* Pamela McDonnell

From: Marie O'Connor Sent: To: Ms Anne Goggin cc: Subject: Attachments:

24 October 201 2 0859

elaine.oconnell@stmer.com; Pamela McDonnell; Dave Keane (DKEANE@limerickcity.ie)

PPC Licence Increase email 2; RN: @ ryker SE1 increase requests email no.1; Ho medica Stryker POO23-02

outline of Stryker orthopaedics discussion with LCC; HowmedicalStryker F d

(3) ("' ,

Anne I am e-mailing in relation to an outstanding response to our Section 99 letter regarding consent to discharge to sewer and the parameters that you wish to have imposed on the Licensee. I have asked the Licensee to engage directly with you in the expectation that you could address the issues with them as there was a significant timelag between the original requests.

I attach a copy of our most recent correspondence from Stryker and also our most recent e-mail to you from Pamela McDonnell the Inspector dealing with this application.

In the absence of any response from you, the Agency can, in accordance with Section 99E(2), proceed with it's proposed decision as if consent had been given to the Licensees proposal or we can assume that you are not in a position to agree to the amendments and therefore consider imposing the requirements of the previous Section 99 response and any amendments agreed by the WSA in the intervening years.

You can give me a call on 021 4875540 if you wish to discuss further. I am aware that the Agency is dealing with issues around the WWDA licence D0013-01 and if this pertinent to this discharge consent you might let me know.

Regards Marie

1

' Pamela McDonnell

From: OConnell Elaine celaine.oconnell@stryker.com> Sent: To: Marie O'Connor cc: Pamela McDonnell Subject: Attachments :

22 October 201 2 18:OO

FW: IPPC Licence Increase ernail 2 0 27 SE increase application.pdf; 16 28-05-09 - Licence increase.pdf; application.pdf c9

Hi Marie Email two 29-08-12 Details the request to meet with Limerick County Council, the information provided. Further information was sent by email on the 05-09-12, and another email was sent on the 19-10-12.

Regards Elaine

. .

From: OConnell Elaine Sent: 18 October 2012 14:44 To: 'Goggin Anne' Subject: FW: IPPC Licence Increase

Hi Anne I was just wondering i f you had a chance to review my email below? I f you need any more information or have any questions can you please contact me on 061498551. Kind regards Elaine

- - . _ _ _ _ From: OConnell Elaine Sent: 05 September 2012 11:56 To: 'Goggin Anne' Cc: Brennan Dona1 Subject: RE: IPPC Licence Increase

Hi Anne, Just to give you some background ...... We received agreement on the 28-05-09 (attached), for a licence increase at SE1. As new IPPCL application had started and Stryker decided as a contingency for future issues at SE1, that Stryker would look for higher limits a t SE1 for BOD, COD, Ammonia and Chlorides.

I met with yourself on the 22-07-10 and with Hugh Campbell and Glen Bain on the 13-08-10 and agreed those changes. So my letter on the 17-09-12 (attached) was to get written agreement on what we had verbally agreed.

To answer your question in your email: We agreed those changes verbally but we never got a formal response, so yes just.the paperwork I am concerned with . I didn't chase it to get a response as I believed that it would be agreed through the IPPCL application. However The EPA has suggested at a meeting in July that Stryker receive agreement ourselves directly from, the local authority - hence I am now requesting a response from Limerick County Council.

I f you wish to give me a call on this to clarify anything please do on 061 498551.

Kind Regards

1

I

Elaine

. ..... . . . ._ . . -. __ . . __ .. .__ . . . . _ _ - . . . ... , , .. . .. ... . . . ,. .. . . .... . ... .. . -. .. . . . . . . . - . . . . .. .._ . ..

From: Goggin Anne Jmailto:aswain@limerickcoco.iel Sent: 04 September 2012 12:26 To: OConnell Elaine Cc: Brennan Dona1 Subject: RE: IPPC Licence Increase

Elaine

I thought those changes had been agreed some time back. Is it just the paper work you are concerned about?

If the changes have not been agreed, then we would need to involve water services and Severn trent in any discussions.

Please let me know

Regards

Anne

Anne Goggin Senior Executive Engineer Environment Section Tel: 061 496419 Mobile: 087 6675076

_ _ _ ___ ~

From: OConnell Elaine [mailto:elaine.oconnell@stwker.com~ Sent: 29 August 2012 18:02 To: Goggin Anne Subject. IPPC Licence Increase

Hi Anne With regard t o the attached letter which was a request for an increase to some sewer parameters, I was hoping that I could set up a call with you to review this again?

Stryker are replying to an EPA section 90 request on our IPPCL application and would like to include correspondence from Stryker‘s local authority regarding this request.

-

Can you let me know when is a convenient t ime to schedule a call o r set up a meeting. Kind regards Elaine

Elaine O‘Connell Stryker Orthopaedics T 061498551 F 061498292 Elaine.nichonmhara@Strvker.com

“Save the Trees! Only print this message / document if absolutely necessary”

The information contained in this e-mail message and any attachments may contain proprietary and confidential information and is intended only for the individbal or entity to.whom it is addressed. Any use, interception. dissemination, distribution. publication, copying or disclosure by any other person is strictly prohibited. If you are not the intended recipient, you should delete this message and kindly notify the sender via reply e-mail and confirm that you will destroy or delete all copies of the email message and any attachments from your system.

2

I I

I This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com

3

Raheen Business P d Limerick, Ireland I: +353 61 498200 f : +3.53 61 498280 wvwv.stryker.com

Attn: Anne Goggin, Senior Executive Engineer

17” September, 201 0

Environmental Section Limerick County Council County Hall, Dooradoy le Co. Limerick

IPPC Licence No. :POO23-02

Ref.: Increase in IPPC Licence Limits at SEI

Dear Ms Goggin,

Stryker are in the process of an IPPC licence review with the EPA.

Orthopaedics

As discussed at our meeting on the 22-07-10, and also discussed in a meeting with Hugh Campbell, and Glenn Bain from Limerick Main Drainage Project Office on the 13-08-10, Stryker seek to increase licence limits and decrease monitoring frequency for parameters at our main sewer emission point SE1 & SE2. The increase to licence limits are required due for the following reasons:

1 The limit increases at SE1 are necessary to support increased demand for Peri-Apatite coated products manufactured in the Limerick facility. Peri-Apatite coating is a process by which hydroxyapatite (calcium phosphate) is manufactured and applied as a thin layer to beaded surfaces of metal implants. The process is currently being performed using two identical coating machines. The hydroxyapatite is manufactured in the process tank by reacting solutions of calcium acetate and ammonium phosphate under controlled conditions of temperature and pH. As the hydroxyapatite forms, it precipitates out of solution and adheres to the beaded surfaces of the implants. Stryker.propose to bring in two new machines which will be slightly larger in size compared to the current machines. The existing Peri-Apatite area will be expanded to accommodate the two new machines and associated equipment The process waste from the Peri-Apatite Coating process consists of aqueous solutions of ammonium acetate, nitric acid and ammonium hydroxide which are pH neutralized in local effluent tanks prior to discharge. The process waste contains high concentrations of ammonia which is currently discharged on a batch basis typically 5-6 discharges per day. This effluent is discharged through Emission Point SE1, along with Emission Point SE2 into the main sewer leaving the Raheen Business Park where it is diluted further (minimum 1 ,000m3/day), which is then treated in the Waste Water Treatment Plant in Bunlicky.

The discharge of effluent from the increased number of Peri-Apatite coating cycles will increase the concentration and mass loading of the following parameters in the process effluent discharged at SE1 :

Ammonia BOD COD

2 Due to increased regulatory requirements of the medical devise sector, Stryker may be required to use RO water in all the cleaning processes of its products. Currently Stryker treat the mains water to a RO standard in various parts of the plant, this treatment uses Sodium Chloride salts. If the need for RO water increases, there will be an increase in chlorides limits in the SE1 effluent.

3 It must be noted that the effluent volume discharged at SEI shows the downward trend in effluent volumes since 2006, this is due to an effort to reduce water usage onsite, and repairing leaks to the main water pipes onsite. Stryker have reduced the average daily flow at SE1 from 82m31day (2009) to 52m3/day (2010), this has resulted in higher concentration values being recorded for effluent parameters such as Ammonia, BOD and COD.

To support the increase in PA production increased requirements on product cleaning and to accommodate the downward trend in flow from the plant Stryker is seeking agreement from Limerick County Council to change our current IPPC Limits at SE1 to the proposed limits for the parameters as presented in the table 1.

Stryker also seek Limerick County Councils approval for proposed changes to monitoring frequency from weekly to monthly for listed parameters (in table 1) at SE1 & Se2

Finally Stryker seek Limerick County Councils approval to discharge flows greater than that of the Flow limit (400m3/Day) at SEI. This approval is sought for only when a safety critical situation occurs with Vacuum furnace and cooling water is discharged. Stryker will notlfy the Bunlicky Effluent Treatment plant, when it is known that this situation occurs.

Table 1 .

I I I '

Sulphates (as SO4) I 500 1 200 Daily

I BOD I 500 I 80 I Weeklv I COD I 1000 I 140 I Weekly I Total Suspended Solids -1 300 I 120 I Weekly

Nitrates (as N) 200 80 Weekly Total Phosphorus (as P) 100 20 Weekly Chlorides 800 200 Weekly Oils, Fat, Grease 100 20 Weekly

SE 1

I Cobalt I 0.5 I 0.2 I Monthlv Chromium 0.5 0.2 Monthly Molybdenum 0.5 0.2 Monthlv Titanium 0.5 0.2 Monthly Volume 400 m3/d 400 m3/d Daily

I DH I 6-9 I 6-9 I Continuous Toxicity Units None None Annually Ethanol 10% vlv Per Batch

SE 2

Methyl methyacrylate None None Per Batch Toxicity Units None None Annuallv Volume 10 m3/d 10 m3/d Daily

PH 6-9 6-9 Continuous

I I

'500 I 200 Daily I 3000 150 Weekly 6000 250 Weekly

200 80 Monthly 100 20 Monthly

3000 250 Monthly 100 20 Monthly 0.5 0.2 Monthly 0.5 0.2 Monthly 0.5 0.2 Monthly 0.5 0.2 Monthly

400 m3/d* 400 m3/d* Daily

6-9 I 6-9 I Continuous I None None Annually

10% v/v Monthly ~ None I None I Monthly 1

Annually Daily

Continuous

During emergency situations when the Foundry Vacuum Furnace process must divert from recycled Cooling water to mains water this flow limit may be increased, only after notifying the Bunlicky Treatment Plant

The above changes to the ELVs will allow for greater leverage, scope and capacity for the Stryker Plant to add more product lines to Stryker Limerick, and will eliminate the need for costly licence reviews each time a new product or change occurs to the Stryker plant.

If you require further information on this matter; please do not hesitate in contacting me. If the proposed limits are acceptable with Limerick County Council, can you please respond in writing to Stryker Orthopaedics.

Yours Sincerely, .,-

CC Hugh Campbell, Limerick Main Drainage Project Office Seamus Ryan, Water Services, Limerick City Council Donal Brennan, Water Services, Limerick County Council Maria Lenihan, EPA, Regional Inspectorate, Inniscarra, Co. Cork

Limerick County Council Comhairle Chontae Luirnnigh

Environment Section E.S. 31011

Ms Elaine Ni Chonniliara Stryker Orthopaedics Rahecn Industrial Estate Linierick

I Environment I: OGI 47621% 6 061 436008

Re: IPPC Licence Limits -

Dear Elaine,

I refer to your letter of valucs for Ammonia, COD and BOD as shown in the table below:

March 2009 regarding an increase in the emission limit

Paranicter Current IPPC Proposed Limits Liniits

Animon i a My1 3 00 800

K d d a y 140 200 BOD Mg/l 500 2000 I Kdday 80, 100,

Kglday 40 60 COD M d l 1000 3600

Our Water Service Section have confirnied that they have no objection to the proposcd increases.

Yours sincerely,

Anne GogginV Senior Exccutive Enginccr Environment Section

$3 S E -

Raheen Business Pak Limerick, Ireland 1: +353 61 498200 f : +353 61 498280 w\w.stryker.com

Attn: Anne Goggin, Senior Executive Engineer

17” September, 201 0

Environmental Section Limerick County Council County Hall, Dooradoy le Co. Limerick

IPPC Licence No. :POO23-02

Ref.: Increase in IPPC Licence Limits at SEI

Dear Ms Goggin,

1

Orthopaedics

Stryker are in the process of an IPPC licence review with the EPA.

As discussed at our meeting on the 22-07-1 0, and also discussed in a meeting with Hugh Campbell, and Glenn Bain from Limerick Main Drainage Project Office on the 13-08-10, Stryker seek to increase licence limits and decrease monitoring frequency for parameters at our main sewer emission point SE1 & SE2. The increase to licence limits are required due for the following reasons:

1 The limit increases at SE1 are necessary to support increased demand for Peri-Apatite coated products manufactured in the Limerick facility. Peri-Apatite coating is a process by which hydroxyapatite (calcium phosphate) is manufactured and applied as a thin layer to beaded surfaces of metal implants. The process is currently being performed using two identical coating machines. The hydroxyapatite is manufactured in the process tank by reacting solutions of calcium acetate and ammonium phosphate under controlled conditions of temperature and pH. As the hydroxyapatite forms, it precipitates out of solution and adheres to the beaded surfaces of the implants. Stryker propose to bring in two new machines which will be slightly larger in size compared to the current machines. The existing Peri-Apatite area will be expanded to accomm’odate the two new machines and associated equipment The process waste from the Peri-Apatite Coating process consists of aqueous solutions of ammonium acetate, nitric acid and ammonium hydroxide which are pH neutralized in local effluent tanks prior to discharge. The process waste contains high concentrations of ammonia which is currently discharged on a batch basis typically 5-6 discharges per day. This effluent is discharged through Emission Point SEI, along with Emission Point SE2 into the main sewer leaving the Raheen Business Park where it is diluted further (minimum 1 ,000m3/day), which is then treated in the Waste Water Treatment Plant in Bunlicky.

The discharge of effluent from the increased number of Peri-Apatite coating cycles will increase the concentration and mass loading of the following parameters in the process effluent discharged at SE1 :

Ammonia BOD COD

2 Due to increased regulatory requirements of the medical devise sector, Stryker may be required to use RO water in all the cleaning processes of its products. Currently Stryker treat the mains water to a RO standard in various parts of the plant, this treatment uses Sodium Chloride salts. If the need for RO water increases, there will be an increase in chlorides limits in the SE1 effluent.

3 It must be noted that the effluent volume discharged at SE1 shows the downward trend in effluent volumes since 2006, this is due to an effort to reduce water usage onsite, and repairing leaks to the main water pipes onsite. Stryker have reduced the average daily flow at SE1 from 82m3/day (2009) to 52m3/day (ZOlO), this has resulted in higher concentration values being recorded for effluent parameters such as Ammonia, BOD and COD.

To support the increase in PA production increased requirements on product cleaning and to accommodate the downward trend in flow from the plant Stryker is seeking agreement from Limerick County Council to change our current IPPC Limits at SE1 to the proposed limits for the parameters as presented in the table 1.

Stryker also seek Limerick County Councils approval for proposed changes to monitoring frequency from weekly to monthly for listed parameters (in table 1) at SE1 & Se2

Finally Stryker seek Limerick County Councils approval to discharge flows greater than that of the Flow limit (400m3/Day) at SE1. This approval is sought for only when a safety critical situation occurs with Vacuum furnace and cooling water is discharged. Stryker will notlfy the Bunlicky Effluent Treatment plant, when. it is known that this situation occurs.

SE 1

SE 2

- Volume

PH

Table 1

10 m3/d 10 m3/d Daily

6-9 6-9 Continuous

I I

Sulphates (as SO4) I 500 I 200 Daily

10 m3/d

6-9

BOD I 500 I 80 I Weeklv

10 m3/d Daily

6-9 Continuous

COD I 1000 I 140 I Weeklv Total Sumended Solids I 300 I 120 I Weeklv Nitrates (as N) 200 80 Weekly Total Phosphorus (as P) 100 20 Weekly Chlorides 800 200 Weekly Oils, Fat, Grease 100 20 Weekly Cobalt Monthly

Daily

500. 200 Daily

3000 150 Weekly 6000 250 Weekly 300 120 Monthly 200 80 Monthly 100 20 Monthly

3000 250 Monthly 100 20 Monthly 0.5 0.2 Monthly 0.5 0.2 Monthly 0.5 0.2 Monthly 0.5 0.2 Monthly

400 m3/d* 400 m3/d* Daily

DH I 6-9 I 6-9 I Continuous Toxicity Units None None Annually ~

Ethanol 10% v/v Per Batch

Continuous Annually

10% VIV Monthly Methyl methyacrylate I None 1 None I Per Batch I None I None, 1 Monthly Toxicity Units I None I None I Annuallv I None I None 1 Annually

' During emergency situations when the Foundry Vacuum Furnace process must divert from recycled Cooling water to mains water this flow limit may be increased, only after notifying the Bunlicky Treatment Plant

The above changes to the ELVs will allow for greater leverage, scope and capacity for the Stryker Plant to add more product lines to Stryker Limerick, and will eliminate the need for costly licence reviews each time a new product or change occurs to the Stryker plant.

If you require further information on this matter; please do not hesitate in contacting me. If the proposed limits are acceptable with Limerick County Council, can you please respond in writing to Stryker Orthopaedics.

Yours Sincerely,

<

CC Hugh Campbell, Limerick Main Drainage Project Office Seamus Ryan, Water Services, Limerick City Council Dona1 Brennan, Water Services, Limerick County Council Maria Lenihan, EPA, Regional Inspectorate, Inniscarra, Co. Cork

J ti&,, "Y*&.[ ,I( b ;-&wi '.( 2 4 L.7, Ci(+,l 7 ~ i L G

,vi' &-

* Pamela McDonnell

From: OConnell Elaine <elaine.oconnell@stryker.com> Sent: 22 October 2012 17:59 To: Marie O'Connor cc: Pamela McDonnell

Attachments: ,I . .I Subject: . . , FW: Stryker SEI increase requests email no.1 r > .'

:.. 14 27-03-09 SEI Limit Increase.pdfyl6 28-05-09 - Licence increase.pdf; 2) SE increase application.pdf; 365"'Attachment 68-4 Notification Letter to Planning Authority.pdf; 351 , .. Request for application.pdf; 40 RE Stryker 0rthopaedics.htm

:. , ( i\

none

27 351 365

Hi Marie

13-08-1 0

17/09/2010 09-1 1-1 0

01 /02/2011

Meeting with Glen Bain and Hugh Campbell in Bunlicky waste water treatment plant on S E I increase proposal S E I Request to Increase Limits in IPPCL application Application to €PA for New IPPCL licence Letter to planning IPPCL - Feb

Email one 28-05-12 Details the correspondence between Stryker Limerick County Council, City Council and Bunlicky treatment plant from 27-03-09 until the 09-05-12.

Regards Elaine

From: OConnell Elaine Sent: 28 May 2012 16:43 To: 'alosullivan@lirnerickcity.ie' Subject: Stryker SE1 increase requests

Hi Alice Many thanks for calling me earlier today in the table below I have tried to give an overview of Stryker's dealings with LCC and the Bunlicky treatment plant and the attached files to give the background on that.

Str'yker were installing 2 new P SEI parameters Stryker met with

14 I 27/03/2009 I S E I Increase in Limits due to new Periapatite operation

1

.

I believe as LCC have already approved the increase to parameters on the 28-05-09 correspondence No. 16, then Stryker should be able to work to those limits for BOD, COD and Ammonia until the new IPPCL is revised.

27-04-1 2 Ernail to Anne Goggin asking. Confirm that LCC is aware of these exceedances and that LCC will allow effluent at these levels to be discharged to sewer until a revised licence is issued.

40 09-05-1 2

Alice if you need to call me tomorrow to go through this email please do as it might be confusing!

Regards Elaine

Elaine O’Connell Stryker Orthopaedics T 061498551 F 061498292 Elaine.nichonm hara @Strvker.com

“Save the Trees! Only print this message / document if absolutely necessary”

The information contained in this e-mail message and any at!achmenis may coqtain proprietary and confidential information and is intended only ior the individual or entily to whom it is addressed Any use, inrerception, dissemination, distribution, publication. copying or disclosure by any other person is strictly prohibited. If you are no! ihe in:ended iecipient, you should delete !his message and kipdly notify lhe sender via reply e-mail ar;d confirm that you will destroy or delete all copies 9f the email message and any attachments from yobr system

This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http:/lwww .symanteccloud.com

2

Pamela McDonnell

From: OConnell Elaine <elaine.oconnell@stryker.com> Sent: To: Marie O’Connor cc: Pamela McDonnell Subject:

22 October 201 2 1758

outline of Stryker orthopaedics discussion with LCC

Hi Marie Pamela asked me to outline Stryker‘s interaction with Limerick CO CO on your sewer discharge request.

I will forward on two emails which I hope will show the information submitted so far to Limerick County and City Council.

Email one 28-05-12 Details the correspondence between Stryker Limerick County Council, City Council and Bunlicky treatment plant from 27-03-09 until the 09-05-12.

25-07-12 - 28-08-12 After our meeting on the 24-07-12, Stryker spoke to Ciaran Kelly in Bunlicky treatment plant directly. As there was a change in personnel in the plant from the previous meeting and agreements, we though it best for Ciaran to meet with us in Stryker so we could show him the process and effluent. The meeting scheduled for the 2gth of August 2012, however it was cancelled and Stryker were advised that we should contact the County Council directly.

Email two 29-08-12 Details the request to meet with Limerick County Council, the information provided. Further information was sent by email on the 05-09-12, and another email was sent on the 19-10-12.

If you have any questions on any of the correspondence please give me a call on the number below.

Kind regards Elaine

Elaine O’Connell Stryker Orthopaedics T 061498551 F 061498292 Elaine.oconnell@Strvker.com

“Save the Trees! Only print this message / document if absolutely necessary”

------̂------- ___- The information contained in this e-mail message and any attachments may contain proprietary and confidential information and is intended only for the individual or entity to whom it is addressed. Any use, interception, dissemination, distribution, publication, copying or disclosure by any other person is strictly prohibited. If you are not the intended recipient, you should delete this message and kindly notify the sender via reply e-mail and confirm that you will destroy or delete all copies of the email message and any attachments from your system.

This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com

1

A & & , d l d 4 LA @floc Q--L/ f lLLchcJd &7uiL b ,+VN

CV'13 1 4

. Pamela McDonnell

From: Pamela McDonnell Sent: To: Ms Anne Goggin Subject: HowmedidStryker Attachments: Letter+to+Local+Authority+-+Section+99E.pdf; jsessionid=

21 December 201 1 1258

0E783341 C4C805850292840557598 1 65. pdf

Parameter

Total Ammonia

Hi Anne

Existing Existing Mass Proposed Proposed Mass Concentration Emission ELV Concentration Emission ELV

300 40 1300 60 ELV (rndl) (kdd) ELV (mdl) ' ( W d )

Further to our telephone conversation earlier today, please find attached (and a t the link below) the Section 99E letter sent to Limerick County Council on the 1" March 2011 in relation to the IPPC licence review of Howmedica International t/a Stryker Orthopaedics, Raheen Business Park, Limerick (POO23-03). It seems we have not yet received a response to this letter.

BOD COD Chlorides

In summary, the changes requested by the licensee with regard to discharges to sewer are as follows:

so0 80 3000 150 1000 , 140 6000 2 50 800 2 00 3000 250

Parameter

Total Suspended solids

Existing monitoring frequency Proposed monitoring

Weekly Monthlv frequency

Changes to the monitoring frequency for certain parameters are also proposed as follows:

Nitrates Total Phosphorus (as P) Chlorides Oils, Fats, Grease

Weekly . Monthly Weekly Monthly Weekly Monthly Weeklv Monthly

The Section 99E letter can be found a t the following link: http://www.epa.ie/licences/lic eDMS/090151b2803d051O.pdf.

Thank you for your assistance,

Kind regards

Pamela

Pamela McDonnel.1

Inspector

Environmental Licensing Programme

Ofice of Climate, Licensing and Resource Use

Environmental Protection Ageng

Inniscama

Cork

Phone: 021 4860841

Email. p.mcdonnell@epa.ie

Web: m. epa. ie .............................................

........................

2

Limer ick County Counci l County Hall Dooradoyle Counly T.imeiick

Dear Si i :Madani

1 Environmental Protection Agency An GhnIomho#rmchl urn Chmmhnli ComhhoWl

01 h.larch 201 1 Reg No: POO23-03

Headquaneis, Po Fox 3000 Johnstown Castle Estate County Wextord. Ireland

Ceanncheathni. Botca Poist 3003 Eastdt Chair!edn Bhaile Shedin Contae Loch Garman. fire

t t353 53 916 0600 F: +353 53 916 0699 E. infoC3epa.k W: nw.epa.le

LoCall: 1890 33 55 99

I ani to ad\;ise )'ou h a t rlie Agency has rccei\-cd o n iippl'icaiioii 1.1-om Howmedica International S.de K.1 ... Ti-adiiiy As Strvkei. Orthopacdics. Raheci i L lusi l icss 1"ai.k. l < i i l i L ! ~ l 1 . County Li i i ier ick. 161. a n Ilitegrated Pollution rJre\.eiition and C:onrl-ol (IPI'C) I I c t l i cc .

The applicniit propose.^ as pari o f I i is iipplicaiioii [ i , pi.o\.i i lc hii- thi: discharge of' process cflliieiit to i l ie sai i i tar? 3 U t Iiori I y ' 5 se \\TI.. i'roce.<l: e f 11 uei i i I iic I tide5 I irade e 111 t ie 111 a i d ot h e r ilia t l e I. (ot he I t l i a 11 d(jriiest I C

se\viiSe 01' s tor i i i \\;atel.) Deta i l s ol'tlie pi~ol~osrd r l i i issioss I(! tlir sai1itai.y atitliority's sc\\.er are conr:iiiied i n the a l ip l icn i io l i fh 111

This being 11ic c~ i sc a n d i r i accordaiice iritli S c c t i o i i 99E ( 1 1 t l ie En\.ii-i~iinientaI Protectioii Ageiic>, Acts 1982 10 2007. I iiiii to q u e s i y o ~ i r coiiseiit io tlie piwposed tliszhnrge. To this end: I enclosc the rele\.ant section 01' the application rclrrii. I sliniild iilw ;idd t l i a i ill acccsrdaiicc. \\(it11 t h e r.equii.cnients o l the IiPA Acts, yoiii' const i i t inay be sub,iect to SLICI~ c ( ? ~ i d i ~ ~ o i ~ s as [lie authority considers appropriate. Your attention is t l ra\vi i to parngrapli (4) ol' [lie s r t ~ ~ c h e c i copy oi' the rele\'ant section of the Act: as ainendedr For your conveii iei ice please l i i i d auaclied ;I wply for111 i i i c l u d i i i ~ a list of dralr condilions coinpilcd b y the A ~ e n c y .

In accordance with parayrepti (2) of'tliis sectioii o l ' the Act. you are iequested to fonvard your I-esponsc w i r h i n S weeks of the date of this letter. ['lease note that a i i y decision g iven after the expi ry period sha l l be iii\;alid and i n rhose circilinstairces tlic /\gency i i iay p i -owed to grant the liceiice concei1ie.d as i f coiiseiit w a s obtained. Ms. Paiiiela McDoi i i ie l l i s dealing \\.it11 this iiiatter and can be contacted at the Licensing Unit of the Agency. Tel . No. 02 1 4875722 il. you have any queries.

Again. your co-opci-aiioii iii t h i s matter is aplircciated

Yours sincerely

Prograinme Of f icer Of f ice o f Climate, Licensing & Resource L'se

.. . .

I

I

I

I i . -

' 1

I i . .

4. . . . I . . * I I O . j , , . . . , ,_ ..

: ..,........ ... . . . . . .... . . . ..,... .. . . ,.- ..._ _ , . ..... .. 1.- . ~ .

Consent granted subject to the consent conditions outlined below. Consent granted without conditions.

. Consent refused I .

I

SANITARY AUTHORITY RESPONSE

Name of Sanitary Authority: Limerick Coiing Council

A ddress: County Hall Dooradoyle County Linrerick

Howrnedica International S.de R.L. Trading As Stiyker Orthopaedics Name of Facility: IPPC Reg. NO: POO23-03

Address: Raheen Business Park Raheen Countj Linrerick

Consetti: Indicate Yes to one of the following statements:

h'ote I outlined in the sesponse.

Where it is proposed to refuse pcrmissioti fhe reasons for the refusnl should bc clenrly

GENERAL CONSENT CONDITIONS Condition to bc

Included

1 . The licensee shall permit authorised persons, of the Agency and Sanitary Authority, to inspect, examine and test, at all reasonable times, any works and apparatus installed in connection with the process effluent and to take samples of the process effluent.

2. The licensee shall at no time discharge or permit to be discharged into the sewer any liquid matter or thing thal is or may he liable to set or congeal at average sewer temperature or is capable of giving off any inflammable or explosive gas or any acid, alkali or other substance in sufficient concentration to cause con-osioti to sewer pipes, penstock and sewer littirigs or the general , integrity of the sewer. !

~ .- ......

A D D I T I O N A L G E N E R A L C O N S E N T C O N D I T I O N S I n respect o f discharges or emissions to sewers, in accordance with Section 99E

of the EnvironmentRI Protcction Agcncy Acrs 1992 to 2007. (Speclb. freq:iired)

Limit Values for Process Effluent to Sewer

Schedule B: Emission Litnits

Pararneler (delete parameters wlticli are not

applicable)

BOD

Emission point reference no:

Emission Limit Value

Daily Mean Daily Mean Loading Concentration (rng/l) (kgld ay)

I

COD ~~

Suspcndcd Solids

DH

Temperature I ADDITlONAL PARAMETERS

(if r-r y 11 ired) -_ I

Frequency of Monitoring Process Effluent to Sewer

Schedule C

(delete parnrneters which ore not cipplico blc)

Parameter I Monitoring Frequency I Sample Type (e.g. monthly, quarterly, (grab, composite)

annually)

Flow to scwer I I

'l'emperarure

uH

BOD

COD I I Suspended Solids

ADDITIONAL PARAMETERS

(if required)

I . I .". . .

Signed on behalf o r Sanitary Authority:

0

Section 99E o f the Environmental Protection Agency Acts 1992 to 2007

99E.- ( 1 ) Where the Agency proposes to grant a licence (including a revised licence) which involves a discharge of any tradc efflucnt or other matter (other than domestic sewage or storm water) to a sewer, it shall obtain the consent of the sanitary authority in which the sewer is vested, or by which the sewer is controlled, to such a discharge being made.

( 2 ) Where consent is sought in accordance with subsection ( l ) , the Agency inay specify a period (which pcriod shall not in any case be less than 4 weeks from the date on which tlie consent is sought) within which the consent may be granted subject to, or without, conditions or refused; any consent purporting to be granted (whether subject to or witliout conditions) after the expiry of that period, or any decision given purporting to refiise consent after that expiry, shall be invalid and in those circumstances the Agency may proceed to grant tlie licence coiicerned as if thc requirements of subsection ( I ) had been satisfied.

(3) Subject to subsection (4). a consent under subsection ( I ) may be granted subject to or wilhout conditions and i f i t is granted subject to conditions the Agency shall include in the licence or revised licence concenied conditions corresponding to them or, as the Agency may think appropriate, conditions more strict than them.

(4) The conditious that may be attached to a consent by a sariitaiy authority under this section ai-e the following and no other conditions, namely conditions-

(a) relating to-

(I) the nature: composition, temperature, volume, level, rate, and location o t tlie discharge conccrned and the period during \vliich the discharge may, or may not, be made.

(ii) thc provision, operation, maintenance and supervision of meters, gauges, manholes, inspection chambers and other apparatus and other means for riioniioring the nature, extent arid effect of emissions.

(i i i) the taking and analysis of samples, the keepiilg of records dnd f~iriiisliing of infiniiatioii CO the sanitary authority,

(b) specifying a date not later than which any conditions attached tinder this section shall be complied W I t I 1 ,

(c) relating to, providing for or specifying such other matter as may be prescribed

( 5 ) A sanitary authority may request the Agency to review a liceiicc or revised licence to wliicli tliis scctiori rclates-

(a) at intervals of not less than 3 years from the date on which the licence or tlie revised licence is granted, or

(b) at any time with the consent, or on the application, of the person making, causing or perniitting the discharge: or

(c) at any time if-

(i) rhe sanitary authority has reasonable grounds for believing that the discharge authorised by the licence or revised licence is: or is likely IO be. injurious to public health or is likely LO render the waters to \vhich the sewer concerned discharges unfit for w e for domestic , commercia I ~ i ndus t ria I , tis her y ( i nc lud i n g fish- fa rini 11 g ) ~

agricultural or rccrcaIiona1 USCS or is: or is ltkcly IO be othcrwisc, a scrious risk IO

the quality of the waters,

(ii) there has been a material change i i i the nature or volume of the discharge,

( i i i ) there has bccn a material change i n relalion 1 0 the waters to which the sewer concerned discharges, or

(iv) further information has become available since the date on which the licence or revised licence was granted relating to polluting matter present in the discharge concerned or relating to the effects of such matter,

and the Agency shall consider and inay comply with such request and shall have regard to any submission on the matter received from the sanitary authority.

P 9

h c 0 U ) U)

0,

.c U m a,

0

._

.- E

L

b

0 a

5

5 D

0,

C 3 U U) U 0

a, Q

.- L

ai U

i2 a,

0

a, m

n .d

z a i U z s! m U ) C 0 U) U)

a,

.-

.- E

U) C 0

m m

._ -

.-

- m

U) m a, U)

0 C

z x m U

- ._

.. ,_.. . . . . . .

$I 3 SI SI SI SI SI 21 SI SI SI SI SI I I SI

t 0.

D

rr, 4

i ! &

2

5

L m (I) x

0) Y .

4 4 4 4 4 4 6 4 4 4 4 4 4 ZI *I ZI ZI zl ' ZI ZI ZI ZI ZI ZI ZI ZI SI 21

SI SI SI SI SI %I SI SI SI SI SI SI SI SI 3

--. 0 C .- lA lA

a,

.- E

VI K 0 VI In

w

.-

.- E

.. .

L

a, Q

-, . ,. ... ., . . ,. :. ,... . , . . .. ... , .. .. .. . , ' ...., , ...... ~. .. , . . . .I.. : , .... -. :... ... ,.. ... : .> .

c 0 U) U)

.-

2 U

L

(I) 0) x 0) Y .

?I PI