annual environmental report jan - dec 2008 · table 6. synopsis of airflow rate ultrafloss a2 -1...

Braun Oral-B , Ireland of 36 Licence Register P0297-02 Annual Environmental Report Date: April 2009

Annual Environmental Report

Licence Number: P0297-02

Braun Oral-B Ireland Ltd. Green Road,

Newbridge, County Kildare.

AER 2008 Peadar Donnelly April 2009


Table of Contents Section 1 Introduction Page Number 1.1 Introduction 5 1.2 Environmental Policy 6 Section 2 Background & Current Status 2.1 General description of company activities 7 Section 3 Data 3.1 Emissions to atmosphere summary 9 3.1.1 Super floss emission to air (A2-2) 9 3.1.2 Ultra floss emissions to air (A2-1) 10 3.1.3 Ultra floss emissions to air (A3-9) 11 3.2.1 Emissions to Sewer (SE6) 13 3.2.2 Emissions to surface water (SW1) 14 3.3 Waste Management 14 3.4 Noise Summary 16 3.5 Resource Consumption Summary 18

3.5.1 Energy 18

3.5.2 Water 19 3.6 Environmental Incidents & Complaints 19 3.7 Environmental Expenditure 19

Braun Oral-B , Ireland of 36 Licence Register P0297-02 Annual Environmental Report Date: April 2009 Section 4 Pollution Emission Register 4.1 Ultra floss Process 20 4.2 Method of measurement 20 4.2.1 How mass balance for each material was calculated 20 4.2.2 Methods of measurement for mass balance 20 4.2.3 Accuracy of analysis 21

4.3 PER proposal 2008 21

4.4 Summary of PER tables 22

Section 5 Environmental Management Programme 23 5.1 Objectives & Targets, the Braun Oral-B approach 5.1.1 Review of EMP 2008 24 5.1.2 EMP Objectives 2009 25 Section 6 Appendices 26 1 Process water estimation 26 Waste graphs for 2008 27 3 Annual Noise Survey Report (BNM report no ECS3207-Noise-Dec08) 29 4 Report surface water/effluent QTR1 2008 (BNM report no.: 17043) 30 5 Report surface water/effluent QTR2 2008 (BNM report no.: 18402) 31 6 Report surface water/effluent QTR3 2008 (BNM report no.: 19504) 32 7 Report surface water/effluent QTR4 2008 (BNM report no.: 20723) 33 8 Report on air emissions 1st biannual 08 (BNM report no.:ECS2978) 34 9 Report on air emissions 2nd biannual 08 (BNM report no.:ECS3179) 35 10 AER / PRTR Returns Worksheet 2008 36

Braun Oral-B , Ireland of 36 Licence Register P0297-02 Annual Environmental Report Date: April 2009 List of tables & figures Table 1. Synopsis of Superfloss A2-2 TOC Emissions to Atmosphere Jan - Dec 2008 9 Figure 1.TOC emissions from Superfloss A2-2 Process vs. ELV Jan - Dec 2008 9 Table 2. Synopsis of Superfloss A2-2 TDI Emissions to Atmosphere Jan – 2008 10 Table 3. Synopsis of airflow rate Superfloss A2-2 Jan - Dec 2008 10 Table 4. Synopsis of TA Luft Class 1 Testing Superfloss A2-2 10 Table 5. Synopsis of Ultrafloss A2-1 TOC Emissions to Atmosphere Jan - Dec 2008 10 Figure 2.TOC emissions from Ultrafloss A2-1Process vs. ELV Jan - Dec 2008 11 Table 6. Synopsis of airflow rate Ultrafloss A2-1 Jan - Dec 2008 11 Table 7. Synopsis of TA Luft Class 1 emissions Ultrafloss A2-1 Jan - Dec 2008 11 Table 8. Synopsis of Ultrafloss Winding A3-9 TOC Emissions to Atmosphere 11 Figure 3.TOC emissions from A3-9 Ultrafloss Winding Process vs. ELV Jan – Dec 2008 12 Table 9. Synopsis of airflow rate Ultrafloss Winding A3-9 Jan - Dec 2008 12 Table 10. Emmission to sewer (SE6) Summary Jan - Dec 08 13 Table 11. Emission to sewer summary SE6 13 Figure 4. Emissions to sewer. SE6. Concentrations Vs IPPC licence limit 13 Table 12. Summary of surface water discharge monitoring results for SW1 14 Table 13. Annual Waste Arising - Hazardous Waste 15 Table 14. Annual Waste Arising - Non-Hazardous Waste 15 Table 15. National Waste Database Report Sheet 16 Table 16. Site Boundary Noise Levels 17 Table 17. Electricity usage 1999 to 2008 18 Table 18. Gas Usage 1999 to 2008 18 Table 19. Water Consumption 1999 to 2008 19 Table 20. Expenditure on Environmental Protection January-December 2008 19 Table 21. Pollution Emissions Register Form: Ultrafloss 22 Figure 5. Waste generated versus units shipped 1995 to 2008 27 Figure 6. Total solid waste in tonnes 1995 to 2008 27 Figure 7. Tonnes of cardboard recycled 2008 28

Braun Oral-B , Ireland of 36 Licence Register P0297-02 Annual Environmental Report Date: April 2009 Figure 8 Tonnes of plastic recycled 2008 28 1.0 Introduction

This Annual Environmental Report (AER) has been drafted in accordance with the EPA Guidance Note

for AER’s and is submitted in order to comply with the requirements of Schedule 5(i), “Recording and

Reporting to the Agency”, of the Braun Oral-B IPC Licence, Reg. No. P0297-02. This AER covers the

period January to December 2008

The following items are included in this report:

• Summary of emissions to atmosphere

• Summary of emissions to sewer

• Waste management report

• Noise summary

• Resource consumption summary

• Energy usage

• Water usage

• Environmental incidents and complaints summary

• Pollution Emission Register (PER)

• Environmental management programme report for 2008

• Schedule of objectives and targets for 2008

Braun Oral-B has developed its environmental policy as part of its environmental management system.

Braun Oral-B has been registered to the ISO 14001 Environmental Management Systems standard since

1996. Braun Oral-B’s environmental policy is outlined in the next section.


P & G Braun Oral-B

Environmental Policy

Revision: 7 ENVIRONMENTAL POLICY Revision Date: 10/04/08 The core business of P & G Braun Oral B Ireland is the manufacture and distribution of Toothbrushes and Dental Floss. These products are distributed globally. Among the stated values of P & G Braun Oral-B Ireland are the following: • That our products will be safe to make, use and ensure that all our products, packaging and operation are

safe for our employees, consumers and the environment. • We will conserve natural resources and we will continue to invest in a better environment. • It is our belief that what is good for the environment, is good for P & G Braun Oral-B, our customers, our

employees and the communities we serve. • The challenge is to achieve a high quality environment without deterring economic purpose. To this end,

the company is committed to continuous improvement - “prevent, reduce, and recycle” - at all levels throughout the organisation.

To sustain continuous improvement and meet its obligation to the environment, P & G Braun Oral-B will: ♦ Measure, reduce and prevent the environmental impact, of our products and packaging in their design,

manufacture, distribution, use and disposal where possible. ♦ Meet or exceed all the relevant laws, Regulations and Directives, at Local, National and International

levels, meet the requirements of IPPC License No. P0297-02 issued by the Environmental Protection Agency and to comply with P & G’s Braun Oral B Environmental Policy.

♦ Develop and follow an Environmental Management System in accordance with ISO14001 and Internal P &

G requirements. ♦ Determine and prioritise the significant effects of the operation. Currently, the most significant

environmental aspect is energy usage. ♦ Establish objectives, with defined plans and targets for achievement, to reduce P & G Braun Oral-B’s

impact on the environment and monitor progress towards environmental goals. ♦ Continually assess and improve the effectiveness and performance of the Environmental Management

System, by way of Internal Audit and Management Review. ♦ This policy will be subjected to annual review per QSI document control system ♦ Communicate this policy to all working for or on behalf of the company, and participate in educating and

motivating our business associates towards a more environmentally interactive industrial sector. ♦ Promote protection of the environment and conservation among fellow citizens in industry and

government. ♦ Signed:____________________________ Date:______________ Mark Masterson Managing Director, P & G Braun Oral-B Ireland

Note: The originals are signed and on display in all reception areas.

Braun Oral-B , Ireland of 36 Licence Register P0297-02 Annual Environmental Report Date: April 2009 2.0 Background & Current Status 2.1 General Description of Company Activities at Braun Oral-B

The manufacturing facility located at the IDA Business Park, Newbridge was established in 1984. Braun

Oral-B now employs approximately 320 people. Braun Oral-B is involved in the oral dental care

industry. The main activities on-site are the manufacture of toothbrushes and dental floss.

Toothbrush Manufacture:

Braun Oral-B is one of the largest toothbrush producers in Europe. Newbridge produces all the Oral-B

premium manual toothbrush products including Vitalizer, Pulsar and Cross Action.

Products are produced by utilizing breakthrough technology including Multi Colour Injection Moulding

and Automated Cellular Manufacturing. Braun Oral-B manufactures around 160 million toothbrushes

every year.

Dental Floss:

Braun Oral-B also manufactures Dental Floss. This involves the extrusion of polymers into yarn,

spinning of this yarn, application of molten wax and flavourings. Following the coating process the yarn

is wound into creels and sent to our sister company in Mexico for final packaging. Braun Oral-B also

produces specialist floss products called Superfloss & Ultrafloss.

Superfloss Manufacture:

Superfloss is a specialist floss product designed to aid dentists in the cleaning of orthodontic appliances.

The Superfloss manufacturing process is a solvent free process. The Solvent free line was introduced in

the latter half of 2003.

Ultrafloss Manufacture:

Ultrafloss is a specialist product with an expanded brush-section. The characteristics of the yarn are

achieved through the use of resins, which are suspended in organic solvents.

QS1 Document N3088/environmental policy


General overview of changes, January to December 2008

• The plant is now part of the Procter and Gamble group of companies.

• ICMS 4 Cell installed ( Toothbrush manufacturing Cell)

• Vitalizer Project has been commissioned and is now in full production.

(Vitalizer is a top end manual toothbrush)

• Plant divided into two separate Value Streams. Value Stream is a self contained manufacturing

centre.

Value Stream 1 . Ciaran Mc Carthy appointed VS1 Manager

Value Stream 2 Eamonn Redmond appointed VS2 Manager

• Introduction of the Procter and Gamble production system IWS. (Integrated Work Systems)

Newbridge designated Phase1 IWS site following successful corporate audit

• Mark Masterson appointed Managing Director P&G Braun Oral B Ireland and Braun Oral B

Carlow.

• Procter & Gamble set 5 year corporate Sustainability targets.

• Unannounced site inspection by EPA Inspector J McEntagart May 9th 2008. No non compliance

raised.

• Successful ISO 14001:2004 recertification audit

Overview on Agency Protocol for the Bypass of Air Emmission Abatement Equipment

In September 2008 the EPA provided a protocol for the bypass of Air Emission Abatement Equipment . This

protocol outlined actions required by licensees to ensure that procedures are in place to include criteria for

assessment of both the potential bypass emission points and the likely impact on the ambient atmosphere.

Air Emission Abatement Equipment is not part of Braun Oral-B Ireland Ltd operations, therefore bypass events

can not occur on site.


3.0 Data

3.1 Emissions to Atmosphere Summary All sampling and analysis is conducted in accordance with NIOSH standard air monitoring methods.

TMS Analytical Ltd, conducted all air sampling. The method of collection for the Volatile Organic

Emissions testing was adsorbent trapping with subsequent thermal desorption analysis via GC-FID. TDI

is trapped onto a pre-treated filter and analyzed via HPLC. Sampling is conducted using calibrated pumps

traceable to a commercial standard calibration cell. The chromatographic systems were calibrated by

generating calibration curves for the target analytes while running blank samples and controls.

Braun Oral-B is required to test two air emission points: Superfloss (A2-2), Ultrafloss (A2-1) The

Agency has agreed that Ultrafloss winding (A3-9) emission point no longer requires testing as the

winding operation concerned was moved to Mexico in 2004. This was confirmed in your letter Ref:

P0297-02/ap03djm.doc which was received November 2008 .

However Superfloss (A2-2) emission point has virtually no emissions due to the installation of the solvent

free process in late 2003. Monitoring of both A3-9 and A2-2 Emission points was carried out in 2008.

3.1.1 Superfloss Emissions to Air (A2-2) Table 1. Synopsis of Atmospheric Emissions for the Superfloss Process Jan – Dec 08

Emission Point Stack A2-2 Test dates

IPPC Limit TOC (mg/m3)

Concentration (mg/Nm3)

Estimated max. mass TOC flow

(kg/hr)

% compliance

May 2008 75 0.5 8.1 x 10-4 100

December 2008 75 < 0.06 < 1.2 x 10-4 100

Average 75 0.28 0.001

Emission point A2-2

Calculation TOC Mass Emissions*

(kg) Max IPPC TOC

Limit (kg) %

compliance

Estimated TOC for 2008

220hrs2 x 0.001

0.23 kg 9526 100

1 Values preceded with a less than sign “<” indicate that the value is below the limit of detection of measurement process.

2 Based on 220 hours. Mixing of Superfloss 175 mixes at 75 min per mix.


1

TOC MaxEmissions (kgs)

Max IPC TOCLimit (kgs)

0

2000

4000

6000

8000

10000

Mass TOC

A2-2 Superfloss TOC Emissions to atmosphere V's IPPC limit Jan-Dec 08

TOC Max Emissions(kgs)

Max IPC TOC Limit(kgs)

Figure 1:A2-2 Superfloss TOC emissions to atmosphere versus IPPC limit: Jan to Dec 08

Table 2. Synopsis of TDI emissions to atmosphere Superfloss

A2.2 Date TDI (as NCO group) in kg/hr

Estimated TDI total kg Jan-Dec 2008*

November 06 <0.03 Average <0.03 6.60

*Based on 220 hrs. Please note that no licence limit applies to TDI emissions.

Table 3. Synopsis of airflow rates Superfloss

A2.2 Date IPPC licence limit Nm3/hr

Airflow rate Nm3/hr % Compliance

May 2008 14500 1671 100 Dec 2008 14500 1816 100

Table 4. Synopsis of TA Luft Class 1 Testing Superfloss A2.2 Test date IPPC Licence limit Measurement % Compliance May 2008 20 mg/m3 < 3.4mg/m3 100

Braun Oral-B , Ireland of 36 Licence Register P0297-02 Annual Environmental Report Date: April 2009 3.1.2 Ultrafloss Emissions to Air A2-1 Table 5: Synopsis of Atmospheric Emissions for the Ultrafloss Process Jan - Dec 2008


IPPC Limit TOC (kg/hr)

Max. Mass TOC Flow (kg/hr)

Concentration mg/Nm3

% compliance

May 2008 1.5 0.87 53.7 100 December 2008 1.5 < 1.1x10-3 < 0.06 100 Average 1.5 0.435 26.88 100

Emission point A2-1

Calculation TOC Mass Emissions1

Max IPPC TOC Limit

% compliance

Total TOC for this period

15064 hrs x 0.435 2203 kg. 13140 kg 100

1Based on 5064 hours. 24 Weeks, 4 day week at 24 hours plus 23 weeks,5 day week at 24 hours. 1 Values proceeded with a less than sign “<” indicate that the value is below the limit of detection of

measurement process.

1

TOC MaxEmissions (kgs)

Max IPC TOCLimit (kgs)

0

5000

10000

15000

Mass TOC

U/floss TOC Emissions A2-1 V's IPPC Limit Jan-Dec 08



Figure 2: A2-1 Ultrafloss TOC emissions to atmosphere Vs IPC limit: Jan - Dec 2008

Table 6. Synopsis of airflow rates Ultrafloss A2.1

A2.1 Test date IPPC licence limit Nm3/hr

Airflow rate Nm3/hr % Compliance

May 2008 21000 16,272 100 December 2008 21000 17,124 100

Table 7. Synopsis of TA Luft Class 1 Testing Ultrafloss A2.1 A2.1 Test date IPPC Licence limit Measurement % Compliance May 2008 20 mg/m3 < 4.4 mg/m3 100 December 2008 20 mg/m3 < 0.17 mg/m3 100

3.1.3 Ultrafloss Winding Emissions to Air A3-9

Braun Oral-B , Ireland of 36 Licence Register P0297-02 Annual Environmental Report Date: April 2009 Table 8: Synopsis of Atmospheric Emissions for the Ultrafloss Winding Jan - Dec 2008


IPPC Limit TOC

(mg/m3)

Concentration mg/Nm3

Max. mass TOC flow (kg/hr)

% compliance

May 2008 150 < 0.1 < 3.3 x 10-5 100

Average 150 < 0.1 0.000033 100

Emission point A3-9

Calculation TOC Mass Emissions*

(kg) Max IPC TOC

Limit (kg) %

compliance

Total TOC for period

5640 x 0.00003

0.19 kg 4467 100

• Based on 5640 hours. 47 weeks at 24 hours. (5 day week). **The Agency has agreed that emissions to A3-9 do not require further monitoring as the process concerned has been relocated to Mexico since 2004 Values proceeded with a less than sign “<” indicate that the value is below the limit of detection of measurement process.

Fig. 3: A3-9 Ultrafloss Winding TOC emissions to atmosphere Vs IPPC limit: Jan - Dec 08

1



0

1000

2000

3000

4000

5000

Mass TOC

U/Floss A3-9 Winding V's IPPC Limit Jan -Dec 08



Table 9. Synopsis of airflow rates Ultrafloss Winding

A3.9 Test date IPC licence limit

Nm3/hr Airflow rate Nm3/hr % Compliance

May 2008 3400 328 100


3.2 .1 Emissions to Sewer Table 10: Emissions to Sewer (SE6) Summary 2008

Date COD mg/l

BOD mg/l

SS mg/l

pH OFG mg/l

% Compliance

Quarter 1 406 141 96 7.6 28 100 Quarter 2 251 105 < 5 7.3 < 1 100 Quarter 3 1162 825 14 6.4 5 100 Quarter 4 133 5 118 7.9 < 1 100

Average 488 269 58 7.1

9

IPC licence Daily mean conc. 8000 mg/l 4000 mg/l 4000 mg/l 6 – 9 200 mg/l

Mass flow Kg/annum*

198.2 kg 109.2kg 23.5 kg ~ 3.55 kg 100

IPC Licence 8760 kg 4380 kg 4380 kg ~ 219 kg • Based on a 329 day year and an average consumption of 1,232 litres per day. ( 405328 litres /Year)

The consumption figure of 1,232 litres / day was based on a typical production period between March 05 to April 05. See analysis appendix 1.

Table 11: Emissions to Sewer (SE6)

02000400060008000

10000

CODmg/l

SSmg/l

OFGIPC Licence

IPC Licence

Mass flow kg/ annum

Emissions to sewer (SE6) Jan - Dec 08Mass flow versus IPPC ELV

Figure 4 Emissions to sewer SE6 Jan – Dec 2008 Mass flow total Vs IPPC licence limits. The total volume of floor-washing water, which is sent to sewer daily, is between 140 and 160litres per day. Given the nature of the product that is produced on-site Braun Oral-B must wash the floor areas daily. There are no large volume aqueous based floss or toothbrush processes remaining at the Braun Oral-B facility. Steam is used on a very small scale for “bulking” Ultra and Super floss products. Water is also used on a very small scale for cooling of Satin Floss extrusion Kildare County Council receives the trade effluent.


3.2.2 Emissions to Surface Water Braun Oral-B surface water discharges at SW1 in accordance with condition 9 and schedule 4 (i) of the IPPC

licence (Reg.No. P0297-02).

Non-process water consists of:

� Storm water from roofs

� Surface water run-off from car parks and paved areas

Surface water discharges at SW1 are measured on a quarterly basis for pH, BOD, suspended solids. A visual

inspection takes place weekly. A summary of the surface water discharge monitoring results is presented in

table 12.

Table 12 Summary of surface water discharge for SW1 2008

Parameter Sample date (SW1) Quarter 1 Quarter 2 Quarter 3 Quarter 4

PH 7.5 7.2 7.2 6.7

BOD < 2 mg/L < 2 mg/L 68 mg/L 9 mg/L

Suspended solids 7 mg/L < 5 mg/L 10 mg/L < 5 mg/L

No licence limits apply to the parameters above.

3.3 Waste Management

Braun Oral-B maintains full details and records of all waste arising on-site in accordance with condition 7 of

it’s IPC Licence. This section of the AER provides comprehensive information regarding these wastes. Data is

presented in tabular form where possible to facilitate the presentation of data as outlined in the Agency’s ‘

Guidance Note For Annual Environmental Report ‘. All data in succeeding tables relates to reporting period

January to December 2008 inclusive.

No licence limits apply to the above parameters.

Data for all hazardous and non-hazardous waste for the period January to December 2008 has been summarised

in the following tables. All hazardous waste materials are disposed / recycled in accordance with all relevant

legislation and through Agency approved waste contractors.


Table 13: Annual Waste Arisings January to December 2008 - Hazardous Waste

Waste EWC Source (000) kgs Disposal or recovery option

Method Location Contractor

Solvents and solvent mixtures plus chemicals

160508 Floss manafacture 1.620 D10 Off-site Germany Indaver Irl Ltd.

Contaminated cleaning rags

150202 Cleaning of

printers 0.720 D10 Off-site Germany Indaver Irl Ltd.

Empty drums 150104 Floss Production 4.1652 R4 Off-site ROI Rilta Env. Ltd

Fluorescent bulbs

100121

Factory Illumination

0.1563 R4 Off-site ROI Irish Lamps Ltd

Hydraulic oil

130111 Moulding machinery

1.318 R9 Off-site ROI Enva Ltd

Waste Toothbrush with

battery 160305

Toothbrush production

2.000 D10 Off-site Germany Indaver Irl Ltd.

Total 2008 9.979

2 253 Steel drums @ 15 kg/drum and 37 @ 10kg. 3 Approx 1334 lamps: 0.156 kgs Table 14: Annual Waste Arisings January to December 2008 – Non-hazardous Waste

Waste EWC Source (000) kgs Disposal or recovery option Method Location Contractor

General waste (Compactor, Canteen Bristle grinding dust)

200301

Production

/Facility 69.77 D1

On-site Ireland

AES

Cardboard (for

recycling)

150101

Production

75.75 R5 On-site Ireland

AES

Plastic recycled (moulded handles, brushes.purge mat. Containers / trays etc.)

150104 Production 155.7 R5 On-site Ireland

AES

Wood ( pallets ) Production / Materials


Recycle 2000

Mixed Dry Recyclables 20301 Production/materials


AES

Total 1014.2


Table 15: National Waste Database Report Sheet

Industrial Sector NACE1 Code (two letters and max.

four numbers)

DH 25.4

Reporting period 1/1/08 to 31/12/08

Number of employees (for reporting period) 320 Average

Hazardous 9.979

Non-Hazardous 1014.2

Total tonnage of Waste Produced 1024.2

Hazardous Recovered 5.483

Non-Hazardous recovered 944.43

Total tonnage of Waste Recovered 949.9

3.4 Noise Summary

Braun Oral-B submitted the 2008 Noise Survey report to the EPA, on 16/01/2009, in accordance with condition

8 of its IPC licence (Reg. Number 511). The annual survey was carried out on the 31st November and 11th &

12th December 2008. Bord Na Mona Environmental Ltd. carried out the noise survey. The survey of the site-

boundary noise levels and noise sensitive locations was conducted in accordance with Condition 8 of the IPPC

licence and EPA guidance note, “Noise in relation to scheduled activities”. The following BATNEEC noise

limits are listed under condition 8 for noise sensitive locations: daytime 55dB (A), night-time 45dB (A), (Leq,

15 minutes). A noise tolerance of +2dB(A) is allowed for both day & night-time limits.

� Site location

The Braun Oral-B site is located adjacent to the M7 motorway in the Newbridge Industrial Estate. Five

factories operate in the estate with one containing a factory shop. The estate is accessed from the Green Road,

which is approximately two miles from Newbridge town centre.

� Noise Sources

There are a limited number of noise sources on-site. As the site is located adjacent to the M7 motorway, traffic

noise is the main contributor to background noise levels in the vicinity of the plant. Traffic entering and

leaving the plant during the day are the main contributors to day time noise levels. This traffic enters/exits at

the front of the factory. Traffic noise in Oral-B also includes vehicles visiting the other four plants on the estate

plus members of the public visiting a factory shop.

The main source of process noise is the dust extraction unit and compressors. These are situated at the rear of

the plant.


Summary of Results Table 16. Noise Levels 31st Nov plus 10 th & 11 th December 2008

Location Day LAeq Day LA10 Day LA90 Night LAeq Night LA10 Night LA90 AN1 56.0 57.0 54.0 57.0 57.0 55.0 AN2 53.0 54.0 52.0 55.0 56.0 54.0 AN3 56.0 57.0 55.0 58.0 60.0 57.0 BN1 51.0 52.0 50.0 53.0 54.0 51.0 BN2 66.0 67.0 62.0 68.0 70.0 65.0 BN3 54.0 55.0 53.0 56.0 56.0 55.0 BN4 56.0 57.0 51.0 57.0 58.0 55.0 NS1 60.0 61.0 58.0 NS2 68.0 68.0 67.0 NS3 61.0 61.0 60.0 NS4 63.0 64.0 63.0

AN1a, 2a, 3a refer to noise levels at the boundary wall of neighbouring residences. BN1-4 refers to noise levels at boundaries and NS refers to readings taken 1 metre from noise sources. � Conclusions

Noise emissions from the Braun Oral-B site are continuous in nature. Although the LAeq results for AN1,

AN2 and AN3 exceeded the licence limit, Braun Oral-B would maintain that as the location of the plant

lies in close proximity to the M7 motorway, the main source of noise at these points would be related to

motorway traffic.

The Noise Sensitive Location AN-1a is the closest location to a dwelling house. An Acoustic barrier has

been erected around cooling fans which are situated in this area in February 2008 . It should be noted that

the noise measurement was taken from the Oral-B side of the boundary and that a 2.4 metre perimeter wall

and a tree line lies between the site and the noise sensitive receptor.

The noise measurements for the other 2 noise sensitive locations AN-2a & AN-3awere also taken from the

Oral-B side of the boundary, there is a built up ditch and boundary wall lying between the plant and the

noise sensitive receptors.

� Definitions

LAeq equivalent continuous sound level – the sound level of a steady sound having the same energy

as a fluctuating sound over the specified measuring period (15 minutes).

L10 the A-weighted sound level, which is exceeded for 10% of the sample period, used to

quantify traffic noise.

L90 the A-weighted sound level, which is exceeded for 90% of the sample period, used to

quantify background noise.


3.5 Resource Consumption Summary 3.5.1 Energy

The ratio of energy usage to unit product (000’s) for each of the energy sources is given below. Table 17. Electricity usage 2008 – 2000

Electricity 2008

2007

2006

2005

2004 2003 2002 2001 2000

Total units

17,363 MWh

19,661 MWh

19,157MWh

18,152 M Wh

16,897

MWh

14,053 MWh

15,267 MWh

13,290 MWh

13,085 MWh

Gas Gas Gas Gas Gas Gas Gas Gas Gas Gas

KWh/unit production

0.005

0.052

0.048

0.0676

0.0719 0.0235 0.0297 0.0265 0.0578

2 Data is the number of toothbrushes produced plus dental floss measured in retail units * Note Dental Floss volumes for 2008 is measured in retail units Note Dental Floss volumes for 2008 is measured in retail units rather than per 1000 metres

Table 18. Gas usage 2008 – 2000

1 Data is the number of toothbrushes produced plus dental floss produced measured in retail units

* Note Dental Floss volumes for 2008 is measured in retail units

A primary objective for Braun Oral-B under it’s ISO 14001 Environmental Management System is to reduce energy consumption per unit production. Braun Oral-B have been successful in reducing the energy consumption rate per unit shipped since 2000. This consumption ratio is very much dependent on production levels remaining high. Note Dental Floss volumes for 2008 is measured in retail units rather than per 1000 metres

2008 2007 2006 2005 2004 2003 2002 2001 2000

Gas usage in m3

233016 m3

228106 m3

224,549 184,901 m3 221,269 m3

224,326 m3

227,275 m3

212,531 m3

180,231 m3

Convert m3 to kWh 1m3 = 11.5 kWh

2,679,684

kWh

2,623,219

kWh

2,575,936

kWh

2,181,832.

kWh

2,610,974.

kWh

2,647,047 kWh

2,681,845 kWh

2,507,866 kWh

2,126,726 kWh

Production units

3210.4

375.11

401.9k1

268.3k

235k 552 K 514 K 500K 226K

KWh/unit production

0.0009

0.007

0.006

0.008

0.011 0.005 0.005 0.005 0.009


3.5.2 Water

Kildare County Council are the suppliers of all water to Braun Oral-B. Oral-B has no aqueous based

processes. However water is used in the following processes:

� Cooling of extruded nylon in a bath. The flow rate through the bath is minimal.

� Ultra Floss steam generator

� Vessel washing

� Floor cleaning

The total consumption per annum for these processes is approximately 405M3. All floor surfaces must be

kept to a very high standard given the nature of the business. A contractor is on-site at all times cleaning the

floors / production areas. Toilets, taps and the canteen facilities account for 87% of water usage. All

wastewater is discharged to foul sewer, which is received by Kildare County Council.

Table 19. Water consumption 2008- 1999

2008

2007

2006

2005

2004

2003

2002

2001

2000

1999

Water use in M3

6,799

8,184

7,408

8,265

8,426 6,526 10,31 12,730 8,000 12,70

3.6 Environmental Incidents & Complaints Braun Oral-B Ireland received no complaints, during the year 2008.

3.7 Expenditure

Table 20. Expenditure on Environmental Protection January –December 2008

Item Expenditure (Ä ) EPA licence fees 10,000 ISO 14001 registration and audit fee 4018 Environmental monitoring costs 7412 Environmental protection equipment 14,325 Hazardous waste disposal 9659 Training 3,000 Internal auditing 6,000 Total 54,414


4. Pollution Emission Register

4.1 Ultrafloss Process

Reporting Period: January – December 2008

The following materials have been tracked for Braun Oral-B’s Ultrafloss Process PER:

Annual Usage (MT)

2008 2007 2006 2005 2004 2003 2002 2001

Methanol 5431 8983 8.838 10.60 11.87 8.255 8.304 7.268

Ethanol 0.00 0.00 0.00 0.00 0.638 0.612 0.430 0.810

Total 5431 8.983 8.838 10.60 12.50 8.87 8.08 8.73

4.2 Method of Measurement Material usage was tracked by the inventory management system. Process waste identification and

quantification was determined via Gas Chromatography. Emissions to air were determined directly by

analysis of stack emissions though the emissions point A2-2, A2-1 and A3-9. This is monitored biannually

and determined via GC-MS and GC-FID.

4.2.1 The mass balance for each material was calculated using the following

Input = Raw material ( Gental E87A) used in the manufacture of Coat 10 and Coat 23.

Output = Emissions to air through point sources + bulk solvent process waste + Residual solvent in product + Fugitive emissions.

Note: No recovered or recycled materials are used in the process.


4.2.2 Methods of measurement for the mass balance were as follows;

� Direct measurement of air emission flue gas at stack A2-1, A2-2 & A3-9 by external laboratory.

� All monitoring was conducted in accordance with standard NIOSH methodologies.

� All the chemicals that Braun Oral-B is required to monitor for the purpose of the AER are

organic solvents.

� The method of measurement for organic substances is to capture an air sample at the extract duct

on the roof. This air sample is passed through a charcoal tube. This tube which contains a

representative volume of extract air and contaminant is desorbed before passing through an

analytical device.

4.2.3 Accuracy of analysis

� The accuracy of sampling is dependent on the following:

� Ratio of the flow rate of organic solvent to flow rate of extract air in duct

� Flow rate of the air in the duct, generated by the fan

� The duration of the sample

� The volume of the impinger

� Efficiency of distilled water and charcoal tube desorption i.e. overloading of tubes,

isokinetics of chemical molecules.

� Possible deposition of chemicals in the ducting

� Process analysis variables of GC-FID & MS processes.

� In general, the more samples that are taken, the accuracy increases. Braun Oral-B takes 2

samples every year from 3 stacks as per schedule 1(i).

� From 2009 onwards Braun Oral – B will take 2 samples per year from 2 stacks. This has been

agreed by the Agency as Stack A3-9 is no longer in use, due to the transfer of the process

associated with the stack to Mexico in 2004.

4.3 PER Proposal for 2008 Methanol was tracked during 2008. Gental E87A is used in the manufacture of Coatings for Ultra Floss production. This is the source of the methanol tracked. Methanol is the main constituent of Gental E87 A. (<80%).


4.4 Summary of PER tables Table 21 Pollution Emissions Register Form: Braun Oral-B Ireland Limited. Ultra floss.

Pollution Emissions Register Form: Braun Oral-B Ireland Limited. Note: All figures below are in Kgs.

Ultrafloss Outputs (kg/year)

Pollutant Name CAS No. Gross

Usage Air MOM Liquid Effluent MOM Waste MOM Product MOM Recovery MOM Unaccounted

Methanol 67-56-1 5,431 5230 E - - - E - - . E 201

-

MOM: Method of Measurement. This refers to the method used in determining losses to Air, Water and Land. The following codes are to be used to demonstrate the method used: Method Code Method Code Direct Measurement M Material Balance B Engineering Estimates E Other O

Note: Estimated Methanol on the product is not included in the AER / PRTR Returns Worksheet (See Appendix No 10)

Braun Oral-B Ireland of 36 Licence Register P0297-02 Annual Environmental Report Date: April 2008

5. Environmental Management Programme Braun Oral-B achieved re-certification to the ISO 14001-2004 Environmental Management System

(EMS) standard in April 2008. One surveillance audit was successfully completed in October 2008. The

audits were performed by SGS. Ltd. Braun Oral-B has implemented an EMS and complies with the

requirements of Condition 2.1 of the IPPC Licence P0297-02

The EMS consists of the following elements:

Environmental Manual, Register of Environmental Aspects, Environmental Operational Control

Procedures, Register of Environmental Legislation, Pollution Emissions Register (PER), Program for

Public Information, Internal Audit Schedule and Environment Management Programme (EMP). The

EMP incorporates all objectives and targets.

The schedule of Environmental Objectives and Targets has been developed by Braun Oral-B and agreed

with the EPA in accordance with Condition 2.2 of the IPPC Licence. The EMP also outlines the means

by which the Objectives and Targets may be achieved and the time scales involved and persons

responsible in accordance with Condition 2.3 of the IPPC Licence. The EMP is revised and updated as

required.

The EMS documentation system complies with Condition 2.5 of the IPPC Licence. Braun Oral-B has a

procedure for corrective-action, in accordance with Condition 2.6 of the IPPC Licence. Procedures are

also in place for ensuring environmental awareness and training is carried out in accordance with

Condition 2.7 of the Licence. Programmes and procedures are in place to ensure effective

communication on environmental performance with the public and the EPA, in accordance with

Condition 2.9 of the IPPC Licence.

5.1 Objectives & Targets, the Braun Oral-B approach

Under the framework of the environmental management system, Braun Oral-B has achieved numerous

internal targets and objectives. The focus of these objectives was to minimise the potential impact of

the company on the surrounding environment and increasing the efficiency of natural resource

utilisation. The objectives and targets involved the following activities energy use reduction,

environmental awareness training, packaging waste reduction and noise reduction,.


5.1.1 Review of the EMP 2008 objectives

1 Achieve recertification of ISO 14001-2004 Environmental standard.

Completed P Donnelly/O Hopkins

2 Support P&G corporate sustainability strategy. This strategy is to reduce the environmental footprint of

our own operations. The goals for this program are :

10% reduction in CO2 emissions

10% reduction in energy use

10% reduction in water use

10% reduction in solid waste

These reductions are per production unit and based over a 5 year period. The core objective for the

Newbridge plant for 2008 is to support Corporate HSE to set plant baselines during 2008. This

baseline will then be used as a measure to help track improvements over the next 5 years.

The Sustainability targets are primarily for corporate performance but will have positive effects in

each facility

Baseline Action plan developed for Newbridge to achieve the corporate sustainability goals for

fiscal year July 2008 to June 2009 and onwards. Tracking tool developed to follow progress

Responsibility P Donnelly& HSE IWS Team

3 Ensure site compliance with REACH Directive. This objective involves supplying all necessary

information to the European corporate REACH implementation team . This corporate team will

prepare the Registration Dossiers for relevant substances.

Project on target with REACH Requirements Responsibility P Donnelly / O Hopkins

4 Replace existing fixed speed compressor with 75kW Variable speed unit. During low demand periods

the compressor will decrease output via a management system. This will decrease energy requirement

at low demand periods.

Project completed in August 2008 Responsibility J McGrath

5 Fit energy efficient lighting plus sensor control to Dispatch area and Pallet Shed

Project completed in 2008 Responsibility J McGrath

6 Automate Circle 3 Packing Line. This project is cost to remove 137,000 Outer packing cardboard

boxes or shippers. The removal of these shippers from the packaging configuration will lead to a

cost reduction in the bill of materials plus the elimination over 30 tonnes of cardboard from the

packing process

Project successfully implemented in July 2008 Responsibility R Walsh / R Cassidy

7 Fit acoustic barrier to VSI Cooling Fans. Target 5dBA noise reduction

Barrier installed in February 2008 Resp. J McGrath/ P Donnelly


EMP Objectives 2009

• Implement equipment turn off program for out of hours and weekend periods

Resp M Balfe & F Delaney

• Recirculate air in Circle 1 production area. Currently drawing in ambient air to room heaters

Resp Jim Mc Grath

• Fit pulse meters to main distribution boards to facilitate ongoing monitoring of electricity

consumption This will help prioritise energy reduction projects. Target 10% reduction over 3

years

Resp. Jim Mc Grath

• Carryout feasibility study on the use of induction heating on moulding machines

Resp. Liam Swords

• Set up waste reduction teams in each Value Stream to help identify opportunities to reduce

waste produced.

Resp. J Ryan / K Byrne

• Request technical amendment to Licence P0297-02 from EPA in relation to A2-1 emission point

relocation. Resp P Donnelly

Braun Oral-B Ireland of 36 Licence Register P0297-02 Annual Environmental Report Date: April 2008 Section 6

Appendix 1 Process water estimations

Estimate of process water used daily, between March 05 to April 05 (plus previous information.)

Daily Annual (50 weeks)

Cleaning

Washing machine

3 machines 128.5

litres/day 43,000 litres

Total per annum 43,000 litres

Points of use

Floss mixing No longer in use

QC laboratory No longer in use

Steam cleaning (process) 10,000 litres

Chillers/coolers 7,500 litres

UF steam bulking 345,000 litres

Total per annum 405,500 litres

Cubic metres 405.5 m3

Based on a 329 day year 1232 litres/day


Appendix 2

Waste Graphs for 2008

Figure 5. Waste to product shipped ratio.

0

500

1,000

1,500

2,000

2,500

3,000

3,500

Waste to product shipped ratiokgs/'000 Units Shipped 1999 - 2008

Figure 6. Total solid wastes in tonnes 1999-2008

0

500

1000

1500

2000

Total Solid Waste (Tonnes)1999-2008


Figure 7. Tonnes of cardboard recycled 2008

0

5

10

15

20

25

30

35

1 2 3 4 5 6 7 8 9 10 11 12

Jan- Dec 2008 Cardboard Recycled (Tonnes)

Figure 8. Tonnes of Plastic recycled 2008

0

5

10

15

20

25

30

35

1 2 3 4 5 6 7 8 9 10 11 12

Jan - Dec 2008 Plastic Waste Recycled (Tonnes)

annual environmental report jan - dec 2008 · table 6. synopsis of airflow rate ultrafloss a2 -1...

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