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Corden Pharmachem - Annual environmental report 2008
Annual Environmental Report 2008
Corden Pharma Ltd
t/a Corden PharmaChem
Wallingstown,
Little Island,
Co. Cork
IPPC Licence Registration No: P0134-03
March 2009
Corden Pharmachem - Annual environmental report 2008
Corden PharmaChem AER 2008 Page 2 of 104
Compiled by:
Peter Keegan
EHS Officer
Approved and Authorised by
Sean Kenrick
EHS Manager
Corden PharmaChem.,
Wallingstown,
Little Island,
Co. Cork
Corden Pharmachem - Annual environmental report 2008
Corden PharmaChem AER 2008 Page 3 of 104
TABLE OF CONTENTS
1. INTRODUCTION......................................................................................................................6
1.1 Site Location.............................................................................................................................................. 6
1.2 Site Activities ............................................................................................................................................. 6
1.3 Company Overview .................................................................................................................................. 7
1.4 Environmental Policy ............................................................................................................................... 8
1.5 Company Organisation Chart ................................................................................................................. 8
2. SELF-MONITORING DATA...................................................................................................9
2.1 EMISSIONS TO SEWER .......................................................................................................................... 9
2.1.1 Summary & PRTR Table......................................................................................................................... 9
2.1.2 Summary of Notification Reports.......................................................................................................... 16
2.1.3 Office of Environmental Enforcement Wastewater Sampling............................................................ 17
2.1.4 EPA Certified Laboratory proficiency scheme .................................................................................... 18
2.2 EMISSIONS TO SURFACE WATER ....................................................................................................... 19
2.2.1 Summary of surface water emissions & PRTR Table ......................................................................... 19
2.2.2 Surface Water Exceedance of Warning Level...................................................................................... 22
2.3 EMISSIONS TO ATMOSPHERE......................................................................................................... 23
2.3.1 Process Emissions Summary.................................................................................................................. 23
2.3.2 Boiler Emissions Summary .................................................................................................................... 25
2.3.3 Dust Emissions Summary....................................................................................................................... 26
2.3.4 PRTR Table – Emissions to Air............................................................................................................. 27
2.4 WASTE MANAGEMENT ....................................................................................................................... 30
3. ENERGY AND WATER CONSUMPTION .........................................................................36
3.1 ENERGY & WATER CONSUMPTION..................................................................................................... 36
4. ENVIRONMENTAL INCIDENTS AND COMPLAINTS ............. .....................................37
4.1 INCIDENTS 2008 ................................................................................................................................. 37
4.1.1 Incident 01-08 Over pressurisation of Waste Drum......................................................................... 37
4.1.2 Incident 02-08 Waste Treatment Incident ......................................................................................... 38
4.1.3 Incident 03-08 PB2 Reaction Vessel Incident – Update.................................................................... 39
4.2 THERMAL OXIDISER BYPASSES......................................................................................................... 40
Corden Pharmachem - Annual environmental report 2008
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4.3 COMPLAINTS ...................................................................................................................................... 42
5. MANAGEMENT OF THE ACTIVITY ......................... .......................................................44
5.1 ENVIRONMENTAL MANAGEMENT SYSTEM ........................................................................................ 44
3.2 HUMAN RESOURCES, TRAINING AND EDUCATION: ........................................................................... 44
5.3 SCHEDULE OF ENVIRONMENTAL OBJECTIVES AND TARGETS .......................................................... 44
5.4 ENVIRONMENTAL MANAGEMENT PROGRAMME................................................................................ 45
6. LICENCE SPECIFIC REPORTS..........................................................................................46
6.1 NOISE ................................................................................................................................................. 46
6.2 GROUNDWATER MONITORING ........................................................................................................... 48
6.3 BUND TESTING ................................................................................................................................... 50
6.4 TOXICITY TESTING OF EFFLUENTS ................................................................................................... 51
APPENDICES ..................................................................................................................................52
APPENDIX I .................................................................................................................................................. 53
Site Plan of the Corden PharmaChem Facility................................................................................................... 53
APPENDIX II ................................................................................................................................................ 54
Corden PharmaChem Organisation Chart......................................................................................................... 54
APPENDIX III............................................................................................................................................... 55
Environmental Policy Statement ......................................................................................................................... 55
APPENDIX IV ............................................................................................................................................... 57
Compliance Summary Tables .............................................................................................................................. 57
APPENDIX V................................................................................................................................................. 63
Dioxin Monitoring Report 2008 ........................................................................................................................... 63
APPENDIX VI ............................................................................................................................................... 64
Dust Monitoring for 2008 ..................................................................................................................................... 64
APPENDIX VII.............................................................................................................................................. 64
PRTR Waste Tables for 2008 ...............................................................................................................................64
APPENDIX VIII ............................................................................................................................................ 75
Utilities Reports 2008 ............................................................................................................................................ 75
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APPENDIX IX ............................................................................................................................................... 78
Review of 2008 Environmental Management Programme................................................................................ 79
APPENDIX X................................................................................................................................................. 87
Proposal for 2009 Schedule of Objectives and Targets...................................................................................... 88
APPENDIX XI ............................................................................................................................................... 89
Environmental Management Projects Proposal 2009........................................................................................ 90
APPENDIX XII.............................................................................................................................................. 95
External Acoustic Survey - November 2008........................................................................................................ 95
APPENDIX XIII ............................................................................................................................................ 96
Groundwater Monitoring Reports....................................................................................................................... 96
APPENDIX XIV............................................................................................................................................. 97
Bund Testing Reports ........................................................................................................................................... 97
APPENDIX XV ............................................................................................................................................ 104
Wastewater Toxicity Reports 2008 .................................................................................................................... 104
CORDEN PHARMACHEM
Section 1: Introduction
Corden PharmaChem AER 2008 Page 6 of 104
1. INTRODUCTION
Name of company: Corden Pharma Ltd t/a Corden PharmaChem.
Location of site: Wallingstown, Little Island, Co. Cork
IPPC License Register Number (issued in Feb 2008): P0134-03
1.1 Site Location
Corden PharmaChem is located at Wallingstown, Little Island, Co. Cork. The facility is situated on a 20-
acre site, within the Little Island IDA Industrial Estate, approximately 5 miles east of Cork City.
Little Island forms the northern shore of Lough Mahon and is relatively low lying. The Corden
PharmaChem facility is located roughly in the centre of Little Island, 400 metres to the north of the northern
shore of Lough Mahon. The plant is bounded to the north, west and south by industrial complexes. The plant
is bounded to the east by a road and a golf club. Considerable environmental monitoring is currently
undertaken throughout Little Island, due to the industry sector of many of the larger industrial sites.
1.2 Site Activities
Corden PharmaChem is licensed under Class 5.16 of the First Schedule of the EPA, Acts 1992 & 2003, to
use a chemical or biological process for the production of basic pharmaceutical products.
Corden PharmaChem is a multi-product cGMP manufacturing facility, which produces bulk active
pharmaceutical ingredients for clients worldwide. The company also operates a research and development
facility, which is actively involved in product development.
Corden PharmaChem holds ISO 14001 certification and is operated to Irish Medicines board (IMB) and US
Food & Drug Administration (FDA) cGMP manufacturing standards
Corden PharmaChem is also an ISO 9002 accredited company. In addition, Corden PharmaChem is licensed
to process controlled substances and is accredited by the National Drugs Advisory Board.
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1.3 Company Overview
Corden PharmaChem was established as Irish Pher in 1974 as a fine chemical production company. In 1992,
the company was purchased by Ecosol AG and it was subsequently renamed Irotec Laboratories Limited.
In 1999, Irotec laboratories Ltd. was acquired by the Cambrex Corporation, and renamed Cambrex
Profarmaco Cambrex Cork Ltd. In mid 2004 the company changed its name to Cambrex Cork Ltd.
Cambrex Corporation is a leading global supplier of products and services to the Life Sciences Industries and
a producer of speciality chemicals through its subsidiaries in the US and Europe.
In 2006 ICIG (International Chemical Investors Group) acquired Cambrex Cork and our sister company in
Landen, Belgium. In January 2007 the company officially changed its name from Cambrex Cork to Corden
PharmaChem
ICIG, based in Frankfurt, Germany is the holding company for a number of subsidiaries in the fine and
specialty chemicals industry, owning eight businesses, with sales of over €300 million. ICIG operates eleven
manufacturing sites in Germany, France, the United States and Poland with over 1800 employees. ICIG
companies include WeylChem, PPC, ENKA, Rütgers Organics, Rütgers Carbotech, CarboTech Engineering
and Nease Corporation.
The Corden PharmaChem product list includes a wide range of bulk active materials, which are used in the
formulation of final dosage forms at secondary pharmaceutical facilities in Europe and the USA. The
therapeutic uses of Corden’s products include: anti-rheumatic, anti-inflammatory, analgesic, anti-coagulant,
anti-fungal, anti-cancer, anti-depressant, anti-psychotic, vasodilator, beta blocker, and stimulant uses.
A plan of the existing Corden PharmaChem facility is presented in Appendix I of this report. The existing
facility consists primarily of two Production Buildings (PB1 and PB2), an administration and laboratory
building, a canteen/social building and miscellaneous site infrastructure, utilities and facilities.
The EHS Manager is responsible for environmental and safety management systems including all EHS
monitoring and reporting functions. Engineering are responsible for the day to day running of the
Wastewater Treatment plant, Air pollution abatement technology (Thermal Oxidiser, Scrubbers, Boilers etc).
A copy of Corden’s Organisation Chart is included in Appendix II of this report. The EHS section is a
dedicated unit with a current staff of 2 full-time employees with further back up from the Engineering
department. The EHS department includes the EHS Manager and Environmental Officer The Engineering
Department consists of 3 full time Engineers, 1 Utilities Officer and 2 EHS Operators.
Corden Pharmachem - Annual environmental report 2008
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Condition 11.7 of the Corden PharmaChem IPPC Licence requires the company to produce an Annual
Environmental Report (AER) and to submit it to the Environmental Protection Agency (EPA). This report
constitutes the AER for the period January 2008 to December 2008.
The format of this report is in compliance with the EPA’s Guidance Note for the AER (February 1997).
1.4 Environmental Policy In 1996, Corden PharmaChem first published its Environmental Policy Statement. This Environmental
Policy Statement has evolved over the past number of years and the current version, issued in January 2006,
is presented in Appendix III of this report.
1.5 Company Organisation Chart
The current version of Corden PharmaChem’s organisation chart is included in Appendix II
CORDEN PHARMACHEM
Section 2: Compliance Summary
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2. SELF-MONITORING DATA 2.1 Emissions to Sewer
2.1.1 Summary & PRTR Table
Treated effluent from the Corden PharmaChem facility was discharged from the Wastewater Treatment Plant
(WWTP) via overhead pipe to the Cork County Council industrial sewer on the East side of the Corden
PharmaChem site., and ultimately to Carrigrennan Waste Water Treatment plant
For Summary of non compliances refer to Appendix IV.
Parameter Licensed Mass Emission (Kg per annum)
2007 Mass Emission (Kg per annum
2008 Mass Emission (Kg per annum
Volume (m3/year) 93,075 23,913 21,398
Temperature Max. 25 ºC 24.1°C
(average 16.01)
23.4°C
(Average16.3°C)
pH 6 - 9 Max 8.7
Min: 6.04
Max: 8.9
Min: 6.4
Toxicity
10 TU
<2 TU (respirometry)
55.5 TU (T Battagliai)
<2 TU (respirometry)
31.2 TU (T Battagliai)
BOD 73,000/73,200 2,315 2,344
COD 365,000/366,000 29,550 13,284
Suspended Solids 10,950 1,982 3,021
Total Nitrogen - 832 405
Ammonia (as N) - 170 272
Total Phosphorus (as P)
- 34.3 107
Sulphates (as SO4) - 14,937 12,546
Cyanide - 0..55 3.4
Fats, Oils & Grease - 60.3 89.7
TABLE 2.1.1 EMISSIONS TO SEWER/WASTE WATER SUMMARY
CORDEN PHARMACHEM
Section 2: Compliance Summary
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PRTR TABLE - RELEASES TO WASTEWATER OR SEWER #VALUE!
28/04/2009 10:49
SECTION A : PRTR POLLUTANTS OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-W ATER TREATMENT OR SEWER
POLLUTANT METHOD QUANTITY Method Used SE1
No. Annex II Name M/C/E Method Code Designation or Description
Emission Point 1
T (Total) KG/Year
A (Accidental) KG/Year
F (Fugitive) KG/Year
06 Ammonia (NH3) M ALT
4500-NH3-D Ammonia selective electrode method 270.0 270.0 0.0 0.0
17 Arsenic and compounds (as
As) M EN14385 0.071 0.071 0.0 0.0
20 Copper and compounds (as
Cu) M EN14385 0.166 0.166 0.0 0.0 82 Cyanides (as total CN) M ALT HACH Method 8027 3.4 3.4 0.0 0.0 23 Lead and compounds (as Pb) M EN14385 0.024 0.024 0.0 0.0 22 Nickel and compounds (as Ni) M EN14385 0.189 0.189 0.0 0.0
07 Non-methane volatile organic
compounds (NMVOC) M USEPA 8260B 20.1 20.1 0.0 0.0
12 Total nitrogen M ALT HACH Method 10022 - digestion/colorimetry 405.0 405.0 0.0 0.0
76 Total organic carbon (TOC)
(as total C or COD/3) C PER COD/3 4430.0 4430.0 0.0 0.0
13 Total phosphorus M ALT HACH Method 8190 digestion/colorimetry 107.0 107.0 0.0 0.0
24 Zinc and compounds (as Zn) M EN14385 1.61 1.61 0.0 0.0
CORDEN PHARMACHEM
Section 2: Compliance Summary
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OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-W ATER TREATMENT OR SEWER
POLLUTANT METHOD QUANTITY Method Used SE1
Pollutant No. Name M/C/E
Method Code
Designation or Description
Emission Point 1
T (Total) KG/Year
A (Accidental) KG/Year
F (Fugitive) KG/Year
238 Ammonia (as N) M ALT
4500-NH3-D Ammonia selective electrode method 270.0 270.0 0.0 0.0
303 BOD M ALT 5120B - standard method - 5 day test 2340.0 0.0 0.0 0.0
305 Calcium M EN14385 608.0 608.0 0.0 0.0 306 COD M EN14385 13300.0 13300.0 0.0 0.0
314 Fats, Oils and Greases M ALT 5520 C - Gravimetric Method 89.7 89.7 0.0 0.0
357 Iron M EN14385 19.8 19.8 0.0 0.0 362 Kjeldahl Nitrogen M ALT HACH Method 424.0 424.0 0.0 0.0 320 Magnesium M EN14385 165.0 165.0 0.0 0.0 321 Manganese (as Mn) M EN14385 1.42 1.42 0.0 0.0
323 Methanol M USEPA 8260B 12.3 12.3 0.0 0.0
327 Nitrate (as N) M ALT
HACH method - 8039 - cadmium reduction method 226.0 226.0 0.0 0.0
370 Selenium M EN14385 0.095 0.095 0.0 0.0
343 Sulphate M ALT HACH method - 8051 - turbidity/colorimitry 12500.0 12500.0 0.0 0.0
240 Suspended Solids M ALT Standard method 2540D - gravimetry 3020.0 3020.0 0.0 0.0
358 Tin M EN14385 1.23 1.23 0.0 0.0 347 Total heavy metals M EN14385 2.18 2.18 0.0 0.0
351 Total Organic Carbon (as C) M USEPA 8260B 4430.0 4430.0 0.0 0.0
CORDEN PHARMACHEM
Section 2: Compliance Summary
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237 Volatile organic compounds
(as TOC) M USEPA 8260B 20.1 20.1 0.0 0.0
CORDEN PHARMACHEM
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Parameter
% Change 2005-2006
Volume (m3/year) -10.5%
Temperature n/a
pH n/a
Toxicity n/a
BOD +1.3%
COD -55%
Suspended Solids +52%
Total Nitrogen -51%
Ammonia (as N) +60%
Total Phosphorus (as P) +212%
Sulphates (as SO4) -16%
TABLE 2.1.2 % CHANGE IN EMISSIONS TO SEWER 2007-2008.
CORDEN PHARMACHEM
Section 2: Compliance Summary
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WWTP Parameters
0
10000
20000
30000
40000
2006 2007 2008
Year
Kgs
BODTSSNitrogenSulphatesVolumeCOD
TABLE 2.1.3 EMISSIONS TO SEWER / WASTEWATER SUMMARY.
100% Compliances.
Effluent is sampled and analysed in accordance with the terms of the Corden PharmaChem
IPPC licence, P0134-03. During 2008, 100% compliance was achieved for the following
licenced parameters:
• Temperature;
• pH
• Nitrates
• Total P
• BOD
• Total Heavy Metals
• Cyanide;
• Volume
• OFGS
• COD
• Total Nitrogen
• VOCs
Effluent is sampled and analysed in accordance with the terms of the IPPC licence and during
2008, there were 4 non-compliances.
CORDEN PHARMACHEM
Section 2: Compliance Summary
Corden PharmaChem AER 2008 Page 15 of 104
Details of these non-compliances have been notified to the Agency in accordance with
condition 11.1 of our IPPC licence. Refer to Notification reports and Biannual reports.
Compliance performance 2003-2008.
0
5
10
15
20
25
30
35
2002 2004 2005 2006 2007 2008
Breaches
A review of the overall WWTP non-compliances has been undertaken and a monthly
summary is provided in Table 2.1.4. A tabulated record of each of the WWTP non-
compliance records is presented in Appendix IV.
Month
Janu
ary
Feb
ruar
y
Mar
ch
Apr
il
May
June
July
Aug
ust
Sep
tem
ber
Oct
ober
Nov
embe
r
Dec
embe
r
Tot
al
pH 0 0 0 0 0 0 0 0 0 0 0 0 0
BOD 0 0 0 0 0 0 0 0 0 0 0 0 0
COD 0 0 0 0 0 0 0 0 0 0 0 0 0
Suspended Solids 1 0 0 1 0 0 0 0 0 0 0 0 2
Total Nitrogen 0 0 0 0 0 0 0 0 0 0 0 0 0
Ammonia (as N) 0 0 0 0 1 0 0 0 0 0 0 0 1
Total Phosphorous 0 0 0 0 0 0 0 0 0 0 0 0 0
Sulphates 0 0 0 1 0 0 0 0 0 0 0 0 1
Cyanide 0 0 0 0 0 0 0 0 0 0 0 0 0
Fats, oil & greases 0 0 0 0 0 0 0 0 0 0 0 0 0
TOTAL 1 0 0 2 1 0 0 0 0 0 0 0 4
Table 2.1.4 Monthly Waste Water Emissions Non-Compliance History
CORDEN PHARMACHEM
Section 2: Compliance Summary
Corden PharmaChem AER 2008 Page 16 of 104
2.1.2 Summary of Notification Reports
FE-01-08 – Suspended Solids
Total Suspended Solids reading of 863 mg/l Vs IPPC licence of 200mg/l Suspended Solids
was detected on 22 January 2008. The total volume wastewater discharged for 22 January
was 82 m3; giving an emission load of 70kg/Day. The reason for these high levels was mainly
due to high volumes entering WWTP and solids in the system. As well as diversion in which
the outfall was diverted to holding tanks, flow rates throughout the system were also reduced
to help reduce the emissions loadings. Diversion and sludge removal helped reduce outfall
flowrates as the plant re-established normal operating conditions. Regular monitoring of
suspended solids was carried out until they come back into compliance
FE-02-08 – Sulphates
Analysis of the composite sample from 09 April indicated sulphate levels of 808 mg/l Vs
IPPC limit of 500mg/l. The total sulphate mass emissions loadings were 49 Kgs/day. Further
sulphate analysis on the 14th, 15th, 16, and 17th April indicated levels of 1070, 1010, 1040 and
1040 mg/l respectively. All other parameters were within IPPC licence compliance. Sulphates
are a monthly test, but frequency of testing was increased until compliance was achieved.
Flow rates were reduced in an attempt to reduce mass loading emissions. A factor giving rise
to increased sulphate levels was the bypassing of the sulphuric acid valve on 09th April.
Approximately 500 litres bypassed directly into the equalisation basin, thereby increasing
sulphate levels. The valve was subsequently fixed and normal service has resumed.
FE-03-08 – Suspended Solids
Analysis of the composite sample on 12 April indicated a Total Suspended Solids reading of
428 mg/l Vs IPPC licence of 200mg/l Suspended Solids. Suspended solids analysis on 13th,
14th and 15th April also indicated levels of 325, 351 and 328 mg/l respectively. The reason for
these high levels was mainly due to high volumes of solids in the system and settleability
problems. Flow rates throughout the system were reduced to help reduce the emissions
loadings and emptying and cleaning out of clarifiers was carried out to help remove solids
from the system
FE-04-08 - Ammonia
CORDEN PHARMACHEM
Section 2: Compliance Summary
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Analyses of the final effluent composite samples from 07, 08, 09 May 2008 indicated
ammonia readings of 156, 80.5 and 110mg/l respectively. Our licence limit is 50mg/L NH3 (as
N).
Since the PB2 incident which occurred on 28th April 2008, production has been stopped and
as a result the usual waste/feed for the wastewater biological system was not available. As a
result the biological system was not operating as effectively as usual. Ammonia levels in the
raw influent were lower than ammonia levels in the final effluent, which shows that there was
an upset to the plant because of production shutdown. There was a source of waste onsite,
which was fed in at a slow rate as it is a strong waste. The main bulk of the waste streams
however were not available due to this shutdown.
2.1.3 Office of Environmental Enforcement Wastewater Sampling. The EPA’s Office of Environmental Enforcement made 1 unscheduled visit to Corden
PharmaChem to sample waste water streams. Analysis was conducted in EPA laboratories in
Iniscarra (wastewater screen) & Kilkenny (VOC screen). The wastewater results reported to
Corden PharmaChem indicate a close correlation with our own QC laboratory wastewater
sample results.
Test Parameter
IPPC Limits
EPA Result
11/11/08
Corden Pharma-
Chem Result
11/11/08
Flow (m3/day) 255m3/day 85 85
pH 6.0 – 9.0 7.79 @ 20°C 7.497 @ 20°C
BOD (mg/l) 1000mg/l or
200kg/day 4.1 130
COD (mg/l) 5000 mg/l or
1000kg/day 138 181
Suspended Solids
(mg/l)
200mg/l or
30kg/day <2 7
Total
Nitrogen (mg/l)
50mg/l <1 2.3
CORDEN PHARMACHEM
Section 2: Compliance Summary
Corden PharmaChem AER 2008 Page 18 of 104
Test Parameter
IPPC Limits
EPA Result
11/11/08
Corden Pharma-
Chem Result
11/11/08
Flow (m3/day) 255m3/day 85 85
Ammonia
(as N) (mg/l)
50mg/l
0.053
0.031
Total Phosphorus
(as P) (mg/l)
10mg/l <0.2 0.03
Sulphates
(as SO4) (mg/l)
500mg/l
190
90
Cyanide
(as HCN) (mg/l)
0.2mg/l <0.010 ND
Table 2.1.3 OEE laboratory results compared to Corden PharmaChem QC laboratory results
2.1.4 EPA Certified Laboratory proficiency scheme
Corden PharmaChem have been accepted into the EPA Certified Laboratory proficiency
scheme for 2006-2009. This program allows facilities to check the validity, consistency and
adequacy of the methods they employ to perform various wastewater test. This scheme will
allow Corden PharmaChem to satisfy itself that our laboratory procedures, systems and
analysis are to a consistently high standard, and where not, to take the necessary action so a
high standard of consistency can be reached.
The categories of testing we have applied to join are:
Category 1 – pH, Sulphates;
Category 2 - BOD/COD, suspended solids;
Category 4 – Ammonia (as mg/l NH4), nitrate (mg/l (NO3), phosphorous (mg/l P).
The Register for 2008 has yet to be drafted but for 2007, Corden PharmaChem were on the
register for COD, Phosphates, Sulphates and Suspended Solids. We are currently working
towards the 2009 register.
CORDEN PHARMACHEM
Section 2: Compliance Summary
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2.2 Emissions to Surface Water
2.2.1 Summary of surface water emissions & PRTR Table
Storm water arising on the Corden PharmaChem facility is discharged into a surface water
drainage system. The combined storm water discharge exits the Corden PharmaChem site at
the southeast corner of the facility. The combined discharge is then conveyed to Lough
Mahon via the Cork County Council surface water drain.
Dedicated Process Area Surface Water Drainage System (PASD) holding tanks are provided
to collect all of the surface water from potentially contaminated areas. Samples of surface
water are taken from the holding tanks and are tested for COD and pH. The surface water
from the PASD holding tanks is discharged to the surface water drain only in the event that it
meets prescribed criteria (COD <100mg/l, pH 6-9). In the event of contamination arising, the
PASD surface water is discharged to the WWTP. This ensures that no contaminated surface
water is discharged from the site.
In accordance with Schedule C 2.3 of the IPPC License, Corden PharmaChem has monitored
surface water discharges and the monitoring data is presented in Table 2.2.1.
Parameter
2007
2008
Total Flow m3/yr 14,667 3,948
Temperature (average ˚C) 17 16
pH (average) 7.1 7.4
BOD ((kg) 337 146
COD ((kg) 543 30
Table 2.2.1 Emissions to Surface Water Summary
CORDEN PHARMACHEM
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Corden PharmaChem AER 2008 Page 20 of 104
PRTR TABLE - 4.2 RELEASES TO WATERS
SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS
RELEASES TO WATERS POLLUTANT QUANTITY
Method Used SW1
No. Annex II Name M/C/E Method Code
Designation or Description
Emission Point 1
T (Total) KG/Year
A (Accidental) KG/Year
F (Fugitive) KG/Year
76 Total organic carbon (TOC) (as total C
or COD/3) C PER COD/3 44.0 44.0 0.0 0.0
* Select a row by double-clicking on the Pollutant
Name (Column B) then click the delete button
SECTION B : REMAINING PRTR POLLUTANTS
RELEASES TO WATERS
POLLUTANT QUANTITY Method Used
No. Annex II Name M/C/E Method Code
Designation or Description
Emission Point 1
T (Total) KG/Year
A (Accidental) KG/Year
F (Fugitive) KG/Year
0.0 0.0 0.0 0.0
* Select a row by double-clicking on the Pollutant
Name (Column B) then click the delete button
CORDEN PHARMACHEM
Section 2: Compliance Summary
Corden PharmaChem AER 2008 Page 21 of 104
SECTION C : REMAINING POLLUTANT EMISSIONS (as requi red in your Licence)
RELEASES TO WATERS POLLUTANT QUANTITY
Method Used SW1
Pollutant No. Name M/C/E Method Code
Designation or Description
Emission Point 1
T (Total) KG/Year
A (Accidental) KG/Year
F (Fugitive) KG/Year
303 BOD M 5120B Standard Method: 5
day test 360.0 360.0 0.0 0.0
306 COD M
5220D or Hach
method 8000
Examination of water and wastewater
digest/colorimetry 130.0 130.0 0.0 0.0 351 Total Organic Carbon (as C) M continuous Protoc 300 220.0 220.0 0.0 0.0
CORDEN PHARMACHEM
Section 2: Compliance Summary
Corden PharmaChem AER 2008 Page 22 of 104
2.2.2 Surface Water Exceedance of Warning Level
SW-01-08
Analysis carried out on the 24-hour composite Surface Water sample from February 07th, indicated a COD
value of 160mg/l from a surface water discharge flow of 20m3. Visually, the sample was colourless and
clear. There was surface water discharge on 06 February 2008 from 18:44 to 20:42 during which there was
an average flow of 8.4m3/hr during which the ph was 6.8.
In late January it was noticed that part of the equipment of the TOC analyser wasn’t in usual condition.
During this time, all surface water discharges were diverted to onsite containment, so there were no surface
water emissions from site. During week 5, February 01st, the service contractors were onsite to service the
analyser and repair the fault. Upon the approval from service contractors the TOC analyser was put back
online and normal surface water management mode resumed.
However on 07 February it was noted by site Instrumentation Engineer that the analyser failed its daily
calibration. It is also the composite sample from this day which exceeded the warning level set by Corden
PharmaChem. The surface water flow was then diverted and remained so until further investigations into the
current status of the analyser is known. The surface water flow automatically diverts to onsite containment
when TOC levels are >33mg/l. Following extensive maintenance and cleaning of the TOC unit, normal mode
resumed.
SW-02-08
Analysis carried out on the 24-hour composite Surface Water sample from February 09th, indicated a COD
value of 120mg/l from a surface water discharge flow of 20m3. Visually, the sample was colourless and
clear,
This was as a result of cleaning and testing of the TOC analyser and surface water chambers on
Friday 08th. Testing and cleaning of the system was carried out on Friday 08th from approx 10:00 to
15:00 with sporadic flows of emissions to surface water during this period. This was in response to
the surface water exceedance on 07th February. While TOC levels were below 33mg/l during these
times, it is possible that there was some stagnant contamination in the sampling chamber at the time
resulting in an exceedance of the warning level. The chambers and sample container have since
been cleaned and cleared of any visible contamination.
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2.3 Emissions to Atmosphere
2.3.1 Process Emissions Summary
Aa summary report of scrubber process emissions emitted via a thermal oxidiser from stack A12/1 to
atmosphere is presented in Table 2.3.1. Results are based on grab sample analysis
2.3.1.1 Emissions from A2/1
Parameter Licensed Mass Emission (Kg per annum)1
2007 Mass Emission (Kg per annum)2
2008 Mass Emission (Kg per annum)3
VOC – Class I (Tubes) 876 0 0
VOC – Class II (Tubes) 4,380 110 7.21
VOC – Class III (Tubes) 6,570 360 82.3
Dioxins 4.38 x 10-6 6.56 * 10-8 7.78 * 10 -08
Hydrogen Chloride 438 64 48 Nitrogen Oxides (as NO2)
4,380 46.5 42
Carbon Monoxide 2,190 47 7 Sulphur Dioxide (SOx) 13,140 27.4 7
Hydrogen Bromide 219 12 6
Hydrogen Cyanide 87.6 7.47 23 Hydrogen Sulphide 219 0 0 Ammonia 2,190 0.45 0.3
Table 2.3.1.1 Licensed Emissions from A2/1 to Atmosphere Summary
Thermal Oxidiser Non-Compliances
There were No thermal Oxidiser compliances during 2008, however a tabulated record is nonetheless
presented in Appendix IV.
1 based on 8760 hrs of operation 2 based on 7920 hrs of operation 3 based on 5803 hrs of operation
CORDEN PHARMACHEM
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2.3.1.2 Emissions from A2/5
Parameter Licensed Mass Emission (Kg per annum)
2007 Mass Emission (Kg per annum)
2008 Mass Emission (Kg per annum)
VOC – Class I (Tubes) 1,314 0 0
VOC – Class II (Tubes) 6,570 2,120 729
VOC – Class III (Tubes) 9,855 5,300 5000
Table 2.3.1.2 Licensed Emissions from A2/5 to Atmosphere Summary
2.3.1.3Emissions from A2/6
Parameter Licensed Mass Emission (Kg per annum)
2007 Mass Emission (Kg per annum)
2008 Mass Emission (Kg per annum)
VOC – Class I (Tubes) 8,760 0 0 VOC – Class II (Tubes) 43,800 5,100 1,510
VOC – Class III (Tubes) 65,700 31,000 10,900
Table 2.31.3 Licensed Emissions from A2/6 to Atmosphere Summary
The figures for 2008 were calculated based on the Thermal Oxidiser (TO) in operation for 5803 hours. These
calculations assume that the average concentration is emitted for the full operating time of the TO. If fugitive
emissions are taken into account, up to 20kgs may have been emitted during bypass time of 389 hours, All
bypass incidents were not of environmental significance as confirmed in notification/TO reports and by
External consultants’ air modelling reports.
As can be seen from the tables above the annual mass emissions are much lower than the permitted mass
emission limits. In addition, the emissions from A2/1meet the Emission Limit Values for all parameters as
specified in Schedule B of the IPPC license. As can be seen from the table above there is mainly a large
reduction in all air emissions in 2008 when compared to 2007 – due to improved monitoring and response
times and also due to reduced hours of operation especially regards the thermal oxidiser.
The air abatement system onsite consists of:
• Waste gas collection system, both general plant and specific to processes/machines and vessels
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• Acidic & Basic aqueous gas scrubbers,
• Catalytic bed thermal oxidiser,
• Stack monitoring system and other necessary instrumentation to abate the waste gas streams from
their production facilities in PB1 and PB2.
A range of instrumentation continuously monitors the operation of the thermal oxidiser, including: LEL
meters, airflow meters, temperature probes and a continuous HCl and TOC monitor. In addition, routine
monthly and quarterly sampling is undertaken by sorbent & adsorbent tube sampling techniques by Corden
PharmaChem personnel. Dioxin Monitoring is carried out by A.S.E.P., an accredited Laboratory based in
Queens University of Belfast.
Additional measures such as operator/supervisor retraining, maintenance and supervision have contributed to
substantially reducing control system and operator error bypasses.
2.3.2 Boiler Emissions Summary
Two Boilers X3021 & X3003, are fuelled by natural gas to generate steam for the site. The boilers are
operated on a demand cycle with one on full duty, supplying steam to the site and another on standby. The
emissions are discharged via stacks A1/1 & A1/2 respectively and are classified as minor emission points.
Samples are drawn from the exhaust flues each month and analysed for boiler emissions (Nitrogen Oxides as
NO2, Carbon Monoxide (CO) and Oxides of Sulphur as SO2. A summary of the results is presented in Table
2.3.4
The average monitoring results from each boiler were used in computing the data in Table 2.3.4 based on the
maximum theoretical exhaust rate for the boilers and the actual operating time for each boiler during the
year.
The calculations assume that each boiler discharged emissions for its full operating time. Only one boiler is
operational at a given time. Boiler X3003 ran for approx. 1464 hrs and boiler X3021 ran for approx 5520 hrs
during 2008 both with an average flowrate of 1600Nm3/Hr.
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2007 Mass Emission (Kg/year)
2008 Mass Emission (Kg/year)
Boiler ID Nitrogen Oxides
(as NO2)
Nitrogen Oxides
(as NO2)
Nitrogen Oxides
(as NO2)
Nitrogen Oxides
(as NO2)
Carbon Monoxide
Sulphur Dioxide
Average of X3021 & X3003
1044 1040 216 53 427 195
Table 2.3.2 Boiler Emissions
2.3.3 Dust Emissions Summary
In accordance with Schedule B, a summary report of dust emissions for 2007 and 2008 to atmosphere are
presented in Table 2.3.5.
Location Licensed Mass Emission (kg/yr)
2007 Mass Emission (kg/yr)
2008 Mass Emission (kg/yr)
A2/1 (Formerly A1/2)
Total Dust n/a 0.5 0.58kg (0.07mg/m3)
Total Dust 54.3 3.9 A2/2 (formerlyA1/3) Active Dust 8.147 Not Detectable
Not in operation
Total Dust 54.3 3.9 A2/3 (formerly A1/4) Active Dust 8.147 Not Detectable
Not in operation
Total Dust 89.9 5.2 A2/4 (formerly A1/5) Active Dust 13.48 Not Detectable
Not in operation
Total Dust 412 4.2 4.3 A2/5 (formerly A2/10) Active Dust 61.7 Not Detectable Not Detectable
A2/6 (formerly A2/17)
Total Dust n/a <1 Not in operation
Active Dust n/a Not Detectable
Table 2.3.3. Summary of Dust Emissions
Refer to Appendix VI for further dust reports of 2008. All analysis were within IPC/IPPC licence limits.
A2/5 monitoring was conducted by Corden Pharmachem personnel, while A2/1 was monitored by ASEP.
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2.3.4 PRTR Table – Emissions to Air
4.1 RELEASES TO AIR SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS
RELEASES TO AIR POLLUTANT METHOD QUANTITY
Method Used A2/1 A2/5 A2/6 Boilers:
A1/1;A1/2
No. Annex II Name M/C/E
Method Code
Designation or Description
Emission Point 1
Emission Point 2
Emission
Point 3 Emission Point 4
T (Total) KG/Year
A (Accidental) KG/Year
F (Fugitive) KG/Year
06 Ammonia (NH3) M ALT NIOSH 6016: Ion Chromatography 0.258 0.0 0.0 0.0 0.258 0.0 0.0
03 Carbon dioxide (CO2) C PER 56.832 tCO2/TJ 0.0 0.0 0.0 1.01 1.01 0.0 0.0
80 Chlorine and inorganic compounds (as HCl) M ALT
1911 to 3 1998: NIOSH 7903 48.2 0.0 0.0 0.0 48.2 0.0 0.0
08 Nitrogen oxides (NOx/NO2) M ALT
Use of MADUR GA 40T plus portable flue gas analyser using electorchemical and IR gas sensors (non dispersive) 0.0 0.0 0.0 53.4 53.4 0.0 0.0
85 Hydrogen cyanide (HCN) M ALT NIOSH 6010:Spectrophotometry 22.6 0.0 0.0 0.0 22.6 0.0 0.0
07 Non-methane volatile organic
compounds (NMVOC) M ALT MDHS 72 - analysis by thermal desorption GCMS 102.0 5720.0
12400.0 0.0 18222.0 0.0 0.0
47 PCDD + PCDF (dioxins +
furans)(as Teq) M EN 1948 USEPA Methods 8290 1613 for analysis 0.0 0.0 0.0 0.0 0.0 0.0 0.0
11 Sulphur oxides (SOx/SO2) M
ISO 1948:19
98 7.43 0.0 0.0 195.0 202.43 0.0 0.0
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SECTION B : REMAINING PRTR POLLUTANTS
RELEASES TO AIR POLLUTANT METHOD QUANTITY
Method Used A2/1 A2/5 A2/6 Boilers
A1/1;A1/2
No. Annex II Name M/C/E
Method Code Designation or Description
Emission Point 1
Emission Point 2
Emission
Point 3 Emission Point 4
T (Total) KG/Year
A (Accidental) KG/Year
F (Fugitive) KG/Year
02 Carbon monoxide (CO) M ALT
Use of MADUR GA 40T plus portable flue gas analyser using electorchemical and IR gas sensors (non dispersive) 7.8 0.0 0.0 427.0 434.8 0.0 0.0
73 Toluene M NRB MDHS 72 7.1 676.0 1290.0 0.0 1973.1 0.0 0.0
* Select a row by double-clicking on the Pollutant Name (Column B) then click
the delete button
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SECTION C : REMAINING POLLUTANT EMISSIONS (As requi red in your Licence) RELEASES TO AIR
POLLUTANT METHOD QUANTITY
Method Used A2/1 A2/5 A2/6
Pollutant No. Name M/C/E
Method Code Designation or Description
Emission Point 1
Emission Point 2
Emission
Point 3 T (Total) KG/Year
A (Accidental) KG/Year
F (Fugitive) KG/Year
206 Benzene & toluene & xylene
(combined) M ALT MDHS 72 7.1 676.0 1290.0 0.0 0.0 0.0 210 Dust M ALT Gravimetric 0.58 0.0 0.0 0.58 0.0 0.0
214 Hydrogen bromide M ALT NIOSH 7903 - Ion chromatography 7.09 0.0 0.0 7.09 0.0 0.0
230 TA Luft organic substances
class 1 M ALT MDHS 72 0.0 0.0 0.0 0.0 0.0 0.0
231 TA Luft organic substances
class 2 M ALT MDHS 72 7.21 729.0 1510.0 2246.21 0.0 0.0
232 TA Luft organic substances
class 3 M ALT MDHS 72 82.3 5000.0 10900.
0 15982.3 0.0 0.0 244 Total Particulates M ALT Gravimetric 0.58 0.0 0.0 0.58 0.0 0.0
237 Volatile organic compounds (as
TOC) M ALT MDHS 72 89.5 5730.0 12400.
0 18239.5 0.0 20.0 323 Methanol M ALT MDHS 72 0.0 11.6 0.0 11.6 0.0 0.0
351 Total Organic Carbon (as C) M ALT MDHS 72 89.5 5730.0 12400.
0 0.0 0.0 0.0
352 Total Organic Carbon (as
Toluene) M ALT MDHS 72 7.21 676.0 1290.0 1973.21 0.0 0.0
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2.4 Waste Management
In accordance with Condition 11.7 & 11.8 of the IPPC License a copy of the waste management record has
been submitted as part of the AER and the PRTR.
During 2008, approximately a total of 1515 tonnes of hazardous waste was generated onsite. The majority of
this was waste solvent, which arose from processes in PB1. Other hazardous waste streams generated on site
included, solid hazardous waste, waste oils, spent fluorescent tubes, batteries and empty gas cylinders.
A total of 221 tonnes of non-hazardous waste was generated on-site in 2008. The majority of this waste
consisted of solid miscellaneous waste (canteen and office waste) and commercial and industrial waste.
However, glass, scrap metal, paper and cardboard were recovered & recycled by approved agents. The Non-
Hazardous waste sent for disposal also consisted of dried sludge from the wastewater treatment plant.
The waste tables for 2008 in appendix VII . A summary of the total annual tonnage of hazardous and non-
hazardous waste for 2007 and 2008 is presented in Table 2.4.1 below:
Waste for 2007 (tonnes)
Non-Hazardous
Waste Hazardous Waste Total
Recovered 228 1182 1410
Disposed 49 1254 1303
Total 277 2436 2713
Waste for 2008 (tonnes)
Non-Hazardous
Waste Hazardous Waste Total
Recovered 194 1006 1200
Disposed 27 509 536
Total 221 1515 1736
Table 2.4.1: Waste Management Report
The total waste figures produced in 2008 show a slight decrease of 36% on the 2007 total (mainly due to
production shutdown during the year). The overall total of waste generated, both hazardous and non
hazardous was 1736 metric tonnes.
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The multi-product and batch nature of production somewhat minimises the possibility of making direct
comparisons from one year to another, however the recovery of hazardous waste is always the preferred
option.
During 2008, the segregation of hazardous liquid wastes on site continued to be addressed. Great emphasis
was placed on segregating solvent waste streams with high calorific value, from streams of lower calorific
value arising from the production processes.
Work on material and waste reduction is continually assessed during the year . Due to the multi product
nature of the facility, cGMP rules regarding solvent recovery, etc we were not able to fully investigate
techniques such as on site solvent recovery.
Aspects of waste management are targeted in our EMP from year to year if feasible. The following
represents the total quantity of waste (HAZ) generated per metric tonne of product sold for 2008 and
previous years.
29
21.9 20.1 20.7
29.7
05
1015202530
2002 2005 2006 2007 2008
Metric tonnes Waste Vs MT Product
MT Waste /MT Product
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Waste Disposal Carriers/Hauliers
The names of the carriers of the waste from the site and their permit details (including issuing authority) are
provided in Table 2.4.2.
Carriers Name Waste Collection
Permit No. Issuing Authority
Ipodec Ireland Ltd CK WMC 10/01 Cork County Council
Tank Trans Ltd CK WMC 67/01 Cork County Council
JP Ryan & Sons Ltd CK WMC 34/01 Cork County Council
Murphy Transport Ltd CK WMC 19/01 Cork County Council
Molloy & Sherry Transport Ltd CK WMC 122/02 Cork County Council
Cleanaway4 (Cara) CK WMC 53/01 Cork County Council
S (Transport) Cork Ltd CK WMC 70/01 Cork County Council
Irish Lamp Recycling Co Ltd CK WMC 57/01 Cork County Council
Returnbatt Ltd CK WMC 80/01 Cork County Council
Johnson Haulage Co Ltd CK WMC 50/01 Cork County Council
Cork Metal Company CK WMC 26/01 Cork County Council
Atlas Environmental Ireland Ltd. CK WMC 16/01 Cork County Council
South Coast transport Ltd CK WMC 07/01 Cork County Council
Bailey Waste Recycling Ltd. CP D59/1 Dublin City Council
Indaver Ireland CP D53/1 Dublin City Council
Gandon Enterprises Ltd t/a Rehab
Recycling Ltd WCP/LK/119/03b Limerick County Council
Collins Waste Disposal CK(S) WMC 18/02 Cork County Council
AVR-safeway
Table 2.4.2: Names of the carrier of the waste and their permit details (including issuing authority)
4 This haulier was only used for a small number of waste IBC collections in the year. This haulier is licensed under the Cara Permit No.
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Waste Disposal Contractors
Details of the ultimate disposal/recovery destination facility for the waste from the site (including its permit
details and issuing authority) are provided below in Table 2.4.3:
Carriers Name Waste Collection Permit No. Issuing Authority
Ipodec Ireland Ltd CK WMC 10/01 Cork County Council
Tank Trans Ltd CK WMC 67/01 Cork County Council
JP Ryan & Sons Ltd CK WMC 34/01 Cork County Council
Murphy Transport Ltd CK WMC 19/01 Cork County Council
Molloy & Sherry Transport Ltd CK WMC 122/02 Cork County Council
Cleanaway5 (Cara) CK WMC 53/01 Cork County Council
S (Transport) Cork Ltd CK WMC 70/01 Cork County Council
Irish Lamp Recycling Co Ltd CK WMC 57/01 Cork County Council
Returnbatt Ltd CK WMC 80/01 Cork County Council
Johnson Haulage Co Ltd CK WMC 50/01 Cork County Council
Cork Metal Company CK WMC 26/01 Cork County Council
Atlas Environmental Ireland Ltd. CK WMC 16/01 Cork County Council
South Coast transport Ltd CK WMC 07/01 Cork County Council
Bailey Waste Recycling Ltd. CP D59/1 Dublin City Council
Indaver Ireland CP D53/1 Dublin City Council
Rehab Recycling Ltd
(Gandon Enterprises Ltd) WCP/LK/119/03b Limerick County Council
Collins Waste Disposal CK(S) WMC 18/02 Cork County Council
AVR-safeway
5 This haulier was only used for a small number of waste IBC collections in the year. This haulier is licensed under the Cara Permit No.
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Disposal and/or Recovery Destination
Facility Name Waste Permit No. Issuing Authority
Rossmore Landfill Site, Co Cork Waste licence No. 22-1 Irish EPA
Innovatherm, Germany
56.8851.1.3/8.1-G
Umweltschutz Ruhr GmbH
Betram, Sturnshof 20, Bottrop,
Germany G62.352/00/0811 B2 Staatliches Umweltamt Herten
Gruba gesellschaft fur, Germany
(formerly Buchen Umweltservice
GmbH, Germany: name change in
Sep/Oct 2003)
529/1772/Efb ZER-QMS GmbH
Cleanaway Ltd, UK
AG8233
UK Environment Agency
Kommunekemi A/S, Denmark
131/070-0002
Miljoministeriet Miljostyrelsen
Sava, Germany
A 51 G 00 508
GOES
Shanks Chemical Services, Scotland IPC/001/1994 Scottish EPA
Soltec (Irl) Ltd., Co Westmeath Waste licence No. 115-1 Irish EPA
SRM, UK (Lancashire) Env Licence AG9248 UK Environment Agency
SRM, UK (Sunderland)
Transfer Station (TW 306
SL)
Solvent Recovery Plant
(AG8594/AT2616)
UK Environment Agency
& Her Majesty’s Inspectorate of
Pollution (UK)
SRM, UK (Rye Harbour)
AG 8039/AH3881
Her Majesty’s Inspectorate of
Pollution (UK)
AVR Chemie
(now closed 09/2005)
NV Afvalverwerking Rijnmond (AVR) Lic.: 340618/20176136
Prof. Gerbrandijweg 10 Rob Sasse
NL-3197KK Rotterdam-Botlek +31-181 273 3479
340618/11.2005 VROM
Shannon Environmental Services, Co. Waste licence No. 41-1 Irish EPA
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Clare
SITA Environmental Ltd Waste licence No. 83-1 Irish EPA
Dow Halterman
Middlesbrough
BT9828
Environment Agency
Kinsale Road Landfill Waste licence No. 12-2 Irish EPA
Cara Waste, Minane Bridge (Sludge) Irish EPA
TRV, Holland (no longer used) Liquid Hazardous VROM
McGill Env. systems (Sludge) Irish EPA
AVG - Hamburg Hazardous Solvent &
packaged waste Council of Hamburg
REMAT Hazardous
LGM 640455
Provincie Noord Brabant,
Holland
Remondis
Remondis Production GmbH Lic.: 21/Fo/Tho-G61/93
Brunnenstr. 138 Michaela Koch
DE-44536 Lunen +49-2306 106342
NH Sludge Germany
NV Afvalwerking Rijnmond Holland
AVR Environmental Solutions Youghal NH Sludge W0211-01 EPA
Table 2.4.3: Details of the ultimate disposal/recovery destination facility for the waste (including its permit
details and issuing authority)
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3. ENERGY AND WATER CONSUMPTION
3.1 Energy & Water consumption.
Details of electricity consumption, boiler fuel consumption and water consumption for 2007 and 2008 are
presented in Table 3.1 below. Refer to appendix VII for a more detailed Electric usage report
Parameter 2007
2008
Electricity consumption (MWh)
4988 3452
Natural Gas consumption (MWh)
6642 5477
Water consumption (m3)
68,377 33,357
Finished product manufactured (tonne)
117.64 51
Table 3.1 Resource Consumption Summary
Corden PharmaChem are still implementing the action items arising from an energy audit carried out in
2003. We have carried out site energy audits to identify losses in the following systems, electrical, gas and
steam distribution, compressed air, nitrogen and hot water systems. An energy Management team has been
set up in 2007/2008 to help enforce energy awareness and to implement energy savings initiatives.
We have also reviewed processes and major pieces of plant such as pumps, fans and motors. We have
replaced defective or inefficient steam traps, installed an additional metering system that monitors power
consumption and utilities consumption.
Projects identified in our 2009 EMP proposal (Appendix XI) address the objective of conserving resources
such as water and energy, other projects include smaller projects such as switching to more energy efficient
lighting
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4. ENVIRONMENTAL INCIDENTS AND COMPLAINTS
4.1 Incidents 2008
Incidents which affected the normal operation of site activities in 2008 are summarised as follows. None of
these had any impact on the environment.
4.1.1 Incident 01-08 Over pressurisation of Waste Drum
An incident occurred on 02nd March at approximately, which involved the over-pressurisation of a 200 litre
drum, containing tetrahydrofuran and magnesium and the subsequent release of its contents causing solvent
spillage, damage to drum store roof and racking and that other drums appeared to have fallen to ground.
This incident occurred in a drum-store onsite. There were no injuries and all liquid spilled was contained
locally. Physical damage to the drum-store was minimal.
The emergency services were called and remained on site for a number of hours during the clean-up in an
observational & supporting role. As the Fire Brigade confirmed their satisfaction with the on-site operations,
they left the site at shortly afterwards. One of the first tasks completed was the venting and removal of
potentially pressurized drums from the drum store, as well as ensuring that all waste drums onsite were in a
safe mode.
Investigation
The material in question is THF/Mg taken from K2009 reactor, prior to beginning a Tramadol Grignard
reaction. Water in Grignard reaction vessel is well known to inhibit initiation of the reaction and could lead
to reactor contents having to be disposed of if the reaction does not initiate. This is hazardous in itself but if
addition continued then accumulation of added materials would result and sudden initiation (possible in
Grignard type reactions) could result in an uncontrollable incident in vessel. All Corden precautions are to
avoid any possibility of this scenario. Thus if initial raw material, Mg and THF , fail the water content in-
process analysis before any reactants are added to vessel, it is removed and fresh material added. This occurs
approximately 1-2 times a year or once every 40 batches.
Hydrogen Evolution Trials
From hydrogen evolution trials carried out by R&D, the presence of rust seems to catalyse the generation of
gas (H2) and prolong gas evolution period.
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Conclusions
The factual conclusions of this investigation are as presented below
1. Failed drum attained pressure of 2.5Bar, or higher, before rupture.
2. Increased water content in drummed material could not be classed as only cause of incident, as material
with far higher water content did not experience the same volume of gas evolution and pressure build up.
3. Presence of rust accelerates rate of generation of gas (H2) and prolongs gas evolution period
substantially. This is actual cause of incident.
4.1.2 Incident 02-08 Waste Treatment Incident
In the course of treating the cyanide-containing wastewater from a CMP Batch in V6033 (waste
treatment tank) on 07th March 2008, an incident occurred which resulted in the shearing of the
polypropylene vent pipes on V6033 and in addition, the agitator motor was found on the catwalk
adjacent to the vessel and the contents leaked through the bottom outlet valve (BOV) into the
bund.
Due to the leaking BOV, all of the batch in V6033 drained to the bund in the aftermath of the
incident. It was recovered and stored in an adjacent vessel along with the bund water.
Incident Description
V6033 contained 2800 L of wastewater at 37 ºC, when the operator added 50 L of 35 % H2O2. The addition
elicited a relatively typical temperature rise (37 to 44 ºC) and level gauge response (to foaming). At 9 am the
operator added a further 50L of 35 % H2O2, and 15 minutes later the incident occurred.
Fuel/Ignition Source
From analysis and calculations carried out it is concluded that a vapour phase explosion occurred
due to presence of acetone in the headspace.
Sparking or overheating due to a failed agitator bearing provided the ignition source.
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4.1.3 Incident 03-08 PB2 Reaction Vessel Incident – Update
An incident occurred in PB2 building on 28th April at approximately 01:30, which unfortunately resulted in
the fatality of an employee, and injury to one other. This was reported to EPA by phone at approximately
03:00 and by notification report dated 09 May 2008. This incident involved the over-pressurisation of a
process reaction vessel in PB2. The emergency services were called at the time and remained on site for a
number of hours.
As a result of this incident, production was put on hold and each process step would only restart once a full
safety review/Hazops review and subsequent action items were completed. Start up of production was
therefore on a gradual basis. Production ultimately restarted in PB1 in Mid August.
PB2 production plant has since partially reopened, ground floor areas such as Mill room, dryers etc are now
operational. However the reactor and centrifuges area remain closed pending final repair and commissioning.
There were no significant emissions or release to the environment as a result of this incident.
The Health and Safety Investigation into this incident is still ongoing. Over 100 hazops and safety reviews
have since been completed since the above incident, as of 20 Janurary 2008 and Corden Pharmachem
Management and Staff are still conducting safety reviews of remaining processes.
In an effort to optimise production from PB1, Corden Pharmachem has moved to a 4 shift cycle since
October 2008.
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4.2 Thermal Oxidiser Bypasses
Thermal oxidiser (TO) bypasses gave rise to the most frequently reported incidents during 2008. The
oxidiser control system is designed in such a way that an automatic and failsafe shutdown occurs when
certain operational limits are exceeded. There were IPPC licence breaches during these bypasses, are during
normal operation of the TO.
4.2.1 Causes of bypass
The vast majority of bypasses during 2008 were caused by low bed temperatures (84 or 64% of bypasses).
When the bed temperatures fall below 260ºC, the TO goes into bypass and will not be available to restart
until temperatures are >320ºC. High LEL caused 23 (17%) bypasses, Mechanical faults caused 14 bypasses.
LEL bypasses are caused by high solvent levels and are detected by a lower explosive limit (LEL) analyser.
LEL bypasses can cause the thermal oxidiser to go into safety shutdown. During a shutdown all process
emissions are discharged to a by-pass vent. The main events giving rise to bypasses in 2008 are summarised
as follows;
• Low bed temperatures.
• High LEL
• Mechanical fault (control valves sticking).
• Planned Maintenance
• Loss of steam
4.2.2 Bypass time
Total by-pass time for January–December 2008 was 389.4 hours (23,364 minutes). Weekend bypass duration
during plant shutdown for Q1 and Q2 alone was 22714 and for Q3 and Q4 alone was 3141minutes. During
Q1 and Q2, 51% of the bypass time occurred during weekend shutdowns. Of the annual bypass duration,
17,459 minutes or 75% of bypass time was caused by Low Bed Temperatures and 761 minutes or 3% of
bypass time was planned. Mechanical faults caused 2,930, minutes or 13% of the bypass time. High LEL
accounted for 363 minutes or 1.6% of the total bypass time for 2008
4.2.3 Mass emissions.
The mass VOC emissions during bypasses for 2008 were ~20Kgs Vs 33Kgs for 2007 Vs 36Kgs for 2006.
This represents a reduction of mass emissions of 65% in VOC mass emissions,. This reduction in VOC
CORDEN PHARMACHEM
Section 4: Environmental Incidents
Corden PharmaChem AER 2008 Page 41 of 104
emissions is due to the fact that most bypasses were mechanical or caused by low bed temperatures during
time of low/No emissions and also due to the production and TO shutdown during the year.
4.2.4 2008 performance
Overall the thermal oxidiser was online for approximately 95% of the time in 2008 including weekends. This
compared to the highest recorded online time of 99.1% for 2005 is a small decrease. However as already
stated the reason for this is due to increased low bed temperature bypasses, which Engineering and the
suppliers, KEU have worked on to help alleviate the issue during the shutdown in July 2007 as is well
documented with the agency
0
5,000
10,000
15,000
20,000
25,000
30,000
35,000
2004 2005 2006 2007 2008
Bypass time (mins)
277
37.4 35.7 33 19.58
0
50
100
150
200
250
300
Jan 2003- Jul2004
2005 2006 2007 2008
VOC massemissions(kgs)
CORDEN PHARMACHEM
Section 4: Environmental Incidents
Corden PharmaChem AER 2008 Page 42 of 104
4.2.5 HCl Compliance
100% compliance with HCl limits during 2008 was achieved.
Month Number of HCl 30 minute mean load breaches (i.e. >20mg/m3)
Percentage HCl 30 minute mean compliance
Number of HCl 24 hr mean load breaches (i.e. daily average >10mg/m3)
Percentage HCl 24 hr mean compliance
Jan ‘08 0 100% 0 100% Feb ‘08 0 100% 0 100% March ‘08 0 100% 0 100% April ‘08 0 100% 0 100% May ‘08 0 100% 0 100% June ‘08 0 100% 0 100% July ‘08 0 100% 0 100% August ‘08 0 100% 0 100% September ‘08 0 100% 0 100% October ‘08 0 100% 0 100% November ‘08 0 100% 0 100% December ‘08 0 100% 0 100%
Table 4.2 HCL Compliance as per continuous Analyser
4.3 Complaints
In accordance with Condition 11.4 and schedule D of the IPPC licence, a summary report of the number and
nature of complaints received is included in the AER. Corden PharmaChem have a documented procedure
for recording environmentally related complaints as part of their Environmental Management System.
1 complaint was received during 2008 Vs 7 in 2006, from a neighbouring Farmer. This is summarised in
Table 4.2.1 below. Summary of incident is below:
Summary of Odour Complaint
On 22nd August 2008 an odour complaint was received from a neighbouring farmer, Mr Delaney. There was
an easterly wind at the time and the complainant reported getting odours from the wastewater treatment
plant.
CORDEN PHARMACHEM
Section 4: Environmental Incidents
Corden PharmaChem AER 2008 Page 43 of 104
Corden carried out an investigation and survey around site and noted that there had been an odour around the
WWTP, mainly due to the recommencement of production and the aeration of old sludge in the sludge tank. .
There were low flows through the wastewater treatment plant due to production being shut down for a
number of weeks and as a result levels of waste and fresh sludge decreased.
It was therefore concluded that the odour had arisen due to the anaerobic activity in the sludge at the bottom
of the sludge tank as it was being emptied (age of sludge greatest at bottom of tank). Levels were lower than
usual due to production shutdown, with no fresh waste/sludge being supplied.
Odour surveys were carried out as per usual and the degree of aeration of the old sludge was controlled so to
avoid the dispersion of further odours.
Category of Complaint
Number of Complaints 2008
Odour 1 Noise 0 Water 0
Procedural 0 Miscellaneous 0
Total
1
Table 4.2.1 Complaints Summary
CORDEN PHARMACHEM
Section 5: Management of the Activity
Corden PharmaChem AER 2008 Page 44 of 104
5. MANAGEMENT OF THE ACTIVITY
5.1 Environmental Management System
In accordance with Condition 2.2 Corden PharmaChem have established and continue to
maintain an Environmental Management System (EMS).
ISO14001 accreditation was achieved in Corden PharmaChemin March 2003.
A very successful surveillance audit was undertaken by NSAI in October 2007 on the Corden
ISO 14001 Environmental Management System, within which the IPC non compliances and
subsequent corrective action plans were noted. It was noted that the EMS and general
environmental performance was of a high standard and continually improving. A
recertification audit is due in 2009.
3.2 Human Resources, Training and Education:
Under Condition 2.2.2.6 of the Company’s IPPC licence, Corden PharmaChem are required
to establish and maintain procedures for identifying training needs, and for providing
appropriate training, for all personnel whose work can have a significant effect upon the
environment. Corden PharmaChem are also required to provide appropriate training for
personnel who perform certain tasks, which have significant environmental implications.
During 2007/2008, in-house environmental training/environmental awareness training
sessions were conducted and as required.
5.3 Schedule of Environmental Objectives and Targets
Condition 2.2.2.2 of Corden’s IPC licence requires a schedule of Environmental Objectives
and Targets to be drawn up. The Licence also requires that time frames be included for the
achievement of set targets.
A review of the 2008 Environmental Objectives and Targets/EMP are presented in Appendix
IX of this report. Due to production shutdown during the year some projects were
deferred/cancelled.
The Environmental Objectives and Targets proposed for 2009 are presented in Appendix X.
CORDEN PHARMACHEM
Section 5: Management of the Activity
Corden PharmaChem AER 2008 Page 45 of 104
5.4 Environmental Management Programme
Condition 2.2.2.3 of the IPPC licence requires an Environmental Management Programme
(EMP) to be maintained. The License requires that the EMP shall include designation of
responsibility for targets, the means by which they may be achieved, the time within which
they may be achieved.
Details of the EMP Review of 2008 are presented on a project basis in Appendix IX.
The EMP proposal for 2009 is included in Appendix XI of this report.
CORDEN PHARMACHEM
Section 6: Licence – Specific Reports
Corden PharmaChem AER 2008 Page 46 of 104
6. LICENCE SPECIFIC REPORTS
6.1 Noise
In accordance with Condition 6.12 of the IPPC licence an annual environmental noise survey
was undertaken at the Corden PharmaChem site. The 2008 survey was undertaken in
November.
The full report on the results and methodology of the 2008 noise survey is presented in
Appendix XII of this report.
Table 6.1.1 outlines a summary of the specific source measurements from the Corden
PharmaChem site. These results are within the limits specified in Schedule 4(i) of original
IPC licence P0134-02
dB (A) @ reference distance
Ref Description
Max. Ref Dist (m)
SPL Limit
SPL 2006
SPL 2007
SPL 2008
NS1 Pump House 5 68 63 62 63
NS2 Glycol Pumps 3 76 76 75 76
NS3 Liquid Ring Pumps 3 75 73 73 74
NS4 Air Handler (high level) 10 60 62 61 60
NS5 Boiler House 5 62 N/A N/A N/A
NS6 Treatment Plant Comp 5 63 65 63 63
NS7 Generator 5 90 N/A9 N/A N/A
NS8 Scrubber Pumps 3 72 73 73 72
Table 6.2.1 Comparison between Schedule 4(i) of IPC license and observed sound pressure
levels (SPL)
NS1, NS2, NS3, NS4, NS5, NS6, and NS8 are within the limits specified by the schedule.
Source NS7/NS5 was not operating during the survey period. The ambient noise levels in
daytime and night time, and predicted impact at our nearest sensitive neighbour have not
changed in 2008 .
CORDEN PHARMACHEM
Section 6: Licence – Specific Reports
Corden PharmaChem AER 2008 Page 47 of 104
Table 6.2.2 outlines the noise levels at noise sensitive locations identified from the Corden
PharmaChem site:
Ambient Noise Daytime,
30 min LAeq
Ambient Noise Night time,
15 min LAeq Ref Description
2006 2007 2008 2006 2007 2008
B1 North Boundary 61 56 54 58 55 53
B2 West Boundary 60 59 64 58 58 58
B3 East Boundary 56 58 55 51 54 50
B4 South Boundary 55 59 51 56 54 49
B5 West Boundary 61 60 61 62 61 61
B6 East Boundary 56 58 56 55 52 53
S1
Sensitive Area 1:
Local farm yard/golf course
55 58 57 53 46 45
S2
Sensitive Area 2:
Private residence – on public road
61 62 64 54 49 51
S3
Sensitive Area 3:
Private residence– Estate off public road
58 61 63 47 46 44
Table 6.2.2 Noise Sensitive Locations Result
Daytime ambient noise
According to Schedule B4 and Condition 4.5 of the IPPC license, the maximum daytime
noise levels measured at NSLs is specified as 55 dB(A) (Leq, T). In 2008, this limit was
exceeded at sensitive areas S1, S2 and S3. This was due to neighbouring facilities and road
traffic
Night-time ambient noise
According to Schedule B4 and Condition 4.5 of the IPPC license, the maximum night time
levels off site is specified as 45 dB(A) (Leq, T). In 2008, this limit was exceeded at S2.
CORDEN PHARMACHEM
Section 6: Licence – Specific Reports
Corden PharmaChem AER 2008 Page 48 of 104
As reported previously, there are other larger plants and road traffic in the area, which
contribute more to the overall noise measured at sensitive receivers in particular, than does
Corden PharmaChem. These sensitive receivers are located adjacent to a main road and
several industrial sites which are situated much closer to the receiver than Corden. S1
sensitive receiver is unoccupied farmland.
6.2 Groundwater Monitoring
In accordance schedule C6 of the IPPC license, groundwater monitoring points have been
sampled and analysed for 2008. This Schedule requires biannual monitoring of pH,
temperature, conductivity, level, major anions, major cations, nitrate, total ammonia,
volatile/semi-volatile organics and heavy metals. A report of this monitoring is submitted
biannually and a summary report submitted as part of this AER.
The groundwater sampling was conducted by O’Callaghan Moran and analysis was
conducted by Alcontrol and the full reports are presented in Appendix XIII. The groundwater
monitoring results for 2008 are improved in quality, especially for MTBE. The results are
summarised below:
• All wells except MW-7 with levels of 13.3mg/l in March 2008 were found to
contain less than the Dutch list indicative level of MTBE (9.2 mg/L).
• MTBE was present in levels over EPA IBV of 0.03mg/l in wells, MW-1, 3, 4, 7, 8,
in both March and November 2008 and MW 10 exceeded this level in March only.
However the MTBE concentration is falling from the levels found in 2003/2004 and
is now usually undetected in 3 wells. There have been no incidents or identifiable
on-site sources of MTBE leakage to groundwater at the facility since the previous
round of monitoring was undertaken. The source(s) of MTBE are not considered to
be associated with on-going releases of these parameters to the ground or
groundwater beneath the site.
• Sewage odours detected in wells MW -5 and 6 and Ammonia levels were above
EPA IGV level of 0.14mg/l in all wells on both sample dates. Ammonia
concentrations continue to be elevated and have generally decreased slightly since
the previous monitoring period. There has been an increase in the concentration in
CORDEN PHARMACHEM
Section 6: Licence – Specific Reports
Corden PharmaChem AER 2008 Page 49 of 104
MW-6 since March 2007. It is likely that elevated ammonia levels in the groundwater
originate from upgradient off-site source areas possibly associated with leaking sewers.
• Corden PharmaChem believe this lends credence to our view that treated effluent
and sewage is leaking from a damaged Cork County Council sewer line, as
previously notified to the Agency. For this reason Corden PharmaChem have
relocated final outfall line disharge line (end 2007/beginning 2008)from old IDA
sewer on west of plant to east side of plant , the flaxfort road sewer
• No other organic compound occurred above EPA IGV levels
• The odours and the high levels of total coliforms detected indicate possible
contamination of the groundwater associated with potential leakage from the former
IDA/County Council foul sewer along the FMC/Corden PharmaChem boundary.
The most likely source of contamination in the groundwater beneath the site is
leakage from the former IDA/Council process sewer system up hydraulic gradient of
the facility.
• Monitoring in accordance with IPPC licence conditions will continue to be used to
assess groundwater quality. The presence of upgradient sources of contamination
inhibits an accurate evaluation at this time.
• Based on the results there still appears to be an ongoing source of pollution up
gradient of Cordens site, emphasizing the need for repair on the council sewer
CORDEN PHARMACHEM
Section 6: Licence – Specific Reports
Corden PharmaChem AER 2008 Page 50 of 104
6.3 Bund Testing
Due to changes in personnel at the contract engineers and due to the incident ot Cordens site
in April 2008, bund testing was delayed. A schedule of testing has been drawn up and all
bunds due for testing will be done this year. The Bunds tested this year so far are B5, B7,
B10, B11, B12, all of which passed. Refer to Appendix XIV for Bund certificates and
procedure for bund testing, which was compiled in accordance with EPA guidance document
on the ‘Storage and Transfer of Materials for Scheduled Activities’ (2004).
The schedule below outlines which bunds are due to be tested during 2009 - include B1, B2,
B3, B4, B8A, and B6A. B1 – B4 cannot be tested until shutdown later in 2009.
Bund 20
03
2004
2005
2006
2007
2008
2009
B1 PB1 Tankfarm * * *
B2 PB1 Tankfarm * * *
B3 PB1 Tankfarm * * *
B3A PB1 Tankfarm * *
B4 PB1 Tankfarm * * *
B5 TO Scrubber Bund * *
B6A Diesel Tank * *
B7 Refrigerant tank bund * * *
B8A PB2 Tank farm (neutralisation tank area) * *
B10 PB2 solvent tank farm * * *
B11 PB1 ambient cooling tank bund * * *
B12 Dump tank PB1 * *
B13 Pump bund strong waste tanks * *
B14 Floor collection bund warehouse * *
B15 PB1 Neutralisation Bund * *
Table 6.4.1 Bund Testing Timetable
CORDEN PHARMACHEM
Section 6: Licence – Specific Reports
Corden PharmaChem AER 2008 Page 51 of 104
6.4 Toxicity Testing of Effluents In accordance with schedule C.3.2 of the licence, requires that respiromety of the final
effluent is tested on an annual basis. In 2008 a Respirometry inhibition test on activated
sludge in March were <2 T.U. for 180 min EC50. The Corden PharmaChem trade effluent
sample exhibited a low level of inhibition to Carrigrenan activated sludge with an EC50 value
“greater than 50 % concentration v/v” and an Inhibition Threshold of 30 to 40 % v/v. This
means that the Corden effluent would need to be less than 30 % of the domestic flow in the
sewer to minimise the risk of acute inhibition/toxicity to the activated sludge in the treatment
plant.
At this level our wastewater does not inhibit the activated sludge mixture from the
Carrigrennan plant. In terms of flow, our 80-90 m3 per day would only be expected to have a
minimal impact on the operation of the plant. Corden PharmaChem are licensed to discharge
a maximum of 255 cubic meters of trade effluent per day to the local authority sewer. The
total Dry Weather Flow (DWF) into the Carrigrenan treatment plant is estimated at around
50,000 cubic meters per day and this flow is in the region of 43 % domestic and 57 %
industrial. Based on the company discharging at their maximum discharge allowance of 255
cubic meters per day and a domestic DWF of 21,500 cubic meters per day the Corden trade
effluent would only represent around 1.2 % of the domestic DWF in the sewer. This is
significantly lower than the inhibition threshold of greater than 50 % v/v.
Test reports are contained in Appendix XV.
Corden PharmaChem AER Appendices Page 52 of 104
APPENDICES
Corden PharmaChem AER Appendices Page 53 of 104
Appendix I
Site Plan of the Corden PharmaChem Facility
Corden PharmaChem AER Appendices Page 54 of 104
Appendix II
Corden PharmaChem Organisation Chart
08-04-02 1
Personnel - Organisation
Managing Director
Finance, Admin & IT
Cust. Support& Logistics
Quality Operations R&D EHS
HR & Admin
IT
QC
RA
Production
Engineering
Customer Support
IRL & UKSales
6 8 20 57 9 2
Chemistry
AnalyticalServices
QAFinance Materials
Process Innovation
Corden PharmaChem AER Appendices Page 55 of 104
Appendix III
Environmental Policy Statement
ENVIRONMENTAL POLICY
We at Corden PharmaChem, recognise that our operations have an impact on the surrounding
environment and are committed to a cleaner, healthier environment. We therefore
acknowledge our duty in ensuring that all activities are conducted in an environmentally
responsible manner. Through this we are committed to the integration of sound environmental
programs and practices into our daily business activities at all workplaces so as to meet the
needs of customers, consumers, the company and the public.
With this policy we are committed to:
� Operating our business to meet or exceed the applicable environmental legislation
such as National and EU Legislation and the relevant Codes of Practice and
Guidelines.
� Identifying and reducing risk to minimise environmental impact arising from our
operations and products.
� Providing a framework for setting and reviewing measurable environmental
objectives and targets and to commit to the policy of continuous improvement aimed
at prevention of pollution and improving environmental performance.
� Maintaining an Environmental Management System of which consideration of
environmental concerns and energy efficiency are integral parts of all development
and planning stages.
� Optimising energy efficiency and conservation practices on all the company’s
operations.
� Promoting waste minimisation and to dispose of all waste in a responsible manner,
according to relevant statutory requirements.
Corden PharmaChem AER Appendices Page 56 of 104
� Ensuring that all Corden PharmaChem employees and persons working on behalf of
the company are aware of this policy and the requirements of Corden’s EMS
� Promoting environmental awareness among Corden PharmaChem employees and to
ensure all managers and employees understand their responsibilities and
accountabilities to deliver against the company’s environmental policy.
� Consulting with relevant regulatory agencies, environmental organisations and
interested parties on environmental matters. We recognise the importance of the
neighbourhood in which we operate and will consult with the local community as
necessary to ensure their views are considered.
____________________________
Patrick Burke Date Managing Director
Corden PharmaChem AER Appendices Page 57 of 104
Appendix IV
Incidents and Non-Compliances 2008 Compliance Summary Tables
Corden PharmaChem AER Appendices Page 58 of 104
WASTEWATER LICENCE NON COMPLIANCES 2008 Corden PharmaChem have had 4 final effluent licence breaches in 2008.
Monthly Monitoring
Period Parameter
Emission Point Ref
No.
No of exceedances
(i.e.>ELV) Vs No of samples
Maximum exceedance vs.
Emissions Limit Value
Cause Corrective Action
January 2008
Final Effluent: Total Suspended Solids
SE1 1 of 7
863 mg/l Vs 200 mg/l
High volumes entering WWTP and high levels of solids in the system
• As well as diversion in which the outfall was diverted to holding tanks, flow rates throughout the system were also reduced to help reduce the emissions loadings.
• Diversion and sludge removal helped reduce outfall flowrates as the plant re-established normal operating conditions.
• Increased monitoring of suspended solids
February 2008 Final Effluent: All Parameters
SE1 0 of 136
NA NA
NA
March 2008 Final Effluent: All Parameters
SE1 0 of 136
NA NA
NA
April 2008 Final Effluent: Total Suspended Solids
SE1 8 of 14
1015 mg/l Vs 200 mg/l
Due to high volumes of solids in the system and settleability problems
• Flow rates throughout the system were reduced to help reduce the emissions loadings
• Emptying and cleaning out of clarifiers carried out to help remove solids from the system
• Increased monitoring of suspended
Corden PharmaChem AER Appendices Page 59 of 104
solids April 2008 Final
Effluent: Total Sulphates
SE1 12 of 13 1340 mg/l Vs 500mg/l
A factor giving rise to increased sulphate levels was the bypassing of the sulphuric acid valve on 09th April. Approximately 500litres bypassed directly into the equalisation basin, thereby increasing sulphate levels. These high levels also continued into May and is counted as 1 Incident Breach
• The valve was subsequently fixed and normal service has resumed.
• Flow rates reduced • Increased monitoring of sulphates
May 2008 Final Effluent: Ammonia
SE1 9 of 24 110 mg/l Vs 50mg/l
Since the PB2 incident which occurred on 28th April 2008, production has been stopped until mid August 2008 and as a result the usual waste/feed for the wastewater biological system is not available. As a result the biological system was not operating as effectively as usual. Ammonia levels in the raw influent were lower than ammonia levels in the final effluent, which shows that there was an upset to the plant because of production shutdown. There was a source of waste onsite, which was fed in at a slow rate as it is a strong waste. The main bulk of the waste streams however were not available due to production shutdown.
• Sourced different waste from around site to improve biological properties of system.
• Increased monitoring of Ammonia
June – December 2008
Final Effluent: All Parameters
SE1 0 of ~ 900
NA NA
NA
Corden PharmaChem AER Appendices Page 60 of 104
SURFACE WATER NON COMPLIANCES
Corden PharamChem had 2 surface/storm water warning level exceedances in 2008 period
Monthly Monitoring
Period Parameter
Emission Point Ref
No.
No of exceedances vs. No. of samples
Maximum exceedance vs. Warning Level
Cause Corrective Action
January 2008
pH, Temp, BOD, COD, TOC
SW1 0 NA NA NA
February 2008
COD SW1 2 of 3 160 Vs 100mg/l COD
Testing of TOC analysers and cleaning of surface water chamber.
• Following extensive maintenance and cleaning of the TOC unit, it was planned to resume normal mode and closely monitor the situation to ensure compliance with IPPC licence.
• Surface water flow diverted to onsite containment
March – December 2008
pH, Temp, BOD, COD, TOC
SW1 0 NA NA NA
Corden PharmaChem AER Appendices Page 61 of 104
Thermal Oxidiser emissions summary Corden had 0 TOC mass emission licence breaches in 2008
Monthly Monitoring Period
Parameter Emission Point Ref No.
No of exceedances vs. No. of samples
Maximum exceedance vs. Emissions Limit Value
Cause Corrective Action
January - December
TOC mass emission
A2/1 0 of 1488 No exceedance No exceedance
No exceedance
February TOC mass emission
A2/1 0 of 1344 No exceedance No exceedance No exceedance
March TOC mass emission
A2/1 0 of 1488 No exceedance No exceedance No exceedance
April TOC mass emission
A2/1 0 of 1440 No exceedance No exceedance. No exceedance
May TOC mass emission
A2/1 0 of 0 (TO Shutdown)
No exceedance No exceedance. No exceedance
June TOC mass emission
A2/1 0 of 0 (TO Shutdown)
No exceedance No exceedance No exceedance
July TOC mass emission
A2/1 0 of 0 (TO Shutdown)
No exceedance No exceedance No exceedance
August TOC mass emission
A2/1 0 of 1008 No exceedance No exceedance No exceedance
September TOC mass emission
A2/1 0 of 1440 No exceedance No exceedance No exceedance
October TOC mass emission
A2/1 0 of 1488 No exceedance No exceedance. No exceedance
November TOC mass emission
A2/1 0 of 1440 No exceedance No exceedance. No exceedance
December TOC mass emission
A2/1 0 of 1008 No exceedance No exceedance No exceedance
Corden PharmaChem AER Appendices Page 62 of 104
HCL Compliances
Corden had 0 HCl licence breaches in 2008
Monthly Monitoring Period
Parameter Emission Point Ref No.
No of exceedances vs. No. of samples (1/2 hour value s >20mg/m3)
Maximum exceedance vs. Emissions Limit Value
Cause Corrective Action
January – December
2008
Hydrogen Chloride
A2/1 0 of ~ 12000 No exceedance No exceedance No exceedance
Corden PharmaChem AER Appendices Page 63 of 104
Appendix V
Dioxin Monitoring Report 2008
Not included, as Full AER Report in PDF would exceed 20mb capacity (already submitted to
EPA and in Paper version of AER - details in summary section of AER)
Corden PharmaChem AER Appendices Page 64 of 104
Appendix VI
Dust Monitoring for 2008
Not included, as Full AER Report in PDF would exceed 20mb capacity (already submitted to
EPA and in Paper version of AER - details in summary section of AER)
Appendix VII
PRTR Waste Tables for 2008
Corden PharmaChem AER Appendices Page 65 of 104
Transfer Destination
European Waste Code
Hazardous
Quantity
T/Year
Description of Waste
Waste Treatment Operation
M/C/E
Method Used
Location of Treatment
Name and Licence /
Permit No. of Recoverer / Disposer /
Broker
Address of
Recoverer / Disposer / Broker
Name and Address of
Final Destination
i.e. Final Recovery /
Disposal Site (HAZARDOUS
WASTE ONLY)
Licence / Permit No.
of Final Destination
i.e. Final Recovery / Disposal
Site (HAZARDOU
S WASTE ONLY)
To Other Countries 07 05 01 Yes 190.0 LRDA Salts D8 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
ATM Afvalstoffen terminal Moerdijk BV Vlasweg 12, Seaport M152, 4782 PW Moerdijk, Netherlands 930809.002/4
To Other Countries 07 05 01 Yes 20.1 LRDA Salts D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Sava GmbH, Osterweute 1 26541 Brunsbuttel, Germany
A 51 G 00 508
To Other Countries 07 05 01 Yes 71.5 Cyanide waste D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Sava GmbH, Osterweute 1 26541 Brunsbuttel, Germany
A 51 G 00 508
Within the Country 07 05 01 Yes 163.0 Aqueous solvent R13 M Weighed
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
AVR Safeway, Corrin, Fermoy, Co. Cork W0050-2
Corden PharmaChem AER Appendices Page 66 of 104
Transfer Destination
European Waste Code
Hazardous
Quantity
T/Year
Description of Waste
Waste Treatment Operation
M/C/E
Method Used
Location of Treatment
Name and Licence / Permit No. of Recoverer / Disposer / Broker
Address of Recoverer / Disposer / Broker
Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
To Other Countries 07 05 01 Yes 45.1 Aqueous solvent D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Sava GmbH, Osterweute 1 26541 Brunsbuttel, Germany
A 51 G 00 508
To Other Countries 07 05 01 Yes 45.9 Aqueous solvent D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Pyros Environmental, Charleston Rd, Southhampton, UK ZP3632SR
Within the Country 07 05 04 Yes 405.0 Mixed Solvent R2 M Weighed
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Soltec Ireland Ltd, Mullingar Co. Westmeath 115-1
To Other Countries 07 05 04 Yes 48.7 Aqueous solvent D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Pyros Environmental, Charleston Rd, Southhampton, UK ZP3632SR
Within the Country 07 05 04 Yes 360.0 Mixed Solvent R13 M Weighed
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
AVR Safeway, Corrin, Fermoy, Co. Cork W0050-2
Corden PharmaChem AER Appendices Page 67 of 104
Transfer Destination
European Waste Code
Hazardous
Quantity
T/Year
Description of Waste
Waste Treatment Operation
M/C/E
Method Used
Location of Treatment
Name and Licence / Permit No. of Recoverer / Disposer / Broker
Address of Recoverer / Disposer / Broker
Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
Within the Country 07 05 04 Yes 22.1 Mixed Solvent D13 M Weighed
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
AVR Safeway, Corrin, Fermoy, Co. Cork W0050-2
Within the Country 07 05 04 Yes 25.0 Mixed Solvent D15 M Weighed
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
AVR Safeway, Corrin, Fermoy, Co. Cork W0050-2
To Other Countries 07 05 04 Yes 21.5 Mixed Solvent R1 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
SRM Morecambe, Lancashire, UK
AG9248/BL7302ID
To Other Countries 07 05 04 Yes 4.23
Waste Packed solvents D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Sava GmbH, Osterweute 1 26541 Brunsbuttel, Germany
A 51 G 00 508
Within the Country 07 05 04 Yes 0.394
Waste Packed solvents R13 M Weighed
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
AVR Safeway, Corrin, Fermoy, Co. Cork W0050-2
Within the Country 07 05 04 Yes 19.7 Waste THF R13 M Weighed
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
AVR Safeway, Corrin, Fermoy, Cork W0050-2
Corden PharmaChem AER Appendices Page 68 of 104
Transfer Destination
European Waste Code
Hazardous
Quantity
T/Year
Description of Waste
Waste Treatment Operation
M/C/E
Method Used
Location of Treatment
Name and Licence / Permit No. of Recoverer / Disposer / Broker
Address of Recoverer / Disposer / Broker
Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
To Other Countries 07 01 04 Yes 0.163
Paked sodium salts D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Sava GmbH, Osterweute 1 26541 Brunsbuttel, Germany
A 51 G 00 508
To Other Countries 07 05 03 Yes 0.198
Packed waste - ethylene dichloride,
methylene chloride,
fluororobenzene, diethyl carbomyl
chloride D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Sava GmbH, Osterweute 1 26541 Brunsbuttel, Germany
A 51 G 00 508
To Other Countries 07 07 04 Yes 3.43 Sodium salts D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Sava GmbH, Osterweute 1 26541 Brunsbuttel, Germany
A 51 G 00 508
To Other Countries 07 07 04 Yes 27.5
Low Ph, Ethyl Acetate / HCL /
IPA R2 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
BIP Organics LTD, Middlewich, Cheshire, UK BS5223IH
Corden PharmaChem AER Appendices Page 69 of 104
Transfer Destination
European Waste Code
Hazardous
Quantity
T/Year
Description of Waste
Waste Treatment Operation
M/C/E
Method Used
Location of Treatment
Name and Licence / Permit No. of Recoverer / Disposer / Broker
Address of Recoverer / Disposer / Broker
Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
To Other Countries 07 05 13 Yes 3.87
contaminated solids wastes D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Pyros Environmental, Charleston Rd, Southhampton, UK ZP3632SR
To Other Countries 07 05 13 Yes 4.3
contaminated solids wastes R3 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
ATM Afvalstoffen terminal Moerdijk BV Vlasweg 12, Seaport M152, 4782 PW Moerdijk, Netherlands 930809.002/4
To Other Countries 07 05 13 Yes 15.8
contaminated solids wastes D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Sava GmbH, Osterweute 1 26541 Brunsbuttel, Germany
A 51 G 00 508
Within the Country 15 01 02 No 5.54
Waste Empty plastic containers
washed D10 M Weighed Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
AVR Safeway, Corrin, Fermoy, Co. Cork W0050-2
Corden PharmaChem AER Appendices Page 70 of 104
Transfer Destination
European Waste Code
Hazardous
Quantity
T/Year
Description of Waste
Waste Treatment Operation
M/C/E
Method Used
Location of Treatment
Name and Licence / Permit No. of Recoverer / Disposer / Broker
Address of Recoverer / Disposer / Broker
Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
To Other Countries 15 01 10 Yes 5.11
contaminated wastes packaging D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Sava GmbH, Osterweute 1 26541 Brunsbuttel, Germany
A 51 G 00 508
Within the Country 15 01 10 Yes 4.52 waste metal drums R4 M Weighed
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
AVR Safeway, Corrin, Fermoy, Co. Cork W0050-2
Within the Country 15 01 10 Yes 0.993
Waste contaminated
drums D10 M Weighed Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
AVR Safeway, Corrin, Fermoy, Co. Cork W0050-2
To Other Countries 15 02 02 Yes 1.43
absorbents, filters, waste PPE, wipes,
gloves, spill kits D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Sava GmbH, Osterweute 1 26541 Brunsbuttel, Germany
A 51 G 00 508
To Other Countries 16 05 07 Yes 0.392
Inorganic wastes - LAB D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Sava GmbH, Osterweute 1 26541 Brunsbuttel, Germany
A 51 G 00 508
Corden PharmaChem AER Appendices Page 71 of 104
Transfer Destination
European Waste Code
Hazardous
Quantity
T/Year
Description of Waste
Waste Treatment Operation
M/C/E
Method Used
Location of Treatment
Name and Licence / Permit No. of Recoverer / Disposer / Broker
Address of Recoverer / Disposer / Broker
Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
To Other Countries 16 05 08 Yes 1.31
discarded organic waste from labs D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Sava GmbH, Osterweute 1 26541 Brunsbuttel, Germany
A 51 G 00 508
Within the Country 16 06 01 Yes 0.002 Wet batteries R4 M Weighed
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
WEEE Recycle, Cappincur IE, Tullamore, Offaly W0113-03
Within the Country 16 06 02 Yes 0.172 Waste dry batteries R4 M Weighed
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
WEEE Recycle, Cappincur IE, Tullamore, Offaly W0113-03
To Other Countries 20 01 14 Yes 1.56 Waste acids D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Sava GmbH, Osterweute 1 26541 Brunsbuttel, Germany
A 51 G 00 508
Corden PharmaChem AER Appendices Page 72 of 104
Transfer Destination
European Waste Code
Hazardous
Quantity
T/Year
Description of Waste
Waste Treatment Operation
M/C/E
Method Used
Location of Treatment
Name and Licence / Permit No. of Recoverer / Disposer / Broker
Address of Recoverer / Disposer / Broker
Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
To Other Countries 20 01 15 Yes 0.056 Solid KOH, NaOH D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Sava GmbH, Osterweute 1 26541 Brunsbuttel, Germany
A 51 G 00 508
To Other Countries 20 01 21 Yes 0.15 Fluorescent tubes R4 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Indaver Relight NV, 2030 Antwerpen, belgium
46003/233/11/1
To Other Countries 20 01 27 Yes 2.08 Waste Resin D10 M Weighed Abroad
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
Sava GmbH, Osterweute 1 26541 Brunsbuttel, Germany
A 51 G 00 508
Within the Country 20 01 36 No 0.417
Electronic Equipment R4 M Weighed
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
techrec Ltd, Nabgor rd, Dublin 12 WP 98099
Within the Country 20 03 07 No 18.6
commercial and industrial waste R13 E
Volume Calculation
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
greenstar MRF, glyntown cork
W 136-2/CK WMC/42/01 & CK WMC/323/05
Corden PharmaChem AER Appendices Page 73 of 104
Transfer Destination
European Waste Code
Hazardous
Quantity
T/Year
Description of Waste
Waste Treatment Operation
M/C/E
Method Used
Location of Treatment
Name and Licence / Permit No. of Recoverer / Disposer / Broker
Address of Recoverer / Disposer / Broker
Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
Within the Country 20 01 01 No 11.4
paper and cardboard R13 E
Volume Calculation
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
greenstar MRF, glyntown cork
W 136-2/CK WMC/42/01 & CK WMC/323/05
Within the Country 15 01 06 No 1.32 mixed packaging R13 E
Volume Calculation
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
greenstar MRF, glyntown cork
W 136-2/CK WMC/42/01 & CK WMC/323/05
Within the Country 17 01 07 No 2.03
demolition waste, concrete etc R13 E
Volume Calculation
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
greenstar MRF, glyntown cork
W 136-2/CK WMC/42/01 & CK WMC/323/05
Within the Country 20 01 38 No 0.578 wood R13 E
Volume Calculation
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
greenstar MRF, glyntown cork
W 136-2/CK WMC/42/01 & CK WMC/323/05
Within the Country 20 03 07 No 11.6
commercial and industrial waste D15 E
Volume Calculation
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
greenstar MRF, glyntown cork
W 136-2/CK WMC/42/01 & CK WMC/323/05
Within the Country 20 01 01 No 7.1
paper and cardboard D15 E
Volume Calculation
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
greenstar MRF, glyntown cork
W 136-2/CK WMC/42/01 & CK WMC/323/05
Corden PharmaChem AER Appendices Page 74 of 104
Transfer Destination
European Waste Code
Hazardous
Quantity
T/Year
Description of Waste
Waste Treatment Operation
M/C/E
Method Used
Location of Treatment
Name and Licence / Permit No. of Recoverer / Disposer / Broker
Address of Recoverer / Disposer / Broker
Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)
Within the Country 15 01 06 No 0.83 mixed packaging D15 E
Volume Calculation
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
greenstar MRF, glyntown cork
W 136-2/CK WMC/42/01 & CK WMC/323/05
Within the Country 17 01 07 No 0.362
demolition waste, concrete etc D15 E
Volume Calculation
Offsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
greenstar MRF, glyntown cork
W 136-2/CK WMC/42/01 & CK WMC/323/05
Within the Country 20 01 38 No 1.27 wood D15 E
Volume Calculation
Onsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
greenstar MRF, glyntown cork
W 136-2/CK WMC/42/01 & CK WMC/323/05
Within the Country 07 05 12 No 160.0
Sludge from wastewater
treatment plant R1 M Weighed Onsite in Ireland
AVR Safeway/W0050-2
Corrin, Fermoy, Co. Cork
AVR Environmental solutions, Youghal Co. Cork W0211-01
Corden PharmaChem AER Appendices Page 75 of 104
Appendix VIII
Utilities Reports 2008
&
Utilities reports for previous years for comparison
Corden PharmaChem AER Appendices Page 76 of 104
Electricity Bill
Breakdown
Date Cost € Consumption
kWh Jan-06 38095.6 446536 Feb-06 36967.4 433452 Mar-06 40009.46 470571 Apr-06 38048.57 446667 May-06 39246.61 462097 Jun-06 36073.96 420570 Jul-06 26782.4 305036 Aug-06 36834.31 431443 Sep-06 35842.36 418736 Oct-06 37107.04 434027 Nov-06 55537.53 428341 Dec-06 45587.65 347905 Jan-07 54635.15 439382 Feb-07 48967.62 392787 Mar-07 43080.13 435902 Apr-07 41019.57 412883 May-07 44755.14 453044 Jun-07 43169.44 438330 Jul-07 28921.17 283933 Aug-07 44064.99 446881 Sep-07 43382.48 439277 Oct-07 44475.06 449368 Nov-07 49174.47 447803 Dec-07 39181.69 349690 Jan-08 50175.18 455059 Feb-08 45651.08 407773 Mar-08 43868.44 390245 Apr-08 52963.59 402200 May-08 27651.37 195420 Jun-08 16778.04 111284 Jul-08 19677.18 124955 Aug-08 31994.57 218669 Sep-08 38458.88 282951 Oct-08 43005.5 276175 Nov-08 42583.45 293390 Dec-08 42583.45 293390
Corden PharmaChem AER Appendices Page 77 of 104
Gas Bill Breakdown
06-08
Date Cost Consumption
kWh Jan-06 29430.6 807010 Feb-06 28606.93 774250 Mar-06 31273.48 852952 Apr-06 17623.66 648143 May-06 22234.25 588171 Jun-06 14173.35 471850 Jul-06 12621.64 272764 Aug-06 15557.36 456131 Sep-06 14062.8 476894 Oct-06 16840.57 586412 Nov-06 26239.39 775190 Dec-06 25553.3 614538 Jan-07 30690.01 853890 Feb-07 25757.08 705810 Mar-07 15820.75 780750 Apr-07 11788.45 592842 May-07 14040.82 588750 Jun-07 12929.53 516741 Jul-07 9602.89 194820 Aug-07 12709.04 396120 Sep-07 13688.95 406778 Oct-07 16428.26 469979 Nov-07 21593.05 611188 Dec-07 20118.93 621891 Jan-08 28913.21 857483 Feb-08 25032.71 764446 Mar-08 24660.44 726322 Apr-08 26075.16 707682 May-08 12287.64 234519 Jun-08 5988.72 8806 Jul-08 8733.8 113293 Aug-08 11953.49 243216 Sep-08 15203.63 297569 Oct-08 17433.18 423473 Nov-08 21062.56 587486 Dec-08 17597.88 513076
Corden PharmaChem AER Appendices Page 78 of 104
Appendix IX
Review of 2008
Environmental Objectives and Targets & Environmental Management
Corden PharmaChem AER Appendices Page 79 of 104
Review of 2008 Environmental Management Programme
Project 01/2008 Waste Management/Responsible Resource Management
Relationship to objectives and targets:
This project is in line with Corden’s 2008 objective number 1 &10. It is also linked to aspect 2.3, 2.8 and 7.1 of the 2008 Aspects impact register.
Reason for undertaking project:
To reduce resource consumption/waste and emissions to atmosphere
Target:
Reduce consumption of Ethyl Acetate and IPA
Project Summary:
Reengineer final step of tramadol HCL to reduce solvent consumption:
Designation of Responsibility:
R&D
Time Frame: 1. Completion of lab trials by plant shutdown in July
2. Implemented thereafter
Status: This project was cancelled
Corden PharmaChem AER Appendices Page 80 of 104
Project 02/2008 Responsible resource management
Relationship to objectives and targets:
This project is in line with Corden’s 2008 objective number 3.
It is also linked to aspect 7.4 of the 2008 Aspects impact register.
Reason for undertaking project:
Reduce energy consumption.
Reduce water consumption by 5%
Target: To run different energy saving campaigns during 2008
Project Summary:
Reduce overall energy usage by increasing awareness and implementing energy savings initiatives/projects
Interlock valve will be fitted to PB1 vacuum pump, when all the vacuum pumps are off the water valve will close. Estimated cost of project is €867; estimated savings is €6000/annum. Payback of 1.4 months.
Investigate Weekend energy consumption:
Designation of Responsibility:
Engineering Manager
Time Frame: December 2008
Completed Items: Set up of Energy Management Team.
During 2008 will run campaigns such as:
1. switch it off
2. Water savings and reduce water consumption by 5%
Status Interlock to be fitted to PB1 vacuum pump in 2009
Corden PharmaChem AER Appendices Page 81 of 104
Project 03/2008 Reduction of emissions to water/sewer
Relationship to objectives and targets:
This project is in line with Corden’s 2008 objective number 2
It is also linked to aspect 2.3 and 4.1 of the 2008 Aspects impact register.
Reason for undertaking project:
Reduction volumes of emissions to sewer
Target: To reduce amount of waste to be treated and therefore volume emitted to sewer
Project Summary:
Diverting of water used to cool HCl cylinders to PASD drain this will save of the cost of treating this water in the WWTP. Preventing rainwater from entering the WWTP during heavy periods of rain by putting in a further drain. Again this will save by not having to treat this water and also help with capacity issues in the WWTP.
Designation of Responsibility:
Utilities Officer
Time Frame: Q3 2008
Completed Items: Ongoing
Status Completed in 2008
Project 04/2008 Emissions to Atmosphere
Relationship to objectives and targets:
This project is in line with Corden’s 2008 objective number 6 &7 and It is also linked to aspect 2.3 of the 2008 Aspects impact register.
Reason for undertaking project:
Reduction of emissions to atmosphere
Target: Reduce spillages/fugitive emissions
Project Summary: Reduce TOC emissions during bypass times when planned maintenance is taking place
Designation of Responsibility:
EHS/Instrumentation
Time Frame: Q, 2008
Completed Items: Ongoing
Status Maintenance work carried out during production shutdown,
No real benefit
Corden PharmaChem AER Appendices Page 82 of 104
Project 05/2008 Emissions to Atmosphere
Relationship to objectives and targets:
This project is in line with Corden’s 2008 objective number 7 and It is also linked to aspect 2.6 of the 2008 Aspects impact register.
Reason for undertaking project:
Reduction of active dust and particulates to local atmosphere and reduction of exposure to personnel. Improving the handling of drug substances is consistent with, and necessary for, reaching the company’s goals of high Quality, Safety, and Environmental and Operational standards.
Target: Improve interior air quality
Project Summary:
Upgrade of sieving and milling activities. Powder handling system will be fully contained and inerted Improving the handling of drug substances is consistent with, and necessary for, reaching the company’s goals of high Quality, Safety, and Environmental and Operational standards.
Designation of Responsibility:
Engineering/Operations
Time Frame: Q4, 2008
Completed Items: Ongoing
Status Deferred to 2009
Corden PharmaChem AER Appendices Page 83 of 104
Project 06/2008 Emissions to Atmosphere
Relationship to objectives and targets:
This project is in line with Corden’s 2008 objective number 3, 6 & 7 and It is also linked to aspect 2.3, 2.6 and 7.4 of the 2008 Aspects impact register.
Reason for undertaking project:
To improve monitoring of critical parameters on vessels during production; to improve recording and reliability of recording and to provide reliable trending
Target: Improve process monitoring which could lead to reduction in emissions to atmosphere e.g. too high pressures could can lead to high emissions and therefore bypass at TO. Improved process monitoring should reduce the frequency of this occurrence
Project Summary:
New Operation Monitoring System; installation of pressure and temperature indicators:
In PB1, currently we have 7 Foxboro Pneumatic Control Chart recorders Model 122-FP, which are at least 25-year-old technology.
It is proposed to replace these pneumatic recorders with a “Multi Channel Process System” (MCPS) data acquisition application, which will allow the reactor sump temperatures and pressures to be displayed on a PC screen in the PB1 supervisor’s office. Historical trending data can be accessed from a server and can then be printed off, selecting any desired timeframe
Designation of Responsibility:
Engineering/Operations
Time Frame: Q4, 2008
Completed Items: Ongoing
Status Completed
Corden PharmaChem AER Appendices Page 84 of 104
Project 07/2008 Emissions to surface water/Groundwater protection
Relationship to objectives and targets:
This project is in line with Corden’s 2008 objective number 8 and linked to aspects 3.1 and 4.1 of the 2008 environmental aspects and impacts register
Reason for undertaking project:
To reduce fugitive emissions and possible surface water/groundwater contamination
Target: Reduce potential emissions
Project Summary:
Upgrade overhead floor drain (from PB2 directly to waste treatment) to Glass Reinforced Plastic
Designation of Responsibility:
Engineering/Operations
Time Frame: Q4, 2008
Completed Items: Ongoing
Status Deferred to 2009
Project 08/2008 Responsible Resource Management
Relationship to objectives and targets:
This project is in line with Corden’s 2008 objective number 3 and is linked to aspect 7.4 of the 2008 impacts and aspects register.
Reason for undertaking project:
• Reduce steam and hence gas required to heat the domestic hot water system
• The installation of solar panels would help raise the environment profile of the site.
Target:
Project Summary:
Upgrade of hotwater generation system
Investigate possible installation of solar panels to supplement the domestic hot water system and install a system to heat water as required rather than the current storage and distribute system.
Designation of Responsibility:
Engineering/Operations
Time Frame: Q4, 2008
Completed Items: Ongoing
Status Project cancelled
Corden PharmaChem AER Appendices Page 85 of 104
Project 09/2008 Emissions to Atmosphere/Sewer
Relationship to objectives and targets:
This project is in line with Corden’s 2008 objective number 10
Reason for undertaking project:
To reduce emissions to WWTP by ensuring it is safely and adequately treated in neutralisation tank
Target: To reduce emissions to WWTP
Project Summary:
Upgrade neutralisation tanks:
This tank needs to be upgraded in order to allow safe treatment of cyanide waste
Designation of Responsibility:
Engineering/Operations
Time Frame: Q4, 2008
Completed Items: Ongoing
Status Deferred to 2009 – major capital project
Project 10/2008 Resource Management
Relationship to objectives and targets:
This project is in line with Corden’s 2008 objective number 3 and It is also linked to aspect 7.4 of the 2008 Aspects impact register.
Reason for undertaking project:
The current insulation is 30 years old. New insulation would reduce the heat loss of the condensate and hence reduce heat load in the boiler to evaporate the water
Target: To reduce energy consumption
Project Summary:
Upgrade of PB1 steam and condensate supply and return
Designation of Responsibility:
Engineering/Operations
Time Frame: Q4, 2008
Completed Items: Ongoing
Status Deferred to 2010
Corden PharmaChem AER Appendices Page 86 of 104
Project 11/2008 Emissions to Atmosphere
Relationship to objectives and targets:
This project is in line with Corden’s 2008 objective number 10 and It is also linked to aspect 2.8 of the 2008 Aspects impact register.
Reason for undertaking project:
Improving the air quality of the work area is consistent with, and necessary for, reaching the company’s goals of high Quality, Safety, and Environmental and Operational standards.
Target: To improve air quality of PB1 general area
Project Summary:
Upgrade PB1 local Exhaust ventilation –
Increase number of local extract point (no. of Niedermann arms etc)
Install a clean/wash room so to reduce personnel exposure during cleaning of equipment
Designation of Responsibility:
Engineering/Operations
Time Frame: Q4, 2008
Completed Items: Ongoing
Status Complete
Corden PharmaChem AER Appendices Page 87 of 104
Appendix X
Environmental Objectives and Targets
Proposal for 2009
Corden PharmaChem AER Appendices Page 88 of 104
Proposal for 2009 Schedule of Objectives and Targets No. Objective Target for 2009
1
Hazardous Waste Management and
process modifications giving improved
yields
Reduce hazardous waste volumes
2 Reduction of Wastewater mass
emissions. Achieve effluent reduction
3 Responsible resource management Reduce electricity and gas use by for
2009
4 Responsible resource management Investigate potential water savings
projects
5 Responsible resource management Reduce Nitrogen losses
6 Reduction of emissions to air Reduce number of Thermal Oxidiser
bypasses and mass emissions.
7 Reduction of emissions to air
Reduce emission of HCL to atmosphere
as well as other emissions such as dust
etc
8 Reduction of emissions to water Reduce contamination of surface water.
9 Protection of groundwater &
stormwater
Ensure integrity of underground drains
and pipes.
10 Reduction of fugitive process emissions
to air
Reduce fugitive emissions from
processes & plant
Corden PharmaChem AER Appendices Page 89 of 104
Appendix XI
Environmental Management Programme (EMP)
Proposal for 2009
Corden PharmaChem AER Appendices Page 90 of 104
Environmental Management Projects Proposal 2009
Project 01/2009 Responsible resource management
Relationship to objectives and targets:
This project is in line with Corden’s 2009 objective number 3 & 4.
It is also linked to aspect 7.4 of the 2009 Aspects impact register.
Reason for undertaking project:
Reduce energy consumption.
Reduce water consumption by 5%
Target: To investigate potential water saving initiatives
Project Summary:
Reduce overall energy usage by increasing awareness and implementing energy savings initiatives/projects
Interlock valve will be fitted to PB1 vacuum pump, when all the vacuum pumps are off the water valve will close. Estimated cost of project is €867; estimated savings is €6000/annum. Payback of 1.4 months.
Designation of Responsibility:
Engineering Manager
Time Frame: Mid 2009 for installation of interlock on vacuum pump
Completed Items: Set up of Energy Management Team.
During 2008 will run campaigns such as:
3. switch it off
4. Water savings and reduce water consumption by 5%
Corden PharmaChem AER Appendices Page 91 of 104
Project 02/2009 Emissions to Atmosphere
Relationship to objectives and targets:
This project is in line with Corden’s 2009 objective number 7 and It is also linked to aspect 2.6 of the 2008 Aspects impact register.
Reason for undertaking project:
Reduction of active dust and particulates to local atmosphere and reduction of exposure to personnel. Improving the handling of drug substances is consistent with, and necessary for, reaching the company’s goals of high Quality, Safety, and Environmental and Operational standards.
Target: Improve interior air quality
Project Summary:
Upgrade of sieving and milling activities. Powder handling system will be fully contained and inerted Install flap vavles on equipment for loading of materials to reactors Improving the handling of drug substances is consistent with, and necessary for, reaching the company’s goals of high Quality, Safety, and Environmental and Operational standards.
Designation of Responsibility:
Engineering/Operations
Time Frame: Q3, 2009
Completed Items: Ongoing
Corden PharmaChem AER Appendices Page 92 of 104
Project 03/2009 Emissions to surface water/Groundwater protection
Relationship to objectives and targets:
This project is in line with Corden’s 2009 objective number 8 and linked to aspects 3.1 and 4.1 of the 2008 environmental aspects and impacts register
Reason for undertaking project:
To reduce fugitive emissions and possible surface water/groundwater contamination
Target: Reduce contamination and ensure intregrity of pipework
Project Summary:
Upgrade overhead floor drain (from PB2 directly to waste treatment) to Glass Reinforced Plastic
Designation of Responsibility:
Engineering/Operations
Time Frame: Q4, 2009
Completed Items: Ongoing
Project 04/2009 Emissions to Atmosphere/Sewer
Relationship to objectives and targets:
This project is in line with Corden’s 2007 objective number 10
Reason for undertaking project:
To reduce cyanide emissions to WWTP by ensuring it is safely and adequately treated in neutralisation tank
Target: To reduce emissions to WWTP
Project Summary:
Upgrade neutralisation tanks:
These tanks need to be upgraded in order to allow safe treatment of waste
Designation of Responsibility:
Engineering/Operations
Time Frame: Q4, 2009
Completed Items: Ongoing – Major capital project
Corden PharmaChem AER Appendices Page 93 of 104
Project 05/2009 Resource Management
Relationship to objectives and targets:
This project is in line with Corden’s 2009 objective number 3 and It is also linked to aspect 7.4 of the 2008 Aspects impact register.
Reason for undertaking project:
The current insulation is 30 years old. New insulation would reduce the heat loss of the condensate and hence reduce heat load in the boiler to evaporate the water
Target: To reduce energy consumption
Project Summary:
Upgrade of PB1 steam and condensate supply and return
Designation of Responsibility:
Engineering/Operations
Time Frame: 2010
Completed Items: Ongoing
Corden PharmaChem AER Appendices Page 94 of 104
Project 06/2009 Emissions to Atmosphere
Relationship to objectives and targets:
This project is in line with Corden’s 2007 objective number 10 and It is also linked to aspect 2.8 of the 2008 Aspects impact register.
Reason for undertaking project:
Improving the air quality of the work area is consistent with, and necessary for, reaching the company’s goals of high Quality, Safety, and Environmental and Operational standards.
Target: To improve air quality of PB1 general area
Project Summary:
to carry out thorough clean and inspection of ducts during 2009, so to ensure build up is not occurring in pipework
Designation of Responsibility:
Engineering/Operations
Time Frame: Q4, 2009
Completed Items: Ongoing
Corden PharmaChem AER Appendices Page 95 of 104
Appendix XII
External Acoustic Survey - November 2008
Not included, as Full AER Report in PDF would exceed 20mb capacity (already submitted to
EPA and in Paper version of AER - details in summary section of AER)
Corden PharmaChem AER Appendices Page 96 of 104
Appendix XIII
Groundwater Monitoring Reports
March & November 2008
Not included, as Full AER Report in PDF would exceed 20mb capacity (already submitted to
EPA and in Paper version of AER - details in summary section of AER)
Corden PharmaChem AER Appendices Page 97 of 104
Appendix XIV
Bund Testing Reports
Corden PharmaChem AER Appendices Page 98 of 104
Bund Testing Certificate
Test details
Client: Corden PharmaChem
Bund Location: B5 – T.O. Scrubber bund
Survey Dates: 25– 27 February 2009 Personnel Involved:
Colin Barry – Utilities Operator Fergal Condon – Utilities Operator
Daily log
Date Comments Water level(mm)
Evaporation Personnel
25/02/09 Relaxation Period
90 0 Colin Barry,
Fergal Condon
26/02/09 Standby vessel 10 L
87 0 Colin Barry,
Fergal Condon
27/02/09 Standby vessel 10 L
87 0 Colin Barry,
Fergal Condon
Comments This bund was tested in accordance to B.S. 8007:1987 – Design of concrete structures for retaining aqueous liquids: section nine, inspection and test of the structure and in conjunction with EPA guidance note on Storage and Transfer of Materials for Scheduled Activities. Test Conducted by: Signed: ________________________________ Utilities Operator ________________________________ Utilities Operator
Conformance to B.S. 8007: Section 9
Passed
Reviewed By: Signed ______________________________
Corden PharmaChem AER Appendices Page 99 of 104
Head of Engineering Approved by: Signed ______________________________ EHS Manager
Bund Testing Certificate
Test details
Client: Corden PharmaChem
Bund Location: B7 –PB1 refrigerant Bund
Survey Dates: 24– 27 February 2009 Personnel Involved:
Colin Barry – Utilities Operator Fergal Condon – Utilities Operator
Daily log
Date Comments Water level(mm)
Evaporation Personnel
24/02/09 Relaxation Period
230 0 Colin Barry, Fergal Condon
25/03/09 Standby vessel 10 L
230 0 Colin Barry,
Fergal Condon
26/03/09 Standby vessel 10 L
230 0 Colin Barry,
Fergal Condon
27/03/09 Standby vessel 10 L
230 0 Colin Barry,
Fergal Condon
Comments This bund was tested in accordance to B.S. 8007:1987 – Design of concrete structures for retaining aqueous liquids: section nine, inspection and test of the structure and in conjunction with EPA guidance note on Storage and Transfer of Materials for Scheduled Activities. Test Conducted by: Signed: ________________________________ Utilities Operator ________________________________ Utilities Operator
Conformance to B.S. 8007: Section 9
Passed
Corden PharmaChem AER Appendices Page 100 of 104
Reviewed By: Signed ______________________________ Head of Engineering Approved by: Signed ______________________________ EHS Manager
Corden PharmaChem AER Appendices Page 101 of 104
Bund Testing Certificate
Test details
Client: Corden PharmaChem
Bund Location: B10 – PB2 Solvent Tank Farm
Survey Dates: 10 – 13 March 2009 Personnel Involved:
Colin Barry – Utilities Operator Fergal Condon – Utilities Operator
Daily log
Date Comments Water level(mm)
Evaporation Personnel
10/03/09 Standby vessel 195mls
453 0 Colin Barry,
Fergal Condon
11/03/09 Standby vessel 195mls
453 0 Colin Barry,
Fergal Condon
12/03/09 Standby vessel 195mls
453 0 Colin Barry,
Fergal Condon
13/03/09 Standby vessel 195mls
453 0 Colin Barry,
Fergal Condon
Comments This bund was tested in accordance to B.S. 8007:1987 – Design of concrete structures for retaining aqueous liquids: section nine, inspection and test of the structure and in conjunction with EPA guidance note on Storage and Transfer of Materials for Scheduled Activities. Test Conducted by: Signed: ________________________________ Utilities Operator ________________________________ Utilities Operator
Conformance to B.S. 8007: Section 9
Passed
Reviewed by: Signed ______________________________ Head of Engineering Approved by: Signed ______________________________ EHS Manager
Corden PharmaChem AER Appendices Page 102 of 104
Bund Testing Certificate
Test details
Client: Corden PharmaChem
Bund Location: B11 –PB1 Ambient Cooling Tank Bund
Survey Dates: 03– 06 March 2009 Personnel Involved:
Colin Barry – Utilities Operator Fergal Condon – Utilities Operator
Daily log
Date Comments Water level(mm)
Evaporation/ Rainfall
Personnel
03/03/09 Relaxation
990 0 Colin Barry,
Fergal Condon
04/03/09 Standby vessel 10 L
1000 10 Colin Barry,
Fergal Condon
05/03/09 Standby vessel 10 L
1000 0 Colin Barry,
Fergal Condon
06/03/09 Standby vessel 10 L
1000 0 Colin Barry,
Fergal Condon
Comments This bund was tested in accordance to B.S. 8007:1987 – Design of concrete structures for retaining aqueous liquids: section nine, inspection and test of the structure and in conjunction with EPA guidance note on Storage and Transfer of Materials for Scheduled Activities. Test Conducted by: Signed: ________________________________ Utilities Operator ________________________________ Utilities Operator
Conformance to B.S. 8007: Section 9
Passed
Reviewed By: Signed ______________________________ Head of Engineering Approved by: Signed ______________________________ EHS Manager
Corden PharmaChem AER Appendices Page 103 of 104
Bund Testing Certificate
Test details
Client: Corden PharmaChem
Bund Location: B12 –PB1 Dump Tank
Survey Dates: 25– 27 February 2009 Personnel Involved:
Colin Barry – Utilities Operator Fergal Condon – Utilities Operator
Daily log
Date Comments Water level(mm)
Evaporation Personnel
25/02/09 Relaxation Period
410 0 Colin Barry,
Fergal Condon
26/02/09 Standby vessel 10 L
410 0 Colin Barry,
Fergal Condon
27/02/09 Standby vessel 10 L
410 0 Colin Barry,
Fergal Condon
Comments This bund was tested in accordance to B.S. 8007:1987 – Design of concrete structures for retaining aqueous liquids: section nine, inspection and test of the structure and in conjunction with EPA guidance note on Storage and Transfer of Materials for Scheduled Activities. Test Conducted by: Signed: ________________________________ Utilities Operator ________________________________ Utilities Operator
Conformance to B.S. 8007: Section 9
Passed
Reviewed by: Signed ______________________________ Head of Engineering Approved by: Signed ______________________________
EHS Manager
Corden PharmaChem AER Appendices Page 104 of 104
Appendix XV
Wastewater Toxicity Reports 2008
March 2008
Not included, as Full AER Report in PDF would exceed 20mb capacity (already submitted to
EPA and in Paper version of AER - details in summary section of AER)