampling plane should be used. Sampling is undertaken from either four sampling points on each plane. Temperature is also measured at nine equally spaced points along the sampling line and average temperature calculated during the initial survey. Should the temperature at any of the sampling points differ by more that ±10% from that of the average, then that point must not be used. The sample port position did not concur with the requirements EN :2002. The required number of sampling points can now be calculated using the following: 8 point sampling, circular stacks X D, 0.25 X D, 0.75 X D, X D Leak checks A leak check is undertaken before and after the isokinetic sampling is carried out. This is to make sure that all intake volume is through the sampling nozzle only. 3

33 Report Number 2009A107(2) ENVIROCO Management Ltd Sampling Once the isokinetic sampling flow rates have been calculated, the probe is inserted into the stack at 90 0 to the stack gas flow, as not to impinge any particulate matter on to the filter media prior to sampling. The filter head is allowed to attain stack temperature. The pump is started and the nozzle is turned into the flow and the timing device is started (automatic on TCR Tecora kit) Duration of sampling Duration of sampling time depends on: Ensuring adequate quantities of particulate matter on the filter for weighing (> 0.3% of the filter weight), Whether cumulative or incremental sampling is undertaken, The number of sampling points, The continuity of the plant operation Cumulative sampling After the first sample is taken from the first sampling location, the probe is moved to the next position and the values recorded. This should be performed until all sampling points have been used. Sampling is continued till all locations are sampled Repeat Velocity and temperature readings. Since the TCR Tecora is an automatic system, continuous velocity and temperature readings are carried out using the instrument. All data is stored upon the on board computer and recorded following the sampling event. The % DI (deviation) is also computed and recorded continuously Weighing of the sample When finished, the sample filter is placed in its container and all particulate from the filter head is added to the particulate matter on the filter (i.e. filter wash). The used filter is placed in an over at C for at least 1 hour and dried thoroughly, cooled and equilibrated is a dessicator and weighed as quickly as possible so as to avoid any errors to moisture. The gross weight of the filter should be measured to within ±0.01 to 0.10 mg. The filter weight and any of the residual particulate matter from the filter head can then be used in the final report to calculate the particulate concentration. 4

34 Report Number 2009A107(2) ENVIROCO Management Ltd 3. Results-Emission testing. The results of testing emission sources 1 to 4 are presented in Table 3.1 to Volumetric flow rate Table 3.1 summarises the flow measurements from the stack and includes the stack velocity, expressed in metres per second (m s -1 ) and volumetric airflow rates expressed in m 3 hr -1 at standard reference conditions of K, kpa (i.e. normalised temperature and pressure). The other operational information gathered during the monitoring program is presented within Table 3.1. Sample port arrangement did not allow measurement to be performed in accordance with EN : Flue gas concentrations Flue gas concentrations were monitored using a pre-calibrated Testo 350/454 MXL flue gas analyser. The results of CO, O 2, SO 2, CO 2 and NO x as NO 2 + NO, are presented in Tables 3.2 to 3.5. The results of ppm have been converted to mg Nm -3 at K, kpa, on a dry gas basis with correction for oxygen content. In accordance with IPPC licence requirements, Oxygen correction to 3% should be performed for each emission point. The average temperature of the gas analyser on the day of sampling was K. 3.3 Total particulates emissions Total Particulates concentrations were monitored using a TCR Tecora automated Particulate sampler. The results of Total Particulates are presented in Table 3.2 and 3.5. The results of mg/m 3 have been converted to mg/nm 3 at K, kpa, on a wet gas basis with correction to 3% oxygen content. 5

35 Report Number 2009A107(2) ENVIROCO Management Ltd Table 3.1. Measurement of Volumetric airflow rate from the exhaust of each boiler stack. Sample location Diameter (m) Airflow rate (m/s) Area (m 2 ) Temperature (K) Volumetric airflow rate (Nm 3 /hr) Emission limit value Boiler 1 - Fulton Boiler 2 - Sime Boiler 3 BLR Boiler 4 BLR Notes: 1 denotes normalised to Kelvin and kpa, dry gas. 2 denotes conversion from 0 C to Kelvin ( 0 C K) 6

36 Report Number 2009A107(2) ENVIROCO Management Ltd Table 3.2. Emission value results from emission point Boiler 1 - Fulton located in GeneMedix PLC, Sragh Industrial Estate, Tullamore, Co. Offaly. Emission Point Boiler 1 - Fulton Values Units Adjusted units (mg/m 3 ) Normalised Emission conc (mg/nm 3 ) Oxygen corrected emission conc. to 3% (mg/nm 3 ) TA Luft Guideline limit values 1 Carbon monoxide (CO) 3.0 ppm mg/nm 3 Oxygen (O 2 ) 5.0 % Total NO X [as NO 2 ] 66 ppm mg/nm 3 Sulphur dioxide (SO 2 ) 2.0 ppm mg/nm 3 Carbon dioxide (CO 2 ) % Total Particulates 8.0 mg/m mg/nm 3 Notes: 1 denotes see section TaLuft

37 Report Number 2009A107(2) ENVIROCO Management Ltd Table 3.3. Emission value results from emission point Boiler 2 - SIME located in GeneMedix PLC, Sragh Industrial Estate, Tullamore, Co. Offaly. Emission Point Boiler 2 - SIME Values Units Adjusted units (mg/m 3 ) Normalised Emission conc (mg/nm 3 ) Oxygen corrected emission conc. to 3% (mg/nm 3 ) TA Luft Guideline limit values 1 Carbon monoxide (CO) 16 ppm mg/nm 3 Oxygen (O 2 ) 7.47 % Total NO X [as NO 2 ] 80 ppm mg/nm 3 Sulphur dioxide (SO 2 ) 13 ppm mg/nm 3 Carbon dioxide (CO 2 ) % Total Particulates 3.0 mg/m mg/nm 3 Notes: 1 denotes see section TaLuft

38 Report Number 2009A107(2) ENVIROCO Management Ltd Table 3.4. Emission value results from emission point Boiler 3 BLR located in GeneMedix PLC, Sragh Industrial Estate, Tullamore, Co. Offaly. Emission Point Boiler 3 BLR52-01 Values Units Adjusted units (mg/m 3 ) Normalised Emission conc (mg/nm 3 ) Oxygen corrected emission conc. to 3% (mg/nm 3 ) TA Luft Guideline limit values 1 Carbon monoxide (CO) 56 ppm mg/nm 3 Oxygen (O 2 ) 2.77 % Total NO X [as NO 2 ] 77 ppm mg/nm 3 Sulphur dioxide (SO 2 ) 29 ppm mg/nm 3 Carbon dioxide (CO 2 ) % Total Particulates 4.20 mg/m mg/nm 3 Notes: 1 denotes see section TaLuft

39 Report Number 2009A107(2) ENVIROCO Management Ltd Table 3.5. Emission value results from emission point Boiler 4 BLR located in GeneMedix PLC, Sragh Industrial Estate, Tullamore, Co. Offaly. Emission Point Boiler 4 BLR52-02 Values Units Adjusted units (mg/m 3 ) Normalised Emission conc (mg/nm 3 ) Oxygen corrected emission conc. to 3% (mg/nm 3 ) TA Luft Guideline limit values 1 Carbon monoxide (CO) 14 ppm mg/nm 3 Oxygen (O 2 ) 3.16 % Total NO X [as NO 2 ] 78 ppm mg/nm 3 Sulphur dioxide (SO 2 ) 22 ppm mg/nm 3 Carbon dioxide (CO 2 ) % Total Particulates 4.80 mg/m mg/nm 3 Notes: 1 denotes see section TaLuft

40 Report Number 2009A107(2) ENVIROCO Management Ltd 4. Discussion of results Tables 3.1 to 3.5 present the results of the emission-monitoring program carried out on the 12 th December 2008 in GeneMedix PLC, Sragh Industrial Estate, Tullamore, Co. Offaly. As can be observed in Tables 3.1 to 3.5, emissions of Carbon monoxide, Oxides of nitrogen, Sulphur dioxide and Total particulates referenced to 3% Oxygen are reported in accordance with IPPC Licence Conclusion The following conclusions were drawn from the study: 1. The volumetric airflow rate of each Boiler emission point 1 to 4 is reported in accordance with IPPC Licence Concentrations of Carbon monoxide, Oxides of nitrogen, Sulphur dioxide and Total particulates were reported in accordance with IPPC Licence The exhaust gas emissions are in the typical concentration range for such compounds in the exhaust flue gas from boilers operating on gas oil / light fuel oil. 4. All recorded values were within the recommended guideline limit values contained in TaLuft

41 Report Number 2009A107(2) ENVIROCO Management Ltd 6. APPENDIX I-SAMPLING AND ANALYSIS DETAILS B.1.1 B.1.2 B.1.3 B.1.4 Location of Sampling GeneMedix PLC, Sragh Industrial Estate, Tullamore, Co. Offaly Date & Time of Sampling 12 th December 2008 Personnel Present During Sampling Dr. John Casey, Odour Monitoring Ireland, Unit 32 DeGranville Court, Dublin Road, Trim, Co. Meath. Dr. Brian Sheridan, Odour Monitoring Ireland, Unit 32 DeGranville Court, Dublin Road, Trim, Co. Meath. Instrumentation Testo 350 MXL/454 in stack analyser. L type pitot and PT100 thermocouple. Testo 400 handheld and appropriate probes. TCR Tecora Isokinetic Particulate sampler and associated nozzles. B.1.5 Standards EN :

42 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT APPENDIX 3 Noise Monitoring Report 13

43 Noise Report for GENEMEDIX PLC. SRAGH INDUSTRIAL PARK, TULLAMORE, CO. OFFALY Printed on Recycled Paper 14

44 GeneMedix plc Noise Report Sragh Industrial Park, IPPC Licence No. P Tullamore, Co. Offaly TABLE OF CONTENTS: 1.0 Introduction Environmental Monitoring Noise Survey Methodology Results Discussion Octave Band Analysis and Discussion / 3 Octave Analysis Conclusions List of Tables: Met Eireann Weather Data Monitoring Locations at the GeneMedix plc Facility, Tullamore, December Summary of Noise Levels at Boundary Locations GeneMedix plc, Tullamore Summary of Noise Levels at Noise Sensitive Locations GeneMedix plc, Tullamore List of Figures: Site Location Map GeneMedix plc, Tullamore Noise Monitoring Locations GeneMedix plc, Tullamore Appendix A Noise Results and Charts ENVIROCO Management Ltd - 1 -

45 GeneMedix plc Noise Report Sragh Industrial Park, IPPC Licence No. P Tullamore, Co. Offaly 1.0 Introduction ENVIROCO Management has been commissioned by Mr. Conor O Dea of GeneMedix plc, Sragh Industrial Estate, Tullamore, Co Offaly to submit an environmental noise survey in response to condition 8.1 of the GeneMedix plc IPC license No; 638 which states: The licensee shall carry out a noise survey of the site operations within one year of the date of commencement of the activity. The licensee shall consult with the Agency on the timing, nature and extent of the survey and shall develop a survey programme to the satisfaction of the Agency. The survey programme shall be submitted to the Agency in writing at least one month before the survey is to be carried out. Figure Site Location of the GeneMedix plc Facility, Tullamore, Co. Offaly The GeneMedix plc facility is located in the Sragh Industrial Park in the northwest section of Tullamore, Co. Offaly, off the N80 road to Clara figure The Sragh Industrial Park is ENVIROCO Management Ltd - 2 -

46 GeneMedix plc Noise Report Sragh Industrial Park, IPPC Licence No. P Tullamore, Co. Offaly dominated by enclosed industrial units, with little mobile machinery operating outside of these units. A green area, with fountain, is located to the centre of the park. This green area is planted with a variety of deciduous trees which improve visual amenity and reduces the impact of noise created within the industrial park. The road which passes through the industrial estate connects the R443 to the N80 and does experience some increased volumes of pass through traffic at times. Two speed ramps and roundabout are present along the industrial park road to limit speeds of vehicles entering the industrial park area. A children s crèche is present within the park with both indoor and enclosed outdoor play area. This noise report has 2 primary objectives: o Assessment of the noise emissions from the GeneMedix plc facility o Compare these results to previous monitoring carried out at the facility. 1.1 Environmental Noise Monitoring ENVIROCO Management was commissioned Mr. Conor O Dea of GeneMedix plc, Sragh Industrial Estate, Tullamore, Co Offaly to carry out environmental noise monitoring. Monitoring occurred on the 3 rd December Monitoring was carried out during normal activity at the facility. 2.0 Noise Survey Noise has many sources, both manmade and environmental. Noise is observer defined, as levels unacceptable to one person may be perceived as necessary or enjoyable to another. As such the monitoring of noise is primarily an observational discipline requiring a full identification of the sources of possible noise and the type of sound that is been emitted (continuous, intermittent, tonal, broad-spectrum, single source, multiple source). The Environmental Protection Agency (EPA) has adopted a noise level (as a continuous equivalent noise reading L eq ) of 55 db (A) as an indicator of annoyance due to noise arising from industrial activity. This level is given at the receptor or noise sensitive location (NSL). Monitoring of noise at the GeneMedix plc facility in the Sragh Industrial Park, Tullamore, took into account both the nature of the site, the history of the site, the intensity of the operations and the proximity of local sensitive receivers. Monitoring was carried out midweek during the hours of 9am to 6 pm; the facility does not operate during night-time therefore readings after 7pm were not recorded. 2.1 Methodology Noise monitoring was carried out to the International Standard ISO 1996/1 Acoustics Description & measurement of environmental noise, using a Bruel & Kjaer Model 2250 Sound Level Meter with outdoor equipment that was fully calibrated prior to the monitoring event. Noise monitoring was carried out on the 3 rd December The GeneMedix plc facility in the Sragh Industrial Park does not operate over-night; therefore noise monitoring was not carried out overnight. ENVIROCO Management Ltd - 3 -

47 GeneMedix plc Noise Report Sragh Industrial Park, IPPC Licence No. P Tullamore, Co. Offaly Weather conditions during sampling were dry and bright with a light breeze. Temperatures were close to freezing in the morning and increased only slightly as the day continued. Table Met Eireann Report REPORTS FROM BIRR WEATHER STATION Date Rainfall Max Min Sunshine Gusts Wind speed (mm) Temp Temp (hours) 3/12/ The monitoring equipment was manned throughout the sampling period and comments/notes taken to assist the interpretation and assessment of results. Sampling was carried out at 3 boundary locations along the facilities boundary and at 3 Noise Sensitive Locations (Figure 2.1.1). ENVIROCO Management staff selected these monitoring locations. The monitoring locations are shown in table below Table Monitoring Locations at the GeneMedix plc plant, Tullamore, Dec 2008 Station Grid Reference* Description Easting Northing GM NB Rear yard of the plant GM NB Side car park of the plant GM NB Front boundary of the plant adjacent to Industrial Park Road GM NS Outside the Grovelands Childcare Facility GM NS Rear of the Moorehill House Hotel, adjacent to newly built townhouse GM NS Within the Moylena Housing Estate GM NB Front boundary of the plant adjacent to Industrial Park Road GM NB Rear yard of the plant GM NB Side car park of the plant * Grid reference is 7 digit WSG84 ITM ENVIROCO Management Ltd - 4 -

48 GeneMedix plc Noise Report Sragh Industrial Park, IPPC Licence No. P Tullamore, Co. Offaly Figure Noise Monitoring Locations GeneMedix plc Facility, Tullamore, 3 rd December Results The complete set of noise measurement results is included in Appendix A. These are summarised and discussed below. Table Location Summary of Site Boundary Noise Levels Start Time L Aeq (2008) Comments Site: Electric doors opening at rear of premises, fans operating at outdoor chiller unit GM NB :06 55 Electric motors operating at the rear of the facility Whining of electric motor pumping fuel from fuel tank Background: dogs barking barely audible, wind rustling trees 6m away, fans from Sennheiser faintly audible 30m away. ENVIROCO Management Ltd - 5 -

49 GeneMedix plc Noise Report Sragh Industrial Park, IPPC Licence No. P Tullamore, Co. Offaly Table Summary of Site Boundary Noise Levels (Cont) Site: Whining of electric motor pumping fuel from fuel tank GM NB :39 52 Pneumatic pump at rear of the facility audible 20m away (outlet pump) Background: Lorry entering Sennheiser and and being unloaded by forktruck, reversing alarm on forktruck sounding frequently, rattling noise of pallets-forks of forktruck. Construction activity to North involving heavy thud noise intermittently Site: Car entering site, rattling noise from the boiler room, car entering the facility. GM NB :11 55 Background: Humming noise from Covidien clearly audible, fans from Sennheiser (approx 40m away) faintly audible. Passing traffic ( 15m away); 20 cars, 4 vans, 3 jeeps and 1 bus. GM NB :52 53 Site: Fans operating at outdoor chiller units, electric motor pumping fuel at the rear of the facility. Pneumatic pump (20m away) operating at the rear of the facility pumping waste water to discharge. Background: trees rustling, lorry entering Sennheiser. Site: Whining of electric motor pumping fuel from fuel tank GM NB :22 54 Pneumatic pump at rear of the facility audible 20m away (outlet pump) Background: Lorry entering Sennheiser and and being unloaded by forktruck, reversing alarm on forktruck sounding frequently, rattling noise of pallets-forks of forktruck. Construction activity to North involving heavy machinery noise intermittently Site: 3 cars s entering site, rattling noise from the boiler room, car entering the facility. GM NB :55 55 Background: Humming noise from Covidien clearly audible (150m away), fans from Sennheiser (approx 40m away) faintly audible. Passing traffic (15m away); 64 cars, 4 vans, 36 jeeps and 9 Lorries. ENVIROCO Management Ltd - 6 -

50 GeneMedix plc Noise Report Sragh Industrial Park, IPPC Licence No. P Tullamore, Co. Offaly Table Location Summary of Noise Levels at Noise Sensitive Locations Start Time L Aeq (2007) Comments Site: No activity audible. GM NS :48 51 Background: Children playing and shouting in crèche playground 10m away for 10 mins, humming noise from operations at Covidien faintly audible. Traffic from main road audible but not visible. Train entering Tullamore sounding horn. Passing traffic; 17 cars, 1 car + trailer, 3 lorries, 3 vans, 3 jeeps and 1 bus. Site: Not audible GM NS :26 57 Background: Passing traffic on the main road (approx. 35m away) audible but not visible, car horn sounding on the road. Birdsong, Covidien barely audible in the distance. Site: Not audible GM NS :00 46 Background: Trees rustling, birdsong, car passing within housing estate 30m away, birdsong, trees rustling, HGV s faintly audible within the IDA industrial estate. ENVIROCO Management Ltd - 7 -

51 GeneMedix plc Noise Report Sragh Industrial Park, IPPC Licence No. P Tullamore, Co. Offaly 2.3 Discussion There are currently no statutory limits for the control of environmental noise in Ireland. However, the EPA has issued a guidance note on noise emissions that states, Ideally, if the total noise level from all sources is taken into account, the noise level at sensitive locations should be kept below an L Aeq value of 55dB(A) by daytime. At night, to avoid disturbance, the noise level at noise sensitive locations should not exceed a L Aeq T value of 45dB(A). Primary activity at the GeneMedix plc facility occurs during the day, with skeletal operations occurring overnight. Noise sources from the plant, audible at the site boundaries have been identified as: Vehicles entering/leaving the site Personnel entering/leaving building Pumps and fans operating to the rear of the plant Of these identified sources the noise associated with the pumps, located at the rear of the plant, were the only sources to offer a relatively continuous noise. The pumps were barely audible at the side of the plant as the size of the GeneMedix plc main building absorbed and reflected most of the sound east. Monitoring stations at the front of the building could not discern noise associated with these pumps and fans. Three boundary locations have been identified as representative of the noise arising from the GeneMedix plc operations at the Tullamore plant. All boundary stations are denoted as GM NB. Each station was monitored twice to establish an accurate sound pressure reading. The monitoring stations were numbered 001 & 007, 002 & 008, and 003& 009 on the East, South and West boundaries of the plant respectively. The Tullamore GeneMedix plc plant is located within the Sragh Industrial Park. This industrial park is typified by pharmaceutical operations and clean room environments, with Covidien Healthcare, Zaninni Ireland, Sennheiser, Boston Scientific, all located within a relatively close proximity to the GeneMedix plc plant. All clean-room environments require controlled ventilation and air supply, and the noise associated with these fans, and other ancillary activities, outside of the primary plant building all increased noise levels within the industrial park All boundary noise monitoring locations to GeneMedix plc showed results below the upper EPA guideline limit of 55 db(a). The highest boundary noise results were recorded along the western boundary (NB003, NB009) with LAeq measurements of 55 db(a) recorded in the morning and afternoon stations. Primary noise associated at this boundary was the continual movement of vehicles through the business park and noise arising from activities at Covidien to the South West of the facility. Passing traffic counted during the morning and afternoon stations showed an average traffic volume of 76 vehicles per hour of which 5.9% were Heavy Commercial Vehicles (HCV,s) ENVIROCO Management Ltd - 8 -

52 GeneMedix plc Noise Report Sragh Industrial Park, IPPC Licence No. P Tullamore, Co. Offaly Stations GM NB 001 & 007, located to the rear of the plant received L eq values of 55 and 53 db(a) respectively. These stations were positioned on the eastern boundary, with clear line of sight to the chiller units and pumping units for the GeneMedix plc plant. The southern boundary of the plant was monitored by stations GM NB 002 & 008. Noise arising at this boundary was a mix of traffic passing on the industrial road, muffled noise arising from the fans and pumps to the rear of the plant and activities arising from neighbouring plant. These stations received L eq values of 52 and 54 db(a) respectively. All boundary stations are classed as non sensitive receivers and displayed results below the EPA guideline limit. Three Noise Sensitive Locations (NSL s) were monitored. These stations were denoted by GM NS. Each station was monitored once with notes taken to identify noise sources. Station GM NS 004 was positioned outside the crèche located within the Sragh Business Park. This station is situated on a higher elevation than GeneMedix plc and has an overview perspective of the business park and its surround. This station recorded a L eq value of 51 db(a). Noise arising at this station was from several varying sources, including children playing; traffic passing through the Business Park and activities at several facilities within the business park. Noise arising from operations at GeneMedix plc was not identified at this station. GM NS005 was positioned to the rear of the Moorhill House Hotel beside the new townhouses, approximately 250m to the East of the Gene-Medix plc facility. These houses are surrounded by a high boundary wall which helps reduce any potential nuisance noise from the Sragh Industrial Estate. The primary noise source at this location was passing traffic on the main road which was audible but not visible from this monitoring location. Station GM NS 005 received a L eq value of 57 db(a). This was the highest result and exceeded the EPA guideline by 2 db(a) GM NS 006 was positioned on the northwest boundary of the Moylena Housing Estate. This station has a view of the northeast boundary of the Sragh Business Park, with dwelling houses located to its east, west and south and open grassland to the north. There was no audible noise from the Gene-Medix plc facility at this location. Station GM NS 006 shows a L eq value of 45 db(a). Activities at the GeneMedix plc plant predominately occur within the plant building, with primary outdoor noise sources being the operation of pumps and fans located to the rear of the plant. The level of noise arising from these items is relatively low. Measurements of noise at NSL s in the vicinity of the plant were low (typically under a L Aeq of 55 db(a)). ENVIROCO Management Ltd - 9 -

53 GeneMedix plc Noise Report Sragh Industrial Park, IPPC Licence No. P Tullamore, Co. Offaly 3.0 Octave Band Analysis and Discussion Octave band analysis of noise is the breakdown of the sound pressure readings, as recorded on site, into specific frequency band width s. This enables a greater understanding of the type of noise evident at a site and can give indications to where tonal noise is present. There are two common forms of octave analysis (i.e. full and 1/3 octave analysis). Full octave analysis groups sound pressure readings into frequency readings that cover a full octave. This type of monitoring gives a good general description of how people will perceive a sound/noise. One third octave analysis, further separates the noise reading into 1 / 3 octave frequency groupings. Each frequency reading is given in Hz. The frequency reading is the central frequency for each band that is been monitored (i.e. Frequency band 250 Hz covers all sound pressure readings recorded between 167Hz to 333Hz) / 3 Octave Analysis Full results of the 1/3 octave analysis are shown in Appendix A, including charted results for each station. These results and charts are discussed below. The overview chart of all monitoring stations shows a similar trend at most stations, with sound pressure levels beginning low and rising sharply at the 20 Hz bandwidth, sound pressure continues to rise across frequency bandwidths until levels peak at 125 Hz to 2.0 KHz, before tailing off at higher frequencies. There are 4 peaks evident in the overview chart; these are located at 63-80, , and Hz. The most extreme peak may be observed at NS005 between Hz ranges. Boundary station GM NB 003 and 009, located to the front of the GeneMedix plc facility show relatively similar readings. The evening station, GM NB009, does indicate some tonal aspects at 125 Hz, which was not identified in the morning station. This short sharp rise may be attributed to passing traffic on the nearby road through the Sragh Industrial Estate. Tonal aspects from activities at the GeneMedix plc facility were not noted. The rear of the facility was monitored by station GM NB 001 and 007. Both stations show strong similarity in relation to sound pressure levels at varying frequencies. Although there were no identifiable tones, peaks were noted at 630 and 2,000 Hz. This station was located closest to the pump and fans associated with GeneMedix plc. These peaks are at the lower frequencies 630 and 2000 Hz, with each of these frequencies showing sound pressure levels in excess of 40 db(a). The pneumatic pump associated with the final discharge of waste water was the most audible of the tonal aspects, followed by the electric pump used for supplying fuel from the fuel tank at the rear of the facility. This proximity and nature of noise arising from these activities would indicate that the pneumatic pump was responsible for the peak at 2000Hz while the electric diesel pump may have been responsible for the peak at 630 Hz. This station is not a noise sensitive location. The southern boundary of the GeneMedix plc plant was monitored by stations GM NB 002 and 008. These stations were both located on the edge of the footpath surrounding the facility. Both stations show a very close resemblance to each other in relation to sound pressure over varying frequencies. The morning station NB003 shows some tonal aspects at 125 Hz which may have been due to a lorry being unloaded by fork-truck in Sennheiser (20m away) with reversing alarm sounding frequently. ENVIROCO Management Ltd

54 GeneMedix plc Noise Report Sragh Industrial Park, IPPC Licence No. P Tullamore, Co. Offaly From the boundary monitoring stations it is noted that tonal aspects were identified at various monitoring locations, however there was only one monitoring location with tonal noise related to activity within the Gene Medix plc facility. This location was at the rear of the facility on the Eastern boundary and was monitored in the morning as NB001 and evening as NB007. The tonal noises observed were identified as the following; 50 db (Z) 630 Hz : Pneumatic discharge pump 45 db (Z) 2000 Hz Electric fuel pump These are results from the boundary monitoring stations and are not noise sensitive stations. The monitoring station established outside the Groveland s crèche (GM NS 004) shows some tonal aspect at 125 Hz. This may have been due to children playing and screeming in close proximity to the noise meter. Monitoring conducted at the newly build Moorehill town houses GM NS 005, identifies a sharp tonal frequency rise at 4000 Hz. This station did not identify any notable noise arising from activities at the GeneMedix plc facility, nor was there tonal noise identified at this frequency within the confines of the facility boundary The primary noticeable noise sources at this location, with a tonal nature, was the heavy traffic flow on the nearby Regional R443 Tullamore to Clara Road. 54 db (Z) 4000 Hz Traffic on R443 Station GM NS 006, established within the Moylena Housing estate identifies tonal aspects at 125 Hz range. This station did not identify any notable noise arising from activities at the GeneMedix plc facility. The tonal peak could have arisen from the increased rev s over the short time duration, as a car passed through the housing estate. Of the three NSL s monitored none showed any indication of tonal noise arising from activities at the GeneMedix plc facility. ENVIROCO Management Ltd

55 GeneMedix plc Noise Report Sragh Industrial Park, IPPC Licence No. P Tullamore, Co. Offaly 4.0 Conclusions Environmental noise monitoring was carried out by ENVIROCO Management Ltd at the GeneMedix plc plant situated within the Sragh Industrial Park, Tullamore, Co. Offaly, on the 3 rd December Monitoring was requested by Mr. Conor O Dea of GeneMedix plc as part of the annual noise monitoring schedule and Annual Environmental Report for submission to the Environmental Protection Agency. Noise monitoring was conducted utilising the Bruel Kjaer 2250 Sound Level Meter. This monitor was operates as a Real Time Analyser (RTA) and Sound Level Meter (SLM), enabling both statistical analysis of the audible noise and breakdown of the sound pressure recorded into frequency bandwidths. The statistical analysis of the noise at boundary monitoring stations shows primary noise at the boundaries of the facility are attributable to road traffic and, to a lesser extent, the operation of pumps and fans on site. Almost all Noise Sensitive Locations show broadband noise pressures below L eq of 55 db(a). 1/3 Octave analysis identified 2 tonal components of note to the rear of the GeneMedix plc facility 630 Hz 2000 Hz These frequencies both showed identifiable peaks on the eastern boundary of the site. Frequency ratings of 630 and 2000 Hz having been associated with the operation of the pneumatic pump at the rear of the facility and the running of an electric fuel pump at the rear of the facility. A comparison of noise levels recorded in December 2008 and August 2007 showed a general reduction in boundary noise levels. All boundary station noise levels were within the EPA guideline limit of 55 db(a) with the exception of GM NS 005 located to the rear of the Moorhill House Hotel. Activity from the GeneMedix plc. Was not audible from this location. This shows that the Gene-Medix plc is unlikely to cause nuisance noise to sensitive receivers. ENVIROCO Management Ltd

56 GeneMedix plc Noise Report Sragh Industrial Park, IPPC Licence No. P Tullamore, Co. Offaly ENVIROCO Management Ltd

57 GeneMedix plc Noise Report Sragh Industrial Park, IPPC Licence No. P Tullamore, Co. Offaly Appendix A Noise Results & Charts ENVIROCO Management Ltd I

58 GeneMedix plc Noise Report Sragh Industrial Park, IPPC Licence No. P Tullamore, Co. Offaly Noise Results Client: GeneMedix plc. Site: Sragh Industrial Park, Tullamore, Co. Offaly Monitoring Date: 3 rd December 2008 Sampler: Eamonn Lee (ENVIROCO Management Ltd) Weather: Overcast, occasional light showers, light and cool breeze, mild - cool Equipment: Bruel & Kjaer 2250 SLM with outdoor equipment Model Number: 2250 Peak Weighting: Flat Serial Number: Detector: Fast Weighting: A Table 1 Noise Results Duration Time (min) L eq db(a) L max db(a) L min db(a) L ( 1) db(a) L ( 5) db(a) L (10) db(a) L (50 ) db(a) L (90) db(a) L (95) db(a) L (99) db(a) Number GM NB : GM NB : GM NB : GM NS : GM NS : GM NS : GM NB : GM NB : GM NB : Table 2 Notes Regarding Monitoring Positions Sensitive Locations Number Grid Ref.* Comments GM NS South of the carpark for the Grovelands Childcare Unit GM NS Rear (south) carpark area of the Moorehill House Hotel, now carpark for newly developed townhouses Within the Moylena Housing Estate, along north boundary at GM NS entrance to field, views of Sragh Industrial Park and Moorehill House *Grid reference s are 7 digit WSG 84 ITM ENVIROCO Management Ltd II

59 GeneMedix plc Noise Report Sragh Industrial Park, IPPC Licence No. P Tullamore, Co. Offaly Table 3 Notes Regarding Monitoring Positions Boundary Locations Number Grid Ref.* Comments GM NB Rear yard area of the GeneMedix plc plant, near outdoor storage areas GM NB Side of the GeneMedix plc plant, along boundary hedge with the Sennheiser facility Front of the GeneMedix plc plant adjacent to the Sragh Industrial Park Road and the entrance to the Zanini Ireland Facility GM NB GM NB GM NB Sennheiser facility GM NB *Grid reference s are 7 digit WSG 84 ITM Rear yard area of the GeneMedix plc plant, near outdoor storage areas Side of the GeneMedix plc plant, along boundary hedge with the Front of the GeneMedix plc plant adjacent to the Sragh Industrial Park Road and the entrance to the Zanini Ireland Facility Table 4 Weather Data REPORTS FROM BIRR WEATHER STATION Date Rainfall Max Min Sunshine Gusts Wind speed (mm) Temp Temp (hours) 3/12/ The above data refer to the period midnight to midnight They are provisional data and have not been quality controlled Rain is total precipitation plus deposition in mm. Max is the maximum temperature in Degrees Celsius Min is the minimum temperature in Degrees Celsius Sun is the total sunshine in hours Gust is the highest gust of wind in knots if 34 knots or greater Wind is the mean wind speed in knots Soil is the mean 10cm temperature in Degrees Celsius G min is the minimum temperature on a grass surface in Degrees Celsius ENVIROCO Management Ltd III

60 GeneMedix plc Appendix A Sragh Industrial Park, IPPC Licence No. P Noise Results Tullamore, Co. Offaly Variation of Sound Pressure at Gene Medix plc Boundary Locations Dec Sound Pressure db GM NB001 GM NB002 GM NB003 GM NB007 GM NB008 GM NB LAeq L1 L5 L10 L50 L90 L95 L99 LAFmax LAFmin Sound Pressure Parameter ENVIROCO Management Ltd IV

61 GeneMedix plc Appendix A Sragh Industrial Park, IPPC Licence No. P Noise Results Tullamore, Co. Offaly Variation in Sound Pressure at Gene Medix plc Noise Sensitive Locatioins, Dec Sound Pressure db GM NS004 GM NS005 GM NS LAeq L1 L5 L10 L50 L90 L95 L99 LAFmax LAFmin Sound Presure Parameters ENVIROCO Management Ltd V

62 GeneMedix plc Appendix A Sragh Industrial Park, IPPC Licence No. P Noise Results Tullamore, Co. Offaly Client: Site: Noise Results GeneMedix plc. Monitoring Date: 3 rd December 2008 Sragh Industrial Park, Tullamore, Co. Offaly Sampler: Eamonn Lee (ENVIROCO Management Ltd) Weather: Dry and bright with a light air breeze. Temperatures freezing. Equipment: Bruel Kjaer 2250 SLM with outdoor equipment Model Number: 2250 Serial Number: Detector: Fast Weighting: A Table 1 Record of Monitoring Events and L Aeq values Station Date Time Duration L eq GM NB rd December 08 9:06 00:30 55 GM NB rd December 08 9:39 00:30 52 GM NB rd December 08 10:11 00:30 55 GM NS rd December 08 10:48 00:30 51 GM NS rd December 08 11:26 00:30 57 GM NS rd December 08 12:00 00:30 45 GM NB rd December 08 13:52 00:30 53 GM NB rd December 08 14:22 00:30 54 GM NB rd December 08 14:55 00:30 55 Table 2 Monitoring Locations Rec # Grid Reference Altitude Description GM NB GM NB GM NB GM NS GM NS 005 GM NS GM NB East Boundary 66 South Boundary 68 West Boundary 70 Grovelands Childcare 63 Newly built townhouse 68 Moylena Housing Estate 60 East Boundary ENVIROCO Management Ltd VI

63 GeneMedix plc Appendix A Sragh Industrial Park, IPPC Licence No. P Noise Results Tullamore, Co. Offaly GM NB GM NB South Boundary 68 West Boundary ENVIROCO Management Ltd VII

64 GeneMedix plc Appendix A Sragh Industrial Park, IPPC Licence No. P Noise Results Tullamore, Co. Offaly Table 3 Sound Exposure Levels and Minimum and Maximum levels Rec # L AIeq -L Aeq LAF Min LAF Max L AIeq GM NB GM NB GM NB GM NS GM NS GM NS GM NB GM NB GM NB Table 4 Statistical Analysis of Noise Readings Rec # L 1.00 L 5.00 L L L L L GM NB GM NB GM NB GM NS GM NS GM NS GM NB GM NB GM NB ENVIROCO Management Ltd VIII

65 GeneMedix plc Appendix A Sragh Industrial Park, IPPC Licence No. P Noise Results Tullamore, Co. Offaly Table 5 L 1 Aeq / 3 Octave Analysis of Measurements taken on the 3 rd December 2008, GeneMedix plc, Tullamore L Aeq Frequency (Hz) GM NB GM NB GM NB GM NS GM NS GM NS GM NB GM NB GM NB ENVIROCO Management Ltd IX

66 GeneMedix plc Appendix A Sragh Industrial Park, IPPC Licence No. P Noise Results Tullamore, Co. Offaly Table 6 L Aeq 1 / 3 Octave Analysis of Measurements, taken on the 3 rd December 2008 L Aeq Frequency in Hz GM NB GM NB GM NB GM NS GM NS GM NS GM NB GM NB GM NB ENVIROCO Management Ltd X

67 GeneMedix plc Appendix A Sragh Industrial Park, IPPC Licence No. P Noise Results Tullamore, Co. Offaly Sound Pressure vs Frequency Chart, Gene Medix, Dec GM NB001 Sound Pressure db(z) Frequency (Hz) GM NB002 GM NB003 GM NS004 GM NS005 GM NS006 GM NB007 GM NB008 GM NB009

68 GeneMedix plc Appendix A Sragh Industrial Park, IPPC Licence No. P Noise Results Tullamore, Co. Offaly Comparison of Monitoring Stations NB001 &NB GM NB001 GM NB007 Sound Pressure db(z) Frequency HZ

69 GeneMedix plc Appendix A Sragh Industrial Park, IPPC Licence No. P Noise Results Tullamore, Co. Offaly Comparison of Monitoring Station NB002 & NB GM NB GM NB008 Sound Pressure db(z) Frequency HZ

70 GeneMedix plc Appendix A Sragh Industrial Park, IPPC Licence No. P Noise Results Tullamore, Co. Offaly Comparison of Monitoring Station NB003 & NB GM NB003 GM NB009 Sound Pressure db(z) Frequency HZ

71 GeneMedix plc Appendix A Sragh Industrial Park, IPPC Licence No. P Noise Results Tullamore, Co. Offaly Variation of Noise over Frequency at GM NS004, Gene Medix plc, GM NS Sound Pressure db(z) Frequency Hz

72 GeneMedix plc Appendix A Sragh Industrial Park, IPPC Licence No. P Noise Results Tullamore, Co. Offaly Variation of Noise over Frequency at Station GM NS GM NS Sound Pressure db(z) Frequency HZ

73 GeneMedix plc Appendix A Sragh Industrial Park, IPPC Licence No. P Noise Results Tullamore, Co. Offaly Variation of Noise over Frequency at GM NS GM NS006 Sound Pressure db(z) Frequency HZ

74 March 2009 Reliance GENEMEDIX PLC ANNUAL ENVIRONMENTAL REPORT APPENDIX 4 Underground tank Assessment Report

75 Name: Denis Bracken Date: 23 Sep. 08 Subject: Emptying and Cleaning of the Process Waste Tanks and Diesel Tank Bund The underground effluent collection tank and downstream balance tank, both located in the rear compound, were inspected in July Both were found to contain a significant amount of dirt and grime. The underground tank collects all of the liquid waste from the process drains within the plant. The balance tank is then fed from the underground tank and mixes all of the liquid waste before it goes on to the ph correction tank. Accelerated Drain Cleaning were engaged to clean both tanks. All staff were instructed not to pour any liquid down the drains and all equipment, where possible, was turned off during the cleaning. Accelerated drains first emptied the contents of both tanks into their vacuum tanker, and then power washed both tanks. The tanks were left in a spotless condition and neither exhibited any visible deterioration in its fabric. Both tanks have now been scheduled for emptying and cleaning every two years. Underground Tank Balance Tank The diesel bund contained rain water primarily, but with a thin oil film on the surface as a consequence of a minor weep on one of the diesel pumps. This leak was repaired and ENVA were called in to drain and clean the bund. Page 2 of 76

76 ENVA first of all removed all the liquid contents, followed by a thorough clean of the bund. The bund and sump were then thoroughly emptied and dried and the waterproof membrane around the side walls of the bund was repainted to restore its weathered finish. Denis Bracken Engineering Department 23 Sep. 08 Page 3 of 76