ANNUAL ENVIRONMENTAL REPORT. For. McGhan Ltd. t/a Allergan Kilbride Industrial Estate, Arklow Co. Wicklow. IPPC Licence Number: P

Transcription

1 ANNUAL ENVIRONMENTAL REPORT 2008 For McGhan Ltd. t/a Allergan Kilbride Industrial Estate, Arklow Co. Wicklow IPPC Licence Number: P (Document Number v3.00) Tel: Fax: energy@iol.ie Registered Office as above. Registered Number

2 QF 1. v2 Document Lead Sheet Document Title Annual Environmental Review 2008 Project No Document No v2.00 Client McGhan Ltd. t/a Allergan Address Kilbride Industrial Estate, Arklow, Co. Wicklow Signed for and on behalf of Issue Status Date Author Environmental Client Efficiency 2.00 Approved POS 3.00 Approved POS Where it is a requirement that this report be issued to a regulatory or other authority, then the client should sign the appropriate place in the above table and, unless specifically agreed in writing to the contrary, forward copies to the appropriate authority (e.g. EPA). EEC Project Manager: EEC Document Author: Bob Sutcliffe, CEng, MIMechE Pádraig O Shea BA, MA Conditions relating to the issue of this report: 1. No alteration to this report by third parties is permitted 2. Where this report is reproduced, it shall only be reproduced in full. 3. Reports remain the property of Environmental & Efficiency Consultants (Ireland) Limited until paid for in full. Environmental Efficiency (Ire) Ltd 2 Document no v2.00

3 Table of Contents 1 Introduction Company Information Company Organisation Chart Site Description Company Profile Description of Equipment Manufacturing Process Summary of Emissions Emissions to Sewer Emission to sewer, monitoring programme Emission to sewer, monitoring results Emissions to Atmosphere Emissions to Atmosphere - monitoring programme Emissions to atmosphere Monitoring results Boiler Emissions Waste Management Hazardous waste generation Non Hazardous waste Resource Consumption Water Consumption Energy Consumption Environmental Incidents and Complaints Reported Incidents Summary Complaints Summary EPA Site Inspections Environmental Management of activity Report on Environmental Objectives and targets for Environmental Management Programme Licence Specific Reports (IPPC licence P ) Pollution Emissions Register (PER) Noise Monitoring Report Solvent Management Plan/ Fugitive Emissions Programme Programme for public information Environmental Improvements on site during 2008 and financial provisions Environmental Liabilities Prevention of Environmental Damage Remedial Action...43 Environmental Efficiency (Ire) Ltd 3 Document no v2.00

4 List of Tables Table 1-1 Company details... 5 Table 1-2 Summary of IPC licence... 5 Table 3-1 Parameters and Monitoring Schedule (licence number: PO115-04)... 9 Table 3-2 Emissions to Sewer Monitoring results Table 3-3 Air Monitoring Programme (IPPC licence PO115-04)...13 Table 3-4 Monitoring Results Volumes m 3 /hr...14 Table 3-5 Monitoring Results 2008 Total Organics (as C, relative to o-xylene)...14 Table 3-6 Monitoring Results 2008 Class A compounds...14 Table 3-7 Boiler Emissions Monitoring Table 3-8 Waste Generation during Table 3-9 Hazardous waste generation Table 3-10 Non-Hazardous waste generation Table 3-11 Summary of wastes generated in 2008 (tonne)...19 Table 4-1 Water Consumption...20 Table 4-2 Energy Consumption Table 5-1 EPA Site Inspection during Table 5-2 EPA Site Inspection 09/05/ Table 6-1 Report on Objectives and targets for Table 6-2 Summary of Environmental Management Programme for Table 7-1 Programme for public information...39 Table 7-2 Environmental Improvements on site...40 List of Figures Figure 3-1 Emissions to sewer 2008: Total Dissolved Solids...11 Figure 3-2 Emissions to sewer 2008: ph...11 Figure 3-3 Emissions to sewer 2008: Fats, Oils, Greases (FOG)...11 Figure 3-4 Emissions to sewer 2008: Biological Oxygen Demand (BOD)...12 Figure 3-5 Emissions to sewer 2008: Chlorides...12 Figure 3-6 Emissions to sewer 2008: Suspended Solids...12 Figure 3-7 Hazardous Waste generated per 1000 units of product produced...17 Figure 3-8 Non Hazardous Waste generated per 1000 units produced...18 Figure 4-1 Water consumption (m 3 ) per 1000 units produced...20 Figure 4-2 Water Consumption Trends Figure 4-3 Electrical Energy Consumption Trend...22 Figure 4-4 Natural Gas Consumption Trends (please note natural gas is on line since 2002)...22 Figure 4-5 Electrical Consumption per 1000 units produced...23 Figure 4-6 National Gas Consumption per 1000 units produced...23 List of Appendices Appendix 1Emissions to Sewer; Certificates of Analysis...44 Appendix 2 Air Monitoring 2008 Certificates of Analysis...56 Appendix 3 Boiler Monitoring Report Appendix 4 Solvent Management Plan...70 Appendix 5 Noise Monitoring...71 Environmental Efficiency (Ire) Ltd 4 Document no v2.00

5 1 Introduction 1.1 Company Information Table 1-1 Company details Company McGhan Limited t/a Allergan Address Kilbride Industrial Estate, Arklow, Co. Wicklow County / City Co. Wicklow Business Manufacturers of medical devices for plastic and reconstructive surgery Employees 320 people Contact Name Noel O Connor Position Environmental, Health & Safety Officer Telephone Fax oconnor_noel@allergan.com IPPC Registration Number P * *During 2005 Allergan requested the Environmental Protection Agency (EPA) to review their IPPC licence in preparation for the installation of a Regenerative Thermal Oxidizer (RTO). In November 2005 a new licence was issued to the company (IPPC licence number 744). This licence number was subsequently changed to P in July 2006 and the company now trades as Allergan. Table 1-2 Summary of IPC licence IP(P)C Licence Reg: No. Period /05/03- November (IPPC licence) November st July 2006 P (IPPC licence) 21/07/ present Environmental Efficiency (Ire) Ltd 5 Document no v2.00

6 1.2 Company Organisation Chart Engineering Manager: Mr. Kevin Dempsey Environmental, Health and Safety Officer: Mr. Noel O Connor Maintenance Manager: Mr. Stephen Diamond Environmental Efficiency (Ire) Ltd 6 Document no v2.00

7 2 Site Description 2.1 Company Profile McGhan Limited trading as Allergan (the company) is a subsidiary of Allergan Inc., a global surgical and medical device company engaged in the development, marketing and manufacturing of medical devices for aesthetic medicine markets. The company is the worldwide leader in breast implants for cosmetic augmentation and breast reconstruction. The company is a leader in facial aesthetics and provides collagen dermal fillers to correct facial wrinkles and scars. Additionally the company is the leading developer of surgical devices for the treatment of severe obesity. The company is based in the South East of the county and employs 320 people, who are involved in all stages of the manufacturing of breast implants. Allergan is an ISO, G-MED, and FDA approved company. The company is committed to continuous improvement, which is the core of our environmental management programme. Manufacturing takes place in a 4000 square metre facility, the three main production areas are dipping, assembly and packaging. 2.2 Description of Equipment Equipment on site includes the following: Mixer Carousels Ovens Air handling units Regenerative Thermal Oxidiser (ConOx 62) Continuous emissions to sewer monitoring equipment Continuous air monitoring equipment Environmental Efficiency (Ire) Ltd 7 Document no v2.00

8 2.3 Manufacturing Process The company is involved in the manufacture of breast implants for plastic and reconstructive surgery. A summary of the manufacturing process is as follows: The implants are manufactured by forming a shell of silicone over a mould. The shell is removed from the mould and patched. This shell is either filled with silicone gel to form gel filled implants or the shell is not filled and is sent unfilled for implants to form saline implants. Mixing Approved raw materials are mixed in the mixing area. Dip Coating Moulds are manually dipped in the silicone mixture to form the shell for the implant Inspection Assembly/primary packaging Sterilisation The moulds are placed in carousels where the solvents are evaporated. The outer shell is removed, which forms the implant. This shell is then filled with silicone gel or the shell is sent unfilled to form the implant. Secondary packaging/finished goods Environmental Efficiency (Ire) Ltd 8 Document no v2.00

9 3 Summary of Emissions The company has the following licensed emissions: Emissions to sewer (SE 1) Emissions to atmosphere (A2-3) Waste emissions 3.1 Emissions to Sewer Emission to sewer, monitoring programme The monitoring schedule for emissions to sewer is provided in Table 3-1 below: Table 3-1 Parameters and Monitoring Schedule (licence number: PO115-04) Parameter Monitoring Emission limit values Frequency Volume m 3 (flow) note 1 Continuous 60m 3 per day (10m 3 max rate per hr) Temperature note 2 Continuous 40 o C (max) ph note 2 Continuous BOD Quarterly 20 mg/l Suspended Solids Quarterly 30 mg/l Total Dissolved Solids Quarterly 3,700 mg/l Oil/Fat/Greases Monthly 50 mg/l Chlorides Monthly 2,500 mg/l Note 1 The allowed volume to be emitted in any one day was increased from 40m 3 to 60m 3 following the IPPC review. In addition the monitoring frequency was changed to continuous monitoring. Note 2 the monitoring frequency for temperature and ph was changed from monthly to continuous following IPPC review Emission to sewer, monitoring results Chemical analysis of emissions to sewer is carried out monthly by Microchem Laboratories located in Clogherane, Dungarvan, Co. Waterford. A summary of monitoring results for 2008 is provided in Table 3-2 below. No chemical parameter exceeded the specified limits during Certificates of analysis are provided in Appendix 1 of this report. The company has installed a continuous metre for flow, ph and temperature. This continuous monitoring equipment has been on line since February Continuous readings for volume, temperature and ph are available on site for inspection. The volume of trade effluent discharge was recorded daily during 2008 with no recorded measurements exceeding the emission limit value of 60m 3 per day. Graphs illustrating the daily flow rates are provided in Appendix 1 of this report. Environmental Efficiency (Ire) Ltd 9 Document no v2.00

10 Table 3-2 Emissions to Sewer Monitoring results 2008 Lab Number Date Sampled 16- Jan 20- Feb 19- Mar 16- Apr 21- May 25- June 23- July 13- Aug 24- Sep 15- Oct 19- Nov 17- Dec Monitoring period Jan Feb Mar Apr May June Jul Aug Sep Oct Nov Dec Parameters Units ph ph Units BOD mg/l 20 ND<1 ND<1 4 ND<1 ND<1 ND<1 ND<1 ND<1 ND<1 ND<1 1 ND<1 Suspended mg/l 30 2 ND<1 3 ND<1 ND<1 2 ND<1 4 3 ND<1 1 ND<1 Solids Total mg/l 3, , , Dissolved Solids Chloride mg/l 2, , , Oils. Fats, Greases mg/l 50 ND<1 ND<1 ND<1 ND<1 ND<1 ND< ND- when shown indicates not detected Environmental Efficiency (Ire) Ltd 10 Document no v2.00

11 Total Dissolved Solids [conc] mg/l Total Dissolved Solids ELV Jan-08 Feb-08 Mar-08 Apr-08 May-08 Jun-08 Jul-08 Aug-08 Sep-08 Oct-08 Nov-08 Dec-08 Monitoring Period Figure 3-1 Emissions to sewer 2008: Total Dissolved Solids ph [Conc] mg/l Jan-08 Feb-08 Mar-08 Apr-08 May-08 Jun-08 Monitoring Period Jul-08 Aug-08 Sep-08 Oct-08 Nov-08 Dec-08 PH ELV lower limit ELV upper limit Figure 3-2 Emissions to sewer 2008: ph FOG [Conc] mg/l Jan-08 Feb-08 Mar-08 Apr-08 May-08 Jun-08 Monitoring Period Jul-08 Aug-08 Sep-08 Oct-08 Nov-08 Dec-08 Figure 3-3 Emissions to sewer 2008: Fats, Oils, Greases (FOG) FOG ELV Environmental Efficiency (Ire) Ltd 11 Document no v2.00

12 BOD [Conc] mg/l Jan-08 Feb-08 Mar-08 Apr-08 May-08 Jun-08 Monitoring Period Jul-08 Aug-08 Sep-08 Oct-08 Nov-08 Dec-08 BOD Figure 3-4 Emissions to sewer 2008: Biological Oxygen Demand (BOD) ELV Chloride 3000 [Conc] mg/l Chloride ELV Jan-08 Feb-08 Mar-08 Apr-08 May-08 Jun-08 Jul-08 Aug-08 Sep-08 Oct-08 Nov-08 Dec-08 Monitoring Period Figure 3-5 Emissions to sewer 2008: Chlorides Suspended Solids [Conc] mg/l Jan-08 Feb-08 Mar-08 Apr-08 May-08 Jun-08 Monitoring Period Jul-08 Aug-08 Sep-08 Oct-08 Nov-08 Dec-08 Suspended Solids ELV Figure 3-6 Emissions to sewer 2008: Suspended Solids Environmental Efficiency (Ire) Ltd 12 Document no v2.00

13 3.2 Emissions to Atmosphere Emissions to Atmosphere - monitoring programme In accordance with the company s IPPC licence, Allergan monitors air emissions for total organic carbon and Class A Compounds. A summary of emission limit values and allowed flow rates for the RCTO (A2-3) on site are provided in Table 3-3 below. Table 3-3 Air Monitoring Programme (IPPC licence PO115-04) Emission point Parameters Monitoring reference Note 1 Frequency Volumes & Concentrations Licensed Volume A2-3 ( RTO) Flow rate Continuous 62,000m 3/ hr 1,488,000 m 3 per day Class A Compounds ( quarterly) Quarterly 2 mg/m 3 Total Organics (as Carbon) Continuous 50 mg/m 3 Nitrogen Oxides (as NO 2 ) Quarterly Not specified Carbon Monoxide Quarterly Not specified Note 1 Please note that emission points A2-1, A3 and A2-2 (formally A4) were decommissioned at beginning of 2007 due to the operation of the RTO. The RCTO (A2-3) was the only air emission point during Emissions to atmosphere Monitoring results Monitoring on site was carried out during 2008 by TMS Environmental. The monitoring results: volumes emitted, total organics (as C) and Class A compounds, and combustion gases are summarised in Table 3-4, Table 3-5 and Table 3-6 respectively below. Any monitoring results highlighted in bold indicates a breach in the emission limit value. Full monitoring reports are provided in Appendix 2 of this report. Environmental Efficiency (Ire) Ltd 13 Document no v2.00

14 Table 3-4 Monitoring Results Volumes m 3 /hr Stack Volumes m 3/ hr Emission Limit Value 62,000 m 3/ hr Emission point A2-3 RCTO Monitoring period 12/02/ ,562 13/06/ ,181 24/09/ ,627 16/12/ ,646 Table 3-5 Monitoring Results 2008 Total Organics (as C, relative to o-xylene) Stack Total Organics (as C, relative to o-xylene) Emission Limit Value 50 mg/m 3 mg/m 3 Emission point A2-3 RCTO Monitoring period 12/02/ /06/2008 < /09/2008 < /12/2008 <0.38 Table 3-6 Monitoring Results 2008 Class A compounds Stack - Class A Compounds Units Emission Monitoring Period Limit Value 12/02/08 13/06/08 24/09/08 16/12/08 1,1,1 Trichloroethane mg/nm 3 2 <0.40 < Toluene mg/nm 3 2 <0.40 <0.40 <0.41 <0.38 m,p - Xylene mg/nm <1.97 <0.82 <0.76 o - Xylene mg/nm <0.40 <0.41 <0.38 Ethylbenzene mg/nm <0.40 <0.41 <0.38 Benzene mg/nm <0.40 <0.41 <0.38 Environmental Efficiency (Ire) Ltd 14 Document no v2.00

15 Table 3-7 Monitoring Results 2008 RCTO Combustion gases Monitoring Period 12/02/ /06/ /09/ /12/2008 Mg/Nm 3 Kg/h Mg/Nm 3 Kg/h Mg/Nm 3 Kg/h Mg/Nm 3 Kg/h Sulphur Dioxide <2.86 <0.102 <2.86 <0.141 <2.86 <0.06 <2.86 <0.06 (SO 2 ) CO <2.05 < NO X as NO 2 <2.05 < < <2.05 <0.04 O 2 (%) Note Note Note Note Note 1 Oxygen levels are greater than 20.0%. Therefore no oxygen correction was considered. 3.3 Boiler Emissions Boiler efficiency monitoring is carried out annually by TMS Environmental. A summary of the monitoring results is provided in Table 3-7 below. A copy of the full report is provided in Appendix 3 of this report. Table 3-7 Boiler Emissions Monitoring 2008 Main Boiler #1 Temperature o C Mg/Nm 3% 0 2 Correction CO <1.24 NO x as NO SO 2 <1.73 O 2 % - Environmental Efficiency (Ire) Ltd 15 Document no v2.00

16 3.4 Waste Management A summary of all wastes generated during 2008 are summarised in Table 3-8 below. Table 3-8 Waste Generation during 2008 Waste EWC No. Hazardous Annual Quantity (tonnes) 2008 Current Disposal Waste Contractor Destination of Waste Company Licence No Xylene/Silicone * Yes D10 Indaver Irl Ltd. Off site abroad 36-2 (AVG Hamburg, Germany as per TFS) IPA & Water * Yes 1.69 D10 Indaver Irl Ltd. Off site abroad 36-2 (AVG Hamburg, Germany as per TFS) Silicone gel * Yes 3.14 D10 Indaver Irl Ltd. Off site abroad 36-2 (AVG Hamburg, Germany as per TFS) Paper/Cardboard No R3 Greenstar Off site Ireland W0220/01 Steel drums No R4 Greenstar Off site Ireland W0220/01 Wood Packaging No 5.92 R3 Greenstar Off site Ireland W0220/01 General plant/office No D1 Greenstar Off site Ireland W0220/01 Aluminium foil No 0.6 R4 Greenstar Off site Ireland W0220/01 Filter material No 0.4 D1 Greenstar Off site Ireland W0220/01 Battery dry cell No R5 Irish Lamp Recycling Off site Ireland 02/2000A Fluorescent tubes Yes R5 Irish Lamp Recycling Off site Ireland 02/2000A Builders No 0.0 D1 Greenstar Off site Ireland W0220/01 PC Monitors Yes 1.4 R5 Indaver Irl Ltd. Off site Ireland 36 PC Bases No 0.3 R5 Indaver Irl Ltd. Off site Ireland 36 Mixed WEEE Yes 0.0 R5 Ecosafe Off site Ireland 54-2 Mixed WEEE Yes R5 Irish Lamp Recycling Off site Ireland 02/2000A Printers Yes 0.13 R5 Indaver Irl Ltd Off site Ireland 36 Plastic Sheeting Yes 60 D10 Ecosafe Off site abroad 54-2 Waste marked with an asterisk (*) is considered as a hazardous waste pursuant to Directive91/689/EEC on hazardous waste, and subject to the provisions of that Directive unless Article 1 (5) of that Directive applies. Environmental Efficiency (Ire) Ltd 16 Document no v2.00

17 3.4.1 Hazardous waste generation The trend of hazardous waste generated per units produced from 2000 to 2008 is summarised in Table 3-9 below. Table 3-9 Hazardous waste generation Year Weight (Kgs) Kg hazardous waste % increase /decrease generated per 1000 units produced , , % , % , % , % , % % , % , % Hazardous Waste 140,000 Kgs hazardous waste generated per 1000 production units 120, ,000 80,000 60,000 40,000 20, Year Figure 3-7 Hazardous Waste generated per 1000 units of product produced Environmental Efficiency (Ire) Ltd 17 Document no v2.00

18 3.5 Non Hazardous waste The trend of non hazardous waste generated per units produced from 2000 to 2008 is summarised in Table 3-10 below. Table 3-10 Non-Hazardous waste generation Kg non -hazardous waste generated per 1000 units produced % increase /decrease Year Weight (Kgs) , , % , % , % , % , % , % , % , % Non-hazardous waste 300,000 Kgs of non-hazardous wastegenerated per 1000 units produced 250, , , ,000 50, Year Figure 3-8 Non Hazardous Waste generated per 1000 units produced Environmental Efficiency (Ire) Ltd 18 Document no v2.00

19 A breakdown of the amount of waste disposed and recovered is provided in Table Table 3-11 Summary of wastes generated in 2008 (tonne) Quantity of wastes Quantity of wastes disposed on site Quantity of wastes disposed off-site Quantity of waste recovered off-site Non-hazardous wastes Hazardous wastes Total Environmental Efficiency (Ire) Ltd 19 Document no v2.00

20 4 Resource Consumption This section of the report details the total annual usage levels of water and energy Water Consumption Water consumption for 2008 is detailed in Table 4-1 below. Water consumption figures for 2004 to 2008 are also included for comparative purposes. Water consumption per 1000 units produced from 2000 to 2008 is provided in Figure 4-1 below. Water usage trends over an eight year period are also shown in Figure 4-2 below. Table 4-1 Water Consumption Year Water Reading On-site ground On-site surface Main supply m 3 m 3/ 1000 units produced m 3 m 3/ 1000 units produced m 3 m 3/ 1000 units produce d m 3 m 3 /1000 units produced m 3 m 3 /1000 units produced N/a N/a N/a N/a N/a N/a N/a N/a N/a N/a N/a N/a N/a N/a N/a N/a N/a N/a N/a N/a 16, , , , , Water Consumption m3 per 1000 units produced Year Figure 4-1 Water consumption (m 3 ) per 1000 units produced Environmental Efficiency (Ire) Ltd 20 Document no v2.00

21 Water Consumption Trend 25,000 20,000 Facility Water Usage m3 15,000 10,000 5, Year Figure 4-2 Water Consumption Trends Energy Consumption Energy is provided by two sources at the company namely: Natural gas Electricity A summary of energy consumption in 2008, in terms of the above, is shown in the Table 4-2 below. Table 4-2 Energy Consumption 2008 Source Natural Gas Consumption 2007 Consumption 2008 Units Consumption per 1000 units produced 2007 Consumption per 1000 units produced 2008 Increase/ Decrease (%) 6,875,563 6,910,552 kwh 5, , % Electricity 6,456,931 5,491,472 kwh 5, , % Trends in electrical energy use and natural gas usage are shown in Figure 4-3 and Figure 4-4 respectively. Environmental Efficiency (Ire) Ltd 21

22 The percentage increase in natural gas can be related to the running of Thermal Oxidiser during 2007 and an increase in boiler temperature supplying the carousels. Electricity Consumption (Energy) 7,000,000 Electricity Consumption (KWh) per 1000 units produced 6,000,000 5,000,000 4,000,000 3,000,000 2,000,000 1,000, Year Figure 4-3 Electrical Energy Consumption Trend Natural Gas Consumption 8,000,000 7,000,000 Natural Gas (KWh) per 1000 units produced 6,000,000 5,000,000 4,000,000 3,000,000 2,000,000 1,000, Year Figure 4-4 Natural Gas Consumption Trends (please note natural gas is on line since 2002) Environmental Efficiency (Ire) Ltd 22

23 The electrical and natural consumption per 1000 units produced are shown in Figure 4-5 and Figure 4-6 respectively, below. Electricity Consumption per 1000 units produced Electricity Consumption (KWh) per 1000 units produced Year Figure 4-5 Electrical Consumption per 1000 units produced Natural Gas Consumption Natural Gas (KWh) per 1000 units produced Year Figure 4-6 National Gas Consumption per 1000 units produced There was an increase in natural gas consumption from This can be related to the running of the Thermal Oxidiser from this period onward with an increase in boiler temperature supplying the carousels. There is a significantly high increase in An energy Environmental Efficiency (Ire) Ltd 23

24 reduction programme was introduced at the start of 2008 with a target of 13% for electrical consumption. Similar measures were also put in place for a Natural Gas Reduction Programme. 5 Environmental Incidents and Complaints 5.1 Reported Incidents Summary There were no reported incidents during Complaints Summary There were no complaints during EPA Site Inspections There was one EPA site inspection during Table 5-1 EPA Site Inspection during 2008 Date of EPA, Inspection Number of Non Number Inspection Reference No conformances observations 09/05/2008 P sm04djm 1 4 of Details of these visits are summarised in Table 5-2. Overall, environmental management practices at the company were found to be well organised and there was a good level of compliance with their IPPC licence. Table 5-2 EPA Site Inspection 09/05/2008 Summary of EPA Findings and corrective action taken.non-conformance The licensee was found to be in non-compliance with condition 5.1 of their licence with regard to a sample taken by the Agency which was in breach of the Emission Limit Value (ELV), set forth in the Schedule B.3 Emissions to water, for Fats, oils and greases. Following this non conformance the processing equipment was analysed and the results for FOG is being carefully monitored in-line with the processing equipment. Observations 1. A clearly audible humming noise was heard from emanating from the A2-1 emissions stack at Mr Cronin s house in light of complaints made by Mr Cronin to the licensee and the Agency. 2. A bypass response procedure had yet to be established for the thermal oxidiser. 3. As part of an application to surrender their licence, the licensee will have to carry out a soil and groundwater investigation to establish all potential contamination sources on site and followed with sampling and analysis of all relevant potential contaminants. 4. The licensee failed to include in the AER 2006 and 2007 condition 12.3, where an annual statement must be included in relation to measures taken or adopted at the site in relation to the prevention of environmental damage, and the measures in place in relation to the Environmental Efficiency (Ire) Ltd 24

25 Summary of EPA Findings and corrective action taken underwriting of costs for remedial actions (closure). This statement and measures are included in the AER for Corrective Action 1. A narrow band analysis noise survey was carried out (Doc. No v3.01) 2. An air emission abatement equipment appropriate response procedure, along with an air dispersion model (conducted by TMS) was carried out and submitted to the EPA 3. A hydro-geological investigation report was submitted to the Agency (ref: DURP001). 6 Environmental Management of activity The company operates an Environmental Management System in accordance with the IPPC licence. As part of this system an environmental management programme (EMP) is documented each year which outlines specific environmental objectives and targets for the company. Due to the closure and cessation of activities at the manufacturing site this year a report summarising the objectives and targets proposed for the upcoming year (2009) will not be possible other than those outlined in Table 6-2. A progress report on the EMP in place during 2008 is also provided. The schedule of Environmental objectives and targets has been established taking into account instruction within Condition of the IPPC Licence (P ). 6.1 Report on Environmental Objectives and targets for 2008 A report on the implementation of the 2008 EMP is provided in Table 6-1 below. Environmental Efficiency (Ire) Ltd 25

26 Table 6-1 Report on Objectives and targets for 2008 Objective reference No. 1 Objective Target/Outcome Achievement Difficulty Additional IPPC Licence Compliance; Maintain regulatory compliance with various relevant regulatory bodies and with IPPC licence requirements. Carry out compliance level gap analysis with IPPC licence and implement corrective actions as required. Review previous EPA site inspection audits and ensure corrective actions raised are implemented. No external non - conformances during # non-conformance noted by the Agency during This was in relation to effluent monitoring of sewer where analysis showed a breach in the ELV for Fats, oils and greases. Corrective action has been implemented, several samples were taken and analysed on various occasions and the results submitted to the Agency. All results were within licence limits. Comment - McGhan Ltd. t/a Allergan ceased their shell fabrication manufacturing activity on the 30th January 2009 and shut down their abatement equipment on Wednesday the 4th February The site will be completely decommissioned by the end of March Environmental Efficiency (Ire) Ltd 26

27 Objective reference No. Objective Target/Outcome Achievement Difficulty Additional 2 Waste: Investigate efficiency of use of raw materials in all processes, with a view to reducing waste generation and conserving natural resources Implement a waste minimisation programme based on the principals of the waste management hierarchy reduce, re-use and recycle of all wastes generated on site and by company activities Establish waste reduction to landfill per unit of product produced. Complete waste audit and implement recommendations Significant waste to landfill reductions for mixed commercial, cardboard, paper, scrap metal and timber. 3 Utility consumption: Develop energy and water efficiency projects Implement energy conservation measures to A further 5% reduction in hazardous waste generated per 1000 units produced reducing hazardous waste to kg per 1000 units produced. Develop plan to reduce solid waste generation, increase recycling rate including hazardous waste recycling in rate >-25%. During 2006 this recycling rate was 22%. Target: Reduce Electrical Consumption (kwh per 1000 units produced) by 5% during Hazardous waste generation increased from 63.56kg per 1000 units produced to 118.2kg per 1000 units produced. There was a 46% increase in hazardous waste generation during Non-hazardous waste generation was reduced from kg per 1000 units produced to 63.2kg per 1000 units produced. There was a 63% decrease in the non hazardous waste generation during 2008 Electrical consumption (kwh per 1000 units produced) was increased by 5 % during Comment - McGhan Ltd. t/a Allergan ceased their shell fabrication manufacturing activity on the 30th January 2009 and shut down their abatement equipment on Wednesday the 4th February The site will be completely decommissioned by the end of March Increase in electrical and natural gas consumption per 1000 McGhan Ltd. t/a Allergan ceased their shell fabrication manufacturing activity on the 30th Environmental Efficiency (Ire) Ltd 27

28 Objective reference No. Objective Target/Outcome Achievement Difficulty Additional ensure optimum efficiency of use Evaluate energy efficiency of systems, Develop energy and water efficiency projects. Reduction in electrical energy consumption and water consumption per unit of product produced Target: Maintain Natural Gas Consumption (kw per 1000 units produced) as per 2007 figures. Natural gas consumption (kwh per 1000 units produced) increased by 19% during 2008 compared to 2007 figures units is due to lower production output and the running of the RCTO The RCTO was fully on line during 2008 therefore natural gas consumption increased on site and also the increase in energy prices contributed to the increase. Comment January 2009 and shut down their abatement equipment on Wednesday the 4th February The site will be completely decommissioned by the end of March Environmental Efficiency (Ire) Ltd 28

29 Objective reference No. Objective Target/Outcome Achievement Difficulty Additional 4 Water Minimisation Establish water minimisation programme within the facility. Maintain water consumption (m 3 ) per 1000 units produced by as per 2007 figures. Water consumption (m 3 per 1000 units produced) increased from during 2007 to during An increase of 28% in water consumption per 1000 units for Figures Depend on production volumes Comment Increase in water consumption per 1000 units is due to lower production output and building weekly fire sprinkler pump testing Environmental Efficiency (Ire) Ltd 29

30 Objective reference No. Objective Target/Outcome Achievement Difficulty Additional 5 Review and improve waste storage on site: Following the agency s observation in 2006 the waste collection area and storage on site will be reviewed and improved Improve housekeeping at the waste collection areas. In consultation with waste contractors provide designated storage skips for all waste types generated on site including the following: Designated /labelled bunded area / bunded containers for the storage of hazardous waste. Designated/ segregated areas provided for non-hazardous recyclable wastes on site. Designated /segregated area provided for general wastes on site. All waste skips to be labelled and stored in an area which will prevent against leakages. Designated waste skips have been put in place for the different waste streams. All waste storage areas are inspected daily. All waste skips labelled - Comment Proper designated storage arrangements are now provided on site for all waste streams Environmental Efficiency (Ire) Ltd 30

31 Objective reference No. 6 Objective Target/Outcome Achievement Difficulty Additional Bunding (Condition 3.5.2): 7 Emergency response procedures All hazardous materials on site are stored in bunded areas in compliance with licence. No non conformances raised during 2007 relating to the storage of hazardous materials on site Review Existing Emergency Response Procedures and Accident Prevention Policy. No non conformance was raised in relation to the storage of materials on site during Emergency response procedures updated to included procedure in the event of a bypass associated with the Thermal Oxidiser. These were included. Air dispersion model was also submitted to the EPA. Comment - Proper storage arrangements are now provided on site for all raw materials Hydrogeological Investigation Submit a hydrogeological investigation to the EPA 2 emergency drills conducted during 2008 This was carried out and a report on the investigation submitted to the Agency - - Environmental Efficiency (Ire) Ltd 31

32 6.2 Environmental Management Programme 2009 There will be no environmental management programme for 2009, other than ensuring the successful clean closure of the manufacturing site (returning it to a suitable environmental state) and those outlined in Table 6-2 because the company will be ceasing operations. Table 6-2 Summary of Environmental Management Programme for 2009 Objective reference number Objective Target Responsibility Method Target completion date 1 IPPC Licence Compliance; Maintain regulatory compliance with various relevant regulatory bodies and with IPPC licence requirements until closure. Ensure no non conformances with licence conditions during 2009 up until point of closure. Mr. Noel O Connor Ongoing environmental management as per IPPC licence (P ). Ongoing implementation of environmental management procedures and inspections. Ongoing until 31 ST March Allergan ceased their shell fabrication manufacturing activity on the 30/01/2009 and shutdown their abatement equipment on Wednesday the 4th February The site will be completely decommissioned by the end of March This objective relates to the proper closure of the site to ensure no future environmental risk. 3 Resource use and waste generation. Ensure no environmental risk associated with the closure of the manufacturing site and no risk on site once closure is complete. Continue measures to ensure resource consumption and waste generation is minimised in 2009 up until closure Mr. Noel O Connor/ Kevin Dempsey Submit Cessation Plan/ closures plan to the Environmental Protection Agency. Ensue all documentation relating to closure will be available for inspection as part of exit audit. A pre-exit audit will be carried once manufacturing has ceased. Mr. Noel O Connor Ongoing implementation of environmental management procedures and inspections. Ongoing until 31 ST March Ongoing until 31 ST March Environmental Efficiency (Ire) Ltd 32

33 Objective Number Objective Title Rationale OT1 IPPC Licence Compliance; maintain regulatory compliance with various agencies and with IPPC licence requirements until closure Maintain regulatory compliance with IPPC licence requirements Target date Up until point of closure in 2009 Target Responsibility N/A Mr. Noel O Connor (Environmental Officer) It is an ongoing objective of the company to maintain compliance with all conditions of the IPPC licence. All operational measures/procedures and inspections will be continued during 2008 to ensure compliance with the licence. Step OT1 Ongoing environmental management as per IPPC licence (P ). Ongoing implementation of environmental management procedures and inspections. Target date Up until point of closure in 2009 Environmental Efficiency (Ire) Ltd 33

34 Objective Number Objective Title OT2 OT2 Rationale To ensure the closure of the site is carried out in accordance with all environmental legislation and to ensure that no risk to the environment arises from the decommissioning of the manufacturing site. Target date Up until point of closure in 2009 Target Responsibility All decommissioning procedures are carried out in accordance with legislation and no environmental risk arises during decommissioning of the site. Mr. Noel O Connor (Environmental Officer) Mr. Kevin Dempsey (Engineering Manager) Step OT2 Target date Submit closure plan to the Environmental Protection Agency completed All documentation relating to the transfer/sales of equipment must be maintained on site for inspection. All wastes generated during decommissioning must be transferred to authorised waste contractors. All documentation relating to the transfer of wastes must be maintained on site for inspection. The decontamination of equipment (removal of oil) must be carried out in bunded areas. Underground surface water and foul water pipes must be inspected and cleaned. Certification of cleaning must be available on site for inspection All bunded areas on site must be inspected and cleaned. As above certification of cleaning from an authorised waste contractor must be available on site for inspection. All information as requested by the agency in letter dated 11 th February 2008 EPA reference P /gc25djm must be submitted as part of exit audit. Ongoing during closure May 2009 May 2009 Ongoing prior to closure Environmental Efficiency (Ire) Ltd 34

35 Objective Number Objective Title Rationale Target date Target Responsibility OT3 Water Energy and Waste ( Use of natural resources) Best environmental practise with long-term economic benefits. Ongoing Ensure no increase in Hazardous and non hazardous waste generation in 2009 up until point of closure (please note this does not refer to any wastes generated as part of the closure procedure for the site). Maintain recovery rate of wastes. Mr. Noel O Connor (Environmental Officer) Mr. Stephen Diamond (Maintenance Manager) Steps OT3 Target Ongoing implementation of environmental management procedures and inspections during Regular reviews of consumption figures. Ongoing implementation of staff awareness procedures to ensure no wastage of water, energy and no raw materials. All these will be carried out prior to closure. Ongoing Environmental Efficiency (Ire) Ltd 35

36 7 Licence Specific Reports (IPPC licence P ) 7.1 Pollution Emissions Register (PER) 2008 A copy of the Web based PRTR reporting excel sheet has been uploaded to the EPA web page. 7.2 Noise Monitoring Report 2008 Environmental Efficiency Consultants Limited (EEC) was commissioned by Allergan. to carry out an environmental noise survey on their site in order to assess the level of noise generated by the site during normal operating conditions. This environmental noise survey was carried out on the 17 th of December NSL4, NSL5 and NSL6 were below those limits set out by the local authority for daytime noise, however was above those limits set out by the local authority for night time noise. Nonetheless, there was a lot of audible noise from outside sources that can be attributed to higher noise levels, most notable the presence of cars passing on the roads. It would be impossible to determine whether these noise levels, above the limits set out, are solely due to noise generated at the Inamed site. There was a tonal noise frequency present when samples were taken from one of the noise sensitive locations. At NSL5, tonal noise was present at the following frequency during the daytime sample, 1.01kHz. During the night time sampling, there were no tonal noise frequencies recorded at any of the monitoring locations. Thus, tonal noise was recorded at one of the noise sensitive locations at the McGhan Limited t/a Allergan site during the day time survey. However, it is difficult to establish the exact source of the tonal noise. The Leq15 readings were below the limits set out by the local authority for daytime noise but above the limits set out for night time noise. However, it can not be concluded whether these elevated noise levels are emanating from the McGhan Limited t/a Allergan site as there were a number of outside sources attributing to the noise levels, most notably the passing of cars. Relevant staff at McGhan Limited t/a Allergan had identified the thermal oxidiser as the probable noise source on site and this is likely to be the main cause of the disturbance. Other possible sources include noise from the soak room fan and noise from the refrigeration unit at the Glenhaven plant nearby. Following this survey it is apparent that both the thermal oxidiser at McGhan Limited t/a Allergan and the refrigeration unit at Glenhaven are responsible for the tonal noise disturbing the neighbouring residence. In response to the noise survey carried out in 2007 McGhan Limited t/a Allergan engaged a specialist acoustic noise company, who installed acoustic panelling around the RCTO valve set in order to reduce noise. Environmental Efficiency (Ire) Ltd 36

37 Environmental Efficiency (Ire) Ltd 37

38 7.3 Solvent Management Plan/ Fugitive Emissions Programme A Solvent Management Plan was documented for the site (Document number v2.00). This plan used a mass balance to calculate the percentage fugitive emission levels. The fugitive emissions were calculated at 1.4%, therefore the company is compliant with Condition of the company s IPPC licence i.e. ensure fugitive emissions losses to within 20% of the total solvent input. A copy of the solvent management plan is provided in Appendix 4 of this report. Environmental Efficiency (Ire) Ltd 38

39 7.4 Programme for public information A programme for public information has been implemented. This programme is subject to continual review and regular updating to ensure it is fully comprehensive and representative of all relevant measures and environmental effects/issues. The measures contained in the programme are outlined in Table 7-1 below: Table 7-1 Programme for public information Measures Notice/Bulletin boards Maintenance of information notice board to include: Opening hours Phone numbers and names of various relevant personnel: site manager, environmental/health and safety manager etc. Licence reference number Communications programme Ensure all environmental information is available on request to public: Monitoring Results Pollution Emissions Register Public Complaints procedure Ensure complaints record form is available from reception Progress to date Completed Completed all information documented and stored in public access folders, the information is stored with the Environmental Officer. Complaints record form is available from reception. Environmental Efficiency (Ire) Ltd 39

40 7.5 Environmental Improvements on site during 2008 and financial provisions A statement of measures in relation to the prevention of environmental damage and remedial actions (environmental improvements 2008) is provided in Table 7-2 below: Table 7-2 Environmental Improvements on site Measures Operation and maintenance of RCTO during 2008 to ensure compliance with emissions limits values as prescribed by IPPC licence. Implementation of Objectives & Targets 2008 Training All staff and new employees are provided with appropriate training relevant to the individual s particular job description. Records of training are kept and updated as appropriate Equipment maintenance All equipment in use is regularly checked in order to identify and remedy any faults, which may compromise the health and safety of staff or have a negative impact on the environment. Environmental Monitoring Emissions to sewer and emissions to air are monitored regularly as required by the IPPC license (Reg. No. P ) Every effort is made to ensure emissions are within emission limit values. Investigations into nonconformances and corrective actions are put in place if emission limit values are exceeded. Installation of continuous monitoring as required on RCTO and emissions to sewer Implementation of energy conservation Progress to date Completed Ongoing Ongoing Ongoing Ongoing Ongoing Environmental Efficiency (Ire) Ltd 40

41 Measures programme (for gas and electrical and water) during Progress reports available for inspection on site. Progress to date There was financial allocation/spend by McGhan Ltd. t/a Allergan towards improving and protecting the environment throughout Environmental Efficiency (Ire) Ltd 41

42 7.6 Environmental Liabilities Under condition 12.3 of their IPPC licence, McGhan Limited t/a Allergan in our AER report must report on: measures taken or adopted at the site in relation to the prevention of environmental damage, and the measures in place in relation to the underwriting of costs for remedial actions following anticipated events (including closure) or accidents/incidents, as may be associated with the carrying on of the activity Prevention of Environmental Damage McGhan Ltd. t/a Allergan have undertaken measures to prevent any environmental damage arising at the site. There are a number of emission points on site. They are as follows, emission to sewer, emission to atmosphere and boiler emissions Emission to Sewer The emission to sewer from the site is completely licenced and monitored under the conditions of their IPPC licence. There is also a rigorous monitoring programme that analyses effluent samples for a number of parameters. Depending upon the parameter, monitoring is either, continuous, monthly or quarterly. This stringent monitoring programme ensures effluent being discharged to sewer is monitored. See Table 3-1 for the details on the monitoring programme for emission to sewer Emission to Atmosphere The emission to atmosphere is monitored under the conditions of their IPPC licence. Inclusive to this, in 2007, McGhan Limited t/a Allergan installed an RCTO to ensure emission limit values are in compliance with those prescribed in their IPPC licence. Depending upon the parameter, monitoring is undertaken either continuously, or quarterly. This monitoring programme is displayed in full in Section and Table 3-3. Environmental Efficiency (Ire) Ltd 42

43 Boiler Emissions Boiler emissions are monitored as part of their IPPC licence conditions. This is undertaken on an annual basis. See Section Hazardous Materials All hazardous materials are stored in bunded areas to prevent any contamination of soil and watercourses Waste All waste on site, hazardous and otherwise is collected by licensed waste contractors. Hazardous waste is never mixed with non-hazardous waste and waste never stays onsite for longer than 6 months Remedial Action In January 2008, McGhan Limited t/a Allergan announced the proposed closure of the manufacturing site and as such have submitted a cessation plan to the EPA. This plan covers measures in place in relation to the underwriting of costs for remedial actions following the closure of the site. At present, McGhan Limited t/a Allergan have ceased their shell fabrication manufacturing activity on the 30 th January 2009 and shut down their abatement equipment on Wednesday the 4th February The site will be completely decommissioned by the end of March Environmental Efficiency (Ire) Ltd 43

44 Appendix 1Emissions to Sewer; Certificates of Analysis Environmental Efficiency (Ire) Ltd 44

45 Environmental Efficiency (Ire) Ltd 45

46 Environmental Efficiency (Ire) Ltd 46

47 Environmental Efficiency (Ire) Ltd 47

48 Environmental Efficiency (Ire) Ltd 48

49 Environmental Efficiency (Ire) Ltd 49

50 Environmental Efficiency (Ire) Ltd 50

51 Environmental Efficiency (Ire) Ltd 51

52 Environmental Efficiency (Ire) Ltd 52

53 Environmental Efficiency (Ire) Ltd 53

54 Environmental Efficiency (Ire) Ltd 54

55 Environmental Efficiency (Ire) Ltd 55

56 Appendix 2 Air Monitoring 2008 Certificates of Analysis Environmental Efficiency (Ire) Ltd 56

57 Environmental Efficiency (Ire) Ltd 57

58 Environmental Efficiency (Ire) Ltd 58

59 Environmental Efficiency (Ire) Ltd 59

60 Environmental Efficiency (Ire) Ltd 60

61 Environmental Efficiency (Ire) Ltd 61

62 Environmental Efficiency (Ire) Ltd 62

63 Environmental Efficiency (Ire) Ltd 63

64 Environmental Efficiency (Ire) Ltd 64

65 Environmental Efficiency (Ire) Ltd 65