co. ireland. · cs2, tank farm 1600 (tf1600), part of tf600 and other significant areas within the...

@& TEMMLER IRELAND

POS13-01 Your Ref:

Ms Noeleen Keavey IPPCL Section Environmental Protection Agency, PO Box 3000, Johnstown Castle Estate, CO Wexford.

Temmler Ireland Ltd., Killorglin, Co. Kerry, Ireland.

13.02.2007

Subject: Outstanding Additional Information for Temmler Ireland Ltd

Dear Ms Keavey,

Enclosed please find outstanding information with regard to application for an

IPPCL as indicated in my correspondence on 1 gfh Dec 2006 and as subsequently

requested by the Office of Licensing & Guidance on 1 7th Jan 2007.

The following sections are enclosed (3 copies in hardcopy format, and two copies

of all files in electronic searchable PDF format on CD-ROM)

0

0

Attachment A. 1 : Non-Technical Summary

Attachment B. 1 - Company Certificate of Incorporation

Attachment C. Organisation Chart

Attachment E.l .A Emissions to Air

0

0

0 Attachment L. Statutory Requirements

Attachment I. 1. Assessment of Atmospheric Emissions

Section I. 1. Application Form

If you have any queries or require any further clarification on the enclosed then do

not hesitate to contact me.

Environment & Utilities Manager.

Incorporated in Ireland under Registration No. 431179 Registered office: 6h Floor, Southbank House, Banow Street, Dublin 4 - Directors: Hans Joachim Ricken, Dr. Wemer Sdmeider

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February 2007 Issue No 2 461 71 701

Attachment A.l Non Tech Summary.doc

Attachment

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Temmler lreland Limited IPPCL Application Attachment No . A . l

Page No

1 . 1.1.

2 . 2.1. 2.2. 2.3. 2.4.

3 . 3.1. 3.2. 3.3. 3.4.

4 . 4.1. 4.2. 4.3.

5 .

6 . 6.1. 6.2.

7 .

8 .

9 .

10 .

INTRODUCTION .............................................................................................................. 3

History of the Site ...................................... ................................ 4

FACILITY OPERATIONS ................................................................................................ 5

.................................................... 6 Products ............................. ............................................

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

Class 12.2.2 Activities .......................

EMiSSIONS TO ATMOSPHERE ..................................................................................... 8

Point Source Emissions .... ..............................................

Control & Abatement Tech ...................................... Fugitive Emissions ............ ................................................... 9

Assessment of Impact of A ................................................ IO

EMISSIONS TO SURFACE WATER ............................................................................. 10

Non Process Water ........................................................................................................ I O Process Water ................................................................................................................ 10 Assessment of Impact of Emissions to Surface Waters ................................................ 12

EMISSIONS TO GROUND ............................................................................................ 12

SITE CONDITION .......................................................................................................... 12

Environmental Setting .................................................................................................... 12 Current Groundwater Monitoring .................................................................................... 13

NOISE EMISSIONS ....................................................................................................... 15

WASTE ~ANAGEMENT ................................................................................................ 15

SAMPLING AND ~ONITORING .................................................................................... 15

ENERGY EFFICIENCY .................................................................................................. 15

11 . CONTAINMENT OF ACCIDENTAL SPILLAGES ......................................................... 16

12. EMERGENCY RESPONSE ........................................................................................... 17

Attachment A.l Non Tech Summary.doc Page 2

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Temmler Ireland Limited lPPCL Application Attachment No. A. l

Section Page No

13. APPLICATION OF BEST AVAILABLE TECHNIQUES AT TEMMLER IRELAND LIMITED ........................................................................................................ 18

14. DECOMMISSIONING .................................................................................................... 18


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Temmler Ireland Limited lPPCL Application Attachment No. A . l

1.

This Integrated Pollution Prevention & Control (IPPC) licence application is for Temmler Ireland Limited. The site in Killorglin was formerly a branch of Astellas Deutschland GmbH and was commonly known as and traded as Klinge Pharma & Co. However, in January 2007 the site was sold and is now known as Temmler Ireland Limited. The IPPC licence for which this application is made replaces an existing licence, Licence Register No. PO01 8-01 for Klinge Pharma & Co.

The site is a 9.29 hectares industrial site located on the N70 approximately 1 km east of Killorglin town centre in Co. Kerry. The site operates on a 24-hour, 3-cycle shift, 5 days per week basis, with occasional weekend work determined by production demands. Surrounding land use in the vicinity of the site is a combination of industrial, amenity, residential and agricultural with neighbouring land use as follows:

North:

West:

South:

East:

A Site Location Map is presented in Attachment No B.2 (Drawing Reference 106101- 01) of Attachment B and a Site Layout Plan is presented in Appendix No. D-2 {Drawing Reference 106101-02) of Attachment D.

River Laune and Agricultural Land

Industrial (Astellas Ireland Company Ltd - AICL) & Killorglin Town

Agricultural Land and residential housing along the N70

Agricultural Land and residential housing

Production facilities on the site have not changed since the original application to the EPA for an IPC licence in 1995. However API production ceased in December 2006 and decommissioning has recently commenced. This has resulted in the closure of CS1 and CS2, Tank Farm 1600 (TF1600), part of TF600 and other significant areas within the site. It is the first decommissioning project of this magnitude to be undertaken by Temmler Ireland Limited and as a result, a dedicated project in the Environmental Management Programme (EMP) is in place to ensure that all environmental aspects of the decommissioning are considered. Appendix D-1 of Attachment D contains a proposal from an engineering firm to decommission all API facilities on site. which Temmler Ireland Limited have accepted. Following API decommissioning, the two remaining production groupings and the subject of this licence application will be:

a) Pellet Production and

b) Pellet Ingredients

The key site facilities are:

* QC Labs, Administration and Canteen

Warehouses

* Production Plants

* Drum Store

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Temmler Ireland Limited IPPCL Application Attachment No. A.l

Year

0 Engineering Workshop and Stores

Developments

0 Environmental Health and Safety Offices and Laboratory

1972

1974

1975

* TankFarms

Foundation of Klinge Pharma in Killorglin, primarily to manufacture bulk active ingredients and pharmaceutical formulations to supply parent Company and Licencees.

Production facilities for extraction of Worsechestnuts and isolation of Escin were constructed.

Extension of Warehousing facilities and utilities. Commencement of production of sustained release pellets.

* Wastewater treatment plant

* Utilities buildings

The purpose of this IPPC licence application is to:

* Replace the existing IPC licence with a new licence that should reflect the requirements of the IPPC Directive and related Irish legislation; and

* Reflect changes on the site that have arisen since the date of granting of the current IPC licence.

The Class of Activity, as defined in Schedule 1 to the Protection of the Environment Act, 2004, applicable to Temmler Ireland Limited for this application is:

* Class 12.2.2: The manufacture or use of coating materials in processes with a capacity to make or use at least 10 tonnes per year of organic solvents.

Temmler Ireland Limited then Klinge Pharma was originally licensed under Class 5.6 in 1995. However, with the closure of the API facility at the end of 2006 Class 5.6 or its current equivalent 5.1 6 is not considered relevant.

1.1. History of the Site

Prior to the construction of the Klinge Pharma Facility in 1972, an old carpet factory was located on site along with a number of trees, grassland, bramble, gorse and other types of wild vegetation. Parts of the site would have been utilised for agricultural purposes.

The site was bounded to the north by the river Laune and agricultural land, to the west by a mix of one off housing and undeveloped agricultural land, to the south and east by agricultural land and residential housing.

Construction works on site began in the early 1970's and the plant began production in 1972 with the manufacture of Kavain. The following is a summary of the significant changes that took place to the physical layout of the site since then:

Attachment A.l Non Tech Surnmary.doc Page 4

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2.

Year

1976

1980

1984

1986

1988

1989

1990

1992

1992- 7 997

1998- 1999

2000

2003

2007

Temmler lreland Limited IPPCL Application Attachment No. A. 1

Developments

Production start-up of Horsechestnut Pellets. I -

Multipurpose Chemical Synthesis facilities completed.

Extension of pellet production unit for manufacture of sustained release pellets: Theophylline. Pentoxifylline.

Upgrade of Chemical Synthesis plants for new chemical products Fcbuprol. Tamoxifen Citrate, Dipivefrine.

Modern Engineering Workshop constructed.

Establishment of Klinge Pharma Sales and Marketing for Irish market.

Purchase of additional 200,000m2 of land at plant in Killorglin

Decision by Fujisawa to locate Prograf facility in Killorglin.

Omnina of new QC laboratorv and new Canteen.

Construction of new Pellet Plant, Modernisation of Chemical Production plant. Extension of Utility and Environmental services. ~-

Pellet production completely transferred to new pellet facility.

Integrated Pollution Control licence issued.

Begin Production Transfer of chemical products from Fujisawa Japan, Zotepine successfully transferred.

Upgrade of Extraction Plant. building 3

Construction of New Chemical Synthesis Pilot Plant CS3.

Beginning of manufacture of pre-clinical and clinical samples for Fujisawa Japan

Sale of the facility to Temmler Ireland Limited.

In 1988, part of the existing site was used by Fujisawa, Japan (Klinge Pharma Parent Company - now known as Astellas Pharma Inc.) to construct another manufacturing facility - Astellas Ireland Company Ltd. (AICL). This facility was constructed in the eastern area of the site. Although both companies were owned by Astellas Pharma, both facilities acted as separate companies with separate management structures and separate workforce. With the sale of Klinge Pharma to Ternmler Ireland Limited it means certain services previously shared by Klinge Pharma and AICL including wastewater treatment, emergency services and emergency generators will continue to be shared. It should be noted that all of these services are owned and maintained by Ternmler Ireland Limited.

FACl LlTY 0 PE RATIO

2.1. Products

The products produced on site in Pellet Production and Pellet Ingredients are:

@ Horsechestnut Extract

0 Diclofenac Sodium Pellets

Theophylline Pellets

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Horsechestnut Extract Pellets

Ethanol

Eudragit L30 D55

* Pentoxifyilline Pellets

Ethyl Cellulose 2OCPS Eudragit L100-55

Eudragit RL100 Eudragit RS1 00

e Nilvadipine Pellets

Horsechestnut Extract

Isopropyl alcohol

0 Omeprazole Pellets

Horsechestnuts Hydroxypropylcellulose (Klucel

EF)

Kollidon 25 Kollidon VA64


Magnesium Carbonate, heavy

The raw materials needed to produce these products are:

I Acetone I Aerosil 200 I Antifoam

Maize Starch

I Avicel PHI01 I Avicel PHI05 1 Croscarmellose Sodium I

Saccharose

Sugar Spheres

Titanium Dioxide -_....__........-.".I___

1 Dextrine

Sodium hydroxide. pearl Sodium Laurylsulphate (Texapon K 12)

Talcum Theophylline

" .___I.I,_____._...._......l.l_._l .... "..__."___________.__._."

I Deionised Water

Cortrol fS3000E Dianodic DN2471

I Diclofenac Sodium

Optisperse PO5090

Inhibitor AZ8104

Sodium Hypochlorite, 14-1 6%

Spectrus BD1500 Spectrus OX1 201

Bactericidal Hydroclean Traywash detergent

Sulphuric Acid 1.4

Foamtech

Gas Oil (35sec)

Microtalc

Hydrated Lime Zetag 7875

Nutrient (Purisol)

Lubricating oils Engine Oils

Light Fuel Oil (200sec)

I Nilvadipine I Omeprazole 1 Palatinol C (Dibutylphthalate) I I Pentoxifyilline I Polyethyleneglycol 6000 1 Propyleneglycol I

2.3. Auxiliary

1 Chematic 901 1 Ethylene Glycol 1 Sodium Hydroxide. 25% 1 ~~ I Hydrochloric Acid, 36% I G r a z r Salt I Ferric Sulphate

Attachment A.1 Non Tech Summary.doc Page 5

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Atomix 1x950 Liquid Nitrogen Carbon

Compressed Gases: Acetylene. Argon, Hydrogen, Helium. Air, Oxygen, Nitrogen

Cosa Foam 40

Cosa CIP 92

2.4. Class 12.2.2 Activities

Cosa DES Cosa Pur 85

Cosa CIP 72 Nitric Acid 20-70%

Temmler Ireland Limited is a pharmaceutical facility engaged in the manufacture of a wide range of products for the treatment of diseases. The main activities are conducted in three buildings on site Pelletising Plant 1 (Building 7) and Pelletising Plant 2 (Building 19) and Extraction/Spraydrying (Building 3). Drawing Reference 106101-02 in Appendix 0-2 of Attachment No. D outlines the locations of all buildings on site.

Building 19 - Pelletising Plant 2: is the new pelletising plant used for the production of pharmaceutical pellets from powder, which are sold in bulk form. All products manufactured in the plant are multi-dose form non-sterile products suitable for oral administration. The manufacturing process briefly consists of dispensing of solid raw materials; granulation using solvent: drying to remove the solvent; sieving; milling and coating of selected pellets with a solvent or aqueous based lacquer medium. All products manufactured in the plant are produced in a similar manner.

Building 19 also has its own warehouse which is located in the west end of the building. The main entrance, staircase, offices and staff welfare and changing facilities are located at the eastern end of the building together with MCC Switch Room, Instrument Rack Room and Extract Rooms. Chiller, HVAC and Solvent Recovery Plant rooms are located on the first floor, mainly over the production areas.

Building 3 - Extractionlspraydrying is the main activity of the Pellet Ingredients department. A spray-dried extract of the horsechestnut seed is produced in the plant. The manufacturing process consists of milling, solid-liquid extraction using aqueous ethanol, evaporation and spraydrying. Some of the spray-dried extract is used in Pellet production while more is sold direct in powder form to customers.

Building 7 - Pelletising Plant 1 , located in the northern part of the site is the older pelletising plant used for pellet production. This process is essentially the same as in building 19, but on a much smaller scale. Building 7 is also used by Pellet Ingredients department. Milling of raw material for subsequent use in Pellet Production is carried out here. Other activities include belt separation, blending and packing of finished pellets. There is a QC laboratory upstairs in building 7 which is used to test pellets.

Monitoring and control of the manufacturing processes is achieved though the use of instrumentation which measure and control, for example, pressures. temperatures, levels, flows, agitator speeds and various analytical properties, as required by the individual processes. Process instrument and motive equipment data is fed to centralised control systems that are monitored 24 hours per day.

A.ttachrnmt A.1 Non Tech Summary.doc Pagg 7

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-..... . . .~. ...... ....

Emission Ref. No.

Temmler Ireland Limited IPPCL Application Attachment No. A. l

3. ISSIOMS TO AT

L Oescription

Area (priority pollutant) Grid Reference

3.1. Point Source Emissions

Building 2. Boiler

A summary list of main emissions points to atmosphere is provided in Table A.l.

Exhaust Fumes from Boiler 8-501 E078637

Table A. l - Details of Main Emission Points.

r’-’ /House NO971 04

Building 2, Boiler House r2 Exhaust Fumes from Boiler 8-502 E078635

NO97101

A1 -3

A2-1

Building 2, Boiler Exhaust Fumes from Boiler 8-503 E078641 House NO97112

Building 19, Pellet Exhaust from central vacuum system E078596

NO9701 9 Plant (dust)

A2-2

A2-3

A2-4

Building 7 No exhaust at present however may be E078659 used in future /~097156

Building 19. Pellet Exhaust from point extract system E078598 Plant (dust)

NO9701 8

Building 3, Chemical Currently exhausts via A2-4. Will be E07861 1

NO97075 Synthesis 1 decommissioned when API is

decommissioned. However, the point is to be retained in case of future use of the building.

Building 8, Chemical Process Vent - this point will be E078587 Synthesis 2 decommissioned when API is NO97062

decommissioned. However. the point is to be retained in case of future use of

There are many minor emissions to atmosphere, broadly categorised as follows:

B Generator Exhausts:

r Process Vents:

Laboratory emissions. ?-

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Temmler Ireland Limited lPPCL Application Attachment No. A.l

The minor emissions are considered to have emissions to atmosphere of pollutants significantly less than those of the main emissions and are not environmentally significant.

A2-2 Building 19

A2-5 Building 7

3.2. Fugitive €missions

Reverse Jet Filter

Cartridge Filter

Fugitive emissions are largely generated in the following operations on the site:

HVACs across the site

Bulk storage tank filling;

Filter

Building ventilation (not otherwise classified as a minor emission)

Temmler Ireland Limited annually completes a Pollution Emission Register (PER), which includes the estimation of fugitive emissions of certain priority substances. The PER is contained in the Annual Environmental Report.

Council Directive 1999/13/EC on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations does not apply to this facility as Temmler Ireland Limited does not finish the product on site in SO far as the product does not leave the site ready for placement on the shelf and solvent consumption on site is less than 50 tonnes per annum. Therefore, Temmler lreland Limited is not a Scheduled Activity under the Council Directive 1999/13/EC as enforced through the Emissions of Volatile Organic Compounds from Organic Solvents Regulations 2002 (S.I. No. 543 of 2002).

3.3. Control & Abatement Technology

The following abatement techniques are applied at Temmler Ireland Limited:

The above abatement unit operations are on a preventative maintenance programme.

Temmler Ireland Limited emissions to air abatement systems are listed 3AT technologies for the activities carried out on the following basis:

Attachment A. 1 Non Tech Summary.doc Page 9

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1. The technology used is noted as BAT technology in relevant BAT guidance (European BAT Reference Document for the Organic Fine Chemicals Sector, August 2006);

2. The site achieves a very high degree of compliance with emission limit values set out in EPA licences.

3.4. Assessment of Impact of Atmospheric Emissions

Temmler Ireland Limited conducted an Air Dispersion Modelling Assessment of Boiler and Generator Emissions in January 2007. The resultant report forms Attachment 1.1. In summary, the results of the modelling exercise indicates that emissions of main polluting substances (Sulphur Dioxide, Nitrogen Oxides and Carbon Monoxide) are unlikely to have a significant impact on the environment.

4. ISSIONS TO SURFACE WATER

There are two types of surface water emissions from the site: Non- process water (i.e. storm water drainage) and treated effluent from the Waste Water Treatment Plant (WWTP). These surface water emissions combine before discharge to the nearby River Laune.

4.1. Non Process Water

Uncontaminated storm water is discharged from the Temmler Ireland Limited site and the AlCL site to the nearby River Laune from one surface discharge point. IPC Licence reference ‘Surface Water. Outfall’. The new IPPC Licence reference for this point will be sw2 .

The emissions to surface water are monitored according to Schedule 5 (i) of the IPC licence. Prior to discharge to the river, the storm water is continuously analysed with a T.0.C monitor. It can be diverted in the event of a contamination incident to the firewater retention lagoon, from where it can be assessed and treated in the WWTP if necessary.

4.2. Process Water

Low strength aqueous process effluent, which can be biologically treated, is generated on site from tank wash down, equipment cleaning, production wastes and domestic sewage.

Full details of emissions from each process are contained in Section D, Infrastructure and Operation, of the main IPPCL application. The main pollutants in the process effluent are:

e Trace organic solvents

9) Dissolved and suspended solids derived from production

Inorganic acids and bases.

Attachment A.l Non Tech Sumrnary.doc Page 10

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Temmler Ireland Limited lPPCL Application Attachment No. A . l

There are two wastewater streams that discharge to the WWTP. The main process (or ’Industrial’) effluent line is a combination of three process effluent streams as follows:

0 Process effluent from the Temmler Ireland Limited pellet production and pellet ingredients and site domestic effluent;

0 Process effluent from the Temmler Ireland Limited API manufacturing process. This will cease once the API facility has been decommissioned;

e Process and domestic effluent from the neighbouring AlCL facility.

The second main line is what is called “E line” effluent from the neighboring AlCL facility. This effluent has a dedicated drainage system that first drains to a batch pH adjustment facility in order to destroy all traces of active ingredients in this effluent. The pH adjustment facility is located adjacent to the main WWTP and consists of two small vessels working on a ‘fill and draw’ basis. Each batch of E line effluent is held for one hour to ensure completed treatment. The treated effluent from the pH adjustment facility then discharges to the balancing tanks of the main WWTP where it combines with the aforementioned industrial and domestic effluent.

Going forward. Temmler Ireland Limited will maintain control over the WWTP and will work with AlCL to ensure that the quality of the effluent received from AlCL will not result in an adverse impact on the WWTP.

This process effluent is treated in an aerobic biological treatment plant before being discharged to the River Laune from one discharge point, IPC Licence reference ’Wl’. The new IPPC Licence reference for this point will be SW1.

All wastewater is collected in one of two balance tanks for equalisation and conditioning prior to discharge to the biological treatment system. The tanks operate on a “flip-flop” basis. While one tank is filling the other is being pumped to the biological treatment system. The total capacity of each tank is 500m3. A minimum retention time of two days is available. Conditioning includes mixing, pH adjustment with acid or causticilime, nutrient addition if required, foam control as required and seeding for bacteria acclimatisation. The conditioned effluent is pumped at a controlled rate to the activated sludge section.

The activated sludge section consists of four aeration tanks and two clarifiers. The capacity of each aeration tank is 365 m3, and each clarifier is 60 m3. Forward feed from the conditioned effluent can be treated in an inter-stage and a final stage if the plant is operated in series. Alternatively the plant can be operated in parallel.

Ferric sulphate is dosed into the outflow from the aeration tanks and this improves sludge settlement and reduces suspended solids in the final effluent. The plant is licenced for a maximum throughput of 290 m’iday.

Excess activated sludge is ‘wasted’ to a 100 m3 tank from where it is dewatered through a belt press. Dewatered sludge produced in the WWTP is composted on-site in a composting tunnel. It is sent off-site for reuse or disposal by an approved contractor.

The emissions to surface water from the WWTP are monitored according to Schedule 2 (ii) of the IPC licence.


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Temmler Ireland Limited IPPCL Application Attachment No. A.l

The treatment plant is considered BAT technology, and especially as it is also a central treatment facility for all process effluents.

Made Ground: Clayey, sandy gravel fill

Drift Deposits: Mainly sands and gravels

Drift Deposits: Silts and clays

Bedrock: Limestone bedrock ..............................................

4.3. Assessment of Impact of Emissions to Surface Waters

0.15- 1.4

0.15 - 9.75

7.0 - 15.0

7.5 + .-___l__ll__.___._...

The treated wastewater from the on-site biological wastewater treatment plant has a very low toxicity (based on testing with species agreed with the Agency). Furthermore, water results at Cloon Island (approx. 150m downstream of the site outfall) for a variety of parameters are within available Statutory Requirements based on the Salmonid Regulations and Phosphorus Regulations. Therefore, the treated effluent discharging from Temmler Ireland Limited is unlikely to be having any significant impact on receiving waters.

5. S TO GROUND

There are no intended emissions to ground from the Temmler Ireland Limited facility. The company is monitoring site groundwater in accordance with IPC licence requirements (refer to Section 6 for more detail).

6.

6.1. Environmental Setting

The topographic elevation of the site is approximately 20 metres above Ordnance Datum. The topography of the surrounding area slopes down towards the River Laune to the north west of the plant.

A summary of the geological conditions on site is given in the table below.

Surface water drainage from the site is reported to flow to the West and North towards the River Laune.

Information from the EPA interactive water quality map indicates that the quality of the River Laune upstream of the town of Killorglin is unpolluted. However the water quality changes to slightly polluted around the town of Killorglin. This is upstream of the Temmler Ireland Limited plant.

-

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6.2. Current Groundwater

Klinge Pharma had operated a groundwater monitoring programme at the site since 1996, as required by their IPC licence. Groundwater has been sampled biannually from six monitoring wells (MW2 to MW7) and from the firewater well (On Site Well 1 or OSWl) at the site (see Drawing Reference. 106101-03 contained in Appendix E . l . l ) . MW1 was dry and was not installed as a well.

MW2 to MW? are located to the northwest of the plant between the main production areas and the River Laune and were interpreted as being down hydraulic gradient from the Temmler Ireland Limited Plant. The wells were surveyed to a common datum (Irish Ordnance Datum) for the first time in 2005 by URS Ireland Ltd (URS) and water levels confirmed these wells to be downgradient of the plant.

The most significant issue detected in these early wells was the presence of elevated monochlorobenzene in MW2 and MW3 which was interpreted as being related either to issues relating to known leaks (repaired) from the site effluent drains close to MW3 or, deriving from contaminated soil found below the floor slab of Area 315 in production building CS1 during reconstruction work in 1990.

In early 2006 URS were requested by Klinge Pharma to carry out additional investigative works within the production areas and the chemical/fuel storage areas as part of a vendor due diligence programme due to the planned divestment of the Killorglin site from the Astellas Pharma group.

Wells MW8 to MW13 were drilled under the supervision of URS close to current or former chemical and fuel storage areas and current or former underground tanks in mid- February 2006. These wells unexpectedly indicated groundwater flow to the east or southeast in the central part of the site and detected elevated chloroform and trichloroethene concentrations in well MW1 I , close to the administration building.

The drilling of a planned well in the roadway between production buildings CS1 and CS2 had to be abandoned in February 2006 after several attempts, due to the density of buried services between the two buildings.

Following a meeting with the EPA in May 2006 to discuss these findings, a further phase of groundwater investigation was carried out in late July 2006. Well MW14 was drilled in the roadway next to CS1, and wells MW 15 to MW17 were drilled along the eastern and southern boundaries of the site to investigate potential contaminant migration in these directions.

The new wells along the eastern and southern boundaries of the site (MW15, MW16 and MW17) show no evidence of chlorinated solvent contamination or groundwater migration from the site in an easterly direction.

The seven trial pits dug in the previously uninvestigated green area in the west of the site show generally gravelly subsoils in this area, with no evidence of undocumented waste disposal or other signs of contamination encountered.

The additional wells have largefy delineated an apparently linear zone of low water levels running in a NNW-SSE direction beneath the main production areas of the site. This zone

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of low water levels coincides with a change in elevation of the bedrock and is inferred to represent a possible structural feature in the bedrock, (possibly a fracture zone or a karstic conduit), which is essentially acting as a drain through the middle of the site.

The water table at well MW14 appears anomalous in this area: at 3.06 m aOD. Well MW14 is screened against low permeability silt just above limestone bedrock and may represent a localised perched aquifer.

Groundwater levels are higher (3-4 m aOD) to the west of the production areas and groundwater in this area appears to flow towards the river. The wells along the east of the site also show higher water levels than beneath the central part of the site. -

The detection of elevated chloroform in MW14 indicates that this is the source area for chlorinated organic solvent contamination (chloroform, trichloroethene), as it is where these solvents were formerly stored and used (mid 1970s to mid/late 1980s). Chlorobenzene was used in CS2 (late 1980’s to 2006).

MW18 to MW22 were installed in September 2006 near the CSI building and in the eastern visitors carpark and MW23 was installed to the north of the Pelletising Plant in October 2006 under the supervision of URS.

The additional wells have proven bedrock elevations along the eastern side of the site and have clearly shown the limestone bedrock to be karstified, which has important implications for groundwater flow and contaminant movement within the bedrock. The karstified limestone is considered the main groundwater flow zone at the site.

The additional wells have delineated a linear zone of low groundwater levels running in a NE-SW direction beneath the main production areas of the site.

This zone of low water levels coincides with a change in elevation of the bedrock and with highly fractured, productive water-bearing limestone bedrock. The change in permeability and water level in this area is inferred to reflect a structural feature in the bedrock (most likely a karstified fracture zone), which is essentially draining from the middle of the site in a northeasterly direction.

Downgradient wells in the fracture zone (MW23, OSW2) have detected trace concentrations of chlorinated solvent contamination (below EPA Guidelines and Irish Drinking Water Standards) and this suggests that the contamination is diluted and dispersed within the bedrock fracture zone to trace concentrations within the site.

There is no long-term groundwater monitoring data available for the production area wells to assess temporal trends in contaminant concentrations at the site.

The wells along the eastern and southern boundaries of the site (MW15, MW16, MW17, MW22) show no evidence of chlorinated solvent contamination or groundwater migration from the site in an easterly or southerly direction.


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Temmler lreland Limited lPPCL Application Attachment No. A.l

7.

There are a number of noise sources on the site that Temmler Ireland Limited are required to monitor annually as per Schedule 4 of the licence. Since the granting of their IPC Licence Temmler Ireland Limited have increased the number of noise sources that they monitor annually. Temmler Ireland Limited also monitor noise at a number of sensitive receptors. According to the latest ANV Technology report for the site 'The dayiime and nighttime noise levels at nearby houses due to Klinge Pharma were determined to be wifhin fhe €PA guideline daytime limit of 55 dB(A), and nighttime guideline limit of 45 dB(A}. '

8. WASTE

As part of the on site Environmental Management Programme Temmler Ireland Limited has a number of waste reduction initiatives. Some major milestones achieved since the original IPC application include:

A 63% reduction in packaging material in the form of fibre drums used in the Pellet Plant in 1996;

A 50% reduction in use of office paper in 1996;

Composting of waste water treatment plant sludge allowing diversion of this sludge waste from landfill;

A 74% reduction in landfilled wastes from 1999 to 2004;

A 30% reduction in hazardous waste from 2000 to 2003;

Recycling initiatives across the site including glass and aluminium recycling in the canteen and paper recycling in the offices; and

In 2002 a dedicated building was constructed for sorting of recyclable non hazardous waste.

9.

Monitoring of emissions to the environment will be conducted to ensure all controlitreatment systems continue to operate to specification and in compliance with emission limit values and the requirements of the IPPC licence.

Emissions to air will be monitored from all main emission points which are in use.

Emissions to surface water will be monitored at two emission points, SW 1 and SW2.

10. ERGV EFFlCBE

A computerised Building Management System (BMS) controls and monitors all energy usage on site. This system was installed in 1984. The system has been expanded and


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Temmler Ireland Limited IPPCL Application Attachment No. A . l

updated over the years to encompass the areas such as energy metering, control of buildings and process services.

The total energy consumed on the entire site in 2005 was 24,242 MWIh’s consisting of electricity (8,972 MW-h), light fuel oil (12,179 MW-h), Gas Oil (2.787 MW-h) and ABF (304 MW-h). Water consumption on site (municipal supply) for 2005 was 25.453m3.

As a member of Responsible Care Ireland, Temmler Ireland Limited is required to comply with various codes of practice including an Energy Management code which requires Temmler Ireland Limited to have an Energy Policy and Monitor Energy usage to name but a few requirements.

To meet their requirements under Responsible Care Ireland Temmler Ireland Limited has numerous energy objectives in place as outlined below:

Temmler Ireland Limited has an energy policy which is updated annually:

An energy officer has been appointed with overall responsibility for reduction in energy consumption:

Temmler Ireland Limited has an energy time zone management procedure in place and it is hoped that the improvements in the management of time zone operation will have energy consumption savings in the future.

Temmler Ireland Limited has a monitoring and data capture system in place for all significant zones to support the long-term goal of driving energy minimisation;

Temmler Ireland Limited has established monthly and annual reporting on energy consumption with a view to energy minimisation.

Temrnler Ireland Limited has established an energy training programme which, when implemented will hopefully increase staff awareness regarding energy conservation.

In 2005 Temmler Ireland Limited successfully reduced the non production operation of the Nitrogen generation plant to the minimum level necessary to support production thereby reducing the utility non production power load by 24%.

11. ENT OF ACCIDENTAL SPILLAGES

Temmler Ireland Limited has in place well developed plans and measures in place to contain and prevent accidental spillages, with key provisions as follows:

0 The storage and containment of all materials at Temmler Ireland Limited conform to existing IPC licence requirements and best practice. Bund capacities incorporate the required 110% of the volume of the largest tank or 25% of the of the total tank volume within the bund, whichever is the greater. All tank farms are adequately bunded to prevent any accidental spillage reaching the WWTP. In all cases, discharge from bunded areas is manually controlled.


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Temmler Ireland Limited lPPCL Application Attachment No. A.1

The Drum Store is en-circled with an interception drain which discharges to a 1,000 litre holding tank. This allows small spillages to be impounded, thus preventing entry to the WWTP.

e

* The warehouses on site also have interception drains fitted which allow spillages to be impounded.

* A 3-year rolling bund and drain programme ensures that any deficiencies in available secondary containment are rectified in a timely manner.

6 Continuous T.0.C monitor on stormwater which can be diverted to the firewater retention lagoon if higher than usual T.0.C levels are detected and, if necessary, treated in the WWTP

* The Building Management System (BMS) triggers and records critical alarms, the basis for emergency ‘call-outs’.

Temmler Ireland Limited also has in place a lined firewater retention pond that has been sized on a worst case fire scenario and is fitted with a firewater overflow to prevent ground Contamination.

Under the SEVESO I I regulations, EU Directive 96/82/EC Temmler Ireland Limited is not classified as a SEVESO site.

Temmler Ireland Limited have Standard Operating Procedures (SOPS) and a highly trained Fire Crew and Emergency Response Team who are on 24 hour call-out in place to deal with Evacuation and Emergency Procedures. Temmler Ireland Limited has in place a Major Emergency Plan (Appendix J-1 of Attachment J) covering a wide variety of potential environmental, safety and health risks, including:

Fire or Explosion;

@ Bulk Chemical!Oil spill;

Spillage of Water Reactive Chemicals;

Significant Environmental Damage;

Intrinsic to the Temmler Ireland Limited Emergency Plan are environmental considerations. Specifically the plan documents detailed actions and procedures in the event: of an environmental release such as a leak or spill.

An Environmental Liabilities Risk Assessment (ELRA) was prepared for the site in 2005. The ELRA must address liabilities arising from past and present activities and must be completed by an independent and appropriately qualified consultant.

The following key points from the above ELRA are as follows:

Aitachment A.1 Non Tech Surnmary.doc Page 17

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One of the key-environmental risks identified is contaminant leaching into soils and groundwater - an issue well under control.

*

* The current environmental management programme on the site has reduced the risk of the development of new significant environmental liabilities to a low level.

0 Insurance cover for the site is considered adequate for risks identified.

* No scenarios have been identified which could result in environmental liabilities that either exceed the insurance cover or would threaten the financial solvency of Temmler Ireland Limited.

The above ELRA will be revised as required by the EPA.

13. APPLICATION OF BEST AVAILABLE TECHNIQUES AT T E ~ ~ L ~ ~

Temmler Ireland Limited incorporates a high standard of Best Available Techniques (BAT) in operations at the site. Specific BAT of note is as follows:

* The site has implemented Environmental Management Systems certified to IS0 14001 which includes an Environmental Policy and Environmental Management Programme.

0 Temmler Ireland Limited has incorporated sophisticated energy monitoring and targeting systems, and has carried out energy auditing to identify targets for energy conservation:

* Temmler Ireland Limited has in place a very rigorous waste management protocol:

0 Drainage systems are segregated such that the volumes of wastewater being sent for on-site wastewater treatment are reduced.

In the unlikely event of cessation of activities on site, Temmler Ireland Limited will complete a planned programme of decommissioning incorporating any EPA requirements in this regard.

A Residuals Management Plan (RMP) was prepared for the facility in 2005. The purpose of the RMP is to ensure that following termination, or planned cessation for a period greater than six months, of use or involvement of all or part of the site in the licensed activity, the licensee shall, to the satisfaction of the Agency, decommission, render safe or remove for disposallrecovery, any soil, subsoils, buildings, plant or equipment, or any waste, materials or substances or other matter contained therein or thereon, that may result in environmental pollution.


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Temmler Ireland Limited lPPCL Application Attachment No. A.1

The RMP addresses both shortimedium-term (Closure Plan) actions and a longer-term programme (Restoration and Aftercare Management Plan).

The individual stages in the closure plan are:

Stage 1 :

Stage 2:

Stage 3:

Stage 4:

Stage 5:

Stage 6:

Stage 7:

Stage 8:

Stage 9:

Production decommissioning, including transfer of residuals to on-site storage:

Removal of excess raw materials, bulk solvent and final product from site;

Removal of production related hazardoushon-hazardous wastes from Site;

Contract cleaning of bulk storage;

Treatment of Bulk Liquid wastes at the on-site WWTP;

Removal of non-process related materials and non-hazardous wastes;

Decommissioning of site services and on-site WWTP;

Removal of residual hazardous materials; and,

Documentation and Certification of decommissioning and decontamination

The Long Term Programme (LTP) or restoration and aftercare management plan addresses a number of potential areas of concern on the site in relation to historic operations including raw materials storage, process drains, the former waste water treatment area and operationlproduction areas

P.tiachmentA.1 Non Tech Summary.doc Page 19

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Number 431179

I hereby certify that

TEIL1MI;ER WELAND LIMITED

is this day incorporated under the Companies Acts 1963 to 2005, and that the company is limited.

Given under my hand at Dublin, !.tiis

Wednesday, the Gth day of December, 2006

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was Incorporated under the Cornpanics Acts, 1963 to 2005,

as a Limited Company on

ay, elfie 6th day of

Certified by me at Dublin, this Wednesday, the 6th day of December, 2006. ( 73X7E’ 1 Registrar of Companies Paul Farrell

CompWjcs Aci 1363, section 370(1), Rlec!mme Commmcu! Act 2000, sett ion^ 1’2 and 13

Note The above certtficate oftncorpomtwn is furnished free of charge by the regzstrar of comparucs &ad is valid solely for publtc ~ M W se A process has bcm put IIL place whmby, where necessary, the cntlficate may be vc&8cd hy a pubhe s m m body on mqquirY

The applicant: for any public service who is iequucd to prodace a cerbficdc of incorporation must certify below &at the cemfirate bas not hcm mnpcred mth in my WRY. The certificate shall bo retmed by the public scniice orgnnlsahon titat r e q u k its delivery and may be ased as evidence of any wrongiil ISC.

__ __ __ - __ _ _ __ ___

the rcpstrar.

___ __- ~ 1, (name) __ __

of(address) . -- - - -. __ __

hereby declare that this is one and the same as Me Certificate of hcorpomtion of the above company that was made available electronically, for public service use, at my rcqueut, by the registrar of companies. 1 further declare that to the best of my knowledgo, information and belief’, ihe said Certi5cate has not been altered or amended in any way. I acknowledge that it is a criminal oiknce to forge a public document with intent ta defraud or deceivc, and that it is an offence lo utter a forged dor;urnent with intent to defkaud or deceive, in each case punishable with imprisonment for a term not exceding two yws.

I mike this C)eclaration for the benefit of

(name of public body) _-_ __ .”

to whom T am i i s b h g the Certificate.

-- .-- - Signnaturc of Applicant Date

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10L 1L 19t. z: :ON anssl

:., ,

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Temmler Ireland Limited IPPCL Application Attachment E. 1 .A Emissions to Air

Page No

I. CHARACTERISATION OF EMISSIONS TO AIR ............................................................ I

1 .I. introduction ................................... .............................. 1 1.2. Main Emissions ............................ .............................................. 1 1.3. Minor Emissions ........................... ............................................ 3 1.4. Requested Changes ..................... .......................................................... ‘ 5 1.5. Assessment of Emissions to Air regarding S.I. No. 394 of 2004 ...................................... 5

2. ABATEMENT OF EMiSSION TO AIR ............................................................................. 7

2.1. Introduction .................................................. ............................................ 7 2.2. Description of Abatement .................................................... .., 2.2.1. Dust Filtration S everse Jet Filter ............................ ... 2.2.2. Water Scrubber .................................................................................

Appendix E. 1.1 : - Drawings indicating Emission to Air

Attachment E.l .A Pagei

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I Temmler Ireland Limited IPPCL Application Attachment E.l .A Emissions to Air

1. CHARACTERISATION OF EMlSSlO

1.1. 1 ntrod U ction

There are three groups of emissions to air from the Temmler Ireland Limited facility in Kiliorglin:

1. Main emissions: - these are the boiler emissions, dust extraction emissions and four emission points that are being declared for future use;

2. Minor emissions: - these are laboratory emissions and process emissions that are low in mass flow of pollutants to air, these pollutants being largely volatile organic compounds and particulate matter:

3. Fugitive and potential emissions - these are emissions that are not captured process emissions and those emissions that would not normally be expected to occur during production.

This attachment describes the main and minor emissions and especially changes to emissions since the grant of the current licence in 1995 (Register Number POO18-001) as well as describing the abatement systems employed on the site.

The location of main and minor emission points are highlighted in Appendix E.l. l on Drawing Reference 106104-03 - Monitoring Wells and Emission Points.

ain Emissions

There are a total of six point source main emissions on the Temmler Ireland Limited site as outlined in Tabie 1 below. Of these, four are emission points which the site wishes to retain in case of future use.

Since the EPA granted Temmler Ireland Limited (previously Klinge Pharma) with an IPC licence in 1995, there have been no additions to main air emission points. In 1995 shortly after the issuing of the IPC licence Temmler Ireland Limited decommissioned A2-5 and A2-6 from the Pelletising Plant No. 1, hence these points are not listed in Schedule 1 of their current licence. A2-5 however is currently accepting minor emissions form a small vacuum system. It is not a main emission at present but is being declared as such to allow for potential future upgrade of the process.

In 2000, main emission point A2-3 was decommissioned and its exhaust routed to A2-4. These emission points are associated with the API facility. As Temmler Ireland Limited ceased production in the API facility in December 2006 and are currently decommissioning the API facility this means that emission point A2-4 will no longer be in use.

Attachment E 1 A Page1

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Temmler Ireland Limited IPPCL Application Attachment E. 1 .A Emissions to Air

In January 2007 Temmler Ireland Limited conducted an Air Dispersion Modelling Assessment of Boiler and Generator Emissions. The resultant report forms Attachment 1.1. In summary, the results of the modelling excercise indicates that emissions of main polluting substances (Sulphur Dioxide, Nitrogen Oxides and Carbon Monoxide) are unlikely to have a significant impact on the environment.

Table I Main Emission Points

Emission Point.

AI-I

AI -2

AI -3

A2-1

A2-2

A2-3

A24

A2-5

A2-6

.. Refer to Section 1

Building No.

Building 2. Boiler House Building 2. Eioiler House Building 2: Boiler House Building 19, Pelletising Plant 2 (New Pellet Plant) Building 19, Pelletising Plant 2 (New Pellet Plant) Building 3. Chemical Synthesis 1

Building 8. Chemical Synthesis 2

Building 7. Pelletising Plant 1

Building 7 , Pelletising Plant I . .....

3

... ................. -. . ................ Description

Exhaust Fumes from Boiler 8-501

Exhaust Fumes from Boiler 5-502

Exhaust Fumes from Boiler B-503

Exhaust from central vacuum system (dust)

Exhaust from point extract system (dust)

Currently exhausts via A2-4, Will be decommissioned when API is decommissioned. However, the point is to be retained in case of future use of the building. Process Vent - this point will be decommissioned when API is decommissioned. However, the point is to be retained in case of future use of the building. Currently accepting minor emissions form a small vacuum system. Not a main emission at present but is being declared as such to allow for potential future upgrade of the process. No exhaust at present however may be used in future

Tables E.l.(i), E,l.(ii) and E.l.(iii) in the main application describe main emission points on site. Details of the abatement systems employed are presented in Section 2 of this Attachment.

Attachment E.l .A Page2

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Temmler Ireland Limited IPPCL Application Attachment E . l .A Emissions to Air

Location

Boiler

QC Lab

QC Lab

QC Lab

QC Lab

__ "__"

1.3. Minor Emissions

i Description ~

Oil Heater 8-903, Chemical Building 3 (Condition 5.6 of Licence Reg. No. PO01 8-01 refers to this boiler) Exhaust from Lab Fume cupboard

Exhaust from Lab Fume cupboard



~ ^ ____ *

Since the EPA issued Temmler Ireland Limited with their there has been some changes to minor emission points.

._ .. QC Lab

QC Lab

riginal IPC licence in 1995

..... ........ - ............ : - Exhaust from Lab Fume cupboard


One minor emission point has been decommissioned namely EP3/7, which comprised an exhaust fume from the development laboratory fume cupboard. This laboratory was split in two to form an in-process laboratory and a development laboratory and relocated to two locations in 1999. The in- process laboratory was moved to Building 8 with emissions via existing A2-4 and the Development IaboratorylPilot Plant moved to Building 7 with emissions also vented to A2-4. The pilot plant is to be decommissioned as part of API closure therefore A2-4 will be decommissioned in the near future.

Pelletising Plant 1 (QC Lab)

Pelletising Plant 1 (QC Lab)

Table E.1 (iv) in the main application outlines the minor emissions to atmosphere.



In the original application to the EPA for an IPC licence; numerous minor emission points from HVACs were listed. However these should have been listed as Fugitive Emissions. Table E.1. (v) in the main application describes these HVACs emissions.

Pelletising Plant 1 (Small scale pellet plant)

Table 2 below outlines Minor Emission Points on site both existing and new points since the original licence application.

Process Vent ex Small scale pellet plant (Loedige mixerlgranulator and Vacuum pump)

. ___- . Table 2 Minor Emission Points

Emission Point

A3-1

... A3-2

A3-3

A 3 4

A 3 5

.. -. ...__l__l_---- A3-6

A3-7

A3-8

A3-9

A3-10

Attachment E 1 A Emissions to Air Main Textdoc Page 3

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Ternmler Ireland Limited IPPCL Application Attachment E. 1 .A Emissions to Air

Table 2 Minor Emission Points

Emission Point .

A3-11

A3-12

A3-13

A3- 14

A3-15

.. A3-16

< A34 7

A3-18

A3-19 new emission point


........................................ A3-21 new emission point



Location _"I

Exhaust from EHS Lab Fume cupboard

Pelletising Plant 2 (New Pellet Plant)





"-


Generator 1 exhaust

Generator 3 Exhaust.

Generator 2 Exhaust

Process Vent - Extraction

Process Vent - Spraydrying

Process Vent - Extraction

Description


Process Vent -dryer Line 1

Process Vent - mixerlgranulator Line 1

Process Vent - coater Line 1

Process Vent - coater Line 2

Process Vent - mixer/granulator Line 2

Process Vent -dryer Line 2

Generator 1 exhaust

Generator 3 exhaust This generator is due to be relocated to AlCL by end of 2007.

Generator 2 exhaust

..l_._._lll.._._.-_ ..... ........... Process Vent - Extraction plant vacuum pumps. Previously vented via A2-4.

Process Vent -Spraydryer scrubber. Previously vented via A2-4.

Process Vent - Extraction plant evaporator

"" ........

The location of all main emissions and minor emissions are depicted on Drawing Reference 106101-03 contained in Appendix E.I.I.

Attachment E 1 A Emissions to Air Main Text.doc Page 4

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Temmler Ireland Limited IPPCL Application Attachment E. l .A Emissions to Air

Air Emission Point A I - I A I -2 A I -3 A2-1

1.4. Requested Changes

A2-2

Temmler Ireland Limited wish to retain main emission points A2-3, A2-4, A2-5 and A2-6 in case of potential future developments on site. Should these points be used at a future date the Agency will be informed in advance and necessary details provided. Tables E 1 (ii) and E 1 (iii) have been completed for these emission points. Temmler Ireland Limited intend to decommission current abatement at these points so if they are used in future new abatement will be installed which shall meet BAT requirements.

Abatement

Monitoring Conducted . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Licence Reg. No. POO18-01 Condition 10.8 requests that the Licensee operate a weather monitoring station. Temmler Ireland Limited wish to remove this condition as the windsock on site is used to monitor wind direction and Temmler Ireland Limited considers that the nature of the process, particularly given the cessation of API production, that a weather monitoring station is not warranted.

NJA NIA NJA Filtration Filtration ".___._" " __I__......... .......... "- ........... -

Schedule 1 (iii) of IPC Licence No. 18

'1.5. Assessment of Emissions to Air regarding Si. No. 394 of 2004

"__"- _I________ _ _ Dust

Asbestos

Chlorine & its Compounds

Temmler Ireland Limited has carried out an assessment of the main emissions to air in respect of the Schedule contained in S.I. No. 394 of 2004 (the revised Licensing Regulations). This assessment is presented in Table S.1.394 below:

__ ______ - - "" __I_ __ ____- - -- N N N Y Y

1

N N N N N

N N N N N

" ............................................. " I..__.-___.._....._.__...... " "

Table S.1.394


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Temmler lreland Limited IPPCL Application Attachment E. 1 .A Emissions to Air

Flourme 8 its Compounds

Arsenic 8, its Compounds

Table S.1.394

N N N N N

N N N N N

Carcinogentcs or Mutagenics I N N N

Cyanides f N I N / N I N ............._..___II.-- :_ __I" _ll_____.lll. " I N ;

N N

Polychlorinated dibenzodioxins and N / N N N \ dibenzofurans


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EPA Export 25-07-2013:21:14:09

2.

2.1.

Type of Emission Point Location on Site Abatement Category

_ " .__I__ ...... - -

Temmler Ireland Limited IPPCL Application Attachment E.l .A Emissions to Air

Target Pollutants

....... ............ -- ......

ISSION TO AIR

Reverse Jet Filter Main

In trod ucti on

A2-1 and A2-2 Particulates Building 19

Temmler Ireland Limited has invested significantly in emissions to air abatement. Much of the abatement will be decommissioned as part of the API decommissioning. Going forward without the API plant, the remaining abatement may be summarised as follows:

Water Scrubber Minor A3-22 Building 3 Particulates and potentially, miscible Volatile Organic Compounds

Cartridge Filter Minor* A2-5, Building 7 Particulates

-~ . .... . Filter Fugitive

such for potential future upgrades.

_ ""____.._ ___ ...... HVACs across the Particulates site.


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Temmier Ireland Limited IPPCL Application Attachment E. 1 .A Emissions to Air

2.2.1. Dust Filtration Systems Reverse Jet Filter

Main emission point A2-1 is a central vacuum system that collects and conveys any accidentally spilt dustlpowder from the plant. filters it and exhausts the clean air to atmosphere.

Main emission point A2-2 is a point extraction system that conveys fugitive dusts from process equipment, filters it and exhausts the clean air to atmosphere.

For both of the above systems, the conveying air is filtered through reverse jet filters, where the dust ‘is seperated from the air and collected in a self contained unit. The filters are needlefelt bag-filters which are kept clean by an automatic blowback with compressed air. There is an audible alartm on the compressed air for the blowback function.

Minor emission point A2-5 is also a central vacuum system, though on a much smaller scale than that from A2-1 (540m3/hr vs. 3750m3/hr). It consits of a cyclone system with cartridge filters also encompassing compressed air blowback for cleaning the filter.

In addition local filter socks are used to contain most of the fugitive dusts within the production vessels at point source.

All of the above systems are maintained as part of Temmler Ireland Limited’s peventative maintenance system.

2.2.2. Water Scrubber

A stainless steel scrubber containing chilled water as the scrubbing fluid is an integral part of the closed-loop spraydryer in building 3. The nitrogen (or air) stream first passes through a cyclone, which separates out the solids that are subsequently drummed off. From there it enters the scrubber which is a counter current single-stage unit of ‘bubble- tray’ construction. In its current application, it is used to remove water-soluble particulate contamination, primarily to prevent solids entering the heat-exchanger on the nitrogen return to the spraydryer. Also, while not done in current processes onsite, it is possible to use the scrubber to recover aqueous alcohol which can then be re-used in the process. The nitrogen stream is for the most part, returned to the process and a small nitrogen bleed from the system for safety reasons, comprises the minor emission A3-22.

The scrubber is operated and controlled as part of the computerised control system (ACOS system) for the spraydryer. The system is maintained as part of Temmler Ireland Limited’s peventative maintenance system.


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Temmler Ireland Limited IPPCL Application Attachment E. l .A Emissions to Air

Attachment E 1 A Emissions to Air Main Textdoc

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- . - . . . -. . -. . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . .-

ir Oi missions

31 January 2007 Final

Issue No 5 45078680 /

IS0 9001:2000 I QUALITY I

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Temmler Ireland Limited ADMS Boilers Air Dispersion Modelling of Boiler and Generator Emissions

Issue No Date

1 1 511 212006

Project Title:

Report Title:

Project No:

Report Ref:

Status:

Client Contact Name:

Client Company Name:

issued By:

Details of Revisions

Original issue

Ternmler Ireland Limited ADMS Boilers

Air Dispersion Modelling of Boiler and Generator Emissions

45078680

__ - ~

2

Final

Bernice Mahony

Temmler Ireland Limited

URS Ireland lveagh Court 6-8 Warcourt Road Dublin 2 Ireland Tel: + 353 (0) 1 41 5 51 00 Fax: + 353 (0) I 415 5101 www.urseurope.com

03/01 12007 Incorporation of clients comments

Document Production I Approval Record

3 1 910 1 I2007

4 I 19/01/2007

Issue No: Name 5

Incorporation of client feedback

incorporation of clients comments

Prepared Klara Kovacic/Cath) bY Cronin

~

5

Checked Fergus Hayes and Approved

3 1 /01/2OO7 Final

Signature Date

3 1 IO 1 12007

31 101 I2007

Position

Environmental Scientist

Operations Director

31 January 2007 Final

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http://www.urseurope.com


LIMITATION

URS Ireland Limited (URS) has prepared this Report for the sole use of Temmler Ireland Limited in accordance with the Agreement under which our services were performed. No other warranty, expressed or implied, is made as to the professional advice included in this Report or any other services provided by us. This Report may not be relied upon by any other party without the prior and express written agreement of URS. Unless otherwise stated in this Report, the assessments made assume that the sites and facilities will continue to be used for their current purpose without significant change. The conclusions and recommendations contained in this Report are based upon information provided by others and upon the assumption that all relevant information has been provided by those parties from whom it has been requested. Information obtained from third parties has not been independently verified by URS, unless otherwise stated in the Report.

,

COPYRIGHT

0 This Report is the copyright of URS Ireland Limited. Any unauthorised reproduction or usage by any person other than the addressee is strictly prohibited.

31 January 2007 Filial

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Section Page No

1 .

1.1. 1.2.

2.

2.1, 2.2. 2.3. 2.4.

3.

INTRODUCTION .............................................................................................................. 1

1 ............................. 2

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

MODEL DESCRIPTION, INPUT DATA AND AIR QUALITY GUtDELlNES ................... 3

Introduction ................... ......................................... The ADMS Model ........................... Model Inputs ............................................................... ................................................ Air Quality Limit Values ..................................... ......................................................... IO

RESULTS AND DlSCUSSfON ...................................................................................... 11

31 January 2007 Page i Final

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Temmler Ireland Limited ADMS Boilers Air Dispersion Modelling of Boiler and Generator €missions

Parameter

1.

EPl/f (AI-1) EP1/2 (A1 -2)

1.1.

Carbon monoxide (mg/Nm3)

TRODUCTION

200 200

Background

An impact assessment of the emissions to air is required for an application for a revised Integrated Pollution Prevention and Control (IPPC) licence. This report presents an air dispersion modelling study completed for the Temmler Ireland Limited (Temmler) site in order to determine the impact of emissions from two boilers and two diesel generators on local air quality. Modelled emission points include:

* Boiler 1 (Emission point Al- I ) ;

* Boiler 2 (Emission point A1 -2);

e Generator (Emission point A3-18);

Generator (Emission point A3-20).

The pollutants modelled are SOZ. NO, and CO.

The emission limit values (ELVs) for the boilers from the current IPC licence (Register No. PO01 8-01) are presented in Table 1.1.

I Maximum flow rate (m3/hr) I 4,650 I 2,870 I I SO2 (mg/Nm3) 3,000 3:OOO I I I I NO, (as NO2) (mg/Nm3) I 760 I 760 I

The ELVs for NO, and CO used in this study are the same as in the IPC licence. However, the SO2 ELV used in this study is 1,700 mg/Nm3. This is because the maximum SO2 concentration of 3,000 mg/Nm3 in the original licence was set at a time when the sulphur content of fuel oil was well above the current statutory maximum of 1%. Normal operations require one boiler to be operational and one on standby. Therefore this modelling exercise assumes that only the larger of the two boilers (Al-1) is in operation for Scenarios 1 and 2. Boiler A1 -1 and A1 -2 are operational at full load in Scenario 3. There is a third boiler on the site A1-3. This boiler is equivalent to A1-2 and only operational in place of AI-2. Therefore Scenario 3 would also be representative of emissions from A1 -1 and A I -3 in operation.

The generators modelled in this study were previously classified as a minor emission point and therefore there are no ELVs in the current licence for this generator. Currently,

31 January 2007 - 1 - Final

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Temmler Ireland Limited ADMS Bailers Air Dispersion Modelling of Boiler and Generator Emissions

the generators provide back up capacity and are running on a daily basis from the 1" of November to 31'' March between the hours of 5 and 7 pm. Generator emissions have been modelled conservatively at full load, normal operations are for the generators to run at 70 - 7556 capacity.

Table 1.2 provides flow rate. NOx and CO emissions rates for the generator as supplied by the manufacturer. The SO2 emission rate is based on the 0.2% sulphur content in diesel.

Table 1.2: Characteristics of the generators

1 Fuel consumption 1 200 litres/hr 1 1 Flue gas flow rate (dry gas. 3% oxygen) 1 2,846 Nm3/hr 1

NOx (as NOp) 2,861 mg/m3

1,044 mg!m3

1.2. Report Outline

Section 2 provides a description of the ADMS model, the required model input data and available ambient air quality guideline values and background concentration data. Section 3 presents the results of the modelling exercise in tabular format. A discussion of the results and recommendations for future work is also included in Section 3.


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2"

2.1 *

2.2.

MODEL DESCRIPTION, INPUT DATA A D AIR QUALITY GUlDELl

Introduction

The ADMS model is an advanced modelling system, which requires a variety of input data to ensure accurate predictions of ground level concentrations due to stack emissions. The ADMS model is described in Section 2.2.

Required inputs include building dimension data: terrain data: surface roughness data, source data (stack height, diameter, flow rate, emission rates for each compound to be modelled), meteorological data and receptor data. These inputs are described in Section 2.3.

This assessment considers the impact of releases of substances from the stacks. No account is taken of the effect of any fugitive or accidental releases.

Dispersion model results do not take account of any background concentrations of the released compounds. However, the model results can be added to the expected background concentration to provide an estimate of actual expected ground level concentrations. The resultant concentrations can be compared with air quality standards and objectives. Available air quality limit values are described in Section 2.4.

The impact of a release on the environment will be dependent on many factors, including:

* the rate of release of each substance;

e other release characteristics. such as release location, release velocity and the temperature of the released material;

0 the physical properties of the released substance (such as its physical form or particle size);

e the chemical properties of the released substances;

0 the nature of the receiving medium, particularly its dispersive and transfer characteristics and how these vary with time;

* ambient concentrations of released substances already present in the environment;

* the locations of receptors in the environment sensitive 'to the released substances: and

* the degree of sensitivity of these receptors to enhanced concentrations of released substances.

31 January 2007 -3 - Final

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To quantify these effects and to establish the predicted ground level concentrations of species emitted from on-site sources! URS has undertaken detailed air dispersion modelling for the site. The selected modet for use in this assessment is ADMS3, produced by Cambridge Environmental Research Consultants (CERC). This model is a 'new-generation' model, which represents local meteorological conditions in a more technically correct way than the older models that utilise semi-empirical stability classes. The main features of ADMS3 are:

* all on-site sources can be modelled together in the same run! to provide an integrated assessment: of the whole site. Source types can include point, area, line, volume and jet sources. Up to 100 sources can be modelled at any one time;

* site-specific hourly sequential meteorological data is used in the modelling assessment to provide worst-case ground level concentrations for realistic conditions;

e meteorology is treated in a more comprehensive way than in early dispersion models, using the Monin-Obukhov length and the boundary layer height to describe the atmospheric boundary layer properties instead of the semi-empirical Pasquill stability classes used in previous models;

Dispersion under convective meteorological conditions uses a skewed Gaussian concentration distribution, while previous models have assumed a symmetric Gaussian distribution. Validation studies have shown the skewed distribution to be a better representation of actual conditions: .

* worst-case conditions can be modelled e.g. adverse combinations of meteorology and emissions, which could result in pollution episodes;

effects such as steep terrain, dry and wet deposition, radioactivity, time varying sources and building effects can be taken into account;

* The model has links to a contour plotting package;

* model outputs can be calculated for a wide range of averaging periods and percentiles, allowing direct comparison with all relevant ambient air pollutant standards and objectives.

The ADMS3 model takes a range of parameters including stack dimensions, emission conditions and representative meteorological data. and calculates the maximum concentrations at specified intervals from the emission source using sequential computer algorithms. It is generally considered that air dispersion models are conservative models, over-predicting ground level concentrations. All results quoted in this report are the maximum values predicted by the model, and therefore in the opinion of URS represent the worst case.

31 Jariuary 2007 - 4 - Final

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Met Parameter

The use of an advanced model such as ADMS3 rather than a simpler screening model is considered the best available analytical technique and enables the incorporation of terrain and building effects on dispersion (if required).

2005

2.3. Model Inputs

Average Cloud Cover (oktas)

Minimum wind speed (m/s)

2.3.1. eteorology

6

0.0

Hourly sequential meteorological data are employed in the model. One year (2005) of continuous meteorological data from the Valentia synoptic monitoring station are employed. The monitoring station at Valentia is the closest synoptic station to Kilorglin and therefore the most suitable for this analysis. The meteorological data employed in the model are summarised in Table 1. Cloud cover is measured in oktas. 0 to 8 shows the fraction, in oktas, of the celestial dome covered by all clouds. The prevailing wind directions and speeds are also indicated in Figures 1 presents the wind roses for 2005 Valentia meteorological data.

Average wind speed (mk) 4.8

I Minimum temperature ("C) I -1.2 I 1 Average temperature ("C) I 11.4 I I Maximum temperature ("C) ~ 25.5 I


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Figure 1 : 2005 Valentia wind rose

2.3.2. Topography

Local topography can have a significant impact on the dispersion of released materials. The ADMS model is capable of including topographical data, if required. There are two parameters, which can be employed in the model to describe local topography, as detailed below.

Surface Roughness

This parameter is specified in all modelling assessments. Surface roughness describes the degree of ground turbulence caused by the passage of winds across surface structures. Ground turbulence is greater in urban areas, for example, due to the presence of tall buildings.

The area surrounding the Ternmler site includes other industrial units. A surface roughness value of 0.5 metres has been chosen which is typical of parklandiopen suburbia and is considered to represent typical surface roughness in the site area.

31 January 2007 - 6 -

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Temmler Ireland Limited ADMS Boilers lodelling of Boiler and Generator €missions

Building Name

Boiler House

Chemical Synthesis 1

Chemical Synthesis 2

Air Dispersion

i Height (m) Length(m) ' Width (m)

2.6 27.5 I 15.5

1 1.85 61 26.5

13.6 28 27.25

I

Complex Terrain

AICL Plant*

Pelletising Plant 1

The presence of steep hills in the vicinity of a site can effect dispersion of emissions. A gradient of 1 :I 0 or greater is normally taken as the criteria for inclusion of terrain in a modelling assessment. There are no hill gradients greater then 1 in 10 within approximately 5km of the plant and so complex terrain data has not been incorporated into this modelling assessment.

12,2 121.5 61

8.5 60.5 20.5

2.3.3.

Ware house 10 33 34

Workshop & Stores 6.8 27 20 I

Building Effects

Buildings in the vicinity of emission points can have a significant impact on the behaviour of the plume after release from the source. The main effect is to entrain pollutants into the cavity (leeward side) of the building. which is isolated from the main flow and in which a reversal of flow can occur. This can result in rapid grounding of undiluted plumes.

Typically buildings are considered to have an impact on dispersion if the building height is greater than 113 of the stack height. Information supplied by Temmler indicates a number of significant buildings on the site, as detailed in Table 2.2. The impact of these buildings on the predicted ground fevel concentrations is investigated as part of this study.

The relative building and stack layouts are presented in Figure 2.

Table 2.2: Approximate dimensions of significant site buildings associated with each unit, metres

I Pelletising Plant 2 12.35 66 32.5 1 I

The impact of other miscellaneous off-site buildings and structures are taken into account in the surface roughness factor specified in the model and described in Section 2.3.2.


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Ternmler Ireland Limited ADMS Boilers Air Dispersion Modelling of Boiler and Genera to r Emiss ions

Figure 2: Relative layout of site buildings and stacks included in the modelling assessment

971 50

971 00

97050

97000

. . . . . . . . . . . . . . . . . . . . I . . . . . .~

Generator

78300 78350 78400 78450 78500 78550 78600 78650 78700

2.3.4. Input Parameters

Data for the boilers is taken from Table E.l(i) of the licence application. Data for the generators is provided by the manufacturer.

Flow rate entered into the model is at normal conditions, but at typical stack moisture of 9% and oxygen content 3%. The model calculates flue gas exit velocity based on the entered flow rate.

The following parameters were modelled:

0 Sulphur dioxide;

e Nitrogen oxides:

0 Carbon Monoxide.

The dispersion model input emissions data is summarised in Table 2.3.

Available air quality guideline values for the compounds are provided in Section 3.

31 January 2007 - 8 -

Final

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Boiler 1

(Al-I)

15.3

0.445

Table 2.3: Summary of the input data used in model

Boiler 2 Generator (A3- Generator (A3-

20) (AI -2) 18)

15.1 6.3 6.3

0.355 0.71 3 0.71 3

Parameter

Height (m)

21 3

0.739

_._.__I_." __.__I"

21 3 483 483

0.41 1 2.262 2.262 1 NOx (gls)

1.282 0.71 3 0.791 0.791

1.654 10.91 9 10.222 10.222 I 0.195 10.108 10.825 10.825 1

2.3.5. Data Output

The model was set up to predict offsite ground level concentrations over a grid covering 1000 metres to the north; south, east and west from the centre of the site. Grid spacing is 50 metres.

The model can also calculate various percentile and average concentration values for each single receptor within the grid. For the purposes of this assessment the model outputs have been chosen as follows for comparison with legislative limits:

* Annual average hourly concentration at each receptor for the year;

* Maximum hourly concentration at each receptor for the year;

0 Various percentile of hourly values at each receptor for the year as required by the legislative limits for SO2 and NOn;

Ground level concentrations are reported as pg/m3

Modelling of NOx emissions was dealt with as follow:

e 50% of NO, converts to NO2 immediately on release to atmosphere (hourly maximum);

e 100% of NO, converts to NOn in the long term (annual average).


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NQ;I

CO

2.4.

health

Human health

Human health

Air Quality Limit Values

European Council Directive 1999/30/EC specifies ambient air quality limit values for Son, NO,, NO2 and CO. This Directive has been transposed into Irish Legislation through S.I. No. 271 of 2002 (Air Quality Standards Regulations, 2002). The limit values and criteria specified in S.I. 271 for NO2 are reported in Table 2.4.

Table 2.4: Limit values from Air Quality Standards Regulations

T Compound Criteria i

Human health

Human health

Ecosystem protection

Averaging Period

1 hour

24

Annual average

1 hour

Annual average

Max daily 8-hour mean

.imit Vatue (1.rg/m3)

350 not to be exceeded

more than 24 time per annum


more than 3 times per annum

20


more than 18 times per annum

40

10,000

-

Percentiie for Compliance

99.73 percent of hours must be less than 350

99.1 8 percent of days must be less thar 125

99.79 percent 0'

hours must be les: than 200

No ambient monitoring data were available from the site for concentrations.

expected background

31 Jariuaiy 2007 -10-

Final

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3. RESULTS AND DlSCUSSlO

The model was run for three scenarios:

0 Scenario 1: The main boiler (Al-1) and two generators (A3-18 and A3-20) running at full load for 24 hours a day for a full year.

Scenario 2: The main boiler (Al-1) at full load for 24 hours a day for a full year, with the two generators (A3-18 and A3-20) running from the I " November to 31'' March between 5 to 7 pm at full load.

* Scenario 3: The main boiler (AI- I ) and boiler (AI-2) at full load for 24 hours a day for a full year with the two generators (A3-18 and A3-20) running from the 1" November to 31" March between 5 to 7 pm at full load.

The model calculates ground level concentrations for each pollutant. The maximum worst case ground level off-site concentrations for both scenarios are presented in Table 3.1,

For Scenario 1, the maximum worst case ground level concentrations of SO2 and CO are significantly lower than the statutory limits. However, the maximum worst cases concentrations for NO2 (99.79 percentile) and NO2 (annual average) exceed the statutory limits. Scenario 1 is a worst-case conservative modelling assessment. in reality the site does not operate the generators 24 hours a day for a full year.

Therefore, Scenario 2 was run with a more representative assessment of current operations at the site. Scenario 2 was run using time variance data, with Boiler A l -1 running for a full year at full load and the two generators (A3-18 and A3-20) running from the 1'' November to the 31" of March between the hours of 5-7 pm. Again results are represented as the maximum worst case results in Table 3.1.

URS uses a conservative approach when converting NOx to NO2 results in line with guidance information available from the UK Environment Agency (www.environment- aaencv.aov.uklsubiects/airauality). A risk-based approach is recommended by the UK Environment Agency with the following conversion steps:

Step 1 (Screeningiworst case) - 50% and 100% of the modelled values should be used for short-term and long-term average concentrations respectively. If the PEC (process contribution and relevant background concentration) exceeds the relevant air quality objective. then proceed to step 2.

Step 2 (Worse case scenario) - A 35% conversion for short-term and 70% for long-term average concentration should be considered.

The results for Scenario 2 show that the maximum ground level concentration of NO2 (annual average) does not exceed the statutory limit based on emission data supplied by the manufacturer. The maximum worst case NO2 (99.79 percentile) marginally exceeds the statutory limit by an estimated 10% using the most conservative NOx to NO2 conversion factor of 50%. However, using the above guidance, if the worse case 35%


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Temmler Ireland Limited ADMS Boilers Boiler and Generator Emissions

54.86

9.94

I.....I "_

381.30 .

61.60

conversion ratio is used instead of the 50% conversion for short-term concentrations, the maximum predicted NO2 (99.79 percentile) would be 152.32 (pgim3) for Scenario 2, which is significantly lower than the statutory limit of 200 pgim3. Maximum worse case results for NO? using the 35% and 70% conversion ratio are presented in Table 3.2. Figure 3.1 presents NO2 ground level concentrations from Scenario 2.

46.76

8.57

..._._......I_ I-

217.60

4.01

The use of the 35% is conservative and considered worse case. The UK Environment Agency only requires justification for case specific modelling where a conversion factor less than 35% is used.

It must also be noted that the modelling assumptions made throughout this assessment are conservative, the modelling assessment models emissions at the current boiler ELVs and emission specifications outlined by the generator manufacturer.

Scenario 3 was run to assess the impact of running both boilers (AI-1 and A1-2 or AI-7 or AI-3) along with the generators. Results from this assessment were similar to those found for Scenario 2.

It is important to note that all modelling used in this study is likely to over-predict ground level impacts and therefore is highly conservative.

Table 3.1 : Maximum off-site ground level concentrations for Scenario 1 2 and 3. Results for NOz were calculated using highly conservative NOx conversion ratio of 50% for short- term concentrations and 100% for long term concentrations.

Compound

SO2

so2

-_ ............. " " - NO2

Statutory Limit (pg/m3)

39.73 percent 3f hours must be less than 350

99.1 8 percent of days must be less than 125

20 (Annual average)

99.79 percent of hours must be less than 200

40 (Annual

Results Results Scenario 3 Results (li!$m3)

164.68

76.46

14.17

-. 21 7.65

-12- 31 January 2007 Final

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P

NO2


c,

of hours must be less than 200

40 (Annual

Compound

CO

Statutory Limit (pg/m3)

average)

10,000 (max daily 8-hour mean)

Scenario 1 Scenario 2 Scenario 3 Results Results Results I (lig/m3) (CIg/m3) (lig/m3)

I I

1144.18 66.59 67.03 t I I I

Table 3.2: Maximum off-site ground level NO:! concentrations using a worse case NOx conversion factor of 35% for short-term concentration and 70% for long-term average concentrations.

Compound Statutory Limit (pg/m3)

99.79 percent

Scenario 2 Results

(I.(g/m3)

152.32

2.81

Scenario 3 Results

(lig/m3)

152.36

4.47

-13- 31 January 2007

Final

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9740C __I

Figure 3.1: Scenario 2 - 99.79fh percentile fpgirn3) 1-hour NO, (graph was drawn using 50% conversion NOx to NO,). Site boundary o ~ t ~ ~ n @ d in red. Background concentrations not inclluded.

Grid coordinates East, Metres

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/a e@?-%

Describe the ~ o n ~ j t ~ ~ ~ n s of the site of the installation

Provide an asscssmcnt of the cffccts of any emissions on the c~~ ironment , including on an en~~ironmental medium other thaii that into which the e ~ i s s ~ o n s aie made.

Describe, whcre appropriatc, measures for min~n~~s ing pollution over long distances or in the territory of other states.

1.1 .Assessment of atmospheric emissions Describe the existing environment in terms of air quality with particulctl- reference to ambient air qirality standards. The site is located in a predominantly rural location with ambient air quality standards expected to be consistent with rural background concentrations.

Provide a statemenl whether or not emissions of main polluting substances (as delined in the Schedule of S.I. 304 of 2004) to the atmosphere are likely to impair the cnv i rorm e nt .

Give summary details and an assessment of the impacts of' m y existing or proposed emissions on the en\, iroiment, including environmental media other thrvl those into which the emissions are to be made.

Attachment Ng 1.1 should also contain full details of any dispersion inodelling of atmospheric emissions from the activiti , ivhere required. An Air Dispersion Modelling Assessment of Boiler and Generator Emissions is included in Attachment 1.1. The conclusion from this assessment implies that emissions of main polluting substances (Sulphur Dioxide, Nitrogen Oxides and Carbon Monoxide) are unlikely to have a significant impact on the environment.

I .2. Assessment of Impact on Receiving Surface U'atcr Describe the existing eiivironment in teiins of water quality with particular reference to environmental quality standards or other legislative standards. Table 1,2(i) should be completed

Provide a statement U hether or not emissions of main polluting substances (as delined in the Schedule of S.1. 394 of2004) to water are likely to impair the environment.

Give summary details and an assessment of the impacts of any existing or proposed emissions on the environment, including environmental media other than those into which the emissions are to be made.

Full details of the assessment and any other relc\,ant infonilation on thc receiving eiwironnient should be submitted as A t ~ ~ c ~ ~ n e n t N2 2.2.

Attachment No. 1.2. contains the relevant information.

1.3. Assessmenf of Impact of Sewage Discharge. NIA

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Ternmler Ireland Limited.

~ i l l o ~ ~ ~ i n ~ Co.

Attachment L Statutory ~ e ~ ~ ~ r e ~ ~ n t ~

February 2007

issue No 2 461 71 701

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Temmler Ireland Limited Attachment L Statutory Requirements

Page No Section

1. REQUIREMENTS OF SECTION 83 (5) OF THE E ~ V I R O ~ M E ~ T A L PROTECTION AGENCY ACTS 1992 AND 2003 ............................................................ 1

1.1. 1.2. 1.3. 1.4. 1.5. 1.5.1. 1.5.2. 1.6. 1.7. 1.8. 1.9.

........................................ * .........,...

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

General ........ . ....... Groundwater . . . . . . . . ......................... .....................................

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

2. DESIGNATED AREAS ...................... =....................................................=........................ 7

3. WATER QUALITY ........................................................................................................... 8

4. REQUIREMENTS OF ENVI~ONMENTA~ PROTECTION AGENCY (LICENSING) ( A ~ E N D ~ E ~ T ) REGULATIONS 2004 .................................................... 8

5. REQUIREMENTS FOR A FIT AND PROPER PERSON .......................................... ..... 9

5.1. Convictions ..................................................................................................................... 10 5.2. Technical Knowledge and qualifications ........................................................................ 10 5.3. Resources ...................................................................................................................... 10

Attachment L Main lext.doc Page i

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1.

1.1.

ENTS OF SECTION 83 (5) OF THE ENTAL PROTECTION AGENCY ACTS 1992 AND

2003

Part IV of the Environmental Protection Agency Act (No. 7 of 1992) was replaced by a new Part IV under Section 15 of the Protection of the Environment Act 2003 (No. 27 of 2003). Under Section 83(5)(a)(i) to (v) and (vi) to (x) of the Environmental Protection Agency Acts 1992 and 2003 (as defined in Section 1 of the Protection of the Environment Act 2003), the Agency shall not grant a licence or revised licence for an activity unless it is satisfied that the operation of the plant meets certain requirements. This section 'describes how the operation of Temmler Ireland Limited will meet these requirements.

Air

Section 83(5)(a)(i) of the Environmental Protection Agency Acts 1992 and 2003 states that the Agency may not grant a licence for an activity unless it is satisfied that any emission from the activity will not result in the contravention of any air quality standard specified under the Air Pollution Act 1987 (No. 6, 1987).

Air quality standards as specified under Section 50 of the Air Pollution Act 1987 are contained in the Air Quality Standards Regulations S.1 No. 244 of 1987. and concern Sulphur Dioxide, Suspended Particulates, Lead and Nitrogen Dioxide. These standards are being replaced on a phased basis, to be completed in 201 0, by Air Quality Standards Regulations 2002 (S.1 271 of 2002), which also bring in standards for NO, and Benzene.

In January 2007 Temmler Ireland Limited conducted an Air Dispersion Modelling Assessment of Boiler and Generator Emissions. The resultant report forms Attachment 1.1, In summary, the results of the modelling exercise indicates that emissions of main polluting substances (Sulphur Dioxide, Nitrogen Oxides and Carbon Monoxide) are unlikely to have a significant impact on the environment.

Therefore compliance by Temmler Ireland Limited with respect to the on site boilers and generators is:

6 Sulphur Dioxide (SO2): The boilers are potential sources of sulphur dioxide. However, as the fuel is light fuel oil with a sulphur content of less than 1% this potential is IOW. There were no breaches in licence limits for SO2 in 2005.

e Nitrogen Dioxide (NOp): The boilers are potential sources of nitrogen dioxide. There were no breaches in licence limits for NO2 in 2005.

* Suspended Particulates: The boilers are potential sources of suspended particulates. However as the fuel is light fuel oil this potential is low. In addition boilers on site are operated so that the smoke colour is less than or equal to shade number 1 on the Ringelmann chart (except during periods of start up, not exceeding 30 minutes)

Attachment L Main Text Page 1

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Regulations 1992-2001 (S.I. 155 of 4992, S.I. 145 of 1994, S.I. 177 of 1998 and S.I. 22 of 2001)

The European Communities (Quality of Salmonid Waters) Regulations (S.I. 293 of 1988)

* Lead: None used on site.

discharge any emissions directly to bathing water.

Temmler Ireland Limited does discharge emissions directly to salmonid water the River Laune however there were no breaches of emission limit values for water in 2005.

e Benzene: None used on site.

1.2. Water Quality Standards

Section 83(5)(a)(ii) of the Environmental Protection Agency Act 1992 and the Protection of the Environment Act 2003 states that the Agency shall not grant a licence for an activity unless it is satisfied that any emission from the facility will not result in the contravention of any standard prescribed under Section 26 of the Local Government {Water Pollution) Act 1977 (No.1 of 1977).

Section 26 of the Water Pollution Act 1977 allows the Minister to set quality standards for water, trade effluent and sewerage. The Local Government (Water Pollution) Act 1977 (Water Quality Standards for Phosphorus) Regulations, 1998 (S.I. 258 of 1998) are the only quality standards set under this section. Phosphorus is not used extensively on site, and the main source of phosphorus emissions to water would be treated effluent from the wastewater treatment plant. Temmler Ireland Limited has an ELV for Total Phosphorous as P of 1 Omg/l, which it did not exceed in 2005.

There are currently no other relevant water standards made under this section in place. The subject of this section will be dealt with in Table 1 below in order to avoid duplication, since many of the limit values and standards currently in force were set in accordance with EC Directives.

l"3. European Legislation

Section 83 (5) (a) (iii) of the Environmental Protection Agency Acts 1992 and 2003 states that the Agency shall not grant a licence for an activity unless it is satisfied that any emission from the activity will comply with, or not result in the contravention of any relevant standard including any standard for an environmental medium prescribed under Regulations made under the European Communities Act, 1972 or any other enactment. Table 1 below summaries the regulations which have been reviewed and Temmler Ireland Limited compliance.

Table 1 - Temmler Ireland Limited compliance with regulations

I I I


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. . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . , . . . . . .. .. . . . .. . . . -. - . - . . . . . - . . . . . -


___--I-- __I - Regulation

Local Government (Water Pollution) Act 1977 (Control of Cadmium Discharges) Regulations ( S I . 294 of 1985)

Local Government (Water Pollution) Act, 1977 (Control of Hexachlorocyclohexane and Mercury Discharges) Regulations (S.I. 55 of 1986)

Local Government (Water Pollution) Acts 1977 and 1990 (Control of Aldrin, Dieldrin, Endrin, Isodrin, HCB, HCBD and CHCL3 Discharges) Regulations 1994 (S.I. 348 of 1993)

Local Government (Water Pollution) Acts 1977 and 1990 (Control of Carbon Tetrachloride, DDT and Pentachlorophenol Discharges) Regulations 1994 ( S I . 245 of 1994)

Quality of Shellfish Water Regulations (S.I. 200 of 1994, amended by Quality of Shellfish Waters (Amendment} Regulations (S.I. 459 of 2001)

Local Government (Water Pollution) Regulations, 1992 (S.I. 271 of 1992)

I_.-

Temmler Ireland Limited Compliance

Cadmium IS not used at the Temmler Ireland Limited facility; therefore, there is no potential for discharges containing cadmium from the site.

Hexachlorocyclohexane and mercury are not used at the Temmler Ireland Limited facility; therefore, there is no potential for discharges containing these substances.

The substances to which these regulations apply are not used at the Temmler Ireland Limited facility. If these substances were to be used at Temmler Ireland Limited in the future, controls would be applied to prevent any discharges containing these substances.

The substances to which theses regulations apply are not used at the Temmler Ireland Limited facility. If these substances were to be used at Temmler Ireland Limited in the future, controls would be applied to prevent any discharges containing these substances.

Temmler Ireland Limited does not discharge any material to shellfish waters, as listed in the Schedule to these regulations. However approximately 3.0km downstream of the site within Castlemaine Harbour, there is an important shellfish area called Cromane, area approximately 3,700 hectares. designated under the Quality of Shellfish Waters Regulations (S.I. No. 200 of 1994, as amended by S.1 No. 459 of 2001).

Temmler Ireland Limited complies with water quality standards laid out in the IPC licence, which take into consideration limits set in these regulations.


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.. -__ . _ -. -. - --. Regulation

Water Quality (Dangerous Substances) Regulations, 2001 (SI. 12 of 2001)

Arsenic, Chromium, Copper, Cyanide, Fluoride, Lead, Nickel, Zinc, Atrazine, Dichloromethane, Simazine, Toluene, Tributyltin, Xylenes

.. . __-_ . - -- - Temmler Ireland Limited Compliance,

Once the API process has been decommissioned Temmler Ireland Limited will not use any of the substances listed in this regulation.

There are no direct emissions to groundwater and the possibility of accidental indirect emissions is minimised by the following measures: -

0 Regular drain surveys to ensure the integrity of all underground piping for the transfer of chemicals and contaminated water in process and foul sewers;

0 There is a fire water retention pond on-site. This ensures that firewater arising on site in the event of a fire scenario is retained and does not pose a threat to surface or groundwater sources; and regular monitoring of groundwater quality;

Bunding of bulk storage tanks and bunding of liquid material storage areas and procedures to ensure that bunding is adequate and of good integrity.

Temmler Ireland Limited (previously Klinge Pharma) have operated a groundwater monitoring programme at the site since 1996, as required by their IPC licence. Groundwater has been sampled biannually from six monitoring wells (MW2 to MW7) and from the firewater well (On Site Well 1 or OSW1) at the Killorglin site. In early 2006 URS Ireland Ltd were requested by Klinge Pharma to carry out additional investigative works within the production areas and the chemicallfuel storage areas as part of a vendor due diligence programme due to the planned divestment of the site from the Klinge Pharma group. This additional investigation work which is ongoing has highlighted elevated chloroform and TCE beneath production areas from historical activities on site. Further delineation and remedial options are under consideration at present.

1.4. oise Regulations

Section 83 (5) (a) (iv) of the Environmental Protection Agency Acts 1992 and 2003 states that the Agency shall not grant a licence for any activity unless it is satisfied that any noise from the activity will comply with or not result in the contravention of any regulations under Section 106 of the EPA act. This section enables the minister to make regulations for the purpose of the prevention of limitation of noise, which may cause a nuisance.

Although no noise control regulations have been made. the EPA Guidance Note for Noise in Relation to Scheduled Activities recommend that to avoid

Attachment L t;ilain Text Page 4

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disturbance the noise level at sensitive locations should not exceed a LAeq T value of 55 dBA during the daytime and a LAeq T value of 45 dBA at night-time. It also recommends that audible tones and impulsive noise at sensitive locations at night should be avoided.'

The most recent noise survey, completed in December 2005, indicated that Temmler Ireland Limited was compliant with EPA Guidance Note for Noise in Relation to Scheduled Activities.

Attachment E.5 provides further information on Noise Emissions.

1.5. Significant Environmental Pollution

1.5.1. General

Section 85 (5) (a) (v) of the Environmental Protection Agency Acts 1992 and 2003 states that the Agency shall not grant a licence for an activity unless it is satisfied that any emissions for the activity will not cause significant environmental pollution.

All monitoring and measurements taken to date indicate that Temmler Ireland 'Limited currently has no significant impact on the environment. There was one breach in emission limit values in 2005. This breach was for an air emission of Ethly Bromide which was above the site's ELV. This breach occurred when an operator used a hose containing a small quantity (approx 1.5L) of Ethyl Bromide to discharge waste water to the industrial sewer. The resulting vapour was extracted by the general extract and caused a licence non-compliance. The corrective action for this non-compliance was that for future batches the waste line will be flushed with IPA after pumping Ethyl Bromide. This process will cease following API decommissioning.

1.5.2. Groundwater

Temmler Ireland Limited (previously Klinge Pharma) have operated a groundwater monitoring programme at the site since 1996, as required by their IPC licence. Groundwater has been sampled biannually from six monitoring wells (MW2 to MW7) and from the firewater well (On Site Well 1 or OSW1) on site (see Drawing Reference. 106101-03). MW1 was dry and was not installed as a well.

The most significant issue detected in these early wells was the presence of elevated monochlorobenzene in MW2 and MW3. interpreted as being related either to issues relating to known leaks (repaired) from the site effluent drains close to MW3 or deriving from contaminated soil found below the floor slab of Area 31 5 in production building CS1 during reconstruction work in 1990.

In early 2006 URS were requested by Klinge Pharma to carry out additional investigative works within the production areas and the chemical/fuel storage areas as part of a vendor due diligence programme due to the planned divestment of the Killorglin site from the Astellas Pharma group.

Wells MW8 to MW23 were drilled under the supervision of URS between February and October 2006. Wells MW8 to MW13 unexpectedly indicated


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groundwater flow to the east or southeast in the central part of the site and detected elevated chloroform and trichloroethene concentrations in well MW 1 1 close to the administration building.

The detection of elevated chloroform in MW14 indicates that this is the source area for chlorinated organic solvent contamination (chloroform, trichloroethene), as it is where these solvents were formerly stored and used (mid 1970s to midllate 1980s). Chlorobenzene was used in CS2 (late 1980's to 2006).

Downgradient wells in the fracture zone (MW23, OSW2) have detected trace concentrations of chlorinated solvent contamination (below EPA Guidelines and Irish Drinking Water Standards) and this suggests that the contamination is diluted and dispersed within the bedrock fracture zone to trace concentrations within the Killorglin site. There is no long-term groundwater monitoring data available for the production area wells to assess temporal trends in contaminant concentrations at the Killorglin site. The wells along the eastern and southern boundaries of the site (MW15, MW16, MW17, MW22) show no evidence of chlorinated solvent contamination or groundwater migration from the site in an easterly or southerly direction.

1.6" Production and Disposal of Waste

Section 83 (5) (a) (vii) of the Environmental Protection Agency Acts 1992 and 2003 states that production of waste should be prevented or minimised. and, where waste is produced, it will be recovered, and, where it is not economically and technically possible to recover it, be disposed of in a manner which will prevent or minimise any impact on the environment.

Waste is prevented or minimised where possible at Temmler Ireland Limited. Recovery and/or reuse is the preferred disposal method for waste produced by Temmler Ireland Limited where this is technically and economically feasible. All wastes are disposed of in compliance with the Waste Management Act 1996 and associated regulations.

Tables H.1 (if and H.l. (ii) in the main application form provide further details on waste generation and disposal.

1 .?. Energy

Section 83 (5) (a) (viii) of the Environmental Protection Agency Acts 1992 and 2003 states that energy is to be used efficiently in the carrying on of the licensed activity.

As a member of Responsible Care Ireland, Temmler Ireland Limited is required to comply with various codes of practice including an Energy Management code which requires the site to have an Energy Policy and Monitor Energy usage to name but a few requirements. Energy consumption is reported to the Agency annually in the Annual Environmental Report. Temmler Ireland Limited is committed to the conservation of energy.

Attachment G provides further information on Energy Conservation.


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1.8. Accident Prevention

Section 83 (5) (a) (ix) of the Environmental Protection Agency Acts 1992 and 2003 requires that necessary measures be taken to prevent accidents in the carrying on of the activity. In addition, it is required that, where an accident occurs, its consequences for the environment are limited, and where there are consequences, these consequences are remedied.

Details relating to accident prevention are presented in Attachment J. The Emergency Plan is maintained and updated regularly. Under the SEVESO I I regulations, EU Directive 96182EC Temmler Ireland Limited is not classified as a SEVESO site.

1.9.

2.

Cessation of the Actiwity

Section 83 (5) (a) (x) of the Environmental Protection Agency Acts 1992 and 203 requires that necessary measures are taken upon the permanent cessation of the activity (including such a cessation resulting from the abandonment of the activity) to avoid any risk of environmental pollution and return the site of the activity to a satisfactory state.

On the cessation of the activity or any part of the activity, Temmler Ireland Limited will take the necessary measures to avoid any risk of environmental pollution. In addition, Temmler Ireland Limited will return the site to a satisfactory state.

URS Ireland Ltd produced a Residuals Management Plan (RMP) for the site based on the EPA Guidance Document entitled “Guidance Documents and Assessment Tools on Environmental Liabilities Risk Assessment and Residuals Management Plans incorporating Financial Provision Assessment (EPA Contract OEE-04-03) Draft for Consultation May 2005.”

Attachment K provides further information on Cessation of the Activity.

DESIGNATED AREAS

The activity is not carried out in such a manner that is liable to have an adverse effect on:

* A site placed on a list in accordance with Chapter 1 of the European Communities (Natural Habitats) Regulations, 1994 (S.I. 94 of 1997);

* A site where consultation has been initiated in accordance with Article 5 of the EU Habitats Directive (92/43/EEC): or

* A European site as defined in Article 2 of the European Communities (Natural Habitats) Regulations.

The Temmler Ireland Limited site is located approximately 3.0 km upstream from Castlemaine Harbour which is listed as a ‘Special Protection Area’ in S.I. 349 of 1994.


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As discussed earlier in this attachment, the operation of Temmler ireland Limited is unlikely to have an adverse effect on water quality with respect to the Local Government (Water Pollution) Act, 1977 (Water Quality Standards for Phosphorus} Regulations, 1998.

The Environmental Protection Agency (Licensing) (Amendment) Regulations 2004 (SI. 394 of 2004) specify indicative lists of principal polluting substances to be taken into account by the Agency, if relevant. in the fixing of emission limit values.

Tables 1 and 2 below lists the polluting substances for Air and Water respectively that are given in the Schedule to these regulations, with an indication of whether they are likely to be present in air emissions at Temmler Ireland Limited.

Tabte 1 - Air polluting substances

Medium Principal Polluting Substance Temmler Ireland Limited, Emissions

Air Sulphur dioxide and other sulphur compounds Present

Air Oxides of nitrogen and other nitrogen Present compounds

Air Carbon monoxide Present

Air Volatile Organic compounds Present as minor emissions

Air Metals and their compounds Unlikely to be present

Air Dust Present

Air Asbestos (suspended particulates, fibres) Unlikely to be present

Air Chlorine and its compounds Unlikely to be present

Air Fluorine and its compounds Unlikely to be present I I

Air Arsenic and its compounds Unlikely to be present

Air Cyanides Unlikely to be present


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1 ,

I 1 I Temmler Ireland Limited I 1 , I Attachment L Statutory Requirements

i l ___.___________II___ ___ _I________-- ~ -- -

Medium Principa! Polluting Substance Temmler Ireland Limited, ' t ( 1 ; Emissions '

Air Substances and preparations which have been Unlikely to be present

Air

proved tq possess carcinogenic or mutagenic properties or properties which may affect reproduction via the air

Polychlor,inated dibenzodioxins and polychlorinated dibenzofurans

I Unlikely to be present

................................. ~ ---.-._I_

Table 2 - Water polluting substances i Medium Principal Polluting Substance

Water Organohalogen cornounds

Temmler Ireland Limited, Emissions

Unlikely to be present

Water

Water

1

Organoptiosphorous compounds

Organotin compounds



5. ENTS FOR A FIT A e> PROPER PERSO

Water

Water

Water

Water

Water

Water

Water

Water

Water

Section 83 (5) (a) (xi) of the Environmental Protection Agency Acts 1992 and 2003 specifies that the Agency shall not grant a licence unless it is satisfied that the licensee is a fit and proper person. Information to enable a determination to be made by the Agency, as required by Section 84 (4) of the Environmental Protection Agency Acts 1992 and 2003, is given below.

I

Carcinogens or mutagens Unlikely to be present

Persistent Hydrocarbons Unlikely to be present

Cyanides Unlikely to be present

Metals and their compounds Unlikely to be present

Arsenic and its compounds Unlikely to be present

Biocides and plant health products Unlikely to be present

Materials in Suspension Present

Substances which contribute to eutrophication Present

Substances which have an unfavourable Present influence on the oxygen balance

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5.1. Convictions

Temmler Ireland Limited or any other relevant person have not been convicted of any offence under the Protection of the Environment Act, the Waste Management Act f 996, the Local Government (Water Pollution) Acts 1977 and 1990 or the Air Pollution Act 1987.

5.2. Technical Knowledge and qualifications

The site has an environmental department and team that are dedicated to environmental management of site operations. This ensures the day-to-day operation of the waste water treatment plant and waste shipment are done in accordance with the companies internal procedures as well as all legal requirements including the IPC Licence. The site has IS0 1.4001 certification. The environmental management team also drive continuous improvement measures and is committed to implementing environmental excellence measures.

5.3. Resources

Temmler Ireland Limited have resources to ensure that any financial commitments or liabilities that may arise can be met, including those that may arise through cessation of activities at the site.

Attachment L Mah Text , Page 10

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4


Attachment L Main Textdoc November 2006

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