Annual Environmental Report. For. Becton Dickinson Insulin Syringe Limited (Irish Branch) and Becton Dickinson Penel Limited (Irish Branch)

Transcription

1 Annual Environmental Report For Becton Dickinson Insulin Syringe Limited (Irish Branch) and Becton Dickinson Penel Limited (Irish Branch) Licence Register No. P March 212

2 Licence Register No.P Table of Contents 1. Introduction General Company Environmental Policy Company Organisation for Environmental Management Summary Information Self-Monitoring Data Agency Monitoring and Enforcement Energy & Water Consumption Environmental Incidents & Complaints Summary of Abatement Plant Bypass Events Management of the Activity Schedule of Environmental Objectives & Targets Environmental Management Programme (EMP) Report Pollution Emission Register Report for Pollutant Emission Register Proposal for Solvent Usage Fugitive Emissions Assessment Report Report on ELRA & CRAMP Separation of Combined Drainage Licence-Specific Reports ANNEX I ANNEX II ANNEX III ANNEX IV ANNEX V AER/ PRTR ELECTRONIC REPORTING WORKBOOK SITE DRAWINGS ENVIRONMENTAL MANAGEMENT PROGRAMME SUMMARY REPORT BUND INTEGRITY TEST REPORT COMPLAINTS AND INCIDENTS

3 Licence Register No.P Introduction 1.1 General This Annual Environmental Report (AER) is submitted to the Environmental Protection Agency (EPA) in compliance with Condition of the IPPC Licence, Register No. P648-1 as amended by Amendments A, B and C to the licence. Amendment B came into place on 28 February 211 to amend the emissions to sewer. Amendment C was received on 4 January 212 to accommodate a higher flow rate through air emission point A2-1. While the changes do not impact on the reporting for the year 211 it is to be noted that the increase addresses any non-conformances that occurred on emission point A2-1 during the reporting year. The reporting method takes into consideration the new templates distributed by the EPA for annual environmental reporting on 6 February 212 where the reporting task had not been completed by that date. Data compiled prior to that date are reported in the same format as in previous years. The AER contains summary information on the environmental performance of Becton Dickinson Insulin Syringe Limited and Becton Dickinson Penel Limited for the year ended 31 st December 211. The items covered in this report are as follows: Emissions to Atmosphere Emissions to Sewer Groundwater Monitoring Surface Water Monitoring Agency Monitoring and Enforcement Resources Consumption Environmental Incidents and Complaints Environmental Objectives and Targets Environmental Management Programmes Pollutant Release and Transfer Register Licence Specific Reports Becton Dickinson (BD) is a manufacturer of a broad range of medical supplies, devices and diagnostic systems for use by health care professionals, research institutions and the general public. The Dún Laoghaire location is home to Becton Dickinson Insulin Syringe (Irish Branch) and Becton Dickinson Penel (Irish Branch). These operations are carried out at the facility on Pottery Road, Dún Laoghaire, Co. Dublin. The plant is a major manufacturing and distribution centre for the BD Consumer division, supplying the European market, Middle East and Far East, Africa, USA and Canada with diabetes products. The Becton Dickinson Penel (Irish Branch) operation comprises the manufacture of Pen Needles for use with a Pen Injector. The Pen Needles are disposable devices used to inject insulin. The operations within the plant have undergone substantial expansion in the last 7 years and by 211 thirteen Pen Needle production lines were operating 24/7. 1 March 212

4 Licence Register No.P Company Environmental Policy The Dun Laoghaire location of Becton Dickinson is committed to the protection of the environment in the interest of our customers, employees and community. In addition, we subscribe to the BD Corporate Safety and Environmental Policy statement. We shall continue to increase the benefits that can be achieved by the reduction, reuse and recycling of all our materials in order to minimise our effect on the environment. BD Dun Laoghaire is committed to achieve the BD Sustainability Goals for 215 set by the Office for Global Sustainability: Reduce energy consumption from operations 3% by 215, from 28 levels Increase renewable energy use in BD s portfolio to 25% by 215, from 28 levels Reduce the use of water by 15%, from 28 levels Reduce the amount of hazardous waste generated by 1%, from 28 levels Reduce waste going off site for disposal (landfill / incineration) by 15%, from 28 levels We shall strive to minimise our impacts upon the environment while pursuing our business activities of manufacturing medical devices to help all people live healthy lives. We are committed to the continual improvement of our environmental performance and to prevention of pollution. An Environmental Management System (EMS) is an integral part of managing the business and we operate in accordance to ISO 141 since 1999 and our IPPC Licence (Register No. 648) since September 23. This system sets forth objectives, programmes, procedures and implementation of controls to review progress in the areas of our environmental objectives and targets. BD Dun Laoghaire's Objective and Targets are reviewed by representatives responsible for each process and notified to the EPA as part of the preparation of the Annual Environmental Report (AER). Progress is annually reported to senior management during Management Review. An Environmental Management Team (EMT), with members representing the major functional areas, administers the EMS, taking into account new and developing requirements. The EMS tracks all relevant National and European legislation, standards and regulations to continually ensure compliance. The EMS is documented, implemented and maintained on the computerised system, SE-PRO. Reference to the computerised Quality Documentation Control System is made for Specified Operating Procedures where they affect environmental services. Access to both systems is available to all staff at their computer; however, changes are strictly controlled and restricted to authorised individuals. Contractors will be informed about our Environmental Policy and are required to conform to mutually agreed high standards and exercise codes of conduct consistent with carrying out their contractual commitments with the least possible effect on the environment. We shall implement, wherever possible, our policy to do business with companies achieving the 2 March 212

5 Licence Register No.P highest level of environmental compatibility and products with the least environmental impact. Our whole work-force will be informed of the fundamentals of the ISO 141 standard and environmental performance via briefing and training sessions. Personnel who have direct impact on the company's environmental Objectives and Targets will understand the contribution they can make to achieve our goals. BD Dun Laoghaire is committed to promoting environmental awareness and makes a copy of its Environmental Policy available to interested parties on request. 1.3 Company Organisation for Environmental Management Purpose To outline Management, Operator and Staff structure, and define responsibilities and authorities with regard to the Environmental Management System. To outline Management's responsibilities to provide adequate resources and personnel to ensure compliance to the Environmental Policy Scope This procedure applies to the Becton Dickinson facility at Dun Laoghaire, Ireland, and covers the following roles: Director of Diabetes Care Manufacturing, Ireland Management Representative Engineering Manager and his staff Environmental Management Team Operations Manager and his staff HR Manager and his staff Financial Controller, Country QA/ RA Manager, Supply Chain Manager and their staff IT Structure Definitions of responsibility and authority Director of Diabetes Care Manufacturing, Ireland The Director of Diabetes Care Manufacturing, Ireland in liaison with the Environmental Management Representative shall set the Environmental Policy. He shall assure compliance of operations at BD Dun Laoghaire with the policy through the Management Review. 3 March 212

6 Licence Register No.P Management Representative Eddie Garry, Sustainability Leader, is the management representative responsible for implementing and maintaining an Environmental Management System (EMS) which meets the requirements of ISO 141:24. In his function as Management Representative he also reports performance of the EMS to senior management during the Management Review Engineering Manager and his staff The Engineering Manager oversees processes that have or are likely to have an impact upon the environment and where necessary inform the appropriate Senior Engineers and the Sustainability Leader about incidents of non-compliance to ISO 141:24. His staff shall perform their tasks which are closely related to environmental impacts accurately and attentively. They shall report any occurrences that might lead to deviation from the Policy, Objectives and Targets, Programmes and/or procedures Environmental Management Team (EMT) The Environmental Management System (EMS) is operated under the stewardship of the Environmental Management Team. This team is a cross functional team consisting of members from Engineering, Operations, Supply Chain and Continuous Improvement. Membership changes from time to time. The current Management Representative is the Sustainability Leader. The Management Representative or his nominee organises the Environmental Management Team meetings on a regular basis. It is the responsibility of the Sustainability Leader to routinely review the Irish/European Legislation for notices affecting the company or its products and to disseminate the information to site management who, in turn, have the responsibility to communicate the changes or new requirements to others throughout the respective departments. This enables us to bring changing requirements to the attention of the individuals who will implement specific changes. Each EMT member represents his or her functional area and conveys information to/from that area. The team should pay particular attention to new developments or processes in the plant. Their input should be at the early stages of the relevant projects so that environmental issues are given due consideration during the design phase. Production and Plant Engineering should always be represented on the team, to ensure all future projects are brought forward for review. Aspects and Impacts should be written/ updated and the team may consider that (a) certain issue(s) should be reflected in the list of Significant Impact items for consideration when setting Environmental Management Programs Operations Manager and his staff 4 March 212

7 Licence Register No.P The Operations Manager has the responsibility and authority to ensure the following is carried out: The correct and efficient operation of production processes and machines in accordance with environmental requirements arising particularly from Objectives and Targets; The provision, implementation and revision of environmental procedures, documentation and records relating to the departments activities; Compliance to environmental procedures; Identification of training needs and implementation of training programmes in liaison with EMT and the Training Co-Coordinator. It is the responsibility of staff working in all production areas to comply with environmental procedures and to show environmental awareness where no procedures exist. Staff should pay attention to any aspects of their tasks that have or are likely to have an impact upon the environment and report observations to their supervisors. Staff shall attend environmental training as per training programmes Manager Human Resources and his staff Manager Human Resources and his staff shall support personnel to perform in accordance to the Environmental Policy by planning and providing training to all employees and specific training to employees in environmentally significant positions. HR staff shall attend environmental awareness training as per training programmes Financial Controller, Manager Q.A/RA., Supply Chain Manager and their staff The Financial Controller, Country QA/RA Manager, Supply Chain Manager and their staff shall support the EMS by making available information required to maintain the EMS. Staff shall attend environmental training as per training programmes IT Structure and support for the SEPro Database Level 1 support is provided by BD Service Desk Level 2 support is provided by Local IT Team and SE-Pro Coordinator: Maintain the Lotus servers and networks. Install Lotus on networked PC's. Install SE-Pro on local PC's Review Access Control List Create and assign access to documents in the system Level 3 support is provided globally by the Corporate Environmental Manager: Maintains database development and design Maintains Access Control List (ACL) for the database (if allowed) Responsibilities arising from SE-Pro maintenance Environmental requirements of the EMS have been defined and broken out into action items. These action items are stored in the SE-Pro system. Each action item has a primary 5 March 212

8 Licence Register No.P responsible person assigned who has the authority and responsibility for implementing the action items. The progress and completion of the task are documented in SE-Pro. Procedures pertaining to the EMS are maintained in the SE-Pro computerised system and hard copies may be printed as required. Environmental procedures are reviewed and updated by the responsible editor of a document as specified in the document s calendar. 2. Summary Information 2.1 Self-Monitoring Data Summary information is provided for the period January to December 211 inclusive, as specified in the EPA s Guidance Note for the Annual Environmental Report, unless otherwise stated. This information is presented in accordance with the Guidance Note as an annualised mass emission figure, derived from the average measured mass emission value multiplied by the duration of the emission. The plant was operational for a total of days during the 211 calendar year Summary of Emissions to Atmosphere IPPC Licence, Register No. P648-1 as amended by Amendment A sets out Emission Limit Values (ELVs) in Schedule 1(i) for emission points to atmosphere: Vacuum Pump Exhaust, A2-1 VOC Abatement Plant, A2-2 Becton Dickinson s licence requires monitoring of emissions to atmosphere to be carried out biannually. However, Becton Dickinson carries out monitoring of emissions to atmosphere on a quarterly basis to assist in the calculation of average emission values. Table 1 summarises the mass emissions to atmosphere from Emission Point A2-1 during 211. Table 1: Summary of Licensed Emissions to Atmosphere from emission point A2-1 Parameter Mass Emission 27 (kg) TOC (as carbon) Mass Emission 28 (kg) Mass Emission 29 (kg) Mass Emission 21 (kg) Mass Emission 211 (kg) ELV Mass Emission (kg) 1, ,572 Table 2 summarises the mass emissions to atmosphere from Emission Point A2-2 during 211. Table 2: Summary of Licensed Emissions to Atmosphere from emission point A2-2 Parameter Mass Emission 27 (kg) TOC (as carbon) Mass Emission 28 (kg) Mass Emission 29 (kg) Mass Emission 21 (kg) Mass Emission 211 (kg) ELV Mass Emission (kg) n/a ,715 6 March 212

9 Licence Register No.P Figure 2 trends the mass emission rate of TOC to atmosphere from Emission Point A2-1 after the ELV changed to 75 mg/m 3 from October 27. A2-1 Total Organics (as carbon) (from 3 th October 27) kg/hr.1.5. Nov-7 Jun-8 Figure 2: Mass Emissions to Atmosphere from Emission Point A2-1after October 27 Figure 3 trends the mass emission rate of TOC to atmosphere from Emission Point A2-2. A2-2 Total Organics (as carbon) (from 3 th October 27) kg/hr Nov-7 Jun-8 Figure 3: Mass Emissions to Atmosphere from Emission Point A2-2after October 27 7 March 212

10 Licence Register No.P Summary of Emissions to Sewer Amendment B to the IPPC licence sets out Emission Limit Values (ELVs) in Schedule 2(i) Emissions to Sewer for emission point SE-1. The amendment came into place on 28 February 211 to increase the ELVs to sewer. The ELV Daily Mean Concentration and Annual Load have been updated compared to previous year s ELVs. Table 3 summarises the monitoring results for 211. Table 3: Summary of Licensed Discharges to Sewer Parameter Conc. (mg/l) Average 29 Annual Load (kg) Conc. (mg/l) Average 21 Annual Load (kg) Conc. (mg/l) Average 211 Annual Load (kg) ph Daily Mean Conc. (mg/l) 6-1 ph units ELV Annual Load (kg) BOD 356 3, , , ,1 COD 61 6, , ,33 1,4 2,2 Suspended Solids Sulphates (as SO 4 ) Detergents (as MBAS) Fats, Oils and Greases 251 2, , , , , 14, , ,428 Phosphates ,428 TOC , ,22 4 5,715 - There were no non-compliances from the composite samples taken as per Schedule 2(iii) Monitoring of Emissions to Sewer which is carried out every two months for the parameters above. There was no non-compliance in the volume flow of 45 m 3 /day which is monitored every four months. 8 March 212

11 Licence Register No.P Figures 4 to 13 trend each of the licensed parameters emitted to sewer for the last 3 years. The current licence limits for each of the parameters are shown in red. Volume Emitted to Sewer in One Day (Flow) m Figure 4: Emissions to Sewer Flow Temperature Figure 5: Emissions to Sewer Temperature 9 March 212

12 Licence Register No.P ph ph units Figure 6: Emissions to Sewer ph BOD (Daily Mean Concentration) 1,4 1,2 1, mg/l Figure 7: Emissions to Sewer BOD 1 March 212

13 Licence Register No.P COD (Daily Mean Concentration) 1,8 1,6 1,4 1,2 mg/l 1, Figure 8: Emissions to Sewer COD Suspended Solids (Daily Mean Concentration) mg/l Figure 9: Emissions to Sewer Suspended Solids 11 March 212

14 Licence Register No.P Sulphates (as SO 4 ) (Daily Mean Concentration) 1,2 1, 8 mg/l Figure 1: Emissions to Sewer Sulphates (as SO 4 ) Detergents (Daily Mean Concentration) mg/l Figure 11: Emissions to Sewer Detergents 12 March 212

15 Licence Register No.P Fats, Oils & Grease (Daily Mean Concentration) mg/l Figure 12: Emissions to Sewer Fats, Oils & Grease Phosphates (as P) (Daily Mean Concentration) mg/l Figure 13: Emissions to Sewer Phosphates (as P) 13 March 212

16 Licence Register No.P Summary of Groundwater Monitoring The analyses of groundwater underlying the Becton Dickinson site for the 211 reporting period are presented in Tables 5 to 7. Biannual groundwater monitoring, undertaken by Fitz Scientific Services, was carried out on 2 March and again on 23 August 211. There are 13 groundwater wells on the site, designated BH1S, BH1D, BH2S, BH2D, BH3S, BH3D, BH5S, BH5D, BH7S, BH7D, BH8S, BH8D and BH1D. A site map showing these locations is included in Annex II. In March the wells BH8S and BH8D were temporarily blocked by a container and the boreholes were sampled on 2 April 211. In August the wells BH2D and BH1 were dry after purging and were sampled on 26 October 211. The groundwater is monitored in accordance with Condition 9.3 and Schedule 4(ii) of the IPPC licence. Figures 14 to 27 trend each of the groundwater monitoring parameters, as listed in the licence, for the last 3 years. The borehole locations have been grouped into shallow and deep boreholes for ease of identification on the graphs. The monitoring results have been compared against appropriate values from Irish legislation and guidance documents, including the Agency s Interim Guidance Values, as listed in Tables 5 to 7. Table 5 lists the results of the borehole monitoring undertaken in 211 which were above their comparison value. Table 5: Groundwater Monitoring Results above guidance Values Date Borehole No. Parameter Measured Value mg/l Comparison Value mg/l 2 Mar 11 2 Apr 11 BH2S BH3S BH3D BH5S BH5D BH7S BH7D BH8S BH8D DRO DRO DRO Conductivity Chloride DRO Mineral Oils Potassium Sodium Conductivity Chloride DRO Mineral Oils Calcium Potassium Sodium DRO Mineral Oils DRO Mineral Oils DRO Potassium DRO , , , , March 212

17 Licence Register No.P Date Borehole No. Parameter Measured Value mg/l Comparison Value mg/l 23 Aug 26 Oct BH1S BH1D BH2S BH3S BH3D BH5S BH5D BH7S BH8S BH8D BH1D DRO Mineral Oil DRO Mineral Oil DRO Mineral Oil DRO Mineral Oil DRO Mineral Oil DRO Mineral Oil Potassium Chloride DRO Mineral Oil Potassium Sodium DRO Mineral Oil DRO Mineral Oil Potassium DRO Chloride March 212

18 Becton Dickinson Licence Register No.P648-1 Annual Environmental Report for 211 Table 6: Summary of Groundwater Monitoring Results, March 211 Parameter Units Comparison BH1 BH2 BH3 BH5 BH7 BH8 BH1 Value S (1) D (2) S D S D S D S D S D D ph ph units (3) COD mg/l 4 (4) Conductivity µs/cm 8-1,875 (5) Chloride mg/l (5) Diesel Range Organics Petroleum Range Organics µg/l 1 (3) µg/l 1 (3) PAHs µg/l.1 (3) Mineral Oils µg/l 1 (3) BTEX µg/l 1 (3) Major Anions Nitrate mg/l 11.3 (5) Sulphate mg/l 2 (3) Major Cations Calcium mg/l 2 (3) Potassium mg/l 5 (3) Sodium mg/l 15 (3) March 212

19 Becton Dickinson Licence Register No.P648-1 Annual Environmental Report for 211 Table 7: Summary of Groundwater Monitoring Results, August 211 Parameter Units Comparison BH1 BH2 BH3 BH5 BH7 BH8 BH1 Value S (1) D (2) S D S D S D S D S D D ph ph units (3) COD mg/l 4 (4) Conductivity µs/cm 8-1,875 (5) ,74 1, ,177 Chloride mg/l (5) Diesel Range Organics Petroleum Range Organics µg/l 1 (3) µg/l 1 (3) PAHs µg/l.1 (3) Mineral Oils µg/l 1 (3) BTEX µg/l 1 (3) Major Anions Nitrate mg/l 11.3 (5) Sulphate mg/l 2 (3) Major Cations Calcium mg/l 2 (3) Potassium mg/l 5 (3) Sodium mg/l 15 (3) March 212

20 Becton Dickinson Licence Register No.P648-1 Annual Environmental Report for 211 Notes for Tables 6 and 7: (1) (2) (3) (4) (5) S shallow borehole D deep borehole EPA Interim Guideline Values (IGVs) for Groundwater from the interim report Towards Setting Guideline Values for the Protection of Groundwater in Ireland Surface Water Quality Standards from SI 294 of 1989, the European Communities (Quality of Surface Water Intended for the Abstraction of Drinking Water) Regulations, 1989 Groundwater Quality Standards and Groundwater Threshold Values from SI 9 of 21, the European Communities Environmental Objectives (Groundwater) Regulations, March 212

21 Licence Register No.P648-1 ph 8 ph units BH1 (S) BH2 (S) BH3 (S) BH5 (S) BH7 (S) BH8 (S) 6.8 Figure 14(a): Groundwater Monitoring ph (shallow boreholes) ph 8 ph units BH1 (D) BH2 (D) BH3 (D) BH5 (D) BH7 (D) BH1 (D) 7 Figure 14(b): Groundwater Monitoring ph (deep boreholes) 19 March 212

22 Licence Register No.P648-1 COD 6 mg/l BH1 (S) BH2 (S) BH3 (S) BH5 (S) BH7 (S) BH8 (S) Figure 15(a): Groundwater Monitoring COD (shallow boreholes) COD mg/l BH1 (D) BH2 (D) BH3 (D) BH5 (D) BH7 (D) BH8 (D) BH1 (D) Figure 15(b): Groundwater Monitoring COD (deep boreholes) 2 March 212

23 Licence Register No.P648-1 Conductivity 2,5 µs/cm at 2 C 2, 1,5 1, 5 BH1 (S) BH2 (S) BH3 (S) BH5 (S) BH7 (S) BH8 (S) Figure 16(a): Groundwater Monitoring Conductivity (shallow boreholes) Conductivity 3, µs/cm at 2 C 2,5 2, 1,5 1, 5 BH1 (D) BH2 (D) BH3 (D) BH5 (D) BH7 (D) BH8 (D) BH1 (D) Figure 16(b): Groundwater Monitoring Conductivity (deep boreholes) 21 March 212

24 Licence Register No.P648-1 Chloride 6 mg/l BH1 (S) BH2 (S) BH3 (S) BH5 (S) BH7 (S) BH8 (S) Figure 17(a): Groundwater Monitoring Chloride (shallow boreholes) Chloride mg/l BH1 (D) BH2 (D) BH3 (D) BH5 (D) BH7 (D) BH8 (D) BH1 (D) Figure 17(b): Groundwater Monitoring Chloride (deep boreholes) 22 March 212

25 Licence Register No.P648-1 Diesel Range Organics 35 3 µg/l BH1 (S) BH2 (S) BH3 (S) BH5 (S) BH7 (S) BH8 (S) Figure 18(a): Groundwater Monitoring Diesel Range Organics (shallow boreholes) Diesel Range Organics 8 µg/l BH1 (D) BH2 (D) BH3 (D) BH5 (D) BH7 (D) BH8 (D) BH1 (D) Figure 18(b): Groundwater Monitoring Diesel Range Organics (deep boreholes) 23 March 212

26 Licence Register No.P648-1 Petroleum Range Organics 12 µg/l BH1 (S) BH2 (S) BH3 (S) BH5 (S) BH7 (S) BH8 (S) Figure 19(a): Groundwater Monitoring Petroleum Range Organics (shallow boreholes) Petroleum Range Organics 6 µg/l BH1 (D) BH2 (D) BH3 (D) BH5 (D) BH7 (D) BH8 (D) BH1 (D) Figure 19(b): Groundwater Monitoring Petroleum Range Organics (deep boreholes) 24 March 212

27 Licence Register No.P648-1 Polycyclic Aromatic Hydrocarbons.12 µg/l BH1 (S) BH2 (S) BH3 (S) BH5 (S) BH7 (S) BH8 (S) Figure 2(a): Groundwater Monitoring Polycyclic Aromatic Hydrocarbons (shallow boreholes) Polycyclic Aromatic Hydrocarbons.12 µg/l BH1 (D) BH2 (D) BH3 (D) BH5 (D) BH7 (D) BH8 (D) BH1 (D) Figure 2(b): Groundwater Monitoring Polycyclic Aromatic Hydrocarbons (deep boreholes) 25 March 212

28 Licence Register No.P648-1 Mineral Oils 3 µg/l BH1 (S) BH2 (S) BH3 (S) BH5 (S) BH7 (S) BH8 (S) Figure 21(a): Groundwater Monitoring Mineral Oils (shallow boreholes) Mineral Oils 25 µg/l BH1 (D) BH2 (D) BH3 (D) BH5 (D) BH7 (D) BH8 (D) BH1 (D) Figure 21(b): Groundwater Monitoring Mineral Oils (deep boreholes) 26 March 212

29 Licence Register No.P648-1 BTEX µg/l BH1 (S) BH2 (S) BH3 (S) BH5 (S) BH7 (S) BH8 (S).5 Figure 22(a): Groundwater Monitoring BTEX (shallow boreholes) BTEX µg/l BH1 (D) BH2 (D) BH3 (D) BH5 (D) BH7 (D) BH8 (D) BH1 (D) Figure 22(b): Groundwater Monitoring BTEX Oils (deep boreholes) 27 March 212

30 Licence Register No.P648-1 Major Anions - Nitrate mg/l BH1 (S) BH2 (S) BH3 (S) BH5 (S) BH7 (S) BH8 (S).2 Figure 23(a): Groundwater Monitoring Nitrate (shallow boreholes) Major Anions - Nitrate 1.2 mg/l BH1 (D) BH2 (D) BH3 (D) BH5 (D) BH7 (D) BH8 (D) BH1 (D) Figure 23(b): Groundwater Monitoring Nitrate (deep boreholes) 28 March 212

31 Licence Register No.P648-1 Major Anions - Sulphate 12 mg/l BH1 (S) BH2 (S) BH3 (S) BH5 (S) BH7 (S) BH8 (S) Figure 24(a): Groundwater Monitoring Sulphate (shallow boreholes) Major Anions - Sulphate mg/l BH1 (D) BH2 (D) BH3 (D) BH5 (D) BH7 (D) BH8 (D) BH1 (D) Figure 24(b): Groundwater Monitoring Sulphate (deep boreholes) 29 March 212

32 Licence Register No.P648-1 Major Cations - Calcium 2 18 mg/l BH1 (S) BH2 (S) BH3 (S) BH5 (S) BH7 (S) BH8 (S) 2 Figure 25(a): Groundwater Monitoring Calcium (shallow boreholes) Major Cations - Calcium 3 mg/l BH1 (D) BH2 (D) BH3 (D) BH5 (D) BH7 (D) BH8 (D) BH1 (D) Figure 25(b): Groundwater Monitoring Calcium (deep boreholes) 3 March 212

33 Licence Register No.P648-1 Major Cations - Potassium 9 8 mg/l BH1 (S) BH2 (S) BH3 (S) BH5 (S) BH7 (S) BH8 (S) 1 Figure 26(a): Groundwater Monitoring Potassium (shallow boreholes) Major Cations - Potassium mg/l BH1 (D) BH2 (D) BH3 (D) BH5 (D) BH7 (D) BH8 (D) BH1 (D) Figure 26(b): Groundwater Monitoring Potassium (deep boreholes) 31 March 212

34 Licence Register No.P648-1 Major Cations - Sodium 25 mg/l BH1 (S) BH2 (S) BH3 (S) BH5 (S) BH7 (S) BH8 (S) Figure 27(a): Groundwater Monitoring Sodium (shallow boreholes) Major Cations - Sodium 3 mg/l BH1 (D) BH2 (D) BH3 (D) BH5 (D) BH7 (D) BH8 (D) BH1 (D) Figure 27(b): Groundwater Monitoring Sodium (deep boreholes) 32 March 212

35 Licence Register No.P Summary of Surface Water Discharge Monitoring The licence sets out in Schedule 4(i) two parameters that are used to monitor surface water discharges at monitoring point SW1: ph and COD. Monitoring of surface water discharges is carried out on a quarterly basis. A summary of the measured discharges at emission point SW1 is presented in Table 8. Table 8: Summary of Surface Water Discharge Monitoring Parameter Units Average Value 29 Average Value 21 Average Value 211 ph ph units COD mg/l Note 1): Quarter 4 monitoring of 28 was carried out early in January 29. Three additional monitoring locations were identified as part of the Hydrogeological Survey undertaken in compliance with Condition of the licence. The survey recommended that monitoring be carried out at these additional locations in order to assess the impact, if any, of Becton Dickinson s operations on the local surface water. These monitoring locations were agreed with the Agency in May 25. They are located upstream of SW1, downstream of SW1 and at an intermediate location upstream from the outfall. Monitoring was carried out at these locations on a quarterly basis during 211. The averaged results are presented in Table 9. Table 9: Summary of Additional Surface Water Discharge Monitoring, 211 Parameter Units Averaged Measured Value Upstream of SW1 Averaged Measured Value at Intermediate Location Averaged Measured Value Downstream of SW1 ph ph units COD mg/l March 212

36 Licence Register No.P648-1 Figures 28 and 29 trend the surface water monitoring parameters, as listed in the licence, for the last three years. ph ph units SW1 Upstream Intermediate Downstream. Figure 28: Surface Water Monitoring ph COD 25 mg/l SW1 Upstream Intermediate Downstream Figure 29: Surface Water Monitoring COD 34 March 212

37 Licence Register No.P Summary of Noise Monitoring Condition 8 of the licence limits the noise level at noise sensitive locations to a sound pressure level (L eq ) of 55 db(a) during the daytime and 45 db(a) during the night-time. In compliance with Condition 8 of the licence, Becton Dickinson commissioned Decibel Noise Control to carry out the annual noise monitoring survey. Daytime and night-time measurements were conducted on specified dates in September 211. The locations used for the noise monitoring survey are shown on the site diagram attached in Annex III. Of the six locations selected for noise measurement, locations (2), (3) and (6) may be regarded as noise sensitive, as they are adjacent to dwellings. The remaining locations, (1), (4) and (5), may be taken as site boundary positions. The results of the annual noise monitoring survey are given in Table 1. Table 1: Summary of Noise Monitoring Location Date Time L Aeq L AF9 L AF1 Tonal Impulsive Remarks 2 Sep 11 1: No No Pottery Road traffic. 2 Sep 11 22: No No Pottery Road traffic. 2 Sep 11 Pottery Road & site 13: No No traffic. 2 Sep 11 23: No No Pottery Road traffic. 2 Sep 11 1: No No Truck movements. 2 Sep 11 Distant road traffic & 23: No No wind in trees. 2 Sep 11 Truck loading 12: No No & site traffic. 21 Sep 11 Wind in trees, plant : No No noise audible. 2 Sep 11 Trim waste fan & fork 11: No No truck movement. 21 Sep 11 : No No Trim waste fan. 2 Sep 11 Children s football 14: No No match. 2 Sep 11 Distant road traffic, 22: No No plant noise audible. 35 March 212

38 Licence Register No.P648-1 Table 11 summarised the non-compliances observed during the 211 noise survey. Table 11: Summary of Non-Compliances Date Non- Compliance Cause Corrective Action 2 Sep 11 Night time measurement is The noise level was The source of the noise is Location 3 51 db vs. limit of 45 db attributed to the wind noise outside BD s control. 2 Sep 11 Location 6 Night time measurement is 48 db vs. limit of 45 db through adjacent trees. Night noise resulting from distant road traffic and plant noise audible. The contribution from road traffic is outside BD s control Waste Management Summary In compliance with condition 7 of the IPPC licence, a waste record is maintained at Becton Dickinson for hazardous and non-hazardous waste. The following details are recorded in the waste record: (a) The tonnages and EWC Code for the waste materials listed in Schedule 3(i) Hazardous Wastes for Disposal/Recovery and Schedule 3(ii) Other Wastes for Disposal/Recovery, sent off-site for disposal/recovery. (b) The names of the agent and carrier of the waste, and their permit details (to include issuing authority). (c) Details of the ultimate disposal/recovery destination facility for the waste and its appropriateness to accept the consigned waste stream, to include its permit details and issuing authority. (d) Written confirmation of the acceptance and disposal/recovery of any hazardous waste consignments sent off-site. (e) Details of all wastes consigned abroad for Recovery and classified as Green in accordance with the EU Transfrontier Shipment of Waste Regulations (Council Regulation EEC No. 259/1993, as amended). The rationale for the classification must form part of the record. (f) Details of any rejected consignments. (g) Details of any approved waste mixing as per Condition 7.6. (h) The tonnages and EWC Code for the waste materials listed in Schedule 3(i) Hazardous Wastes for Disposal/Recovery and Schedule 3(ii) Other Wastes for Disposal/Recovery, recovered on-site. Table 12 overleaf presents a summary of the annual waste arising for the 21 reporting period. 36 March 212

39 Licence Register No. P648-1 Table 12: Summary of Annual Waste Arising for 211 European Waste Catalogue Code Hazardous (Yes/No) Description of Waste Quantity (t/year) Disposal/ Recovery Code Location of Disposal/ Recovery 5 1 5* Yes Oil contaminated water from excavation 3.78 D9 Rilta Environmental, Co. Dublin * Yes Degreasing waste.1 R2 Safety Kleen, Tallaght, (kerosene) Dublin * Yes Waste hydraulic oil 1.75 R9 ENVA Ireland, Co. Laois * Yes Interceptor Waste 6.3 D9 Rilta Environmental, Co. Dublin * Yes Recovered HFE Waste R2 Mullingar Business Park, County Westmeath * Yes Empty drums 1.76 R4 Rilta Environmental, Co. Dublin * Yes Empty drums 1.8 D1 ATM Moerdijk BV, Netherlands * Yes Solid & oily waste.65 R1 Lindenschmidt, Germany * Yes Demolition waste 2.78 D15 Buhck GmbH & Co, containing asbestos Germany * Yes Customer complaints.111 D1 SRCL Kylemore, Dublin * Yes Fluorescent tubes.48 R4/R5 Irish Lamp Recycling Company * Yes WEEE.677 R4 Irish Lamp Recycling Company Name of Waste Disposal Recovery Contractor Horizon Environmental W192-3 Safety Kleen W99-1 ENVA Ireland W184-1 Horizon W192-3 Soltec (Ireland) Limited W115-1 Rilta Environmental W192-3 Rilta Environmental ENVA Ireland Licence / Permit Reference for Treatment Facility and 9U1775 E Oxigen Environmental eg19 Ltd. Ecosafe System Limited W54-2 Irish Lamp Recycling Company Irish Lamp Recycling Company COR-KE COR-KE March 212

40 Licence Register No. P648-1 Table 12: Summary of Annual Waste Arising for 211 (Cont/d) EWC Code Hazardous (Yes/No) Description of Waste Quantity (t/year) Disposal/ Recovery Code Location of Disposal/ Recovery No Paper and cardboard R3 Fassaroe, Bray, Co. Wicklow No Soft plastic 14.6 R Fassaroe, Bray, Co. Wicklow No Timber pallets R3 Shannon Street, Mountrath, Co. Laois No Mixed Packaging R3 Fassaroe, Bray, Co. Wicklow No Off-spec R3 Thorndale components and Environmental granulated waste No Office Paper R3 National Document Management Group T/A Shredit, 5 Parkwest Ind Est, Dublin No Compost R3 Fassaroe, Bray, Co. Wicklow No Metal 3.84 R4 National Waste Management, Tallaght, Dublin No Off-spec. products and general waste No Packaged product and composite paper D1 Ballynagran, Coolbeg and Kilcandra, Co. Wicklow D1 Ballynagran, Coolbeg and Kilcandra, Co. Wicklow. Name of Waste Disposal Recovery Contractor Licence / Permit Reference for Treatment Facility Greenstar W53-3 Greenstar W53-3 C.J. Sheeran W337-1 Greenstar W53-2 Thorndale Environmental WDL 14 Shredit WFP-DC Greenstar W53-3 Guinan Haulage W79-1 Greenstar W165-2 Greenstar W March 212

41 Licence Register No. P648-1 Table 13 lists the Waste Collection Permit numbers for each waste contractors collecting waste from Becton Dickinson in 21. Table 13: Waste Collection Permit Details Waste Collection Contractor Waste Collection Permit No. C. J. Sheeran WCP-DC Ecosafe System Limited WCP-DC ENVA Ireland WCP-DC Greenstar CP D 735/5 Guinan Haulage Ltd. WCP-OY Horizon WCP-DC Irish Lamp Recycling Company WCP-DC Oxigen Environmental Ltd. WCP-DC Rilta Environmental WCP-DC Safety Kleen WCP-DC Shredit WCP-DC Soltec (Ireland) Limited CP D 78/1 Thorndale Environmental WCP-LK March 212

42 Licence Register No. P Agency Monitoring and Enforcement Air Monitoring On 1 February 211 Fitz Scientific Monitoring and Testing Services carried out air monitoring on behalf of the EPA at emission points A2-1 and A2-2. The results of this monitoring exercise are listed in Table 14. Flow rate for A2-1 is exceeding the ELV. However, the calculated mass emission is compliant as the average concentration of TOC is well below the ELV. A request for technical amendment to accommodate the increase in the vacuum pump process flow was submitted to the agency in October 211 and Technical Amendment C was granted on 4 January 212. Table 14: Results of Agency Air Monitoring Emission Point Parameter Result ELV A2-1 TOC 35.3 mg/m 3 75 mg/m 3 A2-1 Volume Flow 2,92.34 m 3 /h 2,75 m 3 /h A2-1 Mass emission.14 kg/hr.26 kg/hr A2-2 TOC <.2 mg/m 3 75 mg/m 3 A2-2 Volume Flow m 3 /h 3, m 3 /h Surface Water Monitoring The Agency did not carry out surface water monitoring during Sewer Monitoring Grab samples were obtained from effluent sample point SE-1 by the Agency on 24 January 211 and 14 July 211. On 24 January COD and Suspended Solids exceeded the ELV as shown in Table 15. In July all results complied with the limits. Table 15: Results of Agency Sewer Monitoring Emission Point Parameter Result ELV SE-1 COD 1,82 mg/l 1,6 mg/l SE-1 Suspended Solids 1,16 mg/l 8 mg/l Site Inspection Report The Agency visited the site on 17 February 211 and carried out a Site Inspection. The Site Inspection Report issued on 18 March 211 stated that Becton Dickinson was in noncompliance with four conditions of the licence on the day of the inspection. The Agency also made 2 observations to improve environmental performance of the facility. Becton Dickinson responded to the report on 7 April 211, setting out the actions that Becton Dickinson will take to address the non-compliance issues and to improve environmental performance at the facility. 4 March 212

43 Licence Register No. P Energy & Water Consumption Energy Consumption Energy consumed by Becton Dickinson during 211 as electricity, natural gas and diesel oil is summarised in Table 16. All values have been converted into megawatt hours (MWh). Table 16: Summary of Energy Consumption Energy Source 28 Usage MWh 29 Usage MWh 21 Usage MWh 211 Usage MWh Electricity 19,596 19,381 19,183 19,917 Natural Gas 2,46 2,456 2,76 2,87 Diesel Oil Total 21,655 21,847 21,954 22, Water Consumption Water readings were obtained weekly from the site water meter during January to April and September to December. The remaining weeks are extrapolated and the annual consumption is estimated to be 18,828 m 3 for Trending of Resource Consumption Table 17 and Figures 3 and 31 trend resource consumption against production output. The reduction targets are tracked for the period 28 to 215. Table 17: Summary of Resource Consumption Million Units produced 2,361 2,879 2,899 3,211 Specific Energy Consumption (MWh per product output) Specific Water Consumption (m 3 per product output) March 212

44 Licence Register No. P648-1 Spec. Energy Consumption (MWh per production output) MWh per production output Figure 3: Specific Resource Consumption Energy Usage Specific Water Consumption (m3 per production output) 8 7 m 3 per production output Figure 31: Specific Resource Consumption Water Usage 42 March 212

45 Licence Register No. P Environmental Incidents & Complaints BD reported 4 environmental incidents to the EPA and received no complaints during 211. The report template as distributed through the document Annual Environmental Report: Standardised Reporting Guidance is attached in Annex V. 2.5 Summary of Abatement Plant Bypass Events One bypass events was recorded in 211 as summarised in Table 18. This event did not lead to significant release of solvent into the air. Table 18: Summary of Bypass Event Date Duration hr:min Cause 27 Nov 211 3:3 During a 2 hour power outage to the site the abatement plant failed. For the first two hours there was no extraction from the process. 3.5 hours passed from restart of the extraction to resetting of the abatement plant. Corrective Action System reset on control panels in Plant office and on abatement plant after start of business on Monday morning. The Facilities Leader and technician were advised about the location and process to reset the equipment in both locations, Plant office and on abatement. Figure 32 graphically represents the TOC mass emissions and ground level concentration of all by-pass events since introduction of the equipment. Abatement Plant By-pass Events /6/29 1/6/29 18/6/29 19/6/29 25/1/21 2/2/21 27/11/211 Date TOC mass emission kg/h ground level mg/m3 Figure 32: TOC Emissions during Abatement Plant By-pass Events 43 March 212

46 Licence Register No. P Management of the Activity 3.1 Schedule of Environmental Objectives & Targets Our Environmental Objectives and Targets for the period from are set out in Table 19. Table 19: Schedule of Environmental Objectives & Targets Top-tier Environmental Objective Waste Reduction Measures Energy Reduction Opportunities Control of Solvent emissions Noise Reduction Water use reductions Efficient use of raw materials Environmental Targets 1) Recycle cartonette waste from packaging area 2) Recycle high grade soft plastic 3) Reduce the amount of hazardous waste generated by 1%, from 28 levels 4) Reduce waste going off site for disposal (landfill / incineration) by 15%, from 28 levels 5) Capture recyclables from all areas of the plant 1) Reduce Compressed Air Consumption 2) Reduce specific energy consumption from operations 3% by 215, from 28 levels 3) Increase renewable energy use in BD s portfolio to 25% by 215, from 28 levels 1) Continue to improve solvent usage efficiency and monitoring of line solvent usage versus lubricant waste, regenerated solvent and process emissions 2) Improve solvent mass balance by accounting for emissions to air from A2-1 and outputs to waste, including solid solvent waste 3) Reduce solvent use by improved cleaning and maintenance systems 1) Control noise emissions from site equipment along all site boundaries 1) Reduce the specific water consumption by 15%, from 28 levels 2) Divert surface water away from sewer drainage system 1) Develop metric assessment for efficient use of raw materials 44 March 212

47 Licence Register No. P Environmental Management Programme (EMP) Report Annex III contains the EMP reports for the objectives and targets of projects continuing until 215. The report uses the EMP summary template as distributed through the document Annual Environmental Report: Standardised Reporting Guidance. The targets that were achieved in 211 and are given a status of 1% are: Recycle high grade soft plastic Increase renewable energy use in BD s portfolio to 25% by 215, from 28 levels Continue to improve solvent usage efficiency and monitoring of line solvent usage versus lubricant waste, regenerated solvent and process emissions Review effectiveness of noise control measures at noise sensitive locations. All objectives and targets that achieved a status less than 1% are ongoing. 3.3 Pollution Emission Register Report for 211 Table 2 lists the emissions reported to the Agency in the AER/ PRTR in accordance with the European Communities (European Pollutant Release and Transfer Register) Regulation 27, S.I. No. 123 of 27 and S.I. 649 of 211, which signed into Irish Law on 13 December 211, the E-PRTR Regulation (EC) No 166/26, concerning the establishment of a European Pollutant Release and Transfer Register. The reported emissions and waste transfers are included in Annex I and were submitted to the Agency electronically. Table 2: Emissions Reported in the AER/ PRTR Electronic Reporting Workbook for 211 Emission Release Medium Type of Emission / Potential Emission Total Organics (as C) Air Routine (process) Carbon Dioxide Air Routine (combustion) Non-methane VOCs Air Routine (process) BOD Water (Sewer) Routine (process) COD Water (Sewer) Routine (process) Suspended Solids Water (Sewer) Routine (process) Sulphates (as SO 4 ) Water (Sewer) Routine (process) Detergents (as MBAS) Water (Sewer) Routine (process) Oils, Fats and Greases Water (Sewer) Routine (process) Phosphates (as P) Water (Sewer) Routine (process) Total Organic Compounds (as C) Water (Sewer) Routine (process) 3.4 Pollutant Emission Register Proposal for 212 BD do not envisage any significant change in the operations. Therefore BD propose to report on the same emissions in 212 as shown for the current year in Table 2 above. 45 March 212

48 Licence Register No. P Solvent Usage Table 21 lists the solvents used at the site during 211. Table 21: Solvent Usage (211) Material Annual Usage (kg) 28 Annual Usage (kg) 29 Annual Usage (kg) 21 Annual Usage (kg) ,2 transdichloroethylene 21,6 15,3 12,825 12,6 2 Methyl nonafluoroisobutyl ether 12,48 8,84 7,41 7,28 3 Methyl nonafluorobutyl ether 12,48 8,84 7,41 7,28 4 Ethyl alcohol 1,44 1, Ethylacetate Isopropanol Fugitive Emissions Assessment Report History of Solvent Use Up until 1987 a CFC material was used as solvent in the lubrication of needles. It was then replaced with a HCFC material of a lower ozone depleting potential. This in turn was replaced with HFE in 25. Compared to the HCFC solvent the HFE has an ozone depleting potential of zero. The introduction of HFE material came despite the increased cost that BD incurred to achieve compliance with the Regulation on Substances that Deplete the Ozone Layer for sites. Successive environmental management programmes were in place to increase the efficiency of solvent use and to reduce waste levels in production. The efficiency of solvent usage has increased due to control measures on the production lines, inventory control and increased production since 23 when consumption was at a peak. The combined effect of these measures is shown in Figure 33 as solvent per product made along with the actual consumption of solvent. As shown in the graph for FY 5 the conversion from solvent based silicone to pure silicone on the NP end reduced consumption by half. Figure 33 represents the reduction of solvent usage in the last 12 years for the financial years dating from 1 Oct to 31 Sep. 46 March 212

49 Licence Register No. P648-1 Solvent use absolute and relative to product units FY98 FY99 FY FY1 FY2 FY3 FY4 FY5 FY6 FY7 FY8 FY9 FY1 FY11 Financial Year Solvent tonnes Solvent per Product Figure 33: Solvent usage in Dun Laoghaire from FY98 to FY Application of Best Available Techniques In January 212 BD submitted a document entitled BAT Assessment for Use of Organic Solvent at BD Dun Laoghaire where activities on site were assessed against four pieces of regulations and guidance documents applicable to the solvent sector. The site achieves a high level of BAT compliance due to number of technical and organisational measures. Gaps identified from the assessment were considered when setting the environmental management programmes as per above schedule. 47 March 212

50 Licence Register No. P Solvent Management Plan The fugitive emissions status is determined using the methodology described as Solvent Management Plan in Annex III of Council Directive 1999/13/EC. The solvent mass balance is summarised in Table 22. All units in tonnes Consumption HFE Isopropanol Ethylacetate Sub Total Emission A Emission A2-2 Recovery Waste Known Loss 4% 1 Total HFE Emissions Fugitive HFE Isopropanol Ethylacetate Sub Total Fugitive % 8% 56% 44% 36% 25% Table 22: Solvent Mass Balance 3.7 Report on ELRA & CRAMP The site s Closure Restoration & Aftercare Management Plan was revised in February 212 to take into account a number of non-significant detections of soil contamination during the site groundwork and inclusion of 211 monitoring results of groundwater sampling were also updated. The known risk of groundwater contamination continues to be managed by groundwater monitoring as per Schedule 4(ii) of the licence. As there were no changes in the Risk Category of the site the closure plan and financial provisions remain adequate. 3.8 Separation of Combined Drainage The site has provided funds to investigate the separation of drainage in the yard to the rear of the site with the aim to divert surface water away from the sewer. Project approval is expected in early March 212

51 Licence Register No. P Licence-Specific Reports In accordance with the conditions of the licence, Schedule 5(i) in particular, the following items were completed to report on between January and December 211: Table 23: Licence Specific Reports Report Licence Status Condition Emissions to atmosphere summary A summary report on emissions to atmosphere is included in this AER. See Section Emissions to sewer summary A summary report on emissions to sewer is included in this AER. See Section Waste Management report 7.8 A summary of reports compiled during 211 is included in Section Resource consumption summary n/a A summary report on consumption of energy and water is included in Section 2.3. Complaints summary 12.3 See Section 2.4. Schedule of Environmental 2.2 See Section 3.2. Objectives & Targets Environmental Management 2.3 Refer to Annex III Programme Summary Report Pollution Emission Register - proposal 2.4 Emissions as per 211 PRTR are proposed for 212. See Section 3.6. Pollution Emission Register - report 2.4 Pollutant Release and Transfer Register was submitted with the AER for 211. See section 3.5. Fugitive Emissions to atmosphere report 5.8 The report on fugitive emissions for the 211 reporting period is in Section 3.8. Noise Monitoring Report 8.1 An annual survey was done in September 211. A summary of the report is contained in Section Surface water monitoring summary Summary report in Section Groundwater monitoring summary Summary report in Section Active underground tank and No such installations exist on site. pipeline testing and inspection report (every three years) Bund integrity report (every three A bund integrity report is attached in Annex VI. years) Reported Incidents 4.3 A report on incidents is included in Section 2.4. Environmental Liabilities Risk The CRAMP was revised in 211 as per Section 3.7 Assessment (Closure, Restoration and Aftercare Management Plan) Energy Audit 1.1 An energy efficiency audit was not required by the Agency during 211. Diversion of surface water emissions away from the sewer The site is investigating the diversion of surface water away from the sewer as per Section March 212

52 ANNEX I AER/ PRTR Electronic Reporting Workbook

53 PRTR# : P648 Facility Name : Becton Dickinson Insulin Syringe Limited (Irish Branch) & Becton Dickinson Penel Limited (Irish Branch) Filename : P648_211 PRTR.xls Return Year : 211 REFERENCE YEAR 211 Guidance to completing the PRTR workbook AER Returns Workbook Version FACILITY IDENTIFICATION Parent Company Name Becton Dickinson Insulin Syringe Limited (Irish Branch) & Becton Dickinson Penel Limited (Irish Branch) Facility Name Becton Dickinson Insulin Syringe Limited (Irish Branch) & Becton Dickinson Penel Limited (Irish Branch) PRTR Identification Number P648 Licence Number P648-1 Waste or IPPC Classes of Activity No. class_name ########################################################################################################################## Address 1 Becton & Dickinson Penel Limited Address 2 Pottery Road Address 3 Dun Laoghaire Address 4 County Dublin Dublin Country Ireland Coordinates of Location River Basin District IEEA NACE Code 212 Main Economic Activity Manufacture of pharmaceutical preparations AER Returns Contact Name Corinna Pfeifer AER Returns Contact Address Corinna_Pfeifer@europe.bd.com AER Returns Contact Position Environemental Officer AER Returns Contact Telephone Number AER Returns Contact Mobile Phone Number AER Returns Contact Fax Number Production Volume Production Volume Units billion Number of Installations 1 Number of Operating Hours in Year 318 Number of Employees 34 User Feedback/Comments Web Address 2. PRTR CLASS ACTIVITIES Activity Number Activity Name 5.1 General 3. SOLVENTS REGULATIONS (S.I. No. 543 of 22) Is it applicable? Yes Have you been granted an exemption? No If applicable which activity class applies (as per Schedule 2 of the regulations)? 8 Is the reduction scheme compliance route being used? No

54 4.1 RELEASES TO AIR Link to previous years emissions data PRTR# : P648 Facility Name : Becton Dickinson Insulin Syringe Limited (Irish Branch) & Becton Dickinson Penel Limited (Irish Branch) Filename : P648_211 PRTR.xls Ret 26/3/212 9: SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS RELEASES TO AIR Please enter all quantities in this section in KGs 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 PRTR POLLUTANTS RELEASES TO AIR Please enter all quantities in this section in KGs POLLUTANT METHOD QUANTITY Method Used A2-1 A2-2 Boiler stack No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 Emission Point 2 Emission Point 3 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year Mass balance derived from usage figures and third 7 Non-methane volatile organic compounds (NMVOC) C MAB party FID monitoring Carbon dioxide (CO2) C OTH CO2 emission factor for natural gas * 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 AIR Please enter all quantities in this section in KGs POLLUTANT METHOD QUANTITY Method Used A2-1 A2-2 Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 Emission Point 2 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year 351 Total Organic Carbon (as C) M ALT EN Additional Data Requested from Landfill operators * Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button For the purposes of the National Inventory on Greenhouse Gases, landfill operators are requested to provide summary data on landfill gas (Methane) flared or utilised on their facilities to accompany the figures for total methane generated. Operators should only report their Net methane (CH4) emission to the environment under T(total) KG/yr for Section A: Sector specific PRTR pollutants above. Please complete the table below: Landfill: Please enter summary data on the quantities of methane flared and / or utilised Becton Dickinson Insulin Syringe Limited (Irish Branch) & Becton Dickinson Penel Limited (Irish Branch) Method Used Designation or Description Facility Total Capacity m3 per hour additional_pollutant_no T (Total) kg/year M/C/E Method Code Total estimated methane generation (as per site model). N/A Methane flared.. (Total Flaring Capacity) Methane utilised in engine/s.. (Total Utilising Capacity) Net methane emission (as reported in Section A above). N/A

55 4.3 RELEASES TO WASTEWATER OR SEWER Link to previous years emissions data PRTR# : P648 Facility Name : Becton Dickinson Insulin Syringe Limited (Irish Branch) & Becton D 26/3/212 9: SECTION A : PRTR POLLUTANTS OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER Please enter all quantities in this section in KGs 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 Please enter all quantities in this section in KGs POLLUTANT METHOD QUANTITY Method Used SE-1 Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year F (Fugitive) KG/Year Standard Laboratory 33 BOD M OTH Method COD M OTH Standard Laboratory Method Suspended Solids M OTH Standard Laboratory Method Sulphate M OTH Standard Laboratory Method Detergents (as MBAS) M OTH Standard Laboratory Method Fats, Oils and Greases M OTH Standard Laboratory Method Ortho-phosphate (as P) M OTH Standard Laboratory Method Total Organic Carbon (as C) M OTH Standard Laboratory Method

56 T /Year Description and Licence / Per mit No.of Recoverer / Disposer / Br oker Addr ess of Recoverer / Disposer / Broker Name and Addr ess of Final Destination i.e. Final Recover y / Disposal Site ( HAZ ARDOUS WASTE ONLY) Licence / Per mit No. of Final Destination i.e. Final Recover y / Disposal Site ( HAZ ARDOUS WASTE ONLY) 5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE PRTR# : P648 Facility Name : Becton Dickinson Insulin Syringe Limited (Irish Branch) & Becton Dickinson Penel Limited (Irish Branch) Filename : P648_211 PRTR.xls Return Year : /3/212 9: Please enter all quantities on this sheet in Tonnes 13 Transfer Destination European Waste Code Hazardous Quantity Quantity (Tonnes per Year) of Waste Method Used Waste Treatment Operation M/C/E Method Used Location of Treatment Name Within the Country Yes 3.78 oil spills D9 M Weighed Offsite in Ireland Haz Waste : Name and Licence/Permit No of Next Destination Facility Non Haz Waste: Name and Licence/Permit No of Recover/Disposer Rilta Environmental,W192-3 degreasing wastes containing dangerous Within the Country Yes.1 substances R2 M Volume Calculation Offsite in Ireland Safety Kleen,W99-1 Within the Country Yes 1.75 other hydraulic oils R9 M Volume Calculation Offsite in Ireland ENVA Ireland,W184-1 Haz Waste : Address of Next Destination Facility Non Haz Waste: Address of Recover/Disposer Rilta Environmental,Block 42B Greenogue Bus Park,Rathcoole,Co Dublin,Ireland Airton Road,Unit 5,Tallaght,Dublin 24,Ireland Clonminam Industrial Estate,.,Portlaoise,Co. Laois,Ireland Name and License / Permit No. and Address of Final Recoverer / Disposer (HAZARDOUS WASTE ONLY) Actual Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY) Rilta Environmental,W192-3,Rilta Environmental,Block Rilta Environmental,Block 42B Greenogue Bus 42B Greenogue Bus Park,Rathcoole,Co Park,Rathcoole,Co Dublin,Ireland Dublin,Ireland Safety Kleen,W99-1,Airton Road,Unit 5,Tallaght,Dublin 24,Ireland ENVA Ireland,W184-1,Clonminam Industrial Estate,.,Portlaoise,Co. Laois,Ireland Airton Road,Unit 5,Tallaght,Dublin 24,Ireland Clonminam Industrial Estate,.,Portlaoise,Co. Laois,Ireland Within the Country Yes 6.3 interceptor sludges D9 M Volume Calculation Offsite in Ireland other halogenated solvents and solvent Within the Country Yes mixtures R2 M Volume Calculation Offsite in Ireland packaging containing residues of or Within the Country Yes 1.76 contaminated by dangerous substances R4 M Weighed Offsite in Ireland To Other Countries Yes packaging containing residues of or 1.8 contaminated by dangerous substances D1 M Weighed Abroad absorbents, filter materials (including oil filters not otherwise specified), wiping cloths, protective clothing contaminated by To Other Countries Yes.65 Rilta Environmental,W192-3 Soltec (Ireland) Limited,W115-1 Rilta Environmental,W192-3 Rilta Environmental,W192-3 dangerous substances R1 M Weighed Abroad ENVA Ireland,W184-1 construction materials containing asbestos To Other Countries Yes 2.78 (18) D15 M Weighed Abroad Oxigen Environmental,W28-1 Rilta Environmental,Block 42B Greenogue Bus Park,Rathcoole,Co Dublin,Ireland Mullingar Business Park,Zone A,Mullingar,Co. Westmeath,Ireland Rilta Environmental,Block 42B Greenogue Bus Park,Rathcoole,Co Dublin,Ireland Rilta Environmental,Block 42B Greenogue Bus Park,Rathcoole,Co Dublin,Ireland Clonminam Industrial Estate,.,Portlaoise,Co. Laois,Ireland Ballymount Industrial Estate,Ballymount Road Lower,Clondalkin,Dublin 22,Ireland Rilta Environmental,W192-3,Rilta Environmental,Block Rilta Environmental,Block 42B Greenogue Bus 42B Greenogue Bus Park,Rathcoole,Co Park,Rathcoole,Co Dublin,Ireland Dublin,Ireland Soltec (Ireland) Limited,W115-1,Mullingar Business Park,Zone A,Mullingar,Co. Westmeath,Ireland Mullingar Business Park,Zone A,Mullingar,Co. Westmeath,Ireland Rilta Environmental,W192-3,Rilta Environmental,Block Rilta Environmental,Block 42B Greenogue Bus 42B Greenogue Bus Park,Rathcoole,Co Park,Rathcoole,Co Dublin,Ireland Dublin,Ireland ATM Moerdijk BV, and 9U1775,Vlasweg 12,.,Moerdijk,NL-4782 PW,Netherlands Vlasweg 12,.,Moerdijk,NL PW,Netherlands Lindenschmidt, ,Kr ombacher Strasse 42- Krombacher Strasse 42-46,.,Kreuztal,57223,Germany 46,.,Kreuztal,57223,Germany Buhck GmbH & Co,eg19,Suedring 38,.,Wentorf,21465,Germany Suedring 38,.,Wentorf,21465,Germany wastes whose collection and disposal is subject to special requirements in order to Within the Country Yes.111 prevent infection D1 M Weighed Offsite in Ireland Within the Country Yes fluorescent tubes and other mercurycontaining waste.48 R4 M Weighed Offsite in Ireland discarded electrical and electronic equipment other than those mentioned in and and containing Within the Country Yes.677 hazardous components R4 M Weighed Offsite in Ireland Ecosafe System Limited,W54-2 Irish Lamp Recycling,COR- KE Irish Lamp Recycling,COR- KE Kylemore Road,Unit 1A Allied Industrial Estate,Ballyfermot,Dublin 1,Ireland Woodstock Industrial Estate,.,Athy,Co. Kildare,Ireland Woodstock Industrial Estate,.,Athy,Co. Kildare,Ireland Ecosafe Systems Limited,W54-2,Kylemore Road,Unit 1A Allied Industrial Estate,Ballyfermot,Dubin 1,Ireland Irish Lamp Recycling,COR- KE-8-4-1,Woodstock Industrial Estate,.,Athy,Co. Kildare,Ireland Irish Lamp Recycling,COR- KE-8-4-1,Woodstock Industrial Estate,.,Athy,Co. Kildare,Ireland Kylemore Road,Unit 1A Allied Industrial Estate,Ballyfermot,Dubin 1,Ireland Woodstock Industrial Estate,.,Athy,Co. Kildare,Ireland Woodstock Industrial Estate,.,Athy,Co. Kildare,Ireland

57 Within the Country No paper and cardboard packaging R3 M Weighed Offsite in Ireland Greenstar,W53-3 Within the Country No 14.6 plastic packaging R3 M Weighed Offsite in Ireland Greenstar,W53-3 Within the Country No wooden packaging R3 C Volume Calculation Offsite in Ireland C. J. Sheeran,W337-1 Within the Country No mixed packaging R3 M Weighed Offsite in Ireland Greenstar,W53-3 organic wastes other than those mentioned To Other Countries No in R3 M Weighed Abroad Thorndale Environmental,WDL 14 Fassaroe,Greenstar Depot,Bray,Co. Wicklow,Ireland Fassaroe,Greenstar Depot,Bray,Co. Wicklow,Ireland Shannon Street,.,Mountrath,Co. Laois,Ireland Fassaroe,Greenstar Depot,Bray,Co. Wicklow,Ireland 11 Clooney Road,Campsie,Londonderry, BT47 3PA,United Kingdom National Document Management Group T/A Park West Industrial Estate,Unit 53,Dublin,Dublin Within the Country No paper and cardboard R3 M Weighed Offsite in Ireland Shredit,WFP-DC ,Ireland Fassaroe,Greenstar Depot,Bray,Co. Within the Country No biodegradable kitchen and canteen waste R3 M Weighed Offsite in Ireland Greenstar,W53-3 Wicklow,Ireland Within the Country No 3.84 metals R4 M Weighed Offsite in Ireland National Waste Management,W79-1 Within the Country No mixed municipal waste D1 M Weighed Offsite in Ireland Greenstar,W165-2 Within the Country No bulky waste D1 M Weighed Offsite in Ireland Greenstar,W165-2 Cookstown Industrial Estate,Unit 41,Tallaght,Dublin 24,Ireland Ballynagran,.,Coolbeg and Kilcandra,Co. Wicklow,Ireland Ballynagran,.,Coolbeg and Kilcandra,Co. Wicklow,Ireland

58 ANNEX II SITE DRAWINGS Noise Monitoring Locations

59 Borehole Locations

60 ANNEX III ENVIRONMENTAL MANAGEMENT PROGRAMME SUMMARY REPORT

61 Environmental Management Programme (EMP)/Continuous Improvement Programme Highlighted cells contain dropdown menu click to view Additional Information 1 Do you maintain an Environmental Mangement System for the site. If yes, please detail in additional information Yes ISO 141 Certification 2 Does the EMS reference the most significant environmental aspects and associated impacts on-site Yes Does the EMS maintain an Environmental Management Programme (EMP) as required in accordance with the 3 licence requirements Yes Do you maintain an environmental documentation/communication system to inform the public on 4 environmental performance of the facility, as required by the licence Yes Environmental Management Programme (EMP) report Objective Category Target Status (% completed) How target was progressed Responsibility Intermediate outcomes Waste reduction/raw material usage efficiency Most packaging lines are now located in one area where a baler is used to collect all mixed recyclables. Waste from the remaining lines needs to collected by Recycle cartonette waste from packaging area different means which are still to be 7 proposed. Section Head Improved Environmental Management Practices Waste reduction/raw material usage efficiency Waste reduction/raw material usage efficiency Waste reduction/raw material usage efficiency Two balers capture waste from stretch Recycle high grade soft plastic wrap and plastic bags that are used 1 internally for product movement. Individual Reduced emissions Develop metric for drums being Reduce the amount of hazardous waste generated by 1%, from 28 levels incinerated from 28 to current year and investigate changes in management 1 of this waste Individual Improved Environmental Management Practices With previous waste reduction and segregation methods BD achieved a 15 Reduce waste going off site for disposal (landfill / incineration) by 15%, from 28 levels % reduction between 28 and 211. However there a further ways to divert waste from landfill which will be 6 implemented by 215 Section Head Reduced emissions Waste reduction/raw material usage efficiency Capture recycleables from all Review the general waste stream and areas of the plant 1 identify fractions that can be recycled. Section Head Reduced emissions

62 Energy Efficiency/Utility conservation Energy Efficiency/Utility conservation Energy Efficiency/Utility conservation Reduction of emissions to Air Reduction of emissions to Air Reduction of emissions to Air Improvements identified in Green Belt programme to be implemented on all Reduce compressed air consumption Pen Needle lines. Develop a site usage 8 map. Section Head Reduced emissions Specific energy consumption in 28 was 9.2 and the target is 6.4. The current value is 6.9. This was achieved by energy savings in moulding, on compressed air and consistent use of more energy efficient equipment to Reduce specific energy consumption from operations 3% by 215, from 28 levels replace older equipment. Also an increase in production volume at the same energy consumption is reducing 7 the specific energy consumption. Section Head Reduced emissions The current energy supply contract contains an element of 3% renewable Increase renewable energy energy to be allocated for the site use in BD s portfolio to 25% usage. Similar contracts will be renewed by 215, from 28 levels 1 in future. Section Head Reduced emissions Continue to improve solvent Recording and reporting of line usage is usage efficiency and carried out at weekly and daily intervals. monitoring of line solvent usage versus lubricant waste, regenerated solvent and process emissions Recording of waste and regenrated solvent is carried out weekly and reported each month for compliance 1 assessment. Section Head Increased solvent recovery Improve solvent mass balance by accounting for emmissions to air from A2-1 Review all methods of data collection to and outputs to waste, account for outputs into solvent mass including solid solvent waste 2 balance. Section Head Improved Environmental Management Practices Review the current cleaning and maintenance methods and propose Reduce solvent use by improved cleaning and maintenance systems changes to implement BAT. This includes training on BAT for critical 1 personnel. Section Head Reduced emissions

63 Noise reduction Reduction of emissions to Wastewater Reduction of emissions to Wastewater Waste reduction/raw material usage efficiency Existing noise sources did not contribute excessively to noise levels along the Control noise emissions from boundary in 211. The noise site equipment along all site contribution from a newly built battery boundaries 9 charging area will be evaluated in 212. Section Head Specific water consumption in 28 was 5.4 it is now 5.9. The target is 4.6. Taking planned production outputs into Reduce the specific water consumption by 15% from 28 level. consideration the amount of water to be saved will be calculated and 1 processes for water savings identified. Individual Project approval is progressing to excavate the drainage system at the back of the plant. Remedial work will Divert surface water away from seprate the surface water pipework sewer drainage system. 1 from the sewer system. Section Head Develop a process to assess Raw material inputs will be measured efficient use of raw materials and a method implemented to track the compared to outputs. 1 efficiency of material usage. Individual Less complaints Reduced emissions Increased compliance with licence conditions Increased compliance with licence conditions

64 ANNEX IV BUND INTEGRITY TEST REPORT

65 Bund/pipe testing report summary ALL IPPC/WASTE licensed facilities Intensive agriculture facilities please use alternative template Bund testing dropdown menu click to see options Additional information Are you required by your licence to undertake integrity testing on bunds and containment structures? if yes please fill out table 1 below listing 1 all bunds and containment structures on site Yes n/a 2 Please provide integrity testing frequency period 3 years n/a Does the site maintain a register of bunds, underground pipelines (including stormwater and foul), Tanks, sumps and containers? (containers 3 refers to "Chemstore" type units and mobile bunds) Yes n/a Table 1: Summary details of bund integrity test Results of Integrity reports retest(if in Bund/Containment maintained on Integrity test failure Scheduled date current structure ID Type Specify Other type Product containment Actual capacity Capacity required* Type of integrity test Other test type Test date site? Results of test explanation <5 words Corrective action taken for retest reporting year) 65 prefabricated n/a Decanting of 2 Litre drums Hydraulic test n/a 3 January 212 Yes Pass n/a n/a Jul 214 n/a Document in a risk assessment Mobile units by design of a that the smaller volume is 592 prefabricated n/a HFE single drum storage Hydraulic test n/a 21 July 211 Yes Fail smaller volume acceptable for this location. Jul 214 n/a Document in a risk assessment Mobile units by design of a that the smaller volume is 5921 prefabricated n/a HFE single drum storage Hydraulic test n/a 2 July 211 Yes Fail smaller volume acceptable for this location. Jul 214 n/a Document in a risk assessment Mobile units by design of a that the smaller volume is 5922 prefabricated n/a HFE single drum storage Hydraulic test n/a 21 July 211 Yes Fail smaller volume acceptable for this location. Jul 214 n/a Document in a risk assessment Mobile units by design of a that the smaller volume is 5923 prefabricated n/a HFE single drum storage Hydraulic test n/a 21 July 211 Yes Fail smaller volume acceptable for this location. Jul 214 n/a Document in a risk assessment Mobile units by design of a that the smaller volume is 5924 prefabricated n/a HFE single drum storage Hydraulic test n/a 28 July 211 Yes Fail smaller volume acceptable for this location. Jul 214 n/a Document in a risk assessment Mobile units by design of a that the smaller volume is 5925 prefabricated n/a HFE single drum storage Hydraulic test n/a 2 July 211 Yes Fail smaller volume acceptable for this location. Jul 214 n/a Document in a risk assessment Mobile units by design of a that the smaller volume is 5926 prefabricated n/a HFE single drum storage Hydraulic test n/a 28 July 211 Yes Fail smaller volume acceptable for this location. Jul 214 n/a Document in a risk assessment Mobile units by design of a that the smaller volume is 5927 prefabricated n/a HFE single drum storage Hydraulic test n/a 21 July 211 Yes Fail smaller volume acceptable for this location. Jul 214 n/a Document in a risk assessment Mobile units by design of a that the smaller volume is 5928 prefabricated n/a HFE single drum storage Hydraulic test n/a 26 July 211 Yes Fail smaller volume acceptable for this location. Jul 214 n/a Document in a risk assessment Mobile units by design of a that the smaller volume is 5929 prefabricated n/a HFE single drum storage Hydraulic test n/a 26 July 211 Yes Fail smaller volume acceptable for this location. Jul 214 n/a Document in a risk assessment Mobile units by design of a that the smaller volume is 5931 prefabricated n/a HFE single drum storage Hydraulic test n/a 28 July 211 Yes Fail smaller volume acceptable for this location. Jul 214 n/a Document in a risk assessment Mobile units by design of a that the smaller volume is 5932 prefabricated n/a HFE single drum storage Hydraulic test n/a 21 July 211 Yes Fail smaller volume acceptable for this location. Jul 214 n/a Document in a risk assessment Mobile units by design of a that the smaller volume is 5933 prefabricated n/a HFE single drum storage Hydraulic test n/a 2 July 211 Yes Fail smaller volume acceptable for this location. Jul 214 n/a Document in a risk assessment Mobile units by design of a that the smaller volume is acceptable for this location. 598 prefabricated n/a HFE single drum storage Hydraulic test n/a 26 July 211 Yes Fail smaller volume Jul 214 n/a 797 prefabricated n/a HFE single drum storage Hydraulic test n/a 28 July 211 Yes Pass n/a n/a Jul 214 n/a Document in a risk assessment Mobile units by design of a that the smaller volume is acceptable for this location. 932 prefabricated n/a HFE single drum storage Hydraulic test n/a 26 July 211 Yes Fail smaller volume Jul 214 n/a 9321 prefabricated n/a HFE single drum storage Hydraulic test n/a 22 July 211 Yes Pass n/a n/a Jul 214 n/a 9322 prefabricated n/a HFE single drum storage Hydraulic test n/a 2 July 211 Yes Pass n/a n/a Jul 214 n/a 9323 prefabricated n/a HFE single drum storage Hydraulic test n/a 2 July 211 Yes Pass n/a n/a Jul 214 n/a Document in a risk assessment Mobile units by design of a that the smaller volume is acceptable for this location prefabricated n/a HFE single drum storage Hydraulic test n/a 28 July 211 Yes Fail smaller volume Jul 214 n/a 9325 prefabricated n/a HFE single drum storage Hydraulic test n/a 21 July 211 Yes Pass n/a n/a Jul 214 n/a

66 5419 prefabricated n/a 542 prefabricated n/a Environmental Chiller Cooling Towers and Chilled Water System Dosing Chemicals Hydraulic test n/a 23 January 212 Yes Fail Environmental Chiller Cooling Towers and Chilled Water System Dosing Chemicals Hydraulic test n/a 23 January 212 Yes Fail Mobile units by design of a smaller volume Mobile units by design of a smaller volume Drums operate at 5% fill level of full capacity. Drums operate at 5% fill level of full capacity. Jul 214 n/a Jul 214 n/a 5421 prefabricated n/a 5422 prefabricated n/a 5423 prefabricated n/a 5424 prefabricated n/a 5425 prefabricated n/a Moulding Chiller Cooling Towers and Chilled Water System Dosing Chemicals and Boiler system Hydraulic test n/a 23 January 212 Yes Pass n/a n/a Jul 214 n/a Moulding Chiller Cooling Towers and Chilled Water System Dosing Chemicals and Boiler system Hydraulic test n/a 23 January 212 Yes Pass n/a n/a Jul 214 n/a Compressor Cooling Towers Dosing Chemicals Hydraulic test n/a 3 January 212 Yes Pass n/a n/a Jul 214 n/a Compressor Cooling Towers Leak due to corrosion in Dosing Chemicals Hydraulic test n/a 3 January 212 Yes Fail bottom of bund Replace unit with new bund Jul 214 n/a 2 litre container solvent and lube mix storage Hydraulic test n/a 3 January 212 Yes Pass n/a n/a Jul 214 n/a 5427 prefabricated n/a Decanting of 2 litre drums Hydraulic test n/a 3 January 212 Yes Pass n/a n/a Jul 214 n/a 5432 prefabricated n/a Storage of cutting fluid Hydraulic test n/a 6 February 212 Yes Pass n/a n/a Jul 214 n/a prefabricated n/a Decanting of 2 litre drums Hydraulic test n/a 23 January 212 Yes Pass n/a n/a Jul 214 n/a prefabricated n/a Decanting of 2 litre drums Hydraulic test n/a 23 January 212 Yes Pass n/a n/a Jul 214 n/a 993 prefabricated n/a Storage of empty 2 liter drums Hydraulic test n/a 24 September 211 Yes Pass n/a n/a Jul 214 n/a 994 prefabricated n/a Storage of empty 2 ltr containers Hydraulic test n/a 24 September 211 Yes Pass n/a n/a Jul 214 n/a 798 general purpose conn/a Storage of raw material solvents and recovered HFE Hydraulic test n/a 18 January 212 Yes Pass n/a n/a Jul 214 n/a Supplementary raw material solvent and oil 7497 prefabricated n/a storage Hydraulic test n/a 14 January 212 Yes Pass n/a n/a Jul 214 n/a 5429 prefabricated n/a Flamvault for lubricant storage Hydraulic test n/a 3 January 212 Yes Pass n/a n/a Jul 214 n/a 543 prefabricated n/a Flamvault for lubricant storage 22 6 Hydraulic test n/a 23 January 212 Yes Pass n/a n/a Jul 214 n/a 713 prefabricated n/a Flamvault for cleaning solvents 22 6 Hydraulic test n/a 3 January 212 Yes Pass n/a n/a Jul 214 n/a 1795 prefabricated n/a Flamvault for lubricant storage 22 6 Hydraulic test n/a 3 January 212 Yes Pass n/a n/a Jul 214 n/a Flamvault for small 696 prefabricated n/a chemical containers n/a n/a Other (please specify) ted within bund ID 7 n/a No n/a n/a n/a Jul 214 n/a 6963 prefabricated n/a Flamvault for Epoxy Hydraulic test n/a 29 July 211 Yes Pass n/a n/a Jul 214 n/a 712 prefabricated n/a Flamvault for lubricant storage 11 6 Hydraulic test n/a 29 July 211 Yes Pass n/a n/a Jul 214 n/a 1259 prefabricated n/a HFE condensate effluent Hydraulic test n/a 6 February 212 Yes Pass n/a n/a Jul 214 n/a

67 * Capacity required should comply with 25% or 11% containment rule as detailed in your licence Commentary Has integrity testing been carried out in accordance with licence requirements and are all 4 structures tested in line with BS87/EPA Guidance? bunding and storage guidelines Yes 5 Are channels/transfer systems to remote containment systems tested? n/a 6 Are channels/transfer systems compliant in both integrity and available volume? n/a 7 Do all sumps and chambers have high level liquid alarms? n/a 8 If yes to Q7 are these failsafe systems included in a maintenance and testing programme? n/a Pipeline/underground structure testing Are you required by your licence to undertake integrity testing on underground structures e.g. pipelines or sumps etc? if yes please fill out 1 table 2 below listing all underground structures and pipelines on site Yes e underground tanks on site 2 Please provide integrity testing frequency period 3 years n/a Table 2: Summary details of underground structures/pipeline integrity test Type of secondary containment Does this structure have Integrity reports Integrity test failure Corrective action Scheduled date Results of retest(if in current Structure ID Type system Material of construction: Secondary containment? Type integrity testing maintained on site? Results of test explanation <5 words taken for retest reporting year) n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a SELECT

68 ANNEX V COMPLAINTS AND INCIDENTS

69