ARRAN - Environmental Protection · PDF fileReview of Residual Management Plan ... regard to...

ARRAN Monksland Industrial Estate CHEMICAL COMPANY LTD Athlone, Co Roscommon, Ireland Tel: +353 (0)90 6494807 Fax: +353 (0)90 6494809 Email: [email protected] Website: www.arranchemical.ie

ARRAN CHEMICAL COMPANY LTD

ANNUAL ENVIRONMENTAL REPORT 2009

Arran Chemical Company Ltd Annual Environmental Report 2009

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CONTENTS 1. Introduction

1.1. Company Details 1.2. Arran Chemical Company Activities 1.3. Annual Environmental Report 2009 1.4. Organisation Chart 1.5. Environmental Policy

2. Summary Information

2.1. Emissions to Sewers 2.2. Emissions to Surface Waters 2.3. Emissions to Atmosphere 2.4. Waste Management 2.5. Agency Monitoring and Enforcement 2.6. Energy consumption summary 2.7. Resource consumption summary 2.8. Incidents and Complaints

3. Management

3.1. Objectives & Targets 3.2. Summary of Work Completed During 2009 3.3. Environmental Management Programme 2009 3.4. Pollutant Release and Transfer Register (PRTR)

4. Licence Specific Reports

4.1. Toxicity Testing 4.2. Ambient Groundwater Monitoring 4.3. New Products & Processes 4.4. Noise monitoring report summary 4.5. Tank and pipeline testing inspection report 4.6. Report on the assessment of the efficiency of use of raw materials in

processes and the reduction in waste generated. 4.7. Report on progress made and proposals being developed to minimise

water demand and the volume of trade effluent discharge 4.8. Review of Residual Management Plan 4.9. Statement of measures in relation to prevention of environmental damage

and remedial actions (Environmental Liabilities). Appendix A: PRTR Worksheets


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1. INTRODUCTION 1.1 Company Details Licence Register No.: P0110-02 Name: Arran Chemical Company Limited Location: Monksland Industrial Estate, Athlone, Co. Roscommon 1.2 Arran Chemical Company Activities Arran Chemical Company commenced manufacturing on-site in Monksland in 1988, with the number of employees currently standing at 47. Arran operates a small batch-mode multi-purpose chemical synthesis plant for the manufacture of products for pharmaceutical and health care, personal care, and other specialised chemical and industrial applications. Arran's manufacturing range includes products for diverse industrial applications, and features a range of alkylamines, pharmaceutical intermediates, flavour & fragrance and other personal care products, organometallics and other specialties. A significant part of the company’s business is in specialized intermediates for the pharmaceutical industry, based on proprietary reaction technology, especially chiral products, which enable the manufacture of drugs with higher efficacy and lower side effects, and it is anticipated that this pattern will continue, and provide a focus for future growth within a pattern of sustainable development. The company works to ISO 9001:2000 standards, including many features of GMP (Good Manufacturing Practice). Arran is in good compliance with health and safety regulations and Safety Management System (SMS) in place. The Responsible Care programme, of which Arran is a member, provides a useful framework to support conformance with environmental, health and safety standards. The ISO14001 environmental management system was upgraded to the 2004 standard and accreditation was received in September 2005. The company made application to the Environmental Protection Agency (EPA) for an Integrated Pollution Control (IPC) Licence on the 1st March 1996, with a licence being granted on 13th December 1996. This licence was reviewed against the Integrated Pollution Prevention & Control (IPPC) Directive and a new licence (P0110-02) granted on 2nd July 2007. 1.3 Annual Environmental Report 2009 This is Arran’s thirteenth Annual Environmental Report (AER), in accordance with condition 11.8 of the company’s IPPC licence. This report has been prepared with regard to the Guidance Note on the preparation and presentation of the Annual Environmental Report published by the Agency in October 2000 and the reporting requirements in Schedule D of the IPPC licence. Over the last thirteen years, as projected in the first AER, Arran has continued to develop, and to upgrade its manufacturing plant and operating systems, including management systems for safety, health and environmental control, with a modest increase in output year on year, while remaining within the original permitted limits, actually reducing emissions in certain categories and improving solvent recovery. As


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well as responding in a positive way to regulatory obligations, the company continues to move substantially in introducing elements of GMP into its ISO 9001 systems, which has required some internal changes and additional controls. During 2009, the Quality Management System was upgraded to the ISO9001:2008 standard with recertification in August 2009. This allowed for integration of the Quality and Environmental systems in certain areas where there was overlap, resulting in an overall improvement in general management of the systems. Many of the new revised IPPC licence requirements and programme targets have now been implemented, and we are continuing with the phase of consolidating and seeking further improvement. This thirteenth AER, which includes an index of contents and a number of sections covering the various aspects of its environmental control programme, also contains an account of progress made in relation to objectives and targets included in the company’s Environmental Management Programme. The completed AER Returns Worksheet is contained in Appendix A. This format is designed to summarise all emissions from the site in conjunction with the reporting requirements of the recent Pollutant Release and Transfer Register (PRTR) regulations and IPPC AER reporting requirements. However, for the purpose of year on year comparisons the same format for presenting tables of emissions has been retained from previous years. In certain sections of this AER, additional tables and graphs have been included to highlight the reductions in process emissions, resulting from improved environmental control. There have been some changes to licence limits during the licence revision and the new limits as per licence P0110-02 have being included in this AER. 1.4 Organisation Chart

Managing Director

Administration Production Quality Control Technical Environmental Manager Manager Manager Manager Manager

QC Administration Engineer Production Chemists R & D Pilot Plant Environmental Staff Supervisors Chemists Operators Chemists

Chargehands &Process operators

1.5 Environmental Policy A copy of our signed Environmental Policy is included on the next page. A copy is contained in our Environmental Manual (part of EMS) in line with the ISO14001 standard.


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2. SUMMARY INFORMATION 2.1 Emissions to Sewer Table 1 below contains Summary Information for 2009 based on daily composite results. The daily composite samples, taken by the composite sampler every day we discharge to sewer, were used to complete the Summary Data Table. Table 1 Summary Data for SE1 Emission Point Reference Number: SE1 Emission to: Sanitary Authority Foul Sewer

Parameter Unit Licensed emission 2007 2008 2009

Volume M3 25,550 18,553 18,966 18,746 Suspended Solids Kg 10,950 3,612 2,843 2,816 BOD Kg 87,600 58,583 60,237 67,149 COD Kg 219,000 105,487 114,214 127,487 Total Dissolved Solids Kg 131,400 77,815 105,059 99,711 Sulphates Kg 65,700 9,552 12,726 12,585 Phenol Kg 328.5 7 63 25 Detergent Kg 219 0.56 1.49 0.9 Chloride Kg 82,175 32,188 39,069 33,710 Sulphite Kg 4,380 244 118 575 Total Phosphorus Kg 219 12 26 10 Heavy Metals Kg 109.5 18 50 37 % Compliance % 100 100 100 Number of samples 335 312 334 Summary of Exceedances There were no exceedances in emissions to effluent during 2009.


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2.2 Emissions to Surface Waters All surface water emissions to the Cross River occur through SW1 at the site front gate. This is visually inspected daily and during the first noticeable flow of the week, the surface water is sampled for pH, conductivity and COD, noting weather conditions. The results are maintained on file at Arran with summary data for SW1 is shown below in Table 2. Surface water that falls within the unloading area in the front yard is collected in the Front Yard Sump (FYS). FYS surface water is analysed for pH, conductivity and COD. This is released to SW1 through a manual valve provided that COD value is <125mg/l and pH & conductivity results are similar to those obtained at SW1. COD values above 125mg/l are investigated to determine the potential source. In 2009 one value above 125mg/l was recorded when sampled after a dry period and diverted to effluent system. Table 2. Summary Data for SW1 Emission Point Reference Number: SW1 Emission to: Surface Water Drain Emissions to surface water 2009 Parameter (average) Unit Average Maximum Minimum pH 7.8 9.1 6.9 Conductivity µS 169 1213 46 COD mg/L 48 240 0 Number of samples 32


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2.3 Emissions to Atmosphere All Vents A1, A2, BE1 & BE2 were monitored during 2009 as required by the licence P0110-02. Vent A1 is the main stack connected to the main scrubber for normal production. Vent A2 is used for solvent recovery and to monitor emissions from specific processes as required. Vent BE1 is the steam boiler and BE2 is the heating boiler. Table 3, 4, 5 & 6 contain summary data for vents A1, A2, BE1 & BE2 respectively, and Table 7 contains the Emissions to Atmosphere Monitoring Results for Vent A1 for 2009. Table 3. Summary Data for A1 Emission Point Reference Number: Vent A1

Emissions to air Parameter Unit Licensed emission 2007 2008 2009 Volume m3 6,701,400 2,184,000 2,788,800 2,226,000 TA Luft Class I Kg 876 121 3 39 TA Luft Class II Kg 17,520 7,366 10,973 5,324 TA Luft Class III Kg 26,280 4,079 10,321 10,382 % Compliance % 94 100 100 Number of samples 16 24 28 Table 4. Summary Data for A2 Emission Point Reference Number: Vent A2

Emissions to air Parameter Unit Licensed emission 2007 2008 2009 Volume m3 6,570,000 696,000 672,000 627,000 TA Luft Class I Kg 876 0* 56 93 TA Luft Class II Kg 17,520 3,414 2,767 1803 TA Luft Class III Kg 26,280 131 13 1 % Compliance % 100 100 100 Number of samples 17 28 7 Note (*): DCM classified as Class III in 2007. Table 5. Summary Data for BE1. Emission Point Reference Number: BE1

Boiler Emissions to air

Parameter Unit Licensed emission

2009

SOx mg/Nm3 1,700 82 NOx mg/Nm3 600 163 CO mg/Nm3 150 4


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Table 6. Summary Data for BE2. Emission Point Reference Number: BE2

Boiler Emissions to air

Parameter Unit Licensed emission

2009

SOx mg/Nm3 1,700 29 NOx mg/Nm3 600 84 CO mg/Nm3 150 1.3 Summary of Exceedances There was no exceedance relating to air emissions during 2009 on vents A1, A2, BE1 & BE2.

Arran Chemical Company Ltd AER 2009

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Table 7. Emissions to Atmosphere from A1 2009

Solvent Acetone DCM Ethanol (IMS)

Ethyl Acetate Heptane Hexane IPA MeOH MTBE ACN TEA THF Toluene Xylene

TA Luft Class III I III III II III III III III II I II II II Date Emission kg/hr

(i) Air Emissions – Quarter 1 2009 09/01/2009 0.002 0.215 22/01/2009 0.011 0.079 05/02/2009 0.012 0.002 0.072 1.326 10/02/2009 0.08 18/02/2009 0.390 0.068 0.436 0.528 24/03/2009 0.238 0.127 0.752 0.084 30/03/2009 1.382 0.804 0.003

Total Emissions kg Q1 0 0 684 71 0 0 582 0 1516 0 0.008 0 1302 6

(ii) Air Emissions - Quarter 2 2009 08/04/2009 0.405 0.581 0.412 22/04/2009 0.382 0.416 21/05/2009 0.115 0.001 0.060 1.251 0.115 0.648 28/05/2009 0.680 0.792 0.003 0.027 0.258 17/06/2009 0.144 0.035 0.827 0.193 0.133 17/06/2009 0.409 0.119 0.361 0.340 0.57

Total Emissions kg Q2 0 0 777 2 0 0 729 0 1,776 7 0 369 883 0


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Table 7. Emissions to Atmosphere from A1 2009 (con’t)

Solvent Acetone DCM Ethanol (IMS)

Ethyl Acetate Heptane Hexane IPA MeOH MTBE ACN TEA THF Toluene Xylene

TA Luft Class III I III III II III III III III II I II II II Date Emission kg/hr

(iii) Air Emissions - Quarter 3 2009 02/07/2009 0.210 0.003 0.003 0.203 0.109 0.441 0.004 09/07/2009 0.177 0.280 13/07/2009 0.583 0.008 0.114 0.153 0.657 26/08/2009 0.202 0.002 0.508 0.117 0.603 0.312 31/08/2009 0.089 0.022 1.425 0.063 04/09/2009 0.021 0.092 0.072 0.849 0.604 16/09/2009 0.018 0.105 1.802 0.692 0.394 22/09/2009 0.018

Total Emissions kg Q3 0 36 652 207 68 16 889 0 807 142 0.018 1,400 683 0

(iv) Air Emissions - Quarter 4 2009 08/10/2009 0.008 0.002 0.083 0.168 0.096 0.387 29/10/2009 0.313 0.198 0.100 0.071 30/10/2009 0.024 0.018 0.207 0.145 0.050 06/11/2009 0.203 0.024 0.607 0.738 0.294 27/11/2009 0.004 0.045 0.337 0.179 0.006 08/12/2009 0.547 0.075 17/12/2009 0.026 0.240 0.001

Total Emissions kg Q4 0 0 360 0 34 204 421 0 585 0 0 259 272 2

Total Emissions in 2009, kg 0 36 2473 279 101 220 2622 3 4684 149 3 2027 3140 8


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Table 8. Summary of Total Emissions to Atmosphere 2009

(v) Air Emissions from A1- Summary 2009

TA Luft Class Total Emissions in 2009

Ethanol III 2473 Acetone III 0

Ethyl Acetate III 279 Hexane III 220

IPA III 2622 MTBE III 4684 MeOH III 3

Heptane III 101 Total Class III 10382

Xylene II 8THF II 2027

Acetonitrile II 148 Toluene II 3140

Total Class II 5324 DCM I 36 TEA I 3

Total Class I 39


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Vent A2 In previous years the Solvent Recovery Column and reactor vessel, R110, (normally used for Methanol recovery) were the only vessels connected to A2. On occasions R110 vessel is used for mixed solvent recovery, e.g. to reduce the water content of a batch of mixed solvent waste. Since 2006, by agreement with the EPA, emissions from specific processes were monitored using the FID analyzer on A2. This accounts for the increase in the total emissions for A2. Actual air flows will depend on pressure drops in vent lines, which depend on scrubbing capacity.

Table 9. Emissions to Atmosphere from A2 2009 (i) A2 Air Emissions – Quarter 1 2009

Date Emission, kg/hr DCM MeOH THF

TA Luft Class I III II 09/01/2009 0.389 19/03/2009 0.001

Total Emissions kg Q1 0 1 523

(ii) A2 Air Emissions - Quarter 2 2009 11/06/2009 0.377 17/06/2009 0.409


(iii) A2 Air Emissions - Quarter 3 2009 27/08/2009 0.462 23/09/2009 0.064


(iv) A2 Air Emissions - Quarter 4 2009 27/11/2009 0.071


Total Emissions in 2009, kg 93 1 1803 Table 10. Total Emissions to Atmosphere from Vent A2 2009

Total Emissions in 2009, kg MeOH 93

Total Class III 93 THF 1803

Total Class II 1803 DCM 1

Total Class I 1


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2.4 Waste Management The total waste produced – hazardous and non-hazardous, recycled and disposed – at Arran during 2009 shows a decrease of 395 tonnes when compared with the previous year, bearing in mind that the production mix in any given year will impact on these figures. Table 11 illustrates that overall recovery of waste (on & off-site) still exceeds disposal tonnages, with the equal reduction for each for 2009. Hazardous waste figures are reduced by 368 tonnes compared to 2008 figures with half of this waste recovered. As discussed in previous AERs, we continue to improve and develop processes by reducing raw material consumption, reducing waste stream volumes, making waste streams more manageable through segregation and balancing and reusing or recovering solvents. Table 12 contains information on the various waste streams produced at Arran. Asterix (*) next to the EWC Code indicates that the waste is hazardous. As can be seen from Table 13, additional solvent streams were segregated and sent externally for recovery and reuse (for example, Tetrahydrofuran), and that some of the mixed solvent waste streams were diverted for fuel blending rather then disposal. Arran operates a small multi-purpose plant, carrying out batch processes, some of which are run only occasionally, so that waste streams and solvent usage are not constant, and there will be periods in the year and even years with substantially less usage and even emissions of particular solvents. Thus, waste streams are continuously changing, and the various balancing options need to be reviewed at regular intervals.


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Table 11. Summary of Waste Produced 2007 - 2009

Waste

2007 2008 2009 Total quantity of waste produced in calendar year(Tonnes) 2398 1645 1250 Total quantity of waste disposed of on-site 0 0 0 Total quantity of waste disposed of off-site 1028 813 594 Total quantity of waste recovered on-site 722 409 353 Total quantity of waste recovered off-site 649 423 303 2007 2008 2009 Quantity of non-hazardous waste produced in calendar year 107 112 86 Quantity of non-hazardous waste disposed of on-site 0 0 0 Quantity of non-hazardous waste disposed of off-site 30 26 21 Quantity of non-hazardous waste recovered on-site 0 0 0 Quantity of non-hazardous waste recovered off-site 77 86 65 2007 2008 2009 Quantity of hazardous waste produced in calendar year (Tonnes) 2293 1532 1164 Quantity of hazardous waste disposed of on-site 0 0 0 Quantity of hazardous waste disposed of off-site 998 787 573 Quantity of hazardous waste recovered on-site 722 409 353 Quantity of hazardous waste recovered off-site 573 336 238


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Table 12. Waste Streams Summary Data

European Waste

Catalogue Code

Description of Waste

Quantity (t/year)

Method of Disposal/ Recovery

Location of Disposal/ recovery

Name of Waste Disposal recovery

Contractor

07 05 04*

non-halogenated solvents – MtBE, MeOH, Et-Ac, 12.25 R2 Ireland Soltec Ltd

15 02 02* charcoal with DCM 1.1 D10 ATM, Holland Soltec Ltd 15 01 10* empty steel drums 2.4 R4 Ireland Soltec Ltd 15 01 10* empty steel drums 32.0 R4 Ireland Rilta Ltd 15 01 10* empty plastic drums 9.5 R4 Ireland Rilta Ltd 15 01 04 empty steel drums 16.5 R4 Ireland AES/Hammond Lane

07 05 03* halogenated mixed solvents 4.7 R2 ATM, Holland Rilta Ltd

07 07 01* aqueous wash & rinse liquids 38 D8 Ireland Rilta Ltd

07 07 01* aqueous wash & rinse liquids 22.0 D9 Ireland ENVA

07 05 04*

non-halogenated mixed solvent 44.66 R1 Ireland

Veolia Environmental Services Ltd.

07 05 03*

halogenated mixed solvent 107.9 D10 AVG, Germany Indaver Ireland

07 05 04* non-halogenated mixed solvent 337.4 D10 SAVA, Germany DEE Environmental

07 05 08* reaction residues 45.3 D10 SAVA, Germany DEE Environmental 15 02 02* absorbents & filters 6.8 D10 SAVA, Germany DEE Environmental 15 01 10* packaging 14.6 D10 SAVA, Germany DEE Environmental 07 05 04* tetrahydrafuran 89.19 R2 SRM Ltd, UK DEE Environmental

07 05 04* Industrial methylated spirits 42.36 R2 SRM Ltd, UK DEE Environmental

20 01 01 paper & cardboard 10.81 R3 Ireland CWR Ltd 20 01 39 plastics 0.26 R3 Ireland CWR Ltd 20 01 99 tetrapak 0.14 R3 Ireland CWR Ltd 15 01 03 timber pallets 31.94 R3 Ireland Connaught Timber 17 02 01 timber waste 4.02 R3 Ireland AES 20 01 02 glass 0.45 R5 Ireland AES

20 03 01 mixed municipal waste 21.32 D1 Ireland AES

13 02 08* waste oil 0.941 R9 Ireland SafetyKleen


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Table 13. Summary of all Waste Produced at Arran for Disposal and Recovery off-site 2002 – 2009 All in Metric Tonnes 2002 2003 2004 2005 2006 2007 2008 2009 Hazardous Disposed Water in mixed solvent 285 373 156 155 523 490 329 234

Solvents in mixed solvent 234 242 157 180 353 315 228 187 Aqueous waste 289 0 0 270 233 175 122 60

Solid Waste 39 56 51 53 53 78 65 67 Total Hazardous Disposed 847 670 364 657 1162 1058 744 589 Hazardous Recycled Empty Steel Drums 49 56 43 75 81 100 54 34

Empty Plastic Drums 5 6 5 10 IMS 22 42 26 13 18 42

MeOH 43 93 59 5 Ethyl Acetate 11 10 5

Water in mixed solvent fuel blend 27 Solvents in mixed solvent fuel blend 14

THF 223 124 121 136 220 331 202 89 Total Hazardous Recycled 174 178 201 373 361 572 338 202 Total Hazardous 1020 848 565 1030 1523 1630 1082 791 Non-hazardous Disposal to Landfill 35 21 13 15 29 30 26 21 Total Non-hazardous Disposed 35 21 13 15 29 30 26 21 Non-hazardous Recycled Timber Waste 8.3 4

Timber Pallets 9 13 14 34 37 41.8 45 32 Cardboard & Paper 3.0 4.7 5.3 6.0 6.9 8.4 11 Plastic & Tetrapak 0.1 0.1 0.6 0.4 1.0 0.7 0.4

Glass 0.2 0.7 1.4 0.8 0.5 0.2 0.45 Empty Drums 14.3 14.2 18.4 18.4 14.3 26.7 23.4 17

Total Non-hazardous Recycled 23 31 37 60 59 77 77 65 Total Non-Hazardous 58 51 50 74 88 107 103 86

Total Tonnage Disposed 882 691 377 672 1191 1088 770 610Total Tonnage Recycled 196 208 238 432 420 649 423 267


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Breakdown of Total Waste Produced for Disposal & Recovery 2009

Water in M ixed Solvent29%

M ethanol1%

Tetrahydrafuran10%

Cardboard & Paper1%

Aqueous waste7%

Plastic0%

Solid Waste8%

Solvent in M ixed Solvent23%

Empty Steel Drums6%

Empty Plastic Drums1%

Brown Glass0%

Timber Waste4%

Ethyl Acetate1%

Landfill4%

IM S5%


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2.5 Agency Monitoring & Enforcement During 2009, the EPA monitoring inspector called unannounced twice to sample our effluent (2) and surface water (1) emissions and Roscommon County Council (RCC) took samples of effluent (6) emissions. Two EPA Inspectors called on an unannounced site inspection with follow-up site inspection report. 2.6 Energy Consumption Summary Table 14. Energy Usage

Energy Consumption Unit Sulphur Content 2007 2008 2009

Light Fuel Oil

m3 0.11-0.14% 165.5 133.9 134.4

Electricity

MW 1799 1552 1752

The increase in energy usage depends on production output and product mix and can vary from year to year. 2.7 Resource Consumption Summary Table 15. Water Consumption

Water

Unit 2007 2008 2009

On-Site groundwater use

m3 0 0 0

On-Site surface water use

m3 0 0 0

Municipal water use

m3 15,566 12,899 11,658


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2.8 Incidents & Complaints There were no incidents and no complaints to report to the Agency during 2009. In line with Condition 11.1 of our IPPC licence, there were 2 notifications to the Agency where monitoring equipment required repair during 2009. Date Notification Cause Corrective Action 12-Jan-09 Composite sampler

malfunction on effluent discharge

Bearing failure in sampler

New parts installed & servicing agent for this equipment.

25-Jan-09 Composite sampler malfunction on effluent discharge

Keypad controller & power transistor board malfunction

Equipment vendor could not identify any reason for malfunction or corrective actions


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3 Management 3.1 Objectives & Targets

In line with Section 2.2.2.2 Schedule of Environmental Objectives and Targets and 2.2.2.3 Environmental Management Programme (EMP), the schedule of environmental objectives and targets is changed somewhat from the format used in the AER 2006 report, to take into account additional requirements specified in the licence conditions listed. As set out in reports in previous years, it is the company’s intention to continue to review and, where appropriate, upgrade its operations, particularly with respect to safety, environmental and product quality, as an integral part of the sustainable growth programme. The environmental objectives set out in the table below continuing in line with previous years, taking into account the requirements of the new licence conditions. Arran’s Environmental Objectives are: Ref No. Area of Focus: Objective

1 Energy and Resource Efficiency: Review all operations and processes, for energy and resource efficiency.

2 Cleaner Technology and Cleaner Production: Review practicable options for use of cleaner technology and cleaner production with reference to the BAT guidelines, inlcuding possible options for replacement of list 1 substances and substances with the risk phrase R50, R51, R53, and R58.

3 Atmospheric and Fugitive Emissions: Review practicable options for reduction in fugitive emissions.

4 Waste Minimisation: Review practicable options for reduction and minimisation of waste.

5 To mimimise the consequence of any accidental discharges to the environment.

3.2 Summary of Work Completed During 2009

Section 3.2 contains a summary of targets completed during 2009. 3.2.1 Energy & Resource Efficiency

Objective: To review all operations and processes for energy and resource efficiency.

Target 1/09/1: Arran has had a successful program in place over the years to maximize resource efficiency in processes and operations, especially with regard to solvent use. The in-house solvent mass balance figures, show that the ratio of virgin solvent input to production output has decreased continually over the last three years, from 4.9:1 (2007), to 2.7:1 (2008) to 1.7:1 (2009). While this will depend on the process mix in production, they demonstrate the environmental and economic benefits of recycling & reusing solvent in production processes.


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Target 1/09/2: The various factors that impact on the operation of equipment in the production plant (quality, order deadlines, raw material inputs, reactors and/or other equipment availability) made it difficult to match usage to suit off peak times. Specific equipment such as the oil heaters were switched operate during the off peak hours.

Target 1/09/3: Possible locations for the storage of rainwater with potential interception points for roof water were identified. However the distance and the cost associated with installing & insulating pipe work was significant, since the storage tank and the point of use are not in close proximity to the storm water interception point. A separate distribution system would also be required to replace process water for non-production usage.

3.2.2 Cleaner Technology and Cleaner Production

Objective: Review practicable options for use of cleaner production options for use of cleaner technology and cleaner production with reference to the BAT guidelines, including possible options for replacement of list 1 substances and substances with the risk phrase R50, R51, R53, and R58. Target 2/09/1: Environmental related instructions on production batch sheets were improved as they arose throughout the year, with the objective of improving communications at operator and supervisor levels through the batch sheet instructions. Specific changes relating to segregation of materials and venting of reactors were included, including many new improvements in methodology.

Target 2/09/2: As part of the company’s implementation of the REACH regulation, the documentation of inventory material and supply chain of raw materials, including for risk phrases R50, R51, R53 and R58 are subject to review. Target 2/09/3: One process was changed to replace DCM with Methyl-t-Butyl Ether (MtBE) as a process material during 2009. This was part of the ongoing work over the last number of years to replace DCM from production processes, were it is feasible, noting the significant process reaction and safety properties of DCM. Charcoal abatement is used to ensure licence compliance for process emissions where there is no alternative to DCM.

3.2.3 Atmospheric and Fugitive Emissions:

Target 3/09/1: Work on the project to identify and install a continuous emissions monitor on the A1 stack that will quantify emission against the TA Luft standards continued during 2009. In collaboration with the instrument supplier, development work with new GC columns to accommodate the range of solvents used at Arran, continuing the resolution and retention time issues highlighted in 2008 trials.

The problem of communicating data to a PLC and/or database, to facilitate trending & calculation of emissions, requires the development of a programme to translate the instrument output via an additional communication port, and was installed by the instrument supplier in August 2009. Recent focus was on optimising the methodology of the sequencing events to get the emission sample to the sample cylinder, and then presentation to the


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Voyager for analysis. Samples using known gases and numerous samples from the stack were analysed to determine the optimum vacuum pressure and purging pressure of the sampling cylinder for accurate analysis. The experience gained from manual sampling with the prototype cylinder provided useful input to develop a cost model for the sampling equipment and the programming required to analyse the results. In general, the work done to date shows that the concept originally envisaged is valid, that is to use an online analytical device, together with suitable sampling methodology and the PLC system for handling and recording data. The information gained to date has provided a useful basis for the necessary further development. Quarterly updates were provided to the EPA on the project during 2009.

3.2.4 Waste Minimisation:

Objective: Review practicable options for reduction and minimization of waste.

Target 4/09/1: The average water content for solvent waste loads sent off site for disposal over the last three years ranged from 61.5% in 2007, to 59% in 2008 and to 56% in 2009. However, best practice may dictate that disposal is the best option for the hazardous components of these waste streams. With this in mind, the option for disposal of waste as fuel blend was examined and some waste sent (to blending plants) on a trial for suitability, with the residual solvent mixture contributing towards calorific value. This option is influenced by market demands for fuel blends and not all waste streams are suitable.

Target 4/09/2: The solvent mass balance is the most suitable measure to monitor process material inputs & outputs, as it tracks the various different aspects of material transfers. During 2009 Isopropanol was added to the solvent list for full mass balance. The solvents selected for full mass balances may vary from year to year given the varying of production trends, and it is best suited to the mainstream solvents used continually over a number of years.

3.2.5 To Minimize the Consequences of any Accidental Discharges to the

Environment.

Target 5/09/1: A bund integrity test indicated weakness on an internal kerbing in the Unit 6 warehouse. Following an inspection the impervious sealant layer was repaired & upgraded. The bund integrity test was repeated and passed successfully. The Unit 4 warehouse was upgraded during 2009 by adding a ramp at the rear door to the backyard to increase the containment capacity within the warehouse. An additional bund was installed in the backyard to accommodate the increased IBC’s storage capability from processes that arose in 2009.


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3.3 Environmental Management Programme: EMP 2010 Section 3.3 contains the details of the EMP 2010. Each of the five Objectives has associated targets for 2010, and these are summarised in the following sections, with a short progress note and comment as appropriate. For 2010, some targets include a continuation or modification of projects carried over from 2009 & 2008.

3.3.1 Energy & Resource Efficiency

Objective: To review all operations and processes for energy and resource efficiency.

Target 1/10/1: Replace the existing steam boiler with a new gas-fired

boiler. This will reduce boiler emissions while improving efficiency of steam generation for current & future production demands.

Timescale: Quarter 4, 2010

3.3.2 Cleaner Technology and Cleaner Production

Objective: Review practicable options for use of cleaner production options for use of cleaner technology and cleaner production with reference to the BAT guidelines, including possible options for replacement of list 1 substances and substances with the risk phrase R50, R51, R53, and R58. Target 2/10/1:

Target 2/10/2: Investigate the potential for the possible replacement of one of the raw material substances listed with the risk phase R50, R51, R53 and R58 with another material. Laboratory work will be required to determine if trial batches with the changes are feasible

Timescale: Quarter 4, 2010 Target 2/10/3: Development work will continue to investigate potential for

replacement of DCM from another process during 2010. Charcoal abatement is used to ensure licence compliance for process emissions where there is no viable alternative to DCM.



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3.3.3 Atmospheric and Fugitive Emissions:

Objective: Review practicable options for reduction in emissions.

Target 3/10/1: The on-going project to identify and install a continuous

emissions monitor on the A1 stack, which will quantify emissions against the TA Luft standards, will continue during 2010. During Quarter 1, the use of a larger 30litre sampling cylinder will be followed by the use of a multi-gas mixture to determine quantatively the sampling cylinder operation. Based on this trial the project will proceed with the development of the final sampling equipment and sampling control system. This will then continue with development of the database programming to gather the analytical data from the instrument and present for emission calculation and trending.

Quarterly updates will be provided to the EPA on the project in 2010.

Timescale: Quarter 4, 2010 Target 3/10/2: Install an additional vent header line from the Pilot Plant to

the A1 & A2 abatement systems to provide options for the selection & differentiation of reactor emissions, and the treatment & abatement of reactor emissions. Install a condenser on the vacuum pump system vent line from the pilot plant to reduce the loading on the scrubber abatement system.


3.3.4 Waste Minimisation:

Objective: Review practicable options for reduction and minimization of waste.

Target 4/10/1: Install a dedicated reactor for the recovery of solvent on

site to reduce the use of ‘fresh’ solvent in production.


Target 4/10/2: Modify the existing reactor vessel R111 to provide for

charging waste materials from drums and IBC’s to bulk tanks for either recovery or disposal.



26

3.3.5 To Minimize the Consequences of any Accidental Discharges to the Environment.

Objective: Review practicable options for improved containment on site.

Target 5/10/1: Install an additional bund at Unit 3 backyard to facilitate

tanks for the storage of solvent for on site recovery, and thereby reducing the amount of storage in IBC’s in bunded areas.



27

3.4 Pollution Release and Transfer Register (PRTR)

The E-PRTR is provided for by EC Regulation 133/2006 and was transposed into Irish law by S.I. 123/2007. The aim of PRTR is to enhance environmental data collection for the public and policy makers in Europe. All member states are required to contribute to PRTR on an annual basis and to meet this requirement the EPA has required all licensed activities in Ireland to combine the PRTR reporting with the requirements for the AER reporting. The PRTR reporting requirement to Europe will then be assessed by the EPA for each facility, and the facility will be informed prior to any PRTR reporting. It is also worth noting that the exceedance of PRTR thresholds does not imply non-compliance with licensed emission limit values. Reporting is required for; • Emission to air and water (controlled & accidental) • Offsite transfer of pollutants in waste water destined for wastewater treatment • Waste transfers of hazardous & non-hazardous waste

Reporting is completed in number of categories, Sector specific PRTR pollutants, licenced pollutants and remaining PRTR pollutants. The reporting as licence pollutants meets the requirements for AER reporting electronically and the remainder is for PRTR requirements. This means that some few pollutants fall into several categories and shall be reported for each of these categories. In these instances it will mean that the same pollutant is reported in duplicate under different categories. The AER Returns Worksheet in Appendix A contains the AER Electronic and the PRTR reporting requirements for 2009. This has being submitted electronically to the EPA for validation before inclusion in the AER Report.

4. Licence Specific Reports

4.1 Toxicity Testing

Toxicity testing was undertaken in July 2009 by Enterprise Environmental on Arran’s composite effluent sample, using ISO8192 (method B) as the test method. The results showed that the effluent toxicity of the effluent sample was less than 2 Toxic Units (TU), similar to previous results and against a licence limit of 10TU. A copy of the Enterprise Environmental report is maintained on file.

4.2 Ambient Groundwater Monitoring

Bi-annual groundwater monitoring has continued since 2001 with one monitoring event completed for July 2009. The overall conclusion from the report is that the levels of organics at all boreholes have decreased substantially and confirms the efficacy of the Monitored Natural Attenuation programme (MNA). Some fluctuations can be expected due to sampling, groundwater levels due to recharge, and groundwater movements.


28

4.3 New Products and Processes In line with Section 1.4 of our IPPC licence, notifications were submitted to the Agency detailing a new product being introduced into our manufacturing range. Data on the product designated CHB, was submitted in the agreed format on 1st September 2009, with Agency approval received on 17th September 2009.

4.4 Noise Monitoring Report Summary This was completed in accordance with the methodology outlined in the EPA Noise Survey Guidance Document. The report is available on file for inspection. Noise sources at the Monksland Industrial Estate in the 2009 survey were related to traffic, with noise levels at the nearest private dwelling compliant with licence night-time limits but up on the previous year due to the new motorway that has opened during the past year. The daytime reduction in noise at this location is mainly due to lesser construction activity at another adjacent factory. No noise is evident from the Arran Chemical Company site.

4.5 Tank and Pipeline Testing Inspection Report

In relation to the requirement of the IPPC licence P0110-02, Condition 6.9, Arran has a programme of testing of bunds with a schedule for re-testing and recording any repairs. There are no underground pipes on the site apart from surface water drainage. All pipe work is over ground and can be inspected visually. Bund testing was undertaken during 2009, with minor repairs required for two bunds which subsequently passed. All test reports and survey reports are maintained on file at Arran for inspection.

4.6 Report on the assessment of the efficiency of use of raw materials in processes and the reduction in waste generated. This is a new requirement of the revised IPPC licence P0110-02. As Arran operates a multi-purpose plant, carrying out batch processes for a range of products, the nature of the product mix and overall output can vary very considerably annually, and this will relate to consumption of raw materials, solvent and energy. We propose in our on-going assessment of the efficiency of the use of raw materials to focus on particular processes, as has been done in the past with some success. The Pollution Emissions Register (PER) has been used to track solvent usage on site on an annual basis. This model will be developed to monitor raw material usage in a process, and a usable index to illustrate the ratio of raw material inputs to product output developed. The inventory management system provides a useful tool for tracking raw materials and product outputs, and this was extended further in 2009 to include an additional solvent, Isopropanol. Bearing in mind the above issues and noting the requirement for validated cleaning procedures with various solvents, seasonal fluctuations etc., it will be clear that waste streams from the plant may vary considerably, and recovery efficiencies will vary depending on actual streams. While it will be clear that not every process or solvent lends itself to efficient recovery, and account has to be taken of process change and new product introduction, we believe continued long term gains, even with individual fluctuations in one or other solvent from year to year, will best come from


29

continued focus on individual process streams. We will continue to support this work of solvent recovery with optimization of individual processes, and these will be included in the ongoing EMP. During 2009 the raw material usage of one of the main processes was tracked. This process requires the use of only one solvent. The process generates solvent–water mother liquor, which depending on the percentage water content, was matched to the subsequent batch’s solvent & water requirements. For this process in 2009, recycled solvent accounted for 54 percent of the solvent requirement by managing the water content of the mother liquors.

4.7 Report on progress made and proposals being developed to minimise

water demand and the volume of trade effluent discharge A new metering system was to be installed on site for water consumption monitoring by the water supplier, Veolia Water, since 2007. This meter was finally installed during February 2010. However the existing company water meter is still used to track and monitor water usage. Water usage has reduced in 2009 and was the lowest usage recorded since 2000, and 20% lower then the average 2006-9 water usage figures. This is due to projects such as the upgrading the cooling water distribution pipe work and recirculation of cooling water on vacuum pumps.

4.8 Review of Residual Management Plan

This is a new requirement of the IPPC licence P0110-02, Condition 10. In line with these requirements a Residuals Management Plan was submitted to the EPA for review in January 2008. Following Agency review and a query for additional information, the plan was approved in January 2009. This plan will be reviewed annually and amendments agreed with the EPA will be reported in the AER’s hereafter. No updates to the RMP have been identified at this time.

4.9 Statement of measures in relation to prevention of environmental

damage and remedial actions (Environmental Liabilities). The measures outlined in the Environmental Management Plan (EMP) and the ISO14001 procedures address the potential risks of environmental incidents. These procedures & practices include; • Air emission monitoring programme • Surface water monitoring • Emissions to sewer monitoring and control • Daily odour patrols • Groundwater monitoring programme • Waste management procedures to ensure that only permitted licensed

and competent waste brokers and facilities are used for waste disposal or recovery.

• Waste segregation to maximize potential for recovery or re-use of waste on or off-site of hazardous or non hazardous waste streams.

• Site infrastructure that provides bunding for chemical & solvent tanks and containment within storage facilities.

• The research & development expertise on site to incorporate waste minimization in all stages of the production process development and


30

from the experience gained when processing existing processes. This provides opportunities for the efficient consumption of raw materials and even the elimination of some hazardous chemicals or solvents.

• The Abnormality procedures for the investigation of incidents and near misses to determine corrective and preventive actions to prevent potential re-occurrence.

• Training & awareness programme among employees of environmental procedures and practices.

• Auditing and checking procedures

Under Condition 12.3 of the revised IPPC licence (P0110-02), Arran Chemical Company submitted an Environmental Liabilities Risk Assessment to the EPA for review & approval. This was completed in July 2008 and final approval received in January 2009. This will be reviewed every three years or to reflect any significant change on site required by the licence. This review will be updated in the 2010 AER. The Company has to date undertaken work to put in place the additional mitigation actions suggested to reduce potential environmental risk. To date the following changes have being made; • Steel cable railing was installed in 2008 on backyard racks to prevent

potential for containers falling off the racks. • Additional spill kits and signage were installed to create greater visibility

for visiting drivers & hauliers of the location of spill response materials for potential spillage in the front yard loading/unloading bund.

• Firewater retention pond was cleaned and inspected in 2008. • Fuel deliveries of diesel oil are bunded at the delivery truck tank

interconnector flange to catch spillages/leaks during deliveries. A non-return valve is fitted and operates to prevent overfilling of the diesel tank.

Appendix A: PRTR Worksheets

Sheet : Facility ID Activities AER Returns Worksheet 30/3/2010 10:11

| PRTR# : P0110 | Facility Name : Arran Chemical Company Limited | Filename : Facility.xls | Return Year : 2009 | 2963 30/03/2010 16:12

Version 1.1.10REFERENCE YEAR 2009

1. FACILITY IDENTIFICATIONParent Company Name Arran Chemical Company Limited

Facility Name Arran Chemical Company LimitedPRTR Identification Number P0110

Licence Number P0110-02

Waste or IPPC Classes of ActivityNo. class_name

5.16The use of a chemical or biological process for the production of basic pharmaceutical products.

Address 1 Units 1-3, Monksland Industrial EstateAddress 2 AthloneAddress 3 Co. RoscommonAddress 4

Country IrelandCoordinates of Location -7.98984 53.4193

River Basin District IEGBNISHNACE Code 2120

Main Economic Activity Manufacture of pharmaceutical preparationsAER Returns Contact Name Cyril Furey

AER Returns Contact Email Address [email protected] Returns Contact Position EHS Manager

AER Returns Contact Telephone Number 090-6494700AER Returns Contact Mobile Phone Number 0

AER Returns Contact Fax Number 090-6494809Production Volume 0.0

Production Volume UnitsNumber of Installations 1

Number of Operating Hours in Year 6000Number of Employees 47

User Feedback/Comments

AER Returns Worksheet

| PRTR# : P0110 | Facility Name : Arran Chemical Company Limited | Filename : P0110_2009.xls | Return Year : 2009 | Page 1 of 1

User Feedback/CommentsWeb Address www.arranchemical.ie

2. PRTR CLASS ACTIVITIESActivity Number Activity Name

4(e)Installations using a chemical or biological process for the production on an industrial scale of basic pharmaceutical products

3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002)Is it applicable? No

Have you been granted an exemption ? NoIf applicable which activity class applies (as per

Schedule 2 of the regulations) ? NoIs the reduction scheme compliance route being

used ? No


Sheet : Releases to Air AER Returns Worksheet 30/3/2010 10:13

4.1 RELEASES TO AIR | PRTR# : P0110 | Facility Name : Arran Chemical Company Limited | Filename : Releases Air.xls | Return Year : 2009 | 30/03/2010 16:138 10 18 21 29 31 6 9 6 9 6 7 9

SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS

QUANTITYVent A1 Vent A2 BE 1 BE 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/YearA (Accidental) KG/Year

F (Fugitive) KG/Year

08 Nitrogen oxides (NOx/NO2) M ISO 10849 0.0 0.0 1072.0 50.0 1122.0 0.0 0.0

07 Non-methane volatile organic compounds (NMVOC) M OTH

In-House Method ASUS711 based on NIOSH 1500 & 1003 15745.0 1897.0 0.0 0.0 17642.0 0.0 0.0

11 Sulphur oxides (SOx/SO2) M BS EN 6069 0.0 0.0 539.0 25.0 564.0 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

QUANTITYVent A1 Vent A2 BE 1 BE 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/YearA (Accidental) KG/Year


02 Carbon monoxide (CO) M ISO 12039 0.0 0.0 26.0 1.0 27.0 0.0 0.0

35 Dichloromethane (DCM) M OTH


73 Toluene M OTH


78 Xylenes M OTH


* Select a row by double-clicking on the Pollutant Name (Column B) then click the delete button

SECTION C : REMAINING POLLUTANT EMISSIONS (As required in your Licence)

QUANTITYVent A1 Vent A2

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 Emission Point 2 T (Total) KG/YearA (Accidental) KG/Year


224 TA Luft carcinogenic substances Class 1 M OTH

In-House Method ASUS711 based on NIOSH 1500 & 1003 39.0 93.0 132.0 0.0 0.0






Additional Data Requested from Landfill operators

RELEASES TO AIRMETHOD

POLLUTANT METHODMethod Used

Method Used

RELEASES TO AIRPOLLUTANT METHOD

Method Used

POLLUTANT

RELEASES TO AIR


Landfill: Arran Chemical Company Limited

Please enter summary data on the quantities of methane flared and / or utilised

additional_pollutant_no T (Total) kg/Year M/C/E Method CodeDesignation or

DescriptionFacility Total Capacity m3

per hourTotal estimated methane generation (as per

site model) 0.0 N/AMethane flared 0.0 0.0 (Total Flaring Capacity)

Methane utilised in engine/s 0.0 0.0 (Total Utilising Capacity)Net methane emission (as reported in Section A

above) 0.0 N/A

For the purposes of the National Inventory on Greenhouse Gases, landfill operators are requested to provide summary data on landfill gas (Methane) flared or utilised on their facilities to accompany the figures for total methane generated. Operators should only report their Net methane (CH4) emission to the environment under T(total) KG/yr for Section A: Sector specific PRTR pollutants above. Please complete the table below:

Method Used


Sheet : Releases to Waters AER Returns Worksheet 30/3/2010 10:16

4.2 RELEASES TO WATERS | PRTR# : P0110 | Facility Name : Arran Chemical Company Limited | Filename : Releases Water.xls | Return Year : 2009 | 30/03/2010 16:138 8 16 16 24 24 6 6 6 6 6 6

SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS Data on ambient monitoring of storm/surface water or groundwater, conducted as part of your licence requirements, should NOT be submitted under AER / PRTR Reporting as this only concerns Releases from your facility

QUANTITY

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/Year0.0 0.0 0.0 0.0


SECTION B : REMAINING PRTR POLLUTANTS

QUANTITY

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/Year0.0 0.0 0.0 0.0


SECTION C : REMAINING POLLUTANT EMISSIONS (as required in your Licence)

QUANTITY

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/Year0.0 0.0 0.0 0.0


Method Used

POLLUTANTMethod Used

POLLUTANT

POLLUTANTRELEASES TO WATERS

Method Used

RELEASES TO WATERS

RELEASES TO WATERS


Sheet : Releases to Wastewater or Sewer AER Returns Worksheet 30/3/2010 10:19

4.3 RELEASES TO WASTEWATER OR SEWER | PRTR# : P0110 | Facility Name : Arran Chemical Company Limited | Filename : Wastewate Sewer.x 30/03/2010 16:148 24 32 40 6 6 6 6 20

SECTION A : PRTR POLLUTANTS

QUANTITYSE1

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/Year55 1,1,1-trichloroethane M PER VOC's USEPA 524.2 0.19 0.19 0.0 0.056 1,1,2,2-tetrachloroethane M PER VOC's USEPA 524.2 0.19 0.19 0.0 0.034 1,2-dichloroethane (EDC) M PER VOC's USEPA 524.2 0.23 0.23 0.0 0.062 Benzene M PER VOC's USEPA 524.2 0.2 0.2 0.0 0.079 Chlorides (as Cl) M ALT APHA 4500B 1995 0.0 0.0 0.0 0.035 Dichloromethane (DCM) M PER VOC's USEPA 524.2 37.59 37.59 0.0 0.065 Ethyl benzene M PER VOC's USEPA 524.2 0.41 0.41 0.0 0.043 Hexachlorobutadiene (HCBD) M PER VOC's USEPA 524.2 0.19 0.19 0.0 0.068 Naphthalene M PER VOC's USEPA 524.2 6.76 6.76 0.0 0.007 Non-methane volatile organic compounds (NMVOC) M PER VOC's USEPA 524.2 41238.29 41238.29 0.0 0.071 Phenols (as total C) M PER HPLC 25.0 25.0 0.0 0.073 Toluene M PER VOC's USEPA 524.2 132.8 132.8 0.0 0.076 Total organic carbon (TOC) (as total C or COD/3) C ALT APHA 5220D 1995 42496.0 42496.0 0.0 0.013 Total phosphorus M OTH HMSO Standard Method 10.0 10.0 0.0 0.054 Trichlorobenzenes (TCBs)(all isomers) M PER VOC's USEPA 524.2 1.53 1.53 0.0 0.060 Vinyl chloride M PER VOC's USEPA 524.2 0.19 0.19 0.0 0.078 Xylenes M PER VOC's USEPA 524.2 2.49 2.49 0.0 0.0


SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence)

QUANTITYSE1

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/Year303 BOD M APHA 5210B 1995 67149.0 67149.0 0.0 0.0306 COD M APHA 5220D 1995 127487.0 127487.0 0.0 0.0308 Detergents (as MBAS) M APHA 5540C 1998 0.9 0.9 0.0 0.0330 Organic solvents M PER VOC's USEPA 524.2 41238.29 41238.29 0.0 0.0343 Sulphate M APHA 4500D 1995 12585.0 12585.0 0.0 0.0364 Sulphites (as SO3) M APHA 4500B 1995 575.0 575.0 0.0 0.0240 Suspended Solids M APHA 2540D 1995 2816.0 2816.0 0.0 0.0363 Total Dissolved Solids M APHA 2540C 1995 99711.0 99711.0 0.0 0.0347 Total heavy metals M EPA Method 200.8 37.0 37.0 0.0 0.0


OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER

OFFSITE TRANSFER OF POLLUTANTS DESTINED FOR WASTE-WATER TREATMENT OR SEWER

Method Used

Method Used

POLLUTANT METHOD

POLLUTANT METHOD

Page 1 of 1Page 1 of 1

Sheet : Releases to Land AER Returns Worksheet 30/3/2010 10:21

4.4 RELEASES TO LAND | PRTR# : P0110 | Facility Name : Arran Chemical Company Limited | Filename : Releases Land.xls | Return Year : 2009 | 30/03/2010 16:138 8 16 16 6 6 6 6

SECTION A : PRTR POLLUTANTS

QUANTITY

No. Annex II Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year0.0 0.0 0.0


SECTION B : REMAINING POLLUTANT EMISSIONS (as required in your Licence)

QUANTITY

Pollutant No. Name M/C/E Method Code Designation or Description Emission Point 1 T (Total) KG/Year A (Accidental) KG/Year0.0 0.0 0.0



RELEASES TO LAND

RELEASES TO LAND


| PRTR# : P0110 | Facility Name : Arran Chemical Company Limited | Filename : P0110_2009.xls | Return Year : 2009 | Page 1 of 1| PRTR# : P0110 | Facility Name : Arran Chemical Company Limited | Filename : P0110_2009.xls | Return Year : 2009 | Page 1 of 1

Sheet : Treatment Transfers of Waste AER Returns Worksheet 30/3/2010 12:41

5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE | PRTR# : P0110 | Facility Name : Arran Chemical Company Limited | Filename : Treatment.xls | Return Year : 2009 | 30/03/2010 16:145 30 28

Quantity (Tonnes per

Year)

Haz Waste : Name and Licence/Permit No of Next Destination Facility Non Haz Waste:

Name and Licence/Permit No of Recover/Disposer

Haz Waste : Address of Next Destination Facility

Non Haz Waste: Address of Recover/Disposer

Name and License / Permit No. and Address of Final Recoverer / Disposer

(HAZARDOUS WASTE ONLY)

Actual Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)

Transfer DestinationEuropean 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 12.25 Various Non-halogenated solvents R2 M Volume Calculation Offsite in IrelandSoltec (Ireland) Ltd.,WO-115-01

Zone A,Mullingar Business Park,Mullingar,Co Westmeath,Ireland

Soltec (Ireland) Ltd,WO-115-01,Zone A,Mullingar Business Park,Mullingar,Co Westmeath,Ireland


To Other Countries 15 02 02 Yes 1.1 Charcoal with DCM D10 M Weighed AbroadSoltec (Ireland) Ltd.,WO-115-01


ATM BV,821780,Vlasweg 12,4782 PW Moerdijk,P.O. Box 30,4780 AA Moerdijk,Netherlands

Vlasweg 12,4782 PW Moerdijk,P.O. Box 30,4780 AA Moerdijk,Netherlands

Within the Country 15 01 10 Yes 2.4 Empty steel drums R4 C Weighed Offsite in IrelandSoltec (Ireland) Ltd.,WO-115-01


Soltec (Ireland) Ltd,WO-115-01,Zone A,Mullingar Business Park,Mullingar,Co Westmeath,Ireland


Within the Country 15 01 10 Yes 32.0 Empty steel drums R4 C Weighed Offsite in IrelandRilta Environmental Services Ltd,WO-192-01

Lower Oriel St.,North Wall,Dublin 1,.,Ireland

Rilta Environmental Services,WO-192-02,Lower Oriel St.,North Wall,Dublin 1,.,Ireland

Block 402,Greenogue Business Park,Rathcoole,Co. Dublin,Ireland

Within the Country 15 01 10 Yes 9.5 Empty plastic drums R4 C Weighed Offsite in IrelandRilta Environmental Services Ltd,WO-192-01




Within the Country 15 01 04 No 16.5 Empty steel drums R4 C Weighed Offsite in IrelandHammond Lane Metal Company,WP-1

Blyr Industrial Estate,Athlone,Co Westmeath,.,Ireland

To Other Countries 07 05 03 Yes 4.7 Halogenated mixed solvents R2 M Weighed AbroadRilta Environmental Services Ltd,WO-192-01


ATM BV,821780,Vlasweg 12,4782 PW Moerdijk,P.O. Box 30,4780 AA Moerdijk,Netherlands

Vlasweg 12,4782 PW Moerdijk,P.O. Box 30,4780 AA Moerdijk,Netherlands

Within the Country 07 07 01 Yes 38.0 Aqueous wash & rinse liquids D8 M Volume Calculation Offsite in IrelandRilta Environmental Services Ltd,WO-192-01




Veolia Environmental

Veolia Environmental Services Technical Solution Ltd W0050-

Method Used

Within the Country 07 05 01 Yes 44.7 Aqueous non halogenated mixed solvents R1 M Weighed Offsite in Ireland

Veolia Environmental Services Technical Solution Ltd,W0050-02 Corrin,Fermoy,Cork,.,Ireland

Ltd,W0050-02,Corrin,Fermoy,Cork,.,Ireland Corrin,Fermoy,Cork,.,Ireland

To Other Countries 07 05 03 Yes 107.9 Halogenated mixed solvents D10 M Weighed Abroad Indaver Ireland,W0036-014 Haddington Terrance,Dun Laoghaire,Dublin,.,Ireland

AVG Abfall-Verwertungs-Gesellschaft mbh,E2310/33/98,Borsigstrasse 2,D-22113,Hamburg,.,Germany

Borsigstrasse 2,D-22113,Hamburg,.,Germany

Within the Country 07 07 01 Yes 22.0 Aqueous wash & rinse liquids D9 M Volume Calculation Offsite in IrelandENVA Ireland LTD,W0041-01

Smithstown Industrial Estate,Shannon,Clare,.,Ireland

ENVA Ireland LTD,W0041-01,Smithstown Industrial Estate,Shannon,Clare,.,Ireland

Smithstown Industrial Estate,Shannon,Clare,.,Ireland

To Other Countries 07 05 04 Yes 337.4 Non Halogenated Mixed Solvents D10 M Weighed Abroad

SAVA Sonderabfall Verbrenmungsaniagen GmbH,A51G00508

Osterweute 1,25541 Brunsbuttel,Germany,.,Germany

SAVA Sonderabfall Verbrenmungsaniagen GmbH,A51G00508,Osterweute 1,25541-Brungsbuttel,Germany,.,Germany

Osterweute 1,25541-Brungsbuttel,Germany,.,Germany

To Other Countries 07 05 08 Yes 45.3 Reaction Residues D10 M Weighed Abroad






Sheet : Treatment Transfers of Waste AER Returns Worksheet 30/3/2010 12:41

Quantity (Tonnes per

Year)

Haz Waste : Name and Licence/Permit No of Next Destination Facility Non Haz Waste:

Name and Licence/Permit No of Recover/Disposer

Haz Waste : Address of Next Destination Facility

Non Haz Waste: Address of Recover/Disposer

Name and License / Permit No. and Address of Final Recoverer / Disposer

(HAZARDOUS WASTE ONLY)

Actual Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)

Transfer DestinationEuropean 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)

Method Used

To Other Countries 15 02 02 Yes 6.8 Absorbants & Filters D10 M Weighed Abroad





To Other Countries 15 01 10 Yes 14.6 Packaging D10 M Weighed Abroad





To Other Countries 07 05 04 Yes 89.19 THF R2 M Weighed Abroad SRM Ltd,AG8128

Hayhole Rd,North Shields,NE296DY,.,United Kingdom

SRM Ltd,AG8128,Hayhole Rd,North Shields,NE296DY,.,United Kingdom


To Other Countries 07 05 04 Yes 42.36 Industrial Methylated Spirits R2 M Weighed Abroad SRM Ltd,AG8128


SRM Ltd,AG8128,Hayhole Rd,North Shields,NE296DY,.,United Kingdom


Within the Country 20 01 01 No 10.81 Paper & Cardboard R3 M Weighed Offsite in Ireland CWR Ltd,WR/03-02Claregalway,Galway,.,.,Ireland

Within the Country 20 01 39 No 0.26 Plastics R3 M Weighed Offsite in Ireland CWR Ltd,WR/03-02Claregalway,Galway,.,.,Ireland

Within the Country 20 01 99 No 0.14 Tetrapak R3 M Weighed Offsite in Ireland CWR Ltd,WR/03-02Claregalway,Galway,.,.,Ireland

Within the Country 15 01 03 No 31.94 Timber Pallets R3 M Weighed Offsite in IrelandConnaught Timber Products Ltd,WR/01

Tynagh,Loughrea,Galway,.,Ireland

Within the Country 17 02 01 No 4.02 Timber Waste R3 M Weighed Offsite in IrelandAES (Ireland Ltd),WP-01-2001

The Cottage,Tipper Rd,Naas,Kildare,Ireland

Within the Country 20 01 02 No 0.45 Glass R5 M Weighed Offsite in IrelandAES (Ireland Ltd),WP-01-2001


Within the Country 20 03 01 No 21.32 Mixed Municipal Waste D1 M Weighed Offsite in IrelandAES (Ireland Ltd),WP-01-2001


SafetyKleen Ireland Ltd W99-Unit 5,Airton Road Tallaght Dublin

SRM Ltd,TP33345F,Weeland Road,Knottingly ,West Yorkshire WF11 8DZ United

Weeland Road,Knottingly West Yorkshire WF11

To Other Countries 13 02 08 Yes 0.941 Waste Oils R9 M Volume Calculation AbroadSafetyKleen Ireland Ltd,W99-1

Road,Tallaght,Dublin 24,Ireland

Yorkshire,WF11 8DZ,United Kingdom

,West Yorkshire,WF11 8DZ,United Kingdom

* Select a row by double-clicking the Description of Waste then click the delete button


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