GLAXOSMITHKLINE (CORK) LTD. IPPC LICENCE REGISTER NO. … · GLAXOSMITHKLINE (CORK) LTD. IPPC LICENCE REGISTER NO. P0004-03 ANNUAL ENVIRONMENTAL REPORT 2009 EPA Submittal Date: March

GLAXOSMITHKLINE (CORK) LTD.

IPPC LICENCE REGISTER NO. P0004-03

ANNUAL ENVIRONMENTAL REPORT 2009

EPA Submittal Date: March 31st 2010

GSK Cork Annual Environmental Report 2009 IPPC Licence Reg. No. P0004-03

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Contents

EXECUTIVE SUMMARY 4

1. INTRODUCTION 5

1.1 Site Description 5

1.2 Main Products 6

1.3 Employment 8

2. ENVIRONMENTAL DATA SUMMARY INFORMATION 9

2.1 Emissions to Water: Storm Water (Ref. Points SW02 and SW03) 9

2.1.1 Summary Information 9

2.1.2 Trend Analysis 10

2.1.3 Surface Water Diversions 11

2.2 Emissions to Water: Treated Effluent (Ref. Point SW01) 12

2.2.1 Summary Information 12


2.2.3 Treated Effluent Non-Compliances 14

2.3 Wastewater from Incineration Activities (Ref. Point W1) 14

2.3.1 Details of Non-Compliances 14

2.4 Emissions to Atmosphere 17

2.4.1 Details of Non-Compliance 20


2.4.3 Validation of Atmospheric Emission Monitoring Systems 23

2.5 Waste Management 23

2.5.1 Waste Generation and Fates 23

2.5.2 Waste Minimisation Indices 27

2.5.3 Rejected Consignments of Waste 29

2.5.4 Waste Analysis 29

2.5.5 Analysis of Aqueous Wastes for Incineration 30

2.5.6 Total Waste Management (TWM) Programme 31

2.5.7 Audits of Waste Management Facilities 32

2.6 Noise 33

2.7 Resource Consumption and Energy Efficiency 36

2.7.1 Resource Consumption 36


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2.7.2 Energy Consumption 36

2.7.3 Energy Audit 37

2.7.4 Operational Excellence in Energy Management 37

2.7.5 Key Energy Management Projects 38

2.7.6 Water Usage and Efficiency 41

2.7.7 Production Efficiency 43

2.8 Control and Monitoring 45

2.8.1 Compliance with Condition 6.1 and 6.2 45

2.9 Agency Monitoring and Enforcement 45

2.9.1 Aqueous Emissions Sampling and Analysis 45

2.9.2 Atmospheric Emission Sampling and Analysis 48

2.9.3 IPPC Licence Audit 48

2.9.4 EPA Site Visits/Inspections 50

2.10 Environmental Incidents 50

2.11 AER Returns Table 59

3. ENVIRONMENTAL MANAGEMENT OF THE ACTIVITY 60

3.1 Environmental Management System 60

3.2 Environmental Management Programme Report 2009 60

3.3 Environmental Management Programme 2010 60

4. POLLUTANT RELEASE AND TRANSFER REGISTER (PRTR) 61

4.1 PRTR Report 2009 61

4.2 PRTR Proposal for 2010 61

5. OTHER REPORTS 61

5.1 Underground Tank and Pipeline Inspection and Monitoring 61

5.1.1 Process Sewer Pipelines 61

5.1.2 Foul Sewer Pipelines 61

5.1.3 Surface Water Pipeline System 62

5.2 Bund Integrity Assessment 62

5.3 Groundwater Quality Monitoring Reports 62

5.3.1 Summary of Monitoring conducted on the 15th & 16

th June, 2009 63

5.3.2 Summary of Monitoring conducted on the 18th of November, 2009 64

5.4 Residuals Management Plan 67


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5.5 Environmental Liability 67

5.6 Financial Provision 68

5.6.1 Known Liabilities (RMP) 68

5.6.2 Unknown Liabilities (ELRA) 68

5.6.3 Statement of Measures 69

APPENDIX A

Site Environmental Policy

APPENDIX B

Hazardous Wastes Arising on Site in 2009

APPENDIX C

Non-Hazardous Wastes Arising on Site in 2009

APPENDIX D

Environmental Management Programme (EMP) 2010

APPENDIX E

Environmental Management Programme (EMP) Progress Report 2009

APPENDIX F

PRTR and AER Summary Data Tables for 2009

Table of Figures

Figure 1.1 General Production Schematic............................................................................................ 7

Figure 1.2 Environmental Staff Organisational Chart………………………………………………………8

Figure 2.1 Comparison of pH of Surface Water Discharge ex SW02 .............................................. 10

(2005 to 2009) ................................................................................................................................. 10

Figure 2.2 Comparison of TOC level of Surface Water Discharge ex SW02 ..................................... 10

(2005 to 2009)..................................................................................................................................... 10 Figure 2.3 Surface Water Diversions 2007 to 2009……………………………………………………… Figure 2.4 Comparison of Mass Emissions to Estuary (SW01) 2005 to 2009 ................................... 13 Figure 2.5 Comparison of Mass Emissions to Estuary (SW01) 2005 to 2009 ................................... 13

Figure 2.6 Comparison of Mass Emissions to Atmosphere 2005 to 2009 ......................................... 22



Figure 2.9 Waste Generation 2005-2009 ........................................................................................... 24

Figure 2.10 Breakdown of Non-Hazardous Waste Streams in 2009................................................. 25 Figure 2.11 Breakdown of Hazardous Waste Fates 2009………………………………………………..26 Figure 2.12 Comparison of Waste Management Data 2005 to 2009 ................................................. 27

Figure 2.13 Comparison of Waste Management Indices 2005 to 2009. ............................................ 29

Figure 2.14 Solvent Usage Breakdown for GSK Cork 2009............................................................... 44

Figure 5.1 Historical Trend in Ammonium Concentrations ................................................................. 66 Figure 5.2 Historical Trend in Total Coliforms Concentrations ........................................................... 66


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EXECUTIVE SUMMARY

In the past year, GlaxoSmithKline Cork continued to produce active pharmaceutical ingredient (API) to supply demand for it’s portfolio of products. This demand has not remained as consistent as the site would hope for. In 2009, the site manufacturing volumes reduced by 60% compared to 2008 following a comparable drop in 2008. The plant is typically operating at ~20% capacity.

Despite these challenging circumstances, the site continues to invest in site infrastructure, to ensure it is central to GSK’s production capability. The site’s flexibility in terms of operation and people is key to return the site to increased production output in the future.

Within the past year, two new products have been introduced to GSK Cork (Horizant (aka Gabapentin Enacarbil/Solzira) & Eltrombopag) and it is hoped that more will follow to utilise the plant capacity available.

In 2009, GSK continued to demonstrate strong environmental compliance reporting 99.99% compliance with it’s IPPC licence. The Environmental Protection Agency visited the site on six occasions. During an audit in May, some non-compliances were raised with the company and these issues have been addressed since that date. A further Agency inspection in December 2009 recorded no non-compliances.

In terms of reduced waste generation at source, early phase process development involves reducing solvent waste and optimising reaction efficiency. Solvent recovery continues to be carried out on-site with sizable investment being undertaken to recover methylcyclohexane (MCH) from Horizant over the coming years.

Despite the challenging business environment, GSK Cork remains committed to environmental compliance. In 2009, the site invested €6million in environmental operational and monitoring expenditure. Capital investment in environmental management projects totaled over €1million.

The past year has seen remarkable performance in the site’s energy reduction initiative. Over 21% (60,000GJ) reduction on 2008 energy usage was achieved through ten major projects. Major improvements were delivered through better management of heat supply to buildings, natural gas conservation in support of incineration and steam usage savings. 2010 is expected to see a further 40,000GJ drop in energy consumption.


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1. INTRODUCTION

Licensee: GlaxoSmithKline (Cork) Ltd.

Location of Activity: Currabinny, Carrigaline, Co. Cork.

Licence Register Number: P0004-03.

GlaxoSmithKline (GSK) Cork Ltd. is based in Currabinny, located on the banks of Lough Beg near to the mouth of Cork Harbour. The facility produces bulk active pharmaceuticals for clinical supplies and final products. Goods are exported to other GSK locations worldwide for formulation and distribution.

GSK was granted an Integrated Pollution Control (IPC) Licence Reg. No. 4 on the 6th of December 1994. Due to new developments on-site, GSK was subsequently granted a revised IPC Licence Reg. No. 473 on 20th August 1999. The entire licence numbering system was changed by the EPA in July 2006, and the register number was changed to P0004-02. An IPPC Licence Review Application was submitted to the Agency in September 2006; IPPC Licence Register No. P0004-03 was issued on 10th July 2007.

One of the requirements of the IPPC Licence (P0004-03) is to prepare an Annual Environmental Report for submission to the EPA by the 31st of March of the subsequent year. This report, in compliance with Condition 11.8 of the licence, details environmental performance at the site for the period January to December 2009. This report has been prepared in accordance with the following EPA AER/PRTR Guidance Documents:

• Principles of PRTR and AER Reporting of Annual Environmental Information (Guidance Doc. No. 1).

• The Step by Step Guide for AER / PRTR Reporting for EPA Licensed Facilities (Guidance Doc. No. 2)

• EPA’s Guidance Note for Annual Environmental Reports, 2000 (Guidance Doc. No. 3)

• The EPA AER Guidance Note Annex on AER PRTR Reporting V.1.1 (Guidance Doc. No. 4)

• The AER/PRTR Electronic Reporting Workbook and Website User Manual (Guidance Doc. No. 5)

• Procedure for Creating and Submitting Your Full PDF AER (Guidance Doc. No. 6)

Condition 2.2 of GSK’s IPPC Licence requires the licensee to establish and maintain an Environmental Management System (EMS). GSK has established the elements of an EMS as relevant to the conditions of the IPPC Licence - refer to Section 3 below.

An Environmental Policy has been prepared and is posted at several locations throughout the site including the site Security Building. A copy is included in Appendix A for reference.

1.1 Site Description

GSK is located at National Grid Reference E 1782 N 0628, near the village of Ringaskiddy. GSK occupies a 52 acre site in Currabinny, approximately 21 km from Cork city on the Currabinny road.


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Features of interest or sensitive locations in the immediate vicinity include the lagoon inside the approach causeway to GSK. The surrounding marsh is home to many animals and birds, a high tide roost for waders and wildfowl and acts as an important staging post during the annual migration of many water species. GSK in conjunction with the Irish Wildbird Conservancy (IWC) play a significant role in maintaining this wildlife sanctuary.

The original plant was developed between 1973 and 1975. Since the plant began operations in 1975, increased production has led to a number of expansions and modifications of production and ancillary facilities. However, throughout these changes attention has been paid to ensuring that the plant and its operations have had minimal impact on the environment.

Pollution control equipment on-site includes: two high temperature incinerators (both incorporating a DeNOx unit); an emergency scrubber; one thermal oxidizer; a wastewater treatment plant (biotreatment/chemical treatment); and three solvent recovery plants.

The site comprises:

• 7 No. Production Buildings (Buildings 1, 2, 3, 5, 6, 7 and 8)

• a Milling/Nanomilling Facility (Building 4),

• a Research and Development Building, (Building 9)

• 2 No. Warehouses (for raw materials, intermediates, finished goods and maintenance supplies),

• External material storage areas including tank farms (waste and raw materials),

• an Environmental Control Centre,

• a Waste Management Facility (for solid wastes),

• Service Utilities,

• Laboratories,

• an Engineering Building,

• Office Buildings,

• a Cafeteria and a Security Building.

1.2 Main Products

The plant operates on a 24 hour day, 7 day week shift basis. 126 tonnes of product (active pharmaceutical ingredient) were produced during the reporting period 2009.

The products are manufactured by organic synthesis using batch processing operations. Each product is generated through a series of intermediate stages with each stage comprising a number of unit operations. A typical production process is outlined in Figure 1.1.


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Figure 1.1 General Production Schematic

The main unit operations carried out on site include the above production operations, as well as solvent recovery, utilities generation and pollution abatement.

The main products produced during 2009 were:

• Lapatinib • Eltrombopag

• Horizant • Abacavir

• Ropinirole

Raw materials are subjected to various physical and chemical changes in order to produce the required chemical in the correct form. As a result, solid, liquid and gaseous emissions are generated. These emissions are subjected to physical and chemical treatment to remove any toxic, odorous or environmentally sensitive substances in accordance with IPPC Licence Reg. No. P0004-03 prior to discharge from the facility.

A large percentage of the non-recoverable solvents and certain aqueous solutions as well as gaseous emissions are treated/destroyed in the two incinerators on-site.

Section 2 below provides a summary of GSK’s monitoring data from the various pollution control installations for 2009 with respect to the following:

• Emissions to water

• Emissions to atmosphere

• Waste management

• Noise

• Resource consumption (energy, water) and energy efficiency

• Environmental incidents and complaints

A summary of EPA monitoring and enforcement is also provided.

Raw materials (reagents) and intermediates

Reactor vessel

(suitable temperature and

pressure)

+ solvent Crystallisation

(under cold temperature)

Centrifuge/ Pressure Filter

Dryer

Milling

(optional)

Product

(bagging/drumming for further

processing)

Product crystals


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1.3 Employment

There were 422 staff employed by GlaxoSmithKline at the end of 20091. The plant is a significant employer in the Ringaskiddy region. Figure 1.2 outlines GSK’s organisation for Environmental Management on-site.

Figure 1.2 Environmental Staff Organisational Chart

1 Excluding contract workers.

Site Director

EHS Team Leader

Environmental Regulatory Leader (ERL)

Environmental Operations Technical Leader (EOTL)

Environmental

Analytical

Chemist

Environmental

Engineer

6 x Shift Operators

(2 per shift)

1 Day Operator


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2. ENVIRONMENTAL DATA SUMMARY INFORMATION

2.1 Emissions to Water: Storm Water (Ref. Points SW02 and SW03)

The main point of discharge of surface water runoff from the site to the estuary is reference point SW02. A monitoring chamber is in place which allows for the continuous monitoring of pH and TOC prior to the discharge of surface water runoff at SW02 in accordance with Schedule C.2.3 of the IPPC Licence. Should the surface water pH exceed the limits of 6-9 or the TOC level exceed 200 mg/L, the monitor automatically shuts the valve on the line to the estuary and diverts the run-off to the retention ponds. From there it can be transferred across to the effluent treatment plant for treatment. A new firewater pond was added in 2007, which increased the retention capacity by 23%, to 984,000 gallons (4,473 m3).

Surface water discharged from SW02 is also inspected visually on a weekly basis for colouration and odour in accordance with Schedule C.2.3 of the IPPC Licence. There were no non-compliances related to surface water discharge from SW02 in 2009.

Surface water originating at Car Park A is discharged from point SW03. The discharge is inspected visually on a weekly basis for colouration and odour in accordance with Schedule C.2.3 of the IPPC Licence. There were no non-compliances related to surface water discharge from SW03 in 2009.

Note: SW04 as referenced in Schedule C.2.3 is a redundant, legacy surface water reference point, no longer applicable to the existing site drainage.

2.1.1 Summary Information

For the purposes of this section, an average value for the pH and TOC results of the surface water discharge ex SW02 obtained over each month during 2009 is provided in Table 2.1.

Table 2.1: Emissions to Surface Water (SW02) in 2009; pH and TOC.

Month pH TOC (mg/L)

January 7.2 21.1

February 7.4 18.9

March 7.5 36.8

April 7.5 16.1

May 7.3 33.1

June 7.5 14.9

July 7.5 34.1

August 7.5 23.2

September 7.4 28.5

October 7.7 35.9

November 7.7 25.2

December 7.2 48.2


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2.1.2 Trend Analysis

Figures 2.1 and 2.2 below show the trend analysis for the emissions to surface water during 2009.

6

6.5

7

7.5

8

8.5

Jan Feb Mar April May June July Aug Sept Oct Nov Dec

Month

pH

2005

2006

2007

2008

2009

Figure 2.1 Comparison of pH of Surface Water Discharge ex SW02 (2005 to 2009)

0

20

40

60

80

100

120

Jan Feb Mar April May June July Aug Sept Oct Nov Dec

Month

TO

C (

mg

/L)

2005

2006

2007

2008

2009

Figure 2.2 Comparison of TOC level of Surface Water Discharge ex SW02 (2005 to 2009)


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2.1.3 Surface Water Diversions

In 2007, the EPA requested that GSK report its diversions from surface water discharge to retention. The current arrangement, as explained in Section 2.1 above, is that surface water is continuously monitored for pH and TOC and non-compliant material is not discharged but directed to the surface water retention ponds and thence to the wastewater treatment plant for treatment. Hence non-compliant surface water is not discharged and there is no issue of non-compliance. There are two penstock valves operating in series that ensure that no discharge to the estuary occurs when surface water is rerouted for biotreatment.

In 2008, there were 213 diversions of surface water, a reduction of 26% from 2007. A series of measures were implemented in 2008 to reduce the number of diversions to the surface water pond, these measures are discussed in the 2008 AER.

A target was set in the EMP for 2009 to reduce the frequency of diversions to the surface water retention ponds by 20% in 2009. The target for 2009 was achieved as there were 120 diversions of surface water, a further reduction of 44% from 2008. These figures are illustrated in Figure 2.3. This improvement was achieved by increasing awareness of the issue with all site teams in addition to reduced plant activity.

Figure 2.3 Surface Water Diversions 2007 to 2009

For the surface water effluent leaving the site, a target was set in the EMP for 2009 that the TOC of the surface water from site be <40 mg/L in 2009, and to maintain awareness of surface water quality across the site. The target for 2009 was achieved as the average TOC content of surface water discharged

0

50

100

150

200

250

300

350

Jan

Feb Mar

Apr

May

June

July

Aug

Sep

tOct

Nov D

ec

2009

2008

2007

Surface Water Diversions 2009

55%

45%

pH

TOC


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from the site at SW02 was 28.0 mg/L. It is planned to further reduce the TOC level in 2010.

2.2 Emissions to Water: Treated Effluent (Ref. Point SW01)

Process and foul effluents arising on site are treated in the on-site wastewater treatment plant. The treated effluent is then discharged into Lough Beg, Cork Harbour from reference point SW01. Two pump-outs are normally discharged each day, 30 minutes after each high tide. Effluent was pumped out on 335 days in 2009.

A daily 24-hr composite sample of the treated effluent is analysed for a variety of parameters. All parameters are monitored in accordance with the requirements of Condition 6 and Schedule C of the IPPC Licence. The sample is analysed for COD and suspended solids on a daily basis, weekly for BOD*, nitrates, total ammonium and phosphate. Organic solvents* are monitored on a quarterly basis, dioxins* on a bi-annual basis, and total heavy metals* and toxicity* on an annual basis.

Note: * denotes that the parameter is analysed by an accredited external contractor.

2.2.1 Summary Information

Table 2.2 below summarises the emissions to SW01 in 2009.

Table 2.2: Emissions of Treated Effluent (Ref. Point SW01)

Parameter 2008 2009 Max. Licensed

Emission % Compliance

in 2009

Volume (m3/yr) 138,397 128,832 474,500 100

pH (average) 8.16 8.16 6-9 100

COD (kg/yr) 25,860 20,742

949,000 100

Suspended Solids (kg/yr) 1,810 2,396 118,625 100

BOD (kg/yr) 803 747 142,350 100

Nitrates (as N) (kg/yr) 374 140 7,118 100

Total Ammonium (as N) (kg/yr) 166 129 23,725 100

Phosphate (as P) (kg/yr) 787 611 7,118 100

Copper (kg/yr) 1.1 4.9 237 100

Zinc (kg/yr) 6.2 12.8 475 100

Toxicity (TU) <3.1 <3.1 10 100

TOC (kg/yr) 11,386 7,653 - -

Incin. 1 0.03 0.5 300 100 Dioxins in scrubber liquor: average conc.

(pg/L ITEQ) Incin. 3A

0.26 0.6 300 100

Note that the mass emission of suspended solids of 2,396 kg in 2009 is equivalent to 2% of the total mass emission permitted under the licence. The issue of high total suspended solids arising in the incineration quench water (refer to Section 2.3.1) does not result in a high suspended solids content in the final effluent actually discharged from the site at SW01.


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Figures 2.4 and 2.5 illustrate the trend analysis for emissions of treated effluent to the estuary from SW01 for the years 2005 to 2009.

0

10000

20000

30000

40000

50000

60000

70000

Ma

ss

Em

iss

ion

s (

Kg

/Yr)

COD Suspended Solids TOC BOD

Parameter

2005 2006 2007 2008 2009

Licenced Mass Emission

949000 kg/yr


118625 kg/yr


N/A


142350 kg/yr

Figure 2.4 Comparison of Mass Emissions to Estuary (SW01) 2005 to 20092

0

200

400

600

800

1000

1200

1400

1600

1800

Mas

s E

mis

sio

ns

(K

g/Y

r)

Nitrates (as N) Phosphate (as P) Total Ammonia (as N) Zinc Copper

Parameter

2005 2006 2007 2008 2009


7117.5 kg/yr


7117.5 kg/yr

Licenced Mass

Emission 23725 kg/yr


474.5 kg/yr


237.25 kg/yr

Figure 2.5 Comparison of Mass Emissions to Estuary (SW01) 2005 to 2009

2 Note: 12 readings for TOC per annum versus daily for COD & SS and weekly for BOD.


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2.2.3 Treated Effluent Non-Compliances

There were no non-compliances in emissions of treated effluent from SW01 with respect to Schedule B.2 of the licence during 2009.

2.3 Wastewater from Incineration Activities (Ref. Point W1)

Incineration waste water is monitored at ref. point W1 and then combined with other treated effluent from the wastewater treatment plant prior to leaving the site as final effluent. Emissions at W1 are subject to Schedule B.2 of the IPPC Licence. The emissions are monitored for a selection for parameters as shown in Table 2.4 below. Monitoring for these parameters began in July 2007 with the issue of the current IPPC licence.

Table 2.4 Monitoring of incineration wastewater at W1

Parameter Average Value in

2008 mg/L

Average Value in

2009 mg/L

Licensed Emission Limit Value

% Compliance

pH 7.55 - -

Flow rate 261.26 m3/d 197.84 m

3/d 600 100

Total suspended

solids

20.64 25.83 45 mg/L for 100% of measurements, and 30 mg/L for 95% of

measurements

95

Hg <0.01 0 0.03 mg/L 100

Cd <0.01 0 0.05 mg/L 100

Tl 0.01 0.0004 0.05 mg/L 100

As <0.01 0.00094 0.15 mg/L 100

Pb 0.01 0.00099 0.2 mg/L 100

Cr 0.052 0.0595 0.5 mg/L 100

Cu 0.03652 0.0126 0.5 mg/L 100

Ni 0.03182 0.0482 0.5 mg/L 100

Zn 0.02 0.0286 1.5 mg/L 100

Dioxins/furans (TEQ)

0.0797 ng/L 0.0006 ng/L

0.3 ng/L 100

2.3.1 Details of Non-Compliances

There were 17 non-compliances in 2009 with Schedule B.2 of the licence with respect to incineration waste water emissions at W1. These are detailed in Table 2.5 below. All relate to a high content of Total Suspended Solids (TSS).

During 2009, the main causes of TSS content were:

� Water hardness (primarily CaCO3);

� Swings in pH when burning Dichloromethane (DCM)


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� Shedding of inert incinerator firebrick as a consequence of normal operation (comprising principally insoluble aluminium oxide and silicon dioxide, with some iron oxide); and

� Carbonaceous soot in quench water whereby steady state conditions arose in the incinerator firebox due to blockages in waste tanks

These non compliances give a result of 95% compliance with the IPPC Licence. Condition 4.5.1 of the licence requires 95% compliance with the emissions limit value of 30 mg/L for total suspended solids.

Table 2.5 Non-compliances related to incineration quench water at W1 in 2009

Date Monitoring Frequency

Parameter Limit mg/l

Non-Compliance

mg/l

1 10/01/2009 Daily Sample TSS 45 117.5

2 11/01/2009 Daily Sample TSS 45 99.6

3 14/01/2009 Daily Sample TSS 45 129.6

4 16/03/2009 Daily Sample TSS 45 61.7

5 17/03/2009 Daily Sample TSS 45 56.2

6 19/03/2009 Daily Sample TSS 45 51.9

7 26/03/2009 Daily Sample TSS 45 80.2

8 27/03/2009 Daily Sample TSS 45 67.1

9 28/03/2009 Daily Sample TSS 45 70.2

10 29/03/2009 Daily Sample TSS 45 74.0

11 10/10/2009 Daily Sample TSS 45 46.1

12 26/11/2009 Daily Sample TSS 45 113.4

13 27/11/2009 Daily Sample TSS 45 286.94

14 28/11/2009 Daily Sample TSS 45 261.4

15 29/11/2009 Daily Sample TSS 45 95.5

16 30/11/2009 Daily Sample TSS 45 73.4

17 01/12/2009 Daily Sample TSS 45 71.5

During 2008, a number of items were progressed by GSK to reduce the TSS levels in this stream and these measures are summarised in the 2008 AER. GSK continued to progress these measures in 2009:

Conclusions regarding TSS at W1

1. GSK acknowledges TSS above ELVs at W1 likely to occur due to water hardness and incineration firebrick shedding despite operational adjustments;


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2. The contents of the firebrick will not cause an adverse impact on the aquatic environment;

3. GSK Cork will manage the suspended solids levels in the incineration quench waters to minimize as much as possible.

4. The incineration waste water joins with other waste water streams to form the final effluent from the site. The final effluent is typically at a level of ~10% of the ELV (250mg/L) and no TSS non compliances occurred in 2009.


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2.4 Emissions to Atmosphere

Monitoring and analysis of emissions to atmosphere is carried out in accordance with Conditions 4 and 5 and as specified in Schedule B.1 of the IPPC Licence. The main emissions to atmosphere from the site are from the emission points listed in Table 2.6 below. Note that the reference point naming/numbering convention has been changed in the new IPPC Licence.

Monitoring of emissions to atmosphere was carried out during normal plant operating conditions. Quarterly sampling of hydrogen fluoride and hydrogen bromide from A2-1 and A2-3(A) is carried out over 30 minute sampling intervals. Annual sampling of particulates from API particulate vents is carried out over 2-hour sampling periods. An external contractor is commissioned to sample dioxins annually from A2-1 and A2-3(A).

Table 2.7 summarises the emissions to atmosphere during 2009. Note that the thermal oxidiser (ref. point A2-15) was not in use during 2009. The licence allows for a second thermal oxidizer (A2-16), which has never been installed.

Particulate vents listed in Table 2.6 were sampled once during the year as required by Schedule B.1 of the IPPC Licence. All results with the exception of A2-10 (refer to Table 2.8) were found to be below the emission limit value of 1mg/m3 for total particulates and all results were found to be below the emission limit value of 0.15 mg/m3 for active pharmaceutical ingredients (API).

Bypass events

During periods where the incinerator is being bypassed, the emissions to atmosphere are vented via a scrubber (SCR1901) at the emission point (formerly termed Vent 3B). The total mass of VOCs emitted during bypasses in 2009 was 1147.9Kg during 77hours 4min of bypass.

In fulfillment of Agency bypass requirements, while on bypass the solvent emissions are monitored by an online continuous monitor and processes will be controlled in order to ensure the relevant air quality limits are adhered to. A dispersion model uses the information from the online analyser and the predicted ground level concentration (GLC) is to be compared with GLC limits i.e. WHO, OEL/42 or Danish C.

An automated viewer is used for environmental operators to monitor solvent emissions during bypass events and will guide operations supervisors if emissions need to be controlled by process shutdown.

The agency is notified of each significant (>1hour) bypass event. Process operations are shutdown after 90 minutes in any event until incineration capability can be re-established. The agency will also be notified of any significant emission as follows:

>25% < 50% GLC Limits – Category 3 Incident

>50% < 100% GLC Limits – Category 2 Incident

>100% GLC Limits – Category 1 Incident

The Agency is furnished with a quarterly summary of all bypass event details. While bypass capability is a key safety feature in incineration/thermal oxidizer operation, root causes of bypass events are addressed with a view to preventing reoccurrence & maximizing incineration uptime. CAPAs (Corrective


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Action & Preventative Actions) resulting from these investigations are managed on the site Environmental Incident tracker.


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Table 2.6 Monitoring of Emissions to Atmosphere

Schedule B.2 Parameters Emission

Point

Emission point ref.

Continuous Quarterly Annual

Incinerator 1 A2-1 TOC, total particulates, CO, HCl, SOx, NOx (as

NO2)

HF, HBr Dioxins (as TEQ), heavy metals

Incinerator 3A A2-3A TOC, total particulates, CO, HCl, SOx, NOx (as

NO2)

HF, HBr Dioxins (as TEQ), heavy metals

Particulate vents A2-10, A2-12, A2-13, A2-14, A2-112, A2-116, A2-123, A2-124, A2-128, A2-126, A2-128, A2-146, A2-149, A2-150, A2-162, A2-163,

A2-166, A2-301, A2-303, A2-308, A2-316, A2-317, 2-318, A2-319, A2-320, A2-325, A2-328, A2-338, A2-339, A2-340, A2-341, A2-342, A2-343, A2-344, A2-345, A2-346, A2-347, A2-348, A2-351,

A2-352.

None None Pharmaceutical dust & total particulates


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Table 2.7 Mass Emissions to Atmosphere

Average concentration (2009)

Parameter

(mg/m3 ) Emission

point

A2-1

Emission point

A2-3A

Mass Emissions

(kg/yr) (2008)

Mass Emissions

(kg/yr) (2009)

% Compliance

3

Particulates 0.01 0.02 0.58 0.6 100

SOx 1.67 0.06 3.6 43.75 100

NOx 39.84 72.25 5491 2261.89 99.99

CO 2.83 0.01 13.11 72.56 99.99

VOC, expressed as TOC

0.03 0 4.75 0.77 100

HCl 0.06 0.08 0.35 2.91 100

HF 0.05 0.05 6.39 2.23 100

HBr 0.17 0.28 8.23 9.13 100

Cd, Tl and their compounds

0.001 0.0102 0.0198 0.201 100

Hg and its compounds

0.005 0.0005 0.0198 0.021 100

Other metals4 0.028 0.238 0.0198 4.79 100

Dioxins/furans (as TEQ) (ng/m

3 )

0.0564 0.0034 0.0198 1.4997 E-06 100

Operating hours during 2009 (hrs)

4747 2974 - - -

2.4.1 Details of Non-Compliance

During 2009, there were three non-compliances with the IPPC Licence relating to emissions to atmosphere, as detailed below in Table 2.8. The compliance rating for the year was > 99.99 %.

3 The IPPC Licence has ten-minute, dual half hour, and daily average limits that preclude calculation of one catch all annual

limit for any measured parameter. % compliance of the monitoring results with the Licence Conditions is considered a more meaningful figure. 4 Other metals = Sb, As, Pb, Cr, Co, Cu, Mn, Ni, V and their compounds.


Page 21

Table 2.8 Non-compliances related to atmospheric emissions in 2009

Date Licence Condition

or Schedule

Period Emission Point Ref.

Parameter Limit Non-Compliance Root Cause CAPA CAPA Status

24th

Mar 2009

Schedule B.1

30min A2-1 CO 100 mg/m

3

CO 30min 105.99 mg/m

3.

Incinerator start-up with unusually large CO release.

Proceduralise a lab precipitation test for waste streams which have high inorganic salts (>5%).

Complete 23

rd Sep.

2009

23rd

April 2009

Schedule B.1

- A2-10 Total Particulates

Pharmaceutical Dust – as

active ingredient

1 mg/m

3

0.15 mg/m

3

Total particulates from dust vent A2-10 was 17.09 mg/m

3.

No pharmaceutical dust detected.

Analysis indicated that the material was rust from the vent shaft.

Decommission vent A2-10.

Complete 31

st Oct.

2009.

18th

Dec 2009

Schedule B.1

30min A2-1 NOx 400 mg/m

3

NOx level of 409.7 mg/m

3 on Incin

No.1.

NOx levels drifted to non-compliant level during 22.30 to 23.00 pm. Root cause appeared to be run out of ammonia feed to deNOx on Incin. No. 1.

Amend incinerator No.1 “HIMA” alarm system to sound and display independently of other HIMA alarms. The alarm is to remain on until the low level ammonia has been resolved.

Complete Feb. 2010


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The mass emissions for emissions to atmosphere from A2-1 and A2-3A during 2009 are compared directly with the mass emissions for previous years in Figures 2.6 to 2.8 below. The trend of decreasing mass emissions to atmosphere is related to a decrease in production levels at the site.

0.00

2,000.00

4,000.00

6,000.00

8,000.00

10,000.00

12,000.00

14,000.00

16,000.00

18,000.00

NOx

kg

/yr

2005

2006

2007

2008

2009

Figure 2.6 Comparison of Mass Emissions to Atmosphere 2005 to 2009

0

100

200

300

400

500

600

700

800

900

1000

Particulates SOx CO VOCs as TOC

kg

/yr

2005

2006

2007

2008

2009



Page 23

0

50

100

150

200

250

HCl HF HBr

Parameter

kg

/yr

2005

2006

2007

2008

2009


2.4.3 Validation of Atmospheric Emission Monitoring Systems

GSK has carried out the quality assurance testing in line with the European Air Emissions Standard IS E.N. 14181. The testing of the Automated Monitoring System (AMS) or Continuous Emissions Monitoring System (CEMS) is to test the validity of the monitoring data from incineration/thermal oxidiser monitors.

Quality Assurance Level 2 (QAL2) testing has been completed and the results are compliant with the regulation requirements. A report has been submitted to the Agency.

GSK will carry out AST (Annual Surveillance Testing) in May of 2010 as required by IS EN 14181. The program for testing over the coming years is as follows:

Year 2010 2011 2012 2013 2014

Test AST AST QAL2 AST AST

2.5 Waste Management

2.5.1 Waste Generation and Fates

In accordance with the EPA’s Guidance Note for Annual Environmental Reports and Condition 11.9 of the IPPC Licence, a record of the types, quantities and fates of all hazardous waste streams arising on site in 2009 is included as Appendix B. A record of all non-hazardous waste streams generated onsite in 2009 is included as Appendix C. The main figures are also included in the electronic AER Returns Worksheet to be submitted to the EPA separately, a copy of which is included in Appendix F.


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Figure 2.9 compares the quantities of hazardous and non-hazardous wastes generated onsite for the years 2005-2009. The decrease in amount of hazardous waste generated in 2009 from 2008 (hazardous waste is down ~4,000 T compared to 2008) is attributed to a 60% decrease in production levels at the site. The increase in amount of non-hazardous waste generated in 2009 from 2008 (non-hazardous waste is up ~ 900 T) is attributed to an increase in construction activity and in particular with demolition projects in Buildings 101 and 120 during 2009. It is noted however, that 76% of non hazardous waste was sent for recycling or recovery in 2009.

2470.52

25101.23

5594.692

20154.168

7601.24

21070.24

1217.45

12042.428

2138.54

8066.62

0

5000

10000

15000

20000

25000

30000

Tonnes

2005 2006 2007 2008 2009

Non-hazardous waste Hazardous waste

Figure 2.9 Waste Generation 2005-2009

Figures 2.10 and 2.11 illustrate the percentage breakdown of each waste stream generated on-site. For summary purposes, the hazardous waste streams are categorised into disposal/recovery routes.


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Glass, 0.07% Food waste, 0.17%

Cooking Oil, 0.11%

Cables, 1%

Paper and Cardboard, 5%

Tarmac, 6%

Timber, 4%

Steel, 15%

Mixed Waste for Landfill, 2%

C&I Dry Mixed Waste, 5%

WWTP sludge, 17%

Dry Mixed Recyclables, 0.40%

C&D Waste, 45%

Figure 2.10 Breakdown of Non-Hazardous Waste Streams in 2009


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R1, Use as a fuel

29%

D10, Incineration

64%

R4, Recovery of metals

0.32%

D9, Physico-chemical treatment

0.13%

D13, Blending or mixing prior to

disposal

0.28%

R2, Solvent recovery

7%

Figure 2.11 Breakdown of Hazardous Waste Fates 20095

5 Of the hazardous waste that is disposed of via D10 incineration, approximately 60% is disposed of via incineration with heat recovery.


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2.5.2 Waste Minimisation Indices

Key annual waste management data for the period January to December 2009 is presented in Table 2.9 below:

Table 2.9 Waste Management Data Required for Calculation of Indices

Period Jan-Dec 2009

Raw Materials Usage (tonnes)5 2,680

Waste Produced (tonnes) 10,205

Waste Recovered (tonnes) 4,599

Off-Site Recovery (tonnes) 1,932

On-Site Recovery (tonnes) 2,666

Note that the figure for on-site recovery includes solvent waste partially recovered on-site as steam (2,372 T in 2009).

Figure 2.12 illustrates the trend in the waste management data between 2005 and 2009.

0.00

5,000.00

10,000.00

15,000.00

20,000.00

25,000.00

30,000.00

Qu

an

tity

(T

)

Raw Materials

Usage

Waste Produced Waste Recovered Off-site Recovery On-site Recovery

2005 2006 2007 2008 2009

Figure 2.12 Comparison of Waste Management Data 2005 to 2009

5 Includes solvent.


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The following indices have been calculated for the period January to December 2009:

Gross Waste Minimisation Index (Gross WaMI)

= 100× MaterialsRaw

Produced Waste

= 1002680

10205×

= 381

Nett of Process Waste Minimisation Index (Nett of Process WaMI)

= 100× MaterialsRaw

Site-On Recovered Amount - Produced Waste

= 1002680

266610205×

−

= 281

Nett of Site Waste Minimisation Index (Nett of Site WaMI)

=

100× MaterialsRaw

Site-Off Recovered Amount -Site-On Recovered Amount - Produced Waste

= 1002680

1932266610205×

−−

= 209


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Figure 2.13 illustrates the trend in the waste management indices between 2005 and 2009:

Figure 2.13 Comparison of Waste Management Indices 2005 to 2009

0

50

100

150

200

250

300

350

400

450

2005 2006 2007 2008 2009

Year

Gross WaMI Nett of Process WaMI Nett of Site WaMI

Figure 2.13 Comparison of Waste Management Indices 2005 to 2009.

2.5.3 Rejected Consignments of Waste

There were no rejected consignments of waste reported in 2009.

2.5.4 Waste Analysis

368.32 tonnes of dewatered WWTP sludge was collected and removed off-site during 2009. Table 2.10 summarises the quarterly and annual monitoring results for dewatered sludge as required by Schedule C.4 of the IPPC Licence. Heavy metals, organic matter and water content are analysed on a quarterly basis and organic compounds annually by an accredited external contract laboratory.


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Table 2.10 Dewatered WWTP Sludge Analysis 2009

Parameter Jan/09 May/09 July/09 Oct/09 Annual

Sludge solids (%w/w) 13.2 12.6 12.46 17.7 -

Organic Matter (%w/w)6 97.8 98.44 98.31 96.94 -

Water Content (%w/w)7 86.8 87.4 87.5 82.29 -

Cadmium (µg/L) 0.46 0.42 0.34 1.08 -

Chromium (µg/L) 3.18 11.9 24.3 2.78 -

Copper (µg/L) 8.40 18.8 27.0 34.1 -

Lead (µg/L) 0.78 1.78 1.93 1.09 -

Mercury (µg/L) <0.06 <0.12 0.18 <0.06 -

Nickel (µg/L) 27.4 31.7 55.0 46.3 -

Zinc (µg/L) 721 1160 659 4570 -

VOCs (mg/L) - - - - 2.26

Semi-VOCs (mg/L) - - - - 0.311

Alcohols (mg/L) - - - - 11.70

- Indicates that no analysis was carried out for that particular parameter.

2.5.5 Analysis of Aqueous Wastes for Incineration

Aqueous waste for on-site incineration is stored in the tanks TK1327, TK1328, TK1354, TK1381 and TK1382. The contents of each tank are analysed on an annual basis for organic solvents, metals, calorific value and water content in accordance with Schedule C.4 of the IPPC Licence.

Where the contents of the tank contain immiscible liquids or layers, a sample from each layer is taken. Samples from the tanks were taken on 30th March 2009 and a summary of the results is presented in Table 2.11. No layering was observed in the contents of the five tanks on this occasion. The presence of a high water content in wastes sent for incineration onsite is the subject of a Waste Accountability project underway as part of the site’s Energy Management System, discussed elsewhere in this report.

6 100% minus Residue on ignition.

7 100% minus Sludge solids content.


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Table 2.11 Analysis of Wastes for On-site Incineration 2009

Parameter TK1327 TK1328

TK1354 TK1381 TK1382

Date of sample

30/03/09 30/03/09 30/03/09 30/03/09 30/03/09

VOCs (g/L) 840.0 459.0 77.0 895.0 403.0

Metals (mg/L) 12,944 916.0

Calorific Value (KJ/Kg)

27,514 Not combustible

Not combustible

30,514 Not combustible

% Water Content

15.36 53.49 90.97 9.37 60.36

% Halogenated solvent (average)

0.11 0.18

2.5.6 Total Waste Management (TWM) Programme

Since March 2005, Indaver Ireland has managed the shipment of all waste (both hazardous and non-hazardous) leaving the site. This Total Waste Management (TWM) approach has led to a reduction in the volume of waste going for disposal. It is GSK’s intention to continue to reduce the amount of waste disposed of off-site to landfill and incineration abroad in 2009. A number of actions are being implemented on-site via the TWM system to further improve waste management and disposal methods. These include:

• Baling of waste liners

Indaver implemented a Waste Labelling and Bailing Project in February 2009. Full onsite training was conducted with operators and the infrastructure was set up to accommodate the project. Significant benefits have been observed from analysis of data from 2009. Whilst production volumes were down, a significant reduction in the amount of “unknowns” were noticed (1.26 drums of waste per batch in 2008 versus 0.26 drums per batch in 2009), reducing GSK’s costs. Also, because compatible/suitable waste liners are baled onsite in the Waste Management Facility, a significant reduction was observed in the amount of steel drums being sent offsite part full and this in turn has resulted in a reduction in the amount of freight containers being sent offsite.

• Redirecting of Waste Solvent onsite

Waste solvents which were previously sent offsite for incineration are now redirected for onsite treatment. Resulting in a reduced volume of drums being sent offsite for treatment with the added bonus of less freight containers being shipped. The empty drums are sent for cleaning to Rilta. Waste Management controls the monitoring and logistics of waste movement to the Environmental facility onsite.


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• Indascan Project

Indaver Belgium have proposals to install a scanning system whereby all waste will be labelled at source of creation and on this label is placed a barcode. This barcode can then be scanned and fed back to a central tracking system, giving a real-time analysis of what waste is onsite at any given time. This will give transparency and facilitate compliance to the Waste Management Operations allowing real time feed back. Initial work has been completed on the software design with work left to complete on allocating business units to all the waste streams.

• Office Waste Reduction

A bin-less office system continues to be implemented on site. All materials are segregated at source by staff into streams for recovery, recycling or residual material for landfill.

• Food waste/Dry Mix Recyclables

Foodwaste continues to be segregated from dry mixed recyclables (DMR) at source and proposals are in place to implement a standalone compacter which will compact the wet matter and leave only dry matter. This will in turn reduce GSK’s costs for weight disposal. The compactor in turn can be used to compact DMR Waste which in turn will reduce collection dates and costs to GSK.

• Manpower

Indaver now provides a full-time personnel resource on site to manage the TWM programme at the GSK site.

• Sample Testing and Analysis

Indaver now provides a GCMS analysis in their Transfer Station in Dublin, for all solvent analysis required for tanker offsite disposal. This has significantly reduced the costs associated with analysis and also enhanced the ability to analyse for unknowns which was not available previously.

• Confidential Shredding

TWM reviewed the Confidential Shredding Operation onsite in 2009 and successfully streamlined operations with Cork Confidential Shredding (CCS). Significant cost savings were noticed in a direct benefit to GSK.

2.5.7 Audits of Waste Management Facilities

During 2009, GSK audited the following waste management facilities as outlined in Table 2.12.


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Table 2.12 Waste Management Facilities audited in 2009

Audit conducted by

Facility Name

Location Facility Type

Conclusion

Gary Hanniffy, Pat Walsh -GSK

Eros Eco Foxhole,

Youghal,

Co. Cork

Sludge Drying Facility

The site is to be used for drying the waste sludge from GSK Cork's WWTP. The audit consisted of a site tour and open discussions. The site area is modern, clean and well presented by staff. Issues addressed included the number of odour complaints received by the site ~10 in 2009. This has resulted in non-compliances in EPA audits in the past year. While there appears to be some odours coming from the neighbouring landfill, there have been operational difficulties with the odour abatement system at Eras. Elevated ammonia levels have been recorded exiting the system, which is monitored by regular lab testing . Findings/Recommendations: Eras should continue to carry out regular ammonia tests. Performance charts should be used to track condensate pH & ammonia - This will improve awareness & help to link source of high ammonia levels with specific unit operations or waste load. Ammonia drager analysis should use suitable resolution. It was felt that there was sufficient technical competence to overcome the challenges faced by the site. GSK started sending waste sludge to Eras in December 2009.

As indicated in the Environmental Management Programme for 2010 (Appendix D), it is GSK’s intention to audit further waste management facilities in 2010.

2.6 Noise

Condition 6.12 of the IPPC Licence requires that a noise survey of the site operations be carried out annually and a summary of the results be submitted as part of the AER.

An external consultant carried out a noise survey of the site on the 13th and 14th of October, 2009. The night-time survey was carried out on the 13th/14th of October and the daytime survey was carried out on the 13th October. The facility was in normal production during the periods of survey. Table 2.13 below outlines the results obtained.

Schedule B.3 of the IPPC Licence sets a daytime noise limit of 55 dB (A) and a night-time noise limit of 45 dB (A) at the nearest noise sensitive locations


Page 34

(LAeq 30 minutes). Measurements were taken at the same noise-sensitive locations as per previous noise surveys, i.e. locations N1 to N4 and N5, a residence located to the west of N1. In summary, the noise levels recorded at noise sensitive locations during 2009 were well within the IPPC Licence limits of 55 dB (A) daytime and at night-time, four of the five monitoring positions were well within the permitted limit of 45 dB (A) LAeq. At monitoring position N2 (adjacent to a residential dwelling on the beach to the north of GSK), the total ambient night-time noise ranged from 45 to 46 dB(A) LAeq. In the absence of noise from birds and wildfowl, the measured noise as N2 was 45 dB(A) LAeq. The ambient noise was determined to arise from the GSK facility and the industrial facility to the east of N2.

It is proposed to undertake a noise survey at N2 during a scheduled plant shut down in 2010 to monitor the noise levels at N2 in the absence of GSK operations and determine the noise contributions at this location from other sources.


Page 35

Table 2.13 Specific noise levels determined at the survey locations during 2009.

Specific Noise Level dB(A)

(Industrial component of noise)

Location Daytime

(Limit: 55 dB(A))

Night-time

(Limit: 45 dB(A))

N1 51 Intermittent noise from

overflying aircraft, road traffic and birds dominant.

30

Intermittent noise from water fowl and barking dogs. Low level broadband industrial

noise audible.

N2 48

Intermittent noise clearly audible, generally broadband.

Some distant construction noise also audible and

intermittent noise from birds.

45-46*

Industrial noise from GSK facility and facility to the east clearly audible – broadband

and no tonal or impulsive elements. Intermittent noise

from water fowl/sea birds.

N3 39-64*

Intermittent Noise from passing traffic. Amplified

music from adjacent property.

32-49*

Industrial noise from GSK facility audible – broadband and no tonal or impulsive

elements. Some extraneous noise from road traffic and

water fowl/sea birds.

N4 47

Intermittent noise from children, dogs, road traffic and birds dominant. Some low level continuous noise

also audible.

34

Intermittent noise from water fowl. Low level broadband industrial noise also audible

(noise source towards western position)

N5 (Residence

near N1) 44

Intermittent noise from cattle, road traffic and birds

dominant. Some low level continuous noise also

audible.

34

Intermittent noise from water fowl and dogs. Low level

broadband industrial noise also audible.

* additional readings were taken with shortened sample times to minimize extraneous noise

There was one complaint in relation to noise during 2009. On the morning of 30th May 2009, a local resident complained about noise. Investigation showed that the fire alarm was found to have problems with interference being induced into the circuits. Loose connections within the panel were found to be the root cause. Two junction boxes were replaced. The complainant was informed of the root cause and corrective action and no further complaints were received.


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2.7 Resource Consumption and Energy Efficiency

2.7.1 Resource Consumption

There are two sources of energy predominantly used on site: electricity and natural gas. Energy and water usage for the site for the period January to December 2009 are given in Table 2.14.

Table 2.14 Resource Consumption 2009

Diesel*

(m3/yr)

Natural Gas8

(m3/yr)

Mains Water

(m3/yr)

Electricity

(MWh)

73.0 3,823,936 236,812 33,473

* Note: Figure for diesel includes transport and non-transport figures.

Table 2.15 below compares the resource consumption levels from 2005 to 2009. Mains water and electricity usage have reduced significantly due to a reduced production demand and improved control and metering. A Waste Accountability project contributed to a reduction in natural gas consumption in 2009 (Ref. Section 2.7.5 and EMP Progress Report 2009 – Appendix E).

Table 2.15 Trend in Resource Consumption

2005 2006 2007 2008 2009

Diesel (m3/yr) 170.5 138.5 141 193 73.0

Mains Water (m3/yr) 475,590 461,829 455,298 331,344 236,812

Electricity (MWh) 54,641 52,491 55,664 46,799 33,473

Natural gas (m3/yr) 4,633,463 4,435,796 3,852,183 4,440,037 3,823,936

Product (1°°°° intermediate) (kg)

1,044,460 725,480 687,540 297,000 126,000

2.7.2 Energy Consumption

The site’s energy usage is broken down as follows in Table 2.16, in accordance with the EPA’s Guidance Note on Energy Efficiency Auditing.

8 It is assumed that 10.8 KWh ≡ 1 m

3.


Page 37

Table 2.16 Site Energy Usage for the period 2006-2009.

Period: 2006 2007 2008 2009

Energy Stream Units Annual Quantity

Annual Quantity

Annual Quantity

Annual Quantity

Electricity Consumed On site

kWh 52,491,056 52,663,589 46,798,865 33,473,265

Electricity Imported

kWh 52,491,056 52,663,589 46,798,865 33,473,265

Electricity Generated On site (CHP sites only)

kWh 0 0 0 0

Electricity Exported offsite (CHP sites only)

kWh 0 0 0 0

Natural Gas Total kWh (Gross CV)

47,906,597 41,603,578 47,952,396 40,894,704

Natural Gas for CHP

kWh (Gross CV)

0 0 0 0

Gasoil Litre 0 0 0 0

LPG Litre 0 0 0 0

Light Fuel Oil Litre 0 0 0 0

Medium Fuel Oil Litre 0 0 0 0

Heavy Fuel Oil Litre 0 0 0 0

Other – please specify: Diesel

Litre 138,456 141,000 193,000 73,000

2.7.3 Energy Audit

Condition 7.1 of the IPPC licence requires GSK to audit the energy efficiency of the site.

During 2009 an SEI consultant conducted a review of the Energy Reduction Programme at GSK Cork in order to identify state of preparedness for EN 16001 certification. Some gaps were identified and these are being closed to enable certification to be achieved during 2010. A key part of the EN 16001 certification is regular internal audits of both the Energy Management System structure and energy efficiency of each significant energy user.

2.7.4 Operational Excellence in Energy Management

A new approach was adopted in 2008 to the tracking and management of energy using the tools of Operational Excellence (“OE”). A Site Energy Council


Page 38

has been established which brings together teams across the disciplines on site to manage energy usage.

During Q4 of 2008, an initial review and analysis of the site’s energy usages was made in order to identify the main energy users on site. This was used to inform the Baseline Event which took place on site during Q1 of 2009 to develop a strategy for energy saving for the year 2009.

A number of projects were identified that will afford significant reductions in energy usage against the baseline once implemented. These are included in the EMP Progress Report for 2009 where already complete and in the programme for 2010 where planned (see Appendices D and E to this AER).

Good progress was made during the year on the projects that were prioritised during the 2009 Q1 Baseline such as:

• Nitrogen System Optimisation

• Refrigeration System Optimistaion

• Waste Accountability and Gas Usage Modelling

• Improved Monitoring and Metering

In June 2009 another OE facilitated Energy Reduction event was held at the site which reviewed progress of the programme and also identified additional energy saving projects and opportunities. The main output of the event was a programme of projects and activities until the end of 2011. A high level audit of the Cork site’s Energy Reduction Programme was also carried out by the Global Manufacturing Supply (GMS) Energy Manager during this event.

2.7.5 Key Energy Management Projects

1. Optimisation of HVAC ventilation rates

This project is intended to reduce the energy usage related to HVAC systems onsite by reducing the number of air changes required and improving equipment efficiency.

Phase 1 of this project focused on areas which delivered a significant cost benefit once improved. Phase 1 was to develop a model of all Production areas on site and their HVAC requirements for air change. The number of air changes required for each production and processing area on site was reduced to the minimum acceptable for health and safety and quality purposes. Variable Speed Drives (VSDs) were fitted on fans and the electrical loads have decreased significantly across the site for HVAC systems as there is less electrical draw from the fans, as well as a decreased steam load over the air heating coils. Phase 1 has been found to be more successful than anticipated so this project was progressed onto the next phase.

Phase 2, progressed and completed in 2009, which rolled this project out over the smaller buildings on site.

2. Waste Accountability Improvement Project


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The Baseline Event held in 2009 to kick off the Operational Excellence approach to Energy Management identified that much of the waste generated on site that is sent to the site incinerators has a high water content. This means that it needs more fuel (natural gas) added to it to make it burn. Various areas of the site were identified where high water content organic waste streams are generated, and these are being addressed as part of a site-wide Waste Accountability Project with the objective of reducing the water content of organic waste sent to the incinerator and a reduction in natural gas consumption. This project was rolled out over 2009.

Following identification of cleaning verification and commissioning as the major sources of undocumented water usage on site, water lifecycle cost awareness training was initiated for those involved in the preparation of cleaning and commissioning documentation. Cleaning and commissioning documentation were updated to enable increased accuracy in the documentation of water usage and routing.

The new documentation was trailed during Q4 2009 and will be rolled out during 2010 with training materials being updated to reflect the new changes. This will enable the Environmental team to identify excessive water usage and deliver a more robust waste model. Quick wins were also identified to reduce water routed to incinerators, such as water for calibration now routed to floor drains and water batches for some processes routed to floor drains.

3. Improved utilisation of site metering systems

The Baseline Event prioritised the areas of energy and resource usage on site to be targeted for optimisation; one of these is the metering of water, electricity and gas usages.

Electricity metering was implemented in all plant areas in 2009 and training has been rolled out to all area owners. The Monitoring & Targeting (M&T) system can generate reports for each area on a daily or weekly basis, this data is currently being used effectively in a number of areas to target reduction in consumption. Natural gas metering is in place and in use for all gas users. M&T reports are generated and reviewed weekly. An analysis of the use of Electricity, Nitrogen and Water was completed for the R&D facility in 2009. Total water usage for the site, against a target value, is also reviewed weekly.

Table 2.17 summarises the implementation costs and associated benefits in terms of energy, money and CO2 emissions from the energy-saving recommendations made in the energy audits.


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Table 2.17: Energy Audit Recommendations

Predicted Annual Energy Savings

Annual CO2

Emissions Saving

Recommendations – Key Energy Management

Projects

Investment Cost

Category9

Payback Period (Year)

(kWh) (€) (Tonne)

Target Completion

Date

Responsibility Comments

Optimisation of HVAC ventilation rates

H 1 3,571,429 500,000 2,275 Phase 1 Completed in

2008

Capital and Projects Group

Reduction in the number of air changes and use of VSDs has decreased electrical loading in

production areas. –

Waste Accountability Improvement Project

M 0.8 3,256,667 130,000 668 Project started in

2009 and will continue in

2010

EHS Team & Energy & Utilities

Champion

The Waste Accountability Improvement project will reduce

the amount of watery waste to be incinerated and deliver gas

consumption saving

Analysis of key utility usage areas by following usage trends in meters

L 0.5 85,714 120,000 46 Project started in

2009 and will continue in

2010

Energy & Utilities Champion

This is a key enabler for tracking energy usage against targets

Optimisation of HVAC ventilation rates – Phase 2

H 1.25 1,871,429 262,000 1,189

Completed in 2009


Reduction in the number of air changes and use of VSDs has decreased electrical loading in

production areas.

Fridge Optimisation H

2.5 1,333,000 190,000 846 Completed in 2009


Fridge is now only supplied to areas of the plant where and

when it is needed.

9 Either no/low cost, medium cost, high cost. No/low cost: €0-50,000; Medium cost: €50,000-150,000; High cost: >€150,000.


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2.7.6 Water Usage and Efficiency

Condition 7.2 of the site’s IPPC Licence requires that GSK identify opportunities for reduction in the quantity of water used on site wherever possible.

Trends of usage in key water usage areas were examined throughout 2009 to identify the nature and location of high usage to identify processes and areas that may be targeted for improvement of efficiency.

Leak testing and repair

During 2008, an examination of water usages across the site identified a major usage by the firewater supply system that was not proportional to use. An external leak investigation contractor was brought in to use ultrasonic equipment to locate any leakages. A below-ground leak of the water supply was identified and was scheduled for repair during Q1, 2009.

A number of major leaks on the underground firewater main were detected and repaired during 2009. This has resulted in a reduction of 56,940 M3/Year in the site’s consumption of mains water. The leak identification and remediation programme will continue during 2010.

Table 2.18 summarises the implementation costs and associated benefits in terms of water and money from the water-saving recommendation made as a result of the site’s Water audit.

Water Reuse Opportunities

In 2010, it is planned to investigate the potential reuse of bioplant effluent and surface water for low grade utilities input. Significant tank capacity will become available in the coming year, which may be used for water storage for feed to the incinerator quench make-up water.


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Table 2.18: Water Audit Recommendation

Predicted Annual Energy Savings

Annual CO2 Emissions

Saving

Recommendations Investment Cost

Category10

Payback Period (Year)

(kWh) (€) (Tonne)

Target Completion

Date

Responsibility Comments

Identify and eliminate water leakage

L 0.25 0 52,000 0 2009 Energy & Utilities

Champion

Major leaks identified and repaired on

firewater main line in

2009

10

Either no/low cost, medium cost, high cost. No/low cost: €0-50,000; Medium cost: €50,000-150,000; High cost: >€150,000.


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2.7.7 Production Efficiency

Condition 7.4 of the IPPC Licence requires the site to undertake an assessment of the efficiency of use of raw materials in all processes, having particular regard to the reduction in waste generated.

1. Reaction Mass Efficiency

The principal products manufactured at GSK Cork have been assessed for process efficiency during research & development. During transfer of each product from R&D to full scale production operations, process efficiency improvement measures are identified. These include solvent recovery viability, process telescoping etc. Table 2.19 shows the Reaction Mass Efficiency (RME) & Mass Productivity both including and excluding water for each process assessed. Mass intensity reflects the contribution of each raw material in producing one kg of product. Mass Productivity is a percentage reciprocal of the mass intensity. Effectively: the higher the mass efficiency, the leaner the process. Reaction Mass Efficiency (%) is an assessment of the efficiency in converting key reactants only (molecule-forming functionalities) to kg of product.

Table 2.19 Mass Efficiency

Product Mass Productivity (%)

Lapatanib11 2.0

Abacavir 2.3

Ropinirole 0.6

Eltrombopag 1.1

Horizant 2.0

These figures are continually assessed by GSK Corporate with an objective of carrying out specific efficiency improvement projects in line with business plans. Process chemistry and solvent recovery improvements will improve process efficiency.

11

Lapatanib stages 2, 3 & 4 currently manufactured at Cork.


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2. Re-use of Recovered Solvents

All products currently made on site have been evaluated for solvent recovery opportunities. Toluene and IPA are currently recovered on-site at GSK Cork for reuse on-site. Tetrahydrofuran is recovered off-site for reuse on-site.

• Toluene is recovered from two stages of production. Recovered toluene can replace up to 100% of the toluene used in this production process. In 2009 115MT of Toluene was recovered on-site. 52.8MT was used on plant; this made up one third of the demand for Toluene in the process from which it can be recovered. This 52.8MT of recovered toluene represents 11.8% of the total toluene usage on site in 2009.

• Isopropanol (IPA) is recovered from and reused in a single stage of production (API). 179.5MT of IPA was recovered on-site in 2009. 103.6MT was reused on plant, representing a 30% replacement of IPA requirements for the process.

• Tetrahydrofuran is recovered off-site by a third party in the UK. The material is recovered from two stages of a process for reuse in three stages of the process. FDA, NDA and IMB filing for use in all three stages of the process was completed and approved in late 2009 for implementation in 2010. In 2009 267MT of foul THF was collected and shipped to the UK. 26MT of recovered THF were returned to site for reuse on plant. Due to carry over of stock from 2008, a total of 53.6MT recovered THF was reused on site in 2009, replacing 17% of the total THF usage with recovered material. 151MT of foul material were sold to the third party.

.

Solvent Usage GSK Cork 2009

IMS

23.40%

IPA

31.68%

MDC

3.93%

THF

11.53%

Recovered THF

2.39%

Toluene

17.50%

Pyridine

0.59%

Methanol

0.28%

n-Heptane

0.43% Recovered IPA

4.61%

Acetonitrile

0.97%

Ethyl Acetate

0.18%

DMEA

(Dimethylethylamine)

0.16%Recovered Toluene

2.35%

Acetonitrile

DMEA (Dimethylethylamine)

Ethyl Acetate

IMS

IPA

Recovered IPA

n-Heptane

MDC

Methanol

Pyridine

THF

Recovered THF

Toluene

Recovered Toluene

Figure 2.14 Solvent Usage Breakdown for GSK Cork 2009


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3. Development Work on Solvent Reuse

All products on site are evaluated for potential solvent recovery opportunities.

• Methylcyclohexane recovery will be introduced to site in 2010. The material will be recovered from a single stage of production for reuse in that same stage. The material will be recovered on site and will have the potential to replace up to 62% of the Methylcyclohexane usage on site. Significant development work on this project was undertaken in 2009. The recovery will be initiated and the reuse of the recovered solvent validated in 2010.

• Other solvents identified as being suitable for recovery going forward are Methanol, Methyl Tert Butyl Ether, Isopropanol, Isopropyl Acetate, Methyl Tetrahydrofuran, Toluene, Diisopropyl Ether and Acetonitrile.

2.8 Control and Monitoring

2.8.1 Compliance with Condition 6.1 and 6.2

In house wastewater analysis is carried out by competent staff. Each analyst has undergone suitable training and has demonstrated competency prior to carrying out compliance testing.

Water testing procedures have been validated for accuracy, precision, suitability with test matrix, LOQ and linearity.

Validation protocols, reports and maintenance contracts are in accordance with the relevant international standard.

Regular calibrations are carried out where possible using laboratory standards. A third party proficiency scheme is also used as quality control. Any out of spec analysis from the 3rd party proficiency scheme is investigated in accordance with Procedure ENVP-025 and the findings documented.

Third party analysis is carried out by suitably accredited laboratories using internationally recognized standard methods.

2.9 Agency Monitoring and Enforcement

2.9.1 Aqueous Emissions Sampling and Analysis

The EPA took samples of emissions to water from the site on the following dates during 2009:

1. 24/03/09 Treated effluent to SW01 (sample not split).

2. 24/03/09 Incinerator Quench Liquor (sample not split).

3. 29/04/09 Grab sample of surface water discharge at SW02. (Sample not split).

4. 29/04/09 Incinerator Quench Liquor (split sample).

5. 29/04/09 Treated effluent to SW01 (split sample).

6. 03/11/09 Treated effluent to SW01 – Grab sample for VOCs (sample not split).

7. 03/11/09 Treated Effluent to SW01 (sample not split).

8. 03/11/09 Incinerator Quench Liquor (split sample).


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Table 2.20 provides a comparison of the EPA monitoring results with GSK’s monitoring results for the split samples. The parallel testing shows comparable results in most cases.

GSK results for suspended solids were higher than those reported by the Agency but significantly lower than the IPPC emission limit value of 300 mg/l. It is likely that the main reason for the difference in suspended solids results between the Agency and GSK is solids settling in the sample prior to taking the split sample. Going forward in 2010, where GSK & EPA analysis carried out in parallel differ significantly (> Z score of 2.0), GSK will follow the onsite procedure ‘ENVP-025 Review of Out-Of-Compliance Environmental Monitoring’ in the same way as out of spec proficiency test results will be investigated.

As reported in Section 2.8, the site laboratory methods are carried out in accordance with International Standards and have been validated for the key performance characteristics; linearity, precision, uncertainty, LoQ, and suitability with the text matrix.

GSK’s Environmental Laboratory participates in a recognised laboratory proficiency testing scheme “Aqua Check” for which several parameters are tested throughout the year. This scheme enables GSK’s Environmental Chemists to continually monitor the accuracy of test methods within the laboratory.


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Table 2.20 Comparison of EPA and GSK Monitoring Results on Split Samples

Parameter

Emission Limit Value (ELV)

1.2 times ELV

12

EPA 29/04/09 Quench Liquor

GSK 29/04/09 Quench Liquor

EPA 29/04/09

Final Effluent

GSK 29/04/09

Final Effluent

EPA 03/11/2009

Quench Liquor

GSK 03/11/2009

Quench Liquor

Sample ref. - - 917 QL-02

917 QL-02

917FHT-03

917FHT-03

944 QL-02

944 QL-02

Volume m

3/d

1,300 1,560 93.8 93.8 223 223.3 65.7 65.72

pH 6-9 N/A 7.88 - 8.0 7.76 8.25 -

COD mg/L 2,000 2,400 - - 284 215.0 -

Suspended Solids mg/L

250

30 QL13

300 <2.0 27.8 2.8 9.5 <2.0 13.5

BOD mg/L 300 350 - - 2.9 - - -

Nitrates (as N) mg/L

15 18 - - 18.4 - - -

Total Ammonium (as N) mg/L

50 60 - - 0.490 - - -

Copper mg/L

0.5

0.5 QL

0.6 0.035 - 0.02 - 0.013 -

Zinc mg/L 1

1.5 QL

1.2 0.042 - 0.098 - 0.006 -

Arsenic mg/l

0.15 QL 0.18 0.005 - - - <0.001 -

Cadmium mg/l

0.05 QL 0.06 <0.0010 - - - <0.0001 -

Chromium mg/l

0.5 QL 0.6 0.081 - - - 0.027 -

Nickel mg/l 0.5 QL 0.6 0.108 - - - 0.061 -

Thallium mg/l

0.05 QL 0.06 <0.010 - - - <0.001 -

Lead mg/l 0.2 QL 0.24 <0.01 - - - <0.001 -

- Indicates that no analysis was carried out for that particular parameter.

12

Ref. IPPC Licence P0004-03, Condition 4.4.3, Discrete Sampling: “For parameters other than pH and temperature, no grab sample value shall exceed 1.2 times the emission limit value.” Therefore, a value which exceeds the composite limit, but is less than the total error target of +20%, may be in conformance when measurement uncertainty is applied. Where a value exceeds the composite limit by more than +20%, this constitutes a non-conformance/non-compliance with the IPPC Licence Limit.

13 Where QL denotes the ELV associated with Quench Liquor prior to mixing with on-site treated effluent.


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2.9.2 Atmospheric Emission Sampling and Analysis

The EPA did not carry out any atmospheric emission sampling on-site during 2009.

2.9.3 IPPC Licence Audit

The EPA carried out an unannounced audit at the GSK site on 6th May 2009. Four non-compliances were recorded.

The auditors held an opening meeting to discuss current IPPC licence compliance issues and the facility’s management of same. They then carried out a tour of the site, focusing on the Environmental Laboratory, Incinerator No. 1, the tank farm, surface water management, foul and process drains. The auditors reviewed an extensive amount of documentation and held a closing meeting at which they made comments and relayed non compliances and observations as shown in Tables 2.21 and 2.22.

Table 2.21 EPA Audit Non-Compliances

Item Condition /Schedule

Non Compliance Action by GSK

1 C 11.1ii Delayed Notification of ELV Exceedence of Particulate Monitoring at A2-10.

Going forward, GSK will ensure that all reportable incidents are notified to the Agency as soon as practicable after their occurrence. Procedure SAFP-018 EHS Accidents and Incidents has been updated accordingly.

2 C 5.1 and S B.2

Exceedence of ELV for Suspended Solids at W1 (Incinerator Quench Water).

The structure of GSK’s Incident Log was revised as requested by the Agency.

Metals monitoring is now carried out when an ELV of TSS occurs that is not thought to be attributable to water hardness.

3 C 6.1.2 No Assessment of Suitability for Test Matrix nor Performance Characteristics determined for Parameters analysed on site.

GSK assessed procedures for their suitability for the test matrix and performance characteristics were determined for the five parameters analysed on site (COD, Suspended Solids, Nitrate, Ammonia and Total Phosphorus). Updated procedures in accordance with international standards are now in place.

4 C 9.3.2 and C 11.4

Follow-Up Reporting of Incidents

Where required, GSK will ensure that a follow up report is submitted to the Agency within one month of an incident occurring.


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Table 2.22 EPA Audit Observations

Item EPA Observation Action by GSK

1 The three most recent Aquacheck verifications were reviewed; one of these reports contained failures for Nitrate and Total Phosphorus but no assessment / investigation of same had been initiated.

GSK will ensure that any failed Aquacheck verifications are investigated and documented. Site procedure ENVP-025 “Review of Out of Compliance Environmental Monitoring” describes how investigations are to be carried out.

2 The Laboratory spreadsheet containing all accreditation details for testing does not contain records of the evaluation of subcontracted laboratory competence for the testing of specific parameters, ie. for BOD, metals, solvents and toxicity.

All analysis that is sub-contracted, is to a competent laboratory, accredited for the exact parameter for which analysis is required. Certificates of scope of accreditation have been collected and filed for contract laboratories.

3 Not all of the in-house laboratory procedures contain specific reference to the CEN/ISO, national or international standard they are conducted in accordance with.

All laboratory in-house procedures have been updated to include specific reference to the CEN/ISO, national or international standard they are conducted in accordance with.

4 There was no recording of daily temperature checks for COD/Suspended Solids analysis.

All daily temperature checks for COD/SS analysis are now recorded and documented in the laboratory notebooks.

5 It is noted, as a separate point, that the licensee will be installing a second laboratory capable of conducting environmental laboratory analysis on-site.

It is acknowledged that the new laboratory is subject to the same compliance requirements as applies to the already existing laboratory. New analysts have been trained accordingly and this has been documented.

6 Recommendations Arising from Groundwater Remediation Report – repair to foul sewer lines.

GSK updated the Agency during the course of the foul sewer remediation project which was completed on 31 Dec 2009. Refer to Section 5.3 of the AER for the most recent update.

7 Bund and Underground Process Pipeline Testing.

An inventory of all bunds and underground process pipelines was prepared detailing the date the last “three yearly testing” was conducted and the date of when the next testing is due. The inventory was subsequently forward to the Agency.

8 Revision of Non-Conformance/Corrective Action Procedure.

Non-Conformance/Corrective Action Procedure -Ref. No.SAFP-018 was updated to account for the Agency’s observations, IPPC Licence P0004-03 and the relevant Conditions therein.

9 Bund Disposal. Procedure Ref. ENV-054 “Bund Wall Contents Disposal” was updated to take account of Condition 3.6.3.

10 Surface Water Monitoring Point SW4. This reference monitoring point is a legacy reference and is no longer applicable to the existing site drainage system or IPPC licence. Copies of the surface water drainage system (Refs. 3221/09/1193 & 1194) were forwarded to the Agency in June 09.


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2.9.4 EPA Site Visits/Inspections

An EPA OEE inspector visited the site on 2nd December 2009, special attention was paid to the crushed concrete and tar macadam storage area, the TALAS room and the environmental control room. The following observations were noted:

Table 2.23 EPA Site Inspection Observations

Item EPA Observation Action by GSK

1 AER PRTR Report 2007 The 2007 AER PRTR Report was amended to record the offsite transfers of waste and the corrected total CO2 emissions value.

2 Annual Environmental Report (AER) 2008

Specific documents/reports referenced within the AER have been forwarded to the EPA as requested and recommendations noted for 2009 AER.

3 GSK Audit Response dated 2nd

June 2009

A copy of the review and subsequent SOP for dealing with drainage from bunded areas was forwarded to the Agency.

Status of Compliance with Conditions 6.1 and 6.2 has been incorporated into 2009 AER.

A bund spreadsheet list is being maintained and updated as required.

4 SAFP-018 EHS Accidents and Incidents

This procedure was updated and forwarded to the Agency.

5 Suspended Solids (SS) incident reports dated 26, 27 and 30

th

November 2009

The results of metal analysis of the W1 sample were forwarded to the Agency as requested.

6 GSK letter requesting the reuse of tar macadam on site dated 2

nd November 2009

Letter was reissued to the Agency referencing the most recent Waste Framework Directive 2008/98/EC.

7 Staff Training for Calibration of the CEMS Units

A documented training procedure for the performance of CEMS calibration which details a training process and sets criteria to verify competency is being developed and will be forwarded to the Agency upon completion.

2.10 Environmental Incidents

All reportable environmental incidents which occurred during the year, such as:

• Malfunctions or breakdown of control equipment or monitoring equipment

• Any incident with the potential for environmental contamination of surface water or groundwater, or posing an environmental threat to air or land, or requiring an emergency response by the Local Authority.

are included in Table 2.24. They are also discussed in more detail in each relevant section above.


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As reported in the 2003 AER, an “Operational Excellence Initiative” commenced in the latter half of 2003 to reduce the frequency and duration of diversions of the Lean Gas Header (LGH) to the emergency scrubber (Incinerator Trips). Since that time, incineration/lean gas header uptime has remained above 98.8%.

A total of 38 incidents were recorded between January to December 2009, of which, 15 were incinerator trip incidents14; incidents reported are outlined in Table 2.24.

14

GSK agreed with the EPA during 2004, that going forward, an incinerator trip will be considered a reportable incident where the duration exceeds 60 minutes.


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Table 2.24 Summary of Environmental Incidents 2009

Date Incident Time Duration Cause Corrective Action

1 10/01/2009 TSS Incident, W1 117.5mg/L Vs IPPC limit 45mg/L

Daily Daily Due to burning of DCM resulting in CaCO3 related suspended solids. While the caustic dosing system neutralises the pH, suspended solids are generated in the wastewater.

Tune caustic dosing response on Incinerator No.3







4 03/02/2009 Vent gases diverted to emergency scrubber SCR1901

- 5hr 10 min

Due to Power outage. Production Operations were stopped before electricity power came back on line. Incin 1 & 3 shutdown.

No CAPA deemed appropriate to prevent power outage.


- 1hr 28 min

Incin No 3 instrument air input was inadvertently switched off by a contract worker erecting scaffolds. Processing was s/d after 90mins. Eng support resolved air intake valve failure.

Contract staff to be reminded of the necessity to take care around valves in order to prevent affecting GSK operations.


- 2d 4hr 25 min

Due to steam boiler tubes damage, Incin No.3 went offline. Root cause was the build up of solids from feed water on the inner lining of the tubes, which resulted

Boiler tubes are to be repaired prior to restarting incinerator No. 1. Boiler tubes will be inspected as part of maintenance check on shutdown inspections. Boiler


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in tube rupture. feedwater treatment to be reviewed to reduce solids precipitation on inner lining of tubes.


Daily Daily Solids are known to shed from firebrick & water hardness due to start up of Incin No. 1.

Incinerator No. 1 to be inspected for damage to refractory lining.


Daily Daily Solids are known to shed from firebrick & water hardness due to start up of Incin No. 1.

Incinerator No. 1 to be inspected for damage to refractory lining & repaired accordingly.


- 1hr 20 min

A localised power failure in one unit of plant equipment caused a false high level switch for liquid in the gas header system resulting in vent gases diverting to scrubber SCR1901.

Processing was stopped after 90mins. Power failure fixed by eng support and vent gases reestablished to incin. Given the v low failure rate of power unit supply, it is appropriate to maintain fail safe conditions. It is not considered beneficial or preventative to replace power units.


Daily Daily Refractory firebrick is known to shed when incineration activities restart after a period of shutdown.

Incinerator No. 1 to be inspected for damage to refractory lining.


- 4 hr 25 min

A VSD control feature failed resulting in the incinerator No1 tripped & vent gases diverting to SCR1901.

Ensure Delta V upgrade is complete with duty/standby pumps interchanging on a week by week basis before Incinerator No. 1 is restarted.


- 1hr 25 min

Control system failure when restarted when rebooted. Processing was stopped after 90 mins. Control system restarted when rebooted. A 1.3million euro upgrade is to be carried out on the control system in Q2 2009. Root cause was control system failure. System fails to fail

To upgrade control system in Q2 2009. Provox to be upgraded to Delta V on Incinerator No. 1.


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safe - bypass.

13 24/03/2009 CO 105.99mg/m

3

breached ELV 100mgm

3

17.30 30 min Incinerator start up with unusually large CO release.

CO levels to be monitored over coming days & each CO forming parameter to be investigated. Proceduralise a lab precipitation test for waste streams which is has high inorganic salts (>5%).


Daily Daily During Incinerator start up some blockages from waste tanks resulted in steady state conditions in Incinerator No. 1 firebox. This resulted in suspected carbonaceous soot being generated in the quench liquor.

The waste feed was changed to an alternative tank & run over the weekend. This purged blockages & the incinerator quench subsequently returned to compliance. Proceduralise a lab precipitation test for waste streams which is has high inorganic salts (>5%).


Daily Daily During Incinerator start up some blockages from waste tanks resulted in steady state conditions in Incinerator No. 1 firebox. This resulted in suspected carbonaceous soot being generated in the quench liquor.

The waste feed was changed to an alternative tank & run over the weekend. This purged blockages & the incinerator quench subsequently returned to compliance. Proceduralise a lab precipitation test for waste streams which is has high inorganic salts (>5%).


Daily Daily While burning waste from a process (089 stage 1) R&D pilot plant, blockages were experienced in the waste feed lines to the incinerator. This affected the firebox steady state

The waste feed to the incinerator from the process was stopped & the introduction of a different waste stream removed the issue of blocked lines. The remaining waste stream in question


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conditions, which resulted in temporary elevated carbon monoxide levels & is thought likely to be the cause of black (carbonaceous soot appearance) solids in the quench liquor.

was tankered for off-site disposal. In future, if processes are known to contain high inorganic solids levels, neutralisation trials will be carried out in the lab to identify if precipitation may occur in the waste tanks. This will reduce the possibility of reocurrance. Proceduralise a lab precipitation test for waste streams which is has high inorganic salts (>5%).


Daily Daily As above As above

18 23/04/2009 Dust from Dust Vent A2-10 was 17.09mg/m3 Vs IPPCL of 1.0mg/m3 Total dust & 0.15mg/m3 Pharma dust.

Annual sample

- Dust vent had 17mg/m3 Vs ELV of 1mg/m3. Analysis indicated that the material was rust from the vent shaft.

Decommission vent A2-10.


- 2 hr 15 min

A faulty pressure switch (PSL-19-590) on Incinerator IN1951 quench incorrectly indicated that no flow in the quench waters, which tripped the incinerators & resulted in the vent headers diverting to SCR1901

Correct electrical wiring malfunction.

Delta V upgrade to Incin No. 1 to include full inspection of pressure switches & upgraded where necessary.

20 30/05/2009 Odour Complaint

09.00 - No odour was detected by GSK security during 3 offsite and 5 onsite patrols on the day and 1/5 patrols on each other day leading up to the complaint. No CEMS or bypass emission attributable.

No CAPA put in place as no odours were detected.


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21 30/05/2009 Noise complaint

09.00 - Panel 15, B1 was found to have problems with interference being induced into the intrinsically safe circuits. Loose connections within the panel were found to be the root cause.

Replace two junction boxes with earthed replacements as per Chubb investigation report (Ref 13018).


- 8 hr 32 min

UPS failure in Environmental area. Incin 3 shut down.

UPS systems in the Environmental area are to be tested & validated or replaced.


- 8 hr 32 min

Blocked filters in quench Inc 3 recirculation

Acid wash to be done on shutdown of incinerator; Filter inspection routine to be implemented


- 2 hr 5 min

Loss of steam pressure due to PSV lifting on AHU, Bld 1 … interlock trip on #1

No actions practicable.


- 6 hr 50 min

CAT burner failure in Inc #1.

Failure of UPS following power dip

Combustion air valve to CAT burner to be repaired.

Comms alarm to be added to FTIR display in Env Control Room


- 2 hr 32 min

Loss of cooling water due to circuit breaker trip - A13. Incin No 1 shutdown.

No actions practicable.


- 27 hr 27 min

Gasket failure on joint between pilot burner and main burner of No.1 (IN1951)

Replace graphite seal on joint with ceramic fibre.


- 1hr 28 min

Inadequate fuse type on Incin No.1 pilot burner system

Replace fuses with anti-surge type at next shutdown opportunity.

Amend Specification to ensure correct anti-surge type fuses are fitted.


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29 08/09/2009 Groundwater well 5 VOC contamination Toluene, MTBE & THF

Biannual sample

Biannual sample

Probable spill of solvent from bunds/sumps in vicinity of GW well.

Hydraulically test and remediate sumps/bunds & pipelines in the area. Leaking line from Area 24 incineration drum charging bund was found & repaired.


- 10 hr 48 min

A passing caustic valve resulting in blinding of quench flow probe & low flow alarms resulting in trip

Repair the caustic flow control valve on Incin No.3 & add to PM list.

Investigate if more suitable probes are available for use in this system.

Set a fixed set point for quench flow.


Daily Daily Quench caustic supply valve (FIC-19-3357) was passing leading to high caustic levels in quench tank.

Repair caustic supply valve & reduce quench tank levels to prevent further solids incidents.

Add Caustic supply valve (FIC-19-3357) to annual PM check list.


Daily Daily Caustic dosing overcompensating for pH drop due to HCl when burning DCM.

1. Tune caustic dosing response on Incin No.3.

2. Investigate if caustic dosing arrangement in quench tank can be optimised.

3. Install floor diffusers in waste tanks.






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38 08/12/2009 NOx 409.7 mg/m

3 on

Incin No.1 Vs IPPC limit 400mg/m

3

22.30 30 min period

NOx levels drifted to non-compliant level during 22.30 to 23.00 time period. Primary cause - low ammonia feed to deNOx.

Amend incinerator No.1 HIMA alarm system to sound and display independently of other HIMA alarms. The alarm is to remain on until the low level ammonia has been resolved.


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2.11 AER Returns Table

The main summary data on environmental performance and emissions from site in 2009 is included in the AER Returns Form Tables which will be submitted separately to the EPA. These tables will incorporate the Pollutant Release and Transfer (PRTR) data for the site (see Section 4 below). A copy of the PRTR and AER Returns Data Table is included herein as Appendix F.

3. ENVIRONMENTAL MANAGEMENT OF THE ACTIVITY

3.1 Environmental Management System

Condition 2.2 of GSK’s IPPC Licence requires the licensee to establish and maintain an Environmental Management System (EMS).

During the implementation phase of the Environmental Management System, all employees received training on general environmental awareness. Environmental awareness training is included as part of new employee induction. The Environmental Regulatory Leader delivers this training in conjunction with the Training Co-coordinator.

Physical site audits and audits of the EMS are carried out in accordance with an internal audit schedule.

Environmental Standard Operating Procedures have been developed and are incorporated into the EHS training programme. All environmental procedures are reviewed on an annual basis to ensure compliance with site practices, legislative and Corporate requirements and other regulatory bodies.

3.2 Environmental Management Programme Report 2009

In accordance with the IPPC Licence, an Environmental Management Programme (EMP) 2009 was submitted to the Agency in March 2009 as part of the AER 2008.

The Environmental Management Programme Report 2009, which details the progress made towards meeting the stated objectives and targets of the EMP 2009, is included in Appendix E.

3.3 Environmental Management Programme 2010

In accordance with Condition 2.3 of the IPPC Licence, an Environmental Management Programme 2010 (Objectives and Targets for 2010) has been prepared and is included in Appendix D.

4. POLLUTANT RELEASE AND TRANSFER REGISTER (PRTR)

4.1 PRTR Report 2009

In March 2009, GSK submitted to the EPA a list of substances to be tracked under the Pollutant Release and Transfer Register (PRTR) Regulations. GSK has completed a mass balance for these substances as listed in the electronic AER Returns Data Table, which will be submitted separately to the Agency. A copy of the PRTR and AER Returns Data Table is included herein as Appendix F.

4.2 PRTR Proposal for 2010

It is proposed to track and report the same pollutants in 2010 for the PRTR as were reported for the year 2009.

5. OTHER REPORTS

5.1 Underground Tank and Pipeline Inspection and Monitoring

Condition 6.8 of GSK’s IPPC Licence requires that all underground effluent and foul sewer pipes are tested at least once every three years. There are no underground tanks on site.

The next round of testing and inspection of underground process pipelines is due by the end of 2011. The complete foul sewer system was hydrostatically tested in 2009.

5.1.1 Process Sewer Pipelines

A CCTV survey of process sewer pipes at GSK was carried out by an external consultant on 21st July 2008. The next round of testing and inspection of underground process sewer pipelines is due by the end of 2011.

During the 2008 survey 1 No. fault was discovered, consisting of an internal blockage causing an 80% loss in height/diameter. The report issued concluded that the obstruction needed to be cut out. The internal blockage in the process pipeline was cut out using high pressure water jetting in 2009.

5.1.2 Foul Sewer Pipelines

A complete hydrostatic testing of the foul system (manhole chambers, main lines and branches into buildings) was completed in 2009. Hydrostatic testing was carried out to standard EN1610 and a small selection of lines and manhole chambers were selected to carry out trial repairs to prove solution prior to completing the whole system. All manhole chambers which failed the hydrostatic testing were repaired with Nanocrete R4 by BASF and retested, all main lines and branch lines into buildings which failed hydrostatic testing have been lined in situ with an epoxy cure in place liner and retested.

A crane location survey was completed in 2009 and a drawing detailing the permitted locations for mobile cranes is now followed when situating a crane anywhere on site. There is a flowchart on the correct positioning of cranes to prevent damage to below ground lines. This flowchart is issued to all personnel who may bring cranes on site detailing restrictions and criteria which must be satisfied prior to using a crane. Costs incurred for inspection and repair totaled €260,000.

5.1.3 Surface Water Pipeline System

A CCTV survey of surface water pipes at GSK was carried out by an external consultant on 11th June 2008. During the survey 25 faults were discovered. A report issued by the external consultant recommended the repair by patch of 24 faults and the cut out of a connection / polythene patch.

All faults found in the survey were rectified in 2009 using a patch repair method of fiber glass patch coated with silicate resin and place over the point of repair and cured under ambient temperature.

A front end study on the practicality of carrying out hydrostatic testing and subsequent repairs on the surface water pipeline system has been initiated for Q1 2010 with a possible project similar to the foul sewer project completed in 2009 being implemented for the surface water pipeline system.

5.2 Bund Integrity Assessment

Condition 6.8 of GSK’s IPPC Licence requires that all bunding structures and containers are tested for integrity and water tightness at least once every three years. There are 159 bunded areas at the GSK facility, with various types of internal finish, 3 of which are redundant.

The site implemented a new schedule for bund integrity assessment in 2009 and this bund integrity testing schedule was subsequently forwarded to the Agency in 2009. The schedule includes visual inspection of all bunds on an annual basis. Approximately 12-13 bunds to be inspected visually per month. All bunds are scheduled to be hydrostatically tested during 2009/2010 and thereafter on a three-year basis, as required by Condition 6.8 of the IPPC Licence.

During 2009, 155 bunds were tested, 114 were hydrostatically tested whereby 75 passed and 39 failed. 41 were visually inspected with 18 passing visual inspection and 23 failing.

In 2010, GSK intends to remediate all failures and test the remaining bunds.

5.3 Groundwater Quality Monitoring Reports

Schedule C.6 of the IPPC licence requires GSK to sample and analyse groundwater from thirteen groundwater wells (AGW-1 to AGW-13) for the following parameters on a biannual basis:

• Total ammonium

• Major anions

• Major cations

• Individual heavy metals

• Trace organics.

Additional bacteriological parameters were analysed in all 13 monitoring wells and one borehole (BH-104) to help determine the potential source of the bacteriological and ammonium contamination in the groundwater on site.

Schedule D requires GSK to submit a summary of these results as part of the AER. The full groundwater monitoring reports are held on file and may be inspected upon request.

5.3.1 Summary of Monitoring conducted on the 15th & 16th June 2009

Groundwater sampling was undertaken by an external consultant on the 15th & 16th June, 2009. 13 bedrock groundwater monitoring wells (AGW-1 to AGW-13) and one perched groundwater well (BH-104) on site were sampled. Additional bacteriological parameters were analysed in all monitoring wells to help determine the potential source of the bacteriological and ammonium contamination in the groundwater on-site.

The main conclusions of the Groundwater Quality Report were as follows:

• The ammonium concentrations were elevated above the relevant standards in all monitoring wells with the exception of AGW-6 and AGW-8 located away from process buildings. The November 2007 surface water analysis from seepage samples on the shoreline and adjacent estuary (which showed lower concentrations of ammonium than those on-site) suggest that the ammonium is likely to be from an on-site source. Identified leaking foul drains on-site are thought to be the main contributor. Historical monitoring has shown an overall decline in ammonium concentrations on-site.

• Total coliforms, which can be naturally occurring, were detected in 7 of the 14 groundwater samples analysed. E.coli contamination which is indicative of relatively recent faecal waste showed a significant decrease in concentration in AGW-13 from very elevated concentrations detected in November 2008. This decrease in concentration is attributed to a programme of drain inspection and repair works undertaken on–site by GSK of which 80% of the foul drains have currently been tested with 20% to complete in 2009.

• Groundwater temperature remains elevated in the groundwater beneath most of the site. The May 2008 additional investigation works of selected monitoring wells on-site showed these elevated groundwater temperatures are related to heat transfer effects from the buildings on-site to the underlying bedrock aquifer. The elevated groundwater temperatures correspond with the older buildings to the north-west of the site.

• The EC readings are generally in the normal range for groundwater with more elevated readings in monitoring wells nearer the coastline which is expected given there is a tidal influence on the site.

• Selected major anions and cations are elevated in relation to EPA IGVs. The presence of some elevated anions and cations is likely to be associated with seawater influence on the site. This is comparable with previous groundwater sampling rounds.

• There was no detection of mineral oil in June 2009 similar to previous monitoring rounds.

• Overall, the concentrations of heavy metals were below the EPA IGV standards with the exception of nickel in one well (AGW-7) and manganese in nine wells, similar to previous monitoring rounds. These metals can occur naturally at elevated concentrations and are not thought to be attributed to the site activities.

• There was a low detection of MTBE in three monitoring wells in June 2009 located in the northern region of the site which have been detected historically. An elevated concentration of MTBE, toluene and

THF was detected in AGW-5 in June 2009 indicating a potential spill/leak or mobilisation of historical contamination in the area. Elevated toluene concentrations in AGW-5 have not being detected in this pumping well since 2002 following the 2001 toluene spill incident in the area. THF has been detected at elevated concentrations in groundwater monitoring wells on-site historically but not at the elevated concentration detected in AGW-5 in June 2009.

• No SVOCs were detected above the laboratory detection limits which are similar to previous monitoring rounds.

The key contaminants detected on-site in June 2009 such as elevated ammonium and faecal bacteria concentrations are being tackled by the drain repair works onsite. Elevated VOCs detected in AGW-5 are being monitored closely by further monitoring rounds and the continuous pumping from this well will act a containment measure for any localised contamination in the vicinity of the well.

Based on the conclusions of the above report, the external consultant recommended that GSK undertake the following actions:

Continue monitoring of the 13 bedrock groundwater monitoring wells and one perched groundwater well biannually for the IPPC Licenced parameters to include continuation of the additional bacteriological analysis. This bacteriological analysis will provide useful trend data to examine the effectiveness of the extensive drain repair works completed on-site on the groundwater contamination being detected.

It was also recommended that GSK personnel carry out an inspection of solvent tank farm tanks and process lines to determine if there is any potential leak in the area. Further groundwater monitoring works will help to determine if there is a trend in the elevated VOCs detected in monitoring well AGW-5 in June 2009.

5.3.2 Summary of Monitoring conducted on the 18th of November 2009

Groundwater sampling was undertaken by an external consultant on the 18th of November, 2009.

All 14 monitoring wells (AGW-1 to AGW-13 & BH-104) on the GSK site were sampled as part of the site’s biannual IPPC Licence requirements using the WYG groundwater sampling protocol.

Additional bacteriological parameters were analysed in all monitoring wells to help in determining the potential source of the bacteriological and ammonium contamination in the groundwater on-site.

The ammonium concentrations were elevated above the relevant standards in all monitoring wells with the exception of AGW-1, AGW-6 and AGW-8 located away from process buildings. The November 2007 surface water analysis from seepage samples on the shoreline and adjacent estuary (which showed lower concentrations of ammonium than those on-site) suggest that the ammonium is likely to be from an on-site source. Identified leaking foul drains on-site are thought to be the main contributor. Historical monitoring has shown an overall decline in ammonium concentrations on-site which is potentially due to foul drain repairs work together with a decrease in personnel working on-site.

Total coliforms, which can be naturally occurring, were detected in 13 of the 14 groundwater samples analysed. E.coli contamination which is indicative of

relatively recent faecal waste remained at relatively low concentrations on-site compared to elevated concentrations detected in November 2008. This decrease in concentration is attributed to a programme of drain inspection and repair works undertaken on–site by GSK.

Groundwater temperature remains elevated in the groundwater beneath most of the site. The May 2008 additional investigation works of selected monitoring wells on-site showed these elevated groundwater temperatures are related to heat transfer effects from the buildings on-site to the underlying bedrock aquifer. The elevated groundwater temperatures correspond with the older buildings to the north-west of the site.

The EC readings are generally in the normal range for groundwater with more elevated readings in monitoring wells nearer the coastline which is expected given there is a tidal influence on the site.

Selected major anions and cations are elevated in relation to EPA IGVs. The presence of some elevated anions and cations is likely to be associated with seawater influence on the site. This is comparable with previous groundwater sampling rounds.

There was no detection of mineral oil in November 2009 similar to previous monitoring rounds.

Overall, the concentrations of heavy metals were below the EPA IGV standards with the exception of arsenic in two wells (AGW-3 and AGW-6) nickel in one well (AGW-7) and manganese in 11 wells, as seen on-site historically. These metals can occur naturally at elevated concentrations and are not thought to be attributed to the site activities.

In June 2009 elevated MTBE, toluene and THF concentrations were detected in AGW-5 indicating a potential spill/leak. GSK carried out an investigation of sumps/bunds and pipelines to determine a possible source of this VOC groundwater contamination. A leaking pipeline was uncovered and repaired. Subsequent sampling of AGW-5 in September 2009 by GSK and in November 2009 by WYG showed there no detection of VOCs from the groundwater in AGW-5 or any other monitoring well on-site.

No SVOCs were detected above the laboratory detection limits which are similar to previous monitoring rounds.

Overall the groundwater quality in November 2009 is consistent with historical trends in groundwater quality. Elevated ammonium and faecal bacteria concentrations are likely to be related to leaking foul drains on-site. The extensive programme of drain repair works on-site is now complete with an improvement in groundwater quality seen in recent monitoring rounds as illustrated in Figures 5.1 and 5.2. Further groundwater monitoring for these parameters will determine if there is a trend in the data that coincides with the drain repair works.

Ju

n-0

5

Au

g-0

5

Oct-

05

Dec-0

5

Fe

b-0

6

Ap

r-0

6

Ju

n-0

6

Au

g-0

6

Oct-

06

De

c-0

6

Fe

b-0

7

Ap

r-0

7

Ju

n-0

7

Au

g-0

7

Oct-

07

De

c-0

7

Fe

b-0

8

Ap

r-0

8

Ju

n-0

8

Au

g-0

8

Oct-

08

De

c-0

8

Fe

b-0

9

Ap

r-0

9

Ju

n-0

9

Au

g-0

9

Oct-

09

AGW-1

AGW-6

AGW-12

0

10

20

30

40

50

60

70

80

90

100

Co

ncen

tra

tio

n (

mg

/l)

Well ID

AGW-1

AGW-2

AGW-3

AGW-4

AGW-5

AGW-6

AGW-7

AGW-9

AGW-10

AGW-11

AGW-12

AGW-13

BH-104

AGW-8

AGW-3

333mg/l

Figure 5.1: Historical Trend in Ammonium Concentrations

Nov-06

Feb-07

May-07

Aug-07

Nov-07

Feb-08

May-08

Aug-08

Nov-08

Feb-09

May-09

Aug-09

Nov-09

AGW-1

AGW-4

AGW-7

AGW-10

AGW-13

0

2000

4000

6000

8000

10000

12000

14000

16000

18000

Co

nce

ntr

ati

on

MP

N/1

00

ml

Monitoring

Well

AGW-1

AGW-2

AGW-3

AGW-4

AGW-5

AGW-6

AGW-7

AGW-8

AGW-9

AGW-10

AGW-11

AGW-12

AGW-13

Figure 5.2: Historical Trend in Total Coliform Concentrations

The bacteriological parameters will degrade more quickly than the ammonium and therefore a decreasing trend in the bacteriological parameters will be more rapid. As the majority of the site has concrete hard-standing, any contaminants in the subsoil will degrade more slowly than if there was exposure to rainfall percolating through these subsoils.

Based on the conclusions of the above report, the external consultant recommended that GSK undertake the following actions:

Continue monitoring of the 13 bedrock groundwater monitoring wells and one perched groundwater well biannually for the IPPC Licenced parameters to include continuation of the additional bacteriological analysis. This bacteriological analysis will provide useful trend data to examine the effectiveness of the extensive drain repair works completed on-site on the decreasing bacteriological and ammonium groundwater contamination being detected.

5.4 Residuals Management Plan

The Residuals Management Plan (RMP) for the site was reviewed in 2009 and submitted to the Agency as part of the 2008 AER. Condition 10.2.2 requires that this RMP be reviewed annually. The RMP is scheduled to be reviewed by GSK Environmental, Health and Safety personnel in conjunction with the external consultants responsible for the original RMP in April 2010 and the reviewed RMP document will be submitted to the Agency.

The scope of the annual review scheduled for April 2010 will cover the following:

• Review in accordance with the facility’s IPPC Licence Condition 10.2;

• Review any incidents that may have resulted in soil or groundwater contamination;

• Review of any changes in underground structures;

• Review of scope of decontamination required; and

• Review of financial provisions required to cover such known environmental liabilities.

• Feedback received from Enviros Consulting/EPA Telesurvey in Jan 2010 with regards to the site’s ELRA/CRAMP/FP.

As the operations and facilities on site have not changed substantially over the last year and volumes of materials on site that would require removal have not decreased significantly, no significant changes are anticipated.

GSK do not anticipate significant changes in the forthcoming revision to the total cost identified for implementation of the plan (including 25% contingency on decommissioning costs) as estimated to be in the order of €3.68m. These costs are primarily related to the cleaning, decontamination and decommissioning of equipment and divestiture/disposal of obsolete equipment and wastes. The basis of the plan is to ensure that, upon completion of the plan, the facility would be in a suitable state for future industrial use and its condition would not pose a risk to public health and safety or the environment.

5.5 Environmental Liability

An Environmental Liabilities Risk Assessment (ELRA) for the site was conducted in 2008 and submitted to the Agency, in accordance with Condition 12.2.2 of the IPPC Licence. The methodology followed that prescribed by the EPA’s Guidance on Environmental Liability Risk Assessment, Residuals Management Plans and Financial Provision. The site lies in Risk Category 3, the highest risk class; hence a detailed site-specific ELRA was conducted on

all foreseen unplanned but possible and plausible events occurring during the operational phase of the facility.

All risks to surface water, groundwater, atmosphere, land and human health were examined. The ELRA identified no risks of massive or major severity. All risks lay within the range moderate-minor-trivial. For each risk, the probability of occurrence over a 30-yr period was rated. Each risk was rated by multiplication of severity by probability of occurrence.

The existing mitigatory measures in place were deemed adequate to manage the environmental risks satisfactorily.

The most likely scenario and probability for each risk was taken and a cost ascribed for remediation. The maximal cost determined for an unplanned environmental liability associated with the operational phase of the facility is €270,000 (including 20% contingency).

The ELRA will be reviewed as necessary to reflect any significant change on site, and in any case every three years, per Condition 12.2.2 of the IPPC Licence. The next review of the ELRA is required in 2011 at the latest.

5.6 Financial Provision

GSK is required to make financial provision for the known environmental liabilities identified and costed in the RMP and the unknown environmental liabilities identified, rated and costed in the ELRA.

5.6.1 Known Liabilities (RMP)

The total cost of known environmental liabilities identified by the RMP for implementation of the plan is estimated to be in the order of €3.68m (including 25% contingency on decommissioning costs).

GSK confirms that the company has more than adequate resources from operations to fund the Residuals Management Plan. In addition, the value of the 52 acre site itself as a fixed asset far outweighs any potential closure or remediation cost.

GSK do not anticipate any significant changes to the implementation costs identified for the RMP in the forthcoming April 2010 RMP review.

5.6.2 Unknown Liabilities (ELRA)

The most likely scenario and probability for each risk was taken and a cost ascribed for remediation. The maximal cost determines for an unplanned environmental liability associated with the operational phase of the facility is €270,000 (including 20% contingency).

The company is insured against environmental accidents/incidents to a value of €250,000. GSK Cork has made financial provision in its accounts for the remediation of environmental pollution and the tackling of unknown environmental liabilities as they are identified. This is more than adequate to cover the envisaged €270,000 (including 20% contingency) required to remediate the most costly risk. Such self-insurance by financial accounting is a suitable financial instrument per Table 5.3 of the EPA’s Guidance Note.

In the case of an off-site event, there are sufficient financial/insurance provisions in place to return the environment to its original condition and pay any associated costs/expenses incurred by third parties or external services/agencies such as the EPA or Health and Safety Authority.

5.6.3 Statement of Measures

GSK is required by Condition 12.2.1 to provide an annual statement as to the measures taken or adopted at the site in relation to the prevention of environmental damage, and the financial provisions in place in relation to the underwriting of costs for remedial actions following anticipated events or accidents/incidents, as may be associated with the carrying on of the activity. The risk assessment exercise will include the accurate estimation of the financial provisions required for the underwriting of such costs. The amount of indemnity held shall be reviewed and revised as necessary, but at least annually.

The expenditure on environmental control and measures to improve environmental protection in and around the site is shown in Table 5.2 below.

Table 5.2 Expenditure by GSK Cork in 2009 on environmental control

€

Capital expenditure on air management onsite 762,000

Operational expenditure on air management onsite 3,497,380

Capital expenditure on waste management onsite 257,800

Operational expenditure on waste management onsite 335,340

Operational expenditure on waste management offsite 862,470

Capital expenditure on water management onsite 33,000

Operational expenditure on water management onsite 1,142,650

Operational expenditure on water management offsite 123,580

Foul sewer upgrade project 260,000

Repairs to bunded structures 110,000

Surface Water Sewer repairs 21,500

Capital expenditure on pipebridge upgrade 3,348,731

Total expenditure on environmental control in 2009 10,754,451

APPENDIX A

SITE ENVIRONMENTAL POLICY

CORK ENVIRONMENTAL POLICY

GlaxoSmithKline has a world-wide commitment to conduct itself in a responsible

fashion to protect people and the Environment.

Facilities are designed, constructed, operated and maintained to achieve the goals, and mandates,

of appropriate laws and regulations world-wide and in Ireland, as well as those incorporated in

GSK’s Environmental Standards.

GlaxoSmithKline’s standards are applicable world wide because it is GSK’s belief that

environmental issues are global in scope and that it should conduct it’s affairs accordingly.

In addition to the above, SmithKline Beecham (Cork) Limited places a specific emphasis on the

areas of operation listed below and consider them to be a vital part of our site operations:

• A commitment to adhere to the GSK Environmental Policy and the Standards and Guidances

issued in support of this.

• A commitment to operate at all times within the terms of the site Integrated Pollution

Prevention & Control (IPPC) Licence issued by the EPA.

• A commitment to continuous improvement on environmental issues.

• A commitment to prevent pollution by eliminating, or if that is not possible, reducing as far

as practicable all emissions to the environment. Reduction at source will be the first priority,

followed by recycling and the use of end-of pipe technology only where reduction at source

or recycling is not possible.

• A commitment to setting environmental objectives and targets on a regular basis.

• A commitment to energy minimisation by incorporating energy efficient technologies in all

aspects of plant design and promoting energy awareness.

• A commitment to liase openly on environmental issues with members of staff, the local

community and other interested parties.

• A commitment to provide information on the environment to the public as per our

undertaking in the IPPC Licence.

• A commitment to assess the environmental impact of all new projects in advance.

• A commitment to raise environmental awareness at all levels within the Company.

Review

This policy will be reviewed annually through the Cork EHS Council.

___________________ March 2009

Finbar Whyte

Vice President & Director, Cork

APPENDIX B

HAZARDOUS WASTES ARISING ON SITE IN 2009

Description of

Waste

EWC Code Tonnage Waste Haulier Waste Contractor/

Agent/Broker

Waste or IPC

Permit or Licence

No.

Final destination Waste or IPPC Permit

or Licence No.

Disposal or

Recovery Code

Dilute hydrochloric

acid

06 01 02 2.569 JP Ryan (CK WMC 34/01) Indaver Ireland Ltd. 36-2 AVG, Abfall-Verwertungs

Gesellschaft, Hamburg,

Germany.

IB2234 D10

Phosphoric acid 06 01 04 0.633 Indaver

(CK WMC 65/01)

Indaver Ireland Ltd. 36-2 Kommunikemi a/s,

Lindholmvej 3, 5800 Nyborg,

Denmark.

8-76-1-449-49-2005 D10

Acidic wastes 06 01 06 0.266 JP Ryan (CK WMC 34/01) / Quay

Transport Ltd. (CK WMC 139/03)

Indaver Ireland Ltd. 36-2 Indaver NV, Polderlietweg, B-

2030, Antwerp, Belgium.

MLAVI / 9800000485 D10

Alkaline wastes 06 02 04 0.6 Quay Transport Ltd. (CK WMC

139/03)



MLAVI / 9800000485 D10

Aqueous sludges 07 05 01 1.938 Quay Transport Ltd. (CK WMC

139/03)



MLAVI / 9800000485 D10

Mixed solvent

waste

07 05 03 22.44 JP Ryan (CK WMC 34/01) Indaver Ireland Ltd. 36-2 Indaver NV, Polderlietweg, B-


MLAVI / 9800000485 D10

Mixed solvent

waste

07 05 03 22.44 JP Ryan (CK WMC 34/01) Indaver Ireland Ltd. 36-2 Indaver Irl, Tolka Quat Rd.,

Dublin Port, Dublin 1

IPPC-36-2 D13

Mixed solvent

waste

07 05 03 9.268 Quay Transport Ltd. (CK WMC

139/03) / JP Ryan (CK WMC

139/03)



MLAVI / 9800000485 D10

Mixed solvent

waste

07 05 03 45.08 JP Ryan (CK WMC 34/01) Indaver Ireland Ltd. 36-2 AVG, Abfall-Verwertungs


Germany.

IB2234 D10

Mixed solvent

waste

07 05 03 63.68 JP Ryan (CK WMC 34/01) Indaver Ireland Ltd. 36-2 Kommunikemi a/s,

Lindholmvej 3, 5800 Nyborg,

Denmark.

8-76-1-449-49-2005 D10

Waste solvent 07 05 04 2.163 Quay Transport Ltd. (CK WMC

139/03)

Indaver Ireland Ltd. 36-2 AVG, Abfall-Verwertungs


Germany.

IB2234 D10

Waste solvent 07 05 04 7.261 Quay Transport Ltd. (CK WMC

139/03)



MLAVI / 9800000485 D10

Waste solvent 07 05 04 278.696 United Transport Tankcontainers( Indaver Ireland Ltd. 36-2 SRM, Hayhole Road, North

Shields NE29 6DY, England.

BV4665IG R2

Waste Sludge 07 05 11 0.6 Quay Transport Ltd. (CK WMC

139/03)



MLAVI / 9800000485 D10

Mixed packaged

waste

07 05 13 0.12 S-Transport(CK WMC 70/01) Indaver Ireland Ltd. 36-2 Rilta Environmental,Block

402,Greenogue Business

Park,Rathcoole, Co. Dublin.

WO192-02 R4

D10Indaver Ireland Ltd. 36-2 Indaver NV, Polderlietweg, B-


MLAVI / 9800000485Mixed solvent

waste

07 05 03 455.27 JP Ryan (CK WMC 34/01)

Description of

Waste


Agent/Broker

Waste or IPC

Permit or Licence

No.


or Licence No.

Disposal or

Recovery Code

Mixed packaged

waste


139/03)



Germany.

IB2234 D10

Mixed packaged

waste

07 05 13 110.154 JP Ryan (CK WMC 34/01) / Quay




MLAVI / 9800000485 D10

Waste Hydraulic

Oils


139/03)



MLAVI / 9800000485 D10

Waste oil 13 02 08 0.2 Quay Transport Ltd. (CK WMC

139/03)



MLAVI / 9800000485 D10

Engineering oil 13 08 99 0.2 Quay Transport Ltd. (CK WMC

139/03)



MLAVI / 9800000485 D10

Empty unclean

metal drums

15 01 10 25.466 S-Transport(CK WMC 70/01) Indaver Ireland Ltd. 36-2 Rilta, Block 402, Greenogue

Business Park, Rathcoole, Co.

Dublin.

EPA W0192-1 R4

Contaminated

filters, liners and

PPE


139/03)



MLAVI / 9800000485 D10

Mixed solvent

wastes from

laboratory

16 05 06 0.363 Indaver Irl.-36-2. CK WMC 65/01 Indaver Ireland Ltd. 36-2 Indaver NV, Polderlietweg, B-


MLAVI / 9800000485 D10

Mixed solvent

wastes from

laboratory


139/03) / S Transport (CK WMC

70/03)



Germany.

IB2234 D10

Mixed solvent

wastes from

laboratory


139/03)



MLAVI / 9800000485 D10

Mixed liquid

chemical waste


139/03)



Germany.

IB2234 D10

Mixed liquid

chemical waste


139/03)



MLAVI / 9800000485 D10

Contaminated

aqueous sludges


139/03)



MLAVI / 9800000485 D10

Incinerator lining 16 11 05 10.544 Quay Transport Ltd. (CK WMC

139/03)


2030, Antwerp, Belgium

MLAVI / 9800000485 D9

Medical waste 18 01 03 0.01 Ecosafe Systems Ltd.,(CK WMC

33/01

Indaver Ireland Ltd. 36-2 Ecosafe Systems Ltd., Unit 1A

Allied Industrial Estate, Kylemore

Road, Dublin 10.

EPA W0054-2 D9

Indaver NV, Polderlietweg, B-


38.252 MLAVI / 9800000485 D10Contaminated

packaging

15 01 10 JP Ryan (CK WMC 34/01) / Quay


Indaver Ireland Ltd. 36-2

Description of

Waste


Agent/Broker

Waste or IPC

Permit or Licence

No.


or Licence No.

Disposal or

Recovery Code

Medical waste 18 01 03 0.03 Healthcare Waste Management

(CK WMC 37/01)

Indaver Ireland Ltd. 36-2 Ecosafe Systems Ltd., Unit 1A

Allied Industrial Estate, Kylemore

Road, Dublin 10.

EPA W0054-2 D9

Fluourescent Tubes 20 01 21 0.19 Irish Lamp Ltd.(DC-08-1115-01) Indaver Ireland Ltd. 36-2 Irish Lamp Recycling, Blackpark,

Kilkenny Road, Athy, Co.

Kildare,

WFP-KE-0348-01 R4

Incineration

on-site of

non-halogenated

solvents

07 05 04 4275.83 N/A N/A N/A GlaxoSmithKline, Currabinny,

Carrigaline.

IPPC P0004-03 D10

4275.83

Onsite reuse

as fuel -

non- halogenated

solvents


Carrigaline.

IPPC P0004-03 R1

Onsite solvent

recovery -

non-halogenated

solvents


Carrigaline.

IPPC P0004-03 R2

2666.2

8066.62 %

2970.672 36.83

5095.95 63.17

Total Incineration on-site

Total Hazardous Waste

Produced 2009 (T)

Total Solvent Recovery

On-Site 2008 (T)


Recovered 2009(T)


Disposed 2009(T)

APPENDIX C

NON-HAZARDOUS WASTES ARISING ON SITE IN 2009

Description of

Waste

EWC Code Tonnage Waste Haulier Waste

Contractor/

Agent/Broker

Waste or IPC Permit

or Licence No.

Final destination Waste or IPPC

Permit or

Licence No.

Disposal or

Recovery Code

Fibre kegs 15 01 01 0 Greenstar

Recycling Cork

(CK WMC 20/04)

Greenstar

Recycling Cork

136-2 Greenstar Recycling (Cork),

Sarsfieldcourt, Glanmire, Cork.

136-2 R3

Dry mixed

recyclables

15 01 06 8.47 Greenstar

Recycling Cork

(CK WMC 20/04)

Greenstar

Recycling Cork



136-2 R3

C&D Waste 17 01 07 824.06 John Butler (CK

WMC 169/03

Indaver Ireland

Ltd.

36-2 John Butler, Riverstick,

Co. Cork.

CK (S) 113/04 R5

C&D Waste 17 01 07 110.78 S Transport Limited

(CK WMC 70/03)

Indaver Ireland

Ltd.

36-2 Greenstar Landfill, Knockharley,

Co. Meath.

W0146-1 D1

C&D Waste 17 01 07 9.64 Greenstar

Recycling Cork

(CK WMC 20/04)

Greenstar

Recycling Cork



136-2 R3

Tarmac 17 03 02 31.18 John Butler (CK

WMC 169/03

Indaver Ireland

Ltd.

36-2 John Butler, Riverstick,

Co. Cork.

CK (S) 113/04 R3

Tarmac 17 03 02 88.44 John Butler (CK

WMC 169/03

Indaver Ireland

Ltd.

36-2 John A. Wood, Killanully,

Ballygarvan, Co. Cork.

CK (S) 88/04 R3

Confidential

paper

20 01 01 79.56 Cork Confidential

Shredding (CK

WMC 127/02

Cork Confidential

Shredding

CK WMC 30-0 Cork Confidential Shredding

CCS Cork Limited, Unit K5,

Marina Commercial Park,

Co. Cork.

CK (S) 288/06 R3

Mixed Waste 20 01 08 21.06 Greenstar

Recycling Cork

(CK WMC 20/04)

Greenstar

Recycling Cork


Co. Meath.

W0146-1 R10

Mixed Waste 20 01 08 31.58 Greenstar

Recycling Cork

(CK WMC 20/04)

Greenstar

Recycling Cork


Co. Meath.

W0146-1 D1

Waste Cooking

Oil

20 01 25 0.52 Frylite Ltd.

(CKWMC 217/04

Indaver Ireland

Ltd.

36-2 Frylite Ltd, Kilcoolgan, Co.

Galway

WR/77 R9


Sarsfieldcourt, Glanmire,

136-2 R9Waste cooking

oil

20 01 25 1.84 Greenstar

Recycling (Cork)

Ormonde Organics

Limited (CK WMC

136-2 Greenstar Composting Facility,

Milltown,

Co. Tipperary.

136-2 R10Food waste 20 01 08 3.74 Greenstar

Recycling (Cork)

Greenstar

Recycling Cork

(CK WMC 20/04)

36-2 Rehab Recycling (Cork),

Monahan Road, Cork.

03/07 R5Glass bottles

and jars

20 01 02 1.5 Indaver Ireland

Ltd.

Rehab Group (CK

WMC 146/03

R3Paper and

cardboard

20 01 01 23.93 Greenstar

Recycling Cork

(CK WMC 20/04)

Indaver Ireland

Ltd.

Greenstar Recycling (Cork),


Cork.

136-236-2

Description of

Waste


Contractor/

Agent/Broker

Waste or IPC Permit

or Licence No.


Permit or

Licence No.

Disposal or

Recovery Code

Waste cable 20 01 36 31.08 Cork Metal

Company Limited

(CK WMC 26/06)

Cork Metal

Company Limited

WP 08/02 Cork Metal Company Limited,

Dublin Hill,

Cork.

WP 08/02 R4

Timber 20 01 38 5.72 S Transport Limited

(CK WMC 70/03)

Indaver Ireland

Ltd.

36-2 Waste Recovery Services,

Fermoy,

Co. Cork.

107-1 R3

Scrap metal -

Stainless Steel

20 01 40 99.89 Cork Metal

Company

Limited(CKWMC

26/06)

Indaver Ireland

Ltd.

36-2 Cork Metal Company Limited,

Dublin Hill,

Cork.

WP 08/02 R4

Waste Sludge 07 05 12 368.32 Greenstar

Recycling Cork

(CK WMC 20/04)

Indaver Ireland

Ltd.

36-2 Collins Waste Disposal,

Farranbrien East, Minane

Bridge, Co. Cork.

CK (S) 18/02 D13

Mixed dry waste

for landfill

20 03 07 115.31 Greenstar

Recycling Cork

(CK WMC 20/04)

Indaver Ireland

Ltd.



136-2 R5

2138.54

1627.86

Total Non Hazardous

Waste Produced 2009

%

Total Non Hazardous

Waste Recovered 2009

76.12

R3

Scrap metal -

carbon steel

20 01 40 211.42 Cork Metal

Company Limited

(CK WMC 26/06) /

O'Donovan

Transport (CK

WMC 115/03)

Indaver Ireland

Ltd.

36-2 Cork Metal Company Limited,

Dublin Hill,

Cork.

WP 08/02 R4

Greenstar

Recycling (Cork)



Cork.

136-2Plastics 20 01 39 n/a Greenstar

Recycling Cork

(CK WMC 20/04)

36-2 Waste Recovery Services,

Fermoy,

Co. Cork.

107-1 R3Timber 20 01 38 70.5 Indaver Ireland

Ltd.

Waste Recovery

Services

(Fermoy) Ltd.

(CK WMC 92/01) /

S Transport Limited

(CK WMC 70/03)


Cork.

oil Recycling (Cork)Limited (CK WMC

328/05)

Description of

Waste


Contractor/

Agent/Broker

Waste or IPC Permit

or Licence No.


Permit or

Licence No.

Disposal or

Recovery Code

510.68Total Non Hazardous

Waste Disposed 2009

23.88

APPENDIX D

ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) 2010

EMP 2010 IPPC Licence Reg. No. P0004-03

Environmental Management Programme (EMP) 2010 Condition 2.2.2.2 of IPPC Licence Reg. No. P0004-03 requires that GlaxoSmithKline (Cork) Ltd. maintain a Schedule of Environmental Objectives and Targets: “The Schedule shall as a minimum provide for a review of all operations and processes, including an evaluation of practicable options, for energy and resource efficiency, the use of cleaner technology, cleaner production, and the prevention, reduction and minimisation of waste, and shall include waste reduction targets. The Schedule shall include time frames for the achievement of set targets and shall address a five year period as a minimum.” Condition 2.2.2.3 of the licence requires that GSK Cork maintain an Environmental Management Programme (EMP) for the achievement of the Objectives and Targets prepared under the Schedule above. The Schedule and the EMP shall be reviewed annually and amendments thereto notified to the EPA for agreement as part of the Annual Environmental Report. This EMP describes the method and time frame in which GSK aims to complete these objectives. The EMP comprises a number of categories as follows:

1. Environmental Management System Review

2. Emissions to Atmosphere of Volatile Organic Compounds

3. Waste Management (Solid and Liquid)

4. Surface Water Quality & Number of diversions

5. Incinerator Wastewater & Bioplant Effluent Quality

6. Groundwater Quality

7. Energy reduction

8. Reduction in water usage.

For each of these headings the following information is outlined:

• Objective

• Rationale behind objective

• Specific targets to achieve objective

• Plan to achieve targets

• Time scale

• Teams responsible.


1.0 Objective Environmental Management System Review

Rationale: Modify EMS as needs be to address compliance issues & continue to improve system

NO. Target Plan Time scale Responsibility

1.1 Update EHS procedures to comply with current/new regulations.

Modify EMS to include details of IPPC licence. Q4 2010 Environmental Regulatory Leader

(ERL)

1.2 Train personnel on IPPC licence and additional new regulations to relevant groups onsite.

Carry out training sessions as required. Q4 2010 ERL

1.3 Optimise incident investigation process

Use Operation excellence tools – 5 why, 5W&H, Fish bone etc to investigate root causes of EPA reportable incidents.

Q1 2010 ERL

2.0 Objective Emissions to atmosphere (Volatile Organic Compounds).

Rationale: To control and prevent emissions of Volatile Organic Compounds from site activities being detected off-site.


2.1 Prevent emission of Volatile Organic Compounds (VOC) from SCR 1901.

Maximise Incinerator uptime (Target 99.5%) Minimise incinerator bypass time (Target <80hours) Manage Bypass emissions to ensure Air quality limits (Ground level concentration) are complied with.

Q4 2010 Environmental Operations Leader

(EOL)

ERL

2.2 Reduce fugitive solvent emissions from storage tanks. There are fugitive emissions from virgin and recovered tanks when backloading from road tankers.

Complete the project to route fugitive solvent emissions ex THF, Ethyl acetate and MDC (virgin) solvent storage tanks from atmosphere to incinerator via Lean Gas Header.

Q2 2010 Process / EHS Team


3.0 Objective To manage liquid and solid waste on-site to meet all IPPC Licence requirements and to identify additional waste reduction, recovery and recycling opportunities.

Rationale: To ensure compliance with IPPC Licence, GSK Corporate and Legislative requirements.


3.1 To assess external waste facilities accepting GSK Cork waste.

Audit two external waste handling facilities.

Q4 2010 EHS Team

3.2 Carry out an assessment of current and future solvent recovery opportunities.

Based on business projections, review solvents in use on current & future proposed processes for recovery feasibility (environmental, technical & financial).

Q4 2010 Technical Operations

3.3 Carry out a review of technology with a view to reducing waste generation.

Review technology use onsite on solvent recovery abatement, wastewater treatment, etc., with a view to improving waste minimisation.

Q4 2010 Technical Operations

3.4 Reduce waste formation at source where possible.

1 Investigate opportunities for waste reduction at source. 2. Resource projects to implement waste reductions

Q4 2010 Technical Development / EHS


4.0 Objective To protect the quality of surface water.

Rationale: To prevent the contamination of surface water.


4.1 To reduce TOC in surface water from site. (2009 average 28 mg/L).

1. Monitor TOC quality. 2. Maintain awareness of surface water quality across the site. 3. Act on significant TOC contaminations. 4. Investigate root causes of spills where possible.

Q4 2010

EHS / Process Dept.

4.2 To reduce the frequency of SW diversions to biotreatment

1. Monitor diversion count. 2. Surface water diversion count to be reduced by 20% in 2010 (from 120 to 96). 3. Integrity test SW pipeline network. 4. Repair damaged/rogue lines

Q4 2010

EHS / Process Dept.

5.0 Objective To protect the quality of incinerator wastewater emissions

Rationale: To ensure IPPC compliance with all parameters in both streams.


5.1 Minimise TSS EPA reportable incidents.

1. Optimise the incinerator wastewater caustic control to reduce pH excursions that lead to water hardness solids precipitating. 2. Instal air diffusers in waste tanks to ensure improved mixing of wastes & reduced ‘layering’.

Q4 2010 EHS Team

5.2 To achieve minimum non-compliances due to high suspended solids in incinerator wastewaters in 2010.

Analyse Incinerator wastewater for metals as per Schedule B.2 (W1) of IPPC licence when solids are >45mg/l ELV.

Q4 2010 EHS Team


6.0 Objective To protect the quality of groundwater.

Rationale: To protect the quality of groundwater sources beneath the site and prevent contamination.


6.1 To monitor groundwater quality. Biannual sampling analysis. 2010 ERL

6.2 Reduce ammonium and bacteriological levels in the groundwater.

1. Monitor levels of contaminants. 2. Pump and biotreat. 3. Fix foul pipeline leaks where necessary.

2010 Engineering/EHs

6.3 To ensure maximum protection of groundwater quality on-site by carrying out remediation of any ruptured underground lines identified.

Carry out repairs / remediation on underground pipelines as required.

2009 and 2010 ongoing

Engineering


Reduction in energy requirements for GSK Cork site

Rationale: To reduce the energy requirements for the operations on site

NO. Target Plan Time scale

Responsibility

7.1 Reduce natural gas consumption Continue implementation of Waste Accountability Improvement Project across the site – reduction in water content of liquid waste for incineration will reduce the fuel requirement (natural gas consumption).

Q3 2010 EHS & Tech Developement Teams

7.2 Reduce natural gas and electricity consumption

Modify Incinerator No.3 to allow it operate in Thermal Oxidiser mode when there is no liquid waste to be incinerated

Q3 2010 Capital & Projects & EHS Teams

7.3 Monitor key energy usage areas for trends

The site metering system will be used to analyse the trends in usages in high usage areas around the site to facilitate future improvements in efficiency.

2010 and onwards

Energy & Utilities Champion

8.0 Objective

Reduction in water requirements for GSK Cork site

Rationale: To reduce the water requirements for the operations on site

NO. Target Plan Time scale

Responsibility

8.1 Reduce leakage of mains water Continue to investigate and repair leaks on underground firewater main.

Q2 2010 Site Services

8.2 Reduce use of mains water on Incinerator quench

Carry out feasibility study on use of redundant aeration basin for storing rainwater & acceptable grade of waste water which could then be used as quench water on Incinerator.

Q4 2010 Capital & Projects & EHS Teams

APPENDIX E

ENVIRONMENTAL MANAGEMENT PROGRAMME (EMP) PROGRESS REPORT 2009

EMP 2009 Report IPPC Licence Reg. No. P0004-03

Report on the Environmental Management Programme (EMP) during 2009 Condition 2.2.2.2 of IPPC Licence Reg. No. P0004-03 requires that GlaxoSmithKline (Cork) Ltd. maintain a Schedule of Environmental Objectives and Targets. The Schedule shall, at a minimum, provide for a review of all operations and processes, including an evaluation of practicable options, for energy and resource efficiency, the use of cleaner technology, cleaner production, and the prevention, reduction and minimisation of waste, and shall include waste reduction targets. The Schedule shall include time frames for the achievement of set targets and shall address a five-year period at a minimum. Condition 2.2.2.3 of the licence requires that GSK Cork maintain an Environmental Management Programme (EMP) for the achievement of the Objectives and Targets prepared under the Schedule above. The Schedule and the EMP shall be reviewed annually and amendments thereto notified to the EPA for agreement as part of the Annual Environmental Report. This EMP describes the method and time frame in which GSK aims to complete these objectives. The 2009 EMP comprises a number of categories as follows:

1. Environmental Management System Review

2. Emissions to Atmosphere of Volatile Organic Compounds

3. Waste Management (Solid and Liquid)

4. Surface Water Quality

5. Incinerator Wastewater & Bioplant Effluent Quality

6. Groundwater Quality

7. Energy reduction

8. Reduction in water usage.

For each of these headings the following information is outlined:

• Objective

• Rationale behind objective

• Specific targets to achieve objective

• Plan to achieve targets

• Time scale

• Teams responsible.


1.0 Objective Environmental Management System Review

Rationale: To install the IPPC Licence on site and ensure full compliance

NO. Target Plan Progress achieved during 2009

1.1 Continue to embed the IPPC licence into EMS in 2008.

Modify EMS to include details of IPPC licence.

1. Environmental testing procedures updated to reflect the use of internationally recognised standards. 2. Laboratory methods validated using the five criteria of validation i.e. linearity, precision, uncertainty, limit of quantification and suitability of test matrix.

1.2 To continue to communicate the conditions of the licence and additional new regulations to relevant groups onsite.

Carry out training sessions as required. 1. Trained IPPC licence requirements to new starters & Eng Ops. 2. Trained incident investigation & emergency response to Operations team. 3. Implemented new incinerator bypass emissions procedure ENVP-046 as per EPA guidance letter. 4. Conducted QAL2 testing in compliance with IS14181.


2.0 Objective Emissions to atmosphere (Volatile Organic Compounds).

Rationale: To control and prevent emissions of Volatile Organic Compounds from site activities being detected off-site.


2.1 Prevent emission of Volatile Organic Compounds (VOC) from SCR 1901.

Optimise operation of the incinerators to give an uptime of 99.5%+ on the Lean Gas Header system to the incinerators and consequently to minimise the run time of the site emergency scrubber SCR1901. This is a key performance indicator for the site. Use the on line FTIR to quantify the VOC emissions from vent of SCR 1901 during incinerator failure on Lean Gas Header. Also use the FTIR to prevent ground level concentrations breaching air quality limits.

1. Incinerator uptime of 98.75%. 2. Hours of LGH on SCR1901 minimised. 3. Bypass analyser used to indicate 1150kg solvent emitted in 2009. 4. FTIR bypass analyser now provides live information of solvent emissions during bypass. Typical levels <2% GLC limits.

2.2 Reduce fugitive solvent emissions from storage tanks. There are fugitive emissions from virgin and recovered tanks when backloading from road tankers.

Complete the project to route fugitive solvent emissions ex THF, Ethyl acetate and MDC (virgin) solvent storage tanks from atmosphere to incinerator via Lean Gas Header.

Project completed in Q1 2009.


3.0 Objective To manage liquid and solid waste on-site to meet all IPPC Licence requirements and to identify additional waste reduction, recovery and recycling opportunities.

Rationale: To ensure total compliance with IPPC Licence, GSK Corporate and Legislative requirements.


3.1 Complete audits of external waste treatment sites

Audit three external waste handling facilities.

One external audit was conducted in 2009. – Eras Eco waste sludge drying facility, Youghal. An audit of Indaver onsite total waste management services completed.

3.2 To carry out solvent recovery on one new waste solvent stream as per site business plan.

Carry out solvent recovery on methyl cyclohexane from Solzira stage 4.

Viability proven out for MCH recovery. MCH being stored for recovery which will happen in 2010.

3.3 Carry out an assessment of current and future solvent recovery opportunities.

Based on business projections, review solvents in use on current & future proposed processes for recovery feasibility (environmental, technical & financial).

Consistently carried out. All new products are assessed for recovery opportunities.

3.4 Carry out a review of technology with a view to reducing waste generation.

Review technology use onsite on solvent recovery abatement, wastewater treatment, etc., with a view to improving waste minimisation.

Corporate team looks at new technologies e.g. supercritical oxidation, chemical oxidation, ozonation etc. for suitability.

3.5 Reduce waste formation at source where possible.

Segregate waste liners from processing to allow for compaction and reduced number of solid waste drums sent for disposal off-site.

Hazardous solid waste compaction project in place and in use. In 2008, 1.26 steel drums (200L) of solids were wasted per batch compared to 0.26 per batch in 2009.


4.0 Objective To protect the quality of surface water.

Rationale: To prevent the contamination of surface water.


4.1 To ensure that the TOC in surface water from site is <40 mg/L in 2009.

Maintain awareness of surface water quality across the site. Track TOC quality and act on significant TOC contaminations.

Surface water quality awareness sessions conducted with relevant teams on site. TOC quality monitored weekly & reviewed monthly by site leadership team. TOC average was 28mg/l in 2009.

4.2 To reduce the frequency of diversions on-site to firewater ponds.

Numbers of surface water diversions to be reduced by 20% in 2009.

Number of diversions reduced from 213 to 120 (45% reduction). Diversions are investigated to root cause where possible.

5.0 Objective To protect the quality of incinerator wastewater emissions

Rationale: To ensure IPPC compliance with all parameters in both streams.


5.1 To manage high Total Suspended Solids (TSS) in incinerator waste water stream.

Regularly test solids for content to confirm water hardness salts/firebrick as constituents. Divert acid washings of incinerator quench tank for bio-treatment to reduce water hardness salt crash out.

As per Agency letter Ref P0004-03 /NC06SMcD.doc, where solids >45mg/l ELV, monitoring for metals is carried out.

5.2 To achieve minimum non-compliances due to high suspended solids in incinerator wastewaters in 2008.

To optimise operational control to minimise number of suspended solids non-compliances.

1. Incinerator quench caustic dosing was enhanced in 2009. 2. New waste streams from R&D are risk assessed & tested for % inorganic salts in response to TSS incidents in March 2009.


6.0 Objective To protect the quality of groundwater.

Rationale: To protect the quality of groundwater sources beneath the site and prevent contamination.


6.1 To monitor groundwater quality.

Biannual sampling analysis. Complete.

6.2 To monitor ammonium and coliform levels in the groundwater.

Track the levels of contaminants from foul sewer leak.

Ammonium and bacteriological contamination of GW monitored in 2009 and reported in Section 5.3 of AER.

6.3 To ensure maximum protection of groundwater quality on-site by carrying out remediation of the underground lines.

Carry out repairs / remediation on underground pipelines as required.

Entire foul sewerage system has been tested and repaired in 2009 at a cost of ~ €260,000.


7.0 Objective Reduction in energy requirements for GSK Cork site

Rationale: To reduce the energy requirements for the operations on site


7.1 Reduce natural gas consumption.

Implement Waste Accountability Improvement Project across the site – reduction in water content of waste solvent for incineration will reduce the fuel requirement (natural gas consumption).

Waste Accountability project contributed to 14% overall reduction in natural gas consumption in 2009.

7.2 Reduce electrical consumption load by improved control of HVAC draw.

Roll out project to optimise HVAC ventilation rates across the site to smaller buildings (Phase 2).

Phase 2 of HVAC air change reduction project completed in 2009.

7.3 Monitor key energy usage areas for trends.

The site metering system will be used to analyse the trends in usages in high usage areas around the site to facilitate future improvements in efficiency.

Site Monitoring and Targeting system used extensively during the year to track energy use against targets.

7.5 Audit site Energy Management System.

A GSK Energy Manager (Corporate) will audit the site’s Energy Management System at a high level.

High level audit of the site’s Energy Reduction Programme was carried out by GSK’s GMS Energy Manager in June 2009.

8.0 Objective Reduction in water requirements for GSK Cork site

Rationale: To reduce the water requirements for the operations on site


8.1 Reduce leakage of mains water. Investigate and repair leaks identified in 2008, particularly on firewater system.

Major leaks on firewater main repaired during 2009

APPENDIX F

PRTR AND AER SUMMARY DATA TABLES FOR 2009

| PRTR# : P0004 | Facility Name : Smithkline Beecham (Cork) Limited | Filename :

Appendix F_AER Returns Worksheet P0004_2009(1).xls | Return Year : 2009 | 3313 24/03/2010 17:50

Version 1.1.10

REFERENCE YEAR 2009

1. FACILITY IDENTIFICATION

Parent Company Name Smithkline Beecham (Cork) Limited

Facility Name Smithkline Beecham (Cork) Limited

PRTR Identification Number P0004

Licence Number P0004-03

Waste or IPPC Classes of Activity

No. class_name

5.16

The use of a chemical or biological process for the production of

basic pharmaceutical products.

11.1 #######################################################

Address 1 Currabinny

Address 2 Carrigaline

Address 3 County Cork

Address 4

Country Ireland

Coordinates of Location -8.31547 51.8169

River Basin District IESW

NACE Code 2120

Main Economic Activity Manufacture of pharmaceutical preparations

AER Returns Contact Name Gary Hanniffy

AER Returns Contact Email Address [email protected]

AER Returns Contact Position Environmental Regulatory Leader

AER Returns Contact Telephone Number 021-4512335

AER Returns Contact Mobile Phone Number

AER Returns Contact Fax Number 021-4378560

Production Volume 125.651

Production Volume Units Metric Tonnes

Number of Installations 1

Number of Operating Hours in Year 8232

Number of Employees 422

User Feedback/Comments

Web Address www.gsk.com

2. PRTR CLASS ACTIVITIES

Activity Number Activity Name

4(e)

Installations using a chemical or biological process for the production

on an industrial scale of basic pharmaceutical products

50.1 General

3. SOLVENTS REGULATIONS (S.I. No. 543 of 2002)

Is it applicable? No

Have you been granted an exemption ? No

If applicable which activity class applies (as per

Schedule 2 of the regulations) ?

Is the reduction scheme compliance route being

used ?

AER Returns Worksheet

4.1 RELEASES TO AIR | PRTR# : P0004 | Facility Name : Smithkline Beecham (Cork) Limited | Filename : Appendix F_AER Returns Worksheet P0004_2009(1).xls | Return Year : 2009 | 24/03/2010 17:50

8 16 24 27 35 43 6 7 6 7 6 7 12

SECTION A : SECTOR SPECIFIC PRTR POLLUTANTS

QUANTITY

A2-1. A2-3A.

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

A (Accidental)

KG/Year

F (Fugitive)

KG/Year

03 Carbon dioxide (CO2) C OTH

Natural gas & bioplant

emission calculations 0.0 0.0 11848.0 0.0 11848.0

11 Sulphur oxides (SOx/SO2) M OTH Infra red spectroscopy 42.7 1.0 43.7 0.0 0.0

08 Nitrogen oxides (NOx/NO2) M OTH Infra red spectroscopy 1019.1 1242.8 2261.9 0.0 0.0

80 Chlorine and inorganic compounds (as HCl) M OTH Infra red spectroscopy 1.5 1.4 2.9 0.0 0.0

47 PCDD + PCDF (dioxins + furans)(as Teq) M BS EN 1948-1:2006 0.000001456 0.000000058 0.000001514 0.0 0.0

07 Non-methane volatile organic compounds (NMVOC) C OTH US EPA AP42 - Tanks 4.0 0.0 0.0 1460.0 0.0 1460.0

19 Chromium and compounds (as Cr) M BS EN 14385:2004 0.35 0.12 0.47 0.0 0.0

20 Copper and compounds (as Cu) M BS EN 14385:2004 0.0 0.086 0.086 0.0 0.0

22 Nickel and compounds (as Ni) M BS EN 14385:2004 0.26 0.19 0.45 0.0 0.0

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

SECTION B : REMAINING PRTR POLLUTANTS

QUANTITY

.A2-1 .A2-3A

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

A (Accidental)

KG/Year

F (Fugitive)

KG/Year

02 Carbon monoxide (CO) M OTH Infra red spectroscopy 72.4 0.2 72.6 0.0 0.0

84 Fluorine and inorganic compounds (as HF) M OTH US EPA AP26 & 26A 1.3 0.9 2.2 0.0 0.0

73 Toluene C OTH US EPA AP42 - Tanks 4.0 0.0 0.0 202.1 0.0 202.1

35 Dichloromethane (DCM) C OTH US EPA AP42 - Tanks 4.0 0.0 0.0 589.3 0.0 589.3


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

QUANTITY

.A2-1 .A2-3A

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

A (Accidental)

KG/Year

F (Fugitive)

KG/Year

351 Total Organic Carbon (as C) M OTH Flame Ionisation Detection 0.8 0.0 0.8 0.0 0.0

209 Dimethylformamide M OTH FT Infra Red 0.0 0.0 0.0 0.0 0.0

210 Dust M OTH Optical Dispersion 0.3 0.3 0.6 0.0 0.0

214 Hydrogen bromide M US EPA AP26 & 26A 4.3 4.8 9.1 0.0 0.0

356 Cobalt M BS EN 14385:2004 0.0 3.8 3.8 0.0 0.0

321 Manganese (as Mn) M BS EN 14385:2004 0.00026 0.052 0.05226 0.0 0.0

230 TA Luft organic substances class 1 M OTH FT Infra Red 0.0 0.0 693.58 0.0 693.58




Additional Data Requested from Landfill operators

Landfill: Smithkline Beecham (Cork) Limited

Please enter summary data on the

quantities of methane flared and / or utilised

additional_pollutant_no T (Total) kg/Year M/C/E Method Code Designation or Description

Facility Total Capacity m3

per hour

Total estimated methane generation (as per site

model) 0.0 N/A

Methane flared 0.0 0.0 (Total Flaring Capacity)

Methane utilised in engine/s 0.0 0.0 (Total Utilising Capacity)

Net methane emission (as reported in Section A

above) 0.0 N/A

Method Used

Method Used

RELEASES TO AIR

POLLUTANT METHOD

Method Used

POLLUTANT

RELEASES TO AIR

RELEASES TO AIR

METHOD

POLLUTANT METHOD

Method Used

For the purposes of the National Inventory on Greenhouse Gases, landfill operators are requested to provide summary data on landfill gas (Methane)

flared or utilised on their facilities to accompany the figures for total methane generated. Operators should only report their Net methane (CH4) emission

to the environment under T(total) KG/yr for Section A: Sector specific PRTR pollutants above. Please complete the table below:

Sheet : Releases to Waters AER Returns Worksheet 24/3/2010 17:10

4.2 RELEASES TO WATERS | PRTR# : P0004 | Facility Name : Smithkline Beecham (Cork) Limited | Filename : Appendix F_AER Returns Worksheet P0004_2009(1).xls | Return Year : 2009 | 24/03/2010 17:50

8 15 23 23 31 36 6 6 6 6 6 6 0

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

QUANTITY

SW01

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

47 PCDD + PCDF (dioxins + furans)(as Teq) M

BS EN 1948-

1:2006 0.0000096 0.0000096 0.0 0.0

19 Chromium and compounds (as Cr) M PER

ICP Inductively coupled

plasma 3.4 3.4 0.0 0.0

20 Copper and compounds (as Cu) M PER AA Atomic absorption 4.9 4.9 0.0 0.0

22 Nickel and compounds (as Ni) M PER AA 2.4 2.4 0.0 0.0

23 Lead and compounds (as Pb) M PER ICP 0.092 0.092 0.0 0.0

24 Zinc and compounds (as Zn) M PER AA 12.8 12.8 0.0 0.0

12 Total nitrogen M

BS EN

12260:2003d 581.39 581.39 0.0 0.0

13 Total phosphorus M

BS EN

6878:2004 685.91 685.91 0.0 0.0


SECTION B : REMAINING PRTR POLLUTANTS

QUANTITY


0.0 0.0 0.0 0.0


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

QUANTITY

SW01

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

351 Total Organic Carbon (as C) M OTH FID 7653.0 7653.0 0.0 0.0

306 COD M ISO15705:2002 20742.0 20742.0 0.0 0.0

240 Suspended Solids M EN872:2005 2396.0 2396.0 0.0 0.0

303 BOD M APHA ETO662 747.0 747.0 0.0 0.0

238 Ammonia (as N) M ISO6778-1984 128.83 128.83 0.0 0.0

327 Nitrate (as N) M

APHA 4500-

NO3E 140.0 140.0 0.0 0.0


RELEASES TO WATERS

RELEASES TO WATERS

Method Used

POLLUTANT

Method Used

POLLUTANT

POLLUTANT

RELEASES TO WATERS

Method Used

| PRTR# : P0004 | Facility Name : Smithkline Beecham (Cork) Limited | Filename : P0004_2009(1).xls | Return Year : 2009 | Page 1 of 2

Sheet : Releases to Waters AER Returns Worksheet 24/3/2010 17:10


4.3 RELEASES TO WASTEWATER OR SEWER | PRTR# : P0004 | Facility Name : Smithkline Beecham (Cork) Limited | Filename : Appendix F_AER 24/03/2010 17:50

8 8 16 16 6 6 6 6

SECTION A : PRTR POLLUTANTS

QUANTITY


0.0 0.0 0.0 0.0


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

QUANTITY

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

0.0 0.0 0.0 0.0


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

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

Method Used

Method Used

POLLUTANT METHOD

POLLUTANT METHOD

4.4 RELEASES TO LAND

8 8

SECTION A : PRTR POLLUTANTS

No. Annex II Name


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

Pollutant No. Name


POLLUTANT

RELEASES TO LAND

RELEASES TO LAND

POLLUTANT

| PRTR# : P0004 | Facility Name : Smithkline Beecham (Cork) Limited | Filename : Appendix F_AER Returns Worksheet P0004_2009(1).xls | Return Year : 2009 |

16 16 6 6

M/C/E Method Code Designation or Description Emission Point 1

0.0


M/C/E Method Code Designation or Description Emission Point 1

0.0


METHOD

Method Used

METHOD

Method Used

| PRTR# : P0004 | Facility Name : Smithkline Beecham (Cork) Limited | Filename : Appendix F_AER Returns Worksheet P0004_2009(1).xls | Return Year : 2009 | 24/03/2010 17:50

6 6

QUANTITY

T (Total) KG/Year A (Accidental) KG/Year

0.0 0.0

QUANTITY

T (Total) KG/Year A (Accidental) KG/Year

0.0 0.0

Sheet : Treatment Transfers of Waste AER Returns Worksheet 12/3/2010 13:12

5. ONSITE TREATMENT & OFFSITE TRANSFERS OF WASTE | PRTR# : P0004 | Facility Name : Smithkline Beecham (Cork) Limited | Filename : Appendix F_AER Returns Worksheet P0004_2009(1).xls | Return Year : 2009 | 24/03/2010 17:50

5 57 56

Quantity

(Tonnes per

Year)

Haz Waste : Name and

Licence/Permit No of Next

Destination Facility Non

Haz Waste: Name and

Licence/Permit No of

Recover/Disposer

Haz Waste : Address of Next

Destination Facility

Non Haz Waste: Address of

Recover/Disposer

Name and License / Permit No. and

Address of Final Recoverer /

Disposer (HAZARDOUS WASTE

ONLY)

Actual Address of Final Destination

i.e. Final Recovery / Disposal Site

(HAZARDOUS WASTE ONLY)

Transfer Destination

European Waste

Code Hazardous Quantity T/Year Description of Waste

Waste

Treatment

Operation M/C/E Method Used

Location of

Treatment Name and Licence / Permit No. of Recoverer / Disposer / Broker Address of Recoverer / Disposer / Broker Name and Address of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY) Licence / Permit No. of Final Destination i.e. Final Recovery / Disposal Site (HAZARDOUS WASTE ONLY)

Within the Country 15 01 06 No 8.47 Dry mixed recyclables R3 M Weighed Offsite in Ireland

Greenstar Recycling (Cork)

,136-2

Sarsfieldcourt,

Glanmire,Cork,.,Ireland

Within the Country 17 01 07 No 824.06 C&D Waste R5 M Weighed Offsite in Ireland John Butler,CK (S) 113/04 Riverstick,Co. Cork,.,.,Ireland

Within the Country 17 01 07 No 110.78 C&D Waste D1 M Weighed Offsite in Ireland Greenstar Landfill ,W0146-1

Knockharley,Co.

Meath,.,.,Ireland

Within the Country 17 01 07 No 9.64 C&D Waste R3 M Weighed Offsite in Ireland


,136-2

Sarsfieldcourt,


Within the Country 17 03 02 No 31.18 Tarmac R3 M Weighed Offsite in Ireland John Butler,CK (S) 113/04 Riverstick,Co. Cork,.,.,Ireland

Within the Country 17 03 02 No 88.44 Tarmac R3 M Weighed Offsite in Ireland John A. Wood,CK (S) 88/04

Killanully,Ballygarvan,Co.

Cork,.,Ireland

Within the Country 20 01 01 No 79.56 Confidential paper R3 M Weighed Offsite in Ireland

Cork Confidential Shredding

Ltd.,CK (S) 288/06

Unit K5,Marina Commerical

Park,Co. Cork,.,Ireland

Within the Country 20 01 01 No 23.93 Paper and Cardboard R3 M Weighed Offsite in Ireland


,136-2

Sarsfieldcourt,


Within the Country 20 01 02 No 1.5 Glass bottles and jars R5 M Weighed Offsite in Ireland

Rehab Recycling

(Cork),03/07'

Monahan

Road,Cork,.,.,Ireland

Within the Country 20 01 08 No 3.74 Food waste R10 M Weighed Offsite in Ireland

Greenstar Composting

Facility,136-2

Milltown,Co.

Tipperary,.,.,Ireland

Within the Country 20 01 08 No 21.06 Mixed waste R10 M Weighed Offsite in Ireland Greenstar Landfill ,W0146-1

Knockharley,Co.

Meath,.,.,Ireland

Within the Country 20 01 08 No 31.58 Mixed waste D1 M Weighed Offsite in Ireland Greenstar Landfill ,W0146-1

Knockharley,Co.

Meath,.,.,Ireland

Within the Country 20 01 25 No 0.52 Waste cooking oil R9 M Weighed Offsite in Ireland Frylite Ltd. ,WR/77

Kilcoolgan,Co.

Galway,.,.,Ireland

Within the Country 20 01 25 No 1.84 Waste cooking oil R9 M Weighed Offsite in Ireland


,136-2

Sarsfieldcourt,


Within the Country 20 01 36 No 31.08 Waste cable R4 M Weighed Offsite in Ireland

Cork Metal Company

Ltd.,WP 08/02 Dublin Hill ,Cork,.,.,Ireland

Within the Country 20 01 38 No 76.22 Timber R3 M Weighed Offsite in Ireland

Waste Recovery

Services,107-1 Fermoy,Co. Cork,.,.,Ireland

Within the Country 20 01 40 No 311.31 Scrap metal - carbon steel & stainless steel R4 M Weighed Offsite in Ireland

Cork Metal Company

Ltd.,WP 08/02 Dublin Hill ,Cork,.,.,Ireland

Within the Country 07 05 12 No 368.32 Waste sludge D13 M Weighed Offsite in Ireland

Collins Waste Disposal,CK

(S) 18/02

Farranbrien East,Minane

Bridge,Co. Cork,.,Ireland

Within the Country 20 03 07 No 115.31 Mixed dry waste for landfill R5 M Weighed Offsite in Ireland


,136-2

Sarsfieldcourt,


To Other Countries 06 01 02 Yes 2.569 Dilute hydrochloric acid D10 M Weighed Abroad Indaver Ireland Ltd,36-2

Tolka Quay Road,Dublin Port

,Dublin 1,.,Ireland

AVG IB2234,IB2234,Abfall-

Verwertungs,Gesellschaft,Ha

mburg,.,Germany

Abfall-


mburg,.,Germany

To Other Countries 06 01 04 Yes 0.633 Phosphoric acid D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Kommunikemi a/s,8-76-1-

449-49-2005,Lindholmvej

3,5800 Nyborg,.,.,Denmark

Lindholmvej 3,5800

Nyborg,.,.,Denmark

To Other Countries 06 01 06 Yes 0.266 Acidic wastes D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Indaver

NV,MLAVI/9800000485,Pllde

rlietweg,B2030,Antwerp,.,Bel

gium

Pllderlietweg,B2030,Antwerp,

.,Belgium

To Other Countries 06 02 04 Yes 0.6 Alkaline wastes D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Indaver



gium


.,Belgium

To Other Countries 07 05 01 Yes 1.938 Aqueous sludges D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Indaver



gium


.,Belgium

Method Used



Quantity

(Tonnes per

Year)




Haz Waste: Name and


Recover/Disposer




Recover/Disposer




ONLY)





European Waste


Waste

Treatment


Location of


Method Used

To Other Countries 07 05 03 Yes 464.538 Mixed solvent waste D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Indaver



gium


.,Belgium

Within the Country 07 05 03 Yes 22.44 Mixed solvent waste D13 M Weighed Offsite in Ireland Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Indaver Irl,IPPC-36-2,Tolka

Quay Rd,Dublin Port,Dublin

1,.,Ireland

Tolka Quay Rd,Dublin

Port,Dublin 1,.,Ireland



,Dublin 1,.,Ireland



mburg,.,Germany

Abfall-


mburg,.,Germany



,Dublin 1,.,Ireland

Kommunikemi a/s,8-76-1-

449-49-2005,Lindholmvej

3,5800 Nyborg,.,.,Denmark

Lindholmvej 3,5800

Nyborg,.,.,Denmark

To Other Countries 07 05 04 Yes 2.163 Waste solvent D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland



mburg,.,Germany

Abfall-


mburg,.,Germany

To Other Countries 07 05 04 Yes 7.261 Waste solvent D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Indaver



gium


.,Belgium

To Other Countries 07 05 04 Yes 278.696 Waste solvent R2 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

SRM,BV46651G,Hayhole

Road,North Shields,NE29

6DY,.,United Kingdom

Hayhole Road,North

Shields,NE29 6DY,.,United

Kingdom

To Other Countries 07 05 11 Yes 0.6 Waste sludge D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Indaver



gium


.,Belgium

Within the Country 07 05 13 Yes 0.12 Mixed packaged waste R4 M Weighed Offsite in Ireland Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Rilta Environmental,WO192-

02,Block 402,Greenogue

Business Park

,Rathcoole,Co. Dublin,Ireland

Block 402,Greenogue

Business Park


To Other Countries 07 05 13 Yes 7.323 Mixed packaged waste D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland



mburg,.,Germany

Abfall-


mburg,.,Germany

To Other Countries 07 05 13 Yes 110.154 Mixed packaged waste D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Indaver



gium


.,Belgium

To Other Countries 13 01 10 Yes 0.1 Waste hydraulic oils D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Indaver



gium


.,Belgium

To Other Countries 13 02 08 Yes 0.2 Waste oil D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Indaver



gium


.,Belgium

To Other Countries 13 08 99 Yes 0.2 Engineering oil D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Indaver



gium


.,Belgium

To Other Countries 15 01 10 Yes 38.252 Contaminated packaging D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Indaver



gium


.,Belgium



Quantity

(Tonnes per

Year)




Haz Waste: Name and


Recover/Disposer




Recover/Disposer




ONLY)





European Waste


Waste

Treatment


Location of


Method Used

Within the Country 15 01 10 Yes 25.466 Empty unclean metal drums R4 M Weighed Offsite in Ireland Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Rilta Environmental,WO192-

02,Block 402,Greenogue

Business Park


Block 402,Greenogue

Business Park


To Other Countries 15 02 02 Yes 12.727 Contaminated filters, liners and PPE D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Indaver



gium


.,Belgium

To Other Countries 16 05 06 Yes 0.453 Mixed solvent wastes from laboratory D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Indaver



gium


.,Belgium

To Other Countries 16 05 06 Yes 0.153 Mixed solvent wastes from laboratory D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland



mburg,.,Germany

Abfall-


mburg,.,Germany

To Other Countries 16 05 08 Yes 0.135 Mixed liquid chemical waste D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland



mburg,.,Germany

Abfall-


mburg,.,Germany

To Other Countries 16 05 08 Yes 4.249 Mixed liquid chemical waste D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Indaver



gium


.,Belgium

To Other Countries 16 10 01 Yes 1.38 Contaminated aqueous sludges D10 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Indaver



gium


.,Belgium

To Other Countries 16 11 05 Yes 10.544 Incinerator lining D9 M Weighed Abroad Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Indaver



gium


.,Belgium

Within the Country 18 01 03 Yes 0.04 Medical waste D9 M Weighed Offsite in Ireland Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Ecosafe Systems Ltd.,EPA

W0054-2,Unit 1A,Allied

Industrial Estate,Kylemore

Road,Dublin 10,Ireland

Unit 1A,Allied Industrial

Estate,Kylemore Road,Dublin

10,Ireland

Within the Country 20 01 21 Yes 0.19 Flourescent tubes R4 M Weighed Offsite in Ireland Indaver Ireland Ltd,36-2


,Dublin 1,.,Ireland

Irish Lamp Recycling,WFP-

KE-0348-

01,Blackpark,Kilkenny

Road,Athy,Co.

Kildare,Ireland

Blackpark,Kilkenny

Road,Athy,Co.

Kildare,Ireland

Within the Country 07 05 04 Yes 4275.83 Non halogenated solvents D10 M Weighed Onsite in Ireland

GlaxoSmithKline,IPPC

P0004-03

Currabinny,Ringaskiddy,Co.

Cork,.,Ireland


P0004-

03,Currabinny,Ringaskiddy,C

o. Cork,.,Ireland


Cork,.,Ireland

Within the Country 07 05 04 Yes 2371.7 Non halogenated solvents R1 M Weighed Onsite in Ireland


P0004-03


Cork,.,Ireland


P0004-


o. Cork,.,Ireland


Cork,.,Ireland

Within the Country 07 05 04 Yes 294.5 Non halogenated solvents R2 M Weighed Onsite in Ireland


P0004-03


Cork,.,Ireland


P0004-


o. Cork,.,Ireland


Cork,.,Ireland

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