environmental considerations and bat · environmental considerations have been made in the...

Environmental Considerations and BAT

Schwarz Pharma Ltd IPPC Licence Application

Issue No 2

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Attachment 1.8 Environmental Considerations and BAT

CONTENTS

Section Page No

1.

1.1.

2.

3. PROCESS CONTROL ...... . .... . ...... . .......................... . .......................... . ..... . ...................... 3

3.1.

0 3.2. 3.3. 3.4. 3.5.

4.

4.1. 4.2. 4.3. 4.4. 4.5. 4.6. 4.7.

5.

5.1. 5.2. 5.3.

0 6. FUGITIVE EMISSIONS .................... ..“...................................* .............................. ...* ........ 8

7. WASTE STORAGE/ABATEMENT .................................................................................. 9

8. ENVIRONMENTAL TRAINING .......................... . ........................................................... IO

ENVIRONMENTAL CONSIDERATIONS ........................................................................ 1

Introduction ........ ............................................................................................................... 1

PROCESS MODIFICATIONS ......... ..*.............................*.............~.......................~ .......... 1

Emission Control/Reduction ............................................................................................. 3 Accidental release Control/Reduction .............................................................................. 3 Waste Control/Minimisation.. ............................................................................................ 3 Energy Control/Reduction ................................................................................................ 4 Environmental Risk Control .............................................................................................. 4

PROCESS MANAGEMENT ............................................ ..~....-.................-~.......- .............. 5

Environmental Risk Control/Reduction ............................................................................. 5 Accidental Release Control/Reduction ............................................................................. 5 Emission Reduction.. ........................................................................................................ 5 Improved Environmental Performance ............................................................................. 5 Improved Environmental Management of Supplies.. ........................................................ 6 Improved Environmental Incident Response. ................................................................... 6 Improved Environmental Management/Awareness.. ........................................................ 6

CLEANING PROCEDURES ............................................................................................ 7

Emission Reduction. ......................................................................................................... 7 Recovery/Re-use/Recycling (On-Site) ............................................................................. 7 RecoverylRe-use/Recycling (Off-Site) ............................................................................. 7

Appendix 1.8.1 -SOPS relating to Environmental Considerations at Schwarz Pharma Limited

Appendix 1.8.2 -BAT Assessment for BPC and Nitration Main Air Emissions

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1. ENVIRONMENTAL CONSIDERATIONS

1.1. Introduction

Schwarz Pharma Ltd is committed to conducting activities such that they have a minimal impact on the environment. The facility strives to reduce negative environmental impacts by continually developing and modifying all procedures.

Environmental considerations have been made in the following areas:

l Process modifications;

0 Process control;

0 Process management;

e Cleaning procedures;

l Recover, reuse and recycle;

l Fugitive emissions; and

0 Solvent recovery.

Details of process improvements and modifications are ali considered Best Available Techniques (BAT) in the context of the management of the facility in respect of emissions to the environment and in consideration of the nature of activities at Schwarz.

2. PROCESS MODIFICATIONS

Processes have been modified as follows:

l An increase in the quantity of the low temperature refrigeration plant. This has improved yields to products, reduced crystallisation times and gives improved recovery efficiency. Chilling to the condensers has resulted in an increase in recovery of methanol, butyl acetate and ethyl acetate.

o A major upgrade of the wastewater treatment plant is being completed, with commissioning of the plant now ongoing. The new plant will consist of an aerobic facility with sludge removal and drying plant, this facility will be handed to Schwarz Pharma by the Construction Contractor in August. This follows a significant investment in time and resources into the investigation of problems with the previous treatment plant and which included detailed studies and pilot treatment work. The treatment plant is expected to deliver a high standard of treatment of trade effluent generated at the site.

. Developments at Schwarz Pharma Ltd. have included the commissioning and operation of the dedicated Nitration production facility. The Nitration plant

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manufactures two principle products namely Isosorbide-5Mononitrate and lsosorbide Dinitrate by chemical synthesis utilising acids, bases, solvents and reagents to form the fine chemical powder. The new process is based on modifications to a previous process utilising fewer reagents and generating fewer wastes. The plant incorporates best practice and technology and energy utilisation is kept to a minimum.

o Schwarz Pharma Ltd is dedicating its Shannon site to the development and manufacture of New Chemical Processes and will be the primary facility within the Schwarz Pharma Ltd. group for the manufacture of these materials. This change in focus will be implemented ensuring that the facility meets as a minimum its regulatory obligations on environment and safety.

The upgraded treatment plant conforms to BAT standards, being a listed technology for wastewater treatment in the relevant European Pollution Prevention and Control Bureau BAT Reference (BREF) publications’*. In respect of plant performance, the key BAT reference removal efficiency is that for Chemical Oxygen Demand (COD), particularly relating to complex chemical synthesis plants where the treatment plant is a ‘central treatment facility’ (as is the case here). Chapter 3 of the Common Gas and Wastewater BREF document provides a removal efficiency of between 60% and 98% for activated sludge plants. The new plant upgrade should consistently maintain a removal efficiency for COD within this range. However, it is noted that the BREF does not consider absolute discharge limits for COD and so removal efficiency will vary simply due to the expected variation in influent COD to the plant.

The definition of Best Available Techniques (BAT) means ‘techniques’ to include not only the technology but also the manner in which the plant is designed, built, maintained, operated and decommissioned. In this respect, there are a number of notable BAT considerations with the treatment plant upgrade:

1) The upgrade was designed following exhaustive studies, including pilot treatability studies;

2) The upgrade maximised existing treatment plant infra-structure;

3) The upgrade will be carried out to the highest construction standards;

4) There will be detailed operation and maintenance manuals and extensive training will be carried out;

’ Horizontal BREF: Reference document on best available techniques in common wastewater and waste gas treatment/management systems in “ihe chemical sector, February 2003.

’ Vertical BREF: Draft reference document on best available techniques for the manufacture of organic fine chemicals (February 2004).


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5) The treatment plant upgrade equipment and instrumentation will be added to the existing PMAC (preventative maintenance) programme.

3. PROCESS CONTROL

3.1. Emission Control/Reduction

Emissions from the Pharma Plant (VE-135) consist only of particulate emissions. This emission point is fitted with a HEPA filtration system, which conforms to BAT.

Significant upgrades have been completed in relation to the main emission points on both the Nitration Plant (NVE-001) and the BPC Plant (VE-079), with two stage scrubbing systems now in place to control organics emissions from these two emission points. It is expected that the upgrades will ensure compliance with TA Luft 1986 organics emission limits. Both emission points have also been fitted with continuous TOC analysers to monitor concentrations of solvents in the waste gas stream.

Other improvements have also been implemented on both plants in the last 12 months to control emissions to atmosphere, including improved condenser performance and installation of orifice plates on reactors to control releases to the vent header. A summary of recent improvements is presented in Section 4.1 of the Non-Technical Summary.

In addition, it has been decided to install two thermal oxidisers associated with the BPC and Nitration Plant in January 2007 as a longer term VOC abatement technique. These proposed emission points NVE-009 and VE-155 will replace NVE-001 and VE-079 respectively.

Descriptions and schematics of the abatements systems are included in Attachment E.l and Attachment F. 1.

BAT assessment documents for both the BPC plant and the Nitration Plant are included in Appendix 1.8.

3.2. Accidental release Control/Reduction

Surface water drain surveys are completed to ensure the integrity of underground foul sewers. Damaged lines are identified and the necessary remedial work completed. All process waste lines are now routed aboveground to prevent the occurrence of leakage from unidentified breaks in underground process lines.

3.3. Waste Control/~Minimisation

All hot and cold Glycol and Nitrogen usage for all major onsite users is measured and monitored on site. This process increases the awareness of resource usage and enables better control of resource usage where possible.


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3.4. Energy Control/Reduction

Energy demand at the Schwarz Pharma Ltd. facility is met by fuel oil and electricity. Steam demand for process purposes is met by three fuel oil steam boilers. Energy consumption remained stable in 2002 and 2003. Electrical demand fell by 4% in 2003 this was attributed to the introduction of metering systems and programmes to encourage and heighten the awareness of energy efficiency.

Meters are fitted to all the principal energy users throughout the site. This allows electricity, fuel and water usage to be tracked and recorded for each building and major plant on site. This has resulted in the identification of high energy users and the steps necessary to reduce energy usage can be implemented.

Schwatz are planning to implement a detailed resource monitoring programme, which will involve quantifying and evaluating key energy usage points and evaluating and implementing reduction programmes as part of the Environmental Management Programme for 2004/5.

3.5. Environmental Risk Control

The control of all Environmental Health and Safety issues arising from the introduction of new materials and equipment and processes on site is met as part of IS014001. This control is necessary in order to ensure the efficient management of all EHS issues, compliance with legal requirements and also to ensure that the EPA can be informed of any notifiable changes as required under the terms of the IPC licence.

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4. PROCESS MANAGEMENT

4.1. Environmental Risk Control/Reduction

A regular review of the methodology behind the storage procedures of materials is carried out. This ensures a proper system of storage is implemented. The methodology for the storage of materials (Separation and Segregation) is addressed in SOP 400.010 Storage of Materials.

A tool for the procurement of chemicals, inventory management, manufacturing, release and shipment of products called Systems, Applications and Products for Data Processing (SAP) is employed at Schwarz Pharma Ltd.. This indirectly benefits environmental management through improved chemical classification for storage and better tracking of hazardous waste in storage and for disposal off-site.

A firewater pump is operational on site. This ensures that firewater arising on site in the event of a fire scenario is retained and does not pose a threat to surface or groundwater

sources.

The classification of the facility as a Tier II Seveso site has helped to improve the identification and control of potential incidents on site, which may have an environmental impact on and off-site.

4.2. Accidental Release Control/Reduction

Tanks and bunds are upgraded as required, and spill kits are installed at specific locations throughout the site. Operators responsible for transport and loading activities receive the necessary training to ensure proper storage, segregation and separation practices are used (SOP 601.007 - Environment Health & Safety Training for Contractors & Transport Companies). Schwarz utilises the services of a contracted Dangerous Goods Safety Advisor when necessary.

4.3. Emission Reduction

Rigid snufflers (vacuum units for use over reactors when materials are being loaded) are installed in various areas throughout the site so that areas producing fugitive emissions can be minimised and the necessary corrective action to reduce this may be

implemented.

4.4. Improved Environmental Performance

All Environmental Equipment requiring calibration is covered by the Calibration procedure (SOP 610.016). A review of the Y2K compliance of all equipment was carried out and no issues regarding Y2K have occurred to date. All Laboratory equipment procedures are also covered under this SOP where specific measures have been written to cover all testing carried out.


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Regular reviews of safety and environment operations are conducted by Schwarz and provide a useful exchange on emergency control, and suggestions on improved environmental practices.

4.5. Improved Environmental Management of Supplies

A programme of ongoing Vendor Environmental Appraisal has been in place at Schwarz for a number of years. This involves the evaluation of the significant suppliers of raw materials, and significant environmental consultants/contractors from an environmental viewpoint, using key performance indicators. In addition, the annual vendor appraisal has been extended to incorporate the key indicators by which all Raw Material suppliers should be assessed. If a supplier is being listed as an approved supplier they receive a copy of the Schwarz Pharma Ltd. Environmental Survey prior to commencement of business. The evaluation of suppliers is incorporated into the standard vendor appraisal procedure.

4.6. improved Environmental Incident Response

All manholes, boreholes and inspection holes are readily identified and secured while in use, and are easy to use when required. All drains and air and water emission sampling points are labelled appropriately for ease of identification. In the event of an incident occurring on site or during an emergency, it is essential to be able to readily identify the source in order to manage the impact to surface and groundwater. A numbering system allows this, particularly during darkness and bad weather.

4.7. improved Environmental Management/Awareness

The achievement of accreditation to EN IS0 14001 Standard is a significant step in the overall evolution of managing the environment better. IS0 14001 ensures that a systematic and integrated model now exists to address on a sustained company-wide basis a range of other issues, which were not addressed in the previous EMP format. Preparation for the standard raised significantly the awareness amongst employees of the environment and how each person could play his/her part. Surveillance audits are carried out regularly to ensure the standard is maintained by Schwarz Pharma Ltd. Internal Auditing also takes place on a continuous basis, with audits undertaken by an audit team that includes various people from the areas being audited.

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5. CLEANING PROCEDURES

5.1. Emission Reduction

Cleaning procedures (in accordance with SOP 301.039 - Cleaning Equipment and Piping Systems) minimise the amount of cleaning material and water used. Spillages are dealt with in accordance with SOP 601 .015 - Accidental Releases.

5.2. RecoveryIRe-use/Recycling (On-Site)

Through an upgrade to the refrigeration plant, chilling to the condensers has resulted in an increase in recovery of solvents on site.

In an effort to minimise the generation of waste on site, a project group was established to Audit Chemical Usage and provide measurement of organic levels in waste streams. In addition, this group is in control of implementing measures to eliminate or minimise such waste levels. In order to eliminate water wastage on site, flowmeters have been provided for the BPC and Pharma plant. This permits intervention locally to reduce water usage. Furthermore, a programme has been implemented to reduce the number of fibre kegs used on the site through reuse/recycle or elimination.

At the facility a system is in use which provides accurate real time measurement of solvent usage. Solvent tracking allows for more accurate control of solvent usage and recovery on site. A piping and pumping process allows the return of recovered solvent to the tank farm. Recovered IMS may be used in the BPC Processes.

5.3. Recovery/Re-use/Recycling (Off-Site)

In an effort to minimise the volume of waste to landfill a study to examine the feasibility of reusing/recycling non-hazardous waste was undertaken. As a result, the measurement of waste quantities disposed to landfill is now based on actual weight rather than number of collections. Timber products and cardboard are collected baled and recycled by an external waste contractor, thereby reducing cost. Furthermore, a system of collection of batteries, and toner and printer cartridges is in operation at the site.

In the Pharma Warehouse facility, all pallets being utilised in this plant will eventually be the aluminium type. Schwarz Pharma Ltd. now participates in a waste timber recycling scheme operated by an external consultant. The company collects, on a for-h-rightly basis, all wood waste from the main site. The material once collected from Schwarz Pharma Ltd. is segregated, and then it is either (a) reworked into pallets or (b) dismantled and shredded with the derivatives sent to either the board Industry or to Scrap Metal Merchants.


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Attachtnent 1.8 Environmental Considerations and BAT

6. FUGITIVE EMISSIONS

Schwarz Pharma Ltd. strives to obtain continuous improvement (reduction/improved abatement) in emissions of fugitive emissions to atmosphere. The following measures have been taken at Schwarz Pharma Ltd. to contend with fugitive emissions on site:

A pump and scrubbing unit are installed at the site to eliminate fugitive emissions of vapours during the unloading of Nitric Acid to the bulk tank;

A Carbon bed is being installed on the desludging building as part of the VVWTP

upgrade;

In order to minimise the loss of VOC’s from the tank condenser vents, the coolant for the condensers is glycol at - 20 ‘C;

Volatile solvents are the last component to be added to a reactor where possible. Fugitive emissions are reduced by this step because no VOC will be released as the reactor will not be opened for further material additions; and

Temperature detectors have been fitted in the vent lines from reactors, to prevent the emission of uncondensed vapours in the event of a reactor control malfunction.

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7. WASTE STORAGE/ABATEMENT

A dedicated Waste Management Area is in operation at the site. All measures have been taken to ensure adequate storage space is provided and the area is of suitable construction to prevent a risk of surface and groundwater pollution. All waste stored is clearly labelled and marked.

All bunds including Drum stores, Scrubbers, WWTP and Glycol bunds are in line with IPC licence conditions and the Drum storage area has been tested for its resilience to fork-lift and truck traffic.

A procedure for collection, storage and disposal of waste oils and scrap metal is employed at the site. Waste Oil control procedures have been put in place and a dedicated waste oil storage area has been created in the drum storage area. Scrap metal, which primarily consists of waste drums, is removed by an external waste contractor for recycling. The storage and crushing process is carried out in the Waste Management area.

To minimise air emissions, treatment/abatement equipment has recently been installed on vessels for dichloromethane (and for any other organics classified as Class I under the TA Luft 1986 Guidelines) which may arise in BPC. This equipment comprises of a number of scrubbers which can be selected for specific duties and a final acid/base scrubber for reduction of emissions from reactors.

The wastewater treatment plant is being upgraded in order to comply with IPC licence conditions.

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Attach-tent 1.8 Environmental Considerations and BAT

8. ENVIRONMENTAL TRAINING

All new employees at the Schwarz Pharma Ltd. site receive environmental awareness training as part of induction to the site. In addition, all contactors undergo an induction programme, which includes environmental awareness training SOP 601.007, Environment Health & Safety Training for Contractors & Transport Companies.

IS0 14001 and Environmental Awareness training is given to ail employees. Training needs are reviewed on a regular basis and focus mainly on Awareness Training, Job Competency with regard to environmental issues and Spillage Response Training. All Environmental Training needs are aligned with the overall training strategy for the site.

Schwarz Pharma Ltd. implement and record environmental training for all contractors and suppliers as outlined in the Schwarz Pharma Ltd. training manual.

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Attachment 1.8 Environmental Considerations and BAT Schwarz Pharma Revised IPCL Application

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Table of Contenti for Abpendix 1.8.1

SOP Number Title

nvrronmental Health and

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SAFETY & ENVIRONMENTAL PROCEDURE SOP Page 1 of 4

Ktle: Environmental Health & Safety Training 601.007 Effective Date: for Contractors and Transport Companies. Revision No: 3 Date: 10.01.00

Prev Rev No: 2 Dated: 18.10.99

1.0 PURPOSE

To define the basic Environmental Health & Safety training which all contractors and transport companies as defined in SOP 3 10.001 must receive prior to commencing work on site and the method by which training is recorded.

2.0 PROCEDURE

2.1 Introduction:

SOFA Ltd. is a Fine Chemical / Pharmaceutical manufacturing facility. The nature of the business results in the presence of chemicals and conditions which have the potential to cause serious safety and environmental issues. Contractors are therefore required to be vigilant at all times, to abide by site rules and to ensure that their actions do not result in injury to themselves or others, damage to equipment or property or damage to the En$onment.

NOTE : It is the sole responsibility of the person responsible for the training of the contractor’s to ensure that he / she passes this training record to the Engineering Administrator for filing.

2.1.1 Contractors must as a minimum requirement, be made understand the regulations outlined in this document before commencing work. If further training is required, it should be completed as necessary and recorded by the person responsible for the contractors while on site. Refer to SOP301.001 for a list of training personnel for each department.

2.1.2 Attachment I should be completed by the person responsible for the introduction of the contractor on site and forwarded to the Engineering Administrator who will update the “Register of Contractor Training” as necessary (See Attachment II). Each contractor on site will receive a copy of the site Environmental Health & Safety regulations as outlined in Attachment III detailed instructions may be found in SIFA’s Environmental Health & Safety Manual for Contractors and Supplies.

Written & Reviewed By: Approved By:

D. Hanrahan, P. Gallagher, Environment Officer. Facilities Manager.

Date: Date:

Approved By: Approved By:

J. Driver, J. O’Donoghue HR Manager. Safety & Envir. Mgr.

Date: Date:

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SAFETY & ENVIRONMENTAL PROCEDURE

litle: Environment Health & Safety Training for Contractors and Transport Companies.

SOP Page 2 of 4

601.007 Effective Date: Revision No: 3 Date: 10.01.00 Prev Rev No: 2 Dated: 18.10.99

2.2 SAFETY REGULATIONS

2.2.1 Eating and Drinking. This is permitted only in the canteen.

2.2.2 Smoking Smoking is permitted only in the canteen. Smoking is strictly forbidden in all outdoor areas. Smoking material must be extinguished before coming on site.

2.2.3 Hot Work Permits Work is any work that may produce heat or a source of ignition (sparks) e.g. drilling, grinding, welding, soldering etc.

Hot Work Permit is required for any hot work to be done outside the engineering building, canteen and oftice building.

,, A Hot Work Permit is a form which is completed by the Facilitator of an area in order to lay down the conditions necessary for safe working in an area of tire risk. It consists of a series of checks which must be signed by the Supervisor, Such checks include for example ensuring movable containers of flammable materials are 1 Om away, fixed storage tanks are under vacuum or sealed, checking the area with a solvent meter and having a fire extinguisher present.

Confined Entrv Permits:

A confined space is any vessel, reactor, drier, container, tank, manhole etc., where there is partial natural ventilation. Again, this permit is issued by the facilitator. Checks include: ensuring moving parts are locked off, ensuring pipelines are disconnected so that no material can be pumped into the confined space, ensuring oxygen levels are adequate, ensuring there are no flammables present, a harness is being used and ensuring another person is present at all times.

Fire Alarm:

If the fire alarm is activated (siren), people must make their jobs safe and report to the assembly point for visitors/contractors in the main car park for roll call.

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SAFETY & ENVIRONMENTAL PROCEDUlb

ritle: Environment Health & Safety Training for Contractors and Transport Companies.

SOP Page 3 of 4


Evacuation:

Upon discovering a fire:

2.3

l Raise the alarm l Make your job area safe e.g. turn off gas bottles if welding l Attack the fire if safe to do so, with fire extinguishers l If the fne cannot be extinguished, report immediately to the emergency co-

ordination point (outside the fire store) and inform the emergency controller as to the nature of the fire.

l Report to the Visitors/Contractors assembly point for roll call.

SAFETY EQUIPMENT The following Safety Equipment must be worn :-

l Safety glasses must be worn at all times on site beyond the ‘red lines’. The only exception to this are office areas.

l Steel toe capped shoes or hoots l Gloves when working with hazardous materials (e.g.) corrosive, hot or sharp. l Additional eye protection must be worn when performing hazardous jobs (e.g.) shield

when welding, goggles when grinding, operating lathe.

2.4 ENVIRONMENTAL REGULATIONS

2.4.1 Drains & sumns Liquids other than clean water may not be discharged of to surface water dram points. Liquids contaminated with traces of oils, solvents, product, concrete etc. must only be discharged at suitable points including sinks or directly to sewer. If there is any doubt about regarding the disposal of liquids contact the S&E Dept. or on site contact for instruction regarding the disposal of the waste.

2.4.2 Hazardous Wastes Hazardous Wastes such as chemical residues, solvent based paints, asbestos, cleaning agents, oils / oil filters, batteries, fluorescent tubes and other chemically contaminated materials must not be disposed of into the site compactor. Hazardous wastes must be suitably packaged and taken off site for disposal or else following prior agreement may be given to SIFA for disposal.

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. . . .

SAFETY &, ENVIRONMENTAL PROCEDURE

We: Environment Health & Safety Training for Contractors and Transport Companies.

SOP Page 4of4


2.4.2 Non-Hazardous Wastes Non-Hazardous Wastes such as paper, cardboard water based paint tins, cardboard, uncontaminated materials and engineering debris excluding metals, may be disposed of to the site compactor. For projects generating large amounts of Non-Hazardous wastes separate arrangements for disposal should be made.

2.5 GENERAL GUIDELINES

1.

2.

3. 4.

If you smell smoke or any strong odour, while working DO NOT IGNORE IT. Bring it to the Area Facilitator or site contact’s attention. DO NOT interfere with equipment unless cleared to do so by the Area Facilitator of the area. DO NOT open valves or break lies without approval. Clean up all spillage’s immediately if it is safe to do so. If the spill is large or the nature of the material is unknown or toxic contact the Area Facilitator immediately

5. I* and inform him I her of the situation. Dispose of all clean up materials in a proper manner.

6. Leave work areas clean and tidy following completion of work and dispose of all materials in a proper manner.

7. DO NOT discharge any liquids or materials to soil. 8. DO NOT dispose containers containing liquid to the skip. 9. Inform the Area Facilitator, Site Contact or S&E Dept. of any Environment

incidents such as spillage’s, leaks, etc. 10. Inform the Area Facilitator, Site Contact or S&E Dept of any Safety incidents,

accidents or unsafe conditions.

3.0 REVISION The SOP is reviewed annually according to SOP 100.007. Any necessary changes will be documented in a new revision of the SOP.

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SAFETY & ENVIRONMENTAL ATTACHMENT I SOP Page 1 of 1

ritle: Safety Training Record For Contractors & 601.007 Effective Date: Transport Companies. Revision No: 3 Date: 10.01.00


CONTRACTOR AND TRANSPORT COMPANIES “ENVIRONMENTAL HEALTH ANJl SAFETY TRAINING RECORD.

I have been informed and understand of the Environmental Health & Safety rules and regulations at SOFA Limited by the SIFA contact person named below and agree to be bound by these. I have also received a copy of the SIFA Limited Environmental Health & Safety Regulations (See Attachment III SOP60 1.007).

Other training received

Contractor Name (EUocks) <*

Company

Signed Contractor

Date

Date

Date

Signed SIFA Representative

Date

:

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SAFETY & ENVIRONMENTAL ATTACHMENT JI SOP Page 1 of 1

Title: Register of Trained Contractors - (Example only). 601.007 Effective Date: Revision No: 3 Date: 10.01.00 Prev Rev No: 2 Dated: 18.10.99

I I Register of Contractor Training

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SAFETY & ENVIRONMENTAL ATTACHMENT III SOP Page 1 of 2

Title: Environmental Health & Safety Regulations at SIFA 601.007 Effective Date: Limited. Revision No: 3 Date: 10.01.00


SAFETY REGULATIONS

Eating and Drinkin& This is permitted only in the canteen. Smoking Smoking is permitted only in the canteen. Smoking is strictly forbidden in all outdoor areas. Smoking material must be extinguished before coming on site. Hot Work Permits Work is any work that may produce heat or a source of ignition (sparks) e.g. drilling, grinding, welding, soldering etc. Hot Work Permit is required for any hot work to be done outside the engineering building, canteen and office building. A Hot Work Permit is a form which is completed by the Supervisor of an area to ensure it is safe to work. It consists of a series of checks which must be signed by the Supervisor. Such checks include for example ensuring movable containers of flammable materials are 1Om away, fuced storage tanks are under vacuum or sealed, checking the area with a solvent meter and having a fire extinguisher present. Confined Entry Pennits: A confined space is any vessel, reactor, drier, container, tank, manhole etc., where there is partial natural ventilation. Again, this permit is issued by the facilitator. Checks include: ensuring moving parts are locked off, ensuring pipelines are disconnected so that no material can be pumped into the confined space, ensuring oxygen levels are adequate, ensuring there are no flammables present, a harness is being used and ensuring another person is present at all times. Fire Alarm: If the fire alarm is activated (siren), people must make their jobs safe and report to the assembly point for visitors/contractors in the main car park for roll call. Evacuation: Upon discovering a fre: l Raisethealarm l Make your job area safe e.g. turn off gas bottles if welding l Attack the fire if safe to do so, with fire extinguishers l If the fire cannot be extinguished, report immediately to the emergency co-ordination point (outside the fire

store) and inform the emergency controller as to the nature of the fire. l Report to the Visitors/Contractors assembly point for roll call. SAFETY EOUIPMENT The following Safety Equipment must be worn : :- * Safety glasses must be worn at all times on site beyond the ‘red lines’. The only exception to this are office

areas. 0 Protective clothing. l Steel toe capped shoes or boots (minimum requirements for laboratory contractors or a closed shoe) l Gloves when working with hazardous materials (e.g.) corrosive, hot or sharp. 0 Additional eye protection must be worn when performing hazardous jobs (e.g.) shield when welding,

goggles when grinding, operating lathe.

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SAFETY & ENVIRONMENTAL ATTACHMENT III SOP Page 2 of 2

Me: Environmental Health & Safety Regulations at SIFA 601.007 Effective Date: Limited. Revision No: 2 Date: 10.01.00


ENVIRONMENTAL REGULATIONS

Drains & smps Liquids other than clean water may not be discharged of to surface water drain points. Liquids contaminated with oils, solvents, product, concrete etc. should only be discharged at suitable points including sinks or directly to sewer. If there is any doubt about regarding the disposal of liquids contact the S&E Dept. or on site contact for instruction regarding the disposal of the waste.

Hazardous Wastes Hazardous Wastes such as chemical residues, solvent based paints, asbestos, cleaning agents, oils / oil filters, batteries, fluorescent tubes and other chemically contaminated materials must not be disposed of into the site zompactor. Hazardous wastes must be suitably packaged and taken off site for disposal or else following prior Pgreement may be given to SIFA for disposal.

Non-Hazardous Wastes Non-Hazardous Wastes such as paper, water bases paint tins, uncontaminated materials and engineering debris may be disposed of to the site compactor. For projects generating large amounts of Non-Hazardous wastes separate arrangemepts for disposal should be made. Cardboard boxes and other cardboard based items must be disposed of to the ‘hardboard only’ skip provided.

GENERAL GUIDELINES

l If you smell smoke or any strong odour, while working DO NOT IGNORE IT. Bring it to the area Facilitator or site contact’s attention.

l DO NOT interfere with equipment unless cleared to do so by the Supervisor of the area. l DO NOT open valves or break lines without approval. l Clean up all spillage’s immediately if it is safe to do so. If the spill is large or the nature of the material is

unknown or toxic contact the local supervisor immediately and inform him / her of the situation. l Dispose of all clean up materials in a proper manner. l Leave work areas clean and tidy following completion of work and dispose of all materials in a proper

manner. l DO NOT discharge any liquids or materials to soil. l DO NOT dispose containers containing liquid to the skip. l Inform the area Facilitator, Site Contact or S&E Dept. of any Environment incidents such as spillage’s,

leaks, etc. l Inform the area Facilitator, Site Contact or S&E Dept of any Safety incidents, accidents or unsafe conditions.

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REWISION LOG

SOP TITLE: Environment Health & Safety Training for SOP NUMBER/CODE: 60 1.007 Contractors and Transport Companies.

REVISION NO. REQUESTED REASON FOR REVISION EFFECTIVE BY: DATE

0 RC N/A 12.07.9s

1 RC To change the SOP numbering from 602.055 to 601.007 and 18.04.96 incorporate approvals of Maintenance Engineer & H.R. Co- ordinator.

2 DH Change SOP and update attachments, to include environmental training content and procedures.

28.10.99

DH Expand attachment I to include Company Name. Modify to new edify training record and

2 section on non-hazardous

‘d, ,, . . ‘,.i,.. .‘.

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I _. I ,

SOP RECEIPT COtiI&+ION

SOP TITLE: Environment Health & Safety Training for Contractors and Transport Companies.

I acknowledge receipt of the above SOP.

For All Covies Excevt 0-A &faster Covv:

I have destroyed (returned in the case of BMI’s returned and CPs) the superseded revision of the SOP.

Signed: Department:

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TITLE: Accidental Release

Page 1 of 6

SOP 601.015 Effective Date:

Revision No: 2 Date: 14.01.02 Prev Rev No: 1 Dated: 18.10.99

1.0 PURPOSE To provide guidelines for dealing with accidental releases of liquids, solids and gases.

2.0 PROCEDURE

2.1 The actions to be taken following the occurrence of an accidental releases depend on the nature of the compound being released, its location and the volume involved

*

(see Attachment 1). Releases can occur in 3 forms namely liquids, solids and gases.

- Liquid releases are the most cornmon and also the most difficult to address. For the purpose of spillage response they are classified into two categories major and minor.

- Solid releases tend to be confined to a specific area and hence can be cleaned up more easily that liquid spills.

- Gaseous releases due to their nature cannot be cleaned up. However, the leak may be contained by isolating the source.

It is the responsibility of the person identifying the spillage to initiate the response actions as outlined below.

Written By : Approved By: Approved By: Approved By:

Dermot Hanrahan, Safety & Env. Officer.

Date:

Fire Crew Leader. Frances Martin, BPC Manf Mgr

Bernie Harten, Nitrates Manf Mgr

Approved By : Approved By : Approved By :

II Werner Kunz, John O’Donoghue, Mary Anne Clifford, Pharrna Manf Mgr. Safety & Env. Mgr Materials & Logistics Mgr.

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Page 2 of6


Revision No: 2 Date: 14.01.02 Prev Rev No: 1 Dated: X10.99

2.2 Liquid Releases.

2.2.1 Minor Liquid Releases. For liquids, minor releases are as a general guideline, classed as liquid spillage’s of less than 15 (2M2 area) litres. The actions to be taken following the occurrence of a minor spillage are as follows:

1.

2.

3.

4.

5.

6.

7.

8.

9.

10. Complete all incident reports as required.

NOTE : Minor spillage’s of toxic materials should be dealt with as major spillage’s.

On seeing or smelling a hazardous material release move a safe distance away from the spill. Always put safety first and inform people in the area of the spill.

If possible assess the risk by identifying what and how much was spilled.

Choose the appropriate PPE (Personal Protective Equipment) to respond to the spill and consult the MSDS sheets for details of the properties or the material as necessary

Speed counts, so limit the spill area by blocking, diverting or confining the spill. Use absorbents, booms, socks, dikes, drain plugs, etc. to confine the spill and prevent it from entering drains or soil.

Once the spill has been confined isolate the source of the spill. This may involve standing up the container, blocking a hole or turning a valve.

Once the spill has been confined and the leak has been stopped, assess the incident and develop a plan to clean up the spill.

If the material which has been accidentally released is classified as a flammable liquid the spillage material must be covered with a layer of foam prior to commencing the clean up using absorbents or transfer methods. A fire extinguisher may be used for this purpose. The function of this application is to suppress vapour generation thus reducing the risk of ignition thereby creating a safer environment for cleanup.

All clean up materials should be collected and disposed of as hazardous materials. All drums used for the collection of the clean up materials should be clearly labelled and moved to a bunded area.

Following the clean up complete personnel, equipment and area decontamination as necessary.

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Page 3 of 6



2.2.2 Major Liquid Releases.

Major releases are as a general guideline classes as liquid spillage’s greater than 15 litres (2m2 area). The actions to be taken following the occurrence of a major spillage are as follows :- 1. On seeing or smelling a hazardous move a safe distance away from the spill, always put

safety first and inform people in the area of the spill.

2. Raise the alarm immediately and contact the Emergency Response Team (tie crew).

3. If possible, assess the risk by identifying what and how much was spilled.

4. Speed counts so if it is possible without personal risk and following the selection and fitting of the correct PPE, limit the spill area by blocking, diverting or confining the spill. Use absorbents, booms, socks, dikes, drain plugs, etc. to confine the spill and prevent it from entering drains or soil.

5. Once the spill has been confined, isolate the source of the spill. This may involve standing up the container, blocking a hole or turning a valve.

6. Once the ERT team arrive they will take responsibility for the containment and clean up of the spill. The ERT team leader will deal with the emergency as he sees fit (See Attachment I ) .

7. If the material which has been accidentally released is classified as a flammable liquid the spillage material must be covered with a layer of -foam prior to commencing the clean up using absorbents or transfer methods. A fire extinguisher may be used for this purpose. The function of this application is to suppress vapour generation thus reducing the risk of ignition thereby creating a safer environment for cleanup.

8. If the release is larger than can be safely dealt with by the ERT team, the emergency plan should be invoked. People’may need to be advised by those dealing with the incident to remain indoors.

9. If there is a risk that environmental damage has been caused by the spillage, environmental monitoring should be set up as necessary.

10. The EPA should be informed of the spillage as necessary by the environmental health and safety manager.

: NOTE Ensure that all contaminated material is disposed of correctly and incident forms have been completed as necessary.

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Page 4 of 6



2.2.3 Solid Releases. As a general guideline for solid releases the following steps should be taken :-

1.

2.

On observing the release of a hazardous solid material move a safe distance away from the spill. Always put safety first and inform people in the area of the spill.

If possible assess the risk by identifying what and how much was spilled.

3. Choose the appropriate PPE (Personal Protective Equipment) to respond to the spill and consult the MSDS sheets for details of the properties or the material as necessary.

4. Speed counts, so limit the spill area by blocking or confining the spill as necessary and prevent it from entering drains or soil especially if the spill occurs outdoors during wet conditions. ,*

5. Once the spill has been confined isolate the source of the spill. This may involve standing up the container or bag and taping or blocking the hole.

6. Once the spill has been confined and the release has been stopped, assess the incident and develop a plan to clean up the spill.

7. Sweep up the material and collect in liners. All clean up materials should be collected and disposed of as hazardous materials. All drums used for the collection of the clean up materials should be clearly labelled and stored for disposal.

8. Following the clean up complete personnel, equipment and area decontamination as necessary.

9. Complete all incident reports as required.

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Page5of6



.I ,’

1 2.2.4 Gaseous Releases.

1.

2.

As a general guideline for gaseous releases the following steps should be taken :-

On observing the release of a gaseous material move a safe distance away from the spill, Always put safety first. Inform people in the area of the spill.

If possible assess the risk by identifying what is the nature of the gas being released.

3. Choose the appropriate PPE (Personal Protective Equipment) to respond to the spill and consult the MSDS sheets for details of the properties or the material as necessary,

4. Speed counts, so limit the release by shutting of the supply if it is possible to do so with personal risk.

5. If the gas is toxic or corrosive seal off the area and contact the ERT team immediately and they will deal with the incident as they see fit.

6. Fill out and incident form as appropriate.

Note :- The S&E Manager will inform the EPA of any environmental damage if it has occurred.

2.2.5 Spillage Response Equipment

2.2.5.1 Spill Response Kits are located in areas where spillage is most likely to occur. These kits are inspected on a routine basis (approx 4 - 6 weeks) by an external supplier and topped up as necessary and details of the additions are recorded in the Spill Response Equipment Usage Log Book outlined in Attachment II. This Log Book will be held in the firehut.

2.2.5.2 If a spill kit is significantly depleted following a spillage it is that departments responsibility to inform the Environmental Technologist of its depletion so that is may be restocked.

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Page 6 of 6 SOP


3.0 DOCUMENTATION

Attachment I : Accidental Release Guidance Table. Attachment II : Example of “Spill Response Equipment Usage Log Book”.

4.0 REVISION

l This SOP is reviewed annually according to SOP 100.007. Any necessary changes will be documented in a new revision of this SOP.

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of 1 SAFETY & ENVIRONMENTAL ATTACHMENT I SOP

601.015 Effective Date: TITLE: Accidental Release Guidance Table. Revision No: 2 Date: 14.01.02

Prev Rev No: 1 Dated: X10.99

Material Incident Type Clean Up Procedure 1 Hazards Associated PPE Disposal Nitric acid Release - Release in a production building Dilute with water and carefully wash to‘lhe effluent. Highly Corrosive Liquid and -Full BA Dilute and wash to Consult MSDS - Release into a Bund fumes ,Oxidising -Chemical Suit effluent

-Leak during loading and unloading -Nitrile Gloves Ammonia Release -Reactor Water spray to keep fumes under control, wash to Toxic, Corrosive, -Full BA Wash to effluent Consult MSDS -Refrigeration Plant effluent Flammable -Gas Tight Suit Bromine -Bottle Breakage Take up liquid with lime Very toxic by inhalation, -Full BA Incineration Consult MSDS -Spillage During Transfer corrosive causes severe bums -Gas Tight Suit HCl Gas Release Cylinder Leak Water Spray to keep fumes under control Highly Corrosive -Full BA Wash to effluent Consult MSDS Oxidising -Gas Tight Suit

Solvent Release -Drum spillage /leak Control Spillage with dikes / absorbents I Flammable -Fire fighting Seal contaminated Consult MSDS -Stack Tank spillage /leak Cover Spillage with foam from portable pump and clothing

-1BC spillage / leak absorbents in bag

foam/ fire extinguisher. -Full BA and then in drums -Pipeline leak / fracture Pump material into collection drnm where possible for disposal

or clean up with aborbents. Acids -Drum Spillage / leak Neutralise with base (Diluted Sodium Hydroxide for Corrosive -Full BA Dilute with water Consult MSDS -Stack Tank spillage /leak example) -Gas Tight Suit

-1BC spillage / leak and wash to effluent

-Pipeline leak / fracture Bases -Drum Spillage / leak Neutralise with acid (Diluted Sulphuric acid for Corrosive -Full BA Dilute with water Consult MSDS -Stack Tank spillage /leak example) - Gas Tight Suit and wash to effluent

-1BC spillage / leak -Pipeline leak / fracture

Oils - Drum Spillage / leak Control with absorbents Irritant -Gloves Seal absorbents in Consult MSDS -Pipeline leak / fracture bags and then in

drums for disposal Solid Activesl - Drum / Bag Rupture Control release and sweep up ’ Corrosive/ Irritant -Face mask with Seal absorbents in Corrosives filter bags and then in Clonsult MSDS -gloves drums for disposal

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