UCB MANUFACTURING IRELAND LIMITED SHANNON FREE … · UCB Manufacturing Ireland Limited is member...
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UCB Manufacturing Ireland Limited, Register no. P0020-02 AER 2014
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UCB MANUFACTURING IRELAND LIMITED
SHANNON FREE ZONE
SHANNON
CLARE
IE LICENSE REGISTER NO: P0020-02
ANNUAL ENVIRONMENTAL REPORT
2014
UCB Ltd, Register No.: P0020-02 AER 2014
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TABLE OF CONTENTS
1.0 Introduction ......................................................................................................... 4 1.1 Foreword ............................................................................................................... 4
1.2 Facility Information Summary .............................................................................. 4
1.3 Environmental Policy ............................................................................................ 6
1.4 Management Structures ........................................................................................ 7
2.0 Summary Information ........................................................................................ 9 2.1 Self-Monitoring Data ............................................................................................ 9
2.1.1 Emissions to Sewer ................................................................................ 9
2.1.2 Emissions to Storm Waters .................................................................. 11
2.1.3 Emissions to Groundwater ................................................................... 12
2.1.3.1 Bund and Pipeline Testing…………………………………..……….21
2.1.4 Emissions to Atmosphere .................................................................... 22
2.1.5 Waste Management .............................................................................. 25
2.2 Agency Monitoring & Enforcement ................................................................... 26
2.2.1 EPA site visit ....................................................................................... 26
2.3 Energy and Water Consumption ......................................................................... 27
2.3.1 Energy Consumption….......................................................................27
2.3.2 Water Consumption ............................................................................. 28
2.4 Environmental Incidents & Complaints ............................................................. 29
2.4.1 Complaints .......................................................................................... 29
2.4.2 Incidents .............................................................................................. 29
2.5 Copy of Electronic Summary Information ........................................................ 29
3.0 Management of the Activity ............................................................................ 30
3.1 EMP 2014 …………………………………………………………………… 31
3.2 EMP 2015……………………………………………………………………...36
3.3 Finance…...………………………………………………………………….…38
3.4 3rd
Party Audits………………………………………………………………...38
4.0 License Specific Reports……………………………………………………….38
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LIST OF TABLES
Table 1 Summary of Mass Emissions to Sewer ................................................ 10
Table 2 Summary of Toxicity Test Results ...................................................... 11
Table 3 Summary of Air Emission Monitored Parameters ............................... 22
Table 4 Summary of Emissions from VE155 ................................................... 22
Table 5 Summary of Emissions from VE135 ................................................... 23
Table 6 Summary of Non-compliances to Atmosphere .................................... 24
Table 7 Summary Information on Waste Arisings ........................................... 25
Table 8 Summary of EPA Visits ....................................................................... 26
Table 9 Summary of Energy Consumption Data .............................................. 27
Table 10 Summary of Water Consumption Data ................................................ 28
Table 11 Summary of Incidents Reported .......................................................... 29
LIST OF FIGURES
Figure 1 Environment, Health & Safety Policy ....................................................... 6
Figure 2 Company Organisational Structure ............................................................ 8
APPENDICES
1 – SMP Spreadsheet
2 - PRTR
3 – ELRA Financial Provision
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1.0 Introduction
1.1 Foreword
This report, covers the period from January 2014 to December 31, 2014 and has been
prepared in accordance with the EPA Guidance for Annual Environmental Report
(Version 2.0_Draft Jan 2014)) and other relevant updated guidance notes as provided
by the EPA on the agency website (www.epa.ie). The report format does not use the
proposed templates which as indicated by the Agency is not mandatory for 2014.
1.2 Facility Information Summary
Current IED Licence Number: P0020-02
Former IPC Licence Number: 729
NACE Code: 2120
National Grid Reference: -8.89779, 52.7098
Class of Activity:
5.16 The use of a chemical or biological
process for the production of basic
pharmaceutical products.
11.1 The recovery or disposal of waste in a
facility, within the meaning of the Act of
1996, which facility is connected or
associated with another activity
specified in this Schedule in respect of
which a licence or revised licence under
Part IV is in force or in respect of which
a licence under the said Part is or will be
required.
Issue Date: 20th
January, 2006
Licensee Address: UCB Manufacturing Ireland Limited
Shannon Free Zone
Shannon
Co. Clare
UCB Manufacturing Ireland Limited is a medium sized Bulk Pharmaceutical
Manufacturing facility located in the north-west corner of the Shannon Industrial
Estate adjacent to the Shannon International Airport approximately 1 kilometre from
the Shannon town centre. The site occupies approximately 17 acres and is physically
separated from the Airport by an open culvert which carries surface water from the
immediate catchment area to the Shannon River which is located approximately 4km
from the site. To the east the site is overlooked by the Westpark development.
Manufacturing operations commenced on site in 1982 and they have expanded over
the intervening years. The facility contains two Bulk Pharmaceutical synthesis
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facilities known as SP1 and SP3 in which Synthetic Chemistry is undertaken to
produce Bulk Pharmaceutical Product. The site also contains a Pharmaceutical
Finishing Facility SP2 together with associated Laboratory, R & D, Administration,
Warehousing, Tank Farm, Pilot Plant, WWTP, TOU and other key utilities. UCB
Shannon also controls the marketing and intellectual property rights for other
Pharmaceutical Products not manufactured on site.
Production Area Products / Processes Product Indication
SP1 Multi Product Neurological
SP2 Nitrates Blending, Milling and
Bulk Packaging
Cardiovascular
SP3 Nitrates Synthesis (5-ISM and
ISDN)
Cardiovascular
UCB Manufacturing Ireland Limited is member of the UCB Group, UCB has its
headquarters in Brussels, Belgium and it is a leading Global Biopharmaceutical
organisation dedicated to the research, development and commercialisation of
innovative pharmaceutical and biotechnology products in the fields of central nervous
system disorders, allergy/respiratory diseases, immune and inflammatory disorders
and oncology. UCB employs approximately 9,000 people in over 37 countries and
recorded revenue of €3.462 billion in 2014. (http://www.ucb.com/about-
ucb/facts/sales) UCB is listed on the Euronext Brussels Exchange. UCB was recently
ranked in 76th
position in the Global 100 list ( ) of the world most sustainable
companies based on an evaluation of environmental, social and governance
performance indicators. UCB Manufacturing Ireland Limited was acquired by UCB in
2006.
In 2014 Operations continued in SP1, SP2 and SP3 manufacturing Cardiovascular
and Neurological API’s. Approximately 112 Tonnes of product was produced as
finished goods.
The site maintained a high level of compliance in 2014, there were no issues of
environmental significance or external complaints. All external audits were positive
and no Major or Minor non-compliances were reported. The site maintained its
program of continual improvement and a number of Environmental projects were
undertaken in the area of Energy reduction, Waste minimisation, Systems
improvement and compliance.
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1.3 Environmental Policy
Figure 1
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1.4 Management Structures
UCB Manufacturing Ireland Limited operates a structured approach to the
management of its operations. The site is led by the Managing Director and the Senior
Management Team and all departments are fully integrated. (See organisational
structure in Fig 2) The site operates a Right First Time and Continual Improvement
ethos.
The organisation operates a relatively flat management structure with a strong
emphasis on team work. The EHS Director reports directly to the Managing Director
and there also is a link with Corporate EHS within the UCB Organisation. There are
currently two Environmental Officers and an Environmental Technician all of whom
report directly to the EH&S Director. The EHS Team is supported by an
Administrator.
Safety, Environmental and Quality management systems are audited on an on-going
basis by a combination of both internal and external audit teams. UCB is accredited to
the Environmental Management System, ISO 14001.
The facility is classified as a Seveso Tier II site under the terms of the regulations.
The facility operates under licence from the FDA and IMB and the site is subject to
routine Regulatory and Customer Quality Audits. The site is also subject to routine
internal Auditing and a high level of on-going compliance has been maintained in
recent years. There is a strong EHS Culture in place on site.
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Figure 2 Companies Organisational Structure
Managing Director
HR Director Finance & SCM
Director /
SCM Manager
Technical Purchasing
Engineering Director
Facilities & Maint Mgr
Senior IT Support
EH&S Director
SP1
Manager
SP2 / SP3 Plant
Manager
QC & Technical
Support Director
Continuous Improvement
Engineer
QA&V Director
Admin. Assistant
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2.0 Summary Information
This section of the Annual Environmental report (AER) summarises all environmental
and resource monitoring information for the calendar year 2014.
Information on emissions and discharges to air and water are summarised as annual
mass emissions. Each section includes an evaluation of all non-compliances with the
conditions and schedules of the Industrial Emissions licence, together with a summary
of environmental incidents reported to the Agency during 2014.
Information on waste arisings are presented in the format of the AER electronic
spreadsheet as directed by the Agency.
Information relating to complaints and incidents are included in the relevant sections.
Full details on the incidents are available on ALDER. No external complaints were
received in 2014.
The Electronic Summary information relating to emissions, discharges, waste arisings
and resource use have been submitted to the Agency as required.
2.1 Self-Monitoring Data
The following sections provide summary details of UCB’s environmental monitoring
data for 2014.
2.1.1 Emissions to Sewer
An aerobic WWTP is in place on the UCB site which is utilised to affect the
biological treatment of aqueous waste arising from site manufacturing, utilities and
laboratory activities. Wastes which require treatment in the WWTP are screened for
toxins and tested for compatibility before introduction to the plant as per License
requirements.
Treated effluent arising from the WWTP is discharged into the industrial estate sewer
network and is subsequently transferred to the municipal waste water treatment plant.
24hr flow proportional samples of the final effluent are taken and tested in the
Environmental Laboratory to confirm compliance with license limits. Samples are
also taken at each step of the treatment process on a daily basis in order to ensure on-
going monitoring of the process and effective process control. The effective
monitoring of the process ensures the early identification of any changes in the
process that may arise and the prompt implementation of remedial actions where
necessary.
In 2014 the WWTP operated effectively and there were no notified Non-Compliances.
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Table 1 Summary of Mass Emissions to Sewer
MASS EMISSIONS TO SEWER YEAR ON YEAR
2012 2013 2014 License
limits Mass Limits
% change
Reason for Change % of Limit in
2014
Volume (m3)
31,369 33,212 30,862 180m³/d 65,700 -7.1% no significant change in volume of final effluent discharged, daily rate ~ 72 m3/d.
47.0%
pH 6-9 6-9 6 - 9 6 – 9 - no significant change
Temp(°C) <43 <43 <43 43 - no significant change
Toxicity (TU)
<3.1 <3.1 <3.1 10 - no significant change
COD (kgs) 2,867 3,551 15,711 10,000mg/l or 1,400 kg/d
511,000 342.4% Increase in COD due to the introduction of new waste streams from new processes being run in SP1. The impact is not significant.
3.1%
Sulphate (kgs)
2,494 2,426 1,448 1,000 mg/l
65,700 -40.3% The reason for the reduction in sulphate levels compared with 2013 is unclear. The impact is not significant.
2.2%
Nitrates (kgs)
60.7 83 41.5 200 mg/l 13,140 -50.0% A change to routing of SP3 waste has resulted in less nitric acid being used in reception tank B01
0.3%
Ammonia (kgs)
313 146 221 200 mg/l 13,140 51.4% Increase due to the introduction of an ammonia rich stream from new plant processes resulting in elevated concentrations in quarter 1 (within licence ELV)
1.7%
Phosphate (kgs)
4.4 3.5 2.4 n/a n/a -31.4% Reduction due to slightly lower P input over course of year.
Suspended Solids (kgs)
622 561 661 400 mg/l 26,280 17.8% Increase in TSS over the course of the year, no identified cause.
2.5%
Chloride (kgs)
61,158 49,396 42,676 5,000 mg/l
328,500 -13.6% Reduction in chloride over course of year, main sources being production effluent and pH neutralisations.
13.0%
Bromide (kgs)
231 169 197 2,200 mg/l
144,540 16.6% Increase in bromide, no changes to inputs over course of 2014, however detection limit did change and may be the sourec of the increase as many of the results were at or below LOD.
0.1%
Sulphide (kgs)
0.81 0.88 0.63 n/a n/a -28.4% Reduction in sulphide, no identified cause.
Oils, Fats & Grease (kgs)
16.5 17.63 17.12 n/a n/a -2.9% No significant change.
Alkalinity (kgs)
27,549 17,027 21,889 n/a n/a 28.6% Increase in alkalinity, no identified cause
Acetate (kgs)
12.79 0.18 84.00 n/a n/a 46566.7%
Most of data is less than detection limit, however average data skewed by a single high data point in June
BOD (kgs) 154.6 142.2 4027 n/a n/a 2731.9% Increase in BOD due to slower degrading component in new waste stream from Production
Copper (kgs)
0.642 1.736 0.13 0.5 mg/l 32.85 -92.5% Reductio due to lower range analytical method being used, with a lower limit of detection.
0.4%
Zinc (kgs) 2.34 2.75 3 0.5 mg/l 32.85 -4.4% No significant change 8.0%
Toluene 0.016 0.018 0.015 0.1mg/l 6.57 -16.7% No significant change. 0.2%
Xylene 0.016 0.018 0.015 -16.7% No significant change.
VOC 180.9 187.1 5.169 n/a n/a -97.2% Most of data is less than detection limit, however average data skewed by a single high data point inNovember
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Notes:
1 – When calculating the load for materials with analysis values of less than the limit of detection 50% of the limit of detection is taken in the mass emission calculation.
2 – For monthly data the annual load is calculated as the average of the daily data times 365. 3 – No data above the limit of detection exists. 4- There were no bypasses of the WWTP in 2014
Toxicity Testing
Schedule B.3, Emissions to Sewer of the Licence sets a limit of 10 toxic units; results
for 2014 were within the set license limits. City Analysts Limited in Shannon carried
out the required toxicity testing in 2014, continuing the same testing regime as
previous years.
Table 2 Summary of Toxicity Test Results
Test Parameter Conc
% vol.
/vol.
Toxic
Units
2011
Toxic
Units
2012
Toxic
Units
2013
Toxic
Units
2014
INDUSTRIAL
EMISSIONS
ELV Toxic
Units
48h LC50 to Tisbe battagliai > 32 <3.1 <3.1 <3.1 <3.1 10
72 h IC50 to Skeletonema
costatum > 32 <3.1 <3.1 <3.1 <3.1 10
30 min EC50 to Vibrio fischeri N/A <2.2 <2.2 <2.2 <2.2 10
2.1.2 Emissions to Surface waters
Surface water from the UCB site is discharged into the North West catchment, this is
a small open culvert which runs along the Northwest Boundary of the site and collects
all of the surface waters from the industrial estate. The site surface water is discharged
into the culvert via two monitored discharge points SW07 and SW44 that are located
at the northern and southern ends of the site.
All surface water leaving the site is continuously monitored for pH, TOC and Oil
film. In the event that the surface water is outside any of the set trigger limits the
discharge is automatically stopped and subsequently diverted to Fire Water Retention
tanks where it is held pending treatment in the WWTP or offsite disposal.
There were no Licence Non-Compliances in 2014 relating to emissions to Surface
Water. Trigger limits were exceed on three occasions in 2014 in which notifications
were made to the agency. See Section 2.4.2 for full details of the incidents. There
were no offsite effects relating to any of these events. Surface water monitoring data
is included in submitted monthly reports.
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2.1.3 Emissions to Groundwater
Groundwater monitoring is carried out on site as per license requirements and Agency
request. There are seven licensed boreholes on site namely GS01, GSO2, GSO3,
GS04, GS06, GS11 and GS12. These are monitored on a biannual basis as per license
requirements.
In 2014 Groundwater samples were analysed by City Analysts Laboratories for
organics, major anions, major cations and heavy metals. In-house testing was
undertaken for Ammonia, Nitrate, pH, conductivity and some anions/cations.
The results for the Bi-Annual licensed groundwater well samples undertaken in 2014
are on file in UCB and are available to view as required.
A summary status of each of the licensed wells is provided below:
1. GS01
a. No solvents were detected in GS01 in 2014.
b. DRO & PRO were both less than detection limits for these parameters
from monitoring carried out in 2014.
c. pH results for the June and November 2014 monitoring rounds were
7.22 and 7.15 respectively. Conductivity results for the June and
November 2014 monitoring rounds were 1252µS/cm and 1219µS/cm
respectively. The Groundwater Regulations 2010 threshold value for
conductivity that provides an ‘assessment for the presence of saline
intrusion or other intrusions’ is 800µS/cm. The location of the site
close to the Shannon estuary could account for possible saline intrusion
and the above mentioned conductivity values.
d. Trends for Magnesium, Sodium, Nitrate as N, Fluoride, Bromide and
Sulphide have been in general similar to previous year’s trends and are
below the guideline values and are not considered significant.
e. Results for Alkalinity as HCO3 and CaCO3 were similar to monitoring
results in previous few years. No guidelines values are available for
Alkalinity but results were on average 293mg/l in 2014.
f. A slight increase on Nitrate values was observed in 2014 over 2013
monitoring results but they are well within guideline values. Results
are not considered significant.
g. Trends for Sulphate, Phosphate and Potassium have in general
remained on par with previous monitoring rounds from previous years
and are outside the guideline values. The Groundwater Regulations
2010 threshold values/ EPA IGV guideline values for Sulphate,
Phosphate and Potassium are 187.5mg/l, 0.03mg/l and 5.0mg/l
respectively. Average results obtained from 2014 monitoring for
Sulphate, Phosphate and Potassium were 326mg/l, 0.62mg/l and
8.6mg/l respectively. Trends maybe due to local variations and are not
considered significant. Calcium was recorded at a level of 168mg/l in
November 2014. This result was within the guideline value and is the
lowest value recorded for all monitoring events since June 2010.
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h. The result for Ammonia as N in June 2014 monitoring had increased
from the 2013 montoring result and was outside the guideline value.
The result obtained was 746ug/l. The Groundwater Regulations 2010
guideline threshold value for Ammonia as N is 65ug/l (0.065mg/l).
This result obtained may have been due to local variations in the area
of groundwater well GS01. The November 2014 result was well within
the guideline value and was similar monitoring rounds in previous
years.
i. The trend for Chloride in 2014 had shown a slight increase from 2013
levels and was outside the threshold value for Chloride. This maybe
due to local variations and saline intrusion. The average result obtained
in 2014 was 47mg/l. The Groundwater Regulations 2010 threshold
value for Chloride is 24mg/l. Overall the results are not considered
significant.
j. The result for Nitrite from the 2014 monitoring of GS01 were within
the Groundwater Regulations 2010 threshold values.
k. Results for Manganese, Iron, Aluminium and Arsenic are slightly
lower or similar to previous year’s results and are within guideline
values. Results are not considered significant.
l. Results for Barium and Cadmium for 2014 are similar to previous
years’ monitoring for these metals. Results are well within EPA IGV/
Groundwater Regulations 2010 threshold values but when compared to
the tighter Dutch Target values of 50ug/l and 0.4ug/l the result for
Barium is slightly outside the target value. The average results for
Barium and Cadmium for 2014 were 73.5ug/l and 0.4ug/l. The results
are not considered significant and maybe due to local variations in the
area.
m. Results for Chromium, Nickel, Zinc, Boron, Antimony, Cobalt, Silver,
Arsenic, Mercury, Lead, Selenium and Beryllium are all comparable
with previous years’ monitoring results. Chromium and Nickel have
shown a slight upward trend with Zinc showing a slightly downward
trend from monitoring results in previous years. Overall results are not
considered significant.
2. GS02
a. No solvents were detected in GS02 in 2014.
b. DRO’s were detected at a level of 90.9µg/l in June 2014. No PRO’s
were detected in June. DRO’s & PRO’s were both less than detection
limits in November 2014.
c. pH results for the June and November 2014 monitoring rounds were
7.28 and 7.09 respectively. Conductivity results for the June and
November 2014 were 1337µS/cm and 1025µS/cm respectively. The
Groundwater Regulations 2010 threshold value for conductivity that
provides an ‘assessment for the presence of saline intrusion or other
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intrusions’ is 800µS/cm. The location of the site close to the Shannon
estuary could account for possible saline intrusion and the above
mentioned conductivity values.
d. 2014 results for Magnesium, Nitrate as N and Bromide have in general
been similar to previous year’s trends and are below the guideline
values. Results are not considered significant.
e. There was no Nitrate detected in GS02 in 2014.
f. The results for Potassium for 2014 were outside the EPA I/GV of
5.0mg/l. The results obtained for Potassium in 2014 were 21.2mg/l and
17.3mg/l respectively. The results for Chloride for 2014 were outside
the Groundwater 2010 Regulation threshold value for Chloride. The
threshold value for Chloride is 24mg/l. The results obtained for
Chloride in 2014 were 66.4 mg/l and 50.1mg/l respectively. The results
obtained for Phosphate were outside the EPA IGV of 0.03mg/l. The
Phosphate results for 2014 were 5.69mg/l and 1.33mg/l respectively.
The results for Nitrite were within the Groundwater Regulations 2010
threshold value of 0.375mg/l. The results for Chloride, Potassium ,
Nitrite and Phosphate are most likely due to a naturally occurring
cause, possibly due to saline intrusion, and local to the area. The result
for Sodium has shown a reduction in November 2014 in comparison to
previous results. Results are not considered significant.
g. Results for Alkalinity were in general variable compared to previous
years monitoring. No guidelines values are available for Alkalinity. An
average result for 2014 for GS02 was 570mg/l.
h. Trends for Ammonia as N in 2014 were similar to previous years and
were outside the guideline values. The Groundwater Regulations 2010
threshold value for Ammonia as N is 65ug/l (0.065mg/l). Results
obtained for 2014 were 0.746mg/l and 0.038mg/l respectively and are
most likely due to a naturally occurring cause. Results are not
considered significant.
i. Results for Calcium and Sulphide for 2014 were similar to previous
years. Results for Calcium were significantly less than the guideline
values. Results for Sulphate in November 2014 monitoring were less
than the guideline values.
j. Results for Manganese were outside the EPA IGV of 50ug/l. The
results from monitoring in June and November 2014 were 1250µg/l
and 1150µg/l respectively. Variations are possibly due to a naturally
occurring cause and local to the area.
k. Results for Aluminium and Chromium in the 2014 monitoring were
within the guideline values.
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l. Monitoring results for Nickel, Zinc, Antimony, Cobalt, Tin, Copper,
Cadmium, Lead, Arsenic, Selenium and Beryllium were in general
slightly lower than previous years and within guideline values.
3. GS03
a. No solvents were detected in GS03 in 2014.
b. DRO’s were detected at a level of 49.2µg/l in June 2014. No PRO’s
were detected in this monitoring round. DRO’s & PRO’s were both
less than detection limits in November 2014.
c. pH results for the June and November 2014 monitoring rounds were
7.48 and 7.31 respectively. Conductivity results for the June and
November 2014 monitoring rounds were 1460µS/cm and 648µS/cm
respectively. The Groundwater Regulations 2010 threshold value for
conductivity that provides an ‘assessment for the presence of saline
intrusion or other intrusions’ is 800µS/cm. The location of the site
close to the Shannon estuary could account for possible saline intrusion
and the above mentioned conductivity values.
d. Trends for Calcium, Magnesium and Bromide are in general similar to
previous years and are within guideline values. Results are not
considered significant.
e. Trends for Ammonia as N were variable in the 2014 monitoring. The
result for June and November 2014 monitoring was 1.173mg/l and
0.139mg/l respectively and were outside the threshold guideline value.
The Groundwater 2010 Regulations threshold value for Ammonia as N
is 65ug/l (0.065mg/l). The results obtained from the 2014 monitoring
maybe due to naturally occurring cause and local to the area and are
not considered significant.
f. The results for NO3-N from the 2014 monitoring were within
guideline values and are not considered significant.
g. Trends for Nitrite, Fluoride and Sulphate from 2014 monitoring are
within the EPA IGV and/ or Groundwater 2010 Regulations threshold
values. Results for PO43-
are 0.45mg/l and 0.28mg/l respectively and
are slightly outside the EPA IGV of 0.03mg/l. Results are not
considered significant.
h. Trends for Potassium and Chloride have decreased over previous
years’ results but they remain outside their respective guideline values.
This may be due to a naturally occurring cause, possibly saline
intrusion, and local to the area for these particular parameters. Results
obtained for Potassium from 2014 monitoring are 11.8mg/l and
7.0mg/l respectively. The EPA IGV for Potassium is 5.0mg/l. Results
for Chloride for the 2014 monitoring were 25.9mg/l and 37.6mg/l
respectively. The Groundwater 2010 Regulations threshold guideline
value for Chloride is 24mg/l. This threshold value is for the assessment
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of the presence of saline intrusion. As mentioned the results obtained
may possibly be due to saline intrusion.
i. Results for Sodium have decreased when compared with previous
years’ results. There is no apparent reason for this and maybe due to a
naturally occurring cause. The Groundwater 2010 Regulations
threshold value for Sodium is 150ug/l. Sodium results obtained from
2014 monitoring were 204mg/l and 39mg/l respectively. The results
are not considered significant.
j. Results for Manganese, Iron, Silver and Aluminium from 2014
monitoring are within guideline values and are not considered
significant.
k. Results for Zinc, Boron, Cadmium, Lead and Copper have shown a
decrease in trends over previous years and are within guideline values.
Results are not considered significant.
4. GS04
a. No solvents were detected in GS04 in 2014.
b. DRO’s was detected at levels of 749µg/l in June 2014 and <50µg/l in
November. No PRO’s were detected in the 2014 sampling rounds.
c. pH results for the June and November 2014 monitoring rounds were
7.75 and 7.17 respectively. Conductivity results for the June and
November 2014 monitoring rounds were 1192µS/cm and 1144µS/cm
respectively. The Groundwater Regulations 2010 threshold value for
conductivity that provides an ‘assessment for the presence of saline
intrusion or other intrusions’ is 800µS/cm. The location of the site
close to the Shannon estuary could account for possible saline intrusion
and the above mentioned conductivity values.
d. Trends for Calcium, Magnesium, Sodium, Nitrate as N, Nitrate,
Fluoride, Bromide and Sulphide have in general been similar to
previous year’s results and are less than their respective guideline
values. Results are not considered significant.
e. Trends for Potassium, Chloride, Nitrite and Phosphate are similar to
previous monitoring rounds and are outside their respective guideline
values. Results obtained for Potassium from 2014 monitoring were
12.9mg/l and 13.0mg/l respectively. The EPA IGV for Potassium is
5.0mg/l. Results for Chloride from the 2014 monitoring were
114.9mg/l and 81mg/l respectively. The Groundwater 2010
Regulations threshold guideline value for Chloride is 24mg/l. This
threshold value is for the assessment of the presence of saline
intrusion. As with other wells on the UCB site the high values are most
likely related to a naturally occurring cause and possible due to saline
intrusion.
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f. Results for Alkalinity as HCO3 and CaCO3 were slightly higher than
previous years. The November 2014 result for Alkalinity as HCO3 was
511mg/l compared with 309mg/l in June 2014 and 349mg/l in 2013.
g. Results for Ammonia as N in 2014 were on average similar to previous
years and were outside the guideline values. Results obtained for 2014
for Ammonia as N were 2.15mg/l and 1.80mg/l respectively. The
Groundwater 2010 Regulations threshold value for Ammonia as N is
65ug/l (0.065mg/l). Results are most likely due to a naturally occurring
cause and are not considered significant.
h. The results for Sulphate were variable in 2014 but were in general
similar to previous years. Results obtained were within guideline
values.
i. Trends for metal results were similar to previous years and inside their
respective guideline values. Two exceptions occurred in relation to
Manganese and Antimony as they were outside their respective
guideline values for at least one monitoring round carried out in 2014.
The result obtained for Manganese in November 2014 was 237ug/l.
The EPA IGV for Manganese is 50ug/l. The result obtained for
Antimony in June 2014 was 0.65ug/l. The Dutch Target value for
Antimony is 0.15ug/l. Again these elevated results maybe due to a
naturally occurring cause and local to the area.
5. GS06
a. Similar to previous years monitoring no solvents were detected at
GS06 in 2014 monitoring.
b. DRO & PRO values were less than detection limits in 2014.
c. pH results for the June and November 2014 monitoring rounds were
7.10 and 6.83 respectively. Conductivity results for the June and
November 2014 monitoring rounds were 1189µS/cm and 1168µS/cm
respectively. The Groundwater Regulations 2010 threshold value for
conductivity that provides an ‘assessment for the presence of saline
intrusion or other intrusions’ is 800µS/cm. The location of the site
close to the Shannon estuary could account for possible saline intrusion
and the above mentioned conductivity values.
d. Trends for Magnesium, Sodium, Nitrate as N, Fluoride, Bromide,
Nitrite and Sulphide were in general similar to previous years and are
below guideline values.
e. Results for Alkalinity as HCO3 and CaCO3 were slightly higher in the
November 2014 when compared with previous years but the difference
is not considered significant.
f. Nitrate or NO3- N was not detected in November 2014 monitoring. A
result of 1.3mg/l NO3- N and 5.76mg/l NO3 was detected in the June
2014 monitoring. These results are within the guideline values.
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g. Trends for Calcium, Potassium, Chloride, Phosphate and Sulphate
were similar to previous years and are outside their respective
guideline values. This may be due to a naturally occurring cause,
possibly saline intrusion, and local to the area for these particular
parameters. The result obtained for Calcium from November 2014
monitoring was 230mg/l. The EPA IGV for Calcium is 200mg/l.
Results obtained for Potassium from 2014 monitoring were 5.6mg/l
and 6.9mg/l respectively. The EPA IGV for Potassium is 5.0mg/l.
Results for Chloride for the 2014 monitoring were 64.2mg/l and
49mg/l respectively. The Groundwater 2010 Regulations threshold
value for Chloride is 24mg/l. The threshold value for Chloride is for
the assessment of the presence of saline intrusion. As mentioned the
results obtained may possibly be due to saline intrusion and results are
not considered significant.
h. Trends for Ammonia as N in 2014 were similar to previous years and
are outside the guideline values. The results obtained were 2.15mg/l
and 1.80mg/l respectively.The Groundwater 2010 Regulations
threshold value for Ammonia as N is 65ug/l (0.065mg/l). This
threshold value provides an assessment of adverse impacts of chemical
inputs from groundwater on associated surface water bodies. Results
are most likely due to a naturally occurring cause and are not
considered significant.
i. Trends for metal results for GS06 in 2014 were similar to previous
years and were inside their respective guideline values. There were two
exceptions in 2014 namely Manganese and Antimony as the results for
these metals similar to previous years’ were outside their respective
guideline values. The EPA IGV for Manganese is 50ug/l. The results
obtained in 2014 were 323ug/l and 324ug/l respectively. The Dutch
Target value for Antimony is 0.15ug/l. The results obtained for
Antimony from the 2014 monitoring were 0.76ug/l and 1.79ug/l
respectively. As with other wells on the UCB site the values obtained
for Manganese and Antimony are most likely related to a naturally
occurring cause in the area and are not considered significant.
6. GS11
a. No solvents were detected in GS11 in 2014.
b. DRO’s and PRO’s were at levels less than detection in 2014.
c. pH results for the June and November 2014 monitoring rounds were
7.10 and 6.90 respectively. Conductivity results for the June and
November 2014 monitoring rounds were 1189µS/cm and 1362µS/cm
respectively. The Groundwater Regulations 2010 threshold value for
conductivity that provides an ‘assessment for the presence of saline
intrusion or other intrusions’ is 800µS/cm. The location of the site
close to the Shannon estuary could account for possible saline intrusion
and the above mentioned conductivity values.
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d. Trends for Calcium, Magnesium, Sodium, Fluoride, Bromide, Sulphate
and Nitrite were similar to previous years’ and are below the guideline
values for these parameters. Results are not considered significant.
e. Results of 8.2mg/l NO3 as N and 36.33mg/l NO3 were detected in the
June 2014 monitoring. These are less than the guideline values. No
NO3 or NO3- N was detected in the November monitoring in 2014.
f. Results for Alkalinity as HCO3 and CaCO3 were slightly higher in
November 2014 in comparison to previous years but the difference is
not considered significant.
g. Trends for Potassium, Phosphate and Chloride are similar to previous
years and were outside their respective guideline values. The results
obtained for Potassium from 2014 monitoring were 13.7mg/l and
16.9mg/l respectively. The EPA IGV for Potassium is 5.0mg/l. Results
obtained for Phosphate from 2014 monitoring were 1.23mg/l and
0.55mg/l respectively. The EPA IGV for Phosphate is 0.03mg/l.
Results for Chloride for the 2014 monitoring were 83.2mg/l and
70.9mg/l respectively. The threshold value for Chloride is 24mg/l. The
threshold value for Chloride is for the assessment of the presence of
saline intrusion. The results obtained may possibly be due to saline
intrusion and local to the area for these parameters and are not
considered significant.
h. Trends for Ammonia as N in 2014 were similar to previous years and
were outside the guideline values. The results obtained from 2014
monitoring were 1.572mg/l and 0.748mg/l respectively.The
Groundwater 2010 Regulations threshold value for Ammonia as N is
65ug/l (0.065mg/l). This threshold value provides an assessment of
adverse impacts of chemical inputs from groundwater on associated
surface water bodies. Results are most likely due to a naturally
occurring cause and are not considered significant.
i. Trends for metal results for GS11 in 2014 were similar to previous
years and were inside their respective guideline values. Results for
Manganese, Antimony, Chromium and Cadmium were similar to
previous years’ and were in general outside their respective guideline
values. The EPA IGV for Manganese is 50ug/l. The results obtained in
2014 for Manganese were 397ug/l and 314ug/l respectively. The Dutch
Target value for Antimony is 0.15ug/l. The results obtained for
Antimony from the 2014 monitoring were 0.17ug/l and 0.37ug/l
respectively. The Dutch Target value for Chromium is 1ug/l. A result
obtained in the 2014 monitoring was 4ug/l. The Dutch Target value for
Cadmium is 0.4ug/l. A result obtained in the 2014 was 0.5ug/l and was
just outside the target value. As with other wells on the UCB site the
values obtained for the above mentioned metals are most likely related
to a naturally occurring cause in the area and are not considered
significant.
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7. GS12
a. No solvents were detected in GS12 in 2014.
b. DRO’s and PRO’s were both less than detection limits in 2014.
c. pH results for the June and November 2014 monitoring rounds were
6.95 and 7.30 respectively. Conductivity results for the June and
November 2014 monitoring rounds were 1066µS/cm and 1015µS/cm
respectively. The Groundwater Regulations 2010 threshold value for
conductivity that provides an ‘assessment for the presence of saline
intrusion or other intrusions’ is 800µS/cm. The location of the site
close to the Shannon estuary could account for possible saline intrusion
and the above mentioned conductivity values.
d. Trends for Magnesium, Sodium, Nitrate as N, Fluoride, Bromide,
Sulphate and Sulphide were similar to previous year’s trends and are
below the guideline values.
e. No Nitrate ( NO3- N) was detected in the monitoring in 2014.
f. Trends for Ammonia as N in 2014 were similar to previous years and
were inside the guideline values. There was one exception in June
2014 where the monitoring result for Ammonia as N was 0.267mg/l.
The Groundwater 2010 Regulations threshold value for Ammonia as N
is 65ug/l (0.065mg/l). Similar to other wells on site this maybe due to a
naturally occurring cause and local to the area. The result is not
considered significant.
g. Results for Alkalinity in 2014 similar to previous years were variable
and were in the range of 278mg/l and 592mg/l. The levels are not
considered significant.
h. Trends for Calcium, Potassium, Chloride and Phosphate for 2014 are
similar to previous years and are outside their respective guideline
values. This may be due to a naturally occurring cause and local to the
area for these parameters. The result obtained for Calcium from
November 2014 monitoring was 231mg/l. The EPA IGV for Calcium
is 200mg/l. Results obtained for Potassium from 2014 monitoring were
6.0mg/l and 8.6mg/l respectively. The EPA IGV for Potassium is
5.0mg/l. Chloride levels in 2014 have increased very slightly compared
to monitoring in previous years and Chloride results for 2014 were
34.6mg/l and 33.2mg/l respectively. The Groundwater 2010
Regulations threshold value for Chloride is 24mg/l. The threshold
value for Chloride is for the assessment of the presence of saline
intrusion. The results obtained may have been possibly due to saline
intrusion. Results obtained for P043-
from 2014 monitoring were
1.4mg/l and 0.44mg/l respectively. The EPA IGV for Phosphate is
0.03mg/l. Results in general are not considered significant.
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i. Trends for metal results were similar to previous years and inside their
respective guideline values. Results for Manganese, Chromium,
Barium and Antimony were outside their guideline values. As
mentioned for some other wells the EPA IGV for Manganese is 50ug/l.
The results obtained in November 2014 for GS12 for Manganese was
86ug/l. The Dutch Target value for Antimony is 0.15ug/l. The results
obtained for Antimony from the 2014 monitoring were 0.29ug/l and
1.14ug/l respectively. The Dutch Target value for Chromium is 1ug/l.
A result obtained in the November 2014 monitoring was 4ug/l. The
Dutch Target value for Barium 50ug/l. Results obtained in the 2014
monitoring 63ug/l and 83ug/l and were slightly outside the target
value. As with other wells on the UCB site the values obtained for the
above mentioned metals are most likely related to a naturally occurring
cause in the area and are not considered significant.
There were no spillages recorded in the vicinity of any of the Groundwater
wells in 2014.
2.1.3.1 Bund / Tank / Pipeline Integrity Testing
Full records of all bund /tank/ and pipeline integrity testing are maintained on site as
per license requirements. There were no new bund introductions in 2014. All bunds
were checked as per the required frequencies in 2014. Two bunds were identified in
late 2013 which required repair and these were completed in Q1 of 2014. All Foul,
Process and Surface Water lines have been tested as per the required frequencies.
Hydraulic Testing was under taken on all lines which fell under the testing schedule
these included the Surface Water and Process networks. Identified defects were
repaired in Q1 2014.
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2.1.4 Emissions to Atmosphere
There are two licensed Atmospheric Emission points on site. VE155 is the reference
for the Thermal Oxidiser Unit (TOU). The TOU treats vent emissions from SP1 and
SP3. VE135 is the reference for the emission point on the SP2 Torit Dust Abatement
Unit. Table 3 below summarises the parameters which are monitored in the
aforementioned emission points.
Table 3 Summary of Monitored Parameters
Location Emission Point Parameters Measured
Main Site Thermal Oxidiser (VE-155) TOC, NOx, HCL, SO2, Cd, TI, Hg, Sb, As, Pb,
Cr, Co, Cu, Mn, Ni, V, CO, Dioxins, Flow
Main Site Pharma (VE-135) Particulates, Flow
Sampling was carried out for all licensed parameters at licensed emission points as
specified by Schedule B1 & C1.2 and Technical Amendment B. Tables 4 and 5 below
outline the total mass emissions from VE155 and VE135 respectively. While minor
variations in emission values relating to some parameters were recorded the reasons
for such variations are not known and they are not of environmental significance.
Table 4 Summary of Emissions from VE155
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Note:
There were 28 TOU downtimes in 2014, 3 of which were planned and 25 unplanned. The
unplanned Shutdowns were primarily related to Power outages/ power dips which were
beyond the control of the site. The remain issues included a low water level in the
scrubber and an issue with the safety PLC on the TOU. Where TOU shutdowns were
initiated the SP3 facility was shut down in less than 30 minutes as per agreement with the
Agency. Records of all shut downs are held on site for Agency inspection as required.
Site Fugitive emissions are detailed in the PRTR Report summary. The fugitive
emissions are estimates that are based on a Fugitive Emissions study carried by AECOM
Consultants. The emissions for CO are based on measured CO emissions from the on-site
CEMS monitoring and also on estimates from boiler emission reports that are carried out
by Geoff Castles Boiler Services Ltd.
Table 5 Summary of Emissions from VE135
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Table 6 – Summary of Non-Compliances to Atmosphere
There were two Non-Complainces relating to Atmospheric emissions in 2014.
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2.1.5 Waste Management
The national waste database table, providing a summary of waste arisings at the UCB
facility has been compiled for the calendar year 2014. This information is tabulated in
Table 7 below. There were no significant changes in waste arisings in 2014.
Table 7 Summary Information on Waste Arising’s
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2.2 Agency Monitoring & Enforcement
2.2.1 EPA site visits
The EPA undertook 3 sampling visits and 1 Audit/Inspection in 2014. The
sampling visits were undertaken as outlined in Table 8 below. A site Inspection
was undertaken by Niamh O’Donoghue in May 2014 as part of the routine
Annual Inspection. Observations were made in the audit and corrective actions
were raised to address the observations. All actions relating to the Inspection
were closed out as per the agreed timelines and communicated to the Agency
via ALDER.
Table 8
Date Type of Visit Emission
Points
Ref
Sample
Type Results within
specification Significant
Deviation
with EPA
Results 13/02/2014 Unannounced
visit
ES02 Effluent Yes No
13/02/2014 Unannounced
visit
SW44 Surface
Water
Yes No
20/03/2014 Unannounced
visit
Audit /
inspection
N/A N/A N/A
21/08/2014 Announced visit VE155 Air Yes No
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2.3 Energy and Water Consumption
2.3.1 Energy Consumption
Energy needs on site are satisfied using oil, electricity and gas. Steam requirements
for the processes are generated using two high efficiency steam boilers which have a
capacity of 5 Tonnes. Oil usage on site saw a significant reduction in 2010 due to
switch over to the usage of gas in the boilers. Gas usage has remained steady despite
increased activity in recent years and this has been due to ongoing energy projects
which have focused on increasing the efficiency of energy usage. Significant
projects in 2014 including the installation of a high efficiency gas boilers and
energy reduction projects associated with HVAC and Heating Turn down. Electrity
usage has also remained steady and again projects aimed at controlling energy usage
such as the turn down of Building HVAC units have had a significant impact on
usage. A cross functional Resource Management Group is in place on site which
focuses on projects associated with the optimisation of resource usage. Details of
related projects are included in the EMP.
Table 9 Summary Energy Consumption Data
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2.3.2 Water Consumption
UCB is supplied with potable water by Clare Co. Council for process and domestic
uses. Water is supplied through two public mains lines, which enter the plant at the
western perimeter and the security gatehouse. Infrastructure is in place which
provides an accurate and real time overview of water usage on site thereby
facilitating the effective and timely management of water usage on site. 2014 usage
saw an increase in consumption which was primarily associated with leaks in the
network which have since been identified and repaired. Some of the increase in
consumption is also attributed to increased activity levels in SP1. Surface water
continued to be harvested where possible in 2014 in order to minimise potable water
consumption.
Table 10 Summary Water Consumption Data
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2.4 Environmental Incidents & Complaints
2.4.1 Complaints
UCB received no complaints in 2014.
2.4.2 Incidents
The following ten incidents were reported to the Agency in 2014, two of which were
elevated to Non-Compliances to Atmosphere as outlined in section 2.1.4.
Table 11 Summary of Incidents
2.5 Copy of Electronic Summary Information
A copy of the electronic summary information has been compiled and uploaded onto the
EPA website as required under the PRTR regulations. A copy of the return is also
provided in Appendix 2.
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3.0 Management of the Activity
Section 3.0 of the AER provides details of the 2015 Environmental Management Programme (EMP), together with a review of the Objectives,
Targets and Plans completion for 2014. The 2015 EMP is also presented within the scope of this document for Agency approval.
The EMP and Schedule of Objectives and Targets fall under the sites ISO14001 Environmental Management System and accordingly are
included within a structured system of Management Review and periodic Auditing by both internal auditors and external certification body
(SGS). The UCB Environmental Management Programme (EMP) is a continuously updated plan which provides detail of the status of key
Environmental Improvement Programmes.
The Objectives and Targets outlined in the EMP are the key drivers of continual EHS performance improvement at UCB Manufacturing Ireland
Limited. They also serve to reduce Environmental Risk and reduce the company’s impact on the environment.
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3.1 Environmental Management Programme
3.1.1 Update on 2014 Programme
Objectives, Targets and Plans as outlined below were addressed in 2014 and 78% of the Plans set out for completion in 2014 were
completed. All incomplete items were carried forward into the 2014 EMP where appropriate.
3 key objectives were set in the 2014 programme.
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3.1.2 Proposed Program for 2015
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3.3 Finance
3.3.1 Expenditure
As an organisation UCB Manufacturing Ireland Limited – Member of the
UCB Group is committed to providing all of the necessary resources and
expertise to the environmental sustainability and compliance of the on-
site activities.
In 2014 approximately €600k was spent on Environment related capital
spending
3.3.2 ELRA and RMP
A Residual Management Plan and Environmental Liabilities Risk
Assessments are in place for the facility. Both documents were submitted
to the Agency in 2009 and remain valid as there have been no significant
changes to the facility since their completion. An updated copy of the
financial provision was also provided to the Agency in 2012. (See
Appendix 3. A review of the ELRA and RMP will be completed in 2015
and submitted to the Agency as necessary.
3.4 Third Party Inspections
An ISO14001 Recertification Audit was undertaken by SGS in March
2014. Continued certification was recommended. There were no Non-
Conformances issued during the Audit and some minor recommendations
were made. The site was also inspected by the H.S.A in 2014 again some
minor observations were made which have since been closed out.
4.0 License Specific Reports The Annual Noise and Odour Reports have been uploaded onto ALDER as
required. The Solvent Management spreadsheet is provided below in Appendix 1.
Waste Records completed as part of the PRTR are included in Appendix 2.
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APPENDIX 1
SMP for 2014
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APPENDIX 2
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APPENDIX 3